Glendale Denied 682 Homes With No Findings — HCD Calls It an HAA Breach

You did everything right. The project meets the objective standards. It carries affordable units. Staff recommended approval. The hearing officer signed off. The city attorney stood up at the dais and told the council, on the record, that the project was protected by state law. And the council denied it anyway — no written findings, no evidence, just a vote.

If that sounds familiar, Glendale just drew a state Notice of Violation for exactly this.

Here's the thing: under the Housing Accountability Act, a compliant project that includes lower-income units isn't something a city gets to turn down because it doesn't like the building. HCD's position is that without specific written findings, backed by evidence, the city had no lawful way to say no — and was required to approve it.

The project — and the paper trail of approvals

The 236 North Central Ave Housing Project in Glendale is big: 682 units, of which 610 are market-rate and 72 units [are] affordable to very low- (VLI) and low-income (LI) households. It sought a 46.25-percent density bonus because 14 percent of the base density (67 units) is set aside for very low-income households, plus two concessions and four development-standard waivers.

By the time it reached the City Council, the record was one-sided. The Planning Commission had approved the related alley vacation as consistent with the General Plan. The Design Review Board voted to recommend approval. The Planning Hearing Officer approved the Density Bonus Housing Plan as consistent with "the General Plan, Municipal Code, and state law." Then, per HCD, the Council denied it —

"…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."

Verified against HCD's Notice of Violation to the City of Glendale (December 30, 2025), reviewing the Council's October 21, 2025 denial of the 236 North Central Ave Housing Project.

The switch the HAA flips

The Housing Accountability Act (Gov. Code § 65589.5) sharply limits a city's ability to deny or downsize a project that meets objective standards. When a project includes units for lower-income households, those protections get stronger. HCD found this one cleared that bar: it "includes a total of 67 units affordable to very low-income households, which is at least 10 percent of the total units," triggering the heightened protections under § 65589.5(d).

Under subdivision (d), HCD explained, a city may deny such a project only in narrow circumstances and only "based upon a preponderance of the evidence in the record…." The specific finding Glendale would have needed under § 65589.5(d)(2) is 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 …."

That's a high, evidence-backed bar. It is not "we'd prefer a different building."

What the Council didn't do

HCD reviewed the video of the October 21 deliberations. Its read: the council raised concerns, but "none appear to HCD to constitute a specific, adverse impact upon public health or safety that would justify denial." And the denial motion itself did the two things that sink a denial —

"…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."

No findings. No evidence. HCD's conclusion was blunt: "By improperly denying the Stage II Design Review application, the City is in violation of the HAA." And it spelled out the remedy: "In the absence of such findings, the City was required to approve the Project." HCD gave Glendale until January 29, 2026 to respond with a corrective plan, and flagged possible referral to the Attorney General under § 65585.

Why this matters for your project

The lesson isn't Glendale-specific. If your project meets the objective standards and carries enough lower-income units to earn heightened HAA protection, a bare "no" — a denial with concerns but no findings and no evidence — is exactly the kind of action HCD treats as an enforcement risk. The findings requirement isn't a formality a council can skip past; it's the whole ballgame.

An HCD letter is the department's enforcement position, not a court's final word, and this isn't legal advice — so confirm how it applies with your jurisdiction and your counsel before you rely on it. But if you're staring at a findings-free denial of a compliant, affordable-inclusive project, you're not powerless.

What CrossBeam does with it

When the letter lands on your desk, CrossBeam turns it around the same day: what each item is actually asking, the code or law behind it, and a written response you can hand to your team or your attorney — the back-and-forth that used to eat weeks, done in a couple of hours.