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Item 1 - Addendum 2 with Exhibits 29 and 30.178 Twin Oaks Dr PREPARED BY: Erin M. Walters Senior Planner Reviewed by: Planning Manager, Community Development Director, Town Attorney 110 E. Main Street Los Gatos, CA 95030 ● (408) 354-6872 www.losgatosca.gov TOWN OF LOS GATOS PLANNING COMMISSION REPORT MEETING DATE: 12/17/2025 ITEM NO: 1 ADDENDUM 2 DATE: December 16, 2025 TO: Planning Commission FROM: Joel Paulson, Community Development Director SUBJECT: Consider a Request for Approval for the Subdivision of One Lot into Twelve Lots with a Vesting Tentative Map, Construction of a New Single-Family Residence on Each Lot, Site Work Requiring a Grading Permit, and Removal of Large Protected Trees Under Senate Bill 330 (SB 330) on Vacant Property Zoned RC. Located at 178 Twin Oaks Drive. APN 532-16-006. Architecture and Site Applications S-24-023 through -033 and S-24-059, Vesting Tentative Map Application M-24-013, and Mitigated Negative Declaration Application ND-25-001. An Initial Study and Mitigated Negative Declaration Have Been Prepared. Property Owner/Applicant: Larry Dodge. Project Planner: Erin Walters. REMARKS: A Responses to Comments document was prepared in response to comment letters received during the public review period of the Surrey Farms Estates Subdivision Project Initial Study/Mitigated Negative Declaration (IS/MND) (Exhibit 13). After the close of the public review period, the Town received one comment letter authored by the Santa Clara Valley Bird Alliance (SCVBA) and Sierra Club Loma Prieta Chapter (SCLP). Exhibit 29 provides responses to the SCVBA and SCLP letter dated October 17, 2025. Exhibit 30 includes public comments received between 11:01 a.m., Monday, December 15, 2025, and 11:00 a.m., Tuesday, December 16, 2025. EXHIBITS: Previously Received with the December 12, 2025, Staff Report: 1. Initial Study and Mitigated Negative Declaration with Appendices A through E (available online at https://www.losgatosca.gov/178TwinOaksDr) 2. Required Findings and Considerations PAGE 2 OF 2 SUBJECT: 178 Twin Oaks Drive, Lots 1-12/S-24-023 to 033, S-24-059, M-24-013, and ND-24-001 DATE: December 16, 2025 3. Recommended Conditions of Approval – M-24-013, S-24-023 to -033 and S-24-059 4. Location Map 5. Project Description and Letter of Justification 6. Consulting Architect’s Report 7. Applicant’s Response to Consulting Architect’s Report 8. Final Arborist Report 9. Consulting Arborist’s Peer Review 10. Visual Renderings 11. Public comments received by 11:00 a.m., Friday, December 12, 2025 12. Mitigation Monitoring and Reporting Program 13. Public Comments and Responses Regarding the Mitigated Negative Declaration 14. Initial Study/Mitigated Negative Declaration Errata Sheet 15. Development Plans – Subdivision 16. Development Plans – Lot 1 17. Development Plans – Lot 2 18. Development Plans – Lot 3 19. Development Plans – Lot 4 20. Development Plans – Lot 5 21. Development Plans – Lot 6 22. Development Plans – Lot 7 23. Development Plans – Lot 8 24. Development Plans – Lot 9 25. Development Plans – Lot 10 26. Development Plans – Lot 11 27. Development Plans – Lot 12 Received with the December 15, 2025, Addendum Report: 28. Public comments received between 11:01 a.m., Friday, December 12, 2025, and 11:00 a.m., Monday, December 15, 2025 Received with this Addendum Report: 29. Responses to the Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter 30. Public comments received between 11:01 a.m., Monday, December 15, 2025, and 11:00 a.m., Tuesday, December 16, 2025 Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 1 INTRODUCTION A Responses to Comments document was prepared in response to comment letters received during the public review period of the Surrey Farms Estates Subdivision Project Initial Study/Mitigated Negative Declaration (IS/MND). The Town of Los Gatos received one comment letter after the close of the public review period. The late letter was authored by the Santa Clara Valley Bird Alliance (SCVBA) and Sierra Club Loma Prieta Chapter (SCLP). According to CEQA Guidelines Sections 15073 and 15074, the lead agency must consider the comments received during consultation and review periods together with the IS/MND. However, unlike with an Environmental Impact Report (EIR), comments received on an IS/MND are not required to be attached to the negative declaration, nor must the lead agency make specific written responses to public agencies. Therefore, pursuant to CEQA and additionally because the letter was not received during the public comment period for the IS/MND, written responses to the SCVBA and SCLP letter are not required. Nonetheless, at the Town’s request, Raney has prepared the following written responses to the late SCVBA and SCLP letter for the record. The comment letter has been bracketed to indicate how the letter has been divided into individual comments. Each comment is given a number. The response to each comment will reference the comment number. CEQA Guidelines Section 15073.5 states the following regarding recirculation requirements for negative declarations: (c)Recirculation is not required under the following circumstances: (1)Mitigation measures are replaced with equal or more effective measures pursuant to Section 15074.1. (2)New project revisions are added in response to written or verbal comments on the project's effects identified in the proposed negative declaration which are not new avoidable significant effects. (3)Measures or conditions of project approval are added after circulation of the negative declaration which are not required by CEQA, which do not create new significant environmental effects and are not necessary to mitigate an avoidable significant effect. (4)New information is added to the negative declaration which merely clarifies, amplifies, or makes insignificant modifications to the negative declaration. Based on the above, and the substantial evidence provided in the below responses to comments, pursuant to CEQA Guidelines Section 15073.5, recirculation of the IS/MND is not warranted. RESPONSES TO VALLEY BIRD ALLIANCE AND SIERRA CLUB LOMA PRIETA CHAPTER LETTER EXHIBIT 29 Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 2 1 Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 3 1 cont. Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 4 1 cont. 2 3 Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 5 3 cont. 4 5 Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 6 5 cont. Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 7 5 cont. 6 Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 8 6 cont. Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 9 6 cont. 7 Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 10 8 9 10 11 Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 11 11 cont. 12 13 14 Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 12 14 cont. 15 16 17 Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 13 17 cont. Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 14 RESPONSES TO SCVBA AND SCLP LETTER Response to Comment 1 The comment is introductory and summarizes the commenter’s concerns that are presented in further detail subsequently in the letter. Detailed responses to the more specific comments presented in the letter are provided below. Response to Comment 2 This comment has already been addressed in the Town’s responses to the Regional Water Quality Control Board (RWQCB) letter referenced by the commenter. Please see Exhibit 13 of the December 17, 2025 Planning Commission Staff Report, which contains the responses to public comments received during the public review period for the IS/MND. Specifically, please refer to Response to Comment 1-1 therein. Response to Comment 3 This comment has already been addressed in the Town’s responses to the Regional Water Quality Control Board (RWQCB) letter. Please see Exhibit 13 of the December 17, 2025 Planning Commission Staff Report, which contains the responses to public comments received during the public review period for the IS/MND. Specifically, please refer to Responses to Comments 1-4 and 1-5 therein. Response to Comment 4 This comment has already been addressed in the Town’s responses to the Regional Water Quality Control Board (RWQCB) letter. Please see Exhibit 13 of the December 17, 2025 Planning Commission Staff Report, which contains the responses to public comments received during the public review period for the IS/MND. Specifically, please refer to Response to Comment 1-4 therein. Response to Comment 5 The comment does not present substantial evidence of a direct significant impact to any special- status species. Urban-adapted and common birds are the most likely to collide with windows due to their higher frequency of occurrence and likelihood of interaction along the built environment interface. Moreover, as reported in the San Francisco Standards for Bird Safe Buildings1 and other documents, the typical bird strike zone is from grade to 60 feet, the primary concern is with any uninterrupted glazing 24 square feet or larger in size, and the likelihood of strike depends on various factors, including the glazing used, the angle of the glass, the orientation of the building, and landscaping. Although the proposed residences would include windows, the features listed within the comment (expansive glass, transparent facades, glass balcony railings, corner glazing, and atriums) are not anticipated to be included within the proposed residences. In addition, based on the architectural design sheets for the proposed project, the proposed building facades would include many materials other than glass that are visible to birds. Such materials would include wood siding and stone veneer. Further, the elevations also feature forms of architectural relief (overhangs, spatially-offset adjacent faces), as well as varied (opaque) materials and colors. All of the aforementioned architectural design features would serve to minimize operation impacts related to the risk of bird strikes. 1 San Francisco Planning Department. 2011. Standards for bird-safe buildings. San Francisco Planning Department, City and County of San Francisco, California. Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 15 Response to Comment 6 Impacts related to lighting are discussed under question I-d within Section I, Aesthetics, of the IS/MND. As stated on Page 29 therein: According to the project applicant, all exterior lighting (i.e., both building-mounted and landscape lighting) would be designed consistent with the Hillside Design Standards and Guidelines outdoor lighting standards, which require the minimum lighting required for pedestrian safety and require compliance with the Town’s Municipal Code. To reduce the potential for disturbance due to nighttime lighting, the project would comply with Town Code Section 29.10.09015, which requires all permanent exterior light fixtures to use shields so that bulbs are not visible and to ensure that light is directed to the ground surface and does not spill onto neighboring parcels or produce glare when seen from nearby homes. As such, the proposed project would comply with both the Town’s Municipal Code and policies within the Hillside Design Standards and Guidelines. The standards referenced above would ensure that project lighting would be shielded and directed downward, among other requirements, consistent with the commenter’s recommendation. In addition, as stated on page 28 of the IS/MND, existing sources of light and glare including, but not limited to, headlights on cars and trucks travelling along nearby roadways and private driveways, exterior light fixtures, and interior light spilling through windows, are present within the project vicinity. Therefore, while the development of the project site with 12 single-family residences would add new sources of light and glare to the site, such sources would be similar in nature to the existing surrounding conditions. Based on such, wildlife species in the vicinity would be expected to be somewhat urban-adapted, particularly to existing lighting in the vicinity. The comment specifically mentions riparian corridor lighting. As discussed in the IS/MND and Response to Comment 24-2 (see Exhibit 13 of the December 17, 2025 Planning Commission Staff Report), the only identified riparian woodland is in the vicinity of Ross Creek in the site’s southwest corner; development within the riparian woodland area is not proposed, and Ross Creek would not be directly impacted by the proposed project. Also see Response to Comment 1-5 of Exhibit 13 of the December 17, 2025 Planning Commission Staff Report, which states that the trees within the ephemeral drainage/drainage swale is mixed oak woodland habitat, not riparian habitat. The comment does not provide any substantial evidence that additional lighting at the site that is designed consistent with the Town’s Municipal Code and policies within the Hillside Design Standards and Guidelines would affect the breeding behavior of any special-status species to a degree that would preclude them from productive breeding. Therefore, substantial evidence that a direct significant impact would occur to any special-status species as a result of project lighting has not been provided. Response to Comment 7 The comment summarizes the commenter’s concerns regarding habitat loss, fragmentation, and special-status species, which are expanded upon within Comments 8 through 11. Please see the detailed responses to the more specific comments below. In addition, although the mitigation measures set forth in the IS/MND require pre-construction surveys, such surveys are not the full extent of the mitigation measure requirements related to special-status wildlife species. Pre-construction surveys are required as the first step to Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 16 conclusively identify the presence or absence of specific species, the mitigation measures included within the IS/MND (including Mitigation Measures IV-2, IV-4, and IV-6 through IV-9) specify what actions shall be taken if the surveys result in positive identification, as well as the appropriate overseeing authority. Response to Comment 8 This comment has already been addressed in the Town’s responses to public comments received during the public review period for the IS/MND. Please see Exhibit 13 of the December 17, 2025 Planning Commission Staff Report. Specifically, please refer to Responses to Comments 2-3 and 24-2 therein. In addition, contrary to the comment, total tree loss is specifically quantified and addressed in the IS/MND (e.g., see page 50 of IS/MND) and a project-specific Arborist Report was prepared. Response to Comment 9 Please see Response to Comment 3 above. Response to Comment 10 Please see Response to Comment 7 above. The commenter incorrectly states that the IS/MND defers species protection to future conditions. Mitigation Measure IV-4 includes standards and actions to implement if active nests are found as a result of the required pre-construction survey. As noted on page 46, such standards include the following: If one or more active nests are found, a construction-free buffer of suitable dimensions shall be established around any active raptor or migratory bird nest for the duration of the project, or until the qualified biologist has determined that the chicks have fledged and are foraging independently from their parents. The buffer shall be identified on the ground with flagging or fencing. The buffer distance shall be determined by the on-site qualified biologist based on the species, level of disturbance activity, location of the nest, and the topography between the nest and the construction activity; the construction-free buffer shall consist of a minimum starting distance of 250 feet for raptors and 25 feet for other birds. Proof of compliance with this mitigation measure shall be provided to the Town of Los Gatos Community Development Department. As stated in Response to Comment 5-25 of the Town’s responses to public comments received during the public review period for the IS/MND (see Exhibit 13 of the December 17, 2025 Planning Commission Staff Report), the mitigation measures included within the IS/MND would provide protection to the species listed in the comment. Although the species listed within the comment were not specifically identified as having a high potential to occur on-site by the Biological Evaluation, the required measures within Mitigation Measures IV-3 and IV-4 through IV-6 would also reduce potential impacts to any unlikely occurrences of the species. Response to Comment 11 As noted on page 42 of the IS/MND, “…Crotch’s bumble bee was eliminated due to a lack of suitable habitat and nectar plants within the project site, as well as the nearest recorded CNDDB observation occurring more than three miles from the site.” Therefore, the species is not anticipated to occur on-site and was not considered further within the IS/MND. Response to Comment 12 Please see Responses to Comments 7 through 11 above. Responses to Santa Clara Valley Bird Alliance and Sierra Club Loma Prieta Chapter Letter Surrey Farms Estates Subdivision Project December 2025 Page 17 Response to Comment 13 CEQA Guidelines Section 15064 also includes the following: (4) The existence of public controversy over the environment effects of a project will not require preparation of an EIR if there is no substantial evidence before the agency that the project may have a significant effect on the environment. (5) Argument, speculation, unsubstantiated opinion or narrative, or evidence that is clearly inaccurate or erroneous, or evidence that is not credible, shall not constitute substantial evidence. Substantial evidence shall include facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts. Please see Responses to Comments 1-1 through 1-6 of the Town’s responses to public comments received during the public review period for the IS/MND (see Exhibit 13 of the December 17, 2025 Planning Commission Staff Report), which comprise the responses to the RWQCB comments. As shown therein, the RWQCB comments do not provide substantial evidence as defined by CEQA Guidelines Section 15064 that would require preparation of an EIR. Response to Comment 14 Please see Responses to Comments 3, 4, 7, and 8 above. Response to Comment 1-15 Please see Responses to Comments 2 and 13 above. In addition, as presented in the Responses to Comments document and Errata Sheet prepared for the proposed project (see Exhibits 13 and 14 of the Town’s December 17, 2025 Planning Commission Staff Report, respectively), and based on the responses included herein, pursuant to CEQA Guidelines Section 15073.5, recirculation of the IS/MND is not warranted. Response to Comment 1-16 CEQA review of the proposed project has not been waived, as evidenced by preparation of the IS/MND. The project, as proposed, has been adequately analyzed pursuant to CEQA. Response to Comment 1-17 The comment is a summary of all preceding comments and a conclusion. Please see the detailed responses above. The comment has been forwarded to the decision-makers for their consideration. This Page Intentionally Left Blank -----Original Message----- From: karri greenfield <> Sent: Monday, December 15, 2025 6:52 PM To: Erin Walters <EWalters@losgatosca.gov> Subject: Dodge Housing Project [EXTERNAL SENDER] Hello Erin, Unfortunately, I won’t be able to attend the planning meeting on Wednesday, December 17th but I wanted to express my opinion. My first concern with the development of the Dodge property is safety especially if there is a fire. I feel very strongly that there should be two ways to evacuate the properties. One entrance/exit off of Twin Oaks and another entrance/exit off of Brooke Acres. Secondly, I am concerned about traffic. Another reason to have two entrances. Thank you for your consideration. Karri Greenfield Longmeadow Dr. Los Gatos Sent from my iPhone EXIHIBIT 30 This Page Intentionally Left Blank