Dear HCD, SF Mayor London Breed, and SF Board of Supervisors,

It is time for the State of California and the City of San Francisco to put affordability, equity, and the protection of tenants and small businesses first! The California Department of Housing & Community Development (HCD) must enforce the City’s implementation of the dozens of State certified equity-based actions in the San Francisco Housing Element, and the City must prioritize these policies for affordable housing, as well as tenant and small business protections.

The Race & Equity in all Planning Coalition (REP-SF), consisting of dozens of grassroots community groups, affordable housing developers, cultural districts, and neighborhood non-profits, worked with San Francisco's Planning Department staff when the SF Housing Element was being developed. This iterative process resulted in dozens of equity-based implementing actions being written into the final SF Housing Element, which guides the City’s housing policies from 2023–2031. The SF Housing Element was approved by the SF Planning Commission and Board of Supervisors, and was certified by HCD at the end of January 2023.

Despite the fact that many of these equity-based actions are labeled as short-term, needing to be implemented by January 31, 2025, the City is ignoring them in favor of encouraging and deregulating expensive, profit-driven housing development. This will cause mass displacement and demolition of both rent controlled homes and small businesses, as the City moves to rezone wide swaths of SF before safeguarding these residential and commercial tenants. In order for San Francisco to stay in compliance with their Housing Element mandates, they must start on these short-term equity actions immediately as part of their legal obligation under AB686 to Affirmatively Further Fair Housing (AFFH).

According to the SF Planning Department, this is “the City's first housing plan centered on racial and social equity,” but in order for this to ring true, HCD must fulfill its legal obligation to AFFH and enforce the implementation of the dozens of approved equity-oriented actions in the SF Housing Element. The REP-SF Coalition demands that HCD prioritize these critical actions within the short-term (0–2-year) and medium-term (3–5-year) deadlines, such as:

-Affordable housing funding, production and preservation;
-Deeper affordability and increased eligibility for affordable housing;
-Eviction prevention, tenant protections and other anti-displacement strategies, which include protections from rezoning impacts;
-Acquisition and rehab of existing buildings for affordable housing;
-Preserving availability of rental housing;
-Community planning;
-Empower, protect and invest in cultural heritage, expression, investments and Districts;
-Acknowledgement and redress of past harms and restitution;
-Fair housing compliance and enforcement;
-Targeted strategies for families with children, transgender and LGBTQ+ people, seniors, people with disabilities and chronic illness, and other vulnerable populations;
-Expand and improve supportive housing and shelters; and
-Accountability for all of the above;

HCD must push San Francisco to prioritize the approved equity-based actions, providing technical assistance as needed, to ensure the City doesn’t fall out of State compliance. So far, San Francisco and their Planning Department have focused their efforts entirely on "reducing constraints" for profit-driven housing, and have ignored our calls for them to put affordable housing first, which the State determined was SF’s most pressing need. Similarly, the Policy & Practice Review published by HCD on October 25, 2023 shows that HCD is also focusing on “removing constraints” to build expensive housing rather than increasing feasibility for affordable housing through state funding. Efforts to promote profit-driven development have actually made it harder to create affordable housing, for example, by passing developer giveaways like the reduction of fees and inclusionary below-market rate housing requirements. If HCD doesn’t force SF to address the approved equity items, it will share responsibility for the City falling out of compliance.

This imbalance in implementation persists despite the Regional Housing Needs Assessment (RHNA) goals clearly indicating that the City's greatest need is for affordable housing. Fifty-seven percent of the City’s new development should be affordable to very low, low and moderate income households according to the SF Housing Element. Affordability and equity are being ignored despite the legal requirements.

I join the REP-SF coalition to demand that the State and the City prioritize real solutions for our most pressing housing needs and focus on the actions of the SF Housing Element that:

-Embrace racial, social, and economic equity;
-Put affordable housing first in order to meet the extraordinary need for affordable housing;
-Honor and respect the expertise of our low-income communities, and of our -American Indian, Black, and other communities of color; and
-Fulfill San Francisco's obligations under State and Federal law, especially to Affirmatively Further Fair Housing.