San Diego City Hall. Photo by Chris Stone

San Diego’s Planning Department, which works for the mayor, is going under the radar to rush through a dangerous land use change. Hiding under the innocuous name “Complete Communities Housing Solutions Initiative,” the scheme would radically and surreptitiously rezone large swaths of San Diego with minimal public participation and potentially reduce affordable housing opportunities in the City.

The premise of Complete Communities is that San Diego needs more housing. But what we really need is more affordable housing. Builders are generating lots of market-rate houses, but young people, first responders, teachers, and especially essential workers are being left behind.

The proposal, built on the department’s false assumption, permits developers to up-zone land permitted for multi-family units — that is, land where five or more homes could be built — and adjacent to a street with a trolley or frequent bus line (called transit priority areas, or TPAs). This up-zoning would permit buildings with four to eight times the square footage of the lot (technically called a floor area ratio, or FAR). While FARs of four are typical for communities north of Interstate 8, FARs of eight — downtown-type densities outside of downtown — are found in neighborhoods south of I-8, where most low-income/minority areas are located.

TPAs could be anywhere there is an existing or proposed trolley line, such as Clairemont or communities where the Orange Line runs.  But they could also happen along existing and proposed bus lines. For example, this up-zoning could happen on El Cajon Boulevard and University Avenue, and on their side streets.  Since the City Council has repealed the requirement for multi-family units in TPAs to have off-street parking, the future for these communities could be walls of high- and mid-rise buildings with cars driving around in search of parking.

How would it happen? If Complete Communities passes, a developer in a TPA would simply go down to city hall and present the building plans. Approval is granted at the counter, regardless of the size of the project, in what is called Process One. The community would not be able to weigh-in on the proposal, there would be no hearing at the Planning Commission, and the neighbors would find out about the high-rise project when the bulldozers show up. In fact, not even the City Council could vote on the project. It would be all up to what the developer wanted to do, with no public accountability.

What would we receive in return? Two things. First, Complete Communities calls for a “public amenity” fee of $9 per square foot of the lot size or, for larger projects, the construction of a public promenade in front of the building. This is a good, primarily because it would be applied in areas where there are huge parks deficits. But it raises the question of why the Planning Department would put the highest FARs exactly in areas with the greatest existing public facilities shortfalls.

Affordable housing benefits, on the other hand, while promoted by the Planning Department, are limited and possibly counterproductive. The department says that 10% of the building would be affordable to those making up to 60% of the area medium income — which is already required by law — and another 10% for those earning up to 120% of the area medium income – which is close to market-rate housing.

The sneaky part of the program is what is meant by 10%. Let us assume a developer uses a TPA to increase density from 10 units allowed under existing zoning to 100 units.  How many low-income affordable units would be required?  The answer is only ONE, because the 10% is based on the density allowed under the prior zoning, not on the up-zoning the developer can get at his or her whim.

But it gets worse than that. There are already parts of San Diego, primarily south of I-8, where there are multi-family units that are already affordable to very low-income households, primarily because these houses are older and smaller (they are not subsidized).  Under Complete Communities, developers are incentivized to buy these properties, scrap the housing, and build medium- to high-rise dwellings. Only a small percentage of these units would be required to be affordable. The process is called gentrification.

The Planning Department is pushing to have the City Council pass its Complete Communities scheme by the end of July. It is up to you to contact your Councilmember and say SLOW DOWN! Take time to think this through, and do not pass something that does more harm than good.

Howard Wayne represented San Diego in the California Assembly and is the Interim Chair of the Linda Vista Planning Group.

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