"Freeing Up the Affordable Housing Gridlock: Process Improvements that Matter"
As seems to happen at the turn of every new year, there is once again lots of chatter about “process improvements” and “streamlining” to speed up the timeline for approving developments. For developers, these are usually code words for eliminating community review and public hearings. But there are certainly aspects of The City’s bureaucratic process that should be improved for the benefit of developers, communities and city staff as well. Addressing the lengthy process for approving affordable housing could be one more way to improve our city’s Housing Balance achievements.
First, however, let us put to rest the notion from streamlining boosters that simply increasing the speed of approvals for market-rate development will increase San Francisco’s housing affordability. Hooey. The problem with affordability is fundamentally an issue of stark and rapidly increasing income inequality — San Francisco has one of the greatest degrees of income inequality of any city in the United States. It’s also the result of the harsh and rapidly increasing evictions crisis as rental housing is lost to the speculation market, and the result of the current imbalance between market-rate and below-market-rate housing production.
Simply speeding up approvals will not solve any of these much deeper problems. Furthermore, The City currently has more than 15,000 fully entitled housing units citywide waiting to be built, 87 percent of which are market-rate housing units, as well as another 23,000 units entitled in major project areas like Park Merced and Hunters Point, which indicates the real challenges are more related to financing and construction schedules than to the approval process of a large-city bureaucracy.
When making improvements, we need to make sure we don’t lose sight of what the permitting process is actually for. Process exists to make sure development is done right. An overarching goal of process improvements should be creating both an efficient and effective process — not simply speeding things up or eliminating community involvement.
In 2014, the Council of Community Housing Organization’s advocacy in a city working group, together with a broad set of stakeholders, led to a number of improvements in the permitting process without eliminating public engagement, a good first step in the right direction. What follows are three ideas we offer for the next step in this conversation: truly prioritizing affordable housing within the bureaucracy; standardizing notification, public meetings and design guidelines; and carefully streamlining environmental review for certain projects.
Prioritize Affordable Housing
We already have several city “directives” that prioritize affordable housing — the problem is that everything seems to be a priority for the Planning Department. One staff person should be dedicated solely to shepherding 100 percent affordable developments through both the Planning and Building Permit process, and the environmental review and the queue for Planning Commission hearings should always prioritize affordable developments. Secondary priorities should be assigned depending on the level of affordability, and high-profile projects, whether a Warriors Stadium or the America’s Cup, should not be allowed to bump affordable housing.
Standardize Public Notification, Community Meetings and Design Guidelines
Public Notification: The Planning Department has a dozen different notifications for different projects and permits, none of which make sense to the average person. We should have a universal notification system that simplifies notifications into just a few categories, with a standardized minimum 30-day timeline, and that makes notifications actually understandable and informative. The geographic area of notification should also have some logical relationship to the type and scale of the project.
Community Meetings: Required “pre-application meetings” are ostensibly an opportunity for the developer to hear from folks who have a stake in the project’s outcome and to respond to questions, improving the project from the outset and building a foundation for a constructive relationship with the community. In actuality, this requirement has no teeth. Meetings should be staffed by public officials, and recorded with a publicly-accessible record of issues raised and promises made, with adequate notification if those promises change. A little more time and seriousness building a relationship with the community on the front-end can save a lot of time later on.
Design Guidelines: The Planning Department’s outmoded Residential Design Guidelines, which set citywide expectations for design, are only for single-family and smaller buildings, and moreover are flawed in some ways (especially dealing with rear-yard development, which is now happening at an increasing rate as property values skyrocket). They are long overdue for an overhaul. And missing entirely are guidelines for larger multi-unit developments, a critical need as the City pushes for higher-density development in infill parcels and commercial corridors adjacent to existing housing. Good guidelines, developed with community input, will create much more certainty for both the developer and the community, and help standardize the review of individual projects.
Improve the Environmental Review Process
The environmental review process can reveal important issues and provide the community and City planners with information and a process to understand a project’s “fit” with its location. But there are certain situations that could warrant a reduced environmental review process if they were evaluated according to clear standards that have been vetted by the public. This could look like a checklist, similar to the existing Categorical Exemption checklist, that identifies specific situations that meet a certain threshold, such as affordable housing projects, where lengthy environmental documents or consultants may not be needed.
Those kinds of administrative reforms would be a significant step in freeing up delays in affordable housing development. In the end, process improvements shouldn’t just be about making things faster, but about making all parts of the process efficient and meaningful so they actually do what’s intended — create real engagement with impacted community members and make sure developments are designed and built in the best way for the community, the environment, and The City.
Fernando Martí and Peter Cohen are directors of the Council of Community Housing Organizations.