Please note: Surfrider neither endorses nor opposes the related measure (Measure G). We are a 501(c)(3) organization and we are opposed to projects that illegally or unnecessarily threaten our oceans, waves, and beaches. The below comments are intended to highlight what Surfrider sees as deficiencies in the Marisol Specific Plan’s Draft Environmental Impact Report.

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Surfrider San Diego’s Beach Preservation Committee has reviewed and formally submitted comments on the Draft Environmental Impact Report (DEIR) for the Marisol Specific Plan. Read our full letter here.

The Specific Plan is important because it would amend local land use documents for a 17.45 acre coastal parcel in Del Mar that sits just north of Dog Beach and just west of the San Dieguito Lagoon. The construction of a multi-story resort development is associated with the Specific Plan. In December, the City of Del Mar issued a DEIR to study the potential environmental impacts associated with approval of the Specific Plan as well as the resort development. 

Surfrider was compelled to comment on this DEIR in large part because the study committed serious errors in its evaluation of geologic erosion rates in the area. These rates are then used as a basis for determining how far development should be “set back” from the blufftop. Surfrider is strongly committed to advocating for safe setbacks that acknowledge the impact of sea level rise on increased bluff erosion. The Sierra Club North County Coastal Group expressed related concerns in their letter to the City as well.

In our letter to the City of Del Mar, Surfrider’s Beach Preservation Committee made six main points regarding the DEIR. Primary potential impacts that were improperly evaluated include:

  1. The methodology used to estimate geological erosion rates in the DIER contains a gross omission because the DEIR fails to utilize recent site specific and immediately adjacent studies of geologic erosion. This results in setback estimates for the proposed project that are far too optimistic.
  1. The DEIR claims that it will provide public access trails, but the trails are positioned seaward of the already optimistic setbacks. Public access will consequently be the first part of the project that is lost to bluff retreat.
  1. There has been a misinformation campaign to paint the Marisol project as the only hope to gain public access along these bluffs, but public access is not unique to this proposed development — public access is required by both the Coastal Act and Del Mar Municipal code.
  1. While Marisol claims there will be no seawall to protect the proposed development, they never explicitly state that they are taking a covenant or deed restriction to prohibit a future seawall. 
  1. The DEIR did not study the blufftop public access easement on the northern perimeter of the site as a “key view” that would be impacted by the project, despite the fact that the project would obstruct highly scenic views of the beach and Pacific Ocean from the existing trail.  
  1. The DEIR’s flooding and stormwater estimates do not take into account increased storm intensity due to climate change.

 

Residents of Del Mar will vote to adopt/reject the Marisol Specific Plan Initiative in March of this year.