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Bettesworth Construction
CEQA

San Diego’s Midway Rising: What the $3.9B Proposal and CEQA Ruling Mean

The Court of Appeal found San Diego’s environmental review for a planning-area height-limit ballot measure inadequate. That ruling is separate from review of the Midway Rising redevelopment plan.

By Bettesworth Construction Team 5 min read
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Midway Rising is a proposed redevelopment of San Diego’s Sports Arena site, not a project the Court of Appeal rejected outright. The court ruled that the City’s environmental review for a ballot measure to remove the area’s 30-foot height limit was inadequate. That planning-area ruling is distinct from the environmental review of the Midway Rising plan itself.

What Midway Rising proposes

The City of San Diego describes Midway Rising as a redevelopment of approximately 49 acres at the Sports Arena site. City Council selected the proposal on September 12, 2022. It combines housing, an arena, open space and entertainment uses.

  • Housing: The City’s project page lists 4,250 homes: 2,000 affordable to households earning 80% of Area Median Income or less, and 2,250 market-rate homes.
  • Arena: A proposed 16,000-seat venue.
  • Open space and other uses: A multi-acre central urban park and an entertainment, arts and cultural district.

The City identifies Chelsea Investment Corporation as the affordable-housing partner, Legends as the sports-venue development and operations partner, and Zephyr as the market-rate housing partner. It says Kroenke Group joined as an equity investor in June 2023. The City also says the proposal received “first priority” under the Surplus Land Act because it offered the highest total number of affordable units among redevelopment teams; that is the City’s explanation, not an independently audited comparison.

The headline figure of $3.9 billion is Axios San Diego’s characterization of the project in a February 5, 2026 update. The City project page and the state CEQA portal filing cited here do not independently confirm an official or final project budget, so the figure should be read as a reported estimate.

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Why the reported home counts differ

The City’s project page gives a total of 4,250 homes, while the California CEQA portal’s Midway Rising Specific Plan filing lists 4,254 residential units on 49.23 acres and 130,000 square feet of commercial development. Those are figures from different documents; the four-unit difference should not be silently reconciled into a single number.

Two environmental-review questions, with different scopes

The central legal distinction is between changing a height rule across a planning area and reviewing a specific redevelopment proposal. The Court of Appeal case addressed the first question. CEQAnet’s 2025 filing concerns the second.

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Question Planning-area height-limit measure Midway Rising Specific Plan
Geographic scope Midway-Pacific Highway planning area Sports Arena redevelopment site, listed as 49.23 acres in the CEQA filing
Decision under review Whether to remove the 30-foot building-height limit across the planning area Environmental review of the proposed site-specific plan
Review at issue The City’s supplemental environmental impact report for the second ballot measure CEQAnet lists a public review period of March 24 to May 8, 2025
What the cited record establishes The Court of Appeal found the review inadequate and remanded for CEQA compliance The filing identifies the plan and review period; it is not the subject of the appellate ruling

What the court found about the 30-foot limit

San Diego voters established the Coastal Zone’s 30-foot building-height restriction in 1972. The later appellate opinion describes its purposes as preserving coastal views and community character and addressing concerns including congestion and pollution.

In 2018, the City adopted the Midway-Pacific Highway Community Plan Update and a program environmental impact report that assumed the height limit remained in effect. A 2020 ballot measure sought to remove the restriction. The City’s environmental review was challenged, and that measure was invalidated; the appellate opinion says the 2018 program EIR had not considered the change.

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For a second ballot measure, the City prepared and certified a supplemental EIR in 2022. In Save Our Access v. City of San Diego, published October 17, 2025, the Fourth Appellate District, Division One held that the City had not meaningfully analyzed the potential environmental effects of allowing buildings above 30 feet across the planning area. It reversed the judgment for the City and remanded with directions to grant the petition and require CEQA compliance.

The court’s concern was broader than views and neighborhood character. It concluded that the City relied on the 2018 program EIR for impact categories that had not actually examined taller buildings, and that deferring those analyses to later site-specific projects was not enough to inform the public and decision-makers about the ballot measure. The opinion emphasized the importance of evaluating an area-wide planning change, particularly where later legislation might exempt some site-specific projects from further CEQA review or streamline their review.

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What the ruling does—and does not—mean for construction

The appellate decision is a CEQA compliance ruling on the City’s 2022 height-limit measure. It is not a finding that Midway Rising itself would cause unlawful environmental harm, a rejection of the project-specific EIR, or an order prohibiting the redevelopment. For construction and project-delivery stakeholders, the distinction matters: the ruling concerns the planning framework for building height across the area, while the specific plan has its own environmental-review record.

CEQAnet’s 2025 filing lists review topics for Midway Rising including air quality, biological and cultural resources, drainage, flooding, geology, greenhouse gases, hazards, hydrology and water quality, noise, public services, sewer capacity, transportation and utilities. The filing also lists aesthetics, cumulative effects, land use, housing, recreation and solid waste. That list describes the subjects identified in the project-specific filing; it does not establish the outcome of the review or resolve the separate height-limit litigation.

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Key dates and the status established by the cited record

  • 1972: Voters establish the Coastal Zone’s 30-foot height restriction.
  • 2018: The City adopts the community plan update and program EIR, which assumes the restriction remains in place.
  • 2020: The first ballot measure to remove the limit is invalidated after an environmental-review challenge.
  • 2022: The City certifies a supplemental EIR and approves a second ballot measure for the November ballot.
  • March 24–May 8, 2025: CEQAnet lists the public-review period for the Midway Rising Specific Plan filing.
  • October 17, 2025: The Court of Appeal publishes its decision on the second height-limit ballot measure.
  • October 20, 2025: Mayor Todd Gloria says he will ask the City Council to authorize an appeal to the California Supreme Court and announces a one-year extension of the exclusive negotiating agreement, through December 4, 2026.

The mayor’s announcement records an intended request to appeal, not confirmation that an appeal was filed or decided. The cited material also does not establish a final lease, final project approval, or whether later legislation changed the project’s legal footing. Accordingly, the October 2025 ruling and the mayor’s stated response should not be treated as a definitive account of the project’s status in October 2026.

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