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Victory at the HRB and CPC: Boards Reject Package A
November/December 2025
We have good news to share. In October 2025, both the Historical Resources Board (HRB) and the Community Planners Committee (CPC) did not recommend approval of “Package A,” a set of proposed changes to San Diego’s historic preservation ordinance that would weaken protections for historic properties citywide.
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The HRB hearing on October 23 lasted until nearly 6pm, and SOHO’s advocacy, joined by Mission Hills Heritage, Neighborhood Historic Preservation Coalition, University Heights Historical Society, and others, proved successful. The HRB ultimately failed to recommend the proposed ordinance revisions, with a majority of the board recognizing that the City had not provided the necessary environmental or factual basis to move forward.
The CPC with 30 of its members in attendance voted unanimously to reject.
The following is regarding the HRB. Our testimony and letters followed along the same lines of information to the CPC one week later on October 28.
SOHO’s testimony emphasized that the HRB’s core duty is to preserve historic resources—not make it easier to erase them. We reminded the board that its decisions should remain fact-based and professional, not political. As we stated:
“Your baseline decision today is simple: Is it historic or not? Just as with environmental reviews—like determining whether a site is a vernal pool—the question is factual, not political. The City Council designed this process so that the HRB, as experts, can make those determinations without burdening the Council, who does not have this expertise…”
For more than 25 years, no HRB and no City Council has endorsed similar ordinance changes, and for good reason. Such proposals would transform a fact-based process into a political one, inviting subjectivity and inconsistency in historic designation decisions.
We also reminded the board of the ongoing, cumulative losses to San Diego’s heritage through decay, fire, demolition, neglect, and overdevelopment. Each year, the number of surviving historic resources dwindles. The proposed changes would only accelerate this irreversible loss.
SOHO further urged the board to recognize that the City lacked the required environmental analysis to make a legal determination on Package A. Under CEQA, ordinance amendments that could lead to physical or environmental impacts—such as the loss of historic resources—require environmental review and mitigation. The City’s segmentation of Packages A and B of the proposed ordinance violates CEQA’s mandate to evaluate the whole of the action together.
Staff claimed that Package A involved only minor changes and was therefore covered by existing environmental documents. This interpretation is incorrect, and, as SOHO noted, the courts have repeatedly rejected similar arguments.
SOHO board member David Swarens also pointed out that by separating the Historic Preservation Element of the General Plan from the larger update, the City has created additional legal and analytical problems. Several other General Plan elements, including Urban Design expressly depend on the Preservation Element. Considering these interdependent elements in isolation undermines the integrity of the plan and any valid environmental review.
As we pointed out, recent court rulings in the last few years—including Save Our Access v. City of San Diego, which successfully challenged the City's attempt to remove a 30-foot height limit in the Midway District—underscore the City’s obligation to conduct full environmental review before adopting such sweeping changes.
“SOHO has said repeatedly that these proposals would weaken existing protections and increase the loss of historic and cultural resources—the very impacts CEQA was designed to prevent,” SOHO Executive Director Bruce Coons told the board. “An Environmental Impact Report is therefore required before forwarding either part of this ordinance to the City Council.”
The hearing’s outcome is an important victory: The proposed program will be moving forward, (next, to the Planning Commission on November 6, 2025), but without a crucial recommendation from the HRB.
SOHO thanks everyone who submitted comments, attended the hearing, or spoke out in defense of our shared heritage. We will continue to monitor the two packages as they move forward and keep you informed. For now, we can all take heart in this significant preservation win.
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