Attachment 12 - Draft ResolutionDRAFT RESOLUTION 2023-___
RESOLUTION OF THE TOWN COUNCIL OF THE TOWN OF LOS GATOS
ADOPTING A GENERAL PLAN AMENDMENT
AND ADOPTING THE HOUSING ELEMENT OF THE GENERAL
PLAN FOR THE PERIOD OF 2023-2031 IN SUBSTANTIAL
COMPLIANCE WITH STATE HOUSING ELEMENT LAW.
GENERAL PLAN AMENDMENT APPLICATION: GP-22-003
WHEREAS, the California Legislature has found that, “California has a housing supply
and affordability crisis of historic proportions” (Gov. Code Section 65589.5); and
WHEREAS, the Legislature has further found that, “Among the consequences of those
actions are discrimination against low-income and minority households, lack of housing to
support employment growth, imbalance in jobs and housing, reduced mobility, urban sprawl,
excessive commuting, and air quality deterioration” (Gov. Code Section 65589.5); and
WHEREAS, the Legislature recently adopted the Housing Crisis Act of 2019 (SB 330)
which states that, “In 2018, California ranked 49th out of the 50 states in housing units per
capita… California needs an estimated 180,000 additional homes annually to keep up with
population growth, and the Governor has called for 3.5 million new homes to be built over 7
years”; and
WHEREAS, State Housing Element Law (Government Code Sections 65580 et seq.)
requires that the Town Council adopt a Housing Element for the eight-year period 2023-2031 to
accommodate the Town of Los Gatos (Town) regional housing need allocation (RHNA) of 1,993
housing units, comprised of 537 very-low income units, 310 low-income units, 320 moderate-
income units, and 826 above moderate-income units; and
WHEREAS, to comply with State Housing Element Law, the Town has prepared Housing
Element 2023-2031 (the Housing Element) in compliance with State Housing Element Law and
has identified sites that can accommodate housing units meeting the Town’s RHNA; and
WHEREAS, as provided in Government Code Section 65350 et. seq., adoption of the
Housing Element constitutes a General Plan amendment; and
WHEREAS, as provided in Government Code Sections 65352 – 65352.5 the Town mailed
ATTACHMENT 12Draft
a public notice to all California Native American tribes provided by the Native American
Heritage Commission; and
WHEREAS, no California Native American tribe requested consultation; and
WHEREAS, the Town conducted extensive community outreach beginning in the
summer of 2021, including 13 Housing Element Advisory Board (HEAB) public meetings; a joint
study session with the HEAB, Planning Commission, and Town Council; four Town Council
meetings; two community meetings; and public engagement at staff hosted information
booths; and
WHEREAS, in accordance with Government Code Section 65585 (b), on August 29, 2022,
the Town posted the Draft Housing Element and requested public comment for a 30-day review
period, and on October 14, 2022, after responding to public comments, the Town submitted
the Draft Housing Element to the State Department of Housing and Community Development
(HCD) for its review; and
WHEREAS, the Town’s deadline to adopt a Housing Element that is in substantial
compliance with State Housing Element law is January 31, 2023; and
WHEREAS, on January 11, 2023, the Planning Commission held a duly and properly
noticed public hearing and recommended that the Town Council adopt the Draft Housing
Element, the General Plan Amendment Application, and associated Environmental Analysis; and
WHEREAS, on January 12, 2023, the Town received a letter from HCD that provides a list
of recommended revisions that will be necessary to comply with State Housing Element Law;
WHEREAS, the Draft Housing Element substantially complies with State Housing
Element Law for the reasons stated in the Findings below and will return to the Town Council
with proposed amendments to add the information recommended by HCD; and
WHEREAS, the Town Council requested the opportunity to consider adopting the
Housing Element in January in order to meet the January 31st deadline for adoption of a
Housing Element that is in substantial compliance with State Housing Element Law, and
anticipate amending the adopted Housing Element subsequent to adoption in order to add the
information recommended by HCD; and Draft
WHEREAS, this matter came before the Town Council for public hearing on January 30,
2023, and was regularly noticed in conformance with State and Town law; and
WHEREAS, Town Council received testimony and documentary evidence from all
interested persons who wished to testify or submit documents. Town Council considered all
testimony and materials submitted, including the record of the Planning Commission
proceedings and the packet of material contained in the Council Agenda Report for their
meeting on January 30, 2023, along with any and all subsequent reports and materials prepared
concerning this matter.
NOW, THEREFORE, BE IT RESOLVED, THAT THE TOWN COUNCIL HEREBY FINDS THAT
BASED ON SUBSTANTIAL EVIDENCE IN THE RECORD:
1. The foregoing recitals are true and correct and are incorporated by reference into
this action.
2. An Environmental Analysis was prepared for the Draft Housing Element. Although
the Housing Element Update could have a significant effect on the environment, all
potentially significant effects have been analyzed adequately in Town of Los Gatos
2040 General Plan Environmental Impact Report (EIR), adopted with statement of
overriding considerations on June 30, 2022, pursuant to applicable standards,
including CEQA Guidelines Section 15168(c)2, and the Draft Housing Element is
consistent with the growth projections evaluated in the General Plan EIR.
3. The Housing Element substantially complies with Housing Element Law, as provided
in Government Code 65580 et seq., in that it:
a. Contains all provisions required by State Housing Element Law;
b. Includes an assessment of housing needs, and an inventory of resources and
constraints upon the provision of housing;
c. Includes a statement of goals, policies, quantified objectives, financial
resources, and scheduled programs for the preservation, improvement, and
development of housing; Draft
d. Identifies adequate sites for housing to accommodate the Town’s RHNA
allocation in that the Town’s RHNA allocation is 1,993 units and sites
accommodating [2,312 units] have been identified; and
e. Makes adequate provision for the existing and projected needs of all
economic segments of the community in that the sites inventory
accommodates the Town’s RHNA, which includes 537 very low-income units,
310 low-income units, 320 moderate-income units, and 826 above
moderate-income units.
4. Based on substantial evidence in the record through the submittal of Property
Owner Interest Forms, the existing uses on the non-vacant sites identified in the site
inventory to accommodate the RHNA do not constitute an impediment to planned
residential development on the sites during the planning period.
5. As required by Government Code Section 65585(e), the Town Council has
considered the findings made by HCD included in HCD’s letter to the Town of Los
Gatos dated January 12, 2023, consistent with Government Code Section 65585(f),
incorporated herein, and determined that the Draft Housing Element substantially
complies with the requirements of State Housing Element Law.
6. The Town Council hereby adopts the 2023-2031 Housing Element, the associated
General Plan Amendment Application (GP-22-003) which includes the revised Sites
Inventory Analysis, revised Sites Inventory Form, and the Environmental Analysis
attached here to as Exhibits 1 and 2.
7. This Resolution shall become effective upon adoption by the Town Council.
8. The Community Development Department is directed to submit a copy of the
adopted Housing Element to HCD.
9. The Housing Element is found to be in substantial compliance with State Housing
Element Law and the Community Development Department is authorized to make
all non-substantive changes to the Housing Element to make it internally consistent
or to address any non-substantive changes or amendments requested by HCD to
achieve certification. Draft
10. The Community Development Department or designee is hereby directed to
distribute copies of the Housing Element in the manner provided in Government
Code Sections 65357 and 65589.7.
PASSED AND ADOPTED at a special meeting of the Town Council of the Town of Los
Gatos, California, held on the 30th day of January 2023, by the following vote:
COUNCIL MEMBERS:
AYES:
NAYS:
ABSENT:
ABSTAIN:
SIGNED:
MAYOR OF THE TOWN OF LOS GATOS
LOS GATOS, CALIFORNIA
DATE: __________________
ATTEST:
TOWN CLERK OF THE TOWN OF LOS GATOS
LOS GATOS, CALIFORNIA
DATE: __________________ Draft
This Page
Intentionally
Left Blank
Town of Los Gatos 6th Cycle
2023-2031 Housing Element Update
HCD Draft
Initial Review Period
October 2022
EXHIBIT 1
This document was produced on recycled paper.
HCD DRAFT INITIAL REVIEW PERIOD
TOWN OF LOS GATOS
6TH CYCLE 2023-2031 HOUSING ELEMENT
O CTOBER 2022
PREPARED BY
Town of Los Gatos
Community Development Department
110 E. Main Street
Los Gatos, CA 95030
Tel 408.354.6872
EMC Planning Group Inc.
601 Abrego Street
Monterey, CA 93940
Tel 831.649.1799
Fax 831.649.8399
www.emcplanning.com
Table of Contents
October 2022 HCD Draft Initial Review Period 2023-2031 Housing Element i
10.Housing Element ......................................................................................................... 10-1
10.1 Introduction .............................................................................................................. 10-1
10.1.1 California Housing Crisis .......................................................................................... 10-2
10.1.2 Regional Housing Needs Assessment. ..................................................................... 10-2
10.1.3 Affirmative Furthering Fair Housing ....................................................................... 10-3
10.1.4 Overview of Planning and Legislative Efforts .......................................................... 10-8
10.1.5 Public Participation ................................................................................................ 10-10
10.2 Overview of Housing Needs and Constraints ............................................................ 10-16
10.2.1 Introduction ........................................................................................................... 10-16
10.2.2 Los Gatos Overview. .............................................................................................. 10-16
10.2.3 Demographics ....................................................................................................... 10-19
10.2.4 Household Characteristics ..................................................................................... 10-22
10.2.5 Housing Stock Characteristics ................................................................................ 10-24
10.2.6 Special Housing Needs ........................................................................................... 10-26
10.2.7 Governmental and Non-Governmental Constraints ............................................. 10-30
10.3 Site Inventory and Opportunities ............................................................................. 10-31
10.3.1 Introduction ........................................................................................................... 10-31
10.3.2 Sites Summary. ...................................................................................................... 10-31
10.4 Energy and Resource Conservation .......................................................................... 10-32
10.4.1 Opportunities for Energy Conservation ................................................................. 10-32
10.4.2 Energy-Related Goals and Policies. ....................................................................... 10-33
10.5 Goals and Policies ................................................................................................... 10-34
10.6 Implementation Programs ....................................................................................... 10-39
10.7 Glossary and Acronyms ........................................................................................... 10-59
Appendices
Appendix A Affirmatively Furthering Fair Housing Reports
Appendix B Housing Needs Assessment
Appendix C Governmental and Non-Governmental Constraints
Appendix D Vacant and Available Sites
Appendix E Review of Previous Housing Element
Appendix F List of Organizations Contacted
Appendix G AFFH Segregation Report Los Gatos
Appendix H Sites Inventory Form
10
10. Housing Element
October 2022 Initial Draft 2023-2031 Housing Element 10-1
This 2023-2031 Housing Element is the Town of Los Gatos’ response to meet the housing needs of our
community while meeting the State's housing goals as set forth in Article 10.6 of the California Government Code.
The California State Legislature has identified the attainment of a decent home and a suitable living environment
for every Californian as the State's major housing goal. The Los Gatos Housing Element represents a sincere
and open-minded effort to meet local and regional housing needs within the constraints of a largely built-out
community, limited land availability, and extraordinarily high costs of land and housing. The Housing Element
serves as Chapter 10 of the Town’s 2040 General Plan.
A copy of the Town’s 2015-2023 Housing Element can be found at this link:
https://www.losgatosca.gov/1735/General-Plan---Housing-Element
10.1 Introduction
Pursuant to State law, the Housing Element must be updated periodically according to statutory deadlines. This
6th Cycle Housing Element covers the planning period 2023 through 2031 and replaces the Town's 5th Cycle
Housing Element that covered the period 2015 through 2023.
Per State Housing Element law, the document must be periodically updated to:
▪Outline the community’s housing production objectives consistent with State and regional growth
projections;
▪Describe goals, policies, and implementation programs to achieve local housing objectives;
▪Examine the local need for housing with a focus on special needs populations;
▪Identify adequate sites for the production of housing serving various income levels;
▪Analyze potential constraints to new housing production;
▪Evaluate the Housing Element for consistency with other General Plan elements; and
▪Evaluate Affirmatively Furthering Fair Housing.
A Housing Element is considered to be out of compliance with the State’s Housing Element law if one of the
following applies:
▪It has not been revised and updated by the statutory deadline; or
▪Its contents do not substantially comply with the statutory requirements.
HCD Draft Initial Review 2023-2031 Housing Element
10-2 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Repercussions for a jurisdiction which does not comply with the Housing Element Law include:
▪Limited access to State Funding.
▪Vulnerability to litigation from housing rights’ organizations, developers, and the Department of Housing
and Community Development (HCD), resulting in the following potential consequences:
a.The court may order the jurisdiction to bring its Housing Element into compliance within 120 days;
b.Suspension of a jurisdiction’s authority to issue building permits or grant zoning changes, variances, or
subdivision map approvals;
c.The court may step in and approve housing projects; and
d.If a jurisdiction faces a court action stemming from its lack of compliance and either loses or settles the
case, it often must pay substantial attorney fees to the plaintiff’s attorneys in addition to the fees paid
to its own attorneys.
10.1.1 California’s Housing Crisis
The 6th Cycle Housing Element Update comes at a critical time because California is experiencing a housing
crisis. As is the case for all jurisdictions in California, Los Gatos must play its part in meeting the demand for
housing. In the last Housing Element cycle (2015 to 2023), Los Gatos’ Regional Housing Needs Allocation
(RHNA) called for 619 new housing units; however, as of December 31, 2021, only 81 percent of these housing
units have been permitted (502 units). Of those constructed, the large majority were affordable only to
households making more than the Town’s area median income (AMI). In 2022, this amounted to $168,500 for a
family of four.
Without immediate action, the housing crisis will only get worse. In the 20-year period (2020 to 2040), Santa Clara
County is projected to add 169,450 jobs, which represents a 15 percent increase. Los Gatos is projected to add
nearly 1,030 jobs in the same period, a five percent increase. These changes will increase demand for housing
across all income levels. The Town and region must identify ways to significantly increase housing production, or
risk worsening the burden for existing lower income households. Many lower income households do not have the
means to move to a new location of employment and are faced with unsustainable increases in housing cost.
The lack of affordable housing has constrained the Silicon Valley economy as well-educated workers have
become increasingly mobile in searching for better jobs and a higher quality of life.
If Los Gatos and the region become more competitive in attracting high-skilled workers and increasingly
unaffordable to lower income workers and seniors, then social and economic segregation will worsen, only
exacerbating historic patterns of housing discrimination, racial bias, and segregation. This potentiality has
become so acute in recent years that the California Legislature addressed the issue with new legislation in 2018.
Assembly Bill (AB) 686 requires all State and local agencies to explicitly address, combat, and relieve disparities
resulting from past patterns of housing segregation to foster more inclusive communities. This is commonly
referred to as Affirmatively Furthering Fair Housing (AFFH). The legislation applies to all Housing Elements
revised after January 1, 2021.
10.1.2 Regional Housing Needs Allocation
The Plan Bay Area 2050 Final Blueprint forecasts that the nine Bay Area counties will add 1.4 million new
households between 2015 and 2050. For the eight-year time frame covered by this Housing Element Update,
HCD has identified the region’s housing need as 441,176 units. The total number of housing units assigned by
HCD is separated into four income categories that cover housing types for all income levels, from very low-
income households to market rate housing.1 This calculation, known as the Regional Housing Needs
1 HCD divides the RHNA into the following four income categories: Very Low income: 0-50 percent of AMI, Low income: 50-80 percent of AMI, Moderate
income: 80-120 percent of AMI, and Above Moderate income: 120 percent or more of AMI.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-3
Determination (RHND), is based on population projections produced by the California Department of Finance as
well as adjustments that incorporate the region’s existing housing need.
Almost all jurisdictions in the Bay Area received a larger RHNA this cycle compared to the last cycle, primarily due
to changes in State law that led to a considerably higher RHND compared to previous cycles.
On January 12, 2022, HCD approved the Association of Bay Area Government’s (ABAG) adopted RHNA
Methodology. For Los Gatos, the RHNA to be planned for this cycle is 1,993 units, an increase from the last
cycle. Table 10-1 shows the RHNA, including breakdown by affordability levels, for Los Gatos for the period 2023
through 2031.
Table 10-1 Regional Housing Needs Allocation
Income Group Percentage of AMI Share
Extremely Low Income 0-30 268
Very Low Income 31-50 269
Low Income 51-80 310
Moderate Income 81-120 320
Above Moderate Income Over 120 826
Total 1,993
10.1.3 Affirmatively Furthering Fair Housing
In 2018, AB 686 established an independent State mandate to address AFFH. AB 686 extends requirements for
Federal grantees and contractors to “affirmatively further fair housing,” including requirements in the Federal Fair
Housing Act, to public agencies in California. Affirmatively furthering fair housing is defined specifically as taking
meaningful actions that, taken together, address significant disparities in housing needs and in access to
opportunity by replacing segregated living patterns with truly integrated and balanced living patterns; transforming
racially and ethnically concentrated areas of poverty into areas of opportunity; and fostering and maintaining
compliance with civil rights and fair housing laws.
AB 686 requires public agencies to:
▪Administer their programs and activities relating to housing and community development in a manner to
affirmatively further fair housing;
▪Not take any action that is materially inconsistent with the obligation to affirmatively further fair housing;
▪Ensure that the program and actions to achieve the goals and objectives of the Housing Element
affirmatively further fair housing; and
▪Include an assessment of fair housing in the Housing Element.
The requirement to AFFH is derived from The Fair Housing Act of 1968, which prohibited discrimination
concerning the sale, rental, and financing of housing based on race, color, religion, national origin, or sex and was
later amended to include familial status and disability. The 2015 U.S. Department of Housing and Urban
HCD Draft Initial Review 2023-2031 Housing Element
10-4 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Development (HUD) Rule to Affirmatively Further Fair Housing and California AB 686 (2018) both mandate that
each jurisdiction takes meaningful action to address significant disparities in housing needs and access to
opportunity. AB 686 requires that jurisdictions incorporate AFFH into their Housing Elements, which includes
inclusive community participation, an assessment of fair housing, a site inventory reflective of AFFH, and the
development of goals, policies, and programs to meaningfully address local fair housing issues.
An AFFH analysis was prepared by Root Policy Research and is included as an appendix to this Housing
Element (see Appendix A).
Defining Segregation
Segregation is the separation of different demographic groups into concentrated geographic locations or
communities, meaning that groups are unevenly distributed across geographic space. Appendix A examines two
spatial forms of segregation: neighborhood level segregation within a local jurisdiction; and Town level
segregation between jurisdictions in the Bay Area.
Neighborhood level segregation (within a jurisdiction, or intra-Town): Segregation of race and income groups can
occur from neighborhood to neighborhood within a Town. For example, if a local jurisdiction has a population that
is 20 percent Latinx, but some neighborhoods are 80 percent Latinx while others have nearly no Latinx residents,
that jurisdiction would have segregated neighborhoods.
Town level segregation (between jurisdictions in a region, or inter-jurisdiction): Race and income divides also
occur between jurisdictions in a region. A region could be very diverse with equal numbers of White, Asian,
Black, and Latinx residents, but the region could also be highly segregated with each jurisdiction consisting solely
of one racial group.
There are many factors that have contributed to the generation and maintenance of segregation. Historically,
racial segregation stemmed from explicit discrimination against people of color, such as restrictive covenants,
redlining, and discrimination in mortgage lending. This history includes many overtly discriminatory policies made
by Federal, State, and local governments. Segregation patterns are also affected by policies that appear race-
neutral, such as land use decisions and the regulation of housing development.
Segregation has resulted in vastly unequal access to public goods such as quality schools, neighborhood
services and amenities, parks and playgrounds, clean air and water, and public safety. Segregation has lasting
generational affects that target low-income and minority communities. Unequal access to public goods
disproportionately affects undeserved communities, leading to lower levels of educational attainment, higher
morbidity rates, and higher mortality rates.
Segregation Patterns in the Bay Area
Across the San Francisco Bay Area, White residents and above moderate-income residents are significantly more
segregated from other racial and income groups (see Appendix B). The highest levels of racial segregation occur
between the Black and White populations. The analysis completed for Appendix A indicates that the amount of
racial segregation both within Bay Area cities and across jurisdictions in the region has decreased since the year
2000. This finding is consistent with recent research from the Othering and Belonging Institute at UC Berkeley,
which concluded that, “[a]lthough seven of the nine Bay Area counties were more segregated in 2020 than they
were in either 1980 or 1990, racial residential segregation in the region appears to have peaked around the year
2000 and has generally declined since.” However, compared to cities in other parts of California, Bay Area
jurisdictions have more neighborhood level segregation between residents from different racial groups.
Additionally, there is also more racial segregation between Bay Area cities compared to other regions in the State.
The Federal Fair Housing Act prohibits discrimination in housing on the basis of race or color, national origin,
religion, sex, familial status, and disability. Figure 10-1 on the following page shows the number of HCD Fair
Housing Inquiries for the period 2013 through 2021.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-5
Figure 10-1 HCD Fair Housing Inquiries (2013- 2021)
Source: California Department of Housing.
Segregation and Land Use
It is difficult to address segregation patterns without an analysis of both historical and existing land use policies
that impact segregation patterns. Land use regulations influence what kind of housing is built in a county, city,
town, or neighborhood. These land use regulations in turn impact demographics, and they can be used to affect
the number of houses in a community, the number of people who live in the community, the wealth of the people
who live in the community, and where within the community they reside. Land use regulations have led to
disparities among neighborhoods based on class and race.
Segregation in the Town of Los Gatos
▪As of 2020, White residents are the most geographically concentrated compared to other racial groups in
Los Gatos, as measured by the isolation index. White residents live in neighborhoods where they are less
likely to come into contact with other racial groups.
▪Among all racial groups, the White population’s isolation index value has changed the most over time,
becoming less segregated from other racial groups between 2000 and 2020.
▪According to the dissimilarity index, within Los Gatos, racial segregation is most significant between Black
and White populations. 2 However, this dissimilarity index 3 value is not a reliable data point due to small
population size.
2 The analysis conducted for this report suggests that dissimilarity index values are unreliable for a population group if that group represents
approximately less than 5% of the jurisdiction’s total population. ABAG/MTC recommends that when cities have population groups that are less than 5%
of the jurisdiction’s population (see Figure B-4 in Appendix B) the assessment could focus on the isolation index or Thiel’s H-Index to gain a more accurate
understanding of neighborhood-level racial segregation in their jurisdiction.
3 The “index of dissimilarity” is the most commonly used and accepted method of measuring segregation, and compares how evenly one population sub-
group is spread out geographically compared to another population sub-group.
HCD Draft Initial Review 2023-2031 Housing Element
10-6 HCD Draft Initial Review 2023-2031 Housing Element October 2022
▪According to the Theil H-Index,4 neighborhood racial segregation in Los Gatos increased between 2010
and 2020. Neighborhood income segregation stayed about the same between 2010 and 2015.
▪Above moderate-income residents are the most segregated compared to other income groups in Los
Gatos. Above moderate-income residents live in neighborhoods where they are less likely to encounter
residents of other income groups.
▪Among all income groups, the above moderate-income population’s segregation measure has changed
the most over time, becoming less segregated from other income groups between 2010 and 2015.
▪According to the dissimilarity index, segregation between lower income residents and residents who are
not lower income has increased between 2010 and 2015. In 2015, the income segregation in Los Gatos
between lower income residents and other residents was higher than the average value for Bay Area
jurisdictions.
Figures 10-2 and 10-3 identify HCD Fair Housing Inquiries by bias for the period 2013 through 2021 and a list
of Fair Housing Assistance organizations within Santa Clara County. Figure 10-2 shows that a total of eight fair
housing inquiries for Los Gatos were submitted with two submittals citing race as a bias and six cases citing no
specific bias.
Figure 10-2 HCD Fair Housing Inquiries by Bias, January 2013-March 2021
Source: California Department of Housing and Community Development AFFH Data Viewer
4 The Theil H-Index is a statistic primarily used to measure economic inequality and other economic phenomena.
Jurisdiction
San Jose 39 9 9 8 0 3 0 146 9 111 225
Santa Clara 2 2 4 4 0 0 0 26 1 12 40
Sunnyvale 7 1 3 0 0 0 0 17 1 16 29
Palo Alto 3 1 3 0 0 1 0 18 1 9 26
Gilroy 3 1 0 0 0 0 0 11 1 4 15
Morgan Hill 3 2 1 0 0 0 0 6 0 6 12
Campbell 3 1 0 0 0 0 0 7 0 5 11
Mountain View 1 0 1 0 0 0 0 9 0 6 11
Los Gatos 0 0 2 0 0 0 0 6 1 5 8
Cupertino 2 1 0 0 0 0 0 4 1 2 7
Milpitas 0 0 0 0 0 0 0 6 0 2 6
Saratoga 0 0 0 0 0 0 0 1 0 0 1
Los Altos 0 0 0 0 0 0 0 0 0 0 0
Los Altos Hills 0 0 0 0 0 0 0 0 0 0 0
Monte Sereno 0 0 0 0 0 0 0 0 0 0 0
TotalDisabilityRace
Familial
Status
National
Origin Religion Sex Color
Failure
to
Respond
None
Cited
Decision
Not To
Persue
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-7
Figure 10-3 Fair Housing Assistance Organizations, Santa Clara County
Source: Los-Gatos-Housing-Resources-Guide (losgatosca.gov)
Name
Project Sentinel Northern California
1490 El Camino
Real, Santa Clara,
CA 95050
(800) 339-6043 https://www.housing.org/
Los Gatos Rental
Dispute
Resolution
Program C/O
Project Sentinel
Los Gatos
1490 El Camino
Real, Santa Clara,
CA 95050
(800) 339-6043 https://www.housing.org/
Housing and
Economic Rights
Advocates
State of California
1814 Franklin St.
Ste. 1040 Oakland,
CA 94612
(510) 271-8443 https://www.heraca.org
Bay Area Legal
Aid - Legal Advice
Line
Parts of Santa Clara
County
2 West Santa Clara
Street, 8th Floor,
San Jose, CA 95113
(408) 850-7066 https://www.baylegal.org
Senior Adults
Legal Assistance
(SALA)
Santa Clara County
160 E Virginia
Street, Ste. 260, San
Jose, CA 95112
(408) 295-5991 www.sala.org
Asian Law
Alliance Silicon Valley
184 East Jackson
Street, San Jose, CA
95112
(408) 287-9710 www.asianlawalliance.org
California
Department of
Fair Employment
and Housing
State of California
2218 Kausen Dr.
Ste. 100 Elk Grove,
CA 95758
(916) 478-7251 https://www.dfeh.ca.gov
Law Foundation
of Silicon Valley
Greater Silicon
Valley, Santa Clara
County
152 N. 3rd St. #3
San Jose, CA 95112 (408) 293-4790 https://lawfoundation.org
WebsiteService Area Address Phone
HCD Draft Initial Review 2023-2031 Housing Element
10-8 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Regional Segregation
▪Los Gatos has a higher percentage of White residents than other jurisdictions in the Bay Area as a whole,
a lower percentage of Latinx residents, a lower percentage of Black residents, and a lower percentage of
Asian and Pacific Islander residents.
▪Regarding income groups, Los Gatos has a lower percentage of very low-income residents than other
jurisdictions in the Bay Area as a whole, a lower percentage of low-income residents, a lower percentage
of moderate-income residents, and a higher percentage of above moderate-income residents.
10.1.4 Overview of Planning and Legislative Efforts
This section provides an overview of planning and legislative efforts that provide the context for development of
the 6th Cycle Housing Element.
2040 General Plan
On June 30, 2022, the Town Council adopted the 2040 General Plan and accompanying Environmental Impact
Report (EIR). As of September 27, 2022, The Land Use and Community Design Elements of the 2040 General
Plan are suspended pending the results of a referendum. In the interim, the Town’s 2020 General Plan Land Use
and Community Design Elements will govern during the suspension period.
Effectiveness of Previous Housing Element
The Town of Los Gatos 5th Cycle Housing Element (2015 to 2023) identified a RHNA of 619 housing units
between January 31, 2015, and January 1, 2023. As of December 31, 2021, 502 new units were added to the
Town’s housing stock in this cycle, achieving approximately 81 percent of the Town’s RHNA. Units affordable to
moderate- and lower-income households that were created during the planning period include senior rental units
(North Forty Phase I), an attached condominium (Union Avenue), single-family homes (Knowles Avenue)
produced through the Town’s Below Market Program (BMP), and accessory dwelling units (ADU). See Appendix
E for a complete review and analysis of Los Gatos’s 5th Cycle Housing Element (2015-2023).
New State Laws Affecting Housing
While the Town has taken steps throughout the 5th Cycle to increase housing production locally, the State passed
numerous laws to address California’s housing crisis during the same period. As the State passes new legislation
in the remainder of the 5th Cycle and during the 6th Cycle, the Town will continue to amend the Municipal Code; to
monitor and evaluate policies and programs designed to meet State requirements; and to proactively implement
new policies and programs to help increase housing production in the Town.
In 2019, several bills were signed into law that include requirements for local density bonus programs, the
Housing Element, surplus lands, ADU streamlining, and removing local barriers to housing production. The Town
has and will continue to implement changes required by State law, through amendments to the Los Gatos
Municipal Code. The following is a summary of recent legislation and proposed Town activities that will further
the Town’s efforts to increase housing production during the 6th Cycle. Please see the previous section for a
discussion of AB 686 (Affirmatively Furthering Fair Housing).
Streamlining for Subdividing Single-Family Lots
Senate Bill (SB) 9, the California Housing Opportunity and More Efficiency (HOME) Act, streamlines the process
for a homeowner to create a duplex or subdivide an existing lot. Any new housing created as a result of this bill
must meet a specific list of qualifications that protects historic districts, preserves environmental quality and the
look of communities, and prevents tenants from being displaced. This legislation will enable homeowners to
create intergenerational wealth, and provide access to more rental and ownership options for working families
who would otherwise be priced out of neighborhoods.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-9
Incentive for Accessory Dwelling Units
AB 68, AB 587, AB 671, AB 881, and SB 13 further incentivize the development of ADUs, through streamlined
permits, reduced setback requirements, increased allowable square footage, reduced parking requirements, and
reduced fees. The Town has amended its regulations and procedures pursuant to State law. In addition, the
Town increased the allowable floor area ratio by an additional ten percent for development of ADUs.
Density Bonus Update
AB 1763 requires jurisdictions to provide a density bonus to development projects that restrict 100 percent of their
units as affordable to lower and moderate-income households.
Objective Standards for Multi-Family and Mixed-Use Development Applications
The Town of Los Gatos is developing objective standards for the review of multi-family housing and mixed-use
development applications. This effort is in response to State legislation requiring jurisdictions to adopt objective
standards and to implement them in a streamlined review of qualifying housing projects. Objective standards are
defined under State law as “standards that involve no personal or subjective judgement by a public official and are
uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by
both the development applicant or proponent and the public official prior to submittal” (California Government
Code, Section 65913.4). Objective standards are a powerful tool that allow communities to respond to State
housing laws that are reducing local control of development. They provide an opportunity to ensure that the
appearance of new development is compatible with the Town’s vision, while reinforcing objectivity in the decision-
making process.
Low-Barrier Navigation Centers
A "Low Barrier Navigation Center" is a low-barrier, service-enriched shelter focused on moving people into
permanent housing that provides temporary living facilities while case managers connect individuals experiencing
homelessness to income, public benefits, health services, shelter, and housing. AB 101 requires jurisdictions to
allow “low-barrier navigation centers” by-right in areas zoned for mixed-uses and in non-residential zones
permitting multi-family uses if the center meets specified requirements. Implementation Program BD has been
included pursuant to the requirements of AB 101.
Surplus Public Land
AB 1255 and AB 1486 seek to identify and prioritize State and local surplus lands available for housing
development that are affordable to lower income households. The Town has not identified surplus lands through
the sites inventory analysis and will report on these lands if identified through the Housing Element Annual
Progress Reports.
Accelerated Housing Production
AB 2162 and SB 2 address various methods and funding sources that jurisdictions may use to accelerate housing
production.
Priority Processing
SB 330 enacts changes to local development policies, permitting, and processes that will be in effect through
January 1, 2025. SB 330 places new criteria on the application requirements and processing times for housing
developments; prevents localities from decreasing the housing capacity of any site, such as through downzoning
or increasing open space requirements, if such a decrease would preclude the jurisdiction from meeting its RHNA
housing targets; prevents localities from establishing non-objective standards; and requires that any proposed
demolition of housing units be accompanied by a project that would replace or exceed the total number of units
HCD Draft Initial Review 2023-2031 Housing Element
10-10 HCD Draft Initial Review 2023-2031 Housing Element October 2022
demolished. Additionally, any demolished units that were occupied by lower income households must be
replaced with new units affordable to households with those same income levels.
Housing and Public Safety
In response to SB 379, SB 1035, SB 99, and AB 747, local jurisdictions must update their Safety Element to
comprehensively address climate adaptation and resilience and identify evacuation routes. These updates are
triggered by any General Plan or Housing Element Update that occurs after January 1, 2014. The Town has
conducted this update through its recent General Plan Update, so that it can direct future development into areas
that avoid or reduce unreasonable risks, while also providing needed housing and maintaining other community
planning goals.
10.1.5 Public Participation
The primary purpose of this section is to describe the effort made by the Town of Los Gatos to engage all
economic segments of the community (including residents and/or their representatives) in the development and
update of the Housing Element. The 6th Cycle RHNA numbers are a significant change for all California
communities, and the success of the update process is dependent on a robust, inclusive, and meaningful
community outreach and engagement program. The COVID-19 pandemic has complicated community outreach
efforts, but the pandemic has also catalyzed the development of new digital tools that have brought interactive
engagement to a new level. The following section outlines efforts taken by the Town of Los Gatos to engage the
community in the Housing Element Update process. The summary below illustrates the efforts that the Town has
employed to reach the community for input and community engagement as part of the 2023-2031 Housing
Element Update process to date:
▪Postcards sent to all property owners and tenants in the Town for a Housing Element Update Community
Meeting (17,446 in total).
▪Announcements provided in the local newspaper for all Housing Element Advisory Board (HEAB)
meetings, community meetings, joint study sessions, and the 30-day public review period of the Initial
Public Review Draft Housing Element (Los Gatos Weekly).
▪17 pop-up informational tables at the Los Gatos Farmers’ Market
▪Information table at the Town Community Event (Spring in the Green).
▪Social posts on five platforms, including Facebook, Instagram, Twitter, Nextdoor, and the What’s New
page on the Town’s website for all Housing Element meetings, interactive on-line engagement, and public
engagement opportunities.
▪Public notices for Housing Element Advisory Board (HEAB) meetings and community meetings posted at
Town Hall and the Library.
▪Targeted email messaging that sends email updates to the Town’s Notify Me subscribers for the 2040
General Plan Update and Housing Element Update.
▪100 Property Owner Interest Forms mailed to all property owners on the Site Inventory.
▪Online advertisements for each Housing Element meeting and interactive on-line engagement
opportunities on the Town’s website, the Town’s General Plan Update website, and the Town’s Housing
Element website.
▪Use of the Balancing Act, a housing simulation tool, available on the Town’s dedicated Housing Element
Update website for online public engagement.
▪201 submissions to the online site surveys and 42 completions of the Balancing Act housing simulation
tool.
▪Seven community group meetings for the 2040 General Plan Update, including discussion regarding
density and affordable housing.
▪Eleven HEAB meetings held to date.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-11
▪Town Council meeting approving the draft Site Inventory.
▪One community meeting hosted by the Santa Clara County Planning Collaborative for Santa Clara County
municipalities.
▪A public meeting hosted by West Valley Community Services; Envisioning an Inclusive Los Gatos:
Housing Element 101.
▪A joint study session with the Town Council and Planning Commission to discuss housing growth options
for the 2040 General Plan.
▪A joint study session with the Town Council, Planning Commission, and HEAB with panelists from both
market rate and non-profit developers.
▪Participation in a Santa Clara County Equity Advisory Group Meeting.
Staff expects to continue this level of outreach and engagement throughout the remainder of the Housing Element
Update process, including: information on the Town’s website; newspaper ads; social media posts; email
notifications; a pop-up tables at the farmers market, library, and public events; and the website for the Housing
Element Update (engagelosgatoshousing.com). Through staff’s engagement with the public at the Farmers’
Market, staff has heard community support for: housing options to meet the needs of seniors and large families;
displacement prevention of existing naturally affordable housing units; housing of essential workers; and lower
wage earners; and the Town incentives to attract affordable housing projects.
Housing Element Advisory Board
On August 3, 2021, the Los Gatos Town Council adopted Resolution 2021-032 establishing the HEAB to serve as
an advisory board for preparation of the Housing Element Update. On September 21, 2021, the Town Council
appointed four at-large members to the HEAB, which when combined with the nine members of the existing
General Plan Committee (GPC), formed a 13-member oversight board.
Housing Element Website
The Town developed a focused Housing Element Update website “Engage Los Gatos Housing” to provide a
forum for the Town’s online community to engage in the Housing Element Update process. The site provides an
interactive place for the public to learn about and be a part of the Town’s work on housing and to help guide
decision makers on the direction of future housing. This online platform has been open throughout the Town’s 6th
Cycle Housing Element Update and updated regularly with key documents, key meeting dates and times,
engagement opportunities, and other information.
Balancing Act Online Public Engagement
The Balancing Act tool was added on the Town’s Housing Element website to allow the public to participate and
provide site selection feedback on the online platform. The Balancing Act is an online simulation-based tool for
public engagement on potential housing sites. The Balancing Act provided an interactive map showing where
potential housing could be placed to fulfill the Town’s RHNA.
Site Surveys Online Public Engagement
As a companion to the Balancing Act mapping tool opportunity to gather public comments about potential housing
sites, surveys were made available for each individual site. The dedicated Housing Element Update website
included opportunities to learn more about the Housing Element Update process and how to contribute to the
process.
Property Interest Forms
Letters were sent to owners of properties that were considered by the Town to be candidates for housing sites.
The letters included a description of the Housing Element Update process and an invitation to include their
property on the Sites Inventory List.
HCD Draft Initial Review 2023-2031 Housing Element
10-12 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Community Meetings
On August 25, 2021, Town staff participated with other municipalities as part of the Santa Clara County Housing
Collaborative to conduct the Let’s Talk Housing meeting, a regional outreach effort. The online event introduced
community participants to the Housing Element Update process. Town staff presented an introduction to the
Housing Element Update and hosted breakout Zoom room discussions to learn more about community members
housing experiences, needs challenges, and opportunities. There were 35 participants.
On March 2, 2022, West Valley Community Services (WVCS) hosted an online community engagement event,
Envisioning an Inclusive Los Gatos: Housing Element 101. The online event provided an opportunity for the
public to discuss opportunities with panelists for the Town to improve the housing community for everyone,
ensuring inclusive, diverse, and affordable housing in Town. Community members, Housing Element experts,
nonprofits, housing developers, and clients with experience in homelessness and affordable housing joined the
conversation, discussing housing challenges, opportunities, and personal experiences. The featured panelists
included:
▪Ande Flower, Principal Planner at EMC Planning Group.
▪Alison Cingolani, Policy and Research Associate at SV@Home.
▪Bianca Neumann with EAH Housing.
▪Two WVCS clients.
Housing Element Advisory Board Public Meetings (HEAB)
The HEAB is an advisory board created for the purposes of advising Town staff, providing a public forum for
public involvement, and making recommendations to the Planning Commission and Town Council on updates to
the Housing Element. The HEAB serves as an advisory body that provides input on specific tasks associated
with the Housing Element Update. The role of the HEAB is to:
▪Provide guidance on the development of the Housing Element Update;
▪Provide an additional forum for public involvement;
▪Forward milestone products to Town Council;
▪Review the Draft Housing Element; and
▪Make recommendations to the Planning Commission and Town Council.
The HEAB meeting agendas allow for two opportunities for public comment, at the beginning and end of each
meeting, to provide the public an opportunity to react to the topics proposed and discussed. The public is invited
to participate and provide comments at the HEAB meetings or in writing. Meetings are advertised through social
media, the Town’s website, the Housing Element Update website, newspaper advertisements, postings at Town
Hall and the Library, and emails to the General Plan Notify Me list. The following meetings were held via Zoom
with public participation and will continue through the Housing Element Update process.
▪October 21, 2021: Kickoff Meeting and Housing Element Overview.
▪December 16, 2021: Review and Discussion of Technical Appendices.
▪February 17, 2022: Review and Discussion of the Housing Site Inventory Analysis Process.
▪April 21, 2022: Review and Discussion of the Housing Element Site Inventory.
▪May 5, 2022: Review and Discussion of the Housing Element Site Inventory.
▪May 19, 2022: Review and Discussion of the Housing Element Site Inventory.
▪June 16, 2022: Review and Discussion of the Housing Element Draft Goals, Policies, and Programs.
▪July 7, 2022: Review and Discussion of the Housing Element Draft Goals, Policies, and Programs.
▪August 4, 2022: Review and Discussion of the Housing Element Draft Goals, Policies, and Programs.
▪August 18, 2022: Review and Discussion of the full preliminary Housing Element Draft.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-13
▪September 15, 2022: Receive Public Comments on the Initial Public Review Draft Housing Element.
In addition, the following groups have been invited to join the Housing Element Advisory Board Meetings:
▪Los Gatos Chamber of Commerce.
▪West Valley Community Services.
▪Los Gatos Interfaith Community.
▪Public and Private Schools.
▪Los Gatos Anti-Racism Coalition.
▪Los Gatos Rotary Club.
▪Los Gatos Kiwanis Club.
▪Los Gatos Lions Club.
▪Architects, Designers, and Market and Affordable Housing Developers who typically do work within Town.
▪The Town’s Senior Services Committee.
The list of organizations that were contacted to participate in the Housing Element Update process is provided in
Appendix F.
Joint Study Sessions
On December 7, 2021, the Town Council and the Planning Commission held a Joint Study session via Zoom to
discuss housing growth options and related analyses for Planning Commission and Town Council consideration
of the 2040 General Plan Update. The public was encouraged to continue to submit comments and participate in
the 2040 General Plan Update, including any preferences for housing growth options.
On April 6, 2022, the Town Council, Planning Commission, and HEAB participated in a Joint Study session via
Zoom titled “Nuts and Bolts of Affordable Housing.” Several residents requested that the Town Council convene
a study session with the Planning Commission and HEAB to learn more about the challenges of building
affordable housing, particularly the financial and legal realities. The residents provided discussion questions to
the panel members. The Town Council, Planning Commission, and HEAB members had the opportunity to ask
questions of panel members. The panelists included the following:
▪Josh Selo, West Valley Community Services Executive Director served as moderator for the panel
discussion.
▪Barbara Kautz, Goldfarb Lipman Attorneys, provided the current legal landscape for Housing Elements.
▪Don Caprobres, Harmonie Park Development, provided expertise in market rate development and
partnerships with affordable housing developers.
▪Andrea Osgood, Eden Housing, provided hands-on knowledge of affordable housing development and
working with market rate developers.
▪Chris Neale, The CORE Companies, provided experience with both market and affordable housing
development.
Public Hearings
On June 7, 2022, the Town Council considered and approved the HEAB’s recommendation for the draft Site
Inventory at a public hearing via Zoom. There will be more public hearings to come following the first review by
HCD.
Justice, Diversity, Equity, and Inclusion
The Town of Los Gatos values justice, equity, diversity, and inclusion (JEDI). The Town works proactively to
ensure the rights and opportunities of everyone in Los Gatos and opposes any attempts to undermine the safety,
HCD Draft Initial Review 2023-2031 Housing Element
10-14 HCD Draft Initial Review 2023-2031 Housing Element October 2022
security, and rights of any members of the community. The Town promotes equal treatment, equitable
distribution of and access to resources, and engagement in issues affecting the lives of residents, workers, and
visitors. The Town does not tolerate discrimination, racial injustice, or police brutality. The Town works toward
realizing the values of diversity, equity, and inclusion by taking specific actions to become a more inclusive
community.
In May of 2017, the Town Council affirmed a commitment to Los Gatos as a diverse, supportive, equitable, and
inclusive community.
On June 5, 2020, the Town affirmed its commitment to stand in solidarity with the black community with a
Proclamation from the Mayor.
On June 17, 2020, the Mayor signed the Obama Foundation’s Mayor’s Pledge, committing to review Police
Department standards, report back to the community, and work on reforms.
On June 19, 2020, the Town launched a new webpage, “Becoming an Inclusive Community,” dedicated to
outlining the shared values of justice, diversity, equity, and inclusion. In naming the new webpage “Becoming an
Inclusive Community,” the Town acknowledged that there is work to do; and by clearly stating the commitment to
inclusivity and diversity, the Town strives to take the steps needed to reach that goal. The dedicated webpage
can be viewed at www.LosGatosCA.gov/Inclusivity and is kept updated on a regular basis with Town efforts and
current information.
On July 30, 2020, the General Plan Update Advisory Committee (GPAC) held a special meeting to review and
discuss the topics including racial, social, and environmental justice in the General Plan. As a result of this
meeting, the first Element of the 2040 General Plan is a new Racial, Social, and Environmental Justice Element.
In 2020, the Town hosted three community workshops via teleconference to foster dialogue on racial and social
justice and how Los Gatos can be more welcoming for all. The three conversations covered police reform, and
housing. The inclusivity webpage contains full video recordings, presentations, and other information associated
with these conversations.
Pop-up Community Outreach
Farmers Market Informational Booth
Town staff hosted a 2040 General Plan Update and Housing Element Update informational booth at the Los
Gatos Farmers’ Market on Sundays from 9:00 a.m. to 12:00 p.m. on the following dates:
▪June 27, 2021.
▪July 18, 2021.
▪August 8, 2021.
▪August 29, 2021.
▪September 19, 2021.
▪October 10, 2021.
▪October 31, 2021.
▪November 21, 2021.
▪December 19, 2021.
▪January 19, 2022.
▪February 13, 2022.
▪March 13, 2022.
▪April 10, 2022.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-15
▪May 22, 2022.
▪June 12, 2022.
▪September 4, 2022.
▪October 9, 2022.
The Farmers’ Market is held at the Town’s Plaza Park located in downtown Los Gatos. The informational booth
provided an opportunity for planning staff to answer the public’s questions regarding housing opportunities and
challenges within the Town, possible housing sites in Town, the General Plan Update and Housing Element
Update process, and key participation opportunities. Informational handouts were provided to members of the
public with links to the Town’s General Plan Update and Housing Element Update websites. Staff interacted with
members of the community, including both Town residents and non-residents, at the Farmers Market. Staff
members will continue hosting this informational booth once a month through the end of the Housing Element
Update process.
Spring Into Green Informational Booth
On April 24, 2022, Town staff hosted an informational booth for the 2040 General Plan Update and Housing
Element Update at the Town of Los Gatos’ Spring into Green event. The outdoor event celebrates Keep Los
Gatos Beautiful Month, environmental sustainability, and Earth Day. The festivities included environmentally
focused exhibitor booths, a tree planting ceremony, the weekly Los Gatos Farmers Market, family-friendly
activities, food, and live music. The informational booth provided an opportunity for Town staff to answer the
public’s questions regarding housing opportunities and challenges within the Town, possible housing sites in
Town, the General Plan Update and Housing Element Update process and key participation opportunities.
2040 General Plan Update
On June 30, 2022, the Town Council adopted the 2040 General Plan. As mentioned above, the 2040 General
Plan includes a new chapter: Racial, Social, and Environmental Justice. The Racial, Social, and Environmental
Justice Element includes goals, policies, and implementation programs that encourage and support local efforts to
increase participation in the local political process and to improve local conditions relative to racial, social, and
environmental justice issues. The themes covered in this element lay the foundation for creating a more equitable
and inclusive Town for all residents of Los Gatos. The Racial, Social, and Environmental Justice Element focuses
on the empowerment of the community, and especially of the members of the community who have not been
previously heard.
General Plan Update Advisory Committee (GPAC)
To help guide the update to the General Plan, the Town Council appointed a GPAC. The GPAC was composed
of the Town’s General Plan Committee (GPC) and three additional residents. The GPC includes two Town
Council members, three Planning Commissioners, and four residents. The GPAC served to review and discuss
issues, opportunities, and the development the Draft 2040 General Plan. The GPAC held more than 35 public
meetings throughout the General Plan Update process, listening to community input and contributing to the
development of Land Use Alternatives, and the content of the General Plan document.
Public Participation to Affirmatively Furthering Fair Housing
The Los Gatos public participation program was also responsive to AFFH, which requires local jurisdictions to
conduct public outreach to equitably include all stakeholders in the housing element public participation program
(see Section 10.1.3 for more complete information on AFFH).
Tribal Consultation
This public participation effort also includes formal consultation, pursuant to Government Code §65352.3, with
representatives from nine Native American tribes that are present and active in Santa Clara County.
HCD Draft Initial Review 2023-2031 Housing Element
10-16 HCD Draft Initial Review 2023-2031 Housing Element October 2022
10.2 Overview of Housing Needs and Constraint s
This section summarizes the housing needs of Los Gatos as determined through the comprehensive housing
data assessment and analysis presented in Appendix B and serves as the basis for housing goals, policies, and
implementation programs. The housing summary gives an overview of population trends: characteristics of the
housing stock; housing affordability; and special needs households.
10.2.1 Introduction
The Bay Area continues to see growth in both population and jobs, which means more housing of various types
and sizes is needed to ensure that residents across all income levels, ages, and abilities have housing
opportunities. While the number of people drawn to the region over the past 30 years has steadily increased,
housing production has stalled, due to the high cost of land, contributing to the housing shortage that communities
are experiencing. In many communities, this has resulted in residents being priced out, increased traffic
congestion caused by longer commutes, and fewer people across income levels being able to purchase homes or
meet surging rents.
10.2.2 Los Gatos Overview
As California works to face its housing crisis, the State of California has adopted rules to ensure that the burden
of housing an economically diverse and growing population is shared proportionately among all California
communities. The Town is committed to meeting the housing challenge, while preserving the essential character
of the community. The Town faces some of the following conditions as summarized below:
▪Population growth trends in the Town are significantly lower than the County and regional rates.
▪The Town has more than double the County share of White population and a correspondingly smaller
percent of minority populations.
▪The Town has a higher share of high-income earners than the County and Bay Area.
▪The income gap between lower income residents and higher income residents in the Town is higher than
the average value for Bay Area jurisdictions.
▪Poverty rates are very low in the Town.
▪The Town is a net importer of workers.
▪Housing prices in the Town are extremely high. Home prices are valued at more than $2 million, and
rental prices increased by 61 percent from 2009 to 2019.
▪The Town does not have any public housing and only a small portion of the Town contains Housing
Choice Voucher usage.
Figures 10-4 and 10-5 on the following pages show the concentration of public housing buildings with less than
seven units and buildings with eight to 35 units in Santa Clara County; and Housing Choice vouchers by census
tract, respectively.
The remainder of this section provides an overview of the demographics, housing characteristics, and special
housing needs that provide the context for Los Gatos’s 6th Cycle Housing Element Update. A more complete
report on housing needs is presented in Appendix B.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-17
Figure 10-4 Public Housing Buildings, Santa Clara County
Source: California Department of Housing and Community Development AFFH Data Viewer
HCD Draft Initial Review 2023-2031 Housing Element
10-18 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Figure 10-5 Housing Choice Vouchers by Census Tract
Source: California Department of Housing and Community Development AFFH Data Viewer
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-19
10.2.3 Demographics
Population Trends
Generally, the population of the Bay Area continues to grow because of natural growth and because the strong
economy draws new residents to the region. The population of the Town of Los Gatos increased by 10 percent
from 2000 to 2020, which is below the 14.8 percent growth rate of the Bay Area. In 2020, the population of the
Town was estimated to be 31,439 according to the Department of Finance. The population of the Town makes up
1.6 percent of Santa Clara County.5 In the Town of Los Gatos, roughly 13.5 percent of its population moved
during the past year, a number that is roughly the same as the regional rate of 13.4 percent. Table 10-2 shows
population growth trends for the Town, Santa Clara County, and the Bay Area as a whole.
Table 10-2 Population Growth Trends
Geography 1990 1995 2000 2005 2010 2015 2020
Los Gatos 27,357 28,751 28,592 28,872 29,413 30,807 31,439
Santa Clara County 1,497,577 1,594,818 1,682,585 1,752,696 1,781,642 1,912,180 1,961,969
Bay Area 6,020,147 6,381,961 6,784,348 7,073,912 7,150,739 7,595,694 7,790,537
Source: California Department of Finance, E-5 series
Population by Age
The distribution of age groups in a town or city shapes what types of housing the community may need in the near
future. An increase in the older population may mean there is a developing need for more senior housing options,
while higher numbers of children and young families can point to the need for more family housing options and
related services. There has also been a move by many to age-in-place or downsize to stay within their
communities, which can mean more multi-family and accessible units are also needed.
In 2019, the median age in the Town was 47 years, an increase from the median age of 41 in 2000. The youth
population of the Town under the age of 18 was 6,767 and the senior population 65 and older was 6,393. These
age groups represent 22 percent and 20.8 percent, respectively, of the Town’s population. This reflects a
nationwide aging trend related to the large baby boom generation, as well as local characteristics. The Town of
Los Gatos is a community with a high quality of life that encourages residents to stay throughout their lives. Aging
in place, attracting retirees, and high housing costs that favor older, more financially stable households all
contribute to the aging trend in the Town. Figure 10-6 shows the distribution of senior and youth population by
race.
5 To compare the rate of growth across various geographic scales, Table 10-2 shows population for the jurisdiction, county, and region indexed to the
population in the year 1990. This means that the data points represent the population growth in each of these geographies relative to their populations in
1990. NOTE: Universe: Total population; For more years of data, please refer to the Data Packet Workbook, Table POPEMP-01.
HCD Draft Initial Review 2023-2031 Housing Element
10-20 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Figure 10-6 Senior and Youth Population by Race, Los Gatos, 2000-2019
Source: ABAG Housing Needs Data Workbook
Population by Race/Ethnicity
Understanding the racial makeup of a town, city, and region is important for designing and implementing effective
housing policies and programs. These patterns are shaped by both market factors and government actions, such
as exclusionary zoning, discriminatory lending practices, and displacement that has occurred over time and
continues to impact communities of color today.6
Figures 10-7 and 10-8 show the population distribution by race and ethnicities in the Bay Area, Santa Clara
County, and specifically Los Gatos, through the period 2000 to 2019. Since 2000, the percentage of residents in
the Town of Los Gatos identifying as “White, Non-Hispanic” has decreased by 13.3 percentage points. At the
same time the percentage of residents of all “Other Race of Multiple Races, Non-Hispanic” has increased. In
absolute terms, the “Asian/API, Non-Hispanic” population increased the most, while the “White, Non-Hispanic”
population decreased the most.
In 2019, 72.3 percent of the Town’s population was White while 0.9 percent was African American, 14.8 percent
was Asian, and 7.9 percent was Latinx. People of color in Los Gatos comprise a proportion below the overall
proportion in the Bay Area as a whole.7
6 See, for example, Rothstein, R. (2017). The color of law: a forgotten history of how our government segregated America. New York, NY & London, UK:
Liveright Publishing.
7 The Census Bureau’s American Community Survey accounts for ethnic origin separate from racial identity. The numbers reported here use an accounting
of both, such that the racial categories are shown exclusive of Latinx status, to allow for an accounting of the Latinx population regardless of racial identity.
The term Hispanic has historically been used to describe people from numerous Central American, South American, and Caribbean countries. In recent
years, the term Latino or Latinx has become preferred. This report generally uses Latinx, but occasionally when discussing US Census data, we use Hispanic
or Non-Hispanic, to clearly link to the data source.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-21
Figure 10-7 Population by Race and Ethnicity, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
Figure 10-8 Population by Race and Ethnicity, Los Gatos, 2000-2019
Source: ABAG Housing Needs Data Workbook
HCD Draft Initial Review 2023-2031 Housing Element
10-22 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Employment
Town residents most commonly work in the Financial and Professional Services industry. From January 2010 to
January 2021, the unemployment rate in the Town decreased by three percentage points. Since 2010, the
number of jobs located in the jurisdiction increased by 4,440 (28.8 percent).
Additionally, the jobs-household ratio in the Town has increased from 1.32 in 2002 to 1.59 jobs per household in
2018, which means the Town has more jobs than housing. A surplus of jobs relative to residents suggests the
need to import workers. Los Gatos has more low-wage jobs than low-wage residents (where low-wage refers to
jobs paying less than $25,000). At the other end of the wage spectrum, the Town has more high-wage residents
than high-wage jobs (where high-wage refers to jobs paying more than $75,000).
10.2.4 Household Characteristics
Extremely Low-Income Households
Despite the economic and job growth experienced throughout the region since 1990, the income gap has
continued to widen. California is one of the most economically unequal states in the nation, and the Bay Area has
the highest income inequality between high- and low-income households in the State.
HUD annually updates it Section 8 Program income limits to reflect changes in median family income (MFI) levels
for different size households and income limits for extremely low-, very low-, and low-income households. HCD
must then annually update its income limits based on HUD’s annual revisions. California law and State Income
Limits reference AMI that, pursuant to Health & Safety Code 50093(c), means the MFI of a geographic area,
estimated by HUD for its Section 8 Program.
In Los Gatos, 65 percent of households make more than 100 percent of the AMI 8, compared to nine percent
making less than 30 percent of AMI, which is considered extremely low-income. Regionally, more than half of all
households make more than 100 percent AMI, while 15 percent make less than 30 percent AMI. In Santa Clara
County, 30 percent AMI is equivalent to an annual income of $39,900 for a family of four. Many households with
multiple wage earners, including food service workers, full-time students, teachers, farmworkers, public safety
officers, and healthcare professionals can fall into lower AMI categories due to relatively stagnant wages in many
industries.
Throughout the region, there are disparities between the incomes of homeowners and renters. Figures 10-9 and
10-10 show the AMI distribution and the poverty rate among different races and ethnicities in the Los Gatos area.
Typically, the number of low-income renters greatly outpaces the amount of housing available that is affordable
for these households. In Los Gatos, the largest proportion of both renters and homeowners is found in the
greater than 100 percent of AMI group.
8 Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan areas, and the nine
county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa
Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County),
Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro Area (Solano County). The AMI levels in this chart are based on the HUD metro area
where this jurisdiction is located. Households making between 80 and 120 percent of the AMI are moderate-income, those making 50 to 80 percent are
low income, those making 30 to 50 percent are very low income, and those making less than 30 percent are extremely low income. This is then adjusted
for household size.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-23
Figure 10-9 Area Median Income by Race and Ethnicity, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
People of color are more likely to experience poverty and financial instability as a result of Federal and local
housing policies that have historically excluded them from the same opportunities extended to White residents.9
These economic disparities also leave communities of color at higher risk for housing insecurity, displacement, or
homelessness. In Los Gatos, Hispanic or Latinx and Other Race or Multiple Races (Hispanic and Non-Hispanic)
residents experience the highest rates of poverty, followed by White (Hispanic and Non-Hispanic) residents.
Figure 10-10 Poverty Rate by Race and Ethnicity, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
9 Moore, E., Montojo, N. and Mauri, N., 2019. Roots, Race & Place: A History of Racially Exclusionary Housing the San Francisco Bay Area. Hass Institute.
HCD Draft Initial Review 2023-2031 Housing Element
10-24 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Tenure
The number of residents who own their homes compared to those who rent their homes can help identify the level
of housing insecurity (i.e., ability for individuals to stay in their homes) in a town, city, and region. Generally,
renters may be displaced more quickly if prices increase. As of 2019, there are a total of 12,083 housing units in
Los Gatos, and fewer residents rent than own their homes: 35 percent versus 65 percent. By comparison, 43.6
percent of households in Santa Clara County are renters, while 43.9 percent of Bay Area households rent their
homes.
Homeownership rates often vary considerably across race and ethnicity in the Bay Area and throughout the
country. These disparities not only reflect differences in income and wealth, but also stem from Federal, State,
and local policies that limit access to homeownership for communities of color, while facilitating homebuying for
White residents. While many of these policies, such as redlining, have been formally disbanded, the impacts of
race-based policy are still evident across Bay Area communities. In Los Gatos, 84 percent of Black households
owned their homes, while homeownership rates were 72 percent for Asian households, 39 percent for Latinx
households, and 65 percent for White households.
In many communities, homeownership rates for households in single-family homes are substantially higher than
the rates for households in multi-family housing. In Los Gatos, 86 percent of households in detached single-
family homes are homeowners, while 13 percent of households in multi-family housing are homeowners.
Displacement
Because of increasing housing prices, displacement is a major concern in the Bay Area. Displacement has
severe impacts on low- and moderate-income residents. When individuals or families are forced to leave their
homes and communities, they also lose their support network.
The University of California (UC), Berkeley has mapped all neighborhoods in the Bay Area, identifying their risk
for gentrification. It finds that in Los Gatos there are no households that live in neighborhoods that are
susceptible to or experiencing displacement and none live in neighborhoods at risk of or undergoing gentrification.
Equally important, some neighborhoods in the Bay Area do not have housing appropriate for a broad section of
the workforce. UC Berkeley estimates that all households in Los Gatos live in neighborhoods where low-income
households are likely to be excluded due to prohibitive housing costs.10 Figure B-18 in Appendix B shows
household displacement risk and tenure.
10.2.5 Housing Stock Characteristics
Number of Homes
The number of new homes built in the Bay Area has not kept pace with the demand, resulting in longer
commutes, increasing prices, and exacerbating issues of displacement and homelessness. The number of
homes in Los Gatos increased by four percent from 2010 to 2020, which is below the growth rate for Santa Clara
County and below the growth rate of the region’s housing stock during this time period.
Between 2015 and 2021, 502 housing units were issued permits in Los Gatos, which represents approximately 81
percent of the RHNA number of 619 units assigned in the 5th Cycle Housing Element. Approximately 66 percent
of permits issued in Los Gatos were for above moderate-income housing, 24 percent were for moderate-income
housing, and 10 percent were for low- or very low-income housing.
10 More information about this gentrification and displacement data is available at the Urban Displacement Project’s webpage:
https://www.urbandisplacement.org/. Specifically, one can learn more about the different gentrification/displacement typologies shown in Figure 18 at
this link: https://www.urbandisplacement.org/sites/default/files/typology_sheet_2018_0.png. Additionally, one can view maps that show which
typologies correspond to which parts of a jurisdiction here: https://www.urbandisplacement.org/san-francisco/sf-bay-area-gentrification-and-
displacement.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-25
Housing Type
It is important to have a variety of housing types to meet the needs of a community today and in the future. In
2020:
▪60 percent of homes in Los Gatos were single-family detached.
▪13 percent were single-family attached.
▪9 percent were small multi-family (two to four units).
▪18 percent were medium or large multi-family (five or more units).
Between 2010 and 2020, the number of single-family units increased more than multi-family units. Los Gatos has
a higher portion of detached single-family homes than other jurisdictions in the region.
The housing stock of Los Gatos is generally in good condition, and few homes require reconstruction or
rehabilitation. The high quality of life, desirable location, walkable neighborhoods, and school system have
provided financial incentive for property owners to rehabilitate homes and maintain them.
Home Prices
A diversity of homes at all income levels would create opportunities for all members of the Los Gatos community
to live in Town.
▪Ownership – The largest proportion of homes had a value greater than $2 million in 2019. Home prices
increased by 98.4 percent from 2010 to 2020.
▪Rental Prices – The typical contract rent for an apartment in Los Gatos was $2,270 in 2019. Rental prices
increased by 61 percent from 2009 to 2019. To rent a typical apartment without cost burden, a household
would need to make $90,960 per year.11
Cost Burden
The U.S. Department of Housing and Urban Development (HUD) considers housing to be affordable for a
household if the household spends less than 30 percent of its income on housing costs. A household is
considered “cost-burdened” if it spends more than 30 percent of its monthly income on housing costs, while those
who spend more than 50 percent of their income on housing costs are considered “severely cost-burdened.” In
Los Gatos, 20 percent of renter households and 16 percent of owner households spend 30 percent to 50 percent
of their income on housing, while 22 percent of renter households and 12 percent of owner households are
severely cost-burdened and use the majority of their income for housing.
Minority communities are more likely to experience poverty and financial instability as a result of Federal and local
housing policies that have historically excluded them from the same opportunities extended to White residents.
As a result, they often pay a greater percentage of their income on housing, and in turn, are at a greater risk of
housing insecurity.
“Other Race” or “Multiple Races, Non-Hispanic” residents are the most cost-burdened, with 28 percent spending
30 to 50 percent of their income on housing, and Hispanic or Latinx residents are the most severely cost-
burdened, with 22 percent spending more than 50 percent of their income on housing.
Neighborhood
100 percent of residents in Los Gatos live in neighborhoods identified as “Highest Resource” or “High Resource”
areas by State-commissioned research, while none live in areas identified by this research as “Low Resource” or
“High Segregation and Poverty” areas. These neighborhood designations are based on a range of indicators
11 Note that contract rents may differ significantly from, and are often lower than, current listing prices.
HCD Draft Initial Review 2023-2031 Housing Element
10-26 HCD Draft Initial Review 2023-2031 Housing Element October 2022
covering areas such as education, poverty, proximity to jobs and economic opportunities, low pollution levels, and
other factors.12
10.2.6 Special Housing Needs
Some population groups may have special housing needs that require specific program responses, and these
groups may experience barriers to accessing stable housing due to their specific housing circumstances. In Los
Gatos, nine percent of residents have a disability and may require accessible housing. Additionally, six percent of
Los Gatos households are larger households with five or more people, and likely need larger housing units with
three bedrooms or more. Eight percent of households are female-headed families, which are often at greater risk
of housing insecurity.
Large Households
Large households, with five or more persons, often have different housing needs than smaller households. If a
town or city’s rental housing stock does not include larger apartments, large households who rent could end up
living in overcrowded conditions. Large families are generally served by housing units with three or more
bedrooms, of which there are 7,760 units in Los Gatos, as shown in Figure 10-11. Among these large units, most
are owner-occupied, and few are renter-occupied, indicating the Town’s rental housing stock lacks larger
apartments.
Figure 10-11 Housing Units by Number of Bedrooms and Tenure, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
Female-Headed Households
Households headed by one person are often at greater risk of housing insecurity, particularly female-headed
households, who may be supporting children or a family with only one income. Female-headed households with
children may face particular housing challenges, with gender inequality resulting in lower wages for women.
Moreover, the added need for childcare can make finding a home that is affordable more challenging.
In Los Gatos, the largest proportion of households is Married-Couple Family Households at 58 percent of the
total, while Female-Headed Family Households make up 8 percent of all households. Additionally, 36 Female-
Headed Households with Children (eight percent) fell in the Below Poverty Level category, while 26 Female-
Headed Households without Children (five percent) fell in the Below Poverty Level category.
12 For more information on the “opportunity area” categories developed by HCD and the California Tax Credit Allocation Committee, see this website:
https://www.treasurer.ca.gov/ctcac/opportunity.asp. The degree to which different jurisdictions and neighborhoods have access to opportunity will likely
need to be analyzed as part of new Housing Element requirements related to affirmatively furthering fair housing. ABAG/MTC will be providing
jurisdictions with technical assistance on this topic this summer, following the release of additional guidance from HCD.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-27
Figure 10-12 Percent of Children in Female Households, 2015-2019
Source: California Department of Housing and Community Development AFFH Data Viewer
HCD Draft Initial Review 2023-2031 Housing Element
10-28 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Senior Households
Senior households often experience a combination of factors that can make accessing or keeping affordable
housing a challenge. Seniors, defined as persons who are 65 years or older, may live on fixed incomes and may
have disabilities, chronic health conditions, and/or reduced mobility. Seniors who rent may be at even greater risk
for housing challenges than those who own, due to income differences between these groups.
When cost-burdened seniors are no longer able to make house payments or rent payments, displacement from
their homes can occur, putting further stress on the local rental market or forcing residents out of their community.
Understanding how seniors might be cost-burdened is of particular importance due to their special housing needs,
particularly for low-income seniors. Of seniors making less than 30 percent of AMI, 74 percent are spending the
majority of their income on housing. For seniors making more than 100 percent of AMI, 86 percent are not cost-
burdened and spend less than 30 percent of their income on housing.
People with Disabilities
People with disabilities face additional housing challenges. Encompassing a broad group of individuals living with
a variety of physical, cognitive, and sensory impairments, many people with disabilities live on fixed incomes and
are in need of specialized care, yet often rely on family members for assistance due to the high cost of care.
When it comes to housing, people with disabilities are not only in need of affordable housing, but accessibly
designed housing, which offers greater mobility and opportunity for independence. Unfortunately, the need
typically outweighs what is available, particularly in a housing market with such high demand. People with
disabilities are at a high risk for housing insecurity, homelessness, and institutionalization, particularly when they
lose aging caregivers. Overall, nine percent of people in Los Gatos have a disability of some kind.
State law also requires a Housing Element to examine the housing needs of people with developmental
disabilities. Developmental disabilities are defined as severe, chronic, and attributed to a mental or physical
impairment that begins before a person turns 18 years old. This can include Down’s Syndrome, autism, epilepsy,
cerebral palsy, and mild to severe intellectual disability. Some people with developmental disabilities are unable
to work, rely on supplemental security income, and live with family members. In addition to their specific housing
needs, they are at increased risk of housing insecurity after an aging parent or family member is no longer able to
care for them.13 In Los Gatos, there are 123 persons with a developmental disability. Out of this nine percent of
the Town’s population, 50 are children under the age of 18 (41 percent) and 73 are adults (60 percent). The most
common living arrangement for individuals with disabilities in Los Gatos is the home of a parent/family/guardian.
Figure 10-13 Share of Population by Disability Status, 2019
Source: ABAG Housing Needs Data Workbook
13 For more information or data on developmental disabilities in your jurisdiction, contact the Golden Gate Regional Center for Marin, San Francisco and
San Mateo Counties; the North Bay Regional Center for Napa, Solano and Sonoma Counties; the Regional Center for the East Bay for Alameda and Contra
Costa Counties; or the San Andreas Regional Center for Santa Clara County.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-29
Figure 10-14 Percent of Population with a Disability by Census Tract, 2019
Source: California Department of Housing and Community Development AFFH Data Viewer
HCD Draft Initial Review 2023-2031 Housing Element
10-30 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Homelessness
Homelessness remains an urgent challenge in many communities across the State, reflecting a range of social,
economic, and psychological factors. Rising housing costs result in increased risks of community members
experiencing homelessness. Many residents who have found themselves housing insecure have ended up
homeless in recent years, either temporarily or longer term. Addressing the specific housing needs of the
unhoused population remains a priority throughout the region, particularly since homelessness is
disproportionately experienced by people of color, people with disabilities, those struggling with addiction, and
those dealing with traumatic life circumstances.
In Santa Clara County, the most common type of household experiencing homelessness is those without children
in their care. Among households experiencing homelessness that do not have children, 87 percent are
unsheltered. Of homeless households with children, most are sheltered in emergency shelters.
People of color are more likely to experience poverty and financial instability as a result of Federal and local
housing policies that have historically excluded them from the same opportunities extended to White residents.
Consequently, people of color are often disproportionately impacted by homelessness, particularly Black
residents of the Bay Area.
In Santa Clara County, White (Hispanic and Non-Hispanic) residents represent the largest proportion of residents
experiencing homelessness and account for 44 percent of the homeless population, while making up 45 percent
of the overall population.
Farmworkers
Across the State, housing for farmworkers has been recognized as an important and unique concern.
Farmworkers generally receive wages that are considerably lower than other jobs and may have temporary
housing needs. Finding decent and affordable housing can be challenging, particularly in the current housing
market.
In Los Gatos, there were no reported students of migrant workers in the 2019-20 school year. The trend for the
region for the past few years has been a decline of more than two percent in the number of migrant worker
students since the 2016-17 school year. The change at the County level is a 50 percent decrease in the number
of migrant worker students since the 2016-17 school year.
10.2.7 Governmental and Non-Governmental Constraints
Housing development is affected by government regulations and other non-governmental forces, such as the cost
of land and building materials and the availability and cost of housing loans. A Housing Element is required to
investigate the impact of these constraints as they present themselves in the municipality in which the Housing
Element is being prepared. Please see Appendix C for a full discussion governmental and non-governmental
constraints in the Town of Los Gatos.
Revisions to the Zoning Code are necessary to achieve consistency with changes in State housing law.
Anticipated zoning changes are detailed in the implementation programs found in Section 10.5 of this Housing
Element.
In terms of non-governmental constraints, land costs will remain a constraint to affordable housing. To help offset
this constraint, programs to use Town-owned lands, such as Town parking lots could be utilized. Due to the cost
of construction materials, the Town may subsidize affordable housing projects with available funds dedicated to
housing in order to increase affordable housing inventory.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-31
10.3 Site Inventory and Opportunities
This section summarizes the housing needs of the Town as determined through the comprehensive housing data
assessment and analysis presented in Appendix D and serves as the basis for housing goals, policies, and
actions. The housing summary gives an overview of population trends, characteristics of the housing stock,
housing affordability, and special needs households.
10.3.1 Introduction
The Plan Bay Area 2050 Final Blueprint 14 forecasts that the nine-county Bay Area will add 1.4 million new
households between 2015 and 2050. For the eight-year time frame covered by this Housing Element Update,
HCD has identified the region’s housing need as 441,176 units. The total number of housing units assigned by
HCD is separated into four income categories that cover housing types for all income levels, from very low-
income households to market rate housing. This calculation, known as the RHNA, is based on population
projections produced by the California Department of Finance as well as adjustments that incorporate the region’s
existing housing need. The adjustments result from recent legislation requiring HCD to apply additional
adjustment factors to the baseline growth projection from California Department of Finance, in order for the
regions to get closer to healthy housing markets. To this end, adjustments focus on the region’s vacancy rate,
level of overcrowding and the share of cost-burdened households and seek to bring the region more in line with
comparable ones. Compared to previous cycles, these new laws governing the methodology for how HCD
calculates the RHNA resulted in a significantly higher number of housing units for which the Bay Area must plan
compared to previous cycles.
10.3.2 Sites Summary
The vacant, partially vacant, and underutilized sites identified in this report are sufficient to accommodate Los
Gatos’ Regional Housing Needs Allocation for the 6th Cycle planning period. The sites also accommodate the
recommended buffer of 15 percent above RHNA, which would equal a capacity of approximately 299 additional
units. This “cushion” for capacity above the base RHNA number is highly recommended because of the State’s
no-net-loss policy, which precludes jurisdictions from approving development that results in an overall housing
site deficit. The “cushion” essentially provides a degree of flexibility for policy makers as they make development
decisions. Many of the sites identified in this report have existing uses that would need to be demolished before
new housing could be constructed.
For communities like Los Gatos that are largely built-out and surrounded on all sides by other communities,
redevelopment and densification is the only practical solution to providing a fair share of future housing for the
San Francisco Bay Area. By its nature, such redevelopment is more costly and more time consuming than
building new units on vacant land. To offset these constraints, higher densities are proposed in some areas.
These higher densities act as a market incentive to offset the added cost and time required to build new housing
on redeveloped sites. Property owner interest will be pivotal for facilitating single-family site opportunities and
policies to add housing through SB 9, which allows for up to four units on a property zoned for single-family
residences. Table 10-3 provides a summary of the number of vacant and underutilized housing sites included in
the Site Inventory for the Town of Los Gatos, and how they compare to the RHNA allocation plus a 15 percent
buffer.
14 Plan Bay Area 2050 is a long-range plan charting the course for the future of the nine-county San Francisco Bay Area. It covers four key issues: the
economy, the environment, housing and transportation.
HCD Draft Initial Review 2023-2031 Housing Element
10-32 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Table 10-3 Summary of Vacant and Underutilized Housing Sites
Item Very Low Low Moderate Above
Moderate Total
Total Estimated Housing for Sites in
Inventory 618 360 388 1,005 2,371
RHNA 537 310 320 826 1,993
Buffer (15 %) 81 46 48 124 299
RHNA + Buffer 618 356 368 950 2,292
Difference Between Housing Estimate and
RHNA + Buffer 0 4 20 55 79
SOURCE: EMC Planning Group, Inc; Town of Los Gatos
10.4 Energy and Resource Conservation
This section summarizes background information and actions being undertaken by the Town of Los Gatos to
address energy and resource conservation. The information is excerpted from Chapter 8 (Environment and
Sustainability Element) of the 2040 General Plan. For a full discussion of energy-related issues, please see
Chapter 8, Section 8.6 (Energy) of the 2040 General Plan.
10.4.1 Opportunities for Energy Conservation
With the escalation in energy prices, consumers and builders have once again become more aware of energy
costs. The Town must balance between development and environmental stewardship to maintain a strong
economy and, at the same time, protect the environment. The following section highlights building standards
and conservation codes contributing to that success.
Title 24 of the California Administrative Code sets forth mandatory energy standards for new development and
requires adoption of an "energy budget." In turn, the home building industry must comply with these standards
while localities are responsible for enforcing the energy conservation regulations. In 2015, the Town adopted a
Solar Energy Code for the purpose of reducing energy costs for new residential developments and adopted an
energy budget. In addition, State law (both the Residential Building Code and CalGreen) have standards that
significantly reduce energy use in new residential construction.
Increasing energy costs, persistent drought, and climate change have reshaped how Californians think when it
comes to buying new homes. Solar roof panels have become more commonplace over the past several decades,
with both State and Federal tax credits available. Energy-efficient appliances and water wise landscaping have
become amenities of choice for homebuyers. Developers can make the most of this paradigm shift by embracing
“green” building practices that incorporate the energy and water efficiencies that consumers desire as well as
environmentally friendly construction that minimizes waste and maximizes the use of resources.
Pacific Gas and Electric (PG&E) distributes electricity throughout Los Gatos, with supplies purchased from Silicon
Valley Clean Energy (SVCE). PG&E supplies natural gas to the community as well. The Town is committed to its
partnership with other local communities under the umbrella of SVCE. Through this partnership, Los Gatos
residents and businesses receive carbon-free electricity at lower rates than those that arise from fossil fuel
consumption. SVCE works to innovate and implement new clean energy programs and presents many of these
innovations at community meetings, Earth Day events, and presentations to businesses. SVCE’s 2020
Community Benefits Summary indicates Los Gatos achieved the following results:
▪$813,000 in on-bill savings for Los Gatos SVCE customers.
▪14,700 households and businesses served.
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-33
▪99 percent reduction in electric utility-related emissions (34,897,000 pounds greenhouse gas emissions
avoided by providing clean energy).
▪$29,900 in cash payments to customers for generating surplus solar energy.
Achieving these goals adds to the overall GHG reduction strategy, with a focus on lowering dependence on
carbon-based fuels and energy sources. Energy efficiency involves a careful balance of assessing energy
sources, educating the public on home and business renewable energy use, implementing energy efficiency
strategies, and encouraging and incentivizing widespread and ongoing implementation of those strategies. This
in turn translates into lower ongoing costs to homeowners and renters.
10.4.2 Energy-Related Goals and Policies
As required by State housing law, the Housing Element must analyze energy conservation opportunities in
residential development. In the following section, Goal HE-5 and its related policies and actions address energy
conservation in residential development in Los Gatos.
The relevant Environment and Sustainability Element goals and policies in the 2040 General Plan are:
▪Carbon-Neutral Energy (ENV-11.1). Support SCVE to continue to procure carbon-neutral energy for long-
term and short-term supplies, including renewable resources.
▪Energy Efficiency in Municipal Facilities (ENV 11.2). Invest in cost-effective energy efficiency and energy
conservation programs in municipal facilities.
▪Future Demand Reduction (ENV 11.3). Explore cost-effective, reliable, and feasible energy efficiency and
demand reduction opportunities and continue to use the Sustainability Plan to include education programs
for these opportunities.
▪Conservation and Reduction (ENV 11.4). Maximize the conservation and efficient use of energy in existing
and new residences, businesses, and municipal buildings in Los Gatos.
▪Solar Systems (ENV 11.5). Support the maximum economic use of solar electric (photovoltaic) systems
on-site to augment the renewable energy portfolio available to new development, businesses, and
municipal facilities.
▪Organic Waste Recycling (ENV 11.6). Comply with SB 1383 regulations to maximize energy recovery
from organic materials such as yard trimmings, food waste, and other compostable resources.
HCD Draft Initial Review 2023-2031 Housing Element
10-34 HCD Draft Initial Review 2023-2031 Housing Element October 2022
10.5 Goals, Policies, and Implementation Programs
The Town does not build housing but, rather creates the policies and implementation programs to plan for where
the housing can be located and how many units can be built on potential sites. The Town is responsible for
enabling the production of housing by reducing regulatory barriers, providing incentives, and supporting programs
that create or preserve housing, especially for vulnerable populations. The Town encourages production of a
diversity of new housing to ensure an adequate supply is available to meet the needs of existing and future
residents. To enable the construction of quality housing, the Town has identified the following goals, policies, and
actions.
Goal HE-1 Facilitate All Types of Housing Construction.
The Town encourages the production of diverse new housing options to ensure that an adequate supply is
available to meet the existing and future needs of all residents.
Policy HE-1.1 Adequate Sites
Designate sufficient, residentially zoned land at appropriate densities to provide adequate sites to
accommodate Los Gatos’s RHNA for 2023–2031 and monitor residential development to ensure
there is an adequate level of remaining development capacity.
Policy HE-1.2 Multi-Family Housing Densities
Encourage builders to develop projects on multi-family designated properties at the high end of
the applicable density range.
Policy HE-1.3 Infrastructure
All new residential development shall be sufficiently served by public services and facilities,
including pedestrian and vehicular circulation, bike lanes, water and wastewater services, police,
fire, schools, and parks.
Policy HE-1.4 Housing Design
Ensure that all new housing is well designed and fosters a sense of community.
Policy HE-1.5 Variety of Housing Choices
Encourage the production of housing that meets the needs of all economic segments of the
Town, including lower and moderate households, to maintain a balanced community.
Policy HE-1.6 Universal Design
Address the special housing needs of persons with disabilities through reasonable
accommodation procedures, zoning provisions for supportive and group housing, homeowner
accessibility grants, and by encouraging universal design.
Policy HE-1.7 Infill Opportunities in Single-Family Neighborhoods
The Town shall increase access to opportunity for lower-income households by encouraging infill
of smaller units in single-family neighborhoods (e.g., ADUs, multi-generational housing units, and
SB 9 projects).
AFFH
AFFH
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-35
Goal HE-2 Provide New Affordable Housing.
Overall housing production has been too slow to keep pace with population growth over the past two decades.
This trend has increased demand on the supply side of housing and increased the cost of all housing. More
affordable housing is needed for extremely low, very low-, low-, and middle-income households.
Policy HE-2.1 Financial Resources
Pursue expanding financial resources to support the production of affordable housing for the
Town’s modest income residents and workforce.
Policy HE-2.2 Housing Vouchers
The Town shall support the Santa Clara County Housing Authority program for Housing Choice
Vouchers (Section 8) to assist extremely low-, very low-, and low-income residents of the Town.
Policy HE-2.3 Mixed-Use Development
Encourage mixed–use developments that provide affordable housing close to employment
centers and/or transportation facilities, particularly along arterials.
Policy HE-2.4 Rental Housing
Strive to ensure that at least 30 percent of the housing stock is rental units and continue to
support the development of ADUs as a means of affordable rental housing.
Policy HE-2.5 Pre-Approved Accessory Dwelling Units
Collaborate with countywide efforts to develop pre-approved ADU plans suitable for Los Gatos,
including designs that are Americans with Disabilities Act (ADA) accessible.
Policy HE-2.6 Promote Accessory Dwelling Unit Construction
Encourage homeowners to construct detached rental ADUs in order to increase the housing
stock of smaller rental units.
Policy HE-2.7 Senior Housing
Support development and maintenance of affordable senior rental and ownership housing and
continue to work with existing senior lifestyle living and assisted living facilities in Los Gatos.
Encourage a variety of senior living options including downsizing and step-down independent
ownership housing.
Policy HE-2.8 Equal Housing and Special Needs
Support the provision of permanent, affordable, and accessible housing that allows persons with
special needs to live independent lives. For the purposes of this Housing Element “persons with
special needs” include extremely low-income households, seniors, overcrowded and large-family
households, the homeless population, those in need of emergency shelter, youth aging out of
foster care, female-headed or single-parent households, and persons with disabilities, including
developmental challenges.
Policy HE-2.9 Public/Private Partnerships
Work with and support collaborative partnerships with nonprofit agencies and housing developers
to plan and develop a mix of affordable housing opportunities in Los Gatos using available
funding.
AFFH
AFFH
AFFH
AFFH
HCD Draft Initial Review 2023-2031 Housing Element
10-36 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Policy HE-2.10 Repurposing Obsolete Commercial Buildings
Encourage property owners to pursue opportunities to integrate housing in underutilized
commercial centers, and to reuse excess or obsolete commercial buildings for affordable
housing.
Policy HE-2.11 Smart Growth
Encourage “smart growth” that accommodates higher density residential uses near transit,
bicycle-, and pedestrian-friendly areas of the Town that encourage and facilitate the conservation
of resources by reducing the need for automobile use.
Policy HE-2.12 Housing on Land Owned by Religious Institutions
Support the provision of affordable housing on congregational land through flexible development
standards, including opportunities for reduced and shared parking arrangements.
Goal HE-3 Remove Barriers to the Production of Housing.
Governmental constraints on the development of housing for households of all income levels needs to be
minimized. The success of development in some opportunity areas will be dependent upon consolidation of
individual parcels into larger development sites. While some of the individual parcels within these areas are
already under common ownership, many are individually owned.
Policy HE-3.1 Regulatory Incentives for Affordable Housing
Facilitate the development of affordable housing through regulatory incentives and concessions,
and/or financial assistance. Continue expediting the permit processing system for affordable
residential development applications and proactively seek out new models and approaches in the
provision of affordable housing.
Policy HE-3.2 Flexible Development Standards
Provide flexibility in development standards to accommodate new models and approaches to
providing housing, such as live/work housing (permitted with a CUP), and micro units (in existing
housing units), to allow housing to adapt to the needs of the occupants.
Policy HE-3.3 Efficient Development Processing
Explore continued improvements to the entitlement process to streamline and coordinate the
processing of permits, design review, and environmental clearance.
Policy HE-3.4 Lot Consolidation
Educate and encourage lot consolidation and lot assemblage in mixed use and commercial
areas.
Policy HE-3.5 Development Impact and Permit Fees
Consider reduced fees and alternative funding to facilitate affordable housing development.
AFFH
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-37
Goal HE-4 Improve the Existing Housing Stock.
Providing more housing is a priority; but maintaining and preserving existing housing also plays a critical role.
Much of the older housing in the Town can be naturally affordable, as priced by the housing market, but must be
well-maintained to provide quality housing across income levels.
Policy HE-4.1 Property and Housing Conditions
Support long-term maintenance and improvement of existing housing units through Code
Enforcement and housing rehabilitation programs.
Policy HE-4.2 Multi-Family Housing Acquisition and Improvement
Improve the quality of rental housing by acquisition and/or rehabilitation using the Affordable
Housing Fund and support nonprofit housing providers in the acquisition and rehabilitation of
older housing stock, and maintenance as long-term affordable housing.
Policy HE-4.3 Home Affordability Preservation
Preserve the affordability of units affordable to very low-, low-, and moderate-income households
in the Town and Bonnie View Park, and enforce zoning regulations regarding conversion of
mobile home parks in Los Gatos.
Policy HE-4.4 Naturally Occurring Affordable Units
Encourage maintaining naturally affordable housing types such as duplexes, townhomes, and
mobile homes.
Policy HE-4.5 Preserve Residences of Historic or Architectural Value
The Town shall encourage the preservation of residential buildings with historic or architectural
value.
Goal HE-5 Encourage Green Building and Energy Conservation.
The Town is dedicated to addressing and mitigating climate change impacts and strives to be a leader in
sustainable development. The General Plan promotes environmentally sound and socially equitable development
by encouraging residential construction that promotes sustainable building and energy conservation practices.
Policy HE-5.1 Green Building
Encourage sustainable housing development throughout the Town by fostering awareness and
encouraging the adoption of green building practices.
Policy HE-5.2 Solar Energy
Promote more efficient energy use and renewable energy to reduce the strain on the existing
energy grid and reduce greenhouse gas emissions.
AFFH
AFFH
AFFH
HCD Draft Initial Review 2023-2031 Housing Element
10-38 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Goal HE-6 Publicize Fair Housing Resources, Including those for Special Needs Populations.
Many programs that address housing access and affordability for lower income households are supported by the
Town and its partners; however, many people who need these resources have trouble finding them. It is
important for the Town to proactively inform residents about housing needs and resources, particularly those
related to Fair Housing issues.
Policy HE-6.1 Fair Housing
Support and publicize housing programs that protect individuals’ rights and enforce fair housing
laws prohibiting arbitrary discrimination in the building, financing, selling or renting of housing on
the basis of race, color, ancestry, religion, national origin, sex, sexual orientation, age,
disability/medical condition, familial status, marital status, source of income or other such factors.
Policy HE-6.2 Financial Assistance
Continue to encourage Los Gatos households to participate in financial assistance programs
provided in the County of Santa Clara.
Policy HE-6.3 Housing for Persons with Special Needs
Continue to provide assistance to service providers who support special needs households and
the homeless, such as Project Sentinel, Santa Clara County Housing Authority, and Santa Clara
County Office of Supportive Housing. Support and publicize efforts and resources to provide
coordinated services for persons with special needs in the Town.
Policy HE-6.4 Affordable Housing Awareness
Raise community awareness of the need for and benefits of affordable housing through Town
outreach. Foster Town-wide discussion on housing needs, resources and ideas and improve
communication channels and methods for meaningful dialogue.
Policy HE-6.5 Infill Opportunities in Single-Family Neighborhoods
The Town shall provide educational materials for the public to promote ADUs, multi-generational
housing units and SB 9 projects that create housing opportunities in single-family neighborhoods
through the infill of smaller units.
Policy HE-6.6 Rental Dispute Mediation and Arbitration Ordinance
The Town will work to prevent evictions of long term, low-income residents living in naturally
affordable housing who can quickly lose their residence due to sudden rent increases or changes
in property owners.
AFFH
AFFH
AFFH
AFFH
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-39
10.6 Implementation Programs
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
A Developer Forum
Establish an annual meeting
between staff and housing
developers to discuss constraints
and opportunities to affordable
and market rate housing projects.
HE-1.1 Adequate
Sites
HE-1.2 Multi-family
Housing Densities
HE-1.3 Infrastructure
HE-1.4 Housing
Design
HE-1.5 Variety of
Housing Choices
Community
Development
Department
Annually provide
focus group or
Town Hall
meeting
opportunities
None
required
B Large Site Program
Encourage property owners and
affordable housing developers to
target and market the availability
of sites with the best potential for
development by facilitating
meetings between willing
property owners of large sites.
To assist the development of
housing, especially for lower
income households, on sites
larger than 10 acres, the Town
will facilitate land divisions and lot
line adjustments to result in
parcels sizes between one half
to10 acres that can
accommodate multiple-family
developments affordable to lower
income households in light of
State, Federal, and local
financing programs.
HE-1.1 Adequate
Sites
HE-1.2 Multi-family
Housing Densities
HE-1.3 Infrastructure
HE-1.4 Housing
Design
HE-1.5 Variety of
Housing Choices
Community
Development
Department
Annually provide
focus group or
Town Hall
meeting
opportunities
None
required
C No Net Loss
Develop and implement an
ongoing formal evaluation
procedure (project-by-project) of
sites identified in the Site
Inventory to maintain sufficient
sites at appropriate densities to
accommodate RHNA for lower
income households. If an
approval of a development
results in a reduction of site
capacity below the residential
capacity needed to
accommodate the remaining
RHNA, including for lower
income households, the Town
HE-1.1 Adequate
Sites
HE-1.3 Infrastructure
HE-1.5 Town
Resources
HE-1.5 Variety of
Housing Choice
Community
Development
Department
Ongoing
tracking as
developments
are approved
None
required
HCD Draft Initial Review 2023-2031 Housing Element
10-40 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
will identify and zone sufficient
adequate sites at appropriate
densities to accommodate the
remaining RHNA.
D Additional Housing Capacity
Amend the North Forty Specific
Plan to increase the maximum
allowable density from 20
dwelling units per acre to more
than 30 dwelling units per acre
and increase the total number of
dwelling units allowed in the
Specific Plan.
HE-1.1 Adequate
Sites
HE-3.3 Efficient
Development
Processing
Community
Development
Department
December 2023 None
required
E Affordable Development on
Town Owned Property
Pursue opportunities to work with
an affordable housing developer
to construct affordable housing
on Town owned property.
HE-1.1 Adequate
Sites
HE-2.9 Public/Private
Partnerships
Community
Development
Department
Ongoing None
required
F Update Permit Software
System
Update the existing permit
software system to better monitor
average processing times for
ministerial and discretionary
development permits. Use data
to set baselines timelines to drive
improvements. Update the Town
planning and zoning regulations
and remove permit processing
constraints as appropriate.
HE-3.3 Efficient
Development
Processing
Community
Development
Department
Review and
update
regulations as
appropriate at
biannual years
None
required
G Report Annually on Housing
Availability
Prepare an annual housing report
for the review of the Town
Council including information on
progress made towards
achieving new construction need,
affordable housing
conserved/developed,
effectiveness of existing
programs and recommendations
for improvement. Consult and
collaborate with non-profit
providers, special need
providers, and other community
HE-1.1 Adequate
Sites
HE-1.5 Town
Resources
HE-3.3 Efficient
Development
Processing
HE-1.5 Variety of
Housing Choices
Community
Development
Department
Annual None
required
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-41
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
resources in preparation and
evaluation of the report.
H Study detached single-family
condominium option.
Study the development of a new
floor area ratio standard for multi-
family development when
developed as detached single-
family condominium units.
HE-1.5 Variety of
Housing Choices
HE-2.7 Senior
Housing
Community
Development
Department
Upon adoption
of this Housing
Element
None
required
I Coordination with Water and
Sewer Providers
Deliver the adopted Housing
Element to the San Jose Water
Company and the West Valley
Sanitation District so that they
can prioritize current and future
resources or services for housing
development that helps meet Los
Gatos’s RHNA for lower income
households.
HE-1.3 Infrastructure Community
Development
Department
Upon adoption
of this Housing
Element
None
required
J Helping Seniors Program
Provide financial assistance for
health, safety, emergency and
accessibility home repairs to low-
income seniors and low-income
mobile homeowners through the
Below Market Price Program
funds, subject to availability of
Program funds.
HE-1.7 Universal
Design
HE-2.7 Senior
Housing
HE-2.8 Equal
Housing and Special
Needs
Community
Development
Department,
Town Council
Ongoing Town
Affordable
Housing
Funds
K Small Multi-Unit Housing
Update the Zoning Code to
facilitate low rise multi-family
structures in the Medium
Residential Density designation.
Promote this program through
publication, to include the
following information: Low rise
multi-family dwelling units
ranging from two to 10 units can
help meet the needs of families,
seniors and students. Permit
processing times tend to be
shorter than larger multi-family
buildings due to the low-rise
nature of the structures.
HE-1.5 Variety of
Housing Choices
HE-2.4 Rental
Housing
HE-3.3 Efficient
Development
Processing
Community
Development
Department
Ongoing None
required
HCD Draft Initial Review 2023-2031 Housing Element
10-42 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
L Rental Housing for Large
Families
Encourage development of multi-
family rental housing that is
greater than two bedrooms to
encourage the provision of
adequate rental housing for
families.
HE-1.5 Variety of
Housing Choices
HE-2.4 Rental
Housing
Community
Development
Department
Ongoing None
required
M Lot Consolidation
The Town will conduct outreach
to property owners in these areas
to identify meaningful incentives
to facilitate lot consolidation, lot
assemblage and redevelopment
in mixed use and commercial
areas. Based on this feedback,
within two years of Housing
Element adoption, the Town will
consider the development of a
Lot Consolidation Ordinance to
include specific incentives such
as: flexible development
standards such as reduced
setbacks, increased lot coverage,
increased heights, reduced
parking, reduced fees, and
streamlined permit processing
through administrative staff
review. Upon adoption of the
Ordinance, the Town will work
with property owners that are
receptive to lot consolidation/lot
assemblage to assist them in
facilitating the parcel merge
process in a streamlined and
timely manner.
HE-3.4 Lot
Consolidation
Community
Development
Department
Within two years
of Housing
Element
adoption
None
required
N Below Market Price Program
Conduct a study to evaluate the
existing BMP Program and
recommend changes to the
program to increase the number
of units constructed. The study
will include evaluation of the
implementation of the BMP
Program to date, including
impacts to market rate housing
related to current market
conditions, project applications,
HE-2.7 Senior
Housing
HE-3.1 Regulatory
Incentives for
Affordable Housing
HE-4.1 Property and
Housing Conditions
HE-4.2 Multi-family
Housing Acquisition
Improvement
Community
Development
Department
Complete study
by June 2025
and implement
recommended
policy actions by
December 2028.
Town
Affordable
Housing
Fund
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-43
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
estimated affordable housing
requirements, fee collection, and
actual construction of affordable
housing units to address
constraints based on the
outcome of the evaluation. The
study will evaluate the feasibility
of requiring BMP’s for senior
assisted living, senior
independent living, and senior
communities.
O Establish a Commercial
Linkage Fee
Conduct a nexus study and
amend the Municipal Code to
include a linkage fee if
appropriate. A commercial
linkage fee is an impact fee
levied on commercial
development for the provision of
affordable housing. Before
levying an impact fee, the Town
is required to complete a nexus
study that shows the linkage
between new development and
the increased demand for
housing.
HE-3.5 Development
Impact and Permit
Fees
Community
Development
Department
Complete study
by June 2024
and implement
recommended
actions by
December 2024.
None
required
P Funds for Development for
Extremely Low Income (ELI)
Households
Continue to encourage the
creation of housing that is
affordable to extremely low-
income households by allocating
a percentage of the Town
Affordable Housing (Below
Market Price) Fund to subsidize
housing for extremely low-income
households. As part of the
Town’s annual budget process,
provide a priority for funding ELI
developments that may be
submitted to the Town with the
Town’s BMP monies. Update the
allocation as recommended by
the BMP study. Additionally,
provide staff technical assistance
with the preparation of Tax Credit
or grant funding applications or
HE-3.1 Regulatory
Incentives for
Affordable Housing
HE-4.1 Property and
Housing Conditions
HE-4.2 Multi-family
Housing Acquisition
Improvement
Community
Development
Department
Ongoing Town
Affordable
Housing
Fund
HCD Draft Initial Review 2023-2031 Housing Element
10-44 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
conducting local Tax Equity and
Fiscal Responsibility Act
(TEFRA) hearings to facilitate the
financing of proposed housing
projects in Los Gatos.
Q Habitat for Humanity Home
Repair Program
Work with Habitat for Humanity to
promote the Home Repair
Program offered by Habitat,
which responds to health,
accessibility, and safety concerns
in homes owned by low-income
families, veterans, and senior
residents on limited incomes. By
fixing the long-deferred
maintenance projects, critical
repairs and code violations, this
program helps families stay in
their already affordable homes
and avoid displacement.
HE-2.7 Senior
Housing
HE-2.8 Equal
Housing and Special
Needs
HE-4.1 Property and
Housing Conditions
Community
Development
Department
Annually meet
with Habitat for
Humanity
None
required
R Development Impact and
Permit Fees
Review the financial needs of
affordable housing projects,
determine whether or not Town
fees can be reduced to facilitate
affordable housing development,
and identify options for the Town
to offset the foregone revenues
from other sources.
HE-3.5 Development
Impact and Permit
Fees
Community
Development
Department,
Parks and
Public Works,
Town Council
January 2023 to
January 2031
Staff Time
S Affordable Housing
Development
Provide incentives for affordable
housing development, including
density bonus, fee deferrals or
reductions, and reduced fees for
studio units. The Town shall also
provide annual outreach to attract
and support affordable housing
developers in the Town, including
developers of senior housing,
extremely low-income units, and
permanent supportive housing for
persons with disabilities and
developmental disabilities.
HE-1.2 Multi-family
Housing Densities
HE-3.5 Development
Impact and Permit
Fees
HE-2.7 Equal
Housing and Special
Needs
HE-2.9 Public/Private
Partnerships
HE-3.1 Regulatory
Incentives for
Affordable Housing
Community
Development
Department,
Town Council
January 2023 to
January 2031
Staff Time
and the
Town
Affordable
Housing
Fund
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-45
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
T Purchase Affordability
Covenants in Existing
Apartments
Create a program for the Town to
purchase affordability covenants
with BMP funding to increase the
supply of affordable housing or
“buy-down” existing affordability
covenants to have deeper
affordable units in existing rental
properties. This program is
analogous to purchasing
covenants in new developments
in conjunction with the BMP
program, but for existing
apartments.
In existing and new rental
developments, the Town could
provide a rehabilitation loan or
another form of subsidy to a
rental property owner in
exchange for securing
affordability covenants on a
percentage of units and the
owner’s agreement to restrict
rents on these units to levels that
would be affordable to very low-
and low-income households.
HE-2.1 Financial
Resources
Community
Development
Department,
Town Council
January 2023 to
January 2031
Town
Affordable
Housing
Fund
U Accessory Dwelling Units
Waive building fees when an
ADU is deed restricted for very
low- and low-income households.
HE-2.4 Rental
Housing
HE-3.5 Development
Impact and Permit
Fees
Community
Development
Department
Amend the Fee
Schedule within
one year of
Housing
Element
adoption
Below
Market
Price
Housing In-
lieu Fees
V Density Bonus
Conduct a study to evaluate the
existing Density Bonus
Ordinance and recommend
changes to increase the number
of units constructed. The study
will include an evaluation of the
implementation of the ordinance
to date and actual construction of
affordable housing units that
utilized the Density Bonus.
Additional density and height
incentives beyond what the State
HE-3.1 Regulatory
Incentives for
Affordable Housing
HE-2.3 Mixed-Use
Development
HE-2.8 Equal
Housing and Special
Needs
Community
Development
Department
Complete study
by June 2026
and implement
recommended
actions by
December 2029
None
required
HCD Draft Initial Review 2023-2031 Housing Element
10-46 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
requires will be considered (i.e.,
fee reductions, add free density
of BMP units). The study shall
recommend improvements to the
Ordinance based on the outcome
of the evaluation.
W Affordable Housing Overlay
Zone (AHOZ)
Continue to encourage
development of housing
affordable to all income levels on
property within this Town Overlay
Zone. The Overlay property on
Knowles Avenue is a key site for
a mixed income affordable
housing project.
HE-3.1 Regulatory
Incentives for
Affordable Housing
HE-2.7 Senior
Housing
HE-2.8 Equal
Housing and Special
Needs
HE-2.9 Public/Private
Partnerships
HE-2.11 Policy Smart
Growth
Community
Development
Department
Complete by
2025
None
required
X Congregational Land Overlay
Zone
Expand site opportunities by
allowing affordable housing on
religious sites. Study new
Congregational Land Overlay to
build upon what is available
through AB 1851 and help
congregations by connecting
them with affordable housing
development partners.
HE-3.1 Regulatory
Incentives for
Affordable Housing
HE-2.7 Senior
Housing
HE-2.8 Equal
Housing and Special
Needs
HE-2.9 Public/Private
Partnerships
HE-2.11 Policy Smart
Growth
Community
Development
Department
Complete by
2025
None
required
Y Nonprofit Affordable Housing
Providers
Support the efforts of nonprofit
affordable housing organizations
that provide housing services in
Los Gatos. Encourage the
participation of these providers in
developing housing and meeting
the affordable housing needs of
Los Gatos households
particularly extremely low-income
households. Staff will meet with
nonprofit groups on at least on an
annual basis to discuss
constraints to development and
develop strategies and actions
for affordable housing
development, including
HE-2.3 Mixed-Use
Development
HE-2.7 Senior
Housing
HE-2.8 Equal
Housing and Special
Needs
HE-2.9 Public/Private
Partnerships
Community
Development
Department
Annually None
required
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-47
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
incentives for the development of
affordable housing as provided
under the Affordable Housing
Overlay Zone.)
Z Increased Range of Housing
Opportunities for the
Homeless
Continue to support the County
of Santa Clara’s Continuum of
Care plan, as well as the
“Housing 1000” campaign by
“Destination: Home” to provide
housing opportunities for
homeless households, including
emergency shelter, transitional
housing, and permanent
affordable housing opportunities.
HE-2.8 Equal
Housing and Special
Needs
HE-2.9 Public/Private
Partnerships
Community
Development
Department
January 2023 to
January 2031
County
CDBG
AA Reasonable Accommodation
Ordinance
Continue to enforce Section
29.10.505–530 of the Town Code
to ensure equal access to
housing for persons with
disabilities under the Fair
Housing Act and provide specific
procedures for requesting and
granting reasonable
accommodations. Review
annually for trends and develop
new procedures and/or materials
in response to annual review.
HE-2.8 Equal
Housing and Special
Needs
Community
Development
Department
Annually None
required
AB Accessibility Design Features
Encourage residential
development that incorporates
accessible design features to
meet the needs of as many users
as possible. The intent is to
reduce the potential for
occupants to be displaced from
their homes due to disability, to
allow those persons to visit
neighboring dwelling units, and to
increase to number of accessible
dwelling units in the local housing
supply that meet long term
housing needs. Remove
identified regulatory constraints
Policy HE-1.6
Universal Design
HE-2.8 Equal
Housing and Special
Needs
HE-2.9 Public/Private
Partnerships
Community
Development
Department
Review and
update
regulations as
necessary; at
least every three
years
None
required
HCD Draft Initial Review 2023-2031 Housing Element
10-48 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
on housing for persons with
disabilities.
AC Housing Opportunities for
Persons Living with
Disabilities
Support the provision of housing
for the disabled population,
including persons with
developmental disabilities,
through several means,
including:
▪By-right zoning for licensed
residential care facilities (six
or fewer residents) in all
residential zones, and
provisions for larger care
facilities (seven or more
residents) in multi-family
residential zones subject to a
conditional use permit.
▪Treatment of supportive and
transitional housing as a
residential use of property,
and subject only to those
restrictions and processing
requirements that apply to
other residential dwellings of
the same type in the same
zone.
▪Programs to facilitate
affordable housing, including
Density Bonus and
Affordable Housing Overlay.
▪Encouraging affordable
housing developers to
integrate supportive housing
units, increasing project
competitiveness for Tax
Credits and other funding
sources.
▪Supporting the creation of
ADUs in all residential
districts.
HE-1.6 Universal
Design
HE-2.8 Equal
Housing and Special
Needs
HE-6.1 Fair Housing
HE-6.3 Housing for
Persons with Special
Needs
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-49
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
AD Special Needs Housing
Prioritize special needs housing
by allowing for reduced
processing times and streamlined
procedures for applicable
zoning/land use applications.
Include preferential handling of
special needs populations in
management plans and
regulatory agreements of funded
projects.
HE-2.7 Senior
Housing
HE-2.8 Equal
Housing and Special
Needs
HE-2.9 Public/Private
Partnerships
HE-3.3 Efficient
Development
Processing
Community
Development
Department
January 2023 to
January 2031
None
required
AE Rental Dispute Resolution
Program
Continue the administration of
the Rental Dispute Resolution
Program and consider revisions
as necessary to make the
program as effective as possible
in protecting both tenants’ and
landlords’ rights.
HE-6.6 Rental
Dispute Mediation
and Arbitration
Ordinance
Community
Services
Department
January 2023 to
January 2031
Program
fees
AF Rental Assistance for Persons
with Developmental
Challenges
Work with local and/or regional
partners to provide rental
assistance for persons with
developmental challenges.
Efforts will include the following:
▪Work with the California
Department of
Developmental Services local
Regional Center to identify
the housing needs specific to
developmentally challenged
persons residing in Los
Gatos and assist in
identifying available housing
that meets those needs.
▪Encourage qualifying
Regional Center clients
residing in Los Gatos to
apply for appropriate rental
assistance programs.
▪Identify outside funding
sources, such as regional or
State programs, that could
HE-2.7 Senior
Housing
HE-2.8 Equal
Housing and Special
Needs
HE-2.9 Public/Private
Partnerships
Community
Development
Department
Annually follow
up on a periodic
basis with
service
providers to
determine
outcomes for
referrals and
update referral
process and
timelines
accordingly
2023-2031
period
None
required
HCD Draft Initial Review 2023-2031 Housing Element
10-50 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
provide rental assistance for
developmentally challenged
persons living in Los Gatos.
▪Make referrals to non-profit
service providers with rental
assistance or rental voucher
programs such as West
Valley Community Services
and the Housing Authority of
Santa Clara County.
AG Supportive Services for the
Homeless
Continue to support community
and nonprofit organizations that
provide supportive services for
homeless persons in Los Gatos
in part by continuing to fund the
Town's annual grant and
disseminating opportunities for
other agency funding to West
Valley Community Services
(WVCS), in order to support its
Comprehensive Emergency
Assistance Program (CEAP).
HE-2.3 Mixed-Use
Development
HE-2.7 Equal
Housing and Special
Needs
Community
Development
Department
January 2023 to
January 2031
Town of
Los Gatos
AH Stabilize Rents
Study and implement
recommendations with regard to
the Town’s Rental Dispute
Mediation and Arbitration
Ordinance 2128 to help further
stabilize rents for long-term
residents.
HE-2.3 Mixed-Use
Development
HE-2.4 Rental
Housing
HE-6.6 Rental
Dispute Mediation
and Arbitration
Ordinance
Community
Development
Department
Complete study
by January 2024
and implement
Municipal Code
changes by
June 2024
AI Reduce Parking Standards
Initiate a study to determine
specific updates for the Municipal
Code to address the following:
▪Align parking requirements
with the preparation of
Objective Design Standards.
▪Reduce parking requirements
near transit.
▪Remove guest parking
requirements.
▪Allow parking to be
unbundled from residential
units.
3.1 Regulatory
Incentives for
Affordable Housing
2.7 Senior Housing
2.8 Equal Housing
and Special Needs
Community
Development
Department
Complete study
by January 2024
and implement
Municipal Code
changes by
June 2024
None
required
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-51
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
AJ Allow for 100 Percent
Affordable Residential
Development in Mixed-Use
General Plan Designations
Amend the General Plan and the
Municipal Code to allow for 100
percent affordable residential
development without the
requirement of commercial uses.
HE-3.1 Regulatory
Incentives for
Affordable Housing
Community
Development
Department
Implement
General Plan
and Municipal
Code changes
by June 2024
None
required
AK Housing Conditions Survey
Seek funding through the Below
Market Price Program funds, or
other funding sources, to conduct
a survey of housing conditions in
the Town. The survey shall
identify housing units in need of
rehabilitation or replacement.
HE-4.1 Property and
Housing Conditions
Community
Development
Department
January 2023 to
January 2031
Town
Affordable
Housing
Fund
AL SB 35 Process Improvements
Develop an SB 35 checklist and
written procedures for processing
SB 35 applications to ensure
efficient and complete application
processing.
HE-3.3 Efficient
Development
Processing
HE-3.1 Regulatory
Incentives for
Affordable Housing
Community
Development
Department
Implement by
December 2023
Staff Time
AM Low Barrier Navigation
Centers
Amend the Zoning Code
Definitions to include the
definition for “Low Barrier
Navigation Center” consistent
with State law. Allow at least two
mixed-use zoning districts to
permit low barrier navigation
centers as a by-right use.
HE-2.7 Equal
Housing and Special
Needs
Community
Development
Department
Implement by
December 2023
Staff Time
AN Fair Housing Law Education
Educate the community about
landlords and renters rights and
responsibilities under Fair
Housing law, needs and benefits
of affordable housing, and
available resources in the Town
by posting information on the
Town’s website, social media
posts and/or brochures,
distributing information through
the business licensing
recertification process, and
HE-6.4 Affordable
Housing Awareness
Community
Development
Department,
Finance
Department,
California
Department of
Developmental
Services
Resources
posted by end of
January 2023
Staff Time
HCD Draft Initial Review 2023-2031 Housing Element
10-52 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
posting fair housing posters in
Town Hall, the community center
and the library. The Town will
continue to work with and fund
local nonprofits, and to
collaborate with local homeless
service providers to provide
information on homeless needs
in the town.
AO Transit Oriented Development
As part of the comprehensive
Zoning Code update, establish
development standards for
transit-oriented development
located within existing transit
areas that promote sustainable
land use practices which reduce
vehicle trips and allow for mixed-
use developments as well as
stand-alone residential. In
addition, the Town shall provide
for CEQA streamlining consistent
with the provisions of SB 375.
HE-2.10 Policy Smart
Growth
Community
Development
Department
January 2023 to
January 2031
Staff Time
AP Preserve “At-Risk” Affordable
Housing Units
Continue to monitor affordable,
multi-family housing units in the
Town to ensure that they retain
their affordability status.
HE-4.3 Home
Affordability
Preservation
Community
Development
Department
January 2023 to
January 2031
None
required
AQ Rental Housing Conservation
Program
Continue to implement Section
29.20.155 of the Town Code that
addresses conversions of
residential use, specifically
Section 29.20.155(a)(2), which
requires that any proposed
conversion satisfy the housing
goals and policies as set forth in
the 2040 General Plan.
HE-2.4 Rental
Housing
HE-4.1 Property and
Housing Conditions
Community
Development
Department
January 2023 to
January 2031
None
required
AR CDBG and other Housing
Rehabilitation Programs
Continue to participate in the
County of Santa Clara
Community Development Block
Grant Joint Powers Authority to
facilitate participation in County
HE-4.1 Property and
Housing Conditions
HE-4.3 Home
Affordability
Preservation
Community
Development
Department
January 2023 to
January 2031
General
Fund
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-53
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
CDBG Housing Rehabilitation
programs by Town residents.
AS Countywide Home Repair
Programs
Continue to support countywide
programs (Habitat for Humanity
East Bay/Silicon Valley,
Rebuilding Together, Housing
Trust of Santa Clara County, etc.)
that provide assistance with
minor home repairs and
accessibility improvements for
lower income households,
including special needs
households.
Support annual funding requests
submitted by rehabilitation
agencies to the County of Santa
Clara, and provide local technical
assistance as needed to
nonprofits submitting funding
applications to the County and/or
applying for building permits
through the Town’s building
permit process.
Contribute funding from the
Town’s Below Market Price
monies to support these
programs. The Continue to
participate as a member of the
County of Santa Clara JPA.
Continue to provide staffing to
the County Technical Advisory
Committee (TAC), which reviews
annual applications for funding
and helps formulate funding
recommendations to the Board of
Supervisors.
HE-4.1 Property and
Housing Conditions
HE-6.3 Housing for
Persons with Special
Needs
Community
Development
Department;
County of
Santa Clara
January 2023 to
January 2031
None
required
AT Energy Conservation
Opportunities
Continue to enforce State of
California Title 24 requirements
for energy conservation.
HE-5.1 Green
Building
Community
Development
Department
Ongoing None
required
AU Residential Rehabilitation
Program
HE-4.1 Property and
Housing Conditions
HE-5.1 Green
Building
Community
Development
Department
January 2023 to
January 2031
Town
Affordable
Housing
Fund
HCD Draft Initial Review 2023-2031 Housing Element
10-54 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
Create a new program to assist
lower income homeowners,
including senior and disabled
households, with funding for
home repairs and improvements.
The program could incentivize
providing grants for the following
activities: accessibility
improvements; exterior or interior
home repair; repair of fencing
and/or landscaping; plumbing;
exterior painting; roof repair; and
similar activities.
AV Solar Energy
Continue to expedite solar panel
installation by requiring only
ministerial building permits.
HE-5.1 Green
Building
HE-5.2 Solar Energy
Community
Development
Department
Ongoing None
required
AW Town Housing Resources
Guide
Continue to provide a guide to
developments that include
affordable housing units as part
of the Housing Resources Guide
posted on the Town’s website,
and available at Town Hall,
Library, and other Town facilities.
Publicize available
warming/cooling centers as
provided by the Santa Clara
County of Office of Supportive
Housing during inclement
weather episodes.
HE-5.1 Green
Building
HE-6.4 Affordable
Housing Awareness
Community
Development
Department
Update list
annually
None
required
AX Santa Clara County Fair
Housing Consortium
Support the efforts of the Santa
Clara County Fair Housing
Consortium, as follows. Continue
to make referrals through Project
Sentinel and provide updated fair
housing information on the
Town’s website and at public
locations through the Town, such
as the Adult Recreation Center,
Library, Farmers Market and
public kiosks. Through an
ongoing partnership with Project
Sentinel, a member of the
Consortium and the Town’s
HE-5.2 Solar Energy
HE-6.3 Housing for
Persons with Special
Needs
Community
Development
Department
January 2023 to
January 2031
None
required
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-55
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
service administrator for the
Rental Dispute Resolution
Program, Town staff is able to
attend the Consortiums annual
Fair Housing Symposium,
receive training, and disseminate
fair housing information
(including how to contact
Consortium agencies for
assistance) to members of the
public who contact the Town
about a potential fair housing
related matter.
AY Senior Housing Resources
Provide regularly updated senior
housing resource materials at the
Adult Recreation Center, Library,
and Farmers Market.
HE-6.1 Fair Housing
HE-6.2 Financial
Assistance
HE-6.3 Housing for
Persons with Special
Needs
HE-6.4 Affordable
Housing Awareness
Community
Development
Department
Update
materials
annually
None
required
AZ Developmental Challenges
Continue to work with the local
California Department of
Developmental Services
Regional Center to proactively
inform families within Los Gatos
about housing and services
available for persons with
developmental challenges, to
include an informational
brochure, information on the
Town’s website, and housing-
related training workshops for
individuals and families.
HE-6.1 Fair Housing
HE-6.3 Housing for
Persons with Special
Needs
HE-6.4 Affordable
Housing Awareness
Community
Development
Department,
California
Department of
Developmental
Services
Update
materials
annually
None
required
BA Use a Variety of
Communication Methods
Broadcast information about
available housing resources
through a variety of
communication methods across
media, technological nonprofit
organizations and traditional in
person outreach methods, such
as the Farmers Market, Library,
and community center, with a
particular focus on reaching the
very low- and low-income
demographic and those who may
HE-6.1 Fair Housing
HE-6.4 Affordable
Housing Awareness
Community
Development
Department,
California
Department of
Developmental
Services
Quarterly
January 2023 to
January 2031
None
required
HCD Draft Initial Review 2023-2031 Housing Element
10-56 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
not have access to online
resources.
BB Educate Single-Family
Property Owners Regarding In-
Fill Housing Options
Create and distribute educational
materials to include information
about the process to construct
ADU’s, multi-generational
housing, and options available
with Senate Bill SB 9.
HE-1.5 Variety of
Housing Choices
HE-1.7 Infill
Opportunities in
Single-Family
Neighborhoods
HE-6.1 Fair Housing
HE-6.4 Affordable
Housing Awareness
Community
Development
Department,
California
Department of
Developmental
Services
Quarterly
January 2023 to
January 2031
None
required
BC Zoning Text Amendments for
Special Needs Housing
Pursuant to recent changes in
State law, the Town’s Municipal
Code may be modified to better
facilitate the provision of a variety
of housing types. These Code
revisions include:
▪Amend parking standards for
emergency shelters from a
ratio based on the size of the
structure to a ratio based on
the number of shelter staff
(per AB 139).
▪Eliminate current spacing
requirements between
shelters and residentially
zoned properties and
schools.
▪Develop and adopt by- right
processing procedures for
Low Barrier Navigation
Centers (per AB 101).
▪Allow small employee
housing (six or fewer) in all
zone districts where single-
family residential is
permitted.
HE-2.7 Equal
Housing and Special
Needs
Community
Development
Department
January 2024 None
required
BD Affordable Development on
Religious Sites
Pursue and expand development
opportunities by allowing
affordable housing on religious
sites per AB 2244.
HE-2.12 Housing on
Land Owned by
Religious Institutions
Community
Development
Department
Ongoing None
required
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-57
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
BE Community Education on
Housing Needs
Provide education on the
problems and needs of affordable
housing as a means of changing
negative attitudes towards the
provision of affordable housing.
HE-6.4 Affordable
Housing Awareness
Community
Development
Department
Ongoing None
required
BF Zoning Code Amendments
The Town will initiate a program
to revise the Zoning Code to
ensure adequate sites are
available to accommodate the
identified sites in the Sites
Inventory.
Amend the Zoning Code to
include a Housing Element
Overlay Zone (HEOZ) to apply to
the sites included in the Site
Inventory to modify the
development standards (i.e.,
density, lot coverage, FAR,
height) on those sites.
Amend the Affordable Housing
Overlay Zone to increase the
maximum allowable density from
20 dwelling units per acre to 40
dwelling units per acre.
Clarify the text of the non-
residential zones regarding
housing.
Rezone the Caltrans ROW – Site
E3 to allow residential
development.
HE-1.1 Adequate
Sites
HE-1.2 Multi-family
Housing Densities
HE-2.11 Smart
Growth
Community
Development
Department
If the Housing
Element is found
in compliance by
January 31,
2023, then
rezonings will be
completed within
3 years and 120
days. If it is not
found in
compliance,
then the
rezonings will be
completed within
1 year of
January 1, 2024.
General
Plan
Update
Fund
BG General Plan Amendment
Amend the General Plan to
establish new maximum densities
for the High Residential, Medium
Density Residential, Low Density
Residential, Mixed-Use,
Neighborhood Commercial, and
Central Business District land
use designations to provide for
the development of housing for
the sites in the Site Inventory.
See Program BF.
HE-1.1 Adequate
Sites
HE-1.2 Multi-family
Housing Densities
HE-2.11 Smart
Growth
Community
Development
Department
If the Housing
Element is found
in compliance by
January 31,
2023, then
rezonings will be
completed within
3 years and 120
days. If it is not
found in
compliance,
then the
rezonings will be
General
Plan
Update
Fund
HCD Draft Initial Review 2023-2031 Housing Element
10-58 HCD Draft Initial Review 2023-2031 Housing Element October 2022
Programs Implements Which
Policy(ies)
Responsible
Supporting
Department(s)
Time Frame Funding
Source
completed within
1 year of
January 1, 2024
BH Provide Adequate Sites for
Lower Income Households on
Nonvacant and Vacant Sites
Previously Identified
Rezone the following sites to
allow development by right
pursuant to Government Code
section 65583.2(i) when 20
percent or more of the units are
affordable to lower income
households as identified in
Appendix I to accommodate the
lower income RHNA for sites that
were previously identified in past
housing elements:
Parcel: 424-08-074;
Parcel 424-08-057; and
Parcel 424-08-21.
HE-1.1 Adequate
Sites
Community
Development
Department
Sites rezoned
no more than
three years from
the beginning of
the planning
period.
General
Plan
Update
Fund
10.Housing Element
10.7 Glossary and Acronyms
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-59
A
Accessible. The ability to accommodate everyone
regardless of ability or pre-existing condition.
Accessory Dwelling Unit (ADU). An accessory
dwelling unit is a detached or attached dwelling unit.
It shall include permanent provisions for living,
sleeping, eating, cooking, and sanitation and is
generally smaller and located on the same parcel as
a proposed or exiting primary dwelling. An accessory
dwelling unit also includes efficiency units and
manufactured homes.
Acres (Gross). An acre is a measurement of land
area equal to 43,560 square feet. The gross acreage
of a lot includes all land within the boundaries of the
lot (including, but not limited to, easements). The
gross acreage is defined as the total area, measured
on a horizontal plane, and is the measure used for
determination of density and intensity calculations.
Acres (Net). A reduced lot size based average lot
slope or other factors and used for the purpose of
calculating the maximum allowed floor area or
density.
Affirmative Furthering Fair Housing. Taking
meaningful actions, in addition to combating
discrimination, that overcome patterns of segregation
and foster inclusive communities free from barriers
that restrict access to opportunity based on protected
characteristics. Specifically, affirmatively furthering
fair housing means taking meaningful actions that,
taken together, address significant disparities in
housing needs and in access to opportunity,
replacing segregated living patterns with truly
integrated and balanced living patterns, transforming
racially and ethnically concentrated areas of poverty
into areas of opportunity, and fostering and
maintaining compliance with civil rights and fair
housing laws. The duty to affirmatively further fair
housing extends to all of a public agency’s activities
and programs relating to housing and community
development. (Gov. Code, § 8899.50, subd. (a)(1).)”
Affordable Housing. Under State and Federal
statutes, affordable housing is housing which costs
no more than 30 percent of gross household income.
Housing costs include rent or mortgage payments,
utilities, taxes, insurance, homeowner association
fees, and other related costs.
Americans with Disabilities Act (ADA). A civil
rights law that prohibits discrimination against
individuals with disabilities in all areas of public life,
including jobs, schools, transportation, and all public
and private places that are open to the general
public.
Area Median Income (AMI). A key metric in
affordable housing. Area median income is defined
as the midpoint of a specific area’s income
distribution and is calculated on an annual basis by
the Department of Housing and Urban Development.
B
Below Market Program (BMP). The BMP Program
implements the Town of Los Gatos’ inclusionary
zoning ordinance, which requires that a portion of the
new residential construction in Los Gatos be
dedicated to affordable housing.
C
California Environmental Quality Act (CEQA).
State law that requires State and local agencies to
evaluate and disclose the significant environmental
impacts of discretionary actions and to avoid or
mitigate those impacts, if feasible.
Commercial. Retail, service, and entertainment
uses (e.g., shopping centers, smaller stores,
restaurants).
D
Density. Residential developments are regulated by
an allowed density range (minimum and maximum)
measured in “dwelling units per acre.” Residential
HCD Draft Initial Review 2023-2031 Housing Element
10-60 HCD Draft Initial Review 2023-2031 Housing Element October 2022
density is calculated by dividing the number of
housings units on the site (excluding accessory units)
by the gross lot area.
Development. The subdivision of land; construction
or alteration of structures, roads, utilities, and other
facilities; installation of septic systems; grading
activities; depositing of refuse; disposal of any
material; dredging or mineral extraction, debris or fill
materials; and the clearing of natural vegetation with
the exception of agricultural activities. This does not
include routine repair and maintenance activities.
Dwelling Unit. A room or group of rooms (including
sleeping, eating, cooking, and sanitation facilities, but
not more than one kitchen) that constitutes an
independent housekeeping unit, occupied or intended
for occupancy by one household on a long-term
basis.
E
Environmental Justice. The fair treatment of
people of all races, cultures, incomes, political and
religious affiliation, and national origins with respect
to the development, adoption, implementation, and
enforcement of environmental laws, regulations, and
policies.
Equality. Is sameness; everyone gets the same
thing. Equality focuses on everyone getting the same
opportunity, but often ignores the realities of historic
exclusion and power differentials among whites and
other racialized groups.
Equity. Ensures that outcomes in the conditions of
well-being are improved for marginalized groups,
lifting outcomes for all. Equity is a measure of justice.
F
Federal Fair Housing Act of 1968. Prohibits
discrimination concerning the sale, rental, and
financing of housing based on race, color, religion,
national origin, - and was later amended to include
familial status and disability.
Fire Hazard Severity Zone. A mapped area that
designates zones, based on factors such as fuel,
slope, and fire weather, with varying degrees of fire
hazard (e.g., moderate, high, and very high).
Floor Area Ratio (FAR). Total building size is
regulated by a maximum FAR standard. FAR means
the gross floor area of a building or buildings on a
zoning plot divided by the area of such zoning plot.
Floor area means the entire enclosed area of all
floors that extend more than four (4) feet above the
existing or proposed grade, measured from the outer
face of exterior walls or in the case of shared walls
from the centerline. The maximum FAR standard
limits the overall size of development on a property.
G
Goal. A statement that describes, in general terms, a
desired future condition or “end” state. Goals
describe ideal future conditions for a topic and tend to
be very general and broad.
H
Housing Element Advisory Board. A Town
Council appointed advisory board for preparation of
the Housing Element.
I
Implementation Program. An action, activity, or
strategy to be taken by the Town to carry out an
adopted policy to achieve a specific goal or objective.
Infill Development. Development of vacant or
underutilized land (usually individual lots or leftover
properties) within areas that are already largely
developed.
Intensity. Developments are regulated by an
allowed intensity, measured by a maximum FAR.
Intensity is a measure of the extent to which a land
parcel is developed in conformity with the zoning
J
K
10. Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-61
L
Land Use Designation. A specific geographic
designation with associated land use or management
policies and regulations.
Lot Coverage. Lot coverage is the percentage of a
lot that is covered by all buildings compared to the
total area of the lot.
M
Missing Middle Housing. Missing middle housing is
a term used to describe a range of house-scale
buildings with multiple units that are compatible in
scale and form with detached single-family homes.
Common housing types include duplexes; triplexes;
fourplexes; courtyard apartments; cottage courts;
townhomes; triplex stacked (vertical); and live-work
spaces. Also referred to as “Small Multi-Unit
Housing”.
Mixed-Use Development. Development projects
where a variety of uses such as office, commercial,
institutional, and residential are combined in a single
building or on a single site in an integrated project.
These developments are regulated by both the
maximum residential density (units per acre) and
maximum FAR standard that incorporates both the
residential and non-residential building floor areas.
Multi-Family Residential. Residential buildings
containing units built one on top of another and those
built side-by-side which do not have a ground-to-roof
wall and/or have common facilities (i.e., attic,
basement, heating plant, plumbing, etc.). Accessory
dwelling units (ADUs) are not considered multi-family
residential.
N
O
Objective Design Standards. Objective standards
are defined under State law as “standards that
involve no personal or subjective judgement by a
public official and are uniformly verifiable by
reference to an external or uniform benchmark or
criteria available and knowable by both the
development applicant or proponent and the public
official prior to submittal “(California Government
Code, Section 65913.4).
P
Persons With Special Needs. Includes extremely
low-income households, seniors, overcrowded and
large-family households, the homeless population,
those in need of emergency shelter, youth aging out
of foster care, female-headed or single-parent
households, and persons with disabilities, including
developmental challenges.
Planning Commission. An appointed commission
responsible for conducting public hearings on the
General Plan and Zoning Code modifications,
considering the input of the public, and making
recommendations to the Town Council on these
matters.
Planned Development. The Planned Development
(PD) overlay zone provides alternative standards for
housing developments with a minimum of 40 percent
of the units affordable to households of very low, low,
or moderate income.
Policy. A statement that guides a specific course of
action for decision-makers to achieve a desired goal.
Q
R
Regional Housing Need Allocation (RHNA). A
State-mandated process to identify the total number
of housing units (by affordability level) that each
jurisdiction must accommodate in its Housing
Element.
S
Setback. The distance between a building and the
property line or other buildings.
Single-Family Residential. Land with detached
buildings with not more than one primary dwelling
HCD Draft Initial Review 2023-2031 Housing Element
10-62 HCD Draft Initial Review 2023-2031 Housing Element October 2022
unit for residential uses, such as single-family homes,
townhomes, and condominiums.
Specific Plan. A planning tool authorized by
Government Code Section 65450, et seq., for the
systematic implementation of the General Plan for a
defined portion of a community’s planning area. A
specific plan must specify in detail the land uses,
public and private facilities needed to support the
land uses, phasing of development, standards for the
conservation, development, and use of natural
resources, and a program of implementation
measures, including financing measures.
Small Multi-Unit Housing. Also known as “Missing
middle housing” is a term used to describe a range of
house-scale buildings with multiple units that are
compatible in scale and form with detached single-
family homes. Common housing types include
duplexes; triplexes; fourplexes; courtyard apartments;
cottage courts; townhomes; triplex stacked (vertical);
and live-work spaces.
T
Town Council. The political body which formulates
and implements policies in Los Gatos. It is the Town
Council, through its decision-making authority, that
affirms the policy direction and priorities contained
within this General Plan. The Town Council is
ultimately responsible for adoption of the General
Plan, as well as the regulations, capital improvement
programs, and financing mechanisms that implement
the General Plan.
U
V
Vacant Land. Land that is not actively used for any
purpose, including land that is not improved with
buildings or site facilities and is sizeable in area to
accommodate development.
W
Wildland/Urban Interface (WUI). Areas where
homes or other structures are built near or among
lands prone to wildland fire.
X
Y
Z
Zoning. The division of the Town into districts, and
the application of different regulations in each district.
Zoning District. A part of the community designated
by the local zoning ordinance for specific of land
uses, such as single-family residential or
neighborhood commercial uses. Only the primary
permitted land uses, their accessory uses, and any
conditional uses permitted in the zoning district may
be placed on the land in that part of the community.
Zoning Ordinance. The adopted zoning and
planning regulations of a town, city, or county that
establish development standards for each zone, such
as minimum lot size, maximum height of structures,
building setbacks, and yard size.
10.Housing Element
October 2022 HCD Draft Initial Review 2023-2031 Housing Element 10-63
List of Acronyms
AB Assembly Bill
ABAG Association of Bay Area Governments
ADA Americans with Disabilities Act
ADU Accessory dwelling unit
AFFH Affirmative Furthering Fair Housing
AHOZ Affordable Housing Overlay Zone
AMI Area Median Income
BMP Below Market Program
CBD Central Business District land use
designation
CC Community Commercial land use
designation
CD Community Design Element
CEQA California Environmental Quality Act
CMU Mixed-Use land use designation
CUP Conditional Use Permit
DFEH California Department of Fair
Employment in Housing
du/ac Dwelling units per acre
EIR Environmental Impact Report
FAR Floor area ratio
FFH Federal Fair Housing Act
HCD Department of Housing and Community
Development
HDR High Density Residential land use
designation
HDS&G Hillside Development Standards and
Guidelines
HEAB Housing Element Advisory Board
HR Hillside Residential land use designation
HUD Department of Housing and Urban
Development
LDR Low Density Residential land use
designation
LHP Landmark and Historic Preservation
Zone
LI Light Industrial land use designation
LID Low Impact Development
LU Land Use Element
MDR Medium Density Residential land use
designation
MTC Metropolitan Transportation
Commission
MU Mixed-Use land use designation
NFHA National Fair Housing Alliance
NF-SP North Forty Specific Plan
PD Planned Development
PS Public School Zone
RHNA Regional Housing Needs Allocation
RHND Regional Housing Needs Determination
RHM Mobile Home Residential
SB Senate Bill
WUI Wildland/Urban Interface
.
Affirmatively Furthering Fair Housing Report A
APPENDIX
Appendix A. AFFH Report
October 2022 Appendix A A-1
A.1 What is AFFH?
The State of California’s 2018 Assembly Bill (AB 686) requires that all public agencies in the state affirmatively
further fair housing (AFFH) beginning January 1, 2019. Public agencies receiving funding from the U.S.
Department of Housing and Urban Development (HUD) are also required to demonstrate their commitment to
AFFH. The Federal obligation stems from the fair housing component of the Federal Civil Rights Act mandating
Federal fund recipients to take “meaningful actions” to address segregation and related barriers to fair housing
choice.
AB 686 requires all public agencies to “administer programs and activities relating to housing and community
development in a manner that affirmatively furthers fair housing and take no action inconsistent with this
obligation.”1
AB 686 also makes changes to Housing Element Law to incorporate requirements to AFFH as part of the housing
element and General Plan to include an analysis of fair housing outreach and capacity, integration and
segregation, access to opportunity, disparate housing needs, and current fair housing practices.
Affirmatively Furthering Fair Housing
“Affirmatively furthering fair housing” means taking meaningful actions, in addition to
combating discrimination, that overcome patterns of segregation and foster inclusive communities
free from barriers that restrict access to opportunity based on protected characteristics.
Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken
together, address significant disparities in housing needs and in access to opportunity, replacing
segregated living patterns with truly integrated and balanced living patterns, transforming racially
and ethnically concentrated areas of poverty into areas of opportunity, and fostering and
maintaining compliance with civil rights and fair housing laws. The duty to affirmatively further fair
housing extends to all of a public agency’s activities and programs relating to housing and
community development. (Gov. Code, § 8899.50, subd.(a)(1).)”
Source: California Department of Housing and Community Development Guidance, 2021, page 14.
A.2 History of Segregation in the Region
The United States’ oldest cities have a history of mandating segregated living patterns and Northern California
cities are no exception. ABAG, in its recent Fair Housing Equity Assessment, attributes segregation in the Bay
Area to historically discriminatory practices, highlighting redlining and discriminatory mortgage approvals as well
as “structural inequities” in society, and “self-segregation” (i.e., preferences to live near similar people).
Researcher Richard Rothstein’s 2017 book The Color of Law: A Forgotten History of How Our Government
Segregated America chronicles how the public sector contributed to the segregation that exists today. Rothstein
highlights several significant developments in the Bay Area region that played a large role in where the region’s
non-White residents settled.
In 1955, builders began developing workforce housing for the Ford Corporation’s plant in the Bay Area, including
Santa Clara County. Initially the units were segregated as no one would sell to the local Black/African American
workers. The American Friends Service Committee (AFSC) worked to find builders who would build integrated
subdivisions. Unfortunately, after four purchased plots were subsequently rezoned to prevent integrated housing,
1 California Department of Housing and Community Development Guidance, 2021, page 9.
HCD Draft Initial Review 2023-2031 Housing Element
A-2 Appendix A October 2022
the original builder quit. After multiple additional iterations, Black/African American workers had “become so
discouraged about finding housing opportunities” that they began carpooling from outside cities such as
Richmond2.
A 2018 Berkeley publication titled, Racial Segregation in the San Francisco Bay Area, describes Los Gatos
among the “most segregated, heavily white cities in the county” with Santa Clara County containing “no truly
integrated city”3. The study also delved into the history of segregation, highlighting 1960s-era laws and practices
connected to urban renewal projects that displaced established communities of color. This was coupled with the
building of transportation infrastructure that resulted in a net loss of affordable housing due to a lack of one-for-
one replacement. Figure A-1 through Figure A-7 illustrates the demographic distribution within the Santa Clara
County.
2 Source: book The Color of Law: A Forgotten History of How Our Government Segregated America by Richard Rothstein, p 121.
3 Racial Segregation in the San Francisco Bay Area, Part 1 | Othering & Belonging Institute (berkeley.edu)
Appendix A. AFFH Report
October 2022 Appendix A A-3
Figure A-1 Percent Non-White Population by Census Block Groups, 2018
Source: California Department of Housing and Community Development AFFH Data Viewer
HCD Draft Initial Review 2023-2031 Housing Element
A-4 Appendix A October 2022
Figure A-2 White Majority Census Tracts
Source: California Department of Housing and Community Development AFFH Data Viewer
Appendix A. AFFH Report
October 2022 Appendix A A-5
Figure A-3 Asian Majority Census Tracts
Source: California Department of Housing and Community Development AFFH Data Viewer
HCD Draft Initial Review 2023-2031 Housing Element
A-6 Appendix A October 2022
Figure A-4 Hispanic Majority Census Tracts
Source: California Department of Housing and Community Development AFFH Data Viewer
Appendix A. AFFH Report
October 2022 Appendix A A-7
Figure A-5 Neighborhood Segregation by Census Tract, 2019
Source: California Department of Housing and Community Development AFFH Data Viewer
HCD Draft Initial Review 2023-2031 Housing Element
A-8 Appendix A October 2022
Figure A-6 Diversity Index by Block Group, 2010
Source: California Department of Housing and Community Development AFFH Data Viewer
Appendix A. AFFH Report
October 2022 Appendix A A-9
Figure A-7 Diversity Index by Block Group, 2018
Source: California Department of Housing and Community Development AFFH Data Viewer
HCD Draft Initial Review 2023-2031 Housing Element
A-10 Appendix A October 2022
History of Segregation in the Region
This history of segregation in the region is important not only to understand how residential
settlement patterns came about—but, more importantly, to explain differences in housing
opportunity among residents today. In sum, not all residents had the ability to build housing
wealth or achieve economic opportunity. This historically unequal playing field in part determines
why residents have different housing needs today.
In addition to historical discriminatory practices that embedded segregation into living patterns throughout the Bay
Area, it’s also necessary to recognize the historical impacts of colonization and genocide on Indigenous
populations and how the effects of those atrocities are still being felt today. The original inhabitants of present-
day San Mateo County are the Ramaytush Ohlone, who have “…lived on the San Francisco Peninsula for
thousands of years and continue to live here as respectful stewards of the land”4. However, “[d]ue to the
devastating policies and practices of a succession of explorers, missionaries, settlers, and various levels of
government over the centuries since European expansion, the Ramaytush Ohlone lost the vast majority of their
population as well as their land”5. The lasting influence of these policies and practices have contributed directly to
the disparate housing and economic outcomes collectively experienced by Native populations today6.
The timeline of major Federal Acts and court decisions related to fair housing choice and zoning and land use
appears on the following page.
As shown in the timeline, exclusive zoning practices were common in the early 1900s. Courts struck down only
the most discriminatory and allowed those that would be considered today to have a “disparate impact” on
classes protected by the Fair Housing Act. For example, the 1926 case Village of Euclid v. Amber Realty Co.
(272 U.S. 365) supported the segregation of residential, business, and industrial uses, justifying separation by
characterizing apartment buildings as “mere parasite(s)” with the potential to “utterly destroy” the character and
desirability of neighborhoods. At that time, multifamily apartments were the only housing options for people of
color, including immigrants.
The Federal Fair Housing Act was not enacted until nearly 60 years after the first racial Zoning Ordinances
appeared in U.S. cities. This coincided with a shift away from Federal control over low-income housing toward
locally-tailored approaches (block grants) and market-oriented choice (Section 8 subsidies), the latter of which is
only effective when adequate affordable rental units are available.
4 https://www.smcoe.org/for-communities/indigenous-people-of-san-mateo-county.html
5 https://www.smcoe.org/for-communities/indigenous-people-of-san-mateo-county.html
6 https://www.americanprogress.org/article/systemic-inequality-displacement-exclusion-segregation/
Appendix A. AFFH Report
October 2022 Appendix A A-11
Major Public and Legal Actions that Influence Fair Access to Housing
A.3 Report Content and Organization
This Fair Housing Assessment follows the April 2021 State of California State Guidance for AFFH.
Section I. Fair Housing Enforcement and Outreach Capacity reviews lawsuits/enforcement
actions/complaints against the jurisdiction; compliance with State fair housing laws and regulations; and
jurisdictional capacity to conduct fair housing outreach and education.
Section II. Integration and Segregation identifies areas of concentrated segregation, degrees of segregation,
and the groups that experience the highest levels of segregation
Section III. Access to Opportunity examines differences in access to education, economic development, and
healthy environments.
Section IV. Disparate Housing Needs identifies which groups have disproportionate housing needs including
displacement risk.
Section V. Contributing Factors and Fair Housing Action Plan identifies the primary factors contributing to
fair housing challenges and the Plan for taking meaningful actions to improve access to housing and economic
opportunity.
Appendices
▪ Map and Data packet, including Fair Housing Organizations in Santa Clara County—mission, services,
and contact information
HCD Draft Initial Review 2023-2031 Housing Element
A-12 Appendix A October 2022
▪ State Fair Housing Laws and Regulations—summary of key State laws and regulations related to
mitigating housing discrimination and expanding housing choice
A.4 Primary Findings
This section summarizes the primary findings from the Fair Housing Assessment for Los Gatos including the
following sections: fair housing enforcement and outreach capacity, integration and segregation, access to
opportunity, disparate housing needs, and contributing factors and the Town’s Fair Housing Action Plan.
▪ Population growth trends in Los Gatos are significantly lower than the county and regional index rates.
The Town has grown 15 percent since 1990, while Santa Clara County grew by 31 percent.
▪ Los Gatos diverges from the county and region overall in racial composition with more than double the
county share of non-Hispanic White population (72 percent versus 32 percent for Santa Clara County).
Yet Los Gatos’ residents have grown more racially diverse since 2000 with the non-Hispanic white
population declining by 14 percentage points and Asian residents increasing in population from eight
percent to 15 percent in 2019.
▪ Conversely, the types of households in Los Gatos mirror the county and are similar to the Bay Area with 58
percent married couples (57 percent in Santa Clara County and 51 percent in the Bay Area). Household
size is in line with the county, except for five or more person households, for which Los Gatos has a
smaller share.
▪ Los Gatos has a higher share of high-income earners (greater than 100 percent AMI) than the county and
Bay Area (65 percent versus 55 percent and 52 percent respectively). Accounting for race and ethnicity,
Asian households are much more likely to comprise high income earners (72 percent), especially when
compared to Black/African American and Hispanic households (50 percent and 46 percent, respectively).
▪ In 2015, the income segregation in Los Gatos between lower-income residents and other residents was
higher than the average value for Bay Area jurisdictions. Segregation also exists among racial groups, yet
is slowly declining.
▪ Poverty rates are minimal but do vary across races and ethnicities with Hispanic residents experiencing
the highest poverty rate (although still a very low six percent) and Black/African Americans the lowest (0.7
percent).
▪ The job to household ratio for Los Gatos tracks closely with Bay Area and is lower than Santa Clara
County’s, indicating that Los Gatos is less of a commuter Town than surrounding jurisdictions with much
higher job to household ratios. This differs, however, by wage, with jobs to household ratios much higher
for low wage workers who cannot afford to live in the Town. Los Gatos has twice as many jobs as
households for low wage jobs.
▪ Los Gatos’ housing opportunities are limited by pricing, and both rental and home values are higher than
the county median. Eighty-three percent of houses are valued at more than one million dollars; Zillow
reports Los Gatos’ market average value at more than three million dollars. The average value of homes
in Los Gatos is 63 percent higher than the County’s 1.3-million-dollar average value. Sixty-three percent of
rentals charge 2,000 dollars or more a month, compared to 56 percent in Santa Clara County. Los Gatos
does not have any public housing and only a small portion of the Town contains any Housing Choice
Voucher usage, a minimal 0-5 percent.
▪ Nearly three-quarters of the Town’s housing are single-family units.
Appendix A. AFFH Report
October 2022 Appendix A A-13
▪ Housing cost burden in Los Gatos is lower than nearby cities but differs by race and ethnicity—and by
tenure (renters/owners). Asian households experience the lowest rates of cost burden (30 percent) in the
Town, followed by non-Hispanic White households (31 percent). This is followed by Black/African
American household (34 percent) and Hispanic households (37 percent). Other/Multiple Race households
(45 percent) are the most likely to be cost burdened (45 percent). Owners experience cost burden at a
lower rate (28 percent) than renters (42 percent).
▪ Mortgage denial rates vary little by race and ethnicity, with 55 percent to 65 percent of loans originated.
Other than Asian applicants, however, applications from non-White applicants are very low in numbers.
▪ Saratoga Elementary School, Los Gatos Union Elementary School, and Los Gatos-Saratoga Union High
School Districts serve the majority of Los Gatos residents. The most up-to-date performance rankings
show that the Los Gatos-Saratoga high school with very few Black/African American or Native American
students. Asian students experienced higher educational outcomes compared to other students, scoring
93.8 percent in a 2019 College/Career Indicator metric. White and Hispanic students scored 71 percent
and 64.6 percent, respectively.
A.5 Contributing Factors and Fair Housing Issues
The disparities in housing choice and access to opportunity discussed above stem from historical actions in the
broader region, socioeconomic factors that have limited employment and income growth among non-White and
Hispanic residents, and a shortage of housing units built to accommodate growth.
Fair Housing Issue
Los Gatos’ very low production of affordable and market rate housing limits housing choices of all
but the highest income households.
Contributing factors:
▪ Since 2010, Los Gatos added 2,000 residents while only building 342 housing units. This lack of
production has exacerbated an already tight housing market.
▪ The housing that was added in Los Gatos between 2015 and 2019 was largely priced for above moderate-
income households. Only 1.5 percent of housing permits approved were for low- or very- low-income
housing.
Fair Housing Issue
Los Gatos’ lack of affordable housing has a disproportionate impact on low- and moderate-income
households who are more likely to be households of color. As such, Los Gatos lacks racial and
ethnic diversity relative to the county overall.
Contributing factors:
▪ Black or African American and Hispanic residents typically work lower wage jobs, stemming from historical
employment discrimination and lack of access to quality educational environments. These jobs do not
support the Town’s very high housing costs.
HCD Draft Initial Review 2023-2031 Housing Element
A-14 Appendix A October 2022
▪ Low wage jobs are necessary to support higher wage industries. Los Gatos’ employment growth has not
been adequately supported by affordable housing development. As such, there are twice as many low
wage jobs as residents in Los Gatos who work those jobs.
Fair Housing Issue
Los Gatos’ households are segregated by income, and income segregation is higher in the Town
than in other Bay Area jurisdictions.
Contributing factors:
▪ Lack of affordable housing overall.
▪ Segregation of the limited affordable housing that does exist into the north central portion of the Town.
Fair Housing Issue
Los Gatos feeds to high performing schools, yet, except for Asian students, students of color
cannot take advantage of these learning opportunities because they cannot afford to live in Los
Gatos.
Contributing factors:
▪ Lack of affordable housing overall.
A.6 Fair Housing Enforcement and Outreach Capacity
This section discusses fair housing legal cases and inquiries, fair housing protections and enforcement, and
outreach capacity.
Fair housing legal cases and inquiries. California fair housing law extends beyond the protections in the Federal
Fair Housing Act (FHA). In addition to FHA protected classes—race, color, ancestry/national origin, religion,
disability, sex, and familial status—California law offers protections for age, sexual orientation, gender identity or
expression, genetic information, marital status, military or veteran status, and source of income (including Federal
housing assistance vouchers).
The California Department of Fair Employment in Housing (DFEH) was established in 1980 and is now the largest
civil rights agency in the United States. According to their website, DFEH’s mission is, “to protect the people of
California from unlawful discrimination in employment, housing and public accommodations (businesses) and
from hate violence and human trafficking in accordance with the Fair Employment and Housing Act (FEHA),
Unruh Civil Rights Act, Disabled Persons Act, and Ralph Civil Rights Act”7.
DFEH receives, evaluates, and investigates fair housing complaints. DFEH plays a particularly significant role in
investigating fair housing complaints against protected classes that are not included in Federal legislation and,
therefore, not investigated by HUD. DFEH’s website provides detailed instructions for filing a complaint, the
7 https://www.dfeh.ca.gov/aboutdfeh/
Appendix A. AFFH Report
October 2022 Appendix A A-15
complaint process, appealing a decision, and other frequently asked questions8. Fair housing complaints can
also be submitted to HUD for investigation.
Additionally, Santa Clara County has a number of local resource and enforcement organizations:
▪ Project Sentinel: Assists with housing discrimination, mortgage foreclosures, rental issues, and more.
▪ Housing and Economic Rights Advocates (HERA) provides legal and advocacy for vulnerable Californians
facing discrimination and economic abuses.
▪ Bay Area Legal Aid engages in broad advocacy focused on helping low-income Bay Area residents lead
stable lives, including housing stability.
▪ The Law Foundation of Silicon Valley provides legal advocacy for social change with a focus on finding
stable homes for low-income residents.
▪ Senior Adults Legal Assistance is a law office dedicated to supporting elder residents obtain independent
living.
From 2013 to 2021, 391 fair housing complaints in Santa Clara County were filed with the U.S. Department of
Housing and Urban Development (HUD) or Fair Housing Advocates of Northern California (FHANC). Most of the
county’s valid complaints cited disability status as the bias. Of these complaints, 69 percent were considered
valid and proceeded to actionable responses. Los Gatos had eight total complaints.
Nationally, the National Fair Housing Alliance (NFHA) reported a “negligible” decrease in the number of
complaints filed between 2019 and 2020. The primary bases for complaints nationally of disability (55 percent)
were represented in Santa Clara County at a much lower rate (16 percent). Familial status represented eight
percent of complaints nationally, similar to the six percent of cases in the county. Figure A-8 and Figure A-9 show
the share of population by disability status within Santa Clara County and the distribution by census tract,
respectively.
NFHA identifies three significant trends in 2020 that are relevant for this AFFH:
▪ First, fair lending cases referred to the Department of Justice from Federal banking regulators has been
declining, indicating that State and local government entities may want to play a larger role in examining
fair lending barriers to homeownership.
8 https://www.dfeh.ca.gov/complaintprocess/
HCD Draft Initial Review 2023-2031 Housing Element
A-16 Appendix A October 2022
Figure A-8 Share of Population by Disability Status, 2019
Source: ABAG Housing Needs Data Workbook
Appendix A. AFFH Report
October 2022 Appendix A A-17
Figure A-9 Percent of Population with a Disability by Census Tract, 2019
Source: California Department of Housing and Community Development AFFH Data Viewer
HCD Draft Initial Review 2023-2031 Housing Element
A-18 Appendix A October 2022
▪ Second, NFHA identified a significant increase in the number of complaints of harassment - 1,071
complaints in 2020 compared to 761 in 2019.
Appendix A. AFFH Report
October 2022 Appendix A A-19
▪ Finally, NFHA found that 73 percent of all fair housing complaints in 2020 were processed by private fair
housing organizations, rather than State, local, and Federal government agencies—reinforcing the need
for local, active fair housing organizations and increased funding for such organizations9.
Outreach and capacity. Santa Clara County, including Los Gatos, has a number of organizations dedicated to
assisting residents with legal services related to housing discrimination and general housing disputes. These
organizations are listed in Figure I-1 of the map and data appendix.
The Town also maintains a resource guide that highlights service providers across multiple categories focused on
housing and quality of life for underserved members of the community10. Additionally, the Town provides links
and email addresses for citizens to participate in the ongoing Housing Element Update process, including links to
the agendas and staff reports for the Housing Element Advisory Board (HEAB) meetings.
Finally, the Town has a strong statement about inclusivity and directly addresses hate speech on its website11.
Compliance with State law. Los Gatos is compliant with the following State laws that promote fair and affordable
housing. The Town has not been alleged or found in violation of the following:
▪ Housing Accountability Act (Gov. Code. Section 65589.5) requiring adoption of a Housing Element and
compliance with RHNA allocations;
▪ No Net Loss Law (Gov. Code Section 65863) requiring that adequate sites be maintained to
accommodate unmet RHNA allocations;
▪ Least Cost Zoning Law (Gov. Code. Section 65913.1);
▪ Excessive Subdivision Standards Law (Gov. Code. Section 65913.2);
▪ Limits on Growth Controls Law (Gov. Code. Section 65589.5).
Housing specific policies enacted locally.
▪ Los Gatos offers a density bonus program to comply with State law.
▪ It also has an affordable housing overlay zone; however, that zone applies to one property only.
▪ The Town allows relative diverse type of housing in residential zones. However, minimum lot area for
duplexes is quite generous (8,000 square feet). The Town could add flexibility for affordable duplexes—
particularly in areas near and within downtown.
▪ The Town requires that development of Accessory Dwelling Units under Town incentive programs be
affordable, and deed restricted to 80 percent AMI households.
▪ The Town’s Below Market Price program requirements apply to developments of five units and more and
require between 10 percent and 20 percent of units to be affordable to low- and moderate-income
households. In-lieu fees are only allowed in limited circumstances, which prioritizes unit development.
9 https://nationalfairhousing.org/2021/07/29/annual-fair-housing-report-shows-increase-in-housing-harassment/
10 Los-Gatos-Housing-Resources-Guide (losgatosca.gov)
11 https://www.losgatosca.gov/2604/Becoming-an-Inclusive-Community
HCD Draft Initial Review 2023-2031 Housing Element
A-20 Appendix A October 2022
Publicly-Assisted Housing. According to the California Department of Housing and Community Development
AFFH Data Viewer (HCD data viewer), Los Gatos does not have any public housing buildings. Additionally, only
a small portion of Los Gatos contains any Housing Choice Voucher usage, a minimal zero to five percent.
A.7 Integration and Segregation
This section discusses integration and segregation of the population by protected classes including race and
ethnicity, disability status, familial status, and income status. The section concludes with an analysis of racially
and ethnically concentrated areas of poverty and affluence.
Integration and Segregation
“Integration generally means a condition in which there is not a high concentration of persons of
a particular race, color, religion, sex, familial status, national origin, or having a disability or a
particular type of disability when compared to a broader geographic area.
Segregation generally means a condition in which there is a high concentration of persons of a
particular race, color, religion, sex, familial status, national origin, or having a disability or a type of
disability in a particular geographic area when compared to a broader geographic area.”
Race and ethnicity. Los Gatos differs from the county and Bay Area overall for its relatively high proportion of
residents identifying as non-Hispanic White (72 percent in Los Gatos compared to 32 percent in Santa Clara
County) and small Hispanic population (eight percent in Los Gatos and 25 percent in the county).
▪ Los Gatos’ proportion of Black/African American and Other and mixed-race residents is less proportional to
the County and the Bay Area overall (Figure A-10).
▪ Los Gatos’ residents have grown more racially diverse since 2000 largely due to growth in Asian and
Hispanic residents (Figure B-4).
▪ Older residents are less racially diverse than other age groups, with 87 percent of the population older than
65 years identifying as White compared to 77 percent of those aged 18 to 24 and 75 percent of children
less than 18 years old. The main shift is the inclusion of more diverse populations in younger age groups,
especially among Asian/API and Other/Multiple race residents (Figure B-3).
▪ Poverty rates are very low for all residents including residents of color. Black/African American have the
lowest poverty rate at less than 1 percent. The highest poverty rate was 6.1 percent among Hispanic
residents (Figure B-13).
Appendix A. AFFH Report
October 2022 Appendix A A-21
Figure A-10 Population by Race
Source: ABAG Housing Needs Data Workbook
15%
37%27%
6%
72%32%39%
4%
4%5%
8%
25%24%
0.0%
10.0%
20.0%
30.0%
40.0%
50.0%
60.0%
70.0%
80.0%
90.0%
100.0%
Los Gatos Santa Clara County Bay AreaPercent of PopulationHispanic or Latinx
Other Race or Multiple Races, Non-Hispanic
White, Non-Hispanic
Black or African American, Non-Hispanic
Asian / API, Non-Hispanic
American Indian or Alaska Native, Non-Hispanic
HCD Draft Initial Review 2023-2031 Housing Element
A-22 Appendix A October 2022
Geospatially, almost all census tracts in Los Gatos have a predominantly White population (Figure A-2 above).
Compared with neighboring Monte Sereno, Los Gatos has a more varied neighborhood composition map and a
more even dispersion of residents of varied races and ethnicities, see Figure A-5 above. Overall, the Town has
low to moderate diversity (Figure A-6 and Figure A-7 above). The Town’s diversity index has improved since
2010 due to changes in racial and ethnic diversity in the northern and eastern portions of Town.
The Association of Bay Area Governments (ABAG), working with UC Merced, created a 2021 report on
segregation in Los Gatos that measured racial and income segregation within the community. This report, in its
entirety can be found in Appendix G. That report utilized several common measures of segregation:
▪ The Dissimilarity Index, or DI, is a common tool that measures segregation in a community. DI is an index
that measures the degree to which two distinct groups are evenly distributed across a geographic area. DI
represents the percentage of a group’s population that would have to move for each area in the county to
have the same percentage of that group as the county overall. DI values range from zero to 100—where
zero is perfect integration and 100 is complete segregation. Dissimilarity index values between zero and
39 generally indicate low segregation, values between 40 and 54 generally indicate moderate segregation,
and values between 55 and 100 generally indicate a high level of segregation.
▪ The isolation index is interpreted as the probability that a randomly drawn minority resident shares an area
with a member of the same minority, it ranges from zero to 100 and higher values of isolation tend to
indicate higher levels of segregation.
ABAG’s assessed measures of segregation above highlighted White residents as the most segregated in Los
Gatos. White residents are more likely than any other racial group to live in a neighborhood where they are
unlikely to come into contact with other racial groups. However, White residents are becoming less isolated over
time—and segregation in Los Gatos is decreasing.
Segregation by income increased between 2010 and 2015. In 2015, the income segregation in Los Gatos
between lower-income residents and other residents was higher than the average value for Bay Area jurisdictions.
Disability status. The share of the population living with at least one disability is nine percent in Los Gatos
compared to eight percent in Santa Clara County. Roughly a third of census tracts in Los Gatos contain 10
percent to 20 percent of persons with a disability, higher than most of the surrounding jurisdictions (Figure A-9
above).
Familial status. Familial status can indicate specific housing needs and preferences. A larger number of non-
family or single person households indicates a higher share of seniors living alone, young adults living alone or
with roommates, and unmarried partners. Higher shares of nonfamily households indicate an increased need for
one- and two-bedroom units.
Los Gatos’ households are as likely to be three to four person households (34 percent) as two person households
(35 percent). Compared to the county and Bay Area overall, Los Gatos mirrors the share of one person
households (26 percent compared to 20 percent in the county and 25 percent for the Bay Area). Married couple
households were the majority household type (58 percent) and 31 percent of all households have at least one
child under the age of 18. The share of single persons and female-headed households mirror the makeup in the
Bay Area.
The Town has no concentrations of adults living alone, suggesting that access to in-home services and care for
single, older adults is less critical for Los Gatos than some surrounding communities within the county. However,
the Town’s age distribution has shifted upwards since 2000 (Figure B-2) and these accommodations may grow in
demand if older adults, 55 and older, in Los Gatos age in place.
Appendix A. AFFH Report
October 2022 Appendix A A-23
Los Gatos’ married couples overwhelmingly own housing: seventy-seven percent of married couple families in the
Town own their homes.
Renters are more likely to occupy studios and one- and two-bedroom units than owners (Figure B-36), and
owners are more likely to be occupying three to four- and 5 or more-bedroom units. Owners and renters are
equally as likely to live alone.
Household income. Los Gatos’ households are higher-income than the county and Bay Area overall: 65 percent
of Los Gatos households earn more than 100 percent of the AMI, compared to 55 percent for the county and 52
percent for the Bay Area (Figure B-11, and infographic below).
Every block group in Los Gatos with available data has a median household income of $125,000 or more. In the
Town, Hispanic or Latinx and Other Race or Multiple Races (Hispanic and Non-Hispanic) residents experience
the highest rates of poverty, followed by White (Hispanic and Non-Hispanic) residents (Figure B-13).
Racially or ethnically concentrated areas of poverty and affluence. Racially Concentrated Area of Poverty or an
Ethnically Concentrated Area of Poverty (R/ECAP) and Racially Concentrated Areas of Affluence (RCAAs)
represent opposing ends of the segregation spectrum from racially or ethnically segregated areas with high
Segregation and Integration
Population by Protected Class
City of Los Gatos Santa Clara County
Race and Ethnicity
American Indian or Alaska Native, NH 0%0%
Asian / API, NH 15%37%
Black or African American, NH 1%2%
White, Non-Hispanic (NH)72%32%
Other Race or Multiple Races, NH 4%4%
Hispanic or Latinx 8%25%
Disability Status
With a disability 9%8%
Without a disability 91%92%
Familial Status
Female-Headed Family Households 8%10%
Male-headed Family Households 3%5%
Married-couple Family Households 58%57%
Other Non-Family Households 5%8%
Single-person Households 26%20%
Household Income
0%-30% of AMI 9%14%
31%-50% of AMI 8%11%
51%-80% of AMI 9%11%
81%-100% of AMI 9%9%
Greater than 100% of AMI 65%55%
0%
15%
1%
72%
4%
8%
0%
37%
2%
32%
4%
25%
9%
91%
8%
92%
8%
3%
58%
5%
26%
10%
5%
57%
8%
20%
9%
8%
9%
9%
65%
14%
11%
11%
9%
55%
Town
HCD Draft Initial Review 2023-2031 Housing Element
A-24 Appendix A October 2022
poverty rates to affluent predominantly White neighborhoods. Historically, HUD has paid particular attention to
R/ECAPs as a focus of policy and obligations to AFFH. Recent research out of the University of Minnesota
Humphrey School of Public Affairs argues for the inclusion of RCAAs to acknowledge current and past policies
that created and perpetuate these areas of high opportunity and exclusion12.
It is important to note that R/ECAPs and RCAAs are not areas of focus because of racial and ethnic
concentrations alone. This study recognizes that racial and ethnic clusters can be a part of fair housing choice if
they occur in a non-discriminatory market. Rather, R/ECAPs are meant to identify areas where residents may
have historically faced discrimination and continue to be challenged by limited economic opportunity, and
conversely, RCAAs are meant to identify areas of particular advantage and exclusion.
R/ECAPs
HCD and HUD’s definition of a Racially/Ethnically Concentrated Area of Poverty is:
▪ A census tract that has a non-White population of 50 percent or more (majority-minority)
or, for non-urban areas, 20 percent, AND a poverty rate of 40 percent or more; OR
▪ A census tract that has a non-white population of 50 percent or more (majority-minority)
AND the poverty rate is three times the average tract poverty rate for the County,
whichever is lower.
Source: California Department of Housing and Community Development Guidance, 2021.
For this study, the poverty threshold used to qualify a tract as an R/ECAP was three times the average census
tract poverty rate countywide, or 22.5 percent.
There are no census tracts in Los Gatos that qualify as R/ECAPs. R/ECAPs in the county are all located in San
Jose.
RCAAs. At the time this report was written, HCD and HUD had not established standard definitions for Racially or
Ethnically Concentrated Areas of Affluence (RCAAs). However, these are generally understood to be
neighborhoods in which there are both high concentrations of non-Hispanic White households and high
household income rates. Comparing Los Gatos to the surrounding county and region, it is safe to speculate that
the Town has more RCAAs as other communities, the county, and the region.
A.8 Access to Opportunity
This section discusses disparities in access to opportunity among protected classes including access to quality
education, employment, and environment.
Access to Opportunity
“Access to opportunity is a concept to approximate place-based characteristics linked to critical
life outcomes. Access to opportunity oftentimes means both improving the quality of life for
residents of low-income communities, as well as supporting mobility and access to ‘high resource’
12 Goetz, E. G., Damiano, A., & Williams, R. A. (2019). Racially Concentrated Areas of Affluence: A Preliminary Investigation. Cityscape: A Journal of Policy
Development and Research, 21(1), 99–124
Appendix A. AFFH Report
October 2022 Appendix A A-25
neighborhoods. This encompasses education, employment, economic development, safe and
decent housing, low rates of violent crime, transportation, and other opportunities, including
recreation, food and healthy environment (air, water, safe neighborhood, safety from
environmental hazards, social services, and cultural institutions).”
Source: California Department of Housing and Community Development Guidance, 2021, page 34.
The California Tax Credit Allocation Committee (TCAC) in collaboration with HCD developed a series of
opportunity maps that help to identify areas of the community with good or poor access to opportunity for
residents. These maps were developed to align funding allocations with the goal of improving outcomes for low-
income residents—particularly children.
The opportunity maps highlight areas of highest resource, high resource, moderate resource, moderate resource
(rapidly changing), low resource and high segregation and poverty. TCAC provides opportunity maps for access
to opportunity in quality education, employment, transportation, and environment. Opportunity scores are
presented on a scale from zero to one and the higher the number, the more positive the outcomes.
TCAC’s economic opportunity score comprises poverty, adult educational attainment, employment, job proximity,
and median home value for Los Gatos and is shown in Figure A-11.
Figure A-11 Population Living in High Resource Areas by Race
Source: ABAG Housing Needs Data Workbook, California Tax Credit Allocation Committee (TCAC)/California Housing and Community Development
(HCD), Opportunity Maps (2020); U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B03002
16%
70%
9%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Low Resource or High
Segregation and Poverty
Area
Moderate Resource Area High/Highest Resource
AreaPercent of PopulationHispanic or Latinx
Other Race or Multiple Races, Non-Hispanic
White, Non-Hispanic
Black or African American, Non-Hispanic
Asian / API, Non-Hispanic
American Indian or Alaska Native, Non-Hispanic
HCD Draft Initial Review 2023-2031 Housing Element
A-26 Appendix A October 2022
Education. TCAC’s education score is based on math proficiency, reading proficiency, high school graduation
rates, and the student poverty rate. According to TCAC’s educational opportunity map, every census tract in Los
Gatos scores higher than 0.75—indicating the highest positive educational outcomes. Opportunity scores are
presented on a scale from zero to one and the higher the number, the more positive the outcomes.
Los Gatos is served by the Los Gatos-Saratoga Union High School District, the Los Gatos Union Elementary
School, the Saratoga Elementary School Districts, Loma Prieta Joint Union Elementary, and Lakeside Joint
School District. The most complete data, due to halted data collection during the COVID pandemic, was from
2019 and highlights a 97.7 percent graduation rate among all students in the Los Gatos-Saratoga Union high
school, a small increase over 2018 (97.1 percent). When broken down by race/ethnicity, Asian students
graduated at a slightly higher rate of 98 percent, while Hispanic and White students graduated at 95 percent and
96.5 percent respectively. There were not enough African American students enrolled to provide accurate data
(less than 11 total). The lowest graduation rate was among students with a disability, yet still relatively high at 88
percent.
The Los Gatos Union Elementary served 2,710 students in 2021, down from 3,024 from 2019, the last year with
complete data. White students accounted for 64 percent of the student body, with Asian (19 percent) and
Hispanic students (9 percent) accounting for the majority of the remainder. The school included four percent
socioeconomically disadvantaged students, one homeless student, and seven percent students with a disability.
Saratoga Elementary had 1,657 students in 2021 and 1,765 in 2019. At Saratoga, 57 percent of students are
Asian and White students accounted for 26 percent and Hispanic students another six percent. Saratoga
Elementary served a student population with 11 percent disabilities, two percent socioeconomically
disadvantaged, and no homeless students.
Employment. The job to household ratio for Los Gatos tracks with the Bay Area and is lower than Santa Clara
County’s (Figure B-8), indicating that Los Gatos is less of a commuter city than surrounding jurisdictions with
much higher job to household ratios. This differs, however, by wage (Figure B-7), with jobs to household ratios
much higher for low wage workers who cannot afford to live in the Town. Los Gatos has twice as many jobs as
workers for low wage jobs.
▪ Notably, Los Gatos had 19,843 jobs (Figure B-5) in 2018 compared to 14,573 job holders (Figure III-3),
indicating a healthy job market for local residents and a need for in-commuting to fill the unoccupied jobs.
▪ Most jobs in Los Gatos are in Financial and Professional Services and Health and Educational Services
(Figure B-9).
▪ Unemployment in Los Gatos is five percent, below the county and area averages (Figure B-10).
HUD’s job proximity index shows that Los Gatos offers a moderate to high proximity to jobs. On a scale from zero
to 100, where 100 is the closest proximity to jobs, the areas near Highway 17 score within the high proximity
range, while most of the remaining parts of the Town scores as moderate proximity. The further away from
Highway 17, the lower the proximity to jobs.
Environment. TCAC’s opportunity areas environmental scores are based on the CalEnviroScreen four indicators,
which identify areas disproportionately vulnerable to pollution sources such as ozone, PM2.5, diesel PM,
pesticides, toxic release, traffic, cleanup sites, groundwater threats, hazardous waste, impaired water bodies, and
solid waste sites.
Three-quarters of Los Gatos scores low on positive environmental outcomes, with no census tracts in the Town
scoring over 0.5 out of one (Figure A-12). Los Gatos almost uniformly had the lowest possible scores according
to the CalEnviroScreen metric for 2021.
Appendix A. AFFH Report
October 2022 Appendix A A-27
Figure A-12 CalEnviroScreen 4.0, Los Gatos
Source: California Office and Environmental Health Hazard Assessment, CalEnviroScreen Maps and Data.
The Town scores high on California Healthy Places Index (HPI) developed by the Public Health Alliance of
Southern California (PHASC) (Figure A-13). HPI includes 25 community characteristics in eight categories
including economic, social, education, transportation, neighborhood, housing, clean environment, and
healthcare13.
13 https://healthyplacesindex.org/about/
HCD Draft Initial Review 2023-2031 Housing Element
A-28 Appendix A October 2022
Figure A-13 California Healthy Places Index, Los Gatos
Source: Public Health Alliance of Southern California, California Healthy Places Index.
Disparities in access to opportunity. All residents live in highly resourced areas, regardless of race or ethnicity
(Figure A-11). Los Gatos and other surrounding areas are entirely high opportunity jurisdictions.
The Social Vulnerability Index (SVI) provided by the Center for Disease Control (CDC)—ranks census tracts
based on their ability to respond to a disaster—includes four themes of socioeconomic status, household
composition, race or ethnicity, and housing and transportation. Los Gatos scores well on the SVI; with no
neighborhoods ill equipped to respond to disasters.
Los Gatos does not have any disadvantaged communities as defined under SB 535 as, “the top 25 percent
scoring areas from CalEnviroScreen along with other areas with high amounts of pollution and low populations”14.
Disparities specific to the population living with a disability. Nine percent of the population in Los Gatos is living
with at least one disability, compared to eight percent in the county. The most common disabilities in Los Gatos
are ambulatory (4.8 percent), independent living difficulty (4.3 percent), and hearing difficulty (3.6 percent). For
the population 65 and over, the share of the population with ambulatory difficulties increases to 18.4 percent,
independent living difficulty increase to 15.2 percent, and hearing difficulty was 13.8 percent. 15 percent of
residents with a disability were unemployed in 2019, while only four percent unemployment for residents without a
disability.
14 https://oehha.ca.gov/calenviroscreen/sb535
Appendix A. AFFH Report
October 2022 Appendix A A-29
Disability
“Disability types include hearing difficulty, vision difficulty, cognitive difficulty, ambulatory
difficulty, self-care difficulty, and independent living difficulty.”
Source: California Department of Housing and Community Development Guidance, 2021, page 36.
Access to Opportunity
Regional Access
City of Los Gatos Santa Clara County
Jobs to Household Ratio 1.59 1.71
Unemployment Rate 5%6%
LEP Population 2%9%
Share of Population by Race in Resource Areas in the City of Los Gatos
Employment by Disability Status
For those in the labor
0%0%
16%
0%
1%
0%
70%
0%
4%
0%
9%
Moderate Resource Area
High/Highest Resource Area
American Indian or Alaska Native, NH Asian / API, NH
Black or African American, NH White, Non-Hispanic (NH)
Other Race or Multiple Races, NH Hispanic or Latinx
96%
85%
4%
15%
No Disability
With A Disability
City of Los Gatos
96%
90%
4%
10%
No Disability
With A Disability
Employed Unemployed
Santa Clara County
Town
Town of Los Gatos
Town
HCD Draft Initial Review 2023-2031 Housing Element
A-30 Appendix A October 2022
A.9 Disproportionate Housing Needs
This section discusses disparate housing needs for protected classes including cost burden and severe cost
burden, overcrowding, substandard housing conditions, homelessness, displacement, and other considerations.
Disproportionate Housing Needs
“Disproportionate housing needs generally refers to a condition in which there are significant
disparities in the proportion of members of a protected class experiencing a category of housing
need when compared to the proportion of members of any other relevant groups, or the total
population experiencing that category of housing need in the applicable geographic area. For
purposes of this definition, categories of housing need are based on such factors as cost burden
and severe cost burden, overcrowding, homelessness, and substandard housing conditions.”
Source: California Department of Housing and Community Development Guidance, 2021, page 39.
Housing Needs. Since 2015, the housing that has received permits to accommodate growth has almost
exclusively been priced for the higher incomes, with only two units permitted for low-income households and none
for very low-income households.
▪ The vast majority of the Town’s homes were built between 1940 and 1979 (69 percent). After this period,
housing production slowed, with only three percent of units built since 2010.
▪ Los Gatos housing is becoming more limited by type with 76 percent single-family units, up from 71
percent in 2010. Multifamily housing, with five or more units, made up the second highest category of units
(18 percent); there were sixty-four mobile/manufactured homes in Los Gatos15.
▪ Eighty-four percent of owner-occupied homes in Los Gatos are valued over one million dollars with another
39 percent valued above two million dollars. This compares to 48 percent for the county and 35 percent
for the Bay Area overall (Figure B-23). According to the Zillow Home Value Index, home values in Los
Gatos are 63 percent higher than home values for the county and almost double the cost of housing in the
Bay Area (Figure B-24).
▪ Rents in Los Gatos are most likely to be at least $2,000 per month (63 percent); 24 percent rent for $3,000
per month. While the Town’s rental costs higher than in the county, the trend of increasing rental costs
matches the changes in the county and Bay Area overall.
Cost burden and severe cost burden. Despite Los Gatos’ comparably high housing costs, cost burden—which
occurs when households spend more than 30 percent of their gross income on housing costs—is slightly better
than the county and Bay Area (Figure A-15). This is indicative of a market with high barriers to entry. The lack of
publicly subsidized housing and opportunity for use of Housing Choice Vouchers limits the ability of low-income
households (who are typically cost burdened) to live in the Town.
Cost burden does vary by tenure (renter or ownership) in Los Gatos, Figure A-16. Renters experience a greater
share of all forms of cost burden while owners experienced less of a cost burden. The cost burden by income
decreases for each increase in earned income (AMI category) with a vast difference between the highest and
lowest income groups. Seventy-eight percent of the lowest income group (zero percent to 30 percent of AMI) pay
15 Housing Needs Data Report: Los Gatos, ABAG/MTC Staff and Baird + Driskell Community Planning, 2021.
Appendix A. AFFH Report
October 2022 Appendix A A-31
more than 50 percent of their gross household incomes in housing costs (Figure A-16). Figure A-14 identifies the
housing vouchers distribution by tract within Los Gatos.
Figure A-14 Housing Choice Vouchers by Census Tract
Source: California Department of Housing and Community Development AFFH Data Viewer
HCD Draft Initial Review 2023-2031 Housing Element
A-32 Appendix A October 2022
Figure A-15 through Figure A-19 shows cost burden distribution by jurisdiction, tenure, Area Median Income
(AMI), race and ethnicity, and the size of the families. Renters experience a greater share of all forms of cost
burden (42 percent) while owners experienced 28 percent cost burden (Figure A-16). The cost burden by income
decreases for each increase in earned income (AMI category) with a vast difference between the highest and
lowest income groups (16 percent versus 90 percent). Seventy-eight percent of the lowest income group pay
more than 50 percent of their gross household incomes in housing costs.
There is consistency in housing cost burden in Los Gatos by race and ethnicity. All households have similar
shares of residents paying less than 30 percent of their income on housing. Hispanic and Black/African American
residents were the only groups to experience a greater percentage of households spending 50 percent or more of
their income than 30 percent to 50 percent of their income, indicating larger shares of extreme cost burdens, see
Figure A-18.
Figure A-15 Overpayment (Cost Burden) by Jurisdiction, 2019
Source: ABAG Housing Needs Data Workbook
Figure A-16 Overpayment (Cost Burden) by Tenure, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
Appendix A. AFFH Report
October 2022 Appendix A A-33
Figure A-17 Overpayment (Cost Burden) by AMI, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
Figure A-18 Overpayment (Cost Burden) by Race and Ethnicity, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
HCD Draft Initial Review 2023-2031 Housing Element
A-34 Appendix A October 2022
Figure A-19 Overpayment (Cost Burden) by Family Size, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
Appendix A. AFFH Report
October 2022 Appendix A A-35
Figure A-20 Overpayment (Cost Burden) for Renter Households by Census Tract, 2019
Source: California Department of Housing and Community Development AFFH Data Viewer
HCD Draft Initial Review 2023-2031 Housing Element
A-36 Appendix A October 2022
Figure A-21 Overpayment (Cost Burden) for Owner Households by Census Tract, 2019
Source: California Department of Housing and Community Development AFFH Data Viewer
Appendix A. AFFH Report
October 2022 Appendix A A-37
Overcrowding. The vast majority of households (97 percent) in Los Gatos are not overcrowded—indicated by
more than one occupant per room (Figure A-22). Renter households are more likely to be overcrowded, with six
percent of renter households with more than one occupant per room, compared to 0.3 percent of owner
households (Figure B-32).
Figure A-22 Overpayment (Cost Burden) for Owner Households by Census Tract, 2019
Source: ABAG Housing Needs Data Workbook, U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability
Strategy (CHAS) ACS tabulation, 2013-2017 release
Hispanic residents experience the highest rates of overcrowding (Figure B-34). The rest of the Town’s population
experiences approximately two percent to 3.5 percent overcrowding.
97%92%93%
5%4%
0.0%
10.0%
20.0%
30.0%
40.0%
50.0%
60.0%
70.0%
80.0%
90.0%
100.0%
Los Gatos Santa Clara County Bay AreaPercent of Households1.00 occupants per room or less 1.01 to 1.50 occupants per room
1.50 occupants per room or more
HCD Draft Initial Review 2023-2031 Housing Element
A-38 Appendix A October 2022
Figure A-23 Occupants per Room by Jurisdiction, 2019
Source: ABAG Housing Needs Data Workbook
Figure A-24 Occupants per Room by Tenure, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
Figure A-25 Overcrowding by Race and Ethnicity, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
Appendix A. AFFH Report
October 2022 Appendix A A-39
Figure A-26 Occupants per Room by AMI, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
HCD Draft Initial Review 2023-2031 Housing Element
A-40 Appendix A October 2022
Figure A-27 Overcrowded Households by Census Tract, 2019
Source: California Department of Housing and Community Development AFFH Data Viewer
Appendix A. AFFH Report
October 2022 Appendix A A-41
Substandard housing. Data on housing condition are limited, with the most consistent data available across
jurisdictions found in the American Community Survey (ACS)—which captures units in substandard condition as
self-reported in Census surveys. Renters in Los Gatos report living in substandard housing in 5.5 percent of
housing units, with the more units lacking complete kitchen facilities (4.1 percent). As shown in Figure A-28,
about 0.4 percent of owner households are lacking complete kitchens and 0.6 percent lack complete plumbing.
Figure A-28 Percent of Units Lacking Complete Kitchen and Plumbing Facilities, Los Gatos, 2019
Source: ABAG Housing Needs Data Workbook
Homelessness. In 2019, 9,706 people were experiencing homelessness in the county during the one-day count
(point-in-time), with only 18 percent of people in emergency or transitional shelter while the remaining 82 percent
were unsheltered. The majority of unsheltered people experiencing homelessness were in households without
children. The majority of people in transitional housing were in households with children or people without
children, as shown in Figure A-29.
People who identify as American Indian or Alaskan Native (approximately eight percent of the homeless
population compared to less than one percent of the total population), Black (approximately 19 percent, compared
to two and a half percent of the total population), , and Other Race or Multiple Races (approximately 24 percent
compared to 16 percent of the total population) are overrepresented in the homeless population compared to their
share of the general population, as shown in Figure A-30. People struggling with chronic substance abuse (35
percent), severe mental illness (42 percent), and post-traumatic stress disorder (33 percent) represented a
substantial share of the homeless population in 2019. Losing a job or being evicted was reported to be the causal
events that led to homelessness in 44 percent of incidents of homelessness16.
16 According to Santa Clara County’s Homeless Census & Survey (2019); 2019 SCC Homeless Census and Survey Exec Summary.pdf (sccgov.org).
HCD Draft Initial Review 2023-2031 Housing Element
A-42 Appendix A October 2022
Figure A-29 Homelessness by Household Type and Shelter Status, Santa Clara County, 2019
Source: ABAG Housing Needs Data Workbook
Figure A-30 Share of General and Homeless Populations by Race, Santa Clara County, 2019
Source: ABAG Housing Needs Data Workbook
Sheltered - Emergency Shelter 7 377 696
Sheltered - Transitional Housing 3 301 400
Unsheltered 266 243 7,413
People in
Households
Solely Children
People in
Households
with Adults
and Children
People in
Households
Without
Children
Appendix A. AFFH Report
October 2022 Appendix A A-43
Displacement. According to the Sensitive Communities map of vulnerable communities, one area north of
Highway 9 and west of Highway 17 were vulnerable to displacement. The Town has 169 assisted units, but all
were rated as low risk of conversion. Figure A-31 illustrates the social vulnerability index, identifying the census
tracts by lower or higher social vulnerability.
Figure A-31 Social Vulnerability Index by Census Tract, 2018
Source: California Department of Housing and Community Development AFFH Data Viewer
HCD Draft Initial Review 2023-2031 Housing Element
A-44 Appendix A October 2022
Displacement Sensitive Communities
“According to the Urban Displacement Project, communities were designated sensitive if they met
the following criteria:
▪ They currently have populations vulnerable to displacement in the event of increased
redevelopment and drastic shifts in housing cost. Vulnerability is defined as:
▪ Share of very low-income residents is above 20 percent, 2017
AND the tract meets two of the following criteria:
▪ Share of renters is above 40 percent, 2017
▪ Share of people of color is above 50 percent, 2017
▪ Share of very low-income households (50 percent AMI or below) that are severely rent
burdened households is above the county median, 2017
▪ They or areas in close proximity have been experiencing displacement pressures.
Displacement pressure is defined as:
▪ Percent change in rent above county median for rent increases, 2012-2017
OR
▪ Difference between tract median rent and median rent for surrounding tracts above median
for all tracts in county (rent gap), 2017”
Source: https://www.sensitivecommunities.org/.
Access to mortgage loans. In many communities, disparities by race and ethnicity are prevalent for home
mortgage applications, particularly in denial rates. This is less true in Los Gatos (Figure A-32). Mortgage denial
rates range from 17 percent to 25 percent. American Indian or Alaska Native, Non-Hispanic and Black/African
American residents experienced the next highest rejection rate at 25 percent and 22 percent.
Appendix A. AFFH Report
October 2022 Appendix A A-45
Figure A-32 Mortgage Applications and Acceptance by Race, 2018 and 2019
Source: ABAG Housing Needs Data Workbook, Federal Financial Institutions Examination Council's (FFIEC) Home Mortgage Disclosure Act
loan/application register (LAR) files.
11%
25%15%
22%
17%18%17%
25%
13%
11%
12%14%11%
25%
5%5%
25%
66%56%65%59%64%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
American
Indian or
Alaska
Native, Non-
Hispanic
Asian / API,
Non-Hispanic
Black or
African
American,
Non-Hispanic
White, Non-
Hispanic
Hispanic or
Latinx
UnknownLoan ApplicationsLoan originated
File closed for incompleteness
Application withdrawn by applicant
Application denied
Application approved but not accepted
HCD Draft Initial Review 2023-2031 Housing Element
A-46 Appendix A October 2022
Disproportionate Housing Needs
Cost Burden, City of Los Gatos, 2019
Area Median Income (AMI)
Overcrowding, City of Los Gatos, 2019
Occupants per Room by Tenure
Substandard Housing, City of Los Gatos, 2019
Incomplete Kitchen and Plumbing Facilities by Tenure
Homelessness, Santa Clara County, 2019
Race and Ethnicity
Share of Homeless
Population
Share of Overall
Population
American Indian or Alaska Native 8%1%
Asian / API 5%37%
Black or African American 19%2%
White 44%44%
Other Race or Multiple Races 24%16%
Displacement, 2020
Assisted Units at High or Very
High Risk of Displacement City of Los Gatos Santa Clara County
Number of Units 0 0
% of Assisted Units 0%0%
10%
28%
39%
49%
84%
12%
22%
38%
33%
12%
78%
49%
22%
4%
0%-30% of AMI
31%-50% of AMI
51%-80% of AMI
81%-100% of AMI
100%+ of AMI
0%-30% of Income Used for Housing 30%-50% of Income Used for Housing
50%+ of Income Used for Housing
0.4%
0.6%
4.1%
1.4%
Kitchen
Plumbing
Owner Renter
2.1%
4.3%
0.3%
0.3%
1.0 to 1.5 Occupants per Room
More than 1.5 Occupants per Room
Owner Renter Series3
1.5+ Occupants
per Room
1-1.5 Occupants
per Room
Town
Town
Town
This Page Intentionally Left Blank
Housing Needs Assessment B
APPENDIX
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-1
B.1 Introduction
This appendix of the Housing Element describes existing housing needs and conditions in the Town of Los Gatos.
The analysis in this section primarily utilizes data compiled by Association of Bay Area Governments/
Metropolitan Transportation Commission (ABAG/MTC) in the “Housing Needs Data Report: Los Gatos”
(ABAG/MTC, Baird + Driskell Community Planning, April 2, 2021). This data packet was approved by the
California Department of Housing and Community Development (HCD).
Overview of Bay Area Housing
The Bay Area continues to see growth in both population and jobs, which means more housing of various types
and sizes is needed to ensure that residents across all income levels, ages, and abilities have a place to call
home. While the number of people drawn to the region over the past 30 years has steadily increased, housing
production has stalled, contributing to the housing shortage that communities are experiencing today. In many
communities, this has resulted in residents being priced out, increased traffic congestion caused by longer
commutes, and fewer people across incomes being able to purchase homes or meet surging rents.
The 2023-2031 Housing Element Update provides a roadmap for how to meet growth and housing challenges.
As required by the State, the Housing Element identifies what the existing housing conditions and community
needs are, reiterates goals, and creates a plan for more housing.
Summary of Key Facts
▪ Population – Generally, the population of the Bay Area continues to grow because of new births (natural
growth) and the strong economy draws new residents to the region. The population of the Town of Los
Gatos increased by 10 percent from 2000 to 2020, which is below the growth rate of the Bay Area.
▪ Age – In 2019, the youth population of the Town, under the age of 18, was 6,767 and the senior
population, 65 and older, was 6,393. These age groups represent 22. percent and 20.8 percent,
respectively, of the Town’s population.
▪ Race/Ethnicity – In 2020, 72.3 percent of the Town of Los Gatos population was White, while 0.9 percent
was African American, 14.8 percent was Asian, and 7.9 percent was Latinx. People of color in Los Gatos
comprise a proportion below the overall proportion in the Bay Area as a whole0F
1.
▪ Employment – The Town of Los Gatos residents most commonly work in the Financial and Professional
Services industry. From January 2010 to January 2021, the unemployment rate in the Town decreased by
2.9 percent. Since 2010, the number of jobs located in the jurisdiction increased by 4,440 (28.8 percent).
Additionally, the jobs-household ratio in the Town of Los Gatos has increased from 1.32 jobs per
household in 2002 to 1.59 in 2018.
▪ Number of Homes – The number of new homes built in the Bay Area has not kept pace with the demand,
resulting in longer commutes, increasing prices, and exacerbating issues of displacement and
homelessness. The number of homes in the Town of Los Gatos increased 4.5 percent from 2010 to 2020,
1 The Census Bureau’s American Community Survey accounts for ethnic origin separate from racial identity. The numbers reported here use an accounting
of both such that the racial categories are shown exclusive of Latinx status, to allow for an accounting of the Latinx population regardless of racial identity.
The term Hispanic has historically been used to describe people from numerous Central American, South American, and Caribbean countries. In recent
years, the term Latino or Latinx has become preferred. This report generally uses Latinx, but occasionally when discussing US Census data, we use Hispanic
or Non-Hispanic, to clearly link to the data source.
HCD Draft Initial Review 2023-2031 Housing Element
B-2 Appendix B October 2022
which is below the growth rate for Santa Clara County and below the growth rate of the region’s housing
stock during this time period1F
2.
▪ Home Prices – A diversity of homes at all income levels would create opportunities for all of the Los Gatos
community to live in Town.
✓ Ownership – The largest proportion of homes had a value greater than $2 million in 2019. Home
prices increased by 98.4 percent from 2010 to 2020.
✓ Rental Prices – The typical contract rent for an apartment in the Town of Los Gatos was $2,270 in
2019. Rental prices increased by 60.9 percent from 2009 to 2019. To rent a typical apartment
without cost burden, a household would need to make $90,960 per year2F
3.
▪ Housing Type – It is important to have a variety of housing types to meet the needs of a community today
and in the future. In 2020, 60 percent of homes in the Town of Los Gatos were single-family detached, 13
percent were single-family attached, 9 percent were small multi-family (two to four units), and 18 percent
were medium or large multi-family (five or more units). Between 2010 and 2020, the number of single-
family units increased more than multi-family units. Los Gatos has a higher portion of detached single-
family homes than other jurisdictions in the region.
▪ Housing Demand – The Town is populated with a higher share of high-income earners (65% greater than
100% of AMI) than the rest of the county, therefore, housing is built for these higher income and amenity
levels. Without goals, policies and programs that specifically address the need to build “affordable
housing” targeting incomes less than 100% of AMI (not above greater than 100% AMI), it is highly unlikely
developers will voluntarily build housing for low and very-low-income levels.
▪ Cost Burden – The U.S. Department of Housing and Urban Development (HUD) considers housing to be
affordable for a household if the household spends less than 30 percent of its income on housing costs. A
household is considered “cost-burdened” if it spends more than 30 percent of its monthly income on
housing costs, while those who spend more than 50 percent of their income on housing costs are
considered “severely cost-burdened.” In the Town of Los Gatos, 20 percent of households spend 30
percent to 50 percent of their income on housing, while 16 percent of households are severely cost
burdened and use the majority of their income for housing.
▪ Displacement/Gentrification – According to research from the University of California (UC), Berkeley no
households in the Town of Los Gatos live in neighborhoods that are susceptible to or experiencing
displacement, and none live in areas at risk of or undergoing gentrification. All households in the Town live
in neighborhoods where low-income households are likely excluded due to prohibitive housing costs.
▪ Neighborhood – All residents in Los Gatos live in neighborhoods identified as “Highest Resource” or
“High Resource” areas by State-commissioned research, while no residents live in areas identified by this
research as “Low Resource” or “High Segregation and Poverty” areas. These neighborhood designations
are based on a range of indicators covering areas such as education, poverty, proximity to jobs and
economic opportunities, low pollution levels, and other factors3F
4.
2 According to HCD Annual Progress Report Dashboard (as of September 20, 2021).
3 Note that contract rents may differ significantly from, and often being lower than, current listing prices.
4 For more information on the “opportunity area” categories developed by HCD and the California Tax Credit Allocation Committee, see this website:
https://www.treasurer.ca.gov/ctcac/opportunity.asp. The degree to which different jurisdictions and neighborhoods have access to opportunity will likely
need to be analyzed as part of new Housing Element requirements related to affirmatively furthering fair housing. ABAG/MTC will be providing
jurisdictions with technical assistance on this topic this summer, following the release of additional guidance from HCD.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-3
▪Special Housing Needs – Some population groups may have special housing needs that require specific
program responses, and these groups may experience barriers to accessing stable housing due to their
specific housing circumstances. In Los Gatos, 9 percent of residents have a disability (physical,
developmental, etc.), and may require accessible housing. Additionally, 6 percent of Los Gatos
households are larger households with five or more people and likely need larger housing units with three
bedrooms or more. 8.2 percent of households are female-headed families, which are often at greater risk
of housing insecurity.
B.2 Population, Employment, and Household
Characteristics
Population
The Bay Area is the fifth-largest metropolitan area in the nation and has seen a steady increase in population
since 1990, except for a dip during the Great Recession. Many towns and cities in the region have experienced
significant growth in jobs and population. While these trends have led to a corresponding increase in demand for
housing across the region, the regional production of housing has largely not kept pace with job and population
growth.
According to the data, the population of the Town of Los Gatos was estimated to be 31,439 in 2020. The
population of Los Gatos makes up 1.6 percent of Santa Clara County4F
5. In Los Gatos, roughly 13.5 percent of its
population moved during the past year, a number that is roughly the same as the regional rate of 13.4 percent.
Table B-1 shows population growth trends for the Town of Los Gatos, Santa Clara County, and the Bay Area as a
whole.
Table B-1 Population Growth Trends
Geography 1990 1995 2000 2005 2010 2015 2020
Town of Los Gatos 27,357 28,751 28,592 28,872 29,413 30,807 31,439
Santa Clara County 1,497,577 1,594,818 1,682,585 1,752,696 1,781,642 1,912,180 1,961,969
Bay Area 6,020,147 6,381,961 6,784,348 7,073,912 7,150,739 7,595,694 7,790,537
SOURCE: California Department of Finance, E-5 series.
NOTE: Universe: Total population; Data from ABAG/MTC Housing Needs Data Packet Workbook, Table POPEMP-01.
Since 2000, the Town of Los Gatos population has increased by approximately 10 percent, which is below the
rate for the region as a whole, at 14.8 percent. From 1990 to 2000, the population increased by 4.5 percent.
During the first decade of the 2000’s the population increased by 2.9 percent. In the most recent decade, the
population increased by 6.9 percent. Figure B-1 shows population growth trends in percentages.
In 2019 the Town of Los Gatos annexed 24 urban islands totaling 116.1 acres. The islands were comprised of
approximately 308 single-family residences and the staff report assumed 2.2 persons per household for an
estimated increase in population of 678.
5 To compare the rate of growth across various geographic scales, Figure B-1 shows population for the jurisdiction, county, and region indexed to the
population in the year 1990. This means that the data points represent the population growth (i.e., percent change) in each of these geographies relative
to their populations in 1990.
HCD Draft Initial Review 2023-2031 Housing Element
B-4 Appendix B October 2022
Figure B-1 Population Growth Trends
Source: California Department of Finance, E-5 series.
Note: The data shown on the graph represents population for the jurisdiction, county, and region indexed to the population in the first
year shown. The data points represent the relative population growth in each of these geographies relative to their populations in that
year. For some jurisdictions, a break may appear at the end of each decade (1999, 2009) as estimates are compared to census counts. DOF
uses the decennial census to benchmark subsequent population estimates. Data from ABAG/MTC Housing Needs Data Packet Workbook,
Table POPEMP-01
Age
The distribution of age groups in a community shapes what types of housing the community may need in the near
future. An increase in the older population may mean there is a developing need for more senior housing options,
while higher numbers of children and young families can point to the need for more family housing options and
related services. There has also been a move by many to age-in-place or downsize to stay within their
communities, which can mean more multi-family and accessible units are needed.
In the Town of Los Gatos, the median age in 2000 was approximately 41 years. By 2019, the median age
increased to approximately 47 years. The cohorts age 25 to 34 and age 35 to 44 decreased between 2000 and
2019, while all age cohorts 55 and above increased during the same time period. Figure B-2 shows population by
age for the years 2000, 2010, and 2019 for the Town of Los Gatos.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-5
Figure B-2 Los Gatos Population by Age, 2000-2019
Source: U.S. Census Bureau, Census 2000 SF1, Table P12; U.S. Census Bureau, Census 2010 SF1, Table P12; U.S. Census Bureau, American
Community Survey 5-Year Data (2015-2019), Table B01001. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table POPEMP-
04.
Note: Universe: Total population.
Looking at the senior and youth population by race can add an additional layer of understanding, as families and
seniors of color are even more likely to experience challenges finding affordable housing. People of color 5F
6 make
up 13.4 percent of seniors and 23.7 percent of youth under 18. Figure B-3 shows population age by race for the
Town of Los Gatos.
6 Here, all non-white racial groups are counted.
HCD Draft Initial Review 2023-2031 Housing Element
B-6 Appendix B October 2022
Figure B-3 Los Gatos Population Age by Race
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001(A-G). Data from ABAG/MTC Housing
Needs Data Packet Workbook, Table SEN-02.
Notes: Universe: Total population. In the sources for this table, the Census Bureau does not disaggregate racial groups by Hispanic/Latinx
ethnicity, and an overlapping category of Hispanic / non-Hispanic groups has not been shown to avoid double counting in the stacked bar
chart.
Race and Ethnicity
Understanding the racial makeup of the Town and region is important for designing and implementing effective
housing policies and programs. These patterns are shaped by both market factors and government actions, such
as exclusionary zoning, discriminatory lending practices, and displacement that has occurred over time and
continues to impact communities of color today6F
7.
Since 2000, the percentage of residents in the Town of Los Gatos identifying as White, Non-Hispanic has
decreased by 13.3 percentage points, with this 2019 population standing at 22,231. At the same time the
percentage of residents of all Other Race of Multiple Races, Non-Hispanic has increased. In absolute terms, the
Asian/API, Non-Hispanic population increased the most while the White, Non-Hispanic population decreased the
most. Figure B-4 shows population for the Town of Los Gatos by race for 2000, 2010, and 2019.
7 See, for example, Rothstein, R. (2017). The color of law: a forgotten history of how our government segregated America. New York, NY & London, UK:
Liveright Publishing.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-7
Figure B-4 Los Gatos Population by Race, 2000-2019
Source: U.S. Census Bureau, Census 2000, Table P004; U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table
B03002. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table POPEMP-02.
Notes: Universe: Total population. Data for 2019 represents 2015-2019 ACS estimates. The Census Bureau defines Hispanic/Latinx
ethnicity separate from racial categories. For the purposes of this graph, the “Hispanic or Latinx” racial/ethnic group represents those
who identify as having Hispanic/Latinx ethnicity and may also be members of any racial group. All other racial categories on this graph
represent those who identify with that racial category and do not identify with Hispanic/Latinx ethnicity.
Employment Trends
Balance of Jobs and Workers
A town houses employed residents who either work in the community where they live or work elsewhere in the
region. Conversely, a town may have job sites that employ residents from the same town, but more often employ
workers that commute from outside of it. Smaller towns typically will have more employed residents than jobs and
export workers, while larger towns tend to have a surplus of jobs and import workers. To some extent the
regional transportation system (bus system, for example) is set up for this flow of workers to the region’s core job
centers. At the same time, as the housing affordability crisis has illustrated, local imbalances may be severe,
where local jobs and worker populations are out of sync at a sub-regional scale. One measure of this is the
relationship between workers and jobs. A town with a surplus of workers “exports” workers to other parts of the
region, while a town with a surplus of jobs must conversely “import” them. Between 2002 and 2018, the number
of jobs in the Town of Los Gatos increased by 23.8 percent. Figure 3-5 shows jobs in the Town of Los Gatos
between 2002 and 2018.
HCD Draft Initial Review 2023-2031 Housing Element
B-8 Appendix B October 2022
Figure B-5 Los Gatos Jobs in a Jurisdiction
Source: U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files, 2002-2018. Data
from ABAG/MTC Housing Needs Data Packet Workbook, Table POPEMP-11.
Notes: Universe: Jobs from unemployment insurance-covered employment (private, state and local government) plus United States Office
of Personnel Management-sourced Federal employment. The data is tabulated by place of work, regardless of where a worker lives. The
source data is provided at the census block level. These are cross walked to jurisdictions and summarized.
The figure below shows the balance when comparing jobs to workers, broken down by different wage groups,
offering additional insight into local dynamics. A community may offer employment for relatively low-income
workers, but have relatively few housing options for those workers. Conversely, it may house residents who are
low-wage workers, but offer few employment opportunities for them. Such relationships may cast extra light on
potentially pent-up demand for housing in particular price categories. A relative surplus of jobs relative to
residents in a given wage category suggests the need to import those workers, while conversely, surpluses of
workers mean the community will export those workers to other jurisdictions. Such flows are not inherently bad,
though over time, sub-regional imbalances may appear. The Town has more jobs than residents in wage
categories below $75,000 per year. At the high end of the wage spectrum (i.e., wages over $75,000 per year),
the Town has more high-wage residents than high-wage jobs7F
8. Figure B-6 shows workers by earnings, place of
residence, and place of work within the jurisdiction of the Town of Los Gatos.
8 The source table is top coded at $75,000, precluding more fine-grained analysis at the higher end of the wage spectrum.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-9
Figure B-6 Workers by Earnings, by Los Gatos Jurisdiction as Place of Work and Place of Residence
Source: U.S. Census Bureau, American Community Survey 5-Year Data 2015-2019, B08119, B08519. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table POPEMP-10.
Notes: Universe: Los Gatos Workers 16 years and over with earnings.
The next diagram shows the ratio of jobs to workers, by wage group. A value of 1.00 means that the Town has
the same number of jobs in a wage group as it has resident workers, in principle, a balance. Values above 1.00
indicate a jurisdiction will need to import workers for jobs in a given wage group. Figure B-7 shows jobs to worker
ratios for the Town Los Gatos.
HCD Draft Initial Review 2023-2031 Housing Element
B-10 Appendix B October 2022
Figure B-7 Los Gatos Jobs-Worker Ratios, By Wage Group
Source: U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files (Jobs); Residence
Area Characteristics (RAC) files (Employed Residents), 2010-2018. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table
POPEMP-14.
Notes: Universe: Jobs in a jurisdiction from unemployment insurance-covered employment (private, state and local government) plus
United States Office of Personnel Management-sourced Federal employment. The ratio compares job counts by wage group from two
tabulations of LEHD data: Counts by place of work relative to counts by place of residence. See text for details.
Such balances between jobs and workers may directly influence the housing demand in a community. New jobs
may draw new residents, and when there is high demand for housing relative to supply, many workers may be
unable to afford to live where they work, particularly where job growth has been in relatively lower wage jobs. The
Town is a “net importer of workers” at the low-wage group, while at the high-wage group the Town is “exporting
workers.” This dynamic not only means many workers will need to prepare for long commutes and time spent on
the road, but in the aggregate, it contributes to traffic congestion and time lost for all road users.
If there are more jobs than employed residents, it means a community is relatively jobs-rich, typically also with a
high jobs-per-employed-resident ratio. Therefore, bringing housing into the measure, the jobs per employed
resident ratio in the Town of Los Gatos has increased from 1.32 in 2002, to 1.59 jobs per employed resident in
2018. In short, the Town of Los Gatos is a net importer of workers. Figure B-8 shows the Town of Los Gatos
jobs per household ratio.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-11
Figure B-8 Jobs-Household Ratio
Source: U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files (Jobs), 2002-2018;
California Department of Finance, E-5 (Households). Data from ABAG/MTC Housing Needs Data Packet Workbook, Table POPEMP-13.
Notes: Universe: Jobs in a jurisdiction from unemployment insurance-covered employment (private, state and local government) plus
United States Office of Personnel Management-sourced Federal employment; households in a jurisdiction. The data is tabulated by place
of work, regardless of where a worker lives. The source data is provided at the census block level. These are cross walked to jurisdictions
and summarized. The ratio compares place of work wage and salary jobs with households, or occupied housing units. A similar measure
is the ratio of jobs to housing units. However, this jobs-household ratio serves to compare the number of jobs in a jurisdiction to the
number of housing units that are actually occupied. The difference between a jurisdiction’s jobs-housing ratio and jobs-household ratio
will be most pronounced in jurisdictions with high vacancy rates, a high rate of units used for seasonal use, or a high rate of units used as
short-term rentals.
Sector Composition
In terms of sectoral composition, the largest industry in which the Town of Los Gatos residents work is Financial
and Professional Services, and the largest sector in which Santa Clara residents work is Health and Educational
Services. For the Bay Area as a whole, the Health and Educational Services industry employs the most workers.
Figure B-9 shows resident employment by industry.
HCD Draft Initial Review 2023-2031 Housing Element
B-12 Appendix B October 2022
Figure B-9 Resident Employment by Industry
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table C24030. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table POPEMP-06.
Notes: Universe: Civilian employed population age 16 years and over. The data displayed shows the industries in which jurisdiction
residents work, regardless of the location where those residents are employed (whether within the jurisdiction or not). Categories are
derived from the following source tables: Agriculture & Natural Resources: C24030_003E, C24030_030E; Construction: C24030_006E,
C24030_033E; Manufacturing, Wholesale & Transportation: C24030_007E, C24030_034E, C24030_008E, C24030_035E, C24030_010E,
C24030_037E; Retail: C24030_009E, C24030_036E; Information: C24030_013E, C24030_040E; Financial & Professional Services:
C24030_014E, C24030_041E, C24030_017E, C24030_044E; Health & Educational Services: C24030_021E, C24030_024E, C24030_048E,
C24030_051E; Other: C24030_027E, C24030_054E, C24030_028E, C24030_055E.
Unemployment
In the Town of Los Gatos, there was a 2.9 percentage point decrease in the unemployment rate between January
2010 and January 2021. Jurisdictions throughout the region experienced a sharp rise in unemployment in 2020
due to impacts related to the COVID-19 pandemic, though with a general improvement and recovery in the later
months of 2020. Figure B-10 shows the unemployment rates over the last decade for the Town of Los Gatos,
Santa Clara County, and the Bay Area as a whole.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-13
Figure B-10 Los Gatos Unemployment Rate
Source: California Employment Development Department, Local Area Unemployment Statistics (LAUS), Sub-county areas monthly updates,
2010-2021. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table POPEMP-15.
Notes: Universe: Civilian noninstitutional population ages 16 and older. Unemployment rates for the jurisdiction level is derived from
larger-geography estimates. This method assumes that the rates of change in employment and unemployment are exactly the same in
each sub-county area as at the county level. If this assumption is not true for a specific sub-county area, then the estimates for that area
may not be representative of the current economic conditions. Since this assumption is untested, caution should be employed when using
these data. Only not seasonally-adjusted labor force (unemployment rates) data are developed for cities and CDPs.
Extremely Low-Income Households
Despite the economic and job growth experienced throughout the region since 1990, the income gap has
continued to widen. California is one of the most economically unequal states in the nation, and the Bay Area has
the highest income inequality between high- and low-income households in the state8F
9.
In the Town of Los Gatos, 65 percent of households make more than 100 percent of the Area Median Income
(AMI)9F
10, compared to 8.6 percent making less than 30 percent of AMI, which is considered extremely low-income.
Regionally, more than half of all households make more than 100 percent AMI, while 15 percent make less than
30 percent AMI. In Santa Clara County, 30 percent AMI is the equivalent to the annual income of $39,900 for a
family of four. Many households with multiple wage earners, including food service workers, full-time students,
teachers, farmworkers, and healthcare professionals, can fall into lower AMI categories due to relatively stagnant
wages in many industries. Figure B-11 shows households by income level.
9 Bohn, S.et al. 2020. Income Inequality and Economic Opportunity in California. Public Policy Institute of California.
10 Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan areas, and the nine
county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa
Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County),
S1anta Rosa Metro
HCD Draft Initial Review 2023-2031 Housing Element
B-14 Appendix B October 2022
Figure B-11 Households by Household Income Level
Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation,
2012-2017 release. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table ELI-01.
Notes: Universe: Occupied housing units. Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates
the AMI for different metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area
(Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and
San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and
Vallejo-Fairfield Metro Area (Solano County). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is
located. The data that is reported for the Bay Area is not based on a regional AMI but instead refers to the regional total of households in
an income group relative to the AMI for the county where that household is located. Local jurisdictions are required to provide an
estimate for their projected extremely low-income households (0-30 percent AMI) in their Housing Elements. HCD’s official Housing
Element guidance notes that jurisdictions can use their RHNA for very low-income households (those making 0-50 percent AMI) to
calculate their projected extremely low-income households. As Bay Area jurisdictions have not yet received their final RHNA numbers, this
document does not contain the required data point of projected extremely low-income households. The report portion of the housing data
needs packet contains more specific guidance for how local staff can calculate an estimate for projected extremely low-income households
once jurisdictions receive their 6th cycle RHNA numbers. AMI levels in this chart are based on the HUD metro area where this jurisdiction
is located. Households making between 80 and 120 percent of the AMI are moderate-income, those making 50 to 80 percent are low
income, those making 30 to 50 percent are very low-income, and those making less than 30 percent are extremely low-income. This is
then adjusted for household size.
Throughout the region, there are disparities between the incomes of homeowners and renters. Typically, the
number of low-income renters greatly outpaces the amount of housing available that is affordable for these
households. In the Town of Los Gatos, the largest proportion of renters falls in the Greater than 100 percent of
AMI group, while the largest proportion of homeowners are found in the Greater than 100 percent of AMI group.
Figure B-12 shows household income by tenure.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-15
Figure B-12 Los Gatos Household Income Level by Tenure
Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation,
2012-2017 release. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table POPEMP-21.
Notes: Universe: Occupied housing units. Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates
the AMI for different metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area
(Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and
San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and
Vallejo-Fairfield Metro Area (Solano County). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is
located.
Currently, people of color are more likely to experience poverty and financial instability as a result of Federal,
State, and local housing policies that have historically excluded them from the same opportunities extended to
White residents10F
11. These economic disparities also leave communities of color at higher risk for housing
insecurity, displacement, or homelessness.
In the Town of Los Gatos, Hispanic or Latinx and Other Race or Multiple Races (Hispanic and Non-Hispanic)
residents experience the highest rates of poverty, followed by White (Hispanic and Non-Hispanic) residents.
Figure B-13 shows poverty status by race.
11 Moore, E., Montojo, N. and Mauri, N., 2019. Roots, Race & Place: A History of Racially Exclusionary Housing the San Francisco Bay Area. Hass Institute.
HCD Draft Initial Review 2023-2031 Housing Element
B-16 Appendix B October 2022
Figure B-13 Los Gatos Poverty Status by Race
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B17001(A-I). Data from ABAG/MTC Housing
Needs Data Packet Workbook, Table ELI-03.
Notes: Universe: Population for whom poverty status is determined. The Census Bureau uses a federally defined poverty threshold that
remains constant throughout the country and does not correspond to Area Median Income. For this table, the Census Bureau does not
disaggregate racial groups by Hispanic/Latinx ethnicity. However, data for the white racial group is also reported for white householders
who are not Hispanic/Latinx. Since residents who identify as white and Hispanic/Latinx may have very different experiences within the
housing market and the economy from those who identify as white and non-Hispanic/Latinx, data for multiple white sub-groups are
reported here. The racial/ethnic groups reported in this table are not all mutually exclusive. Therefore, the data should not be summed as
the sum exceeds the population for whom poverty status is determined for this jurisdiction. However, all groups labelled “Hispanic and
Non-Hispanic” are mutually exclusive, and the sum of the data for these groups is equivalent to the population for whom poverty status is
determined.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-17
Tenure
The number of residents who own their homes compared to those who rent their homes can help identify the level
of housing insecurity (i.e., ability for individuals to stay in their homes) in a town or city and region. Generally,
renters may be displaced more quickly if prices increase.
In the Town of Los Gatos as of 2019, there are a total of 12,083 housing units, and fewer residents rent than own
their homes: 35.1 percent versus 64.9 percent. By comparison, 43.6 percent of households in Santa Clara
County are renters, while 43.9 percent of Bay Area households rent their homes. Figure B-14 shows housing
tenure for Los Gatos, Santa Clara County, and the Bay Area as a whole.
Figure B-14 Housing Tenure
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25003. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table POPEMP-16.
Notes: Universe: Occupied housing units.
Homeownership rates often vary considerably across race and ethnicity in the Bay Area and throughout the
country. These disparities not only reflect differences in income and wealth, but also stem from Federal, State,
and local policies that limited access to homeownership for communities of color while facilitating homebuying for
White residents. While many of these policies, such as redlining, have been formally disbanded, the impacts of
race-based policy are still evident across Bay Area communities.11F
12
In Los Gatos, 84 percent of Black households owned their homes, while homeownership rates were 72 percent
for Asian households, 39 percent for Latinx households, and 65 percent for White households. Notably, recent
changes to State law require local jurisdictions to examine these dynamics and other fair housing issues when
updating their Housing Elements. Figure B-15 shows housing tenure by the race of the householder.
12 See, for example, Rothstein, R. (2017). The color of law: a forgotten history of how our government segregated America. New York, NY & London, UK:
Liveright Publishing.
HCD Draft Initial Review 2023-2031 Housing Element
B-18 Appendix B October 2022
Figure B-15 Los Gatos Housing Tenure by Race of Householder
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25003(A-I). Data from ABAG/MTC Housing
Needs Data Packet Workbook, Table POPEMP-20.
Notes: Universe: Occupied housing units. For this table, the Census Bureau does not disaggregate racial groups by Hispanic/Latinx
ethnicity. However, data for the white racial group is also reported for white householders who are not Hispanic/Latinx. Since residents
who identify as white and Hispanic/Latinx may have very different experiences within the housing market and the economy from those
who identify as white and non-Hispanic/Latinx, data for multiple white sub-groups are reported here. The racial/ethnic groups reported in
this table are not all mutually exclusive. Therefore, the data should not be summed as the sum exceeds the total number of occupied
housing units for this jurisdiction. However, all groups labelled “Hispanic and Non-Hispanic” are mutually exclusive, and the sum of the
data for these groups is equivalent to the total number of occupied housing units.
The age of residents who rent or own their home can also signal the housing challenges a community is
experiencing. Younger households tend to rent and may struggle to buy a first home in the Bay Area due to high
housing costs. At the same time, senior homeowners seeking to downsize may have limited options in an
expensive housing market.
In the Town of Los Gatos, 77.2 percent of householders between the ages of 25 and 34 are renters, and 36.4
percent of householders over 85 are renters. Figure B-16 shows housing tenure by age.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-19
Figure B-16 Los Gatos Housing Tenure by Age
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25007. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table POPEMP-18.
Notes: Universe: Occupied housing units.
In many communities, homeownership rates for households in single-family homes are substantially higher than
the rates for households in multi-family housing. In the Town of Los Gatos, 86.2 percent of households in
detached single-family homes are homeowners, while 13.2 percent of households in multi-family housing are
homeowners. Figure B-17 shows housing tenure by housing type.
HCD Draft Initial Review 2023-2031 Housing Element
B-20 Appendix B October 2022
Figure B-17 Los Gatos Housing Tenure by Housing Type
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25032. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table POPEMP-22.
Notes: Universe: Occupied housing units.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-21
Displacement
Because of increasing housing prices, displacement is a major concern in the Bay Area. Displacement has the
most severe impacts on low- and moderate-income residents. When individuals or families are forced to leave
their homes and communities, they also lose their support network.
The University of California UC, Berkeley, has mapped all neighborhoods in the Bay Area, identifying their risk for
gentrification. They find that in the Town of Los Gatos, there are no households that live in neighborhoods that
are susceptible to or experiencing displacement and none live in neighborhoods at risk of or undergoing
gentrification. Equally important, some neighborhoods in the Bay Area do not have housing appropriate for a
broad section of the workforce. The University of California, Berkeley, estimates that all households in the Town
of Los Gatos live in neighborhoods where low-income households are likely to be excluded due to prohibitive
housing costs12F
13. Figure B-18 shows household displacement risk and tenure.
Figure B-18 Los Gatos Households by Displacement Risk and Tenure
Source: Urban Displacement Project for classification, American Community Survey 5-Year Data (2015-2019), Table B25003 for tenure.
Data from ABAG/MTC Housing Needs Data Packet Workbook, Table POPEMP-25.
Notes: Universe: Households. Displacement data is available at the census tract level. Staff aggregated tracts up to jurisdiction level using
census 2010 population weights, assigning a tract to jurisdiction in proportion to block level population weights. Total household count
may differ slightly from counts in other tables sourced from jurisdiction level sources. Categories are combined as follows for simplicity:
At risk of or Experiencing Exclusion: At Risk of Becoming Exclusive; Becoming Exclusive; Stable/Advanced Exclusive At risk of or
Experiencing Gentrification: At Risk of Gentrification; Early/Ongoing Gentrification; Advanced Gentrification Stable Moderate/Mixed
Income: Stable Moderate/Mixed Income Susceptible to or Experiencing Displacement: Low-Income/Susceptible to Displacement; Ongoing
Displacement Other: High Student Population; Unavailable or Unreliable Data.
13 More information about this gentrification and displacement data is available at the Urban Displacement Project’s webpage:
https://www.urbandisplacement.org/. Specifically, one can learn more about the different gentrification/displacement typologies shown in Figure 18 at
this link: https://www.urbandisplacement.org/sites/default/files/typology_sheet_2018_0.png. Additionally, one can view maps that show which
typologies correspond to which parts of a jurisdiction here: https://www.urbandisplacement.org/san-francisco/sf-bay-area-gentrification-and-
displacement
HCD Draft Initial Review 2023-2031 Housing Element
B-22 Appendix B October 2022
B.3 Housing Stock Characteristics
Housing Types, Year Built, Vacancy, and Permits
In recent years, most housing produced in the region and across the State consisted of single-family homes and
larger multi-unit buildings. However, some households are increasingly interested in “missing middle housing” or
“Small Multi-Unit Housing, including duplexes, triplexes, townhomes, cottage clusters, and accessory dwelling
units. These housing types may open up more options across incomes and tenure, from young households
seeking homeownership options to seniors looking to downsize and age-in-place.
The housing stock of the Town of Los Gatos in 2020 was made up of 60 percent Single-Family Home: Detached,
13 percent Single-Family Home: Attached, 9 percent Multi-family Housing: Two to Four Units, 18 percent Multi-
family Housing: Five-Plus Units, and 0.5 percent Mobile Homes. In Los Gatos, the housing type that experienced
the most growth between 2010 and 2020 was Single-Family Home: Detached. Figure B-19 shows housing type
trends in Los Gatos for 2010 and 2020.
Figure B-19 Los Gatos Housing Type Trends
SOURCE: California Department of Finance, E-5 series. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table HSG-01.
NOTE: Universe: Housing units.
Production has not kept up with housing demand for several decades in the Bay Area, as the total number of units
built and available has not yet come close to meeting the population and job growth experienced throughout the
region. In the Town of Los Gatos, the largest proportion of the housing stock was Built 1960 to 1979, with 6,630
units constructed during this period. Since 2010, 2.6 percent of the current housing stock was built, which is 342
units (U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25034). Figure B-20
shows housing units by the year built.
59.6%
13.0%
9.0%
17.9%
0.5%
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-23
Figure B-20 Los Gatos Housing Units by Year Structure Built
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25034. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table HSG-04.
NOTE: Universe: Housing units.
Throughout the Bay Area, vacancies make up 2.6 percent of the total housing units, with homes listed for rent,
units used for Recreational or Occasional Use, and units not otherwise classified (Other Vacant) making up the
majority of vacancies. The Census Bureau classifies a unit as vacant if no one is occupying it when census
interviewers are conducting the American Community Survey or Decennial Census. Vacant units classified as
For Recreational or Occasional Use are those that are held for short-term periods of use throughout the year.
Accordingly, vacation rentals and short-term rentals like Airbnb are likely to fall in this category. The Census
Bureau classifies units as Other Vacant if they are vacant due to foreclosure, personal/family reasons, legal
proceedings, repairs/renovations, abandonment, preparation for being rented or sold, or vacant for an extended
absence for reasons such as a work assignment, military duty, or incarceration13F
14. In a region with a thriving
economy and housing market like the Bay Area, units being renovated/repaired and prepared for rental or sale
are likely to represent a large portion of the Other Vacant category. Additionally, the need for seismic retrofitting
in older housing stock could also influence the proportion of Other Vacant units in some jurisdictions14F
15.
Vacant units make up 7.5 percent of the overall housing stock in the Town of Los Gatos. The rental vacancy
stands at 8.2 percent, while the ownership vacancy rate is 0.4 percent. Of the vacant units in the Town of Los
Gatos, the most common type of vacancy is Other Vacant, which represents almost half of all vacant rental
units15F
16. Figure B-21 shows vacant units by type.
14 For more information, see pages 3 through 6 of this list of definitions prepared by the Census Bureau:
https://www.census.gov/housing/hvs/definitions.pdf.
15 See Dow, P. (2018). Unpacking the Growth in San Francisco’s Vacant Housing Stock: Client Report for the San Francisco Planning Department. University
of California, Berkeley.
16 The vacancy-rates-by-tenure is for a smaller universe than the total vacancy rate first reported, which in principle includes the full stock (7.5 percent).
The vacancy by tenure counts are rates relative to the rental stock (occupied and vacant) and ownership stock (occupied and vacant) but exclude a
significant number of vacancy categories, including the numerically significant other vacant.
HCD Draft Initial Review 2023-2031 Housing Element
B-24 Appendix B October 2022
Figure B-21 Los Gatos Vacant Units by Type
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25004. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table HSG-03.
NOTE: Universe: Vacant housing units.
Between 2015 and 2020, 502 housing units were issued building permits in the Town of Los Gatos. Of those,
approximately percent were for above moderate-income housing, approximately percent were for moderate-
income housing, and approximately 1.0 percent were for low-income, and approximately 17.0 percent were for
very low-income housing. Table B-2 shows residential building permits issued by the Town of Los Gatos by
income group.
Table B-2 Los Gatos, Residential Building Permits by Income Group, 2015 to 2020
Income Group Number Percent
Very Low-Income Permits 49 revise all below
Low-Income Permits 3
Moderate-Income Permits 119
Above Moderate-Income Permits 331
Total 502 100.0%
SOURCE: California Department of Housing and Community Development (HCD), 5th Cycle Annual Progress Report Permit Summary
(2020). Data from ABAG/MTC Housing Needs Data Packet Workbook, Table HSG-11.
NOTE: Universe: Housing permits issued between 2015 and 2021. Notes: HCD uses the following definitions for the four income categories:
Very Low Income: units affordable to households making less than 50 percent of the Area Median Income for the county in which the
jurisdiction is located. Low Income: units affordable to households making between 50 percent and 80 percent of the Area Median Income
for the county in which the jurisdiction is located. Moderate Income: units affordable to households making between 80 percent and 120
percent of the Area Median Income for the county in which the jurisdiction is located. Above Moderate Income: units affordable to
households making above 120 percent of the Area Median Income for the county in which the jurisdiction is located.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-25
Assisted Housing Developments At-Risk of Conversion
While there is a need to produce new affordable housing units, ensuring that the existing affordable housing stock
remains affordable is also important. Additionally, it is typically faster and less expensive to preserve currently
affordable units that are at risk of converting to market-rate than it is to build new affordable housing.
The data in the table below comes from the California Housing Partnership’s Preservation Database, the State’s
most comprehensive source of information on subsidized affordable housing at risk of losing its affordable status
and converting to market-rate housing16F
17. According to the data, there are 169 assisted units in the Town of Los
Gatos. Of these units, none were at high risk or very high risk of conversion. Table B-3 summarizes assisted
units at risk in the Town of Los Gatos.
Table B-3 Assisted Units at Potential Risk of Conversion
Income Los Gatos Santa Clara County Bay Area
Low-Income Units 169 28,001 110,177
Moderate-Income Units 0 1,471 3,375
High-Income Units 0 422 1,854
Very High-Income Units 0 270 1,053
Total 169 30,164 116,459
SOURCE: California Housing Partnership, Preservation Database (2020). Data from ABAG/MTC Housing Needs Data Packet Workbook,
Table RISK01.
NOTE: Universe: HUD, Low-Income Housing Tax Credit (LIHTC), USDA, and CalHFA projects. Subsidized or assisted developments that do
not have one of the aforementioned financing sources may not be included. While California Housing Partnership’s Preservation Database
is the state’s most comprehensive source of information on subsidized affordable housing at risk of losing its affordable status and
converting to market-rate housing, this database does not include all deed-restricted affordable units in the state. Consequently, there
may be at-risk assisted units in a jurisdiction that are not captured in this data table. Per HCD guidance, local jurisdictions must also list
the specific affordable housing developments at-risk of converting to market rate uses. This document provides aggregate numbers of at
risk units for each jurisdiction, but local planning staff should contact Danielle Mazzella with the California Housing Partnership at
dmazzella@chpc.net to obtain a list of affordable properties that fall under this designation. California Housing Partnership uses the
following categories for assisted housing developments in its database: Very-High Risk: affordable homes that are at-risk of converting to
market rate within the next year that do not have a known overlapping subsidy that would extend affordability and are not owned by a
large/stable non-profit, mission-driven developer. High Risk: affordable homes that are at-risk of converting to market rate in the next 1-5
years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit,
mission-driven developer. Moderate Risk: affordable homes that are at-risk of converting to market rate in the next 5-10 years that do
not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven
developer. Low Risk: affordable homes that are at-risk of converting to market rate in 10+ years and/or are owned by a large/stable non-
profit, mission-driven developer.
Substandard Housing
Housing costs in the region are among the highest in the country, which could result in households, particularly
renters, needing to live in substandard conditions in order to afford housing. Generally, there is limited data on
the extent of substandard housing issues in a community. However, the Census Bureau data included in the
graph below gives a sense of some of the substandard conditions that may be present in Los Gatos. For
example, 4.1 percent of renters in Los Gatos reported lacking a kitchen and 1.4 percent of renters lack plumbing,
compared to 0.4 percent of owners who lack a kitchen and 0.6 percent of owners who lack plumbing. Figure B-22
shows substandard housing issues in Los Gatos.
17 This database does not include all deed-restricted affordable units in the state, so there may be at-risk assisted units in a jurisdiction that are not
captured in this data table.
HCD Draft Initial Review 2023-2031 Housing Element
B-26 Appendix B October 2022
Figure B-22 Los Gatos Substandard Housing Issues
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25053, Table B25043, Table B25049 Data
from ABAG/MTC Housing Needs Data Packet Workbook, Table HSG-06.
NOTES: Universe: Occupied housing units. Per HCD guidance, this data should be supplemented by local estimates of units needing to be
rehabilitated or replaced based on recent windshield surveys, local building department data, knowledgeable builders/developers in the
community, or nonprofit housing developers or organizations.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-27
Home and Rent Values
Home prices reflect a complex mix of supply and demand factors, including an area’s demographic profile, labor
market, prevailing wages, and job outlook, coupled with land and construction costs. In the Bay Area, the costs of
housing have long been among the highest in the nation.
The typical home value in Los Gatos was estimated at $2,109,040 in December of 2020, per data from Zillow.
The largest proportion of homes were valued in excess of $2 million. By comparison, the typical home value is
$1,290,970 in Santa Clara County and $1,077,230 in the Bay Area, with the largest share of units valued $1
million to $1.5 million (county) and $500 thousand to $750 thousand (region). Figure B-23 shows home values of
owner-occupied housing units in Los Gatos.
Figure B-23 Home Values of Owner-Occupied Units
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25075. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table HSG-07.
NOTE: Universe: Owner-occupied units.
The region’s home values have increased steadily since 2000, besides a decrease during the Great Recession.
The rise in home prices has been especially steep since 2012, with the median home value in the Bay Area
nearly doubling during this time. Since 2001, the typical home value has increased 164.0 percent in Los Gatos
from $798,770 to $2,109,040. This change is considerably greater than the change in Santa Clara County and for
the region as a whole. Figure B-24 shows Zillow home value index for Los Gatos.
HCD Draft Initial Review 2023-2031 Housing Element
B-28 Appendix B October 2022
Figure B-24 Zillow Home Value Index (ZHVI)
SOURCE: Zillow, Zillow Home Value Index (ZHVI). Data from ABAG/MTC Housing Needs Data Packet Workbook, Table HSG-08.
NOTES: Universe: Owner-occupied housing units. Zillow describes the ZHVI as a smoothed, seasonally adjusted measure of the typical
home value and market changes across a given region and housing type. The ZHVI reflects the typical value for homes in the 35th to 65th
percentile range. The ZHVI includes all owner-occupied housing units, including both single-family homes and condominiums. More
information on the ZHVI is available from Zillow. The regional estimate is a household-weighted average of county-level ZHVI files, where
household counts are yearly estimates from DOF’s E-5 series For unincorporated areas, the value is a population weighted average of
unincorporated communities in the county matched to census-designated population counts.
Similar to home values, rents have also increased dramatically across the Bay Area in recent years. Many
renters have been priced out, evicted, or displaced, particularly communities of color. Residents finding
themselves in one of these situations may have had to choose between commuting long distances to their jobs
and schools or moving out of the region, and sometimes, out of the State.
In Los Gatos, the largest proportion of rental units rented in the ‘rent $2,000-$2,500 category’, totaling 24.2
percent, followed by 23.7 percent of units renting in the ‘rent $3,000 or More category.’ Looking beyond the
Town, the largest share of units in Santa Clara County is in the ‘rent $2,000-$2,500 category’, compared to the
‘rent $1,500-$2,000 category’ for the Bay Area as a whole. Figure B-25 shows contract rents for renter-occupied
units in Los Gatos, Santa Clara County, and the Bay Area as a whole.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-29
Figure B-25 Contract Rents for Renter-Occupied Units
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25056. Data from ABAG/MTC Housing
Needs Data Packet Workbook, Table HSG-09.
NOTE: Universe: Renter-occupied housing units paying cash rent.
Since 2009, the median rent has increased by 33.5 percent in the Town of Los Gatos, from $1,700 to $2,270 per
month. In Santa Clara County, the median rent has increased 39.6 percent, from $1,540 to $2,150. The median
rent in the region has increased significantly during this time from $1,200 to $1,850, a 54.2 percent increase17F
18.
Figure B-25 shows median contract rent in the Town of Los Gatos, Santa Clara County, and the Bay Area as a
whole.
18 While the data on home values shown in Figure B-24 comes from Zillow, Zillow does not have data on rent prices available for most Bay Area
jurisdictions. To have a more comprehensive dataset on rental data for the region, the rent data in this document comes from the U.S. Census Bureau’s
American Community Survey, which may not fully reflect current rents. Local jurisdiction staff may want to supplement the data on rents with local realtor
data or other sources for rent data that are more current than Census Bureau data.
HCD Draft Initial Review 2023-2031 Housing Element
B-30 Appendix B October 2022
Figure B-26 Median Contract Rent
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data releases, starting with 2005-2009 through 2015-2019, B25058,
B25056 (for unincorporated areas). County and regional counts are weighted averages of jurisdiction median using B25003 rental unit
counts from the relevant year. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table HSG-10.
NOTES: Universe: Renter-occupied housing units paying cash rent. For unincorporated areas, median is calculated using distribution in
B25056.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-31
Overpayment and Overcrowding
A household is considered “cost-burdened” if it spends more than 30 percent of its monthly income on housing
costs, while those who spend more than 50 percent of their income on housing costs are considered “severely
cost-burdened.” Low-income residents are the most impacted by high housing costs and experience the highest
rates of cost burden. Spending such large portions of their income on housing puts low-income households at
higher risk of displacement, eviction, or homelessness. While the housing market has resulted in home prices
increasing dramatically, homeowners often have mortgages with fixed rates, whereas renters are more likely to be
impacted by market increases.
When looking at the cost burden across tenure in the Town of Los Gatos, 20 percent of renters spend 30 percent
to 50 percent of their income on housing compared to 16 percent of those that own. Additionally, 22 percent of
renters are severely cost-burdened (i.e., spend 50 percent or more of their income on housing), while 12 percent
of owners are severely cost-burdened. Figure B-27 shows cost burden by tenure.
Figure B-27 Cost Burden by Tenure, Los Gatos
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25070, B25091. Data from ABAG/MTC
Housing Needs Data Packet Workbook, Table OVER-06.
NOTES: Universe: Occupied housing units. Cost burden is the ratio of housing costs to household income. For renters, housing cost is
gross rent (contract rent plus utilities). For owners, housing cost is “select monthly owner costs”, which includes mortgage payment,
utilities, association fees, insurance, and real estate taxes. HUD defines cost-burdened households as those whose monthly housing costs
exceed 30 percent of monthly income, while severely cost-burdened households are those whose monthly housing costs exceed 50
percent of monthly income.
When one looks at both renters and owners together in the Town of Los Gatos, 15.6 percent of households spend
50 percent or more of their income on housing, while 17 percent spend 30 percent to 50 percent. However, these
rates vary greatly across income categories. For example, 78.3 percent of Los Gatos households making less
than 30 percent of AMI spend the majority of their income on housing. For Los Gatos residents making more than
100 percent of AMI, just 3.7 percent are severely cost-burdened, and 83.9 percent of those making more than 100
percent of AMI spend less than 30 percent of their income on housing. Figure B-28 shows cost burden by income
level.
HCD Draft Initial Review 2023-2031 Housing Element
B-32 Appendix B October 2022
Figure B-28 Cost Burden by Income Level, Los Gatos
SOURCE: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS
tabulation, 2012-2017 release. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table OVER-05.
NOTES: Universe: Occupied housing units. Cost burden is the ratio of housing costs to household income. For renters, housing cost is gross
rent (contract rent plus utilities). For owners, housing cost is “select monthly owner costs”, which includes mortgage payment, utilities,
association fees, insurance, and real estate taxes. HUD defines cost-burdened households as those whose monthly housing costs exceed
30 percent of monthly income, while severely cost-burdened households are those whose monthly housing costs exceed 50 percent of
monthly income. Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different
metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland
Fremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties),
San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro
Area (Solano County). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is located.
Currently, people of color18F
19 are more likely to experience poverty and financial instability as a result of Federal,
State, and local housing policies that have historically excluded them from the same opportunities extended to
white residents. As a result, they often pay a greater percentage of their income on housing, and in turn, are at a
greater risk of housing insecurity.
Hispanic or Latinx residents are the most severely cost burdened with 22 percent spending more than 50 percent
of their income on housing. Figure B-29 shows cost burden by race.
19 As before, this category as it is used here includes all non-White persons.
3.7%
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-33
Figure B-29 Cost Burden by Race, Los Gatos
SOURCE: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS
tabulation, 2012-2017 release. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table OVER-08.
NOTES: Universe: Occupied housing units. Cost burden is the ratio of housing costs to household income. For renters, housing cost is gross
rent (contract rent plus utilities). For owners, housing cost is “select monthly owner costs”, which includes mortgage payment, utilities,
association fees, insurance, and real estate taxes. HUD defines cost-burdened households as those whose monthly housing costs exceed
30 percent of monthly income, while severely cost-burdened households are those whose monthly housing costs exceed 50 percent of
monthly income. For the purposes of this graph, the “Hispanic or Latinx” racial/ethnic group represents those who identify as having
Hispanic/Latinx ethnicity and may also be members of any racial group. All other racial categories on this graph represent those who
identify with that racial category and do not identify with Hispanic/Latinx ethnicity.
Large family households often have special housing needs due to a lack of adequately sized affordable housing
available. The higher costs required for homes with multiple bedrooms can result in larger families experiencing a
disproportionate cost burden than the rest of the population and can increase the risk of housing insecurity.
In the Town of Los Gatos, 12.2 percent of large family households experience a cost burden of 30 to 50 percent,
while 9.6 percent of households spend more than half of their income on housing. Some 17.8 percent of all other
households have a cost burden of 30 percent to 50 percent, with 16.8 percent of households spending more than
50 percent of their income on housing. Figure B-30 shows cost burden by household size.
HCD Draft Initial Review 2023-2031 Housing Element
B-34 Appendix B October 2022
Figure B-30 Cost Burden by Household Size, Los Gatos
SOURCE: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS
tabulation, 2012-2017 release. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table OVER-09.
NOTES: Universe: Occupied housing units. Cost burden is the ratio of housing costs to household income. For renters, housing cost is gross
rent (contract rent plus utilities). For owners, housing cost is “select monthly owner costs”, which includes mortgage payment, utilities,
association fees, insurance, and real estate taxes. HUD defines cost-burdened households as those whose monthly housing costs exceed
30 percent of monthly income, while severely cost-burdened households are those whose monthly housing costs exceed 50 percent of
monthly income.
When cost-burdened seniors are no longer able to make house payments or pay rents, displacement from their
homes can occur, putting further stress on the local rental market or forcing residents out of the community they
call home. Understanding how seniors might be cost-burdened is of particular importance due to their special
housing needs, particularly for low-income seniors.
In the Town of Los Gatos, 74 percent of seniors making less than 30 percent of AMI are spending the majority of
their income on housing. For seniors making more than 100 percent of AMI, only 4.3 percent are spending the
majority of their income on housing. Figure B-31 shows cost-burdened senior households by income level.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-35
Figure B-31 Cost-Burdened Senior Households by Income Level, Los Gatos
SOURCE: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS
tabulation, 2012-2017 release. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table SEN-03.
NOTES: Universe: Senior households. For the purposes of this graph, senior households are those with a householder who is aged 62 or
older. Cost burden is the ratio of housing costs to household income. For renters, housing cost is gross rent (contract rent plus utilities).
For owners, housing cost is “select monthly owner costs”, which includes mortgage payment, utilities, association fees, insurance, and real
estate taxes. HUD defines cost-burdened households as those whose monthly housing costs exceed 30 percent of monthly income, while
severely cost-burdened households are those whose monthly housing costs exceed 50 percent of monthly income. Income groups are
based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan areas, and the nine county
Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda and Contra
Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area
(Santa Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro Area (Solano County). The AMI levels in this
chart are based on the HUD metro area where this jurisdiction is located.
Overcrowding occurs when the number of people living in a household is greater than the home was designed to
hold19F
20. The Census Bureau considers units with more than 1.5 occupants per room to be severely overcrowded.
Overcrowding is often related to the cost of housing and can occur when demand in a town, city, or region is high.
In many towns and cities, overcrowding is seen more amongst those that are renting, with multiple households
sharing a unit to make it possible to stay in their communities. In the Town of Los Gatos, 4.3 percent of
households that rent are severely overcrowded (i.e., more than 1.5 occupants per room), compared to 0.3 percent
of households that own. Figure B-32 shows overcrowding by tenure and severity.
20 There are several different standards for defining overcrowding, but this report uses the Census Bureau definition, which is more than one occupant per
room (not including bathrooms or kitchens).
HCD Draft Initial Review 2023-2031 Housing Element
B-36 Appendix B October 2022
Figure B-32 Los Gatos Overcrowding by Tenure and Severity
SOURCE: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS
tabulation, 2012-2017 release. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table OVER-01.
NOTES: Universe: Occupied housing units. The Census Bureau defines an overcrowded unit as one occupied by 1.01 persons or more per
room (excluding bathrooms and kitchens), and units with more than 1.5 persons per room are considered severely overcrowded.
Overcrowding often disproportionately impacts low-income households. In Los Gatos, less than one percent of
very low-income households (i.e., below 50 percent AMI) experience severe overcrowding. The income group
most experiencing severe overcrowding is the 81%-100% of AMI group. Figure B-33 shows overcrowding by
income level and severity.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-37
Figure B-33 Los Gatos Overcrowding by Income Level and Severity
SOURCE: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS
tabulation, 2012-2017 release. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table OVER-04.
NOTES: Universe: Occupied housing units. The Census Bureau defines an overcrowded unit as one occupied by 1.01 persons or more per
room (excluding bathrooms and kitchens), and units with more than 1.5 persons per room are considered severely overcrowded. Income
groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan areas, and the
nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda
and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara
Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro Area (Solano County). The AMI
levels in this chart are based on the HUD metro area where this jurisdiction is located.
Communities of color are more likely to experience overcrowding similar to how they are more likely to experience
poverty, financial instability, and housing insecurity. People of color tend to experience overcrowding at higher
rates than White residents. In Los Gatos, the racial group with the largest overcrowding rate is Hispanic or Latinx.
Figure B-34 shows overcrowding by race.
HCD Draft Initial Review 2023-2031 Housing Element
B-38 Appendix B October 2022
Figure B-34 Overcrowding by Race, Los Gatos
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25014. Data from ABAG/MTC Housing
Needs Data Packet Workbook, Table OVER-03.
NOTES: Universe: Occupied housing units. The Census Bureau defines an overcrowded unit as one occupied by 1.01 persons or more per
room (excluding bathrooms and kitchens), and units with more than 1.5 persons per room are considered severely overcrowded. For this
table, the Census Bureau does not disaggregate racial groups by Hispanic/Latinx ethnicity. However, data for the white racial group is
also reported for white householders who are not Hispanic/Latinx. Since residents who identify as white and Hispanic/Latinx may have
very different experiences within the housing market and the economy from those who identify as white and non-Hispanic/Latinx, data for
multiple white sub-groups are reported here. The racial/ethnic groups reported in this table are not all mutually exclusive. Therefore, the
data should not be summed as the sum exceeds the total number of occupied housing units for this jurisdiction. However, all groups
labelled “Hispanic and Non-Hispanic” are mutually exclusive, and the sum of the data for these groups is equivalent to the total number of
occupied housing units.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-39
B.4 Special Housing Needs
Large Households
Large households often have different housing needs than smaller households. If the Town’s rental housing stock
does not include larger apartments, large households who rent could end up living in overcrowded conditions.
In Los Gatos, for large households with five or more persons, most units were owner occupied. Figure B-35
shows household size by tenure.
Figure B-35 Household Size by Tenure, Los Gatos
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25009. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table LGFEM-01.
NOTE: Universe: Occupied housing units.
The unit sizes available in a community affect the household sizes that can access that community. Large
families are generally served by housing units with three or more bedrooms, of which there are 7,760 units in the
Town of Los Gatos. Among these large units, most are owner occupied. Figure B-36 summarizes housing units
by the number of bedrooms.
HCD Draft Initial Review 2023-2031 Housing Element
B-40 Appendix B October 2022
Figure B-36 Housing Units by Number of Bedrooms, Los Gatos
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25042. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table HSG-05.
NOTE: Universe: Housing units.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-41
Female-Headed Households
Households headed by one person are often at greater risk of housing insecurity, particularly female-headed
households, who may be supporting children or a family with only one income.
In the Town of Los Gatos, the largest proportion of households is Married-Couple Family Households at 58.1
percent of the total, while Female-Headed Family Households make up 8 percent of all households. Figure B-37
provides information on household type in Los Gatos.
Figure B-37 Household Type
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B11001. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table POPEMP-23.
NOTES: Universe: Households. For data from the Census Bureau, a “family household” is a household where two or more people are
related by birth, marriage, or adoption. “Non-family households” are households of one person living alone, as well as households where
none of the people are related to each other.
Female-headed households with children may face particular housing challenges, with pervasive gender
inequality resulting in lower wages for women. Moreover, the added need for childcare can make finding a home
that is affordable more challenging.
In Los Gatos, 36 female-headed households with children (eight percent) fell in the Below Poverty Level category,
while 26 female-headed households without children (five percent) fell in the Below Poverty Level category.
Figure B-38 shows female-headed households by poverty status.
HCD Draft Initial Review 2023-2031 Housing Element
B-42 Appendix B October 2022
Figure B-38 Female-Headed Households by Poverty Status, Los Gatos
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B17012. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table LGFEM-05.
NOTES: Universe: Female Households. The Census Bureau uses a federally defined poverty threshold that remains constant throughout the
country and does not correspond to Area Median Income.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-43
Seniors
Senior households often experience a combination of factors that can make accessing or keeping affordable
housing a challenge. They often live on fixed incomes and are more likely to have disabilities, chronic health
conditions, and/or reduced mobility. Seniors who rent may be at even greater risk for housing challenges than
those who own, due to income differences between these groups.
In the Town of Los Gatos, the largest proportion of senior households who rent fell into one of the categories
below the Greater than 100% AMI category, while the largest proportion of senior households who are
homeowners fell in the Greater than 100% AMI category. Figure B-39 shows senior households by income and
tenure.
Figure B-39 Senior Households by Income and Tenure, Los Gatos
SOURCE: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS
tabulation, 2012-2017 release. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table SEN-01.
NOTES: Universe: Senior households. For the purposes of this graph, senior households are those with a householder who is aged 62 or
older. Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan
areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro
Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose
Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro Area
(Solano County). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is located.
People with Disabilities
People with disabilities face additional housing challenges. Encompassing a broad group of individuals living with
a variety of physical, cognitive, and sensory impairments, many people with disabilities live on fixed incomes and
are in need of specialized care, yet often rely on family members for assistance due to the high cost of care.
When it comes to housing, people with disabilities are not only in need of affordable housing, but accessibly
designed housing, which offers greater mobility and opportunity for independence. Unfortunately, the need
typically outweighs what is available, particularly in a housing market with such high demand. People with
disabilities are at a high risk for housing insecurity, homelessness, and institutionalization, particularly when they
lose aging caregivers.
HCD Draft Initial Review 2023-2031 Housing Element
B-44 Appendix B October 2022
Overall, 9 percent of people in Los Gatos have a disability of some kind.20F
21 Figure B-40 shows the rates at which
different disabilities are present among residents of Los Gatos.
Figure B-40 Disability by Type, Los Gatos
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B18102, Table B18103, Table B18104, Table
B18105, Table B18106, Table B18107. Data from ABAG/MTC Housing Needs Data Packet Workbook, Table DISAB-01.
NOTES: Universe: Civilian noninstitutionalized population 18 years and over. These disabilities are counted separately and are not
mutually exclusive, as an individual may report more than one disability. These counts should not be summed. The Census Bureau
provides the following definitions for these disability types: Hearing difficulty: deaf or has serious difficulty hearing. Vision difficulty: blind
or has serious difficulty seeing even with glasses. Cognitive difficulty: has serious difficulty concentrating, remembering, or making
decisions. Ambulatory difficulty: has serious difficulty walking or climbing stairs. Self-care difficulty: has difficulty dressing or bathing.
Independent living difficulty: has difficulty doing errands alone such as visiting a doctor’s office or shopping.
State law also requires a Housing Element to examine the housing needs of people with developmental
disabilities. Developmental disabilities are defined as severe, chronic, and attributed to a mental or physical
impairment that begins before a person turns 18 years old. This can include Down’s Syndrome, autism, epilepsy,
cerebral palsy, and mild to severe intellectual disability. Some people with developmental disabilities are unable
to work, rely on supplemental security income, and live with family members. In addition to their specific housing
needs, they are at increased risk of housing insecurity after an aging parent or family member is no longer able to
care for them21F
22.
In the Town of Los Gatos, there are 50 children under the age of 18 with a developmental disability (40.7
percent), while there are 73 adults with a developmental disability (60 percent). Table B-4 below shows the
number of persons in Los Gatos with developmental disabilities by age.
21 These disabilities are counted separately and are not mutually exclusive, as an individual may report more than one disability. These counts should not
be summed.
22 For more information or data on developmental disabilities in your jurisdiction, contact the Golden Gate Regional Center for Marin, San Francisco and
San Mateo Counties; the North Bay Regional Center for Napa, Solano and Sonoma Counties; the Regional Center for the East Bay for Alameda and Contra
Costa Counties; or the San Andreas Regional Center for Santa Clara County.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-45
Table B-4 Los Gatos Population with Developmental Disabilities by Age
Age Group Number
Age Under 18 50
Age 18+ 73
SOURCE: California Department of Developmental Services, Consumer Count by California ZIP Code and Age Group (2020). This table is
included in the Data Packet Workbook as Table DISAB-04.
NOTE: Universe: Population with developmental disabilities. Notes: The California Department of Developmental Services is responsible for
overseeing the coordination and delivery of services to more than 330,000 Californians with developmental disabilities including cerebral
palsy, intellectual disability, Down syndrome, autism, epilepsy, and related conditions. The California Department of Developmental
Services provides ZIP code level counts. To get jurisdiction-level estimates, ZIP code counts were cross walked to jurisdictions using census
block population counts from Census 2010 SF1 to determine the share of a ZIP code to assign to a given jurisdiction.
The most common living arrangement for individuals with disabilities is in Los Gatos is the home of
parent/family/guardian. Table B-5 shows the Los Gatos population with developmental disabilities by residence.
Table B-5 Los Gatos Population with Developmental Disabilities by Residence
Residence Type Number
Home of Parent/Family/Guardian 102
Foster/Family Home 9
Independent/Supported Living 7
Other 4
Community Care Facility 4
Intermediate Care Facility 0
SOURCE: California Department of Developmental Services, Consumer Count by California ZIP Code and Residence Type (2020). This table
is included in the Data Packet Workbook as Table DISAB-05.
NOTE: Universe: Population with developmental disabilities. Notes: The California Department of Developmental Services is responsible for
overseeing the coordination and delivery of services to more than 330,000 Californians with developmental disabilities including cerebral
palsy, intellectual disability, Down syndrome, autism, epilepsy, and related conditions. The California Department of Developmental
Services provides ZIP code level counts. To get jurisdiction-level estimates, ZIP code counts were cross walked to jurisdictions using census
block population counts from Census 2010 SF1 to determine the share of a ZIP code to assign to a given jurisdiction.
Homelessness
Homelessness remains an urgent challenge in many communities across the State, reflecting a range of social,
economic, and psychological factors. Rising housing costs result in increased risks of community members
experiencing homelessness. Many residents have found themselves housing insecure and ended up homeless in
recent years, either temporarily or longer term. Addressing the specific housing needs for the unhoused
population remains a priority throughout the region, particularly since homelessness is disproportionately
experienced by people of color, people with disabilities, those struggling with addiction, and those dealing with
traumatic life circumstances.
In Santa Clara County, the most common type of household experiencing homelessness are those without
children in their care. Among households experiencing homelessness that do not have children, 87 percent are
unsheltered. Of homeless households with children, most are sheltered in an emergency shelter. Figure B-41
shows household type and shelter status in Santa Clara County.
HCD Draft Initial Review 2023-2031 Housing Element
B-46 Appendix B October 2022
Figure B-41 Homelessness by Household Type and Shelter Status, Santa Clara County
SOURCE: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations
Reports (2019). Data from ABAG/MTC Housing Needs Data Packet Workbook, Table HOMELS-01.
NOTES: Universe: Population experiencing homelessness. This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in
the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on
a single night during the last ten days in January. Each Bay Area county is its own CoC, and so the data for this table is provided at the
county-level. Per HCD’s requirements, jurisdictions will need to supplement this county-level data with local estimates of people
experiencing homelessness.
People of color are more likely to experience poverty and financial instability as a result of federal and local
housing policies that have historically excluded them from the same opportunities extended to
White residents. Consequently, people of color are often disproportionately impacted by homelessness,
particularly Black residents of the Bay Area.
In Santa Clara County, White (Hispanic and Non-Hispanic) residents represent the largest proportion of residents
experiencing homelessness and account for 44 percent of the homeless population, while making up 45 percent
of the overall population. Figure B-42 shows the racial group share of the homeless population.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-47
Figure B-42 Racial Group Share of General and Homeless Populations, Santa Clara County
SOURCE: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations
Reports (2019); U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001(A-I). Data from ABAG/MTC
Housing Needs Data Packet Workbook, Table HOMELS-02.
NOTES: Universe: Population experiencing homelessness. This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in
the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on
a single night during the last ten days in January. Each Bay Area county is its own CoC, and so the data for this table is provided at the
county-level. Per HCD’s requirements, jurisdictions will need to supplement this county-level data with local estimates of people
experiencing homelessness. HUD does not disaggregate racial demographic data by Hispanic/Latinx ethnicity for people experiencing
homelessness. Instead, HUD reports data on Hispanic/Latinx ethnicity for people experiencing homelessness in a separate table.
Accordingly, the racial group data listed here includes both Hispanic/Latinx and non-Hispanic/Latinx individuals.
In Santa Clara County, Latinx residents represent 42.7 percent of the population experiencing homelessness,
while Latinx residents comprise 25.8 percent of the general population. Figure B-43 shows the Latinx share of the
homeless population in Santa Clara County.
HCD Draft Initial Review 2023-2031 Housing Element
B-48 Appendix B October 2022
Figure B-43 Latinx Share of General and Homeless Populations, Santa Clara County
SOURCE: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations
Reports (2019); U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001(A-I). Data from ABAG/MTC
Housing Needs Data Packet Workbook, Table HOMELS-03.
NOTES: Universe: Population experiencing homelessness. This data is based on Point-in-Time (PIT) information provided to HUD by CoCs
in the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons
on a single night during the last ten days in January. Each Bay Area county is its own CoC, and so the data for this table is provided at the
county-level. Per HCD’s requirements, jurisdictions will need to supplement this county-level data with local estimates of people
experiencing homelessness. The data from HUD on Hispanic/Latinx ethnicity for individuals experiencing homelessness does not specify
racial group identity. Accordingly, individuals in either ethnic group identity category (Hispanic/Latinx or non-Hispanic/Latinx) could be of
any racial background.
Many of those experiencing homelessness are dealing with severe issues, including mental illness, substance
abuse, and domestic violence, which are potentially life threatening and require additional assistance.
In Santa Clara County, homeless individuals are commonly challenged by severe mental illness, with 2,659
reporting this condition. Of those, some 87.6 percent are unsheltered, further adding to the challenge of handling
the issue. Figure B-44 shows selected characteristics of the homeless population in Santa Clara County.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-49
Figure B-44 Characteristics for the Population Experiencing Homelessness, Santa Clara County
SOURCE: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations
Reports (2019). Data from ABAG/MTC Housing Needs Data Packet Workbook, Table HOMELS-04.
NOTES: Universe: Population experiencing homelessness. This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in
the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on
a single night during the last ten days in January. Each Bay Area county is its own CoC, and so the data for this table is provided at the
county-level. Per HCD’s requirements, jurisdictions will need to supplement this county-level data with local estimates of people
experiencing homelessness. These challenges/characteristics are counted separately and are not mutually exclusive, as an individual may
report more than one challenge/characteristic. These counts should not be summed.
In the Town of Los Gatos, there were no reported students experiencing homeless in the 2019-20 school year.
By comparison, Santa Clara County has seen a 3.5 percent increase in the population of students experiencing
homelessness since the 2016-17 school year, and the Bay Area population of students experiencing
homelessness decreased by 8.5 percent. During the 2019-2020 school year, there were still some 13,718
students experiencing homelessness throughout the region, adding undue burdens on learning and thriving, with
the potential for longer term negative effects. Table B-6 summarizes students in public schools experiencing
homelessness.
HCD Draft Initial Review 2023-2031 Housing Element
B-50 Appendix B October 2022
Table B-6 Students in Local Public Schools Experiencing Homelessness
Academic Year Los Gatos Santa Clara County Bay Area
2016-17 0 2,219 14,990
2017-18 0 2,189 15,142
2018-19 0 2,405 15,427
2019-20 0 2,297 13,718
SOURCE: California Department of Education, California Longitudinal Pupil Achievement Data System (CALPADS), Cumulative Enrollment
Data (Academic Years 2016-2017, 2017-2018, 2018-2019, 2019-2020). This table is included in the Data Packet Workbook as Table
HOMELS-05.
NOTE: Universe: Total number of unduplicated primary and short-term enrollments within the academic year (July 1 to June 30), public
schools. The California Department of Education considers students to be homeless if they are unsheltered, living in temporary shelters for
people experiencing homelessness, living in hotels/motels, or temporarily doubled up and sharing the housing of other persons due to the
loss of housing or economic hardship. The data used for this table was obtained at the school site level, matched to a file containing
school locations, geocoded and assigned to jurisdiction, and finally summarized by geography.
Farmworkers
Across the State, housing for farmworkers has been recognized as an important and unique concern.
Farmworkers generally receive wages that are considerably lower than other jobs and may have temporary
housing needs. Finding affordable housing can be challenging, particularly in the current housing market.
In the Town of Los Gatos, there were no reported students of migrant workers in the 2019-20 school year. The
trend for the region for the past few years has been a decline of 2 percent in the number of migrant worker
students since the 2016-17 school year. The change at the county level is a 50 percent decrease in the number
of migrant worker students since the 2016-17 school year. Table B-7 summarizes migrant worker student
population in the Town of Los Gatos, Santa Clara County, and the Bay Area as a whole.
Table B-7 Migrant Worker Student Population
Academic Year Los Gatos Santa Clara County Bay Area
2016-17 0 978 4,630
2017-18 0 732 4,607
2018-19 0 645 4,075
2019-20 0 492 3,976
SOURCE: California Department of Education, California Longitudinal Pupil Achievement Data System (CALPADS), Cumulative Enrollment
Data (Academic Years 2016-2017, 2017-2018, 2018-2019, 2019-2020). This table is included in the Data Packet Workbook as Table FARM
01.
NOTES: Universe: Total number of unduplicated primary and short-term enrollments within the academic year (July 1 to June 30), public
schools. The data used for this table was obtained at the school site level, matched to a file containing school locations, geocoded and
assigned to jurisdiction, and finally summarized by geography.
According to the U.S. Department of Agriculture Census of Farmworkers, the number of permanent farm workers
in Santa Clara County has increased since 2002, totaling 2,418 in 2017, while the number of seasonal farm
workers has decreased, totaling 1,757 in 2017. Figure B-45 shows farm operation and labor in Santa Clara
County.
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-51
Figure B-45 Farm Operations and Farm Labor by County, Santa Clara County
SOURCE: U.S. Department of Agriculture, Census of Farmworkers (2002, 2007, 2012, 2017), Table 7: Hired Farm Labor. For the data table
behind this figure, please refer to the Data Packet Workbook, Table FARM-02.
NOTES: Universe: Hired farm workers (including direct hires and agricultural service workers who are often hired through labor
contractors). Farm workers are considered seasonal if they work on a farm less than 150 days in a year, while farm workers who work on a
farm more than 150 days are considered to be permanent workers for that farm.
HCD Draft Initial Review 2023-2031 Housing Element
B-52 Appendix B October 2022
Non-English Speakers
California has long been an immigration gateway to the United States, which means that many languages are
spoken throughout the Bay Area. Since learning a new language is universally challenging, it is not uncommon
for residents who have immigrated to the United States to have limited English proficiency. This limitation can
lead to additional disparities if there is a disruption in housing, such as an eviction, because residents might not
be aware of their rights or they might be wary to engage due to immigration status concerns.
In the Town of Los Gatos, 1.7 percent of residents five years and older identified as speaking English not well or
not at all, which was below the proportion for Santa Clara County. Throughout the region the proportion of
residents five years and older with limited English proficiency was eight percent. Figure B-46 shows population
with limited English proficiency in the Town of Los Gatos, Santa Clara County, and the Bay Area as a whole.
Figure B-46 Population with Limited English Proficiency
SOURCE: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B16005. Data from ABAG/MTC Housing Needs
Data Packet Workbook, Table AFFH-03.
NOTE: Universe: Population 5 years and over.
Santa Clara County has approximately 23 emergency shelters, providing close to 800 beds year-round, with an
additional 300 beds available during the winter months (November through March). There are also over 1,100
transitional housing beds throughout the County that offer a combination of stable housing and intensive, targeted
support services for the mentally ill, those with chronic substance abuse, developmental disabilities, and other
factors that prevent the homeless from returning to permanent housing situations. Transitional housing includes
both single site and "scattered site" programs. Table B-8 below provides a summary of homeless facilities,
emergency shelters and transitional housing near the Town of Los Gatos.
1.7%
Appendix B. Housing Needs Assessment
October 2022 Appendix B B-53
Table B-8 Homeless Facilities Near Los Gatos
Facility Beds Target Population Location
Emergency Shelters
Asian Americans for Community
Involvement 12 Women with Children San Jose
City Team Rescue Mission 52 Single men San Jose
Hospitality House, Salvation Army 24 Single men San Jose
Our House Youth Services HomeFirst 10 Homeless and run-away youth San Jose
San Jose Family Shelter 143 Families San Jose
Support Network for Battered Women 18 Domestic violence shelter- women and
children San Jose
Emergency Shelter/Transitional Housing
InnVision 178 Working men, women & children, mentally
ill men & women San Jose
James Boccardo Reception Center 370 Families and single adults San Jose
Transitional Housing
Next Door- Women with Children 19 Domestic Violence Shelter -Women and
children San Jose
St. Josephs Cathedral 45 Worker housing- men, women and children San Jose
YWCA- Villa Nueva 126 Women and children San Jose
SOURCE: Santa Clara County Consolidated Plan, 2010-2015
Governmental and Non-Governmental Constraints C
APPENDIX
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-1
C.1 Governmental Constraints
Potential governmental constraints that impact housing development in Los Gatos include land use and zoning
regulations, building code standards and code compliance, Town design and development standards,
governmental fees and exactions, processing and permitting time, and local housing programs.
This appendix provides a full discussion of both governmental and non-governmental constraints that affect
housing in Los Gatos. Governmental constraints are policies, requirements, or other actions imposed by various
levels of government on land and housing ownership and development. Federal and State agency regulations
that may constrain development are beyond the control of the Town and are therefore not addressed in this
document. Non-governmental constraints are other conditions that impact housing development such as market
factors, environmental setting, and construction costs.
Land Use
On June 30, 2022, the Town Council adopted the 2040 General Plan and accompanying Environmental Impact
Report (EIR). As of September 27, 2022, The Land Use and Community Design Elements of the 2040 General
Plan are suspended pending the results of a referendum. In the interim, the Town’s 2020 General Plan Land Use
and Community Design Elements will govern during the suspension period.
Residential Designations
HR, Hillside Residential. The purpose of this designation very low density single-family residential and
accessory dwelling unit development on large lots or as part of a cluster development. This designation
allows for development that is compatible with the unique mountainous terrain and rural nature of the
hillside areas. Up to one dwelling unit per acre and maximum height of 25 feet.
LDR, Low Density Residential. The purpose of this designation is to provide for accessory dwelling units
and single-family residential purposes. It encourages single-family residential development in either the
standard development established by standard zoning or by innovative forms obtained through a planned
development. Densities range from 0 to five dwelling units per acre, a maximum height of 30 feet and up
to 40 percent lot coverage.
MDR, Medium Density Residential. The purpose of this designation is to provide for accessory dwelling
units, multi-family residential, duplexes, and/or small lot single-family homes. Mixed-use developments are
not permitted in this designation. Densities range from five to 12 units per acre, maximum height up to 30
feet or 35 feet when the building has below grade parking and lot coverage up to 40 percent.
HDR, High Density Residential. The purpose of this designation is to provide for accessory dwelling units,
and more dense multi-family residential development. Its objective is to provide quality housing in
proximity to transit and/or commercial and business areas. Mixed-use developments are not permitted in
this designation. Densities range from 12 to 20 units per acre, maximum height up to 30 feet or 35 feet
when the building has below grade parking and lot coverage up to 40 percent.
Commercial Designations
MU, Mixed-Use. The purpose of this designation is to provide a mixture of commercial uses (including
retail, office, hotel/lodging) and residential, along with allowing stand-alone commercial uses (including
retail, office, hotel/lodging, service uses, recreational uses, and restaurants). Residential is only allowed
when developed in a mixed-use format with retail, office, or hotel/lodging components on the site. Projects
developed under this designation shall maintain primary orientation to arterial street frontages and proper
transitions and buffers to adjacent residential properties. Densities range up to 20 units per acre, with a
maximum height up to 35 feet, and lot coverage up to 50 percent.
HCD Draft Initial Review 2023-2031 Housing Element
C-2 Appendix C October 2022
NC, Neighborhood Commercial. The purpose of this designation is to provide for necessary day-to-day
commercial goods and services required by the residents of the adjacent neighborhoods. This designation
encourages concentrated and coordinated commercial development at easily accessible locations.
Residential uses, developed using a mixed-use format, are allowed in the designation. Densities range up
to 20 units per acre, with a maximum height up to 35 feet, and lot coverage up to 50 percent.
CDB, Central Business District. The purpose of this designation is to encourage a mixture of community-
orientated commercial goods and services within the Downtown CBD. This designation applies exclusively
to the Downtown CBD, with the goal to accommodate and retain local merchants and preserve the Town’s
character. New development in the CBD shall integrate with existing structures of architectural and
historical significance. Residential uses, developed using a mixed-use format, are allowed in the
designation. Densities range up to 20 units per acre, maximum height up to 45 feet and a FAR up to 2.0.
Employment Center Designations
OP, Office Professional. The purpose of this designation is to provide for professional and general
business offices, incubator spaces, and innovation centers. This designation applies to various locations
throughout the Town, often in proximity to neighborhood- or community-oriented commercial facilities, or
as a buffer between commercial and residential uses. The intent of this designation is to satisfy the
community’s need for general business and professional services, and local employment. Residential
uses, developed using a mixed-use format, are allowed in the designation. Densities range up to 20 units
per acre, with a maximum height up to 35 feet and lot coverage up to 50 percent.
Specific Plan Designations
NF-SP, North Forty Specific Plan. The purpose of this designation is to provide land for the North 40
Specific Plan, which includes the designation of mixed-use development (residential and commercial, open
space amenities, and space for a hotel).
Town Code
The Town of Los Gatos Municipal Code provides zoning regulations that are more specific than the General Plan
Land Use designations. This section describes residential development standards, including accessory dwelling
units, overlay zones, and density bonuses. This section also analyzes constraints on housing for persons with
disabilities.
Residential Development Standards
There are seven residential and five commercial zoning districts in Los Gatos that allow residential uses. Table
C-1 provides the regulations for each zone.
Resource Conservation (RC)
Hillside Residential (HR)
Single-Family Residential (R-1)
Single-Family Residential Downtown (R-1 D)
Duplex Residential (RD)
Multi-family Residential (RM)
Neighborhood Commercial (C-1)
Central Business District (C-2)
Highway Commercial (CH)
Office (O)
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-3
Commercial Industrial Zone (LM)
As shown in Table C-1, development standards for each residential district could impede a project’s ability to
develop housing at a density of at least 35 dwelling units per acre on a site. The 30-foot height limit for the
majority of residential designations allows for up to three building stories and the maximum density of 20 dwelling
units per acre in the RM zone limits development.
Table C-1 also provides the parking requirements for residential development in Los Gatos, by zoning district.
Parking is often a significant component of the cost of residential development and can be viewed as a constraint
to the provision of housing. The Town has provided some flexibility in its parking requirements, particularly for
Planned Developments and for some developments providing affordable units for elderly and disabled persons,
generally easing the constraint of parking requirements on the development of higher density and affordable units.
As part of the Housing Element Update, programs to amend the Zoning Code and General Plan to ensure
adequate sites are available to accommodate the identified sites in the Sites Inventory are proposed and include
Amending the Zoning Code to include a Housing Element Overlay Zone (HEOZ) to apply to the sitesincluded in the Site Inventory to modify the development standards (i.e., density, lot coverage, floor arearatio, height) on those sites;
Amending the Affordable Housing Overlay Zone to increase the maximum allowable density from 20
dwelling units per acre to 30 dwelling units per acre;
Amending the North Forty Specific Plan to increase the maximum allowable density from 20 dwelling unitsper acre to more than 30 dwelling units per acre and increase the total number of dwelling units allowed inthe Specific Plan;
Clarifying the text of the non-residential zones that the housing sites contained in the inventory sites tablethat are in these zones must include housing;
Rezoning the Caltrans ROW (Site E3) to allow for residential development; and
Allowing for housing developments that are 100 percent affordable are allowed by-right in Mixed-UseGeneral Plan designation.
HCD Draft Initial Review 2023-2031 Housing Element
C-4 Appendix C October 2022
Table C-1 Residential and Commercial Development Standards by Zoning District
Notes: a Single-family, residential condominiums, and two-family dwellings must provide two parking spaces for each living unit and one additional visitor space for each residential unit is required. See
discussion below for information regarding required visitor spaces.
b The Town requires 1.5 parking spaces per unit for multiple-unit dwellings in all zones and two-family dwellings in the R-1D zone. One visitor parking space for each residential unit other than a detached single-family or two-family dwelling shall be required, unless the Planning Commission makes a finding that more or less visitor parking is necessary due to the size or type of housing unit(s).
c Setbacks vary depending on adjacent uses and streets for commercial designations
Zoning District Density Minimum Lot Area
Maximum Height (Feet)
Front Yard Setback (Feet)
Side Yard Setback (Feet)
Rear Yard Setback (Feet)
Parking Per Unit (No. of Spaces)
Other
RC 1 unit per lot 20 acres 25 30 20 25 2
HR HR-1: 1-5 acres per unit
HR-2.5: 2.5-10 acres per unit
HR-5: 5-40 acres per unit
HR-20: 20-160 acres per unit
40,000 sq. ft. 25 30 20 25 2 Density ranges are dependent
on hillside slope calculations.
R-1 R-1:8 8,000 sq. ft. 30 25 8 20 2
R-1:10 10,000 sq. ft. 30 25 10 20 2
R-1:12 12,000 sq. ft. 30 25 10 20 2
R-1:15 15,000 sq. ft. 30 25 12 25 2
R-1:20 20,000 sq. ft. 30 30 15 25 2
R-1:30 30,000 sq. ft. 30 30 16 25 2
R-1D 5,000 sq. ft. for
single-family
8,000 sq. ft. for
duplex
30 15 5 20
2 for single-
family and
two-family
dwellings
Architecture & Site is required
for all new primary buildings
R-D 8,000 sq. ft. 30 25 8 20 2
R-M
8,000 sq. ft. 30 25 8-10 20
Resident: 1.5
per unit a
Visitor: 1 per
unit b
Maximum height is 30 feet,
except when the building has
below grade parking the
maximum is 35 feet.
C-1 Up to20 units per acre N/A 35 15 0 0 c Dependent
on unit size Residential allowed with CUP
C-2 Up to 20 units per acre N/A 45 15 c 0 c 0 c Residential allowed with CUP.
CH Up to 20 units per acre N/A 35 25 c 15 c 20 c Residential allowed with CUP
O Up to 20 units per acre 8,000 sq. ft. 35 25 10 20 Residential allowed with CUP
LM Up to 20 units per acre 8,000 sq. ft. 35 15 c 0 c 0 c Live/work allowed with CUP
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-5
Overlay Zones
Four overlay zones in the Town Code, the Planned Development (PD) zone, the Landmark and Historic
Preservation (LHP) zone, the Affordable Housing Overlay Zone (AHOZ), and the Public School Zone (PS) that
apply to housing development in Los Gatos.
Planned Development (PD)
The PD overlay zone was updated in 2018 and is intended to preserve, enhance, and/or promote development
that highlights the Town’s characteristics. This includes natural and historic resources, production of affordable
housing, maximization of open space, and projects that provide a public benefit to the Town’s citizens. As an
incentive to housing development, the PD overlay provides alternative standards for housing developments with a
minimum of 40 percent of the units affordable to households of very low, low, or moderate income.
Landmark and Historic Preservation (LHP)
The LHP overlay zone designation is applied to individual sites, structures, or areas deemed as architecturally or
historically significant. There are five designated LHP overlay zones within the Town, including the Almond
Grove, Downtown Commercial, Fairview Plaza, and University-Edelen districts. Existing and proposed
structure(s) within these LHP overlay zones are subject to a special design standard and review process
regarding their appearance, use, and maintenance before the Historic Preservation Committee.
Affordable Housing Overlay Zone (AHOZ)
The AHOZ is intended to increase the supply and variety of housing types to promote tenure and affordability.
The AHOZ promotes densities, development standards and incentives that will encourage the production of
housing affordable to all income levels of the Town's RHNA allocation. The properties can be developed
consistent with the AHOZ development standards, densities and incentives or under the existing zoning
requirements, but not both. The 2023-2031 Housing Element lists the one property, the Southbay Development
located on Knowles Drive, east of Winchester Boulevard as a key housing opportunity site for a mixed income
affordable housing project. The designation of this site will assist the Town in meeting its fair share of the regions
housing needs required by the State.
The AHOZ permits development at a density of 20 units per acre by-right, with an Architecture and Site approval,
for projects in which at least half of the units are affordable to lower or moderate-income households. The AHOZ
provides a 30-foot building height with an automatic allowance for 35 feet for integrated (first floor) garage or
podium parking. Additional height can be granted through the Architecture and Site Plan review process. The 40
percent lot coverage and parking reduction is consistent with the State Density Bonus maximum parking
requirements. Further parking reductions are allowed for properties within a quarter mile of the planned Vasona
Light Rail Station, for senior-only housing and housing for persons with disabilities. All other property
development standards are consistent with the Town's R-M Standards.
The AHOZ also allows up to four automatic concessions. The concessions include reductions in:
Parking: one space for studio and one-bedroom units, two spaces for three-to-four-bedroom units, 2.5spaces for four or more-bedroom units, one space for units reserved for seniors or persons withdisabilities, reduction to one space per unit for developments within one-quarter mile to the proposedVasona Light Rail Station.
Setbacks: Any two property setbacks may be reduced by up to 50 percent.
Increase in lot coverage: The lot coverage may be increased up to 50 percent from 40 percent.
Processing fees: The Town shall waive or defer planning, engineering, and building processing fees,except those that are paid directly to Town consultants or for technical studies.The developer can select one of the following types of fees to be waived as one of the four availableconcessions:a.Planning and engineering application fees (but not Town consultant fees).b.Building plan check and inspection fees.c.Construction mitigation fee.
HCD Draft Initial Review 2023-2031 Housing Element
C-6 Appendix C October 2022
Priority processing: The Town gives projects the highest processing priority for planning entitlements,building plan check and building inspections.
The Valley Transportation Authority has deferred the development of the Vasona Light Rail Station indefinitely.
Given this recent development, the Town will initiate a Code amendment to reduce parking within a quarter mile
of transit stops as a further development incentive in the AHOZ.
Public School Zone (PS)
The PS Overlay Zone is intended to all school buildings to be used for community and educational purposes,
such as museums, community centers, and nurseries, without extensive exterior modifications. Any land owned
by a public school district may be designated as a PS overlay zone.
Multi-family Housing
Multi-family housing is permitted in a residential zone, including the R-M zone and is permitted in a mixed-use
development with a Conditional Use Permit (CUP) in the following commercial zoning districts, C-1, C-2, and CH
zones. One of the intents of these districts is to direct and facilitate housing of various density ranges. A
permitting process that is more onerous or uncertain for multi-family units than for single-family presents a
concern and could be considered a constraint on multi-family housing. In the R-M zone, the Town requires
apartments include one and a half parking spaces per unit, regardless of the number of bedrooms in the unit, plus
one visitor parking space for each apartment unit, unless the Planning Commission makes a finding that more or
fewer visitor parking is necessary due to the size or type of housing unit(s).
A CUP can increase risk and costs associate with the planning entitlement process act as a deterrent to housing
developers. Long permit processing times or permit processes that have a high degree of uncertainty (i.e.,
discretionary reviews or processes with multiple public meetings) increase the cost of housing for developers,
either by increasing their carrying costs as they wait for permits, or by increasing the chance that a project will be
rejected after a long wait. In either case, a developer working in a jurisdiction with an onerous permitting process
will demand higher profits to account for the increased risk, thereby increasing the overall development costs. In
order to remove this regulatory constraint, the Housing Element includes an Implementation Program to remove
the requirement for a CUP for residential development in zoning districts that current allow multi-family uses with
a CUP.
In Los Gatos, the predominant housing type in the Town is single family development which are allowed by right
in the R-M zone. When single family residences are allowed in higher density residential zoning districts, the
likelihood and ability of a developer constructing higher density residential units is diminished. Housing
developers face higher risk, including neighborhood opposition, when single-family homes are present in multi-
family zoning districts.
Manufactured Housing
Manufactured, otherwise known as prefabricated or factory-built, housing is constructed off-site and then
transported to the property. It is allowed in all residential districts in Los Gatos subject to its compliance with Town
regulations.
Transitional and Supportive Housing
According to California Health and Safety Code Section 50675.2, transitional housing is rental housing with, at
most, a six-month limit on the length of stay for tenants. Transitional housing would be available to homeless
individuals and/or families in need of temporary housing until they can secure more permanent housing. The
Town of Los Gatos Zoning Code uses the State’s definitions for transitional housing. Transitional housing is
permitted as a residential use consistent with State law.
According to California Health and Safety Code Section 50675.14, supportive housing is housing that is linked to
on- or off-site services and is occupied by low-income persons with mental disabilities, chronic health issues or
substance abuse issues or persons with disabilities that were developed before age 18. Supportive housing has
no limit on the length of stay for tenants. Supportive housing in Los Gatos consists of small family home
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-7
residential care facilities, which are permitted in all residential zoning districts except Mobile Home Residential
(RMH). In Los Gatos, licensed residential care facilities for six or less persons are allowed by right in all
residential districts consistent with California Health and Safety Code Section 1267.8.
Accessory Dwelling Unit (ADU)
Accessory dwelling units are complete independent housing units that can be either detached or attached from an
existing single-family residence. Based on their relatively small size, and because they do not require paying for
land or major new infrastructure, ADUs are considered affordable by design. ADUs can provide affordable
housing options for family members, seniors, students, in-home health care providers, and other small household
types. ADUs can also be useful to generate additional rental income for the homeowner, making homeownership
more financially feasible.
In 2020 the Town adopted Ordinance 2307, amending the Town Code to further address barriers to the
development of ADUs and to conform with a series of State bills aimed at encouraging single-family homeowners
to add ADUs to their property. Permitted zones allowing the ADUs include the R-1, R-D, R-M, R-1D, RMH, HR
and RC zones. The Town’s ADU Ordinance allows a 10 percent increase in the floor area ratio standards for an
ADU. All detached units must comply with lot coverage maximum of their designated zone. ADUs are not to
exceed 1,200 square feet. One parking space is required per unit or bedroom, unless the ADU is located within
half a mile of a transit stop.
A new ADU requires the submittal of an Accessory Dwelling Unit Application to the Community Development
Department. Over the past three years, the Town has averaged 50 ADUs per year. In order to further incentivize
production, a program to eliminate Building fees if the unit is deed restricted for very low- and low-income
households is included in the Housing Element.
Building and Code Compliance
In addition to the General Plan land use designations and Town Code, Los Gatos has recently adopted updated
building codes that enforce Town regulations with the purpose of protecting the lives, health, property, and public
welfare of Los Gatos residents. Each Code is an enforcement of State and local standards and is not considered
a constraint on housing production in Los Gatos. The following 2019 California Building Standards Codes have
been adopted, as amended by the Town:
Part 1 California Administrative Code.
Part 2 California Building Code, Volumes 1 and 2, including Appendices B, I, and J.
Part 2.5 California Residential Code including Appendices H, K, O, Q, S, V, and X.
Part 3 California Electrical Code.
Part 4 California Mechanical Code.
Part 5 California Plumbing Code including Appendices A, B, D, G, I, K, and L.
Part 6 California Energy Code.
Part 8 California Historical Building Code including Appendices A.
Part 9 California Fire Code.
Part 10 California Existing Building Code including 20118 International Existing Building Code Chapters 9
and 14, as well as Appendices A2, A3, A4, and A5.
Part 11 California Green Building Standards Code (CALGreen) Chapters 1 through8 only.
Part 12 California Referenced Standards Code.
2018 International Property Maintenance Code.
The Town also has a Code Compliance Officer that enforces the Town’s zoning regulations and building and
safety codes. The program reviews and responds to code complaints. The Town has adopted the 2018
HCD Draft Initial Review 2023-2031 Housing Element
C-8 Appendix C October 2022
International Code for Property Maintenance and the 2019 California Existing Building Code, including 2018
International Existing Building Code Chapters 9, 14, and Appendices A2, A3, A4, and A5. Affordable units
developed under the Below Market Price (BMP) Program must undergo an annual compliance audit.
On- and Off-Site Improvements
The Town requires standard on- and off-site improvements for development, which are intended to meet health
and safety requirements of the community. These standard improvements are not considered a constraint on
development because the Town does not include improvements beyond what is required to meet health and
safety requirements. Subdivision design standards for the Town, described in the Town Code starting at Section
29.10.06701, include the following on- and off-site improvements:
Parking bays may be required on narrow streets where parking may be prohibited on either or both sides
of the street.
Roadways must be paved with asphalt concrete.
Sidewalks are required on all streets in a subdivision unless the lots will be 20,000 feet in size or more.
Curbs and gutters must be constructed on all streets.
Culverts, storm drains, and drainage structures will be required in a subdivision.
Sanitary sewers with house service laterals are required to serve each lot, with some exceptions in hillside
areas.
Underground utilities with connections are required for each lot.
Street lighting shall be installed in accordance with Town standards
Design Guidelines and Objective Design Standards
The Town has adopted Residential Design Guidelines for single-family and two-family dwelling units, which
incorporate the Town’s previous Residential Pre-1941 Design Guidelines for historically significant structures,
sites, and historic districts in Los Gatos. The Town has also adopted Hillside Development Standards and
Guidelines. These sets of development standards and design guidelines are used in the development and design
review process for Los Gatos and complement the Town’s zoning regulations. The Hillside Development
Standards and Guidelines were adopted in January 2004 and modified in 2020. The Residential Design
Guidelines were updated and adopted in 2008.
The Town of Los Gatos is developing Objective Design Standards for the review of multi-family housing and
mixed-use development applications. This effort is in response to State legislation requiring jurisdictions to adopt
objective standards and to implement them in a streamlined review of qualifying housing projects. Objective
standards are defined under State law as “standards that involve no personal or subjective judgement by a public
official and are uniformly verifiable by reference to an external and uniform benchmark or criterion available and
knowable by both the development applicant or proponent and the public official prior to submittal” (California
Government Code, Section 65913.4).
On September 14, 2022, the Planning Commission reviewed and recommended approval of the Draft Objective
Design Standards with modifications. The Town Council is expected to consider the Draft Objective Design
Standards in mid-November 2022.
Residential Design Guidelines
Residential Design Guidelines in Los Gatos address the following design characteristics for single-family and two-
family dwelling units in all zoning districts except for the RC and HR zones:
Historic Designations. When necessitated by the designating ordinance, Historic Preservation
Committee review of a development is required for developments that affect a historically designated
property or are located in a historic district.
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-9
Site Development. This section focuses on the design and layout of the housing development in relation
to its site. Site planning issues addressed include site design, solar orientation, shadow effect, and
easements and dedications. This section provides information on landscaping requirements, sensitivity to
adjacent neighbors, and conformity to neighborhood street and sidewalk edges.
Building Design. This section focuses on the design and layout of development in relation to the
surrounding neighborhood. Issues addressed include harmony and compatibility with the streetscape and
surrounding structures; the scale and mass of the development including second-story additions,
significant remodels, demolitions and replacement structures, exterior material and colors, building
components, energy conservation, and privacy. Neighborhood compatibility for replacement structures
shall be based on the following criteria:
Existing architectural style of surrounding neighborhood.
Size of the lot on which the development is located.
Size of homes adjacent to the development and along the street on which the development is
located.
Transitioning neighborhood.
Impacts on the site and surrounding property.
Landscaping/Open Space. This section addresses tree preservation in accordance with Division 2 of the
Town Code for adherence to the Town’s Tree Protection Ordinance.
The Los Gatos Residential Design Guidelines promote safe, compatible, and well-designed housing in Los Gatos.
These standards are not a constraint on single-family and two-family housing development.
Hillside Development Standards and Guidelines
The Hillside Development Standards and Guidelines are consistent with the Town’s policies and complement and
coordinate with the Town’s Hillside Specific Plan. These standards and guidelines apply to all areas zoned HR,
RC, and some lots zoned R-1 as noted on the Town’s Hillside Area Map. The goal of these standards and
guidelines is to encourage high-quality design that incorporates sustainable development and open space
preservation.
The following summarizes the Hillside Development Standards and Guidelines for Los Gatos:
Constraints Analysis and Site Selection. Developers must conduct a constraints analysis as deemed
necessary by the Town, consult with neighbors, meet with Town staff to discuss the development site, and
conduct a view analysis for the development site. The constraints analysis, as required by the Town,
requires that developers of hillside property identify the Least Restrictive Development Area (LRDA), or
areas deemed most feasible for development on hillsides. For the view analysis, developers must analyze
aesthetic impacts; preserve hillside and ridgeline views; and preserve natural features, riparian corridors,
and wildlife.
Site Planning. This section describes site planning standards and guidelines that minimize physical and
aesthetic impacts to the site topography. Standards and guidelines discuss grading, drainage, driveways
and parking, and safety regarding geologic and fire hazards.
Development Intensity. This section outlines the maximum allowable floor area of development based
on lot size.
Architectural Design. The following architectural design characteristics are addressed in this section:
Neighbor-friendliness.
HCD Draft Initial Review 2023-2031 Housing Element
C-10 Appendix C October 2022
Sustainability.
Fire safety.
Building height.
Bulk and mass.
Roofs.
Architectural features and detailing.
Materials and colors.
Site Elements. The specific elements of a hillside development site are addressed:
Fences and walls.
Driveway entries.
Retaining walls.
Outdoor lighting.
Accessory buildings, swimming pools, and sport courts.
Impervious surfaces.
Landscape Design. Because hillside sites are more prone to erosion, landslides, mudslides, and fire and
water hazards than flatter sites in Los Gatos, the following concepts are addressed in the landscaping
standards and guidelines for hillside development:
Fire safety.
Garden and turf locations and plant selection.
Irrigation.
Impervious surfaces.
Plant materials.
Tree preservation.
Planned Development Projects. This section describes standards and guidelines that relate specifically
to hillside Planned Developments (PDs) in Los Gatos. Additional restrictions are placed on the LRDA for
PDs. This section includes standards and guidelines focusing on site preparation, drainage, lot
configuration and building locations, street layout and driveways, and trail design.
Draft Objective Design Standards
The purpose of the Objective Design Standards is to ensure that new qualifying multi-family and mixed-use
projects in Los Gatos provide high-quality architecture, integrate with surrounding development, and include well-
designed amenities and open spaces. The Objective Design Standards will:
Comply with recent State housing legislation.
Implement streamlined and ministerial review processes for qualifying projects.
Ensure that qualifying projects align with the Town’s expectations and vision to maintain and support the
character of the Town.
Provide a set of clear criteria to guide development.
Establish an objective framework by which a qualifying project will be evaluated.
The Draft Objective Design Standards are organized into two primary sections: Site Standards and Building
Design. The Site Standards section includes objective standards for site layout and building placement, vehicular
access and parking, and outdoor spaces and amenities. The Building Design section includes objective
standards for building form and massing, façade articulation, materials, and roof design.
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-11
The Draft Objective Design Standards are intended to promote predictable, safe, and well-designed multi-family
housing in Los Gatos. On September 14, 2022, the Planning Commission reviewed and recommended approval
of the Draft Objective Design Standards with modifications. The Town Council is expected to consider the Draft
Objective Design Standards in mid-November 2022.
Governmental Fees and Exactions
Government policy at both the State and jurisdictional levels play a major role in determining the costs of building
new housing. Regulations and permitting processes that result in lengthy or uncertain development carry higher
risk and increased financing. Additionally, frequent delays in the entitlement and approval process directly
increase costs, such as additional architectural work, inspections, and community meetings.
Streamlining permitting processes, applying permit application processes consistently, increasing
interdepartmental cooperation, having adequately funded and staffed planning departments, and increasing by-
right housing are all actions jurisdictions can take to reduce the constraints represented by fees and permit
processing times.
Governmental fees can be a significant portion of the cost of housing development and can therefore be
considered a constraint to housing development. Table C-2 below provides all of the planning and development
fees that may apply to residential development projects in Los Gatos. Fees are due at the time an application is
accepted by the Town, except for projects in the Affordable Housing Overlay Zone, which can waive or defer their
fees as a development incentive.
Development fees are a standard component of new construction. Although these fees can add to the cost of
residential development, they are necessary for new development to pay its fair share of municipal services and
infrastructure for new development. Without adequate development fees, the Town would be unable to serve
future growth with adequate municipal services. According to the Town of Los Gatos’ Community Development
Department Planning Division, developing a new single-family home (non-hillside) in Los Gatos typically costs
about $11,863.28 in planning fee plus an additional deposit of $2,750 for review by the Town’s consulting
architect and a deposit of $2,200 for a review by the Town’s consulting arborist. The fee for a new two-family unit
is $15,789.16. Multi-family units, three or more units typically cost $16,281.92 in planning fees and the same
consulting architect and arborist fees are applicable. These fees include Planning Commission or Design Review
Committee approval, fees associated with a Planned Development that does not require a General Plan or
Specific Plan amendment, and fees related to finalizing the map and Certificate of Compliance.
On May 4, 2021, the Town Council adopted Ordinance 2318 amending Chapter 25 of the Town Code to establish
a public art requirement for private developments. The requirement for public art will apply to following types of
development:
(a) New commercial developments (including mixed-use projects), including new construction, and additions
and remodels that add more than 50% square footage; and
(b) New residential projects of three or more units, including new construction, and additions and remodels
that add more than 50% square footage.
(c) Notwithstanding subsections (a) and (b) above, this Chapter shall not apply to:
(i)Affordable housing developments, or, if affordable housing is a part of the development, the affordable
housing units shall be subtracted from the valuation of the project as in subsection (d) below;
(ii)Historic renovations;
(iii)Repair or reconstruction of structures damaged by flood, fire, wind, earthquake, or other disaster;
(iv)Seismic retrofit projects;
(v)Single family and two-family residential units;
(vi) Accessory dwelling units or junior accessory dwelling units;
(vii) Any project exempted by federal or state law;
(viii) Municipal facilities; and
(ix) Buildings or structures primarily used for religious worship.
HCD Draft Initial Review 2023-2031 Housing Element
C-12 Appendix C October 2022
A developer may satisfy the requirements of Chapter 25 of the Town Code by constructing or installing on-site
public art valued at one percent of the building permit valuation.
Table C-2 Community Development Department Fees Effective July 1, 2022
Application
Fee
4% Permit
Tracking
Fee
10% General
Plan
Update
10%
Advance Planning
Special
Project
Engineering Dev Review
Services
Fee Total Fee
1 ZONING APPROVALS
A Architecture and Site Applications
1 Development Review Committee (DRC) Approval
a.New single-family detached
(HR & RC zone)$9,508.00 $380.32 N/A $950.80 $4,396.00 $15,235.12
b.New single-family detached
(HR & RC zones) per unit, as
part of a Planned
Development
$6,603.00 $264.12 N/A $660.30 $4,393.00 $11,920.42
c.New single-family or two-
family units $6,552.00 $262.08 N/A $655.20 $4,394.00 $11,863.28
d. New single-family or two-
family (any other zone) per
unit, as part of a Planned
Development
$4,682.00 $187.28 N/A $468.20 $4,398.00 $9,735.48
e.Minor projects (a
development proposal that
does not significantly change
the size, mass, appearance or
neighborhood impact of astructure, property or parking
lot)
$2,375.00 $95.00 N/A $237.50 $3,374.00 $6,081.50
2 Planning Commission Approval
a.Supplemental fee for DRC
applications as determined in
Section 1.A.(1) or minorresidential development
applications that require
Planning Commission approval
$3,355.00 $134.20 N/A $335.50 $1,225.00 $5,049.70
b.New two-family unit $9,994.00 $399.76 N/A $999.40 $4,396.00 $15,789.16
c.New nonresidential $11,471.00 $458.84 N/A $1,147.10 $4,396.00 $17,472.94
d.New multi-family $10,428.00 $417.12 N/A $1,042.80 $4,394.00 $16,281.92
e.All other $5,815.00 $232.60 N/A $581.50 $4,396.00 $11,025.10
B Conditional Use Permits
1 Conditional Use Permit $6,726.00 $296.04 N/A $672.60 $1,431.00 $9,098.64
2
Conditional Use Permit (when
consolidated with another
application for new
development)
$1,118.00 $44.72 N/A $111.80 $820.00 $2,094.52
C Variance $4,947.00 $197.88 N/A $494.70 $1,431.00 $7,070.58
D Rezoning (other than Planned
Development)
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-13
Application
Fee
4%
Permit
Tracking
Fee
10%
General
Plan
Update
10% Advance
Planning
Special
Project
Engineering
Dev Review
Services
Fee Total Fee
1 Without General Plan or
Specific Plan Amendment
Actual Cost
($5,000 min.)
$200
(min.)
$500
(min.)
$500
(min.) N/A $6,200.00
2 With General Plan or Specific
Plan Amendment
Actual Cost
($7,000 min.)
$280
(min.)
$700
(min.)
$700
(min.) N/A $8,680.00
E Planned Development
1 Without General Plan or
Specific Plan Amendment Actual Cost YES YES YES N/A Varies
2
Without General Plan or
specific Plan Amendment (HR
or RC Underlying Zone)
Actual Cost YES YES YES N/A Varies
3 With General Plan or Specific
Plan Amendment Actual Cost YES YES YES N/A Varies
4
With General Plan or Specific
Plan Amendment (HR or RC
Underlying Zone)
Actual Cost YES YES YES N/A Varies
5 Town Council Modification to a Planned Development Actual Cost ($5,000 min.) $200 (min.) $500 (min.) $500 (min.) N/A $6,200.00
6 DRC Modification to a Planned
Development Zone
Actual Cost
($3,000 min.)
$120
(min.)
$300
(min.)
$300
(min.) N/A $3,720.00
7 Publication costs for the Planned Development Ordinance shall be paid by the applicant.
F Minor Residential
Development $2,375.00 $95.00 N/A $237.50 N/A $2707.50
G Agricultural Preserve
Withdrawal $4,035.00 $161.40 N/A $403.50 N/A $4,599.90
H Planning Division Certificates of Use and Occupancy
1 Change of Use $244.00 $9.76 N/A $24.40 N/A $278.16
2
Change of occupancy
(excluding change of
proprietor of a continuing
business enterprise)
$164.00 $6.56 N/A $16.40 N/A $186.96
L Accessory Dwelling Unit
1 New or existing unit $1,419.00 $56.76 N/A $141.90 N/A $1,617.66
M Mobile Home Park Conversion
Permit
Actual Cost
($5,000 deposit) Varies Varies Varies N/A Varies
N General Plan/Town Code
Amendments
Actual Cost
($5,000 deposit) N/A N/A N/A N/A Varies
2 SUBDIVISIONS
A Lot Line Adjustment (DRC
Approval) $2,254.00 $90.16 N/A $225.40 $3,782.00 $6,351.56
B 4 Lots or Less (DRC Approval) $9,081.00 $363.24 $908.10 $908.10 $4,194.00 $15,454.44
C
4 Lots or Less (as part of a
Planned Development) (DRC
Approval)
$3,750.00 $150.00 $375.00 $375.00 $4,398.00 $9,048.00
D 5 Lots or More $10,230.00 $409.20 $1,023.00 $1,023.00 $5,420.00 $18,105.20
E
5 Lots or More (as part of a
Planned Development) (DRC
Approval)
$4,397.00 $175.88 $439.70 $439.70 $5,420.00 $10,872.28
HCD Draft Initial Review 2023-2031 Housing Element
C-14 Appendix C October 2022
Application
Fee
4%
Permit
Tracking
Fee
10%
General
Plan
Update
10%
Advance
Planning
Special
Project
Engineering
Dev Review
Services
Fee Total Fee
F Vesting Tentative Map Actual Cost
($500 deposit) N/A N/A N/A N/A Varies
G Lot Merger and Reversion to
Acreage (DRC Approval) $1,117.00 $44.68 $ N/A $111.70 $3,781.00 $5,054.38
H Condominium $7,884.00 $315.36 $788.40 $788.40 N/A $9,776.16
I Condominium (as part of a
Planned Development) $3,750.00 $150.00 $375.00 $375.00 N/A $4,650.00
J Certificate of Compliance (DRC
Approval) $3,257.00 $130.28 N/A $325.70 $2,350.00 $6,062.98
K
VTM applications that require
Town Council
approval and/or DRC
applications that
require Planning Commission
approval. This
fee supplements the above
established
fees.
$2,824.00 $112.96 N/A $282.40 N/A $3,219.36
3 MISCELLANEOUS
APPLICATION FEES
A Time Extensions to Approved
Applications
50% of Current
Fee Varies Varies Varies Varies Varies
B Modification of Approved
Application
75% of Current
Fee Varies N/A Varies Varies Varies
C Conceptual Development
Advisory Committee Review $2,966.00 $118.64 N/A $296.60 N/A $3,381.24
4 ENVIRONMENTAL
ASSESSMENT FEES
A Categorical Exemption No Fee N/A N/A N/A N/A No Fee
B Initial Study (Deposit)* $5,000.00 N/A N/A N/A Yes Varies
C
Draft Initial Study Review Fee
(or actual
cost if part of a Planned
Development,
General Plan and/or Town
Code
Amendment)
$2,950.00 N/A N/A N/A $2,045.00 $4,995.00
D Environmental Impact Report
(EIR) Consultant’s Fee N/A N/A N/A N/A Varies
E Draft EIR Review Fee $12,184 Plus
10% EIR Cost N/A N/A N/A Varies Varies
F Impact Monitoring Program
(AB3180)
Actual Cost on an
hourly basis plus
cost of
Consultant (if
necessary)
N/A N/A N/A N/A Varies
5 OTHER
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-15
Application
Fee
4%
Permit
Tracking
Fee
10%
General
Plan
Update
10% Advance
Planning
Special
Project
Engineering
Dev Review
Services
Fee Total Fee
A Pre-application Conference
Fee No fee Varies Varies Varies N/A Varies
B Fence Height Exceptions $292.00 N/A N/A N/A N/A $292.00
C Peer/Technical Review Actual Cost
($2,000 deposit) N/A N/A N/A N/A Varies
D
Fees for Additional Tech
Review and/or
DRC Review DRC beyond 3
meetings,
Planning Commission hearing
beyond 2
meetings, Town Council
hearing beyond 1
meeting
Actual Cost N/A N/A N/A N/A Varies
E
Request for Service Not
Covered by Any
Other Fee
Actual Cost N/A N/A N/A N/A Varies
F Building Permit Plan Check Fee 20% of Building
Fee N/A N/A N/A N/A Varies
G Surcharges
1 Permit Tracking Maintenance
and Update Surcharge
4% of
Development
Application Fee
N/A N/A N/A N/A Varies
2 General Plan Update
Surcharge
.5% of Bldg. Valuation for
new construction and
additions or 10% of zone
change & subdivision fee
N/A N/A N/A Varies
3 Advanced Planning Projects
10% of
Development
Application
Fee
N/A N/A N/A N/A Varies
4 Route 85 Study Plan Surcharge
**
10% of Development
Application Fee for property
in Route 85 Study Area Plan
N/A N/A N/A Varies
M Appeals
1
Fee to Appeal Planning
Commission Decision to Town
Council
$464 per
residential
$1,867 per
commercial,
multi-family or
tentative
map
N/A N/A N/A N/A Varies
2
Fee to remand applications
from Town Council to Planning
Commission where no error
was made by Planning
Commission
Actual Cost N/A N/A N/A N/A Varies
HCD Draft Initial Review 2023-2031 Housing Element
C-16 Appendix C October 2022
Application
Fee
4%
Permit
Tracking
Fee
10%
General
Plan
Update
10%
Advance
Planning
Special
Project
Engineering
Dev Review
Services
Fee Total Fee
3
Fee to Appeal Director of
Community Development or
Development Review
Committee decision to
Planning Commission
$234 per
residential N/A N/A N/A N/A Varies
4 Tree Appeals $95.00 N/A N/A N/A N/A $95.00
5 Appeal Transcription fee of
Planning Commission minutes
Actual Cost min.
$500 deposit N/A N/A N/A N/A Varies
L. Research Services Minimum
Charge
Actual Cost min.
$100 deposit N/A N/A N/A N/A Varies
Table C-3 Total Fees per Unit
Jurisdiction Single-Family Small Multi-family Large Multi-family
Campbell $72,556 $20,599 $18,541
Cupertino $136,596 $77,770 $73,959
Gilroy $69,219 $40,195 $39,135
Los Altos Hills $146,631 N/A N/A
Los Gatos $11,202 $15,375 $15,375
Milpitas $77,198 $74,326 $59,740
Monte Sereno $33,445 $4,815 $4,156
Morgan Hill $55,903 $41,374 $36,396
Mountain View $90,423 $69,497 $82,591
San Jose $9,919 $23,410 $23,410
Santa Clara $72,034 $7,299 $3,048
Saratoga $64,272 $17,063 $15,391
Sunnyvale $133,389 $126,673 $98,292
Note: Inclusive of impact, building and entitlement fees. Source: SCCPC, 2022 citiesassociation.org/documents/constraints-survey-data-summary-2022 and Los Gatos staff.
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-17
Table C-4 Fees as a Percentage of Total Development Costs
Jurisdiction Single-Family Small Multi-family Large Multi-family
Campbell 2.6% 2.7% 2.6%
Cupertino 2.9% 10.3% 10.5%
Gilroy 1.5% 5.3% 5.6%
Los Altos Hills 3.1% N/A N/A
Los Gatos 1.2% 0.8% 0.5%
Milpitas 2.8% 9.8% 8.5%
Monte Sereno 0.7% 0.6% 0.6%
Morgan Hill 2.0% 5.5% 5.2%
Mountain View 3.3% 9.2% 11.8%
San Jose 0.4% 3.1% 3.3%
Santa Clara 2.6% 1.0% 0.4%
Saratoga 1.4% 2.3% 2.2%
Sunnyvale 4.8% 16.8% 14.0%
Unincorporated County 0.9% N/A NA
Note: Calculation uses a county-wide average total development cost. Source: SCCPC, 2022 citiesassociation.org/documents/constraints-survey-data-summary-2022
Permit fees and processing times are not significant constraints to housing production in Los Gatos. In the Spring
of 2022, the Santa Clara County Planning Collaborative conducted a survey of fees and permit processing times
in Santa Clara County. Fourteen of fifteen jurisdictions completed the survey, an excellent response rate. The
results indicate that Los Gatos has overall permit fees that are within the average range of Santa Clara County
jurisdictions.
The Town’s fees also represent a relatively low percentage of the overall cost to develop housing in Los Gatos.
Based on the Santa Clara County Planning Collaborative survey results and an analysis on housing development
costs performed by Century Urban, a San Francisco based real estate consulting firm, the fees represent
approximately 1.2 percent of total development costs for a single-family home, 0.8 percent for a 10-unit multi-
family development, and 0.5 percent for a 100-unit multi-family development. The fee structure does not
disproportionally burden multi-family housing.
Processing and Permitting Time
Government policy at both the State and jurisdictional levels play a major role in determining the costs of building
new housing. Regulations and permitting processes that result in lengthy or uncertain development carry higher
risk and increased financing. Additionally, frequent delays in the entitlement and approval process directly
increase costs, such as additional architectural work, inspections, and community meetings. Streamlining
permitting processes, applying permit application processes consistently, increasing interdepartmental
cooperation, having adequately funded and staffed planning departments, and increasing by-right housing are all
actions jurisdictions can take to reduce the constraints represented by fees and permit processing times.
Each stage of the residential development process must go through some form of Town approval. On average, a
single- or multi-family infill residential application typically processes in approximately three to six months, unless
environmental review is required. Hillside residential applications on average take four to six months to process.
Mixed-use projects are processed in approximately four to eight months, unless environmental review is required.
HCD Draft Initial Review 2023-2031 Housing Element
C-18 Appendix C October 2022
With environmental review, the process generally takes six to 18 months, depending on the size and complexity
of the project.
Processing of a typical, market rate single- or multi-family housing application includes the following steps:
Submission of an Architecture and Site Application.
Distribution of the application to Planning, Building, Engineering, and the Santa Clara County Fire District
departments.
Staff review of application and staff conference with the applicant to resolve any concerns or plan
deficiencies, including design issues.
If deemed complete, staff continues processing the application and begins environmental review, if
necessary.
Completion of environmental review and traffic impact analysis, as appropriate. Arborist review,
architectural review, and/or geotechnical review may be conducted during this time through the
Architecture and Site application.
Approval is required by the following bodies:
Development Review Committee (with appeal to the Planning Commission and further appeal to the Town
Council) for projects that require no change in the General Plan or Zoning Code.
For hillside development applications, Planning Commission approval may be required depending on the
scope of the project.
Town Council for projects that require a change in the General Plan or Zoning Code, and for Planned
Developments.
Processing for a typical mixed-use housing project includes the following steps:
Submission of application, including application for a Conditional Use Permit (CUP), and an Architecture
and Site Application.
Distribution of the application to Planning, Building Engineering, and the Santa Clara County Fire District
departments.
Staff review of application and staff conference with applicant to resolve any concerns or plan deficiencies,
including design issues.
If deemed complete, staff continues processing the application and begins environmental review, if
necessary.
Completion of environmental review and traffic impact analysis, as appropriate. Arborist review,
architectural review, and/or geotechnical review may be conducted during this time through the
Architecture and Site application.
Approval is required by one or both of the following bodies:
Planning Commission (with appeal to the Town Council) for projects that require no change in the
General Plan or Zoning Code, and for a CUP and Architecture and Site Application.
Town Council for projects that require a change in the General Plan or Zoning Code, and for
Planned Developments.
Design and neighborhood compatibility issues also often lengthen the permitting and processing time. To
address this problem, the Town contracts out to an architectural consultant to review plans and provide
recommendations on development applications compliance with the Residential Design Guidelines or Hillside
Development Standards and Guidelines.
Architectural, geotechnical, and arborist reviews are conducted early in the development application process.
These reviews are conducted during the review of the Planned Development or Architecture and Site applications
and do not lengthen the processing time. These reviews also streamline the public hearing process, allowing the
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-19
Planning Commission to rely on the recommendations of Town staff and the Town’s consultants to receive
qualified input from an architect, arborist, and geotechnical consultant, leading to a more efficient approval
process.
Table C-5 Processing Times (in months)
Jurisdiction ADU Process Ministerial By-Right Discretionary By-Right
Discretionary (Development Review
Commitee)
Discretionary (Planning Commission)
Discretionary (Town Council)
Campbell 1 1 3 N/A 5 8
Cupertino 1 to 3 1 to 6 2 to 4 2 to 4 3 to 6 6 to 12
Gilroy 1 to 2 1 to 2 2 to 4 N/A 4 to 5 5 to 6
Los Altos Hills 1 to 2 0.5 to 2 2 to 3 3 to 4 4 to 6 5 to 8
Los Gatos 1 to 2 1 to 2 1 to 2 2 to 4 4 to 6 6 to 12
Milpitas 1 to 3 1 to 3 2 to 4 3 to 4 4 to 6 6 to 12
Monte Sereno 0.75 0.75 1 1 to 2 1 to 2 1 to 2
Morgan Hill 1 to 2 1 to 3 *2 to 3 2 to 3 4 to 6 4 to 6
Mountain View 3 to 5 4 to 6 2 to 3 *6 to 18 N/A 12 to 24
San Jose 2 1 to 3 7 7 7 to 11 5 to 12
Santa Clara 0 to 1 0 to 1 0 to 3 4 to 9 6 to 9 6 to 12
Saratoga 1 1 to 2 2 to 3 N/A 4 to 6 6 to 12
Sunnyvale 1 to 3 1 to 3 3 to 6 6 to 9 9 to 18 9 to 18
Unincorporated
County 4 to 6 6 to 8 9 to 12 12 to 15 15 to 18 15 to 18
Entitlements Only. Source: SCCPC, 2022 citiesassociation.org/documents/constraints-survey-data-summary-2022
Jurisdictional permit processing procedures that are lengthy or uncertain can dissuade developers from building
new housing or result in housing that is more expensive. Within Los Gatos, the permit processing times are
within the average range for jurisdictions within Santa Clara County. The Town’s permit process also does not
disproportionally burden ADU applications or applications for multi-family housing.
SB 35 Streamlining
(Government Code section 65913.4) allows qualifying development projects with a specified proportion of
affordable housing units to move more quickly through the local government review process and restricts the
ability of local governments to reject these proposals. The bill creates a streamlined approval process for
qualifying infill developments in localities that have failed to meet their RHNA, requiring a ministerial approval
process, removing the requirement for CEQA analysis, and removing the requirement for discretionary
entitlements granted by the Planning Commission.
Since the adoption of this section of the Government Code, the Town has received one application under these
provisions. The Town has included Program AM in the Housing Element to prepare an SB35 checklist and
written procedures for processing SB35 applications.
HCD Draft Initial Review 2023-2031 Housing Element
C-20 Appendix C October 2022
SB9 California Housing Opportunity and More Efficiency (HOME) Act
SB9, also known as the California Housing Opportunity and More Efficiency (HOME) Act, is a state bill that
requires cities to allow one additional residential unit on parcels zoned for single-dwelling units. Since the
adoption of this section of the Government Code, the Town has adopted an interim SB9 ordinance and is in the
process of developing a permanent ordinance for adoption by the end of 2022.
Requests to Develop at Densities Below Those Permitted
New State Housing Element law now requires the non-governmental constraints analysis to evaluate developer
requests to build at densities below the density identified in the Housing Element sites inventory. In Los Gatos,
properties generally develop around the mid to high range of allowable densities. Requests to develop at
densities below those permitted are not an issue in Los Gatos.
Length of time between Application Approval and Building Permit Issuance
New Housing Element law now also requires an examination of the length of time between receiving approval for
a housing development and submittal of an application for building permits. The time between application
approval and building permit issuance is influenced by a number of factors, none of which are directly impacted
by the Town. Factors that may impact the timing of building permit issuance include: required technical or
engineering studies; completion of construction drawings and detailed site and landscape design; securing
construction and permanent financing; and retention of a building contractor and subcontractors.
The majority of residential permits in Los Gatos are for single-family homes, with building permit issuance
generally taking eight to 14 months after Planning approvals. Hillside properties may take a few months longer
due to the need for technical and engineering studies. Among the Town’s recent multi-family developments, the
time between approvals and permit issuance has averaged 12 to18 months. In Los Gatos, most approved
projects are constructed in a reasonable time period
C.2 Local Housing Programs
State Housing Element law requires that an analysis of governmental constraints on housing production include
local government programs that regulate housing development in any way, including imposing housing cost
limitations or encouraging changes in density. Los Gatos has six local housing programs that are potential
constraints on market-rate housing production in the Town. The Below Market Price Program, Affordable Housing
Fund, Rental Dispute Resolution Program, Density Bonus Program, State Density Bonus Program, and the
Affordable Housing Overlay are discussed below.
Below Market Price (BMP) Program
The BMP Program implements the Town of Los Gatos’s inclusionary zoning ordinance, which requires that a
portion of new residential construction in Los Gatos be dedicated to affordable housing. Los Gatos’s inclusionary
zoning ordinance was adopted in 1979 as one of the first of such programs in California.
The BMP Program promotes the development of affordable housing units by providing standards and guidelines
that require the development of a certain number of quality affordable units per rental or owner development
project, based on the size of the project. The BMP Program requires the development of affordable housing
where sales and rents cannot be more than 80 percent of the current HUD Fair Market Rents (FMR) as
determined by the Santa Clara County Housing Authority. The BMP Program allows low- and moderate-income
households the opportunity to purchase low- and moderate-income housing in Los Gatos.
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-21
The BMP Program requirements apply to all residential development projects that include five or more residential
units or parcels which involve:
New construction of ownership or rental housing units, including mixed-use developments and addition of
units to existing projects.
Subdivision of property for single family or duplex housing development.
Conversion of rental apartments to condominiums or other common interest ownership.
Conversion of non-residential use to residential use.
The intent of the BMP Program is to provide a supply of affordable housing for households who work or currently
reside in Los Gatos. However, there may be circumstances when the construction of a BMP unit is impractical.
The Town will consider, at its discretion, a fee payment in-lieu of constructing BMP units for Planned Unit
Developments with an underlying HR zone or for residential developments with five to nine units. The required in-
lieu fee of six percent of the building permit valuation for the entire project must be paid to the Town prior to
issuance of the certificate of occupancy for the market-rate units.
Additionally, the Town Council may consider off-site construction of BMP units for continuum of care facilities,
residential developments in the HR zone, or residential developments with five to nine units provided that
developers provide sufficient justification that an on-site BMP is infeasible.
The developer of “for sale” BMP units shall enter into an affordability agreement with the Town. The agreement
will ensure that the BMP units are sold to qualified buyers and will be released by the Town through the escrow
process once the BMP is sold to a qualified buyer. Because the BMP Program regulates the number of affordable
units required as part of new residential construction in Los Gatos, the program could be considered a constraint
on market-rate housing development. However, because the BMP Program requires the construction of
affordable units with every new qualifying development, the Town sees this program as an opportunity to create
and preserve affordable housing for the community. Based on a track record of successful development and
preservation of affordable housing through the BMP Program, Los Gatos does not consider the program to be a
constraint on affordable housing development; nevertheless, the Town proposes to study the BMP Program and
implement recommendations to augment and improve it in order to facilitate the construction of more units.
Affordable Housing In-Lieu Fee Fund
In-lieu fees are paid into the Town’s Affordable Housing Fund and are calculated as six percent of building permit
valuation as determined by the Building Official. As previously noted, these fees may be paid by developers of
new residential construction with five or more units but less than 10 units or new residential construction in a
Planned Unit Development with an underlying zone of HR, instead of building an affordable housing unit(s) under
the BMP Program. All residential construction over 10 units must build affordable units. Payment of in-lieu fees is
required for the approval of Hillside Planned Developments with five or more residential sites. Use of the
Affordable Housing Fund includes, but is not limited to:
Subsidizing the cost of owner-occupied units to make them affordable to low and/or moderate-income
households.
Purchasing rental units to make them affordable to low and/or moderate-income households.
Purchasing land for the future development of affordable housing.
Developing affordable housing.
Supplementing affordable housing projects developed through the Los Gatos Redevelopment Agency.
Funding administration of the program, as approved by the Town Council in its annual budget process.
HCD Draft Initial Review 2023-2031 Housing Element
C-22 Appendix C October 2022
This additional fee levied on developers may be considered a constraint on housing development; however, the
fees are paid into a fund that will be used to develop more affordable housing in Los Gatos. Given the low rate of
construction of affordable units, the Town proposes to study the In-Lieu Fund Program and implement
recommendations to augment and improve it in order to facilitate the construction of more units.
Rental Dispute Resolution Program
The Los Gatos Rental Dispute Resolution Program provides conciliation, mediation and arbitration services for
both renters and landlords in Los Gatos. The program is administered by Project Sentinel, a local non-profit
organization contracted by the Town. This program is not considered a constraint on housing development in Los
Gatos. Los Gatos renters may also contact Neighborhood Housing Services Silicon Valley for assistance.
The Town helps preserve affordable rental housing costs through the Rental Mediation and Dispute Resolution
Ordinance which applies to rental complexes of three or more units. The ordinance sets an annual limit on rent
increased to five percent unless the landlord is able to demonstrate capital or financing costs to justify a greater
increase. The Town has similar rent controls for mobile home units.
Mobile homes are an affordable housing resource in the Town of Los Gatos. They are often owned by seniors,
households on fixed incomes, and households within the lower and moderate-income categories. Mobile home
tenants are in the unique position of having made a substantial investment in a housing unit for which ground
space is rented. The Mobile Home Ordinance establishes rent increase control within mobile home parks to
ensure that a variety of housing types, including mobile homes, remain viable options to lower and moderate-
income households in the community. Rents in mobile home parks cannot be increased by more than five
percent annually unless operations and maintenance expenses significantly increased within the most recent year
in comparison to the previous year.
Density Bonus Program
The Density Bonus Program allows qualified projects to add up to 100 percent of the units provided by the
General Plan land use designation as long as these additional units are restricted to seniors, disabled persons,
very low and/or low-income households.
Over the last Housing Element cycle, the Town approved the North 40 Phase One development which included
49 very-low income and one moderate-income manager unit as density bonus units.
The Density Bonus Program has the potential to provide additional opportunities to build more, affordable units in
Los Gatos. The Town is including an Implementation Program to study the existing Density Bonus Ordinance and
recommend changes to increase the number of units constructed. The study will include an evaluation of the
implementation of the ordinance to date and actual construction of affordable housing units that utilized the
Density Bonus Program.
State Density Bonus Program
The Town adopted the State Density Bonus Program in June 2012. The program allows densities, incentives,
concessions and maximum parking standards consistent with State law. In addition, the Town modified the
program to apply to senior and physically handicap populations.
The Town has not processed a request for a State Density Bonus since the ordinance was adopted in June 2012
because the Town’s BMP Program and General Plan policies exempt affordable housing units from the calculated
density in a project. The State Density Bonus Program provides opportunities to build additional, affordable units
in Los Gatos; consequently, this program is not considered a constraint on housing development.
Affordable Housing Overlay Zone
The Town adopted the AHOZ, and it applies to one property in the Housing Sites Inventory (see Table 6-2). The
AHOZ allows densities (up to 20 units per acre on designated sites), development standards, and concessions
that will encourage affordable housing. The Housing Element includes a program to modify the affordability
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-23
requirements in the Town Code to require a minimum of 40 percent affordable units on the Southbay AHOZ site
instead of the currently prescribed affordability levels. Affordability would be for low and very low-income
households.
Constraints on Housing for Persons with Disabilities
State law requires that the Housing Element analyze governmental constraints to housing for persons with
disabilities. How a jurisdiction defines “family” in its zoning regulations can be a potential constraint to facilitating
housing for persons with disabilities. The existing definition of “family” in the Town Code is “one or more persons
who comprise a single housekeeping unit” or “households of six or fewer persons living in a residential care
facilities small family home as defined by the California Community Care Facilities Act.”
In Los Gatos, group homes are defined by the Town Code as synonymous with small family home residential care
facilities, which are defined by the Town Code as “a residential care facility in the dwelling of a licensee in which
care or supervision is provided for six or fewer persons. Whether or not unrelated persons are living together, a
residential facility that serves six or fewer persons shall be considered a residential use of property for the
purposes of this article. In addition, the residents and operators of such a facility shall be considered a family for
the purposes of any law or zoning ordinance which relates to the residential use of property.” Group homes are
permitted by right in all residential districts, consistent with State law, and are permitted with a CUP in the Office
(O), Neighborhood Commercial (C-1), Central Business District (C-2), and Restricted Highway Commercial (CH)
zones. The Town imposes no spacing or concentration requirements on any of the allowed residential care
facilities. Large family home residential care facilities, which have a capacity for seven to 12 children or seven to
15 adults are allowed in all districts with a CUP, except where large family homes are prohibited in the RMH, LM,
and CM districts.
Generally, the Town facilitates housing for persons with disabilities by following the accessibility requirements of
the California Title 24 Multi-family Accessibility Regulations for multi-family housing of three or more units.
Housing rehabilitation assistance and accessibility improvements are provided through the Town’s Community
Services and Community Development departments.
The Town encourages accessibility improvements by requiring that specific design features be incorporated into
all new residential home projects as a condition of approval. These requirements include:
A wooden backing that is no smaller than 2 inches by 8 inches in all bathroom walls, at water closets,
showers, and bathtubs. It will be located 34 inches from the floor to the center of the backing, suitable for
the installation of grab bars.
All passage doors of at least 32 inches wide on the accessible floor.
A primary entrance that is a 36-inch-wide door, including a five-foot by five-foot level landing, no more than
one inch out of plane with the immediate interior floor level, with an 18-inch clearance.
In 2013, the Town adopted a procedure for requesting reasonable accommodation for persons with disabilities
seeking equal housing access under the Federal Fair Housing Act and the California Fair Employment and
Housing Act and in accordance with State housing law. A request for reasonable accommodation may include a
modification or exception to the standards and practices for the siting, development, and use of housing or
housing-related facilities that would eliminate regulatory barriers to accessible housing. Requests for reasonable
accommodation shall be reviewed by the Planning Director within 45 days of the request. However, if the request
is concurrent with a discretionary land use application, then the body overseeing the discretionary land use
application will also make a determination on the reasonable accommodation request. There are seven
mandatory criteria for granting a reasonable accommodation request:
The housing will be used by an individual disabled under the Federal Fair Housing Act and the California
Fair Employment and Housing Act.
The request is necessary to make specific housing available to an individual with a disability.
HCD Draft Initial Review 2023-2031 Housing Element
C-24 Appendix C October 2022
The request would not impose an undue financial or administrative burden on the Town.
The request would not require a fundamental alteration in the nature of a Town program or law, including
but not limited to land use and zoning.
There would be no impact on surrounding uses.
Due to physical attributes of the property or structures the request is necessary.
There is no alternative reasonable accommodation which may provide an equivalent level of benefit.
By adopting a formal procedure, the Town has provided an objective process with clear directions for both the
applicant and the decision makers. This is a benefit to persons with disabilities and is not a constraint on housing.
Low Barrier Navigation Centers
AB 101, adopted in 2019, requires approval 'by right' of low barrier navigation centers that meet the requirements
of State law. A “Low Barrier Navigation Center” means a Housing First, low barrier, service-enriched shelter
focused on moving people into permanent housing that provides temporary living facilities while case managers
connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing.
If the City receives applications for these uses, it will process them as required by State law. A program has been
included in the Housing Element to develop by right procedures for processing low barrier navigation centers.
Employee Housing
California Health and Safety Code Section 17021.5 (Employee Housing Act) requires jurisdictions to permit
employee housing for six or fewer employees as a single-family use. Employee housing shall not be included
within the zoning definition of a boarding house, rooming house, hotel, dormitory, or other similar term that implies
that the employee housing is a business run for profit or differs in any other way from a family dwelling.
Jurisdictions cannot impose a CUP, variance, or other zoning clearance of employee housing that serves six or
fewer employees that is not required of a family dwelling of the same type in the same zone. The Town’s Zoning
Code addresses small employee housing as a residential care facility.
Farm Employee Housing
The Town of Los Gatos does not currently have any identified farmworkers. Given the lack of farmworkers in the
community, the Town has not identified a need for specialized farmworker housing beyond overall programs for
housing affordability.
C.3 Non-Governmental Constraints to Housing Development
Market constraints to housing development in Los Gatos are the primary non-governmental impediment to
housing production. The Town is located near Silicon Valley jobs and offers residents desirable amenities such
as an historic downtown and a school district in which student performance ranks in the top four percent of the
State.
Development Costs
In January 2022, the Santa Clara County Planning Collaborative distributed a survey to Santa Clara County
jurisdictions to better understand the fees and processing times involved in the development of single-family and
multi-family housing. Fourteen out of sixteen jurisdictions responded with locally collected data, which
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-25
Collaborative staff used to identify major trends and produce data tables1. Additionally, the real estate economics
consulting firm Century Urban conducted independent research on land and development costs2. Data and
preliminary reports can be found on the Collaborative website: citiesassociation.org/constraints.
The cost of development is generally high in Santa Clara County and represents a significant constraint on the
production of both single-family and multi-family housing. According to analysis by Century Urban, average
development costs for single-family homes in the county range from $1,667,000 to $5,910,000. The cost of land
and the size of the units are the two factors causing the most variance. Multi-family development costs are also
quite high, though lower on a per unit basis compared to single family homes. Based on a survey of local
development costs, Century Urban estimates the average cost per unit for a 10-unit prototype at $726,000 to
$846,000. The average cost per unit to develop a 100-unit building ranges from $672,000 to $792,000.
Jurisdictions were asked to estimate development fees based on the following hypothetical housing types and
related detailed assumptions:
Single-Family: A new single-family house on an empty lot, 2,600 square feet or 5,000 square feet, in an
existing neighborhood with no significant grading or other complicating factors.
Small Multi-family: A project that includes 10 units in one building on one acre, where no zoning changes
are required and permitting is by-right with medium complexity.
Large Multi-family: A project that is comprised of 100 units on two acres, 80,000 total square feet, with
construction type V over a concrete podium.
Century | Urban was engaged by Baird + Driskell, hired by Association of Bay Area Governments (ABAG)
Planning Collaborative to perform research on the development costs of certain residential prototypes in Santa
Clara County. The estimates shown below are based on data and sources including but not limited to: similar
projects Century | Urban has underwritten and/or priced; specific project economics Century | Urban has
reviewed; direct conversations with developers and cost estimators; database research including CoStar, MLS,
Redfin, and title databases; online research sources including municipality and project websites; market reports
compiled by real estate sales and research organizations; and, Century | Urban’s general experience assessing
residential project feasibility in the San Francisco Bay Area.
Land Costs
The price of land also varies across the county based on site conditions and location, but land costs in Santa
Clara County are notably higher than costs in neighboring counties. Century Urban estimates the average land
price in Santa Clara County for single-family homes (based on sales within the last three years) at $1,320,000.
Land costs are lower for multi-family developments, estimated at $600,000 for small developments and
$6,000,000 for large developments, or $60,000 per unit. The data does not include properties with existing
homes or infrastructure that were redeveloped as new single-family homes, and the data for some cities is limited.
As the data collected is not comprehensive, summaries and averages may be valuable for reaching overall
conclusions about the range of land prices in the counties, but they may or may not be representative of a given
city’s average or median land price or the land price for a given parcel. The information should therefore be
reviewed noting the limited number of data points for certain cities, including Los Gatos where only 15 data points
were available. Land prices vary substantially by location, topography, site conditions, shape of the parcel,
neighboring uses, access, noise, and many other factors. In addition, completed sales are necessarily past
transactions and may not represent the current state of the market and expected future land sale prices.
1 Santa Clara County Planning Collaborative, 2022. Summary of Constraints Survey Data. citiesassociation.org/documents/constraints-
survey-data-summary-2022 2 Century Urban, 2022. San Mateo and Santa Clara Counties Development Cost & San Mateo County Unit Mix Research.
citiesassociation.org/documents/development-cost-data.
HCD Draft Initial Review 2023-2031 Housing Element
C-26 Appendix C October 2022
There are very few vacant parcels zoned for multi-family development, and such parcels demand premium prices
because of the high demand to live in Los Gatos. Additionally, most parcels have existing improvements that
increase acquisition costs. Countywide, the land costs for multi-family development sites cost approximately
$60,000 per unit.
Hard and Soft Costs
Soft costs for housing development include the cost of architectural, engineering, accounting, legal and other
professional services, as well as the cost of obtaining permits and paying government-imposed fees. Carrying
costs and the cost of construction financing can also be considered soft costs. Century Urban’s analysis finds
that soft costs (such as impact fees and costs accumulated through permitting delays) are hard costs. Hard costs
include the costs of labor and materials.
Hard costs are very high in Santa Clara County, and both the high cost of labor and the high cost of materials
could be considered constraints on housing development. According to analysis by Century Urban, residential
hard and soft costs do not vary significantly across Santa Clara County.
Hard and soft costs contribute significantly to the overall cost of developing new housing. Hard costs comprise
over half of development costs for multi-family housing. Although hard costs are significant for single-family
production as well, they comprise a lower percentage of overall costs because of the larger role of land costs in
single-family construction. High hard costs are difficult for individual jurisdiction to mitigate.
Single-family detached ~2,660 square feet: $81 to $965 per square foot.
Single-family detached ~5,000 square feet: $714 to $1,174 per square foot.
Multi-family apartments/condominiums less than 10 units on one acre: $726,500 to $846,500 per unit.
Three- to four-story 100-unit multi-family apartment/condominiums with type V construction over a
concrete podium parking: $672,500 to $792,500 per unit.
Availability of Financing
The residential real estate market is strong in the Town of Los Gatos. Local realtors and developers have noted
that Los Gatos was affected by the home mortgage foreclosure crisis that plagued many communities in the last
fifteen years. Adjustable-rate mortgages, jumbo loans (those above $417,000), and Government-insured Federal
Housing Administration home purchase loans, in addition to all-cash offers, are common in Los Gatos. Adequate
financing through local banks is available to the Los Gatos community.
The Housing Trust of Santa Clara County offer three low-interest, down payment or closing cost loan programs
for income qualified buyers in Los Gatos. Participation in this program includes homebuyer education classes.
The County of Santa Clara Office of Affordable Housing administers three homebuyer assistance programs. The
Home Investment Partnerships Program offers down payment assistance for first-time buyers. The Mortgage
Credit Certificate Program reduces the federal income taxes of qualified borrowers purchasing qualified homes,
thus acting like a mortgage subsidy. The Down payment Assistance Program for First-time Buyers offers a
subsidy for borrowers meeting a maximum income limit and maximum purchase price limit.
The Home Mortgage Disclosure Act (HMDA) requires the reporting of data on residential loan applications, which
provides insight into the availability of financing in the community. Table C-6 summarizes HMDA data for the San
Jose, Sunnyvale, Santa Clara MSA. As shown in the table below, approximately 25 percent of all loan
applications for the lowest income group are denied.
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-27
Table C-6 Home Purchase and Improvement Loans
Income Group
Loan
Applications
Loans Approved (Originated) Loans Denied
# % # %
>50% of MSA AMI 9,757 4,518 46.3% 2,550 26.1%
50-79% of MSA AMI 19,780 12,673 64.1% 2,683 13.6%
80-99% of MSA AMI 8,535 5,775 67.7% 852 10.0%
100-119% of MSA AMI 28,507 20,122 70.6% 2,361 8.3%
≥120 of MSA AMI 87,715 59,930 68.3% 6,951 7.9%
TOTAL 154,294 103,018 66.8% 15,397 10.0%
SOURCE: Home Mortgage Disclosure Act (HMDA), 2020
MSA – Metropolitan Statistical Area
AMI – Area Median Income
Environmental Constraints
The environmental setting affects the feasibility and cost of residential development. These areas contain
environmental constraints on development, such as steep slopes, landslide hazards, fire hazards, or flood
hazards, and therefore, much of the undeveloped land has been set aside as open space. The Town is adjacent
to other built out communities and nestled against the Santa Cruz Mountains, limiting opportunities for expansion.
The following are environmental constraints and hazards that affect, in varying degrees, existing and future
residential developments.
Urban and Wildland Fire Hazards
Wildfires are becoming an all too regular event in California, and both urban and wildland fires are a threat to the
Town of Los Gatos. Wildfires that burn exclusively in uninhabited natural areas generally pose little risk to lives or
property, although the smoke from such fires may cause respiratory problems for people nearby. Fires that occur
along the wildland-urban interface (WUI) are much more of a hazard, as they can spread into urbanized areas.
Wildfire risk is dependent on several factors, including the amount and type of vegetation in the area, weather,
and local topography. Factors such as narrow, winding roads and vegetation also slow response to fires,
increasing the risk of spread.
Based on the increased potential for devasting wildfires in Santa Clara County and the Town of Los Gatos, CAL
FIRE developed and adopted “Fire Hazard Severity Zone” maps. These maps highlight that most of the County is
located within the “high” fire severity zone, with smaller portions of the County within the “moderate” and “very
high” fire severity zones. More than half of the southern portion of the Town is in the Very High Fire Hazard
Severity Zone, with most of the areas to the south in the High or Moderate zones. The Town must therefore
strongly incorporate fire hazard mitigation into its land use decisions and requirements to protect residents and
property. Potential impacts are mitigated by policies in the 2040 General Plan Hazards and Safety Element
including the following:
Require new development, including additions to existing structures, located in or adjacent to fire hazard
areas to minimize hazards to life and property, by using fire preventive site design, access, fire-safe
landscaping, building materials, and incorporating defensible space and other fire suppression techniques.
Minimize exposure to wildland and urban fire hazards through proactive code enforcement, public
education programs, use of modern fire prevention measures, quick and safe access for emergency
equipment and evacuation, and emergency management preparation.
Restrict development in areas with inadequate water flow or emergency access.
HCD Draft Initial Review 2023-2031 Housing Element
C-28 Appendix C October 2022
Monitor and remove excessive buildup of flammable vegetative materials on Town properties and along
critical ingress/egress routes in the WUI.
Geological and Seismic Hazards
The San Francisco Bay Area is in one of the most active seismic regions in the United States. Los Gatos is near
several active faults including the San Andreas, Hayward, and Calaveras Faults. Ground shaking is the primary
risk in an earthquake and can set off a chain reaction of secondary landslides and liquefaction, or loss of soil
strength. The region around the Lexington Reservoir also has higher risk of ground shaking should an earthquake
occur. 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.
Seismic activity within or near the Santa Clara County region has historically caused significant damage to
buildings and infrastructure in the Town of Los Gatos due to ground shaking and landslides. Five earthquakes
have affected Los Gatos in the 20th century, with the 1906 San Francisco and 1989 Loma Prieta earthquakes
having the highest magnitude. Potential impacts are mitigated by policies in the Draft 2040 General Plan Hazards
and Safety including the following:
Require new development to be sited away from high risk geologic and seismic hazard zones or, if located
in a high-risk zone, incorporate construction techniques or specialized technologies to reduce risk. Restrict
new development and redevelopment based on the levels of risk and potential severity of geologic
hazards.
Require geotechnical reports analyzing seismic hazards, grading, and construction methods.
Require that a licensed geologic/geotechnical engineer complete the Town Geologic Hazards Checklist for
all new proposed development to demonstrate that potential hazards have been identified and that
proposed structures, including grading cuts and fills, will be designed to resist potential earthquake effects.
Implement the Hillside Development Standards and Guidelines.
Flood and Inundation Hazards
Flooding can threaten life, safety, and property and can occur in a number of ways. The level in a body of water,
such as a lake or creek, can rise higher than the water body’s banks, causing it to overflow into nearby areas.
Heavy precipitation can overwhelm the ability of soil to absorb water or storm drains to carry it away, causing
water to build up on the surface. Localized flooding may also occur as a result of infrastructure failure, such as a
burst water tank or pipe. In Los Gatos, the floods that are of most concern are from heavy rainfall causing local
flooding or flash floods. Flooding puts various populations in Town at risk. A 500-year flood could affect upwards
of 28,000 people and cause $10 billion of structural damage.
Beyond localized flooding, Los Gatos faces a flood threat from dam inundation. While less common, dam
inundation is recognized in both the Town Emergency Operations Plan and Santa Clara County OAHMP. The
Lexington Reservoir as contained by the James J. Lenihan Dam is the largest concern for dam inundation.
Lexington Reservoir is the third largest reservoir in Santa Clara County storing 19,044 acre-feet of water. The
potential inundation zone in the event of failure is significant, with the potential to affect over 3,000 people and
damage over 1,000 structures. As future climate change-related impacts increase, localized flooding will become
more common due to more extreme storms increasing the potential for more frequent and severe riverine
flooding. Potential impacts are mitigated by policies in the Draft 2040 General Plan Hazards and Safety including
the following:
Require site planning and building design to mitigate identified flood and inundation hazards.
Require that new development and substantial improvements to existing structures meet Federal and
State standards when located within FEMA Flood Insurance Rate Maps (FIRMs) designated 100-year
flood zones, as designated by current FEMA mapping.
Appendix C. Governmental and Non-Governmental Constraints
October 2022 Appendix C C-29
Cooperate with the Santa Clara Valley Water District to develop and maintain additional stormwater
retention facilities in areas where they are needed or where the design capacity of existing retention
facilities cannot be restored.
Hazards and Hazardous Materials
The use, manufacture, production, transportation, storage, treatment, disposal, and clean-up of hazardous
materials and hazardous wastes present a potential threat to the health and safety of those who are using the
materials and those who could be affected by improper or accidental release or disposal. Hazardous materials
include all toxic, flammable, combustible, corrosive, poisonous, and radioactive substances that possess the
potential to bring harm to the public or the environment. The Town maintains a comprehensive list of Hazardous
Waste and Substance sites where hazardous materials are present and cleanup activities are or may be
necessary. Potential impacts are mitigated by policies in the 2040 General Plan Hazards and Safety Element.
Noise and Air Quality
Noise and air quality impacts associated with Highways 17 and 85, other high-volume arterial roadways, and the
Union Pacific Railroad line parallel to and south of Highway 85 could potentially impact housing. The California
Building Code and the Noise Element of the Los Gatos General Plan contain policies and standards that mitigate
noise impacts, and the regulations of the Bay Area Air Quality Management District require careful study and
mitigation of health risks from poor air quality. Potential impacts are mitigated by policies in the Draft 2040
General Plan Environment and Sustainability Element.
Environmental constraints to housing development are mitigated where public health, safety, and welfare can be
protected.
Sites Inventory Analysis D
APPENDIX
EXHIBIT 4
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
D.1 Vacant and Available Sites
The Plan Bay Area 2050 Final Blueprint1 forecasts that the nine-county Bay Area will add 1.4 million new
households between 2015 and 2050. For the eight-year time frame covered by this Housing Element Update, the
Department of Housing and Community Development (HCD) has identified the region’s housing need as 441,176
units. The total number of housing units assigned by HCD is separated into four income categories that cover
housing types for all income levels, from very low-income households to market rate housing. This calculation,
known as the Regional Housing Needs Allocation (RHNA), is based on population projections produced by the
California Department of Finance as well as adjustments that incorporate the region’s existing housing need. The
adjustments result from recent legislation requiring HCD to apply additional adjustment factors to the baseline
growth projection from California Department of Finance, in order for the regions to get closer to healthy housing
markets. The adjustments focus on the region’s vacancy rate, level of overcrowding, and the share of cost
burdened households and seek to bring the region more in line with comparable areas. The new laws governing
the methodology for how HCD calculates the RHNA resulted in a significantly higher number of housing units for
which the Bay Area must plan compared to previous cycles.
D.2 Regional Housing Needs Allocation
In December 2021, ABAG adopted a Final Regional Housing Needs Allocation (RHNA) Methodology. For Los
Gatos, the RHNA required to be planned for the 6th cycle Housing Element Update is 1,993 units, an increase of
322 percent from the last cycle.
RHNA Summary
Los Gatos’ share of the regional housing need for the eight-year period from 2023 to 2031 is 1,993 units, which is
a 322 percent increase over the 619 units required by the 2015 to 2023 RHNA. The housing need is divided into
the four income categories of housing affordability. Table D-1 shows Los Gatos’ RHNA for the planning period
2023 through 2031 in comparison to the RHNA distributions for Santa Clara County and the Bay Area region.
With an update required every eight years by the State of California, this Housing Element covers a planning
period from January 31, 2023, to January 31, 2031 (also referred to as the “6th cycle”).
Table D-1 Los Gatos’ Regional Housing Needs Allocation: 2023–2031
Income Group Los Gatos Units Percent
Santa Clara County Units
Percent Bay Area Units Percent
Very Low Income (<50% of AMI) 537 26.9% 32,316 24.9% 114,442 25.9%
Low Income (50%-80% of AMI) 310 15.6% 18,607 14.4% 65,892 14.9%
Moderate Income (80%-120% of AMI) 320 16.1% 21,926 16.9% 72,712 16.5%
Above Moderate Income (>120% of AMI) 826 41.4% 56,728 43.8% 188,130 42.6%
Total 1,993 100.0% 129,577 100.0% 441,176 100.0%
Source: ABAG 2021
1 Plan Bay Area 2050 is a long-range plan charting the course for the future of the nine-county San Francisco Bay Area. It covers four key issues: the
economy, the environment, housing and transportation
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
D.3 Site Inventory
The purpose of the sites inventory is to identify and analyze specific sites that are available and suitable for
residential development during the planning period between 2023-2031 in order to accommodate Los Gatos’
assigned 1,993 housing units. The Town does not build the housing but rather creates the implementation
programs and policies to plan for where the housing can be located and how many units could be built on
potential sites.
In 2017, Senate Bill (SB) 166 was signed into law and included new “no net loss” provisions that require
communities to provide an ongoing, adequate supply of land resources for housing development during the
entirety of the housing element update planning period. These provisions mean communities face risks of non-
compliance should a housing site be developed with non-residential uses, lower residential densities, or
residential uses at affordability levels higher than anticipated by the Housing Element. To avoid noncompliance,
HCD advises communities to “buffer” their assigned RHNA numbers. The Site Inventory includes 48 sites in
order to have enough capacity for the RHNA and recommended buffer of at least 15 percent. These sites, in
addition to Accessory Dwelling Unit (ADU) Projections, Senate Bill (SB) 9 Projections, and Pipeline Projects have
a total capacity of 2,312 units (1,993 units plus a 16 percent buffer).
Overview of Selected Sites
This section provides information on the current list of potential sites that show how the Town will accommodate
the State’s required minimum of 1,993 housing units. Please note that the site numbers listed here are added
only as a way to reference the site and label it on a map. The site number is not an indication of preference or
priority. Figure D-1 shows an overview of the potential sites inventory map developed for Los Gatos’ 6th cycle
Housing Element Update. The following sites make up the Site Inventory, which is available as Appendix H.
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Figure D-1 Overall Area Parcel Locations
Sites Details
This section provides information on each of the sites selected for inclusion in the site inventory of vacant and
available sites.
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Figure D-2 Downtown Area
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site A-1 Park Avenue
Addresses: 50 Park Avenue and 61 Montebello Way
Number of Housing Units: 5
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Park Avenue Site (A-1) is located in the Downtown Area on the southwest end
of Town on a wooded parcel that is currently identified as Very High Fire Risk. The site is
triangular in shape with parking lots and South Santa Cruz Avenue on one side, Highway 17 on a
second side, and Downtown Los Gatos forming the third side. Proximity to Downtown Los Gatos
ensures that this site provides pedestrian access to urban services. This site currently is
developed with residential units and is designated Medium Density Residential. The site is zoned
R-1D and would allow five housing units developed at a minimum density of five du/ac.
Property Owner Interest Form Submitted: Yes
Constraints: Very high fire hazard; existing residential dwelling units would require demolition.
Figure D-3 Park Avenue (Site A-1)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site A-2 South Santa Cruz Avenue
Address: 101 South Santa Cruz Avenue
Number of Housing Units: 16
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The South Santa Cruz Avenue Site (A-2) is located in the Downtown Area on the
southwest end of Town along South Santa Cruz Avenue on an occupied commercial parcel in
Downtown Los Gatos. The site is currently identified as Medium Density Residential. Proximity
to Downtown Los Gatos ensures that this site provides pedestrian access to urban services. This
site is designated as Central Business District and zoned C-2, which would allow 16 housing units
developed at a minimum density of 20 du/ac.
Property Owner Interest Form Submitted: Yes
Constraints: Very high fire hazard; the existing commercial use would require demolition.
Figure D-4 South Santa Cruz Avenue (Site A-2)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site A-3 University Avenue
Address: 165 Los Gatos-Saratoga Road
Number of Housing Units: 7
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The University Avenue Site (A-3) is located in the Downtown Area at the corner of
Los Gatos-Saratoga Road and University Avenue on an occupied commercial site. Proximity to
Downtown Los Gatos ensures that this site would provide pedestrian access to urban services.
This site is designated as Central Business District and zoned C-2, which would allow seven
housing units developed at a minimum density of 20 du/ac.
Property Owner Interest Form Submitted: Yes
Constraints: Existing commercial building would require demolition.
Figure D-5 University Avenue (Site A-3)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Figure D-6 Los Gatos Lodge Area
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site B-1 Los Gatos Lodge
Address: 50 Los Gatos-Saratoga Road
Number of Housing Units: 264
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Los Gatos Lodge Site (B-1) is located in the Los Gatos Lodge Area
immediately adjacent to the interchange of Highway 9 and Highway 17, east of Downtown Los
Gatos. The site is the current location of the Los Gatos Lodge, with the Los Gatos High School
sports fields to the south, lower-density residential uses across Bella Vista Avenue to the east,
and Best Western Inn across Highway 9 on the north. This site is designated as Mixed-Use
Commercial and zoned CH:PD, which would allow 264 housing units developed at a minimum
density of 30 du/ac.
Property Owner Interest Form Submitted: Yes
Constraints: Existing commercial buildings would require demolition and removal or modification
of the existing Planned Development Overlay to accommodate residential.
Figure D-7 Los Gatos Lodge (Site B-1)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Figure D-8 Los Gatos Boulevard Area
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site C-1 Ace Hardware
Address: 15300 Los Gatos Boulevard
Number of Housing Units: 48
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Ace Hardware Site (C-1) is located in the Los Gatos Boulevard Area on the
east side of Los Gatos Boulevard and north of Gateway Drive. The site is the current location of
Ace Hardware, with commercial uses to the north, south, and west, and lower-density residential
uses to the east. The site is designated as Mixed-Use Commercial and zoned C-1, which would
accommodate 48 housing units developed at a minimum density of 30 du/ac.
Property Owner Interest Form Submitted: Yes
Constraints: Existing commercial building would require demolition.
Figure D-9 Ace Hardware (Site C-1)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site C-2 Los Gatos Boulevard
Address: 15349, 15367, and 15405 Los Gatos Boulevard
Number of Housing Units: 86
“By Right” + 20% Affordable: Required – Not used in previous cycle.
Description: The Los Gatos Boulevard Site (C-2) is located in the Los Gatos Boulevard Area on
the west side of Los Gatos Boulevard, and south of Garden Lane. The site is the current location
of multiple commercial uses, with commercial uses to the north, south, and east, and lower-
density residential uses to the west. The site is designated as Mixed-Use Commercial and zoned
CH, which would accommodate 86 housing units developed at a minimum density of 30 du/ac.
Property Owner Interest Form Submitted: Yes
Constraints: Existing commercial building would require demolition.
Figure D-10 Los Gatos Boulevard (Site C-2)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site C-3 Los Gatos Boulevard
Address: 15425 Los Gatos Boulevard
Number of Housing Units: 33
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Los Gatos Boulevard Site (C-3) is located in the Los Gatos Boulevard Area on
the west side of Los Gatos Boulevard and east of Garden Lane. The site is the current location of
office and commerical uses, with commercial uses located on all sides. The site is designated as
Mixed-Use Commercial and zoned CH, which would accommodate 33 housing units developed at
a minimum density of 30 du/ac.
Property Owner Interest Form Submitted: Yes
Constraints: Existing commercial building would require demolition.
Figure D-11 Los Gatos Boulevard (Site C-3)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site C-4 Affordable Treasures
Address: 15795 Los Gatos Boulevard
Number of Housing Units: 19
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Affordable Treasures Site (C-4) is located in the Los Gatos Boulevard Area at
the northwest corner of Los Gatos Boulevard and Farley Lane. The site is the current location of
Affordable Treasures Party Store with commercial uses located to the north, south, and east and
lower-density residential uses located to the west. The site is designated as Mixed-Use
Commercial and zoned CH, which would accommodate 19 housing units developed at a
minimum density of 30 du/ac.
Property Owner Interest Form Submitted: Yes
Constraints: Existing commercial building would require demolition.
Figure D-12 Affordable Treasures (Site C-4)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site C-5 Los Gatos Boulevard
Address: 16203 Los Gatos Boulevard
Number of Housing Units: 24
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Los Gatos Boulevard Site (C-5) is located in the Los Gatos Boulevard Area at
the northwest corner of Los Gatos Boulevard and Roberts Road. The site is the current location
of NC Boardshop skateboard shop and Autobahn Los Gatos, with commercial uses located to the
north, east, and west and medium-density residential uses located to the south. The site is
designated as Mixed-Use Commercial and zoned CH, which would accommodate 24 housing
units developed at a minimum density of 30 du/ac.
Property Owner Interest Form Submitted: No; however, a Conceptual Development Advisory
Committee application for a mixed-use development was submitted on November 17, 2020
pending an anticipated density increase as part of the General Plan and Housing Element
Updates.
Constraints: Existing commercial buildings would require demolition.
Figure D-13 Los Gatos Boulevard (Site C-5)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site C-6 Los Gatos Boulevard
Address: 16492 Los Gatos Boulevard
Number of Housing Units: 6
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Los Gatos Boulevard Site (C-6) is located in the Los Gatos Boulevard Area on
the east side of Los Gatos Boulevard, north of Spencer Avenue. The site is the current location
of LG Wines and Liquors and Happy Cleaners, with commercial uses located to the north, south,
and west and low-density residential uses located to the east. The site is designated as Low
Density Residential but zoned C-1, which would accommodate six housing units developed at a
minimum density of 10 du/ac.
Property Owner Interest Form Submitted: Yes, and the owner has submitted written interest in
changing the land use designation to Neighborhood Commercial.
Constraints: Existing commercial use would require demolition.
Figure D-14 Los Gatos Boulevard (Site C-6)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site C-7 Los Gatos Boulevard
Address: 15495 Los Gatos Boulevard
Number of Housing Units: 116
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Los Gatos Boulevard Site (C-7) is located in the Los Gatos Boulevard Area on
the west side of Los Gatos Boulevard and east of Garden Lane. The site is comprised of three
separate commercial buildings, with commercial uses located to the north, south, and east. Low-
density residential uses are located to the west. The site is designated as Mixed- Use
Commercial but zoned CH, which would accommodate 116 housing units developed at a
minimum density of 30 du/ac.
Property Owner Interest Form Submitted: No; however, a property owner has contacted staff
with an inquiry for residential development of the site.
Constraints: Existing commercial buildings would require demolition.
Figure D-15 Los Gatos Boulevard (Site C-7)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site C-8 Los Gatos Boulevard
Address: 15445 Los Gatos Boulevard
Number of Housing Units: 46
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Los Gatos Boulevard Site (C-8) is located in the Los Gatos Boulevard Area on
the west side of Los Gatos Boulevard and east of Garden Lane. The site is the current location of
Virtus Performance Club, with commercial uses located to the east and south. Low-density
residential uses are located to the north and west. The site is designated as Mixed-Use
Commercial but zoned CH, which would accommodate 46 housing units developed at a minimum
density of 30 du/ac.
Property Owner Interest Form Submitted: No; however, the site is adjacent to other sites
within the Site Inventory.
Constraints: Existing commercial building would require demolition.
Figure D-16 Los Gatos Boulevard (Site C-8)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Figure D-17 North Forty Area
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site D-1 North Forty Phase II Address: 14859 Los Gatos Boulevard, et. al.
Number of Housing Units: 461
“By Right” + 20% Affordable: Required – Used in previous cycle.
Description: The North Forty Phase II Site (D-1) is located in the North Forty Area on the west
side of Los Gatos Boulevard, south of Burton Road. The site contains existing single-family
residences and agriculture uses. Commercial uses are located to the south and west and arterial
highways located to the north and east. The site is designated and zoned as North Forty Specific
Plan, which would accommodate 461 units at a minimum density of 30 du/ac.
Property Owner Interest Form Submitted: No; however, the property owner has been involved
in attending Housing Element Advisory Board (HEAB) meetings and submitted written public
comments regarding intent and interest in residential development on the site.
Constraints: Existing buildings would require demolition.
Figure D-18 North Forty Phase II (Site D-1)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site D-2 North Forty Phase II
Address: 16245 Burton Road
Number of Housing Units: 38
“By Right” + 20% Affordable: Required – Used in previous cycle.
Description: The North Forty Phase II Site (D-2) is located in the North Forty Area at the
terminus of Burton Road, on the west side of Los Gatos Boulevard. The site is underutilized with
a single-family residence. Commercial uses are located to the east and arterial highways located
to the north and west. The site is designated and zoned as North Forty Specific Plan, which
would accommodate 38 housing units developed at a minimum density of 30 du/ac.
Property Owner Interest Form Submitted: No; however, the parcel is located within Phase II of
the North 40 Specific Plan Area where recent significant housing development is underway.
Constraints: Existing residential building would require demolition.
Figure D-19 North Forty Phase II (Site D-2)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site D-3 North Forty (Phase II) Address: 16240 Burton Road
Number of Housing Units: Eight
“By Right” + 20% Affordable: Required – Used in previous cycle.
Description: The North Forty Phase II Site (D-3) is located in the North Forty Area along Burton
Road and adjacent to the Highway 17/Highway 85 interchange. The site contains a single-family
residence. Other North Forty Specific Plan properties surround the site. The site is designated
and zoned as North Forty Specific Plan, which would accommodate eight housing units
developed at a minimum density of 30 du/ac.
Property Owner Interest Form Submitted: No; however, the parcel is located within Phase II of
the North 40 Specific Plan Area where recent significant housing development is underway.
Constraints: Existing residential building would require demolition.
Figure D-20 North Forty Phase II (Site D-3)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site D-4 North Forty Phase II Address: 16270 Burton Road
Number of Housing Units: 13
“By Right” + 20% Affordable: Required – Used in previous cycle.
Description: The North Forty Phase II Site (D-4) is located in the North Forty Area at the end of
Burton Road and immediately adjacent to the Highway 17/Highway 85 interchange. The site
contains a single-family residence. Other North Forty Specific Plan properties surround the site.
The site is designated and zoned as North Forty Specific Plan, which would accommodate 13
housing units developed at a minimum density of 30 du/ac.
Property Owner Interest Form Submitted: No; however, the parcel is located within Phase II of
the North 40 Specific Plan Area where recent significant housing development is underway.
Constraints: Existing residential building would require demolition.
Figure D-21 North Forty Phase II (Site D-4)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site D-5 North Forty Phase II
Address: 16210 Burton Road
Number of Housing Units: 25
“By Right” + 20% Affordable: Required – Used in previous cycle.
Description: The North Forty Phase II Site (D-5) is located in the North Forty Area along Burton
Road and on the west side of Los Gatos Boulevard. The site contains single-family residences.
Other North Forty Specific Plan properties surround the site. The site is designated and zoned as
North Forty Specific Plan, which would accommodate 25 housing units developed at a minimum
density of 30 du/ac.
Property Owner Interest Form Submitted: No; however, the parcel is located within Phase II of
the North 40 Specific Plan Area where recent significant housing development is underway.
Constraints: Existing residential building would require demolition.
Figure D-22 North Forty Phase II (Site D-5)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site D-6 North Forty Phase II Address: 14849 Los Gatos Boulevard
Number of Housing Units: 28
“By Right” + 20% Affordable: Required – Used in previous cycle.
Description: The North Forty Phase II Site (D-6) is located in the North Forty Area on the west
side of Los Gatos Boulevard, south of Burton Road. The site contains a single-family residence.
Other North Forty Specific Plan properties surround the site on the north, south, and west. East
of the site, across Los Gatos Boulevard there are commercial uses. The site is designated and
zoned as North Forty Specific Plan, which would accommodate 28 housing units developed at a
minimum density of 30 du/ac.
Property Owner Interest Form Submitted: No; however, the parcel is located within Phase II of
the North 40 Specific Plan Area where recent significant housing development is underway.
Constraints: Existing residential building would require demolition.
Figure D-23 North Forty Phase II (Site D-6)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site D-7 North Forty Phase II
Address: 14823 Los Gatos Boulevard
Number of Housing Units: 11
“By Right” + 20% Affordable: Required – Used in previous cycle.
Description: The North Forty Phase II Site (D-7) is located in the North Forty Area at the
southwest corner of Burton Road and Los Gatos Boulevard. The site contains a single-family
residence. Other North Forty Specific Plan properties surround the site on the south and west.
North of the site, across Burton Road, and east of the site, across Los Gatos Boulevard, there are
commercial uses. The site is designated and zoned as North Forty Specific Plan, which would
accommodate 11 housing units developed at a minimum density of 30 du/ac.
Property Owner Interest Form Submitted: No; however, the parcel is located within Phase II of
the North 40 Specific Plan Area where recent significant housing development is underway.
Constraints: Existing residential building would require demolition.
Figure D-24 North Forty Phase II (Site D-7)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Figure D-25 Lark Avenue Area
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site E-1 Oka Road
Address: Oka Road
Number of Housing Units: 124
“By Right” + 20% Affordable: Required – Used in previous cycle.
Description: The Oka Road Site (E-1) is located in the Lark Avenue Area on the east side of Oka
Road, north of Lark Avenue. The site contains residential and agricultural uses. Major arterial
highways are located north and east of the site, with the Los Gatos Swim and Racquet Club
immediately north. Agricultural and commercial uses are located across Oka Road. The site is
designated as Low-Density Residential and Medium-Density Residential. Parcels within the site
are zoned R-1-8 and R-M:5-12, which would allow 124 housing units developed at a typical
density of four du/ac for parcels designated as Low-Density Residential and at a minimum density
of 14 du/ac for parcels designated as Medium-Density Residential.
Property Owner Interest Form Submitted: No; however the property owner has submitted a
public comment to the HEAB regarding future development of the site.
Constraints: Existing buildings would require demolition.
Figure D-26 Lark Avenue (Site E-1)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site E-2 Oka Lane
Address: Oka Lane
Number of Housing Units: 26
“By Right” + 20% Affordable: Required – Used in previous cycle.
Description: The Oka Lane Site (E-2) is located in the Lark Avenue Area on the west side of Oka
Road, north of Lark Avenue. The site contains agricultural uses. Major arterial highways are
located north and east of the site, with the Bonnie View mobile home park to the north.
Agricultural and commercial uses are located across Oka Road. The site is designated as Low-
Density Residential. The site is zoned R-1:8, which would allow 26 housing units developed at a
typical density of 4 du/ac.
Property Owner Interest Form Submitted: No; however the property owner has submitted a
public comment to the HEAB regarding future development of the site.
Constraints: Proximity to adjacent highways.
Figure D-27 Oka Lane (Site E-2)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site E-3 Caltrans Right of Way
Address: Caltrans Right of Way
Number of Housing Units: 69
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Caltrans Right of Way Site (E-3) is located in the Lark Avenue Area south and
west of the Highway 17/Highway 85 interchange. The site is currently vacant. Major arterial
highways are located north and east of the site. Commercial uses are located west of the site
across Oka Road, and the Bonnie View mobile home park is located immediately south of the
site. Should the site be annexed by the Town, it is designated as Medium-Density Residential
and zoned as R-M:5-12, which would accommodate 69 housing units developed at a minimum
density of 14 du/ac.
Property Owner Interest Form Submitted: No, the Town has yet to reach out to Caltrans
regarding future development of the site.
Constraints: Consultation with Caltrans for future development.
Figure D-28 Caltrans Right of Way (Site E-3)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Figure D-29 Winchester Boulevard Area
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Site F-1 Knowles Drive
Address: 110 Knowles Drive
Number of Housing Units: 220
“By Right” + 20% Affordable: Required – Used in previous cycle.
Description: The Knowles Drive Site (F-1) is located in the Winchester Boulevard Area north and
west of the Highway 17/Highway 85 interchange. The site contains industrial uses. Los Gatos
Creek is immediately south and east of the site, with low-density residential uses located beyond.
High-density residential uses are located south and west of the site. Commercial/industrial uses
are located north of the site across Knowles Drive. The site is designated as High-Density
Residential and zoned CM:AHOZ, which would accommodate 220 housing units developed at a
minimum density of 30 du/ac.
Property Owner Interest Form Submitted: No; however the site is located within the Affordable
Housing Overlay Zone.
Constraints: Existing buildings would require demolition and adjacency to the Los Gatos Creek
Trail.
Figure D-30 Knowles Drive (Site F-1)
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site F-2 Winchester Boulevard
Address: 206 Knowles Drive
Number of Housing Units: 72
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Winchester Boulevard Site (F-2) is located in the Winchester Boulevard Area at
the northeast intersection of A Street and Knowles Drive. The site contains office uses. Multi-
family residential is located to the south and office uses are located to the north, south, and west
of the site. The site is designated as High-Density Residential and zoned CM, which would
accommodate 72 housing units developed at a minimum density of 30 du/ac.
Property Owner Interest Form Submitted: No; however, the site is located immediately
adjacent to 110 Knowles Drive (Site F-1), which has an Affordable Housing Overlay Zone.
Constraints: Existing buildings would require demolition and adjacency to the Los Gatos Creek
Trail.
Figure D-31 Winchester Boulevard (Site F-2)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Figure D-32 Union Avenue Area
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site G-1 Los Gatos-Almaden Road
Address: 440 Los Gatos Almaden Road
Number of Housing Units: 8
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Los Gatos-Almaden Road Site (G-1) is located in the Union Avenue Area at the
northwest corner of Leigh Avenue and Los Gatos-Almaden Road. The site contains a gas station
and commercial building. Low-density residential are located north, south, and west of the site.
Leigh High School is located east of the site across Leigh Avenue. The site is designated as
Neighborhood Commercial and zoned C-1, which would accommodate eight housing units
developed at a minimum density of 10 du/ac.
Property Owner Interest Form Submitted: Yes
Constraints: Existing gas station and commercial building would require demolition.
Figure D-33 Los Gatos-Almaden Road (Site G-1)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Figure D-34 Harwood Road Area
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site H-1 Valero Address: 14000 Blossom Hill Road
Number of Housing Units: 7
“By Right” + 20% Affordable: Not Required – Not used in previous cycle
Property Owner Interest Form Submitted:
Description: The Valero Site (H-1) is located in the Harwood Road Area at the southwest corner
of Blossom Hill Road and Harwood Road. The site contains a gas station. Low-density
residential are located north, south, and east of the site. Commercial uses are located
immediately west of the site. The site is designated as Neighborhood Commercial and zoned C-
1, which would accommodate seven housing units developed at a minimum density of 10 du/ac.
Property Owner Interest Form Submitted: Yes
Constraints: Existing gas station and commercial building would require demolition.
Figure D-35 Valero (Site H-1)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Figure D-36 Alberto Way Area
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Site I-1 Alberto Way
Address: 401-409 Alberto Way
Number of Housing Units: 60
“By Right” + 20% Affordable: Not Required – Not used in previous cycle.
Description: The Alberto Way Site (I-1) is located in the Alberto Way Area, located at the
intersection of Alberto Way and Los Gatos-Saratoga Road. The site is currently vacant. Multi-
family residential are located north and east of the site. Commercial uses are located
immediately south and east of the site with Highway 17 to the west. The site is designated as
Mixed Use Commercial and zoned CH, which would accommodate 60 housing units developed at
a density of 27 du/ac based on a development application submitted by the properyt owner to the
Town on December 6, 2022.
Property Owner Interest Form Submitted: Yes
Constraints: Proximity to adjacent Highway 17 onramp.
Figure D-37 Alberto Way (Site I-1)
HCD Draft Initial Review 2023-2031 Housing Element
D-2 Appendix D October 2022
Accessory Dwelling Unit (ADUs and Junior ADUs) Projections
Address: Various Locations
Number of Housing Units: 200
“By Right” + 20% Affordable: Not required, instead a formula exists for projecting the next eight-year cycle,
along with assumptions of 30 percent very-low income units, 30 percent low income units, 30 percent moderate
income units, and 10 percent above moderate categories.
Description: Accessory dwelling units according to ADU Ordinance.
Constraints: To have HCD consider 200 units as a reasonable expectation for construction in this eight-year
cycle, the Town is reliant upon the averaging of previous ADU permit submittals.
Senate Bill 9 (SB 9) Projections
Address: Various Locations
Minimum Number of Housing Units: 96
“By Right” + 20% Affordable: Not required – Instead, formula exists for projecting the next eight-year cycle.
Description: New housing units generated from the SB 9 Ordinance.
Constraints: To have HCD consider SB 9 units as a reasonable expectation for construction in this eight-year
cycle, the Town is reliant upon the averaging of previous SB 9 permit submittals.
Pipeline Projects
Address: Addresses listed below:
105 Newell Avenue – net four units
20101 Foster Road – net one unit
North Forty Phase I – net 14 units
465 North Santa Cruz Avenue – net one unit
16195 George Street – net three units
144 Wood Road – net one unit
16100 Greenridge Terrace – net seven units
15215 Shannon Road – net four units
17200 Los Robles – net two units
400 Surmont Drive – net two units
14915 Shannon Road – net 10 units
16220 Hardwood – net two units
14926 Los Gatos Boulevard – net five units
15415 National Avenue – net one unit
45 Reservoir Road – net one unit
200 Happy Acres – net one unit
15343 Santella Court – net one units
15415 Santella Court – net one unit
15365 Santella Court – net one unit
15860 Winchester Boulevard – net 113 units
120 Oak Meadow Drive – net one unit
Number of Housing Units: 176
“By Right” + 20% Affordable: Not required
Description: New housing units generated from projects with Planning entitlements and Planning applications
currently under Town review.
Constraints: None
Appendix D. Sites Inventory Analysis
October 2022 Appendix D D-1
Inventory of Vacant and Available Sites
This section provides the formal inventory of sites that the Town of Los Gatos will rely on in the 6th Housing
Element planning cycle. Per State law and Housing Policy, the Town is required to maintain “no net loss” of the
housing capacity represented by this list of parcels and the sites they comprise. To facilitate this, the inventory
presented in Appendix H has been designed with excess capacity. This allows some degree of flexibility in
decision making for individual development projects as they come forward for approval.
In short, with some limited flexibility, the Town is committed to permitting housing on each of the parcels listed in
the table below, and in so doing ensuring that the number of units listed for each parcel in the table "planned
capacity” is achieved. Should the Town approve development that is inconsistent with the parcel’s planned
capacity, it is then required as part of that approval to:
1. Find, based on quantitative evidence, that the remaining inventory of housing sites is still sufficient to
meet the Town’s 6th cycle RHNA; or
2. Identify one or more available sites with the realistic development capacity to replace the housing that
would have otherwise been developed had consistency with planned capacity been achieved.
Appendix H provides details and capacity estimates for each of the parcels that comprise the Site Inventory as
identified in the section above.
D. 4 Summary and Conclusions
The sites identified in this report are sufficient to accommodate Los Gatos’ Regional Housing Needs Allocation for
the 6th cycle planning period. This number accommodates a buffer of approximately 16 percent above RHNA,
which would equal capacity of approximately 319 additional units. These sites, in addition to Accessory Dwelling
Units Projections, Senate Bill 9 Projections, and Pipeline Projects have a total capacity of 2,312 units. This
“cushion” for capacity above the base RHNA number is highly recommended because of the State’s no-net-loss
policy, which precludes jurisdictions from approving development that results in an overall housing site deficit.
The “cushion” essentially provides a degree of flexibility for policy makers as they make development decisions.
Many of the sites identified in this report have existing uses that would need to be demolished before new housing
could be constructed.
For communities like Los Gatos that are largely built out and surrounded by other communities and
undevelopable hillsides, redevelopment and densification is the only practical solution to providing a fair share of
future housing for the San Francisco Bay Area. By its nature, such redevelopment is more costly and more time
consuming than building new units on vacant land. To offset these constraints, higher densities are proposed in
some areas. These higher densities act as a market incentive to offset the added cost and time required build
new housing on redeveloped sites. Property owner interest will be pivotal for facilitating single-family site
opportunities to add housing through construction of ADUs and use of SB 9 processes, which allow for up to four
units on a property zoned for a single house.
Review of Previous Housing Element E
APPENDIX
Appendix E. Review of Previous Housing Element
October 2022 Appendix E E-1
E.1 Introduction
In order to effectively plan for the future, it is important to reflect back on the goals of the previous Housing
Element and to identify those areas where progress was made and those areas where continued effort is needed.
State Housing Element guidelines require communities to evaluate their previous Housing Element according to
the following criteria:
Effectiveness of the Element.
Progress on Implementation.
Appropriateness in Goals, Objectives, and Policies.
E.2 Effectiveness of the Element
The Town of Los Gatos’ 2015 Housing Element identified the following goals:
Expand the choice of housing opportunities for all economic segments of the community by supporting the
development of affordable housing in a variety of types and sizes, including a mixture of ownership and
rental housing.
Maintain and/or adopt appropriate land use regulations and other development tools to encourage the
development of affordable housing that is compatible with the neighborhood and the community.
Preserve existing residential opportunities, including the existing affordable housing stock.
Ensure that all persons have equal access to housing opportunities.
Retain and expand affordable housing opportunities for seniors.
Mitigate Town governmental constraints to affordable and special needs housing development.
Encourage residential construction that promotes green building and energy conservation practices.
Ensure that the Town has sufficient resources and takes appropriate measures to implement the Housing
Element.
Maintain the Town’s 2005 jobs-to-household ratio of 1.5 jobs per household.
In order to achieve these goals, the 2015 Housing Element listed a series of policies and programs. The policies
covered a range of housing concerns, including appropriate zoning for lower and moderate-income households,
assisting in developing affordable housing, removing governmental constraints, conserving the existing affordable
housing stock, preventing the conversion of affordable units to market rate, and promoting equal housing
opportunities for all persons. The policies comply with State housing law guidelines.
HCD Draft Initial Review 2023-2031 Housing Element
E-2 Appendix E October 2022
E.3 Progress on Implementation
To assess the Town’s progress on implementing the 2015 Housing Element, the following key areas were
reviewed:
Adopted Programs;
Production of Housing;
Preservation of “At Risk” Units; and
Rehabilitation of Existing Units.
Each of these areas is discussed in detail below.
Overview of Adopted Programs
Table E-1 below identifies all of the actions the Town committed to in the 2015 Housing Element. The table also
includes a description of the progress that was made during the 2015 to 2023 planning period.
Appendix E. Review of Previous Housing Element
October 2022 Appendix E E-3
Table E-1 Overview of Adopted Programs
No. Programs (The text provided in this column is a synopsis only; for complete program language refer to the 2015 Housing Element) Achievements/Effectiveness Continue/Modify/Delete
Goal
HOU-1
Expand the choice of housing opportunities for all economic segments of the community by supporting the development of
affordable housing in a variety of types and sizes, including a mixture of ownership and rental housing. Modify
Policy
HOU-1.1 Develop and utilize all available housing funding resources in order to provide the maximum amount of affordable housing as feasible. Modify
Policy
HOU-1.2 Work with nonprofit agencies and housing developers to plan and develop a mix of affordable housing opportunities in Los Gatos. Modify
Actions
1.1 Continue to implement the Below Market Price (BMP) program and evaluate it
annually to ensure it is not a constraint to development.
BMP Program is implemented on all residential
projects that meet the criteria. Modify
1.2
Amend the Town Code to allow new deed restricted Accessory Dwelling Units
(ADU) to be affordable to lower income households on non-conforming residential
lots over 10,000 square feet and in the Hillside Residential Zone on sites that are
larger than 5 acres.
Town Code has been amended to address this. Modify
1.3
Continue to provide up to a 100 percent density bonus for developments that
include housing for elderly, handicapped, and/or very low and low-income
households.
This is an incentive that is provided to projects
that meet the criteria. Modify
1.4
Using BMP in-lieu fees, implement the proposed programs and initiatives of the
Town’s Affordable Housing Strategies to increase and preserve affordable housing,
such as purchasing affordability covenants in existing apartments.
Use of BMP in-lieu fees will be considered as
opportunities arise. Modify
1.5 Hold a periodic outreach meeting with affordable housing developers to discuss
the development of housing affordable to extremely low-income households.
The Town will consider incentives when projects
of this nature are proposed. Modify
1.6
Encourage the creation of housing that is affordable to extremely low-income
households by considering allocating a percentage of the Town’s Affordable
Housing (Below Market Price) fund to subsidize housing for extremely low-income
households.
Use of BMP in-lieu fees will be considered as
opportunities arise. Modify
1.7
The Town will rezone 13.5 acres within the North 40 Specific Plan area within three
years of Housing Element adoption at minimum a density of 20 dwelling units per
acre to facilitate affordable housing production.
Complete Delete
HCD Draft Initial Review 2023-2031 Housing Element
E-4 Appendix E October 2022
No. Programs (The text provided in this column is a synopsis only; for complete program language refer to the 2015 Housing Element) Achievements/Effectiveness Continue/Modify/
Delete
1.8
To assist the development of housing for lower income households on sites larger
than ten acres, the Town will facilitate land divisions and lot line adjustments to
result in parcels sizes between one to ten acres that facilitate multiple-family
developments affordable to lower income households in light of state, federal and
local financing programs.
Projects are given priority. Continue
Goal
HOU-2
Maintain and/or adopt appropriate land use regulations and other development tools to encourage the development of affordable
housing that is compatible with the neighborhood and the community. Modify
Policy
HOU-2.1
Continue to designate sufficient, residentially zoned land at appropriate densities to provide adequate sites to accommodate Los
Gatos’s RHNA for 2015–2023. Continue
Policy
HOU-2.2
Ensure that the Town will provide sufficient land at appropriate zoning categories to meet its RHNA for very low-, and moderate-
income households, as demonstrated in the Housing Sites Inventory analysis in Chapter 6 of the Housing Element Technical Appendix. Modify
Policy
HOU-2.3
Encourage mixed–use developments that provide affordable housing close to employment centers and/or transportation facilities,
particularly along Los Gatos Boulevard and within a ½-mile radius of the future Vasona light rail station. Modify
Policy
HOU-2.4
Demonstrate that all new residential development is sufficiently served by public services and facilities, including pedestrian and
vehicular circulation, water and wastewater services, police, fire, schools, and parks. Continue
Policy
HOU-2.5 New single-family, multi-family, and mixed-use developments shall be compatible with the character of the surrounding neighborhood. Modify
Policy
HOU-2.6 Strive to ensure that at least 30 percent of the housing stock is rental units. Modify
Policy
HOU-2.7 Create new affordable housing opportunities through acquisition using Affordable Housing Funds. Delete
Actions
2.1 Continue to implement the minimum density and affordable housing incentives
within the AHOZ
This will be implemented when a project in the
AHOZ is considered. Modify
2.2
For multiple-family residential development within the North 40 and the Southbay
AHOZ site, subject to by right development, the Town will amend the Town Code to
add by right development findings.
This has not yet been completed. Modify
2.3 The Town Code (Zoning Regulations) will be amended to clarify that Transitional
and Supportive Housing is permitted in all residential zones by right.
The Town will comply with State Law and SB 743 if
a project is proposed before the Town Code is
amended.
Delete
Appendix E. Review of Previous Housing Element
October 2022 Appendix E E-5
No. Programs (The text provided in this column is a synopsis only; for complete program language refer to the 2015 Housing Element) Achievements/Effectiveness Continue/Modify/
Delete
2.4
For multiple family residential development within the North 40 and the Southbay
AHOZ site subject to by right development, the Town will amend the Town Code to
add by right development findings.
This has not yet been completed. Modify
2.5
To ensure adequate residential capacity to accommodate the RHNA for each
income category, the Town will develop and implement an ongoing formal
evaluation procedure (project-by-project) of sites identified in the Sites Inventory.
If this situation arises the Town will comply with
this requirement. Modify
Goal
HOU-3 Preserve existing residential opportunities, including the existing affordable housing stock. Modify
Policy
HOU-3.1 Encourage the maintenance and improvement of existing housing units. Modify
Policy
HOU-3.2
Support the preservation and conservation of existing housing units that provide affordable housing opportunities for Town residents
and workers. Modify
Policy
HOU-3.3 Improve the quality of rental housing by acquisition and/or rehabilitation using Affordable Housing Fund. Modify
Policy
HOU-3.4
Preserve the affordability of units affordable to very low-, low-, and moderate-income households in Bonnie View Park, and enforce
zoning regulations regarding conversion of mobile home parks in Los Gatos. Continue
Actions
3.1 Continue to monitor affordable, multi-family housing units in the Town to ensure
that they retain their affordability status.
No units have been converted to market rate
rents. Continue
3.2
The Town will continue to implement Section 29.20.155 of the Town Code that
addresses conversions of residential use, specifically Section 29.20.155(a)(2) that
requires that any proposed conversion satisfy the housing goals and policies as set
forth in the General Plan.
This will be considered if a conversion of
residential uses is proposed. Continue
3.3
Continue to participate in the County of Santa Clara Community Development
Block Grant Joint Powers Authority so Town residents can participate in County
CDBG Housing Rehabilitation programs.
The Town still participates in these programs. Continue
3.4
Continue to support countywide programs that provide assistance with minor
home repairs and accessibility improvements for lower-income households,
including special needs households.
The Town supports these programs. Continue
Goal
HOU-4 Ensure that all persons have equal access to housing opportunities.
Policy
HOU-4.1 Support housing programs that protect individuals’ rights. Modify
HCD Draft Initial Review 2023-2031 Housing Element
E-6 Appendix E October 2022
No. Programs (The text provided in this column is a synopsis only; for complete program language refer to the 2015 Housing Element) Achievements/Effectiveness Continue/Modify/
Delete
Policy
HOU-4.2
Continue to provide assistance to service providers who support special needs households such as seniors, persons with disabilities
(including developmental challenges), and the homeless, such as Project Sentinel, Santa Clara County Housing Authority, and Santa
Clara County Office of Supportive Housing.
Modify
Policy
HOU-4.3 Continue to encourage Los Gatos households to participate in financial assistance programs provided in the County of Santa Clara. Continue
Actions
4.1 Continue to provide a guide to developments that include affordable housing units
as part of the Housing Resources Guide posted on the Town’s website.
Town Housing Resources Guide is updated when
necessary. Modify
4.2
Continue the administration of the Rental Dispute Resolution Program and
consider revisions as necessary to make the program as effective as possible in
protecting both tenants and landlords’ rights.
The Town continues to use Project Sentinel to
administer a Rental Dispute Resolution Program. Continue
4.3
Continue to allow for an emergency shelter as a by-right permitted use in the
Controlled Manufacturing (CM) zoning district, subject to appropriate development
standards.
Town Code has been amended to address this. Delete
4.4 Continue to provide support for community and non-profit organizations providing
supportive services for homeless persons in Los Gatos.
The Town continues to support organizations that
provide supportive services for homeless persons. Continue
4.5
Support the efforts of the Santa Clara County Fair Housing Consortium. Continue
to make referrals through Project Sentinel and provide updated fair housing
information on the Town’s website and at public locations through the Town, such
as the Adult Recreation Center and public kiosks.
Project Sentinel is a member of the Santa Clara
County Fair Housing Consortium and administers
the Town's Rental Dispute Resolution Program. Modify
4.6 Support the efforts of non-profit affordable housing organizations that provide
housing services in Los Gatos.
The Town has met with affordable housing
organizations regarding potential development in
Town. Modify
4.7 Continue to support the County of Santa Clara’s Continuum of Care plan, as well as
the “Housing 1000” campaign by Destination: Home.
The Town continues to support Santa Clara
County's Continuum of Care Plan. Continue
4.8 The Town shall amend the Town Code within one year of the Housing Element
adoption to be consistent with the Employee Housing Act.
The Town will comply with State Law if a project is
proposed, or an issue comes up before the Town
Code is amended. Delete
Appendix E. Review of Previous Housing Element
October 2022 Appendix E E-7
No. Programs (The text provided in this column is a synopsis only; for complete program language refer to the 2015 Housing Element) Achievements/Effectiveness Continue/Modify/
Delete
Goal
HOU-5 Retain and expand affordable housing opportunities for seniors. Modify
Policy
HOU-5.1 Promote the Town’s Housing Conservation Program to assist low-income seniors with basic home repairs and maintenance. Modify
Policy
HOU-5.2
Allow and encourage small-scale living facilities of two to six seniors that may include nursing care services that can be integrated into
existing neighborhoods as infill development. Delete
Policy
HOU-5.3
Work with existing senior lifestyle living and assisted living facilities in Los Gatos, and support the development of new senior housing
that includes continuum of care facilities within the Town. Modify
Actions
5.1 Provide regularly updated senior housing resource materials at the Adult Recreation Center.
Senior resource materials are updated when
necessary. Modify
Goal
HOU-6 Mitigate Town governmental constraints to affordable and special needs housing development. Modify
Policy
HOU-6.1 Continue expediting the permit processing system for affordable residential development applications. Modify
Policy
HOU-6.2 Encourage universal design features in all new residential developments, to supplement the Title 24 requirements. Modify
Policy
HOU-6.3 Support the rehabilitation and modification of housing to allow accessible to people of all abilities. Modify
Policy
HOU-6.4
Support the provision of permanent, affordable, and accessible housing that allows persons with special needs to live independent
lives. For the purposes of this Housing Element “persons with special needs” include extremely low-income households, the elderly,
overcrowded and large-family households, the homeless population, those in need of emergency shelter, youth aging out of foster
care, female-headed or single-parent households, and persons with disabilities, including developmental challenges.
Continue
Policy
HOU-6.5 Support efforts to provide coordinated services for persons with special needs in the Town. Modify
Actions
6.1 Regularly review Town planning and zoning regulations and remove affordable
housing development constraints as appropriate.
The Town's Housing Element contains a number
of items that limit or remove constraints. Modify
HCD Draft Initial Review 2023-2031 Housing Element
E-8 Appendix E October 2022
No. Programs (The text provided in this column is a synopsis only; for complete program language refer to the 2015 Housing Element) Achievements/Effectiveness Continue/Modify/
Delete
6.2
Continue to enforce Section 29.10.505–530 of the Town Code to ensure equal
access to housing for persons with disabilities under the Fair Housing Act and
provide specific procedures for requesting and granting reasonable
accommodations.
This has not yet been completed. Continue
6.3 Remove constraints to housing for persons with disabilities and encourage
accessible housing in new residential developments.
Removal of constraints is considered when
necessary. Modify
6.4 Give priority to special needs housing by allowing for reduced processing time and
streamlined procedures for such appropriate zoning/land use applications.
If a project of this nature is submitted it will be
given priority. Modify
6.5 Include preferential handling of special needs populations in management plans
and regulatory agreements of funded projects.
Will be considered when plans are adopted, and
projects are funded. Modify
6.6 Explore opportunities to work with local and/or regional partners to provide rental
assistance for persons with developmental challenges.
The Town will explore opportunities with local
and/or regional partners during the Housing
Element update process. Modify
6.7
Consider development of universal design enhancements to existing design
guidelines and standards to encourage the inclusion of universal design features in
new construction. Periodically study every two years and adopt as appropriate
specific revisions or amendments to the Town’s development documents as part of
the Town Building Code.
The Town considers enhancements to universal
design and the Town requires universal design
features in new construction consistent with
Building Code requirements.
Delete
6.8
Increase awareness of universal design principles by periodically educating the
Town Council, Commissions, and Boards about universal design and making
information available to residents and builders at the Community Development
Counter.
The Town takes appropriate actions to increase
awareness of universal design principles. Delete
6.9
Continue to work with the local California Department of Developmental Services
Regional Center to continue to inform families within Los Gatos on housing and
services available for persons with developmental challenges.
The Town works with the California Department
of Developmental Services to inform citizens of
available services. Modify
6.10
On a biannual basis, continue to review, evaluate, update, and streamline as
necessary, the development process for housing developments that will guarantee
affordable units on a long-term basis for very low-, low-, and moderate-income
households.
The Town considers improvements to the
development review process for affordable
housing projects when they are proposed. Delete
Appendix E. Review of Previous Housing Element
October 2022 Appendix E E-9
No. Programs (The text provided in this column is a synopsis only; for complete program language refer to the 2015 Housing Element) Achievements/Effectiveness Continue/Modify/
Delete
Goal
HOU-7 Encourage residential construction that promotes green building and energy conservation practices. Modify
Policy
HOU-7.1
Encourage sustainable housing development throughout the Town using the Town’s voluntary green building program by continuing to
require that all residential development applications complete the Build It Green GreenPoint Rated Checklist as part of the
development application package.
Modify
Policy
HOU-7.2 Promote the construction of energy efficient new homes utilizing the Energy Star Homes Program. Delete
7.1
Continue to enforce State of California Title 24 requirements for energy
conservation. The Town enforces Title 24 requirements. Continue
Goal
HOU-8 Ensure that the Town has sufficient resources and takes appropriate measures to implement the Housing Element. Modify
Policy
HOU-8.1
All approvals of residential developments of three or more units shall include a finding that the proposed development is consistent
with the Town’s Housing Element and addresses the Town’s housing needs as identified in the Housing Element. Delete
Policy
HOU-8.2 Provide adequate management and staffing of affordable housing funds and programs. Continue
8.1
Prepare an annual housing report for the review of the Town Council including
information on progress made towards achieving new construction need,
affordable housing conserved/developed, effectiveness of existing programs and
recommendations for improvement.
The Town prepares an annual housing report. Continue
8.2 Continue to fund staff for the management and planning of housing programs and
funding for the Town.
The Town has contracted with HouseKeys to
administer our affordable housing program and
has staff that dedicate time to the Town’s
affordable housing program.
Delete
8.3 Deliver the adopted Housing Element to the San Jose Water Company and the
West Valley Sanitation District.
Town staff regularly work with the San Jose Water
Company and West Valley Sanitation District on
upgrades to their infrastructure and they are
involved in development applications and
environmental review.
Modify
HCD Draft Initial Review 2023-2031 Housing Element
E-10 Appendix E October 2022
Production of Housing
The 2015 Housing Element identified a Regional Housing Needs Allocation (RHNA) of 619 housing units in Los
Gatos between January 1, 2015, and June 30, 2023. The RHNA was divided into the following income
categories:
100 units affordable to extremely low-income households.
101 units affordable to very low-income households.
112 units affordable to low-income households.
132 units affordable to moderate-income households.
174 units affordable to above moderate-income households.
As shown in Table A5-2, during the 2015–2023 planning period, 511 new units were added to the Town’s housing
stock, achieving approximately 83 percent of the Town’s RHNA. Units affordable to moderate- and lower-income
households that were created during the planning period include density bonus senior rental units (North Forty
Phase I), an attached condominium (Union Avenue) and detached townhomes (Knowles Avenue) produced
through the BMP program and accessory dwelling units.
Table E-2 Housing Units Produced, January 1, 2015, to June 30, 2023
Affordability New Construction Need Housing Units Produced Percent Achieved
Extremely Low 100 0 *
Very Low 101 49 24.4%
Low 112 3 2.7%
Moderate 132 120 90.9%
Above Moderate 174 339 194.8%
Total 619 511 82.5%
Source: HCD Annual Progress Report Dashboard (as of August 5, 2022).
Note: This table and text will be updated prior to finalization to account for units through January 1, 2023.
Preservation of “At Risk” Units
According to the 2015 Housing Element, there were no affordable units at risk of converting to market rate within
10 years from the beginning of the 2015 to 2023 planning period.
Rehabilitation of Existing Units
The Town did not rehabilitate any housing units between 2015 and 2023.
Appendix E. Review of Previous Housing Element
October 2022 Appendix E E-11
E.4 Appropriateness of Goals, Objectives, and Policies
The goals, objectives, and policies identified in the 2015 Housing Element were appropriate for the 2015 to 2023
timeframe because they directly relate to the program requirements listed by the California Department of
Housing and Community Development.
As for new construction, the greatest progress was made in producing housing in the moderate income and
above moderate-income categories, where the Town permitted approximately 62 percent and 80 percent of the
needed units, respectively. The Town permitted only about a quarter of its needed very low-income units and less
than three percent of its low-income units. As was the case in the in prior years, the cost of housing continued to
be high in Los Gatos, making affordable housing difficult to develop in the Los Gatos market. The Town
successfully provided the governmental framework to encourage and facilitate affordable housing through a
continuation of its BMP program and enhanced Accessory Dwelling Unit Ordinance.
E.5 Summary
Like many communities, the Town of Los Gatos experienced less development than expected in its 2015–2023
planning period. Of the 630 units it identified in its table of quantified housing objectives (Table H-3 on page 47 of
the 2015 Housing Element), the Town permitted 511 units (approximately 81 percent), most of them for above
moderate-income households.
Nonetheless, the goals, objectives, policies, and actions in the 2015 to 2023 Housing Element complied with
State housing law that was in effect at the time and provided proper guidance for housing development in the
Town. In the 2023 to 2031 Housing Element update, objectives for each of the goals will be modified as
appropriate to more specifically respond to the current housing environment in Los Gatos. Policies will also be
modified as needed to respond to current Housing Element law and existing and anticipated residential
development conditions.
List of Organizations Contacted F
APPENDIX
Appendix F. List of Organizations Contacted
October 2022 Appendix F F-1
F.1 List of Organizations Contacted
1 Native American Heritage Commission Tribal Consultation List Santa Clara County
07/22/2020
1 Amah Mutsun Tribal Band
Valentin Lopez, Chairperson
P.O. Box 5272
Galt, CA 95632
Phone number (916) 743-5833
vlopez@amahmutsun.org
2 Amah Mutsun Tribal Band of Mission San Juan Bautista
Irenne Zwierlein, Chairperson
789 Canada Road
Woodside, CA 94062
Phone: (650) 851-7489
Fax: (650) 332-1526
amahmutsuntribal@gmail.com
3 Indian Canyon Mutsun Band of Costanoan
Ann Marie Sayers, Chairperson
P.O. Box 28
Hollister, CA 95024
Phone number (831) 637-4238
ams@indiancanyon.org
4 Muwekma Ohlone Indian Tribe of the SF Bay Area
Charlene Mijmeh, Chairperson
20885 Redwood Road, Suite 232
Castro Valley, CA 94546
Phone: (408) 464-2892
cnijmeh@muwekma.org
5 Muwekma Ohlone Indian Tribe of the SF Bay Area
Monica Arellano
20885 Redwood Road, Suite 232
Castro Valley, CA 94546
marellano@muwekma.org
6 North Valley Yokuts Tribe
Timothy Perez, MLD Contact
P.O. Box 717
Linden, CA 95236
Phone: (209) 662-2788
huskanam@gmail.com
HCD Draft Initial Review 2023-2031 Housing Element
F-2 Appendix F October 2022
7 North Valley Yokuts Tribe
Katherine Perez, Chairperson
P.O. Box 717
Linden, CA 95236
Phone: (209) 887-3415
canutes@verizon.net
8 The Ohlone Indian Tribe
Andres Galvan
P.O. Box 3388
Fremont, CA 94539
Phone: (510) 882-0527
Fax: (510) 687-9393
chochenyo@aol.com
9 The Confederated Villages of Lisjan
Corrina Gould, Chairperson
10926 Edes Avenue
Oakland, CA 94603
Phone: (510) 882-027
cvltribe@gmail.com
2 Additional List of Contacted Organizations
1
2
3
Santa Clara County Social Services Agency
353 West Julian Street
San Jose, CA 95110
clientcomments@ssa.sccgov.org
(408)755-7100
Pancho Guevara
Executive Director
Sacred Heart Community Service
1381 South First Street
San Jose, CA 95110
(408) 278-2160
United Way Bay Area
1400 Parkmoor Avenue San Jose, Ca 95126
(408) 345-4300
Appendix F. List of Organizations Contacted
October 2022 Appendix F F-3
Engage Los Gatos Housing 3
HCD Draft Initial Review 2023-2031 Housing Element
F-4 Appendix F October 2022
Appendix F. List of Organizations Contacted
October 2022 Appendix F F-5
HCD Draft Initial Review 2023-2031 Housing Element
F-6 Appendix F October 2022
Appendix F. List of Organizations Contacted
October 2022 Appendix F F-7
HCD Draft Initial Review 2023-2031 Housing Element
F-8 Appendix F October 2022
This Page Intentionally Left Blank
AFFH Segregation Report Los Gatos G
APPENDIX
1
AFFH SEGREGATION REPORT: LOS
GATOS
UC Merced Urban Policy Lab and ABAG/MTC Staff
Version of Record: March 06, 15:57:57
2
0.1 Table of content
0.1 Table of content .................................................................................................... 2
0.2 List of figures ....................................................................................................... 3
0.3 List of tables ........................................................................................................ 3
1 Introduction .............................................................................................................. 4
1.1 Purpose of this Report ............................................................................................. 4
1.2 Defining Segregation ............................................................................................... 5
1.3 Segregation Patterns in the Bay Area ........................................................................... 5
1.4 Segregation and Land Use ......................................................................................... 6
2 Racial Segregation in Town of Los Gatos ........................................................................... 8
2.1 Neighborhood Level Racial Segregation (within Town of Los Gatos) ...................................... 8
2.2 Regional Racial Segregation (between Los Gatos and other jurisdictions) .............................. 16
3 Income Segregation in Town of Los Gatos ........................................................................ 21
3.1 Neighborhood Level Income Segregation (within Los Gatos) ............................................... 21
3.2 Regional Income Segregation (between Los Gatos and other jurisdictions) ............................. 27
4 Appendix 1: Summary of Findings ................................................................................. 31
4.1 Segregation in Town of Los Gatos .............................................................................. 31
4.2 Segregation Between Town of Los Gatos and Other jurisdictions in the Bay Area Region ............ 31
5 Appendix 2: Segregation Data ...................................................................................... 33
6 References .............................................................................................................. 37
3
0.2 List of figures
Figure 1: Racial Dot Map of Los Gatos (2020) .............................................................................. 9
Figure 2: Racial Isolation Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2020) ....... 11
Figure 3: Racial Dissimilarity Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2020) .. 14
Figure 4: Theil’s H Index Values for Racial Segregation in Los Gatos Compared to Other Bay Area Jurisdictions
(2020) ........................................................................................................................... 15
Figure 5: Racial Dot Map of Los Gatos and Surrounding Areas (2020) ................................................ 16
Figure 6: Racial Demographics of Los Gatos Compared to All Bay Area Jurisdictions (2020) ..................... 18
Figure 7: Comparing the Share of People of Color in Los Gatos and Vicinity to the Bay Area (2020) ........... 19
Figure 8: Income Dot Map of Los Gatos (2015) ........................................................................... 22
Figure 9: Income Group Isolation Index Values for Los Gatos Compared to Other Bay Area Jurisdictions (2015)
................................................................................................................................... 24
Figure 10: Income Group Dissimilarity Index Values for Los Gatos Compared to Other Bay Area Jurisdictions
(2015) ........................................................................................................................... 26
Figure 11: Income Group Theil’s H Index Values for Los Gatos Compared to Other Bay Area Jurisdictions
(2015) ........................................................................................................................... 27
Figure 12: Income Dot Map of Los Gatos and Surrounding Areas (2015) .............................................. 28
Figure 13: Income Demographics of Los Gatos Compared to Other Bay Area Jurisdictions (2015) ............... 29
0.3 List of tables
Table 1: Racial Isolation Index Values for Segregation within Los Gatos ............................................. 10
Table 2: Racial Dissimilarity Index Values for Segregation within Los Gatos ........................................ 13
Table 3: Theil’s H Index Values for Racial Segregation within Los Gatos ............................................ 15
Table 4: Population by Racial Group, Los Gatos and the Region ...................................................... 17
Table 5: Regional Racial Segregation Measures .......................................................................... 20
Table 6: Income Group Isolation Index Values for Segregation within Los Gatos ................................... 23
Table 7: Income Group Dissimilarity Index Values for Segregation within Los Gatos .............................. 25
Table 8: Theil’s H Index Values for Income Segregation within Los Gatos ........................................... 26
Table 9: Population by Income Group, Los Gatos and the Region ..................................................... 28
Table 10: Regional Income Segregation Measures ....................................................................... 30
Table 11: Neighborhood Racial Segregation Levels in Los Gatos ...................................................... 33
Table 12: Neighborhood Income Segregation Levels in Los Gatos ..................................................... 34
Table 13: Regional Racial Segregation Measures ......................................................................... 35
Table 14: Regional Income Segregation Measures ....................................................................... 35
Table 15: Population by Racial Group, Los Gatos and the Region ..................................................... 36
Table 16: Population by Income Group, Los Gatos and the Region ................................................... 36
4
1 INTRODUCTION
The requirement to Affirmatively Further Fair Housing (AFFH) is derived from The Fair Housing Act of
1968, which prohibited discrimination concerning the sale, rental, and financing of housing based on
race, color, religion, national origin, or sex—and was later amended to include familial status and
disability.1 The 2015 U.S. Department of Housing and Urban Development (HUD) Rule to Affirmatively
Further Fair Housing and California Assembly Bill 686 (2018) mandate that each jurisdiction takes
meaningful action to address significant disparities in housing needs and access to opportunity.23 AB
686 requires that jurisdictions incorporate AFFH into their Housing Elements, which includes inclusive
community participation, an assessment of fair housing, a site inventory reflective of AFFH, and the
development of goals, policies, and programs to meaningfully address local fair housing issues. ABAG
and UC Merced have prepared this report to assist Bay Area jurisdictions with the Assessment of Fair
Housing section of the Housing Element.
Assessment of Fair Housing Components
The Assessment of Fair Housing includes five components, which are
discussed in detail on pages 22-43 of HCD’s AFFH Guidance Memo:
A: Summary of fair housing enforcement and outreach capacity
B: Integration and segregation patterns, and trends related to people with
protected characteristics
C: Racially or ethnically concentrated areas of poverty
D: Disparities in access to opportunity
E: Disproportionate housing needs, including displacement risk
1.1 Purpose of this Report
This report describes racial and income segregation in Bay Area jurisdictions. Local jurisdiction staff
can use the information in this report to help fulfill a portion of the second component of the
Assessment of Fair Housing, which requires analysis of integration and segregation patterns and trends
related to people with protected characteristics and lower incomes. Jurisdictions will still need to
perform a similar analysis for familial status and populations with disability.
This report provides segregation measures for both the local jurisdiction and the region using several
indices. For segregation between neighborhoods within a city (intra-city segregation), this report
includes isolation indices, dissimilarity indices, and Theil’s-H index. The isolation index measures
1 https://www.justice.gov/crt/fair-housing-act-2
2 HCD AFFH Guidance Memo 3 The 2015 HUD rule was reversed in 2020 and partially reinstated in 2021.
5
segregation for a single group, while the dissimilarity index measures segregation between two groups.
The Theil’s H-Index can be used to measure segregation between all racial or income groups across the
city at once. HCD’s AFFH guidelines require local jurisdictions to include isolation indices and
dissimilarity indices in the Housing Element. Theil’s H index is provided in addition to these required
measures. For segregation between cities within the Bay Area (inter-city segregation), this report
includes dissimilarity indices at the regional level as required by HCD’s AFFH guidelines. HCD’s AFFH
guidelines also require jurisdictions to compare conditions at the local level to the rest of the region;
and this report presents the difference in the racial and income composition of a jurisdiction relative
to the region as a whole to satisfy the comparison requirement.
1.2 Defining Segregation
Segregation is the separation of different demographic groups into different geographic locations or
communities, meaning that groups are unevenly distributed across geographic space. This report
examines two spatial forms of segregation: neighborhood level segregation within a local jurisdiction
and city level segregation between jurisdictions in the Bay Area.
Neighborhood level segregation (within a jurisdiction, or intra-city): Segregation of race and income
groups can occur from neighborhood to neighborhood within a city. For example, if a local jurisdiction
has a population that is 20% Latinx, but some neighborhoods are 80% Latinx while others have nearly no
Latinx residents, that jurisdiction would have segregated neighborhoods.
City level segregation (between jurisdictions in a region, or inter-city): Race and income divides also
occur between jurisdictions in a region. A region could be very diverse with equal numbers of white,
Asian, Black, and Latinx residents, but the region could also be highly segregated with each city
comprised solely of one racial group.
There are many factors that have contributed to the generation and maintenance of segregation.
Historically, racial segregation stemmed from explicit discrimination against people of color, such as
restrictive covenants, redlining, and discrimination in mortgage lending. This history includes many
overtly discriminatory policies made by federal, state, and local governments (Rothstein 2017).
Segregation patterns are also affected by policies that appear race-neutral, such as land use decisions
and the regulation of housing development.
Segregation has resulted in vastly unequal access to public goods such as quality schools, neighborhood
services and amenities, parks and playgrounds, clean air and water, and public safety (Trounstine
2015). This generational lack of access for many communities, particularly people of color and lower
income residents, has often resulted in poor life outcomes, including lower educational attainment,
higher morbidity rates, and higher mortality rates (Chetty and Hendren 2018, Ananat 2011, Burch 2014,
Cutler and Glaeser 1997, Sampson 2012, Sharkey 2013).
1.3 Segregation Patterns in the Bay Area
Across the San Francisco Bay Area, white residents and above moderate-income residents are
significantly more segregated from other racial and income groups (see Appendix 2). The highest levels
of racial segregation occur between the Black and white populations. The analysis completed for this
report indicates that the amount of racial segregation both within Bay Area cities and across
jurisdictions in the region has decreased since the year 2000. This finding is consistent with recent
research from the Othering and Belonging Institute at UC Berkeley, which concluded that “[a]lthough 7
6
of the 9 Bay Area counties were more segregated in 2020 than they were in either 1980 or 1990, racial
residential segregation in the region appears to have peaked around the year 2000 and has generally
declined since.”4 However, compared to cities in other parts of California, Bay Area jurisdictions have
more neighborhood level segregation between residents from different racial groups. Additionally,
there is also more racial segregation between Bay Area cities compared to other regions in the state.
1.4 Segregation and Land Use
It is difficult to address segregation patterns without an analysis of both historical and existing land use
policies that impact segregation patterns. Land use regulations influence what kind of housing is built
in a city or neighborhood (Lens and Monkkonen 2016, Pendall 2000). These land use regulations in turn
impact demographics: they can be used to affect the number of houses in a community, the number of
people who live in the community, the wealth of the people who live in the community, and where
within the community they reside (Trounstine 2018). Given disparities in wealth by race and ethnicity,
the ability to afford housing in different neighborhoods, as influenced by land use regulations, is highly
differentiated across racial and ethnic groups (Bayer, McMillan, and Reuben 2004).5 ABAG/MTC plans to
issue a separate report detailing the existing land use policies that influence segregation patterns in
the Bay Area.
4 For more information, see https://belonging.berkeley.edu/most-segregated-cities-bay-area-2020.
5 Using a household-weighted median of Bay Area county median household incomes, regional values were $61,050
for Black residents, $122,174 for Asian/Pacific Islander residents, $121,794 for white residents, and $76,306 for
Latinx residents. For the source data, see U.S. Census Bureau, American Community Survey 5-Year Data (2015-
2019), Table B19013B, Table B19013D, B19013H, and B19013I.
7
Definition of Terms - Geographies
Neighborhood: In this report, “neighborhoods” are approximated by
tracts.6 Tracts are statistical geographic units defined by the U.S. Census
Bureau for the purposes of disseminating data. In the Bay Area, tracts
contain on average 4,500 residents. Nearly all Bay Area jurisdictions
contain at least two census tracts, with larger jurisdictions containing
dozens of tracts.
Jurisdiction: Jurisdiction is used to refer to the 109 cities, towns, and
unincorporated county areas that are members of ABAG. Though not all
ABAG jurisdictions are cities, this report also uses the term “city”
interchangeably with “jurisdiction” in some places.
Region: The region is the nine-county San Francisco Bay Area, which is
comprised of Alameda County, Contra Costa County, Marin County,
Napa County, San Francisco County, San Mateo County, Santa Clara
County, Solano County, and Sonoma County.
6 Throughout this report, neighborhood level segregation measures are calculated using census tract data.
However, the racial dot maps in Figure 1 and Figure 5 use data from census blocks, while the income group dot
maps in Figure 8 and Figure 12 use data from census block groups. These maps use data derived from a smaller
geographic scale to better show spatial differences in where different groups live. Census block groups are
subdivisions of census tracts, and census blocks are subdivisions of block groups. In the Bay Area, block groups
contain on average 1,500 people, while census blocks contain on average 95 people.
8
2 RACIAL SEGREGATION IN TOWN OF LOS GATOS
Definition of Terms - Racial/Ethnic Groups
The U.S. Census Bureau classifies racial groups (e.g. white or Black/African
American) separately from Hispanic/Latino ethnicity.7 This report combines
U.S. Census Bureau definitions for race and ethnicity into the following
racial groups:
White: Non-Hispanic white
Latinx: Hispanic or Latino of any race8
Black: Non-Hispanic Black/African American
Asian/Pacific Islander: Non-Hispanic Asian or Non-Hispanic Pacific Islander
People of Color: All who are not non-Hispanic white (including people
who identify as “some other race” or “two or more races”)9
2.1 Neighborhood Level Racial Segregation (within Town of Los Gatos)
Racial dot maps are useful for visualizing how multiple racial groups are distributed within a specific
geography. The racial dot map of Los Gatos in Figure 1 below offers a visual representation of the
spatial distribution of racial groups within the jurisdiction. Generally, when the distribution of dots
does not suggest patterns or clustering, segregation measures tend to be lower. Conversely, when
clusters of certain groups are apparent on a racial dot map, segregation measures may be higher.
7 More information about the Census Bureau’s definitions of racial groups is available here:
https://www.census.gov/topics/population/race/about.html.
8 The term Hispanic has historically been used to describe people from numerous Central American, South
American, and Caribbean countries. In recent years, the term Latino or Latinx has become preferred. This report
generally uses Latinx to refer to this racial/ethnic group.
9 Given the uncertainty in the data for population size estimates for racial and ethnic groups not included in the
Latinx, Black, or Asian/Pacific Islander categories, this report only analyzes these racial groups in the aggregate
People of Color category.
9
Figure 1: Racial Dot Map of Los Gatos (2020)
Universe: Population. Source: U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020
Census of Population and Housing, Table P002.
Note: The plot shows the racial distribution at the census block level for Town of Los Gatos and vicinity. Dots in each census
block are randomly placed and should not be construed as actual placement of people.
There are many ways to quantitatively measure segregation. Each measure captures a different aspect
of the ways in which groups are divided within a community. One way to measure segregation is by
using an isolation index:
• The isolation index compares each neighborhood’s composition to the jurisdiction’s
demographics as a whole.
• This index ranges from 0 to 1. Higher values indicate that a particular group is more isolated
from other groups.
• Isolation indices indicate the potential for contact between different groups. The index can be
interpreted as the experience of the average member of that group. For example, if the
isolation index is .65 for Latinx residents in a city, then the average Latinx resident in that city
lives in a neighborhood that is 65% Latinx.
Within Town of Los Gatos the most isolated racial group is white residents. Los Gatos’s isolation index
of 0.663 for white residents means that the average white resident lives in a neighborhood that is
66.3% white. Other racial groups are less isolated, meaning they may be more likely to encounter other
racial groups in their neighborhoods. The isolation index values for all racial groups in Los Gatos for the
years 2000, 2010, and 2020 can be found in Table 1 below. Among all racial groups in this jurisdiction,
the white population’s isolation index has changed the most over time, becoming less segregated from
other racial groups between 2000 and 2020.
10
The “Bay Area Average” column in this table provides the average isolation index value across Bay Area
jurisdictions for different racial groups in 2020.10 The data in this column can be used as a comparison
to provide context for the levels of segregation experienced by racial groups in this jurisdiction. For
example, Table 1 indicates the average isolation index value for white residents across all Bay Area
jurisdictions is 0.491, meaning that in the average Bay Area jurisdiction a white resident lives in a
neighborhood that is 49.1% white.
Table 1: Racial Isolation Index Values for Segregation within Los Gatos
Los Gatos Bay Area
Average
Race 2000 2010 2020 2020
Asian/Pacific Islander 0.079 0.118 0.197 0.245
Black/African American 0.009 0.012 0.022 0.053
Latinx 0.059 0.082 0.104 0.251
White 0.838 0.774 0.663 0.491
Universe: Population.
Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting
Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census
Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau,
Census 2000, Table P004.
Figure 2 below shows how racial isolation index values in Los Gatos compare to values in other Bay Area
jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For each racial group, the
spread of dots represents the range of isolation index values among Bay Area jurisdictions.
Additionally, the black line within each racial group notes the isolation index value for that group in
Town of Los Gatos, and each dashed red line represents the Bay Area average for the isolation index
for that group. Local staff can use this chart to contextualize how segregation levels for racial groups
in their jurisdiction compare to other jurisdictions in the region.
10 This average only includes the 104 jurisdictions that have more than one census tract, which is true for all
comparisons of Bay Area jurisdictions’ segregation measures in this report. The segregation measures in this report
are calculated by comparing the demographics of a jurisdiction’s census tracts to the jurisdiction’s demographics,
and such calculations cannot be made for the five jurisdictions with only one census tract (Brisbane, Calistoga,
Portola Valley, Rio Vista, and Yountville).
11
Figure 2: Racial Isolation Index Values for Los Gatos Compared to Other Bay Area
Jurisdictions (2020)
Universe: Bay Area Jurisdictions.
Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting
Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.
Another way to measure segregation is by using a dissimilarity index:
• This index measures how evenly any two groups are distributed across neighborhoods relative
to their representation in a city overall. The dissimilarity index at the jurisdiction level can be
interpreted as the share of one group that would have to move neighborhoods to create perfect
integration for these two groups.
• The dissimilarity index ranges from 0 to 1. Higher values indicate that groups are more
unevenly distributed (e.g. they tend to live in different neighborhoods).
12
Dissimilarity Index Guidance for Cities with Small Racial Group Populations
The analysis conducted for this report suggests that dissimilarity index
values are unreliable for a population group if that group represents
approximately less than 5% of the jurisdiction’s total population.
HCD’s AFFH guidance requires the Housing Element to include the
dissimilarity index values for racial groups, but also offers flexibility in
emphasizing the importance of various measures. ABAG/MTC
recommends that when cities have population groups that are less than
5% of the jurisdiction’s population (see Table 4), jurisdiction staff use the
isolation index or Thiel’s H-Index to gain a more accurate understanding
of their jurisdiction’s neighborhood-level segregation patterns (intra-city
segregation).
If a jurisdiction has a very small population of a racial group, this indicates
that segregation between the jurisdiction and the region (inter-city
segregation) is likely to be an important feature of the jurisdiction’s
segregation patterns.
In Town of Los Gatos, the Black/African American group is 0.9 percent of
the population - so staff should be aware of this small population size
when evaluating dissimilarity index values involving this group.
Table 2 below provides the dissimilarity index values indicating the level of segregation in Los Gatos
between white residents and residents who are Black, Latinx, or Asian/Pacific Islander. The table also
provides the dissimilarity index between white residents and all residents of color in the jurisdiction,
and all dissimilarity index values are shown across three time periods (2000, 2010, and 2020).
In Los Gatos the highest segregation is between Black and white residents (see Table 2). Los Gatos’s
Black /white dissimilarity index of 0.369 means that 36.9% of Black (or white) residents would need to
move to a different neighborhood to create perfect integration between Black residents and white
residents. However, local jurisdiction staff should note that this dissimilarity index value is not a
reliable data point due to small population size. See callout box above for more information.
The “Bay Area Average” column in this table provides the average dissimilarity index values for these
racial group pairings across Bay Area jurisdictions in 2020. The data in this column can be used as a
comparison to provide context for the levels of segregation between communities of color are from
white residents in this jurisdiction.
13
For example, Table 2 indicates that the average Latinx/white dissimilarity index for a Bay Area
jurisdiction is 0.207, so on average 20.7% of Latinx (or white residents) in a Bay Area jurisdiction would
need to move to a different neighborhood within the jurisdiction to create perfect integration between
Latinx and white residents in that jurisdiction.
Table 2: Racial Dissimilarity Index Values for Segregation within Los Gatos
Los Gatos Bay Area
Average
Race 2000 2010 2020 2020
Asian/Pacific Islander vs. White 0.106 0.145 0.182 0.185
Black/African American vs. White 0.223* 0.246* 0.369* 0.244
Latinx vs. White 0.119 0.143 0.179 0.207
People of Color vs. White 0.093 0.124 0.157 0.168
Universe: Population.
Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting
Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census
Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau,
Census 2000, Table P004.
Note: If a number is marked with an asterisk (*), it indicates that the index is based on a racial group making up less than 5
percent of the jurisdiction population, leading to unreliable numbers.
Figure 3 below shows how dissimilarity index values in Town of Los Gatos compare to values in other
Bay Area jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For each racial group
pairing, the spread of dots represents the range of dissimilarity index values among Bay Area
jurisdictions. Additionally, the black line within each racial group pairing notes the dissimilarity index
value in Los Gatos, and each dashed red line represents the Bay Area average for the dissimilarity index
for that pairing. Similar to Figure 2, local staff can use this chart to contextualize how segregation
levels between white residents and communities of color in their jurisdiction compare to the rest of
the region. However, staff should be mindful of whether a racial group in their jurisdiction has a small
population (approximately less than 5% of the jurisdiction’s population), as the dissimilarity index value
is less reliable for small populations.
14
Figure 3: Racial Dissimilarity Index Values for Los Gatos Compared to Other Bay Area
Jurisdictions (2020)
Universe: Bay Area Jurisdictions.
Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting
Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.
Note: The analysis conducted for this report suggests that dissimilarity index values are unreliable for a population group if
that group represents approximately less than 5% of the jurisdiction’s total population. ABAG/MTC recommends that when
cities have population groups that are less than 5% of the jurisdiction’s population (see Table 4), jurisdiction staff could focus
on the isolation index or Thiel’s H-Index to gain a more accurate understanding of neighborhood-level racial segregation in their
jurisdiction.
The Theil’s H Index can be used to measure segregation between all groups within a jurisdiction:
• This index measures how diverse each neighborhood is compared to the diversity of the whole
city. Neighborhoods are weighted by their size, so that larger neighborhoods play a more
significant role in determining the total measure of segregation.
• The index ranges from 0 to 1. A Theil’s H Index value of 0 would mean all neighborhoods within
a city have the same demographics as the whole city. A value of 1 would mean each group lives
exclusively in their own, separate neighborhood.
• For jurisdictions with a high degree of diversity (multiple racial groups comprise more than 10%
of the population), Theil’s H offers the clearest summary of overall segregation.
The Theil’s H Index values for neighborhood racial segregation in Los Gatos for the years 2000, 2010,
and 2020 can be found in Table 3 below. The “Bay Area Average” column in the table provides the
average Theil’s H Index across Bay Area jurisdictions in 2020. Between 2010 and 2020, the Theil’s H
Index for racial segregation in Los Gatos increased, suggesting that there is now more neighborhood
level racial segregation within the jurisdiction. In 2020, the Theil’s H Index for racial segregation in Los
15
Gatos was lower than the average value for Bay Area jurisdictions, indicating that neighborhood level
racial segregation in Los Gatos is less than in the average Bay Area city.
Table 3: Theil’s H Index Values for Racial Segregation within Los Gatos
Los Gatos Bay Area
Average
Index 2000 2010 2020 2020
Theil's H Multi-racial 0.011 0.015 0.023 0.042
Universe: Population.
Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting
Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census
Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau,
Census 2000, Table P004.
Figure 4 below shows how Theil’s H index values for racial segregation in Los Gatos compare to values
in other Bay Area jurisdictions in 2020. In this chart, each dot represents a Bay Area jurisdiction.
Additionally, the black line notes the Theil’s H index value for neighborhood racial segregation in Los
Gatos, and the dashed red line represents the average Theil’s H index value across Bay Area
jurisdictions. Local staff can use this chart to compare how neighborhood racial segregation levels in
their jurisdiction compare to other jurisdictions in the region.
Figure 4: Theil’s H Index Values for Racial Segregation in Los Gatos Compared to
Other Bay Area Jurisdictions (2020)
Universe: Bay Area Jurisdictions.
Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting
Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002.
16
2.2 Regional Racial Segregation (between Los Gatos and other
jurisdictions)
At the regional level, segregation is measured between cities instead of between neighborhoods. Racial
dot maps are not only useful for examining neighborhood racial segregation within a jurisdiction, but
these maps can also be used to explore the racial demographic differences between different
jurisdictions in the region. Figure 5 below presents a racial dot map showing the spatial distribution of
racial groups in Los Gatos as well as in nearby Bay Area cities.
Figure 5: Racial Dot Map of Los Gatos and Surrounding Areas (2020)
Universe: Population.
Source: U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population
and Housing, Table P002.
Note: The plot shows the racial distribution at the census block level for Town of Los Gatos and vicinity. Dots in each census
block are randomly placed and should not be construed as actual placement of people.
To understand how each city contributes to the total segregation of the Bay Area, one can look at the
difference in the racial composition of a jurisdiction compared to the racial composition of the region
as a whole. The racial demographics in Los Gatos for the years 2000, 2010, and 2020 can be found in
Table 4 below. The table also provides the racial composition of the nine-county Bay Area. As of 2020,
Los Gatos has a higher share of white residents than the Bay Area as a whole, a lower share of Latinx
residents, a lower share of Black residents, and a lower share of Asian/Pacific Islander residents.
17
Table 4: Population by Racial Group, Los Gatos and the Region
Los Gatos Bay Area
Race 2000 2010 2020 2020
Asian/Pacific Islander 7.6% 10.9% 18.3% 28.2%
Black/African American 0.8% 0.9% 0.9% 5.6%
Latinx 5.2% 7.2% 9.0% 24.4%
Other or Multiple Races 3.2% 4.0% 6.5% 5.9%
White 83.3% 77.0% 65.3% 35.8%
Universe: Population.
Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting
Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census
Bureau, Census 2010, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is from U.S. Census Bureau,
Census 2000, Table P004.
Figure 6 below compares the racial demographics in Los Gatos to those of all 109 Bay Area
jurisdictions.11 In this chart, each dot represents a Bay Area jurisdiction. For each racial group, the
spread of dots represents the range of that group’s representation among Bay Area jurisdictions.
Additionally, the black line within each racial group notes the percentage of the population of Town of
Los Gatos represented by that group and how that percentage ranks among all 109 jurisdictions. Local
staff can use this chart to compare the representation of different racial groups in their jurisdiction to
those groups’ representation in other jurisdictions in the region, which can indicate the extent of
segregation between this jurisdiction and the region.
11 While comparisons of segregation measures are made only using the 104 jurisdictions with more than one census
tract, this comparison of jurisdiction level demographic data can be made using all 109 jurisdictions.
18
Figure 6: Racial Demographics of Los Gatos Compared to All Bay Area Jurisdictions
(2020)
Universe: Bay Area Jurisdictions.
Source U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population
and Housing, Table P002.
The map in Figure 7 below also illustrates regional racial segregation between Los Gatos and other
jurisdictions. This map demonstrates how the percentage of people of color in Los Gatos and
surrounding jurisdictions compares to the Bay Area as a whole:
• Jurisdictions shaded orange have a share of people of color that is less than the Bay Area as a
whole, and the degree of difference is greater than five percentage points.
• Jurisdictions shaded white have a share of people of color comparable to the regional
percentage of people of color (within five percentage points).
• Jurisdictions shaded grey have a share of people of color that is more than five percentage
points greater than the regional percentage of people of color.
19
Figure 7: Comparing the Share of People of Color in Los Gatos and Vicinity to the Bay
Area (2020)
Universe: Population.
Source: U.S. Census Bureau, 2020 Census State Redistricting Data (Public Law 94-171) Summary File, 2020 Census of Population
and Housing, Table P002.
Note: People of color refer to persons not identifying as non-Hispanic white. The nine-county Bay Area is the reference region
for this map.
Segregation between jurisdictions in the region can also be analyzed by calculating regional values for
the segregation indices discussed previously. Table 5 presents dissimilarity index, isolation index, and
Theil’s H index values for racial segregation for the entire nine-county Bay Area in 2010 and 2020. In
the previous section of this report focused on neighborhood level racial segregation, these indices were
calculated by comparing the racial demographics of the census tracts within a jurisdiction to the
demographics of the jurisdiction as a whole. In Table 5, these measures are calculated by comparing
the racial demographics of local jurisdictions to the region’s racial makeup. For example, looking at
the 2020 data, Table 5 shows the white isolation index value for the region is 0.429, meaning that on
average white Bay Area residents live in a jurisdiction that is 42.9% white in 2020. An example of
regional dissimilarity index values in Table 5 is the Black/white dissimilarity index value of 0.459,
which means that across the region 45.9% of Black (or white) residents would need to move to a
different jurisdiction to evenly distribute Black and white residents across Bay Area jurisdictions. The
dissimilarity index values in Table 5 reflect recommendations made in HCD’s AFFH guidance for
calculating dissimilarity at the region level.12 The regional value for the Theil’s H index measures how
12 For more information on HCD’s recommendations regarding data considerations for analyzing integration and
segregation patterns, see page 31 of the AFFH Guidance Memo.
20
diverse each Bay Area jurisdiction is compared to the racial diversity of the whole region. A Theil’s H
Index value of 0 would mean all jurisdictions within the Bay Area have the same racial demographics as
the entire region, while a value of 1 would mean each racial group lives exclusively in their own
separate jurisdiction. The regional Theil’s H index value for racial segregation decreased slightly
between 2010 and 2020, meaning that racial groups in the Bay Area are now slightly less separated by
the borders between jurisdictions.
Table 5: Regional Racial Segregation Measures
Index Group 2010 2020
Isolation Index Regional Level
Asian/Pacific Islander 0.317 0.378
Black/African American 0.144 0.118
Latinx 0.283 0.291
White 0.496 0.429
People of Color 0.629 0.682
Dissimilarity Index Regional Level
Asian/Pacific Islander vs. White 0.384 0.369
Black/African American vs. White 0.475 0.459
Latinx vs. White 0.301 0.297
People of Color vs. White 0.296 0.293
Theil's H Multi-racial All Racial Groups 0.103 0.097
Universe: Population.
Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting
Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census
Bureau, 2010 Census of Population and Housing, Table P4.
21
3 INCOME SEGREGATION IN TOWN OF LOS GATOS
Definition of Terms - Income Groups
When analyzing segregation by income, this report uses income group
designations consistent with the Regional Housing Needs Allocation and
the Housing Element:
Very low-income: individuals earning less than 50% of Area Median
Income (AMI)
Low-income: individuals earning 50%-80% of AMI
Moderate-income: individuals earning 80%-120% of AMI
Above moderate-income: individuals earning 120% or more of AMI
Additionally, this report uses the term “lower-income” to refer to all people
who earn less than 80% of AMI, which includes both low-income and very
low-income individuals.
The income groups described above are based on U.S. Department of
Housing and Urban Development (HUD) calculations for AMI. HUD
calculates the AMI for different metropolitan areas, and the nine county
Bay Area includes the following metropolitan areas: Napa Metro Area
(Napa County), Oakland-Fremont Metro Area (Alameda and Contra
Costa Counties), San Francisco Metro Area (Marin, San Francisco, and
San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa
Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-
Fairfield Metro Area (Solano County).
The income categories used in this report are based on the AMI for the
HUD metro area where this jurisdiction is located.
3.1 Neighborhood Level Income Segregation (within Los Gatos)
Income segregation can be measured using similar indices as racial segregation. Income dot maps,
similar to the racial dot maps shown in Figures 1 and 5, are useful for visualizing segregation between
multiple income groups at the same time. The income dot map of Los Gatos in Figure 8 below offers a
visual representation of the spatial distribution of income groups within the jurisdiction. As with the
racial dot maps, when the dots show lack of a pattern or clustering, income segregation measures tend
to be lower, and conversely, when clusters are apparent, the segregation measures may be higher as
well.
22
Figure 8: Income Dot Map of Los Gatos (2015)
Universe: Population.
Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and Moderate-
Income Summary Data.
Note: The plot shows the income group distribution at the census block group level for Town of Los Gatos and vicinity. Dots in
each block group are randomly placed and should not be construed as actual placement of individuals.
The isolation index values for all income groups in Los Gatos for the years 2010 and 2015 can be found
in Table 6 below.13 Above Moderate-income residents are the most isolated income group in Los Gatos.
Los Gatos’s isolation index of 0.619 for these residents means that the average Above Moderate-income
resident in Los Gatos lives in a neighborhood that is 61.9% Above Moderate-income. Among all income
groups, the Above Moderate-income population’s isolation index has changed the most over time,
becoming less segregated from other income groups between 2010 and 2015.
Similar to the tables presented earlier for neighborhood racial segregation, the “Bay Area Average”
column in Table 6 provides the average isolation index value across Bay Area jurisdictions for different
income groups in 2015. The data in this column can be used as a comparison to provide context for the
levels of segregation experienced by income groups in this jurisdiction. For example, Table 6 indicates
the average isolation index value for very low-income residents across Bay Area jurisdictions is 0.269,
13 This report presents data for income segregation for the years 2010 and 2015, which is different than the time
periods used for racial segregation. This deviation stems from the data source recommended for income
segregation calculations in HCD’s AFFH Guidelines. This data source most recently updated with data from the
2011-2015 American Community Survey 5-year estimates. For more information on HCD’s recommendations for
calculating income segregation, see page 32 of HCD’s AFFH Guidelines.
23
meaning that in the average Bay Area jurisdiction a very low-income resident lives in a neighborhood
that is 26.9% very low-income.
Table 6: Income Group Isolation Index Values for Segregation within Los Gatos
Los Gatos Bay Area
Average
Income Group 2010 2015 2015
Very Low-Income (<50% AMI) 0.125 0.162 0.269
Low-Income (50%-80% AMI) 0.067 0.115 0.145
Moderate-Income (80%-120% AMI) 0.135 0.166 0.183
Above Moderate-Income (>120% AMI) 0.728 0.619 0.507
Universe: Population.
Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-
2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development,
American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.
Figure 9 below shows how income group isolation index values in Los Gatos compare to values in other
Bay Area jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For each income
group, the spread of dots represents the range of isolation index values among Bay Area jurisdictions.
Additionally, the black line within each income group notes the isolation index value for that group in
Los Gatos, and each dashed red line represents the Bay Area average for the isolation index for that
group. Local staff can use this chart to contextualize how segregation levels for income groups in their
jurisdiction compare to the rest of the region.
24
Figure 9: Income Group Isolation Index Values for Los Gatos Compared to Other Bay
Area Jurisdictions (2015)
Universe: Bay Area Jurisdictions.
Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and Moderate-
Income Summary Data.
Table 7 below provides the dissimilarity index values indicating the level of segregation in Los Gatos
between residents who are lower-income (earning less than 80% of AMI) and those who are not lower-
income (earning above 80% of AMI). This data aligns with the requirements described in HCD’s AFFH
Guidance Memo for identifying dissimilarity for lower-income households.14 Segregation in Los Gatos
between lower-income residents and residents who are not lower-income increased between 2010 and
2015. Additionally, Table 7 shows dissimilarity index values for the level of segregation in Albany
between residents who are very low-income (earning less than 50% of AMI) and those who are above
moderate-income (earning above 120% of AMI). This supplementary data point provides additional
nuance to an analysis of income segregation, as this index value indicates the extent to which a
jurisdiction’s lowest and highest income residents live in separate neighborhoods.
Similar to other tables in this report, the “Bay Area Average” column shows the average dissimilarity
index values for these income group pairings across Bay Area jurisdictions in 2015. For example, Table
7 indicates that the average dissimilarity index between lower-income residents and other residents in
a Bay Area jurisdiction is 0.198, so on average 19.8% of lower-income residents in a Bay Area
jurisdiction would need to move to a different neighborhood within the jurisdiction to create perfect
income group integration in that jurisdiction.
14 For more information, see page 32 of HCD’s AFFH Guidance Memo.
25
In 2015, the income segregation in Los Gatos between lower-income residents and other residents was
higher than the average value for Bay Area jurisdictions (See Table 7). This means that the lower-
income residents are more segregated from other residents within Los Gatos compared to other
Jurisdictions in the region.
Table 7: Income Group Dissimilarity Index Values for Segregation within Los
Gatos
Los Gatos Bay Area
Average
Income Group 2010 2015 2015
Below 80% AMI vs. Above 80% AMI 0.142 0.226 0.198
Below 50% AMI vs. Above 120% AMI 0.194 0.234 0.253
Universe: Population.
Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-
2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development,
American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.
Figure 10 below shows how dissimilarity index values for income segregation in Los Gatos compare to
values in other Bay Area jurisdictions. In this chart, each dot represents a Bay Area jurisdiction. For
each income group pairing, the spread of dots represents the range of dissimilarity index values among
Bay Area jurisdictions. Additionally, the black line within each income group pairing notes the
dissimilarity index value in Los Gatos, and each dashed red line represents the Bay Area average for the
dissimilarity index for that pairing. Local staff can use this chart to contextualize how segregation
levels between lower-income residents and wealthier residents in their jurisdiction compared to the
rest of the region.
26
Figure 10: Income Group Dissimilarity Index Values for Los Gatos Compared to Other
Bay Area Jurisdictions (2015)
Universe: Bay Area Jurisdictions.
Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and Moderate-
Income Summary Data.
The Theil’s H Index values for neighborhood income group segregation in Los Gatos for the years 2010
and 2015 can be found in Table 8 below. The “Bay Area Average” column in this table provides the
average Theil’s H Index value across Bay Area jurisdictions for different income groups in 2015. By
2015, the Theil’s H Index value for income segregation in Los Gatos was about the same amount as it
had been in 2010. In 2015, the Theil’s H Index value for income group segregation in Los Gatos was
lower than the average value for Bay Area jurisdictions, indicating there is less neighborhood level
income segregation in Los Gatos than in the average Bay Area city.
Table 8: Theil’s H Index Values for Income Segregation within Los Gatos
Los Gatos Bay Area
Average
Index 2010 2015 2015
Theil's H Multi-income 0.030 0.028 0.043
Universe: Population.
Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-
2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development,
American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.
27
Figure 11 below shows how Theil’s H index values for income group segregation in Los Gatos compare
to values in other Bay Area jurisdictions in 2015. In this chart, each dot represents a Bay Area
jurisdiction. Additionally, the black line notes the Theil’s H index value for income group segregation in
Los Gatos, and the dashed red line represents the average Theil’s H index value across Bay Area
jurisdictions. Local staff can use this chart to compare how neighborhood income group segregation
levels in their jurisdiction compare to other jurisdictions in the region.
Figure 11: Income Group Theil’s H Index Values for Los Gatos Compared to Other Bay
Area Jurisdictions (2015)
Universe: Bay Area Jurisdictions.
Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and Moderate-
Income Summary Data.
3.2 Regional Income Segregation (between Los Gatos and other
jurisdictions)
At the regional level, segregation is measured between jurisdictions instead of between neighborhoods.
Income dot maps are not only useful for examining neighborhood income segregation within a
jurisdiction, but these maps can also be used to explore income demographic differences between
jurisdictions in the region. Figure 12 below presents an income dot map showing the spatial distribution
of income groups in Los Gatos as well as in nearby Bay Area jurisdictions.
28
Figure 12: Income Dot Map of Los Gatos and Surrounding Areas (2015)
Universe: Population.
Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and Moderate-
Income Summary Data.
Note: The plot shows the income group distribution at the census block group level for Town of Los Gatos and vicinity. Dots in
each block group are randomly placed and should not be construed as actual placement of individuals.
When looking at income segregation between jurisdictions in the Bay Area, one can examine how Los
Gatos differs from the region. The income demographics in Los Gatos for the years 2010 and 2015 can
be found in Table 9 below. The table also provides the income composition of the nine-county Bay Area
in 2015. As of that year, Los Gatos had a lower share of very low-income residents than the Bay Area as
a whole, a lower share of low-income residents, a lower share of moderate-income residents, and a
higher share of above moderate-income residents.
Table 9: Population by Income Group, Los Gatos and the Region
Los Gatos Bay Area
Income Group 2010 2015 2015
Very Low-Income (<50% AMI) 10.83% 14.29% 28.7%
Low-Income (50%-80% AMI) 6.56% 10.57% 14.3%
Moderate-Income (80%-120% AMI) 11% 16.34% 17.6%
Above Moderate-Income (>120% AMI) 71.62% 58.8% 39.4%
29
Universe: Population.
Source: Data for 2015 is from Housing U.S. Department of and Urban Development, American Community Survey 5-Year 2011-
2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development,
American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.
Figure 13 below compares the income demographics in Los Gatos to other Bay Area jurisdictions.15 Like
the chart in Figure 3, each dot represents a Bay Area jurisdiction. For each income group, the spread of
dots represents the range of that group’s representation among Bay Area jurisdictions. The smallest
range is among jurisdictions’ moderate-income populations, while Bay Area jurisdictions vary the most
in the share of their population that is above moderate-income. Additionally, the black lines within
each income group note the percentage of Los Gatos population represented by that group and how
that percentage ranks among other jurisdictions. Local staff can use this chart to compare the
representation of different income groups in their jurisdiction to those groups’ representation in other
jurisdictions in the region, which can indicate the extent of segregation between this jurisdiction and
the region.
Figure 13: Income Demographics of Los Gatos Compared to Other Bay Area
Jurisdictions (2015)
Universe: Bay Area Jurisdictions.
Source: U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-2015 Low- and Moderate-
Income Summary Data.
15 While comparisons of segregation measures are made only using the 104 jurisdictions with more than one census
tract, this comparison of jurisdiction level demographic data can be made using all 109 jurisdictions.
30
Income segregation between jurisdictions in the region can also be analyzed by calculating regional
values for the segregation indices discussed previously. Similar to the regional racial segregation
measures shown in Table 5, Table 10 presents dissimilarity index, isolation index, and Theil’s H index
values for income segregation for the entire nine-county Bay Area in 2010 and 2015. In the previous
section of this report focused on neighborhood level income segregation, segregation indices were
calculated by comparing the income demographics of the census tracts within a jurisdiction to the
demographics of the jurisdiction as a whole. In Table 10, these measures are calculated by comparing
the income demographics of local jurisdictions to the region’s income group makeup. For example,
looking at 2015 data, Table 10 shows the regional isolation index value for very low-income residents is
0.315 for 2015, meaning that on average very low-income Bay Area residents live in a jurisdiction that
is 31.5% very low-income. The regional dissimilarity index for lower-income residents and other
residents is 0.194 in 2015, which means that across the region 19.4% of lower-income residents would
need to move to a different jurisdiction to create perfect income group integration in the Bay Area as a
whole. The regional value for the Theil’s H index measures how diverse each Bay Area jurisdiction is
compared to the income group diversity of the whole region. A Theil’s H Index value of 0 would mean
all jurisdictions within the Bay Area have the same income demographics as the entire region, while a
value of 1 would mean each income group lives exclusively in their own separate jurisdiction. The
regional Theil’s H index value for income segregation decreased slightly between 2010 and 2015,
meaning that income groups in the Bay Area are now slightly less separated by the borders between
jurisdictions.
Table 10: Regional Income Segregation Measures
Index Group 2010 2015
Isolation Index Regional Level
Very Low-Income (<50% AMI) 0.277 0.315
Low-Income (50%-80% AMI) 0.157 0.154
Moderate-Income (80%-120% AMI) 0.185 0.180
Above Moderate-Income (>120% AMI) 0.467 0.435
Dissimilarity Index Regional Level
Below 80% AMI vs. Above 80% AMI 0.186 0.194
Below 50% AMI vs. Above 120% AMI 0.238 0.248
Theil's H Multi-income All Income Groups 0.034 0.032
Universe: Population.
Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-
2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development,
American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.
31
4 APPENDIX 1: SUMMARY OF FINDINGS
4.1 Segregation in Town of Los Gatos
• The isolation index measures the segregation of a single group, and the dissimilarity index
measures segregation between two different groups. The Theil’s H-Index can be used to
measure segregation between all racial or income groups across the city at once.
• As of 2020, white residents are the most segregated compared to other racial groups in Los
Gatos, as measured by the isolation index. White residents live in neighborhoods where they
are less likely to come into contact with other racial groups.
• Among all racial groups, the white population’s isolation index value has changed the most over
time, becoming less segregated from other racial groups between 2000 and 2020.
• According to the dissimilarity index, within Los Gatos the highest level of racial segregation is
between Black and white residents.16 However, local jurisdiction staff should note that this
dissimilarity index value is not a reliable data point due to small population size.
• According to the Theil’s H-Index, neighborhood racial segregation in Los Gatos increased
between 2010 and 2020. Neighborhood income segregation stayed about the same between
2010 and 2015.
• Above Moderate-income residents are the most segregated compared to other income groups in
Los Gatos. Above Moderate-income residents live in neighborhoods where they are less likely to
encounter residents of other income groups.
• Among all income groups, the Above Moderate-income population’s segregation measure has
changed the most over time, becoming less segregated from other income groups between
2010 and 2015.
• According to the dissimilarity index, segregation between lower-income residents and residents
who are not lower-income has increased between 2010 and 2015. In 2015, the income
segregation in Los Gatos between lower-income residents and other residents was higher than
the average value for Bay Area jurisdictions.
4.2 Segregation Between Town of Los Gatos and Other jurisdictions in
the Bay Area Region
• Los Gatos has a higher share of white residents than other jurisdictions in the Bay Area as a
whole, a lower share of Latinx residents, a lower share of Black residents, and a lower share of
Asian/Pacific Islander residents.
16 The analysis conducted for this report suggests that dissimilarity index values are unreliable for a population
group if that group represents approximately less than 5% of the jurisdiction’s total population. ABAG/MTC
recommends that when cities have population groups that are less than 5% of the jurisdiction’s population (see
Table 15 in Appendix 2), jurisdiction staff could focus on the isolation index or Thiel’s H-Index to gain a more
accurate understanding of neighborhood-level racial segregation in their jurisdiction.
32
• Regarding income groups, Los Gatos has a lower share of very low-income residents than other
jurisdictions in the Bay Area as a whole, a lower share of low-income residents, a lower share
of moderate-income residents, and a higher share of above moderate-income residents.
33
5 APPENDIX 2: SEGREGATION DATA
Appendix 2 combines tabular data presented throughout this report into a more condensed format. This
data compilation is intended to enable local jurisdiction staff and their consultants to easily reference
this data and re-use the data in the Housing Element or other relevant documents/analyses.
Table 11 in this appendix combines data from Table 1, Table 2, and Table 3 in the body of the report.
Table 12 in this appendix combines data from Table 6, Table 7, and Table 8 in the body of the report.
Table 13 represents a duplication of Table 5 in the body of the report; Table 14 represents a
duplication of Table 10 in the body of the report; Table 15 in this appendix represents a duplication of
Table 4 in the body of the report, while Table 16 represents a duplication of Table 9 in the body of the
report.
Table 11: Neighborhood Racial Segregation Levels in Los Gatos
Los Gatos Bay Area
Average
Index Race 2000 2010 2020 2020
Isolation
Asian/Pacific Islander 0.079 0.118 0.197 0.245
Black/African American 0.009 0.012 0.022 0.053
Latinx 0.059 0.082 0.104 0.251
White 0.838 0.774 0.663 0.491
Dissimilarity
Asian/Pacific Islander vs. White 0.106 0.145 0.182 0.185
Black/African American vs. White 0.223* 0.246* 0.369* 0.244
Latinx vs. White 0.119 0.143 0.179 0.207
People of Color vs. White 0.093 0.124 0.157 0.168
Theil's H Multi-racial All 0.011 0.015 0.023 0.042
Universe: Population.
Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting
Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census
Bureau, 2010 Census of Population and Housing, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is
from U.S. Census Bureau, Census 2000, Table P004.
Note: If a number is marked with an asterisk (*), it indicates that the index is based on a racial group making up less than 5
percent of the jurisdiction population, leading to unreliable numbers.
34
Table 12: Neighborhood Income Segregation Levels in Los Gatos
Los Gatos Bay Area
Average
Index Income Group 2010 2015 2015
Isolation
Very Low-Income (<50% AMI) 0.125 0.162 0.269
Low-Income (50%-80% AMI) 0.067 0.115 0.145
Moderate-Income (80%-120% AMI) 0.135 0.166 0.183
Above Moderate-Income (>120% AMI) 0.728 0.619 0.507
Dissimilarity
Below 80% AMI vs. Above 80% AMI 0.142 0.226 0.198
Below 50% AMI vs. Above 120% AMI 0.194 0.234 0.253
Theil's H Multi-racial All 0.030 0.028 0.043
Universe: Population.
Source: Income data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year
2011-2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban
Development, American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.
35
Table 13: Regional Racial Segregation Measures
Index Group 2010 2020
Isolation Index Regional Level
Asian/Pacific Islander 0.317 0.378
Black/African American 0.144 0.118
Latinx 0.283 0.291
White 0.496 0.429
People of Color 0.629 0.682
Dissimilarity Index Regional Level
Asian/Pacific Islander vs. White 0.384 0.369
Black/African American vs. White 0.475 0.459
Latinx vs. White 0.301 0.297
People of Color vs. White 0.296 0.293
Theil's H Multi-racial All Racial Groups 0.103 0.097
Universe: Population.
Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting
Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census
Bureau, 2010 Census of Population and Housing, Table P4.
Table 14: Regional Income Segregation Measures
Index Group 2010 2015
Isolation Index Regional Level
Very Low-Income (<50% AMI) 0.277 0.315
Low-Income (50%-80% AMI) 0.157 0.154
Moderate-Income (80%-120% AMI) 0.185 0.180
Above Moderate-Income (>120% AMI) 0.467 0.435
Dissimilarity Index Regional Level
Below 80% AMI vs. Above 80% AMI 0.186 0.194
Below 50% AMI vs. Above 120% AMI 0.238 0.248
Theil's H Multi-income All Income Groups 0.034 0.032
Universe: Population.
Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-
2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development,
American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.
36
Table 15: Population by Racial Group, Los Gatos and the Region
Los Gatos Bay Area
Race 2000 2010 2020 2020
Asian/Pacific Islander 7.55% 10.95% 18.28% 35.8%
Black/African American 0.76% 0.86% 0.89% 5.6%
Latinx 5.21% 7.21% 9% 28.2%
Other or Multiple Races 3.16% 3.95% 6.55% 24.4%
White 83.31% 77.03% 65.29% 5.9%
Universe: Population.
Source: IPUMS National Historical Geographic Information System (NHGIS). U.S. Census Bureau, 2020 Census State Redistricting
Data (Public Law 94-171) Summary File, 2020 Census of Population and Housing, Table P002. Data from 2010 is from U.S. Census
Bureau, 2010 Census of Population and Housing, Table P4. Data for 2000 is standardized to 2010 census tract geographies and is
from U.S. Census Bureau, Census 2000, Table P004.
Table 16: Population by Income Group, Los Gatos and the Region
Los Gatos Bay Area
Income Group 2010 2015 2015
Very Low-Income (<50% AMI) 10.83% 14.29% 28.7%
Low-Income (50%-80% AMI) 6.56% 10.57% 14.3%
Moderate-Income (80%-120% AMI) 11% 16.34% 17.6%
Above Moderate-Income (>120% AMI) 71.62% 58.8% 39.4%
Universe: Population.
Source: Data for 2015 is from U.S. Department of Housing and Urban Development, American Community Survey 5-Year 2011-
2015 Low- and Moderate-Income Summary Data. Data for 2010 is from U.S. Department of Housing and Urban Development,
American Community Survey 5-Year 2006-2010 Low- and Moderate-Income Summary Data.
37
6 REFERENCES
Ananat, Elizabeth Oltmans. 2011. “The wrong side(s) of the tracks: The causal effects of racial
segregation on urban poverty and inequality,” American Economic Journal: Applied Economics 3: 34-
66.
Bayer, Patrick, Robert McMillan, and Kim S. Rueben. 2004. “What Drives Racial Segregation? New
Evidence using Census Microdata,” Journal of Urban Economics 56(3): 514-535.
Burch, Traci. 2014. “The Old Jim Crow: Racial Residential Segregation and Imprisonment,” Law and
Policy 36(3): 223-255.
Chetty, Raj and Nathanial Hendren. 2018. “The Impacts of Neighborhoods on Intergenerational Mobility
I: Childhood Exposure Effects,” The Quarterly Journal of Economics 133(3):1107-1162
Cutler, David M., and Edward L. Glaeser. 1997. “Are ghettos good or bad?,” The Quarterly Journal of
Economics 112(3): 827-72.
Lens, Michael and Paavo Monkkonen. 2016. “Do Strict Land Use Regulations Make Metropolitan Areas
More Segregated by Income?,” Journal of the American Planning Association 82(1): 6–21.
Pendall, Rolf. 2000. “Local Land-Use Regulation and the Chain of Exclusion,” Journal of the American
Planning Association 66(2): 125-142.
Rothstein, Richard. 2017. The Color of Law: A Forgotten History of how our Government Segregated
America. New York: Liveright Publishing.
Sampson, Robert J. 2012. Great American city: Chicago and the enduring neighborhood effect.
Chicago: University of Chicago Press.
Sharkey, Patrick. 2013. Stuck in place: Urban neighborhoods and the end of progress toward racial
equality. Chicago: University of Chicago Press.
Trounstine, Jessica. 2015. “Segregation and Inequality in Public Goods,” American Journal of Political
Science 60(3): 709-725.
Trounstine, Jessica. 2018. Segregation by Design: Local Politics and Inequality in American Cities. New
York: Cambridge University Press.
Sites Inventory Form H
APPENDIX
EXHIBIT 5
Please Start Here, Instructions in Cell A2, Table in
A3:B17 Form Fields
Site Inventory Forms must be submitted to HCD for a
housing element or amendment adopted on or after
January 1, 2021. The following form is to be used for
satisfying this requirement. To submit the form,
complete the Excel spreadsheet and submit to HCD
at sitesinventory@hcd.ca.gov. Please send the Excel
workbook, not a scanned or PDF copy of the tables.
General Information
Jurisidiction Name LOS GATOS
Housing Element Cycle 6th
Contact Information
First Name Joel
Last Name Paulson
Title Community Development Director
Email Jpaulson@losgatosca.gov
Phone 4083546879
Mailing Address
Street Address 110 East Main Street
City Los Gatos
Zip Code 94538
Website
https://www.losgatosca.gov/897/Planning
Table A: Housing Element Sites Inventory, Table Starts in Cell A2 For Santa Clara County jurisdictions, please format the APNs as follows: 999-99-999
Jurisdiction Name Site Address/Intersection 5 Digit ZIP Code Assessor Parcel Number Consolidated Sites General Plan Designation (Current)Zoning Designation (Current)
Minimum
Density Allowed (units/acre)
Maximum
Density Allowed (units/acre)
Parcel Size
(Acres)
Existing Use/Vacancy Infrastructure Publicly-Owned Site Status Identified in Last/Last Two Planning Cycle(s)Lower Income
Capacity
Moderate Income
Capacity
Above
Moderate Income Capacity
Total Capacity Optional Information1 Optional Information2 Optional Information3
LOS GATOS 50 Park Avenue 95030 529-01-040 A Medium Density Residential R-1D 5 12 0.18 Residential YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 1 1 Site A-1 consolidated parcels Property Owner Interest Form Submitted
LOS GATOS 61 Montebello Way 95030 529-01-041 A Medium Density Residential R-1D 5 12 0.69 Residential YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 4 4 Site A-1 consolidated parcels Property Owner Interest Form SubmittedLOS GATOS 101 South Santa Cruz Avenue 95030 529-01-022 Central Business District C-2 20 30 0.8 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 16 16 Site A-2 Property Owner Interest Form SubmittedLOS GATOS 165 Los Gatos Saratoga Road 95030 529-04-083 Central Business District C-2 20 30 0.37 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 7 7 Site A-3 Property Owner Interest Form Submitted
LOS GATOS 50 Los Gatos Saratoga Road 95030 529-24-032 B Mixed Use Commercial CH:PD 30 40 7.04 Hotel/motel YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 151 51 9 211 Site B-1 consolidated parcels Property Owner Interest Form SubmittedLOS GATOS Los Gatos Saratoga Road 95030 529-24-001 B Mixed Use Commercial CH:PD 30 40 1.49 Hotel/motel YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 18 9 18 45 Site B-1 consolidated parcels Property Owner Interest Form SubmittedLOS GATOS Los Gatos Saratoga Road 95030 529-24-003 B Mixed Use Commercial CH:PD 30 40 0.28 Hotel/motel YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 3 2 3 8 Site B-1 consolidated parcels Property Owner Interest Form Submitted
LOS GATOS 15300 Los Gatos Bouelvard 95032 424-17-036 Mixed Use Commercial C-1 30 40 1.6 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 33 9 6 48 Site C-1 Property Owner Interest Form SubmittedLOS GATOS 15349 Los Gatos Bouelvard 95032 424-19-049 C Mixed Use Commercial CH 30 40 0.34 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 7 2 1 10 Site C-2 consolidated parcels Property Owner Interest Form SubmittedLOS GATOS Los Gatos Bouelvard 95032 424-19-048 C Mixed Use Commercial CH 30 40 1.2 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 26 8 2 36 Site C-2 consolidated parcels Property Owner Interest Form Submitted
LOS GATOS Los Gatos Bouelvard 95032 424-19-069 C Mixed Use Commercial CH 30 40 1.34 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 28 8 4 40 Site C-2 consolidated parcels Property Owner Interest Form SubmittedLOS GATOS 15425 Los Gatos Bouelvard 95032 424-19-067 Mixed Use Commercial CH 30 40 1.09 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 23 7 3 33 Site C-3 Property Owner Interest Form SubmittedLOS GATOS 15975 Los Gatos Boulevard 95032 529-15-059 Mixed Use Commercial CH 30 40 0.64 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 13 4 2 19 Site C-4 Property Owner Interest Form Submitted
LOS GATOS 16203 Los Gatos Bouelvard 95032 529-16-069 Mixed Use Commercial CH 30 40 0.79 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 17 5 2 24 Site C-5 Conceptual Development Advisory Committee application for a mixed-use development submitted on 11/17/2020 anticipating for increased density per the General Plan updateLOS GATOS 16492 Los Gatos Bouelvard 95032 532-07-086 D Low Density Residential C-1 10 20 0.23 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 2 2 Site C-6 consolidated parcels Property Owner Interest Form SubmittedLOS GATOS Los Gatos Bouelvard 95032 532-07-085 D Low Density Residential C-1 10 20 0.38 Vacant YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 4 4 Site C-6 consolidated parcels Property Owner Interest Form Submitted
LOS GATOS 15495 Los Gatos Bouelvard 95032 424-22-030 Mixed Use Commercial CH 30 40 3.85 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 81 23 12 116 Site C-7 Property Owner contacted staff with inquiry on residential developmentLOS GATOS 15445 Los Gatos Bouelvard 95032 424-19-068 Mixed Use Commercial CH 30 40 1.53 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 32 9 5 46 Site C-8 Adjacent to sites within the Site InventoryLOS GATOS 14859 Los Gatos Boulevard 95032 424-07-094 E North Forty Specific Plan North Forty Specific Plan 30 30 2.9 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 57 13 17 87 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the site
LOS GATOS 16392 Los Gatos Boulevard 95032 424-07-095 E North Forty Specific Plan North Forty Specific Plan 30 30 0.78 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 15 3 5 23 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the siteLOS GATOS 16260 Burton Road 95032 424-07-053 E North Forty Specific Plan North Forty Specific Plan 30 30 0.44 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 8 2 3 13 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the siteLOS GATOS 16250 Burton Road 95032 424-07-009 E North Forty Specific Plan North Forty Specific Plan 30 30 0.44 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 8 2 3 13 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the siteLOS GATOS 14917 Los Gatos Boulevard 95032 424-07-081 E North Forty Specific Plan North Forty Specific Plan 30 30 3.74 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 73 17 22 112 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the site
LOS GATOS 14925 Los Gatos Boulevard 95032 424-07-115 E North Forty Specific Plan North Forty Specific Plan 30 30 6.07 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 118 27 37 182 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the siteLOS GATOS Los Gatos Boulevard 95032 424-07-116 E North Forty Specific Plan North Forty Specific Plan 30 30 1.02 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 20 5 6 31 Site D-1 consolidated parcels Property Owner has been involved in submitting public comments on the Housing Element Update regarding residential development on the siteLOS GATOS 16245 Burton Road 95032 424-06-115 North Forty Specific Plan North Forty Specific Plan 30 30 1.17 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 23 5 7 35 Site D-2 consolidated parcels No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underway
LOS GATOS Burton Road 95032 424-06-116 North Forty Specific Plan North Forty Specific Plan 30 30 0.11 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 2 0 1 3 Site D-2 consolidated parcels No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underwayLOS GATOS 16240 Burton Road 95032 424-07-010 North Forty Specific Plan North Forty Specific Plan 30 30 0.26 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 5 1 2 8 Site D-3 No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underwayLOS GATOS 16270 Burton Road 95032 424-07-052 North Forty Specific Plan North Forty Specific Plan 30 30 0.43 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 8 2 3 13 Site D-4 No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underway
LOS GATOS 16210 Burton Road 95032 424-07-054 North Forty Specific Plan North Forty Specific Plan 30 30 0.26 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 5 1 2 8 Site D-5 consolidated parcels No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underwayLOS GATOS 14831 Los Gatos Boulevard 95032 424-07-063 North Forty Specific Plan North Forty Specific Plan 30 30 0.56 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 11 3 3 17 Site D-5 consolidated parcels No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underwayLOS GATOS 14849 Los Gatos Boulevard 95032 424-07-064 North Forty Specific Plan North Forty Specific Plan 30 30 0.93 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 18 4 6 28 Site D-6 No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underway
LOS GATOS 14823 Los Gatos Boulevard 95032 424-07-065 North Forty Specific Plan North Forty Specific Plan 30 30 0.37 Residential YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 6 1 4 11 Site D-7 No; however, the parcel is located within Phase II of the North 40 Specific Plan Area where recent significant housing development is underwayLOS GATOS 14800 Oka Road 95032 424-08-057 Low Density Residential R-1:8 0 5 2.97 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 0 1 11 12 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.LOS GATOS Oka Lane 95032 424-08-029 Low Density Residential R-1:8 0 5 0.31 Vacant YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 1 1 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.
LOS GATOS Oka Lane 95032 424-08-059 Low Density Residential R-1:8 0 5 1.01 Vacant YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 4 4 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.LOS GATOS Oka Lane 95032 424-08-060 Low Density Residential R-1:8 0 5 1.29 Vacant YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 5 5 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.LOS GATOS 14800 Oka Road 95032 424-08-058 Low Density Residential R-1:8 0 5 1.41 Residential YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 6 6 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.
LOS GATOS 16603 Lark Avenue 95032 424-08-017 Medium Density Residential R-M:5-12 14 22 2.48 Residential YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 3 3 29 35 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.LOS GATOS 14840 Oka Road 95032 424-08-021 Medium Density Residential R-M:5-12 14 22 4.32 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 6 6 49 61 Site E-1 consolidated parcels No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.LOS GATOS Oka Lane 95032 424-08-074 Low Density Residential R-1:8 0 5 6.41 Vacant YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 2 1 23 26 Site E-2 No; however the property owner has submitted a public comment to the HEAB regarding future development of the site.
LOS GATOS Oka Road (Cal Trans ROW)95032 000-00-000 Medium Density Residential R-1:8 14 22 4.9 Vacant YES - Current YES - State-Owned Available Not Used in Prior Housing Element 7 7 55 69 Site E-3LOS GATOS 110 Knowles Drive 95032 424-32-077 High Density Residential CM:AHOZ 30 40 7.34 Commercial YES - Current NO - Privately-Owned Available Used in Prior Housing Element - Non-Vacant 106 79 35 220 Site F-1 No; however the site is located within the Affordable Housing Overlay Zone.LOS GATOS 206 Knowles Drive 95032 424-32-076 High Density Residential CM 30 40 2.41 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 35 26 11 72 Site F-2 No; however, the site is located immediately adjacent to 110 Knowles Drive (Site F-1), which has an Affordable Housing Overlay Zone.
LOS GATOS 440 Los Gatos Almaden Road 95032 527-49-048 Neighborhood Commercial C-1 10 20 0.52 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 5 5 Site G-1 consolidated parcels Property Owner Interest Form SubmittedLOS GATOS 445 Leigh Avenue 95032 527-49-049 Neighborhood Commercial C-1 10 20 0.29 Commercial YES - Current NO - Privately-Owned Available Not Used in Prior Housing Element 0 0 3 3 Site G-1 consolidated parcels Property Owner Interest Form Submitted
Table B: Candidate Sites Identified to be Rezoned to Accommodate Shortfall Housing Need, Table Starts in Cell A2 For Santa Clara County jurisdictions, please format the APNs as follows: 999-99-999
Jurisdiction Name Site Address/Intersection 5 Digit ZIP Code Assessor Parcel Number Very Low-Income Low-Income Moderate-Income
Above
Moderate-Income
Type of Shortfall Parcel Size(Acres)Current General Plan Designation Current Zoning
Proposed General
Plan (GP) Designation Proposed Zoning
Minimum
Density Allowed
Maximum
Density Allowed Total Capacity Vacant/Nonvacant Description of Existing Uses Infrastructure Optional Information1 Optional Information2 Optional Information3
LOS GATOS 50 Park Avenue 95030 529-01-040 0 0 0 1 Shortfall of Sites 0.18 Medium Density ResidR-1D Medium Density ResidR-1D 5 12 1 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 61 Montebello Way 95030 529-01-041 0 0 0 4 Shortfall of Sites 0.69 Medium Density ResidR-1D Medium Density ResidR-1D 5 12 4 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 101 S. Santa Cruz Avenue 95030 529-01-022 0 0 0 16 Shortfall of Sites 0.8 Central Business DistC-2 Central Business DistC-2 20 30 16 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 165 Los Gatos-Saratoga Road 95030 529-04-083 0 0 0 7 Shortfall of Sites 0.37 Central Business DistC-2 Central Business DistC-2 20 30 17 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 50 Los Gatos-Saratoga Road 95030 529-24-032 76 75 51 9 Shortfall of Sites 7.04 Mixed Use CommerciCH:PD Mixed Use CommerciCH:PD 30 40 211 Non-Vacant Hotel/motel YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS Los Gatos-Saratoga Road 95030 529-24-001 9 9 9 18 Shortfall of Sites 1.49 Mixed Use CommerciCH:PD Mixed Use CommerciCH:PD 30 40 45 Non-Vacant Hotel/motel YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Los Gatos-Saratoga Road 95030 529-24-003 1 2 2 3 Shortfall of Sites 0.28 Mixed Use CommerciCH:PD Mixed Use CommerciCH:PD 30 40 8 Non-Vacant Hotel/motel YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 15300 Los Gatos Boulevard 95032 424-17-036 24 9 9 6 Shortfall of Sites 1.6 Mixed Use CommerciC-1 Mixed Use CommerciC-1 30 40 48 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 15349 Los Gatos Boulevard 95032 424-19-049 5 2 2 1 Shortfall of Sites 0.34 Mixed Use CommerciCH Mixed Use CommerciCH 30 40 10 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 15367 Los Gatos Boulevard 95032 424-19-048 18 8 8 2 Shortfall of Sites 1.2 Mixed Use CommerciCH Mixed Use CommerciCH 30 40 36 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 15405 Los Gatos Boulevard 95032 424-19-069 20 8 8 4 Shortfall of Sites 1.34 Mixed Use CommerciCH Mixed Use CommerciCH 30 40 40 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 15425 Los Gatos Boulevard 95032 424-19-067 16 7 7 3 Shortfall of Sites 1.09 Mixed Use CommerciCH Mixed Use CommerciCH 30 40 33 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 15795 Los Gatos Boulevard 95032 529-15-059 9 4 4 2 Shortfall of Sites 0.64 Mixed Use CommerciCH Mixed Use CommerciCH 30 40 19 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 16203 Los Gatos Boulevard 95032 529-16-069 12 5 5 2 Shortfall of Sites 0.79 Mixed Use CommerciCH Mixed Use CommerciCH 30 40 24 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 16492 Los Gatos Boulevard 95032 532-07-086 0 0 0 2 Shortfall of Sites 0.23 Low Density ResidentC-1 Low Density ResidentC-1 10 20 2 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS Los Gatos Boulevard 95032 532-07-085 0 0 0 4 Shortfall of Sites 0.38 Neighborhood CommC-1 Neighborhood CommC-1 10 20 4 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 15495 Los Gatos Bouelvard 95032 424-22-030 58 23 23 12 Shortfall of Sites 3.85 Mixed Use CommerciCH Mixed Use CommerciCH 30 40 116 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 15445 Los Gatos Bouelvard 95032 424-19-068 23 9 9 5 Shortfall of Sites 1.53 Mixed Use CommerciCH Mixed Use CommerciCH 30 40 46 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14859 Los Gatos Boulevard 95032 424-07-094 44 13 13 17 Shortfall of Sites 2.9 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 87 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 16392 Los Gatos Boulevard 95032 424-07-095 12 3 3 5 Shortfall of Sites 0.78 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 23 Non-Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 16260 Burton Road 95032 424-07-053 6 2 2 3 Shortfall of Sites 0.44 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 13 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 16250 Burton Road 95032 424-07-009 6 2 2 3 Shortfall of Sites 0.44 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 13 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14917 Los Gatos Boulevard 95032 424-07-081 56 17 17 22 Shortfall of Sites 3.74 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 112 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 14925 Los Gatos Boulevard 95032 424-07-115 91 27 27 37 Shortfall of Sites 6.07 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 182 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS Los Gatos Boulevard 95032 424-07-116 15 5 5 6 Shortfall of Sites 1.02 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 31 Non-Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 16245 Burton Road 95032 424-06-115 18 5 5 7 Shortfall of Sites 1.17 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 35 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS Burton Road 95032 424-06-116 2 0 0 1 Shortfall of Sites 0.11 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 3 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 16240 Burton Road 95032 424-07-010 4 1 1 2 Shortfall of Sites 0.26 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 8 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 16270 Burton Road 95032 424-07-052 6 2 2 3 Shortfall of Sites 0.43 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 13 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 16210 Burton Road 95032 424-07-054 4 1 1 2 Shortfall of Sites 0.26 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 8 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 14831 Los Gatos Boulevard 95032 424-07-063 8 3 3 3 Shortfall of Sites 0.56 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 17 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14849 Los Gatos Boulevard 95032 424-07-064 14 4 4 6 Shortfall of Sites 0.93 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 28 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 14823 Los Gatos Boulevard 95032 424-07-065 5 1 1 4 Shortfall of Sites 0.37 North Forty Specific PNorth Forty Specific PNorth Forty Specific PNorth Forty Specific P 30 30 11 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 14800 Oka Road 95032 424-08-057 0 0 1 11 Shortfall of Sites 2.97 Low Density ResidentR-1:8 Low Density ResidentR-1:8 0 5 12 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS Oka Lane 95032 424-08-029 0 0 0 1 Shortfall of Sites 0.31 Low Density ResidentR-1:8 Low Density ResidentR-1:8 0 5 1 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS Oka Lane 95032 424-08-059 0 0 0 4 Shortfall of Sites 1.01 Low Density ResidentR-1:8 Low Density ResidentR-1:8 0 5 4 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS Oka Lane 95032 424-08-060 0 0 0 5 Shortfall of Sites 1.29 Low Density ResidentR-1:8 Low Density ResidentR-1:8 0 5 5 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 14800 Oka Road 95032 424-08-058 0 0 0 6 Shortfall of Sites 1.41 Low Density ResidentR-1:8 Low Density ResidentR-1:8 0 5 6 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 16603 Lark Avenue 95032 424-08-017 0 3 3 29 Shortfall of Sites 2.48 Medium Density ResidR-M:5-12 Medium Density ResidR-M:5-12 14 22 35 Non-Vacant Residential YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 14840 Oka Road 95032 424-08-021 0 6 6 49 Shortfall of Sites 4.32 Medium Density ResidR-M:5-12 Medium Density ResidR-M:5-12 14 22 61 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS Oka Lane 95032 424-08-074 0 2 1 23 Shortfall of Sites 6.41 Low Density ResidentR-1:8 Low Density ResidentR-1:8 0 5 26 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS Oka Road (Cal Trans ROW)95032 000-00-000 0 7 7 55 Shortfall of Sites 4.9 Medium Density ResidR-1:8 Medium Density ResidR-1:8 14 22 69 Vacant Vacant YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 110 Knowles Drive 95032 424-32-077 66 40 79 35 Shortfall of Sites 7.34 High Density ResidenCM:AHOZ High Density ResidenCM:AHOZ 30 40 220 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program LOS GATOS 206 Knowles Drive 95032 424-32-076 22 13 26 11 Shortfall of Sites 2.41 High Density ResidenCM High Density ResidenCM 30 40 72 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 440 Los Gatos Almaden Road 95032 527-49-048 0 0 0 5 Shortfall of Sites 0.52 Neighborhood CommC-1 Neighborhood CommC-1 10 20 5 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
LOS GATOS 445 Leigh Avenue 95032 527-49-049 0 0 0 3 Shortfall of Sites 0.29 Neighborhood CommC-1 Neighborhood CommC-1 10 20 3 Non-Vacant Commercial YES - Current Housing Element Overlay Zone (HEOZ) implementation program
3
Table C: Land Use, Table Starts in A2
Zoning Designation
From Table A, Column G
and Table B, Columns L and N (e.g.,
"R-1")
General Land Uses Allowed (e.g., "Low-density residential")
R-1D Single-family dwelling, provided that there is not more than one principal residential structure on a lot, two-family dwelling, provided that there is not more than one principal residential structure on a lot, family daycare home, and residential care facility, small family home.
C-1
Retailing, including formula retail up to six thousand (6,000) square feet, Personal service businesses and service businesses necessary for the conduct of households, Office activities, Limited manufacturing activities when a majority of sales are made, on site, to the ultimate consumer, Activities permitted
in the LM zone which were approved on or before February 1, 1993, provided any change of use must be a conforming use in the C-1 zone, and Group classes, and single-family, two-family, and multi-family in a mixed-use project through a CUP.
C-2
Retailing, including formula retail up to six thousand square feet, Office activities subject to subsection (c), Limited manufacturing activities when a majority of sales are made, on site, to the ultimate consumer, Wholesaling without warehousing on the premises, Single-family and two-family uses, in
conjunction with the other uses permitted in this section and multi-family in a mixed-use project through a CUP
CH
Retailing, including formula retail up to six thousand square feet, Personal service businesses and service businesses necessary for the conduct of households, Office activities, Limited manufacturing activities when a majority of sales are made on site to the ultimate consumer, Group classes, and single-
family, two-family, and multi-family in a mixed-use project through a CUP
CH:PD Hotel up to 300 rooms, a conference facility containing approximately 10,000 square feet, and an underground parking facility
North Forty Specific Plan Retail, Restaurant, Personal Service, Office, Hotel, Townhomes, Rowhouses, Multi-Family, Condominiums, Live/Work Lofts, Park, Public Transpiration and Parking Facilities, Small Family Daycare, Alternating Use/Shared Parking, and Botanical Nursery
R-1:8
Single-family dwelling, provided that there is not more than one principal residential structure on a lot, raising of trees, vegetables and horticultural specialties, but not including commercial greenhouses, retail nurseries, or storage of landscaping equipment, products or supplies for commercial uses,
family daycare home, and residential care facility, small family home.
R-M:5-12 Single-family dwelling, two-family dwelling, family daycare home, residential care facility, small family home, multi-family dwelling, and a transitional Housing facility as defined by Health and Safety Code section 50675.2
CM
Activities involving controlled manufacturing, research and development, wholesaling, warehousing, and other light industrial uses, Sales to the ultimate consumer of articles manufactured on the premises to the customer's order, Professional and administrative offices, Emergency shelters as defined by
Health and Safety Code section 50801
CM:AHOZ Multifamily dwellings, Two-family dwellings, and Single-family dwellings.
HEOZ Housing Element Overlay Zone Implementation Program BF to apply to the sites included in the Site Inventory to modify the development standards (i.e., density, lot coverage, FAR, height) on those sites
This Page Intentionally Left Blank
Environmental Analysis
Los Gatos 6th Cycle Housing Element
2023-2031 Planning Period
December 22, 2022
Prepared by
EMC Planning Group
Exhibit 2
ENVIRONMENTAL ANALYSIS
LOS GATOS 6TH CYCLE HOUSING ELEMENT
2023-2031 PLANNING PERIOD
PREPARED FOR
Town of Los Gatos
Joel Paulson, Community Development Director
110 E. Main Street
Los Gatos, CA 95030
Tel 408.354.6879
jpaulson@losgatosca.gov
PREPARED BY
EMC Planning Group Inc.
601 Abrego Street
Monterey, CA 93940
Tel 831.649.1799
Fax 831.649.8399
Teri Wissler Adam, Senior Principal
wissler@emcplanning.com
www.emcplanning.com
December 22, 2022
This document was produced on recycled paper.
EMC Planning Group Inc.
TABLE OF CONTENTS
A.BACKGROUND ..................................................................................................................... 1
B.DETERMINATION ................................................................................................................ 9
C.EVALUATION OF ENVIRONMENTAL IMPACTS ............................................................. 10
1.Aesthetics .............................................................................................................................. 11
2.Agriculture and Forest Resources ...................................................................................... 15
3.Air Quality ............................................................................................................................. 17
4.Biological Resources ............................................................................................................ 23
5.Cultural Resources ............................................................................................................... 30
6.Energy .................................................................................................................................... 33
7.Geology and Soils ................................................................................................................ 37
8.Greenhouse Gas Emissions ............................................................................................... 44
9.Hazards and Hazardous Materials ..................................................................................... 51
10.Hydrology and Water Quality ............................................................................................ 57
11.Land Use and Planning ....................................................................................................... 64
12.Mineral Resources ................................................................................................................ 67
13.Noise ...................................................................................................................................... 68
14.Population and Housing ..................................................................................................... 72
15.Public Services ...................................................................................................................... 74
16.Recreation ............................................................................................................................. 79
17.Transportation ...................................................................................................................... 80
18.Tribal Cultural Resources ................................................................................................... 89
19.Utilities and Services Systems ............................................................................................. 90
20.Wildfire .................................................................................................................................. 98
21.Mandatory Findings of Significance ................................................................................ 104
D.SOURCES ........................................................................................................................... 106
EMC Planning Group Inc.
Figures
Figure 1 Location Map .................................................................................................................... 5
Figure 2 Site Inventory Location Areas ........................................................................................ 7
Figure 3 Downtown Area Sites’ Fire Hazards ........................................................................... 99
Section A Background 1 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
A. BACKGROUND
Setting
The Town of Los Gatos is located within Santa Clara County, south of the San Francisco Bay.
It’s surrounded by the City of Campbell to the north, the cities of Saratoga and Monte Sereno to
the west, the City of San Jose to the east, and unincorporated land (i.e., the Santa Cruz
Mountains) to the south. The incorporated area of Los Gatos covers approximately 11.5 square
miles and is almost entirely built-out, with its sphere of influence encompassing approximately
18 square miles. Primary access is provided by State Route 17 from the north and south, which is
the main roadway linking the Bay Area to Santa Cruz and the northern Monterey Bay region, and
from State Route 85 from the west and east. Los Gatos can also be accessed from the west by
State Route 9, also known as Los Gatos-Saratoga Road. Figure 1, Location Map, presents the
relationship between the Town of Los Gatos and nearby cities, as well as the state highway
system.
Background
The Town of Los Gatos (Town) has prepared a draft 6th cycle Housing Element that covers the
planning period 2023 through 2031 consistent with the requirements under California state law.
Part of the Housing Element Update requires that the Town identify adequate housing sites to
accommodate the Regional Housing Needs Allocation (RHNA) assigned to the Town by the
California Department of Housing and Development (HCD) and the Association of Bay Area
Governments/Metropolitan Transportation Commission (ABAG/MTC). The RHNA identified
for the Town’s 6th cycle Housing Element is 1,993 units.
Project Title Los Gatos 6th Cycle Housing Element
Lead Agency Contact Person
and Phone Number
Joel Paulson,
Community Development Director
408-354-6879
Date Prepared December 22, 2022
Study Prepared by EMC Planning Group Inc.
601 Abrego Street
Monterey, CA 93940
Project Location Town of Los Gatos
Project Sponsor Name and Address Town of Los Gatos
110 E. Main Street
Los Gatos CA 95030
General Plan Designation Various
Zoning Various
Section A Background 2 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Methodology
The Town received a referendum to repeal the Land Use and Community Design Elements of
the adopted Town of Los Gatos California 2040 General Plan (General Plan). In October 2022, the
Town Council adopted a resolution to provide that the Town of Los Gatos 2020 General Plan’s Land
Use and Community Design Elements will govern during the period of suspension. Therefore,
when the term “General Plan” is used in this environmental analysis, it is the General Plan in
effect that is being referenced (i.e., the Town of Los Gatos California 2040 General Plan with the Town
of Los Gatos 2020 General Plan’s Land Use and Community Design Elements).
The Town’s 2040 General Plan Final Environmental Impact Report SCH#2020070175 (General Plan
Final EIR) (Town of Los Gatos June 2022a) (chrome-
extension://efaidnbmnnnibpcajpcglclefindmkaj/https://losgatos2040.com/images/docs/5_LG
_2040_GP_FEIR_RTC_June_2022.pdf) was certified in June 2022, with the following
documents making up the entirety of the General Plan Final EIR:
2040 General Plan Final Environmental Impact Report Addenda and Errata for Town Council
SCH#2020070175 dated June 2022 (chrome-extension://efaidnbmnnnibpcajpcglcle
findmkaj/https://losgatos2040.com/images/docs/6_LG_2040_GP_FEIR_RTC_
Addenda_Errata_for_Town_Council.pdf);
2040 General Plan Revised Sections of Draft Environmental Impact Report dated
November 2021 (chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://
www.losgatosca.gov/DocumentCenter/View/29410/Revised-Sections-of-Draft-EIR);
and
2040 General Plan Draft Environmental Impact Report (General Plan EIR) dated July 2021
(chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://losgatos2040.com/
images/docs/2040-General-Plan-DEIR-with-Appendices.pdf).
Some of the timing of preparation of the 6th cycle Housing Element Update overlapped with the
preparation of the General Plan EIR, allowing for the two documents to work together on topics
such as allowable density, floor area ratio, and height to assist in meeting the Town’s RHNA
requirement. The General Plan EIR evaluated the potential growth for up to 3,738 dwelling
units, has already evaluated the housing and population growth projections identified within the
6th cycle Housing Element Update.
This environmental analysis relies on the earlier analyses in the General Plan Program EIR
(against which no timely lawsuit challenging its adequacy under CEQA was filed), pursuant to
CEQA Guidelines section 15168(c). Section 15168(c) provides that “later activities [here, the
Housing Element Update] in the program [here, the General Plan] must be examined in light of
the program EIR to determine whether an additional environmental document must be
prepared.” Section 15168(c)(2) provides: “If the agency finds that pursuant to Section 15162, no
subsequent EIR would be required, the agency can approve the activity as being within the scope
of the project covered by the program EIR, and no new environmental document would be
required.” The section further explains that the “within the scope” inquiry is a factual question
that the agency determines based on substantial evidence. While no specific format is required to
document the agency’s determination, an initial study checklist provides a useful, familiar format
Section A Background 3 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
to explain the agency’s reasoning and evidence. As explained in detail for each environmental
resource area herein, there is no evidence that development under the Housing Element Update
would result in any new or more severe significant environmental impacts than previously
determined in the General Plan EIR. Therefore, this analysis supports a determination under
CEQA Guidelines section 15162 that no subsequent or supplemental EIR is necessary for the
Housing Element Update.
The analysis in this initial study contains a brief discussion identifying the following:
a. “Earlier Analysis Used” identifies and states where the General Plan EIR is available for
review (see above).
b. “Impact Adequately Addressed” identifies which effects from the checklist were within
the scope of and adequately analyzed in an earlier document pursuant to applicable legal
standards, and states whether such effects were addressed by mitigation measures based
on the earlier analysis.
c. “Mitigation Measures”—For effects that are “Less-Than-Significant Impact with
Mitigation Measures Incorporated,” mitigation measures are described which were
incorporated or refined from the earlier document and the extent to which they address
site-specific conditions for the project. This mitigation generally takes the form of
General Plan policies.
Description of Proposal
The proposal includes the update and preparation of the Town’s 6th Cycle 2023-2031 Housing
Element in order to comply with the state’s housing goals set forth in the Government Code, and
adopting this element as an amendment to the Town’s General Plan. The Town is currently
proposing a total of 2,312 housing units. Appendix H of the Town’s 2023-2031 Housing
Element provides details and capacity estimates for each of the parcels that comprise the Town’s
housing Sites Inventory. Figure 2, Site Inventory Location Areas, shows an overview of the
proposed sites inventory map with the sites combined into various areas of the Town. The total
number of housing units in the Draft Site Inventory is subject to change; however, the total
number of units will not exceed the maximum of 3,738 units that were considered under the
2040 General Plan Environmental Impact Report (EIR). Development of these housing units
would result in a population increase of approximately 5,780 (California Department of Finance
2022). The Housing Element Update may require the demolition of existing commercial
structures on some of the individual sites, but would not result in a net increase in commercial
square footage to the Town of Los Gatos compared to existing conditions. The assumption in
the General Plan was that there would not be any additional commercial beyond what would
already be allowed by the previous, Town of Los Gatos 2020 General Plan.
Other Public Agencies Whose Approval is Required
California Department of Housing and Community Development
Section A Background 4 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Have California Native American tribes traditionally and culturally affiliated with
the project area requested consultation pursuant to Public Resources Code
section 21080.3.1? If so, is there a plan for consultation that includes, for
example, the determination of significance of impacts to tribal cultural
resources, procedures regarding confidentiality, etc.?
The Town did not receive any requests from California Native American tribes requesting
consultation under Assembly Bill 52 for the Housing Element Update or for the General Plan
EIR.
Note: Conducting consultation early in the CEQA process allows tribal governments, lead agencies, and project
proponents to discuss the level of environmental review, identify and address potential adverse impacts to tribal
cultural resources, and reduce the potential for delay and conflict in the environmental review process. (See Public
Resources Code section 21080.3.2.) Information may also be available from the California Native American
Heritage Commission’s Sacred Lands File per Public Resources Code section 5097.96 and the California
Historical Resources Information System administered by the California Office of Historic Preservation. Please
also note that Public Resources Code section 21082.3(c) contains provisions specific to confidentiality.
Source: ESRI 2014
Figure 1Location Map
Los Gatos 6th Cycle Housing Element Environmental Analysis
0 6500 feet
ProjectLocation
£¤101
£¤101UV1
k
Salinas
UV152Gilroy
Los GatosSan Jose
San Francisco
Santa Cruz
Monterey Seaside
§¨¦580
§¨¦5
§¨¦280
§¨¦680
UV1
UV1
Regional Location
Los Gatos
San Jose
Campbell
Saratoga
Cupertino §¨¦280§¨¦280
UV85
UV85
UV85
UV17
UV17
UV17
Los Gatos Town Limits
Santa Cruz Mountains
Not to Scale
Santa Cruz Mountains
Santa Clara
Section A Background 6 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
This side intentionally left blank.
Source: Santa Clara County GIS 2022,Google Earth 2022
Figure 2Site Inventory Location AreasLos Gatos 6th Cycle Housing Element Environmental Analysis
0 4000 ft
Downtown AreaParcels
Alberto WayArea ParcelsLos Gatos LodgeArea Parcels
Los Gatos Blvd.Area ParcelsNorth Forty Area ParcelsLark Ave.Area Parcels
Winchester Blvd.Area ParcelsUnion Ave.Area ParcelsHarwood Rd.Area Parcels Los GatosTown Limits
Section A Background 8 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
This side intentionally left blank.
Section B Determination 9 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
B. DETERMINATION
On the basis of this initial evaluation:
☐I find that the Housing Element Update COULD NOT have a significant effect on the
environment, and a NEGATIVE DECLARATION will be prepared.
☐I find that although the Housing Element Update could have a significant effect on the
environment, there will not be a significant effect in this case because revisions in the
Housing Element Update have been made by or agreed to by its proponent. A
MITIGATED NEGATIVE DECLARATION will be prepared.
☐I find that the Housing Element Update MAY have a significant effect on the environment,
and an ENVIRONMENTAL IMPACT REPORT is required.
☐I find that the Housing Element Update MAY have a “potentially significant impact” or
“potentially significant unless mitigated” impact on the environment, but at least one effect
(1) has been adequately analyzed in an earlier document pursuant to applicable legal
standards, and (2) has been addressed by mitigation measures based on the earlier analysis as
described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but
it must analyze only the effects that remain to be addressed.
☒I find that although the Housing Element Update could have a significant effect on the
environment, because all potentially significant effects have been analyzed adequately in
Town of Los Gatos General Plan EIR pursuant to applicable standards including CEQA
Guidelines section 15168(c)2, and the Housing Element Update is consistent with the
growth projections evaluated in the General Plan EIR, nothing further is required.
____
Joel Paulson, Community Development Director Date
01/17/2023
Section C Evaluation of Environmental Impacts 10 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
C. EVALUATION OF ENVIRONMENTAL IMPACTS
Notes
1. All answers take account of the whole action involved, including off-site as well as on-
site, cumulative as well as project-level, indirect as well as direct, and construction as
well as operational impacts.
2. Once it has been determined that a particular physical impact may occur, then the
checklist answers indicate whether the impact is potentially significant, less than
significant with mitigation, or less than significant. “Potentially Significant Impact” is
appropriate if there is substantial evidence that an effect may be significant. If there are
one or more “Potentially Significant Impact” entries when the determination is made,
an EIR is required.
3. “Negative Declaration: Less-Than-Significant Impact with Mitigation Measures
Incorporated” applies where the incorporation of mitigation measures has reduced an
effect from “Potentially Significant Impact” to a “Less-Than-Significant Impact.” The
lead agency must describe the mitigation measures and briefly explain how they reduce
the effect to a less-than-significant level (mitigation measures from section XVII,
“Earlier Analyses,” may be cross-referenced).
4. Earlier analyses are used where, pursuant to the tiering, program EIR, or other CEQA
process, an effect has been adequately analyzed in an earlier EIR or negative
declaration. [Section 15063(c)(3)(D)] In this case, a brief discussion would identify the
following:
a. “Earlier Analysis Used” identifies and states where such document is available for
review.
b. “Impact Adequately Addressed” identifies which effects from the checklist were
within the scope of and adequately analyzed in an earlier document pursuant to
applicable legal standards, and states whether such effects were addressed by
mitigation measures based on the earlier analysis.
c. “Mitigation Measures”—For effects that are “Less-Than-Significant Impact with
Mitigation Measures Incorporated,” mitigation measures are described which were
incorporated or refined from the earlier document and the extent to which they
address site-specific conditions for the project.
5. Checklist references to information sources for potential impacts (e.g., general plans,
zoning ordinances, etc.) are incorporated. Each reference to a previously prepared or
outside document, where appropriate, includes a reference to the page or pages where
the statement is substantiated.
6. “Supporting Information Sources”—A source list is attached, and other sources used
or individuals contacted are cited in the discussion.
7. The explanation of each issue identifies:
a. The significance criteria or threshold, if any, used to evaluate each question; and
b. The mitigation measure identified, if any to reduce the impact to less than
significant.
Section C Evaluation of Environmental Impacts 11 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
1. AESTHETICS
Except as provided in Public Resources Code Section 21099 (Modernization of Transportation
Analysis for Transit-Oriented Infill Projects), would the project:
Comments:
a. As identified in the General Plan EIR (Section 4.1, Aesthetics), scenic vistas in Los Gatos
include the hillside area of the Santa Cruz Mountains and open space areas on the edges
of the Town. New development facilitated by the Town, including the housing units
proposed by the Housing Element Update, would be in the existing urbanized area and
generally would not affect views of the hillside areas or other scenic vistas. The General
Plan EIR states that new development in the urbanized area may be visible from ridges in
the hillside area or from isolated locations in other open space areas of the Town, but
would appear similar to existing surrounding urban development. However, new
structures could be oriented or scaled in such a way that views of the hillside area are
blocked from isolated locations in the Town.
The General Plan’s Community Design Element contains goals and policies to minimize
potential visual impacts on scenic vistas from future development such as Goal CD-16
and its associated policies, which promote and protect scenic resources through design of
new structures or remodels that allow scenic views to all affected properties.
Potentially Significant
Impact
Less-than-Significant Impact with Mitigation
Measures Incorporated
Less-Than- Significant Impact
No Impact
a.Have a substantial adverse effect on a scenic vista?☐☐☒ ☐
b.Substantially damage scenic resources, including but
not limited to trees, rock outcroppings, and historic
buildings within a state scenic highway?
☐ ☐ ☐ ☒
c.In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of
the site and its surroundings? (Public views are those
that are experienced from publicly accessible vantage
points.) If the project is in an urbanized area, would
the project conflict with applicable zoning and other
regulations governing scenic quality?
☐ ☐ ☐ ☒
d. Create a new source of substantial light or glare, which
would adversely affect day or nighttime views in the
area?
☐ ☐ ☒ ☐
Section C Evaluation of Environmental Impacts 12 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
The General Plan EIR concludes (p. 4.1-16) that the General Plan’s goals and policies
would minimize visual intrusion and assist in reducing obstructions of view of the scenic
vistas associated with the open space areas of the Town. Because development facilitated
by the General Plan would occur in existing urbanized areas of the Town, and
implementation of these policies would encourage vistas and visibility of scenic open
space, impacts of the General Plan would be less than significant.
The Housing Element Update is consistent with the growth projections evaluated in the
General Plan EIR. Therefore, development consistent with the Housing Element Update
would be required to implement the General Plan’s applicable goals and policies to
reduce impacts on scenic vistas thereby ensuring its impact would be less than significant.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts on scenic vistas.
b. According to the General Plan EIR (Section 4.1, Aesthetics), there are no state designated
scenic highways within the Town limits and there would be no impacts on scenic
resources within a state scenic highway (Town of Los Gatos 2021, p. 4.1-17)
The sites nearest to the officially designated portion of State Route 9, associated with the
Housing Element Update, are located approximately 0.60 miles east. Development
associated with the Housing Element Update is consistent with the growth projections
evaluated in the General Plan EIR and would not facilitate new development adjacent to
the officially designated portion of State Route 9. The General Plan EIR adequately
addressed the Housing Element Update’s potential impacts on scenic resources within a
state scenic highway.
c. As discussed in the General Plan EIR (Section 4.1, Aesthetics), the General Plan would
facilitate incremental change in the visual character of the Town through development
and redevelopment of land. Implementation of the Housing Element Update, consistent
with the growth projections evaluated in the General Plan EIR, would include the reuse
of existing urbanized lands and infill development on vacant parcels to meet the housing
needs of the growing community.
New development would not substantially degrade the visual character or quality of the
Town by complying with existing design guidelines as well as with General Plan policies.
Impacts would be less than significant (Town of Los Gatos 2021, p. 4.1-24).
Some applicable General Plan policies from the Town of Los Gatos 2020 General Plan’s Land
Use Element are presented below:
Policy LU-7.2 - To ensure compatibility with surrounding neighborhoods, infill
projects shall demonstrate that the development meets the criteria contained in the
Development Policy for In-Fill Projects and the deciding body shall make findings
consistent with this policy.;
Policy LU-7.3 - Infill projects shall contribute to the further development of the
surrounding neighborhood (e.g., improve circulation, contribute to or provide
Section C Evaluation of Environmental Impacts 13 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
neighborhood unity, eliminate a blighted area) and shall not detract from the
existing quality of life.
Policy LU-7.4 - Infill projects shall be designed in context with the neighborhood
and surrounding zoning with respect to the existing scale and character of
surrounding structures, and should blend rather than compete with the established
character of the area; and
Policy LU-1.4 - Infill projects shall be designed in context with the neighborhood
and surrounding zoning with respect to the existing scale and character of
surrounding structures, and should blend rather than compete with the established
character of the area.
The Housing Element Update would adhere to the applicable General Plan policies and
the Town’s existing design guidelines to ensure that development facilitated by the
Housing Element Update does not substantially degrade visual character and quality of
Los Gatos. As previously stated, the General Plan EIR concluded that new development
would result in less than significant impacts associated with degrading the visual character
or quality of the Town. Given that the Housing Element Update is consistent with the
growth evaluated in the General Plan EIR, the Housing Element Update would result in
less than significant impacts on scenic quality.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts on scenic quality.
d. As identified in the General Plan EIR (Section 4.1, Aesthetics), new development
facilitated under the General Plan would increase the development intensity throughout
the Town, thereby introducing new sources of light. Potential sources of new nighttime
light from new development include light spillover from the windows of residences and
businesses, outdoor security lighting, lighted signs, and streetlights. New development
could also produce glare from sunlight reflecting off windows, reflective surfaces, etc.
The development that would be facilitated by the General Plan, such as the housing sites
associated with the Housing Element Update, would occur in already-urbanized areas of
the Town, where existing lights and surfaces with glare are common. As a result, the
General Plan EIR concluded that additional light and glare created under the General
Plan, which includes the Housing Element Update, would not illuminate or contribute to
light pollution in currently dark or unlit areas without reflective or glaring surfaces (p. 4.1-
25).
The Housing Element Update would also be required to comply with General Plan Policy
CD-3.2, which requires that street and structure lighting minimize its visual impacts by
preventing glare, limiting the amount of light that falls on neighboring properties, and
avoiding light pollution of the night sky. In addition, safety lighting that may be
implemented with the Housing Element Update would be required to conform to Town-
prescribed lighting regulations provided in Section 29.10.09015, Residential Outdoor
Lighting, of the Los Gatos Municipal Code.
Section C Evaluation of Environmental Impacts 14 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
According to the General Plan EIR, new sources would not substantially increase the
amount of nighttime lighting or glare in the already urbanized Town. The General Plan
has an overall intent to improve the visual quality of Los Gatos and considers light and
glare impacts from new development in the Town; therefore, the General Plan EIR
concludes that impacts associated with light and glare would be less than significant
(p. 4.1-25). The Housing Element Update is consistent with the growth projections
evaluated in the General Plan EIR and, therefore, would result in be less than significant
impacts associated with light and glare. The General Plan EIR adequately addressed the
Housing Element Update’s potential impacts on light and glare.
Section C Evaluation of Environmental Impacts 15 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
2. AGRICULTURE AND FOREST RESOURCES
In determining whether impacts on agricultural resources are significant environmental effects
and in assessing impacts on agriculture and farmland, lead agencies may refer to the California
Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California
Department of Conservation as an optional model to use in assessing impacts on agriculture and
farmland. In determining whether impacts to forest resources, including timberland, are
significant environmental effects, lead agencies may refer to information compiled by the
California Department of Forestry and Fire Protection regarding the state’s inventory of forest
land, including the Forest and Range Assessment Project and the Forest Legacy Assessment
project; and forest carbon measurement methodology provided in Forest Protocols adopted by
the California Air Resources Board. Would the project:
Comments:
a. According to the General Plan EIR (Section 4.2, Agriculture and Forest Resources), the
General Plan does not propose new or expanded conversion of Important Farmland or
forestland to new uses and the Town prioritizes infill development and maximizing the
underutilized parcels in the Town while maintaining existing community character.
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and the housing sites associated with the
Housing Element Update would occur as infill development or on underutilized parcels
in the Town.
Potentially Significant
Impact
Less-than-Significant Impact with Mitigation
Measures Incorporated
Less-Than- Significant
Impact
No Impact
a.Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the
California Resources Agency, to nonagricultural use?
☐ ☐ ☒ ☐
b.Conflict with existing zoning for agricultural use, or a
Williamson Act contract?☐ ☐ ☐ ☒
c.Conflict with existing zoning for, or cause rezoning
of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?
☐ ☐ ☐ ☒
d.Result in the loss of forest land or conversion of
forest land to non-forest use?☐ ☐ ☐ ☒
e. Involve other changes in the existing environment
which, due to their location or nature, could result in
conversion of Farmland to nonagricultural use or
conversion of forest land to non-forest use?
☐ ☐ ☐ ☒
Section C Evaluation of Environmental Impacts 16 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Some of the sites associated with the Housing Element Update’s Lark Avenue Area are
identified as Prime and Unique Farmland by the Farmland Mapping and Monitoring
Program (California Department of Conservation 2018). Conversion of Important
Farmland-designated lands to non-agricultural uses is considered an environmental
impact. However, the Lark Avenue Area sites have been anticipated for residential uses
since the previous general plan in 2011 (Town of Los Gatos 2011, Figure LU-3), are
zoned for residential uses (Town of Los Gatos 2019), and are surrounded by urban uses
(Google Earth 2022). Therefore, development associated with the Housing Element
Update would result in less than significant impacts related to the conversion of
Important Farmlands to non-agricultural uses and would not involve other changes in the
existing environment which, due to their location or nature, could result in conversion of
Farmland to nonagricultural use.
b. None of the housing sites are zoned for agricultural use or are in a Williamson Act
contract. See General Plan EIR Figure 4.2-2, Important Farmlands and Williamson Act
Contracts in Los Gatos and SOI, within Section 4.2, Agriculture and Forest Resources.
Therefore, the Housing Element Update would not conflict with land currently zoned for
agricultural use or with a Williamson Act contract.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts on Williamson Act contracted land and conversion of land zoned for agricultural
use.
c-e. The Town does not contain forest lands (Section 4.18, Effects Found Not to be
Significant, Town of Los Gatos 2021, p. 4.18-1); therefore, development consistent with
the growth projections evaluated in the General Plan EIR, such as the Housing Element
Update, would not facilitate new or additional development that would conflict with
existing zoning of or result in the loss of forest land to non-forest uses. In addition, the
land throughout the southern and eastern portions of Los Gatos are no longer used as a
source of timber for logging (Section 4.2, Agriculture and Forest Resources, p. 4.2-9). No
impact would occur associated with the availability of forestry resources within the Town
(Town of Los Gatos 2021, p. 4.18-1), or involve other changes in the existing
environment which, due to their location or nature, could result in conversion of forest
land to non-forest use.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts on forest lands.
Section C Evaluation of Environmental Impacts 17 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
3. AIR QUALITY
Where available, the significance criteria established by the applicable air quality management
district or air pollution control district may be relied upon to make the following determinations.
Would the project:
Comments:
a. The most recently adopted air quality plan applicable to the Town of Los Gatos is the
Bay Area Air Quality Management District’s Final 2017 Clean Air Plan, which describes
how the San Francisco Bay Area will achieve compliance with the state’s one-hour ozone
standard as expeditiously as practicable, and how the region will reduce transport of
ozone and ozone precursors to neighboring air basins. As discussed in the General Plan
EIR (Section 4.3, Air Quality), some of the General Plan policies within the Environment
and Sustainability Element and the Mobility Element are aimed at reducing vehicle
emissions and energy use, which are two major drivers of criteria air pollutant emissions.
General Plan Policy ENV-11.2 requires the increase in energy efficiency in municipal
facilities; Policy ENV-11.4 promotes the use of efficient energy in new residences,
businesses, and municipal buildings; and Policies ENV-11.5 and ENV-11.6 support the
use of solar and organic waste recycling. Development projected by the General Plan
would also be designed to promote active transportation and reduce vehicle miles
traveled (VMT) in the Town, further reducing vehicle emissions through Policies
ENV-8.3, MOB-1.1, MOB-1.2, MOB-2.2, MOB-2.3, and MOB-2.11.
Implementation of these General Plan policies would ensure that development under the
General Plan would not result in significant criteria pollutant emissions or other
significant air quality impacts. Therefore, the General Plan would be consistent with the
goals of the Final 2017 Clean Air Plan (Town of Los Gatos 2021, p. 4.3-9). The General
Plan EIR also concluded that the General Plan would be consistent with applicable
Potentially
Significant Impact
Less-than-Significant
Impact with Mitigation Measures Incorporated
Less-Than-
Significant Impact
No Impact
a.Conflict with or obstruct implementation of the
applicable air quality plan?☐ ☐ ☐ ☒
b.Result in a cumulatively considerable net increase of
any criteria pollutant for which the project region is
nonattainment under an applicable federal or state
ambient air quality standard?
☐ ☒ ☐ ☐
c.Expose sensitive receptors to substantial pollutant
concentrations?
☐ ☐ ☒ ☐
d.Result in other emissions, such as those leading to
odors adversely affecting a substantial number of
people?
☐ ☒ ☐ ☐
Section C Evaluation of Environmental Impacts 18 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
control measures identified within the Final 2017 Clean Air Plan because it would
implement similar measures through specific goals and policies that would reduce criteria
pollutant emissions (p. 4.3-14). Additionally, it was concluded that buildout of the
General Plan would not preclude planned transit or bike pathways and would not
otherwise disrupt regional planning efforts to reduce VMT and meet federal and state air
quality standards (Town of Los Gatos 2021, p. 4.3-14).
The Bay Area Air Quality Management District’s 2017 CEQA Air Quality Guidelines
threshold for criteria air pollutants and precursors includes an assessment of the rate of
increase of VMT and population. According to the General Plan EIR, because of the
Town’s geographic and socioeconomic context, the rate of increase of service population
is a more appropriate indicator than typical population as to whether the increase in VMT
would be considered significant. It was determined that because VMT associated with
buildout of the General Plan would increase by approximately 25 percent (General Plan’s
507,845 daily VMT/existing conditions 2,044,937 daily VMT), it would not exceed the
rate of increase from the forecast population of approximately 29 percent (General Plan’s
population increase of 8,971/Town’s population of 30,832). Therefore, impacts
concerning criteria pollutants would be less than significant (Town of Los Gatos 2021,
p. 4.3-14).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and would be required to implement the
applicable goals and policies of the Environment and Sustainability Element and the
Mobility Element mentioned previously to ensure that development of the individual sites
would not result in significant criteria pollutant emissions or other significant air quality
impacts. Additionally, because many of the General Plan goals and policies are similar to
the control measures outlined in the Final 2017 Clean Air Plan, implementation of them
by the Housing Element Update would reduce criteria pollutant emissions. The Housing
Element Update would also be required to promote active transportation through
implementation of the applicable policies identified in the Mobility Element and stated
above, reducing vehicle emissions.
The proposed population increase under the Housing Element Update is less than what
was considered under the General Plan’s total buildout population and was evaluated by
the General Plan EIR. Therefore, development associated with the Housing Element
Update would not involve a VMT increase that exceeds the rate of the forecasted
population.
For these reasons, the Housing Element Update, consistent with the growth projections
evaluated in the General Plan EIR, would not conflict with or obstruct implementation of
the applicable air quality plan. The General Plan EIR adequately addressed the Housing
Element Update’s potential impact related to the conflict with an applicable air quality
plan.
b. Development under the General Plan would involve construction activities that may
result in air pollutant emissions such as demolition, grading, construction worker travel,
Section C Evaluation of Environmental Impacts 19 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
delivery hauling of construction supplies and debris, and fuel combustion by onsite
construction equipment. Construction activities would temporarily create emissions of
dust, fumes, equipment exhaust, and other air contaminants during site preparation and
grading, but the extent of daily emissions is unknown as it depends on the quantity of
equipment and the hours of operation for each project.
The Bay Area Air Quality Management District’s 2017 CEQA Air Quality Guidelines do
not have plan-level significance thresholds for construction air pollutant emissions that
would apply to the General Plan. However, there are project-level thresholds for
construction emissions that determine if a project’s construction emissions would be
individually and cumulatively less than significant (i.e., if the construction emissions fall
below the project-level thresholds). The Bay Area Air Quality Management District also
identifies feasible fugitive dust control measures for construction activities that are
recommended for all projects. Additionally, the Bay Area Air Quality Management
District and California Air Resources Board have regulations that address the handling of
hazardous air pollutants such as lead and asbestos, which could be aerially disbursed
during demolition activities.
Section 4.3, Air Quality, of the General Plan EIR determined that construction associated
with development under the General Plan would temporarily increase air pollutant
emissions and possibly create localized areas of unhealthy air pollution concentrations or
air quality nuisances. The General Plan’s goals and policies do not include
implementation of feasible measures to reduce construction emissions associated with
development and, therefore, the following mitigation would be required by all
development under the General Plan to reduce temporary construction air quality impacts
to a less-than-significant level (Town of Los Gatos 2021, p. 4.3-16 and -17).
Mitigation Measure
AQ-1 New discretionary projects in the General Plan Area that exceed the construction
screening criteria of the Bay Area Air Quality Management District shall be
conditioned to reduce construction emissions of reactive organic gases, nitrogen
oxides, and particulate matter (PM10 and PM2.5) by implementing the Bay Area Air
Quality Management District’s Basic Construction Mitigation Measures
(described below) or equivalent, expanded, or modified measures based on
project and site-specific conditions.
Basic Construction Mitigation Measures:
1.All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas,
and unpaved access roads) shall be watered two times per day, with priority
given to the use of recycled water for this activity when feasible.
2.All haul trucks transporting soil, sand, or other loose material off-site shall be
covered.
Section C Evaluation of Environmental Impacts 20 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
3.All visible mud or dirt track-out onto adjacent public roads shall be removed
using wet power vacuum street sweepers at least once per day. The use of dry
power sweeping shall be prohibited.
4.All vehicle speeds on unpaved roads shall be limited to 15 mph.
5.All roadways, driveways, and sidewalks to be paved shall be completed as
soon as possible. Building pads shall be laid as soon as possible after grading
unless seeding or soil binders are used.
6.Idling times shall be minimized either by shutting equipment off when not in
use or reducing the maximum idling time to 5 minutes (as required by the
California airborne toxics control measure Title 13, Section 2485 of California
Code of Regulations). Clear signage shall be provided for construction
workers at all access points.
7.All construction equipment shall be maintained and properly tuned in
accordance with manufacturer’s specifications. All equipment shall be
checked by a certified visible emissions evaluator.
8.A publicly visible sign shall be posted with the telephone number and person
to contact at the lead agency regarding dust complaints. This person shall
respond and take corrective action within 48 hours. The Bay Area Air Quality
Management District’s phone number shall also be visible to ensure
compliance with applicable regulations.
Implementation of the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and may result in the generation of air
pollutant emissions during construction activities. As discussed above, there are no
thresholds for construction-related air pollutant emissions that would apply to the
Housing Element Update because specific developments are unknown at this time.
Therefore, individual development associated with the Housing Element Update would
be required to implement Mitigation Measure AQ-1 in order to reduce temporary
construction air quality impacts and ensure that the Housing Element Update’s potential
increase of criteria pollutants, for which the region is in nonattainment, would be less
than cumulatively considerable.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to the increase of any criteria pollutant for which the region is
nonattainment under an applicable federal or state ambient air quality standard.
c. Sensitive receptors include residences, schools, and hospitals and are located throughout
the Town. Pursuant to the Bay Area Air Quality Management District’s 2017 CEQA Air
Quality Guidelines when assessing community risk and hazards for siting a new receptor,
sources such as freeways or high-volume roadways within a 1,000-foot radius of a project
Section C Evaluation of Environmental Impacts 21 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
site are typically considered. As discussed in the General Plan EIR (Section 4.3, Air
Quality), development projected by the General Plan could result in additional sources of
toxic air contaminants through its commercial uses and, therefore, could increase the
number of stationary or permitted sources that emit toxic air contaminants in the Town
of Los Gatos. There are also several high-volume roadways within and around Los
Gatos, such as State Routes 17 and 85, Los Gatos Boulevard, and Winchester Boulevard.
Areas of high traffic volumes typically result in elevated concentrations of carbon
monoxide as the major source is automobile traffic.
The Bay Area Air Quality Management District’s 2017 CEQA Air Quality Guidelines have
established preliminary screening criteria in determining whether a project would have a
significant impact to localized carbon monoxide concentrations. It is noted that the
screening criteria is not a threshold of significance, but is designed to provide the Town
and project applicants with a conservative indication of whether a project would result in
potentially significant air quality impacts. Using the screening criteria, the General Plan
EIR determined that the highest traveled intersection in the Town (Los Gatos Boulevard
at Lark Avenue) does not exceed traffic volumes for intersections affected by carbon
monoxide and the General Plan would not substantially contribute to or result in the
creation of carbon monoxide hotspots.
However, development under the General Plan may result in sensitive receptors placed in
the proximity to high-volume roadways and freeways, which could expose sensitive
receptors to pollutant concentrations. Development under the General Plan would be
required to comply with General Plan Policy ENV-8.7, which requires that developments
incorporate site planning techniques that reduce exposure of people to the impacts of
high air pollutants from adjacent high-volume roadways. The General Plan EIR,
therefore, concluded that impacts related to exposing sensitive receptors to pollutant
concentrations would be less than significant (p. 4.3-18).
Development associated with the Housing Element Update could place sensitive
receptors (i.e., residences) adjacent to high-volume roadways. The Housing Element
Update does not, however, involve the increase in commercial development over existing
conditions. Therefore, the Housing Element Update would not result in additional
sources of toxic air contaminants through commercial uses increasing the number of
stationary or permitted sources that emit toxic air contaminants in the Town. The
Housing Element Update is consistent with the growth projections evaluated in the
General Plan EIR and, therefore, would be required to comply with General Plan Policy
ENV-8.7.
Because the Housing Element Update was evaluated in the General Plan EIR and
anticipated by the General Plan, development associated with the Housing Element
Update would result in less than significant impacts related to exposing sensitive
receptors to pollutant concentrations.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to sensitive receptors.
Section C Evaluation of Environmental Impacts 22 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
d. The Bay Area Air Quality Management District’s CEQA Air Quality Guidelines state that
the land uses that typically produce objectionable odors include agricultural uses,
wastewater treatment plants, food manufacturing plants, chemical plants, composting,
refineries, landfills, and confined animal facilities. The General Plan would intermix
industrial land uses with residential areas, which could have the potential to expose
sensitive receptors (such as residents) to odors. Therefore, according to the General Plan
EIR’s Section 4.3, Air Quality, the General Plan’s anticipated industrial development in
these areas may result in objectionable odors that may affect a substantial number of
people.
Construction associated with implementation of the General Plan could also emit odors
from the construction vehicles and engine exhaust and idling, which may affect nearby
receptors. Mitigation Measure AQ-1 would reduce construction air quality impacts to a
less-than-significant level by reducing idling times and making sure that construction
equipment is in proper working order (Town of Los Gatos 2021, p. 4.3-18).
The Housing Element Update does not involve the increase in any use other than
residential, which the Bay Area Air Quality Management District determines as not
typically producing objectionable odors. Development associated with the Housing
Element Update is consistent with the growth projections evaluated in the General Plan
EIR. Therefore, the Housing Element Update would not result in the development of
land uses that may expose sensitive receptors to objectionable odors. However,
development associated with the Housing Element Update would involve construction
activities, the equipment of which could emit odors that are objectionable to nearby
sensitive receptors. Therefore, the Housing Element Update would be required to
implement Mitigation Measure AQ-1 to reduce construction air quality impacts and their
effect on nearby sensitive receptors.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
impact sensitive receptors with the creation of objectionable odors.
Section C Evaluation of Environmental Impacts 23 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
4. BIOLOGICAL RESOURCES
Would the project:
Comments:
a. Table 4.4-1 of the General Plan EIR (within Section 4.4, Biological Resources) illustrates
that almost half of the Town is developed or an urban land use and does not provide
habitat for the special-status species reported or known to occur in or near the Town of
Los Gatos. Areas that may provide habitat for special-status species are primarily located
in the open space and undeveloped hillside areas of the planning area and the waterways
and wetlands adjacent to the waterways in the planning area, such as Los Gatos Creek
and Ross Creek (Town of Los Gatos 2021, p. 4.4-12). As discussed throughout the
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a. 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, regulations,
or by the California Department of Fish and Wildlife
or US Fish and Wildlife Service?
☐ ☐ ☒ ☐
b.Have a substantial adverse effect on any riparian
habitat or other sensitive natural community identified
in local or regional plans, policies, or regulations, or by
the California Department of Fish and Wildlife or US
Fish and Wildlife Service?
☐ ☐ ☒ ☐
c. Have a substantial adverse effect on state or federally
protected wetlands (including, but not limited to,
marsh, vernal pool, coastal, etc.), through direct
removal, filing, hydrological interruption, or other
means?
☐ ☐ ☒ ☐
d. Interfere substantially with the movement of any
native resident or migratory fish or wildlife species or
with established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery
sites?
☐ ☐ ☒ ☐
e.Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
☐ ☐ ☐ ☒
f.Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state habitat
conservation plan?
☐ ☐ ☒ ☐
Section C Evaluation of Environmental Impacts 24 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
General Plan EIR, the General Plan focuses on infill development and redevelopment
within the Town limits, which do not provide habitat suitable for special-status species.
Urban development is not allowed in areas of open space and the General Plan would
not change these existing land use designations in order to prevent substantial
development of the Town’s chaparral and scrubland habitats. The General Plan would
also not facilitate permanent development in the riparian vegetation along the Town’s
creeks and adjoining riparian areas.
Although development under the General Plan would occur in urban areas where
infrastructure is already in place, the General Plan facilitates the increase in allowable
density that could occur on some of the infill and redevelopment sites within the Town,
which could require the upgrading of infrastructure facilities within riparian vegetation
along creeks and waterways. Additionally, development within proximity to vegetation
cover could result in new sources of light that affect nesting patterns or wildlife behavior.
This would result in potential temporary riparian and aquatic habitat impacts that support
special-status species. Further, development facilitated by the General Plan could impact
isolated trees and pockets of vegetation in the urbanized areas of Los Gatos. These trees
and isolated pockets could provide habitat for special-status species, including migratory
nesting birds, the disturbance or potential loss of which would be considered a
significant, adverse impact.
Development under the General Plan would be subject to the provisions of various
federal and state natural resources regulations and their respective permitting processes
and would be required to implement the list of various goals and policies of the General
Plan to help prevent loss of special-status species habitat in the Town. Specifically
General Plan Policies ENV-5.2 and ENV-7.1, which would protect special-status plants
and wildlife species and their habitats from adverse impacts of public and private
projects, and Policies ENV-6.1 and ENV-16.2, which would protect aquatic habitat and
adjacent riparian habitat. General Plan Policy ENV-7.11 would also be applicable and
require implementation by development as it reduces indirect impacts to wildlife from
light spill or light trespass from nearby development. Policy ENV-7.5 and ENV-7.10
would also prevent direct impacts to migratory nesting birds. Implementation of the
General Plan’s applicable goals and policies, as well as compliance with state and federal
regulations related to special-status species and their habitats, would ensure that impacts
to special-status species and their habitats would be less than significant (Town of Los
Gatos 2021, p. 4.4-16).
Development associated with the Housing Element Update would involve infill or the
redevelopment of sites. No sites under the Housing Element Update are located within
the Town’s hillside or open space areas that could contain habitats for special-status
species. However, some of the sites associated with the Housing Element Update (within
the Winchester Boulevard Area and Lark Avenue Area) are adjacent to the Los Gatos
Creek. Development at these sites could result in indirect impacts on potential special-
status species that are present in this riparian area through the creation of new light
Section C Evaluation of Environmental Impacts 25 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
sources that may affect the nesting patterns or behavior. Other impacts that could occur
by development include the removal of or disturbance to isolated trees and pockets of
vegetation that could provide habitat to nesting birds.
Development associated with the Housing Element Update would be required to comply
with applicable policies of the General Plan such as Policy CD-3.2 and the Town-
prescribed lighting regulations provided in Town Code Section 29.10.09015, which are
described further in Section 1.0, Aesthetics, checklist question “d;” Policy LU-1.3, which
promotes high quality, well-designed, environmental sensitive, and diverse landscaping in
new and existing developments and the preservation of existing trees, natural vegetation,
natural topography, riparian corridors and wildlife habitats; Policy ENV-5.1, which
requires that all development use native plants or appropriate non-invasive plants that are
indigenous to Los Gatos and Santa Clara County to reduce disturbance of adjacent
natural habitat; Policies ENV-5.2, -5.3, and -5.4, which all require that development
protect special-status native plant species by way of prohibiting development that
depletes or damages existing native plant species and prohibiting the use of invasive plant
species; and Policies ENV-6.1, ENV-7.1, and ENV-16.2 mentioned previously.
Implementation of the General Plan’s applicable goals and policies, as well as compliance
with state and federal regulations related to special-status species and their habitats, would
ensure that impacts to special-status species and their habitats by development associated
with the Housing Element Update would be less than significant.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
impact special-status species and their habitats.
b. The General Plan would facilitate infill development and redevelopment within existing
urbanized areas of the Town and, therefore, is unlikely to contain surface waters and
associated riparian vegetation zones. However, Section 4.4, Biological Resources, of the
General Plan EIR explains that it is possible that the infill development facilitated by the
General Plan would increase density in some areas, which could require upgraded utilities
or stormwater drainage in areas of riparian habitat and streams, the construction of which
could cause adverse, environmental impacts.
The General Plan’s applicable goals and policies would require conservation of existing
creeks and avoidance of disturbing creeks as well as requiring setbacks and measures to
protect riparian areas. Implementation of the General Plan’s goals and policies would
ensure that development under the General Plan would result in less than significant
impacts on riparian habitats (Town of Los Gatos 2021, p. 4.4-17).
Some of the sites associated with the Housing Element Update’s Winchester Boulevard
Area and Lark Avenue Area are located adjacent to the Los Gatos Creek. Development
of these sites could result in ground disturbance that adversely impacts the adjacent
riparian habitat. However, the Housing Element Update would be required to comply
with General Plan Policy ENV-6.1, preventing development from damaging riparian
areas; ENV-6.2, requiring that riparian corridors, among other water courses, be retained
Section C Evaluation of Environmental Impacts 26 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
in their natural condition; ENV-6.3, which requires that setbacks and measures are
implemented to protect riparian corridors; ENV-6.4, promoting the planting of local
naïve trees and shrubs where development occurs on land surrounding streams; and
ENV-16.4, which requires the conservation of existing creeks and the avoidance of
disturbances to these areas.
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and the sites were evaluated with
residential land uses in the General Plan EIR. Therefore, implementation of the
applicable General Plan policies identified above would ensure that impacts on riparian
habitats by development under the Housing Element Update would be reduced to a less-
than-significant level.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
impact on riparian habitats or other sensitive natural communities.
c. The General Plan would facilitate infill development and redevelopment within existing
urbanized areas of the Town and, therefore, is unlikely to contain jurisdictional wetlands.
However, Section 4.4, Biological Resources, of the General Plan EIR explains that it is
possible that the infill development facilitated by the General Plan would increase density
in some areas, which could require upgraded utilities or stormwater drainage in areas of
jurisdictional wetlands and streams, the construction of which could cause adverse,
environmental impacts
Detailed wetland delineations would be needed to determine the extent of any
jurisdictional wetlands and other waters at specific locations and the U.S. Army Corps of
Engineers is responsible for making a final determination for a particular site.
Compliance with the requirements of the Clean Water Act would be required for any
project proposed under the General Plan as well as compliance with the goals and
policies from the Environment and Sustainability Element and the Open Space, Parks,
and Recreation Element of the General Plan; specifically General Plan Policy ENV-6.1,
which would prevent development within wetlands. Implementation and compliance
with state and federal regulations and the General Plan’s goals and policies promoting
restoration of wetland and riparian habitat, impacts from development under the General
Plan on wetlands would be less than significant (Town of Los Gatos 2021, p. 4.4-17).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR; therefore, the Housing Element Update
would not propose residences on land with jurisdictional wetlands. The Housing
Element Update would be required to comply with the requirements of the Clean Water
Act and implement all applicable General Plan policies whose purpose is to protect
wetlands within the Town (e.g., the policies associated with General Plan Goals ENV-6
and ENV-16). Compliance with state and federal regulations and implementation of
applicable General Plan goals and policies would ensure that the Housing Element
Update’s potential impact on wetlands would be less than significant.
Section C Evaluation of Environmental Impacts 27 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts on wetlands.
d. The General Plan promotes redevelopment and infill development, which would occur in
the developed portions of the Town. The developed areas of Los Gatos would not
provide for wildlife movement corridors because the areas are developed with buildings
and roads. Wildlife movements in the Town are generally limited to the hillside areas to
the south and east, and the creeks, such as the Los Gatos Creek. However, Section 4.4,
Biological Resources, of the General Plan EIR states that infill development under the
General Plan could require construction of upgraded utilities and infrastructure that are
near stream corridors (such as stormwater outfalls that are typically near riparian areas
adjacent to creeks), which may result in significant environmental effects.
Development under the General Plan would be required to implement applicable General
Plan goals and policies that would encourage wildlife movements and migration, such as
Policy ENV-7.3, which directs the Town to maintain wildlife habitat and movement
corridors for native wildlife species. Because the General Plan would not facilitate
development in open space areas, including stream corridors, and contains policies to
reduce impacts to stream corridors and protect wildlife movement corridors, the General
Plan EIR concluded that impacts would be less than significant (Town of Los Gatos
2021, p. 4.4-20).
Some of the sites associated with the Housing Element Update (within the Winchester
Boulevard Area and Lark Avenue Area) are located adjacent to the Los Gatos Creek.
However, development at these sites, among the others associated with the Housing
Element Update, would be required to implement General Plan Policy ENV-6.1,
requiring that developments do not damage riparian areas, wetlands, and intermittent or
ethereal [sic] streams; Policy ENV-6.2, which requires that creek beds, riparian corridors,
water courses, and associated vegetation are retained in their natural state; and Policy
ENV-6.3, which requires that setbacks and measures are implemented to protect riparian
corridors.
Consistent with the General Plan, the Housing Element Update would not facilitate
development in open space areas, including stream corridors, and would implement all
applicable General Plan policies to reduce impacts to stream corridors and protect
wildlife movement corridors and open space. The sites associated with the Housing
Element Update are not likely to facilitate major wildlife movement due to current active
disturbance. As such, the Housing Element Update would have a less than significant
impact on wildlife movement.
The General Plan EIR adequately addresses the Housing Element Update’s potential to
interfere with the movement of migratory species.
e. Development under the General Plan could remove trees or substantially prune trees for
construction. As discussed in the General Plan EIR (Section 4.4, Biological Resources),
Section C Evaluation of Environmental Impacts 28 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
development would be subject to all applicable local policies and regulations related to
the protection of important biological resources such as the Town Municipal Code
Chapter 29, Division 2 – Tree Protection. In addition to the Town Municipal Code,
development under the General Plan would be required to comply with the policies
associated with General Plan Goal ENV-2, such as Policy ENV-2.1, which requires that
tree removal and replacement during development is consistent with the latest in tree
conservation standards. Adherence to the tree protection requirements in the Town
Municipal Code and implementation of the applicable General Plan policies would ensure
that development under the General Plan would result in less than significant impacts
related to local policies or ordinances protecting biological resources, such as a tree
preservation policy or ordinance (Town of Los Gatos 2021, p. 4.4-21).
Most of the sites associated with the Housing Element Update contain trees and
development may result in their removal or substantial pruning. However, the Housing
Element Update would be required to comply with the Town Municipal Code’s Tree
Protection standards for the preservation, protection, and maintenance of protected trees,
including Section 29.10.1000 of the Town Municipal Code, which requires that a tree
preservation report be prepared prior to construction on parcels with protected trees.
The Housing Element Update would also comply with all applicable General Plan
policies related to the protection of biological resources. Compliance with the Town
Municipal Code’s Tree Protection standards and applicable General Plan policies would
ensure that development associated with the Housing Element Update would not conflict
with any local policies or ordinances protecting biological resources, such as a tree
preservation policy or ordinance.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
conflict with local policies or ordinances protecting biological resources, such as a tree
preservation policy or ordinance.
f. The Final Santa Clara Valley Habitat Plan (habitat plan) (Santa Clara Valley Habitat Agency
2012) covers approximately 62 percent of Santa Clara County and only a small portion of
this total involves the Town of Los Gatos. The Vasona Lake County Park and the
riparian area on either side of Los Gatos Creek make up the portions of Los Gatos that
are under the habitat plan’s coverage. The General Plan maintains a designation of Open
Space for these areas and would not conflict with the habitat plan. There are no other
adopted Habitat Conservation Plans or Natural Community Conservation Plans
applicable to the planning area and, therefore, the General Plan EIR concluded that the
General Plan would have no impact (Section 4.4, Biological Resources, p. 4.4-21).
Some of the sites associated with the Housing Element Update (the Winchester
Boulevard Area and Lark Avenue Area) are adjacent to the Los Gatos Creek, which is
within the habitat plan’s coverage area. Some portions of these sites are also themselves
located within coverage of the habitat plan (Santa Clara Valley Habitat Agency 2022).
Therefore, pursuant to the provisions of the habitat plan, development within these areas
Section C Evaluation of Environmental Impacts 29 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
would be required to prepare and submit a habitat plan screening form. Development
may also be required to apply for an exemption.
Because the Housing Element Update is consistent with the growth projections evaluated
in the General Plan EIR, development at the Winchester Boulevard Area and Lark
Avenue Area would prepare and submit habitat screening forms reducing its potential to
result in conflict with the provisions of the habitat plan to a less-than-significant level.
The General Plan EIR adequately addresses the Housing Element Update’s potential to
conflict with the provisions of the habitat plan.
Section C Evaluation of Environmental Impacts 30 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
5. CULTURAL RESOURCES
Would the project:
Comments:
a, b. According to the General Plan EIR (Section 4.5, Cultural and Tribal Cultural Resources),
effects on cultural resources are only knowable once a specific project has been proposed
because the effects are dependent on the individual project site conditions, project
activities that may alter the character of an environment’s resources, and/or the
characteristics of the proposed ground-disturbing activity (p. 4.5-10). Ground-disturbing
activities associated with development under the General Plan have the potential to
damage or destroy previously unknown historic or prehistoric archaeological resources
that may be present on or below the ground surface. In addition to compliance with
applicable General Plan policies, development consistent with the General Plan would be
required to complete a Phase I Cultural Resources Inventory of the site, as discussed
under Mitigation Measure CR-1 below (Town of Los Gatos 2021, p. 4.5-12).
None of the sites associated with the Housing Element Update are located within the
Town’s Historic Districts (Town of Los Gatos 2022d); however, because development at
each of the individual sites has not yet been proposed, construction activities could occur
in areas that have not been previously developed with urban uses, have not been studied
through a cultural resources investigation, or the excavation activities could reach depths
that exceed those previously attained. Therefore, in order to ensure that development
within the Town does not have detrimental effects on cultural resources, each individual
project would need to be assessed as it is proposed.
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, would be required to
comply with General Plan Policy ENV-12.1, which requires that archaeological and/or
cultural resources are evaluated early in the development review process through
consultation and use of contemporary professional techniques and Policy ENV-12.5,
requiring that if cultural resource, including archaeological or paleontological resources,
are uncovered during ground-disturbing activities, construction will stop until appropriate
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a.Cause a substantial adverse change in the significance
of a historical resource pursuant to section 15064.5?
☐ ☒ ☐ ☐
b.Cause a substantial adverse change in the significance
of an archaeological resource pursuant to section
15064.5?
☐ ☒ ☐ ☐
c. Disturb any human remains, including those interred
outside of dedicated cemeteries?☐ ☐ ☒ ☐
Section C Evaluation of Environmental Impacts 31 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
mitigation is implemented. In addition to compliance with General Plan policies, the
Housing Element Update would be required to implement Mitigation Measure CR-1 in
order to reduce impacts to a less-than-significant level.
Mitigation Measure
CR-1 If a project requires activities that have the potential to impact cultural resources,
the Town shall require the project applicant or proponent to retain a qualified
archaeologist meeting the Secretary of the Interior’s (SOI) Professional
Qualification Standards (PQS) in archaeology and/or an architectural historian
meeting the SOI PQS standards in architectural history to complete a Phase 1
cultural resources inventory of the project site (NPS 1983). A Phase 1 cultural
resources inventory shall include a pedestrian survey of the project site and
sufficient background archival research and field sampling to determine whether
subsurface prehistoric or historic remains may be present. Archival research shall
include a records search conducted at the Northwest Information Center (NWIC)
and a Sacred Lands File (SLF) search conducted with the Native American
Heritage Commission (NAHC). The technical report documenting the Phase 1
cultural resources inventory shall include recommendations to avoid or reduce
impacts to cultural resources. These recommendations shall be implemented and
incorporated in the project.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts on historic and archaeological resources.
c. As discussed in the General Plan EIR (Section 4.5, Cultural and Tribal Cultural
Resources), the potential to discover human burials within the Town exists even though
much of the Town is built out. Excavation during construction activities would have the
potential to disturb these resources. Therefore, development associated with the Housing
Element Update, which is consistent with the growth projections evaluated in the
General Plan EIR, has the potential to disturb these unknown Native American burials.
The General Plan EIR determined that development under the General Plan (inclusive of
the Housing Element Update) would be required to comply with existing regulations
relating to the treatment of human remains in General Plan Goal ENV-12: Protect the
Town’s archaeological and cultural resources to maintain and enhance a unique sense of
place.
Development associated with the Housing Element Update would also be required to
comply with General Plan Policy 12.4, which states that any human remains discovered
during implementation of public or private projects within the Town shall be treated with
respect and dignity, and Policy ENV-12.6, which encourages development to avoid
impacts to burial sites by designing or clustering development to avoid archaeological
deposits that may contain human remains.
Section C Evaluation of Environmental Impacts 32 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
As concluded in the General Plan EIR, implementation of these General Plan policies
would help ensure that development carried out under the General Plan (including the
Housing Element Update) would have a less than significant impact from potential
disturbance of human remains, including those interred outside of formal cemeteries
(p. 4.5-13).
The General Plan EIR adequately addressed the Housing Element Update’s potential to
disturb human remains, including those interred outside of formal cemeteries.
Section C Evaluation of Environmental Impacts 33 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
6. ENERGY
Would the project:
Comments:
a.Construction Energy Demand. The General Plan EIR (Section 4.6, Energy) discusses
the energy use during construction activities associated with implementation of the
General Plan. It notes that construction would be temporary in nature and the
construction equipment used would be typical of similar-sized construction projects in
the region. Construction contractors would be required to comply with the provisions of
the California Code of Regulations Title 13 Sections 2449 and 2485, which prohibit
diesel-fueled commercial motor vehicles and off-road diesel vehicles from idling for more
than five minutes and would minimize unnecessary fuel consumption. Development
under the General Plan would also be required to comply with construction waste
management practices to divert a minimum of 65 percent of construction debris,
pursuant to the applicable regulatory requirements found in the California Green Building
Standards Code. Compliance with these practices would result in efficient use of energy
necessary to construct development under the General Plan. Therefore, the General Plan
EIR concluded that the General Plan would not involve the inefficient, wasteful, and
unnecessary use of energy during construction, and construction impacts related to
energy consumption would be less than significant (p. 4.6-14).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, developers would be
required to comply with the provisions of the California Code of Regulations Title 13
Sections 2449 and 2485 and the applicable regulatory requirements related to diversion of
construction debris associated with the California Green Building Standards Code in
order reduce unnecessary fuel consumption. The Housing Element Update would result
in the development of residential uses. The Housing Element Update’s energy demand
would not be excessive relative to total Santa Clara County-wide demand or relative to
other land use projects and would not inherently be a source of wasteful energy demand.
Development associated with the Housing Element Update would consume energy, but it
would not be inefficient, wasteful, or unnecessary. Therefore, the impact would be less
than significant.
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a.Result in a potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
☐ ☐ ☒ ☐
b.Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
☐ ☐ ☐ ☒
Section C Evaluation of Environmental Impacts 34 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Operational Energy Demand. Transportation Fuel Consumption - As discussed in the
General Plan EIR (Section 4.6, Energy), operation of the development under the General
Plan would contribute to regional energy demand by consuming electricity, natural gas,
and gasoline and diesel fuels. The General Plan EIR states that fuel consumption is
closely associated with vehicle miles traveled (VMT); the more miles a vehicle travels, the
more fuel that is required and consumed by that vehicle. However, the General Plan EIR
discusses how the VMT generated by the General Plan would not increase boundary
VMT per capita (the VMT within a specific geographic region) in Santa Clara County
and, therefore, the effects from VMT would be localized and not have regional impacts.
This is related to energy because it suggests that fuel consumption resulting from the
General Plan would be consistent with regional trends and would not be wasteful or
inefficient. In addition, this encourages high-density and mixed-use infill developments
with project design that support multi-modal transportation, which improve energy
efficiency because it places residents closer to places of employment. These factors
would help minimize the potential for the General Plan to result in the wasteful,
inefficient, or unnecessary consumption of vehicle fuels.
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, its VMT generation would
not increase boundary VMT per capita in Santa Clara County suggesting that its fuel
consumption, like the General Plan’s consumption, would be consistent with regional
trends and would not be wasteful or inefficient. Implementation of the Housing Element
Update would also involve high-density and mixed-use infill developments thereby
improving energy efficiency.
Natural Gas and Electricity - Development under the General Plan would consume natural
gas and electricity for building heating and power, lighting, and water conveyance, among
other operational requirements. Implementation of the policies associated with General
Plan Goal PFS-6, encouraging development that reduces the use of non-renewable energy
resources and expands the use of renewable resources and alternative fuels, and those
associated with General Plan Goal PFS-7, which promotes green buildings that minimizes
consumption of energy and natural resources, would offset some of the overall energy
demand facilitated by buildout under the General Plan. In addition, developments under
the General Plan would be subject to the energy conservation requirements of the
California Energy Code and the California Green Building Standards Code. In 2018, the
California Building Standards Commission began to require that solar photovoltaic panels
be installed on new low-rise residential buildings (i.e., single-family homes and multi-
family buildings of three stories or less). Because this requirement would involve
applicable new residential development under the General Plan, the operational energy
demand would be supplemented with renewable energy sources to a greater degree.
Therefore, residential development facilitated by the General Plan would, in general, be
less dependent on fossil fuels than previous development.
In addition, the General Plan EIR indicated that a greater proportion of electricity
supplied for operational power needs in Los Gatos through 2040 would be sourced from
Section C Evaluation of Environmental Impacts 35 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
renewables. Renewable energy sources generally result in reduced long-term
environmental impacts compared to non-renewables because renewable sources do not
require combustion of coal or natural gas to generate electricity, which avoids
environmental impacts associated with air pollution and greenhouse gas emissions.
The General Plan EIR concluded that development under the General Plan would not
result in potentially significant environmental effects from wasteful, inefficient, or
unnecessary consumption of energy and this impact would be less than significant
(p. 4.6-14).
Development associated with the Housing Element Update would be required to comply
with the above-mentioned goals and policies located with the Public Facilities, Services,
and Infrastructure Element of the General Plan in order to reduce energy consumption
by development. The Housing Element Update would also be subject to the energy
conservation requirements of the California Energy Code and the California Green
Building Standards Code, which would help offset some of the overall energy demand by
the Housing Element Update. Development associated with the Housing Element
Update would involve new single-family and multi-family structures three stories or less
(i.e., low-rise residential buildings) and, therefore, would be required to install solar
photovoltaic panels pursuant to the adopted 2018 modifications to Title 24 of the
California Energy Code. Therefore, residential development facilitated by the Housing
Element Update, which is consistent with the growth projections evaluated in the
General Plan EIR, would be less dependent on fossil fuels than existing development.
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, would result in less than
significant environmental impacts due to wasteful, inefficient, or unnecessary
consumption of energy resources, during construction or operation. The General Plan
EIR adequately addressed the Housing Element Update’s potential impacts related to
energy demand during construction and operation.
b. Section 4.6, Energy, of the General Plan EIR discussed the General Plan’s consistency
with state plans (California Green Building Standards Code and Title 24 of the California
Energy Code) and a local plan (Los Gatos Sustainability Plan) for renewable energy or
energy efficiency.
State. Any newly constructed buildings under the General Plan would be required to
comply with all building design standards set in the California Building Code’s Title 24
(the California Green Building Standards Code is Part 11 of Title 24). Title 24 requires
the implementation of energy efficient light fixtures and building materials into the design
of new construction projects. The standards identified in Title 24 are updated every three
years and each iteration is more energy efficient than the previous standards.
Development under the General Plan would also be required to comply with Senate Bill
100, which mandates 100 percent clean electricity for California by 2045. Impacts related
to consistency of the General Plan with applicable state plans for increased energy
efficiency and renewable energy use would be less than significant (p. 4.6-15).
Section C Evaluation of Environmental Impacts 36 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, would also be required to
comply with all applicable building design standards identified above and within Title 24.
Compliance with these standards would allow development under the Housing Element
Update to result in more efficient consumption of energy through design features such as
efficient light fixtures and building materials. Additionally, because development
associated with the Housing Element Update would be powered by the existing electricity
grid, it would be powered by renewable energy mandated by Senate Bill 100. The
Housing Element Update, therefore, would not conflict with or obstruct a state plan for
renewable energy or energy efficiency.
Local. The Los Gatos Sustainability Plan was adopted as a long-term strategy to reduce
greenhouse gas emissions in the Town and further implement sustainability measures
from the previous general plan. The document focuses on five sectors, providing specific
measures to reduce greenhouse gas emissions from each sector in order to achieve the
Town’s reduction target of reducing greenhouse gas emissions 15 percent below baseline
emissions (2008 or earlier) by 2020. The sectors covered in this plan are Transportation
and Land Use, Energy, Water, Solid Waste, and Open Space.
The General Plan EIR evaluates the General Plan’s consistency against the Los Gatos
Sustainability Plan in Table 4.6-5, and concludes that the General Plan would be consistent
with the plan and the energy efficiency strategies contained therein. Impacts related to
consistency of the General Plan with applicable local plans for increased energy efficiency
and renewable energy use would be less than significant (p. 4.6-21).
Development associated with the Housing Element Update would be consistent with the
growth projections evaluated in the General Plan EIR and, therefore, would implement
those applicable General Plan goals and policies identified in the consistency analysis
(Table 4.6-5 of the General Plan EIR) in order to comply with the sustainability measures
of the Los Gatos Sustainability Plan. For these reasons, the Housing Element Update
would not conflict with applicable local plans for increased energy efficiency and
renewable energy use.
The General Plan EIR adequately addresses the Housing Element Update’s potential to
conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
Section C Evaluation of Environmental Impacts 37 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
7. GEOLOGY AND SOILS
Would the project:
Comments:
a. Earthquake Rupture. No known fault crosses any one of the sites associated with the
Housing Element Update and the sites are not located in an Alquist-Priolo Earthquake
Zone; the nearest Alquist-Priolo Earthquake Zone is approximately three miles southwest
of the southernmost site associated with the Housing Element Update (California
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a. Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or
death involving:
(1) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other
substantial evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42?
☐ ☐ ☐ ☒
(2) Strong seismic ground shaking? ☐ ☐ ☒ ☐
(3) Seismic-related ground failure, including
liquefaction? ☐ ☐ ☒ ☐
(4) Landslides? ☐ ☐ ☐ ☒
b. Result in substantial soil erosion or the loss of topsoil? ☐ ☐ ☒ ☐
c. Be located on a geologic unit or soil that is unstable,
or that would become unstable as a result of the
project, and potentially result in on- or off-site
landslide, lateral spreading, subsidence, liquefaction, or
collapse?
☐ ☐ ☒ ☐
d. Be located on expansive soil, creating substantial
direct or indirect risks to life or property? ☐ ☐ ☒ ☐
e. Have soils incapable of adequately supporting the use
of septic tanks or alternative wastewater disposal
systems where sewers are not available for the disposal
of wastewater?
☐ ☐ ☐ ☒
f. Directly or indirectly destroy a unique paleontological
resource or site or unique geologic feature? ☐ ☒ ☐ ☐
Section C Evaluation of Environmental Impacts 38 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Department of Conservation 2022). Further, Section 4.7, Geology and Soils, of the
General Plan EIR states that fault rupture is unlikely to affect new or existing structures
in the Town because the only Alquist-Priolo Earthquake Zone is located west of the
Town’s western limits (p. 4.7-19). Therefore, development associated with the Housing
Element Update would also not exacerbate impacts related to earthquake rupture for
faults in an Alquist-Priolo Earthquake Zone.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
directly or indirectly cause potential substantial adverse effects, including the risk of loss,
injury, or death involving rupture of a known earthquake fault.
Seismic Ground-Shaking. The Town is located in an active seismic region with three
faults running through it (Blossom Hill Fault, Shannon Fault, and Berrocal Fault), which
would subject the Town to very strong ground shaking. According to the General Plan
EIR (Section 4.7, Geology and Soils), ground shaking risk would be primarily in the
northern portion of the Town.
Development under the General Plan would result in additional residential and
nonresidential development within the Town, which would potentially expose people and
structures to the effects of seismic ground shaking events. However, the Housing
Element Update is consistent with the growth projections evaluated in the General Plan
EIR and would involve infill development, which would in many cases replace older
structures subject to seismic damage with newer structures built to current seismic
standards that could better withstand the adverse effects of strong ground shaking (p. 4.7-
19). Potential structural damage and the exposure of people to the risk of injury or death
from structural failure would be minimized by compliance with the California Building
Code engineering design and construction measures. Foundations and other structural
support features for development consistent with the General Plan would be designed to
resist or absorb damaging forces from strong ground shaking.
The Housing Element Update would be required to comply with General Plan Policy
HAZ-4.1, which requires new development to be sited away from high risk geologic and
seismic hazard zones or, if located in a high-risk zone, incorporate construction
techniques to reduce risk; Policy HAZ-4.2, which requires a geotechnical report to be
prepared for new development proposed in hazard zones mapped by the state or the
Town; Policies HAZ-4.3 and HAZ-4.4, which both require, respectively, that a
geotechnical report is prepared for development with significant grading, potential
erosion, and sedimentation hazards and for developments proposed in areas with
identified geologic hazards; and Policy HAZ-4.8, which requires that a licensed
geologic/geotechnical engineer complete the Town Geologic Hazards Checklist to
demonstrate that potential hazards have been identified and that proposed structures will
be designed to resist potential earthquake effects (Town of Los Gatos June 2022a). The
General Plan EIR concludes that implementation of the mandatory California Building
Code requirements and the General Plan’s goals and policies would reduce the potential
for loss, injury, or death following a seismic event to a less-than-significant level.
Section C Evaluation of Environmental Impacts 39 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
The housing sites associated with the Housing Element Update are located in areas of
medium to high ground-shaking intensity, according to the General Plan EIR’s Figure
4.7-4. However, development associated with the Housing Element Update is consistent
with the growth projections evaluated in the General Plan EIR and would not exacerbate
seismic hazards associated with seismic ground shaking. The Housing Element Update
would be required to implement the requirements of the California Building Code and
applicable General Plan policies to ensure that impacts related to seismic ground-shaking
are less than significant.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
directly or indirectly cause potential substantial adverse effects, including the risk of loss,
injury, or death involving seismic ground-shaking.
Liquefaction. According to the California Department of Conservation’s mapping, the
Town includes areas susceptible to liquefaction located generally in the center of the
Town and along State Route 17 (California Department of Conservation 2022). Most, if
not all, of the sites associated with the Housing Element Update are in areas of
liquefaction susceptibility. According to the General Plan EIR (Section 4.7, Geology and
Soils), foundations and other structural support features for development under the
General Plan, including the Housing Element Update, would be designed to resist or
absorb damaging forces from liquefaction (p. 4.7-20). The Housing Element Update
would be required to comply with General Plan policies identified under the discussion
for Seismic Ground-Shaking, above.
Implementation of General Plan policies, in addition to compliance with applicable laws
and regulations, would minimize the potential for loss, injury, or death following a
seismic event and would reduce impacts to a less-than-significant level (Town of Los
Gatos 2021, p. 4.7-21). Development associated with the Housing Element Update is
consistent with the growth projections evaluated in the General Plan EIR and would
comply with the General Plan policies listed above and applicable laws and regulations of
the California Building Code to ensure impacts are reduced to a less-than-significant level.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
directly or indirectly cause potential substantial adverse effects, including the risk of loss,
injury, or death involving liquefaction.
Landslides. According to the California Department of Conservation’s mapping, the
Town has areas susceptible to landslides throughout much of the southern and eastern
portions of the Town and extending as far north as Blossom Hill Road (California
Department of Conservation 2022). Outside of the hillside areas of the Town, there is
potential for landslides and slope instability along the steep banks of drainages, and steep
graded slopes associated with excavations. However, according to Section 4.7, Geology
and Soils, of the General Plan EIR, landslide potential is minimal in the gently sloping
west central and northernmost portions of the Town (Town of Los Gatos 2021,
Section C Evaluation of Environmental Impacts 40 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
p. 4.7-19). None of the sites associated with the Housing Element Update are located
within these landslide hazard zones and, therefore, development of these sites would not
exacerbate landslide hazards through grading or other site modification activities that
reduce slope stability.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
directly or indirectly cause potential substantial adverse effects, including the risk of loss,
injury, or death involving landslides.
b. Wind and water are the main forces that cause soil erosion. Depending on how well
exposed soil surfaces are protected from these forces, the erosion process can be very
slow or rapid. Removal of natural or manufactured protection can result in substantial
soil erosion and excessive sedimentation. Construction activities that would occur on
individual sites associated with the Housing Element Update represent the greatest
potential cause of erosion.
According to the General Plan EIR (Section 4.7, Geology and Soils), new development
under the General Plan would involve construction activities that may result in loose or
disturbed soils in the Town, which can increase the potential for erosion and loss of
topsoil.
Construction activities that disturb one or more acres of soil and, therefore, would be
subject to the National Pollutant Discharge Elimination System General Permit for
Storm Water Discharges Associated with Construction and Land Disturbance Activities
adopted by the State Water Resources Control Board under the Clean Water Act. The
Town’s Municipal Code Chapter 22, Article III enforces compliance with the
Construction General Permit. Development of any site that disturbs more than one acre
of soil will also be required to file a Notice of Intent with the State Water Resources
Control Board and prepare a Storm Water Pollution Prevention Plan describing erosion
and sediment control best management practices. Chapter 12 of the Town’s Municipal
Code also provides regulatory standards to ensure grading, erosion, and sediment
associated with development are minimized.
Many of the sites associated with the Housing Element Update would involve
construction activities that disturb one or more acres of soil and, therefore, would be
subject to the General Permit and be required to prepare a Storm Water Pollution
Prevention Plan. Compliance is also required with the Town’s Municipal Code Chapter
12 that provides regulatory standards to ensure grading, erosion, and sediment associated
with development are minimized. Development under the General Plan would be
required to implement applicable General Plan policies and goals that would ensure that
construction projects minimize their potential impacts related to erosion. Compliance
with applicable laws and regulation, as well as implementation of applicable General Plan
policies, would reduce impacts to a less-than-significant level (Town of Los Gatos 2021,
p. 4.7-23).
Section C Evaluation of Environmental Impacts 41 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
According to the General Plan EIR, potential for erosion in Los Gatos is highest in the
eastern, southern, and southwestern areas of the Town, with its potential decreasing
toward the center of the Town and minimal in the flat areas just east of State Route 17.
The sites associated with the Housing Element Update are centrally located in the Town,
along and east of State Route 17, with a few sites in the southwestern and northern ends
of the Town. Therefore, there is potential for development associated with the Housing
Element Update to result in soil erosion or loss of topsoil.
Development associated with the Housing Element Update would be required to comply
with General Plan Policy ENV-15.1, which requires all new developments in areas subject
to soil erosion to prepare erosion control plans to minimize soil erosion; Policy ENV-
15.2, which requires that grading permits be issued to ensure that the grading of slopes
and sites proposed for development will be minimized; and Policy ENV-16.9, which
requires that pollution in urban runoff be reduced from residential land use activities and
other land uses.
Adherence to the state’s stormwater discharge permitting requirements, in addition to the
above-mentioned General Plan policies, would ensure that potential impacts associated
with soil erosion and loss of topsoil would be less than significant.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts associated with soil erosion and the loss of topsoil.
c. According to the General Plan EIR (Section 4.7, Geology and Soils), development under
the General Plan would result in additional residential and nonresidential development
within the Town that would be potentially exposed to the effects of unstable soils.
However, potential structural damage and the exposure of people to the risks from
unstable soils from structural failure would be minimized by compliance with the
California Building Code engineering design and construction measures. Foundations
and other structural support features would be designed to resist or absorb damaging
forces from strong ground shaking and liquefaction. In addition to compliance with
mandatory California Building Code requirements, implementation of applicable General
Plan goals and policies, such as those listed previously in this section, would reduce the
potential for development under the General Plan to exacerbate unstable soil conditions
and ensure impacts are less than significant (p. 4.7-20 to 4.7-21).
Structures constructed on soils which are prone to liquefaction are subject to damage and
possible collapse as a result of settlement and lateral spreading due to liquefaction (Town
of Los Gatos 2021, p. 4.7-13). As discussed previously, most of the housing sites
associated with the Housing Element Update are located on land that is susceptible to
liquefaction. Development on the sites associated with the Housing Element Update
could also result in soil erosion or loss of topsoil.
Construction activities on the individual housing sites associated with the Housing
Element Update could risk exacerbating unstable soil conditions during grading and/or
other site development/excavation activities. Developers are required to comply with the
Section C Evaluation of Environmental Impacts 42 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
General Plan policies identified in checklist questions “a” and “b” as well as the
applicable requirements of the California Building Code. A detailed review of design and
construction plans and incorporation of additional structural safety features would be
required on a project-by-project basis, as necessary, for structures that would be located
in areas subject to soil that is unstable, or that would become unstable as a result of the
Housing Element Update.
Implementation of the applicable General Plan policies and the California Building Code
would reduce the adverse effects of unstable geologic units and reduce the potential to
exacerbate soil instability hazards to a less-than-significant level.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts associated with unstable soils.
d. According to the General Plan EIR (Section 4.7, Geology and Soils), the clay minerals in
the Town’s clay and clay loam soils are prone to expansion and have moderate to high
shrink-swell potential (p. 4.7-23). The California Building Code includes requirements to
address soil-related hazards such as the removal, proper fill selection, and compaction of
soil. In cases where soil remediation is not feasible, the California Building Code requires
structural reinforcement of foundations to resist the forces of expansive soils. According
to the General Plan EIR, compliance with the requirements of the California Building
Code would reduce impacts related to expansive soils to a less-than-significant level (p.
4.7-23).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and would be required to comply with the
applicable requirements of the California Building Code. Therefore, impacts related to
expansive soils on the individual sites associated with the Housing Element Update
would be less than significant.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts associated with expansive soils.
e. Development under the General Plan encourages infill development and redevelopment
within the Town of Los Gatos limits and would minimize encroachment into open space
areas where wastewater infrastructure does not currently exist. Therefore, Section 4.7,
Geology and Soils, of the General Plan EIR concludes that the General Plan would result
in less than significant impacts related to soils that are incapable of supporting septic
tanks or alternative wastewater disposal systems (p. 4.7-24).
All proposed sites associated with the Housing Element Update would connect into the
Town’s existing sanitary sewer system and, therefore, no impacts associated with soils
supporting the use of septic tanks would occur.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
have soils onsite that are incapable of adequately supporting the use of septic tanks.
Section C Evaluation of Environmental Impacts 43 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
f. According to the General Plan EIR (Section 4.7, Geology and Soils), the geologic units
exposed at ground surface in the Town and the vicinity include Mesozoic rocks of the
Franciscan Assemblage, the Miocene Temblor Sandstone, the Miocene Monterey
Formation, the Pliocene-Pleistocene Santa Clara Formation, and Quaternary Alluvium.
The Miocene to Pleistocene sedimentary deposits in the Town have a high potential to
yield paleontological resources (Town of Los Gatos 2021, p. 4.7-24). Therefore,
paleontological resources may be encountered during any ground-disturbing activities
associated with implementation of the General Plan. Directly or indirectly destroying a
unique paleontological site is considered a significant environmental impact and,
therefore, the General Plan would be required to comply with General Plan Policy
ENV-12.5, requiring that if cultural resources, including paleontological resources, are
uncovered during grading or other onsite excavation activities, construction shall stop
until appropriate mitigation is implemented. Additionally, implementation of the
following mitigation measure would ensure this potential impact would be less than
significant (p. 4.7-25).
Mitigation Measure
GEO-1 The Town shall require paleontological resource studies for projects that
involve ground disturbance in project areas mapped as high
paleontological sensitivity at the surface or subsurface determined through
environmental review. Additionally, in the event that a paleontological
resource is disclosed, construction activities in the area shall be
suspended, a qualified paleontologist shall be retained to examine the site,
and protective measures shall be implemented to protect the
paleontological resource.
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and may encounter unknown
paleontological resources during construction activities. The Housing Element Update
would be required to implement Mitigation Measure GEO-1 in order to ensure impacts
would be less than significant.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts associated with paleontological resources.
Section C Evaluation of Environmental Impacts 44 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
8. GREENHOUSE GAS EMISSIONS
Would the project:
Comments:
a. According to the General Plan EIR (Section 4.8, Greenhouse Gas Emissions),
development facilitated by the General Plan would involve activities, such as construction
demolition and grading, that would result in greenhouse gas (GHG) emissions. The Bay
Area Air Quality Management District does not have plan-level significance thresholds
for construction GHG emissions that would apply to the General Plan. Therefore, the
General Plan EIR determined that no significance conclusion would be made with regard
to General Plan programmatic construction-related GHG emissions alone; rather
operational and total (construction plus operational) programmatic GHG emissions are
assessed with regard to significance level (Town of Los Gatos 2021, p. 4.8-25).
Los Gatos GHG emissions are based on the Los Gatos communitywide 2008 emissions
inventory and communitywide GHG emissions anticipated related to ongoing activities
within the community and buildout of the General Plan. Projected GHG emissions for
2030, 2040, and 2045 include implementation of the General Plan as well as several state
and local GHG reduction actions that are assumed to be implemented (p. 4.8-25). The
General Plan EIR determined that the GHG emissions generated by the General Plan
would exceed the 2030 efficiency threshold of 3.31 metric tons of carbon dioxide
equivalents (CO2e) per service person per year as well as exceed the 2040 efficiency
threshold of 1.02 metric tons of CO2e per service person per year.
The General Plan EIR explains that while various goals, policies, and implementation
programs contained in the General Plan would implementation some GHG emission
reduction strategies related to energy use and vehicle miles traveled reduction,
development under the General Plan would not achieve GHG reductions to reach less
than significant levels (represented by equal to or less than 3.31 per capita metric tons
CO2e per service person per year and by 2030 and 1.02 per capita metric tons CO2e per
service person per year by 2040). The General Plan EIR indicates that the exceedance is
primarily due to on-road vehicle miles traveled, which accounts for approximately 81
percent of the total emissions, and the main barrier to reducing vehicle miles traveled is
the lack of public transit options in the Town.
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a.Generate greenhouse gas emissions, either directly or
indirectly, that may have a significant impact on the
environment?
☒ ☐ ☐ ☐
b.Conflict with an applicable plan, policy or regulation
adopted for the purpose of reducing the emissions of
greenhouse gases?
☒ ☐ ☐ ☐
Section C Evaluation of Environmental Impacts 45 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
As discussed in Section 17.0, Transportation, the greatest reduction in vehicle miles
traveled would be from the regional level reduction strategies outlined in Mitigation
Measure T-1, which is explained as not possible since the Town cannot guarantee that
other agencies and municipalities would participate in the regional strategies. Because of
these limitations, development under the General Plan would be required to implement
Mitigation Measure GHG-1.
Mitigation Measure
GHG-1 Los Gatos shall implement the following GHG emissions reduction
measures by sector:
Energy (EN)
Measure EN1: Adopt an ordinance requiring new commercial
construction to be all electric or otherwise operationally carbon
neutral by 2025: Adopt a new building ordinance which bans the
installation of natural gas in new commercial construction by 2025
and requires new commercial buildings to install all-electric equipment
or otherwise be operationally carbon neutral. Support this action by
conducting outreach and education to local developers about the
benefits and resources associated with building carbon neutral
buildings.
Measure EN2: Identify and partner with stakeholders to conduct
electrification outreach, promotion, and education: Leverage
partnerships with stakeholders to conduct outreach, promotion, and
education around new and existing building electrification.
Measure EN3: Develop a Community wide Existing Residential
Building Electrification Plan (EBEP): Support community-wide
existing building electrification through the development of an EBEP
that addresses the feasibility, timeline, equity concerns, local
stakeholder involvement, costs, funding pathways, and
implementation for electrifying existing residential buildings in Los
Gatos.
Measure EN4: Electrify existing residential buildings beginning in
2023: Adopt an electrification ordinance for existing residential
buildings to transition natural gas to electric in two phases, to be
implemented through the building permit process:
Phase I: Limit expansion of natural gas lines in existing buildings
by 2023.
Phase II: Require HVAC system replacements and hot water
heaters replacements to be all-electric by 2023.
Section C Evaluation of Environmental Impacts 46 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Measure EN5: Identify and partner with stakeholders to develop
resident-level funding pathways for implementing electrification
ordinance: Leverage partnerships with stakeholders and establish
funding pathways to ease community members’ costs when complying
with the electrification ordinance, including:
Pass a transfer tax ordinance and provide a rebate for electric
panels and/or other upgrades.
Partner with PG&E, SVCE, and/or other stakeholders to create
or expand electrification/retrofit programs and incentives,
especially for low-income residents. These could include the
PACE program, PG&E’s low-income weatherization. program,
tariffed on-bill financing, metered energy efficiency, or others.
Measure EN6: Decarbonize municipal buildings by 2040: Adopt a
municipal building energy decarbonization plan to decarbonize
municipal building energy operations by 2040. This plan would
include a new building electrification policy as well as an existing
building natural gas phase-out policy.
Measure EN7: Coordinate with stakeholders to provide local energy
generation support and incentives for the community: Partner with
PG&E, SVCE, and/or other stakeholders to support and incentivize
local on-site energy generation and storage resources within the
community.
Measure EN8: Develop an EV Readiness Plan to Support
Installation of 794 Chargers by 2030: Develop an EV Readiness Plan
that supports the installation of 794 chargers (at least 160 of which
would be public chargers) and a 30 percent EV share of registered
passenger vehicles in Los Gatos by 2030. This plan should establish
a path forward to increase EV for implementation of public charging
infrastructure in key locations. In conjunction with an EV Readiness
Plan, conduct a community EV Feasibility Study to assess
infrastructure needs and challenges, particularly in frontline
communities.
Measure EN9: Increase privately owned EV charging infrastructure:
Amend the Town’s Building Code and Local Reach Code to require
the following:
EV capable attached private garages for new single-family and
duplex residential development;
20 percent EV capable charging spaces and panel capacity for new
multi-family residential development;
Section C Evaluation of Environmental Impacts 47 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
20 percent EV capable charging spaces for new commercial
development; and
At least 1 percent working chargers for all new development and
major retrofits.
Measure EN10: Increase Town-owned and publicly accessible EV
charging infrastructure: Work with public and private partners to
ensure there are sufficient publicly accessible DCFC and Level 2 EV
chargers around the Town by 2030, with a focus on providing access
to low-income households and affordable housing. Install new
publicly accessible EV chargers at Town-owned facilities. Develop
and implement a fee for use of Town-owned chargers to encourage
efficient use and turnover, especially for those without home
charging capability.
Measure EN11: Identify and partner with stakeholders to develop
EV-related rebates: Investigate partnerships with public and private
partners for rebates on at-home electric circuits, panel upgrades, and
Level 2 chargers, with a focus on supporting EV purchases for low-
income households in frontline communities.
Measure EN12: Encourage EV adoption and infrastructure
improvements: Conduct outreach, promotion, and education to
encourage EV adoption and infrastructure improvements. This
would include the following:
Providing education and outreach to the community on the
benefits of ZEVs, availability of public charging, and relevant
rebates and incentives available for businesses and residents.
Working with major employers to provide EV charging for
employees and encourage EV adoption among employees.
Transportation (TR)
Measure TR1: Implement Full Recommended Buildout of the
Bicycle and Pedestrian Master Plan (BPMP): Fully implement the
BPMP and add 23.2 new miles of bike network by 2035 to achieve
6 percent bicycle mode share by 2035.
Measure TR2: Identify and partner with stakeholders to conduct
outreach, promotion, and education: Leverage partnerships with
stakeholders to conduct ongoing outreach, promotion, and
education around active transportation in Los Gatos. This could
include:
Section C Evaluation of Environmental Impacts 48 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Establishing Town-wide events or programs that promote
active transportation in the community;
Regularly updating the Town’s Bicycle and Pedestrian
Network Map and sharing through Town and stakeholder
partnership platforms;
Supporting local bike groups in hosting workshops and classes
on bike riding, safety, and maintenance by certified instructors;
Instituting car-free days downtown, potentially coupled with
other large and regular events; or
Consolidating a list of local employer-provided bicycle
parking, lockers, showers, and incentives as a demonstration
tool for other interested employers.
Measure TR3: Facilitate a bike share program: Conduct a bike
share pilot program and facilitate full implementation of a bike
share program within the Town.
Measure TR4: Establish parking meter rates and invest in
transportation improvements: Establish parking meter rates,
considering dynamic parking pricing in the downtown area.
Allocate a designated portion of paid parking revenue to investing
in TDM strategies that will ensure cost-effective downtown access
by improving transit, bicycle facilities, and create incentives for
people to avoid driving.
Measure TR5: Improve curbside management: Improve curbside
management, including updating the municipal code to require
active loading only, prohibit double parking, define locations for
additional loading zones, and design loading zone signage.
Measure TR6: Require transportation system management for new
construction: Draft and implement a Transportation System
Management Plan (TSMP) ordinance for new construction to
allow the Town to shift travel behavior away from single-
occupancy vehicles. Ensure telecommuting is an optional trip
reduction strategy.
Measure TR7: Eliminate parking minimums for developments:
Remove parking minimums and establish parking maximums.
Section C Evaluation of Environmental Impacts 49 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Waste (WS)
Measure WS1: Require residential and commercial organic waste
collection consistent with SB 1383 requirements: Work with local
waste haulers and other community partners to expand organic
waste collection capacity. Pass an ordinance by 2022 requiring
residential and commercial organics generators to subscribe to
organics collection programs or alternatively report organics self-
hauling and/or backhauling. Allow limited waivers and
exemptions to generators for de minimis volumes and physical
space constraints and maintain records for waivers/exemptions.
Measure WS2: Require edible food recovery consistent with SB
1383 requirements: Adopt an edible food recovery ordinance or
similarly enforceable mechanism to ensure edible food generators,
food recovery services, and food recovery organizations comply
with requirements to increase recovery rates.
As discussed in the General Plan EIR, even with implementation of Mitigation Measure
GHG-1 requiring community GHG reduction measures, the General Plan would result in
emissions that exceed GHG efficiency thresholds and, therefore, state targets. As a
result, impacts related to the generation of GHG emissions under the General Plan
would be significant and unavoidable with mitigation incorporated (p. 4.8-31).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and would generate GHG emissions.
Development associated with the Housing Element Update is part of the significant and
unavoidable cumulative GHG emissions impacts associated with the General Plan and,
therefore, development associated with the Housing Element Update, which is consistent
with the growth projections evaluated in the General Plan EIR, would result in significant
and unavoidable GHG emissions impacts even after implementation of Mitigation
Measure GHG-1.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to GHG emissions.
b. Development under the General Plan would result in additional GHG emissions due to
construction, an increase in mobile sources, more building space requiring more heating
and cooling, etc. Section 4.8, Greenhouse Gas Emissions, of the General Plan EIR
evaluated the General Plan’s consistency with the California Air Resources Board 2017
Scoping Plan (which provides the framework for achieving the 2030 target related to
GHG emissions), Senate Bill 32 (which codifies the statewide goal of reducing GHG
emissions to 1990 levels by 2020), and Executive Order B-55-18 (an executive order
mandating the state to achieve carbon neutrality by no later than 2045). The General
Plan EIR determined that the General Plan would conflict with the reduction targets of
all three state plans identified above and would contribute to climate change. Therefore,
implementation of Mitigation Measure GHG-1 would be required.
Section C Evaluation of Environmental Impacts 50 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
However, even with implementation of Mitigation Measure GHG-1, total and per capita
Los Gatos GHG emissions would not be reduced to a level below state targets by 2030
and 2040. Additionally, the General Plan was determined to impede “substantial
progress” toward meeting the California Air Resources Board 2017 Scoping Plan, Senate
Bill 32, and Executive Order B-55-18 targets. Therefore, impacts would be significant
and unavoidable even with mitigation incorporated (p. 4.8-32).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and has been evaluated by the General
Plan EIR. Development associated with the Housing Element Update is part of the
significant and unavoidable cumulative GHG emissions impacts associated with the
General Plan and, therefore, development associated with the Housing Element Update,
which is consistent with the growth projections evaluated in the General Plan EIR, would
result in significant and unavoidable impacts related to consistency with applicable state
plans, even after implementation of Mitigation Measure GHG-1.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
conflict with an applicable state plan related to GHG emissions and targets.
The Town adopted its Statement of Overriding Conditions on June 30, 2022 and
determined that specific economic, legal, social, technological, mobility, or other
considerations, make infeasible the mitigation measures or project alternatives identified
in the General Plan Final EIR related to GHG emissions.
Section C Evaluation of Environmental Impacts 51 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
9. HAZARDS AND HAZARDOUS MATERIALS
Would the project:
Comments:
a. According to the General Plan EIR (Section 4.9, Hazards and Hazardous Materials),
development facilitated by the General Plan would result in approximately 156,400 square
feet of manufacturing development, which would increase the overall routine transport,
use, and disposal of hazardous materials in Los Gatos.
Documentation of compliance with hazardous materials regulations codified in the
California Code of Regulations titles 8, 22, and 26 is required for all hazardous materials
and hazardous waste transport. Individual contractors and property owners must comply
with all applicable federal and state laws and regulations pertaining to the transport, use,
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a.Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
☐ ☐ ☐ ☒
b.Create a significant hazard to the public or the
environment through reasonably foreseeable upset
and accident conditions involving the release of
hazardous materials into the environment?
☐ ☐ ☒ ☐
c.Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
☐ ☐ ☐ ☒
d. Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code section 65962.5 and, as a result,
create a significant hazard to the public or the
environment?
☐ ☐ ☒ ☐
e.For a project located within an airport land-use plan
or, where such a plan has not been adopted, within
two miles of a public airport or a public-use airport,
result in a safety hazard or excessive noise for people
residing or working in the project area?
☐ ☐ ☐ ☒
f.Impair implementation of or physically interfere with
an adopted emergency response plan or emergency
evacuation plan?
☐ ☐ ☐ ☒
g. Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or death
involving wildland fires?
☐ ☐ ☒ ☐
Section C Evaluation of Environmental Impacts 52 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
disposal, handling, and storage of hazardous waste, including but not limited to, Title 49
of the Code of Federal Regulations. Adherence to applicable regulations and laws would
reduce accidental release of hazardous materials during transport. In addition to
mandatory adherence to laws and regulations, the General Plan contains goals and
policies that would apply to routine transport, use, or disposal of hazardous materials
such as those policies associated with General Plan Goals HAZ-7 and MOB-15 (Town of
Los Gatos 2021, p. 4.9-17).
The overall quantity of hazardous materials used and requiring disposal in Los Gatos
could incrementally increase as a result of development under the General Plan.
However, all new development would be required to comply with existing applicable
regulations, programs, and standards as well as implementation of applicable General
Plan goals and policies, which would minimize risks from routine transport, use, and
disposal of hazardous materials and result in less than significant impacts (p. 4.9-19).
Development associated with the Housing Element Update involves only residential
development and would not involve industrial or commercial development that more
commonly involve the storing, using, transporting and/or disposing of hazardous
materials. Therefore, the Housing Element Update would not create a significant hazard
to the public or the environment through the routine transport, use, or disposal of
hazardous material.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impact related to the routine transport, use, or disposal of hazardous materials.
b. The General Plan facilitates and encourages infill development throughout the Town,
which could require the demolition of existing uses to facilitate future development. If
such buildings identified for demolition were constructed prior to the 1970s. Section 4.9,
Hazards and Hazardous Materials, of the General Plan EIR states that lead and asbestos
could be present and released into the environment during demolition activities. The
California Department of Public Health, the California Department of Industrial
Relations, Division of Occupational Safety and Health Administration, and the Bay Area
Air Quality Management District regulate lead and asbestos abatement necessary for
construction and redevelopment projects. California Code of Regulations Section 1532.1
requires testing, monitoring, containment, and disposal of lead‐based materials such that
exposure levels do not exceed California Department of Industrial Relations, Division of
Occupational Safety and Health Administration standards. The control of asbestos
during demolition or renovation of buildings is regulated under the Federal Clean Air
Act. Compliance with the mandatory requirements of California Code of Regulations
and the Federal Clean Air Act would reduce the potential hazards and risks associated
with release of lead and asbestos. Oversight by the appropriate agencies would ensure
that impacts related to the potential accident conditions involving the release of
hazardous materials into the environment would be less than significant (Town of Los
Gatos 2021, p. 4.9-19).
Section C Evaluation of Environmental Impacts 53 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Development associated with the Housing Element Update would involve the demolition
of existing structures as it focuses on infill development and redevelopment. It is
unknown at this time if any of the existing structures were constructed prior to the 1970s
and whether or not hazardous materials are present on each site. As individual
development associated with the Housing Element Update are proposed, a Phase I
Environmental Site Assessment would be required for new development on proposed
land that may be contaminated with hazardous materials or waste, pursuant to General
Plan Policy HAZ-7.2. Should lead and asbestos be detected on any one of the sites
associated with the Housing Element Update, the development would be required to
comply with the mandatory requirements of the California Code of Regulations and the
Federal Clean Air Act to reduce the potential hazards and risks related to the release of
lead and asbestos.
Development under the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR. Therefore, impacts related to the
potential for accident conditions involving the release of hazardous materials into the
environment would be less than significant.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impact related to the accidental release of hazardous materials into the environment.
c. Schools are located throughout Los Gatos. The General Plan would facilitate various
types of development throughout the Town of Los Gatos; residential and office uses do
not typically emit hazardous materials, and it is not possible to know the quantity of
hazardous materials proposed for use at the future commercial and industrial
development sites. Although the quantities of hazardous material used at the future
commercial and industrial development cannot be known, Section 4.9, Hazards and
Hazardous Materials, of the General Plan EIR determines that this type of development
could occur within one-quarter mile of existing public or private schools in Los Gatos.
However, development under the General Plan would be required to comply with the
provisions of the California Fire Code adopted by the Town (Chapter 12, Article II) and
the Santa Clara County Fire Department Certified Unified Program Agency requirements
that comply with provisions set forth in the California Health and Safety Code, Division
20, Chapter 6.95, Articles 1 and 2. Impacts would be less than significant (Town of Los
Gatos 2021, p. 4.9-20).
The Housing Element Update, which is consistent with the growth projections evaluated
in the General Plan EIR, would result in development within one-quarter mile of existing
schools. However, the Housing Element Update involves only residential development,
which does not typically generate or emit hazardous materials. Therefore, the Housing
Element Update would not result in hazardous emissions or handle hazardous or acutely
hazardous materials, substances, or waste within one-quarter mile of an existing or
proposed school.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to hazardous emissions within one-quarter mile of a school.
Section C Evaluation of Environmental Impacts 54 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
d. Existing sites in Los Gatos that may contain hazardous land uses or contamination from
land uses that were on the sites previously generators of hazardous waste, such as gas
stations, dry cleaners, and industrial uses. According to the General Plan EIR (Section
4.9, Hazards and Hazardous Materials), there are active or open sites containing or
potentially containing hazardous materials contamination within the Town limits.
Development facilitated by the General Plan on these sites could expose construction
workers and future occupants of the new uses to hazardous materials (p. 4.9-21). It is
also possible that unknown underground storage tanks may be present within the Town;
if one is uncovered or disturbed during construction activities, it would be removed
under permit from the Santa Clara County Fire Department; tank removal activities could
also pose health and safety risks.
Development at any one of these known sites would be subject to investigation,
remediation, and cleanup under the supervision of the Regional Water Quality Control
Board, the Santa Clara Valley Water District (Valley Water), or the California Department
of Toxic Substances and Control before construction activities could begin. In addition,
development would be required to comply with General Plan Goal HAZ-7 (reduce the
potential for injuries, damage to property, economic and social displacement, and loss of
life resulting from hazardous materials is eliminated) and its associated policies, reducing
the potential for release of hazardous substances through inter-organization cooperation,
site assessments, and hazardous material storage monitoring. Risks posed by
underground storage tanks would be minimized by managing the tank according to
existing standards contained in Division 20, Chapters 6.7 and 6.75 (Underground Storage
Tank Program) of the California Health and Safety Code as enforced and monitored by
the Environmental Programs Division. Compliance with existing state and local
regulations, in addition to implementation of applicable General Plan policies, would
reduce risks related to hazardous material sites to a less-than-significant level (Town of
Los Gatos 2021, p. 4.9-22).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and would not occur on sites identified by
the Town as active or open sites containing or potentially containing hazardous materials
contamination. However, it is possible that unknown underground storage tanks may be
present within those sites associated with the Housing Element Update. Disturbance or
removal activities related to underground storage tanks could pose health and safety risks.
As previously stated, risks posed by underground storage tanks would be minimized by
managing the tank according to existing standards contained in Division 20, Chapters 6.7
and 6.75 (Underground Storage Tank Program) of the California Health and Safety Code
as enforced and monitored by the Environmental Programs Division. Implementation of
applicable General Plan policies such as Policy HAZ-7.2, which requires a Phase I Site
Assessment for new development proposed on land that may be contaminated with
hazardous materials or waste, would reduce risks posed by the underground storage
tanks.
Section C Evaluation of Environmental Impacts 55 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Compliance with existing state and local regulations, in addition to implementation of
applicable General Plan policies, would reduce the Housing Element Update’s potential
risks of disturbing unknown underground storage tanks during construction activities to a
less-than-significant level.
The General Plan EIR adequately addresses the Housing Element Update’s potential
impacts related to hazardous material sites.
e. According to the General Plan EIR (Section 4.9, Hazards and Hazardous Materials),
there are no public or private airports within or adjacent to the Town and the Town of
Los Gatos is entirely outside the area of influence for the airport (Town of Los Gatos
2021, p. 4.9-22). Therefore, development of the Housing Element Update would have
no impact related to airports or their influence areas.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impact related to airports and airport land use plans.
f. Development facilitated by the General Plan would accommodate future population
growth and would increase vehicle miles in the Town, which could lead to increased
congestion during emergency evacuations. Section 4.9, Hazards and Hazardous
Materials, of the General Plan EIR explains that the Town adopted an Emergency
Operations Plan, which provides guidance on effective emergency response approaches,
and the Santa Clara County Office of Emergency Services developed an Operational Area
Hazard Mitigation Plan, which details target programs for improving emergency
preparedness and response in cooperation with local jurisdictions, including the Town of
Los Gatos. Additionally, the General Plan includes policies that address emergency
response, all of which are designed to align with programs set forth in the Santa Clara
County-wide Hazard Mitigation Plan.
Development under the General Plan would be required to implement all applicable
General Plan policies and programs outlined in the local emergency plans associated with
emergency planning and response. Implementation of which would result in less than
significant impacts (Town of Los Gatos 2021, p. 4.9-23).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR. Individual development under the
Housing Element Update would implement the programs of the local emergency
response plans as well as applicable General Plan policies, as appropriate. Because
development associated with the Housing Element Update would involve infill
development and redevelopment of sites, it would not impair implementation of, or
physically interfere with, an adopted emergency response plan or emergency evacuation
plan.
The General Plan EIR adequately addressed the Housing Element Update’s potential
interference with an adopted emergency response plan or evacuation plan.
Section C Evaluation of Environmental Impacts 56 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
g. Development associated with the Housing Element Update would result in the exposure
of people or structures to risks involving wildfires. Refer to Section 20.0, Wildfire, for
the analysis of risk of exposure involving wildland fires.
Section C Evaluation of Environmental Impacts 57 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
10. HYDROLOGY AND WATER QUALITY
Would the project:
Comments:
a. According to the General Plan EIR (Section 4.10, Hydrology and Water Quality),
construction activities facilitated by the General Plan could include road improvements
and realignments, installation and realignment of utilities, demolition of existing
structures for replacement, new development, and the potential replacement and/or
improvements of drainage facilities. Construction activity could result in the alteration of
existing drainage patterns and soil erosion due to earth-moving activities. Disturbed soils
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a.Violate any water quality standards or waste discharge
requirements or otherwise substantially degrade
surface or ground water quality?
☐ ☐ ☐ ☒
b.Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such
that the project may impede sustainable groundwater
management of the basin?
☐ ☐ ☒ ☐
c.Substantially alter the existing drainage pattern of the
site or area, including through the alteration of the
course of a stream or river or through the addition of
impervious surfaces, in a manner which would:
(1) Result in substantial erosion or siltation on- or off-
site;☐ ☐ ☒ ☐
(2)Substantially increase the rate or amount of surface
runoff in a manner which would result in flooding on-
or off-site;
☐ ☐ ☒ ☐
(3)Create or contribute runoff water that would exceed
the capacity of existing or planned storm water
drainage systems or provide substantial additional
sources of polluted runoff; or
☐ ☐ ☒ ☐
(4)Impede or redirect flood flows?☐ ☐ ☒ ☐
d. In flood hazard, tsunami, or seiche zones, risk release
of pollutants due to project inundation?☐ ☐ ☐ ☒
e.Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
☐ ☐ ☒ ☐
Section C Evaluation of Environmental Impacts 58 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
would be susceptible to erosion from wind and rain, resulting in sediment transport via
stormwater runoff from the construction sites, ultimately into collecting waterways
contributing to the degradation of water quality.
Individual construction activities that disturb one or more acres would be subject to the
National Pollutant Discharge Elimination System General Permit for Storm Water
Discharges Associated with Construction and Land Disturbance Activities, Order No.
2012-0006-DWQ (general permit). Permit conditions require development of a
stormwater pollution prevention plan, which, among others, describes the site’s erosion
and sediment control measures, runoff water quality monitoring. Compliance with the
general permit is reinforced through the Town Municipal Code (Chapter 22), the Town’s
Storm Drain Master Plan, and adherence to the San Francisco Bay Regional Water
Quality Control Board’s Basin Plan; whose water quality objectives are incorporated into
individual National Pollutant Discharge Elimination System permits (Town of Los Gatos
2021, p. 4.10-10). The Town is also required, as part of the general permit, to incorporate
construction site storm water runoff control elements into a stormwater management
program as a means to control polluted discharges.
Development associated with the General Plan would be required to implement
appropriate best management practices as measures for post-construction stormwater and
submit a maintenance plan or manufacturers maintenance guide for those measures as
part of the Housing Element Update’s submittal. Compliance with the regulations and
policies abovementioned would reduce the risk of water degradation within the Town
from construction activities to a less-than-significant level (p. 4.10-13).
Long-term alternations to drainage patterns during operation of development under the
General Plan would also occur. If uncontrolled, this could result in the addition of
contaminants into the Town’s stormwater drainage system and ultimately untreated
discharge into nearby waterways. To ensure compliance with the general permit’s
requirements and conditions, the Town’s Municipal Code Chapter 22 outlines regulations
related to stormwater management control that projects would be required to comply
with. Compliance with the Town’s applicable Municipal Code sections would minimize
erosion and siltation that could adversely affect water quality within the Town.
Development under the General Plan would also be required to comply with the
applicable General Plan policies associated with Goal ENV-16 (protect and conserve
watersheds and water quality) as well as General Plan Policy ENV-17.8, which encourages
new development to implement low-impact development measures to limit the amount
of impervious surfaces. Compliance with regional and local requirements listed
previously, in addition to implementation of applicable General Plan goals and policies,
would ensure that the impacts related to development under the General Plan and its
effects to water quality during operation would remain less than significant.
Development associated with the Housing Element Update would result in the increase
in impervious surfaces in the Town, which could result in sediment transport via
stormwater runoff from the sites into collecting waterways contributing to the
Section C Evaluation of Environmental Impacts 59 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
degradation of water quality. However, the Housing Element Update is consistent with
the growth projections evaluated in the General Plan EIR and, therefore, its potential to
degrade water quality in the Town has been evaluated by the General Plan EIR.
Development associated with the Housing Element Update would be required to comply
with the regulations and policies mentioned above related to construction and operational
activities such as the general permit, the San Francisco Bay Regional Water Quality
Control Board, and the Town’s Municipal Code sections related to water quality control.
The Housing Element Update would also be required to comply with applicable General
Plan policies such as Policy ENV-16.1, which requires that all applicants demonstrate that
new development would not contaminate surface water and/or groundwater; Policy
ENV-16.5, which requires that the approval of a development adjacent to a designated
creek includes a condition that the creek be dedicated to the Town in fee with a
maintenance easement granted to Santa Clara Valley Water District; Policy ENV-16.7,
which encourages the implementation of bioswales and other innovations so runoff from
parking lots drain into landscaped areas and rainwater percolates into the ground; and
Policy ENV-17.8, which encourages low-impact development measures to limit the
amount of impervious surface in new development and to increase the retention,
treatment, and infiltration of urban stormwater runoff. The Housing Element Update
would also comply with General Plan PFS-3.1, which requires that CEQA review analysis
for all development projects consisting of single and cumulative impacts on water
drainage (runoff) and contamination (water quality) in all areas, but particularly in or
adjacent to hillsides, riparian corridors, and important undeveloped watersheds.
Adherence to these regulations and standards, as well as the policies within the General
Plan, would ensure that development associated with the Housing Element Update does
not violate any water quality standards or waste discharge requirements or otherwise
substantially degrade surface or ground water quality during construction and operation.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
violate water quality standards.
b. Water demand and services is addressed in Section 19.0, Utilities and Service Systems.
Nearly half of the water used in Santa Clara County is pumped from the Santa Clara and
Llagas Subbasins, with some communities relying solely on groundwater. Local sources
include natural groundwater and surface water supplies. The Santa Clara Valley Subbasin
is the groundwater basin for the Town of Los Gatos.
Groundwater Supply. Development associated with the General Plan would increase
the demand for water from the Santa Clara Valley Subbasin. However, as stated in the
General Plan EIR (Section 4.10, Hydrology and Water Quality), growth in the Town of
Los Gatos that would be facilitated by the General Plan has been incorporated into the
2015 Urban Water Management Plan and it was determined that the future water demand in
Los Gatos is projected to be met by the current water supply. Therefore, projected
growth under the General Plan would not result in a depletion of groundwater supplies in
the Santa Clara Valley Subbasin (Town of Los Gatos 2021, p. 4.10-14).
Section C Evaluation of Environmental Impacts 60 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
The Housing Element Update would comply with General Plan Policy PFS-1.2, which
requires that all new home construction and remodeled homes comply with the Bay-
Friendly Landscaping Guidelines in addition to the landscaping standards in the
GreenPoint Rated Building Guidelines and Policy PFS-1.4, which requires that all new
development install water-efficient irrigation management systems and devices, such as
evapotranspiration or soil moisture-based irrigation controls. Development associated
with the Housing Element Update is consistent with the growth projections evaluated in
the General Plan EIR and, therefore, its impacts on the Santa Clara Valley Subbasin were
evaluated in the General Plan EIR. Therefore, the Housing Element Update would not
substantially decrease groundwater supplies such that the Housing Element Update may
impede sustainable groundwater management of the basin.
Groundwater Recharge. Development associated with the General Plan could
potentially interfere with groundwater recharge; however, the General Plan contains goals
and policies that would encourage groundwater infiltration and promote the use of
recycled water and other conservation efforts. Implementation of General Plan Policy
ENV-17.6, which encourages the Town to participate in the regulation of groundwater
use to protect it as a natural resource and conserve it for potential use during extended
drought, and those applicable policies under General Plan Goal PFS-4, minimize the
amount of stormwater runoff, as well as protect and improve the water quality of runoff,
would maximize groundwater infiltration and increase water use efficiency within the
Town to the maximum extent practicable. The General Plan EIR concludes that the
amount of new impervious surfaces from new development and redevelopment under
the General Plan would be reduced through low impact development-related General
Plan goals and policies and would not substantially interfere with groundwater recharge.
Therefore, the General Plan EIR determined that the development under the General
Plan would result in less than significant impacts related to groundwater recharge
(p. 4.10-14).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, its impacts on the Santa
Clara Valley Subbasin were evaluated in the General Plan EIR. Consistent with the
General Plan EIR conclusion, the amount of new impervious surfaces from new
development and redevelopment under the Housing Element Update would be reduced
through low impact development-related General Plan goals and policies. Therefore, the
Housing Element Update would not interfere substantially with groundwater recharge
such that the Housing Element Update may impede sustainable groundwater
management of the basin.
2020 Urban Water Management Plan. Since certification of the General Plan EIR and
adoption of the General Plan, the San Jose Water Company updated and adopted its 2020
Urban Water Management Plan. The 2020 Urban Water Management Plan concluded that San
Jose Water Company anticipates adequate supplies to meet system demand, even during
prolonged drought conditions, through 2045 (San Jose Water Company 2021, p. 7-11).
The Santa Clara Subbasin has not been identified by the California Department of Water
Resources as being critically overdraft. San Jose Water Company also plans to continue
following all state and federal drinking water requirements and will work with Santa Clara
Section C Evaluation of Environmental Impacts 61 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Valley Water District (Valley Water), the California Division of Drinking Water, other
groundwater basin stakeholders, and the public to ensure that groundwater remains safe
and a reliable source of supply (San Jose Water Company 2021, p. 6-5).
The General Plan EIR adequately addressed the Housing Element Update’s potential to
deplete or interfere with groundwater supply and recharge.
c. According to the General Plan EIR (Section 4.10, Hydrology and Water Quality), most of
the Town is within the 500-year flood zone with a few portions, such as those areas west
of State Route 17 and adjacent to creeks, in the 100-year flood zone. Development in
these areas could be subject to flood hazard and/or could impede or redirect flood flows
to adjacent areas. Development within these areas, as facilitated by the General Plan, are
required to comply with applicable provisions of the Town Municipal Code, which would
minimize the risk and exposure to flood hazards. Chapter 29, Article IX includes
requirements and provisions for reducing losses from flooding and for construction in
flood-prone areas. Development in flood-prone areas would also be required to obtain a
development permit before constriction or development begins per Municipal Code
Section 29.90.070. Compliance with applicable sections of the Town Municipal Code
would ensure that new structures proposed under the General Plan would not impede or
redirect flows within a 100-year flood hazard area. Development under the General Plan
is also required to implement those applicable General Plan policies associated with
General Plan Goal HAZ-3. As concluded in the General Plan EIR, implementation of
these goals and policies and compliance with applicable laws and regulations of the
Town’s Municipal Code, would reduce impacts such that risk of loss, injury or death
involving flooding in the planning area is not exacerbated by the General Plan.
Therefore, impacts related to flooding and flood hazards would be less than significant
(Town of Los Gatos 2021, p. 4.10-17).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and could result in development within
flood-prone zones adjacent to the Los Gatos Creek. Development associated with the
Housing Element Update is required to implement General Plan Policy HAZ-3.3,
requiring site planning and building design to mitigate identified flood and inundation
hazards; Policy HAZ-3.4, requiring new development and substantial improvements to
meet federal standards when within Federal Emergency Management Agency designated
100-year flood zones in the Los Gatos area; and Policy HAZ-3.6, which requires major
new development and redevelopment to provide mitigation to ensure that the cumulative
rate of peak stormwater run-off is maintained at pre-development levels. The Housing
Element Update’s impacts associated with flood hazard has already been evaluated in the
General Plan EIR, but would require implementation of General Plan policies and
compliance with applicable laws and regulations in order to ensure that risks of loss,
injury, or death involving flooding would not be exacerbated by implementation of the
Housing Element Update and would result in less than significant impacts.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to flooding and flood hazards.
Section C Evaluation of Environmental Impacts 62 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
d. The Town of Los Gatos is not located in a tsunami or seiche zone. Therefore,
development of the Housing Element Update would not risk release of pollutants due to
tsunami or seiche inundation of the Town. As determined in the General Plan EIR
(Section 4.10, Hydrology and Water Quality), there would be no impact related to flood
flows or project inundation (Town of Los Gatos 2021, p. 4.10-18).
The General Plan EIR adequately addressed impacts related to the risk release of
pollutants due to tsunami or seiche inundation as a result of the Housing Element
Update.
e. Refer to the discussion under checklist question “a.” According to the General Plan EIR
(Section 4.10, Hydrology and Water Quality ), development under the General Plan
would comply with the general permit, the Town’s Storm Drain Master Plan, applicable
General Plan policies, and adhere to the San Francisco Bay Regional Water Quality
Control Board’s Basin Plan, whose water quality objectives are incorporated into
individual permits authorized by the San Francisco Bay Regional Water Quality Control
Board. Therefore, development facilitated by the Housing Element Update would not
conflict with or obstruct implementation of a water quality control plan.
The Sustainable Groundwater Management Act lists the Valley Water as the exclusive
groundwater management agency for Santa Clara County. The Sustainable Groundwater
Management Act requires that groundwater management agencies prepare a groundwater
sustainability plan or an alternative to achieve sustainability. Pursuant to the Sustainable
Groundwater Management Act, the Valley Water prepared its 2016 Groundwater
Management Plan for the Santa Clara and Llagas Subbains as an alternative. Since the
preparation of the General Plan EIR, the Valley Water has prepared an updated
evaluation of its approved alternatives (i.e., the 2016 Groundwater Management Plan) titled
the 2021 Groundwater Management Plan for the Santa Clara and Llagas Subbains, which was
adopted by its Board of Directors in November 2021. However, the General Plan EIR
utilized the most recent documentation at that time, which was the 2016 Groundwater
Management Plan.
As discussed under checklist question “b” above, growth in the Town facilitated by the
General Plan would implement applicable General Plan policies and goals encouraging
groundwater infiltration, promoting the use of recycled water, and other water
conservation efforts to reduce the potential for depletion of groundwater resources
resulting in less than significant impacts on the Santa Clara Subbasin. According to the
General Plan EIR, compliance with the Sustainable Groundwater Management Act
requirements and adherence to the applicable General Plan goals and policies would
ensure that impacts from development under the General Plan related to obstruction of a
sustainable groundwater management plan would be less than significant (p. 4.10-15).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and its impacts on the Santa Clara
Subbasin, and subsequently on the 2016 Groundwater Management Plan, has already been
evaluated in the General Plan EIR. The Housing Element Update would be required to
Section C Evaluation of Environmental Impacts 63 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
comply with the Sustainable Groundwater Management Act requirements and adhere to
the applicable General Plan goals and policies to ensure that impacts from development
associated with the Housing Element Update related to obstruction of a sustainable
groundwater management plan would be less than significant.
Since the certification of the General Plan EIR and adoption of the General Plan, the
2021 Groundwater Management Plan for the Santa Clara and Llagas Subbasins was adopted by
the Valley Water. The projected demands in the Santa Clara and Llagas subbasins for the
2021 Groundwater Management Plan for the Santa Clara and Llagas Subbasins are based on data
used to develop the Valley Water’s 2020 Urban Water Management Plan. Valley Water
maintains diverse water supply sources to meet countywide demands, including local
surface water and groundwater, imported water, and recycled water. The Valley Water
developed a Water Shortage Contingency Plan as part of its 2020 Urban Water Management
Plan to establish actions and procedures for managing water supplies and demands during
water shortages due to droughts and other emergencies. As stated within the 2021
Groundwater Management Plan for the Santa Clara and Llagas Subbasins, Valley Water will be
able to meet countywide demands through 2045 under normal, a single dry, and five
consecutive dry year conditions. If a five-year drought were to occur in the next five
years, Valley Water would employ a range of response actions, including water
conservation and calling for short-term water use reduction (Santa Clara Valley Water
District 2021, p. 4-21).
The General Plan EIR adequately addressed the Housing Element Update’s potential to
conflict with a sustainable groundwater management plan.
Section C Evaluation of Environmental Impacts 64 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
11. LAND USE AND PLANNING
Would the project:
Comments:
a. As discussed in the General Plan EIR (Section 4.11, Land Use and Planning), the Town
has limited land available for new development; therefore, due to the built-out nature of
the Town, the General Plan encourages strategic growth. The Town would see a higher
percentage of change through redevelopment of lands that have development potential
rather than on vacant land. Many of the General Plan’s Land Use Element goals are
promoting growth through infill development, development variety, and a mix of uses
within the Town (Town of Los Gatos 2021, p. 4.11-12). Compliance with the General
Plan goals and policies would ensure that future development under the General Plan
does not disrupt or divide established communities and impacts would be less than
significant (Town of Los Gatos 2021, p. 4.11-14).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, would be required to
comply with General Plan’s goals that promote growth through infill development and
development variety. Each site associated with the Housing Element Update involves
infill development or the redevelopment of property with existing uses; the Housing
Element Update does not involve the development of any sites that would physically
divide an established community.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts on physically dividing an established community.
b. Section 4.11, Land Use and Planning, of the General Plan EIR identifies three regionally
and locally adopted land use plans that apply to development under the General Plan:
Plan Bay Area 2040 (ABAG 2017), Final 2017 Clean Air Plan (Bay Area Air Quality
Management District 2017), and Los Gatos Sustainability Plan (Town of Los Gatos 2012).
Plan Bay Area 2040 is a long-range land use and transportation plan for the San Francisco
Bay Area region that promotes healthy and safe communities by reducing impacts from
air pollution, protecting open space and agriculture, and increasing active transportation.
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a. Physically divide an established community? ☐ ☐ ☐ ☒
b. Cause any significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
☐ ☐ ☐ ☒
Section C Evaluation of Environmental Impacts 65 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
The General Plan EIR provides a breakdown of the General Plan’s consistency against
the Plan Bay Area 2040’s goals in relation to climate protection, adequate housing, health
and safe communities, open space and agricultural preservation, equitable access
economic vitality, and transportation system effectiveness (refer to Table 4.11-4 of the
General Plan EIR). As discussed in the General Plan EIR, the General Plan would be
consistent with the goals contained in the Plan Bay Area 2040 (Town of Los Gatos 2021,
p. 4.11-18).
As discussed in Section 3.0, Air Quality, the General Plan (and, therefore, the Housing
Element Update) would be consistent with the Final 2017 Clean Air Plan through
implementation of the applicable goals and policies located within the Environmental and
Sustainability Element and the Mobility Element.
The General Plan EIR provides a breakdown of the General Plan’s consistency with the
Los Gatos Sustainability Plan’s sustainability measures associated with transportation, land
use, energy, water, solid waste, and open space (refer to Table 4.6-5 of the General Plan).
The General Plan EIR also discusses consistency with the California Green Building
Standards Code and Title 24 of the California Energy Code. As discussed in Section 6.0,
Energy, the General Plan is consistent with the Los Gatos Sustainability Plan and the energy
efficiency strategies contained therein as well as with Title 24 of the California Energy
Code.
The Town also has two specific plans (Albright and North Forty) and four overlay zones
(Affordable Housing, Landmark and Historic Preservation, Planned Development, and
Public School), which are key implementation mechanisms for the General Plan and its
provisions must be consistent with the General Plan. There are also eight community
place districts throughout the Town that have been identified as having the capacity to
accommodate additional mixed-use developments and have existing infrastructure
necessary to suppose the land uses.
The two specific plans address existing and future development within the Town to
ensure that any development would maintain the existing residential setting while
continuing to meet the needs of its residents. The overlay zones ensure that development
facilitated by the General Plan is consistent with the development goals of the Town and
the goals found within the General Plan provide guidance on the use of overlay zones in
the community.
Therefore, the General Plan does not conflict with any applicable land use plan, policy, or
regulation adopted for the purpose of avoiding or mitigating an environmental effect and
impacts would be less than significant (Town of Los Gatos 2021, p. 4.11-20).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and therefore, would also be consistent
with all of the above-mentioned plans (i.e., Plan Bay Area 2040, Final 2017 Clean Air Plan,
Los Gatos Sustainability Plan, the state’s Title 24 of the Energy Code, and the Town’s
specific plans, overlay zones, and community place districts). Development associated
Section C Evaluation of Environmental Impacts 66 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
with the Housing Element Update would comply with the applicable goals, policies,
measures, and regulations associated with these plans and districts that are adopted for
the purpose of avoiding or mitigating an environmental impact. Therefore, the Housing
Element Update would not result in conflict with any applicable land use plan, policy, or
regulation adopted for the purpose of avoiding or mitigating an environmental effect.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to applicable land use plans, policies, or regulations adopted for the
purpose of avoiding or mitigating an environmental impact.
Section C Evaluation of Environmental Impacts 67 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
12. MINERAL RESOURCES
Would the project:
Comments:
a, b. As discussed in Section 4.18, Effects Found Not to be Significant, no mining occurs
within the Town (Town of Los Gatos 2021, p. 4.18-1). The Lexington Quarry, however,
is in operation and produces construction aggregate at its location at 18500 Limekiln
Canyon Road, Los Gatos (located over 1.3 miles southeast of the nearest housing site
associated with the Housing Element Update).
Development on areas containing mineral resources could result in the permanent loss of
those minerals. However, the development associated with the Housing Element Update
does not include land use designation changes in the area of the Lexington Quarry and
development would not occur on this site. Therefore, the General Plan, inclusive of the
Housing Element Update, would not facilitate new or additional development within the
area of the mineral deposit and the Housing Element Update would not result in the loss
of availability of mineral resources in the Town that are known or of local importance
(Town of Los Gatos 2021, p. 4.18-2).
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts on mineral resources.
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a.Result in loss of availability of a known mineral
resource that would be of value to the region and the
residents of the state?
☐ ☐ ☐ ☒
b.Result in the loss of availability of a locally important
mineral resource recovery site delineated in a local
general plan, specific plan, or other land-use plan?
☐ ☐ ☐ ☒
Section C Evaluation of Environmental Impacts 68 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
13. NOISE
Would the project result in:
Comments:
a.Temporary Noise Levels. As discussed in the General Plan EIR (Section 4.12, Noise),
development under the General Plan would result in construction activities that would
temporarily increase ambient noise levels. However, because there are no specific plans
or time scales for individual development projects that would be carried out under the
General Plan, it is not possible to determine exact noise levels, locations, or time periods
for construction of such projects, or construction noise at adjacent properties (p. 4.12-9).
Sensitive noise receptors in areas where more development and redevelopment under the
General Plan is proposed would be exposed to the highest levels of construction noise
for the longest duration; these areas include the downtown core and the corridors along
Pollard Road, Winchester Boulevard, Lark Avenue, Los Gatos Boulevard, Union Avenue,
Harwood Road, and North Santa Cruz Avenue. It is anticipated that construction noise
as a result of development under the General Plan would exceed ambient noise levels and
may temporarily disturb people at neighboring properties.
The General Plan would be required to comply with the Town’s Municipal Code Section
16.20.035, which identifies timing requirements for when construction noise is permitted
during the weekdays and weekends, and lists the noise level requirements for construction
equipment. The General Plan would also be required to implement the applicable
General Plan policies and goals contained in the Environmental and Sustainability
Element in order to reduce construction noise and associated impacts. General Plan
Policy ENV-21.1 requires that all Town-owned and operated construction and
maintenance equipment, and equipment for these activities operated under contract with
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a.Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the
project in excess of standards established in the local
general plan or noise ordinance, or in applicable
standards of other agencies?
☐ ☒ ☐ ☐
b. Generation of excessive ground-borne vibration or
ground borne noise levels?☐ ☒ ☐ ☐
c. For a project located within the vicinity of a private
airstrip or an airport land-use plan or, where such a
plan has not been adopted, within two miles of a
public airport or public-use airport, expose people
residing or working in the project area to excessive
noise levels?
☐ ☐ ☐ ☒
Section C Evaluation of Environmental Impacts 69 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
the Town, shall contain state-of-the-art noise attenuation equipment. Development
under the General Plan could include private development that is not required to use
noise attenuation equipment, which may result in the generation of noise that exceeds
existing ambient noise levels. Therefore, the following mitigation measure is required in
order to ensure that impacts related to construction noise would be less than significant
(Town of Los Gatos 2021, p. 4.12-12).
Mitigation Measure
N-1 For projects involving construction equipment that are located within 25 feet of
noise-sensitive receptors the following mitigation would be required:
Equipment Staging Areas. Equipment staging shall be located in areas that
will create the greatest distance feasible between construction-related noise
sources and noise-sensitive receptors.
Electrically-Powered Tools and Facilities. Electrical power shall be used to
run air compressors and similar power tools and to power any temporary
structures, such as construction trailers or caretaker facilities.
Smart Back-up Alarms. Mobile construction equipment shall have smart
back-up alarms that automatically adjust the sound level of the alarm in
response to ambient noise levels. Alternatively, back-up alarms shall be
disabled and replaced with human spotters to ensure safety when mobile
construction equipment is moving in the reverse direction.
Additional Noise Attenuation Techniques. During the clearing, earth
moving, grading, and foundation/conditioning phases of construction,
temporary sound barriers shall be installed and maintained between the
construction site and the sensitive receptors. Temporary sound barriers shall
consist of sound blankets affixed to construction fencing or temporary solid
walls along all sides of the construction site boundary facing potentially
sensitive receptors.
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, would result in temporary
construction noise that could exceed existing ambient noise levels. The Housing Element
Update would be required to comply with the Town’s Municipal Code Section 16.20.035
as well as applicable General Plan policies, such as General Plan Policy 18.2, which
requires that all interior residential noise levels be 45 dB or less; Policy ENV-18.3, which
requires that all exterior noise levels be based on the compatibility criteria shown on the
General Plan’s Figure 8-6; and Policy ENV-18.4, which requires that appropriate site and
building design, sound walls, minimum landscape buffers of five feet, and/or the use of
noise attenuating construction techniques and materials be used in order to protect
existing and proposed residential areas from noise.
However, as indicated above, development associated with the Housing Element Update,
which is consistent with the growth projections evaluated in the General Plan EIR, may
include private developers who are not required to comply with General Plan Policy
ENV-21.1 and whose construction equipment could result in noise levels that exceed
Section C Evaluation of Environmental Impacts 70 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
existing ambient noise levels. Therefore, the Housing Element Update would be required
to implement Mitigation Measures N-1 in order to reduce impacts to a less-than-
significant level.
Permanent Noise Levels. Existing sensitive noise receptors could be affected by
buildout and operational noise occurring onsite at properties developed or redeveloped
under the General Plan.
Noise generated by onsite activities for new development would be subject to the Town’s
maximum allowable exterior noise levels contained in Chapter 16 of the Town’s
Municipal Code as well as the goals and policies within the General Plan that reduce
excess noise generated by new development. Compliance with these regulations and
policies would reduce potential onsite noise impacts to a less-than-significant level.
Development facilitated by the General Plan would also result in increased offsite
operational noise levels such as additional vehicle trips on roadways within the Town.
However, implementation of General Plan policies and goals encouraging the use of
public transit and other active transportation modes would reduce vehicle trips and
associated traffic noise to the extent feasible. Therefore, roadway noise would be less
than significant (Town of Los Gatos 2021, p. 4.12-15).
Development associated with the Housing Element Update, which is consistent with the
growth projections evaluated in the General Plan EIR, would result in the increase in
permanent noise levels as a result of increased growth (and, therefore, vehicle trips)
within the Town. However, the Housing Element Update’s increase in vehicle trips and
associated noise levels have already been evaluated in the General Plan EIR.
Development associated with the Housing Element Update would be required to comply
with applicable General Plan polices such as Policy MOB-2.6, which requires that all
development with a frontage greater than 300 feet to provide through-access for bicyclists
and pedestrians to adjacent developments, paths, or bicycle facilities, and Policy MOB-
6.7, which requires that all new development to provide bus shelters and ongoing
maintenance as part of their developments, when appropriate, to encourage public transit
use. Implementation of the applicable General Plan policies would help reduce vehicle
trips and, therefore, reduce impacts related to traffic noise levels as a result of
development associated with the Housing Element Update to a less-than-significant level.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
generate substantial temporary or permanent increases in ambient noise levels.
b. Construction of individual projects facilitated by the General Plan could intermittently
generate groundborne vibration on and adjacent to construction sites. Development
under the General Plan, as discussed in Section 4.12, Noise, would be required to comply
with the permitted construction timing identified in the Town’s Municipal Code Section
16.20.035, which allows construction noise between the hours of 8:00AM and 6:00PM on
weekdays and between 9:00AM and 4:00PM on Saturdays with a valid Town permit.
However, the General Plan does not include any goals or policies that pertain specifically
Section C Evaluation of Environmental Impacts 71 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
to vibration. The Housing Element update is consistent with the growth projections
evaluated in the General Plan EIR and would be required to implement Mitigation
Measure N-2 in order to reduce vibration impacts to a less-than-significant level (Town
of Los Gatos 2021, p. 4.12-17).
Mitigation Measure
N-2 The Town shall include the following measures as standard conditions of
approval for applicable projects involving construction to minimize exposure to
construction vibration:
1.Avoid the use of pile drivers and vibratory rollers (i.e., compactors) within 50
feet of buildings that are susceptible to damage from vibration.
2.Schedule construction activities with the highest potential to produce
vibration to hours with the least potential to affect nearby institutional,
educational, and office uses that the Federal Transit Administration identifies
as sensitive to daytime vibration (FTA 2006).
3.Notify neighbors of scheduled construction activities that would generate
vibration.
Development associated with the Housing Element Update would result in the
generation of vibration during construction activities and require the compliance with the
Town’s Municipal Code Section 16.20.035 to restrict construction activities to the
daytime when sensitive receptors are awake and less sensitive to vibrations. Because the
General Plan does not include any goals or policies that pertain specifically to vibration,
development associated with the Housing Element Update, which is consistent with the
growth projections evaluated in the General Plan EIR, would be required to implement
Mitigation Measure N-2 in order to reduce vibration impacts to a less-than-significant
level.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to vibration.
c. Refer to the discussion under checklist question “e” within Section 9.0, Hazards and
Hazardous Materials. No impacts would occur as a result of development under the
Housing Element Update, associated with airports and airstrips.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to noise levels and airports and airstrips.
Section C Evaluation of Environmental Impacts 72 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
14. POPULATION AND HOUSING
Would the project:
Comments:
a. The General Plan would result in the increase in population within the Town by 7,584
persons (General Plan page 3-5). However, Section 4.13, Population and Housing, of the
General Plan EIR states that growth under the General Plan would also result in more
balanced jobs-housing ratio by increasing housing availability. Therefore, such growth
would not result in any adverse effects associated with an increased imbalance of jobs and
housing in the Town. A fundamental purpose of the General Plan is to direct future
development in such a way that preserves the character of the Town while minimizing
pressure to development on the remaining open space in the Town and directing growth
and redevelopment to infill areas. Therefore, impacts from development under the
General Plan on unplanned population growth would be less than significant (Town of
Los Gatos 2021, p. 4.13-7).
The Housing Element Update involves the potential construction of up to 2,312 housing
units, which would result in the increase in the Town’s population, which is within the
General Plan population projection of 7,584. Development associated with the Housing
Element Update has been evaluated in the General Plan EIR and anticipated by the
General Plan; therefore, the population growth was planned. One of the primary
purposes of the General Plan is to guide growth and development in the Town such that
infill development would be prioritized and open space areas would be preserved and
enhanced; therefore, by its nature, the General Plan is intended to reduce the potential for
uncontrolled growth and associated environmental impacts (p. 5-1). Development
associated with the Housing Element Update is consistent with the growth projections
evaluated in the General Plan EIR and, therefore, would not result in substantial
unplanned population growth in an area, either directly or indirectly.
The General Plan EIR adequately addressed the Housing Element Update’s impacts
associated with population growth.
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a. Induce substantial unplanned population growth in an
area, either directly (e.g., by proposing new homes and
businesses) or indirectly (e.g., through extension of
roads or other infrastructure)?
☐ ☐ ☐ ☒
b. Displace substantial numbers of existing people or
housing, necessitating the construction of replacement
housing elsewhere?
☐ ☐ ☒ ☐
Section C Evaluation of Environmental Impacts 73 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
b. The General Plan facilitates development in the Town that promotes infill development
and redevelopment of underutilized parcels. The new units facilitated by the General
Plan would be in accordance with state and local housing requirements. The General
Plan EIR explains in Section 4.13, Population and Housing, that the General Plan
contains several goals and policies that provide guidance on maintaining neighborhood
cohesiveness through the anticipated growth that would be required to be implemented.
Because the number of new dwelling units would not displace existing residents, and
because the policies of the General Plan promote infill development and preservation of
existing neighborhoods, impacts would be less than significant (Town of Los Gatos 2021,
p. 4.13-9).
Several of the sites associated with the Housing Element Update would require the
demolition of existing residences and, therefore, the displacement of existing people
(Town of Los Gatos October 2022c, Appendix H). However, the primary objective is to
construct new housing to meet the Town’s regional fair share of new housing. The loss
of existing housing would be substantially mitigated by the number of new housing units
constructed with implementation of the Housing Element Update. Therefore, the
Housing Element Update would result in less than significant impacts associated with the
necessary construction of replacement housing elsewhere.
The General Plan EIR adequately addressed the Housing Element Update’s impacts
associated with the displacement of people or housing.
Section C Evaluation of Environmental Impacts 74 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
15. PUBLIC SERVICES
Would the project result in substantial adverse physical impacts associated with the provision of
or need for new or physically altered governmental facilities, the construction of which could
cause significant environmental impacts, in order to maintain acceptable service ratios, response
times, or other performance objectives for any of the following public services:
Comments:
a. The Town is served by the Santa Clara County Fire Department. The Housing Element
Update would result in the increase in population, which would increase the demand on
fire services. Therefore, potential impacts to the Santa Clara County Fire Department
may occur and require the need for new or physically altered facilities, the construction of
which could cause significant environmental impacts.
The General Plan EIR (Section 4.14, Public Service and Recreation) states that new
development under the General Plan would be required to comply with all applicable
federal, state, and local regulations governing the provision of fire services, including
adequate fire access, fire flows, and number of hydrants. In addition, consistency with
the current California Fire Code is required. The Santa Clara County Fire Department
would review building and facility plans through the Town’s development review and
building permit processes and the Department’s personnel would also inspect new and
remodeled buildings and facilities to ensure that the structures meet state and local fire
codes and standards (p. 4.14-20). The General Plan EIR notes that given the demand for
fire services in the Town, staffing needs are likely to increase, which could require the
construction of new facilities. However, it is determined that the location and potential
impacts of new or expanded facilities are unknown and separate environmental review
would be required to determine the evaluation of the physical effects of such activities.
New development would also be required to pay fees as determined by the Town
pursuant to the Municipal Code Sections 9.30.745 and 9.30.750 for fire protection and
contribute their fair share to the cost of funding Town fire services.
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a.Fire protection?☐ ☐ ☒ ☐
b. Police protection?☐ ☐ ☒ ☐
c. Schools?☐ ☐ ☒ ☐
d.Parks?☐ ☐ ☐ ☒
e.Other public facilities?☐ ☐ ☐ ☒
Section C Evaluation of Environmental Impacts 75 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Development under the General Plan would be required to comply with General Plan
Policy PFS-19.3, which requires that new development incorporate adequate emergency
water flow, fire resistant design and materials, and evacuation routes; Policy PFS-19.4,
which requires that new development provide accessibility to emergency vehicles and
don’t impede the ability of service providers to provide adequate emergency response;
Policy PFS-20.3, which requires that new development satisfy fire flow and hydrant
requirements and other fire-related design requirements as established by the Town and
recommended by the Santa Clara County Fire Department; and Policy 20.4, which
requires that new development and remodels comply with California Fire and Building
Code requirements for the installation of interior emergency sprinkler systems, fire-
resistant building materials, early warning systems and sufficient water supply systems for
fire suppression. New fire services facilities that would be constructed in the Town
would require project-specific environmental analysis and implementation of any
necessary project-specific mitigation prior to being considered for approval. The General
Plan EIR concludes that compliance with General Plan policies and applicable state
regulations, as well as payment of Town-required public facilities fees, would ensure that
impacts associated with fire services would be less than significant (p. 4.14-23).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR. Therefore, compliance with the above-
mentioned General Plan policies and applicable state regulations would be required, as
well as payment of its fair share for funding the Town’s fire services. Further, as each site
associated with the Housing Element Update is considered for development, project-
specific environmental analysis would be required. The General Plan EIR adequately
addressed the potential impacts of the Housing Element Update on the Town’s fire
services and, therefore, less than significant impacts would occur associated with the
Housing Element Update.
b. The Town is served by the Los Gatos-Monte Sereno Police Department. The Housing
Element Update would result in the increase in population, which would increase the
demand on police protection services. Therefore, potential impacts to the Los Gatos-
Monte Sereno Police Department may occur and require the need for new or physically
altered facilities, the construction of which could cause significant environmental impacts.
The General Plan EIR (Section 4.14, Public Service and Recreation) states that new
development under the General Plan would be required to comply with all applicable
federal, state, and local regulations governing the provision of police services. The
General Plan EIR notes that given the demand for police services in the Town, staffing
needs are likely to increase, which could require the construction of new facilities.
However, it is determined that the location and potential impacts of new or expanded
facilities are unknown and separate environmental review would be required to determine
the evaluation of the physical effects of such activities.
Section C Evaluation of Environmental Impacts 76 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
New police services facilities that would be constructed in the Town would require
project-specific environmental analysis and implementation of any necessary project-
specific mitigation prior to being considered for approval. The General Plan EIR
concluded that development under the General Plan would result in less than significant
impacts associated with the potential impacts of construction of police protection
facilities (p. 4.14-23).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR. Therefore, it would be speculative to
evaluate physical impacts of the Housing Element Update associated with police services
because the location and timing for development is unknown. As each site associated
with the Housing Element Update is considered for development, project-specific
environmental analysis would be required. The Housing Element Update would also be
required to comply with applicable federal, state and local regulations governing the
provision of police services. The General Plan EIR adequately addressed the potential
impacts of the Housing Element Update on the Town’s police services and, therefore, the
Housing Element Update would result in less than significant impacts associated with the
environmental effects related to the potential construction of new police facilities.
c. The Town of Los Gatos is served by six different school districts: Los Gatos Union
School District, Los Gatos-Saratoga Joint Union High School District, Campbell Union
School District, Campbell Union High School District, Cambrian Union Elementary
School District, and Union Elementary School District. The Housing Element Update
would be served by all but the Campbell Union School District and Union Elementary
School (Los Gatos Union School District 2022) (Los Gatos-Saratoga Joint Union High
School District 2022) (Campbell Union School District 2022) (Campbell Union High
School District 2022) (Cambrian School District 2022) (Union Elementary School
District 2022).
The General Plan EIR (Section 4.14, Public Service and Recreation) determined that
buildout of the General Plan would result in the increase of enough students that all
school districts serving the Town would need to add or expand facilities to meet the
needs of the projected student population in 2040. However, the General Plan EIR
concluded that all future development associated with the General Plan would be
required to pay school impact fees which, pursuant to Section 65995(3)(h) of the
California Government Code (Senate Bill 50), would reduce impacts to a less-than-
significant level (p. 4.14-23).
The Housing Element Update would generate 1,619 students (2,312 x 0.70) based upon
the student generation rate in the General Plan EIR (page 1.14-22) and, therefore, increase
the demand on the school districts serving the sites associated with the Housing Element
Update. The increase in demand on these school districts could result in the need for new
or expanded school facilities, the construction of which could cause adverse
environmental effects. However, development associated with the Housing Element
Update is consistent with the growth projections evaluated in the General Plan EIR and,
Section C Evaluation of Environmental Impacts 77 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
therefore, would be required to pay its fair share of school impact fees, which would
offset the increased demand of developments on the school facilities resulting in less than
significant impacts.
The General Plan EIR adequately addressed the Housing Element Update’s impacts on
the Town’s existing school facilities.
d.According to the General Plan EIR (Section 4.14, Public Service and Recreation), the
Town contains approximately 254 acres of parkland, nearly 7 miles of multi-use trails and
over 65 acres of lawn area. The Town’s parkland goal, pursuant to General Plan Policy
6.7, is 5 acres per 1,000 population. The Town, at preparation of the General Plan EIR,
exceeded this goal by providing 6.2 acres per 1,000 residents (p. 4.14-24). The General
Plan EIR also states that the Town would exceed the Quimby Act’s parkland ratio of 3
acres per 1,000 residents with buildout of the General Plan (p. 4.14-26).
Development consistent with the General Plan is required to comply with General Plan
Policy OSP-4.5, which requires that all residential developments provide permanent
common recreation space and Policy OSP-7.8, which encourages new multi-family
residential developments of eight units or more to include tot lots or similar shared off-
street recreation space for young children. According to the General Plan EIR,
implementation of applicable General Plan policies would ensure that growth in the
Town would not result in adverse environmental effects associated with parks and
recreational facilities. Additionally, because buildout of the General Plan would exceed
the Quimby Act’s parkland ratio of 3 acres per 1,000 residents, it would not contribute to
the need for new or expanded park or recreational facilities.
The Housing Element Update could result in the addition of approximately 5,780 people
and therefore, to be consistent with the Town’s parkland goal (General Plan Policy
OSPR-6.7), would require approximately 29.6 acres of parkland. However, development
associated with the Housing Element Update was evaluated in the General Plan EIR and
anticipated by the General Plan. As stated previously, the General Plan EIR concluded
that buildout of the General Plan would not require the construction of new or expanded
park facilities. Therefore, development associated with the Housing Element Update
would be required to comply with both General Plan Policies OSP-4.5 and OSP-7.8 and
would not result in the need for new or expanded parks or recreational facilities.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts on parks and recreational facilities.
e.The General Plan EIR (Section 4.14, Public Service and Recreation) also evaluates the
impacts of development under the General Plan on the Town’s public library facilities.
The Town of Los Gatos is the primary service provider for library services, with one
public library located within the Town’s Civic Center complex. The El Camino Hospital
operates a Health Library and Resource Center at its Los Gatos campus on the main floor
with the purpose of helping patients, families, and the community access resources and
information to make informed choices about their health. Affiliation with El Camino
Hospital is not required to use its library resources.
Section C Evaluation of Environmental Impacts 78 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
According to the General Plan EIR, the existing library is estimated to be able to meet
the demand from an increase in population as a result of buildout of the General Plan
and impacts would be less than significant (p. 4.14-23). Development associated with the
Housing Element Update is consistent with the growth projections evaluated in the
General Plan EIR and, therefore, the increase in demand on the Town’s library facilities
as a result of the Housing Element Update would not result in the need for new or
expanded facilities, the construction of which could cause environmental effects.
The General Plan EIR adequately addresses the Housing Element Update’s potential to
impact library facilities in the Town.
Section C Evaluation of Environmental Impacts 79 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
16. RECREATION
Comments:
a, b. Refer to the discussion in Section 15.0, Public Services, under checklist question “d.”
The General Plan EIR (Section 4.14, Public Service and Recreation) concluded that
implementation of the applicable General Plan policies would ensure that growth in the
Town consistent with the General Plan would not result in adverse environmental effects
associated with the physical deterioration of public parks and recreational facilities.
Additionally, the General Plan EIR concluded that the Town would exceed the Quimby
Act parkland ratio of 3 acres for every 1,000 residents at buildout of the General Plan
(p. 4.14-26).
The Housing Element Update is consistent with the growth projections evaluated in the
General Plan EIR and would be required to comply with General Plan Policy OSP-4.5
(all residential developments provide permanent common recreation space) and Policy
OSP-7.8 (new multi-family residential developments of eight units or more include tot
lots or similar shared off-street recreation space for young children). Therefore, the
Housing Element Update would not result in the physical deterioration of recreational
facilities or require the construction or expansion of recreational facilities, the
construction of which could cause significant environmental impacts.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts on recreational facilities.
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a. Would the project increase the use of existing
neighborhood and regional parks or other recreational
facilities such that substantial physical deterioration of
the facility would occur or be accelerated?
☐ ☐ ☐ ☒
b. Does the project include recreational facilities or
require the construction or expansion of recreational
facilities, which might have an adverse physical effect
on the environment?
☐ ☐ ☐ ☒
Section C Evaluation of Environmental Impacts 80 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
17. TRANSPORTATION
Would the project:
Comments:
a.Transit. According to the General Plan EIR (Section 4.15, Transportation), buildout of
the General Plan would increase the number of potential transit users on the various
transit systems serving the Town, which would increase the demand for transit.
Additionally, roadway traffic congestion caused from population and employment growth
in the Town facilitated by the General Plan could affect several transit corridors by
increasing travel times and decreasing headway reliability for transit vehicles (p 4.15-19).
Development under the General Plan would be required to comply with the objectives of
the Valley Transportation Plan 2040, which is the long-range Santa Clara County-wide
transportation plan adopted by the Valley Transportation Authority. The General Plan
EIR states that although the General Plan would increase ridership and potentially cause
more traffic delays, the existing transit circulation would be maintained, consistent with
the Valley Transportation Plan 2040.
There are several General Plan policies and goals that would support reducing traffic
congestion and improving transit connectivity such as Policy MOB-1.1, which requires
that all development and redevelopment proposals with more than 10 housing units or
over 5,000 square feet of non-residential square footage to include a detailed, sustainable,
and measurable Transportation Demand Management program with accountability
requirements to ensure that its measures are achieved; Policy MOB-1.3, which requires
development near transit stops to provide Transportation Demand Management
programs or facilities that encourage transit use for all types of trips; and Policy MOB-
6.7, which requires all new developments to provide bus shelters and ongoing
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a.Conflict with a program, plan, ordinance, or policy
addressing the circulation system, including transit,
roadway, bicycle and pedestrian facilities?
☒ ☐ ☐ ☐
b.Conflict or be inconsistent with CEQA guidelines
section 15064.3, subdivision (b)?☒ ☐ ☐ ☐
c. Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
☐ ☐ ☐ ☒
d.Result in inadequate emergency access?☐ ☐ ☐ ☒
Section C Evaluation of Environmental Impacts 81 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
maintenance as part of their developments, when appropriate, to encourage public transit
use. Implementation of these General Plan policies would encourage an increase in
transit ridership, decrease dependence on motor vehicles and reduce transit delays.
However, according to the 2040 General Plan Revised Sections of the General Plan EIR
(Section 4.15, Transportation Revised, p. 4.15-24), development under the General Plan
does not include actions to increase the cost of using vehicles and does not include
provisions for bus services to avoid congestion delays. As a result, transit service will
experience reductions in quality of experience inconsistent with General Plan policies,
which could contribute to lower transit demand in the future and higher demand for
vehicle use contributing to higher VMT levels. Because the needed additional transit
vehicles and supporting infrastructure may not be provided to accommodate additional
transit demand, the General Plan would have a potentially significant impact on transit
ridership. Development under the General Plan would also result in a significant and
unavoidable effect on transit vehicle operations even with improvements such as signal
coordination and transit vehicle preemption, which could potentially improve the overall
reliability of transit in congested areas but not to the level that would fully address this
impact.
The changes to the vehicle circulation system as part of the development under the
General Plan would not interfere with existing transit facilities nor conflict with planned
transit facilities and services or conflict with adopted transit plans, guidelines, policies or
standards.
The Housing Element Update would result in the increase in population, which would
increase the demand on the transit system. Development associated with the Housing
Element Update is consistent with the growth projections evaluated in the General Plan
EIR. The Housing Element Update would be required to comply with the applicable
General Plan policies identified above to reduce its potential to conflict with the existing
transit facilities or adopted transportation plans, guidelines, policies, or standards
associated with the Town’s transit network. However, the Housing Element Update is
part of the significant and unavoidable cumulative transit impacts associated with the
General Plan. Therefore, development associated with the Housing Element Update,
which is consistent with the growth projections evaluated in the General Plan EIR, would
result in significant and unavoidable transit impacts.
The Town adopted its Statement of Overriding Conditions on June 30, 2022 and
determined that specific economic, legal, social, technological, mobility, or other
considerations, make infeasible the mitigation measures or project alternatives identified
in the General Plan Final EIR related to transportation.
Roadways. The General Plan includes modifications to existing street facilities to create
a more pedestrian- and bicycle-oriented street network. Although these modifications
would cause existing and future local and regional traffic to circulate differently, its
influence would be minimal because these roadway modifications would conform to state
and local standards and generally be implemented to improve circulation (Town of Los
Section C Evaluation of Environmental Impacts 82 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Gatos 2021, p. 4.15-21). Therefore, the General Plan would not be expected to interfere
or conflict with existing roadways facilities or adopted transportation plans, guidelines,
policies, or standards. Impacts would be less than significant (p. 4.15-21).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, would conform to state and
local standards to reduce any potential impacts that may occur on the roadway system by
development under the Housing Element Update. However, potential impacts on the
roadway system as a result of the Housing Element Update were evaluated in the General
Plan EIR and would be minimal. Therefore, development associated with the Housing
Element Update, which is consistent with the growth projections evaluated in the
General Plan EIR, would not result in the conflict with existing roadways facilities or
adopted transportation plans, guidelines, policies, or standards.
Bicycle Facilities. Development facilitated by the General Plan would increase the use
of bicycles on the road as a result of increasing the Town’s population. However, the
General Plan contains policies and goals that are designed to accommodate increased
bicycle demand such as Policy MOB-2.5, which requires that all new development be
designed to enhance the safety or convenience of bicycle use through the Town and
Policy MOB-2.6, discussed previously. Implementation of applicable General Plan
policies would encourage bicycling by improving bicycle connectivity within the Town’s
street network, consistent with the Town of Los Gatos Bicycle and Pedestrian Master Plan,
which provides guidance to improve the connectivity of the bicycle and pedestrian
network in the Town. Therefore, the General Plan EIR concludes that development
under the General Plan would have a beneficial effect on bicycle circulation and access
and result in less than significant impacts related to the conflict with existing bicycle
facilities or adopted plans, guidelines, policies, or standards associated with the Town’s
bicycle network (p. 4.15-22).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and would not result in significant adverse
impacts related to the existing bicycle facilities within the Town. The Housing Element
Update would implement applicable General Plan policies, such as those listed above, and
is required to be consistent with the goals and objectives of the Town of Los Gatos Bicycle
and Pedestrian Master Plan. Therefore, development associated with the Housing Element
Update would not result in the conflict with existing bicycle facilities or adopted plans,
guidelines, policies, or standards associated with the Town’s bicycle network.
Pedestrian Facilities. Implementation and buildout of the General Plan would increase
residency in the Town, which could result in more use and demand on existing pedestrian
facilities. According to the General Plan EIR, the General Plan encourages walking by
improving pedestrian facilities and connectivity with a safe and continuous pedestrian
network to shorten walking distances and improve pedestrian connections to popular
local destinations. Development under the General Plan would create new pedestrian
facilities and have a beneficial effect on pedestrian circulation and access consistent with
Section C Evaluation of Environmental Impacts 83 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
the Town of Los Gatos Bicycle and Pedestrian Master Plan (p. 4.15-22). The General Plan EIR
concludes that the General Plan would not interfere with existing or planed pedestrian
facilities or adopted pedestrian system plans, guidelines, policies or standards and impacts
would be less than significant (p. 4.15-23).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and would not result in significant adverse
impacts related to the existing pedestrian facilities within the Town. The Housing
Element Update would be consistent with the goals and objectives of the Town of Los
Gatos Bicycle and Pedestrian Master Plan and, consistent with the growth projections
evaluated in the General Plan EIR, would not result in the conflict with existing
pedestrian facilities or adopted plans, guidelines, policies, or standards associated with the
Town’s pedestrian network.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
conflict with a program, plan, ordinance, or policy addressing the circulation system,
including transit, roadway, bicycle and pedestrian facilities.
b. The population and employment growth facilitated from development envisioned in the
General Plan would generate new vehicle trips. The land use pattern and policies
identified within the General Plan are expected to result in reduced vehicle miles traveled
(VMT) per service population compared to existing conditions. The General Plan EIR
(Section 4.15, Transportation) determined that the General Plan-generated VMT per
service population would be 38.4, which is approximately 19 percent greater than the
applicable VMT threshold of 32.3 (as identified in Table 4.15-2 of the General Plan EIR).
Therefore, the General Plan’s VMT per service population would exceed the applicable
threshold and the following mitigation measure is required.
Mitigation Measure
T-1 For projects that would generate vehicle miles traveled (VMT), one or more VMT
reduction strategies included in the SB 743 Implementation Decisions for the Town of
Los Gatos (July 2020) document shall be required to reduce VMT of the project.
Examples of VMT reduction strategies that shall be implemented are provided
below. The VMT reduction strategies are organized by their relative scale for
implementation (i.e., individual site level, Town-wide level, and regional level).
Individual Site Level
Encourage Telecommuting and Alternative Work Schedules: This strategy
relies on effective internet access and speeds to individual project
sites/buildings to provide the opportunity for telecommuting. This strategy
would reduce commute VMT but also result in a change in VMT for other
travel purposes; thus, this strategy should consider the net change in the
Town’s project-generated VMT.
Section C Evaluation of Environmental Impacts 84 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Provide Ride-Sharing Programs: This strategy focuses on encouraging
carpooling and vanpooling by project site/building tenants.
Provide Local Shuttles: This strategy focuses on providing local shuttle
service. The local shuttles would provide service to transit hubs, schools,
commercial centers, and residential areas to improve transit connectivity and
address the “first/last mile” problems. Alternatively, a demand responsive
service could be provided as subsidized trips by contracting to private
transportation network companies or taxi companies. Note that
implementation of this strategy would require regional or local agency
implementation.
Provide Employer-Sponsored Vanpool/Shuttle: This strategy relies on
employers purchasing or leasing vans or shuttles, and often subsidizing the
cost of at least program administration, if not more. Vanpools typically
service employee’s commute to work, while shuttles service nearby transit
stations and surrounding commercial centers. Scheduling and rider charges, if
any, are within the employer’s purview.
Town-wide Level
Provide Bicycle and Pedestrian Network Improvements: This strategy focuses
on creating a comprehensive bicycle and pedestrian network within the
project and connecting to nearby destinations. Projects in Los Gatos tend to
be smaller so the emphasis of this strategy would likely be the construction of
network improvements that connect the project site directly to nearby
destinations. Alternatively, implementation could occur through an impact
fee program or benefit/assessment district based on regional or local plans
such as the Bicycle and Pedestrian Master Plan and Connect Los Gatos.
Provide Traffic Calming Measures: This strategy combines the California Air
Pollution Control Officers Association (CAPCOA) research focused on
traffic calming with new research on providing a low-stress bicycle network.
Traffic calming creates networks with low vehicle speeds and volumes that are
more conducive to walking and bicycling. Building a low-stress bicycle
network produces a similar outcome. One potential change in this strategy
over time is that ebikes (and e-scooters) could extend the effective range of
travel on the bicycle network, which could enhance the effectiveness of this
strategy.
Implement Car-Sharing Program: This strategy reduces the need to own a
vehicle or reduces the number of vehicles owned by a household by making it
convenient to access a shared vehicle for those trips where vehicle use is
essential. Examples include programs like ZipCar, Car2Go, and Gig.
Section C Evaluation of Environmental Impacts 85 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Limit Parking Supply: When combined with companion transportation
demand management measures, reduced parking supply discourages driving
by limiting easy and convenient parking options. Implementation of this
strategy may require reducing (or removing) minimum parking requirements
and allowing developers to use shared parking strategies.
Unbundle Parking Costs from Property Cost: Unbundling separates parking
costs from property cost, for instance by not including a parking space in a
residential unit’s rent, or by requiring employers to lease each parking space
separately from the building owner. This strategy ensures that the user
understands that the cost of driving includes parking and can encourage
people to use an alternative mode to save money.
Implement Market Price Public Parking (On-Street): This strategy focuses on
implementing a pricing strategy for parking by pricing all on-street parking in
central business districts, employment centers, and retail centers. Priced
parking would encourage “park once” behavior and may also result in area-
wide mode shifts.
Regional Level
Increase Density: This strategy focuses on increasing density of land uses,
where allowed by the General Plan and/or Zoning Ordinance, to reduce
distances people travel and provide more travel mode options. This strategy
also provides a foundation for many other strategies. For example,
densification increases transit ridership, which justifies enhanced transit
service.
Increase Diversity of Urban and Suburban Developments: This strategy
focuses on inclusion of mixed uses within projects or in consideration of the
surrounding area to minimize vehicle travel in terms of both the number of
trips and the length of those trips.
Increase Transit Accessibility: This strategy focuses on encouraging the use of
transit by locating a project with high density near transit. A project with a
residential/commercial center designed around a bus station is referred to as a
transit-oriented development (TOD).
Integrate Affordable and Below Market Rate Housing: This strategy provides
greater opportunities for lower income families to live closer to job centers
since income effects probability that a commute will take transit or walk to
work.
Increase Transit Service Frequency/Speed: This strategy focuses on
improving transit service convenience and travel time competitiveness with
driving. Given existing land use density in Los Gatos, this strategy may be
limited to traditional commuter transit where trips can be pooled at the start
Section C Evaluation of Environmental Impacts 86 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
and end locations, or it may require new forms of demand-responsive transit
service. Note that implementation of this strategy would require regional or
local agency implementation, substantial changes to current transit practices,
and would not likely be applicable for individual development projects.
Implement Area or Cordon Pricing: This strategy focuses on implementing a
cordon (i.e., boundary) pricing scheme, where a cordon is set around a
specific area to charge a toll to enter the area by vehicle. The cordon location
is usually the boundary of an area with limited points of access. The cordon
toll may be constant, applied during peak periods, or be variable, with higher
prices during congestion peak periods. The toll can also be based on a fixed
schedule or be dynamic, responding to real-time congestion levels. Note that
implementation of this strategy requires alternative modes of travel that are
available and reliable, such as high-quality transit infrastructure.
As concluded in the General Plan EIR, the VMT reduction strategies at the regional level
would be required in order to reduce VMT per service population by 19 percent.
However, this would require action on multiple agencies and municipalities in South San
Francisco Bay. Because the Town cannot ensure that the other municipalities would
participate in the regional VMT reduction strategies outlined in Mitigation Measure T-1, it
is not certain that a 19 percent reduction in VMT would be achieved. Therefore, VMT
impacts as a result of development under the General Plan would be significant and
unavoidable even after implementation of mitigation (p. 4.15-26).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and would generate new vehicle trips.
However, development associated with the Housing Element Update is part of the
significant and unavoidable cumulative VMT impacts associated with the General Plan.
Therefore, development associated with the Housing Element Update, which is
consistent with the growth projections evaluated in the General Plan EIR, would result in
significant and unavoidable VMT impacts even after implementation of Mitigation
Measure T-1. Development associated with the Housing Element Update would be
required to implement applicable reduction strategies in Mitigation Measure T-1.
The Town adopted its Statement of Overriding Conditions on June 30, 2022 and
determined that specific economic, legal, social, technological, mobility, or other
considerations, make infeasible the mitigation measures or project alternatives identified
in the General Plan Final EIR related to transportation.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to VMT impact.
c. As discussed in the General Plan EIR (Section 4.15, Transportation), the General Plan is
a program-level document that does not directly address project-level design features or
building specifications. However, the Town maintains improvement standards that guide
construction of new transportation facilities to minimize design hazards for all users of
Section C Evaluation of Environmental Impacts 87 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
the system. Developments that would add traffic to streets that are not designed to
current standards would be evaluated in the environmental review process with mitigation
measures, if necessary, requiring the development to construct, or provide funding for, an
improvement that would minimize or eliminate the hazard. New and upgraded roadways
needed to accommodate new development would be designed according to applicable
federal, state, and local design standards. The General Plan EIR also states that
development and infrastructure projects would be required to implement applicable
General Plan policies intended to result in roadway designs that safely accommodate all
users such as General Plan Policy MOB-2.6, which is described previously under checklist
question “a” and Policy MOB-8.3, which requires that new development minimize the
number of access points along arterial streets to minimize impacts on circulation flow and
safety. Therefore, the General Plan EIR concludes impacts related to hazards due to a
geometric design feature would be less than significant (p. 4.15-29).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, any new or upgraded
roadways necessary to accommodate the new development would be designed according
to applicable, federal, state, and local design guidelines. Further, development under the
Housing Element Update would implement applicable General Plan policies, such as
those listed above, minimizing its impact on circulation flow and safety. The Housing
Element Update would not result in substantially increased hazards due to a geometric
design feature nor would it result in incompatible uses.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to hazards due to a geometric design feature.
d. The General Plan does not propose specific development projects and, therefore, does
not propose developments that could result in inadequate emergency access. According
to the General Plan EIR (Section 4.15, Transportation), the intent of the General Plan is
to improve the overall performance of the transportation network for all modes of
transportation; however, to further ensure that development under the General Plan
would not result in inadequate emergency access, applicable General Plan policies are
required to be implemented such as Policy MOB-12.2, which requires that secondary
emergency access is provided for new discretionary housing approvals in locations that
are identified as Very High Fire Hazard Areas on the Town’s Wildland Fire Severity Zone
Map. With implementation of applicable General Plan policies, future development
projects would be assessed to ensure they result in adequate emergency access. In
addition, mandatory development processes also require project review by emergency
services, including police and fire, to ensure projects maintain adequate emergency access.
This impact would be less than significant (Town of Los Gatos 2021, p. 4.15-30).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, is not proposing specific
development that could be evaluated as providing or not providing adequate emergency
access. However, as future development under the Housing Element Update is
proposed, they will be required to comply with applicable General Plan policies such as
Section C Evaluation of Environmental Impacts 88 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Policy MOB-12.2 identified above. Implementation of applicable General Plan policies
would ensure that future development associated with the Housing Element Update do
not result in impacts related to inadequate emergency access.
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to inadequate emergency access.
Section C Evaluation of Environmental Impacts 89 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
18. TRIBAL CULTURAL RESOURCES
Would the project:
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
Comments:
a. Pursuant to SB18, tribal noticing and consultation in accordance with statutory timelines
is required when a general plan is amended. The Town did not receive any requests from
California Native American tribes requesting consultation under Assembly Bill 52 for the
Housing Element Update or for the General Plan EIR. Further, according to the
General Plan EIR (Section 4.5, Cultural and Tribal Cultural Resources), no tribal cultural
resources have been identified within the planning area (which includes the Town limits
where all sites associated with the Housing Element Update are located) by a California
Native American tribe (p. 4.5-6).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and the General Plan EIR adequately
addresses the Housing Element Update’s impact on tribal cultural resources.
a. Cause a substantial adverse change in the significance
of a tribal cultural resource, defined in Public
Resources Code section 21074 as either a site, feature,
place, or cultural landscape that is geographically
defined in terms of the size and scope of the
landscape, sacred place, or object with cultural value
to a California Native American tribe, and that is:
(1) Listed or eligible for listing in the California Register
of Historical Resources, or in a local register of
historical resources as defined in Public Resources
code section 5020.1(k), or
☐ ☐ ☐ ☒
(2) A resource determined by the lead agency, in its
discretion and supported by substantial evidence, to
be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code Section
5024.1. In applying the criteria set forth in subdivision
(c) of Public Resource Code Section 5024.1, the lead
agency shall consider the significance of the resource
to a California Native American tribe.
☐ ☐ ☐ ☒
Section C Evaluation of Environmental Impacts 90 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
19. UTILITIES AND SERVICES SYSTEMS
Would the project:
Comments:
a. Water. According to the General Plan EIR (Section 4.16, Utilities and Service Systems),
expansion to the existing water system may be needed to service new development under
the General Plan, the construction of which could cause significant environmental
effects. However, it would be speculative to determine the impacts of development that
has not yet occurred about infrastructure improvements whose necessity, in addition to
location and type, are unknown at this time.
The General Plan EIR states that impacts from any required expansion of existing
infrastructure required by new development in the Town would be further analyzed
under separate CEQA review when determinations are made on the type, scope, and
location of the infrastructure improvements (p. 4.16-18). The General Plan EIR
determined that impacts would be less than significant (p. 4.18-19).
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a. Require or result in the relocation or construction of
new or expanded water, wastewater treatment, storm
water drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
☐ ☐ ☒ ☐
b. Have sufficient water supplies available to serve the
project and reasonably foreseeable future
development during normal, dry and multiple dry
years?
☐ ☐ ☒ ☐
c. Result in a determination by the wastewater treatment
provider, which serves or may serve the project that it
has inadequate capacity to serve the project’s
projected demand in addition to the provider’s
existing commitments?
☐ ☐ ☒ ☐
d. Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
☐ ☐ ☐ ☒
e. Comply with federal, state, and local management and
reduction statutes and regulations related to solid
waste?
☐ ☐ ☐ ☒
Section C Evaluation of Environmental Impacts 91 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Development associated with the Housing Element Update would result in the increase
in population and, therefore, an increase in demand on the Town’s existing water
facilities. However, it would be speculative at this time to determine the impacts related
to construction of new, or expansion of existing water facilities. Impacts from any
required expansion of existing infrastructure required by new development associated
with the Housing Element Update would be further analyzed under separate CEQA
review when determinations are made on the type, scope, and location of the
infrastructure improvements. The Housing Element Update’s impacts related to the
potential for expansion of existing or construction of new water facilities would be less
than significant.
Wastewater. The Town’s wastewater is collected and treated by the West Valley
Sanitation District, which then transports wastewater to the San Jose-Santa Clara
Regional Wastewater Facility (wastewater treatment plant). According to the General
Plan EIR (Section 4.16, Utilities and Service Systems), the wastewater treatment plant
treats an average of 110 million gallons per day (mgd), with a design capacity of up to 167
mgd.
The General Plan projects an increase of 8,971 residents, which the General Plan EIR
calculates to be a 30 percent increase above the 2018 population. However,
approximately 34 percent of the wastewater treatment plant capacity is available (67 mgd);
therefore, the wastewater needs of the expected population growth under the General
Plan would be met (Town of Los Gatos 2021, p. 4.16-19).
The sewer collection system within the Town has deficiencies that limit the amount of
wastewater that can be conveyed through the Town. According to the General Plan EIR,
the West Valley Sanitation District’s Capital Improvement Plan has ongoing plans for
replacement and upgrade of old sewer lines and lift equipment. The general maintenance
and correction of deficiencies are funded by user fees; therefore, new development would
be required to pay impact fees for system expansion that would accommodate the
increased growth of the Town envisioned as part of the General Plan. Impact fees on
new development would ensure that the wastewater collection system receives necessary
upgrades to accommodate the additional population (p. 4.16-20). In addition, the
implementation of the applicable General Plan policies under Goal PFS-2 would ensure
proper management of wastewater systems and infrastructure for new development and
redevelopment in the Town.
The ongoing upgrades to the sewer system under the capital improvement plan and the
General Plan would occur in developed areas of the Town that are previously disturbed
and ensure that adequate wastewater systems and infrastructure would be available to
meet future demands. Therefore, the General Plan EIR determined that the
environmental impacts of construction involved with upgrades to the Town’s wastewater
system would be less than significant (p. 4.16-20).
Development associated with the Housing Element Update would increase the
population in Los Gatos, which would increase the demand on the wastewater treatment
Section C Evaluation of Environmental Impacts 92 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
plant. However, the Housing Element Update is consistent with the growth projections
evaluated in the General Plan EIR and its population growth is encompassed within the
General Plan’s anticipated population growth of 8,971. As indicated previously, the
General Plan EIR has already evaluated the population growth projections associated
with the Housing Element Update. Therefore, the Housing Element Update’s increased
demand on the Town’s wastewater system would be adequately accommodated by the
remaining capacity within the wastewater treatment plant.
Development associated with the Housing Element Update would also increase the
amount of wastewater conveyed by the Town’s existing sewer collection system.
However, the Housing Element Update is consistent with the growth projections
evaluated in the General Plan EIR and, therefore, each development associated with the
Housing Element Update would be required to pay impact fees for system expansion
necessary to accommodate the increased growth. Payment of these impacts fees would
reduce potential impacts associated with the construction of new, or expansion of
existing, sanitary sewer system to a less-than-significant level.
Stormwater Drainage. Development facilitated by the General Plan would create new
impervious surfaces, which would result in increased stormwater runoff to the Town’s
municipal storm drain system. However, according to the General Plan EIR (Section
4.16, Utilities and Service Systems), the General Plan focuses on infill development,
which would reduce the amount of open space and permeable surfaces converted into
impervious surfaces. Further, the amount of new impervious surfaces would be reduced
through implementation of best management practices, including low impact
development approaches, aimed at reducing stormwater runoff to ensure downstream
storm drain capacity is not exceeded (Town of Los Gatos 2021, p. 4.16-21).
Because development would occur within urbanized areas of the Town, and best
management practices would be incorporated, the construction or expansion of existing
storm drain facilities would not likely be required as a result of implementation of the
General Plan. However, storm drain improvements or connections to existing storm
drains required for each individual project developed under the General Plan would be
further analyzed under separate CEQA review as part of each individual project. Impacts
related to storm drain facilities would be less than significant (Town of Los Gatos 2021,
p. 4.16-22).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, would primarily involve
infill development. Additionally, the Housing Element Update would be required to
implement best management practices and low impact development approaches to
reduce stormwater runoff and ensure that downstream storm drain capacities are not
exceeded. Development associated with the Housing Element Update would be required
to comply with General Plan Policy PFS-3.1, which requires that CEQA review analysis
occurs for all development projects consisting of single and cumulative impacts on water
drainage (runoff) and contamination (water quality) in all areas. Implementation of best
management practices and compliance with General Plan Policy PFS-3.1 would ensure
Section C Evaluation of Environmental Impacts 93 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
that the Housing Element Update’s impacts related to the potential for construction of
new storm drainage facilities would be less than significant.
Electricity/Natural Gas/Telecommunications. The General Plan EIR concluded
(page 4.16-22) that with implementation of the 2040 General Plan goals and policies,
impacts related to electric power, natural has, and telecommunication would be less than
significant.
Development facilitated by the General Plan would be required to implement the
applicable policies under General Plan Goal PFS-6 (encourage development that reduces
the use of non-renewable energy resources and expands the use of renewable resources
and alternative fuels) and Goal PFS-7 (promote green buildings that minimize
consumption of energy and natural resources). Implementation of the applicable General
Plan policies as well as required separate CEQA review for each individual project that
requires new connection to existing services would ensure that impacts related to the
construction of new, or expansion of existing, electricity, natural gas, or
telecommunications facilities would be less than significant (Town of Los Gatos 2021,
p. 4.16-22).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, would facilitate infill
development where existing electricity, natural gas, and telecommunications facilities
currently exist. Individual development associated with the Housing Element Update
would be required to connect into these existing facilities and the impacts of these new
connections would be determined under separate CEQA analysis at the time such
development is proposed (page 4.16-21). Therefore, development associated with the
Housing Element Update would comply with existing energy efficiency regulations as
well as implement applicable General Plan policies, and separate CEQA analysis would
occur at the time individual projects are proposed to determine the potential for impacts
associated with the new connections. For these reasons, the Housing Element Update
would result in less than significant impacts related to the potential for construction of
new, or expansion of existing, electricity, natural gas, and telecommunications facilities.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
require the expansion of existing or the construction of new water, wastewater,
stormwater drainage, electricity, natural gas, and/or telecommunications facilities, the
construction of which could cause significant environmental impacts.
b. San Jose Water Company is the water service provider for the Town and the Santa Clara
Valley Water District (Valley Water) manages the Santa Clara Valley Groundwater sub-
basin, which supplies approximately one-third of the Town’s water supply. During
preparation of the General Plan EIR, the San Jose Water Company was undergoing the
preparation of the 2020 Urban Water Management Plan. Therefore, the General Plan EIR
relied on the analysis within the 2015 Urban Water Management Plan.
Section C Evaluation of Environmental Impacts 94 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
According to the 2015 Urban Water Management Plan, the San Jose Water Company had
adequate water supply capacity to meet its demands through 2040, which included the
growth in the Town anticipated by the General Plan. Development under the General
Plan would result in the increase in residential and nonresidential uses, which would result
in an incremental increase in the Town’s water demand. As indicated in the 2015 Urban
Water Management Plan, the San Jose Water Company has sufficient supplies to support
development under the General Plan during a normal year. However, it was determined
that projected water demands would likely exceed supply totals in the event of a multiple
dry year scenario. Therefore, the San Jose Water Company would not have sufficient
water supply to accommodate the demand of development and the population increase
facilitated by the General Plan through 2040.
As a result, Section 4.16, Utilities and Service Systems, of the General Plan EIR explains
that the San Jose Water Company would enact its Water Shortage Contingency Plan,
which includes four stages of action based on water supply conditions. The Town would
also increase its reliance on recycled water supply and water conservation measures
implemented by the San Jose Water Company and the Valley Water reducing demands.
Additionally, the Town would impose water conservation tactics on new development to
further reduce water demand. Development under the General Plan would be required
to implement the polices associated with General Plan Goal PFS-1 (ensure an adequate
water supply for the Town’s human, wildlife, and plant populations), which are consistent
with the purpose of the 2015 Urban Water Management Plan to encourage the sustainable
use and management of water supplies and infrastructure in the Town. With reliance on
recycled water supply and water conservation measures, in addition to compliance with
applicable General Plan policies, impacts related to water supply would be less than
significant (p. 4.16-19).
Development associated with the Housing Element Update would result in the increase
of the residential population of the Town, which would increase the demand on water
supplies. Development associated with the Housing Element Update would be required
to implement General Plan Policy PFS-1, which requires that landscaping and
hardscaping for all development is designed to minimize water usage and enhance water
conservation; Policy PFS-1.2, which requires that all new home construction and
remodeled homes comply with the Bay-Friendly Landscaping Guidelines in addition to
the landscaping standards in the GreenPoint Rated Building Guidelines; Policy PSF-1.3,
which requires the use of water-saving devices in new developments and pumping-related
remodels; and Policy PFS-1.4, which requires that all new development install water-
efficient irrigation management systems and devices, such as evapotranspiration or soil
moisture-based irrigation controls.
In addition to compliance with the above-mentioned General Plan policies, the Housing
Element Update’s population growth was already evaluated in the General Plan EIR and
anticipated by the General Plan. Therefore, the Housing Element Update’s impacts
related to increased demand on the Town’s water supplies would be less than significant.
Section C Evaluation of Environmental Impacts 95 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
As previously mentioned, since the certification of the General Plan EIR and adoption of
the General Plan, the San Jose Water Company has adopted its 2020 Urban Water
Management Plan. The 2020 Urban Water Management Plan concluded that San Jose Water
Company anticipates adequate supplies to meet system demand under average year, single
dry year, and multiple dry year conditions through 2045 (San Jose Water Company 2021,
p. 7-11). However, there is the possibility for a call for a mandatory 20 percent
conservation during multi-year droughts (p. 7-12).
The General Plan EIR adequately addressed the Housing Element Update’s potential
impacts related to the Town’s water supplies.
c. Refer to the discussion about wastewater under checklist question “a.” The growth
envisioned in the General Plan would require an increase in wastewater capacity to meet
the treatment demand from new development; however, the wastewater treatment needs
of the General Plan, in addition to existing needs, would be met due to excess capacity
within the wastewater treatment plant. As for the wastewater collection system, ongoing
upgrades under the West Valley Sanitation District’s Capital Improvement Plan would
continue to occur and new development under the General Plan would be required to
pay impact fees for system expansion that would accommodate the increased growth in
the Town.
Therefore, Section 4.16, Utilities and Service Systems, of the General Plan EIR
determined that the growth envisioned by the General Plan would result in less than
significant impacts related to the West Valley Sanitation District’s ability to serve the
projected demand in addition to its existing commitments.
The Housing Element Update is consistent with the growth projections evaluated in the
General Plan EIR and, therefore, the increased wastewater demands associated with
development under the Housing Element Update have been evaluated by the General
Plan EIR. Therefore, the wastewater treatment needs of the Housing Element Update,
which is consistent with the growth projections evaluated in the General Plan EIR, would
be met by the excess capacity remaining within the wastewater treatment plant.
Development associated with the Housing Element Update would be required to pay
impact fees related to the expansion of the wastewater collection system that would
accommodate the increased growth in the Town anticipated by the Housing Element
Update. Therefore, the Housing Element Update would result in less than significant
impacts related to the West Valley Sanitation District’s ability to serve its increased
wastewater demand in addition to its existing commitments.
The General Plan EIR adequately addressed the Housing Element Update’s potential to
impact the West Valley Sanitation District’s ability to serve the projected demand of the
Housing Element Update in addition to its existing commitments.
d. Solid waste within the Town is disposed of at the Guadalupe Landfill, which is permitted
to accept 3,650 tons of material daily and is projected to reach capacity in 2048. Using
the residential disposal rates of the Santa Clara Integrated Waste Management Account,
Section C Evaluation of Environmental Impacts 96 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
residential buildout under the General Plan could result in the daily solid waste generation
of approximately 294,158 pounds per day (or approximately 147 tons per day).
Therefore, as discussed in Section 4.16, Utilities and Service Systems, of the General Plan
EIR, the residential demand in solid waste anticipated by the General Plan would increase
disposal at the Guadalupe Landfill by approximately one percent. Because the landfill has
a remaining capacity of 11,055,000 cubic yards, it would have sufficient capacity to
accommodate the General Plan’s residential increase in solid waste generation (Town of
Los Gatos, p. 4.16-23). Although there would be sufficient capacity, the General Plan
EIR also discusses the reduction in trash production and promotes recycling and
potentially introducing Townwide composting to reduce the amount of solid waste sent
to the Guadalupe Landfill. Implementation of the General Plan policies associated with
Goals PFS-4 and PFS-5 would help conserve space at the landfill and impacts would be
less than significant (Town of Los Gatos 2021, p. 4.16-24).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and its residential solid waste generation
has already been evaluated in the General Plan EIR. The General Plan’s residential solid
waste generation encompasses the total of residential solid waste generation that would
be created by the Housing Element Update. Therefore, because the General Plan EIR
concludes that the General Plan’s residential solid waste generation could be
accommodated by the Guadalupe Landfill, the solid waste generation as a result of the
Housing Element Update would also be accommodated. Development associated with
the Housing Element Update would also be required to implement the policies identified
under General Plan Goals PFS-4 and PFS-5 to help conserve space at the landfill. For
these reasons, the Housing Element Update would not generate solid waste in excess of
the capacity of local infrastructure.
The General Plan EIR adequately addresses the Housing Element Update’s potential
impacts related to solid waste generation.
e. The General Plan EIR (Section 4.16, Utilities and Service Systems) concludes that
implementation of the General Plan’s goals and policies would support the reduction and
diversion of waste consistent with state goals for solid waste reduction. Implementation
of applicable General Plan goals and policies would ensure that development under the
General Plan would comply with federal, state, and local management and reduction
statutes and regulations related to solid waste. Impacts would be less than significant
(Town of Los Gatos 2021, p. 4.16-24).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, would be required to
comply with applicable General Plan policies such as Policy PFS-4.1, which requires the
recycling of reusable materials from residential and construction/renovation activities.
Implementation of applicable General Plan policies would ensure that the Housing
Element Update complies with federal, state, and local management and reduction
statutes and regulations related to solid waste and no impacts would occur.
Section C Evaluation of Environmental Impacts 97 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
The General Plan EIR adequately addresses the Housing Element Update’s potential
impacts related to compliance with federal, state, and local regulations associated with
solid waste.
Section C Evaluation of Environmental Impacts 98 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
20. WILDFIRE
If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the project:
Comments:
The sites associated with the Housing Element Update that make up the “Downtown Area” are
located within lands classified as very high fire hazard severity zones in local responsibility areas
(CalFire 2022). Figure 3, Downtown Area Sites’ Fire Hazards, illustrates those sites associated
with the Housing Element Update that are within a very high fire hazard area.
a. The Santa Clara County Operational Area Hazard Mitigation Plan and the Santa Clara
County Community Wildfire Protection Plan include techniques for reducing wildfire risk
in the Town through land use decisions, inter-agency coordination, community programs,
and emergency response improvements. The General Plan Safety Element also directs
the Town to accommodate safety needs when planning and designing, while increasing
the resiliency of residents and businesses to respond to and be prepared for potential
emergencies and disasters.
The General Plan EIR (Section 4.17, Wildfire) states that all development consistent with
the General Plan shall comply with the applicable General Plan policies and the Santa
Clara County Fire Department shall review and approve all development projects to
ensure that emergency access meets standards. Compliance with such actions would
ensure that potential impacts from implementation of the General Plan on emergency
response and evacuation would be less than significant (p. 4.17-7).
Potentially Significant
Impact
Less-than-Significant Impact with Mitigation
Measures Incorporated
Less-Than- Significant
Impact
No Impact
a. Substantially impair an adopted emergency response
plan or emergency evacuation plan?
☐ ☐ ☒ ☐
b. Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to pollutant concentrations from a wildfire
or the uncontrolled spread of wildfire?
☐ ☐ ☐ ☒
c. Require the installation or maintenance of associated
infrastructure (such as roads, fuel breaks, emergency
water sources, power lines or other utilities) that may
exacerbate fire risk or that may result in temporary or
ongoing impacts to the environment?
☐ ☐ ☒ ☐
d. Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
☐ ☐ ☐ ☒
Source: Santa Clara County GIS 2022,Google Earth 2022, CalFire FHSZ 2022
Figure 3Downtown Area Sites’ Fire Hazards
0 500 ft
Downtown AreaParcels
Los GatosTown Limits Very High Fire Hazard Severity(Local Responsibility Area)
UV17
UV17
UV17
W. Mai
n
S
t
.University Ave.North Santa Cruz Ave.Sarat
o
g
a
-
L
o
s
G
a
t
o
s
R
d
.
Los Gatos 6th Cycle Housing Element Environmental Analysis
Section C Evaluation of Environmental Impacts 100 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
This side intentionally left blank.
Section C Evaluation of Environmental Impacts 101 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, each individual site to be
developed would require careful consideration of the adequacy of water storage for fire
protection during its development review process in compliance with General Plan Policy
HAZ-4.3. Additionally, the Santa Clara County Fire Department would be required to
review and approve each development project’s plans. Such actions would ensure that
the Housing Element Update’s potential impacts related to emergency evacuation and
emergency response plans are less than significant.
The General Plan EIR adequately addresses the Housing Element Update’s impacts
related to emergency response or emergency evacuation plans.
b. Prevailing winds in the Town generally blow southeast; therefore, a wildfire could
potentially be carried, as well as smoke and air pollutants, across or down the nearby east-
and north-facing slopes of the Santa Cruz Mountains into thick vegetation towards the
more urbanized areas of the Town (Town of Los Gatos 2021, p. 4.17-7 and -8).
The risk of wildfire in the Town is most prevalent for those areas of the Town within and
surrounding the Santa Cruz Mountains. However, the General Plan EIR (Section 4.17,
Wildfire) states that development under the General Plan would not introduce new
people or structures to these areas beyond what was already permitted by the previous
general plan. Therefore, compliance with applicable General Plan policies reducing
wildfire risks in the Town, in addition to the fact that the General Plan would not allow
for new development in areas that were not already permitted for development, the
General Plan would not exacerbate existing wildfire risks or expose project occupants to
pollutant concentrations from a wildfire and impacts would be less than significant
(Town of Los Gatos 2021, p. 4.17-8).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and, therefore, would be required to
comply with General Plan Policy HAZ-4.1, which requires that fire preventative site
design, access, fire-safe landscaping, and building materials, as well as the incorporation
of fire suppression techniques, occur in new development located in or adjacent to fire
hazard areas. Because development associated with the Housing Element Update was
evaluated in the General Plan EIR and anticipated by the General Plan, the Housing
Element Update would not exacerbate wildfire risks thereby exposing its occupants to
pollutant concentrations from a wildfire or the uncontrolled spread of wildfire.
The General Plan EIR adequately addressed the Housing Element Update’s impact
related to exacerbating wildfire risks and exposing occupants to pollutant concentrations
from a wildfire.
c. The General Plan EIR (Section 4.17, Wildfire) states that the General Plan would
facilitate strategic growth in the Town and would occur primarily as infill and
redevelopment within the urbanized areas of the Town. Therefore, the majority of roads
and utility infrastructure required for growth facilitated by the General Plan would be
Section C Evaluation of Environmental Impacts 102 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
existing or would occur in currently developed areas, resulting in negligible temporary or
ongoing environmental impacts. Because this development would occur in urbanized
areas of the Town, where large tracts of vegetation cover are not present, the risk of
wildfire would not be exacerbated (Town of Los Gatos 2021, p. 4.17-9). However,
portions of the Town’s southern incorporated areas lie within very high fire hazard
severity zones; therefore, potential development facilitated by the General Plan in these
areas would be subject to the latest California Fire Code, which includes safety measures
to minimize the threat from wildfire. In addition, compliance with applicable General
Plan policies that require the maintenance of fire roads throughout the Town and
adequate emergency response along the wildfire fuel monitoring would be required.
Maintenance and monitoring of wildfire fuel could generate temporary or ongoing
impacts related to noise and vegetation removal, but would occur infrequently and is
limited to the areas immediately next to fire access roads. Maintenance of these areas
would reduce the potential for severe or catastrophic wildfires, rather than exacerbate
them (p. 4.17-9). Therefore, the General Plan EIR concluded that impacts related to fire
protection-related infrastructure that may exacerbate fire risk would be less than
significant (p. 4.17-10).
Development associated with the Housing Element Update is consistent with the growth
projections evaluated in the General Plan EIR and would occur as infill and
redevelopment within the urbanized areas of the Town. The Housing Element Update
would be required to comply with the applicable regulations of the California Fire Code
as well as Title 14 of the California Code of Regulations, which sets forth the minimum
development standards for emergency access, fuel modification, setback, signage, and
water supply, which help prevent loss of structures or life by reducing wildfire hazards.
Because the maintenance and monitoring of wildfire fuel and the creation of fuel breaks
would be infrequent and occur in limited areas, the temporary or ongoing impacts related
to noise and vegetation removal would be considered less than significant. Therefore,
development associated with the Housing Element Update would result in less than
significant impacts related to the installation or maintenance of associated fire protection
infrastructure.
The General Plan EIR adequately addressed the Housing Element Update’s impacts
related to fire protection infrastructure and its potential to exacerbate fire risk.
d. As discussed in the General Plan EIR (Section 4.17, Wildfire), severe wildfires damage
the forest or shrub canopy, the plants below, and the soil, which can result in increased
runoff after intense rainfall putting homes and other structures below a burned area at
risk of localized floods and landslides. Slopes at risk of wildfire in Los Gatos are
primarily limited to the areas along the Santa Cruz Mountains and its foothills (p. 4.17-8).
As previously discussed, development consistent with the General Plan would not result
in more or increased development in the Santa Cruz Mountains or surrounding areas than
what has already been allowed by the previous general plan. Therefore, impacts related to
exposing people or structures to risks, including downslope or downstream flooding or
landslides as a result of runoff, post-fire instability, or drainage changes are determined by
the General Plan EIR to be less than significant (Town of Los Gatos 2021, p. 4.17-8).
Section C Evaluation of Environmental Impacts 103 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Development associated with the Housing Element Update would not be located outside
of the Town’s incorporated limits, where the slopes at the highest risk of wildfire are
located. In addition, because development associated with the Housing Element Update
was evaluated in the General Plan EIR and anticipated by the General Plan, the Housing
Element Update would not expose people or structures to significant risks, including
downslope or downstream flooding or landslides, as a result of runoff, post-fire slope
instability, or drainage changes.
The General Plan EIR adequately addressed the Housing Element Update’s impact
related to exposure of significant risks, including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slop instability, or drainage changes to people or
structures.
Section C Evaluation of Environmental Impacts 104 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
21. MANDATORY FINDINGS OF SIGNIFICANCE
Comments:
a. As discussed in Section 4.0, Biological Resources, special-status plant and wildlife species
are recorded as occurring in the riparian areas of the Town, but are not likely to occur in
the developed portions due to lack of suitable habitat. However, both the General Plan
and the Housing Element Update facilitates the increase in allowable density that could
occur on some of the infill and redevelopment sites within the Town, which could require
the upgrading of infrastructure facilities within riparian vegetation along creeks and
waterways. Additionally, development within proximity to vegetation cover could result
in new sources of light that affect nesting patterns or wildlife behavior. Therefore,
implementation of the General Plan’s applicable goals and policies, as well as compliance
with state and federal regulations related to special-status species and their habitats, would
ensure that impacts to special-status species and their habitats by development associated
with the General Plan and the Housing Element Update would be less than significant.
As discussed in Section 5.0, Cultural Resources, effects on cultural resources are only
knowable once a specific project has been proposed because the effects are dependent on
the individual project site conditions (page 4.5-10), project activities that may alter the
character of a built environment resources, and/or the characteristics of the proposed
ground-disturbing activity. Development associated with the Housing Element Update is
not anticipated to disturb known historic resources; however, ground-disturbing activities
have the potential to damage or destroy previously unknown historic or prehistoric
Potentially Significant Impact
Less-than-Significant Impact with Mitigation Measures Incorporated
Less-Than- Significant Impact
No Impact
a. Does the project have the potential to substantially
degrade the quality of the environment; substantially
reduce the habitat of a fish or wildlife species; cause a
fish or wildlife population to drop below self-
sustaining levels; threaten to eliminate a plant or
animal community; substantially reduce the number or
restrict the range of an endangered, rare, or threatened
species; or eliminate important examples of the major
periods of California history or prehistory?
☐ ☒ ☐ ☐
b.Does the project have impacts that are individually
limited, but cumulatively considerable? (“Cumulatively
considerable” means that the incremental effects of a
project are considerable when viewed in connection
with the effects of past projects, the effects of other
current projects, and the effects of probable future
projects)
☒ ☐ ☐ ☐
c. Does the project have environmental effects, which
will cause substantial adverse effects on human beings,
either directly or indirectly?
☐ ☒ ☐ ☐
Section C Evaluation of Environmental Impacts 105 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
archaeological resources that may be present on or below the ground surface.
Implementation of Mitigation Measure CR-1 would reduce impacts to a less-than-
significant level.
b. As described in Section 3.0, Air Quality, the Housing Element Update’s criteria air
pollutant emissions and their effects to air quality during construction would be reduced
to a less-than-significant level with implementation of Mitigation Measure AQ-1 and the
General Plan EIR concludes that the General Plan, which includes development
associated with the Housing Element Update, would not have a cumulatively
considerable contribution to regional air quality impacts.
The proposed development would result in temporary biological resource impacts during
construction associated with special-status species. However, as described in Section 4.0,
Biological Resources, construction impacts would be reduced to a less-than-significant
level with implementation of applicable General Plan policies. Therefore, development
associated with the Housing Element Update would not have a cumulatively considerable
impact on biological resources.
Section 5.0, Cultural Resources, concludes that earthmoving activities may result in the
loss of unknown prehistoric or historic subsurface archaeological resources onsite.
Because the development associated with the Housing Element Update would implement
Mitigation Measure CR-1, they would not have a cumulatively considerable impact on
cultural resources.
As discussed in Section 8.0, Greenhouse Gas Emissions, development associated with the
Housing Element Update will generate GHG emissions that will contribute to the
cumulative accumulation of GHG emissions is the atmosphere as its effects are not
localized to areas where they are produced. Climate change is a global phenomenon
resulting from the combined effects of GHG emissions produced worldwide.
Consequently, the analysis of climate change impacts from production of GHGs is
inherently cumulative in nature. (See Center for Biological Diversity v. Department of Fish &
Wildlife (2015) 62 Cal.4th 204, 219). However, even with mitigation measures, the
impacts would not be capable of being reduced to a less than cumulatively considerable
level and, therefore, impacts related to GHG are significant and unavoidable.
Section 13.0, Noise, concludes that development associated with the Housing Element
Update would result in temporary construction noise impacts. However, Mitigation
Measure N-1 would reduce impacts to a less-than-cumulatively considerable level.
c. Development associated with the Housing Element Update would have the potential to
expose sensitive receptors to construction toxic air contaminant emissions that can lead
to increased cancer risks that exceed the air district cancer risk thresholds.
Implementation of Mitigation Measure AQ-1 would reduce this impact to less than
significant. Construction noise and vibrations would also occur at buildout of the
General Plan and Housing Element Update; therefore, implementation of Mitigation
Measures N-1 and N-2 would be required to reduce impacts to a less-than-significant
level.
Section C Evaluation of Environmental Impacts 106 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
D. SOURCES
Environmental Setting/Background/Methodology
Town of Los Gatos. January 2011. Town of Los Gatos 2020 General Plan. Los Gatos, CA.
—. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Description of Proposal
California Department of Finance. May 2022. “E-5 Population and Housing Estimates for Cities,
Counties, and the State, January 2021-2022, with 2020 Benchmark.” Accessed on
October 24, 2022. https://dof.ca.gov/forecasting/demographics/estimates/e-5-
population-and-housing-estimates-for-cities-counties-and-the-state-2020-2022/
Town of Los Gatos. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update
– HCD Draft – Initial Review Period.
https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-Initial-Review-
Draft-Submittal-
Aesthetics
Caltrans. “California State Scenic Highway System Map.” Accessed on October 18, 2022.
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46
cc8e8057116f1aacaa
Google Earth. 2022.
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175. Los Gatos,
CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
Section C Evaluation of Environmental Impacts 107 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
—. June 2022. Los Gatos Municipal Code.
https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=THC
OTOLOGACA
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Agriculture
California Department of Conservation. “California Important Farmland Finder.” Accessed on
October 27, 2022. https://maps.conservation.ca.gov/DLRP/CIFF/
Google Earth. 2022.
Town of Los Gatos. January 2011. Town of Los Gatos 2020 General Plan. Los Gatos, CA.
—. November 2019. Town of Los Gatos Zoning Map. Los Gatos, CA.
—. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
Air Quality
Bay Area Air Quality Management District. April 2017. Final 2017 Clean Air Plan.
https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-air-
plan/attachment-a_-proposed-final-cap-vol-1-pdf.pdf?la=en
Town of Los Gatos. October 2012. Los Gatos Sustainability Plan. Los Gatos, CA.
https://www.losgatosca.gov/DocumentCenter/View/8162/LosGatosSustainability-
Plan_October-2012_201308121810582238?bidId=
—. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Section C Evaluation of Environmental Impacts 108 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Biological Resources
Santa Clara Valley Habitat Agency. August 2012. Final Santa Clara Valley Habitat Plan.
https://scv-habitatagency.org/178/Santa-Clara-Valley-Habitat-Plan
—. “Santa Clara Valley Habitat Agency Geobrowser.” Accessed on October 31, 2022.
http://www.hcpmaps.com/habitat/
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Cultural Resources
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
—. “Historic Districts.” Accessed on October 25, 2022d.
https://www.losgatosca.gov/1999/Historic-Districts
Energy
Town of Los Gatos. October 2012. Los Gatos Sustainability Plan. Los Gatos, CA.
https://www.losgatosca.gov/DocumentCenter/View/8162/LosGatosSustainability-
Plan_October-2012_201308121810582238?bidId=
—. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
Section C Evaluation of Environmental Impacts 109 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Geology and Soils
California Department of Conservation. “Earthquake Zones of Required Investigation.”
Accessed on October 19, 2022. https://maps.conservation.ca.gov/cgs/EQZApp/app/
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Greenhouse Gas Emissions
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Hazards and Hazardous Materials
Google Earth. 2022.
Section C Evaluation of Environmental Impacts 110 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Hydrology and Water Quality
San Jose Water Company. June 2021. 2020 Urban Water Management Plan. San Jose, CA.
https://www.sjwater.com/sites/default/files/2021-
06/2020%20UWMP%20FINAL%20with%20Appendices.pdf
Santa Clara Valley Water District. November 2021. 2021 Groundwater Management Plan for the Santa
Clara and Llagas Subbasins. San Jose, CA.
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. June 2022. Los Gatos Municipal Code.
https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=THC
OTOLOGACA
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Land Use and Planning
Association of Bay Area Governments. July 2017. Plan Bay Area 2040.
http://files.mtc.ca.gov/library/pub/30060.pdf
Bay Area Air Quality Management District. April 2017. Final 2017 Clean Air Plan.
https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-air-
plan/attachment-a_-proposed-final-cap-vol-1-pdf.pdf?la=en
Section C Evaluation of Environmental Impacts 111 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Town of Los Gatos. October 2012. Los Gatos Sustainability Plan. Los Gatos, CA.
https://www.losgatosca.gov/DocumentCenter/View/8162/LosGatosSustainability-
Plan_October-2012_201308121810582238?bidId=
—. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Mineral Resources
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. June 2022. Los Gatos Municipal Code.
https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=THC
OTOLOGACA
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Noise
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
Section C Evaluation of Environmental Impacts 112 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
—. June 2022. Los Gatos Municipal Code.
https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=THC
OTOLOGACA
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Population and Housing
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Public Services
California Department of Finance. May 2022. “E-5 Population and Housing Estimates for Cities,
Counties, and the State, January 2021-2022, with 2020 Benchmark.” Accessed on
October 24, 2022. https://dof.ca.gov/forecasting/demographics/estimates/e-5-
population-and-housing-estimates-for-cities-counties-and-the-state-2020-2022/
Cambrian School District. “Cambrian School District.” Accessed on November 8, 2022. chrome-
extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.cambriansd.org/cms/lib
/CA01902282/Centricity/Domain/369/District%20Map%208.2.17.pdf
Campbell Union High School District. “Campbell Union High Explorer.” Accessed on
November 8, 2022. https://campbellhighdistrictexplorer.azurewebsites.net/
Campbell Union School District. “Where We Are.” Accessed on November 8, 2022.
https://www.campbellusd.org/whereweare
Los Gatos-Saratoga Joint Union High School District. “Los Gatos-Saratoga Joint Union High
School District.” Accessed on November 8, 2022. chrome-
extension://efaidnbmnnnibpcajpcglclefindmkaj/https://cdn5-
ss11.sharpschool.com/UserFiles/Servers/Server_87205/File/District%20Information/
2022%20with%20North%2040%20district%20Large%20Map.pdf
Section C Evaluation of Environmental Impacts 113 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
Los Gatos Union School District. “SchoolSite Locator.” Accessed on November 8, 2022.
https://portal.schoolsitelocator.com/apps/ssl/?districtcode=00215
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Union Elementary School District. “Union Elementary School District (Grades K-8).”
Accessed on November 8, 2022.
Chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://1.cdn.edl.io/
4IG0VO3LMqjGlSy47x70hqmSI641ljrtp14Vijs85FsiIzGO.pdf
Recreation
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Transportation
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. November 2021. 2040 General Plan Revised Sections of Draft Environmental Impact
Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
Section C Evaluation of Environmental Impacts 114 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Tribal Cultural Resources
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. June 2022. Los Gatos Municipal Code.
https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=THC
OTOLOGACA
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Utilities and Service Systems
San Jose Water Company. June 2021. 2020 Urban Water Management Plan. San Jose, CA.
https://www.sjwater.com/sites/default/files/2021-
06/2020%20UWMP%20FINAL%20with%20Appendices.pdf
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. June 2022. Los Gatos Municipal Code.
https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=THC
OTOLOGACA
Section C Evaluation of Environmental Impacts 115 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Wildfire
CalFire. “FHSZ Viewer.” Accessed on October 24, 2022. https://egis.fire.ca.gov/FHSZ/
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Mandatory Findings of Significance
Town of Los Gatos. July 2021. 2040 General Plan Draft Environmental Impact Report. Los Gatos, CA.
—. June 2022a. 2040 General Plan Final Environmental Impact Report SCH#2020070175.
Los Gatos, CA.
https://losgatos2040.com/images/docs/5_LG_2040_GP_FEIR_RTC_June_2022.pdf
—. June 2022b. Town of Los Gatos California 2040 General Plan. Los Gatos, CA.
http://losgatos2040.com/documents.html
—. October 2022c. Town of Los Gatos 6th Cycle 2023-2031 Housing Element Update – HCD Draft –
Initial Review Period. https://www.losgatosca.gov/DocumentCenter/View/31815/HDC-
Initial-Review-Draft-Submittal-
Section C Evaluation of Environmental Impacts 116 EMC Planning Group Los Gatos 6th Cycle Housing Element December 22, 2022
This side intentionally left blank.