SB 684: Unlocking Infill Development in Los Angeles

Our team has been studying the details of SB 684, and we're excited to share a roadmap on this transformative new law.

There’s some important context to consider. Right now, just 9% of Millennials in LA own their homes—the lowest share of any city in the US. As Millennials now enter their peak earning years, SB 684's timing couldn't be better for developers ready to meet this cohort’s pent-up demand for homeownership.

Shifting the Status Quo

Think small detached bungalows, clustered townhomes, three-bedroom walk-ups—the sort of starter homes in short supply in the LA market. For qualifying sites, SB 684 allows 100% streamlined approval: no CEQA, no hearings, no appeals. Approvals can come in as few as 60 days.

To put this in perspective: we analyzed 46 recently-approved Small Lot Subdivision projects and found the average duration from start to finish—just for entitlements and the Vesting Tract Map, not including DBS Plan Check—was 24 months. SB 684 represents a dramatic acceleration versus the usual timeline for bringing this type of product to market.

How Do Sites Qualify?

The requirements can be a little prickly, but they're navigable:

✅ Zoned for multifamily use (including R2 zones)

✅ Under 5 acres in size

✅ Planned for 10 or fewer units (excluding ADUs)

✅ Located in an urban infill area

✅ Minimum lot size of 600 square feet

✅ Average unit size of 1,750 square feet or less post-subdivision

✅ No Ellis Act evictions within the past 15 years

✅ No rent-controlled or deed-restricted units

✅ No units occupied by renters within the last five years

What Does SB 684 Mean For Your Project?

● Streamlined Approvals: Projects can get approved within as few as 60 days with no public hearings or discretionary review.

● CEQA Exemption: Eligible projects are exempt from California Environmental Quality Act (CEQA) requirements.

● Density Boosts: Projects can combine SB 684 approvals with Accessory Dwelling Units (ADUs) to maximize unit counts.

● Fee-Simple Ownership: Projects can flexibly deploy strategies to either rent units, sell units individually, or some combination of the two.

● ‘Objective’ Development Standards: Cities cannot put standards on projects that would prevent their development at the proposed density.

How Recent Is This?

● The new rules went into effect on July 1, 2024.

Development Standards

SB 684 overrides several key zoning standards that cities could otherwise use to thwart subdivision projects.

Density & Design

● Minimum 30 units per acre

● Maximum 4-foot side and rear setbacks, with regular front setbacks^[1]

● No parking required if within 1/2 mile of a major transit stop or high-quality transit corridor, or within 1 block of carshare service

● Maximum 1 space per unit otherwise, with no covered parking needed

● No passageway requirements can apply (beyond those required by LA DBS)

^[1] SB 1123 is a ‘clean-up’ bill for SB 684 adopted at the end of the recently-concluded legislative session, in September. The new bill will, among other things, relieve projects from any requirement to comply with otherwise applicable frontage standards. SB 1123 will become effective July 1, 2025.

The ADU Strategy

LA’s implementation of SB 684 gives developers some helpful optionality when it comes to being able to construct ADUs alongside the streamlined subdivision process:

● Small Lot Style: 1 attached ADU/JADU per new unit—perfect for townhome-style projects up to 10 units

● Condo Style: Multiple attached/detached ADUs allowed—more flexible than the small lot approach

Note: the legislative text of SB 684 preserved the authority of cities to decide whether and how they would allow ADUs on parcels created under its streamlining provisions. LA opted to accommodate ADUs in SB 684 projects; however, not every other city is likely to follow the same tack.

Process & Timeline

SB 684’s timeline is standardized. The process operates on a 60-day review clock, with projects deemed approved if no action is taken at the end of that 60-day window. An additional 60-day review period may apply if a City returns to the applicant a list that clearly explains any application deficiencies and outlines the steps necessary to remedy them. In total, we’d expect the process to take no longer than 120 days. No public hearings are required (except in Coastal Zones), and there is no appeals process.

Standard fees still would apply:

● Park fees ($8,400/unit)

● School fees ($4.08/sq ft)

● AHLF fees (varies by area)

● Plan check, permit, and utility fees

Be sure to budget a 30% contingency for any surprise fees.

Housing Element Considerations

If your site is listed in the local Housing Element document, you must build out the site to the minimum capacity indicated. ADUs can be used to meet these minimums. For most projects it will not be an issue to meet these minimum density requirements.

Additionally, the APNs of some sites also appear on cities’ Housing Element documents. These sites will be required to set aside one or more affordable units based on the allocation they previously reported to the State’s housing office (HCD). Affordability requirements will run for 45 years. Contact us to verify any such conditions which may apply.

Discovering SB 684 Value in Cities Beyond LA

The JDJ team has already built a lot of expertise around LA’s local implementation of SB 684. But we also are excited to look beyond LA’s borders, to nearby cities where incomes are higher and housing inventory may be even more constrained.

We’ve included something special in today’s Newsletter: our team has put together a list of several candidate sites within the City of Santa Monica which are likely to qualify for SB 684 streamlining.

Santa Monica is a high-resource submarket. The identity of these sites could be valuable to some. Readers should treat these as live-wire opportunities, and move quickly if they are in a position to do so.

Santa Monica SB 684 Sites

● 1008 18TH ST

● 2102 VIRGINIA AVE

● 1302 YALE ST

● 2832 ARIZONA AV

● 1124 26TH ST

● 1132 26TH ST

● 2020 CALIFORNIA AVE

● 2022 CALIFORNIA AVE

Note: a couple of double lots are listed above (~6,000 square feet each). Potential for side-by-side development of ~6-8 units each (~15 total units) featuring shared driveway. Viability will depend on specific spatial constraints.

Environmental Restrictions

SB 684 cannot be used on sites that are:

● Prime farmland

● Wetlands

● Very high fire hazard zones

● Conservation areas

● Protected species habitats

● Under conservation easements

● Also, special studies may also apply to fault zones, flood zones, or hazardous site

Strategic Advantages vs. Traditional Process

Compared to the standard discretionary review process, SB 684 offers several key advantages:

Time Savings

● No CEQA requirements

● No public hearings or appeals process

● 60-day processing timeline

● Early start permits available

Cost Savings

● Reduced soft costs

● Less carrying costs

● Parking reductions

● Density increases

● Flexible disposition (including fee-simple condos)

Opportunities Accretive to Value

Based on our analysis, the most compelling opportunities lie in:

● R2 zone sites near transit

● Somewhat larger lots which could accommodate more than 10 parcels, and are able to gross up buildable area to fit out the site by situating ADUs next to each townhome

● Sites in gentrifying areas where land value doesn’t yet justify undergrounding parking, but demand for fee simple townhomes is strong

● Areas with complex development overlays

● Sites in High Resource neighborhoods in cities across California

● Sites in primarily single-family neighborhoods peppered with low-density MF, where any proposed project automatically triggers significant pushback from the local community.

The Double Bottom Line

SB 684 creates a powerful new pathway for small and mid-size developers to unlock the potential infill subdivision projects—and streamline the approval process so it’s both quicker and involves less risk than ever before. Given the current macro environment of historically tight supply of attainable for-sale product, particularly in more highly-resourced and centrally-located areas of greater LA, the timing could hardly be better.

With interest rates beginning to moderate, now is the time to position your development strategy. Contact our office for a complimentary zoning assessment of any site that looks like it could be a good fit.

Important Note: While we've made preliminary determinations about site qualification, we have not performed detailed vetting. Until we've confirmed all applicable standards and requirements to our satisfaction, we make no warranty about investment viability based on information referenced here.

^[1] SB 1123 is a ‘clean-up’ bill for SB 684 adopted at the end of the recently-concluded legislative session, in September. The new bill will, among other things, relieve projects from any requirement to comply with otherwise applicable frontage standards. SB 1123 will become effective July 1,