CalHDF Midyear Enforcement Report

We at CalHDF have been hard at work enforcement state housing laws so far in 2025. This report outlines our work on enforcing state housing laws so far in 2025. While covering almost the entire state of California, we review local agendas for housing policies or developments to ensure cities and counties throughout the state comply with housing laws. In the first half of 2025, CalHDF accelerated our enforcement work compared with 2024. From the beginning of January to the end of May, CalHDF sent letters regarding 236 discrete projects and ordinances, totaling 20,478 housing units of which 6,105 are affordable. This represents almost as much housing (and as many projects) as we covered in all of 2024.

Our primary focus is still supporting the approval of housing development projects eligible for the protections of the Housing Accountability Act (“HAA”); we send local governments letters for virtually every HAA-eligible project that we find. One benefit of this line of work is that by submitting a public comment for the project prior to the hearing, we establish standing for CalHDF to litigate on behalf of the project pursuant to the HAA. With CalHDF ready to enforce the law, cities around California have an extra incentive to approve projects to avoid costly litigation. 

Our second most important monitoring activity is accessory dwelling unit (“ADU”) ordinances. We’ve submitted comments on 50 separate ADU ordinances so far this year (more than we commented on in all of 2024). As you’ll see below, 24 cities amended their ADU ordinances in response to our comments over the last six months. As the legislature continues to update state ADU laws to expand housing opportunities, CalHDF’s review of local ordinances ensure these changes are properly implemented at the local level. 

We have also begun to enforce state law that requires cities to compile application completeness checklists and post these lists on their webpages. We hired a new planning intern, Sophie Haugen (whom you may remember from her previous work as a comms intern with the org), who has been drafting letters to all the cities in the Bay Area, asking for copies of the cites’ checklists. So far we have sent letters to every municipality in Marin County asking for their application completeness checklists, and we are now moving onto cities in the South Bay. These completeness checklists help to ensure that the permitting process is predictable by informing applicants of the items that they need to submit. Cities routinely fail to comply with these requirements, then ask housing development applicants for additional documents and studies, prolonging and complicating the permitting process.

Our partnership with Listen Public has continued to bear fruit, as we have expanded our geographic coverage to monitor more and more of California. Listen Public is an AI-powered startup that facilitates transparency in government with an online tool that can monitor and report on local government agendas and other public documents. This tool has been primarily responsible for the growth in our enforcement work, as it has enabled CalHDF to find more actionable items from across the state – this makes our work vastly more efficient.

So far in 2025 we have submitted letters to the following 129 jurisdictions:

American Canyon, Anaheim, Arcadia, Baldwin Park, Beaumont, Belvedere, Berkeley, Beverly Hills, Burlingame, Calistoga, Carmel-by-the-Sea, Carlsbad, Ceres, Cerritos, Chico, Chino, Chowchilla, Claremont, Contra Costa County, Coronado, Corte Madera, Costa Mesa, Culver City, Cupertino, Dana Point, Danville, Eastvale, El Monte, Encinitas, Escondido, Fairfax, Fontana, Fort Bragg, Fountain Valley,  Fremont, Fresno, Fullerton, Gardena, Greenfield, Hayward, Hercules, Hesperia, Hidden Hills, Highland, Hollister,  Jurupa Valley, La Canada Flintridge, La Habra, Lafayette, Laguna Niguel, Larkspur, Livermore, Lodi, Los Altos, Los Altos Hills, Los Angeles, Los Gatos, Marin County, Martinez, Menlo Park, Mill Valley, Millbrae, Milpitas, Modesto, Monterey County, Monterey Park, Moraga, Morgan Hill, Mountain View, Napa, Newport Beach, Novato, Oakland, Oceanside, Orange, Orinda, Oxnard, Palo Alto, Palos Verdes Estates, Pinole, Pleasanton, Pomona, Rancho Santa Margarita, Redlands, Redwood City, Riverbank, Rolling Hills Estates, Ross, San Anselmo, San Bruno, San Carlos, San Diego, San Francisco, San Gabriel, San Jose, San Marino, San Rafael, San Ramon, Sanger, Santa Ana, Santa Clara, Santa Clarita, Santa Cruz, Santa Monica, Santa Rosa, Sausalito, Scotts Valley, Seaside, Simi Valley, Solana Beach, South Gate, South Pasadena, South San Francisco, Stockton, Sunnyvale, Temecula, Tiburon, Torrance, Tracy, Truckee, Tustin, Ukiah, Union City, Vacaville, Ventura, Walnut Creek, Westminster, Woodside, and Yorba Linda

We also have numerous examples of local jurisdictions approving projects and changing their proposed ordinances based on our advocacy. For instance:

  • Palos Verdes Estates removed its requirement for ADUs to have a deed restriction (Jan. 2025)
  • San Anselmo amended its ADU ordinance to the remove the owner-occupancy and  deed restriction requirements (Jan. 2025)
  • Hercules increased its height limits for exemption ADUs up to state law standards (Feb. 2025)
  • Fort Bragg relaxed lot coverage requirements for new, detached multifamily ADUs and allowed the 150 sf allowance for conversion ADUs (Feb. 2025)
  • Pinole amended its code to fully allow statewide exemptions ADUs pursuant to Government Code section 66323 and also eliminated its deed restriction requirement (Feb. 2025)
  • Costa Mesa amended its ADU ordinance to remove the requirement that ADUs comply with underlying zoning; to remove size limitations on new detached ADUs on multifamily parcels; to remove deed restriction requirements for ADUs; and to fully allow statewide exemption ADUs pursuant to Government Code section 66323. (Feb. 2025)
  • Culver City completely revised its ADU ordinance to bring it into compliance with state law, eliminating unlawful prohibitions on commercial space conversion, impermissible size and setback regulations, unlawful definition of existing structure, and impermissible design and review requirements. (Mar. 2025)
  • Sunnyvale amended its ADU ordinance to remove the requirements for historic resources alteration permit and tree removal permit for the removal of trees to facilitate ADU development. (Mar. 2025)
  • Fort Bragg removed unlawful size limits on conversion ADUs in multifamily buildings; relaxed its front setback requirement for 66323 ADUs; and allowed conversion of existing single-family homes into ADUs to ease timing issues. (Mar. 2025)
  • Arcadia amended its zoning code to remove a prohibition on ADUs on parcels that already have multiple accessory structures. (Mar. 2025)
  • Orinda amended its ADU ordinance to comply with state law: the city amended the code to allow both an ADU and a JADU within the primary dwelling; the city also amended its code to remove all discretionary review of ADUs. (Mar. 2025)
  • Fontana amended its ADU ordinance to remove the deed restriction requirement for ADUs (Apr. 2025)
  • Fairfax amended its ADU ordinance to remove size limits for conversions of existing space. (Apr. 2025)
  • Chico amended its ADU ordinance to allow an 800 square foot attached ADU no matter the size of primary dwelling. (Apr. 2025)
  • Greenfield amended its ADU ordinance to make it fully compliant with state law, in particular allowing all four categories of statewide exempt ADUs pursuant to Gov. Code section 66323 (Apr. 2025)
  • La Habra amended its ADU ordinance to allow section 66323 ADUs citywide and also exempt all ADUs under 750 square feet from impact fees. (May 2025)
  • Palo Alto amended its ADU ordinance to allow section 66323 ADUs in the front setback. (May 2025)
  • Sanger amended its ADU ordinance to exempt section 66323 ADUs from all local development standards and to allow eight detached ADUs on existing multifamily properties. (May 2025)
  • Berkeley amended its ADU ordinance to remove front setback restrictions, to allow eight ADUs in conjunction with existing multifamily dwellings, and to remove building to building separation requirements. (June 2025)
  • Fullerton amended its ADU ordinance to exempt ADUs under 750 square feet from impact fees. (June 2025)
  • Highland amended its ADU ordinance to remove the deed restriction requirement for ADU development. (June 2025)
  • Chowchilla amended its ADU ordinance to remove size limits for section 66323 ADUs on multifamily properties, to remove design requirements for section 66323 ADUs, to remove parking requirements for section 66323 ADUs, and to exempt ADUs under 750 square feet from impact fees. (June 2025)
  • Gardena amended its ADU ordinance to remove the deed restriction requirement for ADU development. (June 2025)
  • Oakland amended its ADU ordinance to exempt section 66323 ADUs from historic preservation requirements, to allow up to eight detached ADUs on multifamily parcels, to allow ADUs on multifamily parcels an additional two feet in height to match the roof pitch of the primary dwelling, and to relax the application of underlying standards to section 66323 ADUs on multifamily parcels. (June 2025) 
  • Lafayette amended its proposed objective design standards to remove non-objective regulations (Jan. 2025)
  • Millbrae approved a private activity bond issuance, required for 4% LIHTC financing, for a 97-unit, 100% affordable housing project, based on legal advocacy by CalHDF (Mar. 2025)
  • The City of Solvang sent a developer to CalHDF for assistance with combating a NIMBY lawsuit (Mar. 2025)
  • Redlands revised its SB 9 ordinance to eliminate a blanket ban on projects in fire zones and also eliminate height restrictions, outdoor deck restrictions, and setback requirements that applied only to SB 9 projects. (May 2025)
  • Santa Rosa complied with SB 330 by upzoning another residential parcel in order to compensate for rezoning a property from residential to industrial. (June 2025)
  • Ojai amended its proposed objective design standards to remove numerous state law violations, which had included new density limits, height limits, open space requirements, limitations on ADU development, and subjective design standards. (June 2024)
  • Santa Monica is proposing to eliminate its construction rate program, which imposed a local development moratorium with 500 feet of construction projects (June 2025)

We post all our enforcement letters at @housingdefense on Twitter and at @housingdefense.bsky.social on BlueSky, if you would like to follow along at home.