City Says Environmental Impacts in Community Plan Updates for Clairemont and the College Area are Significant, Unmitigated, Unavoidable but Acceptable
City Council to Vote on December 16 to Approve Plan Updates without Requiring an Updated Environmental Impact Report
By Donna Frye
The following is a letter I sent to the city council on December 14 requesting a continuance on the Community Plan Updates for Clairemont and the College Area and the Overlay Zones.
RE: December 16 City Council Meeting, Items 609, 610 and 611; Request for a Continuance to Allow for the Preparation of an Environmental Impact Report
Dear Councilmember,
On December 16, the San Diego City Council will be voting on whether to approve the Community Plan Update for the College Area (Item 609), the Clairemont Community Plan Update (Item 610) and the Citywide Community Enhancement Overlay Zone and Removal of the Community Plan Implementation Overlay Zone for College Area and Clairemont Community Planning Areas (Item 611).
According to the city, Clairemont and the College Area have not had a comprehensive update to their community plans since 1989 – over 35 years ago. The updates will provide “ a comprehensive policy framework for growth and development over the next 30 years.”
The residents of Clairemont and the College Area are being told by the city that if their updated community plans are approved on December 16, the environmental impacts to their communities such as Aesthetics, Air Quality, Biological Resources, Cultural Resources, Hydrology, Nose, Public Services, Recreation, Transportation, Tribal Cultural Resources, Utilities and Service Systems and Wildfire will be significant, unmitigated, unavoidable, but acceptable.
The city has decided that Clairemont and the College Area will not have a full environmental impact report prepared for their community plan updates, unlike every other community, and is asking the city council to approve the updated plans without providing an updated environmental impact report to go along with it.
The city says that a comprehensive update to a community plan is a minor technical change and does not require an environmental impact report that is specific to those communities.
Instead, the city issued an addendum to an environmental document that was approved in 2024, for two other community plan updates and the SD Blueprint, called a general plan “refresh” that would provide “more meaningful and convenient public engagement opportunities.”
The city states in its findings that it is appropriate to use an addendum because there have been no significant changes since the 2024 environmental document was approved (even though the notice of preparation and scoping documents were prepared in 2021.)
Without an environmental impact report, no alternatives to the community plan updates will be presented to the city council for a vote because an alternatives analysis doesn’t exist.
Without an alternatives analysis, as required when environmental impact reports are prepared, the public is denied the opportunity to submit written comments about how to offset or mitigate any of the environmental impacts to their communities and have them considered by the city council as part of the updates.
The city council will have no discretion to consider other options that could reduce or mitigate any of the significant environmental impacts.
As you well know, an addendum is appropriate for minor technical changes or additions to a project. The comprehensive community plan updates are not minor technical changes or additions. They include comprehensive community rezones, municipal code amendments, density increases, height limit removals to name but a few of the substantial changes.
Plus, a whole lot of state legislation has been enacted since the 2024 PEIR was approved. This includes state budget legislation such as AB 130 and SB 13 and more recent bills such as SB 79. A reasonable argument can be made that the impacts from future development could be much worse than what the city analyzed back in 2024 because of new state laws.
Also, an addendum does not need to be circulated for public review and no public notice is required, unlike an environmental impact report, which requires public notice, a scoping meeting, and responses to the written public comments regarding alternatives to reduce or mitigate the environmental impacts to the community.
We all know there are unintended consequences when new or updated city policies are not fully analyzed. Consider the accessory dwelling unit policy that had to be amended because some of the project approvals by the city defied all reasonable community development standards. According to a December 14 article in The San Diego Union-Tribune, a developer has been approved to build “73 backyard apartments- formally called accessory dwelling units, or ADUs-on a single-family lot.”
And the trash fees that were imposed on San Diego voters at a rate significantly higher than what the ballot material said they would be is now being litigated. It’s another example of what happens without adequate analysis.
Please vote to continue Items 609, 610 and 611. Take the time needed and direct staff to prepare an environmental impact report.
Please do not allow the city to issue an addendum and ignore the unique qualities and characteristics of our individual communities and the significant and unmitigated environmental impacts that have not been analyzed. That’s not streamlining the public process; it’s abusing the public process. Our communities deserve better.
Thank you for your consideration.
Link to December16 meeting agenda: .
Request that the city council continue Items 609, 610 and 611 until an updated environmental impact report is prepared to fully analyze the significant and unmitigated environmental impacts identified by the city in the addendum.
Here is a link to the webform for you to provide comments on Items 609, 610 and 611 for the December 16 meeting.
Additionally, you can call or email the councilmembers directly.
CD1 619-236-6611 joelacava@sandiego.gov
CD2 619-236-6622 jennifercampbell@sandiego.gov
CD3 619-236-6633 stephenwhitburn@sandiego.gov
CD4 619-236-6644 henryfoster@sandiego.gov
CD5 619-236-6655 marnivonwilpert@sandiego.gov
CD6 619-236-6616 kentlee@sandiego.gov
CD7 619-236-6677 raulcampillo@sandiego.gov
CD8 619-236-6688 vivianmoreno@sandiego.gov
CD9 619-236-6699 seanelorivera@sandiego.gov
Thanks Donna. So I surmise that the environmental impacts will be an acceptable disaster of quality of life by the city. Gotcha. No different than the ineptitude of environmental reports with Midway Rising. Good to see the same lack of judgement being applied consistently across the board. No discrimination, you all can live in substandard conditions. Thank you for your attention to this matter.