By South OB Girl
It is unfortunate for San Diegans that many wise words have fallen on deaf ears during the proceedings of the city’s “Preservation and Progress Package A,” which proposes amendments to existing policies for historic properties, historic communities, historic designation, de novo appeal, and San Diego’s historical resources. As Save Our Heritage Organisation (SOHO) described in their January 9, 2026 OB Rag article:
This fast-tracked proposal would weaken San Diego’s historic preservation program by allowing the City Council to override expert historic designations, thereby stripping protections from historic districts… while prioritizing new construction over true preservation.
Package A specifically targets Ocean Beach for the construction of high-density Complete Communities Housing Solutions and specifies Ocean Beach for the removal of historic protections. This would pave the way for high-density housing developments with greatly reduced setback requirements and little to no on-site parking. Such construction is currently not allowed in OB.
Package A paves the way to annihilate the small beach town as we know it while flooding our community with big box apartment buildings that could be mixed in with single family homes and historic beach cottages. Such development would have a myriad of repercussions including oversaturation of on street parking due to limited on-site parking and a strain on public utilities such as water, sewer, and power.
The saga of the preservation community rising into action regarding Package A began at the October 2025 meeting of the Historic Resources Board. The Board had been hurried – and harried – when making a decision regarding Preservation and Progress Package A.
Then, at the November 2025 Planning Commission meeting after a long morning of public comment, words again fell on deaf ears regarding Preservation and Progress Package A. Just how is it that this proposed policy came this far, when the fallacies should have been acknowledged by multiple City departments by now?
On that 6th day of November, perhaps the long morning of public comment from both those in favor and those opposed led the Commissioners to be inattentive to what CEQA and historic preservation attorney, Susan Brandt-Hawley, had to say. This is a misfortune and an oversight. Her words were among many during the hearing that seemed to not have been heard by the Commissioners. Who she is, for starters, seems to have been missed by the Planning Commission.
Susan Brandt-Hawley is a prominent attorney who has been working with CEQA and historic preservation for over thirty years. She has represented hundreds of public-interest groups, including SOHO, in CEQA cases and appeals that have to date resulted in precedent in 50 published opinions in the six districts of the California Court of Appeal and 6 cases in the California Supreme Court. At the Planning Commission meeting, Brandt-Hawley spoke virtually, as she is not based in San Diego. In the time allotted to her, which was one minute, she said:
As you know, the historic environment is protected, just like water and trees and air to equal measure in California and in this case – the problem you have here – I think this commission is at a great disadvantage because it doesn’t – just like the HRB – it doesn’t have the advantage of a CEQA evaluation. The de novo appeal, as well as other things, they were not addressed, ever, in the earlier EIRs, and so the consistency analysis that you’ve been provided with is not accurate. This matter will have, or these changes will have, reduced protections to historic resources so you need to do a Supplemental EIR in order to inform decision of the entire Preservation and Progress, all packages.
Following Brandt-Hawley’s comments, Commissioner Boomhower asked the City Attorney’s Office if taking this as two separate actions, a Package A and Package B, conforms with CEQA. The City Attorney representative responded, stating that:
Package B has not been formulated at this time. So, any analysis of [a Package B] would be speculative at this time. In addition the package before you is independent and has independent utility as a separate project and is not contingent upon further action under Package B.
Commissioner Boomhower asked for clarification, asking a general question to obtain clarity, “So… Package B might never happen?” He was given an affirmative answer: Package B might never happen.
This was, however, a completely different response about a future Preservation and Progress Package B than was given at the City Council’s Land Use and Housing Committee meeting on 1/14/2026. Then Kelley Stanco, the City’s Deputy Director of the Climate, Preservation, and Public Spaces Division in the City’s Planning Department, described the scope, intentions, and timeline of Package B. When presenting to the LUH Committee on January 14th, Stanco said:
Staff has grouped the updates into Package A and Package B. Package A, which is before you today, includes items that are not significantly complex, and that do not involve amendments to the historical resources regulations or historical resources guidelines. Package B, which we aim to bring forth later this year, includes updates that are more complex in nature, that do include amendments to the historical resources regulations or guidelines, or that require more extensive environmental analysis.
It appears that Ms. Stanco has confirmed the existence of Package B, what Package A and Package B are intended to accomplish, and Ms. Stanco also stated that more extensive environmental analysis would be required. Which is what Susan Brandt-Hawley, and others, had asked the Planning Commission to consider in November.
Returning to the events of the Planning Commission hearing on 11/6/2025, first of all, Commissioner Boomhower, and all of the Commissioners, had been led to believe that Package B may never happen and might never exist. Additionally, Boomhower had followed up his question about the future of Package B with the following question: “do these changes actually require a supplemental EIR under CEQA?” The representative from the City Attorney’s Office said she would defer to City Staff on the specifics with respect to the CEQA analysis, and she then went on to say:
However, there is a CONSISTENCY MEMO that goes through everything that’s in front of you and looks at what impacts would be potential with respect to this action and I’ll defer to staff on more of the specifics with respect to that.
Ms. Stanco then began her response to the City Attorney representative and Commissioner Boomhower, stating:
In terms of this package… we’ve done a CONSISTENCY DETERMINATION with a number of other prior environmental impact reports… Part of the reason we have looked at what would be reasonable to look at in Package A versus Package B is that the Package A amendments don’t reduce protections for historic resources. So in introducing the findings not supported, finding, to the appeal process … that decision still needs to be based on whether or not the property meets the City’s criteria for designation and no other consideration.
So it’s still merit-based on whether or not the resource meets the criteria for designation. And, just for some context, when you look at what other jurisdictions across the state and across the country who are certified local governments, how their programs are structured, it’s a variety. There are some jurisdictions that don’t rest any designation authority with their preservation board or commission.
That preservation Board or commission provides a recommendation to the City Council who has the final decision and designation. Here we do rest the designation decision with our historic resources board with appeal oversight by the City Council. And again our expanded findings would focus on the significance of the resource and the State office of historic preservation does not have any issues with that proposed amendment.
This is however where things started. Brandt-Hawley said the consistency analysis is not accurate and a supplemental EIR would be required. Discussion in November not only fell on deaf ears at the Planning Commission, the argument went in a circle and ended where it had started. But none of the Commissioners seemed to realize this.
To some San Diegans it might seem shocking, and to others it might not seem shocking at all.
We have heard completely opposite information regarding the existence and contents of a Preservation and Progress Package B. At the 11/6/2025 Planning Commission hearing Package B was potentially non-existent. At the LUH Committee meeting on 1/14/2026, the contents of Package B were described and the LUH Committee was told that Package B would be finalized later this year.
How has Package A come this far in light of so many shortcomings and inconsistencies? Not only are there arguments that the consistency analysis of Package A is inaccurate, the facts about whether or not a Package B will exist have not been consistent and governing bodies have been given different facts upon which to base their deliberation and decision. The City of San Diego and its officials should “press pause” and examine – for the first time – what Preservation and Progress Package A and B intend to accomplish and the role and importance of CEQA analysis and supplemental EIR in setting forth such amendments.
Thank you South OB Girl. An important story, conveyed with great clarity.
” Just how is it that this proposed policy came this far, when the fallacies should have been acknowledged by multiple City departments by now?” you ask.
It’s not a secret that all those on the Planning Commission are mayoral appointees – I’ve seen ludicrous remarks made, overt rudeness, marginal substance and reasoning underlying votes – it is a sham entity that has biased viewpoint favoring the mayor’s personal agenda.
Everything you described has become more apparent.
If the city wants to save money, it has 49 Committees, Commissions, and Boards, not to mention the student Brigades, the elected Planning Boards, and the extensive support for police ride-along ticket givers and volunteer professional services. And all of the Parks & Arts projects. But thinking about it, these also have City staff members who at least attend meetings and provide other services. When AI is asked how many Plans the City of San Diego has, it answers “too numerous to count.”