OPPOSITION to Proposed Family Zoning Plan (2021-005878 GPA PCA MAP) Items 14(a), 14(b) and 14(c): General Plan Amendments; Planning Code Text Amendments; and Zoning Map Amendments
September 9, 2025
Lydia So, President
San Francisco Planning Commission
49 S. Van Ness, Suite 1400
San Francisco, CA 94103
Via email: commissions.secretary@sfgov.org
RE: OPPOSITION to Proposed Family Zoning Plan (2021-005878 GPA PCA MAP)
Items 14(a), 14(b) and 14(c): General Plan Amendments; Planning Code Text Amendments; and Zoning Map Amendments
Dear President So and Commissioners,
On behalf of the Telegraph Hill Dwellers (THD), we write to strongly OPPOSE the Mayor’s proposed Family Zoning Plan (“Mayor’s Zoning Plan”), specifically the inclusion in the Mayor’s Zoning Plan of major portions of Telegraph Hill, North Beach, and the Northern Waterfront which were not in the 2022 Adopted Housing Element (“Housing Element”) nor were the resulting new impacts considered in the Final Environmental Impact Report (FEIR).
For more than seventy years, since 1954, THD has worked hard to build, maintain, and celebrate the vitality, livability and sustainability of some of San Francisco’s most cherished neighborhoods. We have embraced a vision of housing growth that prioritizes affordable housing while fully protecting our existing tenants, vibrant small businesses, historic resources, and diverse culture of District 3, safeguarding the soul, vitality, and vibrancy of our densely developed neighborhood. Now the Mayor’s Zoning Plan puts all of that at risk.
As set forth below, the Mayor’s Zoning Plan is inconsistent with the approved Housing Element, resulting in new major impacts not considered in the FEIR.
- Remove North Beach, Telegraph Hill, and the Northern Waterfront, including Fisherman’s Wharf from the Mayor’s Zoning Plan.
In mid-2025, Mayor Lurie proposed a Draft Upzoning Plan that for the first time included proposed height increases and density decontrols in the North Beach, Telegraph Hill, and Northern Waterfront areas, which had not been included in any of the previously proposed Upzoning Maps. Most notably, these changes were not in the “Proposed Action” analyzed in the adopted and certified FEIR, nor were they included on any of the “Rezoning Program Scenarios” contained in the adopted Updated 2022 Housing Element (“Housing Element”). And, every figure considered in the FEIR, including for example the possible future consideration of a Housing Sustainability District, specifically excluded these areas.
As revealed in the proposed Addendum to the FEIR, although the Housing Element and FEIR assumed and considered that the Northeast Planning District would provide net new housing units of only 800 units, the Mayor’s Zoning Plan now proposes 5,900 units, a stunning 650% increase. The proposed major height increases and density decontrol in the Mayor’s Zoning Plan to accommodate this increase would have significant additional impacts on existing tenants, small businesses, historic resources, parks and open spaces, and the diverse culture of District 3 that were never considered during the extensive public process leading up the adoption of the Housing Element.
Further, most of the areas in North Beach and the Northern Waterfront area now shown as being added to Mayor’s Zoning Plan are within the Priority Equity Geographies Special Use District, which the Housing Element and FEIR assumed would not be within the areas to be upzoned or density decontrolled.
We have learned from discussions with individuals in the Planning Department, confirmed by emails obtained through a Sunshine Act Request, that the addition to the Mayor’s Zoning Plan of these sensitive areas of District 3 was done with the specific approval of District 3 Supervisor, Danny Sauter. We urge the Planning Commission to require the Planning Department and Office of the Mayor to remove North Beach, Telegraph Hill, and Northern Waterfront areas from the Mayor’s Zoning Plan.
2. Major Impacts to District 3 Neighborhoods Not Addressed in the FEIR
The Mayor’s Zoning Plan would imperil our neighborhood’s existing rent-controlled, multi-unit family housing, ethnic diversity, historic and cultural resources, parks, and economic vibrancy of our small neighborhood businesses. Moreover, it would encourage speculation and set up conditions that would have adverse social and economic effects on our neighborhoods. As pointed out below, such impacts are in direct conflict with the adopted Housing Element.
Significant New Threats to Existing Tenants and Rent-Controlled Housing
North Beach and Telegraph Hill are among the densest neighborhoods in San Francisco, with roughly 82% of our residents living in existing pre-1979 multi-family, rent-controlled buildings that house our City’s workforce and seniors, including a large immigrant Asian population. Based on the City’s profiles of neighborhoods in San Francisco, there are 37,156 people per square mile in North Beach as compared to 17,325 people per square mile in San Francisco.[1] The Planning Department’s own maps show that rent-controlled buildings in District 3 (built before 1979 with 2+ units, excluding condos) represent approximately 32,336 units. And data collected by the SF Anti-Displacement Coalition and the SF Rent Board shows that, as a result of the Ellis Act, owner move-ins, buy-outs, and other no-fault evictions, many of our most vulnerable seniors and low-income tenants have already been displaced by speculators who turned their former homes into TICs and condominiums, often merging units for increased profits.
The Mayor’s Zoning Plan, with its proposed upzoning and density decontrol in North Beach and Telegraph Hill, would further increase property values in these neighborhoods resulting in even greater speculation, demolitions, and displacement of our tenant population, which is in direct conflict with the Housing Element. Section 2 of the Housing Element: “Stabilizing Tenants and Rental Housing” acknowledges these threats:
“Tenants often face greater housing precarity because they do not own their own homes and are more likely than homeowners to be lower income, face high housing cost burdens, and are often at greater risk of displacement. A majority of San Francisco residents are tenants, so tenant stability is often key to stabilizing communities.”
Existing legal protections for tenants have not prevented evictions, nor will the so-called “tenant protections” for rent-controlled buildings contained in the legislation enacting the Mayor’s Zoning Plan prevent the flood of displacement incentivized by the proposed upzoning and density decontrol in District 3. Incentives for redevelopment provided by the upzoning and density decontrol, along with deregulation, will intensify demolition and displacement, destabilizing our communities. This creates long-term blight as properties become vacant, and developers dither because of outside factors like financing and adverse market conditions. Displaced tenants will be unable to afford the new units, even in the very low number of so-called “affordable units” assumed in the Mayor’s Zoning Plan, and will disappear from our neighborhood.
We urge the Planning Commission to require the Planning Department and the Mayor’s office to remove from the proposed Draft Upzoning Plan all height increases and density decontrols from existing multi-family, rent-controlled housing. The density of pre-1979 rent controlled units is the reason North Beach was never, until now, a part of the “Proposed Action” in the adopted and certified 2022 Housing Element EIR.
Significant New Impacts to Small Businesses
Columbus Avenue and Union and Powell Streets are part of the economic and cultural anchors of North Beach. Our small-scale retail corridors, where many are individually listed as Legacy Businesses, support hundreds of jobs, contribute significantly to the economic vibrancy and livability of our neighborhood, and are integral to the tourism industry that further contributes to supporting local employment and small businesses.
Importantly, the Housing Element does not call for upzoning or density decontrol of any of the retail corridors in North Beach, nor did it call for upzoning on Lombard, North Point, Beach, Jefferson, Chestnut, Francisco, or Bay Streets. None of the North Beach or Northern Waterfront retail corridors now shown in the Mayor’s Zoning Plan were considered or analyzed in the adopted FEIR.
As stated in a joint letter to Mayor Lurie from multiple Westside and Northern neighborhood business leaders, including many from North Beach:
“Despite being labeled “family zoning,” the plan will not deliver affordable housing for working families or protect small, family-run businesses. Instead, it threatens to displace workers, shutter long-standing neighborhood institutions, and hand over our communities to speculative development.
“Already, parcels are being acquired and storefronts left vacant in anticipation of redevelopment. Our neighborhood businesses—still recovering from the pandemic, debt, and rising costs—cannot survive without stronger protections. The proposed upzoning, which allows 6–14+ story projects to replace century-old, three-story buildings, would overwhelm narrow streets, strain emergency services, and force closures of businesses that have served San Francisco for generations.”
Although the Mayor’s Zoning Plan offers developers height increases and additional density in return for agreeing to locate displaced businesses in their proposed developments, we are aware that the ground floors of many new large apartment and condominium buildings are mostly vacant – look at those on Market Street or other corridors like Van Ness Avenue.
In District 3, the experience of The Jug Shop, a 60-year-old Legacy Business on Pacific Avenue at Polk Street foretells the future of our small businesses resulting from the Mayor’s Zoning Plan. The Jug Shop was displaced and its home demolished to make way for a large-scale market-rate condominium development. The Jug Shop temporarily relocated a block away, hoping to return to the ground floor of the new condominium building on the site of its former long-time home. Unable to afford the build-out on the ground floor of the new building, it was forced to go out of business after 60 years of continuous operation. This will be the model for District 3 going forward if the proposed upzoning is adopted.
Upzoning these corridors would trigger redevelopment that almost always begins with demolition and displacement of small businesses. Like The Jug Shop, absent legal protections, displaced businesses would not survive the transition. Additionally, adjacent businesses are often dragged down by years of construction-related disruption. Noise, fencing, blocked sidewalks, lost parking, and reduced foot traffic can destabilize commercial blocks. The result is not affordable housing—it is the slow erosion of the vitality and street life, and the interconnectivity of the community, that make our neighborhoods work.
Furthermore, upzoning and density decontrol on commercial corridors in District 3 would increase property values and lead to commercial rent increases, forcing out many small businesses that are thriving economically under the existing zoning. The upscale commercialization of our neighborhood will never lead to more affordable housing.
We urge the Planning Commission to require the Planning Department and the Mayor’s office to remove North Beach and its thriving neighborhood commercial corridors from the Mayor’s Zoning Plan. They were never a part of the Housing Element, never appeared in any prior upzoning maps and were not considered part of the “Proposed Action” in the adopted and certified FEIR.
Significant New Impacts to Historic Resources
North Beach and Telegraph Hill are among the oldest and most significant historic neighborhoods in San Francisco. The Telegraph Hill Historic District, filled with survivors of the 1906 Earthquake and Fire, is one of the earliest historic districts designated under Planning Code Article 10. A fully documented proposed North Beach National Register Historic District, which the Mayor and Supervisor Sauter have thus far refused to support, clearly qualifies for recognition on the California and National Registers of Historic Places. The Washington Square Historic District, The Powell Street Shops Historic District, and the Upper Grant Avenue Historic District are recognized by the City Planning Department as eligible for the California Register of Historic Resources. Washington Square is San Francisco Landmark No. 226. The Northern Waterfront contains at least seven Article 10 landmarks and National Register listed buildings. In addition, surveys of North Beach and the Planning Department’s maps show hundreds more “A-Rated Buildings” in District 3.
As these areas were not included in the Housing Element, the addition of these historic areas to in the Mayor’s Zoning Plan would threaten historic sites and districts with potential demolition and redevelopment, potentially significant additional impacts not analyzed in the FEIR. An Addendum to the FEIR is not a substitute for analysis of additional impacts from a changed project.
Attached to the Addendum to the FEIR is Appendix D, Memorandum Regarding Potential Zoning Map Changes In Supervisor District 3, which proports to use the FEIR and the Addendum to the FEIR as a substitute for environmental review in anticipation of adding even more development to the Mayor’s Zoning Plan, by changing the base density of significant areas within the Article 10 Northeast Waterfront Historic District along Sansome Street to form-based density. Layering a State Density Bonus on form-based density within this historic district would allow building heights to be supercharged upward to as high as 200-300 feet (as demonstrated by proposed buildings at 950 and 1088 Sansome). This increase in development intensity is of particular environmental impact concern given the high frequency and severity of landslides in that area. This addition to the Mayor’s Zoning Plan is clearly a major impact that has not been analyzed in the FEIR.
To illuminate the disparities between the Housing Element and the Mayor’s Zoning Plan, we share the following actions contained in the Housing Element which specifically provide for the designation and promotion of historic districts:
”4.5.5 Designate historically and culturally significant buildings, landscapes, and districts for preservation using the Citywide Cultural Resource Survey, Planning Code Articles 10 and 11, and state and national historic resource registries to ensure appropriate treatment of historic properties that are important to the community. . .and to unlock historic preservation incentives for more potential housing development sites.”
“4.5.8 Promote historic preservation and cultural heritage incentives, such as tax credit programs and the State Historical Building Code, for use in residential rehabilitation projects through general outreach, interagency collaboration with MOHCD and OEWD, building trades collaboration, educational materials, community capacity building efforts, and the regulatory review process.”
In conflict with the above provisions of the Housing Element, there is no provision in the Mayor’s Zoning Plan to provide protections for historic buildings, and there are no historic preservation incentives, such as making available tax credit programs, the Mills Act property tax reduction, or the State Historical Building Code, for use in residential rehabilitation projects. Further, the Mayor and Supervisor Sauter have continued to thwart the designation of the North Beach National Register Historic District.
The protection of cultural assets and historic resources is a legitimate exercise of the City’s police powers and the City’s ability to protect historic resources is a well settled legal principle. The failure to include such protections in the Mayor’s Upzoning Plan is a choice to intensify threats of demolition of our City’s cultural assets and historic resources important to our communities. These protections must be added to the Mayor’s Zoning Plan.
We urge the Planning Commission to recommend the addition of protections and incentives for the preservation of historic properties, and to urge the Mayor and Supervisor Sauter to join with local businesses, organizations, residents, and property owners in support of the designation of the proposed North Beach National Register Historic District.
New Shadow Impacts to Parks and Open Spaces in North Beach
North Beach is among the areas of the City with the greatest density and the least amount of parks and open space per person with only two well-used parks – Joe DiMaggio Playground and Washington Square (Landmark No. 226) – both under the jurisdiction of the San Francisco Recreation and Parks Department. In addition to these parks, Levi’s Plaza Park, a private open space bounded by The Embarcadero and Battery Street, designed by renowned landscape architect Lawrence Halprin, is proposed to be changed to form-based density by Mayor’s Zoning Plan. The additional impacts to these parks and open spaces were not analyzed in the FEIR.
The Mayor’s Zoning Plan proposes to upzone up to 65 feet (from the existing height limit of 40 feet) parcels surrounding Joe DiMaggio Playground for projects using the Housing Choice local program. While State Density Bonus projects could be as high as 2 times the current height limit, or 80 feet (8 stories), a change to form-based density could allow even greater heights. This would also be the case for parcels surrounding Washington Square Park.
Because Joe DiMaggio Playground and Washington Square are under the jurisdiction of the Recreation and Park Department, they are protected by a voter-approved Planning Code amendment restricting the construction of any structure exceeding forty feet in height that would cast a shadow that is adverse to the use of the park from between one hour after sunrise to one hour before sunset. Because of the small size and location of Washington Square, it has been determined that it can tolerate no new shadow. In addition, any new shadow on Washington Square must be assessed for its impact on an Article 10 Landmark site.
Since the area including North Beach, Telegraph Hill and the Northern Waterfront was not proposed for upzoning in the Housing Element, the FEIR did not assess the additional shadow impacts on parks and open spaces in the areas added by the Mayor’s Zoning Plan, including but not limited to Washington Square, Joe DiMaggio Playground, and the Levi Plaza Park.
Significant New Impacts on the Northern Waterfront
For more than 60 years, the northern portion of District 3, nearest to the waterfront, has been zoned at a maximum height of 40 feet. The Mayor’s Zoning Plan proposes increasing those heights to 65 and 85 feet, along with density decontrol. Layering a State Density Bonus on density decontrol could supercharge building heights upward to much higher than 85 feet.
The effect of this layering can be seen for a proposed nearby building at 955 Sansome. Currently zoned to a maximum height of 84 feet, by layering a State Density Bonus and density decontrol, the proposed building is nearly 300 feet in height. For reference, this is more than three times the zoned height limit, more than three times taller than the tallest building in the Northeast Waterfront Historic District in which it is located, and even taller than Telegraph Hill itself.
If the upzoning to 85 feet proposed between Bay Street and Beach Street is adopted, buildings, such as that proposed at 955 Sansome almost certainly would be built, creating a new wall on the waterfront, which was soundly rejected by San Francisco Voters in 2013, and by a supermajority of the Board of Supervisors last year.
Also, the 2022 Housing Element Update identifies significant portions of the Northern Waterfront as earthquake Liquefaction Hazard Zones (see Figure 4.1-26, Liquefaction Hazards). Since none of that area was proposed for upzoning in the Housing Element, the FEIR did not assess earthquake liquefaction impacts in that area and their potential significance. However, the Mayor’s Zoning Plan extended upzoning to portions of the Northern Waterfront that are within the Liquefaction Hazard Zones. As such, analysis of liquefaction hazard impacts must be done.
We further call your attention to the fact that the area being upzoned on the Northern Waterfront is within the Priority Equity Geographies Special Use District and outside of the Well-Resourced Neighborhoods that are the focus of the Housing Element. It appears this area was included to provide incentives for developers to build large market-rate housing with bay views, offering significant profit.
We urge the Planning Commission to require the Planning Department and the Mayor’s office to remove the Northern Waterfront from the Mayor’s Zoning Plan.
- The RHNA Mandate to Build Affordable Housing Is Overstated in the Proposed Upzoning Plan
The 2022 Housing Element update was adopted to promote the construction of housing units to meet San Francisco’s 2023-2031 Regional Housing Needs Allocation (RHNA) that mandates the creation of more than 82,000 units within the city, requiring that 47,000 or 57% of the 82,000 units be affordable by extremely low income, very low income, low income, or moderate-income groups.
The RHNA mandate, however, is based on outdated high-growth population projections that no longer apply. We note that the State’s Department of Finance now forecasts that in 2030, and even in 2050, thousands fewer people will live in San Francisco than in 2020. Why, then, are we letting Sacramento push us into an 82,000-unit RHNA mandate?
In conflict with the adopted Housing Element, the Mayor’s Zoning Plan overstates the RHNA mandates to build or preserve affordable housing. Moreover, the numerous new State (and local) housing laws enacted since the adoption of the Housing Element and certification of Housing Element FEIR have already vastly reduced the constraints on development of market-rate housing, making it even more difficult, if not impossible, for the RHNA affordable housing mandates to be met. The effect of these new State and local laws represent a change in circumstance that was not taken into consideration in the FEIR.
We urge the Planning Commission to ask that the Planning Department and the Mayor’s office revisit the RHNA mandate to better match updated population projections. Please explain why the proposed upzoning plan has no meaningful provision to provide for the affordable housing that the RHNA mandate is predicated on. And, if the currently proposed SB 79 passes, is there any need to upzone?
4. Incorporate by Reference REP Letter
We wish to incorporate by reference the conclusions, recommendations and strategies contained in the letter dated September 4, 2025, to Planning Commission from Race & Equity in All Planning Coalition (REP-SF).
* * * * * * * *
In conclusion,weurge the Planning Commission to recommend to the Planning Department and the Mayor’s office to remove Telegraph Hill, North Beach, and the Northern Waterfront from the Mayor’s Zoning Plan consistent with the 2022 Housing Element.
Sincerely,
Stan Hayes and Nancy Shanahan
Co-Chairs, Planning & Zoning
Telegraph Hill Dwellers
cc: Mayor Daniel Lurie daniel.lurie@sfgov.org
Supervisor Danny Sauter danny.sauter@sfgov.org
Sarah Dennis-Phillips, Director of Planning sarah.dennis-phillips@sfgov.org
Rachel Tanner, Director, Citywide Planning rachel.tanner@sfgov.org
Lisa Chen, Planner lisa.chen@sfgov.org
Kathrin Moore, Vice President kathrin.moore@sfgov.org
Theresa Imperial, Commissioner theresa.imperial@sfgov.org
Derek Braun, Commissioner derek.braun@sfgov.org
Amy Campbell, Commissioner amy.campbell@sfgov.org
Sean McGarry, Commissioner sean.mcgarry@sfgov.org
Gilbert Williams, Commissioner gilbert.a.williams@sfgov.org
Jonas Ionin, Secretary commissions.secretary@sfgov.org
Members, San Francisco Board of Supervisors Board.of.Supervisors@sfgov.org
[1] https://www.city-data.com/neighborhood/North-Beach-San-Francisco-CA.html
