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- La Cañada Flintridge Approves Controversial Builder's Remedy Project
La Cañada Flintridge has abandoned its efforts to right off a controversial builder’s remedy project and has approved the project.
- Constitutionality of SB 9 Will Be Reconsidered
A few months ago, a Los Angeles judge ruled – in a fairly technical opinion – that SB 9, the lot-split law, is unconstitutional for charter cities. But after a new state law was passed clarifying SB 9’s intent, an appellate court has tossed the case back to the judge to reconsider it. Another appellate ruling declaring SB 9 constitutional as it relates to general-law cities still stands. SB 9, which went into effect in 2022, essentially did away with binding single-family zoning in most parts of California. The law permits landowners build up to four units on their single-family parcel by to splitting their parcels in two and build two units on each of the resulting parcels, all by ministerial action. The bill was very controversial during legislative debate in 2021 and has received a lot of national publicity. However, its actual effect has been limited. Relatively few single-family parcel owners have chosen to go the SB 9 route. The general consensus is most single-family homeowners find it easier to add an accessory dwelling unit on the property, an action that is also available by ministerial approval thanks to a different state law. Decades ago, California declared that both a shortage of housing and a lack of affordable housing as matters of statewide concern, thereby allowing the state to override the California Constitution’s guarantee of local home rule. SB 9, however, mentioned only “affordable housing” and not “a lack of housing supply” as the justification for interfering with home rule. This was the basis of the constitutional challenge brought by several cities led by Redondo Beach. Other cities involved in the lawsuit include Carson, Cerritos, Torrance, and Whittier. That led Los Angeles County Superior Court Judge Curtis Kin to rule in favor of the cities in 2024, saying that housing affordability and housing supply are not the same thing. ( CP&DR ’s coverage of Kin’s ruling can be found here. ) This year, however, the Legislature passed SB 450, which expanded the purpose of SB 9 to include housing supply as well as affordability. For this reason, Attorney General Rob Bonta’s office argued that Kin’s ruling no longer applied. The Second District Court of Appeal agreed with Bonta and sent the case back to Kin. “We agree that the amended language of SB 450 is an intervening change in law that is entitled to consideration by the trial court in determining the constitutionality of the statute,” the court wrote. The appellate court also overturned Judge Kin’s award of $270,000 in attorney’s fees to the city and sent that issue back to him for reconsideration as well. Meanwhile, a different appellate court ruling stating that SB 9 applies to general law cities still stands. That ruling was issued by the Second District in January. ( CP&DR ’s coverage of that ruling can be found here .) The Case: City of Redondo Beach v. Bonta , No. B338990 (unpublished, issued November 12, 2025) The Lawyers: For Redondo Beach: Michelle L. Villarreal, Aleshire & Winder, mvillarreal@awattorneys.com For Attorney General’s Office: Kevin J. Kelly, kevin.kelly@doj.ca.gov , Deputy Attorney General
- Despite AB 130, Glendale Rejects Sears Redevelopment Design
A century or so ago, the Sears Corp. sold tens of thousands of catalog homes that were constructed across the United States. Today, the Sears company is still creating homes, as its former stores are converted and redeveloped into housing developments.
- Slow-Growthers Fail To Stop Changes In Carlsbad Growth Management Law
Carlsbad’s growth management plan – dating from the 1980s – is often held up as a model of integrating private residential growth with public infrastructure. (It’s even highlighted in Guide To California Planning . ) Times have changed in the last 40 years and local growth control advocates say the Carlsbad City Council has not stuck to the spirit of the initiative. But the growth control folks keep losing in court.
- City Can Delegate Final Housing Element Approval To Manager
Apparently a city can delegate final approval of its housing element to the city manager – and not hold a final public hearing – so long as the final changes as a result of negotiating with the Department of Housing and Community Development are relatively minor.
- Moving Playground Equipment Is Exempt From CEQA
The City of Davis doesn’t have to do an environmental analysis under the California Environmental Quality Act in order to move playground equipment from one location to another.
- Legal Briefs: Ruling on Incompleteness, Vallejo v. American Canyon
Judge Sides With Developers On Preliminary Application Timing
- APA Conference: When Planners Wish Upon a Star
This is a true story, not a fairy tale: the last time I spent a night in Anaheim was sometime in the 1990s for high school "grad night" at a certain local amusement park. P.M. Dawn was one of the musical acts. Jackets and ties were required for the gentlemen. And I discovered that there is no delirium quite like the delirium that comes with riding "It's a Small World" (sober) at 4 a.m. I vowed never to go back, and I've kept that vow. But, here I am for this week's conference of the California chapter of the American Planning Association. I'm back to speak about good books, learn about good cities, and commune with colleagues after a long hiatus. I apparently am not the typical Anaheim visitor. This morning I exited the 5 Freeway at 7:25 a.m. at Harbor Bl. Orange County, like much of American suburbia, was build around streets like Harbor: six lanes, plus some left-turn lanes; a median with a fence down the middle (to prevent jaywalking); perilously high speed limits; and limited pedestrian crossings. Usually, the shortage of pedestrian crossings doesn't matter. People rarely walk on streets like Harbor, both because they are unpleasant at foot level and because they don't run through walkable neighborhoods. But, in Anaheim, on Harbor Bl., the sidewalks are full. At the crack of dawn on a grey autumn Sunday, they're full like those of the Champs-Elysse, Broadway, or Michigan Avenue at high noon on a summer's day. They're full like those of the Las Vegas Strip at midnight. Where was everyone going? Church? The farmers market? Early-bird brunch? Not exactly. The mouse-eared hats were a pretty strong tipoff. Whatever magic takes place inside Disney's kingdom, the means of ingress are decidedly terrestrial. You either walk from your hotel, or you drive from points beyond. Flying in on an elephant is not an option. On the one hand, the there's a shocking contrast between the lifelessness of Harbor Bl. and the intrigue of Tomorrow, Fantasy, Adventure (and, of course, California Adventure, which you apparently visit if you don't like the real California but also don't want to leave California). On the other hand, that contrast is likely a feature, not a bug. Disneyland came about precisely at the peak of and, I would argue, because of mid-20th century suburbanization. As the country was becoming deliberately dull and homogenous in the late 1950s, a place of excitement, escape, and, indeed, ersatz urbanism became more marketable. Disneyland promoted suburbanization in order to offer an antidote to suburbanization. The uglier Harbor Bl. is, and the less pleasant that walk is, the more exciting those other -lands become. Much of this has been theorized already, most usefully by Jean Baudrillard, who declared Disneyland to be a "simulacrum" -- a copy that overwhelms the original. What even Baudrillard -- or Walt Disney, for that matter -- could not have imagined was the extent to which the Disney empire would grow. This morning's opening session put the empire, and the Empire, on full display. Two Disney "imagineers" gave a brief history of Disney's theme parks (now numbering 12 worldwide), fawningly describing how the original park went from orange groves to opening day in just over a year, and reporting on the latest attractions they are dreaming up. They are a far from from animatronic that Abraham Lincoln that amazed crowds at the 1964 New York World's Fair. They are, to use imagineer parlance, fully immersive worlds, centered on the Star Wars universe and whatever other multi-platform franchise Disney wants to promote. The latest is a two-day stay at a Star Wars Extended Universe hotel, which seems like a cross between space camp and The Shining. At every turn, Disney stands for the ability to create "worlds" that are somehow both idealized and realistic, wholly accessible through suspension of disbelief and steep admission fees. However much effort Disney's folks put into designing Disneyland down to the last detail, today's "imagineers" are working harder that Walt ever could imagine. Fiction on screen merely requires viewers to believe that the scenes they are witnessing could have happened -- if not in front of their eyes in the moment, then perhaps a long time ago in... well, you know where. But fiction in three dimensions means that viewers aren't viewers. They are participants. The action takes place in real time and in the very place where the viewer stands. The viewer doesn't see only what the camera sees; he sees (and hears, smells, and feels) whatever he wants to see. For these reasons, imagineers work very hard. Fooling people in three dimensions is vastly--exponentially--more challenging than fooling them in two dimensions. They design physical spaces down to the finest detail -- the howl of a yeti; the whoomp of a light saber; the hem of a princess' train -- and they design storylines to command visitors' attention. Imperfections or plot holes cannot be wished away. The illusion must become real for the experience to matter. So, what does all of this have to do with Harbor Bl.? Imagineering is not cheap. Disney spends money to make money. So much so that the Disneyland complex alone takes in $3.8 billion annually. That's money that people, over 15 million per year, spend voluntarily. And why? Because, say what you will about artifice, consumerism, and wishing upon a star, Disneyland is nicer than the real world. People are willing to pay for nice, even for only a few hours. That's because, for much of recent history, in the vast majority of places, the imagination and talent has been privatized, funded, and promoted, and the public realm has, in too many cases, been neglected, starved, and vilified. The public realm doesn't get nearly the sort of attention and investment as even a few dozen acres of private realm. That's how we end up with streets like Harbor Bl. and "attractions" like Main Street USA. This morning's presentation was, I presume, supposed to inspire planners. And I hope it did. I hope in inspired them to imagine how to write plans and codes that are every bit as enchanting as the rides and worlds that hum to life every morning atop those former orange groves. I hope no one has to pay an admission fee to spend time in a place that excites them, and I hope no one has to cross eight lanes of traffic to do so. It's a small world after all. A small world with very big streets.
- Rating California's New Transit Lines and Extensions
Not long ago, fans of mass transit in California had to be very patient. An entire decade could go by without the opening of a major transit line in California.
- Economic Headwinds Push Back on State Housing Goals
Roughly speaking, for every percentage point increase in prevailing interest rates for construction, the collective cost of producing the estimated 2.5 million housing units that California needs, at a conservative half-million dollars per unit, increases by $12.5 billion per year.
- The Top Stories of 2022
The most telling CP&DR headline of 2022 came very early in the year, on January 10: "Cities Move Quickly to Regulate SB 9 Housing Units."

