S. Flashman April 5, 2016 letter regarding ballot question
Law Offices of
Stuart M. Flashman
5626 Ocean View Drive
Oakland, CA 94618-1533
(510) 652-5373 (voice & FAX)
e-mail: stu@stuflash.com
Delivery via electronic mail
April 5, 2016
Hon. Barry Chang, Mayor, and
Cupertino City Council
Cupertino City Hall
10300 Torre Ave.
Cupertino, CA 95014
Re: Ballot question for CCSG Initiative.
Dear Mayor Chang and Council Members,
I am writing to you on behalf of my clients, the Cupertino Residents for Sensible
Zoning Action Committee and the proponents of the Cupertino Citizens’ Sensible
Growth Initiative, in regard to tonight’s special city council meeting and its sole agenda
item, a proposal to modify the ballot question for the Cupertino Citizens Sensible
Growth Initiative (CCSGI). The meeting has apparently been set to respond to a letter
the City received from an attorney representing the backers of a counter-initiative
(primarily Vallco Property Owner, LLC [AKA San Hill Property Company]) asserting that
the City’s previously-approved ballot language is inaccurate and must be corrected. My
clients agree with the developer’s attorney that the previously approved language is
inaccurate, but not about the nature of the inaccuracy.
The developer’s attorney relies on the report prepared for the City under
Elections Code §9212 as showing that the height limit in the City’s Neighborhoods
would be increased by the CCSGI. However, that report itself was inaccurate because
it ignored the fact that in October of 2015 the City Council revised and amended the
general plan. In particular, the October 2015 General Plan Amendment revised Figure
LU-1, the Community Form Diagram, and that revised diagram is specifically and
explicitly included in the CCSGI at page 6. A copy of that revised figure is attached to
this letter as Exhibit A. The revised diagram, like that included in the December 2014
general plan revisions, identifies the various “Special Areas” within the City and
identifies key land use standards for those areas. At the lower right corner of the
diagram, the diagram legend, like that in the December 2014 General Plan, lists the
various Special Areas and shows how they are designated in the diagram. However,
the October 2015 General Plan Amendment added, at the bottom of that list (which has
the heading “Special Areas”), “Neighborhoods” with a block next to it showing that this
Special Area is indicated on the diagram in white. The October 2015 General Plan
Amendment also added a box at the bottom of Figure LU-1 that identifies a maximum
density (15 units per acre) and a maximum height (30 feet) for the Neighborhoods
Special Area.
The developer’s attorney’s letter, and the §9212 report on which it is based,
assume that the Neighborhoods are not a Special Area, and are therefore covered by
the CCSGI’s policy that, “Outside of the Special Areas shown in Figure LU-1, building
heights may not exceed 45 feet.” However, as noted, the Neighborhoods are explicitly
shown in Figure LU-1 as a Special Area. Therefore, the quoted policy does not apply to
the Neighborhoods. In fact, the CCSGI explicitly says, in Policy LU-3.0: Community
Form that, “The maximum heights and densities for the Special Areas shown in the
Community Form Diagram (Figure LU-1) shall not be exceeded.”
Hon. Mayor Chang and City Council - Ballot Question for CCSG Initiative
April 5, 2016
Page 2
Since Figure LU-1 shows the maximum height in the Neighborhoods as 30 feet
and the maximum density as fifteen units per acre, those limits are re-enacted by the
CCSGI. The City’s proposed ballot question must therefore be modified accordingly.
My clients also believe that the Elections Code §9212 Report prepared for the City
should also be revised to properly reflect the changes that the City Council made to the
General Plan in October 2015. A suggested revised ballot question (in both clean and
redline form) is attached to this letter as Exhibit B.
Most sincerely
Stuart M. Flashman
Attachments:
October 2015 version of General Plan Figure LU-1 – Community Form Diagram
Proposed Revised Ballot Question
cc: City Manager
City Attorney
Exhibit A
Exhibit B
Shall an initiative ordinance be adopted amending
Cupertino’s General Plan to limit redevelopment of the
Vallco Shopping District, limit building heights along major
mixed-‐‑use corridors, establish a 45 feet maximum building
height in the Neighborhoods maintain existing maximum
heights and densities in all special areas, including the
Neighborhoods, limit lot coverages for large projects,
establish new setbacks and building planes on major
thoroughfares, and require voter approval for any changes
to these provisions?
Shall an initiative ordinance be adopted amending
Cupertino’s General Plan to limit redevelopment of the
Vallco Shopping District, limit building heights along major
mixed-‐‑use corridors, maintain existing maximum heights
and densities in all special areas, including the
Neighborhoods, limit lot coverages for large projects,
establish new setbacks and building planes on major
thoroughfares, and require voter approval for any changes
to these provisions?