See our updated letter on the Residential Expansion Threshold.
San Francisco Planning Commission
1650 Mission Street, Suite 400
San Francisco, California
May 31, 2017
Re: Residential Expansion Threshold / Large Home Application
Dear Ms. Watty and Ms. Bendix,
Earlier this year, the Planning Department released “Housing for Families with Children.” Per that report, “An astonishing 72% of the city’s privately owned parcels are zoned for single-family housing (RH-1) and two-unit housing (RH-2).” The proposed Residential Expansion Threshold would affect an even larger percentage of parcels and therefore has far-reaching implications for the future of housing in San Francisco. We simply will not succeed in solving the housing shortage devastating our city by burying our heads in the sand about the damage that existing low density zoning has done.
While we applaud efforts to incentivize density where zoning allows, the current proposal is far too little far too late — and it comes at the expense of erecting a massive new barrier to making the “Missing Middle” housing type possible. The record clearly shows that the driving force behind the Residential Expansion Threshold was to “limit the size of the finished project to be more consistent with neighborhood character.” This completely contradicts the Department’s own findings in Housing for Families with Children, which clearly states that “Mid-size buildings are much less expensive than single family homes and fit in with the scale of our urban neighborhoods.”
From the outset, the Residential Expansion Threshold has been predicated upon the flawed notion that smaller massing is inherently good. Incentivizing and perpetuating smaller massing further entrenches existing exclusionary zoning at exactly the time it must be reconsidered. Per the attached letter, YIMBY Action recently called for the up-zoning of all single family and duplex lots to allow for more multifamily housing in every neighborhood of San Francisco.
However, you don’t have to take our word for it. Our criticism of the Residential Expansion Threshold practically writes itself from the Planning Department’s own report on “Housing for Families with Children”:
The “Missing Middle” is housing that could be more affordable for families and fit in well with our historic tradition of different types of housing throughout our neighborhoods. These housing types could provide the much-needed family housing that is no longer being built. One reason that the Missing Middle is no longer being built is because of our zoning restrictions. … Larger lots are frequently found in the eastern part of San Francisco where podium-style and even tower housing can be built, but the City has a limited number of lots large enough to host this scale of building. Small-lot, three to five story, family-friendly housing would be entirely in keeping with our western neighborhoods, where relatively few households occupy comparatively large swaths of our city’s land. One tool to change this restriction is to allow neighborhoods to be zoned by the form that the building takes, also known as form-based zoning. This tool allows the City to regulate based on the appearance, the height, the bulk, etc. and not simply based on the number of units. Regulations can still ensure that lot size is considered and that there are a maximum number of total units and/or a minimum number of larger two and three bedroom units to ensure that this type of housing remains family-friendly housing. In a recent feasibility analysis conducted for the Planning Department, limited increase in density allowed made certain projects feasible, thus increasing the number of units that could be built for families throughout our neighborhoods.
It is completely rational to dismantle the system of incentives driving production of oversized units that are out of reach for most San Franciscans; it is completely irrational to squander the remainder of the massing allowed under current zoning in the middle of an extreme housing crisis. That massing can and should be redirected toward producing additional units of housing to help alleviate the shortage.
As detailed in the previously-referenced up-zoning letter, low-income and historically minority neighborhoods have been asked to shoulder a disproportionate amount of our citywide housing needs for far too long, an injustice that must end. Following the theme of higher-income neighborhoods not doing their fair share, we learned from the community conversations hosted by Planning that Districts 2 and 8 are motivating the Residential Expansion Threshold. That is telling.
“Housing for Families with Children” provides the policy prescriptions that should be guiding the Planning Department and Commission’s work. We implore you — do not let the Residential Expansion Threshold stand in the way of building the Missing Middle. Now is the time to talk about up-zoning, form-based zoning, and relaxing density controls — before a new policy enshrining the status quo is enacted, not after. At minimum, the Residential Expansion Threshold should be part of a package deal that reduces density controls.
Our narrower feedback on the current proposal follows:
It increases the burden on the Planning Commission’s scarce time
The Planning Commission is already overburdened. Dates for Discretionary Review hearings are booked many months out, and the proposed Large Home Authorization hearings will only exacerbate the situation. This is the perfect opportunity to get to the root of the problem — an artificial scarcity of Planning Commission hours. This is and always has been a highly solvable problem. Instead of finding new ways to add to the burden the Planning Department and Planning Commission, we should be looking for ways to reduce their workload by streamlining processes. What would it take to drive wait times down to 3-4 weeks? It seems like this will cause such additional work as to require an entire other commission to handle the workload.
Include a reasonable allowance for garage/storage/mechanical space.
Garages are a very common feature of buildings in the residential neighborhoods. When they are factored in, the currently proposed FAR triggers stop making sense. A clear and reasonable allowance for parking vehicle and/or bicycle, storage, and mechanical space should be added, with larger allowances for more units. To avoid incentivizing and especially subsidizing private vehicle ownership, a portion of the allowance should be convertible to interior space as a benefit for projects that choose to forego vehicle parking.
It is already a broad planning trend that parking minimums be eliminated and parking be made optional. When we factor in garage space, the proposed FAR does not make sense. Increased space should not be required to be garage space, and parking should absolutely be optional. The square footage allowance should be increased, to allow for conversion to Accessory Dwelling Units of the future. If the spaces are too small, it is unlikely these homes will be subdivided in the future.
The selected criteria will be of paramount importance in determining the quality of the proposed Large Home Review hearings. Here are some questions and concerns to consider as they are developed in greater detail.
- High quality architectural design
- What is high quality architectural design? This will need to be objectively defined. We were told that the images featured in the May 2016 presentations were not intended to illustrate anything. The details of items 1 and 2 can only be worked out with ample positive and negative examples for all to reference, review, and debate.
- We encourage an emphasis on quality materials over considerations of beauty as materials are much more objective. However, we continue to fail to understand what the Planning Commission brings to this conversation that the professionals that make up our Planning Department do not.
- Contextual and compatible building siting, orientation, massing, scale
- What will this accomplish that the Residential Design Guidelines do not already accomplish? This criterion makes the Residential Expansion Threshold as currently proposed a giveaway to NIMBYs who do not wish to see their neighborhoods grow. It should be eliminated.
- The Planning Department and Commission previously passed DR reform. That effort should be revived rather than running in the opposite direction by effectively granting free DRs for many more projects than were previously ensnared in that process.
- Progress Noe Valley said this before and we’ll say it again. The Residential Expansion Threshold should be data-driven and rigorously tested against real world data from past projects. If appropriate scale really must be reconsidered, evidence should first be compiled to demonstrate the flaws in the current policy. None of this has happened.
- If not eliminated, this criterion should explicitly state that a project’s massing does not have to be equal to or smaller than its neighbors to be contextual and compatible. Additionally, define relevant context in a manner that is not overly narrow.
- Compatibility with surrounding density
- We understand that this criterion is aimed at allowing densities lower than the maximum allowed by zoning when compatible with the surrounding existing density. This goal should be discouraged. This provision is not compatible with a growing city. It should be eliminated.
- We are concerned about the Planning Commission’s recent enthusiasm for economic segregation by forcing large single family homes to be clustered together rather than located amongst multifamily housing.
- Family friendly amenities
- Per Housing for Families with Children’s next step #2 (page 34), there is no clear definition of what a family friendly unit or building should contain. It states that “[t]he inclusion of many amenities would necessitate a trade-off with affordability and would require further study.”
Additional items to consider
We have been disturbed to see potentially discriminatory matters like family status and personal family planning decisions taken into consideration by the Planning Commission in the course of DR hearings. As stated in the community conversations, buildings long outlast their current owners. Any consideration of program should be explicitly separate from the personal situation of the current intended occupants.
Laura Fingal-Surma, Board Member at YIMBY Action
Laura Clark, Executive Director of YIMBY Action