SB10 Position Statement

This letter is posted here for public comment before sending on 7/28/2023.

Normal Heights Planning Group
San Diego, CA 92116
626 390-4190

City of San Diego City Hall
202 C Street
San Diego, CA 92101

Dear Mayor and City Councilmembers:

We strongly oppose San Diego’s proposed implementation of Senate Bill 10 as currently written and urge you to remove it from the Housing Action Package 2.0.

SB 10 would allow 10-unit buildings up to three stories tall on single-family parcels a full mile (and sometimes more) away from existing or future transit stops. It exceeds the density of most of San Diego’s apartment zoning. Even tiny lots of just 1000 sf are eligible for SB 10.

SB 10 violates San Diego’s Climate Action Plan, including its Mobility Mode Shift goals, by encouraging dense development far away from transit. Numerous federal, state, local, and academic studies have shown that few people will use transit if they have to walk more than one-half mile to a bus or trolley.

SB 10’s reduced setbacks will reduce permeable land and increase run-off. Mature trees will be clear-cut and landscaping will never be replaced given the minimal open area left by these setbacks. Our city has many other zoning codes in place that allow dense residential development that is more respectful of San Diego’s environment and Climate Action goals.

SB 10’s market incentives to turn for-sale homes into multi-unit rentals will reduce San Diego’s inventory of for-sale homes and drive up the prices of remaining single-family homes, depriving San Diegans of access to starter homes and family home equity. Housing units constructed under SB10 can and will remain rental units forever.

SB 10 would allow massive block structures that are out of scale with surrounding buildings, with building volumes (FARs) that are 6 times larger than what is allowed on a typical single-family zoned lot. By contrast, existing programs such as Bonus ADUs and SB 9 are constrained by the Floor Area Ratio (FAR) of RS zoning.

This kind of density will overwhelm our over-burdened infrastructure. The lower water pressure and additional vehicles parked on the streets will impede fire response in high-risk areas,

increasing the likelihood that fires will spread rapidly. SB 10’s exclusion of very high fire risk areas is no exclusion at all, as all it does is require that buildings be built to current fire code.

This is not about providing housing for more San Diegans. Neighbors For A Better San Diego estimates that San Diego already has the allowed capacity to build over 2 million homes — 19 times what is required for our housing goals (RHNA). The City needs to explain why this overcapacity has failed to spur sufficient development before introducing new housing programs that can’t be reversed, undermine climate action, and put homeownership further out of reach for most San Diego residents.

Perhaps most importantly, once SB 10 is implemented, it cannot be undone easily, if at all. This is reckless and irresponsible for future generations.

For these reasons, please reject the Mayor’s effort to implement SB 10. Our city deserves a sustainable, walkable, community-driven approach to housing. SB 10 is a poorly conceived barrier to those laudable goals.

We could support a measure such as this if the geographic scope were to be limited to major corridors, as suggested by some planning commissioners during their June 1 HAP 2.0 meeting, and scaled in proportion with those corridors, where there is existing infrastructure to support an increase in density. In our neighborhood of Normal Heights specifically, we would welcome implementation of a similar measure along the El Cajon Boulevard and Adams Avenue corridors to encourage more residential mixed-use development along these corridors, as envisioned in the Mid-City community plan.

Thank you for your attention to this important matter.

Paul Coogan
Normal Heights Community Planning Group

Cc: Assembly Member Chris Ward

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