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Plan Bay Area

More than a million people in SF? Did anyone ask you?

New regional plan, adopted with little public input, pushes massive growth for San Francisco -- with no promise of money for transit or social equity.

It’s hard not to be riveted by the terrifying advance of Donald Trump’s presidency. But it would be a huge mistake to ignore less sensational exercises in autocracy, especially those occurring at home. One such operation, which has gone virtually unnoticed, is the continuing travesty of democratic governance known as Plan Bay Area.

Mandated by SB 375, the Sustainable Communities and Climate Protection Act of 2008, Plan Bay Area is our nine-county region’s Sustainable Community Strategy—a so-called blueprint that knits together transportation and land use plans and investments for each region in California so as to accommodate the area’s projected growth of jobs and households and at the same time meet its official greenhouse gas emissions reduction targets.


Unelected officials run the show

Plan Bay Area’s autocratic character is rooted in the un-democratic governance of the regional agencies under whose aegis it proceeds, the Metropolitan Transportation Commission and the Association of Bay Area Governments. Both entities are putatively overseen by unelected officials—to be precise, elected officials (mayors, city councilmembers, and county supervisors) who were not elected to serve on MTC or the ABAG Executive Board. It follows that when they run for office or re-election, their positions on Plan Bay Area and the regional agencies’ other projects never come up.

Scott Wiener sits on MTC, and Jane Kim is on the ABAG Executive Board, but during their hotly contested campaigns for state senate, nobody asked about MTC’s hostile takeover of ABAG last May (Wiener supported it—vociferously, accusing opponents of “throwing rocks at MTC”; Kim was absent for the Ex. Board’s May 19 vote on the matter) or their positions on Plan Bay Area’s gigantic growth forecasts and allocations for San Francisco and the 11th State Senate District, and its implications for displacement and housing affordability or local control of development.

Augmenting the democratic deficit, both MTC and ABAG are effectively led by staff, not their governing boards, whose members have no staff of their own, and whose obligations to their local jurisdictions in any case preclude their delving into the copious details of regional policy. Since MTC’s coup, ABAG staff report to MTC’s peremptory executive director, Steve Heminger.

After a stormy public planning process, the first edition of Plan Bay Area was approved by MTC and ABAG in July 2013. State law requires each Sustainable Community Strategy to be updated every four years. Plan Bay Area is well into its first quadrennial update. On November 17, following a perfunctory deliberation, MTC and the ABAG Executive Board approved a Final Preferred Scenario and Investment Strategy that will serve as the conceptual template for the update. The fully realized blueprint-cum-Environmental Impact Report is to be finalized next summer or fall.

A farcical public process

Plan Bay Area’s autocratic character is exacerbated by its superficial public planning process. Compared to the public process that culminated in Plan Bay Area 2013, the update proceedings have been uncontentious. That’s because most of the individuals who participated in the first round haven’t shown up for the second one—for a good reason: they’ve realized that the meetings are a time-consuming sham that exist only because SB 375 requires some form of public outreach. No meaningful input could possibly emerge out of the cursory, often infantilizing, staff-dominated activities that the regional agencies peddle online and at their workshops and open houses.

The only members of the public who’ve continued to participate are those who are paid to do so: representatives of the non-profits that weighed in on round one. This motley crew includes equity and housing advocates (Urban Habitat, Working Partnerships USA, Public Advocates, Non-profit Housing Association of Northern California, 6 Wins for Social Equity Network), environmental organizations (Greenbelt Alliance, the Sierra Club), transit promoters (TransForm), and lobbyists for big business and big property capital (SPUR, the Bay Area Council, the Building Industry Association, the Silicon Valley Leadership Group).

Their considerable political differences notwithstanding, these organizations have two things in common: they all accept Plan Bay Area’s growth-to-the-max premise; and, however righteous their missions and valuable their work, they’re all private entities that are ultimately accountable to their donors and their boards of directors, rather than to any public electorate.

The planning process is also rushed. The regional agencies issued a Draft Preferred Scenario on September 2. On October 14, only six weeks later, public comment on the scenario was closed. The Final Preferred Scenario and Investment Strategy was released on October 28 and approved just three weeks later on November 17.

The regional agencies seem to show the local jurisdictions little more respect than they offer the public at large. During the takeover fight last spring, ABAG contrasted its attentiveness to cities, meaning cities’ planning directors and county transportation congestion management agencies, with MTC’s haughtiness.

Perhaps because MTC is now in charge, this fall such solicitude was in scant evidence. In late October, staff to the San Francisco County Transportation Agency, San Francisco’s congestion transportation agency, said that they had yet to be fully briefed about the update by MTC and ABAG.

By October 20, forty-one jurisdictions had commented on the Draft Preferred Scenario. MTC and ABAG staff stated that they would respond to all comments by the end of December—a month and a half after the Final Preferred Scenario was to be approved.

Wild numbers

To achieve its arguably unachievable double goal of accommodating all of the region’s forecasts new jobs and households and at the same time meeting its greenhouse gas reduction targets, Plan Bay Area directs most new residents and employment into so-called Priority Development Areas, existing neighborhoods near transit. San Francisco has twelve PDAs.

SF's Priority Development AreasSF’s Priority Development Areas

The forecasts or projections—we’re not supposed to call them predictions—for San Francisco are wild. Plan Bay Area 2013 expected the city to accommodate 15% of the region’s total growth through 2040, measured against a 2010 base: 92,480 more housing units and 191,000 more jobs—a 25% and 34% jump, respectively.

The numbers in the Plan Bay Area 2017 Final Preferred Scenario are even crazier.

Plan Bay Area 2017 update: Final Preferred Scenario

Household and Employment Forecasts for San Francisco


Households 2010

Households Forecast 2040

Employment 2010

Employment Forecast 2040



483,700 (+137,889 or 40%)


872,500 (+295,650 or 51%)



310,100 (+127,670 or 59%)


741,700 (+267,710 or 64%)

At an average household size of 2.4 people, we’re talking about 1.1 million residents in this geographically limited city.

The big numbers are more meaningful broken down by PDA. High-level city planning staff are still negotiating the PDA allocations with MTC and ABAG. Here are a few of the biggest increases in the Draft Preferred Scenario:




Household Forecast 2040

Employment 2010

Employment Forecast 2040

Bayview/Hunters Point Shipyard/Candlestick Point





Downtown-Van Ness-Geary





Eastern Neighborhoods





Transit Center District





Eroding local control

MTC and ABAG repeatedly assert that nothing in Plan Bay Area constrains local control of development. The October 28, 2016, ABAG/MTC staff memo re the Final Preferred Scenario and Investment Strategy states:

[T]he Final Preferred Scenario does not mandate any changes to local zoning rules, general plans or processes for reviewing projects, nor is it an enforceable direct or indirect cap on development locations or targets in the region. As is the case across California, the Bay Area’s cities, towns and counties maintain control of all decisions to adopt plans and permit or deny development projects.

Strictly speaking, this is true. No jurisdiction can be legally compelled to designate a Priority Development Area. The region’s 191 PDAs were all nominated by local jurisdictions. San Francisco’s PDAs were unanimously approved by the Board of Supervisors in 2007.

And even if a city does designate Priority Development Areas, it can’t be legally forced to approve the number of new housing units that it’s been allocated—at least, not yet.

At the November 17 meeting, held at the regional agencies’ fancy new digs on Beale St., Heminger asserted that the regional agencies needed to get the authority and the funding to build housing to accommodate the region’s entire population.

In response, State Senator-elect Wiener described the current housing scene as “a slow-moving train wreck” and asked, “What is the path to figuring out how many units we need…to stop the bleeding?” (I’ve asked both Wiener and his supervisorial staff whether he supports state legislation that would compel cities to approve the housing they’ve been allocated by Plan Bay Area. So far, no reply.)

Heminger estimated that it would take “over a million” new housing units “to make a dent in the shortfall.” The real challenge, he said, is “to fit that growth in the communities we cherish,” adding, in a non sequitur: “We need to change what the Bay Area looks like.” Heminger noted that such a transformation would require the “legal enforceability” that the regional agencies now lack. He told Wiener: “We’ll be on your doorstep asking for the money and authority to carry it out.”

Heminger’s call for ending local control of residential development was echoed by two new members of the ABAG Executive Board representing San Francisco, both Mayor Ed Lee’s appointees, Planning Department Senior Policy Advisor Anne Marie Rogers and Community Planning Manager Joshua Switzky (The city has four representatives on the board: two supervisors, currently Kim and Mar, and two representatives of the mayor). Rogers called for “enabling legislation” that would provide “the tools we need.” Switzky said, “We need to have the courage to push cities to accept the plan.”

In fact, cities’ prerogatives are already constrained by SB 375 and its statutory progeny. For example, under SB 743, passed in 2013, a development that’s “consistent with a sustainable communities strategy” cannot be challenged under the California Environmental Quality Act on the basis of its “growth-inducing impacts.”

Moreover, a jurisdiction that doesn’t get with the program is going to be moved to the back of the line for money from the regional agencies, especially from MTC, which controls billions of dollars of discretionary transportation funding. That’s a big deal; infrastructure drives development. Without the envisioned new transit, getting 295,000 new workers in and out of San Francisco is going to be well-nigh impossible.

The top staff to the San Francisco County Transportation Authority, whose governing board comprises the city’s eleven supervisors, sent the SFCTA a memo dated October 5 recommending approval of the city’s input on the Plan Bay Area 2040 Draft Preferred Scenario that they were proposing. Referencing the scenario’s Transportation Investment Strategy, the memo lists forty-one Projects in San Francisco and Multi-County Projects of Interest to San Francisco whose total cost comes to $17.6 billion.

The big-ticket items include transit preservation and rehabilitation ($2.26 billion), expanding the Muni transit fleet ($1.5 billion), the Presidio Parkway ($1.6 billion), and the next phase of the Central Subway ($1.6 billion). Another twenty-nine regional and multi-city projects, including the BART Transbay Core Capacity Project ($3.4 billion), high-speed rail in the Bay Area ($8.4 billion), the first phase of Caltrain electrification ($2.4 billion), and the Caltrain/HSR downtown San Francisco Extension ($4 billion) will cost a total of $246 billion.

Unsurprisingly, SFCTA Executive Director Tilly Chang’s October 18 letter to MTC and ABAG commenting on the Draft Preferred Scenario, co-signed by San Francisco Planning Director John Rahaim and San Francisco Municipal Transportation Agency Executive Director Ed Reiskin, opened on a propitiatory note:

Overall we appreciate that the transportation investment scenario supports San Francisco’s transportation policy and project priorities, which is critical given the land use scenario’s proposal for the City to absorb a great amount of the region’s jobs and housing growth through 2040.

No public deliberation in San Francisco

The Preferred Draft Scenario never came before the Board of Supervisors. It appeared only on the agenda of San Francisco County Transportation Authority, the congestion management agency for the city and county of San Francisco. SFCTA’s governing board meets on the fourth Tuesday morning of every month. Staff proposal for San Francisco’s input on the Preferred Draft Scenario was on the Authority’s September and October agendas. At those meetings, not one supervisor asked a question or remarked on staff’s proposed comments to MTC and ABAG. Nobody spoke at public comment. On October 25, the SFCTA unanimously approved the staff recommendations.

The absence of public deliberation is stunning. To be sure, the Draft Preferred Scenario was issued just two months before a highly contested election. People were otherwise preoccupied. And no doubt supervisors and staff were in consultation behind the scenes, which likely explains why the regional agencies dropped their initial expectation that San Francisco’s cap on annual new office development would be eliminated. But given what was at stake, the city’s response should have been a high-profile topic.

The Planning Department should have sponsored substantive community briefings about the update—one meeting in each PDA would have been ideal—solicited and documented residents’ informed responses to the growth projections, and incorporated those responses in the city’s comprehensive comments. It did not. Not incidentally, the draft PDA allocations are not posted on either the city’s or Plan Bay Area websites; I had to ask city staff to provide them.

I asked Calvin Welch, dean of the city’s community activists, whether the Planning Department had ever briefed any neighborhood about a Priority Development Area. His reply: “I know of no specific briefing or notice given to either community organizations or neighborhood groups in these specific neighborhoods.”

The city’s ambiguous response

So we are left with the staffers’ October 5 memo and October 18 letter as statements of the city’s position on the massive growth that the regional agencies expect it to absorb by 2040. As it contemplates those expectations, the October 18 letter moves from appreciation to apprehension to outright opposition. It’s not that the authors are anti-growth. Quite the contrary. It’s just that even they can’t help blinking at the enormous numbers. Watching them grope for language that expresses their unease but doesn’t offend their powerful patron, MTC, is almost comical. But their overall take is alarming.

On housing growth: Though “the [projected] housing growth…far exceeds both historic and recent annual average production numbers, and the 128,000 units proposed in the Draft Preferred Scenario “is a 33% increase over PBA 2013 allocation,” they “feel” that “the land use scenario assumptions for San Francisco are ambitious but achievable,” as long as the city is given “substantial additional revenue sources and new policy tools,” as well as “commensurate transportation investment.”

On jobs growth: “The aggregate jobs allocation for San Francisco,” they write, “is 70% higher than the PBA 2013 (311,00 vs. 190,00).” The regional agencies reduced that figure to 267,710 in the Final Preferred Scenario.

While plausible, this depends substantially on densification of existing space….Densification in existing space is a key aspect of capacity that the City cannot regulate or affect [untrue] and can mostly just speculate as to potential overall capacity and likelihood or pace of such absorption.

On transportation funding:San Francisco has successfully secured local revenues for transportation and housing and is continuing to seek additional revenues given insufficient and reliable state and federal funds….However local funds are not enough to meet our needs as one of the three big cities taking on the most job and housing growth in PBA 2040….We want to ensure we are receiving a commensurate share of regional discretionary dollars and [are] not being penalized for seeking and securing new local dollars.

On the distribution of new housing units among the city’s Priority Development Areas: Here Chang, Rahaim and Reiskin drop the conciliatory gestures. “Distribution of growth within San Francisco should reflect local plans”[emphasis in original). Despite the fact that since May, the "Planning Department has been working with ABAG and MTC staff to make final redistributions of proposed growth within the city to align with current plans and policies,” at the PDA level there are "unrealistic discrepancies that should be rectified.”

For San Francisco, notable over-allocations were shown on the housing side to Mission Bay, Bayview/Hunters Point Shipyard-Candlestick, Treasure Island and the Port, and on the jobs side to Downtown-Van Ness-Geary, Balboa Park, Mission Bay, and non-PDA areas.

On social equity: The trio objects even more strenuously to the Draft Preferred Scenario’s negative implications for social equity. SB 375 says nothing about social equity. Under pressure from the 6 Wins for Social Equity Network, a coalition of non-profit equity advocates, the regional agencies added social equity targets dealing with anti-displacement, and housing and transportation affordability to Plan Bay Area 2013. In preparing for the 2017 update, MTC staff tried to remove the anti-displacement target; ABAG staff wanted to keep it in. An ugly public fight ensued. Thanks to the 6 Wins Network’s effective organizing, the anti-displacement target survived. But Plan Bay Area 2017 is going to miss all three social equity targets—badly.

Adequate housing/community stability: By the regional agencies’ own reckoning, the inflated property values generated by the new development projected by Plan Bay Area 2013 were going to put 30,000 households at risk of displacement. The target in the Draft Preferred Scenario holds that risk steady. Instead, MTC and ABAG staff expect the growth forecast by the Draft Preferred Scenario to increases the risk of displacement by 9%.

Equitable access to transportation and housing: The target decreases transportation and housing costs for lower-income households by 10%. Instead, those costs will increase by 13%.

Affordable housing: The target increases the share of affordable housing in the Priority Development Areas, Transit Priority Areas and high-opportunity areas [too much plannerese to unpack in this story] by 15%. Instead, the share will increase by just 1%.

The equity failures elicited the San Francisco staffers’ unequivocal condemnation. “Despite these ambitious goals [the[the jobs and housing growth] they write, “the Draft Preferred Scenario fails to meet the Plan’s affordability and anti-displacement targets, and this outcome is simply unacceptable.”

Agreed, at least as far as the unacceptability of the equity shortfalls is concerned.

The Chang/Rahaim/Reiskin analysis of those shortfalls is another matter. The projected equity failures will occur, not as the threesome assert, despite the “ambitious” jobs and housing growth, but rather because of them. The affordable housing crisis reflects the influx of tens of thousands of highly paid tech workers into the city—an influx encouraged by Ed Lee and his administration (for starters, think the Mid-Market “Twitter” tax exemption). Predictably, the word “tech” does not appear in the five-and-half-page single-spaced letter. Any analysis that omits that term is deeply flawed.

Like their assessment of the Final Preferred Scenario, the department heads’ proposals are ambiguous. Their recommendations for protecting existing rental units and tenants and enabling production of new below-market-rate rental housing are excellent:

But their overall analysis echoes the real estate industry’s misguided build, baby, build gospel. For Chang, Rahaim, and Reiskin, the main sources of the region’s housing crisis are “constraints in production, many cities not doing their part, lack of funding, and no teeth to enforce the Plan.”

They suggest two ways of expediting the production of affordable housing:

Fine. But their overarching proposal for addressing the affordability crisis is inexpedient: pursue “state legislation to increase housing production and compel local jurisdictions to zone for and entitle housing consistent with regional sustainable communities plans.” They don’t explain why building all the new housing envisioned by updated Plan Bay Area 2040 would help people, especially poor people, who can’t get into the current housing market find shelter. Presumably they believe in the supply and demand argument, which has been repeatedly debunked (here and here). If they have a different theory, I’d be glad to hear it.

In any case, forcing cities to approve the housing units they’ve been allocated by Plan Bay Area 2017 is a bad idea. It’s undemocratic, replacing local control of development with de jure control by unelected officials and de facto control by the real estate industry. Yes, cities can and do refuse to build affordable housing because they don’t want poor people in their neighborhoods. That’s wrong and reprehensible. It’s also illegal. But what drives the real estate industry is neither social justice nor economic democracy; it’s maximizing the rate of return on investment—a motive that, as we’ve recently been seeing, leads to inflated property values, greater inequity, displaced tenants, and fractured communities.

Missing: fiscal impacts, water issues, quality of life, community character

The build-to-the-max position espoused by San Francisco officials and Plan Bay Area raises grave issues that are off the table.

Fiscal impacts: Those 138,000 additional households and 295,650 additional workers are going to need sufficient new services besides transit: schools, police, firefighters, parks, public works. How much will they need, and how will those will those services be funded?

Water: SB 375 narrows environmental sustainability to addressing climate change. What about resource depletion—specifically, water? California is in a long-standing drought. In October scientists at the Bay Institute reported that the diversion of rivers has led to the near-collapse of the San Francisco Bay ecosystem. How much water are those 138,000 additional households and 295,650 additional workers going to consume? Where is the city going to get it?

These questions seem obvious and urgent, but at the November 17 meeting, the issue of water supply was raised by only two voting officials, neither one from San Francisco: Novato Mayor Pat Eklund and Hayward Mayor Barbara Halliday, who sit on the ABAG Executive Board.

And what about the other water problem—sea level rise? Nonsensically, Plan Bay Area channels a good deal of San Francisco’s projected construction into the Eastern Neighborhoods, where sea level rise is a growing concern.

The city's own charts show serious vulnerability to sea-level rise -- right in the priority development areasThe city’s own charts show serious vulnerability to sea-level rise — right in the priority development areas

Quality of life/overcrowding: Most of the forecasted growth would go into parts of San Francisco—what planners are calling the downtown core, plus the southeastern and southwestern neighborhoods, where traffic congestion and transit system crowding were—and are—already acute. SB 743 eliminated traffic congestion as an environmental impact for infill projects under CEQA.

And there are other kinds of congestion. In what turned out to be his final story for the Bay Guardian, a critical look at Plan Bay Area that raised many of the issues I’m flagging here, Tim Redmond asked his readers to imagine ten thousand people headed for Dolores Park on a weekend. Think about it.

Ballot box rebellion in the burbs

Defying the growth autocracy is a daunting task, if only because its leading supporters—. But those powers are not invulnerable.

On November 17, after Heminger, Rogers, and Switzky had advocated changes in state law that would enable MTC and ABAG to force cities to approve the new housing stipulated by Plan Bay Area, Alameda County District 1 Supervisor and MTC Commissioner Scott Haggerty reported that on November 8 every incumbent in his district had lost. The yard signs, he said, all railed against “rampant growth.”

Haggerty’s geographically enormous district includes Fremont, Livermore, and Dublin—all scenes of massive new development (Dublin, said the supervisor, is the second fastest growing city in California)—and Highway 580, a road that’s become synonymous with gridlock.

To Haggerty, the incumbent wipeout didn’t suggest that it’s time to re-think the growth imperative. True, he questioned the big numbers, asking where they came from. Given his many years in leadership role on both the ABAG Executive Board and the Metropolitan Transportation Commission, the query was disingenuous.

Haggerty’s answer—the big numbers came “not from any elected officials,” but from the state’s department of Housing and Community Development—indicated his real concern: the voters “are starting to rebel” against big growth. “They did at the ballot box this year, and they’ll do it again and again,” he declared. To stave off further such rebellion, he wants more money for transit, money that, he complained, “you,” i.e. Plan Bay Area 2013, “didn’t give me.”

Palo Alto Councilmember Greg Scharff, who sits on the ABAG Executive Board, agreed. Scharff warned his colleagues: “If we don’t solve the congestion problem, you’re not going to have the political support to build the housing.” More ominously, he added: “If you really want to see an insurrection,…start talking about taking away local control.”

Would San Franciscans join a slow growth revolt?

Not, to state the obvious, if it’s made in the name of protecting suburban character. Otherwise, the answer is unclear, at least judging from the results of the November 8 election.

The voters decisively (65% No) rejected Prop. K, which would have boosted the local sales 8.75% tax by .75% to pay for homeless services and Muni improvements. Perhaps they were confused: they just as decisively (66% Yes) supported Prop. J, which would have amended the City Charter to pay for the services and improvements that K would have funded. Or perhaps they objected to a regressive sales tax/new set-aside for Muni. Prop. K’s defeat nullified Prop. J’s passage.

On the other hand, the voters narrowly (52% Yes) approved Prop. O, which allows Lennar Corporation a special exemption to build five million square feet of new office space at Candlestick Point and Hunters Point without regard for the city’s annual limit of 950,000 sf of new office space or the transit needs of the project’s 8,000 new workers. Did Prop. O’s passage indicate that pro-growth sentiment now (barely) prevails in San Francisco? Or does it reflect the fact that the measure’s opponents spent zero, and its supporters spent $2 million dollars and still only eked out a victory?

In any case, San Franciscans ought to demand that the supervisors, their elected representatives, publicly vet Plan Bay Area’s big-picture growth agenda. Democracy, like autocracy, begins at home.

Note: For an incisive critique of the Draft Preferred Scenario’s equity failures, see the 6 Wins for Social Equity Network’s October 13 letter to MTC and ABAG.