Symbolic upzoning as fake compliance

Local governments can meet the letter of state mandates by rezoning places that are practically immobile (golf courses, parks, single‑owner parcels), producing legal compliance on paper but no real housing. These moves are deliberate political strategies that preserve existing land uses while deflecting state pressure and optics. — If widespread, symbolic upzoning will hollow out state housing goals, making legislative mandates ineffective and shifting battles from policy design to permit‑level enforcement.