The Santa Clara County Planning Commission on Sept. 25 denied an appeal and upheld a Department of Planning and Development determination that the formal application for the Circle Hill Housing Development Project was incomplete as of the county’s Aug. 1, 2025 letter. The proposed project calls for a major subdivision and grading approval for 20 housing units (16 single‑family homes and four accessory dwelling units) on a roughly 97.5‑acre parcel in a hillsides zoning district.

Senior planner Laura Tran told the commission the county issued five rounds of incomplete letters, beginning with a May 3, 2024 first incomplete letter, and that after several resubmittals the Aug. 1, 2025 (fifth) incomplete letter identified seven outstanding items the county needed to deem the formal application complete. “The fifth incomplete letter dated 08/01/2025 identifies seven incomplete items that are summarized and include: a site plan that identifies all existing and proposed structures and legal access, a proposed floor plan and elevation plan, an energy conservation plan, obtaining a compatible use determination [the parcel is under a Williamson Act contract], provide fire hydrant flow data and provide a geologic investigation report of landslide hazard zone,” Tran said during the staff presentation.

The applicant’s representatives said they had submitted portions of the required materials and disputed whether some items were required at the formal‑application stage. The applicant’s architect and counsel reiterated that certain technical studies (notably a detailed geologic investigation) are time‑consuming and expensive and argued that those studies are often performed after the application is deemed complete and prior to final approval. Travis Brooks, counsel for the applicant, said the applicant intended to continue working with staff to resolve outstanding items. “We will do [the geotech], but we just gotta make sure we have a project,” a project representative told commissioners during rebuttal.

County staff took the opposite position on several items: some checklist materials were not in the plan set; some forms (e.g., the San Francisco Bay watershed questionnaire) contained inconsistent numbers that made the submittal internally contradictory; and other items (fire hydrant flow, geotechnical scope) require coordination with county specialists before a complete report can be accepted. Staff noted that the county’s SB 330 checklist and other subdivision/grading checklists require some items for projects of this type and location.

Neighbors and environmental advocates urged the commission to uphold staff’s determination. Speakers cited wildfire hazard, landslide and seismic vulnerability on steep hillsides, the absence of required fire‑flow data and the lack of geotechnical work to support septic and grading plans. Alice Kaufman of Green Foothills told commissioners the public record included incomplete and, in places, incorrect information and that the county must require accurate technical data before moving applications forward.

After discussion the commission voted to deny the appeal and uphold the Department of Planning and Development’s determination that the Circle Hill application was incomplete. The motion carried 5–2 (Yes: Commissioners Heatherly, Cohen, Levy, Escobar and Chair Rausser; No: Commissioner Belska and Vice Chair O’Donoghue).

Staff reported the county had received hundreds of public comments on the project; Tran noted that 294 comments (as of the hearing) were in the record. County planning staff said plan sets and many submittal materials are available on the county’s SB 330 web page and encouraged applicants to coordinate directly with land development engineering, environmental health, the fire marshal and county geologist to clarify required scope and to supply the outstanding items for re‑review.

What’s next: With the commission upholding the incompleteness determination, the applicant may supply supplemental materials for staff review. Commissioners and staff also noted that the SB 330 vesting dispute and the interpretation of repeated 90‑day resubmittal periods is a separate legal matter pending in court; that question was outside the commission’s scope in this hearing.

(Reporting from the Sept. 25, 2025 Santa Clara County Planning Commission meeting.)