SB9 in Burbank

Burbank earns a B grade reflecting a city that is now actively approving SB9 projects after a slow start. This grade signals a market with growing opportunity for investors willing to engage in a city that has only recently begun to comply fully with SB9 requirements. The city’s trajectory indicates increasing approvals and a regulatory environment that is becoming more predictable.

Burbank is a charter city with an ordinance that was initially restrictive due to ongoing litigation challenging SB9 applicability. The ordinance largely follows standard SB9 provisions but was effectively dormant during the lawsuit period. There are no unusual setbacks, lot minimums, or design standards beyond typical city requirements. Parking requirements remain consistent with state guidelines. The ordinance now functions as a standard SB9 implementation following the court ruling.

Burbank’s SB9 activity was minimal from 2022 through most of 2023 due to its status as a charter city and its role as plaintiff in a lawsuit contesting SB9’s applicability. This litigation suppressed approvals, as the city delayed compliance pending the court’s decision. The zero approvals in 2023 reflect this pause. After the Court of Appeal ruling in September 2025 mandated compliance, Burbank began processing and approving SB9 applications in earnest. This shift is clear in the jump from zero approvals in 2023 to eight in 2024 and nine in 2025, despite a steady increase in applications. The city’s trajectory shows strong growth as it transitions from litigation to active implementation.

There is no record of enforcement action by the California Department of Housing and Community Development against Burbank related to SB9 compliance.

Investors should view Burbank as a market moving into a growth phase for SB9 development. The city’s prior resistance due to charter city litigation has ended, and approvals are increasing steadily. While the overall approval rate remains modest at 24.1%, the upward trend suggests that Burbank is becoming a more reliable environment for SB9 projects. Investors willing to navigate the city’s evolving processes can expect expanding opportunities. This is a buy market for those prepared to engage now and benefit from the city’s recent shift toward compliance and growth. For the grading methodology, see the SB9 City Guide post.