there will be cases of cities resisting this by dragging their feet and it will be interesting to see. if a city wants to make it really expensive or dangerous to develop this opportunity then they certainly can. zoning is not the only consideration. and there are other things that elevate the cost of development like overbearing safety and accessibility regulations that are nation-wide. still, if this bill adds hundreds of thousands of units that will take a pretty meaningful bite out of the total shortage