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2011062005 - Sustainability PlanMEETING DATE: 06/20/11 ITEM NO. CONSENT COUNCIL AGENDA. REPORT DATE: JUNE 8, 2011 TO: MAYOR AND TOWN COUNCIL FROM: GREG LARSON, TOWN MANAGER SUBJECT: SUSTAINABILITY PLAN A. AUTHORIZE THE TOWN MANAGER TO EXECUTE AN AGREEMENT WITH THE PLANNING CENTER DC&E TO PREPARE THE SUSTAINABILITY PLAN IN AN AMOUNT NOT TO EXCEED $79,541.00. B. AUTHORIZE STAFF TO EXECUTE FUTURE CHANGES TO THE AGREEMENT TO INCORPORATE THE DEVELOPMENT OF COMPLETE STREET STANDARDS AND UPDATE TIIE TOWN'S BICYCLE AND PEDESTRIAN MASTER PLAN IN AN AMOUNT NOT TO EXCEED GRANT AWARDS RECEIVED BY THE TOWN. RECOMMENDATION: 1. Authorize the Town Manager to execute an agreement with The Planning Center DC&E to prepare the Sustainability Plan in an amount not to exceed $79,541.00. 2. Authorize staff to execute future changes to the agreement to incorporate the development of complete street standards and update the Town's Bicycle and Pedestrian Master Plan in an amount not to exceed grant awards received by the Town. BACKGROUND: In September 2010, the Town Council adopted the 2020 General Plan. Action ENV-13.1 directs the Town to develop a Greenhouse Gas Emissions Reduction Plan. The subject authorization would allow the Town to proceed with this action item. Action TRA-2.5 directs the Town to revise the Los Gatos Boulevard Plan to incorporate "complete street" strategies and Action TRA-2.6 directs the Town to develop and implement a Streets Master Plan that incorporates "complete street" strategies. Action TRA-11.1 directs the PREPARED BY: Wendie R. Rooney, Director of Community Development Reviewed by: Assistant Town ManagerTown Attorney Clerk Finance ommunity Development Reformatted: 5/30/02 Revised: 6/14/11 10:30 AM PAGE 2 MAYOR AND TOWN COUNCIL SUBJECT: SUSTAINABILITY PLAN CONTRACT June 8, 2011 Town to develop and implement a Bicycle and Pedestrian Master Plan that will result in a comprehensive bicycle and pedestrian network throughout the Town, DISCUSSION: Staff distributed a Request for Proposal (RFP) to 11 consultants to prepare a Sustainability Plan. Three proposals were received and the candidate firms were interviewed by a panel of Town staff in May. The review panel unanimously concluded that The Planning Center DC&E is the best qualified to meet the needs of the Town. Once the consultant agreement has been executed, a detailed scope of work and time -line would be completed by staff and the consultant. DC&E prepared the Open Space, Parks and Trails Inventory, the Housing Element, and the 2020 General Plan for the Town. In March 2011, DC&E merged with The Planning Center to become The Planning Center DC&E. In addition to The Planning Center DC&E's familiarity with the Town of Los Gatos, the firm offers experience working with similar size communities to complete Sustainability Plans and greenhouse gas inventories. DC&E's proposal focuses on the topics identified in the 2020 General Plan Action ENV-13.1, streamlining future development, and obtaining greenhouse gas reduction credit for actions already taken by the Town. The proposed scope of work includes a community workshop, a community open house, and Town meetings. The Town was awarded a grant through the County of Santa Clara Public Health Department for programs that fight obesity. The grant will provide the Town funds to develop "complete street" standards (Action TRA-2.6 and Action TRA-11.1) and update the Town's Bicycle and Pedestrian Master Plan (Action TRA-11.1). Staff proposes that The Planning Center DC&E be retained to perform this work as an adjunct to their work on the Sustainability Plan, to be funded in full by the grant award. Staff believes their expertise and experience would serve the Town's needs to: 1. Draft a Complete Streets Policy for Los Gatos, using the model of the National Complete Streets Coalition. 2. Complete an inventory of all walking and bicycling trails in Los Gatos, and draft an updated map. ENVIRONMENTAL ASSESSMENT: Approval of the contract and initiation of the Sustainability Plan preparation is not a project as defined by CEQA. An environmental assessment would be conducted for the Plan and would be presented to the Planning Commission and Town Council with the Draft Sustainability Plan. PAGE 3 MAYOR AND TOWN COUNCIL SUBJECT: SUSTAINABILITY PLAN CONTRACT June 8, 2011 FISCAL IMPACT: The estimated cost to complete the proposed scope of work described in this proposal is $79,541. The cost for preparation of the Sustainability Plan would come from the General Plan Fund. Sufficient funds are available in this account. The future changes to the contract regarding "complete street" standards and the Town's Bicycle and Pedestrian Master Plan would not result in any fiscal impact to the Town, as it would be fully funded by a pass -through grant funding. CONCLUSION: Staff has concluded that The Planning . Center DC&E provides the best fit and professional expertise to prepare the Sustainability Plan and the development of complete street standards, and to contribute to the Town's Bicycle and Pedestrian Master Plan update. Staff recommends that the Town Manager be authorized to execute an agreement with The Planning Center DC&E to prepare the Sustainability Plan, and in future to execute an amendment to that agreement to add the grant -funded work. Attachments: 1. Sustainability Plan Scope of Work Distribution: The Planning Center DC&E, 1625 Shattuck Avenue Suite 300, Berkeley, CA 94709 WRR:JS:ct N:\DRV\TC REPORTS \201 1\SustainabilityPlanContract.docx THIS PAGE INTENTIONALLY LEFT BLANK a g 1 WORK SCOPE This chapter describes the scope of services to be completed by The Planning Center I DC&E team for the Sustainability Plan. To facilitate your review of this proposal and meet the page limits in the RFP, we have prepared a concise scope that emphasizes key components of our approach to this project. We will prepare a more detailed scope when we enter into a contract. The Planning Center I DC&E will be the prime consultant and will have primary responsibility for developing the Sustainability Plan and modeling emissions. Our only subconsultant will be Fehr & Peers Transportation Consultants, who will help formulate and model transportation -related emis- sions reductions strategies. TASK A. Project Initiation 1. PROJECT KICK-OFF MEETING The Planning Center I DC&E team will meet with the Town to review the scope and discuss our approach to preparing the Sustainability Plan and environmental documentation. At this meeting, we will review existing background data; review existing Town programs and policies that address climate change; discuss data availability, emissions target year, reduction target development strat- egy; different Sustainability Plan document outlines; and identify how Town staff and The Planning Center I DC&E can most effectively work together as a team and minimize demands on Town staff. 2. DATA COLLECTION The Planning Center I DC&E team will collect data relevant to the development of the Sustainabil- ity Plan. Although the Town's GHG emissions affect conditions outside of Town boundaries, data collection and subsequent GHG reduction measures will focus on sources and conditions within Town boundaries. During this task, The Planning Center I DC&E team will gather two types of information: (1) data on existing conditions, plans, and programs, including household and em- ployment growth projection data and townwide transportation model data, and (2) ideas for new plans and programs that can be implemented to reduce GHG emissions. The first set of data will be used to prepare a future year business -as -usual GHG emissions projection against which emis- sions reduction strategies developed in Task C can be measured. The second type of information will feed into the preparation of GHG emissions reduction strategies. 3. REVIEW TOWN POLICY DOCUMENTS The Planning Center I DC&E will review the 2020 General Plan, the General Plan EIR, the Town Code, and other Town documents to identify policies that are already contributing to GHG emis- sions reductions. a SUSTAINABILITY PLAN TOWN OF Los GATOS ATTACHMENT 1 2. Work Scope gt'„-' 5 TABLE 1 WORK PROGRAM SUMMARY Task A: Project Initiation 1. Project Kick -Off Meeting 2. Data Collection Task B: Greenhouse Gas Inventories 1. Evaluate 2005 Greenhouse Gas Inventory 2. Prepare 2010 & Target Year Greenhouse Gas Inventories Task C: Greenhouse Gas Reduction & Adaptation 1. Community Workshop 2, Establish Greenhouse Gas Emissions Reductions Target 3. Town Staff Discussion of Operation Changes OPTIONAL TASK 4. Preliminary Sustainability Plan Measures Task D: Sustainability Plan 1, Administrative Draft Sustainability Plan 3. 2. Public Review Draft Sustainability Plan 3. Review Town Policy Documents 4. Review Town Development Review Process 3. Review Greenhouse Gas Inventory Results with Town Staff Mitigation Strategies 5. 6. 7. 8. 4. Task E: Initial Study/Mitigated Negative Declaration 1. Administrative Draft IS/MND and MMRP 3. 2. Draft IS/MND and MMRP Refined List of Sustainability Plan Measures Quantification of Emissions Reduction Measures Sustainability Plan Monitoring Program Adaptation Mitigation Strategies Open House & Public Hearings on Draft Sustainability Plan Final Sustainability Plan Public Revievv/Responses to Comments 4. REVIEW TOWN DEVELOPMENT REVIEW PROCESS The Planning Center I DC&E will review the Town's development review process, including the environmental review process, to identify measures the Town is already taking to reduce GHG emissions from new development and to understand how additional measures could be added to the development review process, if needed, Assistance Required from Town Staff ® Organizing and attending Kick -Off Meeting • Providing any Town documents The Planning Center I DC&E does not already have J. Responding to questions about Town policies and/or review processes TASK B. Greenhouse Gas Inventories The Planning Center I DC&E team will prepare GHG inventories for both the current year and emissions forecasts for the "business as usual" (BAU) scenario using ICLEI — Local Governments for Sustainability's (ICLEI's) Clean Air and Climate Protection (CACP). The Planning Center I DC&E team will inventory both municipal and community GHG emissions for the current year, relying on available data from the Town and other agencies. 6 FE 2. Work Scope SUSTAINARILITY PLAN Towc OF LOS GATOS 1, EVALUATE 2005 GREENHOUSE GAS INVENTORY The Planning Center I DC&E team will review the Town's 2005 GHG inventory and determine how best to incorporate it into the Sustainability Plan process. Although we have already utilized the final 2005 inventory for the 2020 General Plan EIR, we have not worked with the data that was used to generate the final inventory. This scope assumes that Town staff can provide the back- ground data and methodology used for the 2005 inventory. 2. PREPARE 2010 AND TARGET YEAR GREENHOUSE GAS INVENTORIES The Planning Center I DC&E team will prepare GHG inventories for the Town as a whole and for Town government operations for 2010, relying on available data from the Town and other agen- cies, collected in Task A.2 above. We will also prepare emissions forecasts for the BAU scenario for the agreed upon target year. Since the Town does not have its own travel demand forecasting model, Fehr & Peers will use the Santa Clara Valley Transportation Authority (VTA) countywide model as a starting point to calculate the Town's Base Year (2010) and Future Year total VMT estimates, per BAAQMD Guidelines. The Planning Center I DC&E team will then use the current year GHG inventories as the basis for preparation of GHG emissions projections for BAU conditions. The BAU forecast will not incorpo- rate potential GHG emissions reductions from State and federal GHG reduction efforts, such as Title 24 revisions or fuel economy standards; such reductions will be incorporated into the model- ing work under Task C.4. These inventories will be completed using ICLEI's CACP modeling soft- ware and the BAAQMD GHG Model, with inputs and modifications as described above. The in- ventories will be compiled into a memorandum with text and tables for submittal to Town staff. 3. REVIEW GREENHOUSE GAS INVENTORY RESULTS WITH TOWN STAFF The Planning Center I DC&E will present the findings of the GHG inventories to Town staff and discuss the implications of findings for policy priorities and design of the Sustainability Plan. This presentation is anticipated to be conducted via webinar. Assistance Required from Town Staff ® Provide data and methodology for 2005 inventory • Review GHG inventory results TASK C.. Greenhouse Gas Reduction and Adaptation Mitigation Strategies Based on the inventory and forecast developed in Task B.1, the Town's GHG reduction target, and input from the community workshop, The Planning Center I DC&E team will work with Town staff to prepare a set of preliminary Sustainability Plan measures. 1. COMMUNITY WORKSHOP The Planning Center.I DC&E will prepare for and attend an interactive community workshop to engage the public. At these meetings, The Planning Center I DC&E will present an overview of climate change and related State and local regulations, policies, and programs. The Planning Cen- SUSTAINABILITY PLAN TowN OF Los GATOS 2. Work Scope LIx7.1 7 ter I DC&E will also present the results of the GHG inventories and BAU forecasts, take comments from the public, and solicit input on potential emission reduction measures. 2, ESTABLISH GREENHOUSE GAS EMISSIONS REDUCTIONS TARGET The Planning Center I DC&E team will work with the Town to develop an appropriate reduction target for the Sustainability Plan that is consistent with State and BAAQMD requirements. Issues to consider in setting the target include determining the appropriate target year and whether to measure emissions in absolute numbers, a percentage decrease, or a per capita basis. 3, TOWN STAFF DISCUSSION OF OPERATIONAL CHANGES OPTIONAL TASK As an optional task, The Planning Center I DC&E staff will meet with Town employees to review existing Town operations, including maintenance activities, Town vehicles, and purchasing prac- tices, and discuss feasible opportunities to change Town practices to reduce GHG emissions. 4, PRELIMINARY SUSTAINABILITY PLAN MEASURES The Planning Center I DC&E team will compile a preliminary list of feasible Sustainability Plan measures that will address the best practice areas recommended by the Institute for Local Gov- ernment and identified in the RFP: energy conservation; water and wastewater; green building; solid waste; purchasing; renewable energy and low -carbon fuels; transportation; land use and community design; open space; and community action. The Sustainability Plan measures will be aimed at meeting the target established in Task C.2, and will be developed with regard to the following factors: • State legislation and guidance pertaining to GHGs, including the AB 32 Scoping Plan, SB 375 and Section 15183.5 of the CEQA Guidelines, • Regional frameworks such as the Sustainable Communities Strategy currently being prepared by ABAG, MTC, BCDC, and BAAQMD. ® Existing General Plan policies and Town Code sections that may reduce GHG emissions. ® Best practices developed by other local agencies and organizations. ® Community. input. + Potential significant environmental impacts. • Sustainability Plans in communities around the state that have similar small-town, built -out characters as Los Gatos and a similarly high quality of life. + Urban Land Institute Publication Growing Cooler (partially authored by Fehr & Peers). • CAPCOA GHG emissions quantification methodologies. The preliminary list of strategies will also include any site -specific GHG reduction measures that need to be incorporated into the North Forty Specific Plan or other future significant development proposals. The Planning Center I DC&E team will use available data and research to quantify the effects of these measures as opposed to collecting new data. The Planning Center I DC&E team will provide an order -of -magnitude estimate of GHG emissions reductions for the preliminary list of Sustain - ability Plan measures. Additionally, The Planning Center I DC&E team will identify any emissions reduction measures that may have potentially significant unavoidable environmental impacts. This S _ Vv rL Scope SLnTAINABILIIY PLAN TDWi of Los GATOE additional detail will be necessary to.ensure that Town staff is notified and aware of any measures that might require the preparation of an EIR. For each reduction measure, The Planning Center j DC&E team will define the measure, the im- plementing party (directly done by the Town or through Town development approvals), the order - of -magnitude reduction, the source for this reduction, and any caveats/limitations. The Planning Center I DC&E team will also prepare initial estimates of the relative effectiveness of these various strategies in order to highlight those strategies which have the highest level of effectiveness. 5. REFINED LIST OF SUSTAINABILITY PLAN MEASURES The Planning Center I DC&E will meet with Town staff to review the preliminary list of Sustainabil- ity Plan measures. During this meeting, The Planning Center I DC&E and Town staff will discuss the pros and cons of individual Sustainability Plan measures, the applicability and feasibility of Sustainability Plan measures in Los Gatos, and prioritization strategies. Based on direction from Town staff, The Planning Center I DC&E will refine the list of Sustainability Plan measures that will be modeled. For the final 'list of emission reduction strategies, The Planning Center I DC&E team will provide additional information regarding each strategy, including: ® A detailed description of the strategy and how it might be implemented. ® What parties are responsible for implementing the strategy (Town, private developers, etc). ® An approximate cost of each strategy to both the Town and private parties. ® A final emissions reduction estimate, based on any refinements of the strategy during the vet- ting process. 6. QUANTIFICATION OF EMISSIONS REDUCTION MEASURES The Planning Center I DC&E team will use the refined list of emissions reduction measures as the basis for the target year emissions reduction analysis. The Planning Center I DC&E will use ICLEPs Climate and Air Pollution Planning Assistant (CAPPA), a decision support tool that models GHG emissions reductions and is intended to be used as the counterpart to the CACP model for the GHG inventory, as well as the BMQMD GHG Model. In addition, The Planning Center I DC&E team will model external State -level measures that will help the Town to achieve its GHG emis- sions reduction. This task will use the GHG inventory and BAU forecast referenced as a baseline. The Planning Center I DC&E team will estimate the costs to implement each Sustainability Plan measure. The cost estimates will be based on available information from the CAPPA model, sup- plemented by additional research of implementation costs from other jurisdictions. As. an outcome of this task, The Planning Center I DC&E will submit a matrix containing the Sus- i tainability Plan measures and their associated quantified Carbon Dioxide (CO2) equivalent reduc- tions, costs for implementation, cost effectiveness, implementation tools, and performance meas- ures. The matrix will be in an interactive format so that the consultant team and Town staff can easily gauge the Sustainability Plan's ability to achieve the GHG target under various implementa- tion scenarios, such as a moderate implementation scenario in which only a subset of Sustainabil- i ity Plan measures are implemented. The Planning Center I DC&E will present the preliminary results to Town staff for review. This scope assumes that, given the careful review of the preliminary emissions reduction measures, SUSfA1NABILITY PLAN TDWN OF LOS GATOS 2. Work Scope 3 only minor revisions will be needed and that the suite of emissions reduction measures will be sufficient to achieve the Town's target. Should the Town require detailed revisions or expanded analysis of emissions reduction measures, a scope and fee adjustment may be necessary. 7, SUSTAINABILITY PLAN MONITORING PROGRAM The Planning Center I DC&E team will develop a monitoring and reporting plan that tracks imple- mentation of emissions reduction measures, quantifies progress, and lays out timelines for up- dates. The Sustainability Plan Monitoring Program will outline the types of information to be col- lected quarterly and annually and will assign clear responsibilities for tracking and implementation. 8, ADAPTATION MITIGATION STRATEGIES The Planning Center I DC&E will prepare a set of strategies to guide the Town in adapting to the environmental changes that are expected to result from global warming, such as increased fire risk, decreased water supply, and extreme weather events, Assistance Required from Town Staff A Identify and reserve community workshop location e Respond to consultant suggestion of appropriate target e Review preliminary measures and coordinate other departments' review e Organize meeting to discuss preliminary measures e Review emissions reductions quantification, monitoring program, and adaptation strategies TASK D. Sustainability Plan 1. ADMINISTRATIVE DRAFT SUSTAINABILITY PLAN The Planning Center I DC&E team will utilize the efforts and deliverables developed under the above tasks as inputs to prepare the Administrative Draft Sustainability Plan. The Planning Cen- ter I DC&E will structure the Sustainability Plan in a manner which best suits the Town. However, it is anticipated that the Sustainability Plan will at least contain the following sections: • Introduction ® Los Gatos Municipal and Community GHG Emissions Inventory • GHG Emissions Reduction Targets e GHG Emissions Reduction Measures e Implementation Plan and Monitoring Program e Technical Appendix The Sustainability Plan will include a discussion of the many Town actions and programs already underway that address climate change and reduce GHG emissions. The Sustainability Plan will also describe the GHG reduction measures and modeling results prepared under Task C.3. The implementation plan and monitoring program component of the Sustainability Plan will in- clude a discussion of the costs to implement each measure, as well as the associated cost effec- tiveness of the measures. In addition, the Sustainability Plan will identify responsible parties for implementation and potential financing mechanisms. This cost analysis will inform the prioritiza- tion and implementation schedule of the Sustainability Plan measures in order to achieve the 10 10 2 VVork Scope SUSTAINABILITY PLAN TOWN OF Los GATOS Town's GHG targets while balancing implementation costs. Finally, the implementation plan and monitoring program will provide mechanisms for monitoring progress and updating the GHG inventory and Sustainability Plan measures. The Sustainability Plan will also include an appendix that documents all methodologies and as- sumptions used in the GHG modeling process in plain English. 2. PUBLIC REVIEW DRAFT SUSTAINABILITY PLAN The Planning Center I DC&E team will address all Town comments on the Administrative Draft Sustainability Plan to create the Draft Sustainability Plan. The budget for this task assumes an allowance of 40 hours for revisions to the Administrative Draft Sustainability Plan after Town staff review, If additional labor is necessary due to unforeseen volumes of comments, a contract amendment allowing additional work will be necessary. The Planning Center I DC&E will submit one electronic copy of the screencheck copy of the Draft Sustainability Plan for Town staff review. We assume that any changes to the Screencheck Draft Sustainability Plan will be of a minor, typographical nature and have included an allowance of 10 hours for revisions to the Screencheck Draft Sustainability Plan. The Planning Center I DC&E will provide the Town with one electronic copy of the Draft Sustain - ability Plan. 3. OPEN HOUSE AND PUBLIC HEARINGS ON DRAFT SUSTAINABILITY PLAN The Planning Center I DC&E will attend a public hearing before the Planning Commission on the Public Review Draft Sustainability Plan. The Planning Center I DC&E will prepare for and attend a community open house immediately preceding the Town Council hearing on the Draft Sustainability Plan. The open house will be an opportunity to provide the public with a detailed overview of the draft plan and respond to ques- tions. Following the open house, The Planning Center I DC&E will attend a hearing before the Town Council for the adoption of the Sustainability Plan and approval of the Initial Study/Mitigated Negative Declaration. 4.. FINAL SUSTAINABILITY PLAN Once the Sustainability Plan is adopted, The Planning Center I DC&E will finalize the Sustainability Plan. The final document will include revisions resulting from the environmental review process and those revisions directed by Town decision -makers during the adoption and environmental review process. The Planning Center I DC&E will submit to the Town one electronic copy each of the Final Sustainability Plan. Assistance Required from Town Staff • Review Administrative Draft Sustainability Plan • Review Screencheck Draft Sustainability Plan ® Distribute Public Review Draft Sustainability Plan • Identify and reserve location for open house SUSTAINABILITY PLAN TOWN of Los GATOS 2. Work Scope E TASK E. InitialStudy/Mitigated Negative Declaration The Planning Center I DC&E will prepare a stand-alone Initial Study that will include a project de- scription and information to support all the conclusions regarding the threshold questions con- tained in Appendix G of the CEQA Guidelines. The Initial Study will be tiered off the recent 2020 General Plan EIR, which anticipated the preparation of the Sustainability Plan and which The Plan- ning Center I DC&E prepared. The IS will determine if any environmental impacts are anticipated due to implementation of the Sustainability Plan, and will include mitigation measures as required. If the Initial Study or the Town determines that an EIR will be required, a contract amendment would be required to complete the EIR. The IS will present evidence that indicates that significant environmental effects will be avoided, or mitigated to less -than -significant levels, as appropriate. Through the completion of the IS, The Planning Center I DC&E will evaluate all of the topic areas identified in the CEQA thresholds. In addition, The Planning Center I DC&E will complete a Mitigation Monitoring and Reporting Pro- gram (MMRP) for the IS/MND. This program, shown in tabular form, will identify responsibility for implementing and monitoring each mitigation measure contained in the Initial Study, along with monitoring triggers and reporting frequency. The IS/MND and MMRP will be submitted to the Town for review, as follows: 1, ADMINISTRATIVE DRAFT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION AND MITIGATION MONITORING AND REPORTING PROGRAM The Planning Center I DC&E will submit this first draft to the Town for review in electronic format. The Town will provide The Planning Center I DC&E with a consolidated set of comments on the report. This assumes that The Planning Center I DC&E will respond to one round of comments on the Administrative Draft received from the Town. 2. DRAFT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION AND MITIGATION MONITORING AND REPORTING PROGRAM The Planning Center I DC&E will provide the Town with an electronic copy of the Draft IS/MND. This assumes that the Town will circulate copies of the document to the State Clearinghouse, as required by CEQA, and to interested members of the public. 3. PUBLIC REVIEW/RESPONSES TO COMMENTS • Once the IS/MND is published with the State Clearinghouse, CEQA requires a 30-day public review period during which the document will be available for review and comment. The Planning Cen- ter I DC&E will respond to substantive comments received on the IS/MND in a memorandum form. The Planning Center I DC&E's labor for this task is limited to 16 hours, which includes the time required to revise responses based on input from the Town. Any additional labor for this task beyond .16 hours would require a budget amendment. Assistance Required from Town Staff • Review Administrative Draft IS/MND and MMRP ® Distribute Draft IS/MND to public and State Clearinghouse • Review memo of Response to Comments 12 2 Work Scope SUAAINABPLITY Pun TOWN ce Los GATOS