California Kept the Clock and Started Counting the Rounds
San Francisco turns around a resubmitted building permit in a median of three days. Housing permits still took a median of 280 days, according to a March 5, 2026 report by the Board of Supervisors' Budget and Legislative Analyst to Supervisor Bilal Mahmood. The median housing permit went through three rounds of review.
Fast rounds, slow permits. California's 2022 permit shot clock left that mismatch open: it timed every round of plan review and never counted the rounds. A permit could meet every deadline on paper and still take months.
AB 1621, signed September 29, 2026, keeps the clock and adds a count. After two plan check reviews on a building permit, the city may deny, and only the applicant can ask for a third.
A weak resubmittal stops being a schedule problem and becomes a denial risk.
But the cap reaches building permits only. Standalone grading, offsite improvement, and demolition permits sit outside it. The law puts new pressure on the building permit set and leaves separately permitted civil work where it was.
The BLA's figures are citywide, and the first plan review takes a median of 15 calendar days. The 280 days covers housing permits issued between January 2024 and August 2025. It includes entitlement time on applications filed before January 1, 2024; for applications filed on or after that date, the median was 114 days.
The report's staff, Fred Brousseau and Reuben Holober, found that "approximately half of all applicants are subject to three or more rounds of review." The BLA also pointed to multi-department review and applicant delays, and it couldn't separate staff time from applicant hold time.
The San Francisco Chronicle's coverage set the city's 280 days against figures from Austin, Seattle, Denver, and Washington, D.C., and noted that most projects went through at least three rounds.
What the 2022 Clock Actually Measured
AB 2234 (Robert Rivas, Ch. 651, 2022) set the deadlines most practitioners know, now codified in Government Code §65913.3. The agency gets 15 business days to call a postentitlement application complete. It then has 30 business days to approve or return comments for projects of 25 units or fewer, and 60 for projects of 26 or more.
The pitch was delay. "In fact, many projects spend months or even years waiting for building permit approvals," the author's statement reads in the Assembly Local Government Committee analysis.
The same analysis spelled out how the clock worked on a resubmittal. The resubmitted application "is subject to the same timeframes applicable to an original complete application."
And the bill "does not place limitations on the amount of feedback a public agency may provide" or the revisions it may request. A fresh clock on every round, no limit on comments.
San Francisco's analyst read it the same way: "Any subsequent rounds of review are also subject to the 30 or 60 business day time limits." Under that design a department could finish every round on time, legally, and the permit could still run long.
The statute measured the round, and the typical round was fast, though not uniformly. Seventy-two percent of first-round reviews met the city's 30-calendar-day target, and 88 percent of second-round reviews met its 14-day target.
The BLA couldn't say whether San Francisco met the state clocks. Compliance "cannot be readily determined," the report said, because the Department of Building Inspection's records "do not link the number of rounds of review and number of days."
The city has started treating the round count as the signal anyway. DBI staff supervisors now have to investigate applications that haven't been approved by a third round.
AB 2234 already made a missed deadline a Housing Accountability Act violation, per the 2022 analysis. Assemblymember Lori Wilson's AB 660 in 2025 extended that hook to violations of the postentitlement provisions.
It passed the Assembly and was held in Senate Appropriations in August 2025. Wilson introduced AB 1621 on January 22, 2026.
What AB 1621 Counts
The operative language sits in Government Code §65913.3(c)(1)(C) and (c)(2)(C), as amended by AB 1621 (Ch. 780). A local agency "shall not require or request more than two plan check and specification reviews in connection with an application for a building permit."
It may "deny an application that is not compliant with the permit standards following two plan check and specification reviews." And: "An applicant may request additional submittals."
Two reviews means the first submittal and one resubmittal. On the BLA's numbers, roughly half of San Francisco's recent housing permits went through more rounds than the new law lets a city ask for.
The escape hatch belongs to one party. The March 2026 version let an agency add reviews on written findings backed by substantial evidence. Those findings had to show another round was needed to address a specific adverse impact on public health or safety.
The chaptered text has no such exception. Its four clauses cap reviews at two, allow denial after two, let the applicant request more, and exclude every other postentitlement permit.
A health or safety finding still does something under §65913.3(c)(4): it suspends the time limits. It doesn't buy the city a third review. Only the applicant can open one.
AB 1621 carries no urgency clause or delayed operative date for these sections. The default rule for non-urgency statutes applies, and they take effect January 1, 2027.
Teams with a building permit already in review on that date should ask counsel how the cap applies to it.
The Permits the Cap Doesn't Reach
The statute draws the line itself. The two-review limit "shall not be construed to affect the number of submittals ... for any postentitlement phase permit other than a building permit."
The definitions tell you what falls on each side. Section 65913.3(k)(3)(A)(i) lists building permits "and all interdepartmental reviews required for the issuance of a building permit, including plan checking and building inspection" as one category. It lists permits for minor or standard offsite improvements, permits for demolition, and permits for minor or standard excavation and grading as separate ones.
Those standalone permits stay on the 2022 model, with a fresh clock on each resubmittal. AB 1621 doesn't cap their rounds, and the 2022 law never limited comments.
That line cuts through the middle of the civil engineer's work. Where a city reviews grading or other civil sheets inside the building permit, as an interdepartmental review, that review is inside the cap.
San Francisco's own building permit application checklist, per the BLA, includes "civil engineering documents such as grading plans." Where the same work goes in under its own grading or offsite permit, the cap doesn't touch it.
A team that hears "two plan checks max" and builds the whole permit calendar around it will misjudge which drawings are capped. The question for each civil sheet is which permit it's reviewed under. That depends on how the city sets up its review.
The statute doesn't assign risk among team members. It caps reviews of the building permit application and lets the city deny that application as a whole.
The pressure lands hardest on whoever puts together the building set, usually the architect. Egress and fire separation issues left open at first submittal now have one round to close.
That's our inference from the statute's structure; the text doesn't say it. We've written separately about how liability for drawing errors reaches the architect.
What a City Does With a Noncompliant Second Submittal
The statute gives the agency one move that doesn't depend on the applicant: deny. Under AB 2234, a city with more comments returned them and the clock restarted. Under AB 1621, a city looking at a second submittal that still doesn't comply can deny it or wait for the applicant to request another round.
An applicant who asks for a third review trades time for a shot at approval. The time is the applicant's to lose.
The applicant's remedy after a denial is an appeal on a shorter clock. AB 1621 cuts the deadline for a final written determination on appeal from 60 to 30 business days for projects of 25 units or fewer. For projects of 26 or more, it drops from 90 to 45.
If the appeal is denied, or isn't decided in time, the applicant "may seek a writ of mandate to compel approval." That's a lawsuit asking a court to order the permit issued. It's a real remedy, and it's slow and expensive next to fixing the drawings before they go in.
The strongest objection is about safety. Solana Beach Mayor Lesa Heebner made the case in an August 27, 2026 letter to Wilson. Plan check, the letter said, "is not a discretionary barrier; it is a vital technical safety step."
The letter objected to making building officials approve plans "under arbitrary time schedules" or face liability under the Housing Accountability Act. That choice, it argued, "forces local agencies to choose between thorough public safety reviews and costly state enforcement actions." The California Building Officials listed the bill as oppose in their September 2026 legislative briefing.
Three local government associations took an oppose-unless-amended position in the Assembly Housing Committee analysis of April 8, 2026. They were the League of California Cities, the California State Association of Counties, and the Rural County Representatives of California.
Their concern was that the bill would "eliminate the ability of local governments to require more than two plan checks on a building permit application." The agency's only way past two in that version was a written finding, based on substantial evidence, of a specific adverse impact on public health and safety.
That objection was aimed at the findings path, and the chaptered law doesn't include one. The final text is tighter than the version the cities objected to in April.
Two late-session documents still describe a findings exception. CALBO's September briefing says its amendments "allow locals to require additional plan checks when written findings support need for additional review(s)."
The Solana Beach letter describes the bill as limiting resubmittals "unless complex, onerous findings are established." The chaptered §65913.3(c)(1)(C) and (c)(2)(C) contain no such clause. Practitioners reading the opposition material should check it against the enacted text.
The officials' point holds up. Plan check is where a structural load path or an egress width gets caught on paper instead of in the field.
The best answer to it is in the statute itself. Nothing in AB 1621 requires a city to approve a noncompliant set. The agency keeps the power to deny, and denial is the safety backstop.
What the city loses is the ability to keep a set in review indefinitely. Whether that trade costs any safety depends on how often a second submittal comes in with a real life-safety gap still open. The cap doesn't take effect until January 1, 2027, so there's no track record yet.
SB 1014: An Improvements Ceiling That Arrives After Completeness
The companion bill matters more to civil engineers and to the developers pricing land. SB 1014 (Grayson, Ch. 806), signed the same day, adds Government Code §65941.3 and applies to charter cities as well as general-law ones. It also takes effect January 1, 2027.
It works in two stages, and only the second binds the city. On request, the city must give a preliminary estimate of required onsite and offsite improvements within 30 business days. That estimate is "for informational purposes only and shall not be legally binding" (§65941.3(b)(5)).
Then, within 30 business days of deeming the postentitlement application complete, the city must issue an itemized list of the improvements it will require (§65941.3(c)(1)). After that, under §65941.3(c)(2)(B), the city can't require an improvement that isn't on the list, with three exceptions:
- an improvement needed to address a specific adverse impact on public health or safety, supported by substantial evidence
- an improvement tied to a change in the scope of work the applicant made after applying
- for a discretionary permit, CEQA mitigation
The City of Thousand Oaks objected to the estimate. It warned in the Assembly Local Government analysis of SB 1014 that an estimate made at application "may be wildly inaccurate by the time the project breaks ground two years later." The bill text already made the estimate non-binding, and the chaptered version keeps it that way.
The timing is the catch for anyone underwriting a site. The binding list shows up 30 business days after the postentitlement application is complete, which by definition means the entitlement is already in hand.
For a buyer who needs offsite costs before closing, it arrives too late. It's a ceiling for construction budgeting. It isn't a pre-closing guarantee.
Request the preliminary estimate anyway, since it tells you early what the city expects to ask for. Budget off the itemized list, and read the three exceptions before you treat its total as final.
The Second Round Is the Last Round
Under the old law, a missed comment cost a round. Once the cap takes effect on January 1, 2027, it can cost the building permit. Four habits follow from that.
Sort the drawings by permit before the design is far along. For each civil sheet, ask the city in writing whether it's reviewed inside the building permit or under its own grading or offsite permit. The answer decides whether those sheets get two reviews or as many as the city wants.
Treat the first submittal as half your allowance. Every agency already has to publish a list of what a complete postentitlement application contains (§65913.3(a)). Build the set against that list and run the code check before it goes in, the same logic behind front-loading Austin's completeness check. Then answer every comment on the resubmittal, because there's no third round to catch the one you skipped.
Decide what you'll do if the second review fails before it comes back. Asking for a third review keeps the project in plan check and costs schedule. Appealing puts the city on a 30- or 45-business-day clock with a writ of mandate behind it. Both are defensible choices, and both are better made in advance than under deadline pressure.
On SB 1014, request the preliminary estimate with the application, then calendar the itemized list for 30 business days after completeness. Once the list arrives, hold the scope steady. A change in scope is one of the three ways a city can add improvements the list didn't name.
Standalone grading, offsite-improvement, and demolition permits keep the 2022 rules, with a fresh clock on every resubmittal. Schedule them as the open-ended risk they still are.
On a capped building permit, the comments you catch before the first submittal are the ones that decide whether the permit issues.