Agenda packet — Bradbury City Council, October 22, 2026

FOR CITY COUNCIL AGENDA – October 20, 2026 AGENDA ITEM # _______

City of Bradbury
Agenda Memo
TO: Honorable Mayor and Members of the City Council
FROM: Kevin Kearney, City Manager
Jim Kasama, City Planner
Lisa Kranitz, Assistant City Attorney
DATE: October 20, 2026
SUBJECT: SECOND READING AND ADOPTION OF ORDINANCE NO. 401: AN

ORDINANCE OF THE CITY COUNCIL OF THE CITY OF BRADBURY,
CALIFORNIA AMENDING SECTION 9.25.020 OF THE BRADBURY

DEVELOPMENT CODE RELATING TO DEFINITIONS, AMENDING
SECTION 9.34.020 REGARDING ARCHITECTURAL REVIEW,
AMENDING CHAPTER 9.85 OF THE BRADBURY DEVELOPMENT

CODE RELATING TO ACCESSORY DWELLING UNITS, JUNIOR
ACCESSORY DWELLING UNITS, AND SB 9 UNITS, AND AMENDING
CHAPTER 9.164 OF THE BRADBURY MUNICIPAL CODE RELATING

TO URBAN LOT SPLITS, AND FINDING THAT THIS ORDINANCE IS

SUMMARY
At the September 22, 2026, adjourned meeting, the City Council held a public hearing, and reviewed and introduced Ordinance No. 401 to amend Chapter 85 of the Development Code. However, due to the absence of the Mayor Pro Tem whose district will be significantly affected by the Ordinance, it is anticipated that the Ordinance will be Elizabeth Bruny, Mayor (District 5)
Melodie Szymkowski, Mayor Pro Tem (District 2)
Richard T. Hale, Council Member (District 1)
Richard Barakat, Council Member (District 3)
Bruce Lathrop, Council Member (District 4)
Second Reading and Adoption of Ordinance No. 401

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pulled from the consent calendar for additional discussion. Therefore, the September 22, 2026, Agenda Memo is attached in its entirety.

If the Ordinance is to be adopted as introduced, it is recommended that the City Council waive the reading in full, authorize the reading by title only of Ordinance No. 401, and adopt the Ordinance.

If the City Council wishes to re-open the public hearing, it is recommended that the City Council schedule the Ordinance for a public hearing and re-introduction on the November 17, 2026, regular meeting agenda.

If the Ordinance is to be altered significantly, it is recommended that the City Council refer it back to the Planning Commission for their review.

BACKGROUND
At the September 22, 2026, adjourned meeting, the City Council reviewed and introduced Ordinance No. 401 to amend Chapter 85 of the Development Code to address the required statutory amendments, and as recommended by the Planning Commission, to prohibit Secondary Living Quarters and SB 9 Units on lots that have access only from roadways that are less than 20 feet wide. This is provided by adding the following to Chapter 85:

Sec. 9.85.040. Prohibited Locations
Notwithstanding any other provision in this chapter to the contrary, no ADU, accessory living quarter, or SB 9 unit shall be allowed on any property that has access only from the following streets due to the width of said streets being less than 20 feet and not being able to provide adequate access for emergency fire vehicles:
(a) Furlong Lane—between Deodar Lane and Long Canyon Road; (b) Oak Knoll Lane—east of Bliss Canyon Road;
(c) Woodlyn Lane—between Bradbury Hills Road and El Cielo Lane; (d) Bradbury Hills Road;
(e) Bradbury Hills Lane; and
(f) El Cielo Lane.

ENVIRONMENTAL REVIEW
There are statutory exemptions from the California Environmental Quality Act (CEQA) in Public Resources Code Section 21080.17 and Government Code Sections 65852.21 and 66411.7 for ordinances relating to ADUs, JADUs, and SB 9, and there is the commonsense exemption of CEQA Guidelines Section 15061(b)(3) for a project that Second Reading and Adoption of Ordinance No. 401

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clearly will not have a significant impact on the environment. The City Council found that Ordinance No. 401 qualifies for these exemptions.

FINDINGS
The City Council found that Ordinance No. 401 is consistent with the City’s General Plan and will further Statewide housing goals.

RECOMMENDATION AND ACTION
If the Ordinance is to be adopted as introduced, it is recommended that the City Council waive the reading in full, authorize the reading by title only of Ordinance No. 401, and adopt Ordinance No. 401:

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF BRADBURY, CALIFORNIA AMENDING SECTION 9.25.020 OF THE BRADBURY

DEVELOPMENT CODE RELATING TO DEFINITIONS, AMENDING
SECTION 9.34.020 REGARDING ARCHITECTURAL REVIEW,
AMENDING CHAPTER 9.85 OF THE BRADBURY DEVELOPMENT

CODE RELATING TO ACCESSORY DWELLING UNITS, JUNIOR
ACCESSORY DWELLING UNITS, AND SB 9 UNITS, AND AMENDING
CHAPTER 9.164 OF THE BRADBURY MUNICIPAL CODE RELATING

TO URBAN LOT SPLITS, AND FINDING THAT THIS ORDINANCE IS

EXEMPT FROM CEQA PURSUANT TO PUBLIC RESOURCES CODE
SECTION 21080.17 AND GOVERNMENT CODE SECTIONS 65852.21
AND 66411.7 AND THE COMMON SENSE EXEMPTION OF CEQA
GUIDELINES SECTION 15061(b)(3)
If the City Council wishes to re-open the public hearing, it is recommended that the City Council schedule the Ordinance for a public hearing and re-introduction on the November 17, 2026, regular meeting agenda.

If the Ordinance is to be altered significantly, it is recommended that the City Council refer it back to the Planning Commission for their review.

EXHIBIT ‘A’
Second Reading and Adoption of Ordinance No. 401
Comment Letters Received
1 2
3 4
5 6
7 8
9 10
11 12
13 EXHIBIT ‘B’
Second Reading and Adoption of Ordinance No. 401
September 22, 2026, Agenda Memo with attachments,
including Ordinance No. 401
FOR CITY COUNCIL AGENDA________ AGENDA ITEM # _______

City of Bradbury
Agenda Memo
TO: Honorable Mayor and Members of the City Council
FROM: Kevin Kearney, City Manager
Jim Kasama, City Planner
Lisa Kranitz, Assistant City Attorney
DATE: September 22, 2026
SUBJECT: PUBLIC HEARING AND INTRODUCTION OF ORDINANCE NO. 401: AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
BRADBURY, CALIFORNIA AMENDING SECTION 9.25.020 OF THE

BRADBURY DEVELOPMENT CODE RELATING TO DEFINITIONS,
AMENDING SECTION 9.34.020 REGARDING ARCHITECTURAL
REVIEW, AMENDING CHAPTER 9.85 OF THE BRADBURY

DEVELOPMENT CODE RELATING TO ACCESSORY DWELLING
UNITS, JUNIOR ACCESSORY DWELLING UNITS, AND SB 9
UNITS, AND AMENDING CHAPTER 9.164 OF THE BRADBURY

MUNICIPAL CODE RELATING TO URBAN LOT SPLITS, AND

FINDING THAT THIS ORDINANCE IS EXEMPT FROM CEQA
PURSUANT TO PUBLIC RESOURCES CODE SECTION 21080.17
AND GOVERNMENT CODE SECTIONS 65852.21 AND 66411.7

AND THE COMMON SENSE EXEMPTION OF CEQA GUIDELINES
SECTION 15061(b)(3)
ATTACHMENTS:

A) Ordinance No. 401
B) Ordinance No. 401 – Redline Version
C) Planning Commission Resolution No. PC 26-330
D) Planning Commission Minutes for March 25, 2026 and May 27, 2026 with Exhibits from Residents
E) Planning Commission Minutes for July 22, 2026 – DRAFT F) HCD Fact Sheets – Duplexes and Lot Splits (SB 9) and Accessory Dwelling Unit (ADU)
G) CalMatters Article – California HOA Triumphs Over ADU Law Elizabeth Bruny, Mayor (District 5)
Melodie Szymkowski, Mayor Pro Tem (District 2)
Richard T. Hale, Council Member (District 1)
Richard Barakat, Council Member (District 3)
Bruce Lathrop, Council Member (District 4)
1 Public Hearing and Introduction of Ordinance No. 401

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H) Dudek Memorandum regarding ADU Law
I) Emails from Mr. Al Garcia and Mr. David Szymkowski re Ord. No. 401 J) Maps of Existing Street Widths of Less Than 20 Feet
i) Woodlyn Lane & Bradbury Hills Road
ii) Furlong Road & Oak Knoll Lane
iii) Barranca Road

SUMMARY
State law regulates Accessory Dwelling Units (ADUs), Junior Accessory Dwelling Units (JADUs), and SB 9 developments. The City’s codes need to be amended to comply with 2025 legislation that became effective in January 2026. The attached Ordinance No. 401 (Attachment A) addresses the required amendments and includes an amendment recommended by the Planning Commission to prohibit the development of Secondary Living Quarters (ADUs, JADUs, Guest Houses, SRO Units & SRO Developments) and SB 9 Units at properties that only have access from roadways that are less than 20 feet wide. There are also minor amendments proposed by staff for clarification purposes. The Planning Commission adopted Resolution No. PC 26-330 (Attachment C) to recommend that the City Council approve and adopt Ordinance No. 401.

It is recommended that the City Council introduce Ordinance No. 401.

BACKGROUND
In April 2020, the City Council adopted Ordinance No. 372 to provide local regulations for Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units (JADUs). In July 2022, the Council adopted Ordinance No. 383 for local regulations for SB 9 developments, and included a preclusion of Secondary Living Quarters and SB 9 Units on lots that have access only from roadways that are less than 20 feet wide. In October 2023, the Council adopted Ordinance No. 388 to again amend the codes to comply with State legislation, but also to rescind the preclusion of Secondary Living Quarters and SB 9 Units from properties on roadways of less than 20-foot widths. This was done at the advisement of the Department of Housing and Community Development (HCD) during the review and approval process of the City’s Sixth-Cycle Housing Element.

The State enacted further amendments to the ADU, JADU and SB 9 laws and the City adopted Ordinance No. 398 in July 2025 to amend the City regulations accordingly. The City’s codes need to be amended again to comply with legislation that became effective at the beginning of this year.

Attached is Ordinance No. 401 (Attachment A) that addresses the required amendments, and additionally, as recommended by the Planning Commission, includes the reenactment of the provision that prohibits Secondary Living Quarters and SB 9 Units on lots that have access only from roadways that are less than 20 feet wide. The attached 2 Public Hearing and Introduction of Ordinance No. 401

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redline version of Ordinance No. 401 (Attachment B) shows the changes to the various regulations.

PLANNING COMMISSION ACTION
The Planning Commission adopted Resolution No. PC 26-330 (Attachment C) at the July 22, 2026, meeting to recommend that the City Council approve and adopt Ordinance No. 401. Public hearings were held at the March 25, 2026, May 27, 2026 and July 22, 2026 meetings. The May 27, 2026 meeting also included a discussion item on SB 9 and ADUs.

At the Planning Commission meetings, several residents of the Bradbury Oaks Estates (BOE) addressed the Commission about the inapplicability of SB 9 to their area because of their CC&Rs. They also expressed concern about the inadequate widths of many of the roads in their neighborhood and the problems it causes for emergency fire vehicles to access the properties and for evacuation. Attachment D is the Minutes of the March 25, 2026 and May 27, 2026 Planning Commission meetings. Attached to these Minutes are the following exhibits presented by residents of the BOE:
i) Map of 33 – 41 Woodlyn Lane
ii) Fire Hazard Severity Zones Map
iii) Evacuation Routes Map
iv) “Does Not Apply” Statement regarding SB 9 from the California State Portal v) Letter by State Senator Toni G. Atkins regarding SB 9 vi) SB 9 Lot Splits article from Adams Stirling P.L.C.
vii) Emergency Plan Map
viii) Five Photos of Narrow Roadway serving 35, 37 & 39 Woodlyn Lane ix) Evacuation Routes Information
x) Table 13. Policies and Actions Related to Evacuation xi) AI Overview regarding SB 9
xii) Findings of Denial excerpt
Attachment E is the Minutes of the July 22, 2026 Planning Commission meeting, which are in draft form. They are on the Commission’s September 23, 2026 agenda for review and approval. These Minutes do not have attachments.

At the May 27, 2026 meeting the Planning Commission had a discussion item for SB 9 and ADUs. To facilitate the discussion, the Commission was provided with the attached HCD Fact Sheets and a CalMatters article (Attachments F & G). Following the discussion, the Commission held a public hearing for draft Ordinance No. 401. After closing the public hearing, the Commission directed staff to revise Ordinance No. 401 to preclude Secondary Living Quarters and SB 9 units in areas without adequate roadways for emergency access and evacuation, and to schedule a public hearing for the revised draft Ordinance. Staff examined information about fire risk, emergencies, and roadway widths, and cites the following information and resources:
3 Public Hearing and Introduction of Ordinance No. 401

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• The majority of the City of Bradbury is located in a very high fire hazard severity zone (VHFHSZ). There are numerous properties with horses and other livestock in these areas; • State of Emergencies have become a yearly occurrence in California due to wildfires; • Since 1953 there have been four separate wildfires that have burned through Bradbury and the neighboring communities, including in November 1980 when approximately 50 units were lost in wildfires;
• Since the time that the Governor signed the 2019 ADU/JADU legislation into law, there have been thousands of wildfires in California which have burned tens of thousands of acres, damaged or destroyed hundreds of homes and other structures, caused the death of many people, and resulted in injuries to many more; • In 2020, the Bobcat Fire caused evacuation warnings to be issued to parts of Bradbury; • According to CalFire, in 2025 there were 8,232 wildfires which burned over half-amillion acres resulting in 31 fatalities and the destruction of 16,627 structures. These fires included the tragic Palisades Fire and Eaton Fire in Los Angeles County. The Eaton Fire caused evacuation warnings in Bradbury;
• In 2020, Dudek Consultants prepared a memorandum (Dudek Memorandum) for the City relating to an analysis of ADU law on fire safety – Attachment H. • According to the Los Angeles County Fire Code which has been adopted by reference by the City of Bradbury, and as pointed out in the Dudek Memorandum, the minimum road width needed for fire access is 20 feet unobstructed paved width based on the standard width of fire engines and their ability to pass one another; • The Los Angeles County Fire Code, as pointed out in the Dudek Memorandum, requires vehicular access in order to allow a hose to be pulled therefrom and reach all points around the exterior of a structure within 150 feet; • The Dudek Memorandum also concludes among other things that the four-foot setback requirements and the inability to require fire sprinklers would likely have negative fire related impacts in Bradbury and recommends that fire sprinklers should be required whenever possible;
• The standard width of a fire truck in Los Angeles County, mirror to mirror, is approximately 9 to 10 feet. The standard size of a passenger vehicle is approximately 6 to 7 feet. The width of a horse trailer can be up to 8½ feet; • When a road is less than 20 feet wide, it can impede the access of fire apparatus as a fire truck is not able to pass a passenger vehicle, let alone a vehicle evacuating horses.

If a person evacuating were to have an accident, it could prevent fire apparatus from reaching the fire;
• During the Palisades Fire, bulldozers had to clear abandoned cars so firetrucks could drive past;
4 Public Hearing and Introduction of Ordinance No. 401

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• There are a number of roads within the City that are less than 20 feet in width as shown on the attached maps (Attachment J);
• Residents living on narrow roads within the City of Bradbury have been informed by the Los Angeles County Fire Department that if there is a fire, the Department may not be able to provide service;
• Government Code § 51182 provides that when property is within a very high fire hazard severity zone, there should be 100 feet of defensible space maintained for each side and from the front and rear of the structure, but not beyond the property line; • The majority of the City of Bradbury is zoned R-20,000, A-1, A-2, or A-5 with rear and side yard setbacks of 15 feet in the R-20,000 zone and 25 feet in the three ‘Agricultural’ (“A”) zones, meaning that accessory living quarters and other structures cannot be located closer than 30 feet to each other in these areas; • Under the law pertaining to both ADUs and SB 9 (two-unit housing developments), the City is not allowed to impose a setback of more than four feet from the side and rear property lines, leading to situations where there is a reduction in defensible space; • On August 18, 2020, the International City/County Management Association released a document titled “21st Century – Fire and Emergency Services” which contained the recommendation to “Embrace the use of fire sprinkler technology in all buildings through the rapid adoption of codes and ordinances at the federal, state, and local government levels to dramatically reduce the incidence of deadly and costly fires”. • According to the Southern California Association of Governments’ (SCAG) community profile, only 4.5% of the housing stock in Bradbury was built after 2010, when residential sprinkler systems became a requirement. Therefore, when ADUs are built, fire sprinklers cannot be required on the majority of properties. • Government Code section 66314 provides that cities may designate the areas where ADUs may be permitted based on the impact on traffic flow and public safety. The City Council specifically determines that the findings set forth above demonstrate that where streets are below the width to allow adequate access by fire apparatus, compounded with the inability to provide sufficient setbacks and new residents which will add to the traffic, there is an impact on traffic and public safety which allows the City to restrict the development of additional residential units in such areas. • Government Code sections 65852.21 and 66411.7 provide that the City’s building official may deny a proposed housing development project and lot split under SB 9 if there is a specific, adverse impact on the public health and safety for which there is no feasible method to mitigate or avoid the impact. The requirement that all streets be a minimum width of 20 feet due to the findings set forth above, provides a specific, adverse impact based on an objective standard.
5 Public Hearing and Introduction of Ordinance No. 401

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Ordinance No. 401 was redrafted per the Planning Commission direction and a public hearing for the revised draft Ordinance was scheduled and noticed for the regular Planning Commission meeting of July 22, 2026. In response to the public hearing notice, the attached emails (Attachment I) were received from Mr. Al Garcia of the Woodlyn Lane Improvement Association (WLIA) and Mr. David Szymkowski, a resident of Bradbury Hills Road. Also provided were the attached maps (Attachment J) of Existing Street Widths that have widths of less than 20 feet. After the public hearing, the Planning Commission adopted Resolution No. PC 26-330 (Attachment C) to recommend that the City Council approve and adopt Ordinance No. 401.

ORDINANCE NO. 401
Ordinance No. 401 includes the aforementioned findings related to fire safety. These are presented in Section 1 of the Ordinance. The amendments are presented in Sections 2 – 5 of the Ordinance. The redline version (Attachment B) shows the amendments required by State law with the relevant legislation noted in parentheses.

Section 2 amends the definition of Emergency Shelter to delete ‘minimal’ from the description of supportive services that are to be provided with emergency shelters for the homeless. This is in accordance with SB 340 – Health & Safety Code § 50801.

Section 3 amends the following sections of Chapter 85 to bring the City’s regulations for ADUs, JADUs, and SB 9 Units into conformance with State law; adds the preclusion recommended by the Planning Commission; and provides clarifications as noted by staff:

Sec. 9.85.040 – Adds “Prohibited Locations” to preclude ADUs, accessory living quarters (i.e., guest houses and SRO units) or SB 9 units on properties that have access only from the streets listed below due to their widths being less than 20 feet and not being able to provide adequate access for emergency fire vehicles and being problematic for evacuation purposes – see Attachment J for maps of these streets where Secondary Living Quarters and SB 9 Units are prohibited:
(a) Furlong Lane – between Deodar Lane and Long Canyon Road; (b) Oak Knoll Lane – east of Bliss Canyon Road;
(c) Woodlyn Lane – between Bradbury Hills Road and El Cielo Lane; (d) Bradbury Hills Road;
(e) Bradbury Hills Lane; and
(f) El Cielo Lane.

Sec. 9.85.110 – New subsections (a), (a)(1) and (a)(2) are added regarding the determination of ADU and JADU application completeness. (SB 543 – Gov. Code §§ 66317 & 66335.)
Sec. 9.85.115 – A new subsection (d) is added regarding appeals of ADU and JADU application denials. (SB 543 – Gov. Code §§ 66317 & 66335.) 6 Public Hearing and Introduction of Ordinance No. 401

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Secs. 9.85.130(e)(1) and (g)(6)(f) – The wordings are amended for clarification.

Sec. 9.85.130 – For clarification, a new subsection (k) is added to inform applicants that no portion of an ADU may encroach into any public or private easement unless the easement holder provides written permission, or the applicant provides a written declaration under penalty of perjury affirming permission. This amendment is not specifically required by State ADU law, but there are laws that prohibit construction over an easement belonging to someone else.

Secs. 9.85.135(a) and (b) – The wordings are amended to clarify the fire sprinkler requirements for ADUs and JADUs. (SB 543 – Gov. Code §§ 66323 & 66314.) Secs. 9.85.140(a) and (a)(2) are amended and a new subsection (d) is added to clarify the mandatory approvals for ADU and JADU applications. The new subsection (d) is added to clarify that the ADUs/JADUs that are required to be permitted under the mandatory approval section of 9.85.140 are not to be combined with the units allowed under section 9.85.110. This is not set forth in State ADU law.

Sec. 9.85.150(d) is amended to add wording requiring owner residency only if a JADU does not have independent sanitation facilities. (AB 1154 – Gov. Code § 66333.) Sec. 9.85.150(f)(2) is amended to specify that the 500 square-foot limit for JADUs is to be based on interior livable square feet. (SB 543 – Gov. Code § 66313.) Secs. 9.85.150(f)(3) and (f)(4) are deleted from the provisions for JADU deed restrictions. HCD has indicated that the deed restriction may only contain the provisions specifically identified in State ADU law. The restriction on renting for less than 31 days remains; but is not included in the required deed restriction. (HCD Handbook and Gov. Code § 66333.)
Sec. 9.85.160(b)(1) – This subsection is amended to clarify that the ADU and JADU short-term rental prohibition means rental for not less than 31 consecutive calendar days. (AB 1154 – Gov. Code §§ 66333 & 66315.)
Secs. 9.85.160(c)(1) and (c)(2) are amended to clarify that the city shall not impose owner/occupancy requirements on ADUs, and to clarify the owner-occupancy requirement for a JADU that shares sanitation facilities with the primary unit. (AB 1154 – Gov. Code § 66333.)
Sec. 9.85.160(j) is added to specify that all references to square-footage limits of an ADU or JADU are to be based on interior livable square feet. (SB 543) Sec. 9.85.300(b) is amended to clarify that when a lot has been split per SB 9, the allowed accessory living quarters on the original A-1, A-2 or A-5 zoned lot, shall be split between the two new lots at the same proportion as the lot split. 7 Public Hearing and Introduction of Ordinance No. 401

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Sec. 9.85.300(e) is amended to increase the separation requirement of detached accessory living quarters from 20 feet to 30 feet from any other building to be consistent with the minimum 15-foot setbacks of the R-20,000 zone. The ‘A’ zones have minimum 25-foot setbacks.

Sec. 9.85.400 – the definition of ‘Housing development’ is amended to clarify that it is applicable to Article IV regarding SB 9 Units, and the definitions of ‘Primary unit’ and ‘Unit’ are added for clarification of the types of SB 9 units. (HCD SB 9 Fact Sheet.) Sec. 9.85.410(a) is added to include the 30-day limit for determination of a complete application for a SB 9 unit. (Gov. Code § 65943.)
Sec. 9.85.420(b) is amended relating to the language regarding historic resources to track state law. [AB 1061 – Gov. Code § 65852.21(a)(5)] Sec. 9.85.440(d) is amended to clarify that ‘access’ and not just driveways are to be provided in accordance with Chapter 103 of the Bradbury Development Code.

Sec. 9.85.440(f) is amended to clarify that if a property is on a septic system, the applicant ‘shall’ provide the required percolation tests.

Sec. 9.85.440 (h) is amended to clarify that the accessory living quarters allowed on the original single lot, ‘shall’ be split between the two new SB 9 lots as provided for in section 9.85.300.

Sec. 9.85.460(c) is amended to clarify the specific applicable section number for ease of reference.

Section 4 of the Ordinance addresses the following amendments of Chapter 164, which is for Urban Lot Splits per SB 9:

Sec. 9.164.020(a) is added to include the 30-day limit for determination of a complete application for a SB 9 lot split. (Gov. Code § 65943.)
Sec. 9.164.030(e)(1) – This subsection is amended to clarify that ministerial approval may not be applicable if a parcel is located within a historical landmark property and not just in a historic district. [AB 1061 – Gov. Code § 66411.7(a)(3)(E)] Sec. 9.164.030 – New subsections (f)(3) and (f)(4) are added to specify that ministerial approval is required if the lot split does not require demolition or alteration of a contributing structure within a historic district, or an existing exterior structural wall of a structure located within a historic district. [AB 1061 – Gov. Code § 66411.7(a)(3)(F)] Sec. 9.164.060(d) is amended to clarify the specific applicable section number for ease of reference.
8 Public Hearing and Introduction of Ordinance No. 401

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Sec. 9.164.060(e) is amended to change ‘may’ to ‘shall’ to clarify that the splitting of the allowed accessory living quarters square footage is a requirement.

Section 5 of the Ordinance addresses the applicability of architectural review (Chapter 34). Section 9.34.020(a)(2) is amended for grammatical consistency, and Section

9.34.020(c) is amended to delete the reference to, ‘very high fire zone accessory dwelling units’ and adds JADUs and SB 9 units, as well as, ‘any other approval where such application is preempted by State law.’ This is to be consistent with the requirements of Chapter 85.

FINANCIAL REVIEW
There will be no additional financial cost to the City as Ordinance No. 401 implements measures that are already handled by existing applications and processes, and are required by State law.

ENVIRONMENTAL REVIEW
There are statutory exemptions from the California Environmental Quality Act (CEQA) in Public Resources Code Section 21080.17 and Government Code Sections 65852.21 and 66411.7 for ordinances relating to ADUs, JADUs, and SB 9, and there is the common sense exemption of CEQA Guidelines Section 15061(b)(3) for a project that clearly will not have a significant impact on the environment. The Planning Commission recommends that Ordinance No. 401 qualifies for these exemptions.

FINDINGS
The proposed ordinance is consistent with the City’s General Plan and will further Statewide housing goals.

PUBLIC NOTICE
At least ten days prior to the September 22, 2026 meeting, a notice of the public hearing was posted at the three locations required by Resolution No. 1226 and mailed to the owners of property in the BOE.

RECOMMENDATION
It is recommended that the City Council hold a public hearing, determine that Ordinance No. 401 is exempt under CEQA, introduce the Ordinance, and schedule the second reading and adoption for the next regular meeting on October 20, 2026. 9 - This page intentionally blank -
10 ATTACHMENT A
Agenda Report – September 22, 2026
ORDINANCE NO. 401
11

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ORDINANCE NO. 401

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF BRADBURY, CALIFORNIA AMENDING SECTION 9.25.020 OF THE BRADBURY

DEVELOPMENT CODE RELATING TO DEFINITIONS, AMENDING
SECTION 9.34.020 REGARDING ARCHITECTURAL REVIEW,
AMENDING CHAPTER 9.85 OF THE BRADBURY DEVELOPMENT

CODE RELATING TO ACCESSORY DWELLING UNITS, JUNIOR
ACCESSORY DWELLING UNITS, AND SB 9 UNITS, AND AMENDING
CHAPTER 9.164 OF THE BRADBURY MUNICIPAL CODE RELATING

TO URBAN LOT SPLITS, AND FINDING THAT THIS ORDINANCE IS

EXEMPT FROM CEQA PURSUANT TO PUBLIC RESOURCES CODE
SECTION 21080.17 AND GOVERNMENT CODE SECTIONS 65852.21
AND 66411.7 AND THE COMMON SENSE EXEMPTION OF CEQA
GUIDELINES SECTION 15061(b)(3)
WHEREAS, the City has previously adopted and amended Chapter 9.85 relating to Accessory Dwelling Units (ADUs), Junior Accessory Dwelling Units (JADUs), SB 9 units, and accessory living quarters; and
WHEREAS, the City has adopted Chapter 9.164 relating to urban lot splits to implement SB 9; and
WHEREAS, the Legislature has continued to amend the state statutes relating to ADUs, JADUs and SB 9, as well as revising the definition of emergency shelters which necessitates additional changes to the City’s provisions regarding these uses; and WHEREAS, the Planning Commission held a duly noticed public hearing on March 25, 2026, and May 27, 2026, at which times the Commission considered all evidence presented, both written and oral; and
WHEREAS, after the close of the public hearing on May 27, 2026, the Commission directed staff to return with a revised draft Ordinance which incorporated provisions regarding the prohibition on development in areas where the streets are below 20 feet in width; and
WHEREAS, an additional duly noticed public hearing was held on July 22, 2026 at which time the Commission considered all evidence presented, both written and oral; and WHEREAS, after the close of the public hearing the Planning Commission adopted Resolution No. PC 26-330 recommending that the City Council adopt this Ordinance; and WHEREAS, the City Council held a duly noticed public hearing on _____ __, 2026, at which time the Council considered all evidence presented, both written and oral.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF BRADBURY, CALIFORNIA DOES HEREBY ORDAIN AS FOLLOWS:
12

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SECTION 1. The City Council does hereby make the following findings relating to fire issues and the need to restrict development in areas with a street width of less than 20 feet:

A. The majority of the City of Bradbury is located in a very high fire hazard severity zone (VHFHSZ). There are numerous properties with horses and other livestock in these areas;
B. State of Emergencies have become a yearly occurrence in California due to wildfires;
C. Since 1953 there have been four separate wildfires that have burned through Bradbury and the neighboring communities, including in November 1980 when approximately 50 units were lost in wildfires;
D. Since the time that the Governor signed the 2019 ADU/JADU legislation into law, there have been thousands of wildfires in California which have burned tens of thousands of acres, damaged or destroyed hundreds of homes and other structures, caused the death of many people, and resulted in injuries to many more; E. In 2020, the Bobcat Fire caused evacuation warnings to be issued to parts of Bradbury;
F. According to CalFire, in 2025 there were 8,232 wildfires which burned over half-a-million acres resulting in 31 fatalities and the destruction of 16,627 structures.

These fires included the tragic Palisades Fire and Eaton Fire in Los Angeles County. The Eaton Fire caused evacuation warnings in Bradbury;
G. In 2020, Dudek Consultants prepared a memorandum (Dudek Memorandum) for the City relating to an analysis of ADU law on fire safety.

H. According to the Los Angeles County Fire Code which has been adopted by reference by the City of Bradbury, and as pointed out in the Dudek Memorandum, the minimum road width needed for fire access is 20 feet unobstructed paved width based on the standard width of fire engines and their ability to pass one another; I. The Los Angeles County Fire Code, as pointed out in the Dudek Memorandum, requires vehicular access in order to allow a hose to be pulled therefrom and reach all points around the exterior of a structure within 150 feet; J. The Dudek Memorandum also concludes among other things that the fourfoot setback requirements and the inability to require fire sprinklers would likely have negative fire related impacts in Bradbury and recommends that fire sprinklers should be required whenever possible;
K. The standard width of a fire truck in Los Angeles County, mirror to mirror, is between approximately 9 to 10 feet. The standard size of a passenger vehicle is approximately 6 to 7 feet. The standard width of a horse trailer can be up to 8½ feet; 13

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L. When a road is less than 20 feet wide, it can impede the access of fire apparatus as a fire truck is not able to pass a passenger vehicle, let alone a vehicle evacuating horses. If a person evacuating were to have an accident, it could prevent fire apparatus from reaching the fire;
M. During the Palisades Fire, bulldozers had to clear abandoned cars so firetrucks could drive past;
N. There are a number of roads within the City that are less than 20 feet in width; O. Residents living on narrow roads within the City of Bradbury have been informed by the Los Angeles County Fire Department that if there is a fire, the Department may not be able to provide service;
P. Government Code § 51182 provides that when property is within a very high fire hazard severity zone, there should be 100 feet of defensible space maintained for each side and from the front and rear of the structure, but not beyond the property line; Q. The majority of the City of Bradbury is zoned R-20,000, A-1, A-2, or A-5 with rear and side yard setbacks of 15 feet in the R-20,000 zone and 25 feet in the three ‘Agricultural’ (“A”) zones, meaning that accessory living quarters and other structures cannot be located closer than 30 feet to each other in these areas; R. Under the law pertaining to both ADUs and SB 9 (two unit housing developments), the City is not allowed to impose a setback of more than four feet from the side and rear property lines, leading to situations where there is a reduction in defensible space;
S. On August 18, 2020, the International City/County Management Association released a document titled “21st Century – Fire and Emergency Services” which contained the recommendation to “Embrace the use of fire sprinkler technology in all buildings through the rapid adoption of codes and ordinances at the federal, state, and local government levels to dramatically reduce the incidence of deadly and costly fires”; T. According to the Southern California Association of Governments’ (SCAG) community profile, only 4.5% of the housing stock in Bradbury was built after 2010, when residential sprinkler systems became a requirement. Therefore, when ADUs are built, fire sprinklers cannot be required on the majority of properties.

U. Government Code section 66314 provides that cities may designate the areas where ADUs may be permitted based on the impact on traffic flow and public safety. The City Council specifically determines that the findings set forth above demonstrate that where streets are below the width to allow adequate access by fire apparatus, compounded with the inability to provide sufficient setbacks and new residents which will add to the traffic, there is an impact on traffic and public safety which allows the City to restrict the development of additional residential units in such areas. 14

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V. Government Code sections 65852.21 and 66411.7 provide that the City’s building official may deny a proposed housing development project and lot split under SB 9 if there is a specific, adverse impact on the public health and safety for which there is no feasible method to mitigate or avoid the impact. The requirement that all streets be a minimum width of 20 feet due to the findings set forth above, provides a specific, adverse impact based on an objective standard.

SECTION 2. Section 9.25.020 of the Development Code is hereby amended by revising the following definition:

Sec. 9.25.020. – Definitions of specialized terms and phrases.

Emergency shelter is defined in Health and Safety Code § 50801 as housing with supportive services for homeless persons that is limited to occupancy of six months or less by a homeless person. An “emergency shelter” shall include other interim interventions, including, but not limited to, a navigation center, bridge housing, and respite or recuperative care. No individual or household may be denied emergency shelter because of an inability to pay.

SECTION 3. Chapter 85 of Title IX, Development Code, is hereby amended to read as follows (SB 450 and ADU updates):

CHAPTER 85. – SECONDARY LIVING QUARTERS AND SB 9 UNITS
ARTICLE I. GENERAL
Sec. 9.85.010. Purpose.
(a) The purpose of this chapter is to implement the requirements for the establishment of accessory dwelling units, junior accessory dwelling units, secondary living quarters and Senate Bill 9 (Ch. 162, 2021 Legislative Session) housing. (b) In cases of conflict between this chapter and any other provision of this title, the provisions of this chapter shall prevail. To the extent that any provision of this chapter is in conflict with State law, the mandatory requirement of State law shall control, but only to the extent legally required.

Sec. 9.85.020. Summary of allowed development.

The development allowed in each zone under this Chapter for the primary unit, ADUs and JADUs, SB 9 developments, and Accessory Living Quarters (ALQ) shall be as summarized in the Table below and as further described in the specific provisions of each of the Articles of this Chapter.

ZONE ALLOWED DEVELOPMENT
R-7,500 • Primary unit – 1,500 square foot minimum
• ADU – 1,000 SF max; 800 SF max if combined with JADU
• JADU – 500 SF max
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R-20,000 • Primary unit – 1,850 square foot minimum
• ADU – 1,000 SF max; 800 SF max if combined with JADU
• JADU – 500 SF max
• SB 9 development without lot split – 2 primary units, one of which must meet minimum development size; may have ADU and JADU
• SB 9 development with lot split – 2 units with at least one primary on each lot; ADU and JADU count towards unit numbers. Only one primary unit must meet the minimum development size.

A-1 • Primary unit – 2,250 square foot minimum
• ADU – 1,000 SF max; 800 SF max if combined with JADU
• JADU – 500 SF max
• SB 9 development without lot split – 2 primary units, one of which must meet minimum development size; may have ADU and JADU
• SB 9 development with lot split – 2 units with at least one primary on each lot; ADU and JADU count towards unit numbers. Only one primary unit must meet the minimum development size.
• ALQ of up to 1,500 SF which can be split between SRO development of 2-4 units and guest house. If lot is split, divide proportionately to the lot split percentage.

A-2 • Primary unit – 2,500 square foot minimum
• ADU – 1,000 SF max; 800 SF max if combined with JADU
• JADU – 500 SF max
• SB 9 development without lot split – 2 primary units, one of which must meet minimum development size; may have ADU and JADU
• SB 9 development with lot split – 2 units with at least one primary on each lot; ADU and JADU count towards unit numbers. Only one primary unit must meet the minimum development size.
• ALQ of up to 2,000 SF which can be split between SRO development of 2-6 units and guest house. If lot is split divide proportionately to the lot split percentage.

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• SB 9 development with lot split – 2 units with at least one primary on each lot; ADU and JADU count towards unit numbers. Only one primary unit must meet the minimum development size.
• ALQ of up to 2,500 SF which can be split between SRO development of 2- 10 units and a guest house. If lot is split, divide proportionately to the lot split percentage.
(a) For size of primary unit, see the requirement of the specific zone. (b) For ADU/JADU see Chapter 85, Article II.
(c) For SB 9, see Chapter 85, Article IV.
(d) For ALQ (Accessory Living Quarters), Chapter 85, Article III.

Sec. 9.85.030. Los Angeles County fire department/building code requirements.

Notwithstanding any other provision in this chapter to the contrary, all new construction must:
(a) Meet the requirements of the Los Angeles County Fire Department; and (b) Comply with the provisions of the California Building Code as set forth in Title XVII of the Bradbury Municipal Code.

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ARTICLE II.

ACCESSORY DWELLING UNITS AND JUNIOR ACCESSORY DWELLING UNITS Sec. 9.85.100. Purpose/Definitions
(a) The purpose of this article is to implement the requirements for the establishment of accessory dwelling units and junior accessory dwelling units as required by the State ADU Law (California Government Code sections 66310 through 66342). (b) For purposes of this Chapter 9.85, words and phrases defined in the State ADU Law shall have the same meaning when used herein.

Sec. 9.85.110. Applications.
(a) The City shall determine whether an application for an ADU or JADU is complete within 15 business days after receipt of the application. (1) If the City determines the application is incomplete, it shall provide the applicant with a list of incomplete items and a description of how the application may be made complete within the 15 business day time period.
(2) If a determination is not made within the 15 business days, the application or any resubmitted application shall be deemed to be complete.(b) Applications for accessory dwelling units (ADUs) and junior accessory dwelling units (JADUs) shall be ministerially approved or denied within 60 days of receipt of a completed application and shall be approved if they meet the requirements of this chapter. (1) If the application is submitted in conjunction with an application for a new primary single-family unit, the application for the ADU or JADU shall not be acted upon until the application for the new primary single-family unit is approved. (2) The City shall grant a delay if requested by the applicant. (3) Notwithstanding the above, if the applicant uses a plan for an accessory dwelling unit that has been preapproved by the City or a plan that is identical to a plan used in an application for a detached accessory dwelling unit approved by the City within the current triennial California Building Standards Code cycle, the application shall be approved or denied within 30 days from the date of a completed application. (c) All applications for ADUs and JADUs shall be accompanied by the applicable application fee.
(d) ADUs and JADUs shall be subject to applicable inspections and permit fees. (e) If an application for a detached ADU requires demolition of a detached garage, the application shall be submitted with the demolition application and the two applications shall be reviewed at the same time. If the ADU is approved, the permits shall be issued at the same time.
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Sec. 9.85.115. Denial.
(a) If the City denies an application for an ADU or JADU, the City shall return a full set of comments to the applicant with a list of items that are defective or deficient and a description of how the application can be remedied. The comments must be in writing and returned to the applicant within 60 days of receipt of a completed application. (b) No application shall be denied due to the need to correct a nonconforming zoning condition, building code violation, or due to unpermitted structures, unless those conditions present a threat to the public health and safety and are affected by the construction of the ADU, or JADU.
(c) No application or permit shall be denied for an ADU or JADU that was constructed prior to January 1, 2020, based on either of the following:
(1) The ADU is in violation of building standards pursuant to Article 1 of Chapter 5 of Part 1.5 of Division 13 of the Health and Safety Code (commencing with section 17960); or (2) The ADU does not comply with State law or the provisions of the Bradbury Development Code regulating ADUs.
(3) Subparagraphs (1) and (2) of this subsection (c) shall not apply if the City makes a finding that correcting the violation is necessary to comply with the standards specified in Health and Safety Code section 17920.3 or if the building is deemed substandard pursuant to Health and Safety Code section 17920.3. (4) Upon receiving an application to permit a previously unpermitted ADU or JADU constructed before January 1, 2020, an inspector from the City may inspect the unit for compliance with health and safety standards and provide recommendations to comply with such standards in order to obtain a permit. The City shall not penalize an applicant for having the unpermitted ADU or JADU and shall approve necessary permits to correct noncompliance with health and safety standards.
(d) Appeals. Notwithstanding anything in this Code to the contrary, the applicant may appeal a denial of an application or a determination that an application is incomplete directly to the City Council. A final written determination shall be provided to the applicant no later than 60 days after the receipt of the written appeal and applicable fees.

Sec. 9.85.120. Allowed zones/density.
(a) An ADU or JADU may be constructed in any zone on a lot which contains an existing or proposed primary unit.
(b) ADUs and JADUs shall not count in determining density or lot coverage and are considered a residential use consistent with the existing general plan and zoning designation for the lot.
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Sec. 9.85.130. Accessory dwelling units (ADUs) – Development standards/ requirements.
(a) Type of building. An attached or detached ADU shall be a permanent structure on a permanent foundation with permanent provisions for living, sleeping, food preparation, sanitation, and bathing. A manufactured home as defined by California Health and Safety Code section 18007 shall qualify. An ADU includes an efficiency unit as defined by Health and Safety Code section 17958.1.
(b) Location of ADU. An ADU may be located within, attached to, or detached from an existing or proposed primary unit as further set forth in Government Code section 66314(d).
(c) Height. The height of an ADU shall be as follows:
(1) A height of 18 feet for a detached accessory dwelling unit on a lot with an existing or proposed single family or multifamily dwelling unit. (2) A height of 18 feet for a detached accessory dwelling unit on a lot with an existing or proposed single family or multifamily dwelling unit that is within one-half mile walking distance of a major transit stop or a high-quality transit corridor. An additional two feet shall be allowed if required to accommodate a roof pitch on the accessory dwelling unit that is aligned with the roof pitch of the primary dwelling unit. (3) A height of 18 feet for a detached accessory dwelling unit on a lot with an existing or proposed multifamily, multistory dwelling.
(4) A height of 25 feet or the height limit of the applicable zone that applies to the primary dwelling, whichever is lower, for an accessory dwelling unit that is attached to a primary dwelling unit or built above an existing garage. In no event shall the accessory dwelling unit exceed two stories.
(5) An ADU converted from previously existing permitted space which already exists above the permitted ground floor area or garage – to the height already existing if greater than the height set forth in subsections (c)(1) - (4), above. (d) Size.
(1) Maximum size – an attached or detached ADU shall not exceed 1,000 square feet. (2) Minimum size – the square footage of an ADU shall not be less than that allowed for an efficiency unit.
(e) Application of underlying development standards.
(1) The objective development standards of the underlying zone shall apply, except as may be specified in this chapter.
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(2) If application of any development standard of the underlying zone or this chapter prevents the construction of an ADU that meets the height requirements specified in subsection (c), such development standard shall be waived to the extent needed to allow an 800 square foot ADU. The waiver of standards does not apply to the requirement for minimum four-foot side and rear yard setbacks.
(f) Setbacks.
(1) Attached and detached ADUs shall be located behind the front yard setback line of the primary unit.
(2) The maximum side and rear yard setback requirements for an ADU, including an ADU added in an already existing and permitted space above a garage or other floor area shall be four feet. This does not prevent the applicant from providing a larger setback. (3) The setback requirements in subsections (f)(1) and (2) above shall not apply if the ADU is being converted from an existing accessory structure, including a garage, or is being constructed in the same location and to the same dimensions as an existing accessory structure, including a garage.
(g) Parking.
(1) Parking shall be required at the rate of one space for each ADU. (2) Parking spaces for an ADU may be provided through tandem parking on an existing driveway; provided, that such parking does not encroach into the public right-ofway or a private street. (3) Parking spaces for ADUs may be provided in the paved portions of setback areas; provided, that the amount of paving does not exceed the total amount of paving and hardscaped areas that are otherwise allowed by this title at the time the ADU is approved.
(4) When a garage, carport, uncovered parking space, or covered parking structure is converted into an ADU, or is demolished to accommodate the construction of an ADU, such parking spaces need not be replaced.
(5) Tandem parking and parking in setback areas shall not be allowed if the City Manager makes specific findings that such parking is not feasible based upon specific site or regional topographical, or fire and life safety conditions. (6) Notwithstanding any other provision of this subsection (g), no additional parking shall be required for the ADU if any of the following conditions apply:
a. The ADU is located within one-half mile walking distance of a public transit stop; b. The ADU is located within an architecturally and historically significant historic district;
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c. The ADU is part of a proposed or existing primary unit or an existing accessory structure;
d. When on-street parking permits are required, but not offered to the occupant of the ADU;
e. When there is a car share vehicle located within one block of the ADU; or f. When a permit application for an accessory dwelling unit is submitted with a permit application to create a new single- or multi-family dwelling on the same lot, provided the ADU or parcel satisfies any other criteria listed in this section 9.85.130(g)(6). (h) Design.
(1) The ADU shall be the exact same color as the primary unit. (2) The ADU shall have the exact same roof pitch as the primary unit. (3) The ADU shall have a separate entrance from the primary unit. (i) Utilities—Connections, fees, and capacity charges.
(1) For an ADU contained within an existing primary unit, or an existing accessory structure meeting the requirements of section 9.85.140(a)(1) below, the City shall not require the installation of a new or separate utility connection between the ADU and the utility or impose a connection fee or capacity charge, unless the accessory dwelling unit was constructed with a new single-family dwelling.
(2) For all ADUs other than those described in subsection (i)(1) above, the City shall require a new or separate utility connection between the ADU and the utility and shall charge a connection fee or capacity charge that is proportionate to the burden of the proposed ADU based on the size or number of drainage fixture unit (DFU) values upon the water or sewer system.
(j) Impact fees.
(1) No impact fee shall be imposed on any ADU of up to 750 square feet in size. (2) Notwithstanding any fee resolution to the contrary, for ADUs larger than 750 square feet, impact fees shall be charged proportionately in relation to the square footage of the primary unit.
(3) All applicable public service and recreation impact fees shall be paid prior to occupancy in accordance with California Government Code sections 66000 et seq. and 66012 et seq.
(4) For purposes of this section, "impact fee" shall have the meaning set forth in California Government Code section 66324.
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(5) No impact fees or connection or capacity charges shall be imposed on a homeowner applying for a permit for a previously unpermitted ADU or JADU built before January 1, 2020, except when the utility infrastructure is required to comply with Health and Safety Code section 17920.3 and authorized by Government Code section 66324(e). (k) Easements. No portion of an accessory dwelling unit may encroach into any public or private easement such as a utility easement unless the easement holder has provided written permission to construct the accessory dwelling unit in the manner proposed. To establish a rebuttable presumption of compliance with this requirement, the applicant may provide a written declaration under penalty of perjury affirming compliance with this requirement. The declaration shall be in a form acceptable to the city attorney.

Sec. 9.85.135. Fire sprinklers.
(a) Fire sprinklers shall only be required in an ADU or JADU if they were/are required in the primary unit at the time of construction.
(b) The construction of an ADU or JADU shall not trigger a requirement for sprinklers to be installed in the primary unit.

Sec. 9.85.140. Mandatory approvals.
(a) Notwithstanding any other provision of this chapter, the City shall ministerially approve an application for any combination of the following categories of ADUs and/or JADUs within a residential zone, subject only to the provisions of this Section. (1) An ADU and a JADU within the existing or proposed space of the primary unit or accessory structure, subject to the following requirements:
a. An ADU or JADU shall have exterior access separate from the existing or proposed primary unit.
b. An expansion of up to 150 square feet shall be allowed for an existing accessory structure that is to be converted to an ADU, solely for the purpose of accommodating separate ingress and egress.
c. The side and rear yard setbacks shall be sufficient for fire and safety. d. The JADU shall comply with the requirements of sections 9.85.150 and

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limited to, storage rooms, boiler rooms, passageways, attics, basements, or garages, provided that each dwelling unit complies with State building standards for dwellings. For purposes of this section, “livable” means a space in a dwelling intended for human habitation, including living, sleeping, eating, cooking, or sanitation. (4) On a lot with an existing multifamily dwelling structure, there may be up to eight detached ADUs, but in no event more than the number of existing units, provided that none of the ADUs exceeds the height requirements set forth in sections 9.85.130(c)(1)- (c)(3) and that the ADUs have at least four-foot side and rear yard setbacks. (5) On a lot with a proposed multifamily dwelling, there may be up to two detached ADUs, provided that none of the ADUs exceeds the height requirements set forth in sections 9.85.130(c)(1) - (c)(3) and that the ADUs have at least four-foot side and rear yard setbacks.
(b) For those ADUs and JADUs that require mandatory approval under this section, the City shall not require the correction of legal, nonconforming zoning conditions as a condition of permit approval.
(c) Any ADU created under this Section 9.85.140 shall not be rented for a period of less than 31 days.
(d) ADUs and JADUs approved under this section may not be combined with any other ADU or JADU otherwise authorized by this Article II.

Sec. 9.85.150. Junior accessory dwelling units – Development standards/ requirements.
(a) One JADU shall be allowed on single-family residentially zoned lots in conjunction with an existing or proposed primary single-family unit, including in an attached garage.

A JADU may be allowed on the same lot as a detached ADU where the detached ADU is no larger than 800 square feet and does not exceed the height requirements set forth in section 9.85.130(c).
(b) The JADU shall be required to contain at least an efficiency kitchen which includes cooking appliances and a food preparation counter and storage cabinets that are of reasonable size in relation to the size of the JADU.
(c) The JADU shall be required to have a separate entrance from the primary unit. (d) The JADU may, but is not required to, include separate sanitation facilities. If separate sanitation facilities are not provided, the JADU shall share sanitation facilities with the primary single-family unit and shall have direct access to the primary unit from the interior of the JADU. If sanitation facilities are shared, the owner must reside in either the primary unit or the JADU.
(e) Parking.
(1) No additional parking shall be required for a JADU. 24

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(2) If a garage is converted to develop a JADU, no replacement parking shall be required. (f) The owner of the property on which a JADU is constructed shall record with the County Recorder of Los Angeles County, a deed restriction which shall run with the land and a copy of the recorded deed restriction shall be filed with the City after recordation.

The deed restriction shall provide for the following:
(1) A prohibition on the sale of the JADU separate from the sale of the primary unit; (2) A prohibition on the JADU being larger than 500 interior livable square feet; and (3) A statement that the deed restrictions may be enforced against future purchasers. (g) For the purposes of applying any fire or life protection ordinance or regulation, or providing service water, sewer, or power, including a connection fee, a JADU shall not be considered a separate or new dwelling unit.
(h) The City shall not require the correction of legal, nonconforming zoning conditions as a requirement for approval of a JADU.

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(f) Subsections (d) and (e) above shall not apply to any unpermitted accessory dwelling unit which is subject to Government Code section 66332 unless the City makes a finding that correcting the violation is necessary to protect the health and safety of the public or occupants of the structure.
(g) Guest houses that were previously approved and which have a valid building permit on file shall not be affected by this chapter. However, an application to convert a guest house to an ADU shall be subject to this chapter.
(h) Enforcement. Until January 1, 2030, the City shall issue a statement along with a notice to correct a violation of any provision of any Building Code standard relating to an ADU or JADU that provides substantially as follows:

You have been issued an order to correct violations or abate nuisances relating to your accessory dwelling unit or junior accessory dwelling unit. If you believe that this correction or abatement is not necessary to protect the public health and safety you may file an application with the City Manager. If the City determines that enforcement is not required to protect the health and safety, enforcement shall be delayed for a period of five years from the date of the original notice.

This provision shall only apply to ADUs and JADUs built before January 1, 2020. (i) The City shall not issue a certificate of occupancy for an ADU before it issues a certificate of occupancy for the primary dwelling unit. (j) All references to the square footage of an ADU or JADU are based on the square footage of the interior livable space.

ARTICLE III. ACCESSORY LIVING QUARTERS
Sec. 9.85.300. Development standards for accessory living quarters.

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be split between the two lots in the same percentage as the lot split created in accordance with Chapter 164, provided that the SRO Development on any lot must consist of a minimum of two units and the total square footage identified in subsection (a) above is not exceeded between the two lots.
(c) Accessory living quarters are permitted only on residential lots which are developed with an existing or proposed primary unit. The accessory living quarters may not be built before the primary unit.
(d) Accessory living quarters must comply with the Bradbury Development Code, applicable at the time the plans for Planning Department approval for the accessory living quarters are submitted.
(e) All accessory living quarters, whether attached or detached, must conform to all setback, lot coverage, floor area, emergency evacuation capacity, and building bulk requirements of the applicable zone, and if detached, must be at least 30 feet from any other building.
(f) The maximum allowed height for a detached accessory living quarter unit or building shall not exceed 28 feet, even when allowed as a second story above an existing primary unit, garage, or accessory structure.
(g) No accessory living quarter shall exceed one floor in height; however, that floor may be a second story.
(h) The owner of the property must occupy either the primary unit or an accessory living quarter unit.
(i) A minimum of one on-site parking space shall be provided for each accessory living quarter, in addition to the parking requirement for the primary single-family unit. The parking spaces for the accessory living quarters need not be covered, except for multifamily dwellings for which the parking spaces shall be in carports. All parking spaces shall be paved and accessible from a single, common driveway for the primary and accessory living quarter units. Tandem parking is not permitted to meet this off-street parking requirement.
(j) Single room occupancy (SRO) residential units within an SRO development are subject to the following additional requirements:
(1) Each SRO unit within the development shall have a minimum floor area of 150 square feet and a maximum floor area of 300 square feet. (2) Each SRO unit shall have a private toilet as defined by the California Residential Code.
(3) Each SRO unit shall have a separate closet.
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(4) Each SRO unit shall have an efficiency kitchen which shall include a cooking facility with appliances and a food preparation counter and storage cabinets that are of reasonable size in relation to the size of the SRO.
(5) Each SRO development shall have a laundry room for the storage of cleaning supplies, with a wash tub with hot and cold running water and a minimum of one washer and one dryer for the development.
(6) No more than two persons shall be allowed to reside in any SRO unit.

Sec. 9.85.310. Accessory living quarters – Neighborhood compatibility review – Standards.

All development of accessory living quarters shall be subject to the procedures for neighborhood compatibility review and approval pursuant to Chapter 34 of this title. In addition to the standards and determinations required by Chapter 34 of this title, the following findings shall be required for approval of accessory living quarters:
(a) The accessory living quarter(s) will be appropriate to the size and character of the lot on which it will be located, and to the character of the neighborhood. (b) The accessory living quarter(s) will not overload the capacity of the neighborhood to absorb the physical impacts of the unit(s) in terms of parking, adequacy of water and sewer services, traffic volumes and flows, emergency evacuation capacity, and utilities consumption.
(c) The accessory living quarter(s) will not be materially detrimental to the public health, safety, and general welfare, or to the use, enjoyment, or valuation of property of other persons located in the vicinity.

Sec. 9.85.320. Nonconforming uses.
(a) No nonconforming accessory living quarter(s) may be expanded or remodeled by the addition of any space or addition of plumbing fixtures or cooking facilities unless it is brought into compliance with the provisions set forth in this Code prior to occupancy. (b) Any accessory living quarter legally permitted prior to January 1, 2020, shall be allowed to remain as a legal, non-conforming use.

ARTICLE IV. SB 9 UNITS
Sec. 9.85.400. Definitions.

For purposes of this Article IV, the following definitions shall apply:

Housing development shall mean no more than two primary units on a lot within a singlefamily zone that meets the requirements of this Article. The two units may consist of two new units or one new unit and one existing unit.
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Primary unit shall mean a residential unit that is not otherwise classified as an accessory dwelling unit or junior accessory dwelling unit pursuant to Government Code Section 66313.

Single-family residential zone shall mean the R-7,500 Single-Family Residential Zoning District, the R-20,000 Single-Family Residential Zoning District, the A-1 Agriculture Residential Estate Zoning District, the A-2 Agriculture Residential Estate Zoning District, and the A-5 Agriculture Residential Estate Zoning District.

Unit shall mean a primary dwelling unit, an accessory dwelling unit, or a junior accessory dwelling unit.

Urban lot split means a lot split of a single-family residential lot into two parcels that meets the requirements of Chapter 164 of the Development Code.

Sec. 9.85.410. Application processing.
(a) The City shall have 30 days to determine if an application is complete. If the application is incomplete, the City shall provide an exhaustive list of items that were not complete. If a determination is not made within 30 days, the application shall be deemed complete.
(b) The City shall approve or deny an application for a housing development within 60 days from the date of a completed application.
(c) If the City fails to approve or deny an application within this time frame, the application shall be deemed approved.
(d) If the City denies the application, it must provide the applicant with a full set of comments with a list of items that are defective or deficient and a description of how the application can be remedied within 60 days from a completed application.

Sec. 9.85.420. Housing development approval.

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b. A parcel individually listed as a historical resource included in the State Historic Resources Inventory, as defined in Public Resources Code section 5020.1, or within a property individually designated or listed as a city landmark under a City ordinance.
(2) Wetlands as defined in the Unites States Fish and Wildlife Service Manual, Part 660 FW 2 (June 21, 1993).
(3) A very high fire hazard severity zone as further defined in California Government Code section 65913.4(a)(6)(D). This does not apply to sites excluded from the specified hazard zones by a local agency, pursuant to subdivision (b) of section 51179, or sites that have adopted fire hazard mitigation measures pursuant to existing building standards or State fire mitigation measures applicable to the development. (4) A delineated earthquake fault zone as determined by the State Geologist in any official maps published by the State Geologist, unless the development complies with applicable seismic protection building code standards adopted by the California Building Standards Commission under the California Building Standards Law and by the City's Building Department.
(5) A special flood hazard area subject to inundation by the one percent annual chance flood (100-year flood) as determined by the Federal Emergency Management Agency (FEMA) in any official maps published by FEMA. If an applicant is able to satisfy all applicable federal qualifying criteria in order to provide that the site satisfies this subparagraph and is otherwise eligible for ministerial approval under this section, the City shall not deny the application on the basis that the applicant did not comply with any additional permit requirement, standard, or action adopted by the City that is applicable to that site. A development may be located on a site described in this subparagraph if either of the following are met:
a. The site has been subject to a Letter of Map Revision prepared by FEMA and issued to the City; or
b. The site meets FEMA requirements necessary to meet minimum flood plain management criteria of the National Flood Insurance Program as further spelled out in Government Code section 65913.4(a)(6)(G)(ii).
(6) A regulatory floodway as determined by FEMA in any of its official maps, published by FEMA unless the development has received a no-rise certification in accordance with section 60.3(d)(3) of Title 44 of the Code of Federal Regulations. If an applicant is able to satisfy all applicable federal qualifying criteria in order to provide that the site satisfies this subparagraph and is otherwise eligible for ministerial approval under this section, the City shall not deny the application on the basis that the applicant did not comply with any additional permit requirement, standard, or action adopted by the City that is applicable to that site.
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(7) Lands identified for conservation in an adopted natural community conservation plan, habitat conservation plan, or other adopted natural resource protection plan as further spelled out in Government Code section 65913.4(a)(6)(I). (8) Habitat for protected species identified as candidate, sensitive, or species of special status by State or federal agencies, fully protected species, or species protected by the federal Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.), the California Endangered Species Act (Chapter 1.5 (commencing with section 2050) of Fish and Game Code Division 3), or the Native Plant Protection Act (Chapter 10 (commencing with section 1900) of Fish and Game Code Division 2).
(9) Lands under a conservation easement.
(c) The proposed housing development would not require demolition or alteration of any of the following types of housing:
(1) Housing that is subject to a recorded covenant, ordinance or law that restricts rents to levels affordable to persons and families of moderate, low, or very low income; (2) Housing that has been occupied by a tenant in the last three years. (d) Unless demolition or alteration is prohibited pursuant to subsection (c) above, a housing unit may be demolished.
(e) The parcel is not a parcel on which an owner of residential real property has exercised his rights under Government Code section 7060 et seq. to withdraw accommodations from rent or lease within 15 years before the date of the application. (f) The development is not located within a historic district or property as specified in Government Code section 65852.21(a)(5).

Sec. 9.85.430. Number of units.
(a) For lots developed under Government Code section 65852.21 (SB 9) where there is no lot split, the total number of units allowed shall not exceed four units and may be in any configuration of primary units, ADUs and JADUs, provided there are not more than two primary units, at least one of which must meet the minimum size requirement of the zone. Accessory living quarters shall also be allowed in addition to the four units as provided for in Article III above.
(b) For lots developed under Government Code section 65852.21 where there has been a lot split under Chapter 164 of the Development Code, the total number of units allowed on each lot shall not exceed two units in any configuration of primary units, ADUs, and JADUs, but must include at least one primary unit per lot. At least one primary unit on any of the lots must meet the minimum size requirement of the zone. Accessory living quarters shall also be allowed as provided for in Article III above, provided that the square footage of such units is split in the same proportion as the lot split under Chapter 164 of the Development Code.
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Sec. 9.85.440. Standards and requirements.

The following requirements shall apply in addition to all other objective standards pertaining to the underlying zone. In cases of conflict, the requirements set forth in this section shall prevail:
(a) No setback shall be required for an existing structure or a structure constructed in the same location and to the same dimensions as an existing structure. (b) Except for those circumstances described in subsection (a) above, for any new housing developed under this chapter, the setback for side and rear lot lines shall not be less than four feet. This does not prevent the applicant from providing a larger setback.

The front setback shall be as set forth in the applicable single-family residential zone. (c) The applicant shall provide easements for the provision of public services and facilities as required.
(d) Driveways and access shall be provided in accordance with Chapter 103 of the Development Code. Easements shall be provided as required to ensure pedestrian and vehicular access across lots.
(e) Required off-street parking shall be limited to one space per unit, except that no parking shall be required if the parcel is located within one-half mile walking distance of either a high-quality transit corridor or a major transit stop, or there is a car share vehicle located within one block of the parcel. Parking spaces shall meet the following requirements:
(1) Parking spaces may be covered or uncovered, and shall be allowed in the paved portions of setback areas.
(2) Tandem parking between units shall be prohibited.
(f) For residential units connected to an onsite wastewater treatment system (septic tank), the applicant shall provide a percolation test completed within the last five years, or if the percolation test has been recertified, within the last ten years, which shows that the system meets acceptable infiltration rates.
(g) The number and size of the primary units, ADUs, and JADUs, allowed on a single lot or an SB 9 lot, shall comply with the other provisions of this Title regulating such uses as set forth in section 9.85.020, except that only one primary unit must comply with the minimum size of a primary unit for the zone.
(h) The number and size of accessory living quarters allowed on a single lot in one of the Agriculture Residential Estate zones shall not exceed that allowed in Article III of this Chapter.

If the lot is split into two SB 9 lots, the total amount of accessory living quarters allowed on the single lot shall be split between the two new lots as provided for in section 9.85.300. (i) Design standards. To the extent not superseded by this chapter, the SB 9 unit shall meet all existing objective design standards of the underlying zone. 32

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(j) If there is no existing unit on the original parcel prior to any lot split allowed pursuant to Chapter 9.164, one of the allowed units may be built to the standards for a main house under the applicable zone.

Sec. 9.85.450. Denials.
(a) The City shall not deny an application solely because it proposes adjacent or connected structures provided that all building code safety standards are met and they are sufficient to allow a separate conveyance.
(b) The City may deny the housing development if the building official makes a written finding, based upon a preponderance of the evidence, that the proposed housing development project would have a specific, adverse impact, as defined and determined in California Government Code section 65589.5(d)(2), upon the public health and safety and for which there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact.

Sec. 9.85.460. Affidavit required.

An applicant for housing under this chapter shall be required to sign an affidavit in a form approved by the City Attorney to be recorded against the property stating the following:
(a) That the uses shall be limited to residential uses. (b) That the rental of any unit created pursuant to this section shall be for a minimum of 31 consecutive calendar days.
(c) That the maximum number of units and square footage to be allowed shall be as set forth in section 9.85.020 of the Bradbury Municipal Code.

Sec. 9.85.470. Other municipal code provisions.
(a) Unless contrary to the provisions of this chapter, all other applicable objective provisions of Title IX, including the provisions of the underlying zone, shall apply. (b) Notwithstanding the above, the City shall not impose any zoning or design standards that would have the effect of physically precluding the construction of two units on either of the resulting parcels under an urban lot split or that would result in a unit size of less than 800 square feet.

SECTION 4. Chapter 164 of Title IX, Development Code, is hereby amended to read as follows:

CHAPTER 164. URBAN LOT SPLITS
Sec. 9.164.010. Definitions.

For purposes of this Chapter only, the following definitions shall apply:
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Unit shall mean a primary dwelling unit, an accessory dwelling unit of any type, a junior accessory dwelling unit, or an SB 9 unit. "Unit" shall not include a guest house or an SRO development.

Urban lot split means a lot split of a single-family residential lot into two parcels that meets the requirements of this chapter.

Sec. 9.164.020. Application processing.
(a) The City shall have 30 days to determine if an application is complete. If the application is incomplete, the City shall provide an exhaustive list of items that were not complete. If a determination is not made within 30 days, the application shall be deemed complete. (b) The City shall approve or deny an application for an urban lot split within 60 days from the date of a completed application.
(c) If the City fails to approve or deny an application within this time frame, the application shall be deemed approved.
(d) If the City denies the application, it must provide the applicant with a full set of comments with a list of items that are defective or deficient and a description of how the application can be remedied within 60 days from a completed application.

Sec. 9.164.030. Urban lot split approval.

The City shall ministerially approve a parcel map for a lot split that meets the following requirements:
(a) The parcel is located within a single-family residential zone. (b) The parcel is located at least partially in an urbanized area or urban cluster as designated by the United States Census Bureau.
(c) The parcel map divides an existing parcel to create no more than two new parcels of approximately equal lot area, provided that one parcel shall not be smaller than 40 percent of the lot area of the original parcel.
(d) Both newly created parcels are no smaller than 1,200 square feet. (e) The parcel is not located in any of the following areas and does not fall within any of the following categories:
(1) A parcel located within a historical landmark property included on the State Historic Resources Inventory, as defined in Public Resources Code section 5020.1, or within a site that is designated or listed as a City landmark pursuant to a City ordinance. (2) Wetlands as defined in the Unites States Fish and Wildlife Service Manual, Part 660 FW 2 (June 21, 1993).
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(3) A very high fire hazard severity zone as further defined in California Government Code section 65913.4(a)(6)(D). This does not apply to sites excluded from the specified hazard zones by a local agency, pursuant to subdivision (b) of section 51179, or sites that have adopted fire hazard mitigation measures pursuant to existing building standards or State fire mitigation measures applicable to the development. (4) A delineated earthquake fault zone as determined by the State Geologist in any official maps published by the State Geologist, unless the development complies with applicable seismic protection building code standards adopted by the California Building Standards Commission under the California Building Standards Law and by the City's Building Department.
(5) A special flood hazard area subject to inundation by the one percent annual chance flood (100-year flood) as determined by the Federal Emergency Management Agency (FEMA) in any official maps published by FEMA. If an applicant is able to satisfy all applicable federal qualifying criteria in order to provide that the site satisfies this subparagraph and is otherwise eligible for streamlined approval under this section, the City shall not deny the application on the basis that the applicant did not comply with any additional permit requirement, standard, or action adopted by the City that is applicable to that site. A development may be located on a site described in this subparagraph if either of the following are met:
a. The site has been subject to a Letter of Map Revision prepared by FEMA and issued to the City; or
b. The site meets FEMA requirements necessary to meet minimum flood plain management criteria of the National Flood Insurance Program as further spelled out in California Government Code section 65913.4(a)(6)(G)(ii). (6) A regulatory floodway as determined by FEMA in any of its official maps, published by FEMA unless the development has received a no-rise certification in accordance with section 60.3(d)(3) of Title 44 of the Code of Federal Regulations. If an applicant is able to satisfy all applicable federal qualifying criteria in order to provide that the site satisfies this subparagraph and is otherwise eligible for streamlined approval under this section, the City shall not deny the application on the basis that the applicant did not comply with any additional permit requirement, standard, or action adopted by the City that is applicable to that site.
(7) Lands identified for conservation in an adopted natural community conservation plan, habitat conservation plan, or other adopted natural resource protection plan as further spelled out in California Government Code section 65913.4(a)(6)(I). (8) Habitat for protected species identified as candidate, sensitive, or species of special status by State or federal agencies, fully protected species, or species protected by the federal Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.), the California Endangered Species Act (Chapter 1.5 (commencing with section 2050) of Division 3 of the Fish and Game Code), or the Native Plant Protection Act (Chapter 10 (commencing with section 1900) of Division 2 of the Fish and Game Code). 35

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(9) Lands under a conservation easement.
(f) The proposed lot split would not require demolition or alteration of any of the following types of housing:
(1) Housing that is subject to a recorded covenant, ordinance or law that restricts rents to levels affordable to persons and families of moderate, low, or very low income; (2) Housing that has been occupied by a tenant in the last three years. (3) A contributing structure within a historic district included on the State Historic Resources Inventory, as defined in Public Resources Code section 5020.1, or historic property or district pursuant to a City ordinance.
(4) An existing exterior structural wall of a structure located within either a historic district that is included on the California Register of Historical Resources or within a historic district listed or designated pursuant to a City ordinance. (g) The lot split does not create more units or accessory living quarters than allowed under Chapter 9.85.

Sec. 9.164.040. Standards and requirements.

The following requirements shall apply:
(a) The lot split conforms to all applicable objective requirements of the Subdivision Map Act and Part VII of Title IX of the Bradbury Municipal Code, except as the same are modified by this section.
(b) No setback shall be required for an existing structure or a structure constructed in the same location and to the same dimensions as an existing structure. (c) Except for those circumstances described in subsection (b) above, for any lot resulting from an urban lot split, the setback for side and rear lot lines shall not be less than four feet. The front setback shall be as set forth in the applicable single-family residential zone.
(d) The applicant shall provide easements for the provision of public services and facilities as required.
(e) If a lot does not have direct access to a street, appropriate access easements meeting the minimum size of the driveway requirements set forth in Chapter 103 of the Development Code shall be provided on the tentative and parcel map. (f) Development of the lots shall be in accordance with Chapter 85 of the Development Code.

Sec. 9.164.050. Denials.
(a) The City shall not:
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(1) Require dedications of rights-of-way or the construction of offsite improvements for the parcels being created as a condition of issuing a parcel map. (2) Impose any objective subdivision standards that would have the effect of physically precluding the construction of two units on either of the resulting parcels or that would result in a unit size of less than 800 square feet. (3) Require the correction of nonconforming zoning provisions as a condition for the lot split.
(4) Deny an application solely because it proposes an adjacent or connected structure provided that all building code safety standards are met and they are sufficient to allow a separate conveyance.
(b) The City may deny the lot split if the Building Official makes a written finding, based upon a preponderance of the evidence, that the proposed housing development project would have a specific, adverse impact, as defined and determined in California Government Code section 65589.5(d)(2), upon the public health and safety or the physical environment and for which there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact.

Sec. 9.164.060. Affidavit.

An applicant for an urban lot split shall be required to sign an affidavit in a form approved by the City Attorney to be recorded against the property stating the following:
(a) That applicant intends to occupy one of the housing units as their principal residence for a minimum of three years from the date of approval. This requirement does not apply when the applicant is a "community land trust" or a "qualified nonprofit corporation" as the same are defined in the Revenue and Taxation Code.
(b) That the uses shall be limited to residential uses. (c) That any rental of any unit created by the lot split shall be for a minimum of 31 consecutive calendar days.
(d) That the maximum number of primary units, ADUs of any kind, and JADUs to be allowed on each parcel shall not exceed two units. This shall not include the accessory living quarters allowed pursuant to section 9.85.020 of the Bradbury Municipal Code. (e) That the accessory living quarters allowed on the single lot in the A-1, A-2, or A-5 zone shall be split as provided for in section 9.85.300.

Sec. 9.164.070. Inapplicability of chapter.

This Chapter shall not apply to:
(a) Any parcel which has previously been established pursuant to a lot split in accordance with the provisions of the chapter; or
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(b) Any parcel where the owner of the parcel being subdivided or any person acting in concert with the owner has previously subdivided an adjacent parcel in accordance with this section. For purposes of this section, "acting in concert" shall include, but not be limited to, where the owner of a property proposed for an urban lot split is the same, related to, affiliated with, or connected by partnership to the owner, buyer or seller if transferred within the previous three years of an adjacent lot.

SECTION 5. Section 9.34.020 of the Development Code is hereby amended as follows:

9.34.020. – Architectural review – Minor and significant. (a) Minor architectural review shall be limited to development which meets the following criteria:
(1) Minor modifications to the exterior appearance of any building or structure not facing a street or accessway;
(2) Construction of single-story structures, including accessory structures, which are less than 1,000 square feet of floor area;
(3) Construction which does not exceed a total of 18 feet in height from grade for the finished structure; and
(4) Construction of swimming pools, fences and gates or minor landscaping improvements which do not exceed 25 percent of the parcel size, and installation of exterior mechanical, electrical and plumbing equipment. (b) Significant architectural review shall cover all development other than those listed in subsection (a) above.
(c) Accessory dwelling units, junior accessory dwelling units, SB 9 units, or any other approval where such application is preempted by State law shall not require any architectural review, regardless of where such units are located.

SECTION 6. CEQA. This Ordinance is exempt from CEQA pursuant to Public Resources Code section 21080.17 which provides that CEQA does not apply to the adoption of an ordinance implementing the provisions of the law relating to ADUs, pursuant to Government Code section 65852.21 and 66411.7 which provide that an ordinance to implement the provisions of those sections shall not be considered a project subject to CEQA, and also by the common sense exemption of CEQA Guidelines Section 15061(b)(3) as all changes set forth in this Ordinance are required by State law and therefore apply regardless of whether the City amends the provisions of the Municipal Code.

SECTION 7. Severability. If any provision of this Ordinance is held to be unconstitutional, it is the intent of the City Council that such portion of this Ordinance be severable from the remainder and that the remainder be given full force and effect.

SECTION 8. The City Clerk shall certify to the adoption of this Ordinance. 38

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SECTION 9. This Ordinance shall be sent to HCD in accordance with State law.

PASSED, APPROVED and ADOPTED this _____ day of___________, 2026.

Elizabeth Bruny, Mayor
ATTEST:

Paulina Reyes, Deputy City Clerk

STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) §.

CITY OF BRADBURY )
I, Paulina Reyes, Deputy City Clerk of the City of Bradbury, do hereby certify that the foregoing ordinance, being Ordinance No. 401, was duly passed by the City Council of the City of Bradbury, signed by the Mayor of said City, and attested by the Deputy City Clerk, all at a regular meeting of the City Council held on the ______ day of ______, 2026, that it was duly posted and that the same was passed and adopted by the following vote, to wit:

AYES:

NAYS:

ABSENT:

Paulina Reyes, Deputy City Clerk
City of Bradbury
39 - This page intentionally blank -
40 ATTACHMENT B
Agenda Report – September 22, 2026
ORDINANCE NO. 401 – Redline Version
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Redline
ORDINANCE NO. 401

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF BRADBURY, CALIFORNIA AMENDING SECTION 9.25.020 OF THE BRADBURY

DEVELOPMENT CODE RELATING TO DEFINITIONS, AMENDING
SECTION 9.34.020 REGARDING ARCHITECTURAL REVIEW,
AMENDING CHAPTER 9.85 OF THE BRADBURY DEVELOPMENT

CODE RELATING TO ACCESSORY DWELLING UNITS, JUNIOR
ACCESSORY DWELLING UNITS, AND SB 9 UNITS, AND AMENDING
CHAPTER 9.164 OF THE BRADBURY MUNICIPAL CODE RELATING

TO URBAN LOT SPLITS, AND FINDING THAT THIS ORDINANCE IS

EXEMPT FROM CEQA PURSUANT TO PUBLIC RESOURCES CODE
SECTION 21080.17 AND GOVERNMENT CODE SECTIONS 65852.21
AND 66411.7 AND THE COMMON SENSE EXEMPTION OF CEQA
GUIDELINES SECTION 15061(b)(3)
WHEREAS, the City has previously adopted and amended Chapter 9.85 relating to Accessory Dwelling Units (ADUs), Junior Accessory Dwelling Units (JADUs), SB 9 units, and accessory living quarters; and
WHEREAS, the City has adopted Chapter 9.164 relating to urban lot splits to implement SB 9; and
WHEREAS, the Legislature has continued to amend the state statutes relating to ADUs, JADUs and SB 9, as well as revising the definition of emergency shelters which necessitates additional changes to the City’s provisions regarding these uses; and WHEREAS, the Planning Commission held a duly noticed public hearing on March 25, 2026, and May 27, 2026, at which times the Commission considered all evidence presented, both written and oral; and
WHEREAS, after the close of the public hearing on May 27, 2026, the Commission directed staff to return with a revised draft Ordinance which incorporated provisions regarding the prohibition on development in areas where the streets are below 20 feet in width; and
WHEREAS, an additional duly noticed public hearing was held on July 22, 2026 at which time the Commission considered all evidence presented, both written and oral; and
WHEREAS, after the close of the public hearing the Planning Commission adopted Resolution No. PC 26-330 recommending that the City Council adopt this Ordinance; and WHEREAS, the City Council held a duly noticed public hearing on _____ __, 2026, at which time the Council considered all evidence presented, both written and oral. 42

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NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF BRADBURY, CALIFORNIA DOES HEREBY ORDAIN AS FOLLOWS:

SECTION 1. The City Council does hereby make the following findings relating to fire issues and the need to restrict development in areas with a street width of less than 20 feet.:

A. The majority of the City of Bradbury is located in a very high fire hazard severity zone (VHFHSZ). There are numerous properties with horses and other livestock in these areas;
B. State of Emergencies have become a yearly occurrence in California due to wildfires;
C. Since 1953 there have been four separate wildfires that have burned through Bradbury and the neighboring communities, including in November 1980 when approximately 50 units were lost in wildfires;
D. Since the time that the Governor signed the 2019 ADU/JADU legislation into law, there have been thousands of wildfires in California which have burned tens of thousands of acres, damaged or destroyed hundreds of homes and other structures, caused the death of many people, and resulted in injuries to many more; E. In 2020, the Bobcat Fire caused evacuation warnings to be issued to parts of Bradbury;
F. According to CalFire, in 2025 there were 8,232 wildfires which burned over half -a -million acres resulting in 31 fatalities and the destruction of 16,627 structures.

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J. The Dudek Memorandum also concludes among other things that the fourfoot setback requirements and the inability to require fire sprinklers would likely have negative fire related impacts in Bradbury and recommends that fire sprinklers should be required whenever possible;
K. The standard width of a fire truck in Los Angeles County, mirror to mirror, is between approximately 9 to 10 feet. The standard size of a passenger vehicle is approximately 6 to 7 feet. The standard width of a horse trailer can be up to 8 ½ feet; L. When a road is less than 20 feet wide, it can impede the access of fire apparatus as a fire truck is not able to pass a passenger vehicle, let alone a vehicle evacuating horses. If a person evacuating were to have an accident, it could prevent fire apparatus from reaching the fire;
M. During the Palisades fFire, bulldozers had to clear abandoned cars so firetrucks could drive past;
N. There are a number of roads within the City that are less than 20 feet in width;
O. Residents living on narrow roads within the City of Bradbury have been informed by the Los Angeles County Fire Department that if there is a fire, the Department may not be able to provide service;
P. Government Code § 51182 provides that when property is within a very high fire hazard severity zone, there should be 100 feet of defensible space maintained for each side and from the front and rear of the structure, but not beyond the property line; Q. The majority of the City of Bradbury is zoned R-20,000, A-1, A-2, or A-5 with rear and side yard setbacks of 15 feet in the R-20,000 zone and 25 feet in the three ‘Agricultural’ (“A”) zones, meaning that accessory living quarters and other structures cannot be located closer than 30 feet to each other in these areas; R. Under the law pertaining to both ADUs and SB 9 (two unit housing developments), the City is not allowed to impose a setback of more than four feet from the side and rear property lines, leading to situations where there is a reduction in defensible space;
S. On August 18, 2020, the International City/County Management Association released a document titled “21st Century – Fire and Emergency Services” which contained the recommendation to “Embrace the use of fire sprinkler technology in all buildings through the rapid adoption of codes and ordinances at the federal, state, and local government levels to dramatically reduce the incidence of deadly and costly fires”; 44

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T. According to the Southern California Association of Governments’ (SCAG) community profile, only 4.5% of the housing stock in Bradbury was built after 2010, when residential sprinkler systems became a requirement. Therefore, when ADUs are built, fire sprinklers cannot be required on the majority of properties.

U. Government Code section 66314 provides that cities may designate the areas where ADUs may be permitted based on the impact on traffic flow and public safety.

The City Council specifically determines that the findings set forth above demonstrate that where streets are below the width to allow adequate access by fire apparatus, compounded with the inability to provide sufficient setbacks and new residents which will add to the traffic, there is an impact on traffic and public safety which allows the City to restrict the development of additional residential units in such areas.

SECTION 2. Section 9.25.020 of the Development Code is hereby amended by revising, deleting, and adding definitions as follows the following definition:

Sec. 9.25.020. – Definitions of specialized terms and phrases.

Emergency shelter is defined in Health and Safety Code § 50801 as housing with minimal supportive services for homeless persons that is limited to occupancy of six months or less by a homeless person. An “emergency shelter” shall include other interim interventions, including, but not limited to, a navigation center, bridge housing, and respite or recuperative care. No individual or household may be denied emergency shelter because of an inability to pay.

SECTION 3. Chapter 85 of Title IX, Development Code, is hereby amended to read as follows (SB 450 and ADU updates):

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in conflict with State law, the mandatory requirement of State law shall control, but only to the extent legally required.

Sec. 9.85.020. Summary of allowed development.

ZONE ALLOWED DEVELOPMENT
R-7,500 • Primary unit – 1,500 square foot minimum
• ADU – 1,000 SF max; 800 SF max if combined with JADU
• JADU – 500 SF max
• SB 9 development without lot split – 2 primary units, one of which must meet minimum development size; may have ADU and JADU
• SB 9 development with lot split – 2 units with at least one primary on each lot; ADU and JADU count towards unit numbers. Only one primary unit must meet the minimum development size.

A-2 • Primary unit – 2,500 square foot minimum
• ADU – 1,000 SF max; 800 SF max if combined with JADU
• JADU – 500 SF max
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• SB 9 development without lot split – 2 primary units, one of which must meet minimum development size; may have ADU and JADU
• SB 9 development with lot split – 2 units with at least one primary on each lot; ADU and JADU count towards unit numbers. Only one primary unit must meet the minimum development size.
• ALQ of up to 2,000 SF which can be split between SRO development of 2-6 units and guest house. If lot is split divide proportionately to the lot split percentage.

A-5 • Primary unit – 2,500 square foot minimum
• ADU – 1,000 SF max; 800 SF max if combined with JADU
• JADU – 500 SF max
• SB 9 development without lot split – 2 primary units, one of which must meet minimum development size; may have ADU and JADU
• SB 9 development with lot split – 2 units with at least one primary on each lot; ADU and JADU count towards unit numbers. Only one primary unit must meet the minimum development size.
• ALQ of up to 2,500 SF which can be split between SRO development of 2- 10 units and a guest house. If lot is split, divide proportionately to the lot split percentage.
(a) For size of primary unit, see the requirement of the specific zone. (b) For ADU/JADU see Chapter 85, Article II.
(c) For SB 9, see Chapter 85, Article IV.
(d) For ALQ (Accessory Living Quarters), Chapter 85, Article III.

Sec. 9.85.030. Los Angeles County fire department/building code requirements.

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(a) Furlong Lane—between Deodar Lane and Long Canyon Road; (b) Oak Knoll Lane—east of Bliss Canyon Road;
(c) Woodlyn Lane—between Bradbury Hills Road and El Cielo Lane; (d) Bradbury Hills Road;
(e) Bradbury Hills Lane; and
(f) El Cielo Lane.

ARTICLE II.

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used in an application for a detached accessory dwelling unit approved by the City within the current triennial California Building Standards Code cycle, the application shall be approved or denied within 30 days from the date of a completed application. (cb) All applications for ADUs and JADUs shall be accompanied by the applicable application fee.
(dc) ADUs and JADUs shall be subject to applicable inspections and permit fees. (ed) If an application for a detached ADU requires demolition of a detached garage, the application shall be submitted with the demolition application and the two applications shall be reviewed at the same time. If the ADU is approved, the permits shall be issued at the same time.

Sec. 9.85.115. Denial.
(a) If the City denies an application for an ADU or JADU, the City shall return a full set of comments to the applicant with a list of items that are defective or deficient and a description of how the application can be remedied. The comments must be in writing and returned to the applicant within 60 days of receipt of a completed application. (b) No application shall be denied due to the need to correct a nonconforming zoning condition, building code violation, or due to unpermitted structures, unless those conditions present a threat to the public health and safety and are affected by the construction of the ADU, or JADU.
(c) No application or permit shall be denied for an ADU or JADU that was constructed prior to January 1, 2020, based on either of the following:
(1) The ADU is in violation of building standards pursuant to Article 1 of Chapter 5 of Part 1.5 of Division 13 of the Health and Safety Code (commencing with section 17960); or
(2) The ADU does not comply with State law or the provisions of the Bradbury Development Code regulating ADUs.
(3) Subparagraphs (1) and (2) of this subsection (c) shall not apply if the City makes a finding that correcting the violation is necessary to comply with the standards specified in Health and Safety Code section 17920.3 or if the building is deemed substandard pursuant to Health and Safety Code section 17920.3. (4) Upon receiving an application to permit a previously unpermitted ADU or JADU constructed before January 1, 2020, an inspector from the City may inspect the unit for compliance with health and safety standards and provide recommendations to comply with such standards in order to obtain a permit. The City shall not penalize an applicant for having the unpermitted ADU or JADU and shall approve necessary permits to correct noncompliance with health and safety standards.
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(d) Appeals. Notwithstanding anything in this Code to the contrary, the applicant may appeal a denial of an application or a determination that an application is incomplete directly to the City Council. A final written determination shall be provided to the applicant no later than 60 days after the receipt of the written appeal and applicable fees.

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(5) An ADU converted from previously existing permitted space which already exists above the permitted ground floor area or garage – to the height already existing if greater than the height set forth in subsections (c)(1) - (4), above. (d) Size.
(1) Maximum size – an attached or detached ADU shall not exceed 1,000 square feet.
(2) Minimum size – the square footage of an ADU shall not be less than that allowed for an efficiency unit.
(e) Application of underlying development standards.
(1) The objective development standards of the underlying zone shall apply, except as may be specified hereinin this chapter.
(2) If application of any development standard of the underlying zone or this chapter prevents the construction of an ADU that meets the height requirements specified in subsection (c), such development standard shall be waived to the extent needed to allow an 800 square foot ADU. The waiver of standards does not apply to the requirement for minimum four-foot side and rear yard setbacks.
(f) Setbacks.
(1) Attached and detached ADUs shall be located behind the front yard setback line of the primary unit.
(2) The maximum side and rear yard setback requirements for an ADU, including an ADU added in an already existing and permitted space above a garage or other floor area shall be four feet. This does not prevent the applicant from providing a larger setback.
(3) The setback requirements in subsections (f)(1) and (2) above shall not apply if the ADU is being converted from an existing accessory structure, including a garage, or is being constructed in the same location and to the same dimensions as an existing accessory structure, including a garage.
(g) Parking.
(1) Parking shall be required at the rate of one space for each ADU. (2) Parking spaces for an ADU may be provided through tandem parking on an existing driveway; provided, that such parking does not encroach into the public right-ofway or a private street. (3) Parking spaces for ADUs may be provided in the paved portions of setback areas; provided, that the amount of paving does not exceed the total amount of paving 51

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and hardscaped areas that are otherwise allowed by this title at the time the ADU is approved.
(4) When a garage, carport, uncovered parking space, or covered parking structure is converted into an ADU, or is demolished to accommodate the construction of an ADU, such parking spaces need not be replaced.
(5) Tandem parking and parking in setback areas shall not be allowed if the City Manager makes specific findings that such parking is not feasible based upon specific site or regional topographical, or fire and life safety conditions. (6) Notwithstanding any other provision of this subsection (g), no additional parking shall be required for the ADU if any of the following conditions apply:
a. The ADU is located within one-half mile walking distance of a public transit stop;
b. The ADU is located within an architecturally and historically significant historic district;
c. The ADU is part of a proposed or existing primary unit or an existing accessory structure;
d. When on-street parking permits are required, but not offered to the occupant of the ADU;
e. When there is a car share vehicle located within one block of the ADU; or f. When a permit application for an accessory dwelling unit is submitted with a permit application to create a new single- or multi-family dwelling on the same lot, provided the ADU or parcel satisfies any other criteria listed in this paragraph.section

9.85.130(g)(6).
(h) Design.
(1) The ADU shall be the exact same color as the primary unit. (2) The ADU shall have the exact same roof pitch as the primary unit. (3) The ADU shall have a separate entrance from the primary unit. (i) Utilities—Connections, fees, and capacity charges.
(1) For an ADU contained within an existing primary unit, or an existing accessory structure meeting the requirements of section 9.85.140(a)(1) below, the City shall not require the installation of a new or separate utility connection between the ADU and the utility or impose a connection fee or capacity charge, unless the accessory dwelling unit was constructed with a new single-family dwelling.
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(2) For all ADUs other than those described in subsection (i)(1) above, the City shall require a new or separate utility connection between the ADU and the utility and shall charge a connection fee or capacity charge that is proportionate to the burden of the proposed ADU based on the size or number of drainage fixture unit (DFU) values upon the water or sewer system.
(j) Impact fees.
(1) No impact fee shall be imposed on any ADU of up to 750 square feet in size. (2) Notwithstanding any fee resolution to the contrary, for ADUs larger than 750 square feet, impact fees shall be charged proportionately in relation to the square footage of the primary unit.
(3) All applicable public service and recreation impact fees shall be paid prior to occupancy in accordance with California Government Code sections 66000 et seq. and 66012 et seq.
(4) For purposes of this section, "impact fee" shall have the meaning set forth in California Government Code section 66324.
(5) No impact fees or connection or capacity charges shall be imposed on a homeowner applying for a permit for a previously unpermitted ADU or JADU built before January 1, 2020, except when the utility infrastructure is required to comply with Health and Safety Code section 17920.3 and authorized by Government Code section 66324(e). (k) Easements. No portion of an accessory dwelling unit may encroach into any public or private easement such as a utility easement unless the easement holder has provided written permission to construct the accessory dwelling unit in the manner proposed. To establish a rebuttable presumption of compliance with this requirement, the applicant may provide a written declaration under penalty of perjury affirming compliance with this requirement. The declaration shall be in a form acceptable to the city attorney.

Sec. 9.85.135. Fire sprinklers.
(a) Fire sprinklers shall only be required in the an ADU or JADU if they were/are required in the primary unit at the time of construction.
(b) The construction of an ADU or JADU shall not trigger a requirement for sprinklers to be installed in the primary unit.

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(1) An ADU and a JADU within the existing or proposed space of the primary unit or accessory structure, subject to the following requirements:
a. An ADU or JADU shall have exterior access separate from the existing or proposed primary unit.
b. An expansion of up to 150 square feet shall be allowed for an existing accessory structure that is to be converted to an ADU, solely for the purpose of accommodating separate ingress and egress.
c. The side and rear yard setbacks shall be sufficient for fire and safety. d. The JADU shall comply with the requirements of sections 9.85.150 and

9.85.160 below.
(2) One detached ADU that will have at least four-foot side and rear yard setbacks on an existing lot with an existing or proposed primary unit, provided that the ADU shall not be more than 800 square feet and shall not exceed the height requirements set forth in sections 9.85.130(c)(1) - (c)(3). The ADU may be combined with a JADU so long as it complies with all the requirements of sections 9.85.150 and 9.85.160 below. (3) On a lot with an existing multifamily dwelling structure, up to 25 percent of the total multifamily dwelling units, but no less than one ADU or JADU, shall be allowed within the portions of the existing structure that are not used as livable space, including, but not limited to, storage rooms, boiler rooms, passageways, attics, basements, or garages, provided that each dwelling unit complies with State building standards for dwellings. For purposes of this section, “livable” means a space in a dwelling intended for human habitation, including living, sleeping, eating, cooking, or sanitation. (4) On a lot with an existing multifamily dwelling structure, there may be up to eight detached ADUs, but in no event more than the number of existing units, provided that none of the ADUs exceeds the height requirements set forth in sections 9.85.130(c)(1)- (c)(3) and that the ADUs have at least four-foot side and rear yard setbacks. (5) On a lot with a proposed multifamily dwelling, there may be up to two detached ADUs, provided that none of the ADUs exceeds the height requirements set forth in sections 9.85.130(c)(1) - (c)(3) and that the ADUs have at least four-foot side and rear yard setbacks.
(b) For those ADUs and JADUs that require mandatory approval under this section, the City shall not require the correction of legal, nonconforming zoning conditions as a condition of permit approval.
(c) Any ADU created under this Section 9.85.140 shall not be rented for a period of less than 31 days.
(d) ADUs and JADUs approved under this section may not be combined with any other ADU or JADU otherwise authorized by this Article II.
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The deed restriction shall provide for the following:
(1) A prohibition on the sale of the JADU separate from the sale of the primary unit; (2) A prohibition on the JADU being larger than 500 interior livable square feet; (3) A prohibition on renting either the primary unit or the junior accessory dwelling unit for less than 31 consecutive, calendar days;
(4) A restriction that the owner resides in either the primary unit or the JADU. This restriction shall not apply if the owner of the primary single-family unit is a governmental agency, land trust, or housing organization; and
(35) A statement that the deed restrictions may be enforced against future purchasers.
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(g) For the purposes of applying any fire or life protection ordinance or regulation, or providing service water, sewer, or power, including a connection fee, a JADU shall not be considered a separate or new dwelling unit.
(h) The City shall not require the correction of legal, nonconforming zoning conditions as a requirement for approval of a JADU.

Sec. 9.85.160. Regulations – Accessory dwelling units (ADUs) and junior accessory dwelling units (JADUs).
(a) Sales. ADUs and JADUs cannot be sold separately from the primary unit, except to the extent the sale meets the requirements of Government Code sections 66340 and 66341 with regard to a qualified nonprofit corporation. (b) Rental.
(1) Short-term rentals of the ADU and JADU are prohibited. No ADU or JADU shall be rented for a period of less than 31 consecutive calendar days. (2) The ADU or JADU may be rented separate from the primary unit. (c) Owner/occupancy.
(1) The City shall not enforce or impose any owner/occupancy requirement imposed on an ADU. No owner/occupancy requirement shall be imposed on any ADU. (2) All properties on which a JADU is developed shall have an owner-occupancy requirement in accordance with section 9.85.150(f). If sanitation facilities are shared between the JADU and primary unit, owner occupancy shall be required unless the owner is another governmental agency, land trust, or housing organization. (d) This chapter shall in no way validate any existing illegal ADU nor shall it change a legal, nonconforming unit to a conforming unit.
(e) An application to convert an illegal and/or nonconforming ADU and/or JADU to a legal conforming ADU or JADU shall be subject to the same standards and requirements as for a newly proposed unit.
(f) Subsections (d) and (e) above shall not apply to any unpermitted accessory dwelling unit which is subject to Government Code section 66332 unless the City makes a finding that correcting the violation is necessary to protect the health and safety of the public or occupants of the structure.
(g) Guest houses that were previously approved and which have a valid building permit on file shall not be affected by this chapter. However, an application to convert a guest house to an ADU shall be subject to this chapter.
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(h) Enforcement. Until January 1, 2030, the City shall issue a statement along with a notice to correct a violation of any provision of any Building Code standard relating to an ADU or JADU that provides substantially as follows:

You have been issued an order to correct violations or abate nuisances relating to your accessory dwelling unit or junior accessory dwelling unit.

If you believe that this correction or abatement is not necessary to protect the public health and safety you may file an application with the City Manager. If the City determines that enforcement is not required to protect the health and safety, enforcement shall be delayed for a period of five years from the date of the original notice.

ARTICLE III. ACCESSORY LIVING QUARTERS
Sec. 9.85.300. Development standards for accessory living quarters.

Accessory living quarters shall be developed in accordance with the following standards:
(a) When a lot has not been split under Chapter 164 of the Development Code, which implements SB 9:
(1) A-1 Zone: SRO Development of two to four units and a guest house up to a combined total of 1,500 square feet maximum;
(2) A-2 Zone: SRO Development of two to six units and a guest house up to a combined total of 2,000 square feet maximum;
(3) A-5 Zone: SRO Development of two to ten units and a guest house up to a combined total of 2,500 square feet maximum.
(b) When a lot has been split in accordance with Chapter 164 of the Development Code, the accessory living quarters allowed on the single lot in the A-1, A-2, or A-5 zone shall be split between the two lots in the same percentage as the lot split created in accordance with by per Chapter 164, provided that the SRO Development on any lot must consist of a minimum of two units and the total square footage identified in subsection (a) above is not exceeded between the two lots.
(c) Accessory living quarters are permitted only on residential lots which are developed with an existing or proposed primary unit. The accessory living quarters may not be built before the primary unit.
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(d) Accessory living quarters must comply with the Bradbury Development Code, applicable at the time the plans for Planning Department approval for the accessory living quarters are submitted.
(e) All accessory living quarters, whether attached or detached, must conform to all setback, lot coverage, floor area, emergency evacuation capacity, and building bulk requirements of the applicable zone, and if detached, must be at least 20 30 feet from any other building.
(f) The maximum allowed height for a detached accessory living quarter unit or building shall not exceed 28 feet, even when allowed as a second story above an existing primary unit, garage, or accessory structure.
(g) No accessory living quarter shall exceed one floor in height; however, that floor may be a second story.
(h) The owner of the property must occupy either the primary unit or an accessory living quarter unit.
(i) A minimum of one on-site parking space shall be provided for each accessory living quarter, in addition to the parking requirement for the primary single-family unit. The parking spaces for the accessory living quarters need not be covered, except for multifamily dwellings for which the parking spaces shall be in carports. All parking spaces shall be paved and accessible from a single, common driveway for the primary and accessory living quarter units. Tandem parking is not permitted to meet this off-street parking requirement.
(j) Single room occupancy (SRO) residential units within an SRO development are subject to the following additional requirements:
(1) Each SRO unit within the development shall have a minimum floor area of 150 square feet and a maximum floor area of 300 square feet. (2) Each SRO unit shall have a private toilet as defined by the California Residential Code.
(3) Each SRO unit shall have a separate closet.
(4) Each SRO unit shall have an efficiency kitchen which shall include a cooking facility with appliances and a food preparation counter and storage cabinets that are of reasonable size in relation to the size of the SRO.
(5) Each SRO development shall have a laundry room for the storage of cleaning supplies, with a wash tub with hot and cold running water and a minimum of one washer and one dryer for the development.
(6) No more than two persons shall be allowed to reside in any SRO unit. 58

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Sec. 9.85.310. Accessory living quarters – Neighborhood compatibility review – Standards.

ARTICLE IV. SB 9 UNITS
Sec. 9.85.400. Definitions.

For purposes of this Article IV, the following definitions shall apply:

Housing development shall mean no more than two primary units on a lot within a singlefamily zone that meets the requirements of this sectionArticle. The two units may consist of two new units or one new unit and one existing unit.

Primary unit shall mean a residential unit that is not otherwise classified as an accessory dwelling unit or junior accessory dwelling unit pursuant to Government Code Section 66313.

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Unit shall mean a primary dwelling unit, an accessory dwelling unit, or a junior accessory dwelling unit.

Urban lot split means a lot split of a single-family residential lot into two parcels that meets the requirements of Chapter 164 of the Development Code.

Sec. 9.85.410. Application processing.
(a) The City shall have 30 days to determine if an application is complete. If the application is incomplete, the City shall provide an exhaustive list of items that were not complete. If a determination is not made within 30 days, the application shall be deemed complete.
(a)(b) The City shall approve or deny an application for a housing development within 60 days from the date of a completed application.
(b)(c) If the City fails to approve or deny an application within this time frame, the application shall be deemed approved.
(c)(d) If the City denies the application, it must provide the applicant with a full set of comments with a list of items that are defective or deficient and a description of how the application can be remedied within 60 days from a completed application.

Sec. 9.85.420. Housing development approval.

The City shall ministerially approve a housing development containing no more than two primary units if it meets the following requirements:
(a) The parcel is located within a single-family residential zone. (b) The parcel or development is not located in any of the following areas and does not fall within any of the following categories:
(1) Historic resources as defined below:
a. A contributing structure within an historic district or property included on the State Historic Resources Inventory, as defined in California Public Resources Code section 5020.1, or within a site that is designated or listed as a City landmark or historic property or district pursuant to a City ordinance.
b. A parcel individually listed as a historical resource included in the State Historic Resources Inventory, as defined in Public Resources Code section 5020.1, or within a property individually designated or listed as a city landmark under a City ordinance.
(2) Wetlands as defined in the Unites States Fish and Wildlife Service Manual, Part 660 FW 2 (June 21, 1993).
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(3) A very high fire hazard severity zone as further defined in California Government Code section 65913.4(a)(6)(D). This does not apply to sites excluded from the specified hazard zones by a local agency, pursuant to subdivision (b) of section 51179, or sites that have adopted fire hazard mitigation measures pursuant to existing building standards or State fire mitigation measures applicable to the development. (4) A delineated earthquake fault zone as determined by the State Geologist in any official maps published by the State Geologist, unless the development complies with applicable seismic protection building code standards adopted by the California Building Standards Commission under the California Building Standards Law and by the City's Building Department.
(5) A special flood hazard area subject to inundation by the one percent annual chance flood (100-year flood) as determined by the Federal Emergency Management Agency (FEMA) in any official maps published by FEMA. If an applicant is able to satisfy all applicable federal qualifying criteria in order to provide that the site satisfies this subparagraph and is otherwise eligible for ministerial approval under this section, the City shall not deny the application on the basis that the applicant did not comply with any additional permit requirement, standard, or action adopted by the City that is applicable to that site. A development may be located on a site described in this subparagraph if either of the following are met:
a. The site has been subject to a Letter of Map Revision prepared by FEMA and issued to the City; or
b. The site meets FEMA requirements necessary to meet minimum flood plain management criteria of the National Flood Insurance Program as further spelled out in Government Code section 65913.4(a)(6)(G)(ii).
(6) A regulatory floodway as determined by FEMA in any of its official maps, published by FEMA unless the development has received a no-rise certification in accordance with section 60.3(d)(3) of Title 44 of the Code of Federal Regulations. If an applicant is able to satisfy all applicable federal qualifying criteria in order to provide that the site satisfies this subparagraph and is otherwise eligible for ministerial approval under this section, the City shall not deny the application on the basis that the applicant did not comply with any additional permit requirement, standard, or action adopted by the City that is applicable to that site.
(7) Lands identified for conservation in an adopted natural community conservation plan, habitat conservation plan, or other adopted natural resource protection plan as further spelled out in Government Code section 65913.4(a)(6)(I). (8) Habitat for protected species identified as candidate, sensitive, or species of special status by State or federal agencies, fully protected species, or species protected by the federal Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.), the California Endangered Species Act (Chapter 1.5 (commencing with section 2050) of Fish 61

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and Game Code Division 3), or the Native Plant Protection Act (Chapter 10 (commencing with section 1900) of Fish and Game Code Division 2).
(9) Lands under a conservation easement.
(c) The proposed housing development would not require demolition or alteration of any of the following types of housing:
(1) Housing that is subject to a recorded covenant, ordinance or law that restricts rents to levels affordable to persons and families of moderate, low, or very low income; (2) Housing that has been occupied by a tenant in the last three years. (d) Unless demolition or alteration is prohibited pursuant to subsection (c) above, a housing unit may be demolished.
(e) The parcel is not a parcel on which an owner of residential real property has exercised his rights under Government Code section 7060 et seq. to withdraw accommodations from rent or lease within 15 years before the date of the application. (f) The development is not located within a historic district or property as specified in Government Code section 65852.21(a)(5).

Sec. 9.85.440. Standards and requirements.

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(a) No setback shall be required for an existing structure or a structure constructed in the same location and to the same dimensions as an existing structure. (b) Except for those circumstances described in subsection (a) above, for any new housing developed under this chapter, the setback for side and rear lot lines shall not be less than four feet. This does not prevent the applicant from providing a larger setback.

The front setback shall be as set forth in the applicable single-family residential zone. (c) The applicant shall provide easements for the provision of public services and facilities as required.
(d) Driveways and access shall be provided in accordance with Chapter 103 of the Development Code. Easements shall be provided as required to ensure pedestrian and vehicular access across lots.
(e) Required off-street parking shall be limited to one space per unit, except that no parking shall be required if the parcel is located within one-half mile walking distance of either a high-quality transit corridor or a major transit stop, or there is a car share vehicle located within one block of the parcel. Parking spaces shall meet the following requirements:
(1) Parking spaces may be covered or uncovered, and shall be allowed in the paved portions of setback areas.
(2) Tandem parking between units shall be prohibited.
(f) For residential units connected to an onsite wastewater treatment system (septic tank), the applicant shall provides a percolation test completed within the last five years, or if the percolation test has been recertified, within the last ten years, which shows that the system meets acceptable infiltration rates.
(g) The number and size of the primary units, ADUs, and JADUs, allowed on a single lot or an SB 9 lot, shall comply with the other provisions of this Title regulating such uses as set forth in section 9.85.020, except that only one primary unit must comply with the minimum size of a primary unit for the zone.
(h) The number and size of accessory living quarters allowed on a single lot in one of the Agriculture Residential Estate zones shall not exceed that allowed in Article III of this Chapter. If the lot is split into two SB 9 lots, the total amount of accessory living quarters allowed on the single lot may shall be split between the two new lots as provided for in section 9.85.300.
(i) Design standards. To the extent not superseded by this chapter, the SB 9 unit shall meet all existing objective design standards of the underlying zone. (j) If there is no existing unit on the original parcel prior to any lot split allowed pursuant to Chapter 9.164, one of the allowed units may be built to the standards for a main house under the applicable zone.
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Sec. 9.85.460. Affidavit required.

SECTION 4. Chapter 164 of Title IX, Development Code, is hereby amended to read as follows:

CHAPTER 164. URBAN LOT SPLITS
Sec. 9.164.010. Definitions.

For purposes of this Chapter only, the following definitions shall apply:

Unit shall mean a primary dwelling unit, an accessory dwelling unit of any type, a junior accessory dwelling unit, or an SB 9 unit. "Unit" shall not include a guest house or an SRO development.
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Urban lot split means a lot split of a single-family residential lot into two parcels that meets the requirements of this chapter.

Sec. 9.164.020. Application processing.
(a) The City shall have 30 days to determine if an application is complete. If the application is incomplete, the City shall provide an exhaustive list of items that were not complete. If a determination is not made within 30 days, the application shall be deemed complete.
(a)(b) The City shall approve or deny an application for an urban lot split within 60 days from the date of a completed application.
(b)(c) If the City fails to approve or deny an application within this time frame, the application shall be deemed approved.
(c)(d) If the City denies the application, it must provide the applicant with a full set of comments with a list of items that are defective or deficient and a description of how the application can be remedied within 60 days from a completed application.

Sec. 9.164.030. Urban lot split approval.

The City shall ministerially approve a parcel map for a lot split that meets the following requirements:
(a) The parcel is located within a single-family residential zone. (b) The parcel is located at least partially in an urbanized area or urban cluster as designated by the United States Census Bureau.
(c) The parcel map divides an existing parcel to create no more than two new parcels of approximately equal lot area, provided that one parcel shall not be smaller than 40 percent of the lot area of the original parcel.
(d) Both newly created parcels are no smaller than 1,200 square feet. (e) The parcel is not located in any of the following areas and does not fall within any of the following categories:
(1) A parcel located within a historical landmark historic district or property included on the State Historic Resources Inventory, as defined in Public Resources Code section 5020.1, or within a site that is designated or listed as a City landmark or historic property or district pursuant to a City ordinance.
(2) Wetlands as defined in the Unites States Fish and Wildlife Service Manual, Part 660 FW 2 (June 21, 1993).
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Division 3 of the Fish and Game Code), or the Native Plant Protection Act (Chapter 10 (commencing with section 1900) of Division 2 of the Fish and Game Code). (9) Lands under a conservation easement.
(f) The proposed lot split would not require demolition or alteration of any of the following types of housing:
(1) Housing that is subject to a recorded covenant, ordinance or law that restricts rents to levels affordable to persons and families of moderate, low, or very low income; (2) Housing that has been occupied by a tenant in the last three years. (3) A contributing structure within a historic district included on the State Historic Resources Inventory, as defined in Public Resources Code section 5020.1, or historic property or district pursuant to a City ordinance.
(4) An existing exterior structural wall of a structure located within either a historic district that is included on the California Register of Historical Resources or within a historic district listed or designated pursuant to a City ordinance. (g) The lot split does not create more units or accessory living quarters than allowed under Chapter 9.85.

Sec. 9.164.040. Standards and requirements.

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(f) Development of the lots shall be in accordance with Chapter 85 of the Development Code.

Sec. 9.164.050. Denials.
(a) The City shall not:
(1) Require dedications of rights-of-way or the construction of offsite improvements for the parcels being created as a condition of issuing a parcel map. (2) Impose any objective subdivision standards that would have the effect of physically precluding the construction of two units on either of the resulting parcels or that would result in a unit size of less than 800 square feet. (3) Require the correction of nonconforming zoning provisions as a condition for the lot split.
(4) Deny an application solely because it proposes an adjacent or connected structure provided that all building code safety standards are met and they are sufficient to allow a separate conveyance.
(b) The City may deny the lot split if the Building Official makes a written finding, based upon a preponderance of the evidence, that the proposed housing development project would have a specific, adverse impact, as defined and determined in California Government Code section 65589.5(d)(2), upon the public health and safety or the physical environment and for which there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact.

Sec. 9.164.060. Affidavit.

An applicant for an urban lot split shall be required to sign an affidavit in a form approved by the City Attorney to be recorded against the property stating the following:
(a) That applicant intends to occupy one of the housing units as their principal residence for a minimum of three years from the date of approval. This requirement does not apply when the applicant is a "community land trust" or a "qualified nonprofit corporation" as the same are defined in the Revenue and Taxation Code.
(b) That the uses shall be limited to residential uses. (c) That any rental of any unit created by the lot split shall be for a minimum of 31 consecutive calendar days.
(d) That the maximum number of primary units, ADUs of any kind, and JADUs to be allowed on each parcel shall not exceed two units. This shall not include the accessory living quarters allowed pursuant to Article III of Chapter 85 of Title IXsection 9.85.020 of the Bradbury Municipal Code.
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(e) That the accessory living quarters allowed on the single lot in the A-1, A-2, or A-5 zone may shall be split as provided for in section 9.85.300.

Sec. 9.164.070. Inapplicability of chapter.

This Chapter shall not apply to:
(a) Any parcel which has previously been established pursuant to a lot split in accordance with the provisions of the chapter; or
(b) Any parcel where the owner of the parcel being subdivided or any person acting in concert with the owner has previously subdivided an adjacent parcel in accordance with this section. For purposes of this section, "acting in concert" shall include, but not be limited to, where the owner of a property proposed for an urban lot split is the same, related to, affiliated with, or connected by partnership to the owner, buyer or seller if transferred within the previous three years of an adjacent lot.

SECTION 5. Section 9.34.020 of the Development Code is hereby amended as follows:

9.34.020. – Architectural review – Minor and significant. (a) Minor architectural review shall be limited to development which meets the following criteria:
(1) Minor modifications to the exterior appearance of any building or structure not facing a street or accessway;
(2) Construction of single-story structures, including accessory structures, which are less than 1,000 square feet of floor area;
(3) Construction which does not exceed a total of 18 feet in height from grade for the finished structure; and
(4) Construction of swimming pools, fences and gates or minor landscaping improvements which do not exceed 25 percent of the parcel size, and installation of exterior mechanical, electrical and plumbing equipment. (b) Significant architectural review shall cover all development other than those listed in subsection (a) above.
(c) Accessory dwelling units, and very high fire zonejunior accessory dwelling units, SB 9 units, or any other approval where such application is preempted by State law shall not require any architectural review, regardless of where such units are located.

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implement the provisions of those sections shall not be considered a project subject to CEQA, and also by the common sense exemption of CEQA Guidelines Section 15061(b)(3) as all changes set forth in this Ordinance are required by State law and therefore apply regardless of whether the City amends the provisions of the Municipal Code.

SECTION 8. The City Clerk shall certify to the adoption of this Ordinance.

SECTION 9. This Ordinance shall be sent to HCD in accordance with State law.

PASSED, APPROVED and ADOPTED this _____ day of___________, 2026.

Elizabeth Bruny, Mayor
ATTEST:

Paulina Reyes, Deputy City Clerk

STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) §.

AYES:

NAYS:

ABSENT:

Paulina Reyes, Deputy City Clerk
City of Bradbury
70 ATTACHMENT C
Agenda Report – September 22, 2026

PLANNING COMMISSION RESOLUTION
NO. PC 26-330
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74 ATTACHMENT D
Agenda Report – September 22, 2026

PLANNING COMMISSION MINUTES
FOR
MARCH 25, 2026 AND MAY 27, 2026
WITH

EXHIBITS FROM RESIDENTS
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ATTACHMENT E
Agenda Report – September 22, 2026

PLANNING COMMISSION MINUTES
FOR JULY 22, 2026 – DRAFT
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A C T I O N M I N U T E S

PLANNING COMMISSION

OF THE CITY OF BRADBURY

REGULAR MEETING
Wednesday, July 22, 2026 – 7:00 p.m.

BRADBURY CIVIC CENTER
600 Winston Avenue, Bradbury, CA 91008

1. CALL TO ORDER & PLEDGE OF ALLEGIANCE
The Regular Meeting of the Planning Commission of the City of Bradbury was called to order at 7:00 p.m. by Chairperson Robert Jones. The Pledge of Allegiance was led by Chairperson Jones.

2. ROLL CALL – A Quorum was established by roll call:

Present: Chairperson Robert Jones
Commissioner Frank Hernandez
Commissioner Chelsea Halbmann
Commissioner Darlene Kuba

Absent: Vice Chairperson Daniel Lien
Staff: City Manager Kevin Kearney, City Planner Jim Kasama, and City Clerk Diane Jensen.

Commissioner Kuba made a motion to excuse the absence of Vice Chairperson Daniel Lien.

The motion was seconded by Commissioner Halbmann. The motion passed 4:0.

3. SUPPLEMENTAL INFORMATION FROM STAFF REGARDING AGENDA ITEMS City Planner Kasama advised of two documents before the Commissioners that were received after the agenda packet was distributed:
• Email from David Szymkowski, resident at 6 Bradbury Hills Road • Updated Existing Street Widths map with widths on El Cielo Lane added.

4. AGENDA – Commissioner Kuba made a motion to approve the agenda. Chairperson Jones seconded the motion. The motion passed 4:0.

5. MINUTES
Commissioner Halbmann made a mo�on to approve the Minutes for the March 25, 2026 Regular Planning Commission mee�ng. Chairperson Jones seconded the mo�on. The mo�on passed 4:0.

Commissioner Halbmann made a mo�on to approve the Minutes for the May 27, 2026 Regular Planning Commission mee�ng. Commissioner Hernandez seconded the mo�on. The mo�on passed 4:0.
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6. PUBLIC COMMENT
None

7. PUBLIC HEARING
REVIEW OF DRAFT ORDINANCE NO. 401

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF BRADBURY, CALIFORNIA AMENDING SECTION 9.25.020 OF THE BRADBURY DEVELOPMENT CODE RELATING TO DEFINITIONS, AMENDING SECTION 9.34.020 REGARDING ARCHITECTURAL REVIEW, AMENDING CHAPTER 9.85 OFTHE BRADBURY DEVELOPMENT CODE RELATING TO ACCESSORY DWELLING UNITS, JUNIOR ACCESSORY DWELLING UNITS, AND SB 9 UNITS, AND AMENDING CHAPTER 9.164 OF THE BRADBURY MUNICIPAL CODE RELATING TO

URBAN LOT SPLITS, AND FINDING THAT THIS ORDINANCE JS EXEMPT FROM CEQA PURSUANT TO PUBLIC RESOURCES CODE SECTION 21080.17 AND GOVERNMENT CODE SECTIONS 65852.21 AND 66411.7 AND THE COMMON SENSE EXEMPTION OF CEQA GUIDELINES SECTION 15061(b)(3)
PLANNING COMMISSION RESOLUTION NO. PC 26-330

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF BRADBURY,

CALIFORNIA, SETTING FORTH THE FINDINGS AND A DECISION TO RECOMMEND TO THE CITY COUNCIL APPROVAL AND ADOPTION OF ORDINANCE NO. 401 AMENDING SECTION 9.25.020 OF THE BRADBURY DEVELOPMENT CODE RELATING TO DEFINITIONS, AMENDING SECTION 9.34.020 REGARDING ARCHITECTURAL REVIEW, AMENDING CHAPTER 9.85 OF THE BRADBURY DEVELOPMENT CODE RELATING TO ACCESSORY DWELLING UNITS, JUNIOR ACCESSORY DWELLING UNITS, AND SB 9 UNITS, AND AMENDING CHAPTER 9.164 OF THE BRADBURY MUNICIPAL CODE RELATING TO

URBAN LOT SPLITS, AND FINDING THAT THIS ORDINANCE IS EXEMPT FROM CEQA PURSUANT TO PUBLIC RESOURCES CODE SECTION 21080.17 AND GOVERNMENT CODE SECTIONS 65852.21 AND 66411.7 AND THE COMMON SENSE EXEMPTION OF CEQA GUIDELINES SECTION 15061(b)(3)
City Planner Kasama presented the agenda report and answered the Commission’s questions.

Chairperson Jones opened the Public Hearing. The following residents spoke:
• David Szymkowski of 6 Bradbury Hills Road spoke in support of the Ordinance. • Anne Absey of 44 Woodlyn Lane spoke in support of the Ordinance. • Elaine Bigley of 41 Woodlyn Lane spoke in support of the Ordinance.

The Commission discussed the draft Ordinance. A resident asked to address the Commission.

Chairperson Jones reopened the public hearing.
• Merek Helstrom of 21 Woodlyn Lane asked how the 20-foot road width was derived. Chairperson Jones replied that it is to provide space for vehicles to pass each other. Commissioner Kuba said it is a fire department requirement. City Manager Kearney said it is stated in a safety study.
• Mike Oliver of 5 Woodlyn Lane asked about the maximum size of an ADU. Staff replied that it is 1,000 square feet of living space.
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Chairperson Jones closed the Public Hearing
Chairperson Jones moved to adopt Resolution No. PC 26-330 to recommend approval of the Ordinance. Commissioner Hernandez seconded the motion. The motion passed with a roll call vote:

Commissioner Hernandez: Aye
Commissioner Halbmann: Aye
Chairperson Jones: Aye
Commissioner Kuba: Aye
Commissioner Lien: Absent

8. ITEMS FROM STAFF and COMMISSIONERS
• Commissioner Kuba asked about the status of the development proposal at 1527- 1533 Royal Oaks by Sunrise Real Estate Development. City Manager Kearney replied that the applicant is preparing environmental studies.

A. Development Project Status Report – July, 2026. There were no questions.

B. Upcoming Agenda Items and Other Matters – None

9. ADJOURNMENT
At 7:42 p.m., Chairperson Jones made a motion to adjourn the meeting to the next regular Planning Commission meeting on Wednesday, August 26, 2026 at 7:00 p.m. at the Bradbury Civic Center. Commissioner Kuba seconded the motion. The motion passed 4:0.

APPROVED:

Signature Date Printed Name
ATTEST:

Paulina Reyes, Deputy City Clerk Date
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ATTACHMENT F
Agenda Report – September 22, 2026

HCD FACT SHEETS
DUPLEXES AND LOT SPLITS (SB 9)
&

ACCESSORY DWELLING UNIT (ADU)
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ATTACHMENT G
Agenda Report – September 22, 2026

CALMATTERS ARTICLE

CALIFORNIA HOA TRIUMPHS OVER ADU LAW
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ATTACHMENT H
Agenda Report – September 22, 2026

DUDEK MEMORANDUM

REGARDING ADU LAW
119
12942
1 December 2020

MEMORANDUM
To: Kevin Kearney, City of Bradbury
From: Dudek Fire Protection Planning Team; Michael Huff - Principal Subject: California’s Accessory Dwelling Unit Law (AB No. 68) Date: December 9, 2020
cc: Bradbury City Council
Attachment(s): 1 City Provided Areas of Focused Assessment 2 Bradbury Fire Hazard Map
3 Bradbury and Los Angeles County Code References
Summary
The following analysis provides a response to the City of Bradbury’s concerns regarding the impact of California’s Accessory Dwelling Unit Law (AB No. 68), that can affect fire safety. Specifically, the City requested that Dudek examine issues relating to setbacks and prohibition on fire sprinklers, including the evaluation of the potential for increased fire hazard potential. Separate from the wildfire issues, State law continues to prohibit the City from requiring automatic fire sprinklers in ADU’s when the main residence was not required to have fire sprinklers. Based on the State of California’s findings regarding the effects of climate change on wildfire hazards and risks, and the proposed approaches to addressing it, and on California’s Draft Office of Planning and Research’s direction for General Plan policies and program, it does not appear to be a prudent decision to allow ADUs in fire hazard severity zones without specific fire protection measures, many of which the State is already recommending in their own conclusions and which are discussed in the Conclusions and Recommendations sections that follow.

Our assessment of the general fire safety related to the requirement for four-foot setbacks and the inability to require fire sprinklers results in our opinion that its implementation in Bradbury would likely have negative fire related impacts.

Issue
Bradbury’s concern over portions of State law’s preemption of local requirements that can affect fire safety prompted this analysis. The City’s concern stems from Bradbury’s location and fire history. Most of Bradbury is located within a very high fire hazard severity zone (VHFHSZ), a wildland urban interface area, an ember intrusion zone, and is officially recognized by the federal government as a community at high risk from wildfire (https://www.federalregister.gov/ documents/2001/01/04/01-52/urban-wildland-interface-communities-within-the-vicinity-of-federal-lands-that-areat-high-risk-from.) The City is located at the foothills of the San Gabriel Mountains and adjacent to the Angeles National Forest.

Terrain and fuels throughout portions of Bradbury would facilitate wildfire, particularly under extreme weather conditions. Wildfires regularly occur within the foothills of the San Gabriel Mountains and the area is subject to semi-regular, extreme fire weather including high winds and low humidity, a combination that increases the vegetation ignition potential and enhances fire spread rates and intensity. For example, the City was subject to 120
Memorandum
Subject: California Accessory Dwelling Unit Law (AB No. 68) 12942
2 December 2020
an aggressive wildfire in 1980 that killed one person and destroyed 49 Bradbury homes. An estimated 6,200 acres were burned and approximately $15 million in damage incurred. As this report was prepared, Bradbury residents had recently been under evacuation warning due to the Bobcat Fire that had burned 115,000 acres, including areas just north of the City.

The City requested that Dudek examine issues relating to setbacks and prohibition on fire sprinklers from a fire safety perspective, including the evaluation of the potential for increased fire hazard potential. The term accessory dwelling unit (ADU) often connotes a detached “granny flat,” which seems to be the ADU structure of most concern to the Bradbury City Council. However, the broad definition of the term includes attached and embedded ADUs as well. The following analysis and information will address the detached ADUs, since they were the focus of City provided guidance questions/responses. These questions/responses included the following and are further detailed in Attachment #1:

1. Review any challenges of hillside area setbacks being calculated from property lines instead of by building pads.

2. Investigate safe distances between ADUs or ADUs and other structures in high fire severity zones where there are no sprinklers in the ADUs or main residence. Look at where there are sprinklers in one or both.

3. Describe the danger of fire spreading if the ADU has sprinklers but not the main house. Compare the likelihood of fire communication between structures with and without sprinklers.

4. Is a 20-foot right of way needed to get a fire truck into the street? How does that correlate with 20 feet between buildings fir fire apparatus?

5. Verify if a 1,000 sq. ft. addition is added to an existing home (i.e., not an ADU), would one have to add sprinklers to the existing home?

7. Are there any contradictions between the State’s desire to fortify high fire hazard areas through land use and its housing density regulations?

8. Address any climate change issues related to ADUs – more fires, larger fires, greater risk? For purposes of the fire safety evaluations conducted herein, the following Bradbury Municipal Code (BMC) definitions apply, and can be found in BMC Section 9.85.020:

Accessory dwelling unit shall mean a dwelling unit that is attached, detached, or located within an existing or proposed residential dwelling which provides complete independent living facilities for one or more persons and includes permanent provisions for living, sleeping, eating, cooking and sanitation facilities on the same parcel of land as the residential dwelling. Dudek’s analysis focuses generally on detached ADUs in response to City guidance questions.

Junior accessory dwelling unit shall mean an accessory dwelling unit that is no more than 500 square feet in size and contained entirely within a single-family residence. This does not include an attached garage or other attached accessory structure.

Primary unit shall mean an existing single-family dwelling, or the larger of two proposed units. 121
Memorandum
Subject: California Accessory Dwelling Unit Law (AB No. 68) 12942
3 December 2020
Findings
Our assessment of the general fire safety related to the requirement for four-foot setbacks and the inability to require fire sprinklers results in our opinion that its implementation in Bradbury would likely have negative fire related impacts.

Currently, the City precludes ADUs in the VHFHSZ. Adding dwelling units in this area could increase structure wildfire risk, even though ADUs would be obliged to meet the statewide minimum requirements of ignition resistant construction materials and methods as prescribed in Chapter 7A of the California Building Code. However, even ignition resistant buildings that are not set back appropriately from unmaintained fuels with suitable defensible space may represent an increased risk of structure ignition and potential for structure-to-structure ignition when older, more vulnerable primary residences (those built prior to 2007’s enhanced ignition resistance requirements and 2010’s inclusion of interior sprinklers) are within short setback proximity. Conversely, ADUs that are close to a property line where the owner has no ability to provide defensible space off-site and with natural vegetation beyond, represents a potential ignition source should a structure fire occur, and if that ADU is not sprinklered, the potential for an internal (structure) fire to spread into the open space fuels increases. Neighboring property owners may be required to provide defensible space for a neighbor that builds an ADU. Additional ADUs also increase the density in high fire hazard severity zone areas. This increased density would lead to more vehicles and traffic and, depending on the total number of additional vehicles, may result in impassible or congested roadways for emergency vehicles and less effective emergency access, delayed evacuations and greater potential wildfire risk to residents and incoming responders.

Separate from the wildfire issues, the revised ADU law continues to prohibit the City from requiring automatic fire sprinklers in ADUs when the main residence was not required to have fire sprinklers. The lack of a sprinkler requirement is disappointing, as sprinklers were adopted in the 2010 California Building and Fire Codes for all new one- and two-family homes because, after many years of proving their worth, were recognized to save lives, both occupants’ and firefighters’, reduce damage, protect and benefit the environment, and reduce demand on fire suppression services and resources. The fact that ADUs were specifically carved out of this requirement is incongruous with the residential sprinkler effort of so many years by so many code officials, and frankly, inexplicable.

Example: Santa Barbara ADU
The City of Santa Barbara, like Bradbury, has prohibited ADUs in high fire hazard zones. ADU law could be interpreted as an override of this restriction, which is somewhat confusing given the State’s focus on, and passage of, numerous wildfire safety related laws over the last decade. In late 2019, Santa Barbara passed an emergency ordinance to prohibit new ADUs in their highest fire hazard severity zones, at least until December 2020 so they could evaluate the impacts of the state’s new law. Santa Barbara has drafted a 2020 ADU Ordinance Update, which was scheduled to be considered by the City Council on September 24, 2020. The Ordinance Update would be consistent with State law and apply locally adopted requirements for ADUs in the highest fire hazard severity zones.

The ignition resistant construction provisions as outlined in Chapter 7A of the Building Code would apply, as no variance or modification is allowed (as would be the case in Bradbury). 122
Memorandum
Subject: California Accessory Dwelling Unit Law (AB No. 68) 12942
4 December 2020
The following standards are required for ADUs in Santa Barbara’s fire hazard zones:

1. No Tandem Parking. Santa Barbara recognizes that wildfire related evacuations present a significant risk in their foothill and extreme locations. To that regard, they are prohibiting tandem parking, as it can delay evacuations and cause interruptions in traffic flow when vehicles are backed into the street during an evacuation. Relatedly, they are requiring one parking spot per ADU, whereas, the ADU legislation absolves parking stipulations. “No parking space shall be developed in a tandem configuration.” Note that Santa Barbara includes very dense, smaller parcels and circuitous, narrow roads compared to Bradbury within the higher fire hazard areas.

2. High Fire Construction. The accessory dwelling unit shall be designed to meet high fire construction standards adopted or enforced by the City, as determined by the Chief Building Official or the Fire Code Official. Application of Chapter 7A of the Building Code is consistent with “High Fire Construction”.

3. No Variance or Modification. No variance or modification to any Fire Code requirements or high fire construction standards shall be permitted.

4. Defensible Space. Santa Barbara, noting the need for defensible space, requires that existing defensible space requirements are applied to ADUs. “The site must meet defensible space requirements, pursuant to Chapter 8.04 of this code, prior to occupancy and those requirements must be maintained”.

Similar requirements in a Bradbury ADU Ordinance Update may be appropriate given the similarities between the cities and their fire hazards.
123
Memorandum
Subject: California Accessory Dwelling Unit Law (AB No. 68) 12942
5 December 2020
Conclusions
Based on Dudek’s analysis of State law, research conducted to respond to each comment/question provided by the City, and comparing the similar City of Santa Barbara, the following conclusions are offered regarding building ADUs in Bradbury.

1. ADUs in fire hazard severity zones may increase the potential fire risk by increasing density and the number of lower ignition resistant and unsprinklered structures.

2. Structure to structure ignition of buildings in close proximity to each other is possible, has been experienced in numerous communities, and is related to the exterior ignition resistance levels and distance apart, more so than to the presence of interior fire sprinklers. However, sprinklers may play a role in reducing the damage realized and could minimize structure to structure spread probabilities by controlling an interior fire to the room of origin.

3. If an ADU is sprinklered, then an interior fire will be suppressed or at least controlled and confined, reducing potential for structure to structure ignition. If the primary structure is not ignition resistant, it will be more susceptible to ignition. If the primary structure is not sprinklered, it also may be more susceptible to ignition from an interior structure fire.

4. The state mandated sprinklers in all new one- and two-family dwellings since 2010 yet exempted sprinklers when the state created ADU laws. This is incongruous and fire prevention officials consider unfortunate.

5. The fire code includes provisions for 20-foot unobstructed access roads. This is based on the width of fire engines and their ability to pass one another. There is no spacing requirement between buildings for fire department apparatus access. Fire Department vehicular access must be provided to allow a hose to be pulled therefrom and reach all points around the exterior of a structure within 150 feet. Firefighters pull hoses to the buildings rather than park directly next to a building.

6. Based on the current code, adding a 1,000 square foot addition to an existing home would not likely require that the structure be provided with interior sprinklers. There are specific circumstances where sprinklers would be required, but they are relatively remote occurrences except for additions that exceed 50% and increase the total square footage to over 5,000 square feet and are further than 3 miles from the nearest fire station. We believe the 3-mile fire station distance exception alone would apply to nearly all Bradbury home remodels thereby exempting any sprinkler installation in additions/remodels.

7. Manufactured homes are required to include ignition resistant features meeting Chapter 7A of the building code when located within wildland urban interface and fire hazard severity zones. Depending on the City’s inspection process, there may be some risk that a manufactured home not including ignition resistant features could be brought into the City, in which case it would pose a higher risk of wildfire ignition.

8. Climate change has been declared by California agencies to have a major impact on wildfire frequency and severity. Subsequently, as areas include higher populations within fire hazard severity zones, the result may be higher overall risk. The risk may be related to higher structure density, an increase in ignition sources (more people could lead to more ignitions), and also an increase in the wildfire risk to people from being closer to wildfires and relying on unimproved or insufficient evacuation routes. Adding ADUs may increase the number of vehicles needing to evacuate with no increase in road capacity, which would have the potential to increase evacuation times and pose challenges for incoming responders. 124
Memorandum
Subject: California Accessory Dwelling Unit Law (AB No. 68) 12942
6 December 2020
Recommendations

1. The City must continue to enforce Chapter 7A for all ADUs and any new structures in fire hazard severity zones.

2. Automatic fire sprinklers should be installed in ADUs, whenever possible. The City should consider options to include sprinklers in all ADUs. In addition, educating the public on sprinkler importance could result in the inclusion of sprinklers in ADUs even though it cannot be required in all cases.

3. FMZs should be strictly enforced and where possible, should be extended to 100 feet from all structures; where not possible, alternative materials and methods, such as design features or fire protection systems, may be considered.

4. Manufactured homes should require City direction to resident buyers and inspections to confirm compliance with CBC Chapter 7A has been provided.

5. ADUs should be monitored to assess potential impacts on emergency evacuation (i.e., multiple ADUs on a dead-end street – how many more people and vehicles could this represent?). Limits may need to be explored to minimize the potential for inefficient evacuations.

6. Parking may not be a concern in Bradbury as it is in Santa Barbara due to the large size lots and lower housing densities. It is likely that ADU related vehicles would have adequate parking off the street. However, if tandem parking becomes an issue, enacting a similar ordinance requirement to limit the number of tandem vehicles to facilitate faster evacuations should be explored.

7. Consider a broad fire safety ordinance review to consider if a customized Bradbury-focused fire code instead of merely adopting the Los Angeles County Fire Code is appropriate or other municipal code provisions are necessary. Because most of Bradbury is within a high or very high fire severity zone, a comprehensive review to strengthen the municipal code or guide the adoption process for future code adoptions is recommended.
125
Attachment 1
City Provided Areas of Focuses Assessment
126
Attachment 1
City Provided Areas of Focused Assessment
12942
1-1 December 2020
Fire safety topics and questions that Dudek was asked to assess and provide informed opinions are detailed in the following sections.

1. Review any challenges of hillside area setbacks being calculated from property lines instead of by building pads.

Setbacks for land use planning purposes are established to present a uniform appearance in a development and to prevent structures from encroaching on adjacent lots or streets. Setbacks are typically delineated as prescribed distances from the property lot line, but can also refer to the graded building pad edge. When the edge of the building pad is used for setbacks, the rationale may be for maintaining usable open space on the lot, view preservation from adjacent property, or maintaining safe distances from hillsides or slopes. If the adjacent slope is covered with native vegetation that may be considered a fire hazard (typical in southern California), this may be another reason to enforce a building pad setback. Based on the latter, it is reasonable for the City to measure the setback from the building pad when the lot is sloped and adjacent to wildland fuels to minimize potential for direct flame moving up the slope to intersect with the structure.

From a building code perspective, the separation of structures from other structures is intended to minimize the risk of fire communicating to or threatening an adjacent structure. The openings in exterior walls and the fire resistance of exterior walls are regulated by the distance to property lines. For more than one building on the same lot, the building codes use a concept of “imaginary property lines”. The designer has the freedom to choose where the imaginary property line is between structures on the same lot and then establish the exterior wall fire resistance and opening requirements based on the distances thereto.

For defensible space purposes in the wildland-urban interface, fuel modification zones are established and maintained to provide buffers between flammable fuels and buildings and minimize the likelihood of flame impingement or excessive heat exposure and ultimately, to minimize the possibility that structures may ignite from an approaching wildland fire. In addition, it provides firefighters with a “reduced fuel” area in which to defend the structure. Fuel modification zones are generally 100 feet wide, measured from the closest structure on the lot to the untreated vegetation. If the full width cannot be provided, then additional fire protection measures (i.e., building materials, fire protection systems) may be considered by the fire department as acceptable alternatives.

Conversely, if the fire environment is extreme, the fuel modification zone (FMZ) may be extended to 200 feet or more based on anticipated fire behavior driven by steep terrain, heavy fuels, wind alignments and other factors.

In assessing the setback requirements as they apply to ADUs, a cursory review of the Bradbury Municipal Code (BMC) was conducted to prepare a reference table (Table 1). The setbacks from property lines must comply with the respective City requirements identified in the BMC. Side and Rear Yard setbacks for ADUs are four feet from the property line, which is much less than the setbacks for the primary structure on the lot (varies by Zone – see Residential Zone Setbacks table). [Note: this scenario would most likely be encountered for detached ADUs.] All building separation requirements would need to comply with the Building Code as adopted by the City (the City adopts the Los Angeles County Building and Fire Codes, which are based on the California Codes, with local amendments). This would apply to buildings on the same lot as well as adjacent lots.

State law does not allow the City to require the same setbacks between ADUs and primary structures on other lots, and therefore, could represent an increase in the potential for structure-to-structure ignitions. 127
Attachment 1
City Provided Areas of Focused Assessment
12942
1-2 December 2020
Table 1. Bradbury Municipal Code ADU Setback Requirements Residential Zone Setbacks
Zone
Front yard
(ft)
Side yard
(ft)
Rear Yard
(ft) Min. Area
Min. avg. Width
(ft) Fire Hazard Area
R-7,500 20 20 30 7,500 sf 60 High/Moderate
R-20,000 35 15 15 20,000 sf 80 Very High/High
A-1 50 25 25 1 ac. 100 Very High/High
A-2 50 25 25 2 ac. 120 Very High
A-5 50 25 25 5 ac. 250 Very High/High
Hillside 100 100 100 2 ac. and ≥10% slope NA Very High/High ADUs See above 4 4 See above See above Not permitted in Very High
* ADUs must comply with the requirements for whichever Zone they are located.

As mentioned in 1 above, the California Building Code (CBC) regulates the minimum distances between structures.

There are no specific distances for ADUs as they are treated the same as a primary residence (R3 occupancies).

For an ADU (or house) the California Residential Code (CRC) requires the exterior wall to be one-hour fire resistance rated if it is between zero (0) and five (5) feet of the property line (or imaginary property line between it and another structure on the same lot). At five (5) feet or more, the wall is not required to be fire resistance rated. The aforementioned is for non-fire sprinklered structures. If a residential fire sprinkler system is provided, then three (3) feet separation is the acceptable distance criterion.

Where the codes recognize the unique nature of the wildland-urban interface (WUI), the State of California added specific provisions in the building code (Chapter 7A in CBC, or Section 337 in the CRC) that adds construction features to “harden” structures located in Fire Hazard Severity Zones (FHSZ’s) by making them more ignition resistant. The State requirements apply to new structures only, not to additions, alterations, or remodels, unless the local building department adopted some specific trigger language in their code adoption ordinance. Los Angeles County does amend the Code to require additions, alterations, and repairs to comply with these WUI related requirements. [Note: The City of Bradbury adopts the Los Angeles County Codes for use in the City.] ADUs (as well as residence additions) in fire hazard severity zones would be required to build to the Chapter 7A standards, which does not include fire sprinklers. (https://library.municode.com/ca/los_angeles_county/codes/code_of_ ordinances?nodeId=TIT26BUCO_CH7A _SFMMACOMEEXWIEX_S701ASCPUAP) 701A.1 - Scope.

This Chapter applies to building materials, systems, and/or assemblies used in the exterior design and construction of new buildings, and to additions, alterations, or repairs made to existing buildings, erected, constructed, or moved within a Wildland-Urban Interface Fire Area as defined in Section 702A. (Ord. 2019-0056 § 4, 2019.) 128
Attachment 1
City Provided Areas of Focused Assessment
12942
1-3 December 2020
701A.3 - Application.

New buildings, and any additions, alterations, or repairs made to existing buildings located in or moved within any Fire Hazard Severity Zone within State Responsibility Areas or any Wildland-Urban Interface Fire Area designated by the Los Angeles County Fire Department that is constructed after the application date shall comply with the provisions of this Chapter.

For 2-family dwellings (duplexes), the CRC requires a one-hour fire resistive wall between the two dwelling units.

This requirement would also apply to an ADU to an existing (or new) home (CRC 302.3).

Some of the features required by CRC 337, Materials and Construction Methods for Exterior Wildfire Exposure, (or CBC Chapter 7A) include:
• Vegetation management
• Ignition resistant materials for exterior surfaces (roofs, exterior walls, decks, balconies) • Regulated openings to the outside to control or minimize opportunity for heat transfer into the structure or ember intrusion (vents, windows, skylights, doors)
The overarching theme of these provisions is to lessen the ignitability of the structure from an advancing wildfire’s embers or flame impingement.

In contrast, the value of installing residential fire sprinklers is the life safety of the occupants. Theoretically, a home could still burn down even with sprinklers. If the occupants are able to escape the home unharmed, this is not considered a failure because the sprinklers performed as designed by delaying the burning process. In reality, however, sprinklers significantly preserve property in addition to life. Since sprinklers are relatively inexpensive to install and proven to provide significant benefits, it is confusing as to why ADUs do not have to comply with this requirement if the main structure was not required to comply. The inherent benefit of fire sprinklers is recognized by the Codes.

Sec. 9.85.050. - Development standards/requirements—Accessory dwelling units.

Fire sprinklers. Fire sprinklers shall be required in any accessory dwelling unit if they were required in the primary unit.

Sprinklered buildings provide some level of protection to minimize interior fire spread. However, structure to structure fire relies primarily on proximity and exterior ignition resistance levels. Where older, less ignition resistant buildings are near each other, there is a higher likelihood of structure to structure ignition based on the heat output of one structure that is in close proximity to an unprotected second structure. Sprinklers in one or both of these structures may play a role in limiting fire spread internally, but would not necessarily prevent exterior ignition from occurring and spreading and a sprinklered structure from being lost if the eave/attic were to become involved.

Therefore, structure to structure ignitions are possible, are less likely with higher exterior ignition resistance levels, and are not directly related to interior sprinklers. For buildings within eight feet of one another, the least likely scenario for structure to structure ignition would be where two new ADUs or a new ADU and a newer home were constructed to high exterior ignition resistant levels and including interior sprinklers were located adjacent each other (vs one older building or two older buildings not sprinklered). The greater the spacing and level of ignition resistance, the lower the heat transfer and likelihood of ignition. 129
Attachment 1
City Provided Areas of Focused Assessment
12942
1-4 December 2020

3. Describe the danger of fire spreading if the ADU has sprinklers but not the main house. Compare the likelihood of fire communication between structures with and without sprinklers.

Any structures in a WUI create the risk of becoming an ember-generator if they ignite. A burning structure produces embers and firebrands which can then travel great distances and ignite a wildfire or help spread (an existing) wildfire or to other structures that are vulnerable to ember penetration. Similarly, a structure fire can generate intense heat in a fully involved event. This heat, which can approach 1,200o F can ignite nearby structures that are not designed, constructed, and maintained to withstand this heat source. Most of Bradbury’s structures were built prior to the ignition resistant code and sprinkler requirements of 2007 and 2010, respectively, resulting in a higher level of vulnerability for those structures that did not include enhanced ignition resistance. Setbacks between structures result in reduced heat proportional to the setback. Greater distances between structures allows heat dissipation, reducing the heat impacts. Likewise, ignition resistant construction materials are intended to withstand high intensity fire for a very short timeframe (from wildfires which are typically fast moving), but have weak spots, including windows, that may enable a breach and subsequent fire spread, other openings and vulnerable construction features.

A structure equipped with sprinklers is well protected; the occupants in sprinklered buildings are afforded the ultimate in fire protection, as there is no equivalent to fire sprinkler protection short of an engine company standingby at the home 24/7 providing fire suppression protection. The benefits of sprinklers are often associated primarily with the structure and its occupants. However, sprinklers provide benefits to the firefighters as sprinklers help contain active fire upon their initiation, often controlling fire to the room of origin or extinguishing it and providing safer conditions to firefighters.

Modern construction techniques are dominated by lightweight construction for efficiency in cost and labor.

Additionally, many materials found in both construction materials, and furnishings and home contents are artificial (manufactured, non-natural). Lightweight construction is highly susceptible to early structural collapse and accelerated fire spread. Artificial materials burn faster, producing more toxic byproducts of combustion. All of these are anathemas to both firefighters and home occupants as well as the environment.

If the ADU has sprinklers, then a fire is going to be suppressed or at least controlled and confined. If the primary structure is not ignition resistant, it will be more susceptible to ignition. If the primary structure is not sprinklered, it will also be more susceptible to ignition from a nearby structure fire.

4. Is a 20-foot right-of-way needed to get a fire truck into the street? How does that correlate with 20 feet between buildings for fire apparatus?
The California Fire Code (CFC), which is adopted by the County of Los Angeles (with amendments) and subsequently by the City of Bradbury, identifies what constitutes an approved fire apparatus access road (access road) along with required design standards and when and where they must be constructed.

Access roads must extend to within 150 feet of all portions and exterior walls of all buildings along a route to be approved by the fire department and based on hose pull distances. This distance may be extended upon approval by the fire department based on specified conditions, including installation of an approved automatic fire sprinkler system. 130
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City Provided Areas of Focused Assessment
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1-5 December 2020
The access roads must have an unobstructed width of 20 feet, and must be widened to 26 feet, for a distance of 20 feet from either side of a fire hydrant. For single-family residential lots, access roads may be reduced to 15 feet wide upon approval by the fire department.

There is no fire code reference of minimum distance between buildings for fire apparatus access. However, all exterior doors and emergency egress windows must be accessible by an approved walkway leading from the access road, when required by the Fire Department.

From a practical standpoint, a typical fire engine is approximately nine (9) feet, mirror to mirror. In order to allow a passenger vehicle, which may be 6.5 to 7 feet wide or another fire engine to drive past an engine, 20 feet is desirable. Because fire engines do not need to be able to park directly next to a building, there is no requirement for 20 feet between buildings.

5. Verify if a 1,200 sq. ft. (1,000 sq. ft. in Bradbury) addition is added to an existing home (i.e., not an ADU), would one have to add sprinklers to the existing home?
In most cases, the answer is no. According to the LA County adopted building and fire codes, there are triggers which would cause a home undergoing an addition to be fire sprinklered, but these triggers seem to be set very high, and significant exceptions exist.

For an existing home to be sprinklered due to an addition, it would have to be located in a specific FHSZ in the Malibu-Santa Monica Mountains or San Gabriel Southface areas, the latter of which would include Bradbury. CFC 903.2.11 is amended by LA County to include homes that undergo reconstruction, remodeling, or additions resulting in 50% or more area than prior to the work, within any 12-month period, to be fire sprinklered. There are several exceptions, however, including:
• where the home is located within 3 miles of an existing or planned Los Angeles County fire station, as measured on a direct route on streets accessible to FD apparatus (and the code provides parameters for what planned fire station means);
• when the resulting square footage is less than 5,000 SF.

Therefore, it would seem almost impractical to expect a home undergoing an addition to require fire sprinklers.

Since nearly the entire city is within 3 driving miles of the one LACoFD fire station closest to Bradbury (FS 44 in Duarte), it would practically never be required to add sprinklers for a home remodel/addition. Even if the home was beyond the three-mile driving range, it would have to be at least 3,300 SF prior to the addition and undergo at least 50% of additional area to result in a structure of greater than 5,000 SF in order to trigger fire sprinklers.

An ADU is limited in size to 1,000 square feet in Bradbury. Los Angeles County FD does not count the garage as area against the existing 1,200 sf limit. As long as the living area (the ADU) attached to a garage is 1,200 sf or less then no sprinklers are required, and presumably, the same would apply in Bradbury but with a 1,000 sf limit, unless:
• The residence is already sprinklered
• If there is a code issue of access or water supply then sprinklering may be accepted as mitigation If the ADU exceeds 1,200 sf in LA County (1,000 sf in Bradbury) attached to a garage, then LA County would require sprinklers since it would then exceed the definition of an ADU, and meeting the definition of a new residential unit. 131
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1-6 December 2020
An ADU addition under 1,200 square feet to an existing residence in LA County and 1,000 sf in Bradbury, would not require sprinklers for the same reasons as discussed above. If there is a code issue with access or water supply, sprinklers may be needed as a mitigation. If that same ADU addition exceeds 1,200 sf, (1,000 sf in Bradbury) LA County would not typically require sprinklers since additions to unsprinklered residences rarely trigger sprinklers.

Also, it should be noted that LA County FD enforces access and water supply requirements very strictly. If any part of an ADU, or altered home, exceeds the FD access thresholds of the Fire Code, a fire sprinkler system may be accepted as an alternative to mitigate the access deficiency.

Helpful References:
https://dpw.lacounty.gov/bsd/lib/fp/Building/Residential/Accessory%20Dwelling%20Units/ADU% 20Guideline.pdf
https://dpw.lacounty.gov/bsd/lib/fp/Building/Residential%20Code%20Manuals/2017/RCM%20R313.2% 20A1%20-%20Automatic%20Fire%20Sprinkler%20System%20Requirements.pdf

6. Would the State mandated allowances of manufactured homes in the City, without significant City review, pose any threats in a high fire hazard area? What fire safety issues are being introduced with manufactured homes that are built somewhere else and moved into Bradbury? (Manufacturer, codes, etc.) Based on the requirements for manufactured homes, the answer to the question is essentially, no. Manufactured homes are inspected at the factory to verify code compliance and must have a label attached that certifies the structure has passed inspection. A code compliant manufactured home would not pose any more of a threat in the high fire hazard area than any other structure.

Since manufactured homes are inspected at the factory, a jurisdiction loses “local control”. The quality of the inspection is subject to the manufacturer of the home and any oversight agencies and may vary in the same way a local agencies’ inspections may vary in quality control.

In Bradbury, being [mostly] in a HFHSZ, structures built or brought/moved into the city would be required to comply with the requirements of CBC Chapter 7A (or CRC 337) regarding wildfire exposure protection. Manufactured homes would have to meet these same requirements. If a home was not manufactured to meet the requirements of CBC Chapter 7A (or CRC 337), it would pose a significant threat since it would not the meet the state minimum standards for a structure in a wildfire prone area. These provisions incur more costs and would have to be ordered properly by the buyer. The potential for non-WUI compliant structures being brought into Bradbury within a HFHSZ exists and would represent an unacceptable condition. The City should provide explicit direction to buyers seeking permits regarding the Chapter 7A requirements and an inspection of manufactured homes within HFHSZs to confirm their compliance.

NOTE: The regulations and laws governing manufactured homes are complex. Compliance with CBC Chapter 7A appears to be required, but there appear to be loopholes for units built before 2008. 132
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1-7 December 2020

7. Are there any contradictions between the State’s desire to fortify high fire hazard areas through land use and their housing density regulations?
Our analysis indicates that there appear to be some contradictions, although focused in the high fire hazard areas.

Most of the recent State-mandated housing density regulations are related to multi-family dwellings, affordable housing and inclusionary housing. However, along with the ADU related regulations, small lot subdivision related regulations will affect single family dwelling lots and zones. Aside from lots that can accommodate ADUs, nearly all other housing density regulations will impact the denser urban core of cities, particularly where mass transit hubs and stops are located.

In comparison, the State’s effort to improve fire safety in the high fire hazard areas focuses on the rural and wildlandurban interface areas. The regulations typically address defensible space, construction materials, design standards and access for both new developments and fire prevention activities for existing structures.

In some instances, there is an overlap where cities have a high housing density within a high fire hazard area. There does not appear to be any obvious contradictions between the intent of the high fire hazard area regulations and the housing density regulations. However, in the “overlap” areas it may be challenging to comply with both sets of regulations simultaneously for areas with existing development. Furthermore, when new construction or additions/modifications of existing construction are introduced in these areas, it is possible that alternative means and methods (AM&Ms), on a project by project basis, may be necessary for the project to satisfy the intent of the regulations. This is not a desirable condition. Even though the Fire Code allows modifications to the code based on specific findings, relying on AM&Ms to accommodate ADUs is not a sound policy as AM&Ms should be the exception, not the standard operating procedure.

8. Address any climate change issues related to ADUs – more fires, larger fires, greater risk? According to Governor Gavin Newsom’s Wildfire Strike Force (2019)1, climate change is resulting in an increasingly dangerous wildfire threat to much of California:

Climate change has created a new wildfire reality for California. The state’s fire season is now almost yea- round. More than 25 million acres of California wildlands are classified under very high or extreme fire threat. Approximately 25 percent of the state’s population – 11 million people – lives in that high-risk area.

At the same time that our climate is changing and fueling the devastating force of wildfires, increased development in the wildland-urban interface (WUI) has placed more residents in the potential path of destruction. Today, approximately 25 percent of the state’s population (over 11 million people) lives in high fire-risk areas, including the WUI.

Wildfires are not only more frequent but far more devastating. Fifteen of the 20 most destructive wildfires in the state’s history have occurred since 2000; ten of the most destructive fires have occurred since 2015. The results are visible to all: lives lost, grave fire damage to homes and communities…
1 California Wildfire Strike Force. 2019. Wildfire’s and Climate Change: California’s Energy Future. 53 pp. 133
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City Provided Areas of Focused Assessment
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1-8 December 2020
Among steps that the Wildfire Task Force states should be taken to reduce the wildfire threat incidence and severity are:

Make communities more resilient by considering updating codes that govern defensible space, encouraging cost-effective hardening of homes, strengthening evacuation, encouraging other emergency planning, and improving land use practices to reduce the damage to life and property from wildfires.

Reducing fire risk to these areas will require changes in how higher-risk areas are designed, planned, built, served by utilities, and allowed to grow, and will require people across the state to participate in the solution.

Deprioritize new development in areas of the most extreme fire risk. In turn, more urban and lowerrisk regions in the state must prioritize increasing infill development and overall housing production.

Developing new housing in Very High Fire Hazard Severity Zones presents challenges. Since 2015, CAL FIRE has assisted local governments in land use planning. CAL FIRE is working to identify subdivisions at significant fire risk without secondary evacuation routes and to make recommendations to improve access.

Homeowners are encouraged to actively maintain defensible space, which is defined as a minimum 100-foot area around a home. Maintenance is an ongoing task.

It is critical that roads and other infrastructure be more fire defensible and evacuation ready for the populations in the WUI.

Prioritize Building In Less Fire-Prone Areas: The strike force recommends that at the regional level, governments and planners incorporate CAL FIRE’s fire risk projections and the fire projection information in the Adaptation Clearinghouse and Fourth Climate Assessment into short-and longterm planning, and consider how to encourage more urban and lower-risk regions in the state to provide an alternative for those otherwise shut out of the state’s housing market.

Local General Planning: The strike force recommends that the safety element of local general plans be strengthened in high-risk areas, specifically for local governments to include fire risk projections into general and specific plans, including through zoning and design standards.

Cost-Effective Home Retrofits: While California has stringent building standards and requirements for defensible space, the intensity of the wildfire threat in California now warrants higher levels of fortitude.

CAL FIRE should consider options to encourage cost-effective home hardening to create fire resistant structures within the WUI and with a focus on vulnerable communities.

CAL FIRE and the Department of Housing and Community Development should develop a list of low-cost retrofits that provide comprehensive fire risk reduction to protect structures from fires spreading from adjacent structures or vegetation and to prevent vegetation from spreading fires to adjacent structures.
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Defensible Space and Forest and Rangeland Protection: Compliance and enforcement is key to ensure that defensible space standards are met. CAL FIRE should review and make recommendations to increase defensible space
Similarly, the California Department of Forestry and Fire Prevention (CAL FIRE) (2019)2 states:

Climate change, an epidemic of dead and dying trees, and the proliferation of new homes in the wildland urban interface (WUI) magnify the threat and place substantially more people and property at risk than in preceding decades.

Based on California’s findings regarding climate change’s effects on wildfire hazards and risks and there proposed approaches to addressing it, it does not appear to be a prudent decision to allow ADUs in fire hazard severity zones without specific fire protection measures, many of which they are already recommending in their own conclusions and which are discussed in the Conclusions and Recommendations sections that follow. 2 Community Wildfire Prevention & Mitigation Report. 2019. In response to Executive Order N-05-19. 28 pp. 135
Attachment 2
Bradbury Fire Hazard Map
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Bradbury General Plan Fire Hazard Map
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2-1 December 2020
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Attachment 3
Bradbury and Los Angeles County Code References
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Attachment 3
Bradbury and Los Angeles County Code References
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3-1 December 2020
Bradbury Municipal Code References
BMC Sec. 9.85.020. - Definitions.

For purposes of this chapter, the following definitions shall apply.

Primary unit shall mean an existing single-family dwelling, or the larger of two proposed units.

BMC Sec. 9.85.050. - Development standards/requirements— Accessory dwelling units.
(e) Size.
(1) Attached accessory dwelling unit.
a. Maximum size. The square footage of the accessory dwelling unit shall not exceed 50% of the existing or proposed family dwelling or 1,200 square feet, whichever is less.

Notwithstanding the foregoing, an applicant shall be entitled to build an 800 square foot accessory dwelling unit provided that it is no more than 16 feet in height with at least fourfoot side and rear yard setbacks. b. Minimum size. The square footage of the accessory dwelling unit shall not be less than 250 square feet.
(2) Detached accessory dwelling.
a. Maximum size/lot area less than 10,000 square feet. The square footage of the accessory dwelling unit shall not exceed 50% of the existing or proposed dwelling unit.

Notwithstanding the foregoing, an applicant shall be entitled to build an 800 square foot accessory dwelling unit provided that it is no more than 16 feet in height with at least fourfoot side and rear yard setbacks. b. Maximum size/lot area greater than 12,000 square feet. The square footage of the accessory dwelling unit shall not exceed 50% of the existing or proposed family dwelling or 1,200 square feet, whichever is less. Notwithstanding the foregoing, an applicant shall be able to build an 800 square foot accessory dwelling unit provided that it is no more than 16 feet in height with at least four-foot side and rear yard setbacks. c. Minimum size. The square footage of the accessory dwelling unit shall not be less than 400 square feet.
(3) Interior accessory dwelling unit. The floor area of an interior accessory dwelling unit shall not exceed 50% of the primary structure or 800 square feet, whichever is less. 139
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Bradbury and Los Angeles County Code References
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3-2 December 2020
Sec. 9.85.050. - Development standards/requirements—Accessory dwelling units. (k) Fire sprinklers. Fire sprinklers shall be required in any accessory dwelling unit if they were required in the primary unit.

Los Angeles County Fire Code References
701A.1 - Scope.

This Chapter applies to building materials, systems, and/or assemblies used in the exterior design and construction of new buildings, and to additions, alterations, or repairs made to existing buildings, erected, constructed, or moved within a Wildland-Urban Interface Fire Area as defined in Section 702A.
(Ord. 2019-0056 § 4, 2019.)
701A.3 - Application.

ATTACHMENT I
Agenda Report – September 22, 2026
EMAILS FROM MR. AL GARCIA
& DAVID SZYMKOWSKI
REGARDING ORDINANCE NO. 401
141
142
City of Bradbury
600 Winston Avenue
Bradbury, CA 91008
Re: Support for Dra� Ordinance No. 401 (ADUs and SB 9)
Dear Commissioners and Council Members,
I am a Bradbury resident wri�ng in strong support of Dra� Ordinance No. 401, which amends the Development Code provisions for ADUs, junior ADUs, accessory living quarters, SB 9 units, and related urban lot splits. I especially support the ordinance's prohibi�on on these addi�onal units on substandard, narrow access roads that cannot provide adequate emergency fire and evacua�on access.

On our very narrow, steep roads, even a modest number of new units translates directly into more households and more vehicles trying to use the same constrained escape routes in a crisis.

Bradbury Hills Road is a perfect example of this emergency access problem, with 16 homes on our very narrow, steep, and winding dead-end road.

Experience from recent California wildfires has shown that when too many people and cars are funneled onto limited roadways, evacua�on stalls, vehicles are abandoned, and emergency responders are delayed or blocked. Increasing popula�on density through SB 9 projects and ADUs would worsen conges�on at exactly the moment when every second counts for residents and first responders. Restric�ng addi�onal units on these substandard roads is therefore a necessary lifesafety measure, not just a planning preference.

Allowing more units and vehicles on these steep narrow roads would also strain already limited water supplies and infrastructure in our hillside neighborhoods. Your ordinance is a reasonable, safety-based implementa�on of state ADU and SB 9 requirements and is fully consistent with Bradbury's long-standing goal of preserving rural tranquility while maintaining safe and reliable emergency access for exis�ng residents.

The last big wildfire in Bradbury, in November of 1980, devastated our community, and the next wildfire and associated emergency evacua�on is a mater of if, not when. Therefore, I respec�ully urge you to adopt Ordinance No. 401.

Respec�ully,
David Szymkowski
6 Bradbury Hills Road
Bradbury, CA 91008-1105
[email protected]
626 512 9731
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ATTACHMENT J
Agenda Report – September 22, 2026

MAPS OF EXISTING STREET WIDTHS
OF LESS THAN 20 FEET
i) Woodlyn Lane & Bradbury Hills Road – Includes a
Portion of El Cielo Lane
ii) Furlong Road & Oak Knoll Lane
iii) Barranca Road
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146
147
148

Bradbury City CouncilOctober 22, 2026

Bradbury City Council
October 22, 2026