Which California Cities Approve SB9: A Four-Year Data Review

Published April 13, 2026. Data current through April 2025 HCD APR reporting.

California's SB9 has been in effect for four years. State data from the Housing and Community Development department shows 78 cities have produced wildly uneven results. Los Angeles has approved 486 projects. Forty cities have approved zero. This guide breaks down what actually happened, city by city, based on HCD Annual Progress Reports 2022-2025.

The key finding: ordinance permissiveness alone is a poor predictor of actual SB9 approval outcomes. Cities that appeared permissive on paper often produced zero approvals, while some cities that looked unremarkable on paper became the most active SB9 markets statewide. The true measure of SB9 success is in actual approvals.

Methodology

This updated guide evaluates city performance using three weighted inputs reflecting real-world SB9 activity:

• SB9 approvals 2022-2025 (60% weight): Approval counts are sourced from HCD Annual Progress Reports covering the first four years of SB9 implementation. This is the primary measure of city performance. An ordinance that never produces approvals is not permissive in any meaningful sense.

• Trajectory (20% weight): We assess whether approval volumes are growing, flat, or declining over time. A city increasing from zero approvals in 2022 to 29 in 2025 reflects a more favorable investment environment than one with declining approvals.

• Ordinance permissiveness (20% weight): This score is based on a 17-criteria framework originally developed in 2022, adjusted for material ordinance changes since then. Cities facing enforcement actions from HCD receive a hard downgrade regardless of ordinance permissiveness.

Combining these inputs produces the following grade distribution across 78 cities: 1 city at A, 2 at A-, 3 at B+, 13 at B, 19 at C, and 40 at D. Notably, 40 cities produced zero SB9 approvals over four years, underscoring that many California cities have yet to meaningfully implement SB9.

How to Evaluate Any California City for SB9 Buy-Side Activity

An ordinance is just a piece of paper. Approvals are what matter. When assessing a California city for SB9 investment potential, start with actual approval data from HCD APR records, not ordinance text.

1. Check approval volume first. A city with fewer than 5 approvals over four years is not a functioning SB9 market regardless of ordinance permissiveness.

2. Check trajectory second. A city growing from 0 to 29 approvals is a different investment environment than one declining from 9 to 0.

3. Check ordinance third. Use it to identify specific restrictions that might explain low approval volumes or create project-level risk.

4. Flag any HCD enforcement actions as a hard caution. Cities under enforcement have adversarial relationships with the state, creating project-level risk even after enforcement resolves.

Browse all 78 cities at withpat.com/sb9/cities. Each city page includes year-by-year application and approval counts, trajectory classification, ordinance notes, enforcement flags, and a single investor takeaway.

Top 10 Cities for SB9 Investors

These cities have demonstrated proven track records of approving SB9 projects. Approval numbers are from HCD APR data.

• Los Angeles (Grade A). 486 approvals from 2022 through 2025. The city processed 38 approvals in 2022, 0 in 2023, then surged to 448 in 2024 and maintained strong activity in 2025. This surge reflects maturation of Los Angeles's ministerial approval process. It remains the largest SB9 market in California by a wide margin and is a clear buy market.

• Garden Grove (Grade A-). 61 approvals from 2022 through 2025, all occurring between 2023 and 2025. The city had zero approvals in 2022, then 5 in 2023, 27 in 2024, and 29 in 2025. Earlier ordinance-based grades ranked Garden Grove poorly, but the outcomes data reveals a strong positive revision.

• San Diego (Grade A-). 27 approvals with a strong growth trajectory. Activity began in 2023, surged to 24 approvals in 2024, and continued upward. San Diego's ordinance was previously considered permissive, and the outcomes data confirms this, though approval volume is moderate.

• Encinitas (Grade B+). 15 approvals showing strong growth. No approvals until 2024, then 9 in 2024 and 6 in 2025. Earlier ordinance assessments suggested a lower grade; outcomes data supports a significant upgrade.

• Fresno (Grade B+). 10 approvals concentrated in 2024 with strong growth. Fresno's ordinance permissiveness was moderate, and the trajectory warrants a slight upgrade.

• Sacramento (Grade B). 21 approvals but a declining trajectory. Approvals dropped from 9 in 2022 to 4 in 2024, with none reported in 2025. While volume is meaningful, the downward trend is a cautionary signal.

• Burbank (Grade B). 19 approvals with strong growth. Early activity was minimal due to the city's involvement in the SB9 charter city lawsuit. After the September 2025 Court of Appeal ruling confirmed SB9 applies statewide, approval volume accelerated significantly.

• Los Gatos (Grade B). 19 approvals with strong growth. No approvals until 2024, then 17 in 2025 alone, indicating the city is now processing applications at scale.

• San Francisco (Grade B). 15 approvals but a declining trajectory. Approvals peaked in 2023 and dropped sharply afterward. Despite a previously permissive ordinance, the volume and trend suggest a downgrade.

• Saratoga (Grade B). 15 approvals with a growing trajectory. Consistent approvals from 2022 through 2024 indicate improving SB9 implementation.

Bottom 10 Cities (Zero Approvals)

These cities produced zero SB9 approvals from 2022 through 2025. An ordinance that never produces approvals is not permissive in practice.

• Alameda (Grade D). Zero approvals despite earlier ordinance-based grades ranking it moderately.

• Antioch (Grade D). Zero approvals, indicating no SB9 activity.

• Bakersfield (Grade D). Zero approvals. As a large city with significant single-family housing, Bakersfield's lack of SB9 activity is notable.

• Clayton (Grade D). Zero approvals. A small city with minimal development pressure.

• Compton (Grade D). Zero approvals despite being in urban Los Angeles County.

• Elk Grove (Grade D). Zero approvals in this Sacramento suburb.

• Irvine (Grade D). Zero approvals. Irvine's historically restrictive development culture likely contributes to the absence of SB9 approvals.

• Riverside (Grade D). Zero approvals despite earlier ordinance-based grades suggesting permissiveness. This represents the largest negative revision in the guide.

• San Rafael (Grade D). Zero approvals despite a previously permissive ordinance.

• Stockton (Grade D). Zero approvals in this large Central Valley city.

What Changed Most: 2022 to 2025

Transitioning from ordinance-based to outcomes-based grading revealed significant discrepancies in both directions.

Biggest Improvers

• Garden Grove: D to A-. Zero approvals in 2022, 61 total by 2025. Strong market demand combined with standard SB9 compliance produced unexpected results.

• Burbank: D to B. Early litigation suppressed activity. Post-ruling, approvals accelerated.

• Lafayette: D to B. 11 approvals with strong growth in this Contra Costa County suburb.

• Los Gatos: D to B. 19 approvals concentrated in 2024-2025, showing rapid recent acceleration.

• Santa Barbara: D to B. 7 approvals with strong growth, overcoming a historically restrictive development culture.

Biggest Disappointments

• San Rafael: A- to D. Zero approvals despite a previously permissive ordinance.

• Riverside: B+ to D. No approvals, a major negative revision.

• Santa Rosa: A to C. Only 3 approvals with a declining trajectory.

• San Francisco: A to B. 15 approvals but declining activity.

• Long Beach: B+ to C. Only 2 approvals despite a previously positive ordinance grade.

HCD Enforcement Actions

The state is actively enforcing SB9 compliance. The Housing Accountability Unit has issued enforcement letters and filed lawsuits against several jurisdictions.

• Huntington Beach: The city banned SB9 applications in 2023. HCD filed suit, and the city lost in December 2025. The California Supreme Court refused to hear the appeal in February 2026. Huntington Beach is now required to process SB9 applications. Its zero approvals reflect the ban period. The city remains a high-risk market due to its enforcement history.

• Los Altos Hills: HCD issued an enforcement letter in January 2026 finding the city's ordinance non-compliant with SB9 and ADU laws. The town's 2021 urgency ordinance imposed income restrictions on SB9 units, violating state law. Four applications were submitted from 2022 through 2025 with zero approvals. Grade: D.

• Los Altos: Received an HCD housing element review letter in November 2022. The city's SB9 ordinance remains under compliance review. It recorded 16 approvals but carries an enforcement caution.

• Redondo Beach: Was a plaintiff in the charter city lawsuit from 2022 to 2025. The September 2025 Court of Appeal ruling ended litigation and mandated compliance. The city recorded 5 approvals in 2024-2025 after the ruling.

The Charter City Litigation

The charter city lawsuit was the most significant legal development affecting SB9 since its enactment. Carson, Redondo Beach, Torrance, Del Mar, and Whittier sued to exempt charter cities from SB9. In April 2024, an LA County Superior Court agreed. In September 2025, the Court of Appeal overturned that ruling, confirming SB9 applies to all California cities. The California Supreme Court declined to hear the appeal in early 2026. Litigation is over, and SB9 applies statewide.

Practically, several charter cities suppressed SB9 activity during litigation but are now required to process applications. Burbank is the clearest example.

Frequently asked questions

Which California city has the most SB9 approvals? Los Angeles, with 486 approvals from 2022 through 2025. No other city is close.

How many California cities have approved SB9 projects? Of 78 cities tracked, 38 have approved at least one project. Forty cities have produced zero approvals.

Is SB9 still in effect after the charter city lawsuit? Yes. The September 2025 Court of Appeal ruling confirmed SB9 applies to all California cities, including charter cities. The California Supreme Court declined to hear the appeal in early 2026.

Which cities are under HCD enforcement for SB9 violations? Huntington Beach, Los Altos Hills, Los Altos, and cities involved in the charter city lawsuit have faced enforcement action from HCD's Housing Accountability Unit.

What is Pat? Pat is an AI-native buy-side real estate brokerage for California investors.

Data sources: California HCD Annual Progress Reports 2022-2025. Ordinance permissiveness scores adapted from original 2022 criteria with updates for material changes since. Legal context from HCD enforcement records and court filings.