ACTION:
____________________________
Clerk/Secretary
Department: City Manager Item No: D3
Prepared by: John Conley, City Manager Meeting Date: October 28, 2025 Approved by: John Conley, City Manager Agenda Location: Discussion S
UBJECT: MOVABLE TINY HOMES
RE
COMMENDATION: Discuss movable tiny homes and provide direction to staff.
P
RIOR ACTION: None.
STATEMENT ON THE SUBJECT: Deputy Mayor Melendez requested the City Manager place a discussion item on an upcoming agenda to discuss movable tiny homes, also known as tiny homes on wheels (THOW). Movable tiny homes describes a transportable dwelling unit that is constructed to comply with standards applicable to recreational vehicles.
Both the City of San Diego and the County of San Diego have adopted regulations permitting movable tiny homes. These jurisdictions allow movable tiny homes as accessory dwelling units (ADUs). For reference, the City of San Diego’s regulations are attached as Exhibit 1, and the County of San Diego’s regulations are attached as Exhibit 2.
F
ISCAL IMPACT: There is no direct fiscal impact associated with this discussion item.
E
XHIBITS:
1. City of San Diego DSD Informational Bulletin 403: Movable Tiny House
2. County of San Diego PDS Director’s Determination: Tiny Homes on Wheels AGENDA
REPORT
CITY COUNCIL
COMMUNITY DEVELOPMENT COMMISSION
SUCCESSOR AGENCY
BUENA SANITATION DISTRICT
JOINT POWERS FINANCING AUTHORITY
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Visit our web site at www.sandiego.gov/development-services.
Upon request, this information is available in alternative formats for persons with disabilities.
DS-5403 (10-20)
A Movable Tiny House is a manufactured and transportable accessory structure on a residential lot that provides living facilities for one or more persons, independent of the primary dwelling unit, which includes permanent provisions for living, sleeping, eating, cooking and sanitation.
A Movable Tiny House constructed to comply as relocatable manufactured housing pursuant to Title 25, California Code of Regulations and Title 24, Code of Federal Regulations shall comply with the Building Standards in those respective regulations and with regulations for Movable Tiny Houses found in SDMC Ch. 14, Article 01, Division 03.
I. GENERAL
A Movable Tiny House (MTH) is a transportable dwelling unit that is constructed to comply with standards applicable to recreational vehicles. They shall be licensed and registered with the California Department of Motor Vehicles. A MTH shall:
1. Not be larger than allowed by California state law for movement on public highways; and
2. Not exceed one (1) story in height, and
3. Not be able to move under its own power; and
4. Shall have a floor area that is between 150 and 430 square feet and shall provide independent living facilities for one or more persons, independent of the primary dwelling unit.
5. Shall not have a separate address from the primary dwelling unit.
6. Only one companion unit or movable tiny house, and one junior unit are permitted on a premise. Guest quarters and non-habitable structures shall be permitted in addition to the companion unit or movable tiny house, and junior unit.
7. A companion unit, junior unit, or movable tiny house shall not be used for a rental term of less than 30 consecutive days.
8. Accessory dwelling units, including dwelling units as defined as companion units, junior units, movable tiny houses, or guest quarters are exempt from DIF impact fees.
II. LOCATION
A MTH may be located on a lot where applicable Use Regulation Tables allow for the use of a MTH, and satisfy the following additional requirements:
1. Shall be located on a premise adjacent to a public right-of-way that is at least 20 feet wide; and
2. Shall be located behind or to the side of the primary dwelling unit and not in any front yard or front setback; and
3. Shall be located so that exterior portions of a movable tiny house shall not be located more than 150 feet from the public right-of-way; and
INFORMATION
BULLETIN
403
Development Services Department
City of San Diego
October 2020
Movable Tiny House
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EXHIBIT 1
Visit our web site at www.sandiego.gov/development-services.
Upon request, this information is available in alternative formats for persons with disabilities.
DS-5403 (10-20)
October 2020
4. A MTH shall be accessed from the public right-of-way by a path that is at least 5 feet wide.
5. Shall be located on a lot at a fire separation distance of at least 5 feet from an adjacent lot line and at least 10 feet from any other structures on the lot.
A MTH shall not be located or encroach in:
1. A brush management zone pursuant to Section 142.0412; or
2. The Multi-Habitat Planning Area (MHPA) pursuant to Ch. 14, Article 3, Division 1; or
3. The Coastal Overlay Zone (Section 132.0402) until the California Coastal Commission unconditionally certifies the Movable Tiny House Ordinance (NS O-21223).
III. BUILDING STANDARDS
In addition to the applicable building standards in the California Residential Code, MTH shall be constructed and comply with the following:
1. MTH shall be manufactured to comply with the National Fire Protection Association (NFPA) 1192 Standard on Recreational Vehicles or the American National Standards Institute (ANSI) A119.5 Park Model Recreational Vehicle Standard. A MTH shall also be certified by a recognized national certification body as complying with one of these standards and a certified label shall be placed on the movable tiny house to demonstrate compliance; and
2. When located on a lot where the primary dwelling unit is protected with an automatic fire sprinkler system in accordance with Section R313 of the California Residential Code, a movable tiny house shall be protected with an automatic fire sprinkler system; and
3. Roofs shall be sloped to drain over the roof edge. At least 50 percent of the roof area shall have a roof slope of 2:12 or more. Roof coverings shall comply with the Residential Building Regulations in Chapter 14, Article 9, Division 9; and
4. When sited on a premise, the undercarriage, including wheels, axles, tongue, and hitch, shall be concealed from view. The wheels shall not be removed and shall sit with leveling or support jacks on a paving surface designed in accordance with Section 142.0560(h)(1).
5. A MTH is not required to comply with the regulations of the California Energy Code.
IV. VERY HIGH FIRE HAZARD SEVERITY ZONE
When located within the Very High Fire Hazard Severity Zone, as mapped and established pursuant to Chapter 5, Article 5, Division 94 , a MTH shall comply with the following additional requirements:
1. The MTH shall be protected with an automatic fire sprinkler system installed in compliance with Section R313 of the California Residential Code even if located on a lot where the primary dwelling unit is not protected with an automatic fire sprinkler system; and
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Visit our web site at www.sandiego.gov/development-services.
Upon request, this information is available in alternative formats for persons with disabilities.
DS-5403 (10-20)
October 2020
2. Exterior walls shall be constructed with ignition -resistant materials in compliance with Section R337 of the California Residential Code; and
3. Glazed openings, including skylights, shall comply with Section R337 of the California Residential Code.
Where MTH are subject to the requirements for brush management, additional measures (alternative compliance) may be required. The mitigation is dependent on site conditions and the amount of defensible space (brush management Zone One and Zone Two) provided.
Alternative compliance measures will be coordinated between Landscape, Fire, and Structural reviewers. Please refer to the Brush Management Regulations §142.0412 for more information.
V. UTILITIES
A MTH shall provide for independent living, sleeping, eating, cooking and sanitation independent from the primary dwelling and shall be connected to water, sewer, and electric utilities. Connections to natural gas are prohibited.
Water and sewer utility connections shall comply with the California Plumbing Code and shall provide means for disconnection. If interconnection is proposed to an existing water meter and sewer system, the capacity of the existing utilities shall be shown to be adequate to accommodate the additional number of fixture units in the MTH.
Electrical power extended from the main electrical panel shall be installed to comply with the California Electrical Code and the MTH shall include an electrical service panel with properly sized electrical disconnection means.
VI. DESIGN ELEMENTS
A movable tiny house shall be constructed to include the following design elements:
1. Cladding and Trim: Materials used on the exterior shall not be single piece composite, laminates, or interlocked metal sheathing; and
2. Windows and Doors: Windows shall be at least double pane glass, labeled for building use, and include exterior trim. Windows and doors shall not have radius comers; and
3. All mechanical equipment, including heating, ventilation, and air conditioning, shall be incorporated into the structure and not located on the roof; and
4. Living Area Extensions: The roof and all exterior walls shall not be fixed with slide -outs, tip-outs, or other forms of mechanically articulating room area extensions.
VII. PARKING
MTH is exempt from parking regulations.
VIII. PERMIT APPLICATION PROCESS
You must apply online for a building permit. Please refer to the Project Submittal Manual, Section 2A, for all general requirements related to the submittal process. Minimum submittal requirements for each MTH proposal includes the following (per Project Submittal Manual, Section 2A):
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Visit our web site at www.sandiego.gov/development-services.
Upon request, this information is available in alternative formats for persons with disabilities.
DS-5403 (10-20)
October 2020
Plans:
1. Site Plan and Vicinity Map (See Information Bulletin 122).
2. Floor Plans and Roof Plans.
3. Elevations and Sections (as applicable).
4. Location of water, sewer and electrical connection to existing utilities including the location of the existing electrical service.
Forms:
1. General Application, DS-3032.
2. Owner - Builder Verification DS-3042.
3. Water Meter Data card, showing existing and proposed fixtures DS-16.
4. Storm Water Applicability Checklist, DS-560.
IX. FEES
Specific to MTH as Companion Units
1. Plan Check and Inspection fees are assessed with the type “Single Dwelling Unit/Duplex Addition/Remodel” found in Table 501A of Information Bulletin 501.
2. Development Impact Fees (DIF) and Regional Transportation Congestion Improvement Program (RTCIP) fees do not apply. General Plan Maintenance Fee is waived, unless subject permit includes work unrelated to companion/junior unit.
X. TRANSPORTATION PERMITS
A Transportation Permit is required from the City of San Diego to transport the MTH through City streets as well as from the California Department of Transportation if the MTH is to be transported on the highway system. A traffic control permit may also be required if the installation will require street or alley closure.
Documents referenced in this
Information Bulletin
• Chapter 5, Article 5, Division 94,
• Project Submittal Manual, Section 2A
• How to Prepare a Site Plan and Vicinity Map, Information Bulletin 122 • General Application, DS-3032
• Owner-Builder Verification, DS-3042
• Water Meter Card, DS-16
• Storm Water Applicability Checklist, DS-560
• Fee Schedule for Construction Permits-Structures, Information Bulletin 501 • Transportation Permit, DS-3094
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County of San Diego
Planning & Development Services
Director’s Determination
1 D
ate: September 4, 2025
To: PDS Planning/Counter Staff
From: Vince Nicoletti, Director
RE
: TINY HOMES ON WHEELS (THOW)
An acknowledgement that Tiny Homes on Wheels meet the definition of a Dwelling per the Zoning Ordinance with guidance for required standards.
I
ssue
Clarify the allowance of Tiny Homes on Wheels (THOW) as a dwelling per the Zoning Ordinance. This would not change the allowable density or number of units that can be placed on a property.
B
ackground
The County of San Diego supports new and innovative opportunities to create housing and actively seeks to address a shortage of housing in the region. Some of these opportunities include reviewing alternative construction methods, offsite construction, and self-certification options. An additional option includes the allowance of Tiny Homes on Wheels as housing. The County was asked to review the ordinances of other jurisdictions that allow THOW to determine if a similar ordinance could be supported in County jurisdiction.
A
ll of the jurisdictions that were reviewed that allow THOW have made modifications to their local zoning ordinances to include construction standard ANSI A 119.5. This standard, established by the American National Standards Institute (ANSI), defines nationally recognized building standards for recreational park models. Additional life and safety features were incorporated into the Park Model Construction Standard to ensure that THOW can be safely used as housing in the region.
T
his policy would not change the allowable density or number of homes allowed on a single lot. These requirements would still be governed under the Z oning Ordinance and General Plan regulations shall apply. The placement of a THOW must be within a private lot and may not encroach into County road right-of-way.
R
elevant Sections of the Zoning Ordinance
Section 1008, Interpretation and Application of the Zoning Ordinance, authorizes the Director to interpret the content or application of the Zoning Ordinance. It is the duty of the Director to ascertain all pertinent facts and render a decision on the interpretation. It is the intent of this Director’s Determination to provide guidance as to the acceptance of Tiny Home on Wheels as dwellings per the Zoning Ordinance. 10/28/2025
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EXHIBIT 2
2 Pursuant to Secti on 1100 of the Zoning Ordinance a D welling is a building or portion thereof used exclusively for residential purposes, including one- family, two-family, and multiple dwellings, but not including hotels, boarding and lodging houses. A Dwelling Unit is a single unit providing complete, independent living facilities for one or more persons, including permanent provisions for living, sleeping, eating, cooking and sanitation, and having only one kitchen.
B
uildings are defined as a ny structure used or intended for supporting or sheltering any use or occupancy. Structures which are built or constructed, an edifice or building of any kind, or any piece of work artificially built up or composed of parts joined together in some definite manner. Pursuant to Section 1110 of the Zoning Ordinance the Building Type, Residential: That group of building types comprising the following:
S
ingle Detached: One dwelling unit, freestanding and structurally separated from any other dwelling unit or building, located on a lot or building site which is unoccupied by any other dwelling unit.
Dir
ector’s Determination
In review of the definition of a “dwelling” in the County of San Diego Zoning Ordinance, it was determined that THOW, modified in accordance to ANSI standard A119.5, could be considered a dwelling without any revisions to the Zoning Ordinance. With this policy and the requirements provided herein, THOW will be allowed under the definition of a dwelling and could be used as a primary or an accessory dwelling.
B
ased on this information, it is the Director’s determination that THOW will be allowed as dwellings in the County of San Diego under the current Zoning Ordinance. PDS will include amendments to the Zoning Ordinance for future Board consideration as part of a future Zoning Ordinance update to codify this determination. THOW will need to meet all the following requirements listed in Section 1 below to be considered a dwelling. These construction features prioritize life, safety, and ensure that energy efficiencies align with the California Building Code, local zoning ordinances, and State laws that apply to ADU’s and Dwellings:
S
ection 1:
Any THOW intended for habitation within the unincorporated County of San Diego must meet the following requirements:
1. The THOW must be designed and constructed to ANSI A119.5 standard for Park Models. The proposed THOW must contain a certification sticker prior to permit issuance showing that the unit is certified to this standard by an accredited third party inspection agency.
2. Additional Fire requirements for use in the County of San Diego:
a. Exterior wall surfaces must be non-combustible (Stucco, Masonry, Cement- Fiber board, Metal, etc.), ignition resistant, heavy timber, or log wall construction. Stucco or Cement Plaster to be a minimum of 7/8” thick.
Noncombustible or fire-retardant wood shall be installed per Wildlife and Urban Interface (WUI) guidelines in PDS 664.
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3 b. All windows shall be dual-glazed units with a minimum of one tempered pane OR shall have a resistance rating of 20 minutes.
c. If the THOW has Eaves: Eaves, soffits, and fascia must comply with the requirements for ignition-resistant construction.
d. Roofing provided for THOWs shall have a Class A fire rating as installed per the manufacturer.
e. All THOWs will be constructed with residential fire sprinkler systems.
EXEMPTION: If the unit is being used as an ADU all ADU exemptions would apply.
f. Direct exiting must be provided from any loft space (as defined by the California Building Code) that would allow for egress from the THOW without leaving the loft.
g. All units to have carbon monoxide and smoke detectors.
3. The THOW is not to exceed 430 square feet measured from inside face of walls and must have a minimum of R-13 insulation in all exterior walls.
4. The THOW is to remain licensed and registered with the California Department of Motor Vehicles.
5. The THOW cannot move under its own power
6. The THOW cannot have any slide or pop-out features that increase the habitable square footage.
7. The THOW shall be located a minimum of six (6) feet from any other structures measured from the face of the structures.
8. The THOW shall be parked on a paved pad that includes bumper guards, curbs, or other installations adequate to prevent movement of the THOW. The wheels and leveling or support jacks must sit on a paving surface that meets either of the following criteria:
a. A parking area for a moveable THOW shall be paved with hard, durable asphaltic paving that is at least two inches thick after compaction, or b. With cement paving at least three inches thick
9. The THOW shall be connected to electric, water, and sewer utilities with the issuance of required building permits
10. Extensions. All exterior walls and roof of the THOW shall be fixed with no slide- outs, tip-outs, nor other forms of mechanically articulating room area extensions
11. Mechanical equipment shall be incorporated into the structure, not on the roof.
12. The THOW shall be no greater than one story and shall not exceed a maximum height of 16 feet.
13. The THOW can have a loft for sleeping of up to 150 sq. ft., which is not considered a 2nd story.
14. If the THOW functions as a single-family dwelling, it must comply with the required main building setbacks, building type, density, and any other applicable zoning regulations.
15. No additional parking spaces are required for the THOW that is being used as an ADU, and if used as an ADU any displaced parking caused by the placement of the THOW does not need to be replaced.
16. If THOW is an accessory to a primary residence, it cannot block or remove any required parking spaces for the primary residence.
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4 17. This policy does not change the zoning or allowed density for the property where the THOW is installed. Number of dwellings allowed will be determined on the Zoning building type and allowed density.
A THOW meeting the above standards is eligible for a permit that would allow permanent habitation. A THOW that meets these requirements can be used on any lot that would allow for a single-family dwelling upon issuance of a building permit. When a THOW is removed from a site the owner would need to file for a demolition permit so that the dwelling would be removed from the records.
Vince Nicoletti, Director
Planning & Development Services
10/28/2025
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