11-22-2022 - PC Agenda with Desk Item REGULAR PLANNING COMMISSION MEETING
City of Campbell, California
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November 22, 2022
7:30 p.m.
City Hall, Council Chambers
AGENDA
NOTE: To protect our constituents, City officials, and City staff, the City requests all members of
the public to follow the guidance of the California Department of Health Services', and the County
of Santa Clara Health Officer Order, to help control the spread of COVID-19. Additional
information regarding COVID-19 is available on the City's website at www.campbellca.gov.
This Regular Planning Commission meeting will be conducted in person with the Commissioners
meeting at City Hall, Council Chambers, as well as via telecommunication (Zoom) being available
for members of the public. The meeting is compliant with provisions of the Brown Act.
Commissioner Davis Fields will attend virtually from 6013 83rd Street, Lubbock, TX 79424. A
quorum of the Planning Commission will be in attendance at City Hall.
This Regular Planning Commission meeting will also be live streamed on Channel 26, the City's
website and on YouTube at https://www.youtube.com/user/CityofCampbell for those who only
wish to view the meeting but not participate. Those members of the public wishing to provide
public comment at this meeting virtually are asked to register in advance at
https://campbellca.gov/PCSignup. After registering, you will receive a confirmation email
containing information about joining the meeting via Zoom. Members of the public may attend
the meeting in person at Campbell City Hall - Council Chambers. If attending in person, face
coverings and physical distancing will be required until further notice.
Public comment for the Planning Commission meetings will be accepted via email at
planning@campbellca.gov by 5 p.m. on the day of the meeting. Written comments will be posted
on the website and distributed to the PC. If you choose to email your comments, please indicate
in the subject line “FOR PUBLIC COMMENT” and indicate the item number.
ROLL CALL
APPROVAL OF THE MINUTES November 8, 2022
COMMUNICATIONS
AGENDA MODIFICATIONS OR POSTPONEMENTS
ORAL REQUESTS
This is the point on the agenda where members of the public may address the Commission
on items of concern to the Community that are not listed on the agenda this evening. People
may speak up to 5 minutes on any matter concerning the Commission.
Planning Commission Agenda for November 22, 2022 Page 2 of 2
STUDY SESSION
1.PLN-2022-78 Study Session to consider the preliminary request of Field to
Barrel, LLC (OTB) for property located at 48 Civic Center
Drive, for construction of an approximately 2,770 square-foot
two-level commercial building (first floor seating area + rooftop
patio), to be programed to accommodate a "craft beer
taproom," with related off-site public improvements including
reconfiguration of the adjacent sidewalk and street curb-line to
accommodate a new curbside loading/trash pickup zone. The
application under consideration is a Preliminary Application.
File No.: PLN-2022-78. Project Planner: Daniel Fama, Senior
Planner
OLD BUSINESS
1.PLN-2022-12 Study Session on Campbell’s Plan for Housing (2023-2031
Housing Element) to facilitate further development and
refinement of the Housing Opportunity Map and Goals,
Policies and Programs which will guide housing development
and services throughout the eight-year planning period. File
No. PLN-2021-12. Project Planner: Stephen Rose, Senior
Planner
REPORT OF THE RESIDENTIAL DESIGN STANDARDS SUBCOMMITTEE
REPORT OF THE COMMUNITY DEVELOPMENT DIRECTOR
ADJOURNMENT
Adjourn to the next Regular Planning Commission meeting of December 13, 2022, at 7:30
p.m. This meeting will be in person for the members of the Planning Commission at
Campbell City Hall, Council Chambers, 70 N. First Street, Campbell, CA. Members of the
public are still allowed to participate remotely by Zoom or attend in person (as space allows
while maintaining on-going face covering and social distancing).
Americans with Disabilities Act (ADA)
In compliance with the Americans with Disabilities Act, listening assistance devices are
available for meetings held in the Council Chambers. If you require accommodation to
participate in the meeting, please contact the Community Development Department, at
planning@campbellca.gov or (408) 866-2739.
CITY OF CAMPBELL
Planning Commission Minutes
7:30 P.M. TUESDAY
November 8, 2022
PLANNING COMMISSION REGULAR MEETING
CITY HALL COUNCIL CHAMBERS
The Planning Commission meeting on Tuesday November 8, 2022, was called to order at
7:30 p.m. in the Council Chambers of City Hall, 70 N. First Street, Campbell, CA, by Chair
Ching and the following proceedings were had, to wit:
ROLL CALL
Commissioners Present: Chair: Stuart Ching
Vice Chair: Adam Buchbinder
Commissioner: Matt Kamkar
Commissioner: Davis Fields
Commissioner: Michael Krey
Commissioner: Alan Zisser
Commissioners Absent: Commissioner: Maggie Ostrowski
Staff Present: Senior Planner: Stephen Rose
Associate Planner: Tracy Tam
City Attorney: Bill Seligmann
Admin Analyst: Ken Ramirez
APPROVAL OF MINUTES
Approved October 25, 2022 meeting minutes.
COMMUNICATIONS
Desk Item submitted prior to hearing. Developer of a Housing Opportunity Site commenting
on large site standards.
AGENDA MODIFICATIONS OR POSTPONEMENTS
None
Campbell Planning Commission Meeting Minutes – November 8, 2022 Page 2
ORAL REQUESTS
Chair Ching opened public comments, hearing none, public comments closed.
PUBLIC HEARINGS
Chair Ching asked if any of the Commissioners had any disclosures. Commissioner Fields
stated that he lived within a walkable distance from one the sites discussed.
Chair Ching read Agenda Item No. 1 into the record as follows:
STUDY SESSION
1.PLN-2022-90 Study Session to review and provide feedback on development
of the Multi-Family Development and Design Standards
including mapping of walkable and auto-oriented
neighborhoods, establishment of off-street parking
requirements, and the development of site development and
design standards to be addressed as part of the update (File
No.: PLN-2022-90).
Associate Planner Tracy Tam and Senior Planner Stephen Rose presented along with
Opticos the most recent updates of the Multi-Family Development and Design Standards
including mapping of walkable and auto-oriented neighborhoods, off-street parking
requirements, regulation of design standards, standards to address adjacency and context,
and standards for the development of large sites. Key goal of this study session is to receive
feedback to prepare standards that help close the aspects of the design review process
which was previously not decided until the public review phases.
Presentation covered potential desired standards for the City’s desired outcomes,
proposed updates to project review process, options for a Form-Based approach,
adjacency & context, off-street parking standards, and development standards for large
sites so that they are incorporated into surrounding spaces.
Chair Ching opened public comments.
Dennis Randall from Acquity Realty, was not in agreement with bifurcating and bundling
parking space. Requested that developer be allowed to manage the asset of parking
spaces as it suits them.
Joseph Germiagnani concerned with developers building boxy flat type buildings.
Recommending reducing City fees to entice Developers to choose quality choices over
economic choices.
James Sullivan attended several Developer meetings with City staff and Opticos. Stated
that market rate developers do not build to minimum but rather to what they think the market
wants. Also, that large site standards should take into account the context if there are
freeways on each side.
Campbell Planning Commission Meeting Minutes – November 8, 2022 Page 3
Dorian Lemarchand recommended doing “no-overnight” street parking unless you have a
permit as it would potentially allow to do completely unbundled spots while incentivizing
people to utilize the parking spots themselves.
Peter Beritzhoff from Baywest Development urged that the site on San Tomas Aquino and
Campbell Avenue be considered a drivable site so that they can build larger buildings, with
good architecture.
Chair Ching closed public hearing for a brief break. Chair Ching readjourned the public
hearing.
The Planning Commission provided feedback on key discussion points as summarized
below:
Walkable and Auto-Oriented Neighborhoods
The Planning Commission agreed with the Walkability Map as presented, and advised
that that Areas 1, 2, and 3 should also be considered walkable areas. The Planning
Commission noted that these areas could be more walkable over time, particularly with
property redevelopment.
Off-Street Parking Requirements
While there was not clear consensus, individual members of the Planning Commission
were supportive of establishing a Citywide parking standard of 1.25 spaces per unit based
on the findings/conclusions of the Ad-Hoc Subcommittee, which cited ITE (Institute of
Traffic Engineers) parking rates as the basis of their recommendation (reference Exhibit
B – ITE Standards). The Planning Commission separately recommended allowing for
further parking reductions, when projects provide car sharing, bicycle parking, offering
transit passes, and/or unbundled parking. The Planning Commission also advised that
unbundled parking should be considered in areas where free overnight parking on the
street is not permitted.
Regulation of Design Standards
The Planning Commission agreed that the standards should regulate all aspects of the
building design (e.g., frontages, articulation, site layout) in consideration that the form-
based approach can provide for a range of outcomes – thereby avoiding cookie cutter
outcomes. The Planning Commission agreed that a higher bar should be set for
properties in the Downtown but felt that other areas of the community (e.g., gateways)
should not be held to a higher standard.
Standards to Address Adjacency and Context
The Planning Commission agreed that the standards should address adjacency to low
density residential development, freeways, creeks, schoolyards, and parks. Members of
the Planning Commission noted that a greater emphasis should be paid to the street level
experience to ensure a consistent pedestrian experience, rather than establishing
standards that remove buildable area (or potential unit counts).
Standards for Development of Large Sites
Planning Commission recommended creating standards for the development of large
Campbell Planning Commission Meeting Minutes – November 8, 2022 Page 4
sites and advised that an approximately four-to-five-acre threshold would be appropriate
to apply these development standards. The recommended size was based on the
average acreage of larger housing opportunity sites currently under consideration.
Furthermore, the Planning Commission expressed an interest in breaking up larger sites
into smaller blocks, noting that this could be done in a variety of ways, from private streets
to paseos. Planning Commissioners stated that including open spaces and civic spaces
for large sites would help in breaking up the building but questioned if these were
necessarily for wholly residential projects, particularly if the space was not open to the
public.
REPORT OF THE MULTI-FAMILY DEVELOPMENT AND DESIGN STANDARDS
SUBCOMMITTEE
Vice Chair Buchbinder recommended that the City require 1.25 spaces per unit if there is
available parking nearby in the respective neighborhood and therefore all other available
parking can be unbundled.
Identified parking space ratio was derived from the Institute of Transportation Engineering’s
recommendations.
Commissioner Zisser stated that developers will be including parking so that they are able
to receive financing for their projects.
REPORT OF THE COMMUNITY DEVELOPMENT DIRECTOR
Acting Secretary Stephen Rose communicated that the Community Development
Department appointed Bob Lennen as the new Building Official.
ADJOURNMENT
The Regular Planning Commission meeting adjourned at 10:41 p.m. to the next Regular
Planning Commission Meeting on Tuesday, November 22, 2022, at City Hall, Council
Chambers, 70 N. First Street, Campbell, CA.
SUBMITTED BY: ______________________________________
Ken Ramirez, Administrative Analyst
APPROVED BY: ______________________________________
Stuart Ching, Chair
ATTEST : ______________________________________
Stephen Rose, Acting Secretary
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Out of the Barrel | www.outofthebarreltaproom.com | 48 Civic Center Drive, Campbell, CA 95008
October 10, 2022 Out of the Barrel, Inc
180 Garlic Ave
Morgan Hill, CA 95037
City of Campbell Planning & Building Department
RE: Out of the Barrel Taproom
48 Civic Center Drive
Campbell, CA 95008
To Whom It May Concern,
Out of the Barrel was created to improve the availability and awareness of great,
independently brewed craft beer. I opened our first taproom in the Pruneyard on June 4,
2018. As a Campbell native and Saint Lucy School graduate, I am deeply connected to this
community and so proud that we were able to start our business here.
In just a few short years, Out of the Barrel has achieved overwhelming success in creating
excitement around small craft breweries in Campbell and has expanded that enthusiasm to
communities in Fresno, Los Gatos, Morgan Hill, and soon to be San Carlos. While we greatly
appreciate the opportunity and exposure we’ve had in the historic Pruneyard, we believe
moving our operations to our own property in downtown Campbell is the key to our
continued future success.
The location we’ve chosen to develop our taproom is located on a vacant lot on Civic Center
Drive. This site will require significant investment to develop, including bringing utilities
(water/sewer/power/gas) from N Central Ave, reconfiguring city owned pedestrian
sidewalk/lighting/trees, and constructing a single story commercial building with an
occupiable 2nd floor rooftop.
The building has been designed to create a relaxed, welcoming atmosphere for the community
to reconnect with one another. The entire building will be dedicated to Out of the Barrel
Taproom with the main craft beer draft and bottle shop at the ground level, along with
counter-service small bites, and an outdoor beer garden on both the ground level as well as
the rooftop. We will be pursuing either a Type 41 ABC license type (On-Sale Beer & Wine –
Eating Place) or a Type 40 ABC license (On-Sale Beer Only), which authorizes the sale of beer
both on- and off-premises. We will maintain a small kitchen for hot food available during all
hours of operation, and minors will be allowed on-site. Altogether, our intention is to create a
family friendly atmosphere by offering comfortable seating, counter service food that pairs
well with the best quality craft beer we can source, and a variety of non-alcoholic beverage
options.
Our craft beer taproom will feature several of the best breweries we can find (mostly from
California) with a selection that rotates on a daily basis. We offer full pours, tasters, and mix
Out of the Barrel | www.outofthebarreltaproom.com | 48 Civic Center Drive, Campbell, CA 95008
and match flights of anything on our list. The bottle shop will consist of a constantly rotating
selection of high-end cans, bottles, kombuchas, seltzers, and non-alcoholics.
From our operations in the Pruneyard, we recognize the need to create spaces that can be
reserved for small community gatherings, such as corporate events, wedding pre/post
parties, birthday parties, and the like. We receive requests to rent our space out for these
types of events on a very regular basis, but are unable to accommodate them due to
limitations with our existing space. Therefore, we have designed our new taproom to host
both private parties and regular customer traffic at the same time.
The taproom will be operated with a staff of about 12 – 15 people (with 2 – 6 employees
working at any given time). The majority of the business will be based upon selling craft beer
and food for consumption on the premises. This is estimated to be 80 - 85% of overall sales.
Customers will also have the ability to purchase for consumption off the premises. Off-
premise food, beverage, and merchandise purchases are estimated to be about 15 - 20% of
overall sales.
Our maximum hours of operation will be from 10am opening to 12am closing, with most days
operating between 12pm and 11pm. We will be pursuing a live music permit to host local
musicians to provide casual background music. We want to ensure that we are not creating
excess noise for our residential neighbors, and are designing our space to reduce noise
pollution through the use of walls, glass barriers, and landscaping structures. Additionally, we
are happy to comply with limited hours of live music operations, as directed by the City.
The following security plan will be implemented upon opening to provide a safe and secure
environment for our employees, patrons, and neighbors:
• A Designated Contact Person (24hrs/Day, 7 Days/Week): Evan Jaques – Owner
408-807-8619 | evan@outofthebarrelbeer.com
• All employees are required to provide ABC’s Responsible Beverage Service Training
certification.
• All bartenders and employees have been trained to recognize the symptoms of an
obviously intoxicated person, refuse service of alcoholic beverages to obviously
intoxicated persons, and report emergencies to law enforcement and manager on duty.
• An adequate number of employees are always scheduled to work based upon the
regularly anticipated volume of patrons during all working days.
• Out of the Barrel has partnered with Think Twice to make available a low cost, single
use breathalyzer for all customers to prevent intoxicated driving in our community.
• First Aid supplies shall be maintained on site in the employee back of house area. Type
2A:10B:C fire extinguishers shall be easily and readily accessible to all staff members
in case of a fire emergency.
• Out of the Barrel utilizes state of the art security controls and monitoring such as
commercial door locks, wifi connected alarm system, and wifi connected video
cameras that upload all content to a cloud based 30-day recording system.
Out of the Barrel | www.outofthebarreltaproom.com | 48 Civic Center Drive, Campbell, CA 95008
Please let me know if you have any questions or need further clarification. We look forward to
continue our operations in the City of Campbell.
Evan Jaques
Owner
Out of the Barrel, Inc.
408-807-8619
evan@outofthebarrelbeer.com
November 08, 2022 Job No. 2022_048 AA
Planning Division
City of Campbell
70 N First Street
Campbell, CA 95008
Re: Field to Barrel Campbell Taproom Preliminary Planning Application
To whom it may concern:
This preliminary planning application is for a proposed single-story retail building with occupiable
roof garden to be built on the vacant lot located at 48 Civic Center drive. The building will be
approximately 2,895 square feet in area and will reach a maximum height of 25’-0”. The primary
proposed use is a high-end craft beer taproom (similar to a wine tasting bar) located on the first
floor with a patio and roof garden, all run by the property owner. The patio will also include a small
food preparation kitchen that will host a rotating selection of food vendors.
The building’s scale and massing will be presented as two main components. The first is an
industrial-style brick building similar to that of a repurposed building from Campbell’s early
commercial heritage. The second is a wood structure “addition” that creates a covered patio,
faced in wood siding. The ground-level patio makes use of the site’s unique shape to create profile
that narrows and is enclosed in both wood that matches the building as well as planters and a
green-screen living wall element.
As part of the project the following is proposed:
· The project will request a waiver or a “in lieu of assessment/agreement” for the on-site
parking requirements.
· The building’s trash bins will be wheeled out of the building’s covered loading area for
emptying by waste collection trucks. This would be performed in the early morning hours.
The property owner currently operates similar taproom establishments in downtown Los Gatos,
downtown Morgan Hill, and one currently within the Pruneyard Shopping Center (to be relocated
here). The clientele attracted by a high-end craft beer taproom and restaurant would be beneficial
to the Campbell downtown area, bringing sophisticated palates and encouraging more pedestrian
traffic along the outer downtown corridor along Civic Center Drive.
As a refined and distinctive establishment, the project would support the goals of the Campbell
Downtown Development Plan, enhancing the downtown’s character, diversity, and activity.
José Cotto, aia
Gary J. Aquilina, aia
Richard A. Smith, aia
Michele A. Chadwick, iida
Associates:
Oliver Bollmann, aia
Alyson Williams
Ketki Thanawala
CAS Architects Inc.
1987 Leghorn Street, Ste. 101
Mountain View, CA 94043
Tel. 650.967.6600
www.casarch.com
Planning Division
City of Campbell
October 10, 2022
Page 2
CAS Architects Inc. ¨ 1987 Leghorn Street, Suite 101, Mountain View, California 94043 ¨ Tel 650.967.6600
Very truly yours,
CAS Architects, Inc.
José Cotto, AIA
Principal
License No.: C22170
I:\Prod\22\2022_048\Agency Approval\Packages\2022_048_aa_ltr003.docx
Attachment 4
C-3 Zoning District Design Standards (CMC Sec. 21.10.060.I)
Building Mass
a. Large building facades shall be divided into smaller elements to
complement the intimate scale created by the existing small
property divisions.
b. Second floor decks or terraces at the rear of buildings for use
by adjacent offices or restaurants should be incorporated
whenever practical to add a sense of vitality to the rear building
facades.
c. Roof design shall be consistent with the building's architectural
style. Mansard, shed or residential type roofs are prohibited
unless it is demonstrated that such a roof style is structurally or
architecturally suitable for the particular project or location.
Other Elements
a. Trash collection and storage areas shall be carefully
screened.
b. Mechanical equipment shall be screened from
view. Exhaust louvers shall not be located in the
storefront areas.
c. Colorfully landscaped planters are allowed. These
are especially appropriate below second floor
windows.
d. All building maintenance shall be done
conscientiously.
Storefronts
a. First floor frontages shall have an integrated design including
display windows, an entry, and signing.
b. The design of the building storefront shall be consistent with
the building's architectural style.
c. Walls facing pedestrian ways should have elements of visual
interest, such as fenestration, displays, signing, or landscaping,
unless the effect of such elements would be clearly contrary to
the purposes of this chapter. Large areas of blank walls should
not be permitted unless it is demonstrated that such blank
areas are clearly more appropriate and harmonious than would
be the case if elements of visual interest were incorporated.
d. Entries should be recessed, as they add depth to storefront,
and act as transition areas between the street and shop
interiors, unless the effects of such entries would be clearly
contrary to the purposes of this paragraph.
e. Doors and windows shall be of clear glass. Unglazed wood
doors, screen doors and doors or windows of heavily tinted or
reflective glass should not be approved unless it is
demonstrated that such doors and windows are the only
structurally or architecturally suitable form for the particular
project or location.
f. Storefront windows shall reflect the building's character. For
instance, on 1940's and 50's "showcase" buildings, exposed
aluminum frame windows are appropriate.
g. Awnings on building facades should be employed when
appropriate, as they add color, weather protection, and
opportunities for signing. As in other architectural elements,
the awnings should be designed to reflect the building's
geometry.
Materials, Colors, and Finishes
a. Primary facade materials shall be limited to those
that are characteristic of the building's
architectural style.
b. Exterior wall finishes shall be smooth and of
finished quality, not deliberately rough in an
attempt to look antiqued or used.
c. Primary building colors shall be characteristic of
the building's architectural style. Overly bright,
garish, or otherwise offensive colors or color
combinations are prohibited.
d. Accent materials such as tile bases shall be
carefully chosen to complement the building style
and coordinate with adjacent buildings. The use of
shingles, lava rock, sheet metal siding, or any other
residential or industrial materials should not be
approved unless it is demonstrated that such
material would be the only structurally or
architecturally suitable materials for the project or
location.
e. Painted trim shall coordinate with primary facade
colors to add more depth and interest to the
buildings.
f. A coordinated color scheme that responds to the
style of the structure shall be developed for each
building. The colors of signing, awnings, planters,
accent materials, and primary facade colors should
all be considered. The number of colors should be
limited.
Building form and Composition
a. Traditional commercial building forms should be incorporated whenever practical.
b. Upper stories in multistory buildings are required to have solid surfaces with vertical rectangular windows, augmented
with frames. Glass curtain walls should not be approved unless it is demonstrated that such walls are the only structurally
or architecturally suitable form of wall for the particular project or location.
c. Architecturally exemplary design of high quality shall be employed. Buildings should not be made to look "old time" unless
such design would be clearly more appropriate and harmonious with the purpose of this chapter.
d. Buildings shall incorporate base, cornice, and other elements appropriate to their architectural style.
To: Chair Ching and Planning Commissioners Date: November 22, 2022
From: Daniel Fama, Senior Planner
Via: Rob Eastwood, Community Development Director
Subject: Preliminary Application Study Session
File No.: PLN-2022-78 ~ 48 Civic Center Drive
PURPOSE
The purpose of this study session is to present preliminary plans for construction of an
approximately 2,770 square-foot two-level commercial building with a rooftop patio. Study session
review by the Planning Commission was requested by the property owner so that the Commission
may provide feedback during the early stages of the planning process in order to facilitate
preparation of a formal application. Otherwise, the desire to develop the subject property would not
require pre-application review.
Since the pre-application process does not constitute a formal application review, comments are
considered advisory recommendations for the use of the applicant. Moreover, comments are not
binding upon the Planning Commission as to any determination made on a formal application. In
that regard, staff’s review of the preliminary project plans is limited to the overall project design
concept and is not considered a substitute for formal project review.
PROJECT DATA
Zoning Designation: C-3 (Central Business District)
General Plan Designation: Central Commercial
Area/Neighborhood Plan: Downtown Campbell Development Plan
Lot Size: 4,480 square feet (existing)
Height: 24 feet 45-ft Maximum Allowed
Floor Area Ratio (FAR): .64 1.5 Maximum Allowed
Building Areas:
First Story: 2,485 square feet
Mech./Elevator Penthouse: 410 square feet
2,895 square feet
Parking:
Proposed: 0 stalls
Required: 0 stalls (per AB 2097)
MEMORANDUM
Community Development Department
Planning Division
PC Study Session Memorandum – November 22, 2022 Page 2
PLN-2022-78 ~ 48 Civic Center Dr.
BACKGROUND
Project Site: The project site is an approximately 4,500 square-foot vacant parcel that was previously
owned by the City's defunct Redevelopment Agency and subsequently sold by the Successor
Agency as required by State law. The property is located along Civic Center Drive, across from the
Campbell Library, as shown on the map, below. The site is located in the C-3 (Central Business
District) Zoning District and the Central Commercial General Plan land use district, and is subject
to the Downtown Campbell Development Plan.
Prior Pre-App: The Planning Commission previously considered a preliminary application proposal
for a new office building on the property at a November 27, 2018, study session. However, the
property was subsequently sold, and no further action was taken.
Proposed Project: The preliminary plans indicate a construction of an approximately 2,895 square-
foot two-level commercial building with an interior seating area, ground-level patio, rooftop patio,
and related off-site improvements including reconfiguration of the adjacent sidewalk and curb-line
to accommodate a new curbside loading/trash pickup zone (reference Attachment 1).
As described in the applicant's Project Description (reference Attachment 2), the proposed building
would be programed to accommodate a "high-end craft beer taproom" with a small kitchen facility
and include ancillary live entertainment with business hours of 10:00 AM to 12:00 AM (weekends)
and 12:00 PM to 11:00 PM (weekdays).
DISCUSSION
Design Approach: The applicant's Project Proposal Statement (reference Attachment 3) provides a
narrative that explains the architect's design approach:
The building’s scale and massing will be presented as two main components. The first is an industrial-style
brick building similar to that of a repurposed building from Campbell’s early commercial heritage. The second
is a wood structure “addition” that creates a covered patio, faced in wood siding. The ground-level patio makes
use of the site’s unique shape to create profile that narrows and is enclosed in both wood that matches the
building as well as planters and a green-screen living wall element.
PC Study Session Memorandum – November 22, 2022 Page 3
PLN-2022-78 ~ 48 Civic Center Dr.
Review considerations of the proposed architectural design come from the design policies of the
Campbell Downtown Development Plan (DDP):
Policy LU-4.1: Downtown Character: Require new development to be sensitive to the unique character that
defines Downtown Campbell.
Policy D-1.1: Building Orientation and Layout: New development and major rehabilitation projects shall
orient buildings on the street to create a continuous development pattern geared to the
pedestrian.
Policy D-1.2: Building Articulation: Given the unique character of the Downtown district, new
development and major rehabilitation projects shall incorporate the traditional architectural
style, articulation and details that reflect the City’s history and promote its future.
Policy D-2.1: Ground-Level Design Features: The Ground-Level in the Downtown shall include design
features, such as consistent streetscape patterns, outdoor areas, display windows, and
building articulation, which is attractive and pedestrian oriented.
The policies establish a clear preference for traditionally designed buildings (i.e., not modern) that
maintain a pedestrian-oriented scale of Downtown Campbell. In staff's assessment, the preliminary
proposal succeeds in satisfying this policy intent. The proposed structure incorporates traditional
materials of brick and wood and is designed to be appreciated at a pedestrian scale and lend depth
and interest to the building:
The project is subject to the C-3 Zoning District Design Standards, which provide standards for
"building mass," "building form and composition," "storefronts," "materials, colors, and finishes,"
and "other elements." These standards are excerpted, in Attachment 4. These standards are intended
to further the policy intent of the Downtown Development Plan of encouraging smaller-scale,
traditionally designed buildings that provide visual interest and contribute to the uniqueness of
Downtown Campbell.
The project would further the C-3 Design Standards in that the design represents an artful and
creative approach to the property that is an example of "architecturally exemplary design of high
quality" in a "traditional commercial building form" ('Building form and Composition'); the use of
brick and wood, and the associated scheme, would be "characteristic of the building's architectural
style" ('Materials, Colors, and Finishes'); the predominant single-story massing would "complement
the intimate scale" of the Downtown and the rooftop patio would "add a sense of vitality ('Building
Mass'); the streetscape treatment would incorporate an "integrated design including display
windows, an entry, and signing" with a patio wall incorporating "elements of visual interest"
('Storefronts'); and the property's trash storage and mechanical equipment will be "carefully
screened" ('Other Elements').
PC Study Session Memorandum – November 22, 2022 Page 4
PLN-2022-78 ~ 48 Civic Center Dr.
Site Layout: The proposed structure would occupy the majority of the parcel area, as shown in the
applicant's rendering, below. This includes the enclosed portion of the building as well as the
cantilevered element that would form a covered patio and extended rooftop patio. The remaining
portion of the parcel would be utilized as uncovered patio area, which would be fenced from the
public sidewalk. The overall layout will follow the street consistent Downtown Development Plan
Policy D-1.1 (Building Orientation and Layout) that "new development…shall orient buildings on
the street to create a continuous development pattern geared to the pedestrian."
Parking: The C-3 Zoning District's parking standard would require eight stalls (1 stall per 325 GFA)
for this proposal. The applicant had intended to seek approval of a Parking Modification Permit to
request relief given the constraints of the property. However, under the recently adopted AB-2097,
the City "shall not impose or enforce any minimum automobile parking requirement on a residential,
commercial, or other development project if the project is located within one-half mile of public
transit." As such, this project is no longer subject to a parking requirement as of January 1, 2023.
General Plan Consistency: The property's Central Commercial General Plan land use designation is
described, below.
Central Commercial: The Central Commercial designation is used for the heart of Campbell including parts of
Campbell and Winchester Avenues in Downtown Campbell. This area is intended to provide shopping, services
and entertainment within a pedestrian oriented, urban environment. Building forms in this designation edge the
street and should include retail commercial uses on the ground floor with either office or residential uses on
the second and third floors.
The proposed taproom would further the vision by bringing much needed activity to a currently
quiet section of Downtown Campbell. Moreover, the proposal for a taproom use would advance the
following General Plan and Downtown Development Plan policies and strategies, by furthering
development along on Civic Center Drive, and encouraging more activity within the Downtown
beyond East Campbell Avenue.
Strategy LUT-5.3g: Day and Evening Activities: Encourage restaurant and specialty retail uses in the
Downtown commercial area that will foster a balance of day and evening activity.
Strategy LUT-19.1a: Mix of Uses: Mix of Uses: Encourage a compatible mix of uses (i.e. professional offices,
services and retail uses) with ground floor retail uses.
Goal LU-6: To promote and encourage development along the loop streets, and beyond.
Policy LU-1.1: Development Potential: To maximize the development potential of property within the C-
3 zone, particularly ground floor retail, restaurants, and other pedestrian oriented uses.
PC Study Session Memorandum – November 22, 2022 Page 5
PLN-2022-78 ~ 48 Civic Center Dr.
Downtown Alcohol Beverage Policy: This proposal is subject to review under the City's Downtown
Alcohol Beverage Policy (DABP). The policy, originally adopted by the City Council in 2009,
provides specific guidance to staff and the Planning Commission when considering applications for
new alcohol beverage service. The DABP "strong discourages" new stand-alone bars, including
"nightclubs, ultra-lounges or similar establishments typically offering live entertainment and late
night alcohol service," such that new Conditional Use Permits for alcohol service should generally
be issued only for restaurants. To this end, the Policy is designed to ensure that alcohol beverage
service remains ancillary and subordinate to the primary purpose of serving food to ensure that
restaurants do not evolve into bars or nightclubs in the late-night hours. This is accomplished
through implementation of various operational requirements (e.g., alcoholic beverages must be
served with food, limitation on the size of the "bar area", etc.).
However, when the DABP was modified in 2011, the Council incorporated a new allowance to
permit "wine bars" and "wine tasting establishments" that close at 11:00 PM, as an exception to the
general discouragement of new bars. Although the DABP does not reference beer-oriented
establishments, the Planning Commission previously granted a Conditional Use Permit to a
brewery-tasting room, Strike Brewing Co. (469 E. Campbell Ave.), in 2019 finding that it
constituted the beer equivalent of a "wine tasting establishment" due to operational commonalities,
such as similar licensing restrictions, provision of tasting-pours of 2-4 ounces ("flights"), and
incorporation of a retail element.
This application presents a different, but similar consideration. The proposed building would be
programed to accommodate a beer-oriented establishment that is characterized by the applicant as a
"high-end craft beer taproom (similar to a wine tasting bar)". Staff supports a determination that
extends the DABP's allowance for "wine bars" to the applicant's proposal in that similar to a wine
bar, a taproom offers a variety of beer options from multiple producers in range of serving sizes.
Moreover, many wine bars and taproom establishments serve both beer and wine such that the
distinction between the two concepts is increasingly ambiguous. The applicant has also verbally
agreed to an 11:00 PM closing time consistent with a plain reading of the DABP.
Consistent with the generally understood concept of a "wine bar", where food is offered to
accentuate the beverage experience, staff recommends a potential condition of approval that would
limit the establishment to a "Type 41" license (On-Sale Beer & Wine – Eating Place) rather than a
"Type 40" license (On-Sale Beer Only). According to the California Department of Alcoholic
Beverage Control (ABC), the former requires "suitable kitchen facilities" that allow for preparation
of "meals for consumption on the premises" where the latter only requires that "sandwiches or
snacks must be available." The preliminary plans show a small kitchen at the ground-level and
secondary food preparation station on the rooftop patio. Provision of food maintains consistency
with the purpose and intent of the DABP while still allowing the applicant to operate a beer-focused
establishment that does not need to satisfy the specific operational restrictions applicable to a
restaurant. This approach would also maintain the suitability of the establishment as friendly to
minors, which would not otherwise be appropriate in a traditional bar or tavern.
Overconcentration of Alcohol Establishments: When considering the formal application, the Zoning
Code will also require the Planning Commission to find that there will not be an "over concentration"
of alcohol-serving establishments in the "surrounding area". Although the Commission should not
make a finding as part of a preliminary review, it may wish to affirm past direction in terms of the
meaning of "surrounding area". Recently, the Planning Commission has applied this term to mean
the mapped boundaries of a master plan (e.g., Downtown Development Plan, Winchester Boulevard
PC Study Session Memorandum – November 22, 2022 Page 6
PLN-2022-78 ~ 48 Civic Center Dr.
Master Plan, etc. ) or a specific shopping center (e.g., Hamilton Plaza, Campbell Plaza, etc.). Staff
recommends continuing this recent practice to ensure greater consistency in the overconcentration
analysis as applied to different areas of the City.
Live Entertainment: The 2011 update to the DABP did not specify whether live entertainment was
allowable in conjunction with wine bars. However, the Planning Commission determined that live
entertainment was permissible when it approved a Conditional Use Permit for a Downtown wine
bar, Tessora's Barra di Vino (234 E. Campbell Ave.), in January 2013. In granting that approval, the
Commission imposed limitations on live entertainment to ensure that it would remain an ancillary
feature of the business, such as a prohibition of a cover charge. Given the project site's location to
nearby residences, staff would recommend additional restrictions on live entertainment including
ending at 10:00 PM on Friday and Saturday and 9:00 PM the remainder of the week and restricting
performances to the ground-level patio. Staff will also require preparation of a noise study to
evaluate the noise impacts of the live entertainment and general patron activity on the rooftop to
ensure that the City's noise limitations are not breached.
Off-Site Improvements: The project plans show a reconfiguration of the public right-of-way that
depicts a feathering of the curb-line leading into an expanded loading zone adjacent to the
neighboring property. The expanded loading zone is necessary to accommodate trash/recycling
pickup from the business as well as delivery trucks. Note that this depiction is conceptual and is
subject to change once a civil engineer is involved in the project.
Security: Standard security measures will be required for the project, such as installation of security
cameras (with archived video available to Police Department staff upon request) and preparation of
a security plan for review by the Police Department. The Police Department may also require
security personnel as the discretion of the Police Chief in association with live entertainment as
determined by a Live Entertainment Permit. Lastly, installation of security lighting along the
westerly wall would also be required to illuminate the public/private pathway located on the adjacent
property that connects to the rear alleyway.
SUMMARY
Based on the discussion points raised in this memorandum staff requests comment and direction on
the following items:
➢ Design Approach (building form, massing, materials)
PC Study Session Memorandum – November 22, 2022 Page 7
PLN-2022-78 ~ 48 Civic Center Dr.
➢ Site Layout (placement of the building on the property)
➢ Land Use (acceptability of a taproom with regard to the General Plan, Downtown
Development Plan, and Downtown Alcohol Beverage Policy)
➢ Compatibility (noise impacts, live entertainment, security concerns)
Attachments:
1. Preliminary Project Plans
2. Project Description
3. Project Statement
4. C-3 Design Standards
Planning
Commission
Report
TITLE: Study Session on Campbell’s Plan for Housing (2023-2031 Housing Element) to facilitate further refinement of the Housing Opportunity Map and Goals, Policies, and Programs which will guide housing development and services throughout the eight-year planning period. (File No. PLN-2021-12)
RECOMMENDED ACTIONS
1.Review and make recommendations to the City Council on refinements to theCity’s Housing Opportunity Map and Goals, Policies, and Programs included in
“Campbell’s Plan for Housing.”
BACKGROUND
The City of Campbell is completing its Envision Campbell (2040 General Plan) update in combination with the preparation of Campbell’s Plan for Housing (2023-2031 Housing Element). The General Plan serves as the City’s blueprint for meeting the community’s
long-term vision for the future. The Housing Element, which is part of the General Plan,
serves to provide an analysis of the City’s housing needs, identify Housing Opportunity Sites, and establish Goals, Policies, and Programs which will guide housing development and services throughout the eight-year planning period, demonstrating how the City will satisfy its RHNA (Regional Housing Needs Allocation) and comply with applicable
housing policies and laws.
Between November 2021 and January 2022, the Planning Commission and City Council provided feedback on the Draft Housing Opportunity Sites (location and density) arriving at an initial inventory which could allow for up to 6,644 units. In arriving at this number,
the City Council expressed an intent to reduce the total number and/or density of sites
prior to final adoption of the Housing Element, following completion of the Environmental Impact Report (EIR), and considering additional public review and feedback from Housing and Community Development (HCD), HCD has recommended that all jurisdictions in California at minimum maintain a 30% buffer of Housing Opportunity Sites above the
assigned RHNA in the Housing Element.
Between April 2022 and May 2022, the Planning Commission and City Council were presented with information on housing issues and contributing factors in the community, provided feedback on Goals, Policies and Programs aimed to address key challenges.
Based on this feedback, staff prepared the Public Review Draft of Campbell’s Plan for
Housing.
Item: Category: Old Business Meeting Date: November 22, 2022
Planning Commission Meeting of November 22, 2022 Page 2 of 22 PLN-2021-12 | Campbell’s Plan for Housing – Inventory & Policy Refinements
On June 9, 2022, the City of Campbell released its Public Review Draft of the Housing
Element. The Public Review Draft was circulated for thirty-days for public comment. During the public comment period, the City received twelve (12) letters, and one late response.
On August 2, 2022, the City Council held a public hearing to review public comments and
proposed modifications to the Draft of Campbell’s Plan for Housing (2023-2031 Housing Element) prior to submitting the document to Housing and Community Development (HCD) for their initial 90-day review.
On August 5, 2022, the City of Campbell published its Initial Review Draft of the Housing
Element and submitted a copy to HCD for review. Following submittal, staff held deliberative video conference meetings with HCD staff to discuss their initial questions and comments on the Draft Housing Element. Initial feedback from HCD was identified by staff as falling within two main categories: 1) technical revisions serving to clarify
information presented in the Draft Housing Element; and 2) recommendations on
modifications to policies and programs. HCD staff advised Campbell staff to consider releasing an updated draft of the Housing Element addressing the technical revisions prior to the distribution of HCD’s formal review letter, so that the letter could be more focused in scope.
On October 26, 2022, the City of Campbell published an updated version of the Housing Element with the technical revisions requested by HCD. This included updating the City’s homelessness figures to include the latest PIT (Point in Time) data and non-substantive clarifications to data, such as providing precise numbers where percentages had
previously been provided.
On November 3, 2022, HCD issued its formal review letter on the City’s Draft Housing Element, and on November 15, 2022, staff met with HCD staff to discuss the comments (reference Attachment B – HCD Comment Letter). The subject report reflects
recommendations resulting HCD feedback received to date.
PURPOSE
This meeting is intended to facilitate feedback from the Planning Commission on proposed refinements to the Housing Opportunity Map, as well as changes to Goals, Policies and Programs in Campbell’s “Plan for Housing” (2023-2031 Housing Element) responding to comments raised in the HCD Comment Letter (reference Attachment B).
This item also serves to provide an update on the General Plan and associated Environmental Review (EIR) associated with the effort.
DISCUSSION
The discussion is organized into two main sections which focus on 1) refinements to the Housing Opportunity Map, and 2) amendments to the Housing Element Goals, Policies
and Programs in response to the formal review letter received from HCD. The feedback
received from the Planning Commission and Council on these topics will be used to prepare the Final Housing Element that will be resubmitted to HCD for their review.
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While this report summarizes the significant changes to the Housing Element warranting policy input and direction, staff is also separately completing a table that summarizes all HCD feedback received and staff’s intended response, to be provided to the Commission as a desk item. Further, while this report outlines three options, or landing points, which
may be considered to refine the City’s Housing Opportunity Site Inventory based on the
removal of sites, staff separately intends to present a 4th Option, as a desk item, which will show how the Housing Opportunity Map may be refined by adjusting the planned densities under consideration, in addition to removing the sites recommended for removal by staff.
1)Housing Opportunity Map Refinements
The City of Campbell’s assigned Regional Housing Needs Allocation (RHNA) for the 2023-2031 planning period is 2,977 units.
Table 1 – City of Campbell’s Regional Housing Needs Allocation
As an initial target, Campbell identified potential Housing Opportunity Sites and residential densities that would allow for the development of up to 6,640 units, a target that is over
two times higher than the City’s RHNA. It is important to acknowledge that HCD will only
provide “credit” for 5,139 of the 6,640 units identified using their applied methodology, which finds it unreasonable to assume every site will develop at the maximum allowable density, or at the level and mix of affordability required (reference Attachment C - Housing Opportunity Methodology).
In developing the Draft Housing Opportunity Site Inventory, the Council expressed an intent to reduce the number and/or density of sites identified, prior to final adoption of the Housing Element, by retaining the best sites, and still maintaining a total number of housing units that is above the City’s RHNA plus a 30% buffer as recommended by HCD
(approximately 3,870 units).
SITE REFINEMENT CRITERIA
Based on initial Council direction, staff identified the following factors recommended to be
used as criteria to inform refinements to the Housing Opportunity Site Inventory (staff
input, and HCD feedback where applicable, follow each point):
1.Property owner interest or disinterest in housing development.
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While property owner interest, or disinterest, does not determine whether a site will
be credited by HCD, it does play a significant role in the overall feasibility analysis.
Staff has identified several sites which may warrant removal based on owner disinterest which is discussed in the following section.
2.Redevelopment potential of City-owned sites.
The Draft Housing Opportunity Site Inventory included two City-owned sites, theFirst Street Parking Garage, and the City Corporation Yard. While staff is still inthe process of evaluating the feasibility of redeveloping these two sites, a
preliminary review of the Parking Assessment District and obligations related to
the First Street Parking Garage make it unlikely to redevelop during the eight-yearplanning period.
Further, since developing the Draft Housing Opportunity Site Inventory, AB 2097
passed which eliminated parking requirements for projects within ½ mile from
public transit, and the City Council established a Semi-Permanent Parklet programin the downtown. As both actions will result in higher dependency on the FirstStreet Parking Garage to meet current and future downtown parking demand, itsretention is warranted until a broader study of the Downtown parking needs is
completed.
3.Results of the Draft Environmental Impact Report (EIR).
In developing the Draft Housing Opportunity Site Inventory, the Council identifiedthat the Environmental Impact Report could be used to identify any environmental
impacts associated with the sites and be used to inform the Council on further
revisions or reductions.
The Draft Environmental Impact Report prepared for the General Plan andHousing Element updates did not identify any significant environmental impacts
associated with specific housing opportunity sites and did not identify any
alternatives in the size of the Housing Inventory that would lessen any identifiedsignificant environmental impacts (the EIR identifies significant and unavoidableenvironmental impacts associated with Greenhouse Gas Emissions, Air Quality,and Vehicle Miles Traveled - VMT).
As Campbell is located in a geographic central location, with access to mass transitand jobs, the EIR concluded that the provision of more housing sites would resultin a reduced environmental impact related to VMT.
4.Feedback from Housing and Community Development (HCD) on the DraftHousing Opportunity Site Inventory.
In the comment letter, HCD provided five points related to the adequacy of theDraft Housing Opportunity Site Inventory:
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•Opportunity Areas: HCD commented on the lack of units in higheropportunity or income areas, with a focus on census tracks located in theNorthwest and Southeast portions of the city. In response, staff intends tohighlight the role that SB 9, SB 10, and related programs and policies willaddress this concern, outside of the Housing Opportunity Sites identified.
This change does not impact the mapped sites.
•Small Sites: HCD commented that sites less than .5 acres are assumed tobe inadequate to accommodate lower-income housing unless the city can
provide evidence of success in the prior housing element cycle. Inresponse, staff has assigned a greater allocation of moderate-income unitsto the 64 ‘small-sites’ sites identified, to better adhere to HCD feedback andguidelines. This change does not impact the mapped sites.
•Large Sites: HCD noted that the Site Inventory includes one 16.4-acre site,with an operating commercial shopping center (i.e., Pruneyard). Whilenoting there is interest from the property owner, HCD requested additionalclarification in the intended strategy to ‘carve out’ portions of the site for
housing. In response, staff intends to provide a narrative to HCD explainingthe City’s approach to assigning units to the property, which provides for theretention of the shopping center. This change does not impact the mappedsites.
•City-owned Sites: In consideration of the two City-owned sites identified bythe Housing Opportunity Site Inventory, HCD requested additionaldocumentation to substantiate the suitability and availability of theproperties. Based on initial screening by staff, one of the two City-owned
sites has been flagged for removal in response. This comment results in theloss of one site from the inventory.
•Nonvacant Sites: In review of the Housing Opportunity Site Inventory, HCD
commented that the housing element relies on nonvacant sites toaccommodate more than 50% of the RHNA for lower-incomeneighborhoods. As a result, HCD has requested the element to provideadditional documentation to demonstrate that existing uses will not be animpediment to residential development and will likely discontinue during the
planning period – and document the outcomes of that analysis as findingsin the resolution included in the adoption of the Housing Element. Staffacknowledges the comment and intends to provide the requesteddocumentation. This change does not impact the mapped sites.
In addition to the comments included in the letter, in deliberative discussions HCD staff broadly advised against removing, or reducing the density, of sites included in the Draft Housing Opportunity Site Inventory. This broader guidance notwithstanding, HCD staff seemed receptive to removing sites where retention would conflict with a separate goal or objective (i.e., providing for open space and
parks to affirmatively further fair housing) and in response to recent development
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activity that would impede housing development from occurring within the eight-
year planning period.
5.Potential compatibility and adjacency issues identified by the Multi-FamilyResidential Design Standards work plan.
In developing the Draft Housing Opportunity Site Inventory, members of the CityCouncil expressed concerns that the height and scale of new buildings may not becompatible with any adjacent lower-density residential neighborhoods. Inresponse, staff recommended deferring consideration of such impacts until the
Multi-Family Residential Development and Design Standards (hereinafter “Design
Standards”) were further developed and able to depict how adjacency concernsmay be addressed, and then make refinements to the Housing Opportunity SiteInventory in response.
While several tools, and approaches have been identified to address adjacency
concerns (i.e., application of form-based zones, large site standards, adjacencystandards), the Design Standards under development are not yet refined enoughto be presented as solutions. However, the initial work on the Design Standardshas shown that it may be difficult to apply design solutions that soften impacts of
larger buildings on shallow or smaller lots that are adjacent to single family
neighborhoods.
6.Potential for buildings to exceed the 75-foot Citywide height limit.
Members of the City Council expressed concerns that buildings may exceed the
City-wide maximum height limit of 75-feet in situations where developers seekapproval of a density bonus on top of a higher density residential designation (i.e.,75-units per acre density that would be allowed on select sites near public transit).
In response, the Housing Element and Multi-Family Development and Design
Standards will provide a suite of incentives (i.e., Affordable Housing Overlay Zone) and tools (i.e., application of form-based zones, large site standards, adjacency standards) to help encourage developers to stay under the Citywide height limit
While these incentives and tools will not rule out the possibility that buildings will
exceed the maximum height limit, the likelihood will be significantly reduced. While adjustments to the maximum density range may still be considered, staff recommends retaining the maximum density of 75-units per acre where identified, recognizing market-rate and affordable housing developers have both expressed
the need for this density to deliver low-income units to the community.
7.Initial Inventory Point Scores
During the initial housing opportunity site selection process, which occurred
between November 2021, and January 2022, the Planning Commission and
Council evaluated sites based on a point score that considered several factors (1
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point if “yes” for a factor, 0 points if not):
• Whether the site was greater than a half-acre in area
• Whether the site yielded 50 or more units at maximum density.
• Whether the site was in a good location (near many amenities, close to light
rail, or in a High Opportunity area according to the Tax Credit Allocation
Committee’s Opportunity Maps.
• Whether there was property owner interest.
• Whether redevelopment of the site would not displace a company that is
one of Campbell’s top-100 sales tax producers.
Each of the 131 sites in the Site Inventory was given a point score from 1 (lowest
score) to 5 (highest score). When considering refinements to the Housing
Opportunity Site Inventory, the point score methodology may continue to play an important role. As a result, the staff recommendation, and options presented, consider removal of sites based on initial point scores.
8. Impact of SB6 & AB 2011 on the Housing Opportunity Site Inventory. The adoption of two recent state bills (SB 6, AB 2011) will result in the production of more housing in Campbell by allowing for residential development on property zoned for retail and office space. There is inadequate time to study and analyze to
determine if Campbell could include additional housing opportunity sites affected
by this legislation, particularly in relation to principles such as AFFH (Affirmatively Furthering Fair Housing), prior to the certification deadline (January 31, 2023). Once future guidance is provided by HCD regarding the implementation of these bills and their relationship to Housing Elements and Housing Opportunity sites, this
could be considered in the future.
PROPOSED REFINEMENTS TO SITE INVENTORY The following discussion outlines three options, or landing points, which may be
considered to refine the City’s Housing Opportunity Site Inventory. These options are
intended to ensure the best sites identified are retained, while reducing the City’s Site Inventory, consistent with Council direction, while maintaining an inventory that is above the City’s RHNA plus the 30% buffer recommended by HCD (3,870 units). Considering that the Housing Opportunity Site Inventory needs to account for units at a variety of
income levels, in addition to achieving a minimum number of units, staff strongly
recommends selecting from the options presented to ensure that an adequate buffer in each income category can be achieved. As an example, if the density of large sites were reduced, and all small sites retained, while it may appear that the total number of units will be achieved, the site inventory will fail to provide for enough low-income housing since
large sites have been assigned a higher allocation of low-income units.
Advantages and Disadvantages to a larger Housing Opportunity Site Inventory
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In considering further refinements and reductions to the Site Inventory, the Commission
and Council should also broadly consider the programmatic advantages and disadvantages of having a site inventory that is substantially higher than the assigned RHNA. These advantages and disadvantages are summarized below:
Advantages of a Higher Buffer (larger inventory)
1)Greater Opportunity for Housing Production – If the City maintains more propertiesavailable for housing development, there is a greater chance that enough housingdevelopment will occur over the upcoming eight-year Housing Element cycle to meet
the City’s housing needs, consistent with the assigned RHNA. As described in prior
housing element staff reports, there are stronger penalties today for cities whereactual housing production during the eight-year housing cycle does not meet theassigned RHNA, including a reduction in land use authority in discretionary review ofhousing projects. As it is unreasonable to assume that each designated housing
opportunity site in the city will develop during the upcoming eight-year period, the
retention of a broader number of housing sites allows more buffer and flexibility inallowing housing development to occur at a rate that meets the City’s housing needsand assigned RHNA
2)No Net Loss Provisions – Recent State Legislation (AB 166) requires that the city
maintain enough housing capacity under its zoning and general plan designationsthroughout the eight-year cycle to allow development that meets the City’s assignedRHNA. This legislation not only requires that the City maintain enough capacity forthe overall production of housing units, but also document that the properties available
for housing have sufficient capacity to allow affordable housing development,
providing below market rate units (Moderate, Low, Very Low). The city currently haslimited tools to support and facilitate affordable housing production, but has identifiedthe creation of new tools under this Draft Housing Element (amended InclusionaryHousing Ordinance, Linkage Fees, Affordable Housing Overlay Zone, use of city land
for affordable housing production) to be implemented in the near future. As it will take
a few years for the City to adopt and onboard these tools, it is likely that housingproduction in the near term will continue consistent with past practice, resulting in thedevelopment of market rate units with a small number of affordable units on housingopportunity sites.
Under this scenario, a risk will be that the development of housing sites at market ratewill reduce the identified capacity of Campbell’s housing sites to support below marketrate development, requiring Campbell to identify and rezone additional sites forhousing during the upcoming eight-year cycle. Maintenance of a large Housing
Opportunity Site Inventory will act to ensure that the City maintains sufficient capacity
for the development of affordable housing throughout the upcoming cycle. ABAG /MTC has published a technical memo providing more narrative regarding this, foundhere.
Disadvantages of a Higher Buffer
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1)Eligibility for By-Right Permit Processing – Sites that the City identifies to support
lower income (low- and very-low income) RHNA units may be eligible for “by right1”processing when they were included in the prior planning period’s housing element(i.e., 5th cycle housing element) for non-vacant sites, or included in two or moreconsecutive years (i.e., 4th and 5th cycle housing element) for vacant sites.
By designating fewer sites as housing opportunity sites, the city would reduce the riskthat housing opportunity sites remain undeveloped and are thus carried over into afuture housing cycle, retaining more land use authority and discretionary oversight.However, it should be noted that even projects subject to a “by right” approval process,
will still need to comply with objective standards, such as those being prepared as part
of the Multi-Family Development and Design Standards work plan.
2)SB 330 Challenges – Under Senate Bill 330 “The Housing Crisis Act of 2019”,jurisdictions are prohibited from downzoning, or changing the land-use designation for
residential and mixed-use areas if the change would result in less-intensive use of the
property. As a result, it will be challenging for the city to reduce the density of aHousing Opportunity Site once designated, unless comparable increase in densitywere proposed elsewhere in the community in the same action. As a result, adisadvantage of having a larger housing site inventory is that the changes are largely
permanent (you can go up, but not back down) and as a result, limit the City’s options
to reconsider housing sites for a lower density or a designation to a non-residentialdesignation in the future.
Refinements Recommended by Staff
As an initial action, staff has recommended the removal of eight (8) sites from the Sites Inventory based on one or more of the criteria outlined in the preceding section of this report, and as described further below.
•Former Denny’s on Bascom Avenue
o Property Owner Disinterest: The City received a letter from the propertyowner expressing disinterest in being designated as a housing opportunity
site. While this factor alone is not a basis for removal, follow-up
conversations with the ownership revealed that the site is owned by acorporation which is structured around the long-term ownership ofcommercial property – making redevelopment unlikely in the eight-yearplanning period.
o Site Reference Number: 152
o Units Lost: 38
1 By right means the jurisdiction shall not require a discretionary, local-government review or approval that would constitute a “project” as defined by the California Environmental Quality Act.
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Figure 1: Former Denny’s (Colored Red)
• Campbell Industrial Park
o Property Owner Disinterest: The City received a letter from multiple
parties representing the ownership of the Campbell Industrial Park expressing disinterest in redeveloping the sites for housing. As sites 12.2, 212.1, and 212.1 recently have invested in façade improvements, and site 181 is nearly fully leased, it is unlikely that these sites will be redeveloped
during the eight-year planning period.
o Site Reference Numbers: 12.2, 181, 212.1, and 212.2 o Units Lost: 108
Figure 2: Campbell Industrial Park (Colored Red)
• Former US Bank o Property Owner Disinterest: While the City has not received a letter of
expressing disinterest to redevelop the site for housing, the City recently approved a Conditional Use Permit to allow the relocation of a Social Security Administration office to site. As tenant improvements are now nearing completion, and the Social Security Administration has a long-term lease for the property, the likelihood that the subject site will redevelop
during the eight-year planning period is very low.
o Site Reference Number: 271 o Units Lost: 17
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Figure 3: Social Security Administration Building (Colored Red; with Arrow)
•Jack in the Box
o Property Owner Disinterest: While the City did not receive a letterexpressing disinterest, staff acknowledges that Jack in the Box rarely sellsits holdings. This is evidenced by the Jack in the Box located on S. Bascom
Avenue, not being sold in the redevelopment of the Revere mixed-use
building which surrounds the site on two sides.
o Low Point Score: In addition to a presumed lack of owner interest, the sitescored low for retention due to the size of the site, recognizing it lacks a
common owner as is the case with adjoining properties (Sites 268, 269, &
270).
o Site Reference Number: 268oUnits Lost: 11
Figure 4: Jack in the Box (Colored Red; with Arrow)
•First Street Parking Garage
o Redevelopment Potential of City-owned Sites: As previously mentioned,a preliminary review of the Parking Assessment District and obligations
related to the First Street Parking Garage appear to make it unlikely toredevelop during the eight-year planning period.
o Potential Compatibility and Adjacency Issues: As the First StreetParking Garage is located across the street from a low-density residential
neighborhood, redevelopment of the site at the planned for density of 75-
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units per acre is anticipated to present compatibility and adjacency
concerns for surrounding residents.
o Site Reference Number:3oUnits Lost: 76
Figure 5: First Street Parking Garage (Colored Red)
Additional Site Inventory Refinements - Options
The following discussion outlines two additional options to be considered as refinements to the City’s Housing Opportunity Site Inventory, in addition to the option of only
incorporating the initial reductions recommended by staff. These options are discussed below and depicted in the attached exhibit (reference Attachment A – Housing Opportunity Map Options).
Figure 6: Options Overview
1.Option 1 – Staff Recommended Refinements (4,899 units):
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This option would only include removal of the eight (8) sites identified by staff as
described above. Removing these sites from the inventory would result in a total
of 120 sites containing 4,899 units. Under this option, the city would maintain a
Housing Inventory that is 26.5% above the HCD recommended RHNA (4,899 units
per Option 1 vs. 3,870 units to achieve RHNA + 30% buffer).
2.Option 2 – Remove Campbell Technology Park (4,446 units):
Option 2 focuses on the removal of the Campbell Technology Park which contains
a total of 453 units. Removing these four sites from the inventory would result in a
total of 116 sites containing 4,446 units. Under this option, the city would maintain
a Housing Inventory that is 14.8% above the HCD recommended RHNA (4,446
units per Option 2 vs. 3,870 units to achieve RHNA + 30% buffer).
Figure 7: Additional Sites Removed Under Option 2 (Brown Crosshatch)
The Campbell Technology Park has been flagged for removal by Option 2 in
consideration it received low point scores in categories of access to public transit,
grocery, and schools, despite being adjacent to a public park.
While the property owner has expressed interest in redeveloping the site, and
identified high vacancy rates within the office park, recent correspondence
expresses an interest to reduce the planned density of the site from the intended
26-33 units per acre, to 18-25 units per acre, to allow the development of detached
single-family homes and townhomes (reference Attachment D – Letter
Requesting Reduction in Density for Campbell Technology Park).
Separately, it is recognized that the city has a vested interest in the redevelopment
of the site as it remains subject to a Disposition and Development Agreement with
the city, related to past actions of the City’s Redevelopment Agency (RDA).
Recognizing market conditions may not support redevelopment of the site at a
density appropriate for the area, and in consideration of the development
agreement, the site may warrant removal.
However, staff has recommended that the city maintain the City’s Corporation Yard
as a Housing Opportunity Site and has identified the Campbell Technology Park
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as a potential option for relocation of the Corporation Yard to allow development
of housing at the Corp Yard. Thus, the city may want to keep the site (as a whole
or a portion) open for consideration as a Housing Opportunity Site, as a candidate
for a potential land swap with the City Corporation Yard.
3.Option 3 – Reduced Inventory (3,889 units):
Option 3 focuses on the removal of 43 sites throughout the city which contain a
total of 1,010 units. Removing these sites from the Inventory would result in a
Housing Inventory with a total of 77 sites, containing 3,889 units. Under this option,
the city would maintain a Housing Inventory that is .04% above the assigned RHNA
(3,889 units per Option 3 vs. 3,870 units to achieve RHNA + 30% buffer).
Figures 8 & 9: Sites Removed under Option 3 – East of Downtown & Legend
Figure 10: Additional Site Removed per Option 3 – East of Hamilton Station
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Figure 11: Additional Sites Removed per Option 3 – North of Winchester Station
Figure 12: Additional Site Removed per Option 3 – East of Pruneyard
These sites have been flagged for removal due to a combination of their low point
score value, small size, and unit count (properties East of Downtown were
originally screened out based on this methodology; but added back in response to
Council comments). These sites have also been flagged for removal in response
to a lack of interest by the property owners (no letters have been received
expressing interest in their development).
In addition to the sites identified above, Option 3 would also result in the removal
of Site 49 (320 Virginia Avenue). This site is distinct from the others included in
Option 3, given that the site is larger and has received a developer interest letter.
Nevertheless, Site 49 has been flagged for removal by Option 3 in consideration
the property is the only site in the City’s Housing Opportunity Site Inventory with
an open space land use designation, and that the city may want to consider
whether the site should be redeveloped as a public park – recognizing the city
needs to plan for new parks to meet residential need in association of new housing.
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Figure 13: Additional Site Removed per Option 3 – Near John D. Morgan Park
All these sites are also considered for removal, due to the fact they are anticipated
to result in very few, if any, low-income units.
Options Summary: The following table summarizes the options presented:
Option Summary Unit Count Site Count Buffer over HCD Recommendation
Option 1: Staff Recommended 4,899 120 26.5%
Option 2: Remove Tech. Park 4,446 116 14.8%
Option 3: Reduced Inventory 3,889 77 .004%
As indicated, Option 1 will provide for the greatest number of units, and buffer, beyond
the RHNA + 30% recommended by HCD (3,870 units), whereas Option 3 would result in
the lowest unit count and buffer.
Staff Recommendation: In consideration of the three options presented in this report2,staff recommends pursing Option 1, which would result in the retention of allsites and densities except the eight (8) properties identified for removal in red.Out of the options presented, staff believes this option is most likely to be acceptedby HCD, and as a result, help ensure that the Housing Element will be certified in time.
Option 1 is also recommended by staff since it will provide for additional development
capacity that may be required if sites do not develop at the density, or the level andaffordability required, recognizing that the SB 166 will require that adequatedevelopment opportunities remain available throughout the eight-year planningperiod. Finally, this option is recommended by staff to as it helps ensure sites are welldispersed throughout the city also supports strategies and objectives related to
Affirmatively Furthering Fair Housing (AFFH).
2)Goals, Policies, and Program Refinements
In addition to considering further refinements to the Housing Inventory, staff is also asking
the Commission and Council to provide feedback concerning proposed modifications to
2 Staff will provide a 4th Option, as a desk item, that will reduce the Site Inventory by adjusting planned densities (i.e., units per acre) in addition to removing the sites recommended for removal by staff.
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the Goals, Policies and Programs in the Housing Element, in response to the feedback
received from HCD. The intent of housing goals, policies, and programs is to provide strategic guidance on how to address specific housing issues and achieve identified objectives. For example, the adoption of an inclusionary housing ordinance and commercial linkage fees are actions that implement the goal of improving housing
affordability in Campbell.
HCD’s November 3, 2022, letter on the Draft Housing Element provided comments in several areas requesting that the City modify certain policies and programs to address housing issues and special interest areas. From all the comments included in the HCD
letter, staff has identified five major areas that warrant further discussion with the Planning
Commission and Council concerning proposed modifications to the Housing Element. These are areas where staff has identified that new policies and programs are needed or areas where staff recommends broader or more systematic modifications to the Housing Element. In addition to these five major areas, there are additional modifications required
to the Housing Element to respond to HCD comments. However, these entail either (a)
non-substantial modifications to the document to create better clarity or explanation regarding a housing topic or program or (b) the provision of additional data and information that will help explain a housing topic or program with recommended modifications to the Housing Element.
Staff is currently finalizing a table documenting all of the comments provided in the HCD letter and the recommended responses by the city (in both the major areas and non-substantive areas) that will be provided to the Planning Commission prior to the November 22, 2022, meeting.
The five major areas warranting Commission and Council discussion are (a) Homelessness (b) Preservation of At-Risk Units (c) Affirmatively Furthering Fair Housing (d) Housing related Ordinance updates, and (e) Stronger commitment to milestones and actions associated with Housing Programs, as discussed further below:
A. Homelessness
As required by State Law, the Housing Element is required to identify how the city will address the housing needs of all members of the community, including any individuals that are currently unhoused (homeless). The Draft Housing Element published on
October 26, 2022, has several identified policies and programs addressing
homelessness, including Policy H-5e, which identifies city support for the agencies that provide services to unhoused individuals and distribution of information connecting unhoused individuals to these service agencies.
The HCD Comment letter includes several sections that request that Campbell develop
and implement strategies addressing homelessness within the City. This includes individual comments on pages 3 and 4 of the letter identifying the need for the City to provide Extremely Low Income housing and permanent supportive housing for the homeless.
In addition, on October 25, 2022, the County published its Point in Time (PIT) counts for
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the Homeless population throughout Santa Clara County that identifies homeless counts
within each city in the County. As shown within the published report, Campbell’s unhoused population has increased by 191% since the last count in 2019, increasing from 74 to 216. Compared with all other cities in Santa Clara County, this represents the highest percentage increase between these reporting periods. The increase in
Campbell’s homeless population is highlighted in the HCD letter with a request for the
City to implement more policies and programs addressing homelessness. Staff recommends that the City enfold in the following programs and actions into the Housing Element addressing homelessness.
• Pursuit of a HomeKey project to create Permanent Supportive Housing – The State’s HomeKey program provides funding for permanent supportive housing projects including the conversion of motel or hotel rooms into housing units. There are many successful examples throughout California of cities that have used this
program to convert motels into housing for extremely low-income individuals who are either homeless or at risk of becoming homeless. One motel in Campbell, the Motel 6, was previously used during the Covid pandemic for a RoomKey project to provide emergency temporary housing. Staff recommends that the City commit to pursuing creation of a permanent supportive housing project in Campbell using HomeKey
funding. Under this approach, the City would identify eligible hotels and motels, contact their ownership for interest, and actively apply for HomeKey funding, utilizing support from the County Office of Supportive Housing and potentially the Housing Authority.
• Unhoused Specialist / Homeless Coordinator – The City could hire an unhoused specialist / homeless coordinator position who would be tasked with directly interfacing with homeless individuals in Campbell, to identify their needs and provide assistance in connecting them to housing and other related services. For comparative purposes,
the City of Morgan Hill funds an unhoused specialist that that has been successful in working with and supporting the needs of the homeless community. The City could create a full- or part-time staff position or hire a contractor to provide the services. In addition, as the homeless population is often not geographically bound within one city, Campbell can work with other cities in the West Valley area, including Los Gatos,
Saratoga, Monte Sereno, and Cupertino on potential shared funding and support of a coordinator that provides these support services between the jurisdictions.
• Support of the County of Santa Clara Rapid Rehousing Program – the County
currently operates a Rapid Rehousing Program that provides direct financial support and services that act to prevent individuals at risk of becoming homeless or entering homelessness. Campbell can commit to provide more direct financial support to this program to help support Campbell residents that are at risk of homelessness.
• Safe Parking Program – The City’s Camping Ordinance allows for safe parking programs at Religious Institutions in the City. This allows homeless individuals living in cars or recreational vehicles to park in a secure location and obtain access to onsite
services, such as washing / bathing facilities. The City could provide additional
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support into this program by providing financial assistance or other services needed
to manage the safe parking program.
• Cold Weather Shelter – A cold weather shelter would provide temporary emergency
housing to homeless individuals during the coldest days of the year. The City currently
operates a cooling center at the Community Center that provides refuge to individuals during the hottest days of the year. The City could support a Cold Weather Shelter by either (a) providing financial support to a religious institution (such as the payment for a security guard) to operate a cold weather shelter or it could identify a space within the Community Center that could be used as a cold weather shelter during very cold
days and inclement weather. B. Preservation of At-Risk Units The HCD Letter has also requests the City address approximately housing 73 units in the
City that will lose below market rate regulatory protections by 2026. As shown in table II-13 of the Housing Element, approximately 70 units within the Avalon Bay Housing complex and 3 units within the Gateway project are scheduled to lose existing below market rate regulatory protections in 2026.
Correspondingly, staff has identified the following actions to address this risk and preserve the units as below market rate units.
• Initiate discussions with property owners of these facilities in 2023, three
years prior to the expiration, to identify the upcoming expiration date and monitor adherence to tenant noticing requirements.
• Identify and apply for funding sources by 2024 to maintain below market
rate affordability of the housing units. Funding from these grant programs would be used to “buy down” the affordability of the at-risk units from a market rate price to below market rate for up to 20 additional years.
• Present preservation options and incentives to owners (rehabilitation assistance and / or mortgage refinance in exchange for long term restrictions) in 2024.
• Work with property owners and priority purchasers to implement long term restrictions or actions to maintain affordability in 2025
• Coordinate technical assistance and education with affected tenants in
2025 C. Affirmatively Furthering Fair Housing (AFFH)
Under Housing Law, the City must include in its Housing Element actions that address
fair housing Issues within the City and must take actions that “affirmatively further fair housing”. This could include actions ensuring that all residents in Campbell, irrespective
Planning Commission Meeting of November 22, 2022 Page 20 of 22 PLN-2021-12 | Campbell’s Plan for Housing – Inventory & Policy Refinements
of race and socio-economic status, have fair access to housing and services within the
City and actions by the City to address any legacy issues of racial discrimination or exclusionary practices that have led to segregation. The Draft Housing Element includes several policies and programs that address AFFH, specifically Programs H5a through H5y which include actions that address fair housing issues and address special needs
populations.
The HCD Letter requests that Campbell provide more policies and programs addressing fair housing, specifically identifying how Campbell will (a) provide more affordable housing opportunities within the City and in areas identified as high resource areas (more affluent
and less diverse areas) (b) provide equitable services to areas of the City that are
identified as moderate resource based (less affluent and more diverse) and (c) provide broader opportunities for under-represented communities to actively participate in the City’s housing policy and program development.
In response to (a) and (b) above, staff has not identified the need to create new AFFH
policies or programs within the Housing Element but is modifying the document to more clearly show how the City has proposed programs and actions that will address the identified fair housing areas. Specifically, the revisions will show that the City has programs to support creation of more affordable housing in the high resource areas of the
city to diversify the types of housing that is available and provide more socio-economic
diversity. This includes implementing an affordable housing overlay zone, updating its inclusionary housing ordinance and commercial linkage fees, facilitating more ADU production, pursuing an SB 10 ordinance, and utilizing City owned land (the City’s corporation yard) to create more affordable housing in these areas. In addition, the
revisions will document programs and resources the City implements in moderate
resource areas to provide greater services and support housing rehabilitation and prevent tenant displacement.
• Housing Commission - In response to (c), staff recommends the City pursue
creation of a Housing Commission to allow public engagement and involvement in the implementation of housing policies and programs. Other cities in the County, including Cupertino, Sunnyvale, Mountain View, and San Jose have Housing Commissions that advise the City Council on housing policies and programs. The
structure of the Commission can be designed to foster greater participation and
representation by underserved communities, including seats allocated to geographic areas or represented by renters in the city. D. Housing Ordinance Updates
Several comments in the HCD Letter request that Campbell update its ordinances to comply with applicable housing laws or remove barriers to housing production. This includes compliance with State Laws regarding group homes, ADU standards, emergency shelters, permanent supportive housing, and Single Room Occupancy units.
The letter also requests that Campbell identify firm commitments to approve ordinance
updates that will facilitate different types of housing unit production (missing middle) and revise parking standards.
Planning Commission Meeting of November 22, 2022 Page 21 of 22 PLN-2021-12 | Campbell’s Plan for Housing – Inventory & Policy Refinements
Staff recommends adding modifications to the Housing Element identifying that the City will update its ordinances in these areas by December 2023. Staff believes that a majority of the requested ordinance updates can be accomplished in
March 2023. Several of the requested ordinance updates are already included within the
workplan to create objective standards, such as revisions to parking standards and removal of barriers to allow different types of housing unit production (missing middle). Several of the requested ordinance updates to comply with State Law can be enfolded into this work effort.
E. Stronger Commitment to Milestones and Actions associated with Housing programs Comments within the HCD Letter request that the City identify clearer milestones and
commitments to implement identified Housing Programs and Policies. For example, the
HCD letter identified that several of the City’s programs uses actions such as “study” “evaluate” and “explore” to characterize implementation and requests the City identify clearer process steps, milestones, deliverables, and measurable outcomes.
Correspondingly, staff recommends that the Housing Element be modified to identify
more tangible process steps and milestones. For example, regarding Commercial Linkage Fees (Program H1-b) staff recommends that current language only identifying that a nexus study will be completed by December 2023 be updated to add that the City Council will consider adoption of municipal code ordinances implementing a commercial
linkage fee, following completion of a nexus study, in 2024.
GENERAL PLAN & EIR
During the 45-day public review and comment period on the Draft Environmental Impact Report (EIR) and Draft General Plan, the City received six (6) written comment letters that
address either the General Plan policy document, the Draft EIR, or some combination of
the two. All comments received which relate to the Draft EIR will be responded to in detail as part of the Final EIR. Additionally, staff will compile and organize all comments related to the General Plan policy document and/or Land Use Map, and will present these comments, along with staff recommendations, to the Planning Commission and City
Council at a future meeting to receive direction on whether changes should be made to
the Draft General Plan. Following City finalization of the Housing Element, the Draft General Plan will be reviewed for consistency with the Housing Element, and may be slightly revised, as needed, to
ensure consistency between the two documents. This may include revisions to the Land
Use Map to reflect the final Housing Element Opportunity Sites, minor clean-up of simple mapping errors identified by staff, as well as any minor text changes to ensure policy consistency between the two documents.
Overall, work on the General Plan will largely be “on-hold” until such time that the City
finalizes the Housing Element and receives direction from HCD that no additional
Planning Commission Meeting of November 22, 2022 Page 22 of 22 PLN-2021-12 | Campbell’s Plan for Housing – Inventory & Policy Refinements
changes or revisions are required in order to receive certification.
NEXT STEPS
The feedback provided by the Planning Commission on this item will be forwarded to the City Council, for consideration at their November 29, 2022 meeting, and for authorization
of the City’s second formal submittal to HCD for review and approval. Following
acceptance of the changes by HCD, the Housing Element will be adopted with the General Plan, and Multi-Family Development and Design Standards under development in March of 2023.
Prepared by: _________________________________ Stephen Rose, Senior Planner
Approved by: _________________________________ Rob Eastwood, AICP, Community Development Director
ATTACHMENTS:
A. Housing Opportunity Site Options
B. HCD Comment Letter
C. Housing Opportunity Methodology – Minimum Density Approach
D. Letter Requesting Reduction in Density for Campbell Technology Park
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.5 10.25 Mile
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
Light Rail Stations
City Boundary
17
85
Sa
n
T
o
m
a
s
E
x
p
y Winchester BlvdHamilton Ave
Campbell Ave Bascom AveWinchester BlvdBascom Ave
Hacienda Ave
171
132
12.2
94.2
202.1
248241
19
202.2
242 285.3
212.1
136
279
3
219220
135
91 89
250
21
239
146
31 214.1
35
276
221
243
92.2
90
100.392.1
256
246
159
152
212.2
283
245
145
278
155
181
56
116
62257
22
258259
139 25
100.2
260 63
4
214.4
238
277
170
285.2
28
94.193.29793.1
33
95
143.2141
100.1
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 1 of 5
NE Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
City Boundary
Light Rail Stations
188
49 119
165
39
31
274
282
268
121
51204
275
162
286
164
139
36
167
284
5
168
271
179
207
273
205
270
197
269
12.1
192
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 2 of 5
NW Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
City Boundary
Light Rail Stations
32
188
18
49 119
209
7
31
190.2
282
121
191
190.1
23
36
272
30
5
218.1
168
27
218.2
192
29
218.3
190.3
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 3 of 5
SW Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
City Boundary
Light Rail Stations
32
214.2
188
132
49 119
7
31
214.3214.1
190.2
282
121
191
190.1
36
30
214.4
5
168
192
190.3
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 4 of 5
SE Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
City Boundary
Light Rail Stations
132
244
94.2
119
240 248241
19
242
285.3
3
91
89
250
21
239
39
31
243
282
92.2254
255 90
92.1
256
246
245
285.1
62
257
22
258
259
139 25
36
260
261
63
262
214.4
238
179
263
285.2
28
94.1
93.2
97
266
93.1
33
95
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.09 0.180.05 Mile
Sheet 5 of 5
Downtown Focus
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
City Boundary
Light Rail Stations
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF HOUSING POLICY DEVELOPMENT 2020 W. El Camino Avenue, Suite 500 Sacramento, CA 95833 (916) 263-2911 / FAX (916) 263-7453 www.hcd.ca.gov
November 3, 2022 Rob Eastwood, Director
Community Development Department
City of Campbell 70 North First Street Campbell, CA 95008
Dear Rob Eastwood: RE: City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Thank you for submitting the City of Campbell’s (City) draft housing element update
received for review on August 5, 2022 along with draft revisions on October 26, 2022. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by conversations on September 20 and 27, 2022 with you; Stephen Rose, Senior Planner; and your consultants, Geoff Bradley and Sung
Kwon. In addition, HCD considered comments from several stakeholders and members of the community, pursuant to Government Code section 65585, subdivision (c). The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code).
The enclosed Appendix describes the revisions needed to comply with State Housing Element Law. For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the
statutory deadline (January 31, 2023), then any rezoning to make prior identified sites available or accommodate the regional housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance
pursuant to Government Code section 65585, subdivision (i). Please be aware, if the City fails to adopt a compliant housing element within one year from the statutory deadline, the element cannot be found in substantial compliance until rezones pursuant to Government Code section 65583, subdivision (c) (1) (A) and Government Code section 65583.2, subdivision (c) are completed.
Rob Eastwood, Community Development Director Page 2
Public participation in the development, adoption and implementation of the housing
element is essential to effective housing planning. Throughout the housing element
process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available while considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website
and to email a link to all individuals and organizations that have previously requested
notices relating to the local government’s housing element at least seven days before submitting to HCD. Several federal, state, and regional funding programs consider housing element
compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill
(SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing
element, the City will meet housing element requirements for these and other funding
sources. For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes
the opportunity to provide assistance. For information, please see the Technical
Advisories issued by the Governor’s Office of Planning and Research at: https://www.opr.ca.gov/planning/general-plan/guidelines.html. HCD appreciates the hard work and dedication you; Stephen Rose, Senior Planner; and your consultants, Geoff Bradley and Sung Kwon provided in preparation of the City’s
housing element and looks forward to receiving the City’s adopted housing element. If you have any questions or need additional technical assistance, please contact Shawn Danino, of our staff, at shawn.danino@hcd.ca.gov.
Sincerely,
Paul McDougall Senior Program Manager Enclosure
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 1
November 3, 2022
APPENDIX CITY OF CAMPBELL
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the
supporting section of the Government Code.
Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements
(Building Blocks), available at https://www.hcd.ca.gov/building-blocks and includes the
Government Code addressing State Housing Element Law and other resources.
A.Review and Revision
Review the previous element to evaluate the appropriateness, effectiveness, and progress
in implementation, and reflect the results of this review in the revised element. (Gov. Code,
§65588 (a) and (b).)
Special Housing Needs: As part of the review of programs in the past cycle, the element
must provide an evaluation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers, and persons experiencing homelessness). While the element includes some general reporting such as the City’s website including links to homeless services (p. III.A-6), it should still evaluate
whether programs were effective, individually and cumulatively, and add or modify programs appropriately.
B.Housing Needs, Resources, and Constraints
1.Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with
Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing inthe jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
Enforcement and Outreach: While the element describes some outreach and capacityto enforce fair housing laws, it should also address compliance with existing fair housinglaws as well as any past or current fair housing lawsuits, findings, settlements,judgements, or complaints.
Racially Concentrated Areas of Affluence (RCAA): The element identifies that “much ofthe city is identified as within a Racially Concentrated Area of Affluence,” (p. H-II-63) butshould also include specific analysis to better formulate appropriate programmaticresponse. This analysis should utilize local data and knowledge and other relevant
factors. For example, the element could examine past land use practices, investments,quality of life relative to the rest of the City and region and then formulate appropriateprograms to promote more inclusive communities and equitable quality of life. For
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 2
November 3, 2022
example, the City should consider additional actions (not limited to the Regional
Housing Needs Allocation (RHNA)) to promote housing mobility and improve new housing opportunities throughout the City. Disparities in Access to Opportunity: The element provides information on the access to opportunity through the TCAC opportunity map but must also provide a complete local
and regional analysis of patterns and trends for all components. A comprehensive analysis should include the local and regional disparities of the educational, environmental, and economic scores through local, federal, and/or state data. It should also analyze persons with disabilities as well as access to transit. Please refer to page
35 of the Affirmatively Furthering Fair Housing (AFFH) guidebook
(https://www.hcd.ca.gov/community-development/affh/index.shtml#guidance) for specific factors that should be considered when analyzing access to opportunities as it pertains to educational, employment, environmental, transportation, and any other relevant factors.
Disproportionate Housing Needs, including Displacement risk: The element provides some discussion on cost burdened households and overcrowding. However, the element must evaluate trends and patterns within the City, with regards to overpayment, substandard housing and persons experiencing homelessness. This analysis should
utilize local data and knowledge and other relevant factors (Please see pages 24 and
25 of HCD’s Guidance at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing). For example, the element could utilize information from the City’s code enforcement to evaluate patterns of housing conditions or could contact service providers regarding patterns (areas of higher need) of persons experiencing homelessness and availability of services. Based on the
outcomes of this analysis, the element should add or modify programs as appropriate. Identified Sites and AFFH: While the element provides some analysis of the identified sites and socio-economic concentrations, the element must analyze the identified sites
with regards to the City’s RCAAs. In addition, the element should analyze the lack of
units in higher opportunity or income areas, including census tracts in the Northwest and Southeast portion of the City, including two of the City’s census tracts labeled highest opportunity areas by the Tax Credit and Allocation Committee (Figure IV-5), which appear to have no identified sites or opportunity sites. A complete analysis should
fully assess how the site inventory is expected to improve and/or exacerbate fair housing conditions, including any isolation of the RHNA. This analysis should address the location, number of units by income group, magnitude of the impact, and could consider topics such housing choice (not limited to the RHNA) in other areas of the City, existing or proposed anti-displacement policies, place-based investments, and how
such strategies will improve fair housing conditions when paired with the identified sites. Based on the outcomes of this analysis, the element should add or modify programs as appropriate. Contributing Factors to Fair Housing Issues: Based on the outcomes of a complete
analysis, the element should re-evaluation and prioritize contributing factors to fair
housing issues.
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 3
November 3, 2022
Goals, Priorities, Metrics, Actions & Milestones: While the element includes general
metrics for some programs, the element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to
overcome identified patterns and trends. Actions must have specific commitment,
milestones, geographic targeting and metrics or numerical targets and, as appropriate, address housing mobility enhancement, new housing choices and affordability in higher opportunity or income areas (throughout the City), place-based strategies for community preservation and revitalization and displacement protection.
The element may, for example, commit to a firm date by which it will establish development standards for smaller housing types, including bungalow courts. The element may also, for example, as discussed on the September 27, 2022 call, revise Program H-1m to make a specific commitment for establishing development standards
for small units including missing middle housing types that are feasible in higher
opportunity or income areas. To improve housing opportunities for persons experiencing homelessness or lower-income households employed in the City, the City may, for example, commit to identifying supportive housing projects in the City as part of Project Homekey and provide a date by which sites will be identified and by which the City will
apply for funding. The City may also, for example, revise Program HE-6.D to make
specific commitments to improve pedestrian safety and active mobility as a way to increase disparities in access to opportunity. Additionally, the element should commit to assessing and revising programs through a mid-cycle review. Please see HCD’s AFFH memo for more information: https://www.hcd.ca.gov/community-
development/affh/docs/affh_document_final_4-27-2021.pdf#page=23.
2. Include an analysis of population and employment trends and documentation of
projections and a quantification of the locality's existing and projected needs for all
income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)
Include an analysis and documentation of household characteristics, including level of
payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)
Analyze any special housing needs such as elderly; persons with disabilities, including a
developmental disability; large families; farmworkers; families with female heads of
households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Extremely Low-Income (ELI): While the element briefly quantifies ELI households but should specifically analyze their housing needs, including tenure, overpayment, available resources and strategies, effectiveness of past program and the magnitude or disproportionate impacts on housing needs. Then, the element should add or modify
programs as appropriate.
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 4
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Housing Cost: While the element includes estimated rents for residents, it utilizes
American Community Survey (ACS) data. The element should supplement census data with other sources (e.g., local knowledge). Overpayment: The element must quantify and analyze the number of lower-income
households overpaying by tenure (i.e., renter and owner).
Persons Experiencing Homelessness: The element provides some analysis of persons experiencing homelessness and describes some facility capacity in the County ( Table II-25). However, given the magnitude of the need and the significant increase in the Point in Time Count between 2019 and 2022, the City should evaluate resources and
strategies, gaps in addressing needs and formulate appropriate strategies to address the unmet need. For example, the element could identify and evaluate capacity for permanent supportive housing, or other housing types, for example Single Room Occupancies (SROs), within the City, to evaluate needs and address unmet needs through program actions.
3. An inventory of land suitable and available for residential development, including vacant
sites and sites having realistic and demonstrated potential for redevelopment during the
planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites.
(Gov. Code, § 65583, subd. (a)(3).) Small Sites: The site inventory currently includes 64 sites that are less than 0.5 acres, including several sites with existing housing (p. H-IV-30 and Table A). Sites smaller than
a half-acre in size are deemed inadequate to accommodate housing for lower-income
housing unless it is demonstrated that sites of equivalent size and affordability were successfully developed during the prior planning period or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower-income housing (Gov. Code, § 65583.2, subd. (c)(2)(A).). The element identifies several
site groupings with potential for consolidation. However, the element must also evaluate
whether those sites are suitable to accommodate housing for lower-income households and add or modify programs as appropriate. For example, the element could list past consolidations by the number of parcels, number of owners, zone, number of units, affordability and circumstances leading to consolidation and then relate those trends to
the identified sites or could explain the potential for consolidation on a site-by-site basis. Based on the outcomes of the analysis, the element should modify policies and programs, including a specific commitment to ensure that maximum densities can be accommodated on all sites in the inventory.
Large Sites: The inventory includes several sites over ten acres, including one 16.4-acre site with an operating commercial shopping center. While the element clarifies there is interest from the property owner, it should analyze the suitability of these sites to accommodate housing for lower-income households or rescale assumptions. The City described its strategy for “carving out” portions of some larger parcels,
where some portions of parcels can be developed while maintaining other existing residential and commercial uses. However, the City should clarify the timeline and procedure by which these carveouts will occur. For example, the element should
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 5
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discuss any recent developments of similar size and affordability, opportunities for
parceling, phasing or site planning and generally address how housing affordable to lower-income households will occur given typical state funded developments are approximately 50 to 150 units then rescale assumptions if necessary and add or modify programs as appropriate.
City-Owned Sites: The element identified two City-Owned sites to accommodate 231 housing units; however, must analyze the suitability and availability of those sites for development in the planning period, including how the sites will be available (e.g., surplus or lease), any known barriers, an anticipated schedule and other relevant factors. In addition, the element should include a program with numerical objectives that
ensure compliance with the Surplus Land Act, provides incentives and actions along with a schedule to facilitate development of City-owned sites. Actions should include outreach with developers, issuing requests for proposals, incentives, fee waivers, priority processing, financial assistance and alternative actions if the sites do not become available at a reasonable point in the planning period (e.g., 2028).
Suitability of Nonvacant Sites: The element must include analysis demonstrating the potential for additional development on nonvacant sites and describes existing property owner interest (p. H-IV-21). While the element mentions underutilized sites were identified based on interest in development, structure/site conditions and development
on adjacent sites with similar characteristics, it must support the validity of these factors in demonstrating the potential for redevelopment. For example, the element currently lists prior uses in recent development activity but could also discuss how the recent trends support the various factors. In addition, the element could consider additional factors such existing versus allowable floor area and reflect those values in the sites
inventory. Finally, the element should account for the extent existing uses impede additional residential development including market demand for the existing use and existing leases or contracts that would perpetuate the existing use or prevent additional residential development.
The housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households. As a result, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).)
For your information, absent findings in the resolution as part of adoption based on
substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.
Electronic Sites Inventory: For your information, pursuant to Government Code section 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/planning-and-community-development/housing-elements for a copy of the form and instructions. The
City can reach out to HCD at sitesinventory@hcd.ca.gov for technical assistance.
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 6
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Zoning for a Variety of Housing Types:
• Single Room Occupancy (SRO) Units: The City categorizes SROs under the definition of rooming and boarding houses, “that are rented to between 3 to 5
persons for profit…”(p. H-II-109). The City should analyze this definition as a possible constraint. In addition, the City allows SROs in only certain zones and requires a Conditional Use Permit (CUP) in all zones allowed. The element should demonstrate zoning, development standards, including parking, and
permit procedures encourage and facilitate SROs or add or modify programs as
appropriate.
• By-right Permanent Supportive Housing: While the element states that supportive
housing is permitted in all residential zoning districts by right (p. H-II-109),
supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651. The element must demonstrate compliance with these requirements and include programs as appropriate.
• Emergency Shelters: The element was revised to state that emergency shelters are allowed by-right in a “portion of the M-1 zone” and states that the area is “well served by transit and commercial services” (p. H-III-107). However, the element must also identify and analyze any development standards (e.g., spacing,
parking, concentration requirements) and other requirements imposed on emergency shelters. Lastly, the element must describe compliance with Government Code section 65583, subdivision a)(4)(A) or include a program to comply with this requirement. For your information, pursuant to Government Code section 65583, subdivision a)(4)(A), parking requirements should be limited
to allowing sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone.
• Accessory Dwelling Units (ADU): HCD records indicate permitted ADUs of 5 in 2018, 8 in 2019, 54 in 2020, and 38 in 2021, figures that are inconsistent with those in the element. The element should reconcile these numbers either in the element or Annual Progress Reports (APRs) and adjust assumptions as
appropriate.
After a cursory review of the City’s ordinance, adopted August 16, 2022, HCD discovered some areas which are inconsistent with State ADU Law. HCD will provide a complete listing of ADU non-compliance issues under a separate
cover. As a result, the element should add a program to update the City’s ADU
ordinance to comply with state law.
4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of
housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as
identified in the analysis pursuant to paragraph (7), including land use controls, building
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 7
November 3, 2022
codes and their enforcement, site improvements, fees and other exactions required of
developers, and local processing and permit procedures... (Gov. Code, § 65583, subd.
(a)(5).) Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should
analyze land use controls independently and cumulatively with other land use controls. The analysis should specifically address requirements related to parking for small units including SROs and missing middle housing types; height limits particularly in multifamily zones; maximum lot coverages; minimum lot areas; minimum site sizes;
public and private open space requirements; lot coverage and limits on allowable
densities. The analysis should address any impacts on cost, supply, feasibility, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints. Finally, pursuant to public comments, the City must make a firm commitment to reduce its parking requirements across residential zones.
Processing and Permit Procedures: The element identifies that most developments are subject to a Site and Architectural Review and lists various finding, most notably “The project will aid in the harmonious development of the immediate area”. The element then mentions this is similar to other jurisdictions but should evaluate the impacts of the
finding on housing supply (number of units), cost, timing, feasibility and particularly
approval certainty and then add programs to address identified constraints. Persons with Disabilities: The element describes the City’s reasonable accommodation process and lists its factors for consideration (pp. H-II-141), including the potential
impact on surrounding uses. The element then notes this factor can be addressed by
evaluating alternatives to addressing the needs of persons with disabilities. First, a factor such as impact on surrounding uses is essentially a conditional use finding and a reasonable accommodation procedure should be a unique exception process, instead using factors such as whether the accommodation poses a fundamental alternation of
zoning and land use – a far different standard that should be employed in a manner to
promote access to housing opportunities for persons with disabilities. Second, the surrounding use factor appears to be employed in a manner that seeks to alter requests and fit with the surrounding areas as opposed to considering the exception request. For these reasons alone, the element should identify this finding as a constraint and modify
Program H-5g (Reasonable Accommodation) to remove the constraint early in the planning period (within two years). In addition, the element indicates group homes for seven or more persons are allowed in all residential zones but subjects group homes to a conditional use permit (CUP),
unlike other similar uses. The element should specifically analyze these constraints for impacts on housing supply and choices and approval certainty and objectivity for housing for persons with disabilities and include programs as appropriate.
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C. Housing Programs 1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are
ongoing, such that there will be beneficial impacts of the programs within the planning
period, that the local government is undertaking or intends to undertake to implement
the policies and achieve the goals and objectives of the Housing Element... (Gov. Code,
§ 65583, subd. (c).) Programs must demonstrate that they will have a beneficial impact within the planning
period. Beneficial impact means specific commitment to deliverables, measurable
metrics or objectives, definitive deadlines, dates, or benchmarks for implementation. Deliverables should occur early in the planning period to ensure actual housing outcomes. Several programs and actions have timelines that could be moved earlier in the planning period to ensure a beneficial impact. Examples include Programs H-1E
(Preapproved ADU Plans), H-1m (Microunit Standards), H-2c (Short term Rental
Ordinance), H-3e (Reuse Site Ministerial Review), and H-5t (Employee Housing).
Additionally, programs must have specific commitment to clear housing outcomes or deliverables. Several programs include actions with no description of how those actions will be implemented (e.g., “support”, “study”, “explore”, “evaluate”, etc.,). Programs should be amended, to include specific commitment to a housing related outcome.
Examples include Programs H-1b (Commercial Linkage Fee), H-1c (Affordable Housing
Overlay Zone), H-1k (Achieve Target Densities), H-1m (Micro-unit Standards), H-2d (Workforce Housing Ordinance), H-2e (Housing Rehabilitation Loans), H-2g (Preservation of Assisted Housing), H-3a (Parking Requirement Reduction) H-5d (Shared Housing Program), H-5o (ELI Unit Development), and H-5s (City Density
Bonus).
2. Identify actions that will be taken to make sites available during the planning period with
appropriate zoning and development standards and with services and facilities to
accommodate that portion of the city’s or county’s share of the regional housing need
for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and
to comply with the requirements of Government Code section 65584.09. Sites shall be
identified as needed to facilitate and encourage the development of a variety of types of
housing for all income levels, including multifamily rental housing, factory-built housing,
mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583,
subd. (c)(1).) As noted in Finding B3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs
to address a shortfall of sites or zoning available to encourage a variety of housing types.
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In addition, programs targeting development of publicly owned land (e.g., Program H-
5q) should include a schedule of actions for development in the planning period consistent with the assumptions in the sites inventory, including coordination with developers, requests for proposal, facilitating entitlements, incentives, issuing building permits and compliance with the Surplus Land Act.
3. Address and, where appropriate and legally possible, remove governmental and
nongovernmental constraints to the maintenance, improvement, and development of
housing, including housing for all income levels and housing for persons with
disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with
supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
As noted in Finding B4, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or
mitigate any identified constraints. 4. Promote and affirmatively further fair housing opportunities and promote housing
throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other
characteristics... (Gov. Code, § 65583, subd. (c)(5).) As noted in Finding B1, the element must include a complete assessment of fair housing. Based on the outcomes of that analysis, the element must add or modify programs.
5. The housing program shall preserve for low-income household the assisted housing
developments identified pursuant to paragraph (9) of subdivision (a)... (Gov. Code, §
65583, subd. (c)(6).)
Program H-2g states an objective to “participate in the preservation of at-risk units by providing financial and/or technical assistance” (p. H-IV-55). However, the program should make a specific and firm commitment to maintain the long-term affordability of these units, including a clear commitment of financial assistance or support of funding
applications, coordination with qualified entities and support, education and assistance for tenants. D. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed,
rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1
& 2).)
While the element includes quantified objectives for new construction, it should also consider quantified objectives for rehabilitation and preservation of existing affordable
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 10
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housing. For your information, the quantified objectives do not represent a ceiling, but
rather set a target goal for the City, based on needs, resources, and constraints. E. Public Participation
Local governments shall make a diligent effort to achieve public participation oof all
segments of the community in the development of the Housing Element and the element
shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).) While the City made efforts to include the public through workshops and surveys, moving
forward, the City should employ additional methods for public outreach efforts in the future, particularly to include lower-income and special needs households and neighborhoods with higher concentrations of lower-income households. In addition, several comments questioned the lack of commitments around reducing parking minimums and ensuring the feasibility of missing middle housing types. The City should consider these comments and
make adjustments as appropriate. The City should also analyze the feasibility of sites identified by members of the public, including the site of a former Elephant Bar and Fry’s Electronics and make adjustments as appropriate. The City could also, for example, target higher densities around the Hamilton 880 corridor. To AFFH, the element could revise Program H-3f and commit to development of a rent stabilization ordinance that limits annual
rent increases or develop a city-wide portal for affordable rentals available. Finally, to address noted jobs-housing relationships, the City could also, for example, conduct targeted stakeholder interviews or establish a committee representative of lower-income households and commuters who work inside the City in future public outreach efforts. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-
development/building-blocks/getting-started/public-participation.shtml.
Attachment C
Housing Opportunity Methodology Minimum Density Approach
While the Housing Opportunity Site Inventory allows for the development of up to 6,640
units, such an outcome would only be possible if every site built at the maximum density allowed. As it is not reasonable to assume that every site will develop at the maximum allowable density, or at the level and mix of affordability required per site (i.e., which assumes a mix of very-low, low-, moderate income units), Campbell’s Plan for Housing
uses a “Minimum Density” approach to demonstrate that the inventory will meet the
Regional Housing Needs Allocation (RHNA). Under the Minimum Density Approach, out of the 6,640 units possible, the city would receive “credit” for approximately 5,604 units. Of these units, approximately 30% are
assumed to be affordable (1,685). While the city could argue that all 6,640 units would be
built at the planned for density and level of affordability required, HCD would require a preponderance of evidence to support such claims based on past success. Given the high rate of failure of southern California cities which pursued alternative unit count methodologies, and in consideration that the city was unsuccessful in its previous cycle
to achieve its RHNA, the Initial Review Draft relied on the Minimum Density Approach, as
explained in greater detail as follows: Minimum Density Approach: The Minimum Density approach assumes that every Housing Opportunity Site will achieve the minimum density allowed. While this approach
may seem straightforward, the minimum density of a Housing Opportunity Site varies
based on the density range of the land use designation and the application of Policy H-1.4 from the Draft Housing Element, which requires all Housing Opportunity Sites to achieve at least 75% of the maximum density allowed by the General Plan Land Use designation:
Policy H-1.4: Planned for Densities. All housing opportunity sites shall achieve 75 percent of the maximum General Plan Land Use density. As a result, the minimum density range of some sites is based on the land use designation
itself, while for others, the application of Policy H-1.4 sets the floor, as explained by the following examples:
• Example 1: The Transit-Oriented Mixed Use land use designation allows for 57 to 75 units per gross acre. Applying Policy H-1.4, 75% of the
maximum density of 75 units per acre is equal to 56.25 units per acre. As the minimum density range of the land use designation is 57 units per acre, which is greater than 56.25 units per acre, the minimum density of the land use itself (i.e., 57 units per acre) is used when calculating the minimum allowable density.
• Example 2: The Medium Density Residential land use designation allows
for 18 to 25 units per gross acre. Applying Policy H-1.4, 75% of the
Attachment C
maximum density of 25 units per acre is equal to 18.75 per acre. As 18.75 units per acre is greater than the minimum density range of the land use designation (i.e., 18), the standard set by Policy H-1.4 is used when
calculating the minimum allowable density.
Relying on this policy in the Initial Draft Housing Element submitted to HCD, the Site Inventory results in the production of 5,139 units (out of the 6,640 units possible) from the 131 sites identified. In addition to receiving credit for units included in the Site Inventory,
Pipeline Units (185 units) and ADUs (280 units) also are credited by the methodology
resulting in a total yield of 5,604 units.
Income Level
Very Low Low Moderate Above Moderate Total
0-50% AMI 51-80% AMI 80-120% AMI >120% AMI
Pipeline 29 4 2 150 185
ADUs 84 84 84 28 280
Site Inventory 1,044 883 624 2,588 5,139
Total Units 1,157 971 710 2,736 5,604
Table 1: Total Unit Count in Initial HCD Draft using Minimum Density Approach
While the methodology results in 1,734 more units, or 44% more, than the 3,870 units recommended by HCD (RHNA + 30% buffer), the amount of buffer in any given income
category varies between 9% and 72% as follows:
Income Level
Very Low Low Moderate Above Moderate Total
0-50% AMI 51-80% AMI 80-120% AMI >120% AMI RHNA + 30% buffer 978 564 649 1679 3,870
Total Units 1,157 971 710 2,736 5,604 Unit Surplus 179 (18%) 407 (72%) 61 (9%) 1057 (62%) 1,734 (44%)
Table 2: Total Unit Surplus by Income Level
When considering potential refinements to the Site Inventory, the target of 3,870 units, distributed by the income categories identified in Table 2 above, will be the basis of the discussion.
To: Chair Ching and Planning Commission Members Date: Nov. 22, 2022
From: Stephen Rose, Senior Planner
Via: Rob Eastwood, Community Development Director
Subject: Old Business, Item #1 – Housing Opportunity Map & Goals, Policies and Programs Refinement (PLN-2022-12)
The November 22, 2022, Planning Commission staff report indicated that a table summarizing HCD feedback and recommended responses by the city (in both the major areas and non-substantive areas) would be provided as a desk item.
This desk item serves to provide the HCD Comment Summary Table referenced in the
report.
Encl: Exhibit A-1 – HCD Comment Summary Table
City of Campbell
MEMORANDUM
Exhibit A-1
HCD Comment City Response
A. Review and Revision
Special Housing Needs: As part of the review of programs in the past cycle, the
element must provide an evaluation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers, and persons experiencing homelessness). While the element includes some general reporting such as the City’s website including links to
homeless services (p. III.A-6), it should still evaluate whether programs were effective, individually and cumulatively, and add or modify programs appropriately.
Staff and the Consulting Team (M-Group) will conduct a review of
effectiveness of past policies and actions related to special needs
populations.
B. Housing Needs, Resources, and Constraints
Enforcement and Outreach: While the element describes some
outreach and capacity to enforce fair housing laws, it should also
address compliance with existing fair housing laws as well as any past or current fair housing lawsuits, findings, settlements, judgements, or complaints.
The City has no fair housing lawsuits, settlements, judgements or existing
complaints. The Housing Element (hereinafter “Element”) will be updated
to clarify this point.
Racially Concentrated Areas of Affluence (RCAA): The element identifies that “much of the city is identified as within a Racially Concentrated Area of Affluence,” (p. H-II-63) but should also include specific analysis to better formulate appropriate programmatic response. This analysis should utilize local
data and knowledge and other relevant factors. For example, the element could examine past land use practices, investments, quality of life relative to the rest of the City and region and then formulate appropriate programs to promote more inclusive communities and equitable quality of life. For example, the City should consider additional actions (not limited to the Regional Housing Needs Allocation
(RHNA)) to promote housing mobility and improve new housing opportunities throughout the City.
A large percentage of Campbell is mapped as an RCAA.
The Element will be updated to clarify that Campbell has strategies to
increase the production of affordable housing within Campbell and the
RCAA that will diversify housing types and make Campbell more
accessible for individuals of different backgrounds and socio-economic
status.
The Element will also be revised to provide more analysis of past land use
practices (single family zoning, lower density), including the legacy of
racially restrictive covenants.
Exhibit A-1
Disparities in Access to Opportunity: The element provides information on the
access to opportunity through the TCAC opportunity map but must also provide a complete local and regional analysis of patterns and trends for all components. A comprehensive analysis should include the local and regional disparities of the educational, environmental, and economic scores through local, federal, and/or
state data. It should also analyze persons with disabilities as well as access to
transit. Please refer to page 35 of the Affirmatively Furthering Fair Housing (AFFH) guidebook (https://www.hcd.ca.gov/community-development/affh/index.shtml#guidance) for specific factors that should be considered when analyzing access to opportunities as it pertains to educational,
employment, environmental, transportation, and any other relevant factors.
The Element will be revised to augment analysis of TCAC compared to
region, breaking out and evaluating Educational, Environmental, Economic
Scores separately and analyze results.
Revise the Element to provide greater locational analysis of residences of
persons with disabilities and access to transit.
(reference AFFH Guidebook)
Disproportionate Housing Needs, including Displacement risk: The element provides some discussion on cost burdened households and overcrowding.
However, the element must evaluate trends and patterns within the City, with regards to overpayment, substandard housing and persons experiencing homelessness. This analysis should utilize local data and knowledge and other relevant factors (Please see pages 24 and 25 of HCD’s Guidance at https://www.hcd.ca.gov/planning-and-community- development/affirmatively-
furthering-fair-housing). For example, the element could utilize information from the City’s code enforcement to evaluate patterns of housing conditions or could contact service providers regarding patterns (areas of higher need) of persons experiencing homelessness and availability of services. Based on the outcomes of this analysis, the element should add or modify programs as appropriate.
The Element will be revised to show additional information on trends
regarding homelessness, rent overpayment, and include mapping of code
enforcement issues.
The Element will also be revised to document feedback received from service providers - regarding needs of ELI / homeless populations.
Exhibit A-1
Identified Sites and AFFH: While the element provides some analysis of the
identified sites and socio-economic concentrations, the element must analyze the identified sites with regards to the City’s RCAAs. In addition, the element should analyze the lack of units in higher opportunity or income areas, including census tracts in the Northwest and Southeast portion of the City, including two of the
City’s census tracts labeled highest opportunity areas by the Tax Credit and
Allocation Committee (Figure IV-5), which appear to have no identified sites or opportunity sites. A complete analysis should fully assess how the site inventory is expected to improve and/or exacerbate fair housing conditions, including any isolation of the RHNA. This analysis should address the location, number of units
by income group, magnitude of the impact, and could consider topics such
housing choice (not limited to the RHNA) in other areas of the City, existing or proposed anti-displacement policies, place-based investments, and how such strategies will improve fair housing conditions when paired with the identified sites. Based on the outcomes of this analysis, the element should add or modify
programs as appropriate.
Revise the Element to document how the housing opportunity sites are
dispersed throughout the City in the different TCAC areas, and limited opportunity for housing opportunity sites in certain parts of the City.
Document other strategies to increase affordable housing in all parts of the
city, including ADU, SB9 and SB10 programs.
Clarify and document the City’s approach to facilitating affordable housing development in different areas in the City and expected production of
affordable units in different BMR categories.
Document the City’s anit-displacement policies, including contracts with
Project Sentinel.
Contributing Factors to Fair Housing Issues: Based on the outcomes of a complete analysis, the element should re-evaluation and prioritize contributing
factors to fair housing issues.
Revise Element to show root cause analysis of fair housing issues and
document how proposed goals, policies, and actions will address root
cause issues.
Goals, Priorities, Metrics, Actions & Milestones: While the element includes
general metrics for some programs, the element must be revised to add or
modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must
have specific commitment, milestones, geographic targeting and metrics or
numerical targets and, as appropriate, address housing mobility enhancement, new housing choices and affordability in higher opportunity or income areas (throughout the City), place-based strategies for community preservation and revitalization and displacement protection.
Exhibit A-1
The element may, for example, commit to a firm date by which it will establish development standards for smaller housing types, including bungalow courts. The element may also, for example, as discussed on the September 27, 2022
call, revise Program H-1m to make a specific commitment for establishing
development standards for small units including missing middle housing types that are feasible in higher opportunity or income areas. To improve housing opportunities for persons experiencing homelessness or lower-income households employed in the City, the City may, for example, commit to
identifying supportive housing projects in the City as part of Project Homekey
and provide a date by which sites will be identified and by which the City will apply for funding. The City may also, for example, revise Program HE-6.D to make specific commitments to improve pedestrian safety and active mobility as a way to increase disparities in access to opportunity. Additionally, the element
should commit to assessing and revising programs through a mid-cycle review.
Please see HCD’s AFFH memo for more information: https://www.hcd.ca.gov/community- development/affh/docs/affh_document_final_4-27-2021.pdf#page=23.
Revise the Element to clarify the City is updating its Objective Standards
that will provide for different housing types, including bungalow courts,
scheduled to be adopted in March 2023.
Update Homelessness strategy with identification of creation of a
Homekey funded Permanent Supportive Housing project.
Document investments the City has made to improve pedestrian safety –
including proposed Hamilton Avenue Precise Plan effort that is intended to
improve pedestrian access to the Hamilton Avenue Light Rail.
Commit to a mid-cycle review.
2. Include an analysis of population and employment trends and documentation
of projections and a quantification of the locality's existing and projected needs
for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)
Revise Element to provide more analysis of ELI households.
Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including
overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)
See below
Analyze any special housing needs such as elderly; persons with disabilities,
including a developmental disability; large families; farmworkers; families with
female heads of households; and families and persons in need of emergency
shelter. (Gov. Code
See below
Extremely Low-Income (ELI): While the element briefly quantifies ELI households but should specifically analyze their housing needs, including tenure, overpayment, available resources and strategies, effectiveness of past program
Revise Element to show more analysis of ELI households – overpayment,
resources available, housing needs, past program actions – new programs including development of permanent supportive housing for ELI
households.
Exhibit A-1
and the magnitude or disproportionate impacts on housing needs. Then, the
element should add or modify programs as appropriate.
Housing Cost: While the element includes estimated rents for residents, it utilizes American Community Survey (ACS) data. The element should supplement census data with other sources (e.g., local knowledge).
Evaluate what other data is available that can be provided in the Housing
Element.
Overpayment: The element must quantify and analyze the number of lower-income households overpaying by tenure (i.e., renter and owner).
Revise Element to provide requested data
Persons Experiencing Homelessness: The element provides some analysis of persons experiencing homelessness and describes some facility capacity in the
County ( Table II-25). However, given the magnitude of the need and the significant increase in the Point in Time Count between 2019 and 2022, the City should evaluate resources and strategies, gaps in addressing needs and formulate appropriate strategies to address the unmet need. For example, the element could identify and evaluate capacity for permanent supportive housing,
or other housing types, for example Single Room Occupancies (SROs), within the City, to evaluate needs and address unmet needs through program actions.
Develop and enfold in homelessness strategy including development of Permanent Supportive Housing project, creating of an unhoused specialist
/ homeless coordinator, support for the County’s Rapid Rehousing
program ,coordination with the County on the creation of a regional shelter
serving the West Valley area.
3. An inventory of land suitable and available for residential development,
including vacant sites and sites having realistic and demonstrated potential for
redevelopment during the planning period to meet the locality’s housing need for
a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
See Below
Exhibit A-1
Small Sites: The site inventory currently includes 64 sites that are less than 0.5
acres, including several sites with existing housing (p. H-IV-30 and Table A). Sites smaller than a half-acre in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size and affordability were successfully developed during the prior
planning period or unless the housing element describes other evidence to HCD
that the site is adequate to accommodate lower- income housing (Gov. Code, § 65583.2, subd. (c)(2)(A).). The element identifies several site groupings with potential for consolidation. However, the element must also evaluate whether those sites are suitable to accommodate housing for lower-income households
and add or modify programs as appropriate. For example, the element could list
past consolidations by the number of parcels, number of owners, zone, number of units, affordability and circumstances leading to consolidation and then relate those trends to the identified sites or could explain the potential for consolidation on a site-by-site basis. Based on the outcomes of the analysis, the element
should modify policies and programs, including a specific commitment to ensure
that maximum densities can be accommodated on all sites in the inventory.
Modify Inventory to remove several smaller sites and revise BMR
distirbution to remove assignment to smaller sites.
Large Sites: The inventory includes several sites over ten acres, including one
16.4- acre site with an operating commercial shopping center. While the element clarifies there is interest from the property owner, it should analyze the suitability of these sites to accommodate housing for lower-income households or rescale assumptions. The City described its strategy for “carving out” portions of some larger parcels, where some portions of parcels can be developed while
maintaining other existing residential and commercial uses. However, the City should clarify the timeline and procedure by which these carveouts will occur. For example, the element should discuss any recent developments of similar size and affordability, opportunities for parceling, phasing or site planning and generally address how housing affordable to lower-income households will occur
given typical state funded developments are approximately 50 to 150 units then rescale assumptions if necessary and add or modify programs as appropriate.
Revise Element to clarify large sites identified will develop as “carve outs”,
simulating a smaller site. Document proposed strategies to increase
affordable housing production on large sites, including the creation of an
Affordable Housing Overlay Zone.
Exhibit A-1
City-Owned Sites: The element identified two City-Owned sites to accommodate
231 housing units; however, must analyze the suitability and availability of those sites for development in the planning period, including how the sites will be available (e.g., surplus or lease), any known barriers, an anticipated schedule and other relevant factors. In addition, the element should include a program with
numerical objectives that ensure compliance with the Surplus Land Act, provides
incentives and actions along with a schedule to facilitate development of City-owned sites. Actions should include outreach with developers, issuing requests for proposals, incentives, fee waivers, priority processing, financial assistance and alternative actions if the sites do not become available at a reasonable point
in the planning period (e.g., 2028).
Update Element to modify approach to city owned sites, removing parking
garage, and providing more details and milestones on development of
corporation yard.
Suitability of Nonvacant Sites: The element must include analysis demonstrating the potential for additional development on nonvacant sites and describes
existing property owner interest (p. H-IV-21). While the element mentions underutilized sites were identified based on interest in development, structure/site conditions and development on adjacent sites with similar characteristics, it must support the validity of these factors in demonstrating the potential for redevelopment. For example, the element currently lists prior uses in recent
development activity but could also discuss how the recent trends support the various factors. In addition, the element could consider additional factors such existing versus allowable floor area and reflect those values in the sites inventory. Finally, the element should account for the extent existing uses impede additional residential development including market demand for the existing use
and existing leases or contracts that would perpetuate the existing use or prevent additional residential development. The housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households. As a result, the housing element must demonstrate existing uses are not an impediment to additional
residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) For your information, absent findings in the resolution as part of adoption based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.
Modify Element to highlight actions City has taken to encourage
redevelopment of non-vacant sites, including significant increase in density
and reduction in Parking standards. Document existing developer interest
in development of non-vacant sites and facilitate interest letters from
property owners / developers on non-vacant sites.
Exhibit A-1
Electronic Sites Inventory: For your information, pursuant to Government Code
section 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/planning-and- community-development/housing-elements
for a copy of the form and instructions. The City can reach out to HCD at
sitesinventory@hcd.ca.gov for technical assistance.
Resubmit Element using requested forms.
Zoning for a Variety of Housing Types:
· Single Room Occupancy (SRO) Units: The City categorizes SROs under the
definition of rooming and boarding houses, “that are rented to between 3 to 5 persons for profit…”(p. H-II-109). The City should analyze this definition as a possible constraint. In addition, the City allows SROs in only certain zones and requires a Conditional Use Permit (CUP) in all zones allowed. The element
should demonstrate zoning, development standards, including parking, and
permit procedures encourage and facilitate SROs or add or modify programs as appropriate.
Modify Element to identify City will update its Zoning Ordinance addressing
SRO’s and permitting
• By-right Permanent Supportive Housing: While the element states that supportive housing is permitted in all residential zoning districts by right (p. H-II-109), supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily
uses pursuant to Government Code section 65651. The element must
demonstrate compliance with these requirements and include programs as appropriate.
Modify Element to identify City will update its Zoning Ordinance regarding
Permanent Supportive Housing to comply with state law.
• Emergency Shelters: The element was revised to state that emergency
shelters are allowed by-right in a “portion of the M-1 zone” and states that the area is “well served by transit and commercial services” (p. H-III-107). However, the element must also identify and analyze any development standards (e.g., spacing, parking, concentration requirements) and other requirements imposed on emergency shelters. Lastly, the element must describe compliance with
Government Code section 65583, subdivision a)(4)(A) or include a program to comply with this requirement. For your information, pursuant to Government Code section 65583, subdivision a)(4)(A), parking requirements should be limited to allowing sufficient parking to accommodate all staff working in the emergency
Modify Element to identify that City will update its Zoning Ordinance
regarding development standards for emergency shelters.
Exhibit A-1
shelter, provided that the standards do not require more parking for emergency
shelters than other residential or commercial uses within the same zone.
• Accessory Dwelling Units (ADU): HCD records indicate permitted ADUs of 5 in 2018, 8 in 2019, 54 in 2020, and 38 in 2021, figures that are inconsistent with those in the element. The element should reconcile these numbers either in the element or Annual Progress Reports (APRs) and adjust assumptions as appropriate.
After a cursory review of the City’s ordinance, adopted August 16, 2022, HCD discovered some areas which are inconsistent with State ADU Law. HCD will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance to comply with state law.
Review and update data and statistics regarding ADU’s.
Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The
analysis should analyze land use controls independently and cumulatively with
other land use controls. The analysis should specifically address requirements related to parking for small units including SROs and missing middle housing types; height limits particularly in multifamily zones; maximum lot coverages; minimum lot areas; minimum site sizes; public and private open space
requirements; lot coverage and limits on allowable densities. The analysis should
address any impacts on cost, supply, feasibility, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints. Finally, pursuant to public comments, the City must make a firm commitment to reduce its parking requirements across residential zones.
Update Element to clarify that the City will adopt Objective Standards in
March 2023, addressing this issue.
Exhibit A-1
Processing and Permit Procedures: The element identifies that most
developments are subject to a Site and Architectural Review and lists various finding, most notably “The project will aid in the harmonious development of the immediate area”. The element then mentions this is similar to other jurisdictions but should evaluate the impacts of the finding on housing supply (number of
units), cost, timing, feasibility and particularly approval certainty and then add
programs to address identified constraints.
Update Element to clarify that the City will adopt Objective Standards in
March 2023, addressing this issue.
Persons with Disabilities: The element describes the City’s reasonable
accommodation process and lists its factors for consideration (pp. H-II-141), including the potential impact on surrounding uses. The element then notes this factor can be addressed by evaluating alternatives to addressing the needs of persons with disabilities. First, a factor such as impact on surrounding uses is essentially a conditional use finding and a reasonable accommodation procedure
should be a unique exception process, instead using factors such as whether the accommodation poses a fundamental alternation of zoning and land use – a far different standard that should be employed in a manner to promote access to housing opportunities for persons with disabilities. Second, the surrounding use factor appears to be employed in a manner that seeks to alter requests and fit
with the surrounding areas as opposed to considering the exception request. For these reasons alone, the element should identify this finding as a constraint and modify Program H-5g (Reasonable Accommodation) to remove the constraint early in the planning period (within two years).
Modify Element to identify that City will update its Zoning Ordinance
regarding standards and findings for Reasonable Accomodation.
In addition, the element indicates group homes for seven or more persons are allowed in all residential zones but subjects group homes to a conditional use permit (CUP), unlike other similar uses. The element should specifically analyze
these constraints for impacts on housing supply and choices and approval
certainty and objectivity for housing for persons with disabilities and include programs as appropriate.
Modify Element to identify City will update its Zoning Ordinance regarding group homes to comply with state law.
Exhibit A-1
Programs must demonstrate that they will have a beneficial impact within the
planning period. Beneficial impact means specific commitment to deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation. Deliverables should occur early in the planning period to ensure actual housing outcomes. Several programs and actions have timelines that
could be moved earlier in the planning period to ensure a beneficial impact.
Examples include Programs H-1E (Preapproved ADU Plans), H-1m (Microunit Standards), H-2c (Short term Rental Ordinance), H-3e (Reuse Site Ministerial Review), and H-5t (Employee Housing).
Evaluate timelines for these programs and update Element .
C. Housing Programs
Additionally, programs must have specific commitment to clear housing
outcomes or deliverables. Several programs include actions with no description
of how those actions will be implemented (e.g., “support”, “study”, “explore”, “evaluate”, etc.,). Programs should be amended, to include specific commitment to a housing related outcome.
Examples include Programs H-1b (Commercial Linkage Fee), H-1c (Affordable
Housing Overlay Zone), H-1k (Achieve Target Densities), H-1m (Micro-unit
Standards), H-2d (Workforce Housing Ordinance), H-2e (Housing Rehabilitation Loans), H-2g (Preservation of Assisted Housing), H-3a (Parking Requirement Reduction) H-5d (Shared Housing Program), H-5o (ELI Unit Development), and H-5s (City Density Bonus).
Modify Element to update Milestones for these programs.
As noted in Finding B3, the element does not include a complete site analysis;
therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types.
See response regarding Housing Opportunity Sites.
In addition, programs targeting development of publicly owned land (e.g., Program H- 5q) should include a schedule of actions for development in the
planning period consistent with the assumptions in the sites inventory, including
coordination with developers, requests for proposal, facilitating entitlements, incentives, issuing building permits and compliance with the Surplus Land Act.
See response regarding City-Owned Housing Opportunity sites.
Exhibit A-1
As noted in Finding B4, the element requires a complete analysis of potential
governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.
See responses above.
As noted in Finding B1, the element must include a complete assessment of fair housing. Based on the outcomes of that analysis, the element must add or modify programs.
See responses above.
Program H-2g states an objective to “participate in the preservation of at-risk units by providing financial and/or technical assistance” (p. H-IV-55). However, the program should make a specific and firm commitment to maintain the long-
term affordability of these units, including a clear commitment of financial
assistance or support of funding applications, coordination with qualified entities and support, education and assistance for tenants.
Update approach to addressing at-risk units – including actions and
timeline to contact landlords, apply for funding to continue to buy down affordability of units and subsequent actions.
While the element includes quantified objectives for new construction, it should
also consider quantified objectives for rehabilitation and preservation of existing affordable housing. For your information, the quantified objectives do not represent a ceiling, but rather set a target goal for the City, based on needs, resources, and constraints.
Review Element to consider revisions to quantified objecives.
Exhibit A-1
While the City made efforts to include the public through workshops and surveys,
moving forward, the City should employ additional methods for public outreach efforts in the future, particularly to include lower-income and special needs households and neighborhoods with higher concentrations of lower-income households. In addition, several comments questioned the lack of commitments
around reducing parking minimums and ensuring the feasibility of missing middle
housing types. The City should consider these comments and make adjustments as appropriate. The City should also analyze the feasibility of sites identified by members of the public, including the site of a former Elephant Bar and Fry’s Electronics and make adjustments as appropriate. The City could also, for
example, target higher densities around the Hamilton 880 corridor. To AFFH, the
element could revise Program H-3f and commit to development of a rent stabilization ordinance that limits annual rent increases or develop a city-wide portal for affordable rentals available. Finally, to address noted jobs-housing relationships, the City could also, for example, conduct targeted stakeholder
interviews or establish a committee representative of lower-income households
and commuters who work inside the City in future public outreach efforts. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community- development/building-blocks/getting-started/public-participation.shtml.
Consider creation of Housing Commission and approach to membership
on Commission that encourages inclusivity of stakeholders in under-
represented groups.