Review of Proposed San Diego City Response to San Diego County Grand Jury Report Titled “Housing in San Diego County”
On May 9, 2023, the San Diego County Grand Jury filed a report, titled “Housing in San Diego County”. This report focuses on approaches for dealing with the lack of land and money to build housing. Three of the findings apply to the City of San Diego Office of the Independent Budget Analyst has prepared a response for the Land Use and Housing Committee Meeting on September 21, 2023.
This report examines the findings and responses in relation to the concerns of Normal Heights using a Smart Growth lens. The ten principles of Smart Growth, as outlined by the US EPA are:
In Finding 03, the Grand Jury report states that the City of San Diego did not meet housing allocations per Regional Housing Needs Assessment (RHNA) set by the California Department of Housing and Community Development for all income categories. The actual data paints a much worse picture where
Table 1: City of San Diego Fifth RHNA Cycle Allocation and Production Totals
| Income | Very Low | Low | Moderate | Above Moderate |
| Allocation | 21,977 | 16,703 | 15,462 | 33,954 |
| Produced | 3,797 | 3,715 | 37 | 41,208 |
| % of Need Met | 17.28% | 22.24% | 0.24% | 121.36% |
Chart 1: City of San Diego Fifth RHNA Cycle Allocation and Production Percentages
From the table and chart above it is pretty obvious where the priorities of the city and builders are: plenty of housing choices for the rich while the middle class has been completely ignored. The city’s response “the City received the greatest allocation and produced more total housing than any other jurisdiction in the region during the Fifth RHNA Cycle.” is a weak argument as San Diego accounts for half of all cities in San Diego County with RHNA shortfalls.
Chart 2: Populations of Count of San Diego Cities with RHNA Shortfalls
The city goes on to state that housing for very low-, low-, and moderate-income households were promoted with the creation of the Accessory Dwelling Unit (ADU) density bonus program and the Complete Communities Housing Solutions regulations. The ADU program only provides incentives when more than one ADU is built on a property. This limits the incentive to only projects that are packing a parcel with three or even 10 homes where only one existed previously.
More importantly, the affordable deed restriction allows for one additional ADU for every ADU set aside as affordable to very low income and low income households for a period of not less than 10 years, or as affordable to moderate income households for a period of not less than 15 years. It appears from the data that builders are opting for the shorter term of 10 years exacerbating the missing middle problem. Also problematic is that most ADUs are studios/one bedrooms. The missing middle needs homes for families (2-3 bedrooms).
Complete Communities on the other hand was designed to encourage development along transit corridors in alignment with Smart Growth principles. The big miss was allowing high floor area ratios (FAR) that would allow a mid-rise building to be composed entirely of studio and micro-units. To make matters worse, the city extended the areas where this program would apply by doubling the nationally recognized walking distance to a full mile. Now the Housing Action Package 2.0 is proposing increasing the maximum height to 9 stories and locating the affordable units off-site. Yes, you are reading that right, developers can get around providing affordable housing in their 9 story luxury towers by housing low-income residents several miles away.
Now that we know what the Housing Action Package 2.0 entails, it’s hard to believe the city could respond by saying “The Mayor’s proposed Housing Action Package 2.0 will […] also incentivize and promote new home opportunities in all communities that San Diegans of all income levels can afford.”