Board upholds Zoning Administrator’s bulk-measurement interpretation in 2700 Sloat appeal

The San Francisco Board of Appeals on July 26, 2023 denied an appeal and upheld a Zoning Administrator interpretation of Planning Code Sections 102 and 270 that clarifies how maximum plan dimensions are measured where buildings include multiple vertical elements above a base height. The vote was 4–0.

Appellants — represented by counsel — argued the interpretation reads a new bulk limitation into the code (effectively allowing only one vertical element per building within the maximum plan dimension), would reduce residential capacity on large development sites, and should have been adopted through a legislative process with CEQA review. Counsel presented multiple precedent projects they said had been reviewed under a different approach that applied maximum plan dimensions to individual towers.

Zoning Administrator Corey Teague said the interpretation was necessary to provide consistent administrative measurement standards. He and Planning staff said the plain language of Sections 102 and 270 treats maximum plan dimensions as applying to a building’s portions above the base height and that where code districts intend multiple towers they provide explicit tower-separation and objective criteria. Teague noted projects that do seek to exceed baseline massing may pursue formal exceptions or planning-commission review.

The hearing drew dozens of public commenters on both sides — from neighborhood opponents concerned about scale and character in the Sunset to housing-advocacy groups and development proponents emphasizing the need for new units. Commissioners focused their deliberation on whether the ZA’s action represented a reasonable interpretation of existing code or an unlawful change in policy; they concluded the interpretation supplied necessary clarity and set an administrative baseline while leaving open procedural paths for projects to seek exceptions or legislative changes.

The decision upholds the Zoning Administrator’s guidance on measuring bulk and directs parties seeking alternatives to pursue the code’s existing exception and discretionary review processes or legislative amendment.