On July 18 the Metropolitan Transportation Commission (MTC) and the Association of Bay Area Governments (ABAG) approved a thirty-year “Smart Growth” regional plan. Most notably, the plan seeks to steer the majority of the region’s real estate development into specified locations including most of San Francisco’s eastern neighborhoods--despite projections that the strategy will displace tens of thousands and a finding by a state agency that it is in violation of state law.

Under the plan entitled ‘Plan Bay Area,’ San Francisco is expected to grow its population by over 35%, to over 1,080,000 by 2040 (by comparison, Marin’ is asked to accommodate a 13% increase). Eleventh hour amendments spearheaded by progressives may eventually mitigate or at least soften some of the negative impacts but these broadly stated amendments to the plan leave their outcomes uncertain. And even as amended, the adopted plan fails to incorporate the primary recommendations of an alternative plan proposed by environmental and social equity advocates that would have distributed regional growth more evenly and yielded environmental and social equity outcomes ranked as “superior” even by the standards set by MTC/ABAG’s own researchers.


Although it is too early to assess the full implications of Plan Bay Area it is already clear that if state regulators allow MTC/ABAG to proceed, this plan will have consequences unlike the region’s ‘vision statements’ of the past. Plan Bay Area is literally a road map for public and private investment.

For the first time, this plan knits together land use planning with long term transportation investments—more than $280 Billion in roads, highways, and transit programs over the life of the plan. Where those investments go, private developers will follow with the blessings of regional planners. The plan’s selected transit accessible target communities and neighborhoods for that intensive growth, known as ‘Priority Development Areas’ (PDAs), will then be expected to accommodate more than 60% of the region’s growth in jobs and 70% of the new housing.

In the abstract, concentrating future development near transit comes across as sensible “Smart Growth.” And for some relatively undeveloped PDAs, there will be few negative consequences.

But as critics have noted, many PDAs include existing mostly working class neighborhoods with high concentrations of renters. As a result of refocusing growth in these older urban communities, by MTC/ABAG’s own very conservative estimates, the PDA strategy will put tens of thousands of families and seniors of modest means at greater risk of displacement, including most of the eastern third of San Francisco where a majority of lower income minority residents live and where many also work.

Some of the locations considered to be the best targets for smart growth today are those urban neighborhoods with transit reliant communities that persevered through decades of disinvestment from middle class suburban flight.

How do the regional agencies rationalize how their plan will put tens of thousands of existing Bay Area residents at risk of displacement? First, in their environmental impact analysis the agencies assert that although there will be local displacement at the community/neighborhood level, their plans for overall regional housing production will offset that loss by providing another place in the Bay Area for that displaced family to land. They also reference to San Francisco’s rent control as a policy that will control for local displacement. And finally, they assert that the benefits of improving neighborhoods will outweigh the impacts of displacement.

The inadequacies of the latter two claims are obvious to San Franciscans who have witnessed the gentrification of formerly economically diverse neighborhoods throughout the City. But the slight-of-hand logic of the first claim deserves additional attention.

Although the Plan Bay Area claims that it will “house 100% of the region’s projected growth,” the plan fails to explain how that housing will be affordable to anyone but the upper middle class and very wealthy. For decades, ABAG has been setting goals for housing production for cities and counties in the region, including goals for housing affordable to lower and moderate income households.

But the only goals that have ever been met entirely have been for market rate housing affordable only for upper income households. MTC and ABAG could have set more rigorous standards to achieve these affordability goals in Plan Bay Area. They could have also followed their staff recommendations to dedicate anticipated future revenue from the state’s cap and trade program to affordable housing. But MTC and ABAG commissioners rejected those options. Instead, Plan Bay Area’s claim to address the risk of local displacement by promising affordable housing regionally remains based upon its mythical affordable housing goals.

But those goals have been called into question by the state’s Department of Housing and Community Development . The state agency has challenged the core policy of Plan Bay Area which allows cities and counties in the region to in effect reduce how much housing they will produce by failing to designate PDAs (shortly before the approval of the plan, Marin withdrew its PDA designations apparently for this purpose).

State law requires that all localities accommodate their ‘fair share’ of a region’s need for housing production. In June, HCD found the PDA policy violates that law and instructed ABAG to revise the policy and adjust its goals. But ABAG disregarded HCD’s instructions and approved the unrevised housing goals on July 18 along with the adoption of Plan Bay Area. HCD’s response has not yet been announced. Whatever the state’s next move, the survival of the region’s economically and ethnically diverse communities is likely to require a concerted effort to divert Plan Bay Area from its present path towards unequal development and increased displacement.

Gen Fujioka is the public policy manager at Chinatown Community Development Center. For further supporting documentation see this link.