Campbell Asked HCD Seven SB 684 Questions. Here Are the Answers.
When must the lot be vacant? Do half-stories count toward 1,750 sq ft? Can a prelim app follow the formal one? HCD answered.
You're filing an SB 684 starter-home project on a single-family lot, and the questions pile up before the plans do. Does the lot have to be empty the day you apply, or can you clear it later? Do the half-stories in your design count against the size cap? Can you file a preliminary application after the formal one to lock in today's rules? Cities are still working out the answers — and a wrong guess can cost you units.
Here's the thing: Campbell asked the state those exact questions, and HCD wrote the answers down.
The backdrop
Campbell has become one of the busiest SB 684 counters in California. HCD's letter notes that as of May 20, 2026, the City has received 16 applications for SHRA projects, including 11 in 2026 alone — with 8 of the 16 proposed on single-family-zoned lots. In April 2026 the City sent HCD seven questions about how the Starter Home Revitalization Act (SB 684 of 2023) should work. On July 17, 2026, HCD answered in a Letter of Technical Assistance.
Verified against: City of Campbell SHRA Implementation — HCD Letter of Technical Assistance, dated July 17, 2026 (Gov. Code §§ 65852.28, 66499.40, 66499.41).
Everything below is HCD's position — technical assistance, not a court ruling.
When must the lot be vacant?
Campbell's early interim ordinances let a single-family parcel qualify as vacant “no later than recordation of the project’s final map or issuance of a building permit, whichever occurs first.” HCD rejected that timing. Its answer:
“a parcel should satisfy the statutory definition of “vacant” under the SHRA at the time of application submittal”
HCD read Government Code section 66499.41's reference to “the lot proposed to be subdivided” as pointing to the moment the project is proposed — i.e., when the application goes in. Campbell's April 2026 urgency ordinance already lines up with that, requiring the lot be vacant “on the date that a development proponent submits an application.”
A demolition permit isn't blocked by the Housing Crisis Act
Does the Housing Crisis Act (Gov. Code § 66300.6) force you to have a replacement project approved before you can tear down an existing unit? HCD's answer is no:
“A standalone demolition permit for an existing residential unit does not contain a replacement housing development project and therefore is not prohibited by the section.”
The catch HCD flags: the later housing development still faces the five-year lookback rules — one in section 66499.41 for whether the lot counts as vacant, and one in section 66300.6 for replacing protected units.
A preliminary application can come after the formal one
Vesting is the quiet lever here. Asked whether a preliminary application can follow a formal one, HCD said yes:
“The PSA does not prevent a preliminary application from being submitted after a formal development application has already been filed.”
Nothing in the Permit Streamlining Act requires the preliminary application to come first — so it can still be used to freeze the standards in place.
Height limits — and half-stories
Two size questions closed out the letter. On height, HCD's position is that a city may enforce either a numeric height limit or a story limit — but only the one from the underlying zone:
“The City may not impose a unique height limit applicable only to SHRA-enabled developments.”
On floor area, the one that trips up a lot of designs: half-stories don't count toward the 1,750 net-habitable-square-foot eligibility average. HCD was explicit — “yes, the half-story is not counted toward the 1,750 square foot limit” — and drew the bright line in its conclusion:
“a local definition of floor area that includes half-stories is not applicable to whether a project’s average unit floor area exceeds the SHRA’s limit”
A local floor-area definition that sweeps in half-stories can still govern local development standards — it just can't be used to knock a project out of SB 684 eligibility.
Before you rely on any of it
A Letter of Technical Assistance is HCD's interpretation of state law, not settled law — courts remain the final word, and this letter was written for Campbell's facts. If any of these barriers is standing between you and a starter-home approval, confirm how your own jurisdiction reads it, and run it past your building department or land-use counsel before you count on it. None of this is legal advice.
What CrossBeam does with it
When the letter lands on your desk, CrossBeam turns it around the same day: what each item is actually asking, the code or law behind it, and a written response you can hand to your team or your attorney — the back-and-forth that used to eat weeks, done in a couple of hours.