On March 12, 2014, the WhatPriceMainStreet group sent a letter to Mayor Faulconer requesting that he direct his staff to take a final look at the One Paseo Environmental Impact Report (EIR) before releasing it as a final document. Our concern is that the Draft Environmental Impact Report (DEIR) appeared to us to be biased toward the developer. In our view the processing of the project has skipped important and required steps, the written DEIR shows substantial lack of objectivity, some of the evaluated alternatives were dismissed out-of-hand even though they could have led to a more appropriate development, and the traffic analysis contains major deficiencies. Read the full text of this post (below) for the complete letter to the Mayor.
We are requesting that local residents support this effort by also sending letters to the Mayor, asking for one final review of the DEIR to ensure its objectivity. Please go to our "Write a Letter" Page for additional information on how you can help!
Here is our complete letter to Mayor Faulconer:
March 12, 2014
Mayor Kevin Faulconer
City Administration Building
202 C Street, 11th Floor
San Diego, CA 92101
Dear Mayor Faulconer,
Congratulations on your inauguration as the new Mayor of San Diego. We are enthused by your commitment to neighborhoods, the importance of Community Plans and the engagement of Community Planning Groups in changing those Plans. Especially, we note your promise to work with City staff to ensure the City Council is provided the most accurate and objective analysis of any project application that necessitates a significant Community Plan change.
In that vein, the WhatPriceMainStreet coalition of concerned residents must bring to your attention the One Paseo project application in Carmel Valley. Having completed recirculation of the Draft EIR, the Final EIR will soon be released, initiating statutory time lines for the final hearing and decision by the City Council.
Our concern is that the City staff has allowed the DEIR to move forward with what we consider to be glaring errors and significant bias toward the applicant, giving the City Council an inaccurate view of the project alternatives and their projected impacts. Specifically:
- No Community Engagement on Project Goals or Scale. The original planning for the project included no input on the needs or desires of the community, the bulk & scale of the development, or acceptable impacts to local facilities (streets, parks, schools.) The Carmel Valley Community Planning Board has noted in its comment letter to the DEIR: “Community Planning Engagement Process Was Ignored. The Project Description goals/objectives were not the result of a community planning engagement process set forth in the General Plan.”
- The recirculated DEIR Lacks Objectivity and Common Sense. The original DEIR contained alternatives that seemed so unreasonable that the City required additional alternatives to be studied in a Recirculated DEIR (RDEIR). Alternatives from the RDEIR were then dismissed out of hand as not meeting project objectives, even though some of them contained all the same uses as Kilroy’s proposed “reduced alternative.”
- Traffic Analysis Contains Major Deficiencies. The DEIR’s traffic study contains many shortcomings, including creative analysis of traffic generation and parking requirements, dismissal of evidence that SANDAG traffic forecasts don’t include all future sources of traffic generation in Carmel Valley, lack of analysis of the 15 year period before the SR-56 Connectors are projected to be completed, and no consideration that the connectors may not be built at all.
We are NOT a “no development” group. Rather, we support an appropriate mixed-use center, and look forward to a City Council decision that yields a project that not only creates a vibrant new development of office, retail and residential uses, but one that fits within our existing infrastructure capacity including the remaining, but as yet unbuilt, entitlements in the Community Plan.
However, this can only happen if the Executive Summary issued by City staff and the study documents supporting it are objective, and contain a complete description of reasonable reduced scale project alternatives with sufficient information and analysis to objectively evaluate them.
We request that you have an objective and knowledgeable person on your staff review the existing DEIR documents, the many comments to them, and the final responses being formulated for City staff’s inclusion in the Final EIR prior to the issuance of the FEIR. If that person finds that there is validity to the assertions made above, we request that you require that the document be corrected.
The following pages contain some additional information on these issues for your review.
Thank you for your consideration.
3525 Del Mar Heights Rd. #613
San Diego, CA 92130-2122
Alternatives in the Recirculated DEIR
The original DEIR contained alternatives that seemed so unreasonable that the City required additional alternatives to be studied in a Recirculated DEIR. The RDEIR provided 3 new alternatives:
|Alternative||No. Sq. Ft.||Traffic generated compared to Current Entitlement|
|Reduced Main Street||1,458,569||23,853 Average Daily Trips (4.0X current)|
|Reduced Mixed Use||817,800||11,001 Average Daily Trips (1.8X current)|
|Specialty Food Market||80,000||6,500 Average Daily Trips (1.1X current)|
|Current Entitlement||510,000||5,977 Average Daily Trips|
The Reduced Mixed Use alternative, which might potentially have acceptable traffic impacts, was dismissed out of hand as not meeting project objectives-- even though it had the same uses as the Reduced Main Street alternative (which the developer had promoted as an acceptable concession) and the project objectives had no quantifiable parameters. There was no traffic analysis to show whether the reduced traffic generation would reduce Traffic and Community Character impacts to below a level of significance.
The original DEIR included a Net Fiscal Impact and Economic Benefit Analysis for the Existing Entitlement and the proposed Project. The recirculated DEIR did not include any similar analysis for the new alternatives. In order for a decision maker to make an informed decision regarding the reduced alternatives included in the RDEIR, it should be able to understand the benefits from each alternative and compare it to the negative impacts.
The One Paseo traffic study does not address the 15-year period between project completion in 2015 and the assumed construction of two I-5 to SR-56 connector ramps in 2030. The two connectors, if and when completed, are projected to reduce traffic at Del Mar Heights Rd. and I-5 by 9,100 Average Daily Trips (ADT). Therefore, subsequent to completion of One Paseo but prior to the completion of the two connectors, traffic would approach 9,100 ADT above levels reported in the DEIR for 2030, and even those are worse than what is considered unacceptable by City standards.
Furthermore, the rationale for the two connectors being proposed was to improve functionality of the I-5 and SR 56 freeways and reduce “by-pass” traffic through Carmel Valley from drivers seeking to avoid the known I-5/SR 56 congestion. The I-5/SR 56 Connector Study contained no objective to facilitate development in neighboring communities above existing planned entitlements.
One Paseo, if allowed to be built at what the developer considers the minimum acceptable, will generate more traffic for Del Mar Heights Rd. at I-5 than would be mitigated by the two connector alternative. It will be appropriating the proposed mitigation for its own benefit. Carmel Valley residents will not only never see the traffic mitigation of the proposed $180 million freeway improvement, but will also experience traffic congestion at a much worse level than disclosed in the DEIR until such time as the two connectors are completed.
The DEIR traffic study projections for 2030 are based on Caltrans’ I-5/SR 56 Connector traffic study, which, in turn, is based on SANDAG’s Series 10 traffic projections done in 2006. Data for the Series 10 Traffic Analysis Zone 1742, which corresponds to the Carmel Valley Community Plan’s Town Center zone, data shows a projected increase in traffic from 2010 to 2030 of 3,437 ADT. The existing Del Mar Highlands Town Center has a remaining entitlement to build 150,000 Sq. Ft. of community retail, while the adjacent vacant 3.8 acre Pell property would be entitled to build 125,000 Sq. Ft. of community retail. According to San Diego’s Trip Generation Guide, there would be 19,250 ADT generated from these two remaining entitlements.
When confronted with this very significant discrepancy between SANDAG’s projections and the expected trip generation by City standards, City staff responded only that the Series 10 projections included the acreages of the Del Mar Highlands Town Center and the Pell property. It completely ignored the evidence that the 2030 projections in the traffic study do not include all the remaining entitlements in the Carmel Valley Community Plan. The methodology of the traffic study allowed by City staff clearly does not reflect the “Community Plan at Buildout” scenario, which is required by the San Diego Traffic Impact Study Manual.