Unless modified, the updated General Plan headed to the San Diego City Council for approval will unwisely place new restrictions on the co-location of industrial and residential uses. The guidelines for planners to follow are contained in the document’s Economic Prosperity Element.

A comprehensive review of the proposal leads to two key questions:

• Does the city require restrictions on co-location?
  
  
• If the city does impose these restrictions, what are the potential problems which may result from it?

The answer to the first question is “no.” Indeed, if such restrictions are imposed, over the long term they are likely to create land use inefficiencies, exacerbate San Diego’s housing and transportation problems and result in a general degradation in the quality of life. Moreover, the city and its people are adequately protected under existing rules and guidelines against any problems that might be associated with co-location.

If the restrictions become law, the problems they present are many.

For starters, a law restricting or banning co-location will ultimately contribute to the increase in commute times and traffic congestion as employees grapple with the disconnect between where they work and where they may live. The unintended consequences include making the city less attractive to industry and lowering the quality of life for employees.

We also risk exacerbating our well-documented failure to meet the regional need for housing. In a report issued last year, the San Diego Association of Governments estimates the county should be adding an average of 17,000 housing units each year. With an average of 10,000 actually built, we are running 40 percent short and falling farther behind each year.

Mid- and long-term forecasts also reveal a shortage in industrial land. In a world of shortfalls, the challenge is to increase the supply of industrial space through more intense development, including vertical and mixed-use development. This is the same challenge as with all land use classifications: land is finite, which is the very reason why the city’s General Plan is being updated to promote mixed use, density and infill development.

Existing Law Matters, Too

The proposed co-location restrictions are inconsistent with city policy and laws designed to encourage mixed use and smart growth. If they pass, the city could have on its books two competing land use philosophies.

Also of concern is the lack of clear distinctions in industrial zone classifications. The term “industrial” is used as a catchall for many land uses including manufacturing, warehouse and distribution and commercial office. A single policy cannot fairly apply to all of these, and certainly “buffers” or other measures are not required for most.

While the supply of vacant, industrial land is gradually diminishing through development, we are experiencing a similar diminishing demand from certain industrial sectors. Manufacturing jobs are fading while technology and service sectors grow. This is a result of a changing economy, both locally and globally, that has dictated which jobs and industries are able to thrive in different metropolitan areas. As stated succinctly in a recent issue of The Economist, “The fall in manufacturing employment in developed economies is a sign of economic progress, not decline.” Even though we have lost manufacturing jobs, they have been more than replaced with what the publication describes as “higher-tech, higher value-added sectors such as pharmaceuticals.”

So the argument that a loss of industrial lands is costing us jobs is false. San Diego County has experienced positive job growth since 1993, adding an average of 30,746 new jobs annually between 1994 and 2004.

Industrial jobs will continue to leave San Diego for other places in Southern California or even out of state or to a different country. Preserving industrial zoning won’t change that. Rather, we should focus on the many opportunities associated with the transition from old industrial uses to new types of uses.

An Arbitrary Buffer

Particularly onerous is the provision, tucked away in the element, requiring a 1,000-foot buffer between residential and industrial property lines. It is arbitrary and sets an impossible standard that is in conflict with the goal of mixed use. At minimum, a buffer should be a potential solution to case-by-case conflicts, not a standard of mitigation requiring developers to overcome.

For those worried about the potential hazards of incompatible uses butting up against each other, the county already employs significant and adequate regulatory standards protecting the health, safety and welfare of all San Diego residents. Among the concerns addressed by existing laws and regulations are toxic chemicals, air pollution, noise and safety.

In addition, there is no compelling need to impose an additional bureaucratic layer to the already byzantine approach to entitling and providing new housing within the city of San Diego.

Bluntly, the underlying reason the co-location restriction proposal has made it this far is to address the potential conflict between residential and the noise and safety concerns from truck traffic. It is an overreaction.

What should be adopted is an Industrial Co-location Easement modeled after Avigation Easements. The latter has the purpose of identifying to future residents the present and future adverse effects the industrial operation will have on the residential use.

The policy also should be designed to encourage and accommodate employers who wish to grow and who may thrive in the San Diego region. To do that we need a better linkage between housing and employment and a way to ensure an adequate infrastructure is in place, including transportation systems. All of this can be supported by a creative land use policy that mixes land uses and encourages density. We must promote the integration of land uses, not their separation, as our premier land use policy.

No omnibus policy can be equally helpful or effective with the wide array of so called “industrial” uses. Any proposed restrictions must distinguish among “industrial” uses. Yet, the security already is in place through the entitlement process to police real conflicts of co-location or conversion. This draft of the co-location portion of the General Plan update needs to be sent back to the drawing board.

Gary London’s firm, The London Group Realty Advisors Inc., has available on its Web site — londongroup.com — a white paper on its analysis of the proposed co-location rules.