Clairemont and College Area Community Plan Updates to Be Considered by City Council Dec. 16
[This post has been updated to include links to referenced documents.]
By Donna Frye
Significant, unmitigated, unavoidable but acceptable may soon become the city’s new mantra for describing and addressing environmental impacts when it comes to updating community plans.
And Hillcrest and University may soon be the last two communities to have had an environmental impact report prepared for their community plan updates.
That’s because the city has decided that the July 2024 Programmatic Environmental Impact Report (PEIR) for the Blueprint SD, Hillcrest Focused Plan Amendment and University Community Plan Update (2024 PEIR) is the appropriate environmental document for analyzing the Clairemont and College Area Community plan updates and most likely any future community plan updates.
Instead of each community having an environmental analysis of its own, the city has issued an addendum to the 2024 PEIR for Clairemont and the College Area community plan updates.
Some of the impacts identified as being “significant and unavoidable” in the 2024 PEIR include air quality, biological resources, cultural resources, public services such as fire protection, police protection, schools and libraries, deterioration of parks and recreational facilities, and construction or expansion of recreational facilities.
The 2024 PEIR states that “mitigation measures do not exist or are considered not feasible.
Also according to the city’s addendum for Clairemont and the College Area because “there are no new or more severe significant impacts that were not already addressed in the previously certified Blueprint SD PEIR…” and the impacts caused by the unmitigated environmental impacts have been “found acceptable because of specific overriding considerations.”
Even though the city did not do a PEIR for Clairemont or the College Area they have concluded that the significant and unmitigated impacts are acceptable.
They also imply that nothing has changed, there is no new information and the information they had about Clairemont and the College Area in the summer of 2024 is sufficient. Therefore, there is no need to do further environmental analysis such as a supplemental environmental impact report because the city knew all it needed to know back then.
But even if the city is all-knowing, how in the world would anyone in the public know that their ability to participate in the California Environmental Quality Act (CEQA) process and comment on the environmental document for the Clairemont and College Area community plan updates was going to be limited to an environmental document issued over a year ago for two other communities?
It makes no sense because it’s more city nonsense.
It’s been standard practice for the city to comply with CEQA by preparing a PEIR to analyze general plan and community plan updates.
That’s because it helps identify any adverse environmental impacts that could result if the plans are implemented. A PEIR also requires the city to identify mitigation measures that could avoid or substantially lessen any identified adverse environmental impacts and provide an analysis of alternatives to the plan.
Most importantly, the preparation of a PEIR allows the public to receive notice of what the city is proposing, provide written comments and receive responses to their comments before the plan is made final.
Even though the city implies that nothing has changed since the summer of 2024 and there is no new information that could impact the communities of Clairemont and the College Area over and above what was already analyzed, I disagree.
For example, since the 2024 PEIR was approved there has been lots of state legislation that increases the density allowed in communities, over and above what was analyzed over a year ago.
New state laws such as SB 79 set new density and height standards for projects located near transit. There was AB 130 which exempted many infill housing projects from CEQA review and AB 893 and AB 2011 that allow some housing in commercial corridors to be approved ministerially.
Those are just some of the new state laws that increase building density and height and decrease the public’s right to participate. None of it was analyzed because it happened this year, long after the 2024 PEIR was approved.
And what about the changes to the Clairemont Community Plan such as an amendment to the General Plan, an amendment to the Land Development Code, an amendment to the Balboa Avenue Station Area Specific Plan, an amendment to the Morena Corridor Specific Plan and a rezone action?
How did the 2024 PEIR analyze those issues when they had not yet happened? Do they have a secret crystal ball in the planning department that can predict the future that we don’t know about?
In other words, the city prepared an environmental document in 2024 that they claim addresses all the environmental impacts in both Clairemont and the College Area, so an addendum is all that is needed.
I always thought that an addendum was for minor technical changes or additions, not for comprehensive community plan updates and amendments.
I don’t consider a comprehensive community plan update a minor technical change or addition. Interestingly, the city can’t seem to decide which it is- a comprehensive update or a minor technical change.
It’s own resolution to adopt the addendum states on page 2 that “ The City of San Diego has comprehensively updated the Clairemont Community Plan (Clairemont CPU)” yet on page 4 it says, “… only minor technical changes or additions are necessary…”
Similar statements appear in the College Area resolution to adopt the addendum. On page 2 it states, “The City of San Diego has completed an amendment to effect a comprehensive update to the College Area Community Plan…” yet on page 4 it states, “only minor technical changes or additions are necessary,…”
Worse, addendums do not require public input so the people who live in Clairemont and the College Area have been effectively shut out of the CEQA process. They have been denied the opportunity to provide written comments on the environmental impacts, that according to the city, would be significant, unmitigated, unavoidable but acceptable.
Further environmental analysis would have allowed alternatives to each of the plans to be analyzed and considered. That analysis could help reduce or mitigate the environmental impacts specific to each community.
I am not saying that the city has to start from scratch on their analysis. It would make sense, however, to do a supplemental environmental impact report and analyze the changes that have occurred since July 2024. This would allow the public to participate in the analysis that will impact their communities for years to come.
That doesn’t seem unreasonable and would show some respect and concern for the people in Clairemont and the College Area who live in the impacted communities.
On December 16, 2025, the San Diego City Council is scheduled to hear the Clairemont and College Area Community Plan Updates and addendum to the 2024 PEIR. When the agenda is posted, please send a comment to the city council asking that they postpone approving the 2024 PEIR addendums to the Clairemont and College Area Community Plans and instead direct staff to prepare a Supplemental Environmental Impact Report for both community plan updates.
I’d look into my crystal ball to predict the outcome of the vote, but it’s a bit hazy. What I do see is the same problem happening in City Heights, Eastern Area, Kensington-Talmage, Normal Heights, Rancho Bernardo and Otay Mesa Nestor when their community plans are updated.
This is like hiring staff to study the impacts of getting punched in the face, and concluding that it’s gonna hurt like a bitch, and then doing it anyways.
Thank you Donna for this excellent analysis. In particular, for reminding us of how much of what the City proposes is on top of various state actions which have occurred in the past 2 years (2024-2025) that couldn’t possibly have been considered when developing the 2024 PEIR. It’s way out of date now.
Thanks for the analysis. What catches my eye in the Addendum is the reference to SB99 and AB747 which require evacuation routes as part of the Safety Element. I have still nto seen any evacuation routes published. SDFD has stated they set up evacuation areas based on a number of factors which does not reall address the question of unplanned egress. Leaving Normal Heights encounters traffic jams by commuters every morning. It would be doubled with a fire raging.
Excellent Donna!!! I started the lawsuit against the City of SD called Save 30th Street Parking, in 2019. I kept looking on the CA website trying to find where they did a CEQA. Finally I asked Everett Hauser, Transportation Project Mgr. for 30th. St., if one was done. He said it was “exempt”. When we went to court our Attorney, Craig Sherman asked the City for it, and they said there was not one. One of the things I discovered in reading the CEQA (Calif. Environmental Quality Act) applications, was the City of SD had a wordsmith that made what they did on 30th. read like it was no big deal. In reality, it changed a whole lot of 30th. St. and the surrounding residential neighborhood, and the air quality. In fact the neighborhood of Burlingame will have a hard time getting any emer vehicle to their home now. Because the City removed the center turn lane, used for on/off loading merchandise for the businesses/residents, AND an escape route for emer vehicles if they’re trapped mid block. I presented that scenario to the Fire Dept. that serves that area (Sta. 14). They said they’d call FD Dispatch, and they would send units from Hillcrest and Golden Hill. Both are really congested most of the time. Thanks for the heads up on the Council Meeting. Residents of SD would be better off if you would run for Council and help get the ones against the people out of there.