Glendale Amended Its ADU Ordinance — HCD Still Found Three Bans

You own a house in Glendale and you want a backyard ADU. But you already have a pool house, so the city says no — pick one or the other. Or you want the unit above your detached garage, and the ordinance says that isn't allowed. So you shrink the plan, or drop it.

Here's the thing: California's housing agency looked at Glendale's ADU rules and said three of those bans don't comply with state law — and that the city's ordinance is null and void until it fixes them.

On August 15, 2025, the California Department of Housing and Community Development (HCD) sent Glendale a follow-up Notice of Violation. Glendale had already tried to comply: it amended its ordinance and passed a resolution defending it. HCD found that wasn't enough. In its words, the "amended effective ordinance retains three significant and precedent-setting violations."

Verified against: City of Glendale — HCD Follow-up Notice of Violation, dated August 15, 2025 (ADU Ordinance No. 6035; Resolution No. 24-189).

How Glendale got here

This fight goes back years. On December 7, 2023, HCD reviewed Glendale's ADU ordinance and identified 16 noncompliant provisions. The city disagreed, kept processing applications under its own rules, and told HCD it did not believe the state could declare a local ordinance void "without a formal legal adjudication by a court."

On December 3, 2024, Glendale adopted an amended Ordinance No. 6035 alongside Resolution No. 24-189 and — per HCD — resolved most of the findings. But three survived. On August 7, 2025, HCD and the Attorney General's Office met with the city about the three it hadn't fixed and, HCD wrote, "discussed potential next steps, including further enforcement."

The three bans HCD reaffirmed

1. No detached ADU if you already have a pool house. Glendale's ordinance blocks a detached ADU when the lot already has an "accessory living quarters" — which the ordinance defines to include "a cabana, pool house, recreation room, workshop, studio, rumpus room, and similar." HCD found this violates Gov. Code § 66323(a)(2), which says a local agency "shall approve an application … to create … one detached, new construction accessory dwelling unit" up to 800 square feet. HCD's bright line: "State law does not contain a carveout for lots with other detached accessory structures."

2. You can't be forced to pick one unit type. Glendale read the statute to let applicants build under only one category. HCD disagreed: on a single-family lot, the statute requires "ministerial approval of a total of two ADUs and one JADU, in addition to the primary dwelling." HCD found the city has to allow units under both § 66323(a)(1) and (a)(2), not one or the other.

3. No ADU above a detached garage. Glendale banned new-construction ADUs above detached garages. HCD found that violates Gov. Code § 66314(d)(3), which requires cities to allow ADUs "either attached to, or located within, … an accessory structure." Its reasoning was blunt: "A detached garage is an accessory structure, and an ADU above that garage is attached to the garage."

The line HCD drew

Here's the part with teeth. HCD's position is that under Gov. Code § 66316, a non-compliant ADU ordinance "shall be null and void" and the city "shall thereafter apply the standards established in this article" until it adopts a compliant one. HCD also pointed to § 66325, under which State ADU Law "shall supersede a conflicting local ordinance." And it invoked its enforcement authority: HCD notified the Attorney General under Gov. Code § 65585(j) and gave Glendale until September 12, 2025 to respond with a plan of action.

Glendale doesn't agree — it argued that a court, not HCD, has to declare an ordinance void. That tension is the whole point: HCD letters carry real weight, but they are the agency's enforcement position, not a court ruling. Courts are the final word.

What it means if you're building

If HCD's read holds, the practical takeaway is this: a Glendale ADU rule blocking your detached unit, your unit mix, or your above-garage unit may be one HCD considers unenforceable — and the city may owe you review under State ADU Law in the meantime.

But don't freelance it. This is an enforcement position on a specific ordinance, and how it lands on your lot depends on details the letter alone doesn't settle. Put the ordinance section next to the matching state statute, then verify with Glendale's planning department and your own counsel before you rely on any of it. This isn't legal advice — it's a map of where to look.

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.