Imperial Avenue Terminal (IMT) North Transit-Oriented Development (TOD) Project – Disposition and Development Agreement

Imperial Avenue Terminal (IMT) North Transit-Oriented Development (TOD) Project – Disposition and Development Agreement

On October 16, 2025, the San Diego Metropolitan Transit System Board of Directors adopted Resolution No. 25-13 finding the Imperial Avenue Terminal North Transit-Oriented Development (TOD) Project is a By-Right, Ministerial Downtown Development Project that is Exempt from Environmental Review under the California Environmental Quality Act; the TOD Project is Within the Scope of Development of City of San Diego Plans and Programs Covered in Prior Environmental Impact Reports and No Further Environmental is Required; the TOD Project is Further Exempt from Environmental Review under Public Resources Code section 21080.40 as a One Hundred Percent Affordable Housing Project; and Approving the TOD Project. The Board also authorized MTS’s Chief Executive Officer to execute a Disposition and Development Agreement (DDA) with SDHF 12th & Imperial, LLC for the TOD Project and to take all actions necessary to fulfill MTS’s obligations under the DDA, including, but not limited to, executing a Ground Lease and related regulatory agreements for the project. The TOD Project consists of a six-story mixed-use building with approximately 161 affordable residential units (280 bedrooms) and residential amenities. The concept for this project includes one-, two- and three-bedroom apartments along with limited first floor resident parking (estimated 96 total spaces), common area open space, resident bike storage, and a property management office. The TOD Project is anticipated to be ready for Ground Lease execution and construction to begin in early 2028. Construction is estimated to take 18 to 24 months. The rental units shall remain affordable to, and occupied by, lower income households for a period of at least 55 years. All units shall be rent restricted according to TCAC or CalHFA program requirements, except for two staff units. The 12th and Imperial Transit Center located adjacent to the TOD Project is one of the busiest in the region, offering service on all trolley lines and four major bus routes. The TOD Project would provide housing, jobs, and services adjacent to the transit center consistent with MTS Board Policy 18, Joint Development Program, which aims to promote high quality housing on or near the transit system. The TOD Project would also increase ridership for MTS while contributing to environmentally sustainable livable communities that are focused on transit access. Separate and distinct from the TOD Project, in October 2022, MTS adopted Resolution No. 22-12 approving the expansion of the bus passenger facilities at the IMT to include the National Avenue Property, just east of the existing transit center (“Transit Center Expansion”). As part of the Transit Center Expansion, on March 4, 2025, MTS applied to vacate portions of 13th Street, Commercial Street, and National Avenue within the proposed consolidated parcel to facilitate the new transit center configuration, which is currently in process with the City of San Diego (City of San Diego Project No. PRJ-1132335). Assembly of the TOD Project site requires the street vacation, but MTS will pursue the street vacation for the Transit Center Expansion regardless of TOD Project. While MTS and the designers of the Transit Center Expansion will work with the TOD Project team to harmonize the design of the TOD Project with the design of the Transit Center Expansion, each project will remain separate and independent of the other, and neither project is dependent on the other. The TOD Project is consistent with the City of San Diego’s General Plan, the Downtown Community Plan, and the Centre City Planned District Ordinance. The TOD Project is also located in a Transit Priority Area and a Sustainable Development Area, and there is no limit on the number of dwelling units permitted. The City of San Diego is the lead agency for the TOD Project under CEQA. Because the TOD Project will be carried out pursuant to the responsibilities outlined in the DDA between MTS and SDHF 12th & Imperial, LLC in reliance on the City’s prior environmental review, as explained further below, MTS is a responsible agency with discretionary approval authority. MTS determined the TOD Project was fully analyzed in multiple Program Environmental Impact Reports (“EIRs”) adopted by the City of San Diego that cover the downtown area, and therefore no further environmental review is required. The TOD Project is consistent with and is covered by the following Program EIRs prepared and adopted by the City, as the lead agency for the TOD Project, and collectively referred to as the “Downtown FEIR”: the Final Environmental Impact Report (“FEIR”) for the Downtown Community Plan (“DCP”), Centre City Planned District Ordinance, and 10th Amendment to the Redevelopment Plan for the Centre City Redevelopment Project (SCH No. 2003041001) certified by the former Redevelopment Agency (“Former Agency”) and the San Diego City Council (“City Council”) on March 14, 2006 (Resolutions R-04001 and R-301265, respectively); subsequent addenda to the FEIR certified by the Former Agency and the City Council on August 3, 2007 (Resolutions R-04193 and R-302931, respectively), April 23, 2010 (Resolutions R-04508 and R-305761, respectively), April 13, 2010 (Resolutions R-04510 and R-305759, respectively), and August 3, 2010 (Resolutions R-04544 and R-306014, respectively), and certified by the City Council on February 12, 2014 (Resolution R-308724), July 14, 2014 (Resolution R-309115), and November 17, 2020 (Resolution R-313302); and the Final Supplemental Environmental Impact Report (“SEIR”) for the Downtown San Diego Mobility Plan (SCH No. 2014121002) certified by the City Council on July 6, 2016 (Resolution R-310561). Development within the DCP area is further covered under the following documents, all referred to as the “CAP FPEIR”: the Final Program Environmental Impact Report for the City of San Diego Climate Action Plan (“CAP”) (Project No. 416603/SCH No. 2015021053) certified by the City Council on January 4, 2016 (Resolution R-310176), the Addendum to the CAP FPEIR certified by the City Council on July 12, 2016 (Resolution R-310595), and the Addendum to the CAP FPEIR for the City of San Diego CAP Update (Project No. 416603/SCH No. 2015021053) adopted by the City Council on August 10, 2022 (Resolution R-314298). Development within the DCP area is also covered under the Complete Communities: Housing Solutions and Mobility Choices Final Program Environmental Impact Report (SCH No. 2019060003) certified by the City Council on November 9, 2020 (Resolution R313279). MTS considered the Downtown FEIR, the CAP FPEIR, and the Complete Communities FPEIR. (CEQA Guidelines, §15168.) The TOD Project is within the scope of the plans or programs covered in the Program EIRs and substantial evidence demonstrates no new initial study or environmental document is required. (See CEQA Guidelines, § 15168, subd. (c)(1).) Any potentially significant environmental impacts of the TOD Project were adequately addressed in the Program EIRs. Accordingly, because the TOD Project would not result in new significant impacts, the TOD Project is consistent with the City’s General Plan, the DCP, and the CCPDO, and therefore is within the scope of the development program described in the Program EIRs and no further environmental review is required. Under Public Resources Code section 21166 and CEQA Guidelines section 15162, there is no change in circumstance, new information, or project changes to warrant additional environmental review for the TOD Project.

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