Key Takeaways from the Comparison

• SB 684 is best for urban sites zoned for multifamily housing—even small ones.

• SB 1123 opens the door to building on vacant single-family lots, a major expansion of infill housing potential.

• Both laws cut out CEQA delays and discretionary review, making small housing projects faster and cheaper.

• SB 1123 is more restrictive on tenant history but more flexible with ADUs and shared ownership models.

If your site doesn’t qualify under one law, it might qualify under the other. Many developers will use both to build small, affordable homes across multiple site types.

Real-World Impact: What’s Happening on the Ground

SB 684 and SB 1123 aren’t just policy ideas—they’re already shaping how housing gets built across California. Cities, developers, and community leaders are testing these laws and exploring how they can speed up infill housing without major battles.

Let’s look at how these laws are beginning to work in real time.

Developer interest and early municipal adoption

Since SB 684 went into effect in July 2024, developers across California have shown strong interest in using the law—especially in Los Angeles County, Santa Clara, and parts of the Inland Empire. Many developers are focusing on underutilized multifamily lots near transit or in older commercial corridors.

Some cities are taking the lead by actively encouraging 10-home ministerial subdivisions. Examples include:

• Hawthorne: Released a detailed SB 684 application checklist and site map

• Cudahy: Amended zoning to align with SB 684 objectives

• Rosemead: Created pre-approved parceling templates to reduce processing time

Cities that embrace the law are seeing faster permitting and more interest from small to mid-size builders who had previously avoided infill projects due to delays and uncertainty.

Meanwhile, cities that haven’t adopted internal procedures yet are creating confusion. Some applicants report inconsistent interpretations or long wait times—despite the 60-day approval clock in the law.

Permitting speed and financial impact for builders

One of the biggest benefits of SB 684 is time. By skipping CEQA and avoiding discretionary review, developers can save 6 to 18 months on the approval timeline.

That matters. Every month of delay increases carrying costs and financing risk. Faster approval means:

• Lower pre-construction costs

• More certainty for lenders and investors

• Reduced soft costs like legal fees, environmental studies, and design revisions

Some cities have also begun coordinating SB 684 with SB 937, which allows cities to defer impact fees until after units are built or sold. This provides huge cash flow advantages for smaller developers without deep capital reserves.

On a 10-home project, total savings could range from $150,000 to $400,000, depending on location, permitting fees, and whether ADUs are included.

Starter home production and gentle density

The biggest potential win? More starter homes built where people already live—without needing massive upzoning or disruptive towers.

These laws encourage what planners call “gentle density”: adding a small number of units to neighborhoods without changing their character. Think:

• Cottages in a cul-de-sac

• Rowhomes near a commercial strip

• Clustered bungalows on an empty corner lot

These homes often fall into the “naturally affordable” category—smaller by design, with lower prices than larger market-rate units.

Analysts project that SB 684 alone could enable 8,000 to 15,000 new homes statewide per year, especially in coastal regions where zoning is tight and land is expensive.

SB 1123, when it goes into effect in 2025, could double that number by unlocking vacant single-family lots across suburban areas—sites that were nearly impossible to build on until now.

Strategic Guidance for Stakeholders: How to Use SB 684 and SB 1123 Effectively

SB 684 and SB 1123 offer powerful new tools—but success depends on knowing how to navigate them. Whether you’re a developer, city planner, homeowner, or community group, understanding the rules and timelines will help you move faster and avoid setbacks.

Below is guidance tailored for each stakeholder group.

For Developers and Builders: How to unlock small-lot housing now

If you’re a builder interested in 10-home infill projects, here’s how to get started:

1. Identify eligible sites early
Look for lots that are:

• Zoned multifamily (SB 684) or vacant single-family (SB 1123)

• Under the acreage limits (5 acres for SB 684, 1.5 for SB 1123)

• Free of environmental constraints or recent tenant activity

Use public GIS tools and zoning maps to screen properties quickly.

2. Prepare clean, compliant site plans
Ministerial approval only works if your plans:

• Meet all objective zoning standards

• Follow setback, height, and parking rules

• Include clear parcel boundaries and access points

Cities cannot deny you if your plans meet the law—but they can delay you if documents are incomplete.

3. Consider alternative ownership models
If traditional fee-simple sales don’t pencil out, look into:

• Tenancy in common (TIC)

• Condominium mapping

• Community land trusts

These options give flexibility in financing and long-term use.

4. Take advantage of fee deferrals and layered incentives
Combine SB 684/SB 1123 with:

• SB 937 (fee deferral)

• SB 450 (objective design standards)

• SB 1211 (ADU exemptions)

This approach can improve project cash flow and lower risk.

For Planning Staff and Local Governments: How to implement the laws responsibly

Cities are required to process these applications—but many haven’t built internal systems yet. Here’s what local governments should prioritize:

1. Adopt clear administrative procedures
Cities must publish:

• Checklists

• Application forms

• Parcel qualification tools

Standardizing the process protects staff from legal challenges and improves developer compliance.

2. Train staff and update zoning interpretations
Code enforcement, planning, and building officials should:

• Understand the difference between discretionary and ministerial review

• Avoid applying subjective design reviews to qualifying projects

• Know when CEQA does or does not apply

3. Track project volume and identify common roadblocks
Cities should monitor:

• How many SB 684/SB 1123 projects are filed

• How long approvals take

• What issues slow the process down

This helps build trust with both developers and community members.

For Homeowners and Community Advocates: What this means for your neighborhood

If you’re a homeowner or housing advocate, these laws give you a way to support small-scale housing without major disruption to your community.

What you can do:

• Identify vacant lots in your neighborhood that could be developed

• Encourage your city to adopt SB 684/SB 1123 procedures quickly

• Talk with small builders or nonprofit developers about infill partnerships

• Support gentle density in neighborhood meetings and planning sessions

These homes aren’t luxury condos or high-rise towers. They’re often duplexes, bungalows, or cottages—ideal for seniors, young families, or first-time buyers.

Challenges, Risks, and Open Issues with SB 684 and SB 1123

While SB 684 and SB 1123 open exciting opportunities for small-scale housing, they are not without friction. Developers and cities face legal, political, and practical hurdles in putting these laws into action.

Understanding these risks can help you plan smarter and avoid missteps.

Municipal resistance and ordinance delays

Even though SB 684 is already in effect (and SB 1123 starts July 2025), many cities have been slow to adapt.

Common issues include:

• No published procedures for ministerial applications

• Staff still using discretionary review standards

• Confusion about objective vs subjective design rules

• Local policies that still contradict state law

Some cities may resist implementation outright. Others may try to delay projects with vague requirements or excessive plan check requests.

Tip: If you’re a developer, cite the law in writing, track deadlines (like the 60-day rule), and escalate if necessary.

Litigation risk and legal uncertainty

Because these laws override local control, legal challenges are likely. Possible issues include:

• Cities being sued for denying eligible projects

• Neighbors filing lawsuits over CEQA exemptions

• Disputes over density calculations or tenant status

Most legal experts expect state law to prevail, but lawsuits can still cause delays.

Also, many terms in the bills—like “vacant” or “objective standards”—can be interpreted differently. Until courts clarify them, gray areas remain.

Design compatibility and infrastructure concerns

Some cities worry these projects may not fit neighborhood aesthetics or strain infrastructure.

Key concerns include:

• Lack of uniform design (no subjective reviews allowed)

• Increased need for sewer, water, or stormwater upgrades

• Parcel access on flag lots or mid-block sites

• No street frontage requirements under SB 1123

While the laws preserve safety standards, cities may feel they lack tools to manage growth effectively.

Equity and displacement concerns

Even with tenant protections, some advocates worry that:

• These laws could indirectly gentrify low-income areas

• Developers may use legal loopholes to displace tenants

• New homes may still be out of reach for working families

On the other hand, supporters argue that starter homes are critical for young families, seniors, and essential workers priced out of large-lot housing.

To ensure equitable outcomes, cities and builders should:

• Explore community land trusts and shared equity models

• Keep ADU rents affordable

• Focus on high-opportunity zones, not just gentrifying areas

Conclusion: A New Era for Small-Scale Housing in California

California needs more homes—and fast. SB 684 and SB 1123 offer a practical path forward. Instead of waiting years for approvals, developers can now build up to 10 homes ministerially on small, urban lots and even vacant single-family parcels.

These laws:

• Cut through red tape

• Eliminate CEQA reviews

• Remove the politics from housing approvals

For developers, that means less risk and more predictability. For cities, it means a steady flow of new homes in walkable, transit-rich areas. And for families, it means a new supply of starter homes, duplexes, and cottages—often naturally affordable by design.

But success depends on education, action, and oversight. Builders must follow objective rules. Cities must adopt clear procedures. And advocates must ensure equity is part of every project.

California’s housing crisis won’t be solved by one law. But this is a step in the right direction.

Ready to explore small-lot development under SB 684 or SB 1123?

Our experienced land use consultants at JDJ Consulting Group are here to help you understand California’s changing housing laws. Whether you’re a developer seeking streamlined approvals or a property owner exploring subdivision options, we’ll guide you through every step—from site eligibility to ministerial mapping strategies.

Call us at +1 (818) 827-6243 or contact us online to schedule a FREE consultation and take the next step toward building smarter, faster, and within the law.

FAQs About SB 684 and SB 1123

What is ministerial approval in California housing?

Ministerial approval means a city must approve a project if it meets objective standards. There are no public hearings, no CEQA review, and no political discretion. It’s faster and more predictable than discretionary approval.

How many homes can be approved under SB 684 and SB 1123?

Up to 10 homes can be approved ministerially per project. Under SB 684, ADUs count toward that cap. Under SB 1123, ADUs and JADUs do not count toward the 10-home limit.

Can I use SB 684 on a lot in a single-family zone?

No. SB 684 only applies to multifamily-zoned lots. If your lot is zoned single-family and is vacant, you may be able to use SB 1123, starting July 1, 2025.

What are the size limits for homes built under these laws?

SB 684 requires the average home size to be ≤ 1,750 sq ft (net habitable space). SB 1123 has minimum parcel sizes of 1,200 sq ft, but no unit size cap.

Do these laws override local zoning codes?

No, they do not override zoning. But they do limit local discretion. As long as a project meets written zoning standards, cities must approve it ministerially.

Are CEQA and public hearings required?

No. Both laws exempt eligible projects from CEQA and do not allow public hearings or appeals. This keeps the approval process short and focused.