June 20, 2025
Supervisor Danny Sauter
San Francisco Board of Supervisors 1 Dr. Carlton B. Goodlett Place
San Francisco, CA 94102
Via Email: danny.sauter@sfgov.org
Re: Proposed Draft Upzoning Plan for District 3
Dear Supervisor Sauter,
We represent longstanding organizations in District 3 that have a shared interest in the vitality, livability and sustainability of some of San Francisco’s most celebrated, cherished neighborhoods. We write to express our concerns with the Mayor’s proposed draft upzoning plan (“Draft Upzoning Plan”), which the Board of Supervisors will be considering in the months ahead. We invite you to engage with us to collectively work toward a vision of housing growth that fully protects our existing tenants, vibrant small businesses, historic resources, and diverse culture of District 3, while safeguarding the soul, attractiveness, and culture of our densely developed neighborhood. We request an in person meeting with the representatives of our organizations and all District 3 neighborhood and merchant organizations to discuss our concerns.
We seek to understand your position on each of the following issues and concerns with the proposed Draft Upzoning Plan.
Upzoning and Density Decontrol Added for North Beach, Telegraph Hill, and the Northern Waterfront, including Fisherman’s Wharf Undermine the Entire Effort
In 2025, for the very first time, the proposed Draft Upzoning Plan includes height increases and density decontrols in the North Beach, Telegraph Hill, and northern waterfront areas, which were not included on any of the previously proposed Zoning Maps prior to you becoming our District 3 Supervisor. Notably, these changes were not in the “Proposed Action” analyzed in the adopted Housing Element EIR, nor were they included on any of the three “Rezoning Program Scenarios” contained in the adopted Updated Housing Element.
We have been told by individuals in the Planning Department that these new density decontrol and additional height limit increases in District 3 were added to the map at your specific request. We urge you to reconsider and to request that the Planning Department and Office of the Mayor remove these height increases and density decontrols from all future versions of the Draft Upzoning Plan.
Impacts to Our District 3 Neighborhoods Must be Addressed
As proposed, the Draft Upzoning Plan would imperil our neighborhood’s existing rent- controlled, multi-unit family housing, ethnic diversity, historic and cultural resources, and economic vibrancy of our small neighborhood businesses. 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 relevant goals and policies of the adopted 2022 Updated Housing Element.
1. Threats to Existing Tenants and Rent-Controlled Housing
North Beach and Telegraph Hill are among the densest neighborhoods in San Francisco, with 65% of our residents living in existing multi-family, rent-controlled buildings that house our City’s workforce and seniors, including a large immigrant Asian population. Unfortunately, because 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 proposed upzoning and density decontrol in North Beach and Telegraph Hill would increase property values, thereby resulting in even more speculation and displacement of tenants.
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.”
Unfortunately, existing legal protections for tenants have not prevented evictions, nor will the so-called “tenant protections” for rent-controlled buildings in the Housing Element prevent the flood of displacement incentivized by the proposed upzoning and density decontrol. Incentives for redevelopment provided by the upzoning and density decontrols, along with deregulation, will intensify demolition and displacement, destabilizing our communities.
We urge you to require the Planning Department and Office of the Mayor to remove from the proposed Upzoning Plan all height increases and density decontrols from areas with existing multi-family, rent-controlled housing. The protection of these areas is the reason North Beach was not a part of the “Proposed Action” in the adopted and certified 2022 Housing Element EIR.
2. Endangering Existing Neighborhood-Serving Retail Corridors
Columbus, Union and Powell 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 adopted 2022 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 Draft Upzoning Plan were considered or analyzed in the adopted Housing Element EIR.
Although policies in Goal 5 of the Housing Element recommend that new buildings include services or retail on their ground floors, we are aware from existing new large scale residential buildings that the new ground floors are mostly vacant as evidenced by new large apartment and condominium buildings on Market Street or on other corridors like Van Ness Avenue. In District 3, please consider the experience of The Jug Shop, a 60-year-old Legacy Business on Pacific Avenue at Polk Street. It was displaced and its former home demolished to make way for a large-scale market-rate condominium development. The Jug Shop moved 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 is now going out of business after 60 years of continuous operation. This will be the model for our district 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. And, 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, likely leading 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 you to require the Planning Department and Office of the Mayor to remove from the Draft Upzoning Plan the proposed upzoning and density decontrol within all Neighborhood Commercial Districts in District 3, especially the thriving North Beach NCD, which was never a part of any prior upzoning maps and was not considered part of the “Proposed Action” in the adopted and certified 2022 Housing Element EIR.
3. Significant Impacts to Historic Resources
North Beach and Telegraph Hill are among the oldest and most significant historic neighborhoods in San Francisco. Telegraph Hill Historic District is one of the earliest historic districts designated under Planning Code Article 10. A North Beach Historic District, which you refuse to support, clearly qualifies for recognition on the California and National Registers of Historic Places.
The proposed Draft Upzoning Plan shows all of the Telegraph Hill Historic District with density decontrol, and a significant portion of the proposed North Beach National Register Historic District with a height increase and accompanying density decontrol. Incentives for redevelopment that would be provided by the upzoning and density decontrols, coupled with deregulation, would greatly intensify threats of demolition within these historic districts.
To illuminate a point made above, these height increases and density decontrols on these historic districts were not in the “Proposed Action” considered in the adopted Housing Element EIR, nor were they included on any of the three “Rezoning Program Scenarios” in the adopted Housing Element.
The following actions contained in the Housing Element 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.
Unfortunately, due in large part to misinformation and your lack of support for a North Beach National Register Historic District, which conflicts with the above provisions of the Housing Element, there is no acknowledgment of the availability of historic preservation incentives for potential housing development and historic preservation incentives, such as tax credit programs and the State Historical Building Code, for use in residential rehabilitation projects available as a result of the listing North Beach Historic District.
We urge you, therefore, as our District 3 Supervisor, to join with local businesses, organizations, residents, and property owners in support of the designation of the North Beach National Register Historic District as proposed.
4. Risking a New Wall on the Waterfront
For more than 60 years, the northern portion of District 3 nearest the waterfront has been zoned at a maximum height of 40 feet. The Draft Upzoning Plan proposes to increase 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.
The proposed Draft Upzoning Plan must to be revised to prevent this eventuality. Please do not let this happen. Urge the Planning Department and Mayor’s office to remove the upzoning and density decontrol from the areas on the northern waterfront.
Proposed Upzoning Plan Fails to Address the RHNA Mandates to Build Affordable Housing.
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.
We note that the State’s Department of Finance 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 target?
In conflict with the adopted 2022 Updated Housing Element, the Mayor’s Draft Upzoning Plan fails to further the RHNA mandates to build or preserve affordable housing. Moreover, the numerous new State (and local) housing laws enacted since the certification of the 2022
Housing Element EIR and adoption of the Housing Element have 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.
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?
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In conclusion, we reiterate our invitation to you, Supervisor Sauter, to work with us toward a collective vision of housing for District 3 that fully protects our existing tenants and rent- controlled housing, our vibrant small businesses, and our historic resources, while safeguarding the soul and diversity of our neighborhoods.
Sincerely,
North Beach Business Association
Stuart Watts, President
North Beach Tenants Committee
Theresa Flandrich, Chair
Pacific Avenue Neighborhood Association
Robyn Tucker, President
Russian Hill Community Association
Kathleen Courtney, Chair
Telegraph Hill Dwellers
Nick Ferris, President
Upper Chinatown Neighborhood Association
Hanmin Liu, Chair
cc: Mayor Daniel Lurie daniel.lurie@sfgov.org
Rich Hillis, Outgoing Planning Director rich.hillis@sfgov.org
Sarah Dennis-Phillips, Incoming Planning Director sarah.dennis-phillips@sfgov.org Rachel Tanner, Planner rachel.tanner@sfgov.org
Lisa Chen, Planner lisa.chen@sfgov.org
Members, San Francisco Planning Commission commissions.secretary@sfgov.org Members, San Francisco Board of Supervisors Board.of.Supervisors@sfgov.org