Dear Friends of UC,
This is the first of two posts in the next day or so regarding our responses to the City’s latest drafts of the Community Plan and the EIR for University City.
This email discusses our comments on the Draft Program Environmental Impact Report (DPEIR) prepared by the City in association with the University Community Plan Update. We submitted these detailed comments to the City on April 25, 2024.
As discussed in our prior communications, we are disappointed by the City’s failure to perform little to no quantitative analysis of the environmental impacts of adding 30,000 more dwelling units (potentially more than doubling the current population of the area - or more). Most of the City’s “analysis” is qualitative with the catch-22 conclusion that the City can’t do a specific analysis because it doesn’t know what will actually be built. However, as detailed in our comments, HSUC believes that for a program-level EIR (which removes the requirement that future projects perform their own EIR), the City must do an analysis of the quantitative impacts assuming full build-out of the Plan.
Community comments on the EIR must be submitted by Monday, April 29, 2024 to planningceqa@sandiego.gov. Please note this is a different city email address than we use for plan update comments.
You may also want to copy Mayor Todd Gloria at mayortoddgloria@sandiego.gov, Councilmember Joe LaCava at JoeLaCava@sandiego.gov, and Councilmember Kent Lee at KentLee@sandiego.gov.
If you agree with our recommendations (which are lengthy at over 20 pages!) we encourage you to submit your own comments on the EIR. The following sample email summarizes our main points. Please feel free to use it.
To Whom It May Concern:
I am submitting comments on the Draft Program Environmental Impact Report (DPEIR) for Blueprint SD Initiative, Hillcrest Focused Plan Amendment to the Uptown Community Plan and University Community Plan and Local Coastal Program Update - Document issued March 14, 2024.
My comments are with respect to the analysis performed for the University Community Plan Update. I support all of the comments submitted by Help Save UC dated April 25, 2024. I especially want to comment on the following:
The City should prepare a DPEIR specific to the University Community Plan Update. Combining the Blueprint San Diego program, the Hillcrest Plan Amendment and the University Community Plan Update into one document made the document confusing, overwhelming and not accessible to the public, thus failing CEQA’s requirement to provide an informational document to inform the general public of the significant environmental effect of a project.
The City’s failure to evaluate the full environmental impacts of the University Community Plan Update at full buildout, including the impact of the Complete Communities program, makes the document inadequate, specifically for areas such as Aesthetics, Air Quality, Biological Resources, Greenhouse Gas Emissions, Noise, Public Services, Recreation, Transportation, and Wildfire.
The City’s failure to conduct an updated traffic study to support the reduction of Governor Drive to two lanes renders the DPEIR inadequate.
The DPEIR is inadequate due to its failure to evaluate appropriate alternatives. It is disingenuous for the City to evaluate the High Density Alternative (formerly known as Scenario 1) that was no longer under consideration for the University Community Plan Update. The City is supposed to evaluate alternatives that are feasible and capable of avoiding or substantially lessening any significant effects of the project. The appropriate way to do that would have been to evaluate a lower density alternative, such as the “community-preferred alternative” (Scenario B) in the City’s last draft of the Plan Update. Instead, the City evaluated a Higher Density alternative that the City admitted wasn’t feasible.
Finally, the City’s conclusion that the High Density Alternative was the environmentally superior alternative isn’t supported by the evidence. Table 8-1 shows that the High Density alternative results in greater impacts on the environment. Furthermore, the City’s own conclusion states, “No significant impacts of the project would be completely avoided by this [High Density] alternative and on the balance, impacts would slightly increase compared to the project.” (Section 8.2.3, underline added.)
The City should revise the DPEIR to address these issues.
Next Steps
In the next day or so, we will also post our comments on the March 2024 Second Draft of the University City Plan Update, so please be on the lookout for that.
Sincerely,
Help Save UC