Attachment 14PREPARED BY: JENNIFER ARMER
Associate Planner
Reviewed by: Planning Manager and Community Development Director
110 E. Main Street Los Gatos, CA 95030 ● 408-354-6874
www.losgatosca.gov
TOWN OF LOS GATOS
PLANNING COMMISSION
REPORT
MEETING DATE: 05/10/2017
ITEM NO: 2
ADDENDUM B
DATE: MAY 9, 2017
TO: PLANNING COMMISSION
FROM: JOEL PAULSON, COMMUNITY DEVELOPMENT DIRECTOR
SUBJECT: ARCHITECTURE AND SITE APPLICATION S-15-056, CONDITIONAL USE
PERMIT APPLICATION U-15-009 AND ENVIRONMENTAL IMPACT REPORT
EIR-16-001. PROJECT LOCATION: 401-409 ALBERTO WAY. PROPERTY
OWNER: CWA REALTY. CONTACT PERSON: SHANE ARTERS, LP
ACQUISITIONS, LLC.
REQUESTING APPROVAL TO DEMOLISH THREE EXISTING OFFICE
BUILDINGS AND CONSTRUCT A NEW, TWO-STORY OFFICE BUILDING WITH
UNDERGROUND PARKING ON PROPERTY ZONED CH. APN 529-23-018.
REMARKS:
Parks and Public Works (PPW) Department staff have updated their previous Project
Information Sheet (Exhibit 41) for this project (available online
http://www.losgatosca.gov/2415/Project-Information-Sheets) to add the following two
additional questions and answers:
Q: Does the Town Engineering staff or the Town's engineering consultants have concerns
with the proposed project creating safety issues regarding traffic, grading, drainage,
and/or soil conditions?
A: No. The project analysis on the traffic, grading, drainage, and soil conditions has been
reviewed by Engineering staff and the Town's consultants. As currently designed the
proposed project meets the Town Code requirements as well as accepted engineering
standards.
Q: Does this mean the Commission cannot require changes to the design based on
perceived concerns about traffic, grading, drainage, and/or soil conditions?
A: The Commission can request that the developer make changes to the project due to
perceived concerns regarding traffic, grading, drainage, and/ or soil conditions. PPW
ATTACHMENT 14
PAGE 2 OF 4
SUBJECT: 401-409 ALBERTO WAY PROJECT/S-15-056, U-15-009, AND EIR-16-001
MAY 9, 2017
N:\DEV\PC REPORTS\2017\AlbertoWay401-409 05.10.17 ADD-B.docx 5/9/2017 2:46 PM
Engineering would require an analysis of these changes by the developer’s engineering
team, which Engineering staff and the Town’s consultants would then review to verify
compliance with Town Code requirements and accepted engineering standards. The
Commission-requested changes could cause impacts to the developer’s project
objectives, require additional design, and incur additional development costs to the
developer for these changes.
The applicant has provided an additional letter in response to the latest public comments on
the proposed project, attached as Exhibit 45.
EXHIBITS:
Previously received under separate cover:
1.Draft Environmental Impact Report
Previously received with August 10, 2016 Staff Report:
2.Location Map
3.Required Findings and Considerations (two pages)
4.Required CEQA Findings of Fact (24 pages)
5.Recommended Conditions of Approval (15 pages)
6.Letter of Justification/Project Description (15 pages), received July 15, 2016
7.Project Construction Details (three pages), received August 3, 2016
8.Letter of Outreach Conducted (40 pages), received February 10, 2016
9.Second Letter of Neighborhood Outreach (26 pages), received August 3, 2016
10.Consulting Arborist’s Report (41 pages), dated September 26, 2015
11.Architectural Consultant’s First Report (five pages), received September 10, 2015
12.Architectural Consultant’s Final Report (five pages), received March 18, 2016
13.Conceptual Development Advisory Committee Meeting minutes, June 10, 2015 meeting
(four pages)
14.Public Comments
15.Final EIR and Mitigation Monitoring and Reporting Program, dated June 29, 2016
16.Development Plans (37 pages), received July 15, 2016
Previously received with August 10, 2016 Desk Item:
17.Comments received from 11:01 a.m. on Thursday, August 4, 2016 to 11:00 a.m. on
Wednesday, August 10, 2016
Previously received with August 24, 2016 Staff Report:
18.Comments received from 11:01 a.m. on Wednesday, August 10, 2016 to 11:00 a.m. on
Thursday, August 18, 2016
19.Applicant’s Response Letter, received August 19, 2016
PAGE 3 OF 4
SUBJECT: 401-409 ALBERTO WAY PROJECT/S-15-056, U-15-009, AND EIR-16-001
MAY 9, 2017
N:\DEV\PC REPORTS\2017\AlbertoWay401-409 05.10.17 ADD-B.docx 5/9/2017 2:46 PM
Previously received with August 24, 2016 Desk Item:
20.Comments received from 11:01 a.m. on Thursday, August 18, 2016 to 11:00 a.m. on
Wednesday, August 24, 2016
21.Applicant’s Response Letter, received August 24, 2016
Previously received with October 26, 2016 Staff Report:
22.Communication from the applicant, received October 10, 2016 and October 19, 2016
23.Public comments received from 11:01 a.m., Wednesday, August 24, 2016 to 11:00 a.m.,
Thursday, October 20, 2016
Previously received with January 11, 2017 Staff Report:
24.Communication from the applicant, received November 11, 2016
25.Public comments received from 11:01 a.m., Thursday, October 20, 2016 to 11:00 a.m.,
Thursday, January 5, 2017
Previously received with March 22, 2017 Staff Report:
26.Communication from the applicant, received February 28, 2017
27.Comments received from 11:01 a.m. on Thursday, January 5, 2017 to 11:00 a.m. on
Thursday, March 16, 2017
Previously received with April 12, 2017 Staff Report:
28.Revised Required Findings and Considerations
29.Revised Conditions of Approval (21 pages)
30.Comments received from 11:01 a.m. on Thursday, March 16, 2017 to 11:00 a.m. on
Thursday, April 6, 2017
31.Applicant’s Response Letter (23 pages), received March 17, 2017
32.Architectural Consultant’s Report on Revised Plans (six pages), received February 22, 2017
33.Applicant’s Response letter to Architectural Consultant’s Report (three pages), received
March 16, 2017
34.Architectural Consultant’s Second Report on Revised Plans (eight pages), received March
17, 2017
35.Traffic Consultant Letter (eight pages), received April 6, 2017
36.Revised Development Plans (35 pages), received March 17, 2017
Previously received with April 12, 2017 Addendum Report:
37.Communication from the applicant, received April 10, 2017
38.Public Comment received between 11:01 a.m. Thursday, April 6, 2017 and 11:00 a.m.
Tuesday, April 11, 2017
Previously received with May 10, 2017 Staff Report:
39.Applicant’s Supplemental Response Letter, received April 24, 2017
40.Town Consultant Peer Review of Transportation Report, received April 28, 2017
PAGE 4 OF 4
SUBJECT: 401-409 ALBERTO WAY PROJECT/S-15-056, U-15-009, AND EIR-16-001
MAY 9, 2017
N:\DEV\PC REPORTS\2017\AlbertoWay401-409 05.10.17 ADD-B.docx 5/9/2017 2:46 PM
41.Project Information Sheet, prepared by the Parks and Public Works Department
42.Public Comment received between 11:01 a.m. Tuesday, April 11, 2017 and 11:00 a.m.
Friday, May 5, 2017
Previously received with May 10, 2017 Addendum Report:
43.Town Consultant Peer Review of Geotechnical Report, received May 8, 2017
44.Public Comment received between 11:01 a.m. Friday, May 5, 2017 and 11:00 a.m. Monday,
May 8, 2017
Received with this Addendum B Report:
45.Applicant’s Supplemental Response Letter, received May 9, 2017
Distribution:
Shane Arters, LP Acquisitions, LLC, 535 Middlefield Road, Ste. 190, Menlo Park, CA 94025
Buchalter
May9, 2017
VIA E-MAIL (JARMER@LOSGATOSCA.GOV) & FEDEX
Ms. Jennifer Armer
Town of Los Gatos
Community Development Department
110 E. Main Street
Los Gatos, CA 95031
Phone: ( 408) 354-6872
Email: jarmer@losgatosca.gov
55 Second Street
Suite 1700
Snn Francisco, CA 1!4105
415.227.0900 Phone
415.227.0770 Fax
File Number. L4342-0002
415.227 .3508 D'rect
aguerra@buchallar.com
Re: Planning Commission Public Hearing of May 10, 2017 -Supplemental Responses
401-409 Alberto Way
Architecture and Site Application S-15-056
Conditional Use Permit Application U-15-009
APN 529-23-018
Buchalter represents LP Acquisitions, the developer of the project located at 401-409
Alberto Way in Los Gatos. I have reviewed the May 5, 2017 Town of Los Gatos Staff Report
(the "May 5lh Staff Report'') regarding the Architecture and Site Application S-15-056,
Conditional Use Permit Application U-15-009, and Environmental Impact Report EIR-16-001
for the 401-409 Alberto Way Project (the "Project") on behalf of my client. The May 5th Staff
Report includes comment letters received after distribution of the staff report addendum for the
originally scheduled April 12, 2017, meeting (Exhibit 42 1). Most of the comments are the same
comments that the commenters submitted in f'\.ugust 2016 and in March 2017. The purpose of
this letter, however, is to respond to comments from the following commenters regarding the
technical documents that the Project team submitted on April 24, 2017:
• Provencher & Flatt, LLP ("Provencher & Flatt") on behalf of the Alberto Way
Neighbors: Los Gatos Commons, Pueblo de Los Gatos, Las Casitas and Bella Vista
Village ("Alberto Way Neighbors") for the upcoming Planning Commission meeting
1 Page 1 of3 in the May 5th Staff Report indicates that the new comment letters are found in Exhibit 44, but the
Table of Contents on page 3 of 3 indicates that the new comment letters are included in Exhibit 42. It appears that
the comment letters are found in Exhibit 42.
EXHIBIT 4 5
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buchalter.com
Los Angeles
Napa Valley
Orange County
Sacramento
San Francisco
Scottsdale
Buchalter
Ms. Jennifer Armer
May9, 2017
Page2
on May 10, 2017 for the 401-409 Alberto Way Project including the Hydrology
Report for 401-409 Alberto Way Addendum "A" dated May4, 2017 prepared by Dr.
Geissler ("Geissler Addendum");
• Los Gatos Commons Committee on Alberto Way Project ("Commons"); and
• Alberto Way Citizens
All of the letters continue to raise the same basic comments about the Project. This letter
responds to the latest comments from the commenters regarding the Project team's responses
concemmg:
• alleged groundwater and seismic impacts due to the subsurface parking garage;
• trip generation methodology and corresponding traffic impacts;
• the loss of on-street parking spaces;
• the request for a new residential alternative; and
• the request that the EIR be recirculated.
Groundwater and Seismic Impacts
None of the comment letters included in the May 5th Staff Report contain any new
comments or any information indicating that the Project would have a new significant impact.
When an agency prepares an EIR (like the Town of Los Gatos prepared the 401-409 Alberto
Way EIR here), the issue is whether substantial evidence supports the agency's conclusions, not
whether others might disagree with those conclusions (see e.g., North Coast Rivers Alliance v.
Marin Municipal Water Dist. Bd of Directors, 216 Cal.App.4th 614, 624 (2013)). In North
Coast Rivers Alliance v. Marin Municipal Water Dist. Bd of Directors, 216 Cal.App.4th 614
(2013), the court upheld the geologic/seismic analysis of an EIR as being adequate because the
EIR and supporting record included detailed information on geologic conditions in the area and
considered the potential for seismic hazards including ground shaking and liquefaction. Nothing
more was required" Id. at 635. In other words, just because the commenters disagree with the
conclusion of the EIR and associated technical analyses, it does not mean that the EIR and its
associated technical studies are inadequate.
That is the same case here. ENGEO conducted an extensive Geotechnical Evaluation
that was peer reviewed by the Town of Los Gatos, and it was used by the Town's EIR consultant
to support the analysis contained in the Town's EIR. ENGEO then responded to all of Dr.
Geissler' s comments in the March 31, 2017 Technical Report (see the LP Acquisitions' April
24th Letter). ENGEO also addressed Dr. Geissler's latest comments reflected in the Geissler
Addendum and the Provencher Letter in an addendum to its Technical Memorandum dated May
8, 2017 ("ENGEO Addendum"). The fundamental comment from Dr. Geissler and other
commenters is that they believe construction of a parking garage will result in hydro logic-related
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Ms. Jennifer A...rmer
May9, 2017
Page 3
impacts to surrounding properties. As we stated previously in our April 24th submittal package
and as further explained in the EN GEO Addendum, the Project has taken into consideration the
need for an appropriate building foundation, garage design, groundwater pumping, and other
measures to ensure that the underground parking garage would not cause cracked foundations or
other similar impacts to the neighbors' properties. As you know, underground parking garages
are built in Los Gatos and in other locations in the Bay Area. This garage is no different. Thus,
all of the issues Dr. Geissler continues to raise were already addressed, and there are no new
significant impacts triggering the need for further analysis or a change in the project to replace
the parking garage with surface parking.
Trip Generation Methodology and Traffic Impacts
None of the comment letters included in the May 5th Staff Report contain any new
comments regarding the adequacy of the traffic analysis. In summary, the comm.enters' primary
objections to the traffic analysis continue to be:
• that the ITE manual and staridard methodology fur calculating trips may
underestimate project traffic, particularly because the average date of the studies is 37
years old;
• there is too much traffic under existing conditions and traffic conditions will worsen
with the addition of project traffic, so the Town should base it's determination that
the project would have significant traffic impacts on the "maximum magnitude" of
the project traffic impacts using worst case assumptions; and
• the project removes 8-12 on-street parking spaces so the residents' guests will no
longer have anywhere to park.
CEQA requires that an EIR include adequate information to ensure informed decisions
are made about a project. CEQA further requires that the lead agency evaluate whether or not a
proposed project will result in a significant environmental impact based on substantial evidence.
Under Public Resources Code Section 21082.2( c ), substantial evidence includes facts, reasonable
assumptions predicated upon facts, and expert opinion supported by facts . Argument,
speculation, unsubstantiated opinion are not substantial evidence. The substantial evidence
standard of review applies to disagreements concerning the methodology used for studying an
impact, and the reliability or accuracy of the data upon which the EIR relied. Even when
commenters suggest that different conclusions should be reached, or different methods of
gathering and compiling statistics could have been used, that does not constitute substantial
evidence. The issue is not whether other methods might have been used, ''but whether the agency
relied on evidence that a reasonable mind might accept as sufficient to support the conclusion
reached in the EIR." North Coast Rivers Alliance v. Marin Municipal Water Dist. Bd. Of
Directors, 216 Cal.App.4th 614, 615 (2013).
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Bu chalter
Ms. Jennifer Armer
May9, 2017
Page4
Moreover, "CEQA does not require lead agencies 'to engage in speculation in order to
analyze a worst case scenario"' (North Coast Rivers Alliance v. Marin Municipal Water Dist. Bd.
Of Directors, 216 Cal.App.4th 614, 635 (2013), quoting Napa Citizens for Honest Government v.
Napa County Bd. Of Supervisors , 91 Cal. App. 4th 342, 373 (2001)). When an agency prepares
an EIR, the issue is whether substantial evidence supports the agency's conclusions, not whether
others might disagree with those conclusions (North Coast Rivers Alliance v. Marin Municipal
Water Dist. Bd. Of Directors, 216 Cal.App.4th 614, 624 (2013)).
With respect to the Alberto Way Project, Hexagon first prepared the 401-409 Alberto
Way Traffic Impact Analysis in accordance with the Town's and the Valley Transportation
Agency (VTA)'s rules for how traffic studies are performed in Santa Clara County. Hexagon
used the ITE trip generation manual to calculate Project-generated trips in accordance with the
Town's guidelines. Contrary to the commenters' comments that the manual is based on studies
that are an average of37 years old, the ITE manual provides 37-years' worth of data in order to
substantiate the applicable trip generation rates for various types of land uses. The Hexagon
analysis used the ITE trip generation data to calculate the traffic generated by the Project, and
then prepared a Traffic Impact Analysis based on the standard methodology. The Hexagon
Traffic Impact Analysis underwent the Town's review before it was used in the EIR. The Town
circulated the Hexagon Traffic Impact Analysis and the EIR for review by VT A and Caltrans, as
well. Hexagon followed the standard methodology approved by the Town, and the Town
concurred with the findings of the analysis.
Hexagon even went a step further to validate its analysis. Following the August 2016
Planning Commission meetings, Hexagon collected trip generation data for four office buildings
in Los Gatos to verify the trip generation data used for the traffic analysis so that it would reflect
conditions in Los Gatos. The empirical data collected for the office buildings in Los Gatos
validated the data used in the 401-409 Alberto Way Traffic Impact Analysis as summarized in
the Hexagon Trip Generation Memorandum dated April 6, 2017. Then, Hexagon prepared a
further response included in the Applicant's April 24th Supplemental Responses Memorandum
addressing the same comments submitted by the commenters regarding the traffic impact
analysis . All of this information provides substantial evidence that contains facts and expert
opinions based on facts demonstrating that the 401-409 Alberto Way Traffic Impact Analysis
complied with the Town's procedures for conducting traffic analyses, and supports the
conclusions that the Project impacts will be mitigated to a less-than-significant level.
Regarding the loss. of on-street parking, my client has offered to the neighbors time and
again that replac ement parking spaces within the surface parking area can be made available for
nearby residents to use after hours when the employees have left for the day. My client is
willing to work with the Town to facilitate on-site parking opportunities for the neighbors.
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Buchalter
Ms . Jennifer Armer
May9, 2017
Page5
Thus, all of the traffic comments that the commenters continue to raise were already
addressed in the BIR, the technical analyses and the prior responses to comments, including our
April 24th Supplemental Responses, and there are no new significant impacts triggering the need
for further analysis or a change in the project to address the Project's traffic impacts .
New Residential Alternative
One commenter has suggested that my client has not evaluated a reasonable range of
alternatives that would significantly reduce or avoid the Project's impacts or explained why the
other alternatives were rejected in light of the ''unacknowledged" impacts raised by the
commenter, implying that the smaller office building surrounded by surface parking in lieu of a
subsurface parking garage should be evaluated as an alternative to the Project. Another
commenter suggested that a residential alternative for an active adult community be evaluated.
Regarding the EIR's analysis of alternatives, the EIR evaluated three alternatives to the
Proposed Project. An alternative site location alternative was considered but rejected because
the reason for the Project is to redevelop the Project site, and no other suitable sites were
available in the vicinity of the Project site that could accomplish that same basic project purpose
as explained in Section 6.3 of the Draft EIR. The applicant's further revisions to the Project
reflected in the revised Project were designed to reduce the size of the Project to 83,000 square
feet to respond to the Planning Commission's direction from August 2016 . The revised Project
at 83,000 square feet is greater than the 74,260 square foot Reduced Scale Alternative included
in the Draft EIR and less than the 92,800 square foot project evaluated in the EIR.
Public Resources Code Section 21061.l defines "feasible" as "capable of being
accomplished in a successful manner within a reasonable period of time, talcing into account
economic, environmenta~ social and technological factors." Among the factors that may be
taken into account when addressing the feasibility of on-site alternatives are site suitability,
economic viability, availability of infrastructure , general plan consistency, other plans or
regulatory limitations, and jurisdictional boundaries. No one of these factors establishes a fixed
limit on the scope ofreasonable alternatives under CEQA. 14 Cal Code Regs. Section
15126.6(f)(l); Citizens of Goleta Valley v. Board of Supervisors, 52 Cal 3d 553, 565 (1990).
Economic infeasibility must be supported by evidence and analysis showing that it cannot
reasonably be implemented, based on a reasonably prudent standard. Kings County Farm Bureau
v. City of Hanford, 221 Cal App. 3d 692 , 737 (1990).
The revised Project at 83,000 square feet with the subsurface parking garage is feasible,
as explained in my client's April 24th Supplemental Responses. As LP Acquisitions indicated on
numerous occasions, one of the ke y proje ct objectives is to build a Class A office building in the
Los Gatos market. Specific factors that are critical to the development of a Class A office
building to accommodate this market sector include:
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Buchalter
Ms. Jennifer Armer
May 9, 2017
Page 6
• Class A tech company users require large footprints of 35,000 square feet per floor
and above as demonstrated by the recent approval of the Netflix campus.
• Recruiting, hiring and retention of employees is extremely competitive in Silicon
Valley and large facilities with many amenities are the future of high tech
employment opportunities for the foreseeable future.
• Class A tech users need a minimum building(s) size for the amenities they offer their
employees to provide the services and fully absorb the costs (i.e., fitness rooms, bike
storage, cafeteria, outside common spaces and large conference facilities).
• Employee health and wellbeing requires access to natural light as a priority and is
facilitated by large glass lines and skylight areas where possible.
• Secured parking is a Class A space advantage for a company by locating tenant
parking underground.
Regarding a smaller office building surrounded by surface parking, by contrast, the
building developer would be unable to provide secured parking for its tenants, or accommodate
the types of building amenities and features that are included in a Class A office building in
response to market demands.
Regarding a senior residential community alternative, my client met with Town advisory
officials early in the process to discuss a residential project for the site, and was advised that
residential uses would not be permitted on the property for the following reasons:
• residential use is not a permitted or conditionally permitted use in this zoning district,
and thus would require a general plan amendment and rezoning in order to change the
land use on the site;
• a residential project would impact schools by adding more kids to the Town that
would lead to further crowding in the schools and result in the need to add more
classrooms and teachers. (Admittedly, an active adult community would not have the
same impact on schools).
Additionally, given the site's proximity to Highway 9 and Highway 17, a residential
community on the property would be exposed to elevated noise and air quality impacts due to
exposure to vehicular-generated noise and air pollutant emissions. Senior citizens are considered
sensitive receptors and may be exposed to potential respiratory issues due to the proximity to the
freeway. Also, if the commenters are concerned about the potential exposure to inundation due to
dam failure at Lenihan Dam then that concern would be exacerbated by locating more residents
in the area as compared to the proposed Project which would result in exposure of an office
building that is not occupied on a full-time basis. Moreover, residential uses would generate
approximately 9 to 10 daily trips per unit depending on the type of dwelling unit, thereby
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Buchalter
Ms. Jennifer Armer
May9, 2017
Page 7
exacerhating traffic conditions during the peak period commute hours. For these reasons .•
although a residential project would be compatible with the surrounding residences 1 a residential
aiternative would not meet most of the basic project objectives for the Project as set forth on
page 2-2 of the EIR, and it would not substantially reduce or eliminate the potential impacts that
the commenters express concern about.
Recirculation of the Draft EIR
Some commenters requested that the Town recirculate the Draft EIR due to new
information that they have submitted that alleges the revised Project would resuk in new
significant geologic and hydrologic impacts when the latest round of comments raise the same
issues as the earlier comments opposing the Project.
The modifications included in the revised Project are feasible and represent minor
revisions and clarifications to the overall project that will not add significant new information to
the Town of Los Gatos 401-409 Alberto Way Draft and Final Environmental Impact Report
(EIR). As we stated in our April 24th Supplemental Responsest recirculation of the EIR is not
required because the proposed modifications will further lessen impacts that the Town previously
found to be less than significant. Further the changes incorporated into the Project would not
involve a new significant environmental impact, a substantial increase in the severity of a prior
environmental impact, or a feasible mitigation measure or alternative that LP Acquisitions
declined to adopt and that will clearly lessen any project impacts. No information provided in
the latest round of comments indicates that the Draft EIR was inadequate or conclusory or that
the public was deprived of a meaningful opportunity to review and comment on the EIR.
Consequently, the Project EIR complies with CEQA and the Town is not required to recirculate
the EIR because there are no new significant impacts n.or is there a substantial increase in the
severity of the impacts previously evaluated in the EIR.
Conclusion
Finally, we apologize for any confusion created by our responses that incorrectly
attributed comments to the wrong group. We note the comments raised by comm.enters such as
Loretta Fowler, Los Gatos Commons, who questioned the validity of our responses because the
Project team incorrectly attributed the comment to the wrong neighborhood group in our April
24th submission. Nonetheless, our response to the comment continues to apply regarding the
substantive issue (e.g., construction impacts to surrounding properties, impact to views of the
Santa Cruz Mountains, etc.), and we note that the response is updated to the extent that a
different homeowners group would be affected as indicated by the commenter. Additionally, we
note the concern raised by some of the commenters that a particular demographic group, such as
Senior Citizens, would be impacted by the Project because Senior Citizens reside in the
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Buchalter
Ms. Jennifer Armer
May9, 2017
Page 8
neighborhood. We also are cognizant of the Town's General Plan policies that encourage the
preservation of the small town character of Los Gatos.
Our April 24th response explained that CEQA requires an evaluation of a project's
physical effects on the environment, but because it does not require that socioeconomic effects
be evaluated in an EIR, an EIR is not required to evaluate potential impacts on a particular
demographic group. We understand that the Town will consider as part of its deliberations
regarding the merits of the Project, whether or not the Project complies with the General Plan
policies, and that evaluation may serve as the vehicle for the Town's consideration of effects on
the neighbors residing in the Project vicinity.
We appreciate your consideration of our responses and look forward to the Planning
Commission's consideration of the Alberto Way Project on Wednesday.
AG:ej
cc (via email): Randy Lamb
Shane Arters
Gary Black
Dan Mitchell
Dan Kirby
By
Gregory Cubbon, CEG, PE
Janet Kan, CE, CEG
Robert H . Boeche, CEG
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Sincerely,
BUCHALTER
A Professional Corporation
(-'\
. ~~~-·-·--
AlidJ Guerra' . ..._ _,, ..
Buchalter
Ms. Jennifer Armer
May 9J 2017
Page 9
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ATTACHMENT
Buchalter Nemer
401-409 Alberto Way, Los Gatos
SECOND SUPPLEMENTAL RESPONSE TO PUBLIC COMMENTS
12175.000.000
May 8, 2017
Page2
A GE is recognized by the California Board fo r Professional E ngineers, Land Surveyors and
Geologists as a professional who demonstrates a higher level of knowledge and judgement over
a Professional Civil Engineer on geotechnical subjects. We are confident that our geotechnical
engineers supporting the 401-409 Alberto Way project are knowledgeable on the standard of care
in geotechnical engineeri ng withi n California.
Please note that ENGEO's conclusions and recommendations on the proposed development at
401-409 Alberto Way were peer reviewed by Mr. Robert Wright and Mr. Christopher Coutu.
Mr. Wright and Mr. Coutu are two highly reputable Certified Engineering Geologist (CEG) and
Geotechnical Engineer (GE) with AMEC who have worked on and reviewed many large public
projects in the Bay Area including the Town of Los Gatos .
PROVENC!-H:R G FLATT, LLP COMMENTS
Provencher & Flatt, LLP provided the following comments in thei r letter dated May 4 , 2017
(Reference 8). Our responses to each of Provencher & Flatt, LLPs comments are as foUows :
Comment 1
The ground floor to groundwater elevation provides unsafe conditions, therefore the Project's
impacts have not [been] fully acknowledged and adequate mitigation has not been proposed.
ENGEO Response to Comment 1
As stated in References 2 and 5, below grade structures below the ground water table are
routinely constructed in the San Francisco Bay area using proven engineering controls and
construction techniques. These structures include hospitals, police stations, large technology
campus and residential structures, where unsafe conditions related to static groundwater level
have not been reported. It is our opinion that constructing the below grade levels as currently
planned is feasi ble from a geotechnical standpoint.
Comment2
There is no logical basis for the claim that the site is not susceptible to liquefaction in the event of
strong shaking due to a nearby earthquake and therefore the Project's impacts have not been
;u11y acknowledged and adequate mitigation has not been proposed.
ENGEO Response to Comment 2
As described in References 3 through 5, we identified that site soils at seiect depths may be
potentially liquefiable during a seismic event. Our design team acknow l ~dged the potential risk of
liquefaction and applied sound engineering to mitigate the associated effects. The s ite-specific
foundation design parameters provided in our geotechnical report (Reference 3) are intended to
mitigate liquefaction-induced settlement (differential and total) by spanning over irregularities at
foundation subgrade if liquefaction occurs. Designing foundation elements to tolerate anticipated
settlement is a common practice in the Bay Area .
Comment3
ENGEO's assertion that seasonal fluctuations in groundwater mimic the effects of construction
dewatering is false . Seasonal fluctuations in the depth of groundwater can cause foundation
settlement but not differential foundation settlement. By contrast, construction dewatering induces
differential foundation settlement. Cracked slabs are associated wi th differential foundation
settlement not uniform settlement.
SUBJECT TO AlTORNEY DIRECTION -ATTORNEY WO RK PRODUCT
Buchalter Nemer
401-409 Alberto Way, Los Gatos
SECOND SUPPLEMENTAL RESPONSE TO PUBLIC COMMENTS
ENGEO Resoonse to Comment 3
12175.000.000
May 8, 2017
Page 3
Fluctuations in groundwater mimic the effects of vertical stress changes in soil. As stated in our
comment, vertical stress increase may result in compression of soft clays or loose sandy/gravelly
deposits. We want to point out that site soils have already experienced vertical stress change due
to groundwater level drop in the past. Soil that have experienced higher vertical stress in the past
will demonstrate lower compression potential. Moreover, site soils consist of medium dense to
dense clayey gravels, which have low to very low compressibility potential to begin with. Based
on these reasons, the risk of settlement (both total and differential) in the vicinity of the project
site due to controlled and temporary dewatering is low.
Comment4
ENGEO's analysis of health and safety impacts is incorrect; ENGEO used an outdated map dated
1991 . The more recent 2002 map shows that the proposed development is located within the
Fault Rupture Hazard Zone and the Liquefaction Zone.
ENGEO Resoonse to Comment 4
We're unclear on the map that Geissler is referencing but we believe the referenced 2002 is either
the Seismic Hazard Zone Map for the Los Gatos Quadrangle (California Geologic Survey, 2002),
which depicts liquefaction and earthquake induced landslide zones or the Santa Clara County
Fault Rupture Hazard Zone Maps (2002). The Seismic Hazard Zone Map (CGS, 2002) is
discussed in our previous report. The Santa Clara County Fault Maps Zone, which includes a
majority of faults identified by the United Sates Geologic Survey within Santa Clara County, is
also discussed in our previous report. It is important to understand that not all mapped faults pose
a risk of ground rupture. When evaluating the risk of ground rupture due to faulting , the standard
of care in the engineering industry refers to active faults identified under the State of California's
Alquist-Priolo (AP) Act. AP regulatory fault zones include fault traces that are active and well
defined to create the potential for surface fault rupture . Faults that are within AP regulatory fault
zones, also known as active fault zones, have had identifiable surface rupture during the
Holocene age (defined by the CGS as the last 11,000 years). Active faults (regulatory fault zone)
pose a high geologic risk to development.
Many of the faults shown on the Santa Clara County Fault Rupture Hazard Zone Map are not
considered active under the State of California criteria described above, including the Santa Clara
County Fault Rupture Zone noted in Comment 4. County Fault Hazard Maps are provided for the
general public to keep them abreast of potential geologic hazards within the County. Because of
its failure to identify age of mapped faults, the County Fault Rupture Hazard Zone Maps are not
used to assess whether an active fault traverses a project site and poses rupture hazards.
The Alquist-Priolo Act is standard, well known and widely adopted by the geotechnical
engineering industry; however, the Alquist-Priolo act may not be easily understood by the general
public or a Civil Engineer not familiar with local geotechnical standards or practices .
The most recent California Geologic Survey Alquist Priolo zone map for the Los Gatos
Quadrangle (dated 1991) can be found at the following website:
http://maps.conservatlon.ca.gov/cgs/informationwarehouse/index.html?map=regulato
rvmaps
The project site is not located in a State of California Fault Rupture Hazard Zone.
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Please note that ENGEO performed a thorough review of fault maps In our project geotechnical
report (Reference 3), prepared under the guidance and supervision of a California Engineering
Geologist (CEG). In our geotechnical report, we discussed the above mentioned Santa Clara
County Fault Rupture Hazard Zone Map, the Town of Los Gatos fault rupture hazard zone map,
fault lineament and coseismic deformation maps, va ri ous regional geologic maps for the area and
aerial photographs. Moreover, we reviewed studies performed after the 1989 Loma Prieta
earthquake that detail locations of coseismic deformation ln the Town of Los Gatos as a result of
sympathetic fault movement along the Berrocal and Monte Vista S hannon faults. Based o n our
thorough review of multiple fault maps and studies , it is our opinion that the possibility of ground
rupture as a result of fault movement at the subject site is low. This finding was reviewed and
deemed acceptable by AMEC, which included review by a CEG.
Please note that we agree that the site is located In a liquefaction zone as defined by both the
State and the County. However, both state and county liquefaction maps clearly state that a
professional engineer or professional geologist should be retained to further evaluate the hazard
level of liquefaction. This is because the risk of liquefaction is dependent on many factors and
only a professional knowledgeable with liquefaction analysis can evaluate the effects of
liquefaction and associated settlement. Many structures within mapped liquefaction zones in the
Bay Area are successfully developed or retrofitted based on results of liquefaction analysis
performed by professionals.
Comments
Due to differential foundation settlement, a mat slab foundation cannot be uniformly supported by
subgrade soils subject to liquefaction in the event of strong shaking due to a nearby earthquake
unless the mat foundation exceeds 4' in thickness. Subsequent structural cracks allow massive
influx of groundwater.
ENGEO Response to Comment 5
We estimate differential settlements to be on the order of% inch as a result of liquefaction. We
also recommended that the foundation be designed to withstand an edge cantilever distance of 6
feet and an interior span distance of 15 feet to span localized irregularities.
A registered professional Structural Engineer (SE) on our design team will consider the above
criteria in the foundation design and determine the appropriate thickness of the mat foundation.
Comment6
Percolation analysis was based on the performance of a 1-foot thick garage slab floor subject to
liquefaction In the event of strong shaking due to a nearby earthquake, which would allow the
influx of approximately 500 gallons per minute into the underground garage. This amount of water
leakage cannot be controlled by the use of the Project's proposed sump pumps and is inadequate
to ensure the public's safety.
ENGEO Response to Comment 6
Please see our response to Comment 5 above . We do not anticipate severe cracking of the
building foundation as a result of liquefaction provided our recommended geotechnical design
criteria are incorporated into the structural design_. An appropriate foundation thickness will be
selected by the project structural engineer.
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Comment 7
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Page 5
The permitting of an underground garage in an area that is subject to the inundation of floodwaters
in the event of an upstream dam failure represents unnecessary and unreasonable risk to health
and safety.
ENGEO Response to Comment 7
Please see our response to Comment 8 below and our prior response in Reference 5.
CommentB
Leniham[n] Dam is located adjacent to the Fault Rupture Hazard Zone. Strong shaking in the
Earthquake Fault Rupture Hazard Zone is likely to cause the earthen dam to fail. The 2012
Terra/GeoPentech report does not take into account the close proximity between Leniham[n] Dam
and the Earthquake Fault Rupture Hazard Zone. Therefore, ENGEO 's unfounded reliance upon
the findings and conclusions of the 2012 Terra/GeoPentech Leniham[n] report represents a failure
to comply with the standard of care of the engineering profession.
ENGEO Response to Comment 8
As explained in our response to Comment 4 above, the fault hazard evaluation made by
Mr. Geissler falls below industry standards . The USGS Quaternary Fault and Fold Database lists
the Lexington Fault Zone, which is hatched on the Santa Clara County maps on the east of the
dam, as a Quaternary Fault, meaning it is has exhibited displacement in roughly the last 1.6 million
years. This fault is not considered active by our current industry standard.
The 2012 Terra/GeoPentech report, which indicates a very low likelihood of failure during the
Maximum Considered Earthquake (MCE), is backed with extensive exploration and detailed
engineering analyses. The report indicates that the Division of Safety of Dams (DSOD), which
performed their own independent analyses and reviewed the referenced report, concluded that
no seismic remedial measures were necessary.
We consider the 2012 Terra/GeoPentech report highly reliable, particularly because it was
prepared by reputable and experienced geotechnical engineering firms and was further reviewed
by a higher authority specialized in certification and regulating dams within the state.
Comment9
ENGEO stated, u ••• the construction of a subsurface garage will not dramatically impede
groundwater flow." Geissler Engineering pointed out that the construction of a subsurface garage
necessarily impedes groundwater flow; the flow of groundwater is diverted around the
underground parking garage. There is an increased level of groundwater on the upstream side of
the underground parking garage and a decreased level of groundwater on the downstream side
of the underground parking garage, which leads to cracked slabs in neighboring buildings. This
is an indirect impact that must be analyzed by the EIR.
ENGEO Resoonse to Comment 9
We disagree with the likelihood of the negative impacts to surround ing properties implied by
Geissler Engineering. Please see our response to comments in Reference 5.
Comment 10
A 12-inch thick slab floor is too flexible to span over areas of soil subsidence caused by
liquefaction and too weak to prevent cracking. In comparable situations in San Francisco where
liquefaction causes soil subsidence, 48-inch thick mat slabs are proposed. If the top of slab of the
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underground garage is locaied below the groundwater then the i nflux of groundwater into the
cracked underground parking structure, water floods the damaged and submerged underground
garage leading to health and safety impacts.
ENGEO Response to Comment 10
Please see our response to Comments 5 and 6 above. We do not anticipate severe cracking of
the building foundr:tion as a result of liquefaction provided our recommended geotechnical design
criteris are incorporated into the structural design. An appropriate foundation thickness will be
selected by the project structural engineer.
We are unable to comment on the thickness of mat slabs in San Francisco as noted in the
comment without understanding their site condition, design criteria and performance standard.
GEISSLER ENGIN :::ERli'!G REBUTfAL COM MENTS
Geissler Engineering provided the following rebuttal comments on pages 16 through 23 of their
Addendum "A" Hydrology Report dated May 4, 2017 (Reference 7). Our responses to each of
Geissler Engineering's rebuttal comments .are as follows:
Gei ssler Engineering Rebuttal Comment 1
Leniham Dam is located adjacent to the Fault Rupture Hazard Zone. Strong shaking in the
Earthquake Fault Rupture Hazard Zone is likely to cause the earthen dam to fail. The 2012 Terra
I GeoPentech report does not take into account the close proximity between Leniham Dam and
the Earthquake Fault Rupture Hazard Zone. Therefore, ENGEO's unfounded reliance upon the
findings and conclusions of the 2012 Terra I GeoPentech report represents a failure to comply
with the standard of care of the engineering profession .
ENGEO Response to Geissler Engineering Rebuttal Comment 1
Please see our response to Comments 4 and 8 to Provencher & Flatt, LLP above.
Geissler Engineering Rebuttal Comment 2
ENGEO intentionally misleads the reader Into thinking that seasonal fluctuations in groundwater
mimic the effects of construction dewatering. That is not true. Seasonal fluctuations in the depth
of groundwater can cause foundation settlement but not differential foundation settlement. By
contrast, construction dewatering induces differential foundation settlement. Cracked slabs are
associated with differential foundation settlement not uniform settlement.
ENGEO Response to Geissler Engineering Rebuttal Comment 2
Please see our response to Comment 3 to Provencher & Flatt, LLP above.
Geissler Engineering Rebuttal Comment 3
The proposed underground garage is both wide and deep; of course it shall divert the flow of
subsurface · seepage. The diversion of subsurface seepage is complete; all of the subsurface
seepage is diverted around the impermeable structure.
ENGEO states, "... the construction of a subsurface garage will not dramatically impede
groundwater flow." Geissler Engineering respectfully points out that the construction of a
subsurface garage necessarily impedes groundwater flow; the flow of groundwater is diverted
around the underground parking garage. There is an increased level of groundwater on the
upstream side of the underground parking garage and a decreased level of groundwater on the
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downstream side of the underground parking garage. This is an economic issue rather than a
safety issue. Cracked slabs in neighboring buildings must be repaired at considerable expense
to the· neighbors. However, this problem poses no safety risk to the public.
ENGEO Response to Geissler Engineering Rebuttal Comment 3
Please see our response to Comment 9 to Provencher & Flatt, LLP.
Geissler Engineering Rebuttal Comment 4
Geissler Engineering stands corrected as to ENGEO's recommendation of an 8-inch slab.
Architectural drawings dated 9 March 2017 specify a 12-inch concrete slab for the garage slab
floor not an 8-inch thick slab. Geissler Engineering holds the opinion that a 12-inch thick slab floor
is too flexible to span over areas of soil subsidence caused by liquefaction and too weak to prevent
cracking. Jn comparable situations in San Francisco where liquefaction causes soil subsidence,
Geissler Engineering specifies the construction of a 48-inch thick mat slab. A thick slab affords
protection against differential foundation settlement and cracking in saturated sandy and silty soils
in the event of strong seismic shaking.
Provided the top of slab of the underground garage is located above the groundwater, the cracking
of the underground parking structure is primarily an economic problem. Contrariwise, if the top of
slab of the underground garage is located below the groundwater then the influx of groundwater
into the cracked underground parking structure is a matter of public safety because water floods
the damaged and submerged underground garage.
ENGEO Response to Geissler Engineering Rebuttal Comment 3
Please see our response to Comment 5 to Provencher & Flatt, LLP.
Geissler Engineering Rebuttal Comment 8
ENGEO is incorrect because ENGEO used an outdated map dated 1991 . The more recent 2002
map shows that the proposed development is located within the Fault Rupture Hazard Zone and
the Liquefaction Zone.
ENGEO Response to Geissler Engineering Rebuttal Comment 8
Please see our response to Comment 4 to Provencher & Flatt, LLP.
ALBERTO WAY CITIZE i\'S REBUTTAL COMMENTS
Citizen Rebuttal Comment 1
Irrespective of the 2012 Terra/GeoPentech report, ... Both its primary and emergency spillway
surfaces failed in 2017, and a large evacuation ensued.
ENGEO Response to Citizen Rebuttal Comment 1
Please see our response to Comments 4 and 8 to Provencher & Flatt, LLP above regarding fault
rupture hazard.
As stated in our Response to Geissler Engineering Comment 1 in Reference 5, it is the
responsibility of the Santa Clara Water District to perform surveillance, inspections and
maintenance to reduce the risk of dam failure and overtopping . Moreover, SCWD collaborates
with local public agencies such as the Town of Los Gatos to provide warnings and emergency
response. The citizen rebuttal mentioned the Oroville's Dam's recent spillway failure. This recent
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incident demonstrated exactly how warnings and responses aie implemented when public safety
may be compromised due to potential dam/spillway failure.
Citizen Rebuttal Comment 2
There is a substantial difference in the forces exerted on the surrounding structures . . . interior
walls & floors will be since settling is increasingly pronounced with length.
ENGEO Response to Citizen Rebuttal Comment 2
Please see our response to Comment 3 to Provencher & Flatt, LLP above. Due to the dense
nature of site soils and previous stress history, the risk of settlement (both total and differential)
due to controlled and temporary dewatering is low.
Citizen Rebuttal Comment 3
Water travels beneath the Planned Development and surrounding properties where we live as
drainage travels from uphill of our properties ... the next major drought recovery (similar to the
cu"ent water year recovery after the 2010-2016 drought) without damages to our residences.
ENGEO Response to Citizen Rebuttal Comment 3
We believe the citizens misunderstood our response to Geissler Engineering Comment 3.
Groundwater flow from the Los Gatos hills to the vicinity of the site is a regional flow, which does
not correlate to high flow gradient in the vicinity of the site. This is because groundwater head
difference between the Los Gatos hills to the site is distributed over a long distance in an
unconfined environment, resulting in a relatively stable gradient around the site. We anticipate
the groundwater level to stabilize around the basement, i.e. no significant flew difference from
opposite ends of the site, after temporary construction dewatering wells are decommissioned.
Citizen Rebuttal Comments 4 & 8
ENGEO is inco"ect. The Planned Development is situated on both a Fault Rupture Hazard Zone,
shown in pink... We have only unacceptable Environmental Impacts and Economic Risks that
have not been fully disclosed. ·
ENGEO Response to Citizen Rebuttal Comments 4 & 8
Please see our response to Comments 4 and 8 to Provencher & Flatt, LLP above. Our
geotechnical engineers and certified engineering geologist followed the profession's standard of
care to come up with the conclusion that the project site is not located within a State of Cal ifornia
Fault Rupture Hazard Zone. We need to stress that no active faults are mapped wi t hin the project
site .
Citizen Rebuttal Comment 11
There has been no submission of evidence that the present Depth to Water has been discovered
through another set of borings ... (continue from page 11 to 19) ... opinion would have changed
the prior EIR conclusion, requiring earthquake mitigation by constructing several much smaller
buildings, and without below ground parking.
ENGEO Resoonse to Citizen Rebuttal Comment 11
Historic photographs and topographic map review is performed and presented in our geotechnlcal
report. The citizen rebuttal letter presented a detailed research in historic photographic and maps.
However, the presented information lacks reliable scale and mapping accuracy to identify the
Planned Development limits in relation to the historic Los Gatos Creek channel. For example, the
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red -boxed area on Page 17 represents the size of six major city blocks, which significantly
deviates f rom the size of the Planned Development.
We acknowledged that the Los Gatos Creek has been rerouted in the past, as stated in our
original response; however, we did not observe the Los Gatos Creek to have formerly located
within the limits of the Planned Development when we utilize geo-referenced maps and historic
photos. We believe our original response to Comment 11 adequately explains our conclusion that
undocumented fill within the site due to the past rerouting of Los Gatos Creek does not pose a
geotechnical hazard to the project. If undocumented fills a re encountered during grading, they will
be removed and replaced as engineered fill as described in our report.
CLOSI N G
We strived to perform our professional services in accordance with generally accepted
geotechnical engineering principles and practices currently employed in the area.
If you have any questions regardin the contents of this letter, please do not hesitate to contact
us.
Sincerely
E NGEO Incorporated
Attachment: List of Selected References
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LIST OF SELECTED REFERENCES
1. AMEC; Peer Review -Geotechnical Exploration Report; 401 Alberto Way, Los Gatos,
California; November 4, 2015. AMEC Project No. 0084491960.
2. AMEC Foster Wheeler; Geotechnical Peer Review; 401-409 Alberto Way, Los Gatos,
California; April 28, 2017. AMEC Project No. 084491960.
3. ENGEO; Geotechnical Exploration; 401 Alberto Way, Los Gatos, California; July 17, 2015
(Revised August 13, 2015}. ENGEO Project No. 12175.000.000.
4. EN GEO; Response to AMEC Foster Wheeler Peer Review Comments; 401 Alberto Way, Los
Gatos, California; January 11, 2016. ENGEO Project No. 12175.000.000.
5. ENGEO; Supplemental Response to Public Comments; 401-409 Alberto Way, Los Gatos,
California; April 19, 2017. ENGEO Project No. 12175.000.000.
6. Geissler Engineering; Hydrology Report; 401-409 Alberto Way, Los Gatos, California, 95032;
dated March 31, 2017.
7. Geissler Engineering; Hydrology Report, Addendum "A•; 401-409 Alberto Way, Los Gatos,
California, 95032; dated May 4, 2017.
8. Provencher & Flatt, LLP; RE: Comments on the EIR prepared for the 401-409 Alberto Way
Project; May 4, 2017.
9. Residents of Alberto Way submitted by Bob Burke; Alberto Way Citizens Rebuttal to Lamb
Partners April 19, 2017 Comments on the Expert Peter Geissler & Bob Burke Reports on 405
(aka 401-409) Alberto Way.
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2012 HISTORIC TOPO
0 FEET 500 401 ALBE RTO WAY
0 Ml!11!RS 250 I OS G ATOS. C:AI IFORNIA