Policy at the Terner Center for Housing Innovation at UC Berkeley, who served in the Obama Administration as the Assistant Secretary at the U.S. Department of Housing and Urban Development (HUD), stated that “It (CEQA) has been abused in this state for 30 years by people who use it when it has nothing to do with an environmental reason, ... NIMBY-ism is connected to the fact that for everyone who owns their little piece of the dream, there&apos;s no reason to want development next door to them, CEQA gives them a tool to effectuate their interest ... We need to fundamentally rethink how the CEQA process works in this state." CEQA has been used by residents in San Francisco and Los Angeles to attempt to block homeless shelters and affordable housing projects from being located in their neighborhoods. A 2015 study by Jennifer Hernandez and others at the environmental and land-use law firm Holland & Knight, looking at all CEQA lawsuits filed during the three-year period 2010-2012, found that less than 15% were filed by groups with prior records of environmental advocacy. (such as the Sierra Club) While environmental groups largely agree that building dense housing in urban areas ("infill development") is better for the environment than converting open space to new homes, 4 out of 5 CEQA lawsuits target infill development projects; only 20% of CEQA lawsuits target "greenfield" projects that would convert open space to housing. A report by the California Legislative Analyst's Office found that in the state's 10 largest cities, CEQA appeals delayed projects by an average of two and a half years. CEQA's requirement that automobile congestion be considered as an "environmental impact" that must be mitigated has resulted in the law both preventing the creation of bicycle lanes on already existing streets, as well as allowing lawsuits challenging new bike lanes both before and even after they have passed environmental review and been created. In one case, anti-abortion activists filed a CEQA lawsuit to try to block a new tenant (Planned Parenthood) from using an already constructed office building in South San Francisco. They cited the noise caused by their own protests as the environmental impact requiring mitigation. This lawsuit delayed the new tenancy by at least 18 months. Labor unions file CEQA lawsuits against projects to try to force them to pay prevailing wage. Governor Jerry Brown, in an interview with UCLA's Blueprint