The Radio Towers in Emerald Hills — Another Chapter in the Stacking of the Deck

Thursday, November 20th, at 9am, the San Diego Planning Commission will hold hearing on the “Radio Towers” of Emerald Hills

By Rob Campbell 

This Thursday, November 20th, at 9am, at 7650 Mission Valley Road, San Diego, the San Diego Planning Commission will hear agenda item #2. This agenda item concerns what some call the “Radio Towers” of Emerald Hills.

In the historically Black enclave of the neighborhood of Emerald Hills in San Diego, the latest development upheaval lays bare how old injustices don’t die. They merely get repackaged in the language of progress.  What was once a promise of expanding parkland for a neighborhood long denied environmental justice or infrastructure, the last and largest green space is now being transmuted into a windfall for a for-profit multibillion-dollar corporation, with the full complicity of the City of San Diego and its planning apparatus.

The project in question — what locals call the “Radio Towers” — is a parcel on Old Memory Lane, formerly earmarked for new parkland in Emerald Hills, a “destination” park offering sweeping downtown and ocean views.  It is now slated instead to host 130 private homes with a single entrance and exit with an up-zoning at roughly 400% the density allowed in the same zoning white-neighborhood just to the north in La Jolla.

Here’s the brutal arithmetic of injustice:

• Residents of Chollas Valley, including Emerald Hills and Encanto, San Diego discover a zoning footnote, Footnote 7.  It was inserted under cover of COVID-era chaos that shrinks minimum lot size from 20,000 sq ft to 5,000 sq ft but only in historically redlined Black and Latino neighborhoods like Emerald Hills and Encanto. (KPBS)
• Footnote 7 enables dense, market-rate housing in low-resource areas, a de facto reverse redlining, while wealthier, whiter areas maintain large lot sizes and fewer houses per parcel unaffected by Footnote 7.  (SD Voice and Viewpoint)
• On one lot in Emerald Hills, a developer is now being allowed to build “120 homes where zoning would only allow 70 anywhere else in the city.” (KPBS)
• The city itself acknowledges the way this footnote slipped in was in their words, “not best practice” and that it lacked transparent community engagement. (KPBS)
• A vital parcel of land that should have been a publicly-accessible park, especially in a neighborhood long starved of park space and environmental infrastructure is being swallowed by private housing.

The result: the same patterns of disinvestment, environmental burden, and exclusion that characterized redlining are being re-authorized under the guise of solving a housing crisis. The playbook is cynical: promise “density” in neighborhoods already overloaded with pollution, traffic, lack of parkland and environmental amenities, while preserving open space and low-density living for wealthier, whiter parts of the city.

A New Legacy of Environmental Injustice

Emerald Hills is not an incidental case.  It sits within the broader Southeast San Diego region, south of 94, a historically redlined zone with disproportionate environmental burdens.  The zoning changes now being leveraged point directly to environmental justice failures:

• Denial of parkland expansion. Rather than completing the promise of a new celebrated park (downtown view, open space, tourist and neighborhood destination), the land is being rezoned for housing instead of recreation.
• Increased density without infrastructure.  The roads servicing this land were never designed for 100+ additional homes crawling into what remains a hilly, narrow terrain on 60th street.  Traffic calming?  Absent.  Civic amenities?  Missing.  It’s a private HOA with single ingress and egress.
• Lack of meaningful community consent.  The residents in Emerald Hills and neighboring Encanto, demanded investigation into the footnote and the zoning changes.  Any public engagement has resulted in vehement opposition to the molestation of this land.  (Times of San Diego)
• The city’s own “Park DIF” funding map acknowledges Southeast neighborhoods are “park-deficient communities and in a Community of Concern.” (Inside San Diego)

A neighborhood suffering from decades of divestment, denied the basic amenities of parkland, is now asked to absorb a high-density development that would never be pitched in other parts of San Diego.  In fact, a similar size lot in La Jolla, Foxhill conceded that they will now add 13 additional homes to the 5 mansions planned for a total of 18 where Emerald Hills will be expected to absorb 130! (San Diego Union Tribune)

By approving such up-zoning under Footnote 7, and then allowing the project to be applied retroactively while driving the footnote out only afterwards, the city has locked in growth patterns that exploit our low-resource, largely minority neighborhoods.

The Klauber Project: Prototype of the Pattern

The drama unfolding at 1362 Klauber Avenue in nearby Encanto lays bare the mechanics of how the land-grab proceeds:

• Residents discovered Footnote 7 while appealing the Klauber housing project.  Without the Footnote, the lot would have been capped at 13 homes; with it, the developer could build 23 (originally 25) homes. (inewsource)
• That appeal process culminated in a 6-3 city council vote approving the project despite over 60 minutes of public comment all opposed, and a legal memo arguing state and local law violated. (OB Rag)
• In the council’s own words:
  “The lack of transparency and engagement in policy-making affecting neighborhoods, especially those historically discriminated against like District 4, is unacceptable.” – Councilmember Henry Foster III (San Diego Documenters)
• The site is designated “future parkland” under the community plan, yet the developer is still pushing housing. (OB Rag)
• Focus: a low-resource, historically redlined area gets housing densification; not a park.

The Corporate Land Play & the Parkland Betrayal

Let’s turn back to Emerald Hills and the land in question.  A multibillion-dollar corporation, DR Horton (not to be confused with Council Member Herny Forster’s Chief of Staff with the same name, Dan Horton) has purchased the last remaining parcel that was earmarked for park-expansion in this historically underserved, redlined neighborhood.  Under the guise of addressing a housing crisis, the corporation is activating Footnote 7 to up-zone the land for 130 homes instead of a flagship citywide park for all San Diegans which both the San Diego General Plan and Chollas Valley Community Plan call for.

Consider these facts:

• Emerald Hills has been denied meaningful parkland expansion despite being a “community of concern.”
• The vantage views (downtown, ocean) make the parcel highly desirable for market rate housing.  For the neighbors who live in the community today, a world class park.
• The city’s zoning apparatus is being leveraged to bypass the standard lot sizes in rich neighborhoods; Footnote 7 shrinkage gives developers the upper hand.
• The local roads, infrastructure, traffic calming, environmental mitigation for steep slopes etc., are all, by residents’ testimony and CEQA review and traffic study, wholly inadequate.
• Meanwhile, the city touts “Parks for All of Us” and new DIF funds, yet this parcel, in one of the most underserved parts of the city, is being flipped to private housing rather than public open space. (Inside San Diego)

The net effect: the city is prioritizing housing for profit over parkland for people and doing so in a neighborhood whose residents historically lacked both the political power and land access of the white, wealthier parts of the city.

What This Means: Redlining Disguised as Inclusion

This is not “densification for equity,” it is densification for extraction.

In the old redlining regime, Black and brown neighborhoods were cut off from investment: fewer parks, more pollution, worse infrastructure.  Now a new playbook has taken aim: those same neighborhoods are being targeted for high-density development, while the corporate and planning elite cash in.  It’s not “inclusion”; it’s containment plus profiteering.

Under this frame:

• The “housing crisis” becomes a cover story for corporations and local government to overlay new development on communities that have not been meaningfully compensated for decades of neglect.
• The “equity” narrative is hollow when the voices of the community are ignored (e.g., in the Klauber case “Not a single person spoke in favor of the development.”) (OB Rag)
• The environmental justice dimensions are inverted: the neighborhoods that have carried the burden of under-investment are now being further burdened with density, traffic, tree removal, loss of open space.
• Meanwhile, the real system of large-lot, low-density neighborhoods remains intact in areas of greater whiteness and wealth so the benefits of reduced density and park access stay concentrated in low resource, historically redlined neighborhoods.

Action Steps

If the residents of Emerald Hills, Encanto, Chollas Valley and similar neighborhoods do nothing, if the city continues to allow land earmarked for parks to become private housing at four times the density in low resource neighborhoods than in high resource neighborhoods of the rest of the city then we will have unquestioningly ushered in a new generation of redlining under the banner of “housing” and “density.”

Residents and advocates should demand:

• The parkland designation be honored.  This parcel in Emerald Hills must either become the promised community destination park or revert to low?density zoning, not high-profit housing.
• Retroactive review of all projects dependent on Footnote 7.  The repeal of the footnote in January 2025 (KPBS) did not apply retroactively, those approvals already locked in continue to exploit.
• Transparent community engagement and environmental justice review.  Projects in neighborhoods long underserved must face the same scrutiny given to affluent areas not be rubber-stamped.
• Equity in open space and infrastructure.  If wealthy neighborhoods get open space while underserved communities get density, the playing field remains tilted.
  Build the housing we need, but not at the expense of the people who are already here.  Market-rate homes are welcome, but they cannot replace the public good of parkland and community voice.

Final Thoughts

The Emerald Hills situation is not an isolated incident.  When a city abandons its responsibility to create parks for all and instead rearranges zoning so that the least powerful populations become dumping grounds for density, while their open space dreams are sold off, the result is not progress. It is perpetuation.

If history has taught us anything, it’s that designations inserted in code can codify inequity.  The city knew, or should have known, that a footnote permitting higher density in predominantly Black and Latino neighborhoods is at minimum exploitative.  The fact that the footnote is now being applied to a parcel that should have been parkland means the betrayal is two-tiered: first, the failure to build the park; second, the profiteering of the land.

So here’s the urgency: the decision being made on Thursday at the Planning Commission hearing regarding Emerald Hills will ripple across San Diego.  Either we choose to correct course park for people, equity for all, or we allow the new era of redlining under the banner of “density and housing” to become our city’s legacy instead.

It’s time the voices of Emerald Hills and fellow neighboring communities are not just “heard” but acted upon.  Our neighborhoods, our views, our park dreams and our environmental justice must not be sacrificed for the sake of corporate housing windfalls and political points scored.

Let this be a signal moment.  If we allow parkland to be rezoned for maximum profit in historically oppressed communities, we are not solving a housing crisis.  We are deepening a justice crisis.

I hope you can attend the Planning Commission meeting in support of the community on Thursday morning at 9am.  If you are unable to attend in person, please consider submitting a webform comment.

Robert Campbell is a resident of Encanto, member of the Chollas Valley Community Planning Group