top of page
Deregulating San Diego

SENATE BILL 10 & Missing Middle Housing

The SB 10 bullet we dodged was peddled as "Missing Middle Housing" by City Hall.
It wasn't, and here's why it matters...

In 2023 Mayor Gloria intended San Diego to be the first California city to "opt-in" to Senate Bill 10 (SB 10). Thankfully, he was eventually forced to remove SB 10 from Housing Action Package 2.0 as the details of this irrevocable state law became public.


Parroting the Mayor and the Planning Department, building industry proponents argued that SB 10 would deliver "Missing Middle Housing."


For those unfamiliar with the term, "Missing Middle Housing" represents duplexes, classic row houses, townhomes, and properly-scaled apartment buildings, all seamlessly blending in with the surrounding neighborhoods, incrementally adding density closest to transit corridors.


Using this term to market and sugarcoat SB 10 was no accident. And since SB 10 may be resurrected after the November elections, we thought it worthwhile to explain.

Missing Middle diagram.jpg

What is Missing Middle Housing?

The term "Missing Middle Housing" was coined by Opticos Design founder Daniel Parolek in 2010. The term is specific to planning implementation and does not mean "middle-income" housing, as some assume.


Missing Middle Housing transitions from low- to high-density housing and includes architectural standards that complement the surrounding neighborhood.


As defined, Missing Middle Housing "typically has small- to medium-sized footprints, with a body width, depth, and height no larger than a detached single-family home. This allows a range of various Missing Middle types — with varying densities but compatible forms — to be blended into a neighborhood, encouraging a mix of socio-economic households and making these types a good tool for compatible infill."


Kensington, one of San Diego's historic mid-city neighborhoods, contains perfect examples of Missing Middle Housing.


Kensington's multi-family homes blend seamlessly with the surrounding single-family homes. These apartment homes are a short walk to neighborhood shopping, medical offices, restaurants, and transit.

Examples of single-family homes in Kensington:

Examples of "Missing Middle" multi-family homes in Kensington:

Kensington's Missing Middle Homes are examples of well-planned, well-designed multi-family homes that

  • are located in multi-family zoning

  • are scaled to the surrounding neighborhood

  • are architecturally compatible with the surrounding neighborhood

  • are within a block of shopping and transit

  • contain 2 or more units

  • provide a smooth transition from mixed-use to single-family zoning

  • include back and front yards

  • provide some off-street parking for tenants

Compare to SB 10

When the Planning Department pitched its SB 10 implementation to the public and the Council, it used the concept of Missing Middle Housing, even including the above graphic from Opticos, to argue that it would provide neighborhood-compatible infill housing. However, the actual code completely contradicted these principles in both scale, impact, and design.

Examples of what could have been built in single-family-zoned neighborhoods under San Diego's SB 10 implementation:

SB 10 Example 4.png
SB 10 example - small.png
SB 10 example 3.png
SB 10 example 5.png

These photos represent the scale and mass of what San Diego's proposed SB 10 would have allowed in single-family neighborhoods, resulting in

  • dense development scattered throughout single-family-zoned neighborhoods

  • massive apartment buildings with 10x more building volume than most nearby houses

  • no architectural standards

  • density up to a mile away from transit

  • up to ten units (+ more ADUs) on a single-family lot

  • no design standards for compatibility with the surrounding neighborhood

  • dense development within 4 feet of the property line

  • no onsite parking

  • no usable yard space requirements

  • bypassing environmental impact review (EIR)

  • no way for a future City Council to remove it from our building code — ever

Yard sign - low res.png

Why it matters

By mislabeling their proposed SB 10 implementation as Missing Middle Housing and using the CEQA exemption in the state law, Mayor Gloria and his Planning Department tried to slide through poorly-written code in a giant omnibus housing package (HAP 2.0).


While this obfuscation strategy worked when the Council adopted programs such as Complete Communities and the Bonus ADU Program during the darkness of COVID, San Diegans are now on high alert to relentless attempts by the Mayor and Planning Department to unnecessarily destroy single-family neighborhoods under the false flag of "housing crisis" — when in reality, San Diego is suffering from an affordable housing shortage, which these programs will not resolve.


Proper planning does not take shortcuts. It works best when designed by and for a local jurisdiction; soliciting input from residents, owners, businesses, and developers with repeated and transparent feedback. This ensures that the plans can work and that all stakeholders have buy-in to see those plans succeed.


No city should consider opting into one-size-fits-all state mandates such as SB 10 because they effectively give planning departments a pass on proper planning, analysis, or outreach. This is an injustice to residents and business owners who are deeply committed to their communities.

Read our other installments of "Deregulationg San Diego":

Deregulating San Diego: Complete Communities

Deregulating San Diego: The Bonus ADU Program

Deregulating San Diego: The Sustainable Development Area

Was this helpful?

We hope you find our content helpful. Please subscribe to our emails to stay informed on issues that affect your neighborhood.


Neighbors For A Better San Diego is a grassroots organization formed to bring homeowners back into the discussion of urban development. We seek the creation of policies that benefit homeowners, renters, small businesses, and other stakeholders.

We are all volunteers, but our efforts require funding, so please consider donating to help our cause.

bottom of page