An Open Letter to the San Diego City Council’s Land Use and Housing Committee

The Committee to Consider Dumping OB’s Historic District Should Use Current Housing Data Before Making Decision

By South OB Girl

Dear Land Use and Housing Committee Members:

San Diego’s Historic Preservation and Progress Package A will be brought before you by city staff on Wednesday, January 14 for your consideration. However, this package involves controversial proposals regarding preserving the city’s historic housing ideals and districts, yet current housing data is not available. Decisions about San Diego housing should be delayed until the housing data for 2025 has been prepared and analyzed in the forthcoming 2026 Annual Report on Homes.

A report issued once a year based on data from a full year prior does not seem sufficient for assessing the current housing crisis nor sufficient information for
government officials to make decisions about housing moving forward into this year.

This annual reporting seems particularly insufficient given the escalation of public concern and opposition in the past year regarding ADUs, high density projects, plans for resiliency, evacuation route safety, Complete Communities Housing, and Preservation and Progress Package A, among other issues. Given this escalation of public concern in recent years and some of the concern expressed in this letter, now would also be a good time to consider how San Diego’s housing data and building permit data is tracked, managed, and evaluated.

Here’s an example. On Tuesday November 4th, 2025 an “Informational Presentation” about San Diego housing was presented to City Council by Samuel Solis, a Senior Planner with the City Planning Department. As an informational item on the agenda, City Council representatives were not voting on anything that day pertaining to this agenda item.

The data that was shared that day was, however, old data. Data from 2024. The Annual Housing Report is usually issued with data from a full calendar year prior to the release of the report. So, the 2025 Annual Report on Homes was based on data from 2024 — which is essentially old news. This leaves some of us feeling a little stumped about what San Diego’s housing data actually looks like currently in January 2026.

Members of the Planning Commission at their November 6th, 2025 meeting incorrectly observed that Ocean Beach was the main community concerned about new measures being put in place for communities which are designated as Historical. This is not the case, and the extensive concern about Preservation and Progress Package A in communities throughout San Diego was seen at that meeting. Speakers from throughout San Diego spoke in opposition of Package A and attendees were from all over the city, plus several organizations also spoke in opposition. These organizations (including OB-based groups) were:

• SOHO (Save Our Heritage Organisation)
• OB Historical Society
• OB Planning Board
• Mission Hills Heritage
• Kensington Talmage Planning Group
• Community Planners Committee
• University Heights Historical Society
• And, the “Preservation Community” represented by Laura Hensen and Place Economics.

The Land Use and Housing Committee should take into consideration that an evaluation of San Diego’s Historical Resources and Historical Communities is being undertaken by Place Economics, as stated by Laura Hensen — representing the Preservation Community. It should also be noted that the City has not itself stepped forward to conduct a similar evaluation despite requests for such an evaluation.

The concerns raised by these various organizations on November 6th should be considered more fully as Package A comes before your key committee. Several points were raised then seemed to have been ignored by the Planning Commissioners, when additional inquiry and consideration would have been judicious and advisable.

Some questions and concerns about the 2025 Annual Report on Homes, the Housing Element data, and City Planning’s Informational Presentation about San Diego’s
housing data in November 2025 are  examined here.

The Preservation Community has a variety of concerns about the impacts of Package A on historical communities and historical resources and the process of de novo appeal. Now is an ideal time to evaluate San Diego’s current housing data in full and examine the Work Plan for Housing, as laid out by the Land Use and Housing Committee, before the City of San Diego stomps on and destroys the protections currently in place for historical communities and historical resources. As one prominent and vocal San Diegan has said, before the City of San Diego begins a complete destruction of communities.

Another concern is about the Housing Element data, and in particular the data according to income categories.

The Data

I have examined the City’s data for housing which is available to the public. I found some columns lacking in the 2021-2024 Housing Element which can be viewed here. If the value is zero but the category should still be represented in the data for State purposes, that should be examined by City Planning. I found that San Diego organizes data according to the following categories: Very Low Income, Low Income, Moderate Income, and Above Moderate Income. As a viewer looks at the 6th Cycle Housing Element data, one wonders what  categories of data are presented in the spreadsheet and what other categories of data could be useful for analysis.

Even a few rows of data on the spreadsheet shows the low number of building permits issued in 2024 for Very Low Income, Low Income, and Moderate Income.

San Diego’s categories are different than what is described for income limit categories on the California Department of Housing and Community Development website. The State website outlines the following categories and the categories are based on the local Area Median Income, the AMI. The website states that “income categories commonly used in California are approximately as follows (subject to variations for household size and other factors)”:

• Acutely low income: 0-15% of AMI
• Extremely low income: 15-30% of AMI
• Very low income: 30% to 50% of AMI
• Lower income: 50% to 80% of AMI; the term may also be used to mean 0% to 80% of AMI
• Moderate income: 80% to 120% of AMI.

If Moderate Income can represent up to 120% of the AMI, what does San Diego’s income category of Above Moderate Income represent? Should Acutely Low and
Extremely Low Income be represented in San Diego’s housing data? State income limits are derived from Federal guidelines, and San Diego’s plans for housing are
supposedly based upon State guidelines. Perhaps San Diego’s terminology connects all the dots correctly, but it does get a bit confusing when the State website says that the Moderate Income category is associated with incomes of 80% to 120% of the AMI and then San Diego’s data has a category of Above Moderate Income. Of significance here is also that the Above Moderate Income category also accounted for 88% of new building permits issued in 2024 (2025 Annual Report on Homes, page 8).

Lastly, I will explore some concerns about the current RHNA (Regional Housing Needs Assessment) and statements in the Staff Report from City Planning that say: “The City has permitted more homes than anticipated…”

The RHNA

Now, the RNHA — what is it currently?

The Land Use and Housing Work Plan issued on February 4th, 2025 by Council President Pro Tem Kent Lee stated that the the City still needed to permit 82,343 more homes to meet the RHNA allocation by 2029, majority of which must be allocated to Very Low-, Low-, and Moderate- income levels for our working families.

The 2025 Annual Report on Homes states on page 67 that the City has permitted 27% of homes allocated by RHNA, with half of the cycle remaining.  The City will need to permit 78,978 additional homes by 2029 — about 9,800 per year for the next 5 years to meet its RHNA allocation.

The Informational Presentation PowerPoint presented to City Council on November 4th wrapped up with a slide stating that 73,796 additional homes need to be permitted by 2029 to meet RHNA goals, which should include 58,353 affordable homes (Slide 29).

Yet, between the release of the 2025 Annual Report on Homes and the Land Use and Housing Work Plan dated 2/4/2025 the RHNA decreased by 3,365.

From the Annual Report to the Informational Presentation to City Council on 11/4/2025, the RHNA decreased by 5,182.  From 2/4/2025 to 11/4/2025 the RHNA decreased by 8,547 (82,343 – 73,796 = 8,547).  That would indicate that the number of permits issued in 2024 was 8,547 and so the RHNA went down by 8,547.  However, the number of new homes permitted for construction in 2024 is indicated to be 8,782 in the Informational Presentation PowerPoint (slide 4) and the 2025 Annual Report on Homes (page 8).

So, what is the current RHNA?  New housing permits and new Housing and Land Use policies should be based upon how to achieve the RHNA allocation.  It would also be valuable to consider qualitative data and not just the quantitative.  Housing policy should aim to achieve the state mandated RHNA and should also provide what San Diegans need and want.  And, what San Diegans need and want may actually look quite different from what the City is designing with plans and policies to achieve the RHNA.

“More than anticipated…”

I am also interested in some verbiage in the Staff Report issued to City Council from City Planning regarding the 2025 Annual Report on Homes dated September 30th, 2025.  The following is stated on page 3 of the Staff Report:

“The City has permitted more homes than anticipated on vacant sites identified in the Housing Element’s adequate sites inventory in Mobility Zone 3. The City has also permitted more homes than anticipated on non-vacant sites identified in the adequate sites inventory in Mobility Zones 1 and 2.”

I would think that with accurate and appropriate planning, “more permits than anticipated” would not occur.  Also, numerically, what is “more homes than anticipated”?  How many more homes than anticipated?  What was the original goal and then what happened?  The City of San Diego should be anticipating its housing needs and working towards its RHNA allocation with accuracy and in ways that don’t result in statements that say “the City has permitted more homes than anticipated…”

City staff held a public webinar on October 8th, 2025 and given the amount of concern expressed by members of the public about housing and housing policies, perhaps another public webinar should be arranged and additional community outreach efforts coordinated which pertain to the 2025 Annual Report on Homes.

As you think of all the construction sites, scaffolding, bulldozers, and cranes you’ve seen around town this past year, 2024 seems a while ago and one wonders what the current housing data is.  The Land Use and Housing Committee should take steps to promote excellence in the data of the City and promote improved tracking, management, and analysis of San Diego’s housing data.  Additionally, new housing policies should be tabled until the 2026 Annual Report on Homes is finalized and published, until the Housing Element data has been reevaluated, and until a current and accurate RHNA goal has been assessed.

Sincerely,

South OB Girl