Chris Elmendorf Profile picture
Mar 27, 2022 24 tweets 13 min read Read on X
@sfplanning just released drafts of the keystone pieces of city's housing element: (1) analysis of site capacity (as zoned), (2) analysis of constraints.

tl,dr: big progress on conceptual level, huge problems in practice.

This 🧵 covers sites; stay tuned for constraints. 1/22
The big & welcome news is that SF, like LA, undertook to comply w/#AB1397 by modeling sites' probability of development during planning period & discounting sites' nominal zoned capacity by p(dev). 2/

The leadership of SF and LA on this issue, coupled with @California_HCD's rejection of nearly all housing elements from SoCal cities, is going put pressure on other cities to get on board the p(dev) train. 3/
This is *so* important, b/c for last 40 years, cities have gotten away with junk plans premised on patently false assumption that if a site could be developed during planning period, it would be developed. 4/
papers.ssrn.com/sol3/papers.cf…
Reality check: in Bay Area, a typical 5th cycle "housing element site" had less than a 1-in-10 chance of development during planning period.
A site zoned for 100 homes should have counted for 10 or fewer, but it was counted for 100. 5/

escholarship.org/uc/item/6786z5…
The false p(dev) = 1 assumption allowed nearly all cities in expensive places to avoid rezoning for additional capacity. /6

lewis.ucla.edu/research/a-rev…
But as LA and now SF have discovered, a city that's realistic about p(dev) will have to rezone. A lot.
Or at least it should... /7
SF hired an economics consultant to fit a p(dev) model to data from 2001-2018 and, as described, the model seems reasonable. So far, so good. /8
Consultant concluded that SF has p(dev)-adjusted capacity for ***less than 21,000 new homes, under current zoning, over the next 30 years.***

Whereas the city's state-assigned housing target exceeds 80,000 homes over just the next 8 years! /9
So, big rezoning? There ought to be! But SF purports to backfill most of deficit w/ handwavy, "trust us" assumptions about other sources of capacity, ultimately committing to rezone for only ~22,000 more units.

The money table is on p. 8. Let's break it down. /10
For starters, city posits that 50% of modeled capacity over next 30 years will materialize in next 8 years.

Rationale: state law is now better for development, so a model fit w/2001-18 data understates capacity under current law. Ok, that's directionally correct. /10
But even using that indulgent assumption, SF has "modeled" capacity for only about 10k homes, leaving massive shortfall (another 72k-84k units).

And this is where things get real wacky. /11
First, city posits that sites which "met criteria provided by mayor's office" for funding 100% affordable projects have p(dev) = 0.50!
City provides *zero* information about rate at which such sites have been developed in the past. /12
It takes real chutzpah to assert, w/o any evidence or even info about city's financial capacity to acquire these sites, that sites targeted for social housing have vastly higher p(dev) than other sites.

But this "saves" S.F. from rezoning for 8600 more units. /13
Now to the biggest skeletons: the "development pipeline."

City credits itself w/nearly 50,000 units from "housing ... projects that have been proposed or that have already received [planning] approvals but that have not received building permits." /14
What's the basis for these numbers? "[D]iscussion with city agencies working on the [pipeline] projects to assess units likely to be delivered over RHNA period."

That is, "trust us." /15
Notably absent: any analysis of what share of "pipeline" projects from last housing element got developed during the last planning period. (SF's last plan counted ~35,000 "filed or approved" units.) /16
Finally, after all the massaging of numbers, SF concludes that it ought to rezone for ~22,000 more homes, & that for fair-housing reasons, they should be located on west side of city.
Some housing advocates are rejoicing. /17
But: in connection w/ analysis of constraints (more on that later), SF hired consultant for pro-forma analysis of different types of housing projects in different areas...and the consultant concluded that *nothing pencils out on the west side*. /18
On basis of that study, @sfplanning says that w/ current permitting process, impacts fees, exactions, & construction costs, the *only* kind of project that's economically feasible is a 24+ story high-rise in city's highest-demand neighborhoods. /19
Yet SF "plans" to meet its ~22,000 unit shortfall (after hand-waving) by rezoning west-side corridors for 55'-85' projects that per city's own analysis would have *negative* rate of return.

This is a cruel joke. Except it's no joke. /20
Here's the big picture: to meet its 82k unit target, San Francisco must *triple* its typical annual housing production.
Rezoning the west side for 22,000 economically infeasible homes won't cut it. /21
@California_HCD should nix this plan unless SF:
(1) backs up its "pipeline" & "mayor's office" projections w/ public data, &
2) commits to ministerial review + waiver of fees/exactions/standards that render projects economically infeasible until city reaches RHNA target.
/end

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More from @CSElmendorf

Jun 8
.@Planning4LA has issued new CEQA streamlining checklist for projects within scope of housing element EIR.

Here's a 🧵comparing L.A. & S.F.'s use of housing element EIRs to streamline CEQA review of projects & rezoning.
1/16
planning.lacity.gov/odocument/d9f4…
Both cities (wisely) did a full EIR for their housing elements, saving time, grief & litigation risk down the road.

Even more wisely, both cities put most developable parcels in their housing element site inventories, w/ p(dev) adjustments.
/2
This (should) mean that almost any proposed development in either city is within scope of housing element EIR, at least until the time that the city has hit its (huge) target for new homes.
/3
Read 16 tweets
Jun 3
California shoots self in foot, again:

@AsmChrisWard's bill to revisit CA Building Code w/ goal of reducing construction costs by 30% has been gutted.

It now just prescribes study of whether to allow 3-10 unit buildings under residential code.



1/12 leginfo.legislature.ca.gov/faces/billNavC…
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CA's "housing crisis policy" has been to pass dramatic bills allowing big apartment & condo projects to be built as of right & in derogation of local zoning--but only if the projects would be so costly that (almost) none get built.
/2

papers.ssrn.com/sol3/papers.cf…

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Our cities do the same.

And so we end up w/ ironies like the many San Jose developers who are proposing builder's remedy projects that are *less dense* than local zoning allows.

And using state "density bonus" law to reduce, rather than increase, a project's density.
/3

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Read 12 tweets
May 18
Pictured below is a S.F. & California housing policy failure unfolding in my neighborhood.

The corner lot, upzoned in 2009, was designated in city's housing element for up to 72 units of housing.

It's now being gut-renovated for 2.

1/🧵. Image
The lower level of the building is a storefront and has been boarded up for as long as I can remember. Ages.

The upper level is listed in city records as a single dwelling unit and I think was occupied (probably rented).
/2
A 2009 rezoning of the city's "Eastern Neighborhoods" designated the corner lots at this intersection for greater height (55') than the citywide default (40').
/3
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Read 16 tweets
Apr 30
🥳New papers! A cornucopia! (well, 3).🎆

#1: "What State Housing Policies Do Voters Want? Evidence from a Platform-Choice Experiment" (w/@ClaytonNall & @stan_okl)

written for a @JPIPE_journal symposium on political economy of housing



🧵/21 papers.ssrn.com/sol3/papers.cf…
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#2: the long-awaited revision of "Folk Economics and the Persistence of Political Opposition to New Housing" (w/@ClaytonNall & @stan_okl)

a/k/a, our "Housing Breaks Brains" paper

now greatly improved, thanks to @aletheia_tweets peer-review process


/2 papers.ssrn.com/sol3/papers.cf…

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#3: "Plain-Bagel Streamlining? Notes from the California Housing Wars" (w/ @ClaytonNall)

forthcoming in a @CaseWRsrvLRev symposium on "Permitting the Future," organized by @jadler1969
/3


papers.ssrn.com/sol3/papers.cf…
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Read 21 tweets
Apr 25
New superior court decision holds that California's SB 9 (duplex and lot-split bill) unconstitutionally infringes on charter cities' "home rule" authority.

It's a weird, narrow decision that turns on a lawyerly sleight of hand. I don't think it will hold up on appeal.🧵/15 Image
Under California law, legislation that limits local control over a traditional field of municipal concern like land use must be reasonably tailored to advance a matter of statewide concern.
/2
In SB 9, the legislature "found and declared" that "ensuring access to affordable housing is a matter of statewide concern."
/3 Image
Read 15 tweets
Apr 21
Must read @SFjkdineen story on SF's "inclusionary housing" program for middle-income households.

It's yielding mass vacancy rather than housed middle-income families.

Why? B/c of panoply of death-by-good-intention allocation & pricing rules.
🧵/12.

sfchronicle.com/sf/article/mis…
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Sin #1: An arcane set of "preference" categories, which make applications cumbersome to fill out & review, and which result in units sitting vacant b/c they've been pre-allocated to a different preference group.
/2 Image
Sin #2: An inane requirement that units not merely be affordable to households in the target income bracket, but also be leased for at least 20% less than their fair-market rent.
/3 Image
Read 12 tweets

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