Save Our Access v. City of San Diego

CourtCalifornia Court of Appeal
DecidedOctober 17, 2025
DocketD084132
StatusPublished

This text of Save Our Access v. City of San Diego (Save Our Access v. City of San Diego) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Save Our Access v. City of San Diego, (Cal. Ct. App. 2025).

Opinion

Filed 10/17/25 CERTIFIED FOR PUBLICATION

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

SAVE OUR ACCESS, D084132

Plaintiff and Appellant,

v. (Super. Ct. No. 37-2022- 00035094-CU-TT-CTL) CITY OF SAN DIEGO,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of San Diego County, Katherine A. Bacal, Judge. Reversed. DeLano & DeLano, Everett L. DeLano III and Ezgi Kuyumcu for Plaintiff and Appellant. Mara W. Elliott and Heather Ferbert, City Attorneys, M. Travis Phelps, Assistant City Attorney, and Benjamin P. Syz, Deputy City Attorney, for Defendant and Respondent. I. INTRODUCTION

This appeal challenges the City of San Diego’s 2022 approval of a second ballot measure to exclude the Midway-Pacific Highway Community Planning area (Midway-Pacific Highway area) from San Diego’s Coastal Height Limit Overlay Zone, which generally limits building heights to 30 feet. We previously affirmed a judgment invalidating the first ballot measure approved in 2020 because the City did not consider important potential environmental impacts of removing the height limit in the Midway- Pacific Highway area, as required by the California Environmental Quality

Act (Pub. Resources Code, § 21000 et seq.1) (CEQA). (Save Our Access v. City of San Diego (2023) 92 Cal.App.5th 819, 829–830 (Save Our Access).) For that ballot measure, we concluded the City could not rely on the program environmental impact report prepared in 2018 (PEIR) for the Midway-Pacific Highway Community Plan Update (MPH CPU) because removing the height limit was “a significant change that was not considered” in the program document. (Id. at p. 859.) While that appeal was pending, the City prepared a supplemental environmental impact report (SEIR) and approved a second ballot measure to remove the height limit from the same area. When we inquired about whether these actions rendered the prior appeal moot, both parties asked us to decide the merits of the appeal then before us. (Save Our Access, supra, 92 Cal.App.5th at p. 829, fn. 3.) The City said the SEIR and ballot measure were separate actions for a distinct project that was being challenged by a

1 Undesignated statutory references are to the Public Resources Code unless we state otherwise.

2 new lawsuit—this one. Save Our Access had filed new litigation contending

the City’s actions still failed to comply with CEQA.2 The superior court ultimately denied Save Our Access’s petition for writ of mandate related to the second ballot measure. Save Our Access appealed. The issue before us now is limited: whether the City complied with the CEQA requirements to adequately inform the public of the potential environmental impacts of approving the second ballot measure to remove the height limit in the Midway-Pacific Highway area, to identify possible mitigation measures, and to disclose the reasons for approving removal of the height limit even if there are significant environmental impacts. We conclude it did not. The City’s initial study and SEIR adopted the 2018 PEIR analysis without actually considering the environmental impacts of buildings greater than 30 feet, other than views and neighborhood character. This was inadequate. As a result, neither the City decisionmakers nor the public were able to make a meaningful decision about the second ballot measure. Recent legislative changes to CEQA do not alter our analysis. We invited the parties to submit supplemental briefs addressing whether any changes to CEQA from recently enacted Assembly Bill No. 130 and Senate Bill No. 131 impact the issue presented in this appeal. Save Our Access responded by saying the recent amendments do not appear to affect this appeal, but are focused on “obligations agencies must undertake regarding individual projects.” The City did not respond. We conclude

2 Save Our Access describes itself as “a non-profit corporation that seeks to support the quality of life in Southern California by advocating for public access to beaches, parks, water, and public land and for creating more parkland.”

3 removal of the height limit for an entire planning area is not encompassed by the recently enacted CEQA exceptions identified by the Legislature. We, therefore, reverse and remand with directions to grant Save Our Access’s petition for writ of mandate and to direct the City to comply with CEQA. II. BACKGROUND

A. Background of Midway-Pacific Highway Community and Prior Appeal3 Briefly, San Diego voters passed an ordinance in 1972 prohibiting construction of or additions to buildings higher than 30 feet “ ‘within the Coastal Zone of the City of San Diego,’ ” which is defined as “ ‘that land and water area of the City of San Diego from the northern city limits, south to the border of the Republic of Mexico, extending seaward to the outer limit of City jurisdiction and extending inland to the location of Interstate [Highway] 5 on January 1, 1971’ ” (Coastal Zone). (Save Our Access, supra, 92 Cal.App.5th at pp. 829–830.) The ordinance, codified at San Diego Municipal Code as section 132.0505, excludes the downtown area of San Diego and a few other specific projects allowed by subsequent voter initiatives. The arguments in favor of the 1972 initiative included maintaining access to beaches, preserving the nature and character of coastal communities, and preventing high-rise buildings from obstructing “ ‘needed ocean breezes, sky and sunshine.’ ” (Save Our Access, supra, 92 Cal.App.5th at p. 830.) It also sought to provide “ ‘ “protection against unwanted high

3 We incorporate by reference the detailed historical background of the Midway-Pacific Highway area and the height limit ordinance described in our prior opinion. (Save Our Access, supra, 92 Cal.App.5th at pp. 829–832.)

4 population density with its problems of congestion, lack of parking space, increased crime rate, noise, air pollution, inadequate public utilities and increased taxes.” ’ ” (Ibid.) In 2018, the City approved the MPH CPU along with amendments to the general plan. The land use goals of the MPH CPU included “developing a ‘vibrant, balanced, and pedestrian-oriented community that provides residential, commercial, office, industrial, institutional, military, and civic uses’ using a ‘compatible mix of land uses that support active transportation and a healthy environment’ and a ‘variety of housing types for all age, income, and social groups.’ ” (Save Our Access, supra, 92 Cal.App.5th at p. 832.) The MPH CPU rezoned some areas within the Midway-Pacific Highway area with City-wide zoning designations and adopted new zoning designations, including a mixed commercial residential land use designation. (Ibid.) The 2018 MPH CPU and the supporting PEIR were prepared with the understanding that the 30-foot height limit applied to the area. (Save Our Access, supra, 92 Cal.App.5th at p. 855.) The scoping statement for the PEIR informed the public that the Coastal Zone “ ‘applies to the entire Midway- Pacific Highway community,’ which ‘limits construction of new development to 30-feet in height to protect coastal views.’ ” (Save Our Access, supra, 92 Cal.App.5th at p. 831.) The final MPH CPU also stated the Coastal Zone “ ‘limits the height of new buildings to protect coastal views.’ ” (Id. at p. 832.) In 2020, the City approved the first ballot measure asking the voters to exclude the Midway-Pacific Highway area from the 30-foot height limit. In invalidating the 2020 ballot measure for failure to comply with CEQA, the superior court identified the failure to address the impact of taller buildings on scenic views and vistas. However, the court expected the City would

5 analyze other potential environmental impacts associated with removing the height limit. (Save Our Access, supra, 92 Cal.App.5th at p.

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Bluebook (online)
Save Our Access v. City of San Diego, Counsel Stack Legal Research, https://law.counselstack.com/opinion/save-our-access-v-city-of-san-diego-calctapp-2025.