Exhibit 15. Project Description and Letter of JustificationNovember 6, 2024
Revised: March 5, 2025
Revised: May 21, 2025
Revised: August 18, 2025
Sean Mullin, Planning Manager
Community Development Department
110 E. Main Street
Los Gatos, CA 95030
Project: RH – Los Gatos
Location: 31 University Ave
Subject: Letter of Justification for Architecture and Site Approval; Conditional Use Permit
PROJECT DESCRIPTION & REQUEST
RH is requesting architecture and site approval, as well as a conditional use permit (“CUP”) for 1)
formula retail use exceeding 10,000 sf, and 2) for restaurant use with the selling of alcoholic beverages
for consumption on-premises. RH is seeking these approvals to allow for the remodel of a 15,330 sq.
ft. building located at 31 University Avenue, which will feature an innovative retail experience
seamlessly integrating luxury home furnishings collections within a curated hospitality program (the
“Proposed Project”).
BACKGROUND
A curator of design, taste and style in the luxury lifestyle market, RH offers collections through its
retail galleries, sourcebooks and online at RH.com, RHContemporary.com, RHModern.com,
RHBabyandChild.com, RHTEEN.com, and Waterworks.com.
Committed to creating architecturally inspiring and immersive retail spaces that blur the lines
between residential and retail, indoors and outdoors, home and hospitality, RH Design Galleries are
bespoke design destinations presenting the largest curated and fully integrated assortment of luxury
home furnishings in the world. From restored landmark buildings to grand-scale contemporary
structures, these architecturally inspiring spaces reimagine and redefine the shopping experience.
Designed with sensory-inspiring spaces that cannot be replicated online, these innovative and
architecturally significant retail environments include lush gardens, professional design services, one-
EXHIBIT 15
of-a-kind culinary experiences, and artistic installations of curated RH Collections by internationally
acclaimed designers and artisans across the globe.
In addition to RH Madrid, the Gallery at Plaza del Marqués de Salamanca, RH Aynho Park, a
magnificent 17th-century estate in the English countryside, and RH Brussels, a grand 18th century
French baroque mansion prominently situated on the premier Boulevard de Waterloo, RH chairman &
CEO Gary Friedman has revitalized several landmark properties across North America, including the
former Museum of Natural History in Boston, the historic Three Arts Club in Chicago, the Historic Post
Office in Greenwich, Connecticut; the Bethlehem Steel Building in San Francisco, and the brand’s
impressive Gallery in New York’s Meatpacking District.
The plan for a RH Design Gallery, together with a food and beverage program, allows for the
reimagination of an exceptional building that is appropriately scaled and sited on a key intersection of
Old Town Los Gatos.
SITE DETAILS
The existing 15,330 sf building for the Proposed Project is sited at the corner of University Ave and Elm
St, and sits on a 4.18 acre parcel that spans both sides of University Ave which houses an outdoor
retail center known as the Old Town Shopping Center.
The Proposed Project will combine two previously separate tenant spaces within the existing building,
which were previously home to a 6,400 sf Steamers of Los Gatos and a 8,641 sf Gap.
The zoning for the site is C-2:LHP:PD: Central Business District with a Landmark & Historic Preservation
and Planning Development overlay. The Proposed Project’s uses are allowed per zoning with a
Conditional Use Permit. The Proposed Project will maintain the existing square footage of the existing
building and would comply with the zoning ordinance standards for setbacks and building height.
ARCHITECTURE
The primary proposed building material is a multi-coat cement plaster system with steel and
aluminum decorative building elements. The existing structural system is maintained in place.
Architectural aluminum windows line the exterior elevations and provide transparency across the
facades facing Elm St, University Ave, and along the pedestrian pass-through on the building’s
southern side.
The length of the facades across University Ave and Elm St are scaled down through sections that
alternatively step back in ground plane from each other. These wall panels also alternatively feature
rectangular- or semicircular- topped windows, as well as a parapet line that steps up and down in
height in line with the panels. These features ultimately provide a sense of rhythm, symmetry, visual
relief, and interest to the length of the existing building. Further, the fenestration sits materially inside
the edge of the exterior wall, providing for deep shadows, which along with projected louvered
awnings add additional textural detail across the facades.
Finally, the full-service restaurant sits centrally inside the Proposed Project and is covered by a
pyramidal skylight that brings in light and highlights the cafe as a central gathering space. Barrel-
vaulted hallways bookend both sides of the cafe, which add an uncommon architectural expression,
facilitates a unique play of light, and creates a sense of place as customers enter the Gallery or exit the
cafe.
COMPLIANCE WITH COMMERCIAL DESIGN GUIDELINES
31 University Ave sits within the C-2A subdistrict, which specifies site development and building design
guidelines for projects within its boundaries. Applicable guidelines to the site are noted below along
with the Proposed Project’s conformance:
3.2 Site Development:
3.2.1: Facades should be setback from the public street property lines no more than five
feet: The Proposed Project is a renovation of an existing building, so the existing
building’s existing footprint and setback are proposed to remain. Currently, the building’s
façade is set back farther than five feet, but this was part of and consistent with the
overall design included Planned Development Ordinance 2025. Landscaping elements
including planters, benches, and trees are included within this setback area.
3.2.3. Pass-through pedestrian walkways from rear parking lots may be required: The
Proposed Project will maintain and enhance the existing pedestrian walkway along its
southern side.
3.3 Building Design:
3.3.1 Maintain a building front module that is consistent with the remaining block front
streetscape: As the Proposed Project is a renovation of an existing building with less than
50% of the façade being demolished, the massing, setbacks, and cadence remain
consistent with the larger Old Town Shopping Center it is a part of. The proposed
changes harmonize and rationalize the façade to further integrate, rather than separately
distinguish itself, from the surrounding streetscape.
3.3.3 Emphasize display windows and storefront entries: The Proposed Project includes
abundant display windows and several entries. Architectural aluminum windows line the
exterior elevations and provide transparency across the facades facing Elm St, University
Ave, and along the pedestrian pass-through on the building’s southern side.
3.3.4 Maintain transparent storefronts and public right-of-way walls: The Proposed
Project’s amount of openings are consistent with the existing buildings, although they
have been expanded in several areas.
3.3.5 Provide vestibules at building entries: There is no vestibule at the main entrance to
the Proposed Project; however, the entry opens into a barrel-vaulted passage which acts
as a transition point within the gallery.
3.3.6 Utilize high quality storefront materials: The primary proposed building material is a
multi-coat cement plaster system with steel and aluminum decorative building elements.
Architectural aluminum windows line the exterior elevations. These materials will serve
to elevate the building from its existing material palette.
3.3.7 Operable windows and French doors are encouraged for restaurants and coffee
cafes: The restaurant is in the middle of the Proposed Project, however; full-height
windows/doors line the perimeter, several being operable.
3.3.8 Install awnings: The Proposed Project includes awnings along all facades.
The Commercial Design Guidelines further note conformance guidelines for the University/Edelen
Historic District which 31 University Ave sits within – these guidelines and the Proposed Project’s
conformance are noted in detail in the Supplemental Letter of Justification submitted for the February
26, 2025 Historic Preservation Committee.
USES
A majority of the Proposed Project will display furniture and décor in a series of complete living, bath,
and bedrooms. There will also be a restaurant on the ground floor beyond the entryway, along with a
kitchen and other back of house. An Interior Design Studio room will also be sited toward the back of
the store, where interior designers can provide customers further assistance. Further information on
how the gallery and restaurant will operate is as follows:
Hours of Operation: Proposed operating hours for the design gallery and restaurant will be from
10:00am to 10:00pm (last seating at 9:00p) Monday to Saturday, and 10:00am to 9:00pm (last
seating at 8:00pm) on Sunday. Note: these hours are subject to change.
Maximum hours of operation, including maximum staff shifts, start no earlier than 6AM and end
no later than midnight.
Staffing: The design gallery would employ 20 full-time staff. Shifts will start no earlier than 6AM
and the latest shift will end no later than two hours after closing. Shifts will likely be overlapped
and max out mid-day at around 15 employees. Gallery shifts are typically 8-hours long.
The restaurant would employ approximately 50 staff – 40 of these are expected to be full-time
staff. Restaurant shifts would start no earlier than 7AM and the latest would end by 12AM.
Restaurant shifts are typically 8-hours long. A maximum of 35 staff would be working at the
highest point of crossover (Saturday 2-4PM), while the average amount of staff on-site will total
15-20.
ABC License: RH intends to apply for an On-Sale General – Eating Place License (Type 47) from the
ABC. RH may apply for a Type 41 beer and wine license in lieu of a Type 47.
Other: RH will consider all group dining and buyout requests within normal business hours.
The vision within the building is to reimagine the retail experience by blurring the lines between
residential and retail, hospitality and home, indoors and outdoors – creating an immersive retail
environment that is more home than store. All amenities will be made available to the public during
the hours of store operation.
PLANNED DEVELOPMENT ORDINANCE AMENDMENT FINDINGS
The existing building at 31 University Avenue is governed by Planned Development Ordinance 2025,
adopted on December 16, 1996. RH is requesting an amendment to Planned Development
Ordinance 2025 – specifically, to remove the requirement that the building be designed to “appear to
be a collective of individual structures that abut each other.” This change would allow for a more
cohesive and contextually appropriate façade.
Currently, the building’s façade is articulated to resemble three separate structures. The styles
represented by the existing façade largely do not correspond to the architectural character of the
University-Edelen Historic District, which includes the contributing styles of Mission Revival,
Mediterranean, Craftsman, and Victorian. In contrast, the proposed redesign adopts a unified
Mediterranean-style façade that thoughtfully reflects the proportions, window types, and
architectural articulation seen throughout Old Town. As such, the revised design offers a more
harmonious and respectful relationship to its surroundings.
Town code Section 29.80.120 allows for amendments to PD’s, provided the proposed amendment
meets the requirements and findings of Town code Section 29.80.095. The proposed PD Amendment
and the Proposed Project comply with the required findings in the following manner:
1) The proposed PD is in compliance with all sections of this division.
The proposed PD amendment is within the limitations of use of a planned development as
it pertains to property within a landmark and historic preservation overlay zone, and
serves to enhance the Town’s historic resources that provide a public benefit to the
citizens of the Town.
2) The proposed PD is in conformance with the goals, policies, and applicable land use designation(s)
and standards of the Town's general plan.
The proposed PD amendment maintains a baseline set of requirements consistent with
the Town's general plan. The policies consistent with the PD amendment include, but are
not limited to:
Policy LU-6.5: The type, density, and intensity of new land use shall be consistent with
that of the immediate neighborhood.
Policy LU-9.3: Maintain a variety of commercial uses, including a strong Downtown
commercial area combined with Los Gatos Boulevard and strong neighborhood
commercial centers to meet the shopping needs of residents and to preserve the small-
town atmosphere.
Policy CD-9.1: Exterior building materials in the Central Business District should be
consistent with those used in existing, tastefully executed surrounding buildings.
Policy CD-12.2: Encourage the preservation, maintenance, and adaptive reuse of existing
residential, commercial or public buildings.
3) The proposed PD is in conformance with all other applicable land use regulations, including but
not limited to Town Council adopted guidelines, except as otherwise provided in section
29.80.095(4).
The PD amendment seeks a modification specifically to requirements in PD Ordinance
2025 but otherwise maintains a baseline set of requirements consistent with the Town's
land use regulations and design guidelines, including Ordinance 1920 and 2168, which
governs over the University/Edelen Historic District, and which includes the Proposed
Project’s site.
The Proposed Project is consistent with the design guidelines for the remodel of a non-
contributing structures within the University/Edelen Historic District. The Proposed Project
is sensitive to and supportive of the larger District as it expands the Mediterranean
components of the existing building’s and Old Town Shopping Center’s style while
maintaining the existing building’s footprint, setbacks, massing, and density. The
Proposed Project’s stucco building material, as well as doors and window rhythm, type
and proportions, are consistent to the existing building’s Mediterranean style, as well as
that of the larger Old Town Shopping Center across University Ave. In particular, the
stucco and proposed openings evoke the style of 50 University Ave, a significant
commercial structure within the University/Edelen Historic District. The Proposed Project
limits decorative details and scale however, in sensitivity and support of the Historic
District’s contributing structures.
The proposed PD amendment and Proposed Project also conform with required findings
for landmark and historic preservation applications per Town Code Section 29.80.290, as
the proposed work does not adversely affect the exterior architecture or its relationship
with its surroundings. The Proposed Project is more harmonious and consistent with the
larger Old Town Shopping Center’s style and aesthetic:
“Sec. 29.80.290. Standards for review. In evaluating applications, the deciding body shall
consider the architectural style, design, arrangement, texture, materials and color, and
any other pertinent factors. Applications shall not be granted unless:
(2) In historic districts, the proposed work will neither adversely affect the exterior
architectural characteristics or other features of the property which is the subject of the
application, nor adversely affect its relationship, in terms of harmony and
appropriateness, with its surroundings, including neighboring structures, nor adversely
affect the character, or the historical, architectural or aesthetic interest or value of the
district.”
4) Any proposed use or development standards that deviate from the underlying zoning district(s)
result in innovative and creative site planning to develop:
b. Mixed commercial, or mixed residential, or mixed commercial and residential
development; or
e. The proposed PD provides a public benefit to the citizens of the Town.
The proposed PD amendment facilitates the revitalization of two vacant storefronts into a
mixed commercial amenity of innovative and creative use programming for the benefit of
both residents and visitors, which satisfies conditions (b) and (e) above.
CONDITIONAL USE PERMIT FINDINGS
In the C-2 zone, Town code requires a CUP for a formula retail business exceeding 10,000 sf and for
restaurant use with the selling of alcoholic beverages for consumption on-premises (Section
29.20.185). Los Gatos stipulates terms for the approval or denial of conditional use permits under
Section 29.20.190. The Proposed Project and its uses will comply with the objectives in the following
manner:
(1) The proposed uses of the property are essential or desirable to the public convenience or
welfare;
The proposed uses provide for a bespoke dining and shopping experience which will be
desirable to both residents and visitors as a destination within Los Gatos. Further, the
Proposed Project will be an addition to an existing RH gallery at 26 N Santa Cruz Ave,
which has been an integral part of the Los Gatos community for over 10 years.
(2) The proposed uses will not impair the integrity and character of the zone;
The proposed use will not impair the integrity and character of the zone as it is a
commercial use located in a commercial zone.
Further, the Proposed Project is consistent with the Commercial Design Guidelines for C-
2A zones and as a non-contributing structure within a historic preservation district. The
Proposed Project maintains the existing building’s massing and density, reimagines the
existing facade variation, and maintains the pedestrian pass-through along the southern
wall.
(3) The proposed uses would not be detrimental to public health, safety or general welfare;
The proposed uses, formula retail use and restaurant use with the selling of alcoholic
beverages for consumption on-premises, represent no change from the current uses of
the most recent tenants at the existing building (Gap and Steamer’s), and would not be
detrimental to public health, safety, and general welfare.
(4) The proposed uses of the property are in harmony with the various elements or objectives of the
general plan and the purposes of this chapter.
The proposed uses are in harmony with the General Plan and the Town Code because
they contribute to the variety of commercial uses in the Central Business District.
The goals and policies of the 2040 General Plan (2020 Land Use and Community
Development Elements) applicable to this project include, but are not limited to:
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.
Policy LU-9.3: Encourage a mix of retail and office uses in commercial areas, except in the
Central Business District designation, where retail should be emphasized and office should
be limited to upper floors and other areas as defined by the Town Code.
Policy LU-9.6: Encourage development that maintains and expands resident-oriented
services and/or creates employment opportunities for local residents consistent with
overall land use policies of the Town.
Policy CD-1.4: Development on all elevations shall be of high quality design and
construction, a positive addition to and compatible with the Town’s ambiance.
Development shall enhance the character and unique identity of existing commercial
and/or residential neighborhoods.
(5) A hazardous waste facility proposal is subject to the California Health and Safety Code, Article
8.7, Section 25199—25199.14 and shall be consistent with the Santa Clara County Hazardous
Waste Management Plan.
Not Applicable
FORMULA RETAIL CONDITIONAL USE PERMIT FINDINGS
Further, the Formula Retail CUP requires that none of the additional findings below are made for a
proposed formula retail business exceeding 10,000 sf, pursuant to Town Code Section 29.20.190(b).
None of the below findings can be made to deny the Proposed Project, as further elaborated below:
(1) The proposed use of the property is not in harmony with specific provisions or objectives of the
general plan and the purposes of this chapter;
The proposed use is in harmony with the specific provisions and objectives of the general
plan and the purposes of Chapter 29 of the Town Code. Please review finding #2 under
Planned Development Ordinance Amendment (above) and finding #4 under Conditional
Use Permit (above) on how specific objectives of the general plan are met.
(2) The proposed use will detract from the existing balance and diversity of business in the
commercial district in which the use is proposed to be located;
The Proposed use will not detract from the existing balance and diversity of business in
the commercial district it is located within. The proposed uses, formula retail use and
restaurant use with the selling of alcoholic beverages for consumption on-premises,
represent no change from the current uses of the most recent tenants at the existing
building (Gap and Steamer’s).
(3) The proposed use would create an over-concentration of similar types of businesses, or
The proposed use would not create an over-concentration of similar types of businesses
as the former RH store will transform into a different concept, and the Proposed Project
also includes a hospitality component, which is unseen in other merchandise uses in the
neighborhood.
(4) The proposed use will detract from the existing land use mix and high urban design standards
including uses that promote continuous pedestrian circulation and economic vitality.
The proposed use does not detract from the existing land use mix and high urban design
standards. As noted previously, the Proposed Project complies with commercial design
guidelines including those which encourage pedestrian circulation. Further, the Proposed
Project replaces two vacant storefronts which currently deter pedestrian circulation and
additionally hinders economic vitality.
CONCLUSION
We believe the Proposed Project will enhance the corner of University Ave and Elm St in Old Town Los
Gatos by at once seamlessly fitting into the character and scale of the neighborhood surrounding,
while also providing visual interest through harmonious, textured, and elevated design. While the
Proposed Project’s programming does not represent a change of use from the existing use at the
building, the reimagined dining and shopping space will help improve customer experience, thereby
helping to activate pedestrian activity in this area.
The Proposed Project:
● Respects the existing scale and character of surrounding structures, and blends rather than
competes with the established character of the area.
● Presents elevations that are of high-quality design and construction, and a positive addition to
and compatible with the Town’s ambiance. The Proposed Project enhances the character and
unique identity of the existing commercial neighborhood.
● Represents no change in use from the former tenants at the existing building; rather the
Proposed Project will improve and reimagine a blend of both uses under one roof.
DEVELOPER and DESIGN FIRM INFORMATION
RH
RH is a curator of design, taste and style in the luxury lifestyle market. The company offers collections
through its retail galleries, sourcebooks and online at RH.com, RHContemporary.com, RHModern.com,
RHBabyandChild.com, RHTEEN.com, and Waterworks.com.
RH operates Galleries and outlets throughout the U.S., Canada, UK and Europe.
There are places you visit and those you remember™
Awards and Recognition
Award of Merit - Interior/Tenant Improvement – ENR Mountain States - RH Denver - 2016
Connecticut Preservation Award - Connecticut Trust for Historic Preservation – Former Greenwich
Post Office - 2015
Preservation Excellence Award (Adaptive Reuse) – Chicago Landmarks – Three Arts Club - 2016
MBH Architects
MBH Architects is a full service architecture and integrated services firm building innovative solutions
from offices in the San Francisco Bay Area, New York City, Denver, Mumbai and Bengaluru since 1989.
MBH Architects is a Minority-Owned Business Enterprise (MBE) with staff from around the world.
Their wide array of experience includes over 10,000 projects of nearly every project type, and their
global reach spans more than 96 countries worldwide. MBH Architects take incredible pride in our
work and clients' satisfaction.
Awards and Recognition
Gold - Shop! Design Awards - Bucherer Time Machine Flagship Store - 2023
Commercial Construction & Renovation Project Profile Award - 300 Grant - 2021
AIA East Bay Design Awards - 930 Brittan - 2021
Urban Confluence Design Competition - Breeze of Innovation - 2021
Honorable Mention - MNSD’s Retail Renovation Competition - Peet’s Coffee Georgetown - 2017