CED Committee
September 22, 2026
AGENDA REPORT
TO: Elizabeth Lake FROM: William Gilchrist
Interim City Administrator Director, Planning and
Building
SUBJECT: S-8 (SB 79) Amendments DATE: August 26, 2026
City Administrator Approval Date:
RECOMMENDATION
Staff Recommends That The City Council Conduct A Public Hearing And, Upon Conclusion, Adopt An Ordinance As Recommended By The Planning Commission:
1. Amending Oakland Municipal Code Title 17 (The Planning Code) Chapter 17.86 S-8 Abundant and Affordable Homes Near Transit (Senate Bill 79) Combining Zone Regulations To Address Comments Received from California Department of Housing and Community Development;
2. Amending The Planning Code Chapter 17.86 To Exclude Additional Industrial Zoned Parcels Previously Designated as Ineligible for SB 79 Within The Areas That Were Not Previously Excluded;
3. Making Related Oakland Zoning Map Amendments to Update Parcels Designated Within The S-8 Combining Zone And To Update Identification Of Whether Such Designated Parcels Are Excluded From The Senate Bill 79 Property Development Standards; And
4. Making Appropriate California Environmental Quality Act Findings.
EXECUTIVE SUMMARY
On March 16, 2026, the Oakland City Council adopted Ordinance No. 138751, amending Oakland Municipal Code Title 17 (Planning Code) to establish new regulations implementing Senate Bill 79 (SB 79/Abundant and Affordable Homes Near Transit Act). Specifically, the ordinance temporarily excluded certain Transit-Oriented Development (TOD) zones and individual parcels from SB 79 property development standards to secure the necessary time for the City of Oakland (City) to develop an Alternative Plan and to coordinate this work with the General Plan Update Phase 2, which is currently underway. The future Alternative Plan will 1 Ordinance No. 13875 C.M.S. can be accessed directly via link here:
https://oakland.legistar.com/View.ashx?M=F&ID=15326359&GUID=7D357213-644C-45DE-912B6A5942EA1151 Elizabeth Lake (Sep 10, 2026 14:49:30 PDT) Sep 10, 2026 Elizabeth Lake, Acting City Administrator
Subject: S-8 (SB 79) Amendments
Date: August 26, 2026 Page 2
CED Committee
September 22, 2026
allow the City to tailor height and density rules to specific local conditions while still meeting the overall aggregate density required by SB 79.
On June 12, 2026, the California Department of Housing and Community Development (State HCD) issued a Findings Letter regarding City Ordinance No. 13875, which established the S-8 Abundant and Affordable Homes Near Transit (Senate Bill 79) Combining Zone. After reviewing the Ordinance and staff’s supporting data, State HCD concluded that the City's implementing framework is not in full compliance with SB 79 due to different interpretations of eligibility of Oakland’s Open Space and Industrial Zones.
To achieve full state compliance, staff is proposing targeted amendments to the City’s ordinance implementing Senate Bill 79. These amendments directly address State HCD’s comments, incorporate missing transit stops identified by the Metropolitan Transportation Commission (MTC), as well as aligning minor discrepancies between local and regional maps, and correct minor clerical errors.
BACKGROUND / LEGISLATIVE HISTORY
The Abundant and Affordable Homes near Transit Act (commonly known as Senate Bill 79 or SB 79) was introduced in 2025 and became effective on July 1, 2026. This State law mandates increased density, height, and Floor Area Ratios (FAR) for housing developments within a half mile of designated transit stops, collectively known as Transit-Oriented Development (TOD) zones.
SB 79 categorizes local transit stops into two tiers. Because half-mile radiuses cross city borders, Oakland's affected zones include stops located both inside and just outside the city limits:
• Tier 1 (Heavy Rail / BART): Applies to 9 total zones (8 Oakland BART stations + 1 overlapping from Ashby BART).
• Tier 2 (Bus Rapid Transit / Tempo): Applies to 39 total zones (38 AC Transit Tempo stops in Oakland + 1 overlapping from the Durant Ave stop).
SB 79 prohibits local governments from imposing height limits or maximum densities lower than the state's specified minimums within these zones. Furthermore, developers can stack the State density bonus on top of these SB 79 baselines to achieve even greater height and density. The mandated baselines depend on the transit tier and distance from the stop, as shown below.
Elizabeth Lake, Acting City Administrator
Subject: S-8 (SB 79) Amendments
Date: August 26, 2026 Page 3
CED Committee
September 22, 2026
Table 1: SB 79 Density Standards
Tier Distance from Stop Height Limit* Max Density
Tier 1
Adjacent (200 feet) 95 feet 160 du/ac
Quarter mile 75 feet 120 du/ac
Half mile 65 feet 100 du/ac
Tier 2 Adjacent (200 feet) 85 feet 140 du/ac
Quarter mile 65 feet 100 du/ac
Half mile 65 feet 80 du/ac
*Note: Projects may build up to the SB 79 height limit or the local height limits, whichever is higher.
The City adopted Planning Code Chapter 17.86 as its local SB 79 implementation ordinance on March 16, 2026, well in advance of the 90-day window prior to the law's July 1 effective date.
The Planning Code Chapter 17.86, which implemented Ordinance No. 138752, did the following:
• Excluded parcels that met at least 50% of the density required by SB 79 in low-resource areas,3 except for areas East of Lake Merritt and in the San Antonio neighborhood as well as areas around the Coliseum BART stations as these areas were removed from exclusion by City Council.
• Excluded most of the TOD zones that fall within a low-resource area and met at least 40% of the density required by SB 79, except for areas East of Lake Merritt and in the San Antonio neighborhood as well as areas around the Coliseum BART stations as these areas were removed from exclusion by City Council. • Excluded all Local Register Historic Resources within all areas that are eligible for SB
79. Staff determined that creating a comprehensive Alternative Plan was not feasible before the July 1, 2026 deadline. Therefore, the City adopted temporary exclusions to secure the necessary time to develop an Alternative Plan and to coordinate this work with the General Plan Update Phase 2 that is currently underway. The future Alternative Plan will allow the City to tailor height and density rules to specific local conditions while still meeting the overall aggregate density required by SB 79.
Prior City Council Hearing
2 Ordinance No. 13875 C.M.S. can be accessed directly via link here:
https://oakland.legistar.com/View.ashx?M=F&ID=15326359&GUID=7D357213-644C-45DE-912B6A5942EA1151 3 A low-resource area is a designation created by the State of California Tax Credit Allocation Committee and Department of Housing and Community Development as a component of the state opportunity area maps. The State first created the opportunity maps in 2017 to inform how to award low-income housing tax credits and have since annually updated the maps. The opportunity maps score neighborhoods across eight economic and educational indicators, plus one environmental burden indicator, and designate areas as low-, moderate-, high-, and highest resource depending on the score relative to other neighborhoods in the same region.
Elizabeth Lake, Acting City Administrator
Subject: S-8 (SB 79) Amendments
Date: August 26, 2026 Page 4
CED Committee
September 22, 2026
On March 16, 2026, the Oakland City Council adopted amendments to Oakland Municipal Code Title 17 (Planning Code) to establish a new chapter: 17.86 S-8 Abundant and Affordable Homes Near Transit (Senate Bill 79) Combining Zone Regulations.
Prior to this adoption, staff conducted extensive research on local transit stops to establish appropriate TOD zones and to analyze how the bill would impact Oakland. This initial analysis proposed excluding certain TOD zones, as well as individual parcels, from SB 79 property development standards.
During deliberation on March 3, 2026, the City Council requested that certain TOD zones be removed from the exclusion list to accommodate higher-density residential development pursuant to SB 79. These removed exclusions were largely located in the Rockridge, Lake Merritt/San Antonio, and Coliseum BART station areas.
Specifically, the City Council passed a motion to amend the ordinance to allow SB 79 standards in the following areas:
• North Oakland: Parcels within a half mile of the Ashby, MacArthur, and Rockridge BART stations were removed from the exclusion for sites meeting SB 79’s 50% density threshold. Because these TOD Zones are in high-resource areas,4 they do not qualify for exclusion under SB 79 even if they meet the 40% overall density requirement. • Lake Merritt: The Lake Merritt BART station and specific AC Transit TOD Zones (Maps 16-28) were removed from the exclusion for parcels meeting at least the 40% density requirement of SB 79 in low-resource areas. In addition, all parcels between Lake Merritt (including the Lake Merritt Channel) and 25th Avenue that are zoned to provide maximum densities and residential FAR exceeding 50% of SB 79 standards are subject to SB 79.
• Deep East Oakland: Removed exclusions for parcels meeting the 40% density requirement of SB 79 for the Coliseum BART Station TOD Zone and AC Transit TEMPO TOD Zones at Seminary, 63rd Ave, 67th Ave, 73rd Ave, 77th Ave, and 82nd Ave. • 66th Avenue to Hegenberger Road: Removed these parcels from being excluded from using SB 79 that are located between 66th Avenue and Hegenberger Road that met the 50% density requirements of SB 79 are subject to SB 79. • For all of the areas listed above, parcels designated as Local Register Historic Resources remain excluded from SB 79 property standards.
The exact motion language from March 3, 2026 can be found in Attachment A: Excerpt from Meeting Minutes from the City Council hearing on March 3, 2026.
Planning Commission Action on the Proposed Amendments
4 A high-resource area means an area designated as highest resource or high resource on the most recently adopted version of the opportunity area maps published by the California Tax Credit Allocation Committee and the department.
Elizabeth Lake, Acting City Administrator
Subject: S-8 (SB 79) Amendments
Date: August 26, 2026 Page 5
CED Committee
September 22, 2026
On September 2, 2026, staff presented the proposed amendments to the Planning Code Chapter 17.86 and Zoning Map to the Planning Commission. The Planning Commission unanimously approved forwarding the staff recommendation to the City Council for adoption, without modifications.
ANALYSIS AND POLICY ALTERNATIVES
As the regional Metropolitan Planning Organization, MTC is required to provide a regional map to assist Bay Area jurisdictions in implementing SB 79. MTC shared a preliminary draft regional map on April 8, 2026. Because MTC’s mapping effort occurred after Oakland’s implementation of SB 79, Oakland staff identified minor discrepancies between the local and regional maps and informed MTC on May 1, 2026.
On June 10, 2026, MTC responded to Oakland’s comments that MTC understood that while the mapping discrepancies were minor, they needed to continue to utilize their half-mile buffers in order to be consistent regionwide in their methodology for determining the access points for BART stations. MTC also noted that they had identified additional AC Transit stops associated with the Uptown Transit Center qualify as “stops served by frequent service” that will be added to the regional map. The final regional map with the incorporated changes was released by the effective date of SB 79, July 1, 2026. Staff has been able to prepare this request for amendment.
State HCD concluded in its June 12, 2026 Findings Letter that upon review of the City’s Ordinance and staff’s supporting data that the City's current framework needed to be brought into full compliance with their interpretation of SB 79 for reasons detailed in the subsections below.
To achieve full state compliance, staff proposes targeted amendments to the Ordinance. These amendments directly address State HCD’s comments, incorporate required transit stops identified by MTC as well as aligning minor discrepancies between local and regional maps, and correct minor clerical errors.
Industrial and Open Space Zones
The majority of State HCD’s findings relate to a strict interpretation of Government Code Section 65912.157(a), which mandates that housing developments be allowed on sites zoned for “residential, mixed, or commercial development” near transit stops. While the statute does not explicitly define what constitutes “mixed” or “commercial” uses, State HCD is enforcing a broad interpretation: if a parcel’s zoning allows any residential or commercial uses along with another use, then it is considered a mixed-use zone and is subject to SB 79 standards. Therefore, since Oakland’s industrial zones allow for certain commercial uses, they are considered mixed use zones and since Oakland’s Open Space Zones also allow for certain commercial uses, they are considered mixed use zones. Because Oakland’s Industrial and Open Space Zones are Elizabeth Lake, Acting City Administrator
Subject: S-8 (SB 79) Amendments
Date: August 26, 2026 Page 6
CED Committee
September 22, 2026
considered to be mixed use zones, State HCD has determined that SB 79 applies and parcels that have that zoning designation must be considered eligible.
To comply with this directive, staff updated Chapter 17.86 S-8 Abundant and Affordable Homes Near Transit (Senate Bill 79) Combining Zone in the Planning Code to amend Planning Code Section 17.86.050 Eligibility to add “Parcels over which the City of Oakland Planning Bureau does not have zoning authority” as one of ineligible sites, and to remove the following zones that were originally listed as ineligible:
• OS Open Space Zoning Designations
• M-40 Industrial Zone Designations
• CIX, IG, and IO Industrial Zone Designations
• D-CE-5, D-CE-6 Central Estuary District Industrial Zone Designations • D-GI Gateway District Industrial Zone Designations
• D-CO-5, D-CO-6 Coliseum Area Industrial Zone Designations • D-DT-JLI Downtown District Jack London Industrial Zone Designations Staff has removed any parcels zoned Open Space (OS) or Industrial (M-40, CIX’s, IG, IO, DCE-5, D-CE-6, D-GI, D-CO-5, D-CO-6, and D-DT-JLI) from the ineligible list, and have designated them as “Excluded” if they fall within an adopted exclusion or “Covered” if they have do not fall within an adopted exclusion. The newly eligible parcels have been incorporated into a revised S-8 Combining District and Eligibility Map, and it can be found in Exhibit B of the Ordinance: Updated S-8 Combining District and Eligibility Map.
In addition, staff is proposing to designate any industrial zoned parcels that did not fall within a previously adopted exclusion as “Excluded.” This approach preserves the City’s industrial land supply, upholds current zoning restrictions, and prevents the environmental and land-use incompatibility issues that arise when housing is mixed with industrial operations. Any potential changes to the zoning or permitted uses of these industrial parcels will be deferred and comprehensively evaluated as part of the General Plan Update Phase 2 process. See Exhibit C of the Ordinance: Newly Excluded Industrial Parcels for maps showing the industrial zoned parcels now proposed to be excluded. The exhibit illustrates two areas in the city -- one near waterfront area near 14th Avenue and another around the Coliseum area -- where industrialzoned parcels are now designated as “Excluded” in TOD zones that were previously removed from the exclusion list.
Impact on Housing Capacity
To ensure these changes do not affect the requirement to meet 40% density of SB 79 density requirements, staff recalculated the density allowance for each TOD zone. Even with the addition of these open space and industrial parcels, the density capacity for all applicable TOD zones remains above the 40 percent threshold required to maintain the low-resource area Exclusions allowed under SB 79 (Attachment B: Analysis of Housing Capacity Based on Oakland Zoning Compared to SB 79 Standards for Additional TOD Zones).
Elizabeth Lake, Acting City Administrator
Subject: S-8 (SB 79) Amendments
Date: August 26, 2026 Page 7
CED Committee
September 22, 2026
Only one TOD zone, AC Transit TEMPO 14th Avenue Southbound Stop, fell below the 40 percent density capacity due to these changes. However, because this specific TOD Zone was already removed from the excluded list via prior City Council amendments, this drop will not affect the overall SB 79 implementation.
As stated above, staff has designated these newly added parcels as “Excluded” or “Covered” to comply with the State HCD’s comment letter. Moving forward, staff is working on an Alternative Plan in conjunction with its General Plan Update Phase 2 process that allows the City to tailor height and density rules to specific local conditions, while still meeting the aggregate density requirements of SB 79.
New Transit Stops Added
Following the release of MTC’s preliminary draft SB 79 regional map, staff submitted a memorandum requesting to reconcile the regional dataset with the local one. The local dataset incorporates extensive research and reflects real-world access points for both tier 1 and tier 2 transit stops. After reviewing the data with transit providers such as Bay Area Rapid Transit (BART) and Alameda-Contra Costa Transit District (AC Transit), MTC responded that its dataset will remain unchanged, stating it is “required to apply a consistent regional methodology.” However, as part of its evaluation with local agencies, MTC did identify and update its dataset to include “additional stops at the Uptown Transit Center and stops served by frequent service”, as well as one missing entrance at the 12th Street BART station that it found after evaluating Oakland’s dataset.
In response to MTC comments, staff has since added these missing access points and their corresponding buffers. After evaluating the parcels within these new buffers, staff determined that all four stops are TOD zones that can be excluded, as their TOD zone density remains above 40 percent. The map analysis and density calculations for these missing TOD zones are available in Attachment C and incorporated into Exhibit D to the Ordinance. The related text changes are reflected in Exhibit A of the Ordinance, under Subsection 17.86.030 (Tier 1 and Tier 2 Transit Oriented Development Stops), which adds the Uptown Transit Center as an eligible Tier 2 transit stop, and under Subsection 17.86.060(B) (Exclusions), which adds four additional Uptown Transit Center stops to the low-resource area exclusion list.
Additionally, staff adjusted the dataset to align with the regional dataset, shifting TOD zones negligibly. This change is reflected in the updated S-8 Combining District and Eligibility Map in Exhibit B of the Ordinance.
Other Miscellaneous Amendments
As part of their review, State HCD identified, which then staff confirmed, a clerical error in Planning Code Section 17.86.060(B) (Exclusions). This section mistakenly lists Map 28 (AC Transit TEMPO 20th Avenue Stop) as an excluded TOD zone. The City Council previously removed this map to allow parcels within the 20th Avenue TOD zone, that are not otherwise excluded, to utilize SB 79. The proposed Ordinance amendment removes the reference to this Elizabeth Lake, Acting City Administrator
Subject: S-8 (SB 79) Amendments
Date: August 26, 2026 Page 8
CED Committee
September 22, 2026
stop. This correction has already been incorporated and is currently reflected on the City’s S-8 Combining District and Eligibility Map.5
Summary of Staff Recommendations
To bring the City’s previously adopted Ordinance, which was adopted on March 16, 2026, into full compliance with SB 79, staff recommends the following targeted amendments to Planning Code Chapter 17.86 and updates to the zoning map associated with the S-8 Combining Zone:
Planning Code amendments:
• Remove Open Space and Industrial Zones from the Eligibility Section (Section
17.86.050).
• Update Section 17.86.060(B) to exclude previously ineligible industrial parcels that were not part of an existing exclusion.
• Update Sections 17.86.030 and 17.86.060(B) to reflect the added eligible Tier 2 transit stop, Uptown Transit Center.
• Correct a clerical error (removing the reference to Map 28 (Section 17.86.060(B)) Zoning Map amendments:
• Update the S-8 map to designate these Open Space and Industrial parcels as either “Covered” or “Excluded” (Exhibit B of the Ordinance). All industrially zoned parcels, however, are designated as “Excluded” (Exhibit B and C of the Ordinance). • Add four AC Transit stops associated with the Uptown Transit Center as excluded TOD zones (Attachment C and Exhibit D of the Ordinance).
• Align Oakland’s SB 79 dataset to MTC’s regional dataset, which will result in negligible shifts in TOD zones (Exhibit B of the Ordinance).
RELATED PLANNING EFFORTS (Include All Applicable Plans) This agenda item is a routine reconciliation of Planning Code Changes and does not impact any Oakland Strategic Planning efforts.
FISCAL IMPACT
Implementation of these amendments to Oakland Planning Code Chapter 17.86 will be a component of the existing approval process for development projects administered by the Planning and Building Department, which collects fees for such review and approvals as established in the Master Fee Schedule. Staff will inform the public of the updated regulations as part of all applicable inquiries and apply the updated regulations as part of all applicable 5 The S-8 Combining District and Eligibility map is available on the SB 79: Transit-Oriented Housing in Oakland project page at www.oaklandca.gov/sb79. The map can be directly accessed via the following link:
https://oakgis.maps.arcgis.com/apps/mapviewer/index.html?webmap=53d0a204f8ad451f9d9b748a1ebbf 563
Elizabeth Lake, Acting City Administrator
Subject: S-8 (SB 79) Amendments
Date: August 26, 2026 Page 9
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September 22, 2026
planning and building permit applications. Staff will also update any applicable application materials including summaries and guides using internal resources and staff time.
PUBLIC OUTREACH / INTEREST
The proposed ordinance brings the City’s Planning Code into compliance with State law as established by SB 79. A public hearing was conducted by the Planning Commission on September 2, 2026. The meeting was noticed in the Oakland Tribune on August 14, 2026.
COORDINATION
Planning staff, in consultation with the City Attorney’s Office and coordination with State HCD, prepared the proposed ordinance amendments to reflect the comment letter and follow-up discussions from State HCD after their review of the original ordinance, which was adopted by the City Council on March 16, 2026.
RACE AND EQUITY
The City’s Environmental Justice (EJ) Element “serves as the foundation for achieving equity and environmental justice when planning for future growth and development in Oakland.” The EJ Element identifies communities that are disproportionately impacted by environmental justice issues, and proposes goals, policies, and objectives to reduce the unique or compounded health risks in these communities. It also contains a comprehensive table of actions to achieve those goals and objectives, many of which have already been implemented. • Policy EJ-7.1 Complete Neighborhoods. Promote “complete neighborhoods” -- where residents have safe and convenient access to goods and services on a daily or regular basis -- that address unique neighborhood needs, and support physical activity, including walking, bicycling, active transportation, recreation, and active play.
Staff Analysis: The recommended exclusions will allow additional time in low-resource areas to update the City’s development regulations and consider how “complete neighborhoods” that address community needs and services can be provided in conjunction with new housing.
• Policy EJ-7.2 Accessible Neighborhoods. Encourage active modes of transportation and transit accessibility by supporting neighborhoods that provide access to a range of daily goods, services, and recreational resources within comfortable walking or biking distance. Encourage transit providers to prioritize, establish and maintain routes to jobs, shopping, schools, parks and healthcare facilities that are convenient to EJ Communities.
Elizabeth Lake, Acting City Administrator
Subject: S-8 (SB 79) Amendments
Date: August 26, 2026 Page 10
CED Committee
September 22, 2026
Staff Analysis: The Environmental Justice Element defers Policy EJ-A.26 to Phase 2 of the General Plan Update to promote walkable, car-independent neighborhoods through detailed land-use planning. Adopting the recommended exclusions supports this strategy by folding the state-mandated SB 79 density requirements into the ongoing local update process. Ultimately, this approach allows the city to carefully analyze and integrate denser housing in a way that supports existing neighborhood structures while ensuring ample opportunity for community input.
• Policy EJ-8.1 Meaningful, Relevant Engagement. Design and implement public engagement processes and events that emphasize participation from low-income communities and communities of color; that are driven by resident priorities, that are easily accessible and understandable and that provide meaningful opportunities for participants to influence outcomes.
Staff Analysis: While SB 79 development densities incentivize much-needed housing, immediate implementation of these state regulations requires careful local oversight, as the majority of the City's transit stops and TOD zones are located in low-resource areas.
To best serve Policy EJ 8.1 of the Environmental Justice Element, these areas should be excluded from immediate SB 79 standards and evaluated instead through the General Plan Update process. Deferring implementation allows for a more equitable approach by ensuring that local residents, particularly communities of color, have meaningful opportunities to provide public input on how these new housing developments will impact their neighborhoods.
CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
The proposed Planning Code and Zoning Map amendments are statutorily exempt from California Environmental Quality Act under Government Code Section 65912.160(c)(2).
ACTION REQUESTED OF THE CITY COUNCIL
Staff Recommends that the City Council conduct a public hearing and, upon conclusion, adopt an ordinance as recommended by the Planning Commission:
1. Amending Oakland Municipal Code Title 17 (The Planning Code) Chapter 17.86 S-8 Abundant and Affordable Homes Near Transit (Senate Bill 79) Combining Zone Regulations To Address Comments Received from California Department of Housing and Community Development;
2. Amending The Planning Code Chapter 17.86 To Exclude Additional Industrial Zoned Parcels Previously Designated as Ineligible for SB 79 Within The Areas That Were Not Previously Excluded
3. Making Related Oakland Zoning Map Amendments to Update Parcels Designated Within The S-8 Combining Zone And To Update Identification Of Whether Such Designated Parcels Are Excluded From The Senate Bill 79 Property Development Standards; And
Elizabeth Lake, Acting City Administrator
Subject: S-8 (SB 79) Amendments
Date: August 26, 2026 Page 11
CED Committee
September 22, 2026
4. Making Appropriate California Environmental Quality Act Findings.
For questions regarding this report, please contact KELLY CHA, PLANNER IV, at (510) 238- 2166.
Respectfully submitted,
William Gilchrist (Sep 8, 2026 12:53:15 PDT)
WILLIAM GILCHRIST
Director, Planning and Building Department
Reviewed by:
Ed Manasse, Deputy Director, Planning Bureau
Laura Kaminski, Strategic Planning Manager
Prepared by:
Kelly Cha, Planner IV
Planning Bureau
Attachments (3):
A: Excerpt from Meeting Minutes from the City Council hearing on March 3, 2026 B: Analysis of Housing Capacity Based on Oakland Zoning Compared to SB 79 Standards for Additional TOD Zones
C: Added New Transit Maps (Maps 49-52) and Density Capacity Analysis