Can 2 ADUs be attached to each other but detached from primary dwelling?

Per the HCD handbook, Gov Code Section 66313-66332 (previously 65852.2, subdivision (e)) allows “Up to two detached ADUs on a lot that has existing multifamily dwellings that are subject to height limits of 16 feet and four-foot rear and side yard setbacks.” This application proposes two ADUs detached from the main multifamily structure but are attached to each other.

There is no legislation that requires that ADUs on a multi-family lot be separated from each other, and floor area limits apply to the ADUs separately and do not apply to the whole structure. Where two ADUs are allowed, the ADUs may be attached to each other.

Legislative Background:

Government Code Sections 66313-66332 provides for “[no] more than two accessory dwelling units that are located on a lot that has an existing or proposed multifamily dwelling, but are detached from that multifamily dwelling and are subject to a height limitation in clause (i), (ii), or (iii), as applicable, of subparagraph (D) of paragraph (2) of subdivision (c) and rear yard and side setbacks of no more than four feet.”