Testimony to the California State Assembly Committee on Housing and Community Development

Deputy Director of Policy David Garcia testified to the California State Assembly Committee on Housing and Community Development on Wednesday, February 25, 2026.

Watch the recording video (testimony starts at 01:03:53)

Good morning, Chair Haney and Member Wicks. Thank you for the opportunity to join today’s hearing. My name is David Garcia, and I am the Deputy Director of Policy at UC Berkeley’s Terner Center for Housing Innovation. 

Today I will be presenting the Center’s preliminary analysis of AB 2011’s impact to date, as well as summarizing some of the research we have published regarding the potential of converting commercially zoned land to residential. 

Ostensibly, AB 2011 was passed in hopes of getting more homes built on land that is currently zoned for commercial or retail uses. About five years ago, the Terner Center published an analysis of how common such conversions have been in California in recent years. We found that such conversions were somewhat rare between 2014 and 2019, a period of time when the state’s residential real estate market was actually relatively strong. 

Specifically, In the state’s four major metro regions, less than 1 percent of all commercially zoned parcels were converted to residential use between 2014 and 2019, yielding just over 38,000 estimated new housing units. Most of those conversions happened in Los Angeles, which has strong policies supporting the conversion of existing buildings and commercial land to housing. But even in the Los Angeles region, commercial-to-residential conversions made up just 13 percent of overall residential development during the five-year analysis period. 

The report concludes with recommendations that, in order to meet broader statewide housing goals, the legislature should consider the creation of a statewide standard for what can be built on commercial land. This recommendation was reflected in the development of AB 2011. 

But what do we know about the success of AB 2011 so far? 

Unfortunately, we don’t yet have a full picture of how impactful AB 2011 has been, since the law has only been in effect since July 2023. As we know, it takes time for the market to adjust to new policies and other external factors, such as construction costs and interest rates, which make it difficult to construct any new housing, regardless of regulatory changes. 

That said, we do have some data and anecdotal evidence that shed light on where AB 2011 has been invoked since its passage. And what they show so far is that uptake has been modest. 

Our biggest source of information comes from data in Annual Progress Reports, or APRs, which detail development patterns at the local level. These reports are completed annually by each jurisdiction across the state and include a field for local planners to denote when a housing project has been applied for, approved, and permitted using AB 2011.

Through an analysis of APR data, as well as a scan of AB 2011 activity in local media and city documents, we have found that roughly 5,800 new homes have been either applied for, entitled, or permitted using AB 2011. Of this activity, a little over half has been specifically for affordable housing. And as you can see, the activity so far has been relatively scattershot throughout the state, with most development happening in San Francisco and Los Angeles. 

One important caveat is that we only have state APR data through 2024, so we are likely missing most AB 2011 projects that would have been applied for in 2025. I should also note that APR data can be flawed or incomplete. Local planners may incorrectly note when AB 2011 is used, or omit information on AB 2011 activity entirely. And there are cases where projects may be double-counted when, for example, a developer resubmits a project with a new design. 

To ensure that we were getting the best possible look at AB 2011 usage, we checked AB 2011 activity in the APRs to ensure that reported projects were eligible and not being double-counted in some way. Moreover, to supplement what we observed in the APR data, we also examined media reports of AB 2011 usage and mentions of AB 2011 in city documents. 

While the uptake appears modest according to the data, AB 2011 is still a relatively new law. It takes time for legislation to impact the market, and just because developers are not invoking AB 2011 in large numbers yet, that does not mean that the law will not be important moving forward. And there are likely positive impacts from the law that we cannot ascertain from APR data, such as cities that have updated their zoning or created their own local programs that mirror AB 2011 in intent.

AB 2011 created a statewide baseline for what can be built on commercially zoned land throughout California. While the results so far are limited, it’s too early to determine the true impact of this new law just yet, especially as developers deal with uncertain economic conditions. 

Thank you again for the opportunity to contribute to today’s conversation, and I look forward to the discussion.