Exhibit 19 - Mitigation Monitoring and Reporting ProgramMitigation Monitoring and Reporting Program
143 & 151 E. Main Street
Mixed-Use Project
March 21, 2025
Prepared by
EMC Planning Group
EXHIBIT 19
Table of Contents
MITIGATION MONITORING AND REPORTING PROGRAM .................................................. 1
1.1 Introduction ............................................................................................................................... 1
1.2 Monitoring and Reporting Program ....................................................................................... 1
1.3 Monitoring and Reporting Program Procedures .................................................................. 1
1.4 Monitoring and Reporting Checklist ...................................................................................... 2
Mitigation Monitoring and Reporting Program 1 EMC Planning Group 143 & 151 E. Main Street Mixed Use Project March 2025
Mitigation Monitoring and Reporting Program
1.1 Introduction
CEQA Guidelines section 15097 requires public agencies to adopt reporting or monitoring
programs when they approve projects subject to an environmental impact report or a negative
declaration that includes mitigation measures to avoid significant adverse environmental effects. The
reporting or monitoring program is to be designed to ensure compliance with conditions of project
approval during project implementation in order to avoid significant adverse environmental effects.
The law was passed in response to historic non-implementation of mitigation measures presented in
environmental documents and subsequently adopted as conditions of project approval. In addition,
monitoring ensures that mitigation measures are implemented and thereby provides a mechanism to
evaluate the effectiveness of the mitigation measures.
A definitive set of project conditions would include enough detailed information and enforcement
procedures to ensure the measure's compliance. This monitoring program is designed to provide a
mechanism to ensure that mitigation measures and subsequent conditions of project approval are
implemented.
1.2 Monitoring and Reporting Program
The basis for this monitoring program is the mitigation measures included in the project mitigated
negative declaration. These mitigation measures are designed to eliminate or reduce significant
adverse environmental effects to less than significant levels. These mitigation measures become
conditions of project approval, which the project proponent is required to complete during and after
implementation of the proposed project.
The attached checklist is proposed for monitoring the implementation of the mitigation measures.
This monitoring checklist contains all appropriate mitigation measures in the mitigated negative
declaration.
1.3 Monitoring and Reporting Program Procedures
The Town of Los Gatos shall use the attached monitoring checklist for the proposed project. The
monitoring program should be implemented as follows:
Mitigation Monitoring and Reporting Program 2 EMC Planning Group 143 & 151 E. Main Street Mixed Use Project March 2025
1. The Town of Los Gatos Community Development Department should be responsible for
coordination of the monitoring program, including the monitoring checklist. The Community
Development Department should be responsible for completing the monitoring checklist and
distributing the checklist to the responsible individuals or agencies for their use in monitoring
the mitigation measures.
2. Each responsible individual or agency will then be responsible for determining whether the
mitigation measures contained in the monitoring checklist have been complied with. Once all
mitigation measures have been complied with, the responsible individual or agency should
submit a copy of the monitoring checklist to the Community Development Department to be
placed in the project file. If the mitigation measure has not been complied with, the monitoring
checklist should not be returned to the Community Development Department.
3. The Town of Los Gatos Community Development Department will review the checklist to
ensure that appropriate mitigation measures and additional conditions of project approval
included in the monitoring checklist have been complied with at the appropriate time, e.g. prior
to issuance of a use permit, etc. Compliance with mitigation measures is required for project
approvals.
4. If a responsible individual or agency determines that a non-compliance has occurred, a written
notice should be delivered by certified mail to the project proponent within 10 days, with a copy
to the Community Development Department, describing the non-compliance and requiring
compliance within a specified period of time. If non-compliance still exists at the expiration of
the specified period of time, construction may be halted and fines may be imposed at the
discretion of the Town of Los Gatos.
1.4 Monitoring and Reporting Checklist
Step 1 - Prior to Issuance of Ground-Disturbing Activities Including Demolition or Tree Removal Permits
AQ-1 The applicant shall prepare a Construction Management Plan for review and approval by
the Town of Los Gatos Community Development Department prior to the start of any
ground-disturbing activities, including tree removal. The Construction Management Plan
shall include the following measures to reduce toxic air contaminant emissions during
construction:
a. Heavy-duty diesel vehicles will have 2010 or newer model year engines, in
compliance with the California Air Resources Board’s Truck and Bus Regulation;
b. Idling of construction equipment and heavy-duty diesel trucks will be avoided
where feasible, and if idling is necessary, it will not exceed three minutes;
Mitigation Monitoring and Reporting Program 3 EMC Planning Group 143 & 151 E. Main Street Mixed Use Project March 2025
c. All construction equipment will be maintained and properly tuned in accordance
with manufacturer’s specifications and will be checked by a certified visible
emissions evaluator; and
d. All non-road diesel construction equipment will, at a minimum, meet Tier 3
emission standards listed in the Code of Federal Regulations Title 40, Part 89,
Subpart B, §89.112. Further, where feasible, construction equipment will use
alternative fuels such as compressed natural gas, propane, electricity, or biodiesel.
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Community Development Department
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
BIO-1 To avoid impacts to nesting birds during the nesting season (January 15 through
September 15), construction activities within or adjacent to the project site boundary that
include any tree or vegetation removal, demolition, or ground disturbance (such as
grading or grubbing) should be conducted between September 16 and January 14, which
is outside of the bird nesting season. If this type of construction is scheduled during the
nesting season (February 15 to August 30 for small bird species such as passerines;
January 15 to September 15 for owls; and February 15 to September 15 for other
raptors), a qualified biologist shall conduct nesting bird surveys.
a. One survey for active bird nests shall occur within 48 hours prior to ground
disturbance. Appropriate minimum survey radii surrounding each work area are
typically 250 feet for passerines, 500 feet for smaller raptors, and 1,000 feet for
larger raptors. The survey shall be conducted at the appropriate time of day to
observe nesting activities. Locations off the site to which access is not available
may be surveyed from within the site or from public areas. If no nesting birds are
found, a letter report confirming absence will be prepared and submitted to the
Town of Los Gatos Community Development Department and no further
mitigation is required.
b. If the qualified biologist documents active nests within the project site or in nearby
surrounding areas, an appropriate buffer between each nest and active construction
shall be established. The buffer shall be clearly marked and maintained until the
young have fledged and are foraging independently. Prior to construction, the
qualified biologist shall conduct baseline monitoring of each nest to characterize
“normal” bird behavior and establish a buffer distance, which allows the birds to
Mitigation Monitoring and Reporting Program 4 EMC Planning Group 143 & 151 E. Main Street Mixed Use Project March 2025
exhibit normal behavior. The qualified biologist shall monitor the nesting birds
daily during construction activities and increase the buffer if birds show signs of
unusual or distressed behavior (e.g., defensive flights and vocalizations, standing
up from a brooding position, and/or flying away from the nest). If buffer
establishment is not possible, the qualified biologist or construction foreman shall
have the authority to cease all construction work in the area until the young have
fledged and the nest is no longer active. Once the absence of nesting birds has
been confirmed, a letter report will be prepared and submitted to the Town of Los
Gatos.
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Community Development Department
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
BIO-2 Per Town Code Section 26.20.010 and Chapter 29, Article 1, Division 2, the developer
shall obtain a tree removal permit prior to the removal of protected trees on private or
Town property. The project developer shall abide by any tree replacement ratios and/or
in-lieu payments, tree protection measures, and best management practices required by
the tree removal permit and/or within the arborist report dated October 24, 2024
(Appendix D).
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Community Development Department
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
CUL-1 The following language shall be incorporated into any plans associated with tree removal,
grading, and construction, “In the event that archaeological resources are encountered
during ground disturbing activities, contractor shall temporarily halt or divert excavations
within 50 meters (165 feet) of the find until it can be evaluated. All potentially significant
archaeological deposits shall be evaluated to demonstrate whether the resource is eligible
Mitigation Monitoring and Reporting Program 5 EMC Planning Group 143 & 151 E. Main Street Mixed Use Project March 2025
for inclusion on the California Register of Historic Resources, even if discovered during
construction. If archaeological deposits are encountered, they will be evaluated and
mitigated simultaneously in the timeliest manner practicable, allowing for recovery of
materials and data by standard archaeological procedures. For indigenous archaeological
sites, this data recovery involves the hand‐excavated recovery and non‐destructive
analysis of a small sample of the deposit. Historic resources shall also be sampled
through hand excavation, though architectural features may require careful mechanical
exposure and hand excavation.
Any previously undiscovered resources found during construction activities shall be
recorded on appropriate California Department of Parks and Recreation (DPR) forms
and evaluated for significance by a qualified Archaeologist. Significant cultural resources
consist of but are not limited to stone, bone, glass, ceramics, fossils, wood, or shell
artifacts, or features including hearths, structural remains, or historic dumpsites.”
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Community Development Department
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
CUL-2 The following language shall be incorporated into any plans associated with tree removal,
demolition, grading, and construction, “In the event that human remains (or remains
that may be human) are discovered at the project site, Public Resource Code Section
5097.98 must be followed. All grading or earthmoving activities shall immediately stop
within 50 meters (165 feet) of the find. The Santa Clara County Coroner will be notified
immediately, and the coroner shall be permitted to examine the remains as required by
California Health and Safety Code Section 7050.5(b).
Section 7050.5 requires that excavation be stopped in the vicinity of discovered human
remains until the coroner can determine whether the remains are those of a Native
American. If human remains are determined as those of Native American origin, the
project proponent shall comply with the state relating to the disposition of Native
American burials that fall within the jurisdiction of the NAHC (Public Resource Code
[PRC] § 5097). The coroner shall contact the Native American Heritage Commission
(NAHC) to determine the most likely descendant(s) (MLD). The MLD shall complete
his or her inspection and make recommendations or preferences for treatment within 48
Mitigation Monitoring and Reporting Program 6 EMC Planning Group 143 & 151 E. Main Street Mixed Use Project March 2025
hours of being granted access to the site. The MLD will determine the most appropriate
means of treating the human remains and associated grave artifacts, and shall oversee the
disposition of the remains. In the event the NAHC is unable to identify an MLD or the
MLD fails to make a recommendation within 48 hours after being granted access to the
site, the landowner or his/her authorized representative shall rebury the Native
American human remains and associated grave goods with appropriate dignity within the
project area in a location not subject to further subsurface disturbance if: a) the Native
American Heritage Commission is unable to identify the MLD or the MLD failed to
make a recommendation within 48 hours after being allowed access to the site; b) the
descendent identified fails to make a recommendation; or c) the landowner or his
authorized representative rejects the recommendation of the descendent, and the
mediation by the Native American Heritage Commission fails to provide measures
acceptable to the landowner.”
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Community Development Department
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
GEO-2 The following measure shall be included in project plans, prior to issuance of a
demolition permit:
“If paleontological resources are uncovered during demolition, grading or other on-site
excavation activities, construction activities in the area shall be suspended. The developer
shall retain a qualified paleontologist to examine the site and identify protective measures
to be implemented to protect the paleontological resource. The measures shall be subject
to review and approval by the Community Development Director.”
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Community Development Department
Monitoring Notes:
______________________________________________________________
______________________________________________________________
Mitigation Monitoring and Reporting Program 7 EMC Planning Group 143 & 151 E. Main Street Mixed Use Project March 2025
______________________________________________________________
N-1 The project developer shall ensure that no individual piece of construction equipment
produce a noise level exceeding 85 dBA at 25 feet. Prior to the start of ground disturbing
activities, the applicant shall demonstrate compliance with this requirement to the Town
of Los Gatos Building Department for review and verification.
The project developer shall also ensure that best management practices are
incorporated during construction activities. The following shall be placed on all
ground-disturbing project plans:
All construction equipment shall be properly maintained and muffled as to minimize
noise generation at the source.
Noise‐producing equipment shall not be operating, running, or idling while not in
immediate use by a construction contractor.
All noise‐producing construction equipment shall be located and operated, to the
extent possible, at the greatest possible distance from any noise‐sensitive land uses.
Locate construction staging areas, to the extent possible, at the greatest possible
distances from any noise‐sensitive land uses.
Signs shall be posted at the construction site and near adjacent sensitive receptors
displaying hours of construction activities and providing the contact phone number
of a designated noise disturbance coordinator.
Party Responsible for Implementation: Applicant
Party Responsible for Monitoring: Town of Los Gatos Building Department
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
Step 2 - Prior to Issuance of Grading Permits
GEO-1 The applicant shall prepare a soils report addressing, but not limited to: foundation and
retaining wall design recommendations, and impacts associated with lateral spreading,
subsidence, or collapse. The soils report shall be submitted to the Town Building
Division for review and approval prior to issuance of a grading permit. All
Mitigation Monitoring and Reporting Program 8 EMC Planning Group 143 & 151 E. Main Street Mixed Use Project March 2025
recommendations outlined in the soils report shall be incorporated into the project
design.
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Building Division
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
HAZ-1 The project developer shall conduct soil vapor testing on the project site prior to
issuance of a grading permit. The results of the soil vapor testing shall be reviewed by
the Town Engineer and only with approval by the Town Engineer can any grading and
earth-moving construction activities take place.
If soil vapor testing comes back with concentration levels that exceed safety thresholds
for residential uses, the Town Engineer shall determine if Environmental Solutions
should provide recommendations for construction of the project. If soil vapor testing
comes back with concentration levels below safety thresholds, no further action is
necessary.
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Engineer
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
Step 3 - Prior to Issuance of Building Permits
AQ-2 The project applicant shall ensure that MERV 13 air filtration systems, or an equivalent
system, are included in the design and operations of the proposed project. Prior to the
issuance of building permits, the applicant shall submit detailed plans and specifications
demonstrating compliance with this requirement to the Town of Los Gatos Building
Department for review and verification. These plans shall identify the locations and
Mitigation Monitoring and Reporting Program 9 EMC Planning Group 143 & 151 E. Main Street Mixed Use Project March 2025
specifications of the air filtration systems and confirm they meet the performance
standards for particulate and airborne pollutant removal.
The air filtration systems must be operational prior to the issuance of a certificate of
occupancy. Verification of proper installation and functionality shall be conducted by a
licensed professional and documented in a final compliance report, which must be
submitted to the Town of Los Gatos Building Department for approval. The property
owner or operator shall also establish a maintenance plan for the air filtration system to
ensure ongoing performance in accordance with manufacturer specifications.
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Building Division
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
GHG-1 The project developer shall incorporate the following GHG emissions reduction
performance standard into the final project design:
No permanent natural gas infrastructure shall be permitted as part of the project
plans; no natural gas shall be made available through permanent natural gas
infrastructure. The project shall be all electric.
Final plans for the development shall be reviewed by the Town Community
Development Department prior to issuance of a building permit to ensure this
performance standard is incorporated into the project design. Verification of
development consistent with this performance standard shall be assured prior to
approval of occupancy permits.
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Community Development Department
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
Mitigation Monitoring and Reporting Program 10 EMC Planning Group 143 & 151 E. Main Street Mixed Use Project March 2025
Step 4 - Prior to Issuance of Occupancy Permits
AQ-2 The project applicant shall ensure that MERV 13 air filtration systems, or an equivalent
system, are included in the design and operations of the proposed project. Prior to the
issuance of building permits, the applicant shall submit detailed plans and specifications
demonstrating compliance with this requirement to the Town of Los Gatos Building
Department for review and verification. These plans shall identify the locations and
specifications of the air filtration systems and confirm they meet the performance
standards for particulate and airborne pollutant removal.
The air filtration systems must be operational prior to the issuance of a certificate of
occupancy. Verification of proper installation and functionality shall be conducted by a
licensed professional and documented in a final compliance report, which must be
submitted to the Town of Los Gatos Building Department for approval. The property
owner or operator shall also establish a maintenance plan for the air filtration system to
ensure ongoing performance in accordance with manufacturer specifications.
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Building Department
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
GHG-1 The project developer shall incorporate the following GHG emissions reduction
performance standard into the final project design:
No permanent natural gas infrastructure shall be permitted as part of the project
plans; no natural gas shall be made available through permanent natural gas
infrastructure. The project shall be all electric.
Final plans for the development shall be reviewed by the Town Community
Development Department prior to issuance of a building permit to ensure this
performance standard is incorporated into the project design. Verification of
development consistent with this performance standard shall be assured prior to
approval of occupancy permits.
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Community Development Department
Mitigation Monitoring and Reporting Program 11 EMC Planning Group 143 & 151 E. Main Street Mixed Use Project March 2025
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
N-2 The project developer shall install mechanical ventilation or air conditioning for all
residential units so that windows and doors can remain closed for sound insulation
purposes. Implementation of this measure is subject to review and approval by the Town
Building Department, prior to issuance of an occupancy permit.
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Building Department
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
TRANS-1 Project improvements plans shall include the following, subject to review and approval
by the Town Engineer, prior to issuance of an occupancy permit:
a. Stripe a loading space along the project frontage on E. Main Street;
b. Apply 10 feet of No Parking (Red Zone) on both sides of the project driveway on
Church Street; and
c. Provide adequate landing space at the top and bottom of the garage ramps.
Party Responsible for Implementation: Developer
Party Responsible for Monitoring: Town of Los Gatos Engineer
Monitoring Notes:
______________________________________________________________
______________________________________________________________
______________________________________________________________
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