Cities scramble to comply with or fight major state housing law - CalMatters
California Cities Maneuver to Delay or Defang Landmark State Housing Law Before July Deadline
Cities scramble to comply with or fight major state housing law - CalMatters
In-Depth Report
With 73 days until SB 79 takes effect, Los Angeles, San Diego, and San Francisco are exploiting escape clauses, while Governor Newsom threatens funding cuts and the state attorney general stands ready to levy fines of up to $50,000 per month against noncompliant jurisdictions.
Bottom Line Up Front (BLUF)
Senate Bill 79, California's most significant transit-oriented housing law in decades, takes effect July 1, 2026, overriding local zoning to allow mid-rise apartment buildings of up to nine stories near qualifying transit stops in eight urban counties. Rather than accept the state-imposed density standards, most of the state's largest cities—including Los Angeles, San Francisco, San Diego, and Oakland—are racing to invoke the law's built-in deferral mechanisms, adopting modest upzoning ordinances designed to reach the 50-percent density threshold that triggers multi-year delays. Governor Newsom has responded by threatening to withhold homelessness and housing funding from noncompliant cities and directing the Department of Housing and Community Development (HCD) to refer violators to the Attorney General, who can impose fines of $10,000 to $50,000 per month. Pro-housing groups such as California YIMBY and YIMBY Law have signaled that litigation will follow any outright defiance. The net effect is a high-stakes standoff between Sacramento's preemptive authority and local governments defending what remains of their land-use autonomy—all against the backdrop of a housing affordability crisis in which 82 percent of California households cannot afford the median-priced home.The Law: Eight Years From Concept to Statute
Senate Bill 79, the "Abundant and Affordable Homes Near Transit Act," was signed into law by Governor Gavin Newsom on October 10, 2025, and is codified at Government Code sections 65912.155 through 65912.162. Authored by State Senator Scott Wiener (D-San Francisco), the legislation represented the culmination of an eight-year legislative campaign that began with SB 827 in 2018 and continued through SB 50 in 2020, both of which failed to pass.
The law applies exclusively to "urban transit counties"—those with more than 15 passenger rail stations. Currently, eight counties qualify: Alameda, Los Angeles, Orange, Sacramento, San Diego, San Francisco, San Mateo, and Santa Clara. Within those counties, the statute creates a two-tiered framework based on transit quality: Tier 1 covers heavy rail and very-high-frequency commuter rail stops (72 or more trains per day), while Tier 2 encompasses light rail, high-frequency commuter rail, and qualifying bus rapid transit routes.
On sites zoned residential, mixed-use, or commercial within one-half mile of a qualifying transit stop, developers may build housing projects of at least five dwelling units at a minimum density of 30 units per acre. Height allowances depend on proximity and transit tier: buildings may rise as high as nine stories directly adjacent to Tier 1 stops, seven stories within a quarter-mile, and six stories within a half-mile. An "adjacency intensifier" adds 20 additional feet of height, 40 extra units per acre, and a 1.0 floor-area ratio increase for projects immediately next to a transit stop. Projects exceeding 85 feet must use a skilled and trained workforce.
Critically, the law includes inclusionary housing requirements: projects of more than ten units must dedicate 7, 10, or 13 percent of total units to extremely low-, very low-, or lower-income households, respectively. The legislation also prohibits the demolition of rent-stabilized buildings of three or more units, or any multifamily housing occupied by tenants within the prior seven years.
The Deferral Playbook: How Cities Are Buying Time
Although SB 79 represents the most aggressive state override of local zoning authority since the 2021 HOME Act (SB 9), its final version was negotiated to include substantial flexibility mechanisms for local jurisdictions. Cities that already permit at least half of the housing capacity called for under SB 79 may defer full implementation until one year after the start of the next Regional Housing Needs Allocation (RHNA) cycle—2030 for Southern California jurisdictions and 2032 for Bay Area cities. Additional temporary exemptions apply to low-resource neighborhoods, historic preservation districts, areas at risk of wildfire or sea-level rise, and designated industrial employment hubs of 250 or more contiguous acres.
These deferral provisions have become the primary instrument through which California's major cities are managing SB 79 implementation.
Los Angeles: "Maximum Delay"
On March 24, 2026, the Los Angeles City Council voted unanimously to adopt what housing advocates have characterized as a strategy of maximum delay. The council approved "Option C1," the least aggressive of three alternatives presented by the Department of City Planning, which expands the Citywide Housing Incentive Program (CHIP) to permit buildings of up to four stories with 4 to 16 residential units in 55 single-family and low-density areas near transit hubs in Central and West Los Angeles, the South Valley, and parts of the Eastside.
By doing so, the city brought those areas above the 50-percent density threshold needed to invoke the multi-year deferral, effectively delaying the full force of SB 79 until 2030. The council simultaneously exempted low-income neighborhoods, fire zones, and historic preservation overlay zones (HPOZs) established before 2015.
The political history behind the vote was contentious. The City Council had voted 8-5 in August 2025 to formally oppose SB 79 before it was signed. Mayor Karen Bass wrote to Newsom urging a veto, arguing that the bill's rigid timelines and limited flexibility "create unnecessary burdens" and "diminish neighborhood input on planning and zoning." Councilmember Traci Park declared the bill would open "the floodgates to developers, displacement and gentrification." In January 2026, the Board of the Los Angeles Metro voted to urge the state to exempt all of L.A. County from SB 79, with only county supervisors Janice Hahn and Lindsey Horvath dissenting.
—L.A. Councilmember Bob Blumenfield
Pro-development groups expressed frustration. Scott Epstein, policy and research director with Abundant Housing Los Angeles, warned that the approach is unlikely to generate meaningful housing production because smaller apartment buildings are not financially feasible in areas with extremely high land costs. Councilmembers Nithya Raman and Katy Yaroslavsky both acknowledged that CHIP's Corridor Transition program has not generated a single development application since its 2025 inception. Yaroslavsky introduced follow-up motions to reform the program's incentives and accelerate higher-density development near transit corridors before 2030.
San Francisco: A Faster Local Alternative
San Francisco is pursuing a variation on the deferral strategy but with a compressed timeline. City officials plan to exempt industrial areas and low-resource neighborhoods while preemptively increasing allowable density on certain low-rise parcels to clear the 50-percent threshold and qualify for a delay until 2032. Unlike Los Angeles, however, San Francisco intends to roll out its own local implementation plan before the July 1 deadline rather than spend years developing an alternative. This approach was facilitated by Mayor Daniel Lurie's "Family Zoning Plan," a citywide densification effort completed in 2025, which provides a ready-made framework for the city's SB 79 compliance strategy. The proposal was scheduled for a Board of Supervisors subcommittee hearing in mid-April 2026.
San Diego: Phased Implementation Under Scrutiny
San Diego, which notably supported SB 79 during the legislative process, is nonetheless proposing to phase implementation across the city. In an initial analysis released in early 2026, the City Planning Department determined that only San Diego Trolley stops qualify as transit-oriented development stops under the law; the city's bus rapid transit routes were not included. The city has proposed exempting areas beyond a one-mile walking distance from qualifying stops (accounting for canyons, freeways, and other barriers) and delaying implementation in fire zones, historic districts, and low-resource areas.
The approach drew sharp criticism from pro-housing advocates. Former La Mesa City Councilmember Colin Parent posted on social media that San Diego was "proposing to exempt itself from almost all of SB 79." Governor Newsom's press office reposted Parent's comment and issued a statement: the city must "implement SB 79 in a manner that meets the moment," adding that "the bare minimum isn't going to cut it." Circulate Planning & Policy, a San Diego transportation advocacy group, submitted a formal letter to the Planning Commission on April 14 detailing elements of the draft plan that must change if the city intends to implement the law at "full force."
Oakland: A Neighborhood-Level Debate
In Oakland, the implementation question has produced an unusual intra-council divide. City planning staff initially proposed taking every available deferral to buy time for a comprehensive zoning overhaul already underway and expected to conclude in 2027. Planning Director William Gilchrist told the council the disagreement was about timing, not outcome.
Three council members dissented. Zac Unger, representing affluent North Oakland neighborhoods, argued that parcels already above the 50-percent density threshold should not be deferred, particularly on busy commercial corridors. Charlene Wang and Ken Houston, whose districts include low-resource neighborhoods entitled to delay, also called for immediate adoption. Wang argued that Oakland, as a mature urban area, "should be far exceeding the density minimums" established by state law. Unger characterized the debate as "a matter of urgency—and a statement of values," noting that implementing SB 79 one year earlier would not cause buildings to "blow up from the street."
Sacramento: Accepting the State Framework
Sacramento has taken the most straightforward approach among major affected cities. The city is preparing a modest ordinance that tweaks the way it processes development applications under SB 79 but otherwise leaves the state-set zoning standards intact—effectively accepting the law as written.
The Governor's Enforcement Posture
Governor Newsom has made clear he views local resistance to SB 79 as unacceptable. In a series of social media posts, Newsom publicly criticized Los Angeles and San Diego for efforts to shield portions of their cities from the law's requirements. At a March 2026 press conference, the governor explicitly linked SB 79 compliance to state funding, declaring: "If you don't build, we're not going to fund, period."
On the same day, the Newsom administration announced legal action against 15 cities found to be more than two years behind schedule on housing element compliance, describing them as lacking "a path to compliance within 60 days." The governor framed these actions as part of a broader policy of tying homelessness and housing funding to local compliance with state housing production mandates.
Under SB 79's enforcement architecture, the California Department of Housing and Community Development is empowered to review and approve (or reject) any local ordinance or alternative transit-oriented development plan. HCD may suspend non-compliant local ordinances and refer violating jurisdictions to the Attorney General of California for prosecution. The Attorney General may levy fines of $10,000 to $50,000 per month on non-compliant local governments. Beginning January 1, 2027, a local government that denies a qualifying SB 79 project in a high-resource area is presumed to be in violation of the Housing Accountability Act and is immediately liable for penalties.
The Housing Crisis Driving the Law
SB 79 was enacted against the backdrop of one of the most severe housing affordability crises in American history. California ranks 49th among the 50 states in housing units per capita. The state's median home price is projected to reach a record $905,000 in 2026, according to the California Association of Realtors—roughly twice the national median of approximately $423,000. Only about 18 percent of California households can afford to purchase the median-priced home, meaning 82 percent are priced out. The state's Legislative Analyst's Office reports that only 23 percent of households would qualify for a mid-tier home mortgage based on income, down from 35 percent in 2019.
California's housing shortage has been building since 1970. The state needs approximately 180,000 new units per year to keep pace with demand, yet annual production has not returned to pre-Great Recession levels. New-home closings in Los Angeles fell 30 percent in 2025 compared to the prior year, reaching their lowest level since 2012. In San Diego, the median new-home price has reached approximately $1 million.
Homelessness, the most visible consequence of the shortage, has worsened substantially: point-in-time estimates from the U.S. Department of Housing and Urban Development indicate California's homeless population grew from 123,000 in 2007 to 181,000 in 2023, a 47-percent increase during a period when the state's overall population grew only 7 percent.
The Skeptics' Case
Not all critics of SB 79 are motivated by parochial resistance to density. Neighborhood advocacy groups, represented by organizations such as Neighbors For A Better San Diego, argue that the law displaces housing development from transit-proximate sites—where existing rent-controlled buildings are protected from demolition—to single-family neighborhoods farther from transit, where increased property values incentivize teardowns. They point to San Diego's experience with its "Bonus ADU" program, in which development shifted to areas beyond transit corridors, as a precedent.
The League of California Cities, which opposed SB 79 during the legislative process, has noted that many smaller jurisdictions lack the planning staff and budget to develop alternative plans. Lobbyist Jason Rhine has urged state lawmakers to extend the July 1 deadline, arguing that unresolved questions about transit infrastructure definitions and distance measurement have left planners unable to get started on compliance. No legislator has taken up the proposal.
Transit agencies themselves have expressed ambivalence. In January 2026, the LA Metro Board voted to request that the state exempt all of Los Angeles County from SB 79, arguing that denser housing near transit stations could galvanize housing opponents against new light rail stations and dedicated bus lanes, thereby undermining the transit agency's expansion goals.
The Transit Gap: Density Without Service
There is a structural contradiction at the heart of SB 79 that neither its proponents nor its critics have adequately addressed: the law zones for transit-oriented density without requiring—or funding—the transit service that would make that density livable.
SB 79's eligibility thresholds are tied to infrastructure type and peak-period capacity, not to round-the-clock operational schedules. Tier 1 qualification requires 72 or more trains per day across both directions; Tier 2 requires 48. For bus rapid transit, the standard references peak-period headways of 15 to 20 minutes. None of these metrics require weekend or nighttime service. The San Diego Trolley stops running entirely around 1 AM and does not resume until approximately 5 AM. BART's last trains depart between midnight and 12:30 AM, and weekend service starts later and runs at reduced frequency. Sacramento RT operates on similarly limited schedules. Even New York City's MTA—the largest and most heavily utilized transit system in the Western Hemisphere—runs substantially reduced overnight and weekend service, and underwent its first-ever systemwide overnight shutdown during the COVID pandemic.
The practical consequence for residents of SB 79 buildings is significant. A shift worker returning home at 2 AM, a family needing to travel on a Sunday morning, or a resident who simply wants to go out in the evening may find the transit stop that justified the building's nine-story height allowance dark and closed. Meanwhile, AB 2097, passed in 2022, eliminated parking minimums within a half-mile of transit stops, meaning developers of SB 79 projects have no obligation to provide on-site parking. Residents who need a vehicle for off-peak travel must either pay for structured parking—which typically costs $200 to $400 per month in urban California, when spaces are available at all—or compete for street parking in already-congested neighborhoods.
This burden falls disproportionately on exactly the residents SB 79's inclusionary mandates are designed to serve. The 7 to 13 percent of units set aside for extremely low- to lower-income households house the people least able to afford a parking space or a ride-hailing fare when the trains aren't running. Higher-income residents in market-rate units will absorb those costs without difficulty. The result is a two-tier system within each building: transit-oriented living for those who can afford alternatives when transit isn't available, and effective confinement for those who cannot.
A Possible Solution: HOA-Funded Transit Assessments
One approach that has not yet entered the policy conversation—but could fit squarely within SB 79's existing flexibility framework—is requiring transit-oriented developments to fund transit service improvements through mandatory homeowner association assessments.
The mechanism would be straightforward. A dedicated transit assessment would be written into the CC&Rs of every SB 79 project at the time of approval, running with the land and binding all future owners and residents. The HOA board would collect the assessment and remit it to the local transit agency or a designated transit improvement fund. The obligation would persist for the life of the development, would not require annual legislative appropriations, and would not create a new administrative bureaucracy.
California real estate law already supports analogous structures. Mello-Roos community facilities districts fund infrastructure through special property assessments. Numerous condominium associations in transit-adjacent buildings bulk-purchase transit passes as a resident amenity. Some master-planned communities and senior developments fund private shuttle services through HOA dues. Portland's South Waterfront district required developers to fund a streetcar extension; San Francisco's BART station area plans have included developer contributions to transit operations; Denver's transit-oriented development framework includes negotiated transit service commitments. The HOA model would formalize and scale what already exists in scattered form.
The assessment could be structured to scale inversely with transit service quality: stations with less frequent or less comprehensive service would carry a higher per-unit assessment, creating a financial incentive for transit agencies to improve service and reduce the burden on residents. For deed-restricted affordable units, the assessment could be waived or subsidized, with market-rate units carrying a proportionally larger share—a cross-subsidy that reflects the market-rate residents' greater capacity to pay and their greater benefit from the density premium.
At the individual building level, revenue from a single 100-unit project would not be sufficient to fund extended Trolley hours or weekend service expansion. But aggregated across dozens of SB 79 projects along a transit corridor, the pooled revenue could finance late-night shuttle circuits connecting residents to the nearest active transit hub, subsidize dedicated evening and weekend bus overlay routes, or contribute to the operating costs of extended rail service. The assessment revenue would flow into a pooled fund managed at the transit agency or metropolitan planning organization level—in San Diego's case, SANDAG or MTS—rather than being spent building by building.
Critically, an HOA-based transit assessment would make the transit subsidy visible to buyers and renters at the point of purchase, appearing in HOA disclosure packets and estimated monthly cost breakdowns. No one moves into the building without understanding they are contributing to the transit service that supports the development. That transparency is superior to burying the cost in developer impact fees passed through as higher unit prices.
From a legal and political standpoint, this approach could fit within SB 79's existing local flexibility provisions. The statute authorizes cities to adopt implementing ordinances and transit-oriented development alternative plans, subject to HCD review for "substantial compliance." The statutory test is whether the alternative maintains at least the same net zoned capacity in units and floor area. Nothing in the law prohibits cities from adding conditions that support the transit-oriented purpose of the legislation, provided those conditions do not function as a backdoor density reduction or feasibility killer. A city that presents HCD with an alternative plan that maintains full unit capacity while adding a mechanism to fund the transit service that makes the density workable would be demonstrating that local planning adds value the default state framework does not provide—the strongest possible argument for the local control that cities claim to be defending.
No California city has yet proposed such a mechanism. But the law's flexibility provisions—the same "wiggle room" that Los Angeles, San Francisco, and San Diego are currently using to delay and defer—could just as readily be used to build something constructive. The irony of the current implementation battles is that cities expending their political energy on resistance are missing the design opportunity embedded in the statute itself. The wiggle room is not merely defensive. It is a policy design space—one that could transform transit-oriented development from a zoning label into an integrated housing-and-transportation system that actually serves the residents it claims to benefit.
The Enforcers' Case
California YIMBY, one of the bill's sponsors, acknowledges the law's imperfections but views the current implementation battles as evidence that the statute is working as designed. Aaron Eckhouse, the group's local policy programs director, frames even the delay strategies adopted by Los Angeles and other cities as progress, noting that city officials previously resisted any zoning changes in single-family neighborhoods. The state, Eckhouse argues, "forced the issue."
YIMBY Law, the movement's legal enforcement arm, has established a track record of prevailing against Los Angeles in housing-related litigation, winning all four of its completed lawsuits and recovering approximately $500,000 in legal fees. If cities attempt to defy SB 79 outright after July 1, Eckhouse has suggested that enforcement actions—from the state, from advocacy groups, or both—are likely to follow.
One preliminary analysis by Streets for All estimated that SB 79 would zone capacity for nearly 1.5 million new housing units in the City of Los Angeles alone, enough to double the city's existing housing stock of 1.37 million homes. Over 448,000 of those units would be zoned after the law's initial effective date, with more than one million additional units anticipated during the 7th RHNA cycle beginning in 2031.
What Comes Next
The period between now and July 1 will be defined by three unresolved questions. First, will HCD approve or reject the local ordinances submitted by Los Angeles, San Diego, and other jurisdictions seeking to invoke the law's deferral provisions? HCD officials have not publicly weighed in on any individual city's plan. Second, will cities that have done nothing to prepare—particularly smaller jurisdictions with limited planning capacity—face immediate enforcement action? Third, will any jurisdiction attempt outright defiance?
History provides a partial guide. When the 2021 HOME Act (SB 9) authorized lot splits and fourplexes on single-family parcels statewide, several density-averse cities pushed back: some filed lawsuits, others explored adopting municipal charters, and one briefly considered designating itself a mountain lion refuge. None of these measures ultimately succeeded.
The scale of SB 79 dwarfs those earlier battles. With potential impacts spanning more than 17,900 acres in Los Angeles alone—over half of which were previously zoned for single-family homes—the law represents the most significant restructuring of California's urban land-use framework since the state first delegated zoning authority to local governments. Whether that restructuring produces housing, litigation, or both will depend on decisions made in the 73 days that remain.
Verified Sources & Formal Citations
- California Senate Bill 79, "Housing Development: Transit-Oriented Development," Cal. Gov. Code §§65912.155–65912.162 (2025). https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260SB79
- California Department of Housing and Community Development, "SB 79 Transit-Oriented Development," official program page (updated 2026). https://www.hcd.ca.gov/planning-and-research/sb79-tod
- Christopher, Ben. "Cities scramble to comply with or fight major state housing law." CalMatters, April 15, 2026. https://calmatters.org/housing/2026/04/sb-79-implementation/
- Los Angeles Department of City Planning, "Senate Bill (SB) 79" project page, including Reportback 1 (Nov. 2025) and Reportback 2 (Feb. 2026). https://planning.lacity.gov/resources/senate-bill-sb-79
- "L.A. City Council to allow apartments in some single-family zones to delay SB 79." Urbanize LA, March 25, 2026. https://la.urbanize.city/post/la-city-council-allow-apartments-some-single-family-zones-delay-sb-79
- "L.A. council approves plan for SB 79." Beverly Press & Park Labrea News, March 25, 2026. https://beverlypress.com/2026/03/l-a-council-approves-plan-for-sb-79/
- "Los Angeles City Council Votes on Limited Upzoning." The Real Deal, March 25, 2026. https://therealdeal.com/la/2026/03/25/los-angeles-city-council-votes-on-limited-upzoning/
- "City Council Moves to Delay SB 79 Until 2030." Westside Current, March 25, 2026. https://www.westsidecurrent.com/la_city_news/city-council-moves-to-delay-sb-79-until-2030/article_11af3f74-f1a5-4189-8d09-d39a07f97729.html
- LA Conservancy, "City of Los Angeles SB 79 Implementation" timeline. https://www.laconservancy.org/save-places/issues/city-of-los-angeles-sb-79-implementation/
- City of San Diego Planning Department, "Senate Bill 79" implementation page (updated March 2026). https://www.sandiego.gov/planning/work/senate-bill-79
- "San Diego City starts plan to implement SB 79." FOX 5 / KUSI San Diego, April 2, 2026. https://fox5sandiego.com/news/politics/city-plans-sb79-implementation/
- Circulate Planning & Policy, "Comments on SB 79 Implementation," policy letter, April 14, 2026. https://www.circulatesd.org/comments_on_sb_79_implementation
- "Newsom warns cities of lawsuits over California SB 79 law." HousingWire, March 2026. https://www.housingwire.com/articles/los-angeles-sb79-density/
- "Half Moon Bay among 15 cities Newsom gave 'final warning' over housing law violations." CBS News San Francisco, March 2026. https://www.cbsnews.com/sanfrancisco/news/half-moon-bay-newsom-final-warning-housing-law-violations/
- "Gavin Newsom issues 'final warnings' amid California housing crisis." Newsweek, March 2026. https://www.newsweek.com/gavin-newsom-issues-final-warnings-amid-california-housing-crisis-11742119
- "Newsom Signs Ambitious Bill to Boost Housing Density Near Public Transit." KQED, October 11, 2025. https://www.kqed.org/news/12059533/newsom-signs-ambitious-bill-to-boost-housing-density-near-public-transit
- Holland & Knight LLP, "California Gov. Gavin Newsom Signs SB 79, Unlocking Higher Residential Density Near Transit," October 2025. https://www.hklaw.com/en/insights/publications/2025/10/california-gov-gavin-newsom-signs-sb-79
- Burke, Williams & Sorensen LLP, "SB 79 Explained: How California's Newest Housing Law Changes the Rules Around Transit-Oriented Development," January 12, 2026. https://www.bwslaw.com/insights/sb-79-explained-how-californias-newest-housing-law-changes-the-rules-around-transit-oriented-development/
- California YIMBY, "Governor Newsom Signs Historic Housing Legislation" (press release), October 10, 2025. https://cayimby.org/news-events/press-releases/governor-newsom-signs-historic-housing-legislation/
- California YIMBY, "SB 79 (Wiener): Transit-Oriented Development and Upzoning" (legislative summary). https://cayimby.org/legislation/sb-79/
- "California Senate Bill 79." Wikipedia (updated April 2026). https://en.wikipedia.org/wiki/California_Senate_Bill_79
- "Local Leaders Urge Newsom to Veto SB 79." California City News, September/October 2025. https://californiacitynews.org/2026/03/local-leaders-urge-newsom-veto-sb-79.html
- Neighbors For A Better San Diego, "SB 79" analysis page. https://www.neighborsforabettersandiego.org/sb-79
- Association of Bay Area Governments (ABAG), "Senate Bill 79 (2025)" summary and mapping resources. https://abag.ca.gov/our-work/housing/regional-housing-technical-assistance/senate-bill-79-2025
- California Association of Realtors, "2026 California Housing Market Forecast" (press release), September 17, 2025. https://www.prnewswire.com/news-releases/car-releases-its-2026-california-housing-market-forecast-302558323.html
- California Legislative Analyst's Office, "California Housing Affordability Tracker (4th Quarter 2025)," January 22, 2026. https://lao.ca.gov/LAOEconTax/Article/Detail/793
- Public Policy Institute of California (PPIC), "Three Decades of Housing Challenges in the Golden State," January 27, 2026. https://www.ppic.org/blog/three-decades-of-housing-challenges-in-the-golden-state/
- YIMBY Law, "YIMBY Law to Appeal Sausalito Housing Element Decision" (press release), March 2026. https://www.yimbylaw.org/press/yimby-law-to-appeal-sausalito-housing-element-decision
- Buchalter LLP, "High-Density Transit Zones: California Authorizes Transit-Oriented Development with Senate Bill 79," December 4, 2025. https://www.buchalter.com/insights/high-density-transit-zones-california-authorizes-transit-oriented-development-with-senate-bill-79/
- Lozano Smith LLP, "2025 Land Use & Housing Legislative Developments," Client News Brief No. 60, December 22, 2025. https://www.lozanosmith.com/news-clientnewsbriefdetail.php?news_id=3460
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