UPDATE To HCD: Santa Cruz YIMBY Comments on City of Capitola Draft Housing Element (August 2023)
September 1, 2023
Letter sent to HCD on September 1, 2023
Santa Cruz YIMBY (1) advocates for abundant housing at all levels of affordability to meet the needs of a growing population in Santa Cruz County.
Thank you for the discussion about the City of Capitola Draft Housing Element (August 2023). We appreciate that Capitola made some modifications in response to our earlier comments, however major issues remain. What follows is a summary of what we shared with you regarding this updated submitted draft.
Capitola Mall
The Capitola Mall (“Mall”) is critical to Capitola’s current plan to meet its 6th cycle goals. Capitola is counting on this redevelopment for nearly half of their RHNA and ⅔ of their affordable housing.
Merlone Geier, a market-rate developer “[p]rimarily focused on community and neighborhood shopping centers” (2), would do the redevelopment of the mall. We are also sending you their letter that goes deeper into concerns with the Housing Element.
- The six (6) Capitola Mall parcels are non-vacant. Capitola has not described the realistic development potential of the site. Government Code section 65583.2(g)(1)
- They do not indicate the likelihood of development during the 6th cycle, including feasibility, which uses will remain and timing.
- Capitola does not have a trend of doing similar redevelopment on non-vacant sites.
- The Capitola Mall parcels highlighted on the site inventory include all smaller commercial stores and interior of the mall which are integral to Mall operation. Capitola has not provided an “analysis that demonstrates the extent to which existing uses constitute an impediment to residential development.” (3)
- Capitola indicates the overall minimum residential density of 29 dwelling units/acre. Discussions with the developer suggest that the potential realized density of this site falls well short of the 50-70 du/acre at which development would be feasible. Merlone Geier’s letter calculates that this site needs 80 du/acre to meet the numbers of the HE.
- Capitola’s mixed-use zoning requires first floor commercial uses. (4) This reduces the density of housing when coupled with other development constraints (height, FAR, etc.).
- Through the Incentives for Community Benefits (5), Capitola offers the modest incentives of increased FAR (2.0) and height (50’) in exchange for public benefits of significant cost.
- The public benefits are subject to discretionary review by the Planning Commission and City Council.




