The Problems with Sustainable Development Areas

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Neighbors For A Better San Diego led the fight against the adoption of the definition of Sustainable Development Areas (SDAs) as anywhere within 1 mile of a future bus stop. This was clearly done to maximize random infill housing opportunities for developers, not to promote transit adoption. Instead NFABSD argued for a widely accepted standard of 1/2 mile walking distance to existing transit.

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As we stated in our letter to the City Council:

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Dear Council President Elo-Rivera and Councilmembers,

Neighbors For A Better San Diego (NFABSD) opposes the introduction of so-called
Sustainable Development Areas (SDAs) as a replacement for Transit Priority Areas (TPAs)
in local land development codes, as proposed in Item 5 of the Land Development Code
update.

While the proposed SDA does use walking distance to determine distance to a Major
Transit Stop, as advocated by NFABSD, the replacement of the half-mile distance with a
one mile distance basically undoes the benefits of mapping walking distance and results
in a map that is even larger than the already overly-expansive TPA map.

Every home built one mile from transit under SDA incentives will take away from the
number of homes built close to transit. The resulting low-density infill development
violates San Diego’s Climate Action Plan both by reinforcing suburban automobile use
patterns for longer trips and by failing to create centralized mixed-use densities that
would facilitate walking and biking for local neighborhood trips.

The SDA definition has been materially revised at every step of the review process. The
justification and analysis of these changes has not been properly presented or analyzed
in the Staff Reports or represented on the DRAFT webmap, including the most recent
changes to add Specific Plans to the SDA definition. (Specifically, the Staff Report has not
been updated to include the unspecified added acreage from Specific Plans.)

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Read the full letter here.

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Our detailed and rigorous analysis of the problems with the SDA definition can be found in the attachments listed below. 

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A. LACK OF ADHERENCE TO WIDELY-ADOPTED TRANSIT-ORIENTED DEVELOMENT
STANDARDS
• A.1 One-Half Mile Walking Distance Standard for Transit-Oriented Development
• A.2 Critique of San Diego’s Transit Priority Map
• A.3 Viability of “Rolling” to Transit as Justification for 1 Mile Distance From Transit
• A.4 Permitting of Affordable ADUs Based on Future Transit Stops
• A.5 Misclassification of Rapid Buses as Bus Rapid Transit
 

B. OMMISSION OF A FULL ANALYSIS OF SAN DIEGO’S HOUSING CAPACITY UNDER SDAS
• B.1 Equating Acreage to Housing
• B.2 SDA Housing Capacity
• B.3 Expanded SDA Undermines Climate Action
• B.4 Response to Staff Report
 

C. EVER-CHANGING CODE DURING REVIEW AND OUT OF SCOPE FOR THE LDC UPDATE
• C.1 Sustainable Development Area Code Revision Timeline
• C.2 EIR Considerations
• C.3 Definitional Incongruities
• C.4 Need for EIR to Convert Bonus ADU Code to SDAs
• C.5 Need for EIR to Convert Complete Communities Housing Solutions to SDAs

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D. OVERCONSIDERATION AND UNDERCONSIDERATION OF REGULATORY RISKS
• D.1 Grant Restrictions
• D.2 AFFH Requires Close Proximity to Transit
• D.3 Challenges of Changing Mobility Zones
• D.4 Challenges of Changing Opportunity Zones
• D.5 SANDAG’S Controversial Endorsement of 1 Mile SDA
• D.6 SANDAG Letter 1-19-23
• D.7 HCD Letter 2-9-23
• D.8 SDAs and Transit Equity

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ADDENDUM

• Fire Hazard and Specific Plans

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