CEQA – Our comments

Today Play Outside Del Mar submitted its environmental comments on the Del Mar Heights Elementary School Project.

Please click here to download our CEQA Comments or skim the table of contents without downloading.

Extensive time and research went into these comments, and you may want to review them before submitting your own comments to DMUSD.

For those of you not familiar with CEQA, it is California’s signature environmental law, designed to inform and protect the public. 

In a nutshell, DMUSD has filed an environmental document called a Mitigated Negative Declaration (or MND) on the Heights’ school rebuild.  The MND claims that it is not possible for anyone to make a fair argument that any aspect of the Heights’ rebuild project will have a significant impact on the community environment. “Environment” in this context means: recreational facilities, parks and fields; local traffic, air quality, noise, scenic views, biological resources, wildfire risk, evacuation risk, and other things within the community environment. 

We disagree with DMUSD on three main issues – playfields and blacktop, traffic, and wildfire risk.

Our focus was to show that on those issues, there is indeed a fair argument to be made for a substantial adverse effect on our community – and therefore that the MND is an improper shortcut.  Instead, we believe the community deserves a full review of these issues where both sides of the argument are weighed and considered, and where alternatives can be considered that lessen the impact on the community.  That’s called an Environmental Impact Review or EIR.

In more detail, we said:

1 – Slashing the playfields by 50% (from 160,00 square feet to 78,000 square feet) and the blacktop by 56% (from 49,000 sf to 21,500 sf) creates a substantial adverse effect on our public resources and community parks.

2 – Changes in parking, traffic, and student population driven by the project will create a substantial adverse effect on community traffic.

3 – The project design changes the existing school in a way that creates a substantial adverse effect on wildfire risk at the site and in the community – and a time evacuation study must be done for the sake of the parents, students, staff, and Heights community that would need to evacuate the area.

You’ll see we commented extensively on wildfire risk, which may come as a surprise to a few of you. Those issues came to light when we were working with fire experts to evaluate Rolf Silbert’s alternative design. We feel the public has a right to know.

Any citizen can submit a comment on the MND and encourage DMUSD to acknowledge that their are two sides to the argument and that an EIR should be conducted.

Here’s a link that allows you an effortless way to comment. Click here and It will open a draft email with bare bones comments similar to paragraphs 1-3 above. You can add whatever comments you like or delete ours and make your own from scratch. Make sure and insert your name at the end.

Comments must be sent by 5:00 p.m. this Monday, March 30.

Stay safe and healthy.

John

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