G2-2026_Environmental_Update.pdf

MEMORANDUM

To: Nicolle Burnham, Town of Los Gatos Parks and Public Works Department

From: Dana Link-Herrara, Gondica Strykers, Dudek

Subject: Town of Los Gatos Roadway Vegetation Management Project - CEQA Approach Memorandum

Date: May 27, 2026 cc: Emily Scricca, Dudek

Attachments: A, Notice of Exemption

B, SWCA CEQA Exemption Memo

1 California Environmental Quality Act Approach

1.1 Review of Proposed Project and Previous California

Environmental Quality Act Analysis

The Town of Los Gatos (Town) Roadway Vegetation Management Project (project) would remove hazardous vegetation and create defensible space around approximately 31.09 miles of Town-owned hillside roadways

(Figure 1, Project Vicinity; Figure 2, Project Overview) that have been identified by the Town and Town residents as roadways of high concern. Vegetation management is limited to roadside fuel reduction and maintenance activities intended to reduce wildfire intensity and allow for improved access for emergency response and evacuation safety during a wildfire. Vegetation management would not involve the removal of healthy, mature, or scenic trees, except where trees pose a public safety hazard because they are leaning toward a roadway of concern, are structurally compromised and above a roadway of concern, or are otherwise at risk of falling into a roadway of concern or obstructing required emergency access. Work would focus on removing roadside vegetation within a maximum

20-foot horizontal distance from roadways, and 13-foot, 6-inch vertical distance above roadways, as well as clearance of non-fire-resistant vegetation within 10 feet of the roads. The activities proposed do not involve land use changes, expansion of existing facilities, or grading.

A California Environmental Quality Act (CEQA) Notice of Exemption (NOE) was filed for the project in 2020

(Attachment A, Notice of Exemption) with an accompanying CEQA Exemption Memo prepared by SWCA (SWCA 2020;

Attachment B). Project details outlined in the CEQA Exemption Memo for the previously planned project are assumed to remain the same for the current project. As such, clearing activities would include the following:

▪ Cutting back or removing vegetation and tree limbs that encroach into the roadway to create at least 20 feet of horizontal clearance. This would not include removal of mature trees other than as noted below.

▪ Removing low hanging tree limbs that extend over the roadway to create at least 13 feet, 6 inches of vertical clearance.

TOWN OF LOS GATOS ROADWAY VEGETATION MANAGEMENT PROJECT - CEQA APPROACH MEMORANDUM

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MAY 2026

▪ Removing all non-fire-resistant vegetation located within 10 feet of the roadways. Vegetation to be removed includes, but is not limited to, combustible vegetation such as Eucalyptus (Eucalyptus sp.) trees, acacia

(Acacia sp.) trees, scotch broom (Cytisus scoparius), French broom (Genista monspessulana), and toyon

(Heteromeles arbutifolia).

▪ Creating vertical spacing between trees and shrubs by removing vegetation that provides ladder fuels such as low branches and understory shrubs within 10 feet of the roadways.

▪ Removing tree limbs and low branches on mature trees within 10 feet horizontal of the edges of the roadways to 6-10 feet vertical above the ground, and at least 13 feet, 6 inches vertical above road surfaces to allow for emergency vehicle access.

▪ Tree removal would be limited to trees that could reasonably fall into the public right‑of‑way or compromise required defensible space along public roadways, and would be completed in a manner consistent with permit requirements and exemptions under the Town of Los Gatos Tree Protection Ordinance.

▪ Redwoods would be left in place unless thinning of small saplings is required.

▪ String-trimming groundcover, such as grasses, to achieve a height of 4 inches or less within 10 feet of the roadways.

▪ Coordinating the removal of vegetation entangled in overhead wires. The Town is not responsible for directly removing vegetation from overhead wires. However, any required removal of vegetation entangled in overhead wires would be coordinated with PG&E. Private contractors would prune the balance of any trees partially pruned by PG&E outside of the 10-foot safety zone.

▪ Coordinating with property owners along private roadways where additional vegetation management is recommended. While these private roadways are not a part of this project, the Town would communicate with these property owners regarding associated risks and recommendations for vegetation management to be completed by the property owners.

▪ All work would be conducted in compliance with applicable Town codes, ordinances, and regulations, including requirements related to defensible space, public safety, roadway access, and tree protection.

Although the priority level of some roads has been modified relative to the prior project, no substantial changes have been made to the project and proposed treatment activities since filing the previous NOE. Accordingly, the program qualifies for exemption from CEQA, as summarized in Section 1.3.

1.2 Local Regulations

The objective of the project is to ensure Town roadways are consistent with the Government Code 51175-51189, the Town Municipal Code, and Santa Clara County Fire Department access road standards.

Santa Clara County Fire Department Standards (Santa Clara County Fire Department 2021)

The Santa Clara County Fire Department access road standards include the following requirements:

▪ The minimum clear width of fire department access roads shall be 20 feet. Modifications to the design or width of a fire access road, or additional access road(s) may be required when the fire code official determines that access to the site or a portion thereof may become compromised due to emergency operations or nearby natural or manmade hazards (flood prone areas, railway crossings, bridge failures, hazardous material-related incidents, etc.).

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▪ The width of secondary access roads may be reduced to less than 20 feet provided turnouts are installed adjacent to the roadway every 500 feet with a minimum dimension of 10 feet wide and 40 feet long or as otherwise determined by the fire code official.

▪ Vertical clearance over required vehicular access roads and driveways shall be 13 feet, 6 inches.

Town of Los Gatos Municipal Code Chapter 9 – Fire Prevention and Protection (Town of Los Gatos 2026a)

Section 4907.3 Requirements. Hazardous vegetation and fuels around all buildings, roads, driveways, and structures shall be maintained in accordance with the following laws and regulations:

1. Public Resources Code, Section 4291 through 4296.

2. California Code of Regulations, Title 14, Division 1.5, Chapter 7, Subchapter 3, Article 3, Section 1299.03.

3. California Government Code, Sections 51175 - 51189.

4. California Code of Regulations, Title 19, Division 1, Chapter 7, Subchapter 1, Section 3.07.

5. Any local ordinance of the Town of Los Gatos.

Town of Los Gatos Municipal Code Section 29.10.09050. DIVISION 2 - TREE PROTECTION (Town of Los Gatos 2026b)

Section 29.10.0960. - Scope of protected trees.

This division shall apply to every property owner and to every person, corporation, partnership, sole proprietorship or other entity responsible for removing, maintaining or protecting a tree. The trees protected by this division are:

1. All trees which have a twelve-inch or greater diameter (thirty-seven and one-half-inch circumference) of any trunk or in the case of multi-trunk trees, a total of eighteen inches or greater diameter (fifty-six and one-half-inch circumference) of the sum of all trunks, where such trees are located on developed residential property.

2. All trees which have an eight-inch or greater diameter (twenty-five-inch circumference) of any trunk or in the case of multi-trunk trees, a total of eight inches or greater diameter (twenty-five-inch circumference) of the sum of all trunks, where such trees are located on developed Hillside residential property.

3. All trees of the following species which have an eight-inch or greater diameter (twenty-five-inch circumference) located on developed residential property: a. Blue Oak (Quercus douglasii); b. Black Oak

(Quercus kellogii); c. California Buckeye (Aesculus californica); d. Pacific Madrone (Arbutus menziesii).

4. All trees which have a four-inch or greater diameter (twelve and one half-inch circumference) of any trunk, when removal relates to any review for which zoning approval or subdivision approval is required.

5. Any tree that existed at the time of a zoning approval or subdivision approval and was a specific subject of such approval or otherwise covered by subsection (6) of this section (e.g., landscape or site plans).

6. Any tree that was required by the Town to be planted or retained by the terms and conditions of a development application, building permit or subdivision approval in all zoning districts, tree removal permit or code enforcement action.

7. All trees, which have a four-inch or greater diameter (twelve and one half-inch circumference) of any trunk and are located on property other than developed residential property.

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8. All publicly owned trees growing on Town lands, public places or in a public right-of-way easement, which have a four-inch or greater diameter (twelve and one-half-inch circumference) of any trunk.

9. A protected tree shall also include a stand of trees, the nature of which makes each dependent upon the other for the survival of the stand.

10. The following trees shall also be considered protected trees and shall be subject to the pruning permit requirements set forth in section 29.10.0982 and the public noticing procedures set forth in section 20.10.0994:

a. Heritage trees;

“Heritage tree means a tree or grouping of trees specifically designated by action of the Town Council, upon the recommendation of the Historic Preservation Commission, that possess exceptional aesthetic, biological, cultural, or historic value and is expected to have a continuing contribution to the community,” Section 29.10.0955

b. Large protected trees.

“Large protected tree means any oak (Quercus), California buckeye (Aesculus californica), or Pacific madrone (Arbutus menziesii) which has a 24-inch or greater diameter (75-inch circumference); or any other species of tree with a 48-inch or greater diameter (150-inch circumference).” Section

29.10.0955

Section 29.10.0965. - Prohibitions.

Except as provided in Section 29.10.0970, it shall be unlawful to perform the following:

1. To remove or cause to be removed any protected tree in the Town without first obtaining a permit pursuant to this chapter.

2. To prune, trim, cut off, or perform any work, on a single occasion or cumulatively, over a three-year period, affecting twenty-five (25) percent or more of any protected tree without first obtaining a permit pursuant to this chapter.

3. To prune, trim, or cut any branch or root greater than four (4) inches in diameter (twelve and one-half (12.5) inches in circumference) of a Heritage tree or large protected tree without first obtaining a permit pursuant to this chapter.

4. To conduct severe pruning as defined in section 29.10.0955 without first obtaining a permit pursuant to this chapter.

5. For any person or business entity engaged in the business of removing trees or tree care to perform work requiring a permit under this division without first obtaining a permit under this division. The permit shall be posted on-site at all times during the removal or permitted pruning of a tree and must be made available upon request from the Chief of Police, Code Compliance Officer, Director of Parks and Public Works

Department, or their designee. After a second violation, the Los Gatos business license of the violating person or entity shall be suspended for a period of one (1) year.

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Section 29.10.0970. - Exceptions.

The following trees are excepted from the provisions of this division and may be removed or severely pruned without

Town approval or issuance of a tree removal permit:

1. A fruit or nut tree that is less than eighteen (18) inches in diameter (fifty-seven-inch circumference).

2. Any of the following trees that are less than twenty-four (24) inches in diameter (seventy-five (75) inches in circumference): a. Black Acacia (Acacia melanoxylon) b. Tulip Tree (Liriodendron tulipifera) c. Tree of

Heaven (Ailanthus altissima) d. Blue Gum Eucalyptus (E. globulus) e. Red Gum Eucalyptus (E.

camaldulensis) f. Other Eucalyptus (E. spp.)-Hillsides only g. Palm (except Phoenix canariensis) h. Privet

(Ligustrum lucidum)

3. Any removal or maintenance of a tree to conform with the implementation and maintenance of Defensible

Space per Chapter 9 - Fire Prevention and Protection with the exception of any tree listed in subcategories

(3) and (10) of Section 29.10.0960 - Scope of Protected Trees.

1.3 Recommended CEQA Approach

The original CEQA memorandum determined that the project was exempt from CEQA review pursuant to the

Emergency Projects statutory exemption under CEQA Guidelines Section 15269. While the project remains exempt from CEQA, further review indicates that the project is more appropriately exempt under a Categorical Exemption, specifically Class 4 – Minor Alterations to Land (Section 15304).

Categorical Exemptions (CEQA Guidelines, Title 14 CCR) Class 4 – Minor Alterations to Land (Section 15304):

Class 4 consists of minor public or private alterations in the condition of land, water, and/or vegetation that do not involve removal of healthy, mature, scenic trees except for forestry and agricultural purposes. The project involves minor alterations to vegetation and land that do not result in significant environmental effects. This exemption expressly includes fuel management activities within 30 feet of structures to reduce the volume of flammable vegetation, provided that the activities would not result in the taking of endangered, rare, or threatened plant or animal species or significant erosion and sedimentation of surface waters. This exemption also expressly includes fuel management activities within 100 feet of a structure if the public agency having fire protection responsibility for the area has determined that 100 feet of fuel clearance is required due to extra hazardous fire conditions.

Vegetation treatments are limited in scope and do not involve substantial ground disturbance.

Accordingly, the project qualifies for a Class 4 Categorical Exemption under CEQA Guidelines Section 15304, and no further environmental review is required.

Exceptions to Categorial Exemption Analysis

15300.2 Exceptions (a) Location. Classes 3, 4, 5, 6, and 11 are qualified by consideration of where the project is to be located – a project that is ordinarily insignificant in its impact on the environment may in a particularly sensitive environment be significant. Therefore, these classes are considered to apply all instances, except where the project may impact on an environmental

19208 6 resource of hazardous or critical concern where designated, precisely mapped, and officially adopted pursuant to law by federal, state, or local agencies.

The proposed project would occur primarily within existing, disturbed roadway corridors and involves limited vegetation trimming and fuel reduction activities designed to maintain emergency access and roadway clearance, and because these activities would not result in a significant effect on any designated, precisely mapped environmental resource of hazardous or critical concern, the location exception under CEQA Guidelines Section

15300.2(a) does not apply.

(b) Cumulative Impact. All exemptions for these classes are inapplicable when the cumulative impact of successive projects of the same type in the same place, over time is significant.

This exception does not apply to the proposed project. No other vegetation management or defensible space projects are expected to occur within the planned treatment areas and there are no known or reasonably foreseeable other projects that would occur within or adjacent to the planned treatment areas.

(c) Significant Effect. A categorical exemption shall not be used for an activity where there is a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances.

This exception does not apply to the proposed project. There are no unusual aspects to the project or the planned treatment areas that would create a reasonable possibility of significant effects to the environment. The existing conditions within the planned treatment areas are similar to conditions present along roads in similar communities throughout California. Best Management Practices (BMPs) would be undertaken during the duration of the project.

With BMPs, the project would not impact biological or cultural resources. The project would not generate significant air quality, hazardous materials, noise, traffic, or water quality impacts.

(d) Scenic Highways. A categorical exemption shall not be used for a project which may result in damage to scenic resources, including but not limited to, trees, historic buildings, rock outcroppings, or similar resources, within a highway officially designated as a state scenic highway.

This does not apply to improvements which are required as mitigation by an adopted negative declaration or certified EIR.

This exception does not apply to the proposed project. According to the California Department of Transportation, California State Route 9 (SR 9) in Santa Clara County is a designated State Scenic Highway, and SR 17 and SR 35 are eligible as State Scenic Highways (Caltrans 2026). However, the project would involve vegetation reduction on local roads, outside of the designated and eligible scenic highways.

(e) Hazardous Waste Sites. A categorical exemption shall not be used for a project located on a site which is included on any list compiled pursuant to Section 65962.5 of the Government Code.

This exception does not apply to the proposed project. No portion of the vegetation management project occurs on a hazardous site or a site that is included on any list compiled pursuant to Section 65962.5 of the Government

Code. There are three locations identified on the GeoTracker database where hazardous materials cleanup efforts have been or are underway adjacent to the project area. All three sites involve releases from dry cleaners into the local groundwater, and none of the sites involve the adjacent roads.

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(f) Historical Resources. A categorical exemption shall not be used for a project which may cause a substantial adverse change in the significance of a historical resource.

This exception does not apply to the proposed project. The project would remain on or adjacent to existing roads.

Vegetation removal along existing roads would not impact any structures.

1.4 Best Management Practices

The following BMPs outlined in the previously prepared CEQA exemption memo would apply to the current project.

The Town’s project design avoids impacts to sensitive resources by selecting work area footprint locations in the least environmentally sensitive areas available. The Town has incorporated the following general BMPs into the proposed project to minimize impacts to residents as well as potential jurisdictional features, special-status species

(including federal and state-listed species), wildlife habitat and movement corridors, and natural communities.

ID# Best Management Practices

Additional Action

Needed for Updated

NOE?

1 A cultural resources records search was completed for the Town General

Plan and resources were not found in areas that will be impacted by the roadways. In addition, only minimal soil disturbance is expected as part of the project. Therefore, cultural and paleontological resource impacts are not anticipated. If during any phase of the project, cultural and/or paleontological resources or human remains are discovered, work will be stopped until the find has been evaluated and the potential significance determined by a qualified professional archaeologist and an appropriate course of action has been recommended.

Regulatory Basis: CEQA Guidelines Section 15064.5; Public Resources Code

Section 5097.98; Health and Safety Code Section 7050.5.

Potential need for updated cultural records search

2 During project activities, all trash that could attract wildlife shall be properly contained, removed, and disposed of regularly. Following vegetation management activities, trash and debris shall be removed from work areas.

Regulatory Basis: 14 CCR Section 17867; Los Gatos Municipal Code Chapter

18.

3 Project activities will be designed to avoid significant effects on special-status species that are listed as rare, threatened, or endangered under

Federal law or are listed as rare, threatened, endangered, candidate, fully protected, or species of special concern under State law. A desktop review of the California Diversity Database and U.S. Fish and Wildlife Service (USFWS)

Information for Planning and Consultation System has been conducted and a reconnaissance survey of the roadways was completed by SWCA

Environmental Consultants in July 2020.

A. A qualified biologist will be retained to conduct a training to field personnel on sensitive habitat and species prior to vegetation management work.

B. A qualified biologist will be engaged prior to roadway work to review the work locations. The biologist will be retained to survey the project area for special-status species if work occurs adjacent to suitable habitat.

Potential need for updated database searches and reconnaissance survey.

During project implementation, WEAP training needed, bio surveys needed, nesting bird surveys needed if work occurs during nesting season

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ID# Best Management Practices

Additional Action

Needed for Updated

NOE?

C. A qualified biologist will be retained to conduct a nesting bird survey if work occurs during the nesting bird season (generally March 1 through

September 15). If a nesting bird is found, the biologist will provide measures to avoid impacting the species, such as implementing an appropriate no disturbance buffer until nesting activity ceases.

Regulatory Basis: Federal Endangered Species Act (16 U.S.C. Section 1531 et seq.); California Endangered Species Act (Fish & Game Code Section

2050 et seq.); Fish & Game Code Section 3503, 3513.

4 If special-status wildlife is encountered during project activities, it will be unharmed, allowed to leave the area on its own volition, or the appropriate regulatory agency (i.e., California Department of Fish and Wildlife [CDFW] or

USFWS) will be contacted to determine the appropriate action to relocate the species.

Regulatory Basis: Fish & Game Code Section 2080, 3513.

5 If project activities occur within or immediately adjacent to riparian vegetation or other potentially jurisdictional features, the Town will consult the Regional Water Quality Control Board (WQCB) and CDFW, as appropriate.

The following table identifies whether planned treatment areas contain riparian vegetation that may need to be trimmed. These resources were identified using the National Hydrologic Dataset mapping tool and were verified in the field as shown in the table below.

Road Name Extent of Riparian Vegetation

Almendra Avenue No riparian vegetation observed.

Blackberry Hill Road No riparian vegetation observed.

Foster Road No riparian vegetation observed.

Hernandez Avenue No riparian vegetation observed.

Hicks Road Well-developed riparian corridor consisting of willow, walnut, and western sycamore between town boundary near Wagner Road and town boundary near Burke Ave. The majority of this vegetation is within

10' of the road.

Kennedy Road Non-contiguous canopy of individual western sycamore trees situated on the north side of the road between Forrester Road and

Corporate Limit. Likely supported by an ephemeral roadside ditch/ drainage. Some bed and bank observed near roadway.

Shannon Road Limited willows and walnut riparian vegetation between Cerro Vista

Court and midway between

Sunview Drive / Sky Lane. Semi-contiguous canopy in areas.

Potential need to recheck National

Hydrologic Dataset and field verify.

Potential need to reconsult WQCB and

CDFW.

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ID# Best Management Practices

Additional Action

Needed for Updated

NOE?

Supported by an ephemeral ditch/drainage. Additional willow riparian vegetation observed at intersection with Kennedy Road.

Some semicontiguous and non-contiguous willow and walnut riparian canopy between Kennedy and Hicks Road. Supported by an ephemeral ditch/drainage.

Short Road No riparian vegetation observed.

Talt Avenue No riparian vegetation observed.

University Avenue No riparian vegetation observed.

Victory Lane No riparian vegetation observed.

All work adjacent to identified riparian features would be limited to trimming necessary to maintain required roadway clearance, with no removal of riparian trees or understory vegetation.

Regulatory Basis: Fish & Game Code Section 1602; California Water Code

Section 13000 et seq.; Clean Water Act Section 401.

6 Where riparian vegetation is present, vegetation removal shall be limited to trimming necessary to maintain roadway clearance. No riparian trees or understory vegetation shall be removed.

Regulatory Basis: Fish & Game Code Section 1602; 23 CCR Section 3670 et seq.

7 Heavy equipment operations will not be conducted on slopes greater than

50 percent or in any slide or unstable areas.

Regulatory Basis: Los Gatos Municipal Code Chapter 29, Article IV, Division 3

Mapping of slopes would be helpful to establish avoidance areas.

8 Where streams, creeks, or standing water are present within the project area, project activities shall avoid work within standing water associated with these features.

Regulatory Basis: Clean Water Act Section 401

9 During VMP implementation, fuel and hazardous materials will be kept at least 100 feet from waterbodies to provide protection from accidental leaks or spills.

Regulatory Basis: California Water Code Section 13260; 23 CCR Section

3700 et seq.

10 All fueling and maintenance of vehicles and other equipment and staging areas shall occur at least 100 feet from potentially jurisdictional drainages.

Regulatory Basis: California Water Code Section 13260; Clean Water Act

Section 402 (NPDES).

11 Prior to the onset of work, the Contractor shall ensure that there is a plan to allow a prompt and effective response to any accidental spills of hazardous

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ID# Best Management Practices

Additional Action

Needed for Updated

NOE?

materials. All workers shall be informed of the importance of preventing spills, and of the appropriate measures to take should a spill occur.

Regulatory Basis: California Water Code Section 13260; 23 CCR Section

2250 et seq.

12 Soil and trimmed or chipped vegetation will not be placed where it could enter a waterbody or cover vegetation.

Regulatory Basis: Clean Water Act Section 401; Porter-Cologne Water Quality

Control Act.

13 Herbicides will not be used as part of the project. This BMP represents a voluntary project design feature.

14 Project activities will be conducted to avoid introducing or spreading invasive plant species. The following are California Invasive Plant Control (CAL-IPC)

Best Management Practices to prevent the spread of invasive species:

A. Provide prevention training to staff and contractors prior to starting work.

B. Schedule activities to minimize potential for introduction and spread of invasive plants.

C. Designated waste disposal areas for invasive plant materials and contain invasive plant material during transport.

D. Plan travel routes to avoid areas infested with invasive plants.

E. Clean tools, equipment, vehicles and animals before transporting materials and before entering and leaving worksites.

F. Clean clothing, footwear and gear before leaving infested areas.

G. Carry portable cleaning tools that can be used without water.

H. Prepare worksites to limit the introduction and spread of invasive plants.

I. Minimize soil and vegetation disturbance.

J. After activities, monitor worksites for invasive plants.

K. Prevent invasive plant contamination of project materials when stockpiling and during transport.

This BMP represents a voluntary project design feature.

Confirm CAL-IPC BMPs remain the same

15 When possible, project activities will ensure that fuel breaks or tree removals are blended into the surrounding environment. This BMP represents a voluntary project design feature.

16 Idling of construction vehicles and equipment shall be minimized to no more than three minutes to the extent feasible. Construction foremen shall include briefing crews on vehicle use as part of preconstruction site meetings. These briefings shall include discussion of “common sense” vehicle use.

Regulatory Basis: Health & Safety Code Section 39650 et seq.; 13 CCR

Section 2485.

17 Prepare and implement a Traffic Control Plan to describe procedures to guide traffic (such as signage and flaggers), safeguard construction workers, provide safe passage of traffic, and minimize traffic impacts, as necessary, through the duration of the vegetation management project. Coordinate with

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ID# Best Management Practices

Additional Action

Needed for Updated

NOE?

work with local emergency services providers, as necessary, to ensure that emergency vehicle access and response is not impeded.

Regulatory Basis: California Vehicle Code Section 21367, Town of Los Gatos

Municipal Code Chapters 9 and 15.

18 Per the Town of Los Gatos Noise Ordinance (Section 16.20.035), vegetation management activities will be limited to the hours between 8:00 am and

6:00 pm Monday through Friday and 9:00 am to 4:00 pm on Saturday.

Regulatory Basis: Los Gatos Municipal Code Section 16.20.035.

19 The Project will maintain fire-safe working conditions and best management practices. These will include:

A. All work vehicles will be required to carry fire suppression equipment.

Workers will be trained in the use of equipment for incipient stage fire suppression.

B. No smoking is allowed in any areas of vegetation management activities along Town roadways. All vehicle parking will be restricted to paved or graveled surfaces.

C. All off-road equipment will be equipped with spark arrestors.

D. Monitor weather and fire danger on a daily basis. During Red Flag

Warnings, a crew member will be assigned to fire watch for each separate and distinct active work area.

Regulatory Basis: Public Resources Code Section 4291; Government Code

Section 51175–51189; Santa Clara County Fire Department Access

Standards (2021).

2 References

Caltrans (California Department of Transportation). 2026. California State Scenic Highways. Accessed April 2026.

https://experience.arcgis.com/experience/47e2009986264718a5a13a2c81382774#data_s=id%3Awi dget_22_output_config_default_geocode_0_0%3A0.

Town of Los Gatos. 2026a. Municipal Code. Chapter 9 – Fire Prevention and Protection. Accessed April 2026.

https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=CO_CH9FIPRPR.

Town of Los Gatos. 2026b. Municipal Code. Division 2 – Tree Protection. Accessed April 2026.

https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=CO_CH29ZORE_ARTIIN

GE_DIV2TRPR.

Santa Clara County Fire Department. 2021. Standards and Specifications. Accessed April 2026.

https://www.sccfd.org/wp-content/uploads/documents/fire_prevention/standards/SD&S%20Second%

20round%20Standards-2/A1-%20Fire%20Department%20Apparatus%20Access%2005.12.2021.pdf.

SWCA (SWCA Environmental Consultants). 2020. California Environmental Quality Act Exemption Analysis.

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Town of Los Gatos Roadway Vegetation Management Project

Project Location

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Other Roadways

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SOURCE:

Town of Los Gatos Roadway Vegetation Management Project

Project Overview

FIGURE 2-1

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Townb of Los Gatos Boundary Vegetation Management Road

Priority 1 Priority 3

Other Roadways

1 3 5 7

2 4 6 8

SOURCE:

Town of Los Gatos Roadway Vegetation Management Project

FIGURE 2-2

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Johnson Avenue

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Jackson Street

Forrester Road

Alpine Avenue

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Townb of Los Gatos Boundary

Vegetation Management Road

Priority 1

Priority 2

Priority 3

Other Roadways

1 3 5 7

2 4 6 8

SOURCE:

Town of Los Gatos Roadway Vegetation Management Project

FIGURE 2-3

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Loma Alta Avenue

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Kennedy Road

Phillips Avenue

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Twelve Oaks Road

Foster Road

Blackberry Hill Road

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Vegetation Management Road

Priority 1

Priority 2

Priority 3

Other Roadways

1 3 5 7

2 4 6 8

SOURCE:

Town of Los Gatos Roadway Vegetation Management Project

FIGURE 2-4

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Vegetation Management Road

Priority 1

Priority 2

Priority 3

Other Roadways

1 3 5 7

2 4 6 8

SOURCE:

Town of Los Gatos Roadway Vegetation Management Project

FIGURE 2-5

Deer Park

Court

Sky Lane

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View Drive

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Kennedy Road

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Priority 1

Priority 2

Priority 3

Other Roadways

1 3 5 7

2 4 6 8

SOURCE:

Town of Los Gatos Roadway Vegetation Management Project

FIGURE 2-6

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Townb of Los Gatos Boundary

Vegetation Management Road

Priority 1

Priority 2

Priority 3

Other Roadways

1 3 5 7

2 4 6 8

SOURCE:

Town of Los Gatos Roadway Vegetation Management Project

FIGURE 2-7

Deer Park Court

Kennedy Road

Arnerich Road

Hicks Road

Shannon Road

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Townb of Los Gatos Boundary Vegetation Management Road

Priority 1 Priority 2

Other Roadways

1 3 5 7

2 4 6 8

SOURCE:

Town of Los Gatos Roadway Vegetation Management Project

FIGURE 2-8

Attachment A Notice of Exemption

Attachment B SWCA CEQA Exemption Memo

Town of Los Gatos Vegetation Management Project CEQA Exemption Memo Page 1

Half Moon Bay Office 60 Stone Pine Road, Suite 100 Half Moon Bay, California 94019 Tel: 650.440.4160 Fax: 650.440.4165

CALIFORNIA ENVIRONMENTAL QUALITY ACT

EXEMPTION ANALYSIS

PROJECT DESCRIPTION

The Town of Los Gatos (Town) Roadway Vegetation Management Project (Project) will remove hazardous vegetation and create defensible space around approximately 31.09 miles of Town-owned hillside roadways that have been identified by the Town and Town residents as roadways of high concern (Figure 1). These town-owned roadways1 include evacuation routes and other collector, neighborhood, and hillside collector roads that are located within the wildland urban interface (WUI) and/or are have been identified by the Town and Town residents as having inadequate access for emergency response during a wildfire.

Under the project, work will focus on removing roadside vegetation to create a clear space that is 20 feet wide and 13 feet, 6 inches above roadways, as well as clearance of non-fire-resistant vegetation within 10 feet of the roads. Clearing these areas will not only improve emergency vehicle access and evacuation safety, but will also reduce the amount of heat that evacuating residents might be exposed to during a fire, improve visibility, and expand the usable width of roadways on narrow hillside streets.

The Town will work with private contractors annually to inspect and clear vegetation along the roadways.

Clearing activities will include:

• Cutting back or removing vegetation and tree limbs that encroach into the roadway to create at least 20 feet of horizontal clearance.

• Removing low hanging tree limbs that extend over the roadway to create at least 13 feet, 6 inches of vertical clearance.

1 Although private roadways are not included in this project the Town has identified a limited number of private roadways where vegetation management is recommended. The Town will communicate with property owners on these private roadways regarding associated risks and recommendations for vegetation management to be completed by the property owners.

Town of Los Gatos Vegetation Management Plan

CEQA Exemption Memo Page 2

• Removing all non-fire-resistant vegetation located within 10 feet of the roadways. Vegetation to be removed includes, but is not limited to, combustible vegetation such as Eucalyptus (Eucalyptus sp.) trees, acacia (Acacia sp.) trees, scotch broom (Cytisus scoparius), French broom (Genista monspessulana), and toyon (Heteromeles arbutifolia).

• Creating vertical spacing between trees and shrubs by removing vegetation that provides ladder fuels such as low branches and other understory shrubs within 10 feet of the roadways.

• Removing tree limbs and low branches on mature trees within 10 feet horizontal of the edges of the roadways to 6-10 feet vertical above the ground, and at least 13 feet, 6 inches vertical above road surfaces to allow for emergency vehicle access.

• Removing trees that are on steep slopes leaning at angles that could fall and block a roadway.

• Redwoods should be left in place unless thinning of small saplings is required.

• String-trimming groundcover, such as grasses, to achieve a height of 4 inches or less within 10 feet of the roadways.

• Coordinate the removal of vegetation entangled in overhead wires. The Town is not responsible for directly removing vegetation from overhead wires2. However, any required removal of vegetation entangled in overhead wires will be coordinated with PG&E. Private contractors will prune the balance of any trees partially pruned by PG&E outside of the 10-foot safety zone.

• Coordinate with property owners along private roadways where additional vegetation management is recommended. While these private roadways are not a part of this project, the Town will communicate with these property owners regarding associated risks and recommendations for vegetation management to be completed by the property owners.

The Town has identified three priority levels of roadways where vegetation management for fire safety is of utmost concern. These levels are based on Vegetation Management Action Levels (VMAL) which are defined by the amount of vegetation encroachment into and along the edges of the roadway. Existing VMAL’s along roadways of high concern were identified and mapped during a reconnaissance-level survey

2 The Town and/or its contractors must remain a minimum of 10 feet from energized conductors and cannot remove any vegetation that is entangled in overhead wires. Therefore, removal of vegetation entangled with overhead wires will be coordinated with PG&E. The Town and/or contractors will also coordinate with PG&E where vegetation treatment creates risk of limbs falling onto wires and lane/road closures for vegetation management activities. Private contractors will prune the balance of any trees partially pruned by PG&E outside of the 10-foot safety zone.

CEQA Exemption Memo Page 3 by SWCA Environmental Consultants biologists and arborist in June and July 2020 (Figure 2). Specifically, these levels are defined as:

• VMAL 1. High level of encroachment of roadside vegetation. Typically includes areas of dense native woodland vegetation with canopy overhanging the roadway. Vegetation often entangled in overhead wires. Pockets of dense flammable non-native invasive vegetation (e.g., acacia, broom) in the understory on hillslopes adjacent to roadways.

• VMAL 2. Moderate encroachment of roadside vegetation. Some areas of dense native woodland as in VMAL1. Additional areas of native scrub vegetation on open hillsides with non-native annual grasses. Pockets of dense flammable non-native invasive vegetation (e.g., acacia, broom) in the understory on hillslopes adjacent to roadways.

• VMAL 3. Minimal encroachment of roadside vegetation3. Urban streetscape within the WUI that contains irrigated ornamental/landscaped non-native vegetation. VMAL 3 roads are typically adjacent to the Town center with wide streets and sidewalks. Vegetation often entangled in overhead wires at point of connection to adjacent structures.

Based on these VMAL designations and an updated fuel model and hazard assessment, the Town has prioritized project roadways into three levels as follows (Figure 3):

• Priority Level 1: Priority 1 roadways include evacuation routes within the Town with VMAL 1 and VMAL 2 designations. Vegetation management along these roads is essential to ensuring emergency vehicles can access locations along these roads and ensuring the safety of residents as they evacuate in the event of a wildfire.

• Priority Level 2: Priority 2 roadways include roadways identified by the Town as high priority roadways that are not specifically identified as evacuation routes, but may require improvements to allow safe and efficient emergency vehicle access and resident evacuation, and have been identified as VMAL 1 and VMAL 2. These roads need work to meet Los Gatos Municipal Code and other relevant requirements and ensure the safety of Town residents in the event of a wildfire. Priority 2 roadways also include arterial and collector streets with a VMAL 1 and VMAL 2 designations.

• Priority Level 3: Priority 3 roadways have some vegetation encroachment that could increase the intensity of a fire and/or increase wildfire spread. Priority 3 roadways have been identified as any roads that are within the WUI with a VMAL 3 designation. These roads generally meet Los Gatos Municipal Code and other requirements and are not expected to need immediate or regular routine vegetation maintenance to meet requirements. These roads should be inspected

3 VMAL 3 roads outside the WUI were removed from the project since these roads generally meet the Los Gatos Municipal Code and other relevant requirements and are not expected to require vegetation maintenance to ensure the safety of Town residents and emergency vehicles can access locations along the roadways in the event of a wildfire.

CEQA Exemption Memo Page 4 every few years to ensure they do not need vegetation maintenance to comply with fire requirements, such as the Los Gatos Municipal Code.

PROJECT PURPOSE

The objective of the project is to ensure Town roadways are consistent with the Government Code 51175-51189, the Town Municipal Code, and Santa Clara Fire Department access road standards, to support safer evacuation routes for residents and emergency response vehicles by creating a fuel break along evacuation routes and other roads within the Town in the event of a wildfire. 4,5,6

The combination of increasing development in or near wildlands, the accumulation of wildland fuels, a drying and warming climate, longer fire seasons, and rugged terrain has resulted in significant wildfire risk to communities located in or near the WUI. The WUI area is best described as a wildland-urban intermix with homes scattered amongst wildland fuels. The Town WUI planning area includes primarily Very High Fire Hazard Severity Zone areas, as defined by CalFire and the Town of Los Gatos Fire Prevention and Protection Ordinance. 7 A Community Wildfire Protection Plan (CWPP) was prepared for the County of Santa Clara.8 Annex 9 of the CWPP (updated in 2019) addressed specific wildlife prevention and mitigation for the Town and identified the need for removal of obstructions on road systems for evacuation (Strategic Goal FC-8) and a roadside fuel treatment program (Strategic Goal FR-7).9 This Vegetation Management Plan (VMP) is being prepared to address those needs.

4 Town of Los Gatos. 1996. Town of Los Gatos Municipal Code. Chapter 9. Fire Prevention and Protection.

Available at:

https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=CO_CH9FIPRPR. Accessed July 28, 2020.

5 Santa Clara County Fire Department. 2009. Standard Details & Specifications. Fire Department Apparatus Access. Available at:

https://www.sccfd.org/images/documents/fire_prevention/standards/2.4.6_fire_department_apparatus_acc ess.pdf. Accessed July 28, 2020.

6 Town of Los Gatos. 2020. Ordinance 2301. Ordinance of the Town of Los Gatos Amending Chapter 9 (Fire Prevention and Protection) of the Town Code Regarding Weed Abatement Regulations. Available at:

https://www.losgatosca.gov/DocumentCenter/View/24284/Ord-2301---Amend-Chapter-9-Fire-Prevention- _-Protection-regarding-Weed-Ab. Accessed August 21, 2020.

7 Town of Los Gatos. 2009. Very High Fire Hazard Areas Map. Available at:

https://www.losgatosca.gov/DocumentCenter/View/24122/Los-Gatos-WUI-and-State-VHFHA- Map?bidId=. Accessed July 28, 2020.

8 Santa Clara County. 2009. Santa Clara County Community Wildfire Protection Plan. Available at:

https://www.sccfd.org/santa-clara-county-community-wildfire-protection-plan. Accessed Jul 28, 2020.

9 Santa Clara County. 2009. Santa Clara County Community Wildfire Protection Plan. Annex 9. Available at:

https://www.sccfd.org/santa-clara-county-community-wildfire-protection-plan. Accessed Jul 28, 2020.

https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=CO_CH9FIPRPR https://www.sccfd.org/images/documents/fire_prevention/standards/2.4.6_fire_department_apparatus_access.pdf https://www.sccfd.org/images/documents/fire_prevention/standards/2.4.6_fire_department_apparatus_access.pdf https://www.losgatosca.gov/DocumentCenter/View/24284/Ord-2301---Amend-Chapter-9-Fire-Prevention-_-Protection-regarding-Weed-Ab https://www.losgatosca.gov/DocumentCenter/View/24284/Ord-2301---Amend-Chapter-9-Fire-Prevention-_-Protection-regarding-Weed-Ab https://www.losgatosca.gov/DocumentCenter/View/24122/Los-Gatos-WUI-and-State-VHFHA-Map?bidId= https://www.losgatosca.gov/DocumentCenter/View/24122/Los-Gatos-WUI-and-State-VHFHA-Map?bidId= https://www.sccfd.org/santa-clara-county-community-wildfire-protection-plan

CEQA Exemption Memo Page 5

State law designates all lands within the Town as a Local Responsibility Area (LRA) for the purposes of wildland fire protection.10 Therefore, areas within the Town are required to maintain defensible space as outlined in Government Code 51175-51189 and Los Gatos Municipal Code Chapter 9. As a result, all fire apparatus access roads are required to have an unobstructed width of no less than 20 feet, exclusive of shoulders, or as required by fire department access road standards, and an unobstructed vertical clearance of 13 feet, 6 inches. In addition, all areas within 10 feet of fire apparatus roads and driveways are required to be cleared of non-fire-resistant vegetation growth. The Santa Clara Fire Department access road standards also include the following requirements:

• The minimum clear width of fire department access roads shall be 20 feet. Modifications to the design or width of a fire access road, or additional access road(s) may be required when the fire code official determines that access to the site or a portion…