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Confidential Broker Opinion of Value
536 W Palm Street
Altadena, CA 91001
Altadena Strong · 10 Doors Ministerially · 1.03-Acre Rebuild Site
45,000Lot SF
10Doors, Ministerial
R-1-7,500Zoning
20+At Full Buildout
Luka Leader
Luka Leader
Associate Investments
Filip Niculete
Filip Niculete
Senior Managing Director Investments

Confidential Broker Opinion of Value

APN 5829-012-016 · Eaton Fire Rebuild Site · September 2026

Team Track Record
LA Apartment Advisors at Marcus & Millichap
LAAA Team of Marcus & MillichapExpertise, Execution, Excellence.
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"We Didn't Invent Great Service, We Just Work Relentlessly to Provide It."

Since 2013, the LAAA Team has closed 460+ multifamily transactions totaling $1.47B+ in volume across Los Angeles, Ventura, and Santa Barbara counties. In the aftermath of the January 2025 Eaton Fire, the team has been at the center of the Altadena rebuild market — advising owners of fire-impacted land on entitlement pathways, subdivision economics, replacement cost, and the scarcity-driven pricing that now defines this submarket.

Our practice is built on disciplined underwriting, the deepest comparable-sales dataset in the submarket, and a marketing engine that reaches every active multifamily and development buyer in Los Angeles. For 536 W Palm Street, that means an evidence-based opinion of value anchored in the most recent Altadena land trades, the property's confirmed like-for-like rebuild rights, and the subdivision yield its 1.03-acre size makes possible.

Our Team
#1 Most Active Multifamily Sales Team in LA County
CoStar • 2019, 2020, 2021 • #4 in California
Luka Leader
Luka Leader
Associate Investments · National Multi-Housing Group
Lead advisor on 536 W Palm Street. Luka focuses on Altadena and the eastern San Gabriel Valley, where he has tracked the post-Eaton-Fire rebuild market parcel by parcel — entitlement pathways, debris-clearance status, and the land trades resetting value across the burn area.
Filip Niculete
Filip Niculete
Senior Managing Director Investments
Co-founder of the LAAA Team and one of Southern California's top multifamily brokers. Since 2011, Filip has built a reputation for execution, integrity, and relentless work ethic, helping lead the team to $1.4B+ in closed transactions while consistently leading the market in active inventory.
Glen Scher
Glen Scher
Senior Managing Director Investments
Co-founder of the LAAA Team and one of the most active multifamily brokers in Los Angeles, with 450+ transactions and $1.4B+ in closed sales. Glen brings deep experience underwriting land, value-add, and new-construction multifamily across the LA basin.
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Chairman's Club — Marcus & Millichap's top-tier annual honor
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Sales Recognition Award — every year since 2016
40+ transactions per year — one of SoCal's most active groups

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The Opportunity
Altadena — 536 W Palm Street
45,000Lot SF (1.03 ac)
10Doors, Ministerial Now
RSOExempt (New Build)
20+At Full Buildout*

536 W Palm Street is a 45,000 SF (1.0331-acre) parcel in west Altadena — one of the largest single ownerships remaining inside the Eaton Fire burn area. It was improved before the January 2025 fire with a 4,881 SF, 5-unit apartment building (built 1942, 10 BR / 6 BA). The Assessor's 2025 roll now carries no improvement value — land value only, at $321,677 — consistent with a total-loss removal following the fire.

The most probable execution is also the simplest one, and it is available today with no map, no hearing, and no discretionary approval: rebuild the 5 units like-for-like under the County's fire-rebuild program, then add 5 detached ADUs under SB 1211, which since January 2025 permits up to eight detached ADUs on a lot with an existing multifamily dwelling, capped at the number of primary units. Five units plus five ADUs is 10 doors, entirely ministerial, on a site with room to spare at 45,000 SF.

Beyond that, the acreage carries genuine subdivision optionality. A conventional 4–6 lot tract map can be started today. And because the parcel is now vacant, R-1-zoned, and under 1.5 acres, it fits the profile the Starter Home Revitalization Act (SB 684 / SB 1123) was written for — a ministerial 10-lot subdivision with ADUs that do not count against the cap, taking the site to 20+ doors. That pathway is time-locked by a five-year tenancy lookback until approximately January 2030, and the Zoning section sets out exactly what it would take to unlock.

All newly constructed post-fire units are exempt from the LA County Rent Stabilization Ordinance, so the rebuild-plus-ADU program underwrites to market rents from day one.

*20+ doors under a 10-lot SB 1123 subdivision with one ADU per lot, available from approximately January 2030. The 10-door rebuild-plus-ADU program is available immediately. See Zoning and Buildout & Value. All rebuild, ADU, lot-yield, and statutory-eligibility assumptions to be verified with LA County Regional Planning.

Opportunity Highlights

  • 1.03 acres — 45,000 SF — among the largest remaining single parcels in the burn area
  • 10 doors, ministerial, available now — 5-unit like-for-like rebuild + 5 detached ADUs under SB 1211
  • No map, no hearing, no lookback on the rebuild-plus-ADU program
  • Conventional subdivision — 4–6 single-family lots, tract map can start today
  • SB 1123 pathway to 10 lots — ministerial, no CEQA, no hearing, no affordability (from ~Jan 2030)
  • 20+ doors with ADUs — ADUs do not count against the SB 1123 10-unit cap
  • RSO-exempt new construction — market-rate underwriting from lease-up
  • Severe supply shortage — 9,400+ structures lost to the Eaton Fire
Location Overview
West Altadena — 91001

Altadena is an established, unincorporated community at the base of the San Gabriel Mountains, immediately north of Pasadena. It has long been one of the San Gabriel Valley's most desirable residential enclaves — wide lots, mature streets, mountain views, and no city layer of process on top of County entitlement.

The subject sits on West Palm Street in west Altadena, the residential grid between Lincoln Avenue and Fair Oaks Avenue. This is a single-family neighborhood in character and in zoning, and it was among the areas most heavily impacted by the January 2025 Eaton Fire. The rebuild is now the defining activity on these blocks: debris clearance is substantially complete across the tract, and permitted single-family rebuilds are underway street by street.

The location offers direct access to Lincoln and Fair Oaks Avenues, Metro bus service into Pasadena and the wider LA County network, proximity to Huntington Hospital and Kaiser, and roughly a three-mile drive to Caltech and JPL — the anchor employers that underpin durable housing demand across the 91001 ZIP.

The defining market fact is supply. The Eaton Fire destroyed 9,400+ structures inside the burn perimeter, including an estimated 1,500+ rental units. The result is acute, multi-year scarcity of both deliverable housing and clean, buildable land — and a 1.03-acre assemblage-scale parcel under single ownership is now an exceptionally rare offering.

Location Details
CommunityAltadena (Unincorporated LA County)
ZIP91001
NeighborhoodWest Altadena (Lincoln / Fair Oaks)
Census Tract460301
Tax Rate Area07-608
Anchor EmployersCaltech, JPL, Huntington Hospital
CharacterEstablished single-family residential
ZoningLCR175 — R-1-7,500 (Single-Family)
Median HH Income [A]~$129,000 (Altadena CDP)
Median Home Value [A]~$1.2M (Altadena, pre-fire)
Population [A]~42,800 (Altadena CDP)

[A] Community-level figures for the Altadena CDP (U.S. Census / ACS). A property-specific 1-, 3-, and 5-mile demographic pull is available on request.

Property Details
536 W Palm Street
Site
APN5829-012-016
Lot Size45,000 SF (1.0331 ac)
LegalAltadena Map No. 3, Tract 11527, Lot 1 / Block 3 (ptn Lot 30)
ConfigurationStepped parcel — approx. 93.5' frontage on W Palm St, ~377' deep, widening to ~153.5' across the rear
ZoningLCR175 — R-1-7,500 Single-Family Residence
JurisdictionLA County (Unincorporated)
Map Coordinate19-F4
Pre-Fire Improvements
Year Built1942
Building SF4,881 gross
Units5 residential
Bedrooms / Baths10 BR / 6 BA (full)
Est. Unit Mix2 BR average (~975 SF avg)
Quality / HeatingGood / Floor-wall furnace
StatusEaton Fire loss (Jan 2025) — no improvement value on 2025 roll
Rebuild & Subdivision Rights
Like-for-Like5 units, ministerial
SF EntitlementUp to 5,369 SF (+10%)
Discretionary HearingNone required for rebuild
Permit PathwayCounty fire rebuild center (~30-day target)
Min. Lot Size (R-1)7,500 SF → 6 lots theoretical, 4–6 practical
Subdivision ProcessParcel Map (≤4 lots) / Tract Map (5+ lots)
Detached ADUs (SB 1211)Up to 5 — capped at primary unit count; no replacement parking required
ADU / JADU EligibleYes — state law, per lot if subdivided
Regulatory & Assessment
Rent Control (RSO)Exempt — new construction
AB 1482Exempt (<15 yrs once built)
SB 1123 Small-Lot SubdivisionFits on size & zoning — available ~Jan 2030 (5-yr tenancy lookback)
SB 9 Urban Lot SplitAvailable ~Jan 2028 (3-yr tenancy lookback)
Density Bonus / SB 423Possible — requires General Plan density verification
Debris / Site PrepCounty / USACE program eligible
2025 Assessed Value$321,677 (land only, Prop 13 base)
Annual Property Tax$5,090.02 (2025)
Verification Note
Fire-loss status is inferred from the Assessor's 2025 roll, which carries land value only with no improvement value — the standard treatment following a Governor-declared disaster loss. Rebuild rights, buildable unit counts, SF entitlements, and subdivision lot yield are based on the County's post-fire rebuild guidance, LCR175 (R-1-7,500) development standards, and state housing law as understood at the time of writing. Because the parcel is irregular and deep with limited street frontage, achievable lot count is highly dependent on access design (private drive vs. flag lots) and must be tested by a civil engineer. A buyer should confirm all entitlement and subdivision assumptions directly with the LA County Department of Regional Planning and Public Works. Phase I/II environmental clearance and debris certification are standard due-diligence items on fire-impacted sites.
Zoning & Entitlement Analysis
LCR175 (R-1-7,500) · Fire Rebuild + SB 1211 ADUs, Subdivision & SB 1123 Pathways

536 W Palm Street is zoned LCR175 — R-1-7,500 Single-Family Residence in unincorporated LA County, with a 7,500 SF minimum lot area. The pre-fire 5-unit building was a legal nonconforming use, and post-fire executive orders preserve the right to rebuild it. That creates an unusual duality: the site carries both a multifamily rebuild right and single-family subdivision capacity across 45,000 SF. These pathways are not mutually exclusive in value — a buyer acquires the certainty of the ministerial rebuild today while retaining subdivision optionality that grows over time.

Most Probable Pathway
Like-for-Like Rebuild + 5 Detached ADUs — 10 Doors, Ministerial, Available Now

The pathway a buyer is most likely to actually execute requires no subdivision map, no public hearing, no discretionary approval, and no waiting period. Step one is the County's fire-rebuild program: a confirmed ministerial right to rebuild the 5 pre-fire units like-for-like, up to 5,369 SF (a 10% expansion). Step two is SB 1211, effective January 1, 2025, which raised the detached-ADU allowance on a lot with an existing multifamily dwelling from two to as many as eight — capped at the number of primary units on the lot. Five primary units therefore support five detached ADUs.

The result is 10 doors, every one of them ministerially approved and every one exempt from the County RSO as new construction. SB 1211 also bars the County from requiring replacement parking for the ADUs. At 45,000 SF the site has ample room for five detached cottages behind a rebuilt 5-unit building — this is not a program straining against its lot. It is also the pathway with no statutory lookback of any kind: unlike SB 9 and SB 1123, nothing about the property's tenancy history delays it. On timing it is the fastest development route on the site — income beginning around mid 2028 and a saleable stabilized asset by roughly 2029, against 2030–2031 for a tract-map-plus-homes program and 2031–2032 for SB 1123. The sale-date and first-revenue analysis later in this section sets out that comparison in full.

Sequencing note: SB 1211 is written around a lot with an existing multifamily dwelling. The practical order is to permit and complete the like-for-like rebuild first, then permit the detached ADUs against the rebuilt building; whether the County will accept a concurrent application should be confirmed with Regional Planning at the outset, as it affects the construction schedule but not the ultimate door count.

Maximum-Value Pathway — Time-Locked
SB 1123 Small-Lot Subdivision — 10 Lots, 10 Homes, Plus ADUs

The Starter Home Revitalization Act (SB 684, 2023, as expanded by SB 1123, 2024, operative July 1, 2025) requires local agencies to ministerially approve a subdivision of up to 10 parcels and 10 residential units on a vacant single-family-zoned parcel of 1.5 acres or less in an urbanized area — no public hearing, no discretionary review, no CEQA, and no affordability requirement. Newly created parcels need only be 1,200 SF. Critically, where the local agency permits ADUs on the new parcels, those ADUs cannot be counted against the 10-unit cap.

On the physical facts, the subject is an unusually clean fit: 1.0331 acres (inside the 1.5-acre cap), R-1-7,500 single-family zoning, now vacant, and surrounded by urban residential uses. Ten parcels across 45,000 SF averages 4,500 SF each — nearly four times the 1,200 SF statutory minimum. That is 10 fee-simple homes plus up to 10 ADUs: 20+ doors, ministerially approved.

The constraint — and it is a hard one: SB 1123's definition of "vacant" excludes a site that contained housing occupied by tenants within the five years preceding the application — expressly including units since demolished or vacated. The subject's five apartments were tenant-occupied until the January 2025 fire, and the statute contains no natural-disaster exception. This pathway is therefore unavailable until roughly January 2030. It is real, it is large, and it is time-locked — and it is underwritten in this BOV as discounted optionality, not as the base case.

The Statutory Unlock Calendar

Because two separate state streamlining laws are gated by tenancy lookbacks that began running when the building burned, this parcel has a defined schedule on which its development rights expand. A buyer is not choosing one pathway — they are acquiring a sequence.

DateWhat UnlocksYieldApprovalGating Condition
Available nowLike-for-like fire rebuild (+10%)5 unitsMinisterialNone — confirmed right
Available nowRebuild + 5 detached ADUs (SB 1211)10 doorsMinisterialNone — no lookback applies
18–30 months
can file now
Conventional tract / parcel map4–6 lotsDiscretionary mapNone statutory — but discretionary approval, not guaranteed
~January 2028SB 9 urban lot split + duplexUp to 2×Ministerial3-year tenancy lookback clears
~January 2030SB 1123 small-lot subdivision + ADUs10 lots / 20+ doorsMinisterial5-year tenancy lookback clears
January 2030RTC 69 base-year transfer deadline (seller-side)5 years from the Eaton Fire

Three observations a buyer should draw from this table. First, nothing about the tenancy lookbacks constrains the most probable pathway. The rebuild-plus-ADU program reaches 10 doors ministerially, today, with no waiting period at all — a buyer who never touches a subdivision map still gets a 10-door RSO-exempt asset. Second, the wait on the subdivision pathways is shorter than it looks. A conventional tract map can be filed today but takes 18–30 months to record, and carries real discretionary risk; an SB 1123 application filed in January 2030 is approved ministerially within 60 days. The practical delta between finishing a 5-lot discretionary map and finishing a 10-lot ministerial one is roughly a year to eighteen months — for double the lots and materially less risk. Third, the pathways are sequential, not exclusive. The natural strategy is to rebuild and lease the 10-door program now, collect RSO-exempt market rents through the lookback period, and re-evaluate the SB 1123 subdivision in 2030 with the asset already producing.

PathwayUnits / LotsAffordabilityApprovalAvailableEntitlement Risk
1. Fire Rebuild (like-for-like + 10%)5 unitsNoneMinisterialNowLowest — confirmed right
2. Fire Rebuild + 5 Detached ADUs (SB 1211)10 doorsNoneMinisterial — no hearingNowLow — no lookback applies
3. Conventional SFR Subdivision (R-1-7,500)4–6 lotsNoneParcel / Tract Map18–30 mo (can file now)Moderate — discretionary; lot count at risk
4. Conventional Subdivision + ADU / JADU12–18 doorsNoneMinisterial (post-map)24–36 mo (can file now)Moderate
5. SB 1123 Small-Lot Subdivision + ADUs10 lots / 20+ doorsNoneMinisterial — no CEQA, no hearing~Jan 2030Timing — 5-yr tenancy lookback
Alt: SB 9 Urban Lot SplitUp to 2×NoneMinisterial~Jan 2028Timing — 3-yr tenancy lookback
Alt: Density Bonus / SB 4239–12+ unitsVLI or 100% affordableBy-right / streamlined~2 yrsHigh — GP density must be verified
Pathway 2 — Rebuild + 5 ADUs (Most Probable)
AuthorityCounty fire-rebuild program + SB 1211 (Gov. Code §66323)
Primary Units5 (like-for-like, nonconforming preserved)
Detached ADUs5 — up to 8 allowed, capped at primary unit count
Total Doors10
Max Building SF (primary)5,369 (+10%)
Replacement ParkingCannot be required for ADUs (SB 1211)
Affordable Set-AsideNone
RSOExempt (new construction)
ApprovalMinisterial — no map, no hearing, no lookback
Pathway 3 — Conventional SFR Subdivision
BasisR-1-7,500 min. lot area
Theoretical Yield6 lots (45,000 ÷ 7,500)
Practical Yield4–6 lots after access & setbacks
ProcessParcel Map (≤4) / Tract Map (5+)
Key Constraint~93.5' frontage → private drive or flag lots
Best forLot developer / homebuilder
Pathway 5 — SB 1123 (Maximum Value, ~2030)
LawSB 684 (2023) / SB 1123 (2024) — Starter Home Revitalization Act
Parcels / UnitsUp to 10 / up to 10
Min. New Parcel1,200 SF (subject averages 4,500 SF)
Max Site Size1.5 acres (subject is 1.0331)
Avg Unit Size Cap1,750 net habitable SF
ADUsDo not count toward the 10-unit cap where permitted locally
ApprovalMinisterial — no hearing, no CEQA, 60-day decision
AffordabilityNone required
Blocker5-year tenancy lookback — available ~Jan 2030
Alt — ADU Layer, SB 9 & Density Bonus
ADU / JADU per lot1 SFR + 1 ADU + 1 JADU (state law)
Doors, conventional map12 at 4 lots → 18 at 6 lots
SB 9 eligibilityR-1 zone qualifies on zoning
SB 9 blocker3-year tenancy lookback — available ~Jan 2028
Density BonusRequires a General Plan density permitting multifamily; R-1 base is 1 unit/lot
SB 423Available to a 100%-affordable sponsor, subject to the same verification
PositionUpside optionality, not underwritten in the base case

Subdivision Yield — Four Lots, Five, or Six?

The conventional subdivision pathway is the site's principal alternative to the rebuild-plus-ADU program, and its value turns almost entirely on lot count. That number is not yet established, and it deserves a direct treatment rather than an assumption.

On gross area the arithmetic is exact and unforgiving: 45,000 SF ÷ 7,500 SF minimum lot area = 6.00 lots. There is zero margin. Every square foot of the parcel would have to count toward lot area for six to work, leaving nothing for access.

The parcel's shape works in the seller's favor here. It is not a uniform rectangle. Per the recorded legal description it is a stepped configuration: roughly 93.5 feet wide for the first 170 feet from the W Palm Street frontage, then widening westward by 60 feet to approximately 153.5 feet across the rear 207 feet — about 377 feet of total depth. A narrow neck opening into a wide rear body.

That is close to the ideal geometry for a central private drive, which is the standard and expected solution for a parcel of this depth. The drive runs south from W Palm Street through the neck — where the remaining 69.5 feet of width still supports one conforming street-fronting lot alongside it — and opens into the rear body, which at 153.5 feet across accommodates lots on both sides of the drive at roughly 64.8 feet of width each. Two-sided frontage off a single drive is far more land-efficient than stringing flag lots down one edge, and it produces regularly shaped, marketable lots rather than awkward remnants.

Central Drive ConfigurationLength × WidthLand ConsumedRemainingLots at 7,500 SF
Neck only, hammerhead turnaround200 × 20 ft4,000 SF41,000 SF5.47
Neck into rear body — likely configuration250 × 24 ft6,000 SF39,000 SF5.20
Through the rear body300 × 24 ft7,200 SF37,800 SF5.04
Wide drive with cul-de-sac bulb300 × 28 ft8,400 SF36,600 SF4.88
Full depth, conservative377 × 24 ft9,048 SF35,952 SF4.79

Illustrative Layout — Central Drive into the Rear Body

W PALM STREET PRIVATE DRIVE TURNAROUND 1 street frontage 2 3 4 5 93.5′ frontage 153.5′ across the rear body 170.05′neck 207′rear body 60′ step west 377′ total depth N Buildable lot 24′ private drive & turnaround

Illustrative only — not a survey and not a proposed tentative map. Boundary dimensions are taken from the recorded metes-and-bounds description; lot lines, drive alignment and turnaround are schematic and drawn to show configuration, not to establish areas. Individual lot sizes in this arrangement run close to the 7,500 SF minimum, which is precisely why the yield must be confirmed by a civil engineer before it is relied upon.

Across every reasonable drive configuration the answer is five lots. The range runs 4.79 to 5.47, clustering at 5.0–5.2 for the configurations most likely to be built. Four lots results only if the drive must run the full depth at generous width; five is achievable under normal design, and is the base case carried throughout this BOV.

Six lots remains the open question, and it is worth $373,000. Six requires the entire 45,000 SF to count toward lot area, which means the drive must be carried as an easement over the lots rather than as a separate common lot or lettered parcel. Whether LA County permits that treatment under Title 22 is the single most valuable question to put to Regional Planning. Two further constraints must be tested at the same time: minimum lot width (typically 50–60 ft in R-1-7,500) against the 64.8 ft available on each side of a centered drive, and LA County Fire's turnaround requirement for a dead-end drive of this length, which can consume meaningfully more area than a simple hammerhead.

Dimensions are reconstructed from the recorded metes-and-bounds description and are approximate; the reconstructed area runs modestly above the 45,000 SF of record, so the closing course and exact boundary geometry require survey confirmation. All yield figures above are planning-level and subject to a civil engineering study.

The Single Largest Unverified Assumption
This BOV models five lots as the conventional-subdivision base case. That figure has not been tested by a civil engineer and has not been confirmed with LA County. A yield study — typically a few thousand dollars and a few weeks — would resolve four versus five versus six, establish whether a parcel map or a tract map applies, and convert the largest soft assumption in this analysis into a hard number. We would recommend commissioning one before going to market: a buyer's engineer will run it regardless, and it is far better to have the answer first.

Subdivision Process & Timeline

Lot count also determines which map process applies, and the two are materially different in cost, risk, and duration. The threshold is four: four or fewer lots proceeds by Parcel Map; five or more requires a Tract Map, which carries a Regional Planning Commission hearing and heavier CEQA exposure.

 Parcel Map — 4 lots or fewerTract Map — 5 or more lots
Approval bodyOften administrative / Subdivision CommitteeRegional Planning Commission hearing
CEQACommonly a Class 32 infill exemptionExemption or Mitigated Negative Declaration (+6–12 mo)
Discretionary riskLowerHigher — conditions, appeals, denial possible
Tentative map to approval12–18 months18–30 months
Final map, improvement plans, bonds+6–12 months+9–15 months
Total to Recorded Map~18–24 months~24–36 months
Then: building permits3–6 months (faster via the County fire-rebuild permit center)
Then: vertical construction12–18 months

What Each Lot Count Is Worth

Indicated land value under a build-and-sell program — 2,100 SF homes at $400/SF all-in, 15% developer margin, 5% selling costs — across the plausible yield range and three pricing assumptions.

Lot CountAt Today's Pricing2-Yr Delivery, 5%/yr2-Yr Delivery, 10%/yrBreakeven Home Price
4 lots — Parcel Map$603,938$1,112,741$1,646,366$1,812,693 ($863/SF)
5 lots — Tract Map (base case)$839,923$1,475,926$2,142,957$1,699,071 ($809/SF)
6 lots — Tract Map (upside)$1,085,907$1,849,111$2,649,549$1,621,259 ($772/SF)

Each additional lot is worth roughly $363,000 to $373,000 of land value. Note the tension the table exposes: the four-lot parcel map is the faster and lower-risk process, but at $863 per SF it does not support the recommended price at today's observed new-construction pricing. The five- and six-lot tract maps do — but only on a two-year delivery with appreciation, and only after clearing a Commission hearing. This is the central trade-off in the conventional subdivision pathway: speed and certainty on one side, value on the other.

What It Would Take to Unlock SB 1123 Sooner

Because SB 1123 is the site's largest single source of value, the question of whether the five-year lookback can be shortened deserves a direct answer rather than a footnote. The operative statutory language is narrow and deliberate. A site is excluded from the definition of "vacant" if it held:

"housing occupied by tenants within the five years preceding the date of the application, including housing that has been demolished or that tenants have vacated prior to the submission of the application"

Two features of that sentence govern everything below. The lookback is measured backward from the application date, not from approval or acquisition. And it reaches housing that is already gone — the words "or that tenants have vacated" capture a building destroyed by fire just as surely as one taken down by a demolition permit.

What Could Genuinely Move the Date
Establish actual last-tenancy dateThe one material lever. January 2025 is an assumption drawn from the fire date, not an established fact. If the last remaining tenant vacated earlier — a realistic possibility in a 1942 building held by an out-of-area family trust — the unlock moves earlier by the same margin. Evidence: rent roll history, Schedule E for 2021–2024, utility accounts, and the insurance claim file, which will enumerate occupied units. Note the test is the last tenant across the whole property, not per unit.
Confirm occupants were "tenants"Family members occupying without a tenancy are not tenants. All five units would need to qualify, which is unlikely — but it falls out of the same document request at no additional cost.
Legislative amendmentNo casualty or disaster exception exists anywhere in the statute. Given the political salience of the Eaton and Palisades rebuild, one is plausible and would accelerate this pathway materially. It is worth tracking; it is not something to underwrite.
Two-step map (counsel question)The pre-fire building occupied roughly 4,881 SF of a 45,000 SF site — most of this parcel never held housing. Whether a never-improved remainder parcel, created by a conventional map, could independently qualify as "vacant" is a question for land-use counsel. The text is not obviously against it and no anti-circumvention clause appears in the Act, but agency treatment of parent-parcel history is untested and the conventional map consumes 18–30 months regardless — so the timing gain is modest against real legal risk.
What Does Not Work
"It burned — it wasn't demolished"The statute is disjunctive: demolished or vacated. The tenants vacated. This reading fails on the plain text and should not be relied on.
Rezone to multifamily and use the original SB 684 pathwayThe identical protected-housing restriction applies to both the multifamily and single-family pathways under the same code section. A zone change buys nothing here — and would itself be discretionary and slow.
Sell to a new owner to reset the clockThe restriction attaches to the property's tenancy history, not to ownership. A buyer inherits the same date.
Wash the history through a lot line adjustmentReconfiguring boundaries does not erase what stood on the land. Distinguish this from the two-step question at left, which turns on a genuinely never-improved remainder, not on redrawing lines around the former building footprint.
The Practical Conclusion
A buyer does not need to solve this. The most probable pathway — the 5-unit rebuild plus 5 detached ADUs, 10 doors — is fully ministerial, available immediately, and subject to no lookback of any kind. The conventional 4–6 lot tract map is likewise unaffected and can be started the day escrow closes. SB 1123 is upside layered on top of a program that already works, and it is priced in this BOV as discounted optionality at a 40% weight, not as a contingency the deal depends on. The single action worth taking is the cheapest one: request the tenancy records and establish the real date. If it proves earlier than January 2025, every buyer in the pool is holding a shorter option than they assumed.

Two further items remain open regardless of timing. LA County's ADU election: SB 1123 bars a jurisdiction from counting ADUs toward the 10-unit cap, but permitting them on the newly created parcels is at the agency's option — the County's position must be confirmed with Regional Planning. Statutory drift: the Starter Home Revitalization Act has been amended in each of its first two years and may be amended again; current law must be verified at the time of application. Nothing in this section is legal advice, and a buyer intending to rely on SB 1123 should engage land-use counsel before removing contingencies.

Lot counts and unit counts are planning-level estimates based on LA County post-fire rebuild guidance, LCR175 (R-1-7,500) standards, state ADU law, SB 9 (Gov. Code §65852.21), the Starter Home Revitalization Act (SB 684 / SB 1123, Gov. Code §65852.28 and Subdivision Map Act Ch. 4.5), and California density-bonus law (Gov. Code §65915). The fire-rebuild right is the most certain of these; conventional subdivision yield is subject to a civil engineering study and County map approval; SB 1123 eligibility is subject to the tenancy lookback described above; and any density-bonus pathway depends on the General Plan land use designation. All to be verified with LA County Regional Planning.

Sale Timing & the Cost of Waiting
When the Seller Closes · What Each Pathway Costs in Time

Two timing questions decide how this asset is brought to market: when the seller can actually close, and what it would cost to wait and sell a processed parcel instead. This section answers both. The short version is that the land transacts now under every pathway, and that every alternative to selling as-is requires the land to appreciate substantially just to break even.

Set the routes against the calendar and the case for the most probable pathway becomes clear. The rebuild-plus-ADU program is the only development route that requires no map, no hearing, no CEQA, and no waiting period of any kind. All dates below run from September 2026 and include the permitting step separately from construction.

The Land Itself Transacts Now
Every pathway in this report is available to a buyer on close of escrow. The land carries no entitlement condition, no pending application, and no approval a buyer must wait for before taking title — it is a clean, unencumbered R-1 parcel with a confirmed ministerial rebuild right attached. The timelines below are what a buyer elects to take on after closing, not delays to the sale. A 60–90 day marketing period and a standard escrow put a buyer in title in Q1 2027.

Seller's Path to Closing

MilestoneDurationTarget
Listing agreement executed, marketing launchedSept – Oct 2026
Marketing period — offers and best-and-final60–90 daysOct – Dec 2026
Purchase agreement executedNov – Dec 2026
Buyer due diligence30–45 daysDec 2026 – Jan 2027
Close of Escrow — Seller's Sale Date30–45 daysQ1 2027

Roughly four to six months from listing to close. Fire-lot transactions in this submarket are typically all-cash or insurance-funded, which compresses due diligence and financing contingencies relative to a conventional escrow.

Option 1 — Sell As-Is: the Date Does Not Move

Pathway a Buyer ElectsSeller's Sale DateYieldBuyer's Entitlement BurdenBuyer's Completion
5 units + 5 ADUs (SB 1211)Q1 202710 doorsNone — ministerial permit, ~30-day County target~2029
4-lot Parcel Map — sell lots entitledQ1 20274 lots18–24 months, largely administrative~mid 2028
4-lot Parcel Map + build homesQ1 20274 homes18–24 months, then 15–24 mo build2029 – 2030
5–6 lot Tract Map — sell lots entitledQ1 20275–6 lots24–36 months, Commission hearinglate 2028 – late 2029
5–6 lot Tract Map + build homesQ1 20275–6 homes24–36 months, then 15–24 mo build2030 – 2031
SB 1123 — 10 lots + homesQ1 202710–20 doorsBlocked to ~Jan 2030, then 60 days ministerial2031 – 2032

The repeated column is the point. Selling as-is, the seller closes in Q1 2027 under every pathway. Entitlement time, construction time, and the January 2030 SB 1123 lookback are all risks and costs the buyer takes on after title transfers — none of them delays the sale, and none is a condition the seller must satisfy to close. The property is sold unentitled and as-is; what a buyer does with it afterward is priced into the offer, not into the escrow.

Option 2 — Entitle First: the Sale Date Follows the Entitlement Calendar

The seller is not obliged to transfer that risk. The trust could carry a subdivision entitlement itself and bring a recorded map to market, selling at a higher price to a buyer who no longer has to wait or gamble on approval. In that case the seller's sale date is no longer Q1 2027; it moves out to match whichever map is pursued.

Note what is not on this list: the 5-unit rebuild plus 5 ADUs. That right is already confirmed and ministerial — it transfers with the land at close and requires no application, no map and no waiting. Selling as-is is selling the 10-door opportunity. It is the baseline row below, not a strategy that costs time.

The question is whether the premium the market pays for a processed parcel exceeds what the delay costs. Each row below shows the full cost of waiting — consultants and County fees, holding costs, and the opportunity cost of not having net sale proceeds working at 5.50% — and the price the land would then have to fetch simply to break even against selling today.

Seller's Pre-Sale WorkTimeSeller's Sale DateTotal Cost of Waiting [B]Land Must Then FetchPremium Required
None — sell as-is
Includes the confirmed 5-unit rebuild right and 5 SB 1211 ADUs — already ministerial, nothing to apply for
Q1 2027$1,495,000— baseline
4-lot Parcel Map recorded18–24 mo~mid 2028~$389,000$1,916,000+28.2%
5–6 lot Tract Map recorded24–36 molate 2028 – late 2029~$582,000$2,125,000+42.1%
SB 1123 map — 10 lotsblocked to Jan 2030~mid 2030~$712,000$2,264,000+51.5%

[B] Consultant, engineering and County fees, plus holding costs, plus replacement-property income forgone over the delay period at a 6.00% cap (see below). Entitlement cost figures are planning-level estimates and should be quoted by a civil engineer and land-use consultant before this option is pursued. A final map may additionally require improvements to be constructed or bonded, which is not included above.

The Cost of Waiting Is Not Abstract — It Is Rent Not Collected
Selling as-is places $1,382,875 into a 1031 exchange, and a replacement apartment acquired at a 6.00% cap begins producing roughly $82,972 per year — about $6,914 per month — within 45 to 180 days of closing, with the capital gain deferred rather than recognized. That income starts in 2027 and runs continuously thereafter.

Entitling first produces the mirror image: no rent at all, while the trust continues to pay property taxes, insurance and consultant invoices on a vacant parcel. The land is not merely sitting during that period — it is costing, on both sides of the ledger at once. That is the largest single component of the premiums required above, and it is why they climb so steeply with time.
Pre-Sale WorkDelayReplacement Income ForgoneHolding Costs PaidNet SwingRTC 69 Window [C]
None — sell as-is$0 — income begins 2027$0Open
4-lot Parcel Map18 mo($124,459)($15,000)($139,459)Open
5–6 lot Tract Map30 mo($207,431)($25,000)($232,431)Closing — tight
SB 1123 map — 10 lots40 mo($276,575)($35,000)($311,575)MISSED

[C] The RTC Section 69 Prop 13 base-year transfer must be completed within five years of the January 2025 Eaton Fire — a January 2030 deadline. Replacement income assumes an all-cash acquisition at a 6.00% cap. Consult a CPA on all tax matters.

The final column carries a consequence that is easy to miss. Waiting for SB 1123 does not merely delay the sale — it forfeits the RTC Section 69 base-year transfer entirely. A mid-2030 closing lands past the January 2030 deadline, so the trust would arrive holding a valuable ten-lot entitlement and no remaining ability to carry its Proposition 13 assessment into a replacement property. A five- or six-lot tract map finishing in late 2029 fits inside the window, but with little margin for the appeal or continuance that a Commission hearing can produce.

The Return on Waiting

If the trust holds the land, the land appreciates. But holding also gives up the rent a 1031 replacement apartment would have paid. The table below runs both for each subdivision strategy — the 5-unit-plus-5-ADU program is excluded because it requires no waiting at all — and ends in the only number that matters: the return per year earned by waiting. Land is shown appreciating at 5% a year; the replacement apartment is acquired at a 6.00% cap.

StrategyTimelinePrice Point at SaleAppreciation from Waiting1031 Rent Missed (total, 6% cap)Net Appreciation from WaitingROI per Year
4-Lot Parcel Map18 mo$1,608,515+$113,515($124,459)($10,944)−0.49%
5–6 Lot Tract Map30 mo$1,688,941+$193,941($207,431)($13,490)−0.36%
SB 1123 — 10 Lots40 mo$1,759,026+$264,026($276,575)($12,549)−0.25%

Price point at sale is today’s $1,495,000 compounded at 5% a year over the wait, and reflects appreciation only — it does not include any premium for the entitlement itself, which is addressed separately below. Rent missed is net proceeds of $1,382,875 at a 6.00% cap, or $82,972 a year. ROI per year is the net divided by the $1,495,000 land value, annualized.

Every Strategy Returns a Negative — Here Is Why
At a 6.00% cap, the exchange out-earns the land:

A 1031 replacement apartment at a 6.00% cap on $1,382,875 pays $82,972 a year.
Land appreciating at 5% a year on $1,495,000 earns $74,750 a year.

The exchange wins by roughly $8,200 a year. That is why every net in the table is negative and every ROI sits between −0.25% and −0.58%. Waiting does not pay for itself on appreciation alone — the trust would be giving up a higher-yielding income stream to hold a lower-yielding asset. The gap is small, but it runs the wrong way, and it runs the wrong way before a single dollar of entitlement cost is spent.

The Same Table if Land Moves Faster — or Not at All

StrategyNet at 0%/yrROI/YrNet at 5%/yrROI/YrNet at 10%/yrROI/Yr
4-Lot Parcel Map($124,459)−5.55%($10,944)−0.49%+$105,307+4.70%
5–6 Lot Tract Map($207,431)−5.55%($13,490)−0.36%+$194,812+5.21%
SB 1123 — 10 Lots($276,575)−5.55%($12,549)−0.25%+$282,502+5.67%

The pattern is clean. If land is flat, waiting costs 5.55% a year — precisely the rent given up, with nothing to offset it. At 5% it is roughly break-even, tilted slightly negative. At 10% waiting earns 4.3% to 5.7% a year over what the exchange would have produced. Land would need to appreciate faster than about 5.5% a year for waiting to earn anything at all, before entitlement costs.

And Entitling Is Not Free

The tables above measure appreciation against rent only. They exclude what it costs to obtain the entitlement, which is the entire reason for waiting. Adding it back gives the real hurdle:

StrategyNet at 5% AppreciationCost to Entitle & HoldAdded CommissionTrue Net Cost of WaitingEntitlement Must Add
4-Lot Parcel Map($10,944)($265,000)($8,514)($284,458)$307,522
5–6 Lot Tract Map($13,490)($375,000)($14,546)($403,036)$435,714
SB 1123 — 10 Lots($12,549)($435,000)($19,802)($467,351)$505,244

The final column is the true net divided by 0.925, because 7.5% of any additional sale price goes to commission and closing costs. Entitlement cost figures are planning-level estimates and should be quoted by a civil engineer and land-use consultant before this option is pursued.

This is the number that decides it. Appreciation roughly offsets the rent given up, so the real cost of waiting is essentially the cost of entitling — and the entitlement has to be worth more than that to a buyer.

None of these is comfortable. A four-lot parcel map must add $307,522 of value against roughly $265,000 of cost — achievable, but thin, and it yields the fewest lots. A tract map must add $435,714, earned against a Commission hearing that can condition, delay, or deny it. SB 1123 must add $505,244 while also forfeiting the RTC 69 base-year transfer. Against all of them sits the as-is sale, which closes in Q1 2027 with the 10-door rebuild right already attached and no capital at risk.

One Caution on the Appreciation Numbers
The 5% and 10% figures are illustrative, not forecasts. The Altadena burn-area land market is thin, driven by a one-time supply shock, and has no long price history to project from — the 10% figure borrows a home-price rate observed on one builder’s identical floorplan over nine months, which is not the same as a land-price series. Land here could equally be flat or lower in three years, in which case waiting costs 5.55% a year with nothing to show for it. Holding is a directional bet on Altadena land, made with the entire value of the asset. Selling and exchanging converts that bet into diversified, income-producing replacement property with the capital gain deferred.

Every one of these requires the land to appreciate substantially just to break even. The cheapest, a four-lot parcel map, needs a 28% premium after roughly $389,000 of spend and 18 to 24 months. None of them is a modest adjustment to the timeline; each is a multi-year commitment of capital and risk in pursuit of a price the market has not yet demonstrated it will pay for entitled Altadena land.

The map options are a much harder case. A tract map requires the land to fetch a 42% premium after roughly $582,000 of spend and up to three years of waiting — and the risk runs the wrong way. A map that is conditioned, appealed, or denied can leave the parcel worth less than it is today, because a public record of a failed application is itself a disclosure item. Selling as-is transfers that risk entirely to a buyer who is in the entitlement business and is equipped to price it. SB 1123 is the most extreme version of the same trade: the largest premium required, on the longest wait, with the entire value dependent on a statute that has been amended in each of its first two years.

Read down the table and the breadth of the offering is the point: a buyer can be collecting rent in roughly eighteen months, selling entitled lots in under two years, or delivering finished homes in three to four — all from the same parcel, all elected after closing. That optionality is what widens the buyer pool well beyond a typical single-use land trade, and it is priced into the recommendation.

Note also that a subdivision buyer has two distinct exits, not one. Entitled lots can be sold as soon as the map records, with no vertical construction ever carried — roughly eighteen months earlier than delivering finished homes, and at materially lower risk. A buyer who wants the entitlement play without the building business has a clean route to it.

Reading the Structures — What a Buyer Is Acquiring
The rebuild-plus-ADU program remains the most probable pathway, and the reason is timeline and certainty rather than raw value. It reaches ten RSO-exempt doors with a ministerial permit, no discretionary approval, no lookback, and no possibility of a hearing going badly — roughly one to two years ahead of a conventional tract-map-plus-homes program and two to three years ahead of SB 1123 — and it is the only development route that produces income before it produces a sale. For a buyer who wants the site producing rather than sitting in entitlement, it is the answer — and it is the pathway most likely to be underwritten by the owner-rebuilder, insurance-funded and 1031 buyers active in this submarket.

The subdivision routes are worth more but cost time and carry discretionary risk. A five-lot tract map indicates $1.48M of land value on a two-year delivery, against a Commission hearing, CEQA review, and 24–36 months before a map records — the pathway a lot developer or homebuilder underwrites. A four-lot parcel map is meaningfully faster and lower-risk but does not clear the recommended price at today's pricing. SB 1123 produces by far the most value and the least approval risk, but not before January 2030.

These pathways are sequential, not exclusive. Nothing prevents rebuilding the ten doors now, holding them as RSO-exempt market-rate income, and revisiting a subdivision later — and the lookback that blocks SB 1123 expires while that building is still new. A buyer is acquiring a schedule of expanding rights, not a single fixed use.
Buyer Profile & Anticipated Objections
Target Buyers & Data-Backed Responses

Target Buyer Profile

Lot Developers & Homebuilders

The primary buyer. An acre of R-1 land in Altadena that maps to 4–6 lots, in a market where finished rebuild parcels clear at $475K–$590K each, is the single scarcest product type in the burn area.

Merchant & Local Multifamily Developers

Builders who want the certainty of a fully ministerial 10-door program today — a 5-unit like-for-like rebuild plus 5 detached ADUs under SB 1211 — with no map, no hearing, no affordable set-aside, and RSO exemption from lease-up.

Owner-Rebuilders / Insurance-Funded & 1031 Buyers

Displaced owners deploying insurance proceeds into a like-for-like replacement they can rebuild ministerially and hold long-term as market-rate income, or an owner-user seeking a 1.03-acre Altadena estate compound.

Affordable & Mission-Driven Sponsors

Nonprofit and SB 423 sponsors are active buyers across the burn area — a full acre under one ownership is the kind of site that supports a meaningful project, subject to General Plan density verification.

The combination of size, confirmed rebuild rights, RSO exemption, and subdivision optionality broadens the buyer pool well beyond a typical single fire-lot trade.

Anticipated Objections

"A subdivision takes years and the map isn't approved."

Correct — and the price reflects it. The recommended list is set at roughly 55% of the gross finished-lot value, a full merchant discount for map risk, infrastructure, and carry. A buyer who wants zero entitlement risk still has the 5-unit ministerial rebuild available on day one.

"The frontage is narrow — can it really yield 5 or 6 lots?"

The honest answer is that yield depends on access design. We underwrite 5 lots as the base case and show the 4-lot and 6-lot sensitivities explicitly. At 4 lots the residual still supports a price in the low $1M range — the downside case is modeled, not glossed over.

"Construction costs are high right now."

True — Altadena construction runs $350–$400/SF all-in for production work, and this analysis underwrites the upper end at $400/SF. That is precisely why product size matters: Set C shows sale price is far less elastic to house size than cost is, so the margin is made by building more, smaller homes rather than fewer, larger ones. It is also why sale prices rising 10.7% annualized on identical product matter more than the cost number itself.

"It's a fire lot — financing and insurance are hard."

The site is eligible for the County / USACE debris program and the streamlined fire-rebuild permit center. Most buyers transacting in this market are insurance-funded or all-cash, which is reflected in the pricing and the breadth of the buyer pool.

"603 Villa Zanita on the same block sold at $23/SF — why is this $33?"

Villa Zanita is 20,037 SF, under half the subject's size and short of the 22,500 SF needed for even a three-lot R-1-7,500 split — so it tops out at two lots. It carried no multifamily rebuild right, and it took 239 days to sell. The subject is 45,000 SF with a confirmed 5-unit ministerial rebuild, a 10-door SB 1211 program, and a 4–6 lot map. Compare instead to 412 W Altadena Dr, marketed on two-to-three-lot potential: it cleared in 8 days at $44.65/SF, and the subject is priced 25.6% below it.

"The SB 1123 upside is four years out — why should I pay for it today?"

You are paying for part of it, not all of it. The recommended price reconciles a 60% weight on pathways available now against a 40% weight on the SB 1123 residual — the price sits well below what a 10-lot ministerial map would support and only 18% above the conventional 5-lot residual. Meanwhile the wait is not dead time: the 5-unit rebuild can be built and held as RSO-exempt market-rate income throughout, and a conventional map takes 18–30 months anyway. The optionality is priced at a discount precisely because it is deferred.

Sale Comparables
Three Comp Sets — What the Subject Is, Produces, and Ultimately Sells For

This valuation uses three distinct sets of closed sales, and the distinctions matter. Set A is the direct peer group: large, single-family-zoned Altadena land parcels — what the subject is today. Set B is the individual Altadena rebuild parcel — what a subdivision of the subject would produce as finished lots, and therefore the input to the residual analysis. Set C is completed new-construction homes — what a builder ultimately sells, which sets the ceiling on everything below it. Reading any set in another's role produces a badly wrong number.

Set A — Direct Comparables: Large Altadena R-1 Land

AddressAPNLot SFZoningSale Price$/Land SFSold
412 W Altadena Dr5829-019-02327,545LCR175$1,230,000$44.65Jul 2025
3430 Chaney Trl [1]5831-005-00627,978LCR175$885,000$31.63Feb 2026
603 Villa Zanita St (same block)5829-012-01020,037LCR175$470,000$23.46Jan 2026
Set A — three LCR175 parcels, avg 25,187 lot SF$2,585,000$33.25 avg
Excluded — 3748 Sunset Ridge Rd (APN 5863-028-006), 21,382 SF, $700,000, $32.74/SF, sold May 2026. Zoned LCR110 (R-1-10,000), not LCR175, and classified in County records as Resid-Planned / PUD — a lot inside the gated La Vina community with an HOA, guard gate, and shared amenities. Different zone, different product, and no subdivision potential. Shown for completeness; excluded from the conclusion. Notably, it prices at $32.74/SF — within a dollar of the Set A average.

[1] 3430 Chaney Trail appeared twice in the MLS pull under separate listing numbers (CV25198320MR and P1-21101PF). Public records confirm a single transaction — $885,000, recorded 02/18/2026. It is counted once.

These three trades are the most direct evidence available on the subject's value. All are LCR175 — identical zoning to the subject — all are large Altadena land parcels sold for their land value, and all closed between July 2025 and February 2026. They bracket a wide range, $23.46 to $44.65 per land SF, and that spread is itself informative: it tracks subdivision potential. The top of the range, 412 W Altadena Drive at $44.65/SF, was marketed explicitly on the basis that the 27,545 SF site could be split "into 2 or possibly 3 parcels," and it cleared at 94.6% of ask in 8 days. The bottom, 603 Villa Zanita Street at $23.46/SF, sat 239 days on market.

603 Villa Zanita is the comparable a buyer's broker will lead with, and it deserves a direct answer. It is APN 5829-012-010; the subject is 5829-012-016 — the same block. At 20,037 SF it is under half the subject's size and short of the 22,500 SF needed for a three-lot R-1-7,500 split, which caps its yield at two lots. It carried no multifamily rebuild right. And it took 239 days to sell. The subject is 45,000 SF with a confirmed 5-unit ministerial rebuild right, a 10-door SB 1211 program, and a 4–6 lot conventional map. The premium over Villa Zanita is earned on yield and on entitlement, not asserted.

Averaging the three LCR175 trades gives $33.25 per land SF. Applied to 45,000 SF that indicates $1,496,000 — and the recommended list price of $1,495,000 sits essentially on that number. The subject is larger than every comp in the set, which normally argues for a per-SF discount; that pressure is offset by the fact that it is also the only parcel in the set carrying multifamily rebuild rights and a genuine path to five or more lots.

Set B — Finished-Lot Benchmark: Individual Altadena Rebuild Parcels

AddressUseLot SFZoningSale Price$/Land SFSold
2490 Lake AveCommercial / Office — priced as land4,119LCC3$475,000$115.32Dec 2025
916 Marcheta StMultifamily Land — 4-Unit Fire Rebuild (Phase 2 cleared)5,406C-3 / LCPYYY$515,000$95.27Apr 2026
915 Beverly WayMultifamily Land — 5-Unit Fire Rebuild (Phase 1 cleared)6,625R-3-P / LCPYYY$590,000$89.09Aug 2025
Finished-lot benchmark — price per individual Altadena parcel$475K–$590K

Set B answers a different question: what does one buildable Altadena parcel cost? Three arm's-length trades between August 2025 and April 2026 cleared at $475,000, $515,000, and $590,000. That is the number a lot developer uses to price the finished lots a subdivision of the subject would produce, and this BOV underwrites $525,000 — the midpoint — in the conventional subdivision residual.

Set B's per-SF figures must not be applied to the subject. These parcels run 4,119 to 6,625 SF and price at $115.32, $95.27, and $89.09 per land SF — a steep declining curve even across that narrow size band. The subject is 45,000 SF, roughly 8.4× the average. Applying $99.89/SF would imply $4.5M, a figure with no support anywhere in this market. Set A exists precisely to prevent that error, and the gap between the two sets — $33.25/SF against $99.89/SF — is the clearest available measure of how hard per-SF land pricing falls with parcel size in this submarket.

The subject's own assessment is not a market indicator. The 2025 roll carries a land value of $321,677. That is a Prop 13 base-year figure on a parcel held in the Hartwick Family Trust, not a current market opinion, and it should be read only as evidence that the improvements were removed from the roll following the fire.

Set C — New-Construction Resale: What a Builder Sells

Set C is the exit price for a for-sale development program, and it is the ceiling that governs what any builder can pay for land. Six of the seven sales below are Warmington Residential's "The Oak Grove of Altadena" — Tract 72939 on E Palm Street, the same street as the subject.

AddressPlanLiving SFLot SFSale Price$/SFSold
195 E Palm StWarmington Plan 22,8575,185$1,650,000$578Oct 2025
173 E Palm StWarmington Plan 22,8574,572$1,699,900$595Apr 2026
193 E Palm StWarmington Plan 12,6538,425$1,725,000$650Apr 2026
197 E Palm StWarmington Plan 22,8575,534$1,749,900$613May 2026
175 E Palm StWarmington Plan 12,6534,453$1,649,900$622May 2026
177 E Palm St (most recent)Warmington Plan 22,8578,621$1,780,900$623Jul 2026
3010 Highview Ave [2]Ocean Development2,1106,484$1,600,000$758Dec 2025
New-construction range — Altadena, 2,110–2,857 SF$1.65M–$1.78M$578–$758

[2] 3010 Highview is west of Lake and reports a 1948 year built with tax and MLS square footage nearly identical — consistent with a renovation or restoration rather than a ground-up rebuild. Treated as an indication of west-of-Lake pricing, not as a new-construction cost comparable.

The Strongest Single Exhibit
Identical Product, Four Sales, Prices Rising 10.7% Annualized

Warmington's Plan 2 — the same 2,857 SF floorplan — sold four times on the same street between October 2025 and July 2026:

$1,650,000  →  $1,699,900  →  $1,749,900  →  $1,780,900

+7.9% in nine months — +10.7% annualized, with product, builder, and street held constant. This is the cleanest same-product price series available in the post-fire Altadena market, and it is the single most important input to any development underwrite on the subject: a builder entitling today delivers in 2028–29 and prices to that market, not this one.

Two secondary observations. Lot size carries a measurable premium within the project — the same Plan 2 on a 4,572 SF lot sold at $1,699,900 while an 8,621 SF lot reached $1,780,900, roughly $20 per additional lot SF. And total price is far less elastic to house size than $/SF suggests: from 2,110 SF to 2,857 SF, sale prices move only from $1.60M to $1.78M while $/SF falls from $758 to $623. The practical implication for the subject is direct — a builder maximizes margin by building more, smaller homes rather than fewer, larger ones, which is precisely the program SB 1123 enables.

Comp Set Note
All three sets are closed sales; no active listings are relied upon, because the available Altadena on-market inventory is commercial and mixed-use land rather than R-1 single-family land and is not comparable to the subject. Set A is drawn from a TheMLS closed-sales pull dated September 2026, verified against public records for APN, lot size, zoning, and recorded price; Set B comprises the LAAA Team's verified Altadena fire-rebuild land trades; Set C combines TheMLS and public-record sale data for Warmington's Tract 72939 and one west-of-Lake resale. No arm's-length sale of a one-acre-plus Altadena parcel has closed in the post-fire market — the largest Set A comp is 27,978 SF, still well under the subject's 45,000 SF — so a size adjustment remains a matter of judgment rather than direct observation. All six Warmington sales are east of Lake Avenue; the subject is west, and east Altadena has historically carried a premium, so Set C should be discounted before being applied to the subject. No new-construction comparable below 2,110 SF was available, so pricing for the smaller homes contemplated under SB 1123 is extrapolated from the observed size gradient rather than directly observed. Lot dimensions, access, topography, and subdivision feasibility for 603 Villa Zanita have not been independently verified.
Development Buildout & Value
What Can Be Built — and What It Supports

1. What Can Be Built

The 45,000 SF R-1-7,500 parcel supports a materially wider range of programs than a typical fire lot. The like-for-like rebuild of 5 units is ministerial and available now — no map, no hearing, RSO-exempt. A conventional 4–6 lot map can also be started today. And from approximately January 2030, SB 1123 opens a ministerial 10-lot subdivision with ADUs that do not count toward the statutory cap — the largest program the site supports. State ADU / JADU law layers additional doors onto whichever path a buyer chooses. All new units are exempt from County rent control.

10
Rebuild + 5 ADUs — Most Probable
5 units (5,369 SF) + 5 detached ADUs under SB 1211 · ministerial, no map, no hearing · available now · RSO-exempt
4–6
Conventional SFR Subdivision
Parcel / Tract Map · ~18–30 mo · available now · $475K–$590K per finished lot
20+
SB 1123 Small-Lot + ADUs
10 lots at 4,500 SF · ministerial, no CEQA · ADUs uncapped · from ~Jan 2030
PathwayTotal Doors / LotsMarket RateAffordable RequiredTimelineRSO
Like-for-Like Rebuild + 10% (5,369 SF)5 units5NoneAvailable now (ministerial)Exempt
Like-for-Like Rebuild + 5 Detached ADUs (SB 1211)10 doors10NoneAvailable now (ministerial)Exempt
Single Estate SFR + ADU + JADU3 units3NoneAvailable nowExempt
Conventional Subdivision — 5 lots (base case)5 lots5None~18–30 monthsExempt
Conventional Subdivision — 4 lots (downside)4 lots4None~18–24 monthsExempt
Conventional Subdivision — 6 lots (upside)6 lots6None~24–30 monthsExempt
Conventional Subdivision + ADU / JADU per lot12–18 doors12–18None~24–36 monthsExempt
SB 1123 Small-Lot Subdivision (10 × 4,500 SF lots)10 lots10NoneMinisterial — from ~Jan 2030Exempt
SB 1123 + one ADU per lot20 doors20NoneMinisterial — from ~Jan 2030Exempt
Alt: Density Bonus / SB 423 (affordable)9–12+ unitsVariesVLI or 100%~2 yearsExempt

Pathways per LA County post-fire rebuild guidance, LCR175 (R-1-7,500) standards, and California ADU / density-bonus / SB 423 law. Subdivision yield is subject to civil engineering and County map approval. Buyer to verify with LA County Regional Planning and Public Works.

2. Most Probable Pathway Pro Forma — 5 Units + 5 ADUs (10 Doors)

The program a buyer is most likely to execute: a rebuilt 5-unit building plus five detached ADUs under SB 1211, underwritten at market rents (RSO-exempt on every door). This is fully ministerial and available immediately — no map, no hearing, no waiting period.

Completed value is presented across a cap-rate band, but the base case for a merchant developer is a 5.50% exit. That is the disciplined assumption for a build-to-sell or build-to-refinance underwrite in this submarket, and it is the rate carried through the residual analysis below. The band runs 5.00% to 6.00% in quarter-point steps. The tighter end reflects a hold buyer — an owner-rebuilder, insurance-funded replacement, or 1031 buyer not underwriting a merchant exit; the wider end reflects a softer capital market at delivery.

Stabilized Operations — 10 DoorsAnnualPer Door
Gross Scheduled Rent [3]$324,000$32,400
Less: Vacancy (5%)($16,200)($1,620)
Effective Gross Income$307,800$30,780
Operating Expenses (~35%) [4]($107,730)($10,773)
Net Operating Income$200,070$20,007
Completed Value by Exit CapValuePer Door
5.00% cap$4,001,400$400,140
5.25% cap$3,810,857$381,086
5.50% cap (developer exit — base)$3,637,636$363,764
5.75% cap$3,479,478$347,948
6.00% cap$3,334,500$333,450

Notes & Assumptions

[1] Subdivision & Infrastructure: Tentative and final map, civil engineering, private drive or flag-lot access, utility extensions, grading, drainage, County fees, and a contingency for post-fire site preparation. Scaled by lot count — the 10-lot SB 1123 case carries a longer drive and more service laterals.

[2] Carry: Land loan interest, property taxes, insurance, and consultant costs. 18–30 months for a conventional map; ~54 months in the SB 1123 case, running from acquisition through the January 2030 lookback expiry, the 60-day ministerial approval, and lot sales.

[3] GSR: 5 × 2BR/1BA (~975 SF) at $3,200/mo, consistent with the record's 10 BR / 6 BA configuration, plus 5 × detached 1BR ADU (~750 SF) at $2,200/mo. All new construction; market rents from lease-up (RSO-exempt).

[4] OpEx: ~35% of EGI — taxes (reassessed at sale), insurance, utilities, R&M, management, reserves. New build carries the lowest maintenance tier.

What the ADUs add: The 5-unit building alone produces $118,560 of NOI ($2,155,636 at a 5.50% cap). The five ADUs add $81,510 of NOI — roughly $1.48M of additional value at the 5.50% developer exit ($1.63M at 5.00%), at a materially lower marginal build cost per SF than the primary structure. This is the single largest value-add available on the site without an entitlement process.

SB 1211 detail: The County may not require replacement parking for the detached ADUs.

Illustrative completed value. Not an appraisal; actual results depend on the executed program, construction cost, and market conditions at delivery.

3. Vertical Residual — What the 10-Door Program Supports on Its Own

Running the same residual discipline through the most probable pathway. The build is 5,369 SF of primary structure plus five detached ADUs at ~750 SF each (3,750 SF); ADU hard costs are modeled $50/SF below the primary structure, reflecting the lower marginal cost of detached cottage product. The base case is $400/SF all-in on the primary structure — hard and soft costs combined, per developer input current to September 2026 — with the ADUs at $350/SF all-in. Because the quoted figure already includes architecture, engineering, permits and fees, no separate soft-cost line is added. Lower cost points are shown as sensitivities.

Residual Build-Up (10 Doors, 9,119 SF, 5.50% developer exit)@ $400 / $350 all-in (Base)@ $350 / $300 all-in@ $325 / $275 all-in
Completed Value (5.50% exit)$3,637,636$3,637,636$3,637,636
Less: Construction Cost, All-In (primary + ADUs) [A]($3,460,100)($3,004,150)($2,776,175)
Less: Site Prep / Debris Contingency($100,000)($100,000)($100,000)
Less: Financing & Carry (~24 mo)($235,000)($235,000)($235,000)
Less: Developer Profit (12% of value)($436,516)($436,516)($436,516)
Indicated Residual Land Value — Developer($593,980)($138,030)$89,945
Same build-up at a 5.00% exit (hold buyer)($273,868)$182,082$410,057
Same build-up at a 6.00% exit (softer market)($860,740)($404,790)($176,815)

At $400/SF all-in and a 5.50% merchant exit, the vertical build still does not support land value — the residual is negative $593,980. That remains the single most important thing for a seller to understand about this asset: a merchant developer running a build-to-rent underwrite will not be the buyer who pays the most for this site. The residual only turns meaningfully positive by combining the tight end of the exit band with a materially lower construction cost: $182,082 at a 5.00% exit and $350/SF, and $410,057 at $325/SF. At a 6.00% exit it is negative under every cost assumption.

Two things follow. First, construction cost is the dominant variable: moving from $325/SF to $400/SF all-in swings the residual by roughly $684,000 at any given exit cap. Second, the buyer's cost of capital matters as much as the program. An owner-rebuilder, insurance-funded replacement, or 1031 buyer is not underwriting a merchant profit and a near-term sale; they are underwriting a long-term hold of an RSO-exempt, ten-door, new-construction asset in a submarket that lost most of its rental stock, and they will value it well inside a 5.50% cap. The SB 1211 ADU layer remains what makes even that work — the five ADUs are the difference between a build that does not pencil and one that can.

[A] Construction Cost — Basis
The $400/SF base case is an all-in figure covering both hard and soft costs — construction, architecture, engineering, permits, and fees — per developer input current to September 2026. ADUs are modeled at $350/SF all-in, reflecting the lower marginal cost of detached cottage product. No separate soft-cost line is added, because the quoted figure already includes it. Published Altadena custom rebuild costs run $450–$750/SF all-in; a production program of five to ten units reasonably sits below that range. Site preparation, debris contingency, and financing carry are shown separately and are additional to the $400/SF. A buyer should price the vertical program against firm contractor bids rather than any per-SF assumption.

Both readings point the same direction on land value. A vertical income build cannot, on its own, support the land value of a full acre in Altadena at a merchant exit. That is not a criticism of the 10-door program — it is precisely why the program is the most probable pathway rather than the pricing basis. Land value here is created by lot yield: 4–6 conventional parcels today, or 10 SB 1123 small lots from January 2030, each trading at what the market has demonstrably paid for a buildable Altadena parcel. The marketing implication is direct — lead with lot developers and homebuilders, who bid to the subdivision residual and to a for-sale exit, and reach owner-rebuilders and long-term holders second. A merchant build-to-rent developer is the buyer least likely to clear the price.

4. Conventional Subdivision Residual — What a Buyer Can Start Today

A lot developer's residual land value = gross finished-lot value − (subdivision and infrastructure cost + entitlement carry + developer profit). Finished-lot value is taken at $525,000, the midpoint of the three closed Altadena fire-parcel trades ($475K / $515K / $590K). The base case is a 5-lot tract map begun immediately.

Residual Build-Up — Conventional 5-Lot Map@ $475K/Lot@ $525K/Lot (Base)@ $575K/Lot
Gross Finished-Lot Value (5 lots)$2,375,000$2,625,000$2,875,000
Less: Subdivision, Access & Infrastructure [1]($550,000)($550,000)($550,000)
Less: Entitlement Carry & Financing (~30 mo) [2]($195,000)($195,000)($195,000)
Less: Developer Profit (20% of gross)($475,000)($525,000)($575,000)
Indicated Residual Land Value$1,155,000$1,355,000$1,555,000
Lot-Yield Sensitivity (at $525,000 per finished lot)4 Lots5 Lots (Base)6 Lots
Gross Finished-Lot Value$2,100,000$2,625,000$3,150,000
Less: Subdivision, Access & Infrastructure($475,000)($550,000)($625,000)
Less: Entitlement Carry & Financing($175,000)($195,000)($215,000)
Less: Developer Profit (20% of gross)($420,000)($525,000)($630,000)
Indicated Residual Land Value$1,030,000$1,355,000$1,680,000

Across both sensitivities the conventional residual brackets $1.03M to $1.68M, clustering at roughly $1.35M in the base case. This is the value supported by what a buyer can start today.

5. SB 1123 Residual — The 10-Lot Maximum-Value Case

The same discipline applied to the SB 1123 pathway. Ten fee-simple parcels averaging 4,500 SF each — smaller than the 5,400–6,600 SF comparable parcels, and therefore underwritten at a discount to them — with ministerial approval, no CEQA, no hearing, and no affordability requirement. The trade-off against the conventional map is more lots at lower value each, higher infrastructure cost, and a longer hold to the January 2030 unlock.

Residual Build-Up — SB 1123, 10 Small Lots@ $350K/Lot@ $400K/Lot (Base)@ $450K/Lot
Gross Finished-Lot Value (10 lots)$3,500,000$4,000,000$4,500,000
Less: Subdivision, Access & Infrastructure [1]($850,000)($850,000)($850,000)
Less: Carry & Financing to Jan 2030 unlock (~54 mo) [2]($420,000)($420,000)($420,000)
Less: Developer Profit (20% of gross)($700,000)($800,000)($900,000)
Indicated Residual Land Value$1,530,000$1,930,000$2,330,000

The SB 1123 residual brackets $1.53M to $2.33M against the conventional pathway's $1.03M–$1.68M — an uplift of roughly $575,000 at the midpoint, and that is before crediting the ADU layer, which adds up to ten more doors at no cost to the 10-unit cap. Note also what the table does not charge for: no discretionary map risk, no CEQA exposure, no hearing, and no possibility of a hostile condition of approval. On a risk-adjusted basis the gap is wider than the raw numbers show.

This BOV does not adopt the SB 1123 residual as the base case. Two inputs carry real uncertainty — the small-lot value (there is no closed 4,500 SF Altadena lot trade to anchor it) and the four-year statutory wait, over which the law may be amended in either direction. The reconciliation in the Pricing section weights the conventional pathway 60% and SB 1123 40%, which is the posture we would defend to a buyer and to an appraiser.

6. Exit Structures — Rental vs. For-Sale

The question every developer asks on the first call: can the units be built and sold off individually? The answer turns on a single point of law that materially shapes which pathway a buyer chooses.

The Governing Constraint — ADUs Cannot Be Sold Separately Here
AB 1033 (effective January 1, 2024) permits a city or county to adopt an ordinance allowing an ADU to be sold or conveyed separately from the primary dwelling as a condominium under the Davis-Stirling Act. It is opt-in — the local agency must affirmatively adopt an ordinance. Unincorporated Los Angeles County has not adopted one. Only a small group of jurisdictions have, among them San Jose, Santa Monica, Santa Cruz, and unincorporated San Diego County (effective April 2026). Absent a County ordinance, the five ADUs in the most probable program are rental doors, not separately sellable units.
Exit StructureIndividually Sellable UnitsAvailableWhat It Requires
Hold — 5 units + 5 ADUs0 (single asset)NowNothing. Ministerial build, RSO-exempt income from lease-up. The asset trades as one 10-door property.
Conventional fee-simple tract map4–6 lots18–30 mo (can file now)Discretionary tentative and final map, civil engineering, access design, infrastructure. DRE public report at five or more lots. Each lot sells as a house with its own ADU attached — no AB 1033 needed, because the ADU conveys with the lot rather than separately.
Condominium map over the primary units5 condos18–30 mo (can file now, if permitted)Tentative and final condominium map, CC&Rs, HOA formation, DRE public report. ADUs would be assigned as exclusive-use common area rather than sold. Weakest of the three: County acceptance of a condominium map over legal-nonconforming residential density on R-1 land is not a given and must be confirmed with Regional Planning.
SB 1123 small-lot subdivision10 fee-simple lots~Jan 2030Ministerial map — no CEQA, no hearing, 60-day decision. The statute expressly contemplates fee-simple ownership (and permits CID, co-op, community land trust, or tenancy-in-common structures). No HOA required.

The finding that matters: SB 1123 is the only pathway that produces ten individually sellable units. Nothing available today gets past six. That reframes the statute's value on this site — it is not merely "more doors," it is the only for-sale structure at scale, and fee-simple homes command a premium over the sum of rental doors. It is also why the January 2030 date is worth tracking rather than dismissing.

The strategic split is therefore cleaner than it first appears. The 5-unit-plus-5-ADU program is a hold play — ten doors, ministerial, income from day one, RSO-exempt, no map, no waiting. It is the right structure for an owner-rebuilder, an insurance-funded replacement buyer, or a long-term holder, and the wrong structure for a merchant sell-off. Any for-sale exit requires a subdivision, and fee-simple is the cheaper path: no HOA, no CC&Rs, and no DRE public report below five lots.

Valuation Note
The subdivision residuals in this section are underwritten to a finished-lot exit — the developer sells entitled lots and never carries vertical construction cost. The build-and-sell exit is modeled separately below. A buyer intending a for-sale exit should build their own vertical pro forma against firm bids, and should confirm ADU conveyance rules and subdivision feasibility with LA County Regional Planning and land-use counsel before removing contingencies.

7. Build-and-Sell Cross-Check

The Set C comparables make it possible to test the subject directly against a build-and-sell exit — the program a merchant homebuilder actually runs. The structural advantage over an apartment build is large and worth stating plainly: a completed home sells at roughly $620–$650 per SF of building, while a stabilized apartment at a 5.50% cap is worth about $399 per SF of building. Construction cost per SF is broadly similar. Retail pays roughly 1.6× per square foot built, and that single fact is why the buyer pool for this site is homebuilders rather than apartment developers.

Build-and-Sell Residual at $400/SF All-In, 15% Developer MarginHome PriceIndicated Land Value
5 lots × 2,700 SF — Warmington-size product, priced at today's market$1,720,000$379,500
5 lots × 2,100 SF — right-sized, priced at today's market [3]$1,536,823$839,923
5 lots × 2,100 SF — delivery in ~2 years, 5%/yr appreciation$1,694,347$1,475,927
5 lots × 2,100 SF — delivery in ~2 years, 10%/yr appreciation [4]$1,859,556$2,142,957
SB 1123 — 10 lots × 1,600 SF, priced at today's market$1,378,000$2,967,350

[3] Home prices for 2,100 SF and 1,600 SF product are extrapolated from the observed Set C size gradient, not directly observed; no Altadena new-construction comparable below 2,110 SF was available. [4] 10%/yr is shown against the 10.7% annualized rate actually achieved on Warmington's Plan 2 between October 2025 and July 2026.

Three conclusions follow, and together they reconcile the recommended price from a direction entirely independent of the land comparables.

First, product size decides the deal. Holding lot count, hard cost, and margin constant, shrinking the house from 2,700 SF to 2,100 SF moves the indicated land value by roughly $460,000 — because Set C shows total sale price is far less elastic to size than cost is. Building large destroys margin in this market.

Second, a builder underwrites to delivery, not to today. A conventional map takes 18–30 months, so a builder acquiring now delivers into the 2028–29 market. At the appreciation rate Warmington has actually realized, the right-sized 5-lot program indicates $2,142,957 — comfortably above the recommended list price. Underwritten at flat 2026 pricing it indicates $839,923, and at a more modest 5%/yr it indicates $1,475,927 — essentially the list. The gap between those two numbers is the price trend, and the price trend is observed rather than assumed.

Third, SB 1123 clears by a wide margin. Ten smaller homes indicate roughly $2.97M of land value at today's pricing, with no appreciation required — the highest indication produced by any lens in this report, and further support for treating the January 2030 pathway as real value rather than speculative upside.

Pricing & Recommendation
Land-Value Reconciliation
Valuation Summary
Subject & Recommendation
Lot Size45,000 SF (1.0331 ac)
ZoningLCR175 — R-1-7,500
Most Probable Program10 doors (5 units + 5 ADUs)
Conventional Subdivision Yield4–6 SFR lots
SB 1123 Yield (from ~Jan 2030)10 lots / 20+ doors
Suggested List Price$1,495,000
Implied Pricing Metrics
$ / Land SF$33.22
$ / Lot at 4 (conventional)$373,750
$ / Lot at 5 (conventional base)$299,000
$ / Lot at 10 (SB 1123)$149,500
$ / Door at 20 (SB 1123 + ADUs)$74,750
Benchmarks
412 W Altadena Dr (27,545 SF, LCR175)$44.65/SF
3430 Chaney Trl (27,978 SF, LCR175)$31.63/SF
603 Villa Zanita St (20,037 SF, same block)$23.46/SF
Finished-Lot Value Used (conventional / SB 1123)$525K / $400K
Subject vs Set A Average−0.1%
Reconciliation of Lenses
Set A Direct Comps (avg $33.25/SF × 45,000)$1,496,000
Conventional Residual (5 lots @ $525K)$1,355,000
SB 1123 Residual (10 lots @ $400K)$1,930,000
Residuals Weighted 60 / 40$1,585,000
Reconciled Recommendation$1,495,000
Build-and-Sell, 5 lots × 2,100 SF (2-yr delivery)$2,142,957
Build-and-Sell, SB 1123 10 lots (today's pricing)$2,967,350
10-Door Vertical Residual (5.50%, $400/SF all-in)($593,980)
2025 Assessed Land Value (Prop 13 base)$321,677
Suggested List Price
$1,495,000
$33Price / Land SF
$299KPer Lot at 5 (Conventional)
$150KPer Lot at 10 (SB 1123)
$75KPer Door at 20

Pricing Matrix — Land-Value Lenses

List Price$/Land SF$/Lot (4)$/Lot (5)$/Lot (10 SB 1123)$/Door (20)vs Set A Avg ($33.25)
$1,300,000$28.89$325,000$260,000$130,000$65,000−13.1%
$1,350,000$30.00$337,500$270,000$135,000$67,500−9.8%
$1,400,000$31.11$350,000$280,000$140,000$70,000−6.4%
$1,450,000$32.22$362,500$290,000$145,000$72,500−3.1%
$1,495,000$33.22$373,750$299,000$149,500$74,750−0.1%
$1,550,000$34.44$387,500$310,000$155,000$77,500+3.6%
$1,600,000$35.56$400,000$320,000$160,000$80,000+6.9%
$1,650,000$36.67$412,500$330,000$165,000$82,500+10.3%
$1,700,000$37.78$425,000$340,000$170,000$85,000+13.6%
A Trade Price in the Current Environment Of
$1,350,000 — $1,600,000

Pricing Rationale

The recommended list price of $1,495,000 is anchored, first and most heavily, in direct comparable sales. Three closed LCR175 Altadena land trades — 412 W Altadena Drive at $44.65/SF, 3430 Chaney Trail at $31.63/SF, and 603 Villa Zanita Street at $23.46/SF — average $33.25 per land SF, which applied to 45,000 SF indicates $1,496,000. The recommendation sits on that number. These are same-zone, same-submarket, large-parcel land sales closed between July 2025 and February 2026; they are the most direct evidence available and they carry the greatest weight in this opinion.

The residual analyses corroborate the number from above. The conventional lens — a 4–6 lot tract map at a $525,000 finished-lot value — indicates $1,355,000 in the 5-lot base case, with the full band running $1,030,000 to $1,680,000. The SB 1123 lens — a 10-lot ministerial small-lot subdivision at a $400,000 lot value — indicates $1,930,000 before crediting up to ten ADUs that do not count against the statutory unit cap. Weighted 60/40 in favor of what a buyer can start today, the residuals indicate $1,585,000. The recommendation is set below that, at the direct-comparable indication, because observed trades outrank modeled residuals when both are available.

The 40% weight on SB 1123, rather than a higher one, is deliberate. The pathway is time-locked to approximately January 2030 by the statute's five-year tenant-occupancy lookback, which expressly reaches units since demolished or vacated and contains no natural-disaster exception. Four years is a long option, the small-lot value input has no direct closed comparable, and the Starter Home Revitalization Act has been amended in each of its first two years. Equally, the pathway is not speculative zoning theory: the parcel's acreage, zoning, vacancy, and 4,500 SF average lot size clear every physical eligibility test in the statute by a wide margin, approval is ministerial, and it is the only structure that produces ten individually sellable units.

Against the direct comps, $33.22/land SF prices the subject 25.6% below 412 W Altadena Drive, 5.0% above 3430 Chaney Trail, and 41.6% above the same-block 603 Villa Zanita sale. That positioning is deliberate: the subject is larger than all three, which normally argues for a per-SF discount, but it is also the only parcel in the set carrying a confirmed multifamily rebuild right, a 10-door ministerial program, and a path to five or more lots. Villa Zanita, at 20,037 SF, cannot reach a three-lot split and sat 239 days on market; 412 W Altadena, marketed on two-to-three-lot subdivision potential, cleared in 8 days at $44.65/SF. The subject's yield sits above both. On a per-lot basis, $299,000 per lot on the conventional 5-lot case is a 43% discount to the $525,000 finished-lot benchmark — the correct spread for raw land needing a map, access design, infrastructure, and 18–30 months of carry. On the SB 1123 case the price implies just $149,500 per lot and $74,750 per door at 20 doors. On the build-and-sell lens — the exit an actual homebuilder underwrites — a right-sized 5-lot program at $400/SF all-in indicates $2,142,957 of land value when priced to a 2028–29 delivery at the appreciation rate Warmington has realized — and $1,475,927 at a more conservative 5%/yr — while the SB 1123 10-lot program indicates roughly $2.97M at today's pricing with no appreciation assumed. Both land within or above the recommended price, from evidence entirely independent of the land comparables. On the build-to-rent lens, by contrast, the same 10-door program at a 5.50% exit and $400/SF all-in produces a land residual of negative $593,980 — confirming that a merchant apartment developer is the buyer least likely to clear the price, and that the vertical rental build is what a buyer does with the site rather than what sets its land value.

At $1,495,000 we would expect the strongest interest from lot developers and homebuilders — particularly those already underwriting SB 684 / SB 1123 execution elsewhere in LA County — with secondary depth from owner-rebuilders and long-term holders drawn to the 10-door ministerial program, owner-users seeking a 1.03-acre Altadena compound, and affordable sponsors. A merchant build-to-rent developer is the buyer least likely to clear the price. We anticipate a trade price in the $1,350,000–$1,600,000 range within a 60–90 day marketing window, with the upper end achievable from a buyer who underwrites the SB 1123 pathway or a for-sale vertical exit more aggressively than this analysis does.

Assumptions & Conditions: This Broker Opinion of Value is not an appraisal. It is based on the First American property record dated 09/03/2026, a TheMLS closed-sales pull of large Altadena R-1 land parcels verified against public records, the LAAA Team's verified Altadena fire-rebuild comparable set, County post-fire rebuild guidance, the text of SB 684 / SB 1123 and published legal commentary on it, and illustrative subdivision and completed-value pro formas. Fire-loss status is inferred from the absence of improvement value on the 2025 assessment roll and should be confirmed with ownership. Conventional subdivision lot yield (4–6 lots) depends on access design and civil engineering and has not been tested with the County. SB 1123 eligibility depends on the date tenants last occupied the pre-fire units, on LA County's election to permit ADUs on newly created parcels, and on the statute remaining in its current form — none of which has been confirmed. Finished-lot values ($525,000 conventional / $400,000 small-lot), subdivision and infrastructure costs, entitlement timelines, construction costs (base case $400/SF all-in, hard and soft combined, per developer input current to September 2026), new-construction resale prices, and rent assumptions are estimates a buyer must verify in due diligence. The build-and-sell analysis relies in part on an assumed rate of home-price appreciation over a two-year entitlement period; the 10.7% annualized figure cited is the rate observed on one builder's identical floorplan over nine months and is not a forecast. Rebuild rights, subdivision feasibility, statutory eligibility, ADU treatment, and any density-bonus pathway should be confirmed with LA County Regional Planning and Public Works and with land-use counsel. All projections are illustrative and based on unverified information.
Property Tax Benefit — RTC Section 69
Transfer Your Prop 13 Base Year Value to a Replacement Property

California Revenue & Taxation Code Section 69 provides a significant tax benefit for owners whose property was destroyed in a Governor-declared disaster: you can sell this land and transfer your existing Prop 13 base year value to a comparable replacement property within Los Angeles County — preserving your low property tax assessment on the new property rather than being reassessed at today's market value.

This is particularly relevant here. The 2025 roll carries a base-year land value of $321,677 and an annual tax bill of $5,090.02 on a parcel held in the Hartwick Family Trust — an unusually low basis reflecting decades of Prop 13 protection. Transferring that base year value to a replacement property, rather than surrendering it, is likely the single largest ancillary economic consideration in a sale of this asset.

Any TypeApplies to All Property — Not Just Primary Residences
LA CountyReplacement Must Be Within Same County
5 YearsWindow to Acquire or Build Replacement
How It Works
Sell 536 W Palm Street, use the proceeds to acquire a comparable property (similar size and unit count) anywhere in LA County, and apply to transfer your existing Prop 13 base year value to the new property. The new property is taxed on your old assessed value — not the new purchase price — resulting in substantially lower annual property taxes. The replacement must be acquired or newly constructed within 5 years of the January 2025 Eaton Fire (deadline: January 2030).

Important: RTC Section 69 and the rebuild-in-place relief (RTC Section 170) cannot both be claimed for the same event on the same property — you must choose one strategy. A Section 1031 exchange is a separate and potentially complementary tool for deferring capital gain on a low-basis asset like this one. Please consult a CPA to verify all of the above before making any decisions.
A Note on Timing
The RTC Section 69 replacement window closes in January 2030 — the same month the SB 1123 five-year tenancy lookback expires and the 10-lot ministerial subdivision becomes available to a buyer. That convergence argues for selling well inside the window rather than at the end of it. A buyer purchasing today acquires the SB 1123 optionality and carries it; a seller who holds the land waiting for that same date arrives at January 2030 with the subdivision right in hand but no remaining time to complete a Section 69 replacement acquisition. The two clocks run in opposite directions, and the seller's clock is the one that expires.