Executive Summary
The subject is a 21.95-acre vacant hillside parcel at the southwest corner of Bayshore Blvd and Main St in Brisbane, immediately south of the San Francisco city line and directly across Bayshore Blvd from the 660-acre Brisbane Baylands. It is the larger of the two parcels that make up the City's Guadalupe Hills General Plan subarea, and Brisbane's planning documents have referred to it for decades as the "Levinson" site. It is zoned PD (Planned Development District) and carries a General Plan designation of Planned Development, Subregional Commercial/Retail/Office, which requires a Specific Plan and an environmental impact report before any development. The parcel sits inside the San Bruno Mountain Habitat Conservation Plan boundary, the same framework under which the neighboring Northeast Ridge was entitled and built out with 499 homes between the 1990s and 2015.
Two things make this the right moment to value the site. First, on July 1, 2026 the State rescinded Brisbane's housing element certification because the City missed its May 18, 2026 deadline to rezone the Baylands, which puts Brisbane under the Builder's Remedy until the Baylands Specific Plan is adopted and the housing element is recertified; City Council hearings began September 3, 2026, so the window is measured in months. Second, the northern San Mateo County for-sale market has just reset its comps: Toll Brothers opened Crestmoor Estates in San Bruno on August 26, 2026 at roughly $2.1 million and up on a 40-acre site that traded for $86.55 million in February 2025, and KB Home opened Point Martin townhomes in Daly City in January 2026 from $1.31 million. This opinion values the property as raw, unentitled land today, shows how each entitlement path changes the number, and is preliminary pending a title report, a biological survey, and closed-sale verification through CoStar.
Subject Property
The parcel is the lower slope of San Bruno Mountain's northeast flank. It climbs west from Bayshore Blvd toward PG&E's transmission corridor on its western edge, with the steepest ground in the upper southwest portion. The City's General Plan describes a wetland marsh at the northern end of the subarea (the Levinson Marsh, a detention basin the City rebuilt in the late 1990s), soils along the north edge affected by PG&E's former gasification plant to the north and subject to Department of Toxic Substances Control oversight, San Francisco Water Department lines crossing the subarea, slopes with a high erosion rate and moderate-to-high seismic landslide risk, and traffic noise of CNEL 65 dB or more within 300 feet of Bayshore Blvd. Access and utility infrastructure are described as limited. These are the items a buyer's due diligence will price, and they are the reason the General Plan routes this subarea through a Specific Plan rather than by-right zoning.
Zoning & General Plan Framework
Brisbane's General Plan carved the Guadalupe Hills out of the Northwest Bayshore subarea in 2018 to reflect its different character: two large vacant lots (the roughly 22-acre Levinson site, which is the subject, and the roughly 11-acre Peking Handcraft site) separate from the PG&E substation to the north. The designation is Planned Development, Subregional Commercial/Retail/Office. Under that designation retail, service, office and public uses are the primary uses, and residential, research and development, light industrial, and commercial recreation may be permitted conditionally in the implementing zoning. The zoning is PD, which the Housing Element describes simply as "subject to Specific Plan and PD Permit approval." No residential density has been set; the standard is written per Specific Plan.
General Plan standards, Guadalupe Hills subarea
| Standard | Requirement | Source |
|---|---|---|
| Entitlement path | One or more Specific Plans with CEQA documents (negative declaration, mitigated negative declaration, or EIR) prior to any development | Policy GH.1 |
| Intensity | 2.8 FAR per Specific Plan (commercial); no residential density stated | Land Use Table 1 |
| Open space | Minimum 25% of the land area dedicated to open space | Policy GH.4(c); PD designation |
| Habitat | Preserve habitat per the San Bruno Mountain Habitat Conservation Plan; study the upland slope, marsh-to-Bay hydrology and a habitat migration corridor with any development on the Levinson property | Policies GH.11, GH.13 |
| Form | Greenbelt separation from Daly City; visual impact analysis of building heights and view corridors; terrace with the slope, minimize grading and exposed retaining walls | Policies GH.2, GH.3, GH.5 |
| Residential | "Consider the concept of live-work residential development" | Policy GH.6 |
| Access | Investigate shared access and streets between the two parcels to minimize grading and the number of entrances from Bayshore Blvd | Policy GH.7 |
| Hazards | Avoid structures under or near transmission lines; remediate per DTSC and Regional Water Board approvals; consider noise insulation | Policies GH.15 to GH.17 |
The Northeast Ridge precedent
The slope directly south of the subject was entitled the same way. Southwest Diversified received Planned Development approval for 579 units in 1989; after the Callippe silverspot butterfly was listed the plan was reduced to 499 units (125 detached homes, 160 townhomes and 214 stacked flats) on about 92 developed acres of a 237-acre holding, with the balance dedicated as conserved habitat. The General Plan records its densities as 5 units per acre (Landmark), 10 (Viewpoint) and 15 (Altamar). Build-out ran from the 1990s to 2015. That is the template a Specific Plan for the subject would follow: cluster the homes on the lower slope, dedicate the upper slope, and mitigate under the HCP.
The Builder's Remedy Window
Brisbane adopted its 2023-2031 Housing Element on May 18, 2023 and was one of the first Bay Area cities certified by the California Department of Housing and Community Development (HCD). The element put almost all of the City's 1,588-unit allocation on the Baylands (1,800 units) and committed the City to adopt a Baylands Specific Plan within three years. The subject is not in the housing sites inventory. The City missed the May 18, 2026 rezoning deadline, and on July 1, 2026 HCD rescinded its finding of compliance. In the City's own words, while decertified Brisbane "is now subject to the Builder's Remedy," which allows housing projects that do not conform to local zoning to be proposed and potentially approved.
| Item | Status |
|---|---|
| Housing element certified | May 25, 2023 (adopted May 18, 2023) |
| Statutory rezoning deadline (Baylands) | May 18, 2026, missed |
| HCD rescission of compliance finding | July 1, 2026 |
| Baylands Specific Plan hearings | Planning Commission June 25, June 30, July 23 and August 13, 2026; City Council from September 3, 2026, with additional dates through the fall |
| Recertification | HCD has indicated an expedited review once the Specific Plan and rezoning are adopted, within its statutory 60-day window |
| What vests the remedy | An SB 330 preliminary application filed while the element is out of compliance; noncompliance is locked in as of that filing date |
What a Builder's Remedy project could look like here (AB 1893 rules, effective January 1, 2025)
| Rule | Application to the subject |
|---|---|
| Affordability | At least 13% of units for lower-income households, or 10% very-low-income, or 100% moderate-income |
| Density cap | The greatest of: 50% above the "default" lower-income density (20 units per acre for a suburban jurisdiction such as Brisbane, so 30 units per acre); three times the density allowed by the General Plan or zoning (none is set here); or the housing element density for the site (not an inventory site). The 35 units-per-acre transit add-on requires a major transit stop within half a mile; Bayshore Caltrain is about 0.85 mile away, so it likely does not apply. |
| Site eligibility | The General Plan designation allows retail and office, which qualifies. The site must also clear the SB 35 site-exclusion list: no wetlands, no habitat for protected species, no very high fire hazard zone unless mitigated, no unresolved hazardous-materials site. On this parcel that means the developable footprint is the portion a biological survey shows is outside butterfly habitat and the marsh, which is why the survey is the first dollar a buyer or ownership should spend. |
| CEQA | AB 130 (2025) exempts infill housing on sites of up to 20 acres from CEQA, but only 5 acres for a Builder's Remedy project, and the subject is 21.95 acres. A project on a defined portion of the parcel should be evaluated by counsel; otherwise the Housing Accountability Act process with CEQA applies. |
| Illustrative program | 30 units per acre on a 10-acre developable footprint is about 300 units; 13% lower-income is about 39 affordable units. Whether that footprint exists is the survey question above. |
Development Pathways
Four ways a buyer can underwrite the site. Unit counts assume a developable footprint of roughly 8 to 11 acres on the lower and mid slope, with the balance in open space and conserved habitat, and are planning-level estimates until a biological survey and slope analysis fix the footprint.
- The Northeast Ridge model: 10 to 15 units per acre on the buildable slope, upper slope dedicated under the HCP, 25% open space.
- Specific Plan, EIR, PD Permit, HCP compliance and a tract map; three to five years of entitlement.
- Exit is the Crestmoor Estates and Point Martin buyer at $1.3M to $2.1M+ per home.
- AB 1893 density of 30 units per acre on the eligible footprint, 13% lower-income set-aside, Housing Accountability Act processing.
- Preliminary application must be on file before HCD recertifies Brisbane, likely late 2026 or early 2027.
- Site exclusions (habitat, wetlands, fire zone) shape the footprint; the survey decides whether this pathway is real.
- The designation as written: subregional retail, office, R&D, commercial recreation, with live-work residential encouraged by Policy GH.6.
- Peninsula office and life-science land demand is at a cycle low in 2026; the Clearview campus in San Mateo just sold to be converted to homes.
- Useful as a fallback use and as leverage in the Specific Plan negotiation, not as the pricing basis.
- San Bruno Mountain Watch has named the Levinson property among the undeveloped lands it wants protected; the City, County Parks and the State Coastal Conservancy have bought Brisbane Acres habitat lots since 1998.
- Conservation buyers pay appraised fair market value for habitat land, historically a small fraction of development land value per acre.
- Best used as the exit for the upper slope inside Pathway A or B, or as HCP mitigation credit, rather than for the whole parcel.
Development-Land Comp Analysis
Large residential development sites rarely trade in northern San Mateo County, so the set below reaches from Daly City to San Mateo and includes the two active listings on Bayshore Blvd in Brisbane. Closed prices come from public announcements by the seller or buyer (the San Mateo Union High School District for Crestmoor, Harvest Properties and Stockbridge for Clearview, the County of San Mateo for Eastmoor) and should be confirmed against the recorder before this goes to a client. Per-acre and per-unit figures are computed from those prices.
Closed sales numbered in navy, active listings lettered in blue, subject in orange. Comp 2 (Clearview, San Mateo) is 12 miles south of the frame.
Closed Land Sales, 2025
| # | Property / Status | Site Area | Entitlement at Sale | Price | $/SF Land $/Acre | Per Unit |
|---|---|---|---|---|---|---|
| 1 | 300 Piedmont Ave, San Bruno (Crestmoor)Closed Feb 6, 2025 | 40.0 ac 1,742,400 SF | Entitled, 155 homes | $86,552,000 | $49.67 $2,163,800 | $558,400 per lot |
| Notes:Former Crestmoor High School site sold by the San Mateo Union High School District to SummerHill Homes after SummerHill secured City approval for 155 single-family homes; SummerHill then sold to Toll Brothers, which opened Crestmoor Estates on August 26, 2026 from about $2.1 million. Flat, graded school site outside the HCP. The entitled ceiling for the set. | ||||||
| 2 | 3000-3155 Clearview Way, San Mateo (Clearview Business Park)Closed Sep 2025 | 22.0 ac 958,320 SF | Unentitled (office in place) | $102,000,000 | $106 $4,636,400 | $453,300 per planned unit |
| Notes:22-acre hilltop office campus (379,615 SF, six buildings, partially leased to GoPro) bought off-market by Harvest Properties and Stockbridge from Goldman Sachs Asset Management to re-entitle as up to 225 for-sale townhomes and single-family homes with 15% affordable. Price supported by in-place office income; unentitled for housing. Same acreage as the subject. | ||||||
| 3 | 493 Eastmoor Ave, Daly CityClosed Dec 2025 | 0.37 ac 16,117 SF | Unentitled, affordable program | $4,440,000 | $275 $12,000,000 | $61,700 per unit |
| Notes:County of San Mateo purchase of a 0.37-acre infill lot for a 72-unit, 100% affordable project with The Core Companies. Public buyer, small urban site; shown for its per-door land budget, not as a size comp. | ||||||
Active Competing Listings
| # | Property / Status | Site Area | Entitlement | List Price | $/SF Land $/Acre | Per Unit |
|---|---|---|---|---|---|---|
| A | 239 Serramonte Blvd, Daly CityListed Mar 27, 2026 | 6.24 ac 271,814 SF | Entitled, 499 units | $68,000,000 | $250 $10,897,400 | $136,300 per unit |
| Notes:Fully entitled 499-unit (plus one manager's unit) four-building high-rise site adjacent to Serramonte Center, marketed for rental, condominium or hybrid; AGH Realty Group. The entitled multifamily ceiling in northern San Mateo County. | ||||||
| B | 3100 Bayshore Blvd, Brisbane (adjoining)Listed since 2018 | 9.36 ac 407,722 SF | Unentitled, M-1 | Undisclosed | n/a n/a | n/a |
| Notes:APN 005-141-100, 9.36 acres zoned M-1, the other Guadalupe Hills parcel; marketed by Kidder Mathews for office development since January 2018 with no disclosed price and no sale. Eight years on the market is the clearest signal of what unentitled commercial land on this slope is worth. | ||||||
| C | Bayshore Blvd, Brisbane (four R-1 lots)Listed 2021, unsold | 4.30 ac 187,308 SF | R-1 hillside, unentitled | $3,200,000 (combined ask) | $17.08 $744,200 | n/a |
| Notes:APNs 007-250-010, 007-350-130, 007-350-140 and 007-350-160, 4.3 hillside acres in the Southwest Bayshore area with Bay views, listed October 2021 at a combined $3,200,000 across the four lots; no longer advertised and no recorded sale found. Buyer was told to verify permitted uses with the City. | ||||||
| D | 3750-3780 Bayshore Blvd, BrisbaneActive | 2.0 ac 87,120 SF | PD, 30 condos approved (2005) | Price on request | n/a n/a | n/a |
| Notes:2.0 acres per the listing (2.9 acres per the City), PD-zoned, with a 30-unit residential condominium approval granted in 2005 that has sat in permit review since; Norcal Realty, price upon request. | ||||||
Sources: San Mateo Union High School District and San Mateo Daily Journal (Crestmoor, February 2025); The Registry, The Real Deal and REBusinessOnline (Clearview, September 2025); Hoodline and County of San Mateo (Eastmoor, December 2025); LoopNet listings for 239 Serramonte Blvd, 3100 Bayshore Blvd, 3750-3780 Bayshore Blvd and the Bayshore Blvd R-1 lots, checked September 11, 2026. Not shown as comps: the Brisbane Baylands (2,200 units in the pending Specific Plan, not for sale), the Pacifica Quarry (86 acres, Builder's Remedy application for 1,225 units, purchase price not public) and Serramonte Del Rey in Daly City (1,235 units on school-district ground lease).
What conservation buyers pay
In April 2008 the State Coastal Conservancy authorized up to $242,500 toward the City of Brisbane's purchase of five Brisbane Acres parcels totaling 6.4 acres of Mission Blue and Callippe habitat on the upper slope of San Bruno Mountain, matched by City and federal funds, at appraised fair market value. Even allowing for the match and eighteen years of appreciation, habitat land on this mountain has traded at a small fraction of the development-land figures above. That is the floor for the subject's upper slope, and it is why the developable footprint, not the gross acreage, carries the value.
Finished-Product Values: What the Homes Would Sell For
Pathway A's exit is a for-sale home on a Brisbane hillside. Two new communities opened in the last eight months within five miles of the subject and set the new-construction bar; Brisbane's own resale market, including the Northeast Ridge homes on the same slope, sets the resale band. Resales below are MLS closings reported by Movoto, checked September 11, 2026; each address links to its Zillow page, and each community name links to its Zillow community page.
New construction, opened 2026
| Community | Product | Size | Pricing | $/SF (approx.) |
|---|---|---|---|---|
| Crestmoor EstatesToll Brothers, San Bruno · opened Aug 26, 2026 · Montara Collection on Zillow | 155 detached homes, 4 bd / 3 ba, 2-car garage, two collections | 2,300 to 2,800 SF | From about $2,100,000 | $750 to $910 |
| Point MartinKB Home, Daly City (Carter St & Saddleback Dr) · opened Jan 30, 2026 · 132 homes | Three-story townhomes, up to 4 bd / 4 ba | 1,835 to 1,994 SF | $1,311,990 to $1,383,990 | $694 to $715 |
Brisbane resales, closed May to August 2026
| Address | Area | Bd / Ba | SF | Sale Price | $/SF | Closed |
|---|---|---|---|---|---|---|
| 150 Elderberry Ln | Northeast Ridge | 5 / 4 | 3,440 | $2,600,000 | $756 | Aug 21, 2026 |
| 146 Elderberry Ln | Northeast Ridge | 3 / 2.5 | 2,127 | $1,960,000 | $922 | Jul 13, 2026 |
| 285 Humboldt Rd | Central Brisbane | 3 / 3.5 | 2,417 | $1,757,500 | $727 | Aug 12, 2026 |
| 480 Klamath St | Central Brisbane | 3 / 2 | 2,211 | $1,575,000 | $713 | Aug 10, 2026 |
| 153 Golden Eagle Ln | Northeast Ridge | 3 / 3 | 2,273 | $1,300,000 | $572 | May 29, 2026 |
| 141 Kestrel Ct | Northeast Ridge | 2 / 2 | 1,413 | $938,888 | $665 | May 20, 2026 |
| 633 Swallowtail Ct | Northeast Ridge | 3 / 2 | 1,550 | $815,000 | $526 | Jul 27, 2026 |
| 332 Crescent Ct | Northeast Ridge | 2 / 2 | 1,242 | $785,000 | $632 | May 12, 2026 |
Key Takeaways
Twenty-two contiguous acres, one parcel, one owner, on a boulevard, eight miles from downtown San Francisco, inside a city that has entitled exactly this kind of hillside community before. The only other site of this scale on the Peninsula that traded in the last two years (Clearview, 22 acres) went for $102 million with office income attached.
Habitat, the marsh, the transmission corridor, slope and the 25% open-space minimum mean that roughly 8 to 11 acres of the 21.95 will carry the homes. Every buyer will price the parcel on that footprint. A biological survey and a slope study, at low cost, turn a guess into a number and are the first items for the data room.
Crestmoor cleared at $558,400 per entitled lot on flat ground. Raw hillside land that still needs a Specific Plan, an EIR and HCP clearance is worth a fraction of that per lot today. The gap between the two is the value ownership or a land entitler can create over three to five years, and it is the reason the buyer pool for this site is builders and entitlers rather than end users.
Brisbane is decertified today and will likely be recertified within months of adopting the Baylands plan this fall. A preliminary application filed before that date vests the Builder's Remedy on this parcel; nothing filed after it does. Filing costs little and adds a second buyer pool that underwrites per door rather than per lot.
The adjoining 9.36-acre M-1 parcel has been marketed for office use since 2018 without a sale, and 4.3 acres of R-1 hillside lots on Bayshore Blvd have sat since 2021 at $744,000 per acre. Unentitled land on this slope does not sell on a per-acre ask; it sells on a program. Pricing the subject on its program, not its acreage, is what separates it from those listings.
Toll Brothers and KB Home both opened new communities within five miles in 2026, and Brisbane's own resales on the Northeast Ridge are clearing at $750 to $920 per SF for detached homes. A builder does not have to imagine the end buyer for this site; the end buyer is already writing contracts a few miles away.
Pricing Recommendation
Basis of the recommendation. The opinion is built on Pathway A, a 100 to 150 home Specific Plan community, valued from the finished-home comps back to the land and then discounted for the entitlement that has not happened yet. A detached home of about 2,400 SF sells today for $1.9M to $2.1M on the Northeast Ridge and at Crestmoor Estates. Toll Brothers' Crestmoor purchase implies roughly $1.4M per home of all-in cost excluding land on a flat site; a hillside site with HCP mitigation, retaining structures, off-site drainage and Bayshore Blvd improvements runs closer to $1.5M. At a 15% builder margin on a $2.0M home that leaves about $200,000 per lot for entitled land, or $20M to $25M for 100 to 125 lots, which is the "if carried to approval" figure above. Discounting that number for three to five years of Specific Plan, EIR and HCP process, the soft cost of getting there, and the real possibility that the surveyed footprint supports fewer lots, produces the $10.5M to $12.5M as-is range: 45% to 55% of entitled value, which is where raw land with a multi-year entitlement path has traded against finished lots in this cycle.
Cross-checks. On a per-gross-acre basis the range is $478,000 to $569,000, below the $744,000 per acre at which the unsold Bayshore Blvd R-1 lots have been offered since 2021, which is appropriate for a site whose upper slope is habitat. On a per-door basis, a 300-unit Builder's Remedy program prices the range at $35,000 to $42,000 per door, well inside the $61,700 per door the County paid for affordable land in Daly City and a fraction of the $136,300 per entitled door asked at Serramonte, so a rental or attainable-housing developer can reach the same number from a different direction. On a per-SF basis, $11 to $13 per SF of land is one-quarter of Crestmoor's $49.67 entitled and one-tenth of Clearview's $106 with income in place.
Suggested list price. $12,950,000, which is about 4% above the top of the opinion range and leaves room for the two buyer pools to compete. The list price should go out with, at minimum, a biological survey, a slope and constraints map, the DTSC file for the north edge, and a filed Builder's Remedy preliminary application. Each of those items moves the offering from "22 acres of hillside" to "a program on a footprint," and each is cheap relative to the spread it protects.
What would change the number. Up: a survey that shows 12 or more developable acres; a vested preliminary application at 30 units per acre; confirmation that the parcel is outside the Very High Fire Hazard Severity Zone; or a Baylands approval that brings a Bayshore Blvd streetscape and infrastructure to the frontage. Down: a surveyed footprint under 8 acres; a VHFHSZ designation covering the buildable slope; an unresolved DTSC condition on the north edge; or a City position that residential is not a conditional use the Specific Plan will entertain. The last item is the one to test with the Community Development Department before launch.
This opinion is preliminary. It has not been verified against recorded deeds, a title report, a biological survey, a geotechnical report or a fire-hazard map, and the closed sales should be confirmed through CoStar and the San Mateo County Recorder before the document is shared with a client. It is not an appraisal.
The Listing Team
This assignment is presented by The LAAA Team and The Ziegler Group, both of Marcus & Millichap's Encino office.
filip.niculete@marcusmillichap.com
CA DRE #01905352
matt.ziegler@marcusmillichap.com
CA DRE #01280909
glen.scher@marcusmillichap.com
CA DRE #01962976
The LAAA Team · Marcus & Millichap · 16830 Ventura Blvd, Suite 100, Encino, CA 91436 · www.laaa.com
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