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C

SB9 in Los Altos

16 approvals 2022-2025; growing trajectory; HCD enforcement action

⚠ HCD Enforcement Action

HCD housing element review letter Nov 2022; SB9 ordinance under review

By the numbers

Applications 2022–25
29
Approvals 2022–25
16
Approval rate
55%
Trajectory
Growing

The grade

Los Altos earns a C grade for SB9 implementation, indicating a moderate level of activity and approval but with clear limitations. For investors, this means the city is neither highly permissive nor outright hostile to SB9 projects. There is some opportunity for development, but it comes with regulatory friction and slower approval rates compared to more proactive cities.

What the ordinance does

Los Altos is still reviewing its SB9 ordinance following a November 2022 letter from the California Department of Housing and Community Development (HCD). The city’s approach remains somewhat restrictive, with no fully adopted ordinance easing SB9 development. Standard features such as minimum lot sizes, setbacks, and design standards remain in place, limiting the ease of subdividing lots or adding units. Parking requirements and other local design controls continue to apply, making SB9 projects more complex than in cities with streamlined ordinances.

What happened

Despite its reputation for restrictive housing policies, Los Altos has seen growing SB9 activity. The number of applications more than tripled from 3 in 2022 to 10 in 2024 and 2025. Approvals have also increased but remain just over half of applications overall. The city’s slow ordinance adoption process has created uncertainty, but some projects have moved forward under existing zoning and state SB9 law. The November 2022 HCD letter prompted the city to review its ordinance, which likely contributed to increased scrutiny and cautious approvals. The upward trend in 2025 approvals suggests some loosening or better administrative handling, but the approval rate still reflects significant local barriers. Los Altos is not a charter city, so no litigation has affected SB9 activity here.

Enforcement status

HCD issued a housing element review letter in November 2022 that specifically addressed Los Altos’ SB9 ordinance review and enforcement. This letter signaled HCD’s concern about the city’s compliance with state SB9 requirements and pushed the city to update its policies. There is no record of a lawsuit or formal enforcement action beyond this letter. The city remains under HCD oversight to ensure progress on SB9 implementation.

Investor takeaway

Los Altos presents a wait-and-see market for SB9 investors. The growing number of applications and approvals shows some momentum, but the city’s restrictive environment and ongoing ordinance review create uncertainty. Approval rates remain moderate, and local regulations still impose significant hurdles. Investors should monitor ordinance developments closely and expect a slower, more cautious approval process. This is not a high-opportunity SB9 market at present, but it is not closed off either. Patience and careful project selection are essential. For the grading methodology, see the SB9 City Guide post.

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