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SOHO President's Message
By David W. Goldberg
November/December 2023
 Photo by Sandé Lollis |
In February 2023, San Diego City Council President Sean Elo-Rivera asked the Independent Budget Analyst (IBA) to analyze “historical resource review policies and processes related to construction permitting.” His memo also requested streamlining recommendations “so as to not delay the creation of new homes.” Elo-Rivera expressed concern “that the historic review process is reportedly a major bottleneck in the construction permitting process, creates uncertainty, requires significant staff time to complete, and ultimately delays the creation of new homes.”
Although I read the report with some trepidation, it was encouraging that the importance of historic preservation is clearly acknowledged. It begins with an overview of preservation policies and regulations; and the benefits of preservation, which include fostering cultural heritage, educational opportunities, environmental impact reduction, and economic growth through increased tourism.
For the record, preservation contributes substantially to the economy beyond tourism. The City needs to factor into the analysis these established benefits: sparking renewal of declining neighborhoods, creating jobs, and strengthening the middle class by providing opportunities for home ownership, wealth building, and economic security.
The IBA’s Mills Act program analysis also needs to be expanded. The report details the loss of tax revenues on designated historic resources with Mills Act contracts, a common refrain. But the associated reduced taxes are only one part of the equation. Research has shown that Mills Act properties create a “halo” effect on surrounding properties, meaning that the aggregate increase in a neighborhood’s property values may actually result in a net tax revenue gain for local governments.
The full scope of both these overarching benefits must be included in the City’s financial assessment of historic preservation.
To assess whether construction permits, i.e. new housing units, are being delayed while staff evaluates older structures subject to development proposals, the IBA looked at nearly 11,000 such reviews completed during fiscal years 2020, 2021, and 2022, and their impact. The IBA’s conclusion? “We believe it is unlikely that Potential and Designated Historical Resource Reviews, as only one part of a multi-disciplinary permit review process, are holding up permit issuances.” Moreover, it’s important to note that less than 1% of these reviews resulted in historic designation.
Let the record show: The report invalidates the argument that the historic designation process slows down or adversely affects housing production.
The report’s recommendations range from reasonable to mixed to unacceptable. It suggests conducting an intensive citywide historic survey, such as SurveyLA in Los Angeles, which covered over 880,000 legal parcels, to minimize uncertainty for property owners and developers in project planning. Oddly, it also recommends establishing a historic district program—a popular preservation tool that’s been in place in San Diego for years—that proactively identifies properties of historic significance. Both would benefit the preservation community. Frustratingly, San Diego’s historic district program is seriously lagging in evaluating potential districts.
Most importantly, the report’s first recommendation must be defeated because it runs contrary to streamlining procedures and would upend San Diego’s historic landmarking process for no good reason. It states: “Historical preservation decisions should be made with consideration of other citywide priorities, and costs and benefits of historical preservation should be considered when making decisions affecting future development opportunities of historical resources. The Municipal Code could be revised to allow the City Council to overturn historical designation decisions on a broader basis.”
The historical resource review process, despite its shortcomings, is based on the application of defined standards and largely lies outside the political realm, as it should. Today, designations can be appealed to the City Council and overturned when the process included factual errors, procedural violations, or when new information comes to light. It makes no sense to expand designation criteria to include “other factors” or “costs such as the potential impacts on housing development” when the designation process isn’t slowing down or impeding new housing production. On the contrary, changes such as these will lead to more problems and litigation, threaten existing designations, and demote historic resources protection to second-class status in the planning process.
This is the report’s fatal flaw. It must be corrected.
Since penning my message, the San Diego Historical Resources Board held an informational-only IBA hearing on October 26. SOHO, in collaboration with a coalition of historic preservation and history organizations and groups, submitted a compelling response letter to the hearing. More than 75 dedicated San Diego residents wrote in and shared their important and insightful comments with the IBA staff and HRB, with numerous residents and organizations providing impactful, knowledgeable in-person testimony.
Read our Neighborhood Historic Preservation Coalition's response to the IBA Report letter.
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