Completeness Letter 2 - 2019.11.22
CITY OF CAMPBELL
Community Development Department
70 North First Street • Campbell, CA 95008-1423 • TEL (408) 866-2140 • FAX (408) 866-5140 • E-MAIL planning@cityofcampbell.com
via USPS and electronic mail
November 22, 2019
Mr. Gordon Wong
710 E. McGlincy Lane, Suite 109
Campbell, CA 95008
gordonkwong@gkwarchitects.com
Re: File No: PLN2019-39/40/41/42
Address: 2575 / 2585 S. Winchester Boulevard
Application: Planned Development Permit, Tentative Parcel Map, Tree Removal Permit
Status: Incomplete
Dear Mr. Wong:
Thank you for your resubmittal of a development permit application to allow the demolition of
two residential single-story homes to construct a 48-foot tall, 15-unit apartment building with a
ground floor commercial component and at-grade and underground parking. Based on a review
of the application materials, the Campbell Municipal Code (CMC), and the City of Campbell
Uniform Development Application, your application remains incomplete, pursuant to CMC Sec.
21.38.040 and the California Permit Streamlining Act. The following additional information and
revisions to the plans are needed in order to continue processing of this application:
GENERAL COMMENTS
1. Context of Review: The subject property has a P-D (Planned Development) zoning
designation and a mixed-use general plan land use designation of ‘RCPO’ as follows:
‘Residential / Commercial / Professional Office’: There are several areas within the City
with this designation including the NOCA area, several parcels on Hamilton Avenue west
of San Tomas Expressway and areas along the Vasona Light Rail line. The Residential /
Commercial / Professional Office Designation is intended to provide a residential
component to traditional commercial and/or professional office uses. The intent of this
designation is to maintain the commercial and office uses on the ground floor, with
residential on the upper floors. Development standards will be created for these areas
regarding minimum lot coverage and floor ratio requirements. The Development
standards will also ensure quality site design (e.g. encouraging building placement
toward the street edge and parking in the rear or underneath).
Under this mixed-use land use designation, commercial and/or office uses on the ground
floor are mandatory and for this project would require the ground floor facing Winchester
Boulevard to be commercial and/or office in order to be consistent with the land use
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designation – and therefore is considered a completeness comment. Understanding your
plans attempt consistency with the general plan land use designation as well as the
development standards of the Winchester Boulevard Master Plan (WBMP)1 (which also
requires ground floor commercial) the entire ground floor should be converted to
commercial use. While live-work units may be explored, the size requirements for each
space (1000 sq. ft.) and parking requirement (3-spaces per unit) in addition to other
standards would likely preclude the option.
In short, understanding changes to the plan may be required to provide a commercial
and/or office component on the ground floor facing Winchester Blvd. (such as changing
the height of the building, or mass of the building) – you may need to deviate from the
standards of the WBMP to comply.
2. Screening and Buffering Requirements: Screening between different zoning districts
must be provided pursuant to the requirements of 21.18.120 of the Campbell Municipal
Code. If a fence/wall taller than six-feet is proposed, please clarify that as part of your
permit request as special findings would need to be made to approve the request.
Regardless of the height proposed, please detail all fencing/walls proposed on all
perimeters of the project. Please coordinate with adjoining property owners to determine
their preferences and support for any fencing/walls proposed on a common lot line. It is
strongly recommended to document what efforts you make with neighbors as frequently
the treatment of boundaries becomes a discussion point at public hearings.
3. Architectural Consultant Review: The City collected a deposit of $3,000 for third-party
review by an architectural consultant. Understanding changes to the design will be made
to accommodate a commercial ground level, transmittal of a scope of services to an
architectural consultant have been on hold. Pending receipt of the revised plans – staff
will transmit the revised plans to the architectural consultant for feedback. This
consultant report needs to be completed prior to review of the project by the City’s Site
and Architectural Review Committee (SARC).
4. Density Bonus & Inclusionary Housing Ordinance: As the project has more than 10-
units, 15% of the units must be affordable. For a 15-unit project this equates to a
requirement to provide at least 2 units (2.25 units ~ 2 units after rounding down in
accordance with CMC 21.24.040.A. - Percentage requirement.). For rental projects, forty
percent of the required 15% (or 6% of the total units of the residential project) shall be
provided at a very-low income level with the remainder made available to a low-income
level. For a 15-unit rental project, this translates to a requirement to provide one (.9
rounded up) very-low income unit and one (.6 rounded up) low-income unit.
As a density bonus project, your proposal includes a plan to provide 5% very-low income
(15 x .05 = .75 ~ 1 unit) and 10% (15 *.10 = 1.5 ~ 2 units) low-income units. Please be
advised that this allocation exceeds the minimum allocation to meet the requirements of a
density bonus project while also satisfying the City’s inclusionary housing requirements.
In other words, providing 5% very-low, and 5% low-income units would similarly result
in the same reduction in parking requirements as well as one incentive and concession.
1 More specifically this project is encouraged to be treated as an extension of “Area 1”.
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To ensure a proper count, staff seeks clarification if it is the intention of the project to
provide affordability beyond that required to maximize the understood benefit per code
and state law.
The project materials note that the requested concession is for a reduction in required
backup distance for vehicular parking spaces. For any concession request, the applicant
must provide a cost pro forma demonstrating that the change results in identifiable,
financially sufficient and actual cost reductions to make the project viable shall be
required. Further, as the depth of parking stalls is also inadequate, it may be advisable to
position the concession as a request for a reduced stall depth (rather than a reduced stall
depth and driveway backup distance; which would amount to two separate concessions
on paper).
5. Parking: Understanding that the project will include a ground floor commercial
component, the project must provide a parking analysis that includes the parking demand
for the residential component (in accordance with density bonus standards) and a separate
parking analysis demonstrating compliance with commercial parking standards taking
into account required accessible and electric vehicle/clean air parking spaces. If a parking
management plan is proposed to address situations where accessible guest parking spaces
may double as required accessible parking for commercial tenant spaces – such a
proposal needs to be articulated and reconciled with applicable requirements. Further,
while the parking allocation and even assignment of residential parking spaces was clear
– it was somewhat ambiguous how the guest parking space and commercial parking
relationship would work – and it may make more ‘sense’ to group two parking spaces
together of any given unit to make transfer of materials between cars easier.
6. 2019 Building Code: The project plans make multiple references to satisfying 2016
Building Code requirements where the project will be submitted and reviewed under the
2019 Building Code. Please plan to address 2019 Building Code requirements as part of
your resubmittal and preferably provide an explanation of changes made to the plans to
comply which have a material impact on the building design (interior or exterior) in order
to comply with such provisions.
7. Parcel Map: The revised plans indicate a proposal to submit a parcel map for concurrent
review and approval but a plan for a parcel map (showing easements; like the utility
easements proposed along the rear property line) was not included.
8. Streetscape Standards: Please see public works comments on streetscape standards; the
plans reflect treatments applicable to Winchester Boulevard which should be revised to
follow the standard detail for Winchester established by the Streetscape Standards.
9. CEQA Technical Documents: No additional environmental documents have been
received at this time. This comment serves to follow up on the status and submittal
progress of the Phase 1 environmental site report; Air Quality Report (which is likely
pending the outcome of traffic counts); Flood Zone Analysis, Geotechnical Investigation
Report, Biological Resources Assessment, Acoustic Analysis etc. – while the project may
continue to progress without these documents up and through review by the City’s Site
and Architectural Review Committee (SARC) – an environmental assessment must be
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concluded prior to progressing to Planning Commission. Pending on the outcome of these
preliminary studies, staff will determine the appropriate level of environmental review.
PLAN REVISIONS
Note: A redlined copy of the plans has been provided for ease of reference. The following
serves to summarize the majority of those same comments.
10. Cover Sheet & Information (Sheet A000): The following must be revised:
a. Project Intent: The project intent still indicates that the project ‘aims to propose a
zoning amendment’ where no application for a zoning map and/or zoning code
amendment has been proposed in association with the application. The project is that
the project is comply with current zoning (i.e. P-D) which preclude future conversion
of the project to condominium units (i.e. C-PD). If a zoning map amendment is
proposed with the permit, please include this as part of your written request paying
fees as appropriate to facilitate the review.
Instead of indicating the project ‘aims to propose…’ language, consider substituting
that the ‘the project seeks a density bonus in accordance with state law’ which is
more accurate an illustrative of the proposal.
b. Project Scope:
• Parking. The parking table provided does not accurately capture the number and
type of stalls provided. Please be advised that residential parking stalls require a
minimum dimension of 9-feet by 20-feet.
• Lot Line Adjustment. The project scope includes a proposal for a lot line
adjustment which, while true, would be imposed as a condition on the project.
Alternatively, it is recommended to apply for a parcel map which could be
reviewed/processed concurrently and could serve to resolve several issues at once
– such as a 10-foot light/air easement generally along the Winchester Boulevard
side of the property, and any required vacations/dedications. See Public Works
Department comment letter.
c. Project Information: The project information references following the ‘base district
guidelines’ of the C-2 and R-3 zoning districts. This instead should be referencing the
general plan land use designation of 'RCPO' - Residential/Commercial/Professional
Office which allows up to 27 units / gr. acre (not 27 du. / acre).
d. Floor Area Ratio & Lot Coverage: Please provide a calculation of proposed floor area
ratio and lot coverage where a standard has been provided. While residential floor
area does not count against lot coverage a separate number should
e. Vicinity Map: You may want to add Safeway and the Winchester Light Rail Station
as points of interest on this map. (Optional)
11. Architectural Notes and Symbols (Sheet A001): The following revisions are required:
a. General Notes: #10 – Paint Color must be specified pre-entitlement for this project;
please provide a color and material sheet indicating the proposed exterior colors and
materials with manufacturer specification details (i.e. brand / color code). Note: It is
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recommended to provide this color and material board as a separate sheet to be
responsive to this request.
12. SF Exhibit and Adjacent Land Uses (Sheet A002): The following must be revised:
a. Gross Lot Area: The total gross lot sf analysis is inadequate (roughly approximating
the gross floor area of the project over an assessor’s parcel map without showing how
net and gross areas were calculated). Please have a surveyor/engineer confirm the net
and gross lot size of the project on one of the civil drawings that also reflects
centerline of street (such as the boundary survey and topographic map; Sheet C-1).
Note: This is still outstanding; and the measurement depiction should include the
triangle to the center of street (see redlined plans for clarity on this detail).
13. Project Data, Occupancy, and Egress Analysis (Sheet A004): The following additional
details must be provided.
a. Utilities: Please show the proposed location of any transformer, electrical switchbox,
gas meters, or similar equipment and/or backflow preventers, fire connections, taller
than 12-inches off the ground and/or with a footprint greater than four square feet.
Note: This is still an outstanding comment.
14. Parking Analysis (Sheet A009): The following additional details must be provided:
a. Assignment. Please indicate the retail parking space assignment in the parking chart
for grade level and basement level. Please be advised if an inadequate number of
commercial parking spaces are allocated; a separate fee and application for a parking
modification permit may be required.
b. Required Parking Aisle Width: The proposed width is not adequate; as a concession
has been proposed to address this a cost pro-forma is required to demonstrate it is
financially supported (i.e. for example a reduced commercial tenant space depth on
the ground floor to achieve compliance would result in lower rent rates etc.).
15. Onsite Grading and Drainage Plans (Sheet 1 to 11):
a. Sheet 3: DMA-6 is reflected as a walkway path on Sheet A007. Please check for
similar conflicts. Please also reconcile landscape plans with the bioretention areas and
plant species proposed; if trees/bushes etc. are proposed in a bioretention area it
should be reflected in the bioretention detail to address how that would be
accomplished. DMA-14; Note: This comment remains outstanding.
16. Master Planting Plan (Sheet L1): The following must be revised:
a. The plans note the proposal for several large species of bushes and trees in bio
retention areas where it is more likely that tall grasses would be proposed. Please
confirm that the species selections can be achieved in the planting areas proposed
(note that a horticultural soil report will be eventually required to ensure suitability of
the installed soil). Please check with Public Works if the proposed species could be
accommodated and/or engineered around in bioretention swales. Check with Public
Works Department. Note: This comment remains outstanding.
17. Hydrozone Plan (Sheet L2): Please update calculations if/when plant species are changed
per changes to Sheet L1. Note: This comment remains a perpetual requirement.
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18. Floor Plan, Level 2 through Level 4 (Sheet A102 through A104): Open space is measured
in areas meeting a minimum dimension of 10-feet x 10-feet. It would be helpful to
document which areas satisfy that requirement, separate from other areas. Note: This
comment has been addressed, but it is recommended to separately tally all open space not
meeting the 10-feet x 10-feet requirement to have it available as a discussion point (to
your credit).
19. Sections (Sheet 400): The following must be revised on the cross sections sheet:
a. Include the following height measurement in relative values (feet and inches) as well
as lot specific elevation benchmark (AMSL) levels established by the Grading and
Drainage Plan and Topographic and Demolition Plan:
(1) Existing grade.
(2) Maximum structure height as measured from existing (natural) grade.
Note: This comment is partially outstanding; detailed measurements in relative
values were provided but without a natural grade note/detail on this page for
comparison there is no relation to the topographic survey to know exactly how
much cut/fill is anticipated to the lots. Please add at least a line indicating natural
grade in relation to these lines with the AMSL level used.
20. Photometric calculation - exterior (Sheet E1.0): The following additional details must be
provided:
a. The provided photometric calculation concludes some light would spill beyond the
property line. Please clarify which lights are the source of this spill and explain why
they cannot be corrected by a taller fence (or by accounting for the fence proposed)
and/or enhanced down shielding of the fixture. It is strongly recommended to revisit
this exhibit to demonstrate no light will extend beyond the property line by making
such revisions, changes, or corrections to the plans.
DESIGN COMMENTS
These comments are non-binding considerations in review of your project.
21. Mixed-Use/Commercial Component: In anticipation of a redesign of the ground floor to
accommodate a commercial component; please be advised taller ceiling heights (as called
for by the WBMP) should be explored. Further, it is encouraged to have distinct tenant
spaces by design using varied exterior materials, and to distinguish commercial
door/glazing entry systems from residential systems. A series of mixed-use design
comments will be provided under separate cover as suggestions.
22. Driveway Entry: The driveway entry to the at-grade parking is very close to the
intersection. While the proposed ‘tightening’ of the curb radius at this intersection (see
Public Works comments) may help slow traffic in this area; it may be advisable to
evaluate a one-way driveway design for at grade parking with the entrance on Winchester
and the exit on Friar. However, this design may result in concerns that commercial trips
that miss the Winchester entry may elect to park on the street on Friar.
DEPARTMENTAL REVIEW
This application was also reviewed by the Public Works Department, County Fire District, and
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70 North First Street • Campbell, CA 95008-1423 • TEL (408) 866-2140 • FAX (408) 866-5140 • E-MAIL planning@cityofcampbell.com
Building Division, the comments from which are enclosed for your review. Please note that the
Fire District and Public Works Department comments require revisions to the plans and/or
additional information before the plans may be approved.
If you should have any questions, please feel free to contact me at (408) 866-2142 or by email at
stephenr@cityofcampbell.com. With resubmittal, please provide five 24" x 36", two 11"x17",
and one electronic (PDF) copy of the revised project plans.
Sincerely,
Stephen Rose
Associate Planner
Encl: Department Comments
Redlined Project Plans
cc: Paul Kermoyan, Community Development Director
Mohammad K. Mohammadagha, 5739 Camden Avenue, San Jose, CA 95124 // mike_agha@yahoo.com