Attachment B - Basis of approvalATTACHMENT B
BASIS FOR APPROVAL
Eligibility for Modification Request Under Government Code Section 65913.4(g)
Under Government Code section 65913.4(g)(3), a proposed project modification qualifies
for limited -scope review under 65913.4(g) unless (A) "[t]he development is revised such
that the total number of residential units or total square footage of construction changes
by 15 percent or more, or (B) "[t]he development is revised such that the total number of
residential units or total square footage of construction changes by 5 percent or more and
it is necessary to subject the development to an objective standard beyond those in effect
when the development application was submitted in order to mitigate or avoid a specific,
adverse impact, ... and there is no feasible alternative method to satisfactorily mitigate
or avoid the adverse impact." The number of residential units is unchanged in the
modified project, and the proposed modifications increase the total square footage of
construction by approximately 1.3%. Thus, the modified project qualifies for review as a
modification request under Government Code section 65914.4(g).
Eligibility for Streamlined Review Under SB 35
The following is an analysis to determine whether the project continues to meet the
eligibility requirements of Government Code section 65913.4. The eligibility
requirements are listed in the form of questions with responses based on whether this is
applicable to the modification request.
1. Has the Department of Housing and Community Development ("HCD") determined that the
local agency is subject to SB 35?
Not applicable to the modification request, since there are no modifications proposed
which impact this criterion.
In 2018, when the original application was submitted, HCD had determined that due
to the type and amount of affordable housing generated in the City of Cupertino, the
project was subject to SB 35 streamlining.
2. Is the project a multifamily housing development (2 or more residential units)?
Not applicable to the modification request, since there are no modifications proposed
which impact this criterion.
The proposed project continues to be a mixed -use development with 2,402 residential
units and therefore, qualifies as a multifamily housing development.
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3. Has the applicant dedicated the applicable minimum percentage of units in the project to
households making below 80% of the area median income?
Not applicable to the modification request, since there are no modifications proposed
which impact this criterion.
In 2018, HCD had identified the City of Cupertino as a "50% Affordable Housing
jurisdiction" for purposes of SB 35 streamlining and ministerial review. The approved
project and the modification request both include 50% (1,201 units) of the total (2,402
units) as affordable to very low income or low income households earning annual
incomes less than 80% of the area median income.
4. If the site is in a city, is a portion of the city designated by the United States Census Bureau
as either an "urbanized area" or "urban cluster," or, if the site is in an unincorporated area, is
the parcel entirely within the boundaries of "urbanized area" or "urban cluster"?
Not applicable to the modification request, since there are no modifications proposed
which impact this criterion.
In 2018, the U.S. Census data identifies the City of Cupertino as being a part of the San
Jose urbanized area.
5. Does at least 75% of the perimeter of the site adjoin parcels currently or formerly developed
with "urban uses"?
Not applicable to the modification request, since there are no modifications proposed
which impact this criterion.
California Government Code section 65913.4(h)(8) defines "urban uses" to mean any
current or former residential, commercial, public institutional, transit or
transportation passenger facility, or retail use, or any combination of those uses.
The City determined in 2018 that at least 75% of the perimeter of the project site adjoin
parcels currently or formerly developed with urban uses.
6. Does the site have either zoning or a general plan designation that allows for residential use or
residential mixed -use development and does the development designate at least two-thirds of
the square footage for residential use?
Residential or Mixed -Use Designation
Not applicable to the modification request, since there are no modifications proposed
which impact this criterion.
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The 2018 Cupertino General Plan: Community Vision 2015 - 2040 identified the
parcels at the project site as the Vallco Shopping District Special Area which had the
following General Plan land use designation: Commercial/Office/Residential. This
land use designation allows mixed -use developments with commercial, (including
retail and hotel uses), office, and residential uses.
The 2018 zoning of the property was Planned Development with General Commercial
uses (P(CG)) south of Vallco Parkway and Planned Development with Regional
Shopping uses (P(Regional Shopping)) north of Vallco Parkway. While the zoning did
not allow residential uses, the General Plan designation in effect in 2018 allowed for
a mix of uses including residential.
Government Codes section 65913.4(a)(5)(B) provides that in the event an objective
zoning standard (here, the 2018 zoning designation) is mutually inconsistent with an
objective general plan standard (here the 2018 General Plan land use designation), the
general plan designation prevails. The proposed modified project continues to
propose a mixed -use development with residential, commercial and office uses.
Therefore, the proposed modification request is consistent with the 2018 General Plan
land use designation allowing a mix of uses, including residential.
Residential Square Footage
Applicable to the modification request, since there are modifications proposed that
change residential and nonresidential square footage.
Government Code section 65913.4(a)(2)(C) requires that projects qualifying for
ministerial approval must show that "at least two-thirds of the square footage of the
development is designated for residential use." The residential and nonresidential
square footage calculations must be performed using the "same assumptions and
analytical methodology" that were used in the 2018 project approval.
In 2018, the definition of "floor area" in the 2018 Cupertino Municipal Code section
19.08.030(F) was used to determine what percentage of the proposed development is
designated for residential use. The Municipal Code defines "floor area" to mean "the
total area of all floors of a building measured to the outside surfaces of exterior walls,
and including the following:
1. Halls;
2. Base of stairwells;
3. Base of elevator shafts;
4. Services and mechanical equipment rooms;
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5. Interior building area above fifteen feet in height between any floor level and the
ceiling above;
6. Basements with lightwells that do not conform to Section 19.28.070(I);
7. Residential garages;
8. Roofed arcades, plazas, walkways, porches, breezeways, porticos, courts, and
similar features substantially enclosed by exterior walls;
9. Sheds and accessory structures.
"Floor area" shall not include the following:
1. Basements with lightwells that conform to Section 19.28.070(I);
2. Lightwells;
3. Attic areas;
4. Parking facilities, other than residential garages, accessory to a permitted
conditional use and located on the same site;
5. Roofed arcades, plazas, walkways, porches, breezeways, porticos, courts and
similar features not substantially enclosed by exterior walls."
Cupertino Municipal Code section 19.08.030(A) defines an "attic" to mean "an area
between the ceiling and roof of a structure, which is unconditioned (not heated or
cooled) and uninhabitable." Therefore, mechanical electrical and other areas between
the ceiling and roof are not included in the calculation of floor area.
Cupertino Municipal Code section 19.08.030(F) defines "first floor" to mean "that
portion of a structure less than or equal to twenty feet in height, through which a
vertical line extending from the highest point of exterior construction to the
appropriate adjoining grade, passes through one story."
Based on an independent review conducted by the City's contract plan check
consultant, under the supervision of City Planning and Building staff, the
modification request complies with the minimum residential square footage
requirement of SB 35. The proposed modification is a mixed -used residential
development consistent with General Plan land use designation and Municipal Code
definitions with at least two-thirds of the area designated for residential use.
The following table shows the square footage of various uses provided by the
applicant and the square footage calculated by the City's consultant, based on plans
submitted by the applicant. Any methodological differences between the applicant's
calculation and the City's review do not impact the project's compliance with SB 35
criteria or applicable objective standards.
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Approved
(2018)
% of
Total
2022 Project
Plans (SF)
% of
Total
2022 Modification
(SF)
% of
Total
Residential
4,961,904
66.8
5,119,005
68.1
5,219,907
68.1
Retail
485,912
6.5
429,408
5.7
500,344
6.5
Office
1,981,447
26.7
1,973,494
26.2
1,949,797
25.4
Total
7,429,263
100
7,521,907
100.0
7,670,348
100.0
7. Does the project involve a subdivision of land and is the development subject to a requirement
that prevailing wages will be paid and a skilled and trained workforce will be used?
Not applicable to the modification request, since there are no modifications proposed
which impact this criterion.
The modification request proposes a tentative map amendment. The applicant has
certified that the project will be subject to the applicable requirements of California
Government Code section 65914.3(a)(8) related to the payment of the general
prevailing rate of per diem wages for all construction workers and that a skilled and
trained workforce will be used.
8. Is the project outside of each of the following areas? (The full text of the criteria listed below
can be found in section 65913.4(a)(6).)
Not applicable to the modification request, since the proposed modifications do not
impact this criterion and pursuant to Govt Code section 65913.5(g), the City is
prohibited from revisiting these determinations from 2018.
• Coastal zone — The project site is outside a coastal zone. The City of Cupertino's
General Plan does not identify any portions of the City within a Coastal Zone.
• Prime farmland or farmland of statewide importance — The project site is outside
prime farmland or farmland of statewide importance. The City of Cupertino's
General Plan does not identify any portions within the City to be prime farmland
or farmland of statewide importance.
• Wetlands as defined under federal law — The project is outside any wetlands as
defined under federal law. There are no wetlands as defined under federal law
identified on the project site.
• High or very high fire hazard severity zones — The project site is outside the high
or very high fire hazard severity zones. The high or very high fire hazard severity
zones are identified in Chapter 16.74 of the Municipal Code.
• Hazardous waste site — The site is not listed as a hazardous waste site pursuant to
Health and Safety Code section 65962.5 or 25356.
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Earthquake fault zones in an official map published by the State Geologist, unless
the development complies with state seismic protection building code standards
and by local building standards — The project site is outside earthquake fault zones
and will comply with applicable state seismic protection building code standards
and local building standards.
• FEMA designated flood plain or floodway — The project site is outside a FEMA
designated flood plain or floodway.
• Lands designated for conservation in a habitat conservation plan — The project site
is outside lands designated for conservation in a habitat conservation plan.
• Protected species habitat — The project site is outside any protected species habitat.
• Lands under a conservation easement — The project site does not include lands
under a conservation easement.
• Require demolition of (a) housing subject to recorded rent restrictions, (b) housing
subject to rent control, (c) housing occupied by tenants within past 10 years, or (d)
an historic structure placed on a local, state, or federal register — The project site is
outside an area that would involve the demolition of any housing subject to rent
restriction, rent control or occupied by tenants in the past 10 years or an historic
structure placed on a local, state, or federal register. The site has historically been
used and operated as a regional mall. There has never been any housing located
on the project site. While the site is identified as a "Community Landmark" in the
City's General Plan, the site does not contain an historic structure that was placed
on a national, state, or local historic register as referenced in SB 35.
Land governed by the Mobilehome Residency law, the Recreational Vehicle Park
Occupancy Law, the Mobilehome Parks Act, or the Special Occupancy Parks Act
— The project site is not located on land governed by the Mobilehome Residency
law, the Recreational Vehicle Park Occupancy Law, the Mobilehome Parks Act, or
the Special Occupancy Parks Act.
9. Has the project proponent certified that either the entire development is a "public work" for
purposes of the prevailing wage law or that the construction workers will be paid at least the
prevailing wage?
Not applicable to the modification request, since there are no modifications proposed
which impact this criterion.
The applicant has affirmed in its project application that all construction workers will
be paid at least the prevailing wage.
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10. Has the project proponent certified that "a skilled and trained workforce" will be used to
complete the development, if the requirement is applicable?
Not applicable to the modification request, since there are no modifications proposed
which impact this criterion.
California Government Code section 65914.3(a)(8)(B)(ii) defines a skilled and trained
workforce for purposes of this section to have "the same meaning as provided in
Chapter 2.9 (commencing with Section 2600) of Part 1 of Division 2 of the Public
Contract Code." The applicant has affirmed in the project application that it will use
skilled and trained workforce to complete the development.
Compliance with Objective Standards
Density
Not applicable to the modification request, since there are no modifications proposed
which impact this criterion.
The project meets the maximum allowable General Plan density for the site. The project
is located on 50.822 acres, prior to dedication of required right-of-way to accommodate
frontage improvements. In 2018, the City determined that the base maximum residential
yield would be 1,779 units. With a 35% density bonus (as the Density Bonus provisions
stood at the time the project application was made), the maximum residential yield is
2,402 units.
Office Allocation
Applicable to the modification request, since there are modifications proposed which
impact this criterion.
The project meets the maximum General Plan office allocation for the site. The 2018
General Plan allowed a maximum of 2,000,000 sq. ft. of office development at the Vallco
Shopping Center Special Area. Both the applicant provided calculations and the city's
independent reviewer identified that the office development is less than this maximum.
Please see the table on Page 5.
Objective Zoning Standards
Applicable to the modification request, since there are modifications proposed which
may impact this criterion.
The General Plan related to the Vallco Shopping Center Special Area in effect in 2018 (see
Attachment B) contemplated the preparation of a specific plan for the project site. The
specific plan was expected to include zoning standards. The draft specific plan was being
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prepared and was not adopted as of the date the original project application was
submitted to the City in March 2018.1 Only objective planning standards in effect at the
time that the original application was submitted to the City can be applied to the project
or to the modification request. (Gov. Code, §§ 65913.4(a)(5), 65913.4(g)). As a result, there
was no specific plan or associated zoning standards, applicable to the project application.
As determined in 2018, there are no height limits applicable to the original or modified
project. However, the Community Form Diagram (Figure LU-2) in the Land Use Element
of the 2018 General Plan identifies building planes the project must meet. Figure LU-2
states as a foot note: "Maintain the primary building bulk below a 1:1 slope line drawn
from the arterial/boulevard curb line or lines except for the Crossroads Area" and "For
the North and South Vallco Park areas (except for the Vallco Shopping District Special
Area): Maintain the primary building bulk below a 1.5:1 (i.e.,1.5 feet of setback for every
1 foot of building height) slope line drawn from the Stevens Creek Blvd. and Homestead
Road curb lines and below 1:1 slope line drawn from Wolfe Road and Tantau Avenue
curb line." In 2018, it was determined that the original project met this standard. The 2022
modified project continues to meet this standard by maintaining the 1:1 slope line for all
proposed buildings, including the green roof deck, from the arterial/boulevard curb line
from Stevens Creek Boulevard. There are portions of the green roof deck that continue to
encroach into the 1:1 slope line from Wolfe Road; however, the primary building bulk
continues to remain outside of the 1:1 slope line. Slope line sections are indicated on
Sheets P-0508 and P-0508.01.
Applicable to the modification request, since there are modifications proposed which
may impact this criterion.
As was determined in 2018, there are no specific "objective design review standards" for
this site (e.g., architectural design standards). However, there are standard project
requirements that are broadly applicable to development within the City (for example,
standards that relate to streets). There have been no changes to the project which impact
standard project requirements and therefore, the modification request complies with
design review standards.
1 The Vallco Town Center Specific Plan was adopted on September 18, 2018. However, upon a
referendum by local residents, the City Council eventually rescinded the adopted Plan in May
2019.