After months of rigorous debate on the Heights’ new school design and submittal of substantial factual comments on the MND by Sierra Club, Play Outside Del Mar, Save the Field, and many citizens such as yourselves, I believe there’s little more that needs to be said about the environmental process. As lawyers are keen to say after the witnesses are done and the documents have been put into evidence: the facts are in.
Sure, there’s going to lots more talking, and based on what I’m seeing, a lot of personal accusations, finger-pointing, and no end of speculation about motivations of players on both sides.
But at the end of the day, we have the facts and we have the judges. The facts stand naked and alone, without motivation or agenda, and the DMUSD Board of Trustees has to decide what to do on CEQA based on the law and facts. It’s a weighty decision that is considered so important and fundamental under the law, that the law forbids the Board of Trustees from delegating a final decision on a Negative Declaration to consultants, staff, or anyone else. It’s on the Board of Trustees – them alone.
We hope that after the arguments stop, that our elected trustees will put the children’s safety first and make the right decision that will impact Del Mar’s children for the next fifty years or more. Will they get it done right for the children and community based on the facts presented and the law, or will they just insist on getting it done NOW because that’s what they want and because one side or the other is pushing them harder?
There are many important issues raised by the CEQA filings, and I don’t want to diminish the importance of any of them – legally or factually. But today I want to focus on wildfire risk. If you read my CEQA comments for Play Outside, you’d know I spent 23 pages of detailed analysis on this. I also explained how I got wind of these issues: I wanted to make sure Rolf Silbert’s alternative design complied with fire codes and was safe for the children and the residents nearby – before putting Play Outside’s name (and my own) behind it. Those days have passed, but my knowledge did not disappear, and I’m not the type to bury it.
Heights’ residents and prominent organizations such as the Sierra Club have voiced genuine and well-founded concerns about the fire safety of the proposed new school design. We stand on this side. We say these issues are too crucial to be buried, but instead have to be seriously studied and understood in an EIR and wildfire time evacuation study before moving ahead.
Others have claimed the current school is irremediable – a rat infested dump, a longstanding safety hazard for students – and that those signs point to moving full speed ahead right now, no matter what flaws there may be in the current design. We don’t stand on this side.
At Play Outside, we believe the elevated wildfire risk caused by substantial design changes must be addressed rather than ignored. And we believe a wildfire evacuation time study must be conducted to analyze whether the new site configuration and the neighborhoods can be safely evacuated under the pressure of time, particularly with 16% of the children at the school being students with disabilities. These safety issues won’t ever go away – even after all of us have left the conversation and have long been forgotten. The Sierra Club and Save the Field comments echo our concerns.
Here is a summary excerpt of public comment provided to DMUSD by Play Outside Del Mar:
The site location presents unusual inherent hazard because it is surrounded more than 180º by the Torrey Pines Nature Reserve Extension. The Reserve Extension presents a potent combination of factors that could cause high rate of spread (ROS) of wildfire – 197 acres of abundant dry fuel that is protected, under beetle attack, and often cannot be removed due to site topology and density; extensive human interface around the Reserve; average 17% upslopes to the school site, increasing to 38% just before you reach the buildings; south facing aspect; prevailing westerly winds toward the school; increasing local temperatures with increasing Santa Annas; and difficult terrain that has made past fires in the Reserve difficult to reach and control.
No EIR or time evacuation study for the site (which is increasingly considered a standard best practice) has ever been conducted. The new school design makes several site changes that enhance wildfire risk compared to the existing school. The only fire road able to access the core of the school site runs tight alongside the western rim of the heavily wooded area of the Reserve – potentially block-able by wildfire either before or after emergency vehicles arrive. All buildings have been moved closer to the edge of the Reserve, with the 27’ 7” awning of the tallest and most vulnerable (the Innovation Center) less than 20’ from the drop-off into dense woods and vegetation. The 100’ defensible space requirement for wildfire interface is not met and is ignored in the MND. The preexisting 160,000 sf fire buffer of play field grass between the school buildings and the reserve has been shrunk in half to 78,000 sf, with all buildings scooted closer to the Reserve as a result.
All of these factors suggest extra care needed to be taken into designing a failsafe plan to get emergency vehicles on site and to evacuate others, yet inexplicably the east fire access road (which could possibly be the only one operable during a high ROS wildfire) seems ripe for congestion rather than smooth evacuation and entry of emergency vehicles. It combines emergency access with bi-directional traffic, drop-off, pick-up, 45 perpendicular parking spaces that pull-out directly into the fire lane, and a merger of lanes at the turnaround. There are only two pedestrian exits to the school – with walls and fencing still preventing egress directly to the East. This issue is ignored in the MND.
The MND’s justification for avoiding an EIR is based on a foundation of key errors or falsehoods. Among the worst are misstatements that there is a fire road “around the entire campus,” and that the area around the site is “predominantly flat.” The specific questions from CEQA about “prevailing winds,” “uncontrolled spread of a wildfire” and “other factors” are ignored.
Click here to page through the slides of our full 23 page fire analysis in plain English.
These facts and many others are in. After today, it’s time to let the trustees decide whether to protect Del Mar’s children from a potential wildfire and insure a safe school no matter how remote the possibility may seem (to some) today. As we all “shelter at home” under the unimaginable reality of a pandemic that is destroying lives and the economy, let’s not ignore that the unimaginable can happen, and when we have the facts on hand we can’t responsibly ignore them to the detriment of the children of today and tomorrow.
If you want to email the Board of Trustees, here’s a link that will open a properly addressed blank email.