SB 684 + SB 1123

Brick Work specializes in SB 684 and SB 1123 property analysis for Los Angeles landowners. We've completed 3,000+ development feasibility reports analyzing your property under these state housing laws. Our $250 Brick Work report analyzes your property under the Starter Home Revitalization Act (SB 684 as amended by SB 1123), on the multifamily path or the vacant single-family path, and where a small-lot subdivision applies it includes a massing diagram. A Brick Work report is $250 and covers every California housing law that applies to up to 10 adjoining parcels under one base zone, delivered in 2 business days. Sites with more than one base zone, multiple overlays, or other advanced land-use diligence take the $500 Advanced report. Pro is $250 a month and includes 2 reports a month plus priority turnaround.

Your zoning decides which path you would use. If your lot is zoned to allow multifamily housing (in the City of LA: R2, RD, RW2, R3, RAS3, R4, RAS4, R5 and all C zones), you would use the multifamily path that SB 684 created. If it is zoned single-family (in the City of LA: A, RA, RE, RS, R1, RU, RZ and RW1), the path SB 1123 added is open only if the lot is vacant and no larger than 1.5 acres. A single-family lot with a lived-in house qualifies for neither. Zoning alone does not make a lot eligible: lot size, existing tenants or rent-stabilized units, fire and other hazard zones, and minimum density also apply (Gov. Code § 66499.41(a)). Our $250 Brick Work report analyzes your specific property.

They are two bills that make up one law, the Starter Home Revitalization Act (Gov. Code §§ 65852.28, 65913.4.5 and 66499.41). SB 684 (Stats. 2023, ch. 783) added those sections, operative July 1, 2024, for lots zoned to allow multifamily housing. SB 1123 (Stats. 2024, ch. 294) amended §§ 65852.28 and 66499.41, operative July 1, 2025. It added vacant single-family-zoned lots of up to 1.5 acres, and it changed the rules for both lot types: ADUs and JADUs a city allows don't count toward the 10-home cap, minimum density on sites not listed in the housing element dropped from the zoning maximum to 66% of it, frontage minimums are barred, and tenancy in common is allowed. A lot qualifies on the multifamily path, the vacant single-family path, or neither.

No area qualifies automatically by zone. The lot must be in an incorporated city that includes part of a Census urbanized area, or in an urbanized area or urban cluster in a county of more than 600,000 people. A multifamily-zoned lot must be 5 acres or less and a vacant single-family-zoned lot 1.5 acres or less, and both must be substantially surrounded by qualified urban uses (Gov. Code § 66499.41(a)(2)). There is no jobs, schools or transit test; transit only affects parking. Sites are excluded in very high fire hazard severity zones (plus high zones in state responsibility areas; City of LA guidance excludes high and very high zones), wetlands, prime farmland, protected habitat and conservation land, and flood, earthquake-fault and hazardous-waste sites qualify only with conditions. The project can't demolish or alter rent-controlled (in LA, RSO), deed-restricted or recently tenant-occupied (past 5 years) housing, and the lot can't have had an Ellis Act withdrawal in the past 15 years. Parcels in ZIP codes 91001 and 91003 (Altadena) can't use the law for applications submitted on or after October 1, 2026, with limited exceptions (SB 1090). Our analysis checks each of these for your specific property.

Only if the lot counts as vacant. Under Gov. Code § 66499.41(a)(2)(A)(ii), “vacant” means having no permanent structure, unless the structure is abandoned and uninhabitable. Three kinds of housing never count as vacant: housing whose rent or sales price is restricted to lower-income levels by a recorded covenant, ordinance or law; housing under rent or sales-price control; and housing occupied by tenants in the 5 years before the application. For applications a city receives on or after January 1, 2027, SB 1116 (Stats. 2026, ch. 808) loosens the test: a structure no longer blocks vacancy if it is abandoned or untenantable, meaning it does not meet the characteristics in Civil Code § 1941.1(a)(1)–(5) and (8). The three exclusions stay.

Not for new applications. SB 1090 (Stats. 2026, ch. 1006), an urgency law in effect since September 30, 2026, says Gov. Code §§ 65852.28 and 66499.41 do not apply to projects in ZIP codes 91001 and 91003 when the application is submitted on or after October 1, 2026. There are two exceptions. First, a project with a development or preliminary application submitted before October 1, 2026, if a complete application follows within 180 days after October 1, 2026 and any missing items are supplied within 90 days of the agency's written notice. Second, a project where 100% of the units are affordable, with recorded deed restrictions of at least 55 years (rental) or 45 years (ownership), built by a community land trust or a qualifying nonprofit.

SB 1116 (Stats. 2026, ch. 808), carried into the code by SB 1090, changes Gov. Code § 66499.41 for applications a city receives on or after January 1, 2027 (§ 66499.41(l)). The 5-acre cap on multifamily lots goes away, and both lot types must instead meet the urban-site test in Pub. Res. Code § 21080.66(a)(3); vacant single-family lots stay capped at 1.5 acres. The 66% minimum density is replaced by a ceiling: the base zoning, ignoring density bonuses, overlays, ADU allowances and incentive programs, may allow no more than 15 units, or no more than 26,250 sq ft of residential floor area where zoning sets no unit maximum. A lot listed in the housing element for lower-income units can qualify instead by delivering its proportional share of those units. With lot-size averaging, new parcels can be as small as 480 sq ft on multifamily lots (600 sq ft average) or 960 sq ft on single-family lots (1,200 sq ft average). Final maps get their own 60-day deemed-approved deadline, and vacancy is redefined as described above. Under § 65852.28, height limits apply to a building's physical height rather than its number of floors, and front and internal setbacks are limited.