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A judge in Stanislaus County has relied heavily on the U.S. Supreme Court’s Sheetz case to strike down the City of Patterson’s newly updated impact fees.

This article is brought to you courtesy of the paying subscribers to  California Planning & Development Report . You can subscribe to  CP&DR  by clicking  here . You can sign up for  CP&DR ’s free weekly newsletter  here . Los Angeles Seeks to Promote "Missing Middle" Housing The Los Angeles Department of City Planning launched  the Missing Middle LA program to expand housing options by making it easier to build smaller, neighborhood-scale homes such as accessory dwelling units, duplexes, townhomes, and other “missing middle” housing types across the city’s residential zones. The median home cost in Los Angeles is over $1 million, and only 36% of Angelenos own a home. Missing Middle attempts to address the rising cost of living by creating infill housing. The initiative will implement targeted zoning code amendments organized around three pillars: updating rules to allow the sale of ADUs and implement state two-unit provisions, revising small-lot subdivision regulations to enable a range of ownership models, and creating objective design standards. Draft ordinances are expected to be released for public review, with community outreach planned to gather input and refine proposals before formal hearings and adoption. Federal Government Releases Details on Leases of Over 1 Million Acres for Extraction  The U.S. Bureau of Land Management is proposing  to lease 1 million acres of public land in California to oil and gas developers. The report claims that the environmental impact is minimal, though The Center for Biological Diversity sued the federal agency over similar previous proposals, leading to a settlement in 2022 and agreement that development would be halted until an additional environmental review. Despite this agreement, the new report analyzed no new alternatives, and attorneys for the Center say the science used in more recent reports is out of date. The proposal seeks to lease over 400,000 acres of surface land throughout central California, plus over 1 million acres of underground mineral estate. The proposal could include acreage in parks and conservation areas, including Pinnacles National Park and Mount Diablo State Park. San Francisco to Merge Development-Related Departments San Francisco plans  to consolidate its Department of Building Inspection, Planning Department and PermitSF into a single entity. San Francisco is one of the few large California cities that currently keeps building inspection and planning fully separate. The merger is targeted for completion by mid-2027, but will first require changes to the city charter and approval by voters. The move comes amid long-standing issues with the Department of Building Inspection, which has been working to overcome past corruption scandals and challenges posed by outdated software systems that are incompatible with other departments. The proposed consolidation of building and permitting into one entity reflects broader efforts within San Francisco to keep up with housing mandates by helping move stalled development projects forward and shortening lengthy permitting timelines. Pro-Housing Groups Sue to Compel San Francisco to Upzone YIMBY Law, California Housing Defense Fund (CalHDF) and Californians for Homeownership filed  a lawsuit against San Francisco regarding the recently adopted Family Zoning Plan. The lawsuit argues that the city is in violation of state housing requirements in their failure to zone enough land to meet its legal obligation to enable at least 36,000 new homes, instead adopting a plan that would produce far fewer units. The law also creates new constraints on unit size, parking, and curb cuts for new developments, which the plaintiffs claim will slow housing production further. The lawsuit alleges that the city is also out of compliance with density standards and non-residential use limits for lower-income housing. Two Housing Bills Advance in Congress The House of Representatives passed  the bipartisan Housing for the 21st Century Act by 390-9. The bill aims to speed up housing development, sharing many similarities with last year’s Renewing Opportunity in the American Dream to Housing Act. It also directs the Department of Housing and Urban Development to create guidelines for local officials in zoning and to create preapproved designs to streamline permit approval. The bill also revises the definition of manufactured housing, removing the previously required steel chassis. The two measures are expected to be combined before being sent to the president in a few weeks. While the Trump administration supports the bill’s general direction, it noted the absence of a proposal to restrict large institutional investors from purchasing single-family homes. Another bipartisan housing bill known as The Build Housing, Unlock Benefits and Services Act (Build HUBS) was introduced  in Congress with aims to encourage development near transit. It would make TIFIA and RRIF more available for transit-oriented development (TOD) projects by extending their authorization through 2031 and clarifying what qualifies as TOD. The bill also aims to accelerate review timelines, implement a lending model that retains federal oversight while utilizing private involvement, and waive certain environmental review requirements for specific infill and conversion projects. CP&DR Coverage: Affluent Communities Still Fight Builder's Remedy Projects Builder’s remedy projects continue to generate controversy  in affluent communities around the state – and the whole process has now received national publicity. Much of the debate is focused in the expensive but traditionally low-rise communities in Silicon Valley. Most recently, Mountain View approved a 15-story builder’s remedy project. Meanwhile, Menlo Park has – so far – rejected a builder’s remedy project on the iconic Sunset Magazine headquarters site because, the city says, only 61% of the site is devoted to residential, rather than two-thirds. In Beverly Hills, the planning commission rejected a 26-story housing project but the developer has appealed to the city council, saying the city has no choice but to approve the project because it did not have a valid housing element at the time the project was submitted. Quick Hits & Updates California Forever   signed  what it describes as the largest construction labor agreement in history, a 40-year deal with the Napa/Solano Building Trades Council and the Northern California Carpenters Union covering nearly 70,000 acres in Solano County. The pact mandates that most construction on the site, including infrastructure, public works, major commercial, office, retail, industrial, defense and energy projects, will be done by union labor under project labor agreements. (See related CP&DR coverage .) The Washoe Tribe  of Nevada and California has purchased  10,000 acres north of Lake Tahoe from the city of Santa Clara for $6 million, 175 years after the tribe was forced to leave the lands in the wake of the Gold Rush. The Wildlife Conservation Board contributed $5.5 million toward the deal, with the rest of the funding coming from private donations with fundraising efforts aided by the Northern Sierra Partnership and the Feather River Land Trust. California’s fire safety regulators are more than a month late in delivering  a state-mandated study on whether mid-rise apartment buildings can safely be built with just a single staircase . The report was ordered to help assess whether relaxing the current requirement for two staircases in buildings over three stories could expand housing options on tight urban lots. Calfire's assistant deputy director of legislation has said that the report is still under review, but did not provide an expected release date. A California appeals court has ruled  in favor of the town of Tiburon  in a legal challenge over its environmental review of an updated housing plan and general plan. The case centered on whether Tiburon’s program-level environmental review under CEQA needed to include a detailed, site-specific analysis for a 9-acre parcel rezoned for higher-density housing, which local opponents argued was required. The court found that because no specific housing project has been proposed for that parcel yet, the town’s broader environmental review was appropriate and that detailed review can wait until a concrete development is planned. The Santa Barbara  County Board of Supervisors adopted  phase two of three of a set of new zoning ordinances including increasing the residential area height limit to 45 feet and a density of 20 units per acre, creating specific design exceptions for ADUs, and increasing the required open space for some projects. A federal bankruptcy judge approved  a bankruptcy exit agreement for downtown Los Angeles's Oceanwide Plaza skyscraper known as the "Graffiti Towers," bringing the property one step closer to a sale. The agreement resolves disputes among creditors, sets repayment terms, and establishes a framework for selling the $1 billion mixed-use complex. Construction on the Oceanwide Holdings project was halted after the company ran out of money; they also planned to build two skyscrapers in San Francisco’s financial district, but construction was halted for the same reason in 2020. The Beverly Hills City Council granted  a developer’s appeal for a Builder’s Remedy housing project at 9229 Wilshire Boulevard, sending a revised proposal back to the Planning Commission for review. The original 14‑story plan would include 116 apartments, 24 of which are affordable, a 60‑room hotel, retail space, and parking. The applicant is now pursuing a larger 26‑story version with more units and parking. The California Department of Housing and Community Development launched  the Housing Choice Voucher (HCV) Data Tracking Program & Dashboard , a statewide initiative established through AB 653. The program requires all public housing authorities in California to report key data metrics on tenant-based Housing Choice Vouchers and for HCD to make the reported data publicly available. Los Angeles's top budget official proposed  fee relief for all types of properties that were damaged in the Pacific Palisades during the January 2025 wildfires. The revised plan expands relief from just single-family homes to include condos, apartments, townhouses, and commercial buildings. (See related CP&DR coverage .)

In the two years since plans for a new city of potentially hundreds of thousands of people in Solano County were leaked, the project has already cycled through several names: Flannery Associates, California Forever, and the East Solano Plan. If the latest suppositions are true, it could gain yet another: East Suisun City. Last month, the city council of Suisun City — a city of 28,000 in the southwest corner of Solano County — voted 4-1 to study the annexation of potentially all land within its sphere of influence. That would encompass a trapezoidal area east of the city and south of Travis Air Force Base. It includes some of the 60,000 acres owned by Flannery Associates throughout unincorporated portions of the county and would abut a major industrial development planned by the company. “We gave direction to begin conversations with our local partners like (the Local Agency Formation Commission),” said Suisun City Mayor Alma Hernandez, who sits on the LAFCO board and brought the item to council. Those conversations will cover “all the areas within our sphere of influence.” She insisted that the city and Flannery Associates have had essentially no contact with each other, with Flannery collaborating more closely with cities such as Fairfield and Vallejo in their ballot measure campaign, including promised investments in those cities. Suisun City is financially distressed with little infill opportunity. Annexation could enable the city to gain jurisdiction over a portion of the East Solano Plan, which has, thus far, failed to receive support from the county Board of Supervisors or and has not yet been submitted to county voters (California Forever’s backers pulled a proposed ballot measure a few months ago; see related CP&DR coverage ). The move could enable a portion of the plan to go forward purely through municipal action. The East Solano Plan envisions a mixed-use, New Urbanist-style city to the east of its proposed industrial zone.

Neighbors in the Echo Park section of Los Angeles have failed in their attempt to use a federal constitutional challenge to stop an apartment project that L.A. approved ministerially because it used both state Density Bonus Law and Mayor Karen Bass’s Executive Directive 1, or ED-1.

The Ventura panel of the Second District Court of Appeal has issued two unpublished opinions, both favoring a city in Ventura County over claims made by local residents and property owners.

Position Available, California State University- Northridge is seeking a Part-Time Lecturer

This article is brought to you courtesy of the paying subscribers to  California Planning & Development Report . You can subscribe to  CP&DR  by clicking  here . You can sign up for  CP&DR ’s free weekly newsletter  here . Los Angeles Consolidates Development-Related Services Los Angeles City Planning has launched  the Development Services Bureau, designed to streamline planning and zoning reviews and improve customer experience. This bureau consolidates zoning review functions previously split between the Department of City Planning and the Los Angeles Department of Building and Safety under one umbrella to accelerate project reviews. The new department will consolidate the Development Service Centers (DSC) Division, the Office of Zoning Administration (OZA), and tailored consultation services. By centralizing responsibilities, the city hopes applicants will have clearer pathways and faster responses, with fewer department hand-offs and less redundant review. San Diego Advances Scaled-Down Regional Transit Plan The San Diego Association of Governments has walked back  major future transit network aspirations in their latest $125 billion blueprint for a new regional infrastructure plan. The agency’s 2020 plan included a high-speed commuter rail system that has been replaced in favor of what SANDAG believes is a more realistic approach, including more rapid bus routes, express lanes on freeways, micro-transit shuttles and light trolley service. Even in the wake of this massive scaling back, the agency is still faced with the issue of who will foot the bill. The agency’s current proposal would rely on a proposed 2036 ballot measure which increases sales tax by three-quarters of a cent, and eventually revenue from MTS itself. San Diego City Council President Joe LaCava expressed his support for the updated plan as well as frustration at a perceived lack of delivery on over-scale promises. L.A. Metro Approves Subway Connecting Westside to San Fernando Valley After years of debate, the Los Angeles Metro’s board of directors unanimously approved  one of the most significant transit projects in the country, the Sepulveda Transit Corridor project, selecting an underground heavy-rail option that would connect the San Fernando Valley to the Westside in under 20 minutes. The plan has gone through several iterations due to concerns about environmental risks, interference with existing infrastructure, and overall inconvenience. The latest draft was received with overwhelming support from the public after changes were made, including eliminating a monorail proposal and controversial Getty center stop. Questions still remain about funding for the project, which has secured roughly $3.5 billion through Measure M and Measure R, just a fraction of the $24.2 billion estimated for a previous version of the plan. The agency has cited a need to rely on state, local, federal and possibly private funding to complete the project, but has not provided a specific fundraising plan. National City Adopts Bayfront Plan with Coastal Commission Blessing After more than a decade of planning, National City in southwestern San Diego County, won  unanimous approval from the California Coastal Commission for its National City Balanced Plan, clearing the way for long-sought public access to the city’s bayfront. National City is the only West Coast city with waterfront land but no direct public access, as all three miles of bayfront are controlled by the Navy or the Port of San Diego. The plan expands Pepper Park by nearly 50% and adds new public amenities, including a promenade, viewing areas, and pedestrian and bike connections. There are also commercial developments in this plan, including a recreational vehicle park with approximately 150 RV sites, 29 tent sites, 25 structured tents and 12 cabins, with future plans to replace up to 65 RV spaces with two hotels containing around 365 rooms. The commission approved the plan unanimously, with only two objections during public comment, one requesting air pollution monitors before proceeding and another seeking additional changes to the plan. Both were rejected by commissioners after noting extensive review and stakeholder collaboration. CP&DR Coverage: National APA Recognizes California Wildfire Education Program Despite increasing urgency to plan  around fire hazards and prevent urban wildfires, it is widely understood that planners are not necessarily trained to address wildfires, and firefighters are not necessarily trained to understand urban planning. Enter, the Land Use Planning for Wildfires in California Training Program -- this year’s recipient of one of the American Planning Association’s National four National Planning Awards. The program is a series of one-day workshops conducted around the state jointly by the nonprofit Community Wildfire Planning Center (CWPC) and the California Department of Forestry and Fire Protection (Cal Fire). CWPC Executive Director, Molly Mowery, and Cal Fire Deputy Chief for Land Use Planning, Shane Vargas, share insight into the national importance of their budding program. Among the timeliness of this initiative, the pair discuss key successes, the commitment of attendees, implementation beyond the training, and what the future may hold for this program. Quick Hits & Updates The City of Hollister  has released  a new revised version of its draft General Plan 2040, replacing an earlier plan that was rescinded by the City Council in 2025 after local activist groups argued it would allow too much growth. The updated plan  lays out the city’s vision and policies for land use, housing, transportation, environment, open space, and conservation for the next two decades. (See related CP&DR coverage .) The Peninsula Open Space Trust (POST) has purchased  2,284 acres of the historic Sargent Ranch in southern Santa Clara County for $23 million, effectively halting plans for a controversial sand and gravel quarry. With this acquisition, POST now owns 6,114 of the ranch’s 6,500 acres and is under contract to acquire the remaining land, making it the largest conservation deal in the organization’s nearly 50-year history. The trust plans to preserve the land’s biodiversity, maintain wildlife corridors, safeguard cultural sites, and potentially allow public outdoor activities like hiking. A Solano County coalition that includes California Forever and regional economic leaders is urging  the federal government to designate the California Delta as a “maritime prosperity zone” to help revive large-scale shipbuilding in Solano County and the surrounding region. The push is backed by Solano Economic Development Corporation, Cal Poly's Maritime Academy, the owners of Mare Island, the Nimitz Group, the Bay Area Council, and California Forever, who is now the county’s largest landowner. (See related CP&DR coverage .) The Trump administration approved  a Newsom-backed plan to build Sites Reservoir , a 13-mile long off-stream lake north of Sacramento. The reservoir would cost between $6.2 and $6.8 billion and provide water to residents of Santa Clara County, parts of the East Bay and Los Angeles, and irrigation to 500,000 acres in the Central Valley.  After years of delays, a Metrolink commuter train between Ventura and Santa Barbara could start running  on pre-existing Amtrak train tracks. Transportation planners hope the new train service will help reduce congestion on Highway 101. Service could start as early as April 2026. A federal appeals court upheld  an order requiring the U.S. Department of Veterans Affairs to build more than 2,500 housing units for veterans on its West Los Angeles campus, finding that the VA discriminated against unhoused veterans by failing to use the land for its intended purpose. The ruling invalidated several commercial leases on the property, including the Brentwood School’s athletic facilities, but allowed UCLA’s lease for Jackie Robinson Stadium to remain in place for now. The  Lincoln Institute of Land Policy launched  Public Land for All Communities and the Environment (PLACE), a national campaign to empower local government and civic partners to overcome common procedural and legal barriers to the effective transfer and transformation of public land, including for affordable housing, nature-based solutions, conservation, and other public benefits.

The Inland Empire warehouse wars continue. In the latest skirmish, an appellate court – overturning a lower court ruling – has said that the City of Upland’s environmental analysis for a 200,000-square-foot warehouse near Cable Airport is sufficient. The dispute was over the significance threshold that should be used for greenhouse gas emissions – as well as the environmental baseline under the California Environmental Quality Act. The ruling is especially important because it was published, meaning it can be used as precedent in other cases.

This article is provided to you for free by the paying subscribers to;California Planning & Development Report.;To learn how you too can subscribe to;CP&DR;and support our work, just click;here. Gov. Gavin Newsom signed 21 bills related to planning and development on Thursday ; the vast majority of them dealing with increasing housing production. About 15 planning and development bills remains on his desk and he has until the end of September to sign them. Taken together, the bills don’t include any extremely aggressive moves by the state to box in local governments. Indeed, in a few cases ; such as a new bill on the builders remedy ; the new legislation actually does the opposite and boxes in developers a bit. But some ; such as an ADU law ; are aggressive in their own way. There’s also definitely a trend toward transparency ; posting more information on the internet about fees especially. Here are the bills Newsom signed Thursday. ADUs SB 1211: Increases the number of allowable accessory dwelling units on a parcel from 2 to 8, depending on the situation. Builders Remedy AB 1893: Boxes in the builders remedy, among other things limiting the amount of additional density a developer can obtain. Previous CP&DR coverage is available here. CEQA AB 2117: Ensures that permits don’t expire when a project is subject to a CEQA challenge. SB 393: Puts the burden of proof on the plaintiff when seeking a bond from a CEQA defendant. A response to the $500,000 bond placed on the citizen group Save Downtown Livermore in litigation over Eden’s affordable housing project in Livermore. Previous CP&DR coverage of that case can be found here. AB 2199: Extends infill exemption from 2025 to 2032. Density Bonus Law AB 2694: Extends Density Bonus Law to residential care facilities for the elderly. A dense eldercare facility was recently an issue in a court case from Los Angeles (previous CP&DRcoverage here), though the DBL was not at issue in that case. Fees AB 2430: Prohibits imposition of monitoring fees to monitor affordable housing requirements if the project is 100% affordable. AB 2663: Requires cities and counties to post housing in-lieu fees on the internet and explain how they were spent. AB 937: Allows delay of impact fee payment on residential projects Housing Elements AB 1886 and AB 2023: Clarifies that a Housing Element is compliant with state law if a court says so and there’s a “rebuttal presumption” in court that a Housing Element is in or out of compliance of the Department of Housing and Community Development says so. The question of whether a local government can independently certify Housing Element compliance has been a huge legal issue, as evidenced by CP&DR’s coverage here.) AB 2667: Requires HCD to create standardized Affirmatively Furthering Fair Housing reporting, which local governments must use in Housing Elements starting with the 7th RHNA cycle. AB 3093: Adds two new categories to Housing Element income categories to account for homelessness. (Detailed CP&DR coverage of the HCD report that recommended these changes can be found here.) Other Housing AB 1413: Expands definition of “disapproval” under the Housing Accountability Act and also expands notification requirements in those situations. AB 2243: Extends AB 2011, which permits residential development in commercially zoned areas, to high-rise districts not in commercial corridors as well as near freeways and clarifies that affordability requirements apply to base units in Density Bonus Law, not bonus units. SB 450: Tightens SB 9 so that it's harder to deny lot splits, among other provisions. (For more background on how cities are ; or are not ; implementing SB 9, check out CP&DR’s previous coverage here.) SB 7: Specifies that cities and counties can’t object to Regional Housing Needs Determination. SB 312: Further clarifies CEQA streamlining for student housing contained in SB 886, which was passed after the so-called “People’s Park” decision. (For more background on the case and SB 886, see CP&DR’s previous analysis here.) AB 2488: Allows tax-increment financing for office-to-residential conversion in Downtown San Francisco. Transit-Oriented Development AB 2553: Redefines a “major transit stop” under state law as a transit stop with 20-minute headways instead of 15-minute headways. This is important because much TOD streamlining is geared toward “major transit stops” and post-COVID transit agencies have been cutting back service. AB 2712: Specifies that TOD projects with lower parking requirements in Los Angeles. must be excluded from residential permit parking.

Gov. Gavin Newsom has signed all but one of the 40-odd planning and development bills the Legislature passed, including – at the last minute – the controversial bill regulating warehouses.

Cities and counties in California are aggressively – and sometimes in a coordinated way – adopting the “objective design standards” required by the Housing Accountability Act.

The new State Capitol Annex has survived yet another court challenge, this one arguing that SB 174 – the bill exempting the project from the California Environmental Quality Act – runs afoul of a 44-year-old constitutional amendment designed to protect the Capitol’s historic character.