SB 450: Are Single-Family Homes Racist?!

Senate Bill 450 limits the autonomy of local governments across California to pass housing restrictions protecting single family zoning. Should the state restrict the power of local governments in matters of residential housing? And, is single family zoning important to preserve, or does it promote discrimination and racial segregation?

Summary of SB 9

To fully understand this bill, we first must understand a previous bill that set the scene for SB 450. Senate Bill 9, also known as the Housing Opportunity and More Efficiency, or HOME, Act was passed through the legislature and approved by Governor Newsom in 2021. The goal of the bill was to address the current housing crisis and provide a new avenue for development across the state.[1] It allowed homeowners who lived in single-family zones to split their lot and build additional homes, up to four dwelling spaces total.[2]

Zoning refers to the regulation that the city puts in place over how certain areas or plots of land can be used, and what type of construction can occur in those designated “zones.”[3] Zones are important because they protect the interests of the people in the area and the purposes for which they are there. For example, residential zoning means that there can only be homes or small businesses developed there. That’s why big box retailers aren’t planted in the middle of neighborhoods. Large store chains can only be built in commercial zones. It’s also why we don’t see factories next to local parks, causing residents of the neighborhood to endure the air pollution they create. Factories are only allowed in industrial zones, which are usually far from residential zones.[4] In this way, city planners can protect residents as well as efficiently plan out the use of the land within the city, including which parts of the city have the optimal terrain for each type of zone.

Single-family zoning is a type of residential zoning wherein each parcel of land can only have one house built on it. Single-family homes stand alone, unlike townhouses or apartments, and usually have defining characteristics like a driveway, garage, yard, and so on.[5] The benefit of single-family zoning is that it helps to keep population density at a manageable level so that not every neighborhood is packed with apartments, duplexes, and fourplexes. It also helps to manage resources, like water and electricity, especially in a state like California where we have constant droughts and an overloaded electrical grid.[6]

But single-family zoning only exists if there are certain places that the city can specify are only allowed to have one property per parcel of land. SB 9 removed that by opening the door for homeowners to build up to four properties on one parcel of land. This effectively killed single-family zoning across the state, meaning that if even city planners designate residential areas as single-family zones, that can mean duplexes, triplexes, and even fourplexes can be built in these neighborhoods – which no longer fits the definition of a single-family home.

Let’s walk through an example of how someone would use SB 9 to split their lot, because just the theory of lot splitting can be difficult to grasp. Sam Andreano lives in Whittier California, which is in Los Angeles County. In an interview by the Los Angeles Times, Andreano explained how he adopted SB 9 between buying his house in 2021 and completing his lot split in 2023. He originally bought a single-family home for $790,000. The house was 1,200 square feet and the lot was a little over 6,000 square feet, giving him ample land. He worked with an architect, engineers, inspectors, and a land surveyor, and eventually turned what used to be one house on 6,000 square feet of land into two houses, split almost evenly on the lot. The result was a 1,200 square foot house on roughly 3,300 square feet of land, and a smaller 1,100 square foot house on the remaining 2,800 square feet of land. He sold the larger house for $778,000 and lives in the smaller one, practically recouping his cost for the original property and gaining the worth of the smaller house as straight revenue whenever he decides to sell it.[7] Thus, Andreano took one house and created two.

There are some regulations carved into SB 9 that Andreano and other homeowners who hope to follow in his footsteps must follow to lot split. Each new lot must be at least 40% of the size of the original lot, meaning it must be split evenly. Additionally, the owner of the split lot is required to occupy one of the new properties for at least three years. The land itself can only be split into two parcels, so that would either yield two single-family homes – like in Andreano’s story, or two duplexes, limiting the total number of livable spaces allowed to four.[8] Finally, projects under SB 9 still must be permitted and approved by local government jurisdiction.

What were the reasons for this bill? As mentioned earlier, this was designed to help ease the housing crisis by allowing homeowners to develop their own lots, thus increasing housing supply, decreasing demand, and driving down housing costs to make living here more affordable. At the time the bill was passed, a study conducted on the impacts of the bill estimated that SB 9 could result in 700,000 new homes being built across California.[9] We can see how this could, in theory, help to address the problems we have discussed related to the housing market. If, after all, it is high demand and low supply that has caused home prices to rise, then it makes sense that by enacting measures that allow for more development and more houses, a decrease in demand and therefore a decrease in prices would soon follow.

Is that what has happened, though? SB 9 took effect on January 1, 2022; yet Californians across the state still report housing costs as a major issue. What have the effects of SB 9 been so far? The reality is that not many homeowners have taken advantage of the program. In the year that followed SB 9’s passage, the City of Los Angeles was the city in California that had the most activity related to what SB 9 now allows, but they saw just 211 applications for new homes, only 38 of which were actually approved.[10] Yikes, 38 new homes are a far cry from the 700,000 estimated new homes that the bill should be creating. Take that in context that Los Angeles permitted 20,000 new homes the year before, and this is practically nonexistent activity.

Summary of SB 450

This is where SB 450 comes in. When SB 9 went into effect, many local governments opposed the bill. In fact, polls showed that 71% of Californians across the state were not in favor of SB 9.[11] As a result of this overwhelming opposition, local governments passed strict standards that would make it harder for homeowners to take advantage of lot splitting. Some of these standards include design requirements, minimum lot sizes for single-family homes, height restrictions, increased parking requirements per home, lengthy review times, and environmental impact fees.[12] These specifications by each local government are unique to the needs of their communities but tend to make it difficult for homeowners who may be interested in splitting their lot to actually do so. Even in the case where homeowners are not deterred from trying, they have made it so that cities can prolong the process.

Senator Toni Atkins, who has been a California Senator since 2016 and has entered the race for Governor in 2026, introduced SB 450 to address these restrictions. SB 450:

1.      Limits local government’s ability to impose restrictions on things like zoning and design standards, unless they apply equally to non-SB 9 properties as well,

2.      Sets a 60-day timeframe for local governments to approve applications for SB 9 projects. If local governments don’t act on these applications within the 60 days, they will automatically be approved,

3.      Restricts denial of these projects to cases of specific public safety concerns, not aesthetic or even environmental impacts,[13]

4.      Increases the California Department of Housing and Community Development’s oversight and enforcement power over local governments to ensure they comply with the requirements of the bill.[14]

This essentially knocks all the teeth out of local government autonomy to prevent, restrict, or slow the development of SB 9 housing, and local leaders are - understandably - not too happy about it.

Cities like Simi Valley, Yorba Linda, Santa Clarita, Laguna Niguel, San Mateo, and Palos Verdes Estates have all come out in opposition to the bill.[15] Several of them wrote to Senator Atkins directly expressing their concerns. For example, Santa Clarita Mayor Jason Gibbs wrote the following in his opposition:

“Local zoning and project application review is reserved in the city to ensure sound standards to preserve public health, safety, and welfare. This includes confirming public utility services including power, water, and sewage, meet anticipated population, dwelling unit densities, and service requirements. Additionally, local zoning and project application review is established in the City to mitigate traffic congestion and ensure that adequate and innovative infrastructure is developed to preserve public welfare and safety.”[16]

He is speaking to the very real considerations that must be made when pursuing new development projects – considerations like population and density increases and their impacts on power, water, sewage, and fire hazards. He goes on to address the necessity for local governments to have autonomy over these areas:

“The City has the tools, knowledge, and policies in place to continue to plan and develop innovative residential units that enhance the quality of life for our community. It is critical for the City to maintain local land use and zoning authority and ensure that the City continues to have the ability to consider unique factors when reviewing residential development proposals.”[17]

The City of Palos Verdes Estates echoed concerns about the new 60-day requirement in a letter sent by their Mayor, Dawn Murdock, also to Senator Atkins. Murdock writes:

“SB 450 would [require] cities to approve or deny projects within 60 days, thus forcing cities to set aside other housing development applications to prioritize SB 9 projects.”[18]

And lastly, Mayor of the City of Laguna Niguel Kelly Jennings, wrote directly to Governor Newsom to oppose the bill, saying:

“SB 450 would prohibit local governments from accounting for specific, adverse impacts on the physical environment of a proposed lot split, which may lead to unintended consequences for local communities. By removing the ability of local governments to account for this, these streamlined housing projects may have negative impacts on the environment, agriculture, noise levels, and wildlife.”[19]

The main concerns cited by these local government leaders are that SB 450 will take away their discretion to impose restrictions specific to the needs of their communities, it will require a significant amount of administrative work to review applications in the 60-day window – inevitably resulting in the automatic approval of projects that have not been properly vetted, and will adversely impact communities due to the withdrawing of local governments’ ability to plan and enforce zoning and housing regulations in the best interests of their cities.

Why Legislation Matters

Why does it matter? Why do we care about this housing legislation?

Both bills may seem small and fairly insignificant on their face. After all, by November of 2022, across all large cities in California there had been just 282 applications for SB 9 projects, and only 53 city approvals.[20] The reason why it is important to look at bills like these, which it would be easy and tempting to just glance over without another thought, is because the quality of life in a state, and the issues facing that state, are all compiled of many seemingly insignificant bills. There are countless things that you do over the course of your normal week that you don’t give a second thought, without realizing that the only reason life is the way that it is for you is because it is built on years of legislation and bills which make it that way.

Why do you wear a seatbelt when you get in your car? To you, it’s probably instinctual. It’s just a given that you would buckle your seatbelt when driving. But the reason why it is commonplace is because California passed legislation through the Assembly back in 1986 that first required drivers and passengers to wear seatbelts.[21] Why do you have a carbon monoxide detector in your house? That was because of Senate Bill 183, passed in 2010, requiring that all single-family homes install a carbon monoxide detector.[22] When you go to the store, and you see a handicapped spot and then you see spot next to it with stripes in the space so that you can’t park there, that is a direct result of Title 24 of the California Code of Regulations.[23] Why on trash day do you see houses have green trash bins and brown trash bins? That’s because Senate Bill 1383 requires California residents to separate yard waste from regular trash.[24] All of these are examples of things that I guarantee you see as normal without ever stopping to think, why is it like this? Why do we wear seat belts? Why is that monitor on the wall of my house? Why can’t I park in that spot? Why do I separate my trash? The answer to all these questions is because it is mandated by law – by bills that were passed at some point in our state and made all of these things normal parts of our everyday lives.

Legislation has the power to introduce new requirements into our lives, then 20 years later it seems like it has always been that way. This is why it’s important for states to use their powers of legislation well, and to refuse to overburden their residents with constant regulation or useless laws. When these laws all compound on top of each other, it ends up making life in one state very different than life in another state. It is also how we end up with all different issues across the country. It’s no secret that California has a housing crisis, we’ve talked about it several times already on the show. Yet, the reality is that there have been over 100 new housing laws passed in the state since Governor Newsom took office, all under the premise that they would help ease this housing crisis.[25] I think it’s safe to look around us and say, the housing crisis has not been eased. Rather, our state government has continued to regulate and re-regulate and re-regulate again, and the problems we face have spiraled further and further.

When I see a bill like SB 450 pass, I don’t see it as too small or niche or insignificant to care about. We need to shed light on more bills like this to expose all the ways that our government is passing laws that change what we can and can't do in our state, as well as what our local governments have the authority to do. By untangling the mess of legislation that we are in, then we might be able to pinpoint some of the direct root causes of the problems sprouting up around us.

Responses to SB 9 and SB 450

There are a few responses I have specifically related to SB 9 and SB 450 that I want to share with you.

Big versus Small Government

First, I believe these bills show us a familiar pattern of governance in California wherein the state takes a “big government” approach and removes power from local governments. Did you catch how the state did that in this case? They passed SB 9 – which removed single family zoning on a statewide level and mandated that all cities, counties, and local governments allow lot splitting in their districts – and then when local governments reacted by enacting restrictions that would keep SB 9 projects in line with the character and requirements of existing communities, the state walked back in and passed SB 450 – essentially saying all the restrictions that local governments have passed to make SB 9 properties specific to their neighborhoods are no longer allowed, and not only that, but if local governments even take too long in reviewing applications, projects will just be automatically approved. What are mayors supposed to do now? The City of Santa Clarita mayor expressed concerns about the strain on public utility services like power, water, and sewage. The City of Palos Verdes Estates mayor conveyed a lack of administrative staff to handle the new 60-day approval requirement. The City of Laguna Niguel mayor warned of unintended consequences such as negative impacts on the environment, agriculture, noise levels, and wildlife. But what can they do about these concerns? Now that the state has taken away any ability to enact and enforce regulations over SB 9 housing, there’s nothing they can do but go along with what the state has mandated and try to advocate for their communities as they do so.

This approach isn’t a surprise either, we saw it last week when we looked at SB 1174 to ban Voter ID laws. Huntington Beach residents voted to require Voter ID in elections, the state didn’t like that, and so they slapped a bill on the issue to say, nope, you can’t do that! It’s the same thing here. Local governments want to ensure the allowances made by SB 9 don’t negatively impact their communities and neighborhoods, the state doesn’t like that, and so they pass SB 450 to say nope, you can’t govern that either! It’s a big government approach that keeps all power with the higher form of government and takes power away from the people.

You might ask, so what approach should the California government be taking? If it wants to try to bring down the costs of housing, then how would it do that without sweeping statewide mandates like SB 9 and SB 450? Well, let’s look at some other states who have refused state-imposed mandates to see how they have handled housing issues. Florida is a great example of how to address affordable housing while still respecting local government autonomy. Governor DeSantis passed the Live Local Act in 2023 which did several things to encourage and create more affordable housing, like:

-        Created new property tax rebates,

-        Focused on rolling back regulation to boost housing development, specifically mixed income multifamily development, and

-        Worked with local governments not to mandate affordable housing across the state, but to incorporate at least 40% of new housing as affordable housing through various compromises on building and parking requirements.[26]

This didn’t mean that the Live Local Act didn’t pass any specific requirements, but it took into consideration the requirements that local governments were passing, like building and parking requirements, and met them in the middle to advance the goals of affordable housing while still giving local governments autonomy. The key to this approach is incentivizing the outcome that the state government wants. Instead of mandating certain activities and not addressing the problems that it causes across cities, state governments should incentivize the activities they want to happen and work with them to reduce concerns and negative impacts, resulting in encouraging local governments to adopt those approaches because they have been given motivation to do so.

Another great program that Florida has in place to this effect is the State Housing Initiatives Partnership, which fosters partnerships between private and public sectors. This program gives funds to local governments across the state for the purpose of working with private developers to create affordable housing. This way it is not entirely managed by the government, and it rewards developers for building affordable housing, again creating that incentive.[27]

These are just examples showing how another large state like Florida – which is the third most populated state in the country – approaches lowering housing costs and creating affordable housing for residents of the state. Governor DeSantis’ approach has been completely opposite to Governor Newsom’s approach, and it uses the principles of local control rather than statewide mandates, and encouraging private-sector development.

Protection of Single-Family Zoning

But I want to probe even further than the issue of the governmental approach that California takes, because by encouraging our state government to give local governments more control, we must consider the flip side wherein local governments don’t want to enact laws like SB 9. California could adopt the same approach that Florida does to incentivize and reward local governments for taking steps toward increasing affordable housing, but when you take that approach, then the inevitable result is that there will be counties that don’t agree with the state’s suggestions and don’t enact that type of legislation. We see this clearly with cities like Santa Clarita, Simi Valley, and all the other cities I listed are opposed to SB 9 and SB 450. These cities have expressed concern over allowing lot splitting under single family zoning. What are we to think about that? Is California’s allowance of lot splitting within single family zoning as outlined by SB 9 really a good thing that cities should be eager to adopt?

I would argue that it again depends on the city and the community. I want to note that I respect the State Senate for getting creative with affordable housing initiatives, and I appreciate the attempt to address the housing crisis that is affecting so many Californians across our state. I don’t want to belittle that attempt, because it is good for our representatives to consider how to help increase housing supply, decrease demand, and drive down housing prices on a large scale. But, by enacting it statewide, it has effectively eliminated the idea of single-family zoning, and as much as I want to like the efforts to build more houses, I cannot support getting rid of single-family zoning entirely across the entire state.

Single-family zoning is good for families, as married couples leave population-dense cities for suburban houses where they have more space with attractions like yards and pools, as well as parks and communities just down the street for their kids. Los Angeles City Councilman Kevin de León put it this way, “The life of suburbia attracted so many Americans from all over the country to come to sunny California, especially when the Rose Bowl was being played during the winter months. On the East Coast and the Midwest, folks would say, ‘Wow, orange trees, lemon trees, front yard, backyard, a swimming pool, a single-family home. Let’s pack it up, let’s leave Michigan, let’s leave Ohio, and let’s go out to the West Coast.’”[28] Truthfully, not every person wants to live in a crowded, big city. Not every person wants to live next door to large apartment buildings, or fourplexes, or even duplexes. Some people prefer the suburbs because they want more space and land to live on. They want a quieter, slower life. They want to move out of the areas that tend to have the highest crime rates and most expensive cost of living. But by the California government mandating that single family zoning must include non-single-family homes, it effectively takes this choice away from the homeowner. It also poses the threat of lowering the value of single-family homes, as houses that are located next to high density housing tend to be worth less than houses in lower density neighborhoods.[29]

Another factor is mental health. For instance, a new study published in the International Journal of Environmental Research and Public Health earlier this year found that “city dwellers who have more exposure to urban green spaces require fewer mental health services.”[30] Jay Maddock, who conducted the study and both has his PHD and is a Professor of environmental and occupational health, described the findings of the study as such, “We found that a NatureScore above 40 — considered Nature Adequate — seems to be the threshold for good mental health. People in these neighborhoods have a 51 percent lower likelihood of developing depression and a 63 percent lower likelihood for developing bipolar disorders.”[31] The lead author of the study, Omar Makram, described the effects this study should have on city planning, “Increasing green space in cities could promote well-being and mental health, which is critically important given that more than 22 percent of the adult population in the United States has a mental health disorder.”[32]

Single-family zoning allots more space per property than multifamily zoning, usually resulting in front, side, and backyards for homes, building green space right into owning a home and living in a community of single-family homes. Suburban areas with low-density neighborhoods also enables the development of parks and community spaces, which is found to be good for society and mental health. So, do I agree with the eradication of single-family zoning on a state level? No, I don’t. I think it takes choices away from residents of cities and should again be a decision made at the local government level.

Is Single-Family Zoning Racist?

Now, what about the criticism that you may have heard which says the preference for single-family homes, and the protection of single-family zoning, is racist? If you have never heard that before, then I’m telling you, it’s a thing, and it’s becoming very common. Just try googling “benefits of single-family zoning,” and you won’t get any articles on the positive aspects we just discussed. Instead, you get a ton of articles on why supporting single-family homes is racist.  

Let me read you a few excerpts from the articles that pop up:

“[An] Othering & Belonging Institute study found that as you increase the percentage of single-family zoning in a city, you increase the percentage of white residents. It’s a legacy of racist housing policies, like redlining, that barred Black families from receiving federally-backed loans following the Great Depression. Policies like these were later outlawed, but they still persist in practice, with lenders often charging higher interest rates or refusing home loans to Black buyers. Taken together, it’s helped drive a huge wealth gap between white and Black families. That makes it harder for Black families to purchase homes in single-family neighborhoods.”[33]

Or, take this one:

“Zoning regulations today still do what racially restrictive real estate covenants did yesterday: prevent neighborhoods from being diverse and equitable. Zoning requiring single-family housing is the worst culprit.”[34]

Or, take this quote directly from the White House website under the Biden administration:

“Numerous policies have systemically discriminated against Black families who wish to pursue [homeownership]…Exclusionary zoning laws place restrictions on the types of homes that can be built in a particular neighborhood…Some zoning laws have been used to discriminate against people of color and to maintain property prices in suburban and, more recently, urban neighborhoods.”[35]

These articles all come to the overall conclusion that single-family zoning is discriminatory; yet, as I was reading through them, I noticed that they all admit at one point within their argument that laws specifically restricting non-white Americans from moving into neighborhoods have been outlawed. Despite that, they still argue that because there seems to be a disparity among ethnic groups between neighborhoods connected to wealth, zoning itself is racist and bad and promotes discrimination. How do we respond to this?

The Fair Housing Act of 1968 made it illegal to discriminate housing by race, sex, religion, and all other protected classes on a federal level[36], so at the very top of our government, any racism or discrimination in terms of housing has been outlawed. This means that the claim that things like zoning are systemically discriminating against certain communities is false, because our system of government has made it clear that type of behavior is illegal, and both can and should be criminally prosecuted if it is occurring. From a legal perspective, zoning is not racist.

What about the claim that certain communities are not as wealthy as other communities and therefore single-family zoning is still discriminatory? That argument has a presupposition that if there is not equality of outcome, then there is discrimination. I don’t agree with that, and you shouldn’t either. A law or bill or structure in society is not discriminatory if it is not actively keeping one group of people out. Single-family zoning does not keep Black or Hispanic or other minority residents out based on their skin color or race. Single-family zoning doesn’t keep anyone out based on its nature. Rather, single family homes are attractive to a lot of people who want to live in suburbs rather than crowded cities. It is the laws of economics that then explain how as the rise in demand begins to exceed the supply available, housing prices become less affordable. This is not to prevent racial groups from purchasing single-family homes, this is simply the result of many people wanting to live in one place and one type of community.

I know this is true because I am white, and yet I cannot afford a single-family home. My husband is Indian, and he cannot afford a single-family home. We have friends in our community who are black and Hispanic who DO own single-family homes. Single-family zoning is not discriminatory based on race, it just zones certain areas to have certain types of housing, which then you as an individual have to work to afford. We have white friends who worked for ten years before being able to afford a single-family home in our area because housing is just so expensive in LA County. We have black friends who worked for less time. The key is that in America, there is not equal outcome, but there is equal opportunity, meaning that you can work hard to achieve the quality of life that you desire. Whether or not you can afford a single-family home will depend on your job, your income, the sacrifices that you make, the risks you take and so on, not on your race or your color. Any argument to the opposite is a manipulative argument meant to guilt you into just agreeing that because you want to live in a nice neighborhood with parks and space for your kids to run around makes you racist. Don’t agree to that. It’s not true, and it doesn’t promote rational discussion of policies put in place by our state that affect your life.

What can you do about these bills? As always, you can be informed, you can contact your representatives to let them know you disagree with SB 9 and SB 450, and you can reject the lies being spread about these policies. Most importantly of all, you can advocate for the importance of understanding legislation to shed light on how our government is changing our communities and our lives, even in a bill that may seem unimportant on its face.

 
References:

[1] Los Angeles City Planning. “Senate Bill 9.” planning.lacity.gov, n.d. https://planning.lacity.gov/project-review/senate-bill-9#:~:text=Senate%20Bill%209%20(SB%209,unit%20development%20on%20a%20single%2D.

[2] Garcia, David. “California’s HOME Act Turns One: Data and Insights From the First Year of Senate Bill 9 - Terner Center.” Terner Center, January 18, 2023. https://ternercenter.berkeley.edu/research-and-policy/sb-9-turns-one-applications/.

[3] Healey, Jon, and Matthew Ballinger. “What Just Happened With Single-family Zoning in California? - Los Angeles Times.” Los Angeles Times, September 17, 2021. https://www.latimes.com/homeless-housing/story/2021-09-17/what-just-happened-with-single-family-zoning-in-california.

[4] Mazzoni Valvano Szewczyk & Karam. “What Are the Different Types of Zoning Classifications? | MVSK.” MVSK Law, May 23, 2023. https://www.mvsklaw.com/what-are-the-different-types-of-zoning-classifications/#:~:text=to%20the%20rule.-,Residential,you%20would%20with%20a%20Walmart.

[5] Healey and Ballinger, “What Just Happened With Single-Family Zoning in California? - Los Angeles Times.”

[6] Ibid.

[7] Flemming, Jack. “As Court Overturns a Lot-splitting Law, One Early Adopter Asks Why - Los Angeles Times.” Los Angeles Times, May 2, 2024. https://www.latimes.com/california/story/2024-05-02/as-court-overturns-a-lot-splitting-law-sb-9-one-early-adopter-asks-why.

[8] Horgan, Katelyn. “SB9: A Comprehensive Guide to Lot-Splits in California.” Maxable, September 30, 2024. https://maxablespace.com/sb9-a-comprehensive-guide-to-lot-splits-in-california/#:~:text=Instead%2C%20property%20owners%20who%20want,specific%20to%20their%20local%20ordinance.

[9] Garcia, “California’s HOME Act Turns One: Data and Insights From the First Year of Senate Bill 9 - Terner Center.”

[10] Ibid.

[11] Meares, Hadley. “What Supporters and Critics Say About 2022 California Law Permitting More Duplexes.” The Hollywood Reporter, June 7, 2022. https://www.hollywoodreporter.com/lifestyle/real-estate/sb9-california-housing-laws-critics-supporters-1235159680/.

[12] California Renters Legal Advocacy and Education Fund. “SB 9 – CalHDF.” CalHDF, June 9, 2023. https://calhdf.org/sb-9/#:~:text=In%20the%20following%20cases%2C%20though%2C%20local%20governments,a%20car%20share%20vehicle%20within%20one%20block.

[13] Best Best & Krieger LLP. “SB 450: Legislature Curtails Local Regulation of SB 9 Projects,” October 9, 2024. https://bbklaw.com/resources/la-100924-sb-450-legislature-curtails-local-regulation-of-sb-9-projects.

[14] Senator Toni G. Atkins. “Senate Leader Atkins Introduces Legislation to Improve Access,” March 20, 2023. https://sd39.senate.ca.gov/news/20230320-senate-leader-atkins-introduces-legislation-improve-access-oversight-california-home.

[15] “SB 450: Housing Development: Approvals. | Digital Democracy,” n.d. https://digitaldemocracy.calmatters.org/bills/ca_202320240sb450.

[16] Gibbs, Jason and The City of Santa Clarita. “SB 450 (ATKINS): OPPOSE.” Santaclarita.Gov, July 17, 2023. https://santaclarita.gov/intergovernmentalrelations/wp-content/uploads/sites/5/2023/07/Letter-State-Senator-T.-Atkins-SB450-Oppose-1.pdf.

[17] Ibid.

[18] Murdock, Dawn and The City of Palos Verdes Estates. “SB 450 (Atkins) Letter of Opposition.” Pvestates, August 30, 2024. https://pvestates.granicus.com/MetaViewer.php?view_id=1&clip_id=2140&meta_id=100976.

[19] Jennings, Kelly and The City of Laguna Niguel. “SB 450 (Atkins) Housing Development: Approval, Request for VETO.” Cityoflagunaniguel.Org, September 17, 2024. https://www.cityoflagunaniguel.org/DocumentCenter/View/27346/SB-450-Letter-of-Opposition.

[20] Wiley, Hannah. “California Duplex Law Not yet Working as Expected  - Los Angeles Times.” Los Angeles Times, January 19, 2023. https://www.latimes.com/california/story/2023-01-18/new-california-duplex-law-housing-sb9-homeowners.

[21] Monroe, Willie. “FROM THE ARCHIVE: 1st Day of Driving When Wearing Seat Belts Became CA Law in 1986.” ABC7 San Francisco, January 1, 2021. https://abc7news.com/seat-belts-law-california-wearing/9207393/.

[22] County of Alameda, Public Works Agency, Building Inspection Department. Residential CO & Smoke Alarms (2022 CBC). Brochure, 2022. https://www.acpwa.org/acpwa-assets/docs/permits/forms-and-handouts/2023/Residential-COandSmoke-Alarms-2022-CBC.pdf.

[23] “ADA ( Handicap ) Parking Requirements California | ADA-Striping.” ADA Striping (blog), October 7, 2023. https://ada-striping.com/ada-parking-requirements/#:~:text=The%20Americans%20With%20Disabilities%20Act%20(ADA)%20and%20state%20laws%20mandate,spaces%20for%20people%20with%20disabilities.

[24] Republic Services, Inc. “Senate Bill 1383,” 2022. https://oclandfills.com/sites/ocwr/files/2022-06/Repub%20Services%201383%20Organics.pdf.

[25] Terner Center for Housing Innovation. “Database of California Housing and Land Use Laws - Terner Center.” Terner Center, April 6, 2023. https://ternercenter.berkeley.edu/california-land-use-housing/.

[26] Day Pitney LLP. “Governor Signs SB 328, Reinforcing Florida’s Live Local Act to Spur Mixed Income Housing Development | Day Pitney.” Day Pitney, October 31, 2024. https://www.daypitney.com/insights/publications/2024/05/17-governor-sb-328-fl-live-local-act-mixed-income-housing/.

[27] Pinellas County Government. “Florida State Housing Initiatives Partnership Program - Pinellas County.” Pinellas County, April 1, 2024. https://pinellas.gov/programs/florida-state-housing-initiatives-partnership-program/#:~:text=The%20State%20Housing%20Initiatives%20Partnership,is%20available%20in%20the%20NOFA.

[28] Healey and Ballinger, “What Just Happened With Single-Family Zoning in California? - Los Angeles Times.”

[29] Poole, Robert. “A Brief History of Single-Family Zoning.” Reason.Com, June 11, 2023. https://reason.com/2023/06/10/a-brief-history-of-single-family-zoning/.

[30] Benson, Darren. “Study Suggests People in Urban Areas With More Green Space Have Better Mental Health - Texas a&Amp;M Today.” Texas a&M Today, February 21, 2024. https://today.tamu.edu/2024/02/22/study-green-space-improves-mental-health/.

[31] Ibid.

[32] Ibid.

[33] Solomon, Molly. “The Racist History of Single-Family Home Zoning.” KQED, September 23, 2024. https://www.kqed.org/news/11840548/the-racist-history-of-single-family-home-zoning.

[34] Simama, Jabari. “The Troubling Connection Between Zoning and Racism.” Governing, October 1, 2023. https://www.governing.com/community/the-troubling-connection-between-zoning-and-racism.

[35] Rouse, Cecilia, Jared Bernstein, Helen Knudsen, and Jeffery Zhang. “Exclusionary Zoning: Its Effect on Racial Discrimination in the Housing Market.” The White House, November 30, 2021. https://www.whitehouse.gov/cea/written-materials/2021/06/17/exclusionary-zoning-its-effect-on-racial-discrimination-in-the-housing-market/.

[36] “Federal Protections Against National Origin Discrimination,” July 11, 2023. https://www.justice.gov/crt/federal-protections-against-national-origin-discrimination-1#:~:text=These%20examples%20may%20be%20violations%20of%20the%20federal%20Fair%20Housing,(202)%20514%2D4713.