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D. Lot Coverage Limits Coverage limits can be applied to all structures on a lot, combined (e.g., primary house, detached garage, garden shed, ADU); all accessory structures combined, including an ADU; or a separate lot coverage applicable just to detached ADUs that are not part of another accessory structure. Lot coverage allowances and limits intersect not only setbacks but floor area ratio limits and height limits. If detached or attached ADUs are significantly constrained by a lot coverage limit, then the possibility of having a two-story ADU may determine whether the investment in an ADU will generate a big enough return to justify its construction. Steep slopes and impacts on stormwater runoff may require differences in lot coverage allowances for some sites. Some communities are under consent decrees entered into with the U.S. Environmental Protection Agency to address stormwater discharges. These consent decrees, which set standards for the maximum proportion of a lot that can be covered with impermeable surfaces, must be incorporated into local standards. Requiring or allowing the use of permeable pavers, which can be exempted from lot coverage calculations, helps address those standards. These consent decrees are another good reason not to require on -site parking. Whenever possible, limitations on lot coverage should be addressed at the planning stage (for example, through the use of overlay districts) rather than being determined and applied in the permitting process. Siting and design standards that help meet performance standards for building safety and stormwater runoff can be determined and adjusted at the permitting stage for these kinds of sites. That is preferable to a complete prohibition. An accessory dwelling unit (detached, attached or built by expanding the footprint of an existing dwelling) on a lot of 4,000 square feet or larger shall not occupy more than 15% of the total lot area. For single family lots of less than 4,000 square feet, the combined lot coverage of the primary dwelling and the accessory dwelling shall not exceed 60%. Accessory dwelling units built within the footprint of existing, legal accessory structures are considered not to have changed existing lot coverage. E. ADU Setbacks (1) A setback of no more than 4 feet from the side and rear lot lines shall be required for an accessory dwelling unit that is not converted from an existing structure or a new structure constructed in the same location and with the same dimensions as an existing structure. (2) No setback shall be required for an existing garage living area or accessory structure or a structure constructed in the same location and with the same dimensions as an existing structure and converted to an accessory dwelling unit or to a portion of an accessory dwelling unit. (3) A detached accessory dwelling unit is not permitted on the front half of a lot, except when located a minimum of 30 feet from the front line or if it falls within the provision of subsection (2). Adapted from California Government Code 65852.2(a)(D)(vii) and Los Angeles Metropolitan Code 12.22 A.33(d)(3). 38 1 HARP - Accessory Dwelling Units: Model State Act and Local Ordinance