Housing & Ballot Measures
Prop. 45 CEQA Ballot Measure Splits Bay Area Housing Advocates
Oakland Assemblymember Buffy Wicks and Eden Housing’s Linda Mandolini back the 365-day review and 270-day court shot clocks, while Greenbelt Alliance and Eastbay for Everyone warn of exurban sprawl.

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Proposition 45 on California’s Nov. 3, 2026 ballot—a statewide initiative to streamline reviews and litigation under the California Environmental Quality Act (CEQA) for housing and infrastructure—has split the Bay Area and statewide pro-housing movement over whether faster approvals should extend beyond urban infill to suburban and exurban projects, according to a San Jose Inside / CalMatters report published Tuesday, Oct. 27, 2026, by reporter Ben Christopher.
How Proposition 45’s 365-Day Review and 270-Day Court Clocks Work
Rather than exempting projects from environmental review outright, Proposition 45 narrows the scope of CEQA reviews for projects classified as “essential”—including all types of housing, roads, hospitals, schools, clean energy facilities, water systems, and broadband infrastructure—and requires public agencies to complete those reviews within 365 business days.
If a lawsuit is filed challenging an essential project under CEQA, Proposition 45 establishes a judicial shot clock giving judges 270 business days to resolve the litigation while making such challenges harder to sustain in court. The measure also applies timelines to subsequent permits issued later in the development process.
Oakland’s Buffy Wicks Supports Prop. 45 as Bay Area Groups Split Over Sprawl
While Oakland Democratic Assemblymember Buffy Wicks, the Housing Action Coalition, and major for-profit and nonprofit homebuilders support Proposition 45, traditional allies Eastbay for Everyone and the Greenbelt Alliance oppose the measure. Meanwhile, California YIMBY, YIMBY Action, SPUR, and Abundant Housing Los Angeles have all taken neutral positions.
“It’s been a weird campaign so far,” said Ali Sapirman, advocacy manager at the Housing Action Coalition. “The housing community has been a little bit fractured.”
In California YIMBY’s non-endorsement statement, Max Dubler wrote that “the central question here is how you feel about sprawl,” expressing concern that speeding up CEQA for all housing types—including subdivisions on the metropolitan fringe—would make it easier to build “car-dependent sprawl housing and the freeways and water infrastructure necessary to serve that sprawl.”
Jordan Grimes, legislative director for the Greenbelt Alliance, called Proposition 45 “a doubling down on essentially 75 years of land-use patterns that we know haven’t worked” and “a return to the sprawl era.” Grimes noted that Gov. Gavin Newsom last year signed Assembly Bill 130, a Wicks-authored law that took effect in July 2025 and exempted most urban infill housing on sites of 20 acres or less from CEQA. According to the state Office of Land Use and Climate Innovation, developers have already used AB 130 to entitle 17,913 housing units.
Wicks said she backs Proposition 45 because infill exemptions alone are not enough to resolve the state’s shortage. “I’m an ‘all of the above’ person when it comes to housing,” Wicks said. “I think we need housing of all different types, shapes, and sizes.” Mahdi Manji of the Inner City Law Center in Los Angeles’ Skid Row also endorsed the measure, noting that many low-income clients live in outer-ring communities such as Lancaster and Palmdale.
Eden Housing Cites Two-Year CEQA Lawsuit Over 130 Affordable Units in Livermore
Affordable housing developers argue that even infill projects remain vulnerable to costly CEQA lawsuits and that urban redevelopments larger than 20 acres are not covered by AB 130.
Linda Mandolini, president of Hayward-based affordable housing developer Eden Housing, pointed to a planned 130-unit affordable housing development that Eden Housing has sought to build on a former grocery store parking lot behind a row of downtown restaurants in Livermore since 2018. In 2021, a nonprofit funded by a group of Livermore residents sued the city under CEQA. A trial court ruled the challengers’ CEQA arguments were “almost utterly without merit,” an appellate court affirmed, and the California Supreme Court let the ruling stand—but the litigation still cost the project two years.
“The clock is endless and the number of people and entities who can challenge you are also endless,” Mandolini said. “Every year you lose in litigation is real money for real projects and another year that 130 families don’t get to live in that housing. It’s a great way to kill a project.”
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