STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
651 Bannon Street
Sacramento, CA 95811
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
December 30, 2025
Roubik R. Golanian, City Manager
City of Glendale
613 E. Broadway,
Glendale, CA 91206
Dear Roubik R. Golanian:
RE: City of Glendale – Denial of 236 North Central Ave Housing Project and Applicability of the Housing Accountability Act – Notice of Violation The California Department of Housing and Community Development (HCD) has reviewed the City Council’s denial of the Stage II Design Review Application for the 236 North Central Ave Housing Project (Project) on October 21, 2025. In denying the application, the City of Glendale (City) has violated the Housing Accountability Act (HAA),
1 as detailed in this letter.
Background
The Project consists of 682 units, including 610 market-rate units and 72 units affordable to very low- (VLI) and low-income (LI) households. The Project is located at 236 North Central Avenue, 212 West California Avenue, and 201 West California Avenue. Additionally, the Project includes a request for a conditional vacation of a portion of Alley 239 to allow for vehicular access.
The Project is entitled to a 46.25-percent density bonus because 14 percent of the base density (67 units) is affordable to VLI households.2 The Project includes the following concession requests: (1) to deviate from the proportionality requirements for inclusionary units with respect to unit mix, and (2) to allow a floor area ratio (FAR) of
4.07 where the maximum allowable by code is 3.00. Additionally, the Project includes the following four development standard waiver requests: (1) publicly accessible open space (PAOS) requirements, (2) contiguous publicly accessible open space requirements, (3) private outdoor space requirements, and (4) setback requirements for building walls over 60 feet in height.
On August 6, 2025, the related request to vacate a portion of an adjacent alley received approval from the Planning Commission, which determined that the partial alley 1 Gov. Code, § 65589.5.
2 Gov. Code, § 65915, subd. (f)(2).
CC_01272026_Exhibit 15 - Notice of Violation from the California Department of Housing and Community Development (HCD), December 30, 2025 Roubik R. Golanian, City Manager
vacation was consistent with the goals and objectives of Glendale’s General Plan. On September 11, 2025, the Design Review Board voted to recommend approval to the City Council of the Stage II Design Review application, subject to certain comments.
Subsequently, on October 14, 2025, the Density Bonus Housing Plan received approval from the Planning Hearing Officer, who determined that it was consistent with the General Plan, Municipal Code, and state law.
The final review authority for the Project is the City Council. HCD understands that on October 21, 2025, the City Council denied the Project despite City staff’s recommendation to approve the Project and the City Attorney informing the City Council that the Project qualifies for protection under Government Code section 65589.5, subdivision (d) of the Housing Accountability Act.
Housing Accountability Act Violation
The Housing Accountability Act (HAA), Government Code section 65589.5, significantly limits the ability of a local agency to deny or reduce the density of a housing development project that complies with applicable, objective standards. Based on the materials reviewed, including the October 21, 2025 staff report, the record demonstrates that the Project, as well as the associated alley vacation, is consistent with the General Plan and applicable zoning regulations, and complies with all objective standards of the Downtown Specific Plan except those proposed to be lawfully modified under the provisions of the State Density Bonus Law (SDBL). The Planning Hearing Officer likewise approved the Density Bonus Housing Plan, determining that the Project satisfied all affordability requirements of the SDBL.
Additionally, the protections afforded under the HAA are more robust for housing development projects that include units affordable to lower income households. This Project includes a total of 67 units affordable to very low-income households, which is at least 10 percent of the total units, and therefore qualifies for the heightened protections under Government Code section 65589.5, subdivision (d). 3 Under subdivision (d), a
local government may only deny a project under narrow circumstances and “based upon a preponderance of the evidence in the record….”4 For this project, in particular, the City would be required to make the finding under subdivision (d)(2) – that the Project “would have a specific, adverse impact upon the public health and safety, and there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact without rendering the development affordable to low- and moderate-income households ….” (None of the other statutory findings are applicable to the site or the City.) Subdivision (d)(2) goes on to define “specific, adverse impact.” HCD reviewed the video recording of the deliberations at the October 21, 2025 meeting.
Despite staff’s findings and recommendation to approve the Project, the City Council 3 See also Gov. Code, § 65589.5, subds. (h)(3)(A), (h)(3)(C)(i)(II). 4 Gov. Code, § 65589.5, subd. (d).
Roubik R. Golanian, City Manager
voted to deny the Stage II Design Review application. Accordingly, the City was required to adopt the written findings mandated by the HAA.5 While the City Council raised a variety of concerns during its review of the Project, none appear to HCD to constitute a specific, adverse impact upon public health or safety that would justify denial. Moreover, the motion adopted by the City Council on October 21, 2025 to deny the Project did not include any directive for the City to make the required findings, nor did it identify any meaningful evidence in the record to support such findings.
Conclusion
By improperly denying the Stage II Design Review application, the City is in violation of the HAA. The City was required to make the required findings under the HAA before denying the Project. In the absence of such findings, the City was required to approve the Project.
Under Government Code section 65585, HCD must notify a local government when that local government takes actions that violate the HAA and may notify the California Office of the Attorney General.6
The City has until January 29, 2026, to provide a written response to this letter. In its response, the City should include a specific plan and timeline for corrective action, including the reconsideration and approval of the Project as proposed. HCD will consider any written response before taking further action authorized by Government Code section 65585, subdivision (j), including, but not limited to, referral to the California Office of the Attorney General.
If you have any questions regarding the content of this letter or would like additional technical assistance, please contact Mackenzie Goldberg at [email protected].
S
incerely,
David Zisser
Assistant Deputy Director
Local Government Relations and Accountability
cc: Bradley Calvert, Director of Community Development
Michael J. Garcia, City Attorney
Gillian van Muyden, Chief Assistant City Attorney
5 Gov. Code, § 65589.5, subd. (d)(2).
6 Gov. Code, § 65585, subds. (i)(1), (j)(1).