Does the city have to give me all ADU plan check comments at once?

If the city denies your ADU application, state law says it must return a full set of comments in writing, listing every defective or deficient item and how to fix it. HCD's ADU Handbook explains that a full set includes comments from all reviewers at every permitting agency. That gives you a strong basis to expect one consolidated list per review, although new issues can still come up if your revisions change the design.

What the law requires

• Full set of comments on denial. Government Code section 66317(b), as summarized in HCD's ADU Handbook, requires a permitting agency that denies an ADU application to return in writing a full set of comments with a list of items that are defective or deficient and a description of how the application can be remedied.
• All reviewers, all agencies. HCD says a full set includes all comments from all reviewers, from every permitting agency, and that the 60-day countdown continues until the complete list is provided. "Permitting agency" is defined broadly to include planning and building departments, utilities and special districts.
• Completeness notices. The agency must tell you in writing within 15 business days whether your application is complete. If it is not, the notice must list the incomplete items and describe how to make the application complete.
• Appeals. The agency must provide a process to appeal an incompleteness determination or a denial, and issue a final written determination within 60 business days of receiving the written appeal.

What it does not do

• HCD notes that a subsequent application after a denial resets the 60-day period.
• It does not freeze your design. If a resubmittal changes equipment, routing or layout beyond what the comments asked for, the reviewer has new work to check.
• For previously unpermitted units, HCD notes that building code and health and safety corrections remain under local discretion, and points applicants to the local appeals process.

Practical steps

1. Ask whether the list you received includes every reviewer, including fire, utilities and planning.
2. Keep revisions focused on the comments so you do not open new issues.
3. If comments arrive piecemeal, a polite written request for the complete set, citing section 66317(b), is reasonable.
4. If you are stuck, HCD offers technical assistance through its ADU portal once an application has been submitted, after you have worked through the agency's own process.

What this means for your MEP plans

One complete list lets the MEP sheets, the Title 24 report and the architectural plans be fixed together in a single round. MEP Plans USA includes city plan-check corrections on its sheets with every order, so forward each list as soon as it arrives. Read more about the 60-day rule and plan check corrections. This is general information, not legal advice; confirm the process with your building department.

Sources: hcd.ca.gov.