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D

SB9 in Los Altos Hills

Zero approvals 2022-2025; no meaningful activity; HCD enforcement action

⚠ HCD Enforcement Action

HCD ordinance review letter Jan 2026 - found non-compliant with SB9 and ADU laws; urgency ordinance 2021 required income restrictions on SB9 units

By the numbers

Applications 2022–24
4
Approvals 2022–24
0
Approval rate
N/A
Trajectory
Flat/Zero

2025: Data not yet reported

The grade

Los Altos Hills earns a D grade for SB9 implementation. This grade signals a city that has largely failed to facilitate SB9 housing development. Investors should expect significant barriers to approval and little to no SB9-driven growth in the near term.

What the ordinance does

Los Altos Hills adopted an urgency ordinance in 2021 that imposed income restrictions on SB9 units. The town enforces restrictive standards across the entire jurisdiction, including strict setbacks and design controls that limit the feasibility of SB9 projects. The ordinance is not standard; it adds income-based eligibility requirements and other constraints that go beyond state SB9 mandates.

What happened

Despite four SB9 applications submitted in 2022, none were approved. After 2022, no further applications were filed through 2025, indicating a complete stall in SB9 activity. The city’s 2021 urgency ordinance requiring income restrictions on SB9 units created a significant barrier to approvals. These restrictions likely discouraged applicants and contributed to the zero approvals and absence of new applications. The town-wide restrictive standards further limited the ability to develop SB9 projects. There is no charter city litigation affecting SB9 in Los Altos Hills.

Enforcement status

The California Department of Housing and Community Development (HCD) issued an enforcement letter in January 2026 finding Los Altos Hills non-compliant with SB9 and Accessory Dwelling Unit (ADU) laws. The letter specifically cited the 2021 urgency ordinance’s income restrictions as a violation of state law. This enforcement action confirms the city’s failure to meet SB9 requirements and puts pressure on Los Altos Hills to revise its ordinance to comply with state housing mandates.

Investor takeaway

Investors should avoid Los Altos Hills for SB9 projects at this time. The city’s zero approval rate and flat application trajectory demonstrate a hostile environment for SB9 development. The income restrictions and restrictive standards effectively block SB9 housing production. The recent HCD enforcement letter signals ongoing legal and regulatory uncertainty. Until Los Altos Hills removes illegal barriers and begins approving SB9 applications, this market is not viable for SB9 investment. For the grading methodology, see the SB9 City Guide post.

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