State technical assistance
HCD’s July 17, 2026 guidance to Campbell
California’s Department of Housing and Community Development answered seven questions from Campbell about implementing the Starter Home Revitalization Act. Several answers are directly relevant to understanding the Holmes Avenue chronology.
What the letter is
On July 17, 2026, HCD sent Campbell Community Development Director Rob Eastwood a five-page “City of Campbell SHRA Implementation – Letter of Technical Assistance.” The letter addresses vacancy timing, demolition of existing housing, preliminary-application vesting, height and story limits, and treatment of half-stories.
HCD noted that, as of May 20, Campbell had received 16 Starter Home applications, including 11 during 2026, with eight proposed on single-family-zoned lots.
Read the full July 17, 2026 HCD letter (PDF) →
For analysis of the letter, please read below.
1. HCD interpreted vacancy as a condition at application submittal
HCD acknowledged that the SHRA does not expressly state a definitive point in time for vacancy. HCD nevertheless concluded that a parcel should satisfy the statutory definition of “vacant” at the time of application submittal. In answering Campbell’s second question, HCD rejected the timing approach Campbell had placed in Ordinance No. 26-2347, under which vacancy could be achieved later, by final-map recordation or building-permit issuance.
How the statutory language reads
Government Code section 66499.41(a) directs a local agency to ministerially consider a map for a housing development project that meets a series of requirements. Subdivision (a)(2) then says that “the lot proposed to be subdivided” must meet specified conditions, including being either zoned for multifamily residential use or “vacant and zoned for single-family residential development.” The statute defines “vacant,” but it does not expressly say “vacant on the date the application is submitted.”
That omission is the source of the timing dispute. Campbell read the statute as allowing the vacancy condition to be satisfied later in the process and wrote that approach into Ordinance No. 26-2347. HCD read the same language differently: because the statute describes eligibility of the lot proposed for subdivision and repeatedly uses the application date as the measuring date for related tenant-occupancy protections, HCD concluded that vacancy should exist when the application is submitted.
2. The cited Housing Crisis Act provision does not prohibit a standalone demolition permit
Campbell asked whether Government Code section 66300.6(a) applies to approval of a standalone demolition permit for an existing residential unit. HCD answered “no.”
HCD explained that the provision applies to a housing development project that requires demolition. A standalone demolition permit contains no replacement housing development project and therefore is not prohibited by that section.
3. Demolition does not erase the five-year lookbacks
HCD specifically cautioned that a later development remains subject to the five-year lookback in Government Code section 66499.41(a)(2)(A)(ii)(III) when determining Starter Home eligibility and vacancy. HCD also identified a separate five-year lookback under Government Code section 66300.6(b) concerning replacement of protected units.
Accordingly, physical vacancy after demolition and the parcel’s prior occupancy/protected-unit history are distinct questions.
4. HCD did not decide whether Campbell may adopt a demolition-control ordinance
Campbell asked whether it could limit demolition permits for existing residential units unless a replacement housing project had already received the necessary approvals. HCD expressly declined to provide a determination.
HCD added that if Campbell pursued such an ordinance, it should consider possible unintended consequences because a restrictive demolition-control ordinance could impede beneficial redevelopment and housing-production goals.
This should not be characterized as HCD either approving or prohibiting a Campbell demolition-control ordinance.
5. Preliminary applications may follow formal applications
HCD said the Permit Streamlining Act does not prevent a preliminary application from being submitted after a formal development application. HCD said the relevant statutes do not require the preliminary application to come first for vesting purposes.
This general answer does not resolve the separate ownership and entity-documentation issues identified by Campbell in its review of the 1124 Holmes preliminary application.
6. Campbell may enforce underlying-zone height or story limits
HCD said Campbell may enforce either numeric height limits or limits on number of stories where those are applicable in the underlying zoning. The limit imposed on a Starter Home development must be exactly the limit of the underlying zone; Campbell may not create a unique height limit applicable only to Starter Home projects.
7. Half-stories and the 1,750-square-foot calculation
HCD concluded that a half-story is excluded from the SHRA calculation of the 1,750-square-foot average net-habitable-floor-area limit, even where local rules allow habitable area in a half-story. HCD distinguished that state-law eligibility calculation from compliance with otherwise permissible local objective development standards.
Why the letter matters to Holmes Avenue
The City’s May 20 review of the original 1124 Holmes application had already described a possible sequence of withdrawing the application, demolishing the existing house, and submitting a new application after the parcel became physically vacant. HCD’s July 17 letter subsequently confirmed two relevant legal interpretations: vacancy should exist at application submittal, and Government Code section 66300.6(a) does not prohibit a standalone demolition permit.
Campbell issued the whole-house demolition permits for both 1115 and 1124 Holmes on August 13, 2026, after receiving HCD’s July 17 letter.