17 November 2023 

Gustavo Velasquez, Director HCD 

Tyrone Buckley, Assistant Deputy Director of Fair Housing, HCD 

Re: "Policy and Practice Review" from the State of California's Department of Housing and Community Development 

The San Francisco Anti Displacement Coalition (SFADC), the Race & Equity in all Planning Coalition - San Francisco (REP-SF), and the Council of Community Housing Organizations (CCHO) submit this letter to express our grave concerns regarding the "San Francisco Housing Policy and Practice Review" (PPR) released by the California Department of Housing and Community Development (HCD) on October 25, 2023. 

Together, our coalitions represent nearly 90 community-based organizations that have played critical roles for decades in innovating affordable housing, tenants rights, and anti-displacement policies in San Francisco. As coalitions deeply committed to moving forward solutions and investments to address fair housing, racial and social equity, affordability, and displacement, we are deeply concerned that HCD's PPR will further exacerbate our affordability crisis and move our City out of compliance with its obligations to Affirmatively Further Fair Housing. 

In an attempt to facilitate housing development “at all income levels”, the PPR in fact seeks to fully deregulate expensive, market rate housing while undermining provisions of San Francisco's Housing Element designed to achieve our city's affordability, fair housing, and anti displacement goals. Moreover, the PPR contains numerous misleading and inaccurate assertions -- and then leans on these faulty assertions to justify hasty and extreme actions that threaten to further destabilize and displace our most vulnerable and historically marginalized communities.

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Community Recommendations Regarding Opportunity Framework: Letter to CA DHCD from CCHO & REP SF

August 1, 2023

We appreciate HCD engaging in this important conversation regarding the Opportunity Framework, and the recognition that new approaches are needed to achieve fair housing opportunities in high resource communities while concurrently implementing community stabilization measures in historically disinvested neighborhoods.

In response to your solicitation for comments on the Opportunity Framework, the Council of Community Housing Organizations (CCHO) and the Race & Equity in All Planning Coalition (REP-SF) have compiled a set of overall recommendations based on the experience and expertise of our member organizations. 

We believe that as cities grapple with the complex layering of local and state factors that impact development, displacement, housing, and affordability across diverse neighborhoods and communities, it is critical to articulate an affirmatively advancing fair housing framework that centers the needs of BIPOC residents in all geographies.  This can be achieved through a combination of program, policy, tools, and investment, and an overall balance among focused interventions in historically disinvested areas, reducing displacement pressures in gentrifying neighborhoods while supporting access to high opportunity areas, and initiatives to support fair housing integration.

We propose the following four overall recommendations to strengthen the State’s role in advancing the Opportunity Framework. 

Focused Interventions in Historically Disinvested Areas

Reducing Displacement Pressures in Gentrifying Neighborhoods

Supporting Access to High Opportunity Areas

Initiatives to Support Fair Housing Integration

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Building the Affordable Housing San Francisco Needs
By Karoleen Feng, Gina Dacus, Anni Chung and Maurilio Leon | Council of Community Housing Organizations |

March 7, 2023
San Francisco Examiner

The certification of San Francisco’s Housing Element by the California Department of Housing and Community Development is a big milestone, and it provides The City a powerful impetus to address the housing affordability crisis. With a mandate to build 46,000 affordable housing units out of 82,000 units total, San Francisco must rise to the occasion.

As a coalition of nonprofit organizations that have built housing for extremely low- to moderate-income San Franciscans, the Council of Community Housing Organizations seeks the inclusion of equity and affordability strategies in Mayor London Breed’s Housing for All Plan. This gives San Francisco a fighting chance to achieve the affordable housing goal in the 2023-2031 Housing Element cycle.

Let’s put this in context: During the last cycle, San Francisco achieved 150% of its market rate housing goals, while building much less than 50% of the affordable housing targeted at low- and moderate income levels. To successfully meet the Housing Element’s affordable housing goal and to truly build housing for all, The City will need to collaborate in new ways with community leaders to identify strategies and scale up its investments. For tens of thousands of residents in communities across San Francisco who are experiencing housing insecurity, The City must not fail. We worked alongside The City during the pandemic to keep households as housing secure as possible, and we know we can succeed together.

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Coalition of Community Organizations Call upon the CA HCD to Protect Fair Housing goals

Dec. 2, 2022

Dear Director Velasquez, 

We are seeking your support regarding the application of Affirmatively Furthering Fair Housing principles to the Housing Element in San Francisco. Your support is more critical than ever as San Francisco finalizes its Housing Element. This is especially important given the escalating erosion of affordable housing opportunities in San Francisco, particularly in our historic cultural neighborhoods and ethnic enclaves in what has become one of the nation’s highest-cost cities.

We recognize that the fact that state and federal agencies have enacted AFFH provisions demonstrates the need for a guiding framework around development to ensure equity and inclusion. HCD’s August 8th, 2022 letter to the San Francisco Planning Dept. commends the department for its efforts in the Housing Element in “acknowledging and repairing the harms of past decades of inequitable and discriminatory land use and planning policies that resulted in exclusionary and disinvested communities.”

We are concerned, however, that affirmative priorities would be undermined if the Housing Element does not have the requisite dedicated affordable housing funding, while at the same time eliminating certain elements that HCD calls “development constraints” in ethnic enclaves. We ask that HCD and the San Francisco Planning Department take great care to maintain and strengthen all culturally protective provisions necessary for Affirmatively Furthering Fair Housing which requires that our ethnic enclaves be prioritized for both public investment in affordable housing as well treated with a more nuanced approach in handling issues related to displacement and segregation. 

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Council of Community Housing Organizations Decries CA DHCD’s Review of SF Housing Element

September 15, 2022

On August 8th, the Department of Housing and Community (DHCD) wrote San Francisco Planning Director Rich Hillis highlighting the changes that the DHCD deems necessary to bring San Francisco’s Housing Element into compliance with various state mandates. This letter affirmed DHCD’s mandate to boost San Francisco’s overall housing production to 82,069 units, 57% of which or 46,598 units would have to below-market-rate including 20,867 units for very low income residents, 12,014 units for low-income residents, and 13,717 units for moderate-income residents.

DHCD’s letter is long on housing targets and short on the solutions to achieve them. Lacking in DHCD’s compliance letter is any mention of resources to enable San Francisco to achieve the aforementioned below-market rate regional housing goals. “Government policies and resources should be our best backstop to combat the housing affordability crisis,” said Charlie Sciammas, Policy Director of the Council of Community Housing Organizations. “But it's like the Department of Housing and Community Development demanding the city to construct all the housing necessary to bring San Francisco into compliance without sharing any of the resources to fulfill our affordable housing targets.”

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December 21st, 2021

The Mayor’s Office of Housing and Community Development is in charge of both Small Sites and DAHLIA. So, in many ways, the buck stops with them. Nonetheless, the Mayor’s Office of Housing and Community Development offered no specific comments to this reporter regarding solutions.

Peter Cohen, the co-director of the Council of Community Housing Organizations, said he and other organizations sent a list of Small Sites reforms to the Mayor’s Office of Housing on Aug. 31, though conversations about resolutions began as early as January. But like mayor’s offices in the past, the office has been “rigid and unwilling” to reform it, Cohen said.

“What is the reason they are stalling?” he asked.

As supervisors and housing advocates point out, neither the problems nor the solutions appear insurmountable.

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December 13th, 2021

Finally, a city study looks as the price tag for the pro-development policies of the past.

The planners used information like new office building applications, but those may never be built. The report ignored other types of job growth, like gig work, retail, and related services.

As the Council of Community Housing Organizations noted, This JHF assumes mostly Office growth and leaves out projections for Retail, hotel, PDR and arts uses, reducing the projected need for affordable housing. Some of the Area Plans and Major Projects listed in the Jobs-Housing Fit analysis also seem to show significantly less retail, hotel, and PDR and arts uses than contemplated in the EIRs for those area plans and projects.

In other words: The shortfall in affordable housing could be worse than the city suggests.

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December 2nd, 2021

The vote, which was supported by a coalition of housing tenants, labor and community organizations, was a huge win for housing advocates. The ability of the program to purchase properties at scale, keep them affordable, and build new units will be a test of the viability of social housing as a sustainable solution to current housing pressures.

In a tweet, the Council of Community Housing Organizations wrote: “Next step: rapidly acquire homes in every neighborhood, and secure the political commitment for permanent allocation of the annual revenues.”

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November 30th, 2021

The Council of Community Housing Organizations noted:

This action by our City legislators was not simply about an installment of $64 million to invest in affordable housing, but about listening to the voters who passed the Proposition I ballot measure overwhelmingly in November 2020 with the intention of funding a wide range of social housing programs: from preservation of small apartment buildings facing Ellis Act evictions to large residential hotels deteriorating in the hands of private owners, from land trusts to homeownership cooperatives. This will result in real housing for real everyday people – from seniors and people with disabilities whose hard work built this city, to hotel and service workers, to the jobs we used to think of as middle-class, the educators, healthcare workers and electricians who can no longer afford a home in San Francisco’s inflated real estate market.

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November 30th, 2021

Despite the program's issues, affordable housing advocates deemed Tuesday's vote a victory.

"This action by our city legislators was not simply about an installment of $64 million to invest in affordable housing, but about listening to the voters who passed the Prop. I ballot measure overwhelmingly in November 2020 with the intention of funding a wide range of social housing programs — from preservation of small apartment buildings facing Ellis Act evictions to large residential hotels deteriorating in the hands of private owners, from land trusts to homeownership cooperatives,” said the Council of Community Housing Organizations — a coalition of affordable housing providers— in a statement on Tuesday.

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November 9th, 2021

According to a report released last month by Jobs with Justice, the Council of Community Housing Organizations, and San Francisco Labor Council, the overall area median income for San Francisco is $93,250, while the 2020 median annual income of union workers is considerably less at about $67,350.

Given such disparities, the report found that while occupations like registered nurses made about $4,000 monthly, that’s barely enough to afford a one bedroom apartment in The City, which according to market rental rates goes for about $3,289.

Firefighters, sanitation workers, transit workers and nonprofit workers, among other occupations, earn far less so face even more barriers to housing, according to the report.

The report also found over 40% of the city’s union workers live outside The City.

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November 9th, 2021

The school district put out a request for qualifications in 2019 for future educator housing but has “not explored further opportunities for the three sites at this time,” said district spokesperson Laura Dudnick.

“I don’t think the district right now, in the near term, is going to shift (priorities)” said Peter Cohen, co-director of the Community Council of Housing Organizations. “That doesn’t mean it’s the only way to develop educator housing. Does it have to be on district land? I don’t know.”

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November 5, 2021

Others are what’s called limited equity housing cooperatives. These are often subsidized by federal, state or local dollars to keep the buy-in price lower for low- and moderate-income earners. They put in a certain amount of money — similar to a down payment — and then pay mortgage payments on the co-op itself. There are limits on resale values and buyer income.

“As an ecosystem and as a way of thinking about housing, both (co-op models) are really important,” said Fernando Marti from Council of Community Housing, a local housing nonprofit.

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November 2nd, 2021

The limited funding and disagreement over how it should be spent is causing the city to be more discerning in buildings it acquires through the program, but housing providers say that the lack of clarity on what type of buildings the city is prioritizing for acquisition is leaving some tenants at risk of displacement.

Smaller buildings have a higher per-unit cost than larger buildings, said Fernando Marti, co-director of the Council of Community Housing Organizations, adding that if the goal is save people's homes that have been targeted for eviction, "you might say it makes sense to pay higher per unit cost per building."

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November 1st, 2021

Only a fraction of certain union workers can afford to live in the city without working more than one job, according to a new report sponsored by the Council of Community Housing Organizations, San Francisco Labor Council, and Jobs with Justice.

The report investigates how jobs and housing “fit” together. Roughly 50,000 trade and union workers volunteered wage data for the study, which the UC Berkeley Labor Center analyzed and compared to local housing prices.

The report spanned industries from nursing to airport staff, and found that only 7 percent of those employees could afford market-rate rent.

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October 14, 2021

For three decades Fernando Marti has been among the progressive political activists demonstrating outside the homes of families facing evictions.

The sometimes raucous anti-eviction protests — often featuring Aztec dancers and burning white sage to chase away bad juju — are a staple of the city’s leftist political community. They’re a way to shame landlords, expand movements, and build momentum for new laws and policies that protect tenants.

They were protesting at the displacement of artists during the live-work loft craze in the dot-com boom of the 1990s, and the rash of tenancy-in-common conversions of the early 2000s. There were protests against a 2013 eviction of the family of 80-year-old Poon Heung Lee at Jackson and Larkin streets, and a few years later to save the home of 100-year-old Iris Canada at Page and Steiner streets.

“There is the question of saving someone’s home and then there are the policies and laws needed to address the problem,” said Marti. “(The rallies) put a face on it.”

So on Tuesday morning when Marti joined about 75 demonstrators on 23rd Street in Noe Valley to protest an eviction, it was both familiar and very different. That’s because this time the family being evicted was his own, and the faces giving meaning to the tale of displacement were that of Marti, wife Michelle Foy and their 12-year-old son, Carmelo.

“It’s a very strange thing to be fighting for your own home,” said Marti, who is an architect and co-director of the Council of Community Housing Organizations.

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September 9, 2021

While strolling through an affordable housing community in downtown San Francisco, Executive Director of the Council Community Housing Organizations Peter Cohen points out it’s important to increase funding for buildings like these, so people like Larrilou aren’t forced to find housing hours from where they work.

“When you put together the lack of sufficient funding for affordable housing and the constant pressure of displacement on low-income folks, that’s why our crisis exists.”

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August 24, 2021

In June, more than 50 affordable housing and housing justice organizations sent a letter to Governor Newsom and the State Legislature's leaders advocating five core principles to guide equitable development policy, which include "not pre-emption of zoning or approval processes for market-rate housing in communities at risk of displacement."

"SB 9 looks mostly symbolic and certainly not like an affordable housing strategy. Understandably, symbolism may have political importance, but it is different from substantive affordable housing policy," said Council of Community Housing Organizations executive director Peter Cohen.

He said the upzoning and "missing middle infill strategy" proposed by SB 9 could work if targeted to the right places — the "huge swaths of the region's suburban cities," rather than hot-market rapidly gentrifying cities like San Francisco and central San Jose and Oakland.

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August 5, 2021

“Part of the way that we finance affordable housing right now is through loans through traditional banks. And those loans are not necessarily made because traditional banks love to invest and lend to affordable housing, but because we have laws in place — the Community Reinvestment Act — that require banks to do that kind of lending. That said, those are the same banks that are investing in fossil fuels; are investing in, or have connections to, payday lending institutions, all sorts of kind of bad actors. And so the city’s investments, whether they’re in affordable housing or others, are now tied up with all of these things that at the same time, we’re passing resolutions and saying we as a city don’t support these things.”

— Fernando Martí

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July 23, 2021

Those meetings and prior efforts by the city’s advocates to push affordable housing production westward resulted in the formation of the Westside Community Coalition, a group that runs the gamut of neighborhood residents, teachers, housing organizers and others vying to see the project through in an area that is increasingly grappling with rising housing costs.

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