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Planning commission flags ambiguity in ADU ordinance, asks staff to seek HCD guidance

Sierra Madre Planning Commission · March 20, 2026
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Summary

The Sierra Madre Planning Commission reviewed a staff-drafted amendment to the city’s accessory dwelling unit (ADU) ordinance, focused on ambiguity around the phrase “proposed space,” and directed staff to revise the redline and request guidance from the California Department of Housing and Community Development before returning with a draft for public hearing on April 16, 2026.

The Sierra Madre Planning Commission spent most of its March 19, 2026 meeting reviewing Municipal Code Text Amendment MCTA26‑01, a staff-drafted update to the city’s accessory dwelling unit (ADU) ordinance meant to align local rules with recent state law and HCD expectations. Senior Planner Wolf, who presented the item, told commissioners that ADUs “are meaningfully contributing to the city’s RHNA obligations for affordable housing.”

Commissioners and staff discussed several state statutes called out in the draft, including AB 1154 (owner‑occupancy and deed‑restriction limits), AB 462 (certificate‑of‑occupancy rules for ADUs after declared emergencies), and SB 543 (requirements for application completeness checks and decision timelines). Staff summarized how SB 543 requires completeness checks within 15 business days and final action within 60 days for a complete ADU/JADU application, and noted HCD handbook guidance about items cities must submit to the department.

The meeting turned to a sustained, technical exchange about the statutory phrase “proposed space of a single family dwelling,” a term commissioners said can produce widely different outcomes depending on local interpretation. Staff walked through an example lot and addition illustrating how labeling parts of a proposed addition as an attached ADU or JADU could reduce the gross floor area counted toward local design‑review thresholds, change setback expectations and parking triggers, and potentially allow larger primary dwellings without discretionary review. A commissioner summarized the concern: “The ambiguity is purely coming from that term ‘proposed space.’”

City staff recommended mirroring Government Code section 66323 in the redline while separately drafting explanatory local language to set counter‑expectations for applicants. Senior Planner Wolf said staff would seek targeted guidance from HCD and bring a revised ordinance back to the commission. “We will seek guidance from HCD on this topic,” Wolf said during the meeting.

Commissioners also discussed a range of detailed code elements: whether conversions of accessory structures should have numerical maximums, JADU limits (500 sq ft) and shared‑bath allowances, detached ADU limits (commonly 800–1,200 sq ft depending on conversion/new construction), 4‑foot vs. larger setbacks, and state‑directed objective height limits (16 ft or 18 ft in specific contexts). On life‑safety issues, staff noted state law limits when local jurisdictions may require sprinklers for ADUs (for example, requirements tied to distance for fire access) and said the code would retain a fire‑code compliance clause.

On procedural items, commissioners debated a proposed timely resubmittal period for incomplete ADU applications. Options discussed included 90 days, 180 days, or one year; several commissioners favored 90 days to avoid carrying applicants under outdated laws. Staff said it would research comparable jurisdictions and return with a recommendation.

No final code text was adopted at the March 19 meeting; commissioners provided line‑by‑line feedback and directed staff to return with a redline reflecting the commission’s clarifications and a request for HCD advice. The commission set a public hearing for April 16, 2026 and reserved the option to continue deliberations at the April 2, 2026 meeting.