EHL filed extensive CEQA comments on a proposal to increase density on 9,000 acres of rural land.



In 2011, San Diego County adopted a historic update of its General Plan (the “land use constitution”). Rural, farm, and habitat lands were given low housing densities, and future growth was concentrated in towns and villages. Billions were saved on infrastructure. 

But the ink was not dry when a divided Board of Supervisors re-opened the plan to previously rejected proposals by landowners to increase densities in rural and locations. The cost would be borne at taxpayer expense, though the benefit would be purely private. EHL opposed it at the time, noting that as all the initial designations were proper, there was no planning merit.

Called “Property Specific Requests,” these initially limited proposals ballooned to 9,000 acres and 1,800 units. The changes involve productive farmland and high quality wildlife habitat. Many are in remote and high fire hazard locations. A draft EIR was released late last year.

EHL filed extensive comments – both legal and biological – exposing many flaws. The General Plan would be repeatedly violated, both in spirit and letter. Biological impacts could have been better disclosed but were not. Water supply didn’t get a close look. 

While staff devised some less damaging options, these are not sufficient, and might or might not be adopted by the Board. In any event, it will be difficult if not impossible to make lemonade out of this lemon.