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- California's Rubiks Cube Just Got More Complicated
Well, it took COVID-19 to knock the housing crisis off the front page of California’s newspapers. Or, maybe more to the point, COVID-19 has caused coverage of the housing crisis to morph into additional coverage of the virus, with a focus not on NIMBY v. YIMBY but on housing the homeless , banning evictions , and desperate families squatting in vacant houses .
- Where Is California's Population Really Declining?
So, it’s official: California is losing population. According to the state Department of Finance, the state lost almost 200,000 people in 2020, the year that COVID caused home prices to rise dramatically and people to flee large cities. This is the first time in the modern history of California – some 170-plus years – that the population has gone down. But a close examination of the trends reveal that the population isn’t going down everywhere. It’s only going down in expensive coastal areas, where pretty much any house will now cost you at least $1 million. The population growth is continuing at more or less the same pace in inland areas, though even there it did dip a bit in 2020. As this column has previously reported , California’s population growth continued to be reasonably healthy until 2017, when it started to flatline for the first time ever. Population growth has been plummeting ever since and finally went negative last year. So it makes sense to look at recent population trends in five-year increments: What happened in 2016-2021 compared to 2011-2016? What we see is a pretty clear trend that growth has been wiped out in coastal areas but not in inland areas. Take a look at the first chart, which compares raw population growth in coastal and inland counties during these two periods. Between 2011 and 2016, the coastal counties grew by 1 million people, while the inland counties grew by about a half-million. Now look at 2016-2021: The coastal counties lost population, while the inland counties continue to grow by … about a half-million people. Incidentally, even though the rate (i.e. percentage) of inland population growth has been much faster than coastal population growth for decades, this is the first time that the raw number has been higher in the inland areas than in the coastal areas. That alone may be the most important takeaway from DOF’s new numbers. But what’s happening within each metropolitan area? Is it true that people are fleeing the Bay Area in enormous numbers, while other regions are doing okay, as the popular press would have it? Well, not exactly. Take a look at the second chart, which depicts population growth at the metropolitan region level for the same two periods. What is shows is pretty startling: The population of the three coastal Southern California counties (Ventura, Los Angeles, and Orange) dropped dramatically between 2016 and 2021, while Central Coast counties dropped slightly – and Bay Area population hung in there and even grew slightly. (It is true that the Bay Area’s population dipped slightly in 2020, but it’s still higher than it was in 2016 – which is not true of coastal Southern California.) Meanwhile, population in the Sacramento region, the Central Valley, and the Inland Empire all went up between 2016 and 2021 – and, indeed, all three inland regions gained population even in 2020. Now let’s take this analysis one step further down, to the county level. And here is where the difference becomes truly startling: After adding almost 300,000 people in the first half of the decade, Los Angeles County alone lost more than 100,000 in the second half of the 2010s and is settling in at about 10 million. Meanwhile, both San Francisco and Santa Clara counties experienced population gains during this period, though they were much smaller than the gains experienced in 2011-2016. Curiously, Contra Costa County – which you’d think would gain population in a COVID rush from San Francisco to the suburbs – also lost a lot of population in the second half of the decade. And though it’s not depicted on the chart, all of Contra Costa’s population decline occurred during 2020 – while San Francisco and Santa Clara experienced miniscule population drops. It’s worth noting that the three large counties depicted on this chart – Riverside, Sacramento, and Fresno – all experienced more or less the same raw population growth in the second half of the decade as they did in the first (and in fact they all added population in 2020). Meanwhile, El Dorado County – the mountainous county east of Sacramento – added population faster, in percentage terms, than the larger inland counties.’ So, overall, we see two trends – one that’s not surprising and one that is. It’s not the least bit surprising that inland areas have held their population growth while coastal areas have declined. After all, the inland areas are just about the only place in the state where middle-class families can afford to buy a house these days. But it is somewhat surprising, given all the publicity about the urban exodus from San Francisco, to see that the Bay Area’s population is holding steady while L.A. County’s declines. You’d think it would be the other way around, given the Bay Area’s higher housing prices, the presence of many dense neighborhoods, and the publicity surrounding remote work in the tech industry. Yet that’s not the case. As economic geographer Michael Storper made abundantly clear in his book The Rise and Fall of Urban Economies , the Bay Area has done a much better job of managing to keep its economy afloat in a high-cost environment than Los Angeles. In many ways, L.A. these days has the worst of both worlds: It’s a low-wage, high-cost city – and the Bay Area, despite all of its inequities, isn’t quite in the same boat. It’s impossible, of course, to know whether the state’s current population decline will continue. Fertility and immigration may come back and the state may start growing again. But the internal trends are likely to continue: The bulk of the population growth will be in the inland areas, and the Bay Area is better positioned to weather this storm that L.A.
- Is Newsom's Infrastructure Package Real CEQA Reform?
Gov. Gavin Newsom got a lot of publicity on May 19 when he announced his infrastructure streamlining package. The Los Angeles Times called it “sweeping” . The San Francisco Chronicle went further, calling it “the most significant reform of the landmark California Environmental Quality Act in decades.” CalMatters reported that Newsom himself said : “If we get nothing else done in the next three years, this may be one of the most consequential things that we can actually deliver.”
- Who Will Be HCD's Next Target?
So who’s next?
- Newsom's Infill-CEQA Play Isn't About Housing. It's About Transportation
When Gov. Gavin Newsom announced on July 31 that he had signed an executive order to stimulate infill development, most of the publicity was around reforming building codes – and possibly finding a way to ditch the two-stairway requirement for apartment buildings, which YIMBY advocates say would significantly decrease the cost of multifamily housing.
- Donald Shoup Wasn't Just About Parking. He Was About The Economics Of Public Goods.
This piece is brought to you free of charge courtesy of the paying subscribers to California Planning & Development Report. To become a paying subscriber with access to all of our content, just click here . The passing of the legendary “parking guru” Donald Shoup has saddened everyone in the world of urban planning – especially former students like me. Don was an amazing guy. As an individual he was unfailingly kind and generous to everybody, although he did have an acerbic sense of humor. As an academic he was rigorous. And of course he changed the way the entire world looks at parking. It is remarkable, in retrospect, that a quirky guy who had never been a prominent academic became in his later years the object of a cult-like following. He called himself “Shoup Dogg” and his devoted followers called themselves “Shoupistas”. Even when it was unfashionable to do so, I was always proud to count myself among the Shoupistas. I knew Don for more than 40 years – half of his life and two-thirds of mine, ever since I showed up in his required public economics class at UCLA planning school back in the ‘80s. Our paths crossed innumerable times, most notably around 2010, when as Mayor of Ventura, California, I was involved in the implementation of a controversial Shoupian parking strategy for the downtown area. Don was proud of the fact that his old student helped bring about change in the real world based on his ideas and the Ventura story gained a lot of currency in urban planning circles, partly because of Don’s great celebrity as a result of his seminal 2005 book The High Cost Of Free Parking – and also the fact that he talked about Ventura endlessly in his speeches and interviews. Our personal relationship was a warm one, and Don often told funny stories about me – some of which were even true. (You can read more about how Ventura implemented Shoupian parking principles in my old mayoral blog here . I go into much more detail about my experience in Ventura and the whole history of relationship with him in the upcoming Routledge book, The Shoup Doctrine. ) But as I have reflected over the past few days about Don’s career and my interaction with him, it dawned on me that, in the end, he wasn’t really about parking. Don was an economist, and his mission was to help people understand the underlying economics of public goods and services. Parking was simply the vehicle, one might say, that he chose to do so. Whenever anybody asked him how he got so focused on parking, Don always had a funny answer. If you are a public policy academic, the ones who study national issues – the presidency in particular – are at the top of the heap. Far behind were those who study state issues. At the bottom of the barrel, where Don jokingly used to argue he could be found, were those studying local government. (In some cases, local government doesn’t even count toward scholarly achievement in academia.) And among those studying local government, there were two issues nobody ever wanted to touch: parking and sewage. Don didn’t want to study sewage. So he studied parking. In later years Don always made fun of my paper on this topic, claiming that it was “just one long sentence,” and when he asked me why, I said, “That’s how I thought economists wrote.” This was not true, but he did grade it very thoughtfully, which I always appreciated. (FWIW, you can find my paper here ; let me know if you need access.) The larger point, though, is that Don was fascinated by the economics of all public services, not just parking. What really led him to parking (other than the fact that it wasn’t sewage) was the fact that it was a classic case of the government giving away something for free or at a below-market price to individuals who benefitted from the giveaway. Every public parking space has both a cost to the government and a value to individual users. In some cases, the demand for this particular public resource exceeds the supply. As an economist, Don understood that if demand exceeds supply, the supply must be allocated one way or another. For the government, the simplest way to allocate resources is on a first-come, first-served basis. This is how most public commodities are allocated, ranging from housing vouchers (think of the waiting list) to campgrounds (though they often come with a small price tag) to parking spaces. But Don believed first-come, first-served was not the only way, nor even in many cases the best way, to allocate public resources. There were at least two other ways. The first was to restrict the amount of time that people can use the commodity, which is (supposedly, if enforcement is good) what happens with many parking regimes. And the second is to charge money. In point of fact, all three are sometimes used in combination. You may have to sign up months in advance for a desirable campground but depending on the location you may pay a fairly hefty fee and you may be able to stay only a certain number of days. I doubt rigorous research goes into the impact of this combination, but it is illuminating to look at it this way. Now, charging money for a public commodity is a controversial idea. In some cases – housing vouchers, for instance – it’s not a realistic alternative, since the whole purpose of housing vouchers is to give people money to pay for housing. And it’s always very difficult to get people to pay for something they are accustomed to getting for free. But over time, Don came to persuade millions of people that charging for parking owned by the government makes sense. He did this in two ways. First, he used the supply and demand argument, which is hard to argue with. (Curiously, ideological right-wingers sometimes did argue with it, which I never understood.) But second, as an economist, he understood that when a payment is involved, there’s both a loser and a winner. In the case of parking, the loser is the motorist who pays (though Don would argue the motorist is a winner because they have access to spaces that would otherwise be occupied by freeloaders). The winner is whoever gets to spend the money. And Don shrewdly understood that this was a very important question. If the government throws the money into the general fund, never to be seen again, there’s no political benefit to anybody. But if you give that money back to the neighborhood where the paid parking is occurring, you can provide a tangible benefit to that neighborhood – and begin to overcome political opposition to paid parking. A couple of weeks ago in San Diego, where I live, the city doubled on-street parking fees. Fehr & Peers did do a rigorous parking study for the city which proposed dynamic pricing and extended hours for paid parking (eliminating free parking on Sunday’s for example, and the city is likely to implement those moves in the future. But the doubling of fees occurred simply because the city is trying to plug a big budget eficit. This is exactly the wrong way to go about things not only economically but politically, because the worst thing you can do is price a public commodity higher just because it’s a cash cow. Don Shoup singlehandedly punched a big hole in that idea. And while politicians will inevitably fall victim to the temptation every now and then, we Shoupistas will always be around to call them out. If you'd like to learn more about Donald Shoup's ideas and their impact on parking policy, check out my one-hour, on-demand course on parking , eligible for AICP CM credit. (Be sure to click on "Course Info" for a full description. This course has been updated to honor Shoup's passing and expand on his ideas.
- Is The Era Of Ballot-Box Zoning Over?
Like some 60 other cities in California, Davis has a voter-approved requirement that some development projects require a vote before they can move forward. Four developers in Davis want their projects to go before the voters next year. The Davis City Council has declined so far to move those ballot measures forward, saying the time is not right and they want to focus on a revenue measure instead. Now, one of the developers, is invoking the builder’s remedy. Is this the end of ballot-box zoning in California? Ballot-box zoning – the practice of adopting land use legislation by initiative and often requiring a subsequent vote to approve future projects – was once a predominant feature of the California planning landscape. Beginning in the 1970s – and accelerating during the ‘80s and ‘90s – ballot-box zoning was a critical component of that era’s growth management regime. Such vote requirements were typically imposed in coastal cities such as Carlsbad and Costa Mesa, college towns such as Davis and San Luis Obispo, and affluent suburbs in inland California such as Redlands and Lodi. (For a history of ballot-box zoning trends from that period, check out the 2002 report that Solimar Research Group did here .) Now, however, ballot-box zoning is running up against the recent state-level push to allow more housing production. And it may be that ballot-box zoning will lose. As pressure to build more housing has mounted, some cities have looked for ways to deal with their longstanding voter-approval requirements. Already in Costa Mesa, voters have amended the ballot-box zoning requirement to exempt certain commercial and industrial property. But the big question that remains is whether the state’s aggressive housing production regime will pre-empt local voters’ power to restrict development via initiative. Not all development projects are subject to the initiative process, of course. Only legislative matters can go on the ballot – not ministerial projects. For 40 years, however, the courts have ruled that this means any general plan amendment or zone change is a legislative matter and therefore can go on the ballot. (Conversely, as the Legislature has passed SB 35 and other laws allowing projects to move forward ministerially, that means such projects not only evade the California Environmental Quality Act but also the ballot.) The Davis situation seems like to be the flashpoint for the issue. The recent story goes something like this: Four different developers wanted to get on the ballot in 2024. But on April 11, the City Council decided it would not put those projects on the ballot next year. Councilmembers cited a lack of staff time – saying the planning department is understaffed – and a desire to focus instead on a revenue measure in 2024. “I do not think November 2024 is right for any of them,” said Councilman Bapu Vaitla. But that’s not where the story ends. At the same time that the Davis City Council was considering whether to move any of the four projects to the ballot, the Department of Housing and Community Development was reviewing the city’s housing element. And on April 3, HCD wrote a letter that was somewhat encouraging – but nevertheless found the housing element to be out of compliance. In particular, HCD was critical of the fact that a mixed-use project known as University Commons had dropped its residential component, requiring the city to identify more possible locations for housing.
- When Is An Infill Parcel Not An Infill Parcel?
What’s infill development and what’s not? And how good does transit service have to be for new projects nearby to be regarded as “transit-oriented development”? As a recent court ruling from, of all places, King City illustrates, there are lots of different definitions in California state law about these kinds of things – and interpreting those definitions makes a huge difference in whether projects move through the entitlement process quickly or grind through environmental review slowly. The King City case appeared to be a classic case of a labor union using the California Environmental Quality Act to try to slow or kill a project involving a business that would threaten a nearby unionized business. King City agreed to sell an old piece of redevelopment property to Grocery Outlet, the discount grocery chain. (Most Grocery Outlets are not unionized.) The property used to be a car sales lot and is completely surrounded by developed property, including a cemetery and Highway 101. So King City invoked the so-called Class 32 exemption under CEQA. But the Grocery Outlet would be located less than a half-mile away from an existing Safeway store, where workers are represented by the United Food and Commercial Workers. Organizations and individuals affiliated with UFCW sued, claiming that a different set of definitions about infill development should apply, which the plaintiffs claimed the Grocery Outlet didn’t meet. But that’s not the only confusing set of definitions we find in state law dealing with infill development. Transit-oriented development also sometimes qualifies for a CEQA exemption (as well as, in many cases, reduced parking requirements.) But TOD too is subject to various definitions, including a pretty significant change from a new law passed in 2024 and set to go into effect in 2025. The Class 32 CEQA exemption that King City used for Grocery Outlet (CEQA Guidelines §15332) is pretty straightforward. Although it’s subject to some additional conditions, basically any development project that is less than five acres and “substantially surrounded by urban uses”. Cities are using the Class 32 exemption more and more these days, and the King City situation seemed typical.
- How Will SB 79 Affect Cities In California?
YIMBYs are over moon about the passage of SB 79, the law designed to facilitate construction of housing near major transit stations. But what does it mean for cities and counties in California? For most cities and counties, it won’t have any effect at all. That’s because SB 79 only applies to major transit stations – stations with frequent rail or bus rapid transit service. Many areas with frequent bus service – even “high-quality transit stops” under state law – won’t be affected. (SB 79 doesn’t apply to unincorporated areas, even those in urban areas, until the next Regional Housing Needs Allocation cycle.0 But for any jurisdiction that does have a rail or BRT station, life is about to get very different. You won’t have much control over development near these stations – if any at all. What Does SB 79 Do? At its core, SB 79 does two things: First, it essentially upzones all land in close proximity to major transit stations throughout the state – allowing housing developments of up to 65-95 feet, often with the option of ministerial approval. Densities can range up to 100-120 units per acre plus density bonuses. Although approval is not ministerial, this upzoning trumps local general plans and zoning and local governments are supposed to amend their plans – including their housing elements – to conform to the law. Second, the bill authorizes local transit agencies to develop their own zoning and objective design standards, effectively transferring land use authority from local governments to the transit agencies. The bill also beefs up the role of the Department of Housing & Community Development, giving HCD the power to determine how to account for SB 79 capacity in the Regional Housing Needs Allocation. Last-minute amendments made a number of changes, including creating a minimum project size of 7 units and limiting the average unit size for SB 79 areas to 1,750 square feet. The changes did not, however, bring around the League and the many cities opposed to the bill.
- CP&DR News Briefs January 20, 2026: HCD Audit; Corporate Homeownership; L.A. Fire Zone Lawsuit; and More
This article is brought to you courtesy of the paying subscribers to California Planning & Development Report . You can subscribe to CP&DR by clicking here . You can sign up for CP&DR ’s free weekly newsletter here . Audit Supports HCD Efforts to Encourage Housing Element Compliance An audit of the California Department of Housing and Community Development (HCD) found that the agency’s letters jurisdictions regarding noncompliant housing elements were generally able to provide valuable feedback, but certain jurisdictions may require individualized assistance. HCD generally met statutory deadlines. But, many jurisdictions still struggled to revise plans due to complex new legal requirements, increased housing allocations, and community opposition. From August 2021 to August 2023, HCD reviewed 1,049 housing elements for 389 jurisdictions. As of January 2026, 90.2 percent of jurisdictions have adopted housing elements found to be in compliance with state law. HCD’s written findings alone often weren’t sufficient, and local governments emphasized that one-on-one assistance was vital to understanding and addressing required changes. However, HCD’s capacity to provide individualized support was strained by heavy workloads, turnover, and overlapping submission deadlines.The report found that online guidance was detailed but not always issued in time to be maximally useful. HCD has indicated that it largely agrees with the CSA findings and recommendations and will implement suggested changes to strengthen the program. (See related CP&DR coverage .) Newsom Seeks to Rein in Corporate Owership of Housing Gov. Gavin Newsom will target large corporate landlords and private equity investors that buy up housing in California, saying their practices make it harder for ordinary residents to afford homes. In his State of the State address, Newsom said he wants to work with the Legislature to regulate or curb the influence of these big investors, potentially through enhanced oversight, enforcement, and changes to the state tax code. Newsom’s proposal reflects growing political concern about how investor-owned homes affect affordability and competition for buying opportunities in the state. Los Angeles Faces Lawsuit over Building in Fire Zones The city of Los Angeles is being sued for repeatedly approving new development in areas known to be at high risk for wildfires, allegedly ignoring state fire safety regulations. The lawsuit by State Alliance for Firesafe Road Regulations and the Federation of Hillside and Canyon Associations cites 75 examples of building permits and other approved plans that they allege violate fire safety regulations. The state’s “minimum firesafe regulations” require approved developments to meet certain criteria including wide, flat roads with only short dead-end roads, standardized water sources, and when applicable, at least 30 feet of space between buildings and property lines. In areas recently impacted by the January 2025 wildfires, the debate of housing density and fire safety is especially relevant, with residents worried that the state’s push for denser housing in the city will further endanger them by further slowing evacuation. San Francisco Approves City's Third-Tallest Building The San Francisco Planning Department approved plans for a 67-story mixed-use skyscraper at 10 South Van Ness Avenue, replacing a two-story commercial building with 1,019 apartments, ground-floor retail, and parking. In 2021, the developer purchased a lot at 1979 Mission St. and transferred ownership to the city in order to meet off-site affordable housing requirements, which allowed the company to develop a fully market-rate skyscraper at the Van Ness property. Recent updated plans for the tower include 89 below-market-rate units and reduce the total number of units but increase the building’s height, with a mix of studio-sized and family-sized apartments, parking for 255 cars, and bicycle storage. If built as proposed, the project would become the third-tallest building in the city. CP&DR Coverage: The Legislature's Approach to CEQA in 2026 As the Legislature prepares to convene in January, another round of changes to the California Environmental Quality Act seems likely. The question is whether the 2026 changes will be incremental – clarifying, among other things, some of the “Swiss-cheese” holes punched in CEQA in 2025 – or whether someone in the Legislature will attempt a more comprehensive attempt at reform. Notably, the California Chamber of Commerce has attracted significant attention with proposals for 2026 that would make major changes in CEQA, which includes adding several “shot clocks” to move the CEQA process along faster, a streamlined alternatives analysis, and an exemption for small projects. However, executing a holistic reform remains complicated, as several players, namely pro-housing advocates, conservation organizations, and environmental justice groups, remain steadfast in advancing their varied missions. All of which leaves the legislators themselves in the middle, trying to figure out how to straddle all of these competing political interests – most of which work against comprehensive CEQA reform. Quick Hits & Updates California’s plan to build a 45-mile tunnel under the Sacramento-San Joaquin River Delta to transport water from north to south hit a financial roadblock when a court ruled the state lacked authority to issue $16 billion in bonds for the project. The tunnel, supported by Gov. Newsom and water agencies but opposed by environmental groups, would bypass delta wetlands and take about 13 years to construct. The San Diego Unified School District is seeking a plan to build hundreds of affordable homes for its own employees on excess district property in response to the region’s high housing costs, but discussions have now paused the process over concerns regarding quality and cost per unit. Board leaders reviewed more than a dozen developer proposals that could have produced around 1,500 new homes, but at a recent board meeting, long-time member Richard Barrera suggested developers revise proposals completely to better align with the district’s goals. The state launched a new website to connect Eaton and Palisades fire victims with resources for rebuilding, including access to vetted contractors and builders and four homebuilding pathways including modular, pre-designed, semi-custom and custom homes. Launched nearly one year after the fires, the website also includes resources for mortgage relief, building estimates and support. The City of Inglewood has voided its development agreement with L.A. Rams owner Stan Kroenke’s Hollywood Park Land Company, saying it was improperly adopted and therefore unenforceable, and has refused to perform under its terms. In response, Kroenke’s companies, which developed SoFi Stadium and the surrounding Hollywood Park complex, argue that they are owed hundreds of millions of dollars after the City received over $25 million in revenue from the Hollywood Park campus. Residents of Woodland Hills in Los Angeles are organizing against a proposed 20-acre, 398 home development in a Very High Fire Hazard Severity Zone on the grounds of the Woodland Hills Country Club. Residents say the future remains unclear as to whether the project will be able to bypass public hearings and environmental review under AB 2011 and its subsequent amendments, which expand its protections beyond its original intent to increase affordable housing stock. A town north of Sacramento is set to be the first 3D printed neighborhood in California. The development, a project of Sacramento startup 4dify , consists of five homes made of concrete. The technology produces homes in a much shorter time frame and with lower construction costs, with one machine able to print eight to ten houses per year.
- Since 2022, New Housing Has Caught Up With New Population
California’s housing cost is still the highest in the nation and Sacramento is still focused on increasing housing production. And although overall production has not gone up much in recent years, it’s outpacing population growth – at least according to the demographers at the California Department of Finance. The latest numbers show that between 2022 and 2025, California added one new housing unit for every resident – 349,000 new people and 364,000 new housing units, or a little over 100,000 each per year. A quarter of those units were built in Los Angeles County even though the population barely moved at all, while second place – far behind – went to San Diego County. Most of the population and housing growth – 300,000 out of around 360,000 -- came in 15 large counties. But there was a big difference in the type of housing, and the population composition, between coastal and inland counties. Of the 15 counties with the largest population and housing increases, eight were in coastal areas (including the Bay Area) and seven were in inland areas. But the differences were notable: In the eight coastal counties, housing growth was almost double that of population growth – 202,000 compared to 117,000. Almost half of the housing growth in these eight counties came in Los Angeles County. In the seven inland counties, the trend was the opposite. Population growth was almost double housing growth, 182,000 to 100,000. For example, Riverside County added 60,000 residents – most in the state – but only 29,000 housing units. Part of the reason for this difference, of course, was housing type. In the coastal counties, about 117,000 of the 200,000 new housing units were multifamily, while in the inland areas, about 80,000 of the 100,000 new units were single-family. Statewide, 43% of new units were multifamily, a significant increase over the 2022 overall statewide number of 31%. Among coastal counties, multifamily units in Alameda – which has seen aggressive prohousing policies in places like Oakland, Emeryville, and Berkeley – accounted for 80% of new units. Santa Clara County saw 67% multifamily and San Diego 60%. Some “coastal” counties with significant greenfield inland areas, including Los Angeles and Contra Costa, hovered around 50-50. Meanwhile, in Riverside County, only 12.6% of new units were multifamily. San Francisco and Kern had almost the same number of units built but were complete opposites in housing type. The SF/MF split in San Francisco was 89/11, while in Kern is was 7/93.
- Benicia Properly Used SB 35 For Projects In Historic Arsenal District
A challenge to two SB 35 projects in Benicia by a local preservation group – arguing, among other things, that the projects involved historic structures and wetlands – has been struck down by the First District Court of Appeal. The ruling is unpublished and therefore cannot be used as precedent.





