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Web exclusive:  The article below is more detailed than the article which appeared in the print edition.

Fairgrounds Plan 2008 ... or 1908?
Which Century Are They Living In?
May 2008 | by Dawn Rawls

The 22nd District Agricultural Association, which administers the Del Mar Fairgrounds, issued a Notice of Preparation (NOP) for their 2008 Master Plan Environmental Impact Report (EIR) in late March. Even a quick reading of this document (available on www.sdfair.com under the “News” column) prompts a gasp and the question “Which century are they living in?”

In the early 20th century people thought progress was synonymous with more and more industry and wresting the land into shapes we found more comfortable and profitable. By the 1960s we were learning that unrestrained manufacturing produced polluted water and air, as well as barren, degraded land and toxins causing human illness. Bigger, we found, was not necessarily better.

Californians asserted, through law, that our coastlines were a precious commodity not to be carved up into individual ownership and that the California Coastal Commission was to protect those coastlines and our views of vibrant Pacific. With a new understanding of wetlands, Californians began to protect these rich ecosystems that underpin our ocean fish species as hatching and nursery grounds, host thousands of birds on their migratory routes, and safeguard species of plants and animals that are squeezed out of their native habitat by development.

The Fairgrounds was created in the midst of the San Dieguito Lagoon and wetlands in the 1930s. The fill consumed about 350 acres of wetlands. In the late 1970s, the Coastal Commission reviewed the damage to the Fairgrounds wetlands and gave the 22nd DAA permission to use the Fairgrounds west of Jimmy Durante Blvd as a site they could develop, but put constraints on their use of the dirt parking lots east of Jimmy Durante Blvd.

The East Overflow Lot and the South Overflow Lot (EOL/SOL) could only be used for overflow traffic from the Fair and the Races. These two lots were surveyed for wetlands in 1993 by the Army Corps of Engineers and, even after hard use and multiple scrapings by the Fairgrounds, all of the SOL and more than 1/3rd of the EOL still showed the wetland plants, watery subsoils and periodic flooding that characterize wetlands.

That was the 20th century, now in the 21st century when we have learned about global warming, the need for green technology to save water and energy, and decades-long efforts to preserve the San Dieguito River Valley and Lagoon as the San Dieguito River Park, just what does the Fairgrounds propose in its Master Plan? Despite 30 years of reminders from the Coastal Commission, the Fairgrounds plans to pave over the entire EOL and parts of the SOL. Despite citizen complaints of traffic impacts during all of the summer and a growing number of other weekends, the Fairgrounds wants to go into the convention center business – as many meetings as they can book.

And where will this convention center be? One massive building, more than ¼ mile in length will consume the northern bank of the river west of Jimmy Durante Blvd. The hotel rises more than 60 feet high and the exhibit/meetings area will top 50 feet high area. A tower will claw the sky at a height of 85ft.

Do we want this dam-like structure, with a veneer of “mission style” makeup, sitting in our river valley? Do we want paved-over wetlands adjacent to the newly restored Lagoon? Do we want even more traffic, noise and pollution from the crowds that descend into our San Dieguito River Park?

Is the Fairgrounds living in 1908 or 2008?


Dawn Rawls is a member of the San Dieguito Lagoon Committee.

Additional Project Information

2008 Master Plan, Del Mar Fairgrounds and Horsepark

(Refer to Near-Term and Long-Term Projects Maps)



Map Number


Maximum Height

Paving East Lot

Near-term #2



East Lot Parking Structure

Long-term blue



Condo-Hotel Complex





Near-term #4

66.5 ft


Exhibit Halls

Near-term #4

51.5 ft


Entrance Structure

Near-term #4

51.1 ft



Near-term #4


86.5 ft

Administration/Entrance gate

Near-term #4







Building A (use unspecified)

Near-term “A”

34 ft

56 ft

Building B (use unspecified)

Near-Term “B”

24 ft

103 Rooftop parking spaces

Maintenance Building D

Near-term #7

30 ft

Open steel structure

Health Club/Paved parking

Near-term #10

48 ft

75 ft tower

Fire Station relocation

Near-term #8



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How to Read These Documents:

The Notice of Preparation (NOP) has several sections.

You might want to turn first to page 12, a table of the proposed projects. Most of these projects are indicated on the two maps: Near-Term Projects and Long-Term Projects. The table ________________________(fill in blank for location of table) provides a reference key for these maps. The floorplan _________________ gives the ground floor layout for the hotel/convention center. This building is more than ¼ mile from end to end.

A summary of the proposed projects is given in pages1-4.

Topics to be treated in the EIR are elaborated in pages 5-11. These topics are those in the CEQA checklist (see Alphabet Soup ).

The response letter from the Del Mar's San Dieguito Lagoon Committee commences with introductory remarks and then provides detailed comments following this table of contents:

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I. General Comments

A. Omissions in NOP

B. Items requested for inclusion in the EIR

C. Alternatives to the proposed projects

D. Overarching Considerations

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II. Comments on specific sections of the NOP

A. CEQA Topics

B. Specific Projects: Near-term

C. Specific Projects: Long-term

“Alternatives to the proposed projects” is a category that every EIR must address. Once environmental impacts of the proposed project (all the proposed demolition and construction are analyzed together as one project) are assessed, alternatives with lesser impacts must be analyzed. Usually these alternatives are dismissed for one reason or another, often because the alternatives don't meet carefully constructed “objectives” for the project. Suggesting alternatives at least draws attention to flaws and inadequacies in the proposed project.

Comments on specific sections of the NOP follows the same order, page by page, as the material in the NOP.

I Don't Really WANT to Read All These Documents!

Can't blame you! Here is the heart of the matter (from the Lagoon Committee's response letter of April 19, 2008):

D. Overarching Considerations

1. Environmental changes to Fairgrounds environs since Master Plan of 2000 and the most recent NOP of Dec 6, 2004 should command full attention in the EIR. Chief among these changes is the status of the San Dieguito River Park, the San Dieguito Lagoon and the nearby beaches.

The River Park is now a full-blown reality and a public resource. The River Park is administered by the San Dieguito River Park Joint Powers Authority (JPA) that was formed as a separate agency by the County of San Diego and the Cities of Del Mar, Escondido, Poway, San Diego and Solana Beach. The JPA was empowered to acquire, plan, design, improve, operate and maintain the San Dieguito River Park. This park of regional and statewide significance borders the Fairgrounds from Horsepark all along the river to the beach.

The San Dieguito Lagoon Wetlands Restoration is underway and expected to be completed in 2009. Mandated by the State of California through the Coastal Commission to mitigate for loss of ocean species of fish at the SCE power plant in San Onofre, the $86 million project will serve as a nursery for fish that will replenish the ocean fishing stocks of California . Further these wetlands provide for a large range of plant and animal life that buoys and protects the larger ecosystem of Southern California . Such wetlands are being recognized as a rare resource. The investment in this restoration project must be assiduously protected. From a practical viewpoint, these wetlands help protect adjacent communities from flood and fire damage.

The beaches at the mouth of the San Dieguito River are a critical driver of tourism in our locality. Recent intensification of storm water pollution prevention requirements addresses the importance of maintaining clean water in the rivers that empty into our ocean beaches.

These environmental changes to the Fairgrounds environs must, of necessity, call the Board of Directors and staff of the 22nd DAA to a higher standard of water quality protection than that of a standard industrial permit.

2. Management of the Fairgrounds is purported to be “fiscally sound and environmentally conscientious…for the benefit of all” (Mission Statement). Fiscal and environmental responsibility would mandate an analysis of the capacity of the current property of the Fairgrounds west of Jimmy Durante Blvd. This analysis should consider not only the maximal impact events of the Fair and Races, but also the cumulative effects of the ever-expanding interim-events schedule. At the present-day schedule, local communities and the resources of the River Park , Lagoon and River are adversely impacted. Current events often call upon parking, storage and public services beyond the capacity of the Fairgrounds. Intensifying use of the Fairgrounds without providing for adequate parking, storage and services for the public within the current footprint will exacerbate these problems, not solve them. Unpermitted use of wetlands is not an environmentally conscientious answer. Over-expansion of facilities is not fiscally sound. In summary: the 2008 Master Plan and EIR should specify a reasonable, final state of development for the Fairgrounds.

3. Unfair Competition. The DAA's entering into commercial ventures that compete with nearby enterprises could adversely impact local economies. A 330-room condominium hotel and 60,000 square foot health club and sports training facility are substantial projects to the area, and would add significant supply to the local market affecting the supply/demand balance. This could result in higher vacancies and lower rates for existing operators in Solana Beach , Del Mar, San Diego and La Jolla .

The DAA cost structure creates an uneven playing field. Operators in private industry must pay market rents and property taxes. The DAA has an unfair advantage because it has no basis (cost) in the land, it pays no carry costs (mortgage), it pays no property taxes, and it may charge whatever it chooses to undercut the competition. Should state-owned Fairgrounds, whose mandate includes promoting California industries, compete with existing local businesses? A commercial-hotel use is inappropriate for a publicly owned facility.

4. Mission of the Agricultural Association . The 2008 Master Plan should take into account that the initiating mission of the agricultural associations of California was to promote the agriculture and industries of the state. Equestrian activities were emphasized. Sacrifice of the effectiveness of the 22nd DAA's ability to fulfill this mission by entering into commercial ventures that compete with local enterprise not only fails to address this mission, but also could adversely impact the local economies the DAA's were meant to support.

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Alphabet Soup

EIR Environmental Impact Report laying out studies of all environmental potential impacts caused by a proposed building project.

CEQA California Environmental Quality Act specifies a thorough checklist of questions an EIR must answer.

DEIR Draft Environmental Impact Report is an early version of an EIR. The public can comment on inadequacies or inaccuracies in a DEIR. The final EIR must respond to all issues raised in comment letters.

NOP Notice of Preparation for a DEIR. The NOP is sent to agencies, political jurisdictions and interested citizens in the general public to ask what issues those groups wish to see addressed in the DEIR.

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