Item 6 - Addendum with Exhibit 17.15349-15367 Los Gatos BlvdPREPARED BY: Sean Mullin, AICP
Planning Manager
Reviewed by: Town Attorney and Community Development Director
110 E. Main Street Los Gatos, CA 95030 ● (408) 354-6872
www.losgatosca.gov
TOWN OF LOS GATOS
PLANNING COMMISSION
REPORT
MEETING DATE: 04/23/2025
ITEM NO: 6
ADDENDUM
DATE: April 22, 2025
TO: Planning Commission
FROM: Joel Paulson, Community Development Director
SUBJECT: Consider a Request for Approval to Demolish Existing Commercial Structures,
Construct a Multi-Family Live/Work Development (55 Units), a Conditional
Use Permit for a Live/Work Development, a Condominium Vesting Tentative
Map, Site Improvements Requiring a Grading Permit, and Removal of Large
Protected Trees, Under Senate Bill 330 (SB 330) on Property Zoned CH:HEOZ.
Located at 15349-15367 Los Gatos Boulevard. APNs 424-19-048 and 424-19-
049.Architecture and Site Application S-24-015, Conditional Use Permit U-24-
006, Subdivision Application M-24-008. No Additional Environmental Review
is Necessary Pursuant to CEQA Guidelines Sections 15162: Subsequent EIRs
and 15168: Program EIR, Since the Proposed Project’s Environmental Impacts
were Adequately Addressed in the 2020 General Plan EIR and/or 2040
General Plan EIR, as Applicable. Property Owner: Jonathan Peck. Applicant:
City Ventures. Project Planner: Sean Mullin.
REMARKS:
Exhibit 17 includes public comments received between 11:01 a.m., Friday, April 18, 2025, and
11:00 a.m., Tuesday, April 22, 2025.
EXHIBITS:
Previously Received with the April 18, 2025, Staff Report:
1.Final Initial Study – March 2025
(available online at https://www.losgatosca.gov/DocumentCenter/Index/2223)
2.Required Findings and Considerations
3.Recommended Conditions of Approval
4.Location Map
5.Project Description Letter
6.Letter of Justification
7.Consulting Architect’s Report
PAGE 2 OF 2
SUBJECT: 15349-15367 Los Gatos Boulevard/S-24-015, U-24-006, and M-24-008
DATE: April 18, 2025
8. Applicant’s Response to Consulting Architect’s Report
9. Letter of Justification for SDBL Concession and Waivers
10. Final Arborist’s Report
11. Neighbor Outreach Summary
12. Visual Renderings
13. Objective Design Standards Checklist
14. Site Photos
15. Public comments received by 11:00 a.m., Friday, February 7, 2025
16. Development Plans
Received with this Addendum Report:
17. Public Comments between 11:01 a.m., Friday, April 18, 2025, and 11:00 a.m., Tuesday, April
22, 2025
From: Zoha Rousta
Sent: Monday, April 21, 2025 9:53 AM
To: Planning <Planning@losgatosca.gov>
Subject: Public Comment Regarding 15349-15367 Los Gatos Blvd Project
[EXTERNAL SENDER]
Dear Planning Commission,
I hope this message finds you well. My name is Zoha, and I’m writing on behalf of my
daughter, Liana, who is a 3rd grader at an Elementary school in Los Gatos. Liana is deeply
concerned about the proposed development on Los Gatos Boulevard, and she has written
a letter expressing her thoughts on the project.
As a young resident who loves our town and cares about nature, Liana wanted to share her
feelings about the impact this project may have on our community. I hope you’ll take the
time to read her heartfelt message and consider her perspective as you make decisions
about the future of Los Gatos.
Thank you very much for your time and consideration. We appreciate the opportunity to be
a part of this important conversation.
Sincerely,
Zoha
Public Comment Regarding 15349–15367 Los Gatos Blvd Project
Dear Planning Commission,
Hi, my name is Liana, and I’m in 3rd grade at a school in Los Gatos. I love our town, and I care a lot about
nature and animals.
I’m concerned about the proposed development on Los Gatos Boulevard. Los Gatos is a beautiful, historic
town known for its green spaces and old trees. This project doesn’t match the small-town needs, and I
don’t think it’s good for our community. The roads and infrastructure weren’t made for so many people
and buildings.
If the development goes ahead, it could cause a lot of problems. First, there will be more traffic, and that
will make it harder for people to get around. It might take longer to get to school or work, and we could
even see more accidents because of the extra cars on the road. Also, with more buildings, we may not
have enough space for everyone to park. Our town could become crowded, and the charm that makes Los
Gatos special could start to disappear.
It’s also very sad that the plan includes cutting down large, protected trees. Trees are important because
they help animals live, clean our air, give us shade, and make our town beautiful. It feels even worse that
this is happening during Earth Week, a time when we should be caring for nature. Once the trees are gone,
we can’t bring them back.
I’m also worried about how this might affect our environment. More buildings mean less open space for
animals to live, and the construction could harm the plants and trees around. The noise and pollution
could make the town less peaceful and healthy.
There are better ways to grow our town without hurting the environment. I hope we can protect our
town’s special character and keep it beautiful for future generations.
Thank you for listening.
Sincerely,
Liana
From: Alex Kamas
Sent: Monday, April 21, 2025 7:02 PM
To: Planning <Planning@losgatosca.gov>
Subject: Public Comment Item #6
[EXTERNAL SENDER]
My name is Alex Kamas and I live near the proposed development at 15349 and 15367 Los Gatos Blvd.
This is a well thought out and much needed development.
Not only will the development provide desperately needed housing, but these homes will also give
families a way to get access to the great schools in Los Gatos, ensuring that low enrollment doesn’t force
Los Gatos schools to close. I’m a teacher and I’ve seen the projected enrollments for districts in our
county and they’re not optimistic.
According to the California Dept of Education, ten years ago, Los Gatos Union School District had 3,320
students. Last year, it had 2,673. That’s a decline of 20% in less than a decade. If that trend continues
then Los Gatos might be forced to follow the path of districts like Cupertino which have had to close
multiple schools in the last few years due to a 30% decline in enrollment.
Our students and their families are more than numbers though. They’re an integral part of who we are. I
look at my students and I worry that the place they’re growing up in will be inaccessible to them in the
future. If we don’t build new housing then most of my students will be forced to move far from their friends
and families.
I’m excited to meet the people who will become my neighbors. I want to see them enrich our community
and fill it with even more character. I’m asking that the Planning Commission vote to approve this project.
Thank you.
From: Des Kam
Sent: Monday, April 21, 2025 7:25 PM
To: Planning <Planning@losgatosca.gov>
Subject: Public Comment Item #6
[EXTERNAL SENDER]
To the Planning Commission,
I live two blocks from the planned development at 15349 and 15367 Los Gatos Blvd. I’d like to
share my wholehearted support and excitement.
This is a great spot for these homes. They would be within easy walking distance of grocery
stores, restaurants, two parks, and they aren’t far from the creek trail. The site is adjacent to
stops for both public transit and tech commuter shuttles.
These homes would benefit anyone from empty nesters looking to downsize, young families
needing room to grow and a place to plant roots, and families like mine who want more choices
in deciding where they live.
I hope that the commission sees the value in approving this project, and other housing
developments, not just for helping Los Gatos achieve its housing goals, but because of the real
people that will get the opportunity to live and thrive in this community.
Thank you.
Sincerely,
Desmond Kamas
From:
Sent: Tuesday, April 22, 2025 9:34 AM
To: Clerk <Clerk@losgatosca.gov>
Subject: Subject: PC Meeting 4/23/25 - Item 6 - Objection to Tiering from 2040 General Plan EIR –
Application S-24-015 (15349 & 15367 Los Gatos Blvd)
[EXTERNAL SENDER]
Date: April 22, 2025
To:
Chair and Members of the Planning Commission
Town of Los Gatos
110 E. Main Street
Los Gatos, CA 95030
Subject: Objection to Tiering from 2040 General Plan EIR – Application S-24-015 (15349 & 15367 Los
Gatos Blvd)
Dear Chair and Members of the Planning Commission:
On behalf of the Los Gatos Community Alliance, we submit this comment to respectfully object to the
Town’s reliance on the 2040 General Plan Environmental Impact Report (EIR) for its CEQA
determination regarding Application S-24-015, a proposed 55-unit live/work development at 15349
and 15367 Los Gatos Boulevard. While this project is not a Builder’s Remedy application, it is
being reviewed and processed in the context of an unprecedented volume of high-density
housing proposals, including a substantial number of Builder’s Remedy projects, which are
changing the development landscape of the Town in a significant and foreseeable way.
⸻
Project Context – Not a Builder’s Remedy Project, But Part of a New Development Pattern
Application S-24-015 seeks approval to:
• Demolish existing commercial structures
• Construct a 55-unit multi-family live/work development at 35/DU per acre
• Obtain a Conditional Use Permit and Condominium Vesting Tentative Map
• Complete grading, site improvements, and removal of large protected trees
• Be reviewed under SB 330, which limits local discretion in project approvals
Although this project is not proceeding under the Builder’s Remedy provision of state
housing law, it is one of many current proposals that reflect a material departure from the
development patterns and assumptions studied in both the 2020 and 2040 General
Plans and their respective EIRs.
⸻
Tiering from the 2040 EIR Is Inappropriate
CEQA Guidelines Section 15162 prohibits tiering from a previously certified EIR when substantial new
information or changed circumstances arise. Since the certification of the 2040 General Plan EIR in
2022, the Town has received at least a dozen Builder’s Remedy applications, many of which
propose:
• Much higher densities than what was studied in either General Plan
• Clustering along Los Gatos Boulevard, compounding localized and cumulative impacts
• Minimal inclusion of below-market-rate units, potentially triggering further rezoning
This volume and concentration of development is new information of substantial
importance under CEQA Guidelines §15162(a)(3)(B), and it was not contemplated by the
2040 General Plan EIR. Therefore, it is legally inappropriate to rely on tiering from that
document to assess this or similar projects.
⸻
Cumulative Impacts & Net Loss Concerns Not Evaluated
The Town has not conducted a cumulative environmental impact analysis of the collective effects
of these concurrent projects, including Application S-24-015. Impacts related to vehicle miles traveled
(VMT), greenhouse gas emissions, infrastructure capacity, tree removal, noise, and
neighborhood compatibility cannot be properly understood when each project is reviewed in
isolation.
Furthermore, the Builder’s Remedy application for Phase II of the North 40 is likely to trigger
the “No Net Loss” requirements under Government Code §65863. This will obligate the Town
to rezone additional sites to meet low- and very-low-income housing targets, creating another
foreseeable layer of environmental consequences that remain unstudied. Please refer to the attached No
Net Loss Analysis.
⸻
Conclusion
Even though Application S-24-015 is not a Builder’s Remedy project, it is being processed amid a
wave of high-density housing proposals that cumulatively alter the Town’s planning and
environmental baseline. These changes invalidate the assumptions of the 2040 General Plan
EIR, and CEQA does not permit the Town to rely on tiering from that document under Section
15162.
We therefore urge the Planning Commission to reject the conclusion that no further environmental review
is necessary, and to require that the Town conduct a Subsequent or Supplemental EIR to properly
evaluate the cumulative and foreseeable impacts of current development pressures.
Sincerely,
Los Gatos Community Alliance
Facts Matter; Transparency Matters; Honesty Matters
www.lgca.town
No Net Loss Analysisof Pending and Approved Projects VL L M A Total
Total Units - Table 10-3 RHNA Credits and Sites Strategy 694 421 411 845 2,371
6th Cycle RHNA 537 310 320 826 1,993
Surplus Above RHNA 157 111 91 19 378
Net Site Impact from Proposed and Approved Projects
>50 Los Gatos-Saratoga Road (Los Gatos Lodge)(86)(70)(52)103 (105)
>15349-15367 Los Gatos Blvd (19)(5)(5)38 9
>North 40 (184)(11)(92)274 (13)
>ADU actual production 2023 and 2024 adjustement 6 4 (15)(5)(10)
Total Adjustments (283)(82)(164)410 (119)
Remaining Housing Element Site Inventory Surplus/(Deficit) (126)29 (73)429 259
Note:
This analysis is conservative with regard to the remaining surplus because there is no evidence the Housing Element assumed unit production of 2,371 will be distributed by
income as planned. The Housing Element Site Inventory assumes 47% (694+421/ 2371)of the total units will be very-low and low income units. Actual production has shown that no more
than 20% of the units produced will be very-low and low income units. If this analysis was adjusted to reflect "realistic development by income category" the remaining surplus
would be less. Or stated another way the net loss numbers would be even greater.