The 24-Month CoA Life

Per SPMC 2.65(e)(11), a Certificate of Appropriateness is valid for 24 months from the date of final approval. “Final approval” is the date the Commission’s decision becomes effective — on an unappealed Minor or Major Project decision, that is generally the date of the Commission’s action; on an appealed decision, it is the date the City Council’s decision becomes final under SPMC 2.65(e)(13).

The 24 months is the period in which the Certificate must move toward construction. It is not a separate construction deadline.

The 24-month clock does not require that construction actually be completed within 24 months. The Certificate remains valid if either of two events has occurred during the period:

1. An associated building permit application has been submitted to the Building Division and is being diligently pursued, or
2. Work authorized by the Certificate has commenced.

“Diligently pursued” is the operative standard for the most common case: a permit application that is in active plan check. In practice, a permit application that is responding to plan check corrections within reasonable timeframes is being diligently pursued. A permit application that has been dormant for an extended period — no responses to corrections, no contact with the examiner — is more likely to draw a “no longer being diligently pursued” determination.

This matters because plan check on a complex historic project — Title 24 corrections, structural corrections, mechanical-electrical-plumbing coordination — can run substantial time against the 24-month clock. Sequencing the Certificate-to-permit handoff promptly preserves the Certificate’s life.

Beyond the original 24 months, SPMC 2.65(e)(11) authorizes the Director to grant up to two one-year extensions on written application by the property owner. The extensions are administrative — they do not require a Commission hearing — but they require an affirmative written application from the owner and a Director decision. They do not extend automatically.

Each extension covers one additional year. Two extensions, taken in sequence, extend the administrative life of the Certificate to 48 months total from the original final approval.

Beyond 48 months — the 24-month original term plus the two one-year extensions — any further extension is no longer an administrative matter for the Director. SPMC 2.65(e)(11) requires that further extensions be heard by the Cultural Heritage Commission under the Division 36.630 public-hearing procedures. That means a noticed hearing, a public comment opportunity, and a Commission vote on whether to grant the additional extension.

The CHC hearing path is procedurally meaningful. It returns the project to the discretionary review track, with no guarantee that a further extension will be granted, and it adds the time required to schedule, notice, and hold the hearing.

On projects with phased construction, complex financing timelines, or other discretionary reviews stacked alongside the Certificate, the 48-month cap is the critical planning number. Common cases where the cap becomes relevant:

• Projects financed with construction loans that take longer to close than originally anticipated.
• Phased projects where the first phase is permitted and built, but later phases stall.
• Projects where structural-engineering discovery during construction triggers a partial redesign.
• Projects where ownership changes mid-construction.
• Projects that stack additional discretionary reviews — variances, conditional use permits, hillside development reviews — on top of the Certificate.

Source: South Pasadena Municipal Code Chapter 2, Article IVH (Cultural Heritage Ordinance, Ord. No. 2315 § 2, 2017, amended Ord. No. 2400, 2025), § 2.65(e)(11). SPMC Chapter 36, Division 36.630 (Public-hearing procedures).