The Carmel Valley Recreation Council, a community volunteer group formed to provide the City of San Diego with local community input on City Parks, decided to comment on the Recreation Element of the One Paseo DEIR because of perceived errors in the parks analysis. You'd think this would be the perfect group to comment, as the members are very familiar with the local parks and their use. The item was added to the agenda and the meeting was announced at last week's Planning Board meeting, which was attended by representatives from Kilroy. Somehow, in the short time between these meetings, the City decided it wasn't appropriate for the Council to comment on the DEIR!

Was there outside pressure to stop the Council from taking action, or did the City simply decide on its own? The current line from the City is that Recreation Councils aren't allowed to comment on land use in the community, even if it impacts local recreation.

So, what was so controversial in the Council's letter? Well, you can read the letter yourself (download 2012-parks-letter.pdf). There are three basic points:

• First, that the City's park analysis was incorrect, counting parks that should not be included. This led to the conclusion that we have excess park land, which everyone who has kids on sports teams knows is blatantly wrong. Every year, Carmel Valley has to turn away children who want to play sports because we don't have adequate facilities.
• Second, while Kilroy will pay a fee to the City to cover their park impacts, it doesn't really help because there isn't any land available to purchase for a new park! By City standards, Kilroy should have to add more than 4.5 acres of park land to serve the new residents in the development. But, if Kilroy doesn't include that park land on their site, there isn't anywhere else to put it.
• The third point is that Kilroy must include an alternative development plan in the DEIR that includes a new park. That's not hard to do, here's a letter I wrote to the Planning Board (20120426_cvcpb_letter.pdf) that includes such a plan on page 3.

Note that it appears that, in its processing of the One Paseo DEIR, the City itself has decided to reclassify certain greenbelts and parks that should not be counted in the development application. This reclassification could result in sports teams and other active use activities being permitted on formerly passive areas. What is being done shouldn't have been allowed, but the City is relying on a broad interpretation of new policies that were inserted into the General Plan in the last update. Here's yet another City policy that allows the developers to build these oversized projects without accompanying updates to the local facilities and infrastructure.