Letter to Mayor Lurie re Housing Element Capacity FZP Amendments

District 1

Dear Mayor Lurie:

In partnership with community advocates across the city, we have been working with you in good faith to improve the proposed upzoning plan by doing more to mitigate harm to tenants and small businesses facing displacement. We understand that the proposal is one version in response to the state-mandate, but we need full and transparent accounting of the capacity the City has created over the past year to ensure we protect San Francisco and maintain local control.

After months of meeting and public discussion, and now with the steadfast support of our community stakeholders, we remain committed to the following “non-negotiable” amendments:

  1. We will not demolish people’s homes to replace them with market-rate units. Our existing housing is our most affordable housing.
  2. We will not demolish the most important parts of San Francisco’s iconic history and culture.
  3. We will protect our coastal zone and defend against Trumpian privatization of public access.
  4. We demand real family housing.

As stated in the proposed ordinance, Housing Element 2022 requires that the city has a realistic capacity for 82,000 additional units by 2032. This capacity comes from a combination of pipeline projects, inventory of the city’s existing development sites, and changing the city’s existing zoning. The Sites Inventory in the Housing Element identified approximately 58,500 units of existing realistic capacity and was certified by California Housing and Community Development (HCD) in 2023. The proposed upzoning plan aims “to rezone and address the shortfall of 36,200 housing units” (File No. 250701, Page 7, Line 2).

Since the Sites Inventory was conducted over two years ago, the shortfall of 36,200 units was determined according to the conditions in 2022 and has not been updated to account for any capacity created as a result of zoning changes between then and the publication of the proposed upzoning plan. This is a fact that Planning had foreseen in its Sites Inventory, citing that pending legislations – including Board File 210866 “Fourplex” and Board File 211092 "Automotive Uses and Housing Density” – “will raise the number of available sites in sites inventory output and lower theanticipated shortfall and potential rezoning proposal accordingly” (Housing Element – Appendix B, Page 46). Both of the legislations have since passed and been signed into law.

Additionally, in March of this year, the Board of Supervisors unanimously passed legislation sponsored by the Mayor and Supervisor Matt Dorsey, which reduced commercial and office development requirements for large projects in the Central SoMa Area Plan and the Transit Center C-3-O SUD (Board Files 240787 and 250003). This action alone increased the city’s realistic housing capacity by as much as 8,500 units.

For example, the following five large sites can now accommodate thousands more additional housing units according to new project applications submitted by developers after the recent policy change:

  • 610 Brannan (Former Flower Mart) - Developer Kilroy Realty submitted new plans to Planning in September 2025 which include a variant with 3,532 additional housing units.
  • 88 Bluxome - Developer Strata has submitted new plans in response to this new legislation with 1,500 new housing units.
  • 725 Harrison - Currently entitled office project (845,000 sf) can now accommodate up to 1,000 housing units (Estimation proportionate to Flower Market project variants).
  • 598 Brannan - Entitled office project (1 million sf) can now accommodate 1,175 housing units (Estimation proportionate to Flower Market project variants).
  • 490 Brannan - Entitled office project (269,000 sf) can now accommodate 315 housing units (Estimation proportionate to Flower Market project variants).
  • 3 large “opportunity sites” – approximately 1,000 unentitled units spread across three undisclosed “soft sites” identified by SF Planning.”One of these sites is in the Transit Center District and two are in Central SoMa” (SF Planning Department report on its change to the Central SoMa Plan, Page 6).

It is evident that the Board of Supervisors has been proactively working towards compliance of the Housing Element, but San Francisco has yet to receive credit for capacity created before the proposed upzoning plan. The upzoning plan’s goal of creating 36,200 should be amended to reflect the increased capacity.

Again, we remain committed to meeting the State’s housing mandate. We also believe that San Francisco has the capacity to meet this goal and develop family housing without displacement and erasure of San Francisco’s most critical assets.We sincerely urge you to stand with San Francisco, defend local control, and accept the collective amendments into your proposed upzoning plan.

Sincerely,
Connie Chan
Board of Supervisors

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