REPORT TO COUNCIL
SUBJECT
Title
Action on Introduction of a “Special Event Zone” Ordinance Regulating and Prohibiting Certain Activities within a Protected Area in Connection with the 2026 Major Events at Levi's® Stadium
Report
BACKGROUND
At the November 18, 2025 Council meeting, the City Council considered a proposed Special Event Zone ordinance (Ordinance) intended to support public health, safety, and general welfare, including mobility management, and operational logistics for Special Events, including the 2026 Super Bowl LX and FIFA World Cup events at Levi’s® Stadium (Attachment 1, RTC 25-1591). The City Council conducted an extensive discussion regarding the proposed regulations for the 2026 Major Events and raised questions related to the geographic boundaries of the proposed Special Event Zone, the effects of temporary restrictions on local businesses and residents, enforcement roles, community outreach, and opportunities to ensure that local vendors are appropriately informed and able to participate within permitted activations.
In response, staff prepared a simplified ordinance, making it easier for the public to understand, and removing restrictions the City Council felt were too restrictive and not necessary to address public health, safety, and welfare concerns. To better evaluate the effects of event time periods and the geographic footprint involved, staff recommends narrowing the current ordinance to address only Super Bowl LX at this time. A separate resolution for the FIFA World Cup will be brought forward once the operational plans for those events are further developed and can be more accurately assessed. The updated Ordinance also expressly requires compliance with existing City Code provisions to ensure the City’s standard protections remain in place. While staff continues to recommend adoption of the originally proposed map, a reduced-footprint alternative is also provided for Council consideration, along with clarifying explanations in the FAQ sheet, Attachment 2, and enhanced implementation and outreach strategies consistent with Council direction.
DISCUSSION
Overview of the Updated Ordinance Structure
The updated Ordinance, Attachment 3, restricts itself to six temporary special event specific regulations that apply only during the Special Event Time Period and within the designated Special Event Zone. A comparison of the original ordinance and the updated Ordinance, Attachment 4, is also included with this report.
All other regulatory frameworks for sidewalk vending, special events permits, temporary uses, counterfeit goods enforcement, signage, noise, and public safety requirements remain governed by existing State, Federal, and local (City Code) regulations and do not need restatement in the ordinance.
Key Elements of the Revised Ordinance
The simplified Ordinance introduces only the following Special Event-specific restrictions:
1. Pause on Sidewalk Vending Permits within the Zone
Only Chapter 5.05 permits within the Zone are paused during activation; permits remain valid elsewhere.
2. Prohibition on Outdoor Sales of Food and Beverage
The prohibition applies to outdoor sales when visible from public areas except when food and beverage sales are distributed in the ordinary course of business, at the usual location of properly permitted businesses.
3. Prohibition on Outdoor Merchandise Sales
The prohibition applies to outdoor sale or distribution of merchandise when visible from public areas except when merchandise sales are distributed in the ordinary course of business, at the usual location of a properly permitted business.
4. Prohibition on Mobile-Unit Vending and Advertising
The prohibition applies to any trucks, trailers, carts, bikes, or any wheeled vending unit not fixed to a foundation.
5. Prohibition on Free Product Sampling or Giveaways in Public Areas
This prohibition applies to promotional giveaways on streets, sidewalks, and outside an enclosed building. Based on feedback from the City Council, staff modified this section to expressly allow distribution of coupons when directly connected to businesses operating within the enclosed building, and where the distribution occurs wholly on private property outside of that building. Staff feels that adding this exception assists in narrowly tailoring the regulation in a way that still addresses the safety impact created by free product sampling or giveaways happening in public areas.
6. Permit Required for Temporary Structures. No temporary structure shall be constructed, placed, occupied or used (including, but not limited to, temporary location of tents, canopies, umbrellas and air supported, air-inflated and tensioned membranes) on non-residential property unless it is approved as an associated use with a Temporary Use Permit issued by the City pursuant to Santa Clara City Code Chapter 18.122.
In addition, and in response to concerns expressed from the City Council at the November 18, 2025 City Council meeting, staff removed the following prohibitions:
1. Permit requirements for Parades, Races and Block Events. Staff felt comfortable removing this requirement as the City’s Code provides sufficient protections in Chapter 12.15 (Parades and Processions).
2. Outdoor Commercial Signs and Advertising Displays. Staff felt comfortable removing this requirement as the City’s Code provides sufficient protections in Chapter 18.42 (Sign Regulations). Section 18.42.080 of the City Code broadly prohibits a wide range of sign types citywide including animated, inflatable, portable, rooftop, natural-feature-mounted, nonconforming, billboard, and certain illuminated signs unless expressly allowed elsewhere in the Sign Regulations.
These changes improve clarity, maintain public safety goals, and respond directly to the City Council concerns expressed during the prior meeting. The Ordinance also includes standard clarifying sections on compliance with existing laws, enforcement authority, and administrative penalties.
Special Event Zone Time Periods
The Special Event Zone time periods remain unchanged from the original Ordinance. They are proposed as follows:
• Super Bowl LX: Proposed activation February 1, 2026 (8:00 a.m.) - February 10, 2026 (10:00 p.m.).
• Additional Special Events, including, FIFA World Cup 2026: By separate Council resolution designating the event, dates, and map.
Special Event Zone Map Options
In response to the City Council’s feedback, staff has developed an alternative Special Event Zone Map, “Map A”, that reduces the overall boundary area, thereby limiting the application of regulations in residential and commercial neighborhoods farther from the Stadium and its associated impacts. Additionally, the initial proposed map, “Map B”, is included in this staff report for reference and as an option for the City Council to consider, should it feel that the changes to the ordinance sufficiently address prior concerns and the initial zone is preferred.
The updated Special Event Zone boundary continues to focus on the streets, public access routes, and outdoor gathering areas surrounding the Stadium and the adjacent entertainment and transit corridors. The revised boundary reflects current patterns of pedestrian and vehicle activity anticipated during major event operations, including event load-in, active event days, and post-event load-out. It also incorporates key ingress and egress routes that remain essential for emergency response, transit services, rideshare operations, Stadium patrons, and credentialed event vehicles, ensuring that temporary commercial activity does not interfere with critical mobility needs.
The Special Event Zone boundary is important for the City to maintain public health, safety, and general welfare by allowing for predictable and coordinated management of outdoor commercial activity, crowd movement, and emergency access during Special Events. The boundary is intended to establish a refined geographic approach providing a consistent and transparent regulatory framework that builds on Santa Clara’s established major-event practices, enabling the City to continue prioritizing public health, safety, and mobility while supporting efficient event operations and improved experience for residents and visitors.
A. Map A
Map A was designed to reduce the area affected by temporary restrictions while still retaining core public safety and mobility benefits. This area is a slightly smaller boundary and provides a more limited, tightly drawn zone, focusing primarily on:
• Immediate area surrounding the Stadium
• Critical emergency and transit corridors
• Key ingress/egress routes with historically high pedestrian and traffic congestion
B. Map B
Alternatively, Map B, Larger Boundary (Original Proposal) was designed to fully integrate all areas utilized for load-in/out, fan mobility, broadcast, temporary security perimeters, and emergency response staging. Map B reflects the full operational footprint identified for Super Bowl LX and FIFA World Cup 2026, including:
• Levi’s® Stadium and immediate surroundings
• Circulation corridors used for pedestrian flow, shuttles, rideshare, and emergency access
• Large sections of the surface parking lots
• Adjacent properties expected to host hospitality, media operations, or credentialing
• Portions of Great America Parkway, Tasman Drive, and associated access point
Both maps are provided as Attachment 5 (Map B) and Attachment 6 (Map A) for City Council consideration. Map B remains Staff’s recommendation because it most accurately reflects the full area anticipated to experience increased activity, traffic, and commercial impacts associated with Super Bowl LX. This broader boundary provides clearer expectations for residents and businesses while ensuring the City can effectively manage public safety, operations, and enforcement during the event period.
Enforcement
The updated Ordinance continues the enforcement structure previously discussed. Enforcement will happen primarily through Code Enforcement with back-up support from the City’s Police Department, as well as partnerships with other law enforcement agencies to address particular violations, such as counterfeit goods. We have outlined the enforcement process to provide a clearer division of responsibilities. Enforcement will follow a coordinated, tiered approach:
1. Administrative Citations
o Violations of mobile-unit vending restrictions within public streets/parks: penalties under City Code Chapter 5.05.
o All other violations: administrative penalties under § 1.10.
2. Immediate Abatement and Seizure where applicable
3. Coordinated Field Teams
o Police Department: primary response for safety risks, coordination of various law enforcement agencies, traffic management, and provides support for Code Enforcement when needed
o Code Enforcement: monitoring of temporary structures, signage, and unpermitted activities
o Public Works: right-of-way management
o Event Security / NFL / FIFA: coordination for perimeter controls and credentialed access
4. Education-First Approach
Prior to the activation period, staff will emphasize education and voluntary compliance, including multilingual materials and on-site pre-event outreach to small businesses and vendors.
The Ordinance uses existing administrative citation authority and does not create any new enforcement mechanisms.
Community Outreach
In response to the City Council direction, staff have broadened and strengthened the outreach plan to ensure clear communication and wide community awareness:
• A dedicated Special Event Zone webpage featuring updated maps, FAQs, and related resources.
• Notices distributed through City email lists, social media channels, and local business associations.
• Coordination with residential HOAs and the Stadium Relations Ad Hoc Committee to support targeted outreach.
• Opportunities for community members to subscribe for updates and request additional information.
The goal is to provide consistent, transparent, and early information to ensure residents and businesses understand what the ordinance does and does not do.
Major Event Agreement Provisions Regarding Adoption of a Special Event Zone
Both the FIFA Assignment and Assumption Agreement (FIFA Agreement; Section 5.14) and the Super Bowl League Event Agreement (LEA; Section 6.9) contemplate City Council consideration and adoption of a Special Event Zone ordinance. Neither agreement, however, requires the City Council to adopt an Ordinance, and the City Council reserves the right to approve or disapprove such an ordinance in its sole discretion. There would be consequences, however, under the LEA if the City Council does not take action to approve an SEZ. As provided in LEA Section 6.9, if the Council doesn’t initiate action to approve an SEZ by a specified date (now updated to be December 9, 2025), in a form consistent with NFL standards, StadCo and City shall meet and confer on what other lawful measures can be taken to assure that, to the maximum extent possible, equivalent protections can be implemented for the Super Bowl event. If such alternative measures cannot be agreed to by January 8, 2026, StadCo would have the right to terminate the LEA (and, if StadCo took such action, the City would have the right to terminate its agreements with BAHC for use of the Convention Center). Although a StadCo election to terminate the LEA seems unlikely, given the uncertainty this would create for all parties, the effect of such an election would be to revert the parties to their respective rights and obligations for hosting the Super Bowl under the original Stadium Lease (Article 21) and the related agreements with the City for public safety support for such events. Under these agreements, the SCSA’s position has been that an LEA must be entered into to allow for a Super Bowl at the Stadium. SCSA also takes the position that while the City may be required to provide public safety support for the Super Bowl, StadCo would be responsible to reimburse City costs, and there is no “threshold” above which the SCSA would have to reimburse such costs to StadCo. While StadCo has agreed that they would be obligated to reimburse City public safety costs, they have not agreed that the SCSA can require an LEA as a condition to hosting the Super Bowl, or that no public safety cost “threshold” applies to this event. If agreements cannot be reached, such matters would likely need to be resolved under the applicable Stadium Lease arbitration provisions.
Next Steps. If introduced with the first reading waived, staff will return for final adoption at the next regular City Council meeting.
ENVIRONMENTAL REVIEW
The action being considered does not constitute a “project” within the meaning of a California Environmental Quality Act (“CEQA”) pursuant to the CEQA Guidelines section 15378(a) as it has no potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment. Even if adoption of the Ordinance was considered to be a project under CEQA, it would be exempt from CEQA review pursuant to CEQA Guidelines section 15061(b)(3) because it can be seen with certainty that there is no possibility that adoption of the Ordinance would have a significant effect on environment given that it does not involve or authorize any construction or physical activity that could impact the environment.
FISCAL IMPACT
There is no General Fund impact anticipated beyond staff time to implement and enforce time-limited activations.
COORDINATION
This report and ordinance were coordinated with the City Manager’s Office, City Attorney’s Office, Police, Public Works, Community Development (Planning/Building/Code); Economic Development and Marketing; Communications; and the Stadium Authority.
PUBLIC CONTACT
Public contact was made by posting the Council agenda on the City’s official notice bulletin board outside the City Hall Council Chambers. A complete agenda packet is available on the City’s website and in the City Clerk’s Office at least 72 hours prior to a Regular Meeting and 24 hours prior to a Special Meeting, and hard copies of any agenda report may be requested by contacting the City Clerk’s Office at (408) 615-2220, emailing clerk@santaclaraca.gov, or visiting the public information desk at any City of Santa Clara public library.
In addition, the City developed a dedicated Special Event Zone webpage to provide ongoing updates, information, and FAQs, and created a subscription option to allow interested community members to receive notifications. Direct email outreach was also conducted to businesses located within the original proposed zone, as well as to all permitted mobile vendors citywide, to ensure broad awareness of the proposed ordinance and engagement opportunities.
RECOMMENDATION
Recommendation
Introduce an uncodified ordinance entitled “An Ordinance of the City of Santa Clara, California, Regulating Certain Activities within a Protected Area in Connection with Major Events and Related Activities in the City of Santa Clara,” with Map B, waive first reading, and direct staff to return for final adoption at the next regular meeting, with authority for the City Attorney to make non-substantive edits.
Staff
Reviewed by: Glen Googins, City Attorney
Approved by: Jovan Grogan, City Manager
ATTACHMENTS
1. RTC 25-1591
2. FAQs on Special Event Ordinance
3. Proposed Ordinance
4. Ordinance Comparison
5. Special Event Zone Map B
6. Special Event Zone Map A