1.  Cities Must Update Local Ordinances and Processes

Cities are required to align their subdivision ordinances with SB 684/SB 1123.

For example, the Berkeley City Council directed staff to draft ordinance updates to its municipal code (Titles 21 & 23) specifically for the implementation of SB 684 and SB 1123.  This directive acknowledges that cities need to bring their subdivision and zoning codes into compliance with the new state requirements.

Similarly, Los Angeles issued a formal planning department implementation memo outlining internal procedures, standards, and timelines for SB 684, which served as the blueprint for SB 1123’s adoption.

What this means for SB 1123:

Cities will adopt ordinances that:

• Recognize SB 1123 as a ministerial subdivision pathway
• Amend local lot size, dimension, and small‑lot subdivision chapters
• Remove discretionary triggers that conflict with state Law
• Update internal review checklists and objective standards

2.  Cities Must Implement an SB 1123 Eligibility Review System

SB 684 already requires cities to maintain an eligibility checklist and apply it during intake; Los Angeles explicitly created such a checklist under its ZIMAS zoning system.
Cities will extend the same system to SB 1123 projects.

Required eligibility checks (per statute):

Cities must confirm that:

• The parcel is vacant
• The parcel is zoned single-family, and ≤ 1.5 acres (per SB 1123 expansion)
• The site is a legal parcel located in an incorporated city or urbanized area
• Qualifying urban uses surround at least 75% of the perimeter

Cities typically create:

• An SB 1123 intake form
• A GIS-based eligibility map layer
• A standardized site screening worksheet

3.  Cities Must Process Subdivisions and Housing Applications Ministerially

SB 1123 retains all ministerial requirements from SB 684.
Cities must process:

• Parcel maps
• Tentative and final maps
• Associated Housing development applications

Without:

• Public hearings
• CEQA review
• Discretionary findings

City officials and planners can trust that approvals or denials will be issued within 60 days of a complete application, fostering confidence in a predictable and transparent process.

Internal changes cities make:

• Replace discretionary staff reports with ministerial approval letters
• Train planners to evaluate applications using objective standards only
• Revise workflow timelines and internal routing to meet the 60-day deadline

4.  Cities Must Enforce Objective Development Standards Only

Cities may apply objective standards, but must waive or modify any standard that would “physically preclude” the project from meeting minimum statutory density.

Cities, therefore, must:

• Review their zoning codes
• Identify any subjective standards (e.g., “neighborhood character”)
• Convert or delete standards that cannot be applied ministerially

Typical objective standards cities implement include:

• Setbacks (e.g., 4 ft side/rear, no interior setbacks)
• Parking maximums (e.g., 1 per unit, or 0 near transit)
• Height standards not lower than base zoning
• Minimum FAR protections (1.0 for 3–7 units; 1.25 for 8–10 units)

• Implementing objective standards requires substantial code cleanup and staff training to ensure consistent, ministerial application of regulations.

5.  Cities Must Apply SB 1123’s Specific Development Restrictions

Cities must verify that no SB 1123 project:

• Demolishes protected, rent-controlled, or recently occupied Housing
• It is on environmentally sensitive land
• Was previously created under SB 9 or SB 684

Cities typically implement:

• A protected‑unit screening checklist
• A review of past subdivision History
• A flag for environmental constraints within their GIS systems

6.  Cities Must Update Building Permit Processing

SB 684 requires cities to issue building permits by ministerial order once the subdivision map is approved, and SB 1123 extends this mandate.

Cities, therefore, must:

• Treat SB 1123 building permits as ministerial
• Eliminate design review board oversight
• Remove discretionary architectural reviews
• Ensure review is limited to building code and objective zoning standards

This aligns building permit departments with planning and subdivision staff.

7.  Cities Must Educate Staff, Applicants, and the Public

Both Los Angeles and Berkeley are prepared:

• Implementation memos
• Eligibility checklists
• Planning Commission presentations

Cities implementing SB 1123 will provide:

• Guidance documents for applicants
• FAQ sheets
• Public website updates
• Training sessions for planners, engineers, and counter staff

This helps avoid misapplication of subjective or outdated standards.

Implementation requires coordination across multiple departments, including Planning, Public Works, Building & Safety, Housing, and the City Attorney’s Office, fostering teamwork and shared purpose.

Implementation typically involves:

• Planning Department
• Public Works / Engineering
• Building & Safety
• Housing Departments
• City Attorney’s Office

Los Angeles’ SB 684 memo is a clear example of multi-department coordination (Planning, Building and Safety, and Public Works).

Cities will follow a similar interdepartmental process for SB 1123 since:

• Subdivisions require engineering review
• Objective infrastructure standards (water/sewer) must be verified
• Final maps require signatures from multiple city departments

Summary: How Cities Implement SB 1123

Cities implement SB 1123 by:

·         Updating local subdivision & zoning ordinances to comply with state Law.

·         Creating SB 1123 eligibility checklists and GIS screening tools.

·         Processing subdivisions and Housing applications ministerially within 60 days.

·         Applying objective standards only and waiving obstructive rules.

·         Screening for protected units and environmental constraints.

·         Processing building permits ministerially after map approval.

·         Issuing public and staff guidance documents.

·         Coordinating across planning, engineering, and building departments.

Bottom line:

SB 1123 requires cities to replace discretionary processes with a fast, predictable, state-mandated approval system—extending the reach of SB 684 into vacant single-family zones and dramatically expanding the number of sites eligible for small, for-sale infill Housing.

How Cities Handle Appeals Under SB 1123

SB 1123 adopts and expands the same ministerial, CEQA-exempt approval framework created by SB 684.  Under that framework, no appeals are allowed—not to planning commissions, not to city councils, and not through CEQA—because ministerial actions are non-discretionary by definition.

This is confirmed explicitly in SB 684/SB 1123 implementation guidance:

• SB 684 and SB 1123 projects are “exempt from discretionary review, environmental review under CEQA, and the right to appeal.”

Given that SB 1123 extends SB 684’s ministerial subdivision process to additional zoning categories (primarily vacant single-family lots), this prohibition on appeals applies identically.

Below is a detailed breakdown of what that means in practice.

1.  SB 1123 Eliminates All Local Administrative Appeals

No appeal to the Planning Commission

Normally, parcel maps and tentative maps can be appealed to a Planning Commission under local codes.
SB 1123 blocks this because the approval is ministerial only.  Cities cannot route SB 1123 applications into their discretionary appeal structure.

No appeal to the City Council

Local appeal procedures that send decisions from Planning Commissions to City Councils do not apply.
State Law preempts any city ordinance that attempts to create an appeal pathway.

Why?

Ministerial approvals are binary:
If an application meets objective standards, the city must approve it.
There is no discretionary judgment to review—therefore, nothing to appeal.

This requirement mirrors SB 684’s implementation memos, which emphasize that qualifying applications must be approved “without discretionary review or a hearing”. [planning.lacity.gov]

2.  No CEQA Appeals or Environmental Challenges

Because SB 1123 approvals are ministerial, they are automatically exempt from CEQA, just as SB 684 projects are.
The Allen Matkins legal summary confirms that SB 684/SB 1123 projects are:

• “Exempt from discretionary review, environmental review under CEQA, and the right to appeal.

This means:

• No CEQA notices
• No environmental Impact reports
• No CEQA lawsuits based on negative declarations or EIR adequacy
• No administrative CEQA appeals

The ministerial nature of the process removes environmental review entirely.

3.  No Public Hearing Means No Public Appeal

SB 1123 retains the structure where:

• A city cannot hold a public hearing, and
• A city must use objective standards only
  Since there is no hearing, there is no official action that the public can appeal.

Public opposition—or support—cannot influence the outcome.

4.  The Only “Appeal-like” Process Allowed: Written Denial Findings (Rare)

Although cities cannot allow appeals, they may deny an SB 1123 application only if they issue a written finding of a specific, adverse Impact on health or safety that cannot be mitigated through feasible conditions.
This rule appears explicitly in SB 684/SB 1123 implementation presentations:

• Cities may deny only based on a “Specific Adverse Impact Test” requiring written findings.
• If a project is denied, the applicant may challenge the decision outside the city’s appeal process—typically via:

• A writ of mandate in the Superior Court
• A Housing accountability challenge

But cities may not offer an internal appeal process.

5.  Cities Must Purge Appeals from Their Local Ordinances

Cities implementing SB 1123 must:

• Amend local subdivision ordinances
• Disable appeal routes for SB 1123‑qualifying projects
• Remove or bypass the Planning Commission and City Council discretionary review steps
• Rewrite public notices to indicate that no hearing or appeal is available

This follows the same implementation steps described for SB 684 at the local level.
For example, Berkeley’s implementation directive shows the city must create a local ordinance updating its subdivision code to comply with SB 684/SB 1123’s ministerial requirements and timelines, which, by nature, exclude appeals.

6.  Why the State Eliminated Appeals for SB 1123

SB 1123 advances the same policy rationale as SB 684:

• California needs more small, for-sale Housing (“starter homes”)
• Small projects face outsized entitlement barriers
• Appeals introduce unpredictability, delay, and costs incompatible with small-scale infill development

Removing appeals ensures:

• Predictable 60-day approvals
• No political interference
• Objective‑standard-only review
• Faster lot creation and homebuilding
• Reduced holding costs for small developers and homeowners

7.  Summary: How Cities Handle Appeals Under SB 1123

Cities do not handle appeals at all—because appeals are not allowed under SB 1123.

Under SB 1123, cities must:

• Provide ministerial approval only
• Allow no internal appeals to Planning Commissions or City Councils
• Allow no CEQA appeals
• Provide no public hearing, eliminating public appeal rights
• Use objective standards only, giving no discretionary basis for appeal
• Only issue denials based on specific, adverse health/safety impacts, with written findings
• Update local ordinances to remove appeal pathways

Because SB 1123 applies SB 684’s process to new zones, the same absolute prohibition on appeals applies.