SDMGA comments to Coastal Commission on City's Torrey Pines Projects Phase I Parking Lot renovation
The San Diego Municipal Golfers Alliance oppose the Torrey Pines Clubhouse projects in their entirety including the Phase I parking lot improvements on the Commission’s docket for Thursday, January 11. The City has bifurcated its Torrey Pines Clubhouse Project into more than project. Phase I is the parking lot improvement project. The SDMGA is in opposition to approving the permit for Phase I construction.
The full text of the SDMGA comments on its opposition are given below.
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SAN DIEGO MUNICIPAL GOLFERS ALLIANCE
P.O. Box 22575
San Diego, Ca 92192-2575
January 8, 2007
Re: Torrey Pines Parking Lot Permit Item 8e on Coastal Commission Agenda 1/7/07
Comments of San Diego Municipal Golfers Alliance In Opposition to Approving Permit
To the Coastal Commissioners:
The over 1350 members of the San Diego Municipal Golfers Alliance oppose the Torrey Pines Clubhouse projects in their entirety including the Phase I parking lot improvements on the Commission’s docket for Thursday, January 11. Although we believe that some updating of the parking lot could be helpful, we believe that the $5 million project proposed -- $2.8 million in construction costs on top of 2.2 million in “soft costs” – should not be approved because it is being funded by sharply increased greens fees for local golfers, which frustrates the Coastal Act’s policy in favor of low cost coastal recreational facilities, and because it has unnecessary environmental impacts which could be mitigated by a less ambitious, less costly project. We therefore ask that the Commission either disapprove the project as currently proposed or consider the Phase I application (for parking lot improvements) as part of the overall application and therefore not vote to approve the project at Thursday’s meeting (delaying it for further consideration).
We respond briefly to the staff report and articulate our reasons for continuing to oppose approval of Phase I in light of the staff report. Our opposition is based on two key concerns: (1) Impact on Low Cost Recreational Facilities; and (2) Environmental/Parkland Concerns. We discuss each in turn.
(1) Clubhouse Projects will dramatically increase the cost of golfing at Torrey Pines, frustrating the Coastal Act policy in favor of preserving low-cost coastal recreational facilities.
(a) The Enterprise Fund and the Cost Impact of the Projects as a whole. The Torrey Pines Municipal Golf Courses are unique coastal recreational facilities which are highly valued by San Diego residents as low cost, easily accessible facilities. The Golf Courses are funded by an Enterprise Fund which means that courses must pay for themselves through the greens fees charged. In order to pay for the Clubhouse Projects, the City has instituted a five-year plan of sharply increased greens fees, increasing fees charged to local golfers from as much as 252% (from $65 to $229; South Course Weekends) for San Diego County residents, to 86% (from $15 to $28; North Course) for senior city residents, to 69% (from $45 to $76; South Course Weekends) for non-senior city residents. In addition to these increases a new advance reservation system charges $25 per local resident per round to get preferential reservations that severely limits access for many residents whose golfing budget cannot afford these fees. As discussed in our Supplemental Statement which was attached to the documents for the January meeting, these fee increases have an enormous impact on local residents: $41,000 over five years for the once-a-week county golfer, $8,750 over five years for the twice-a-week resident golfer, $6,250 for the once-a-week user of the advance reservation system or for a senior who must now pay weekend, non-senior rates on Fridays.
(b) The Specific Cost Impact of the Parking Lot Improvements. The parking lot permit is for 2.8 million, but the whole project is budgeted at 5 million (2.2. million in soft costs). This results in higher costs for local golfers (over 1/3 of the entire project costs are allocated to the parking improvements). All of the payments come out the Golf Enterprise Fund. Even just counting the hard costs, this amounts to $3.50 per round to pay for the parking lot or $875 over five years for the once-a-week golfer and $1,750 over five years for the twice-a-week golfer. The effect of approving this project is to adversely affect the goal of maintaining low cost recreational facilities. Although the staff report notes that the parking lot should remain free, it really is not free because golfers are paying for it in higher greens fees. Thus, the Commission’s concern about free parking will be frustrated if the project is approved without conditions on greens fees. We believe that the Commission should consider these issues in the context of the whole project since this would allow it to consider the possibility of imposing conditions on the fees charged to the low-cost users of the golf course. Approving the parking lot improvements without considering the overall costs of the project, could lock in 1/3 of the costs being imposed on local golfers before the Commission considers the full impact on fees of the overall project.
(c) Subsidy to Lodge at Torrey Pines. A significant portion of the parking lot improvements (and the soft costs) are to redesign the lot to allow for a different traffic flow so that deliveries to the Lodge will not block the parking lot. Although the significance of the problem for the public is unclear, if a change in traffic flow is made it would be for the benefit of the Lodge and is a cost that should be legitimately borne by the Lodge which designed its delivery entrance to encroach on the parking lot. This redesign is not a cost that should be borne by golfers. Although the staff did not think that the Commission had jurisdiction over who pays for the parking lot, the Commission could protect low-cost recreational use of the courses with a condition – no parking lot improvements unless greens fees are kept low enough to assure low-cost access to the golf courses for local residents. Again, we feel this issue could best be handled in the context of the entire project and the overall greens fees.
(2) Environmental/Parkland Concerns. The proposed permit increases the amount of surface areas by enlarging the parking lot in violation of the objective of the UC Plan (p.101) to “minimize the total amount of impervious surfaces such as parking.” The proposed parking lot would pave over substantial non-paved areas to achieve additional spaces. This same purpose could be achieved by using the pine straw and dirt parking area and improving it. This could also reduce costs and lower the impact on low-cost coastal access fees. The staff treated this as only a drainage issue, but it involves at least four additional environmental issues not addressed by the staff: (a) paving parkland and thereby decreasing the pedestrian experience; (b) diminishing the amount of land which can absorb water inevitably affects the water table regardless of what drainage efforts are made; (c) moving endangered Torrey Pines trees (always chancy no matter how skilled the practitioner); and (d) global/community warming issues – pavement is a solar collector and heats the area (you can feel the difference in temperature when you step off the black top parking lot area and move onto the grass to the West). SDMGA believes that these undesirable impacts could be mitigated by keeping the pine straw area unpaved and not moving any of the Torrey Pines trees in that area. CA Pub. Res. Code ' 21080.5(d)(2)(A) provides that An activity will not be approved or adopted as proposed if there are feasible alternatives or feasible mitigation measures available that would substantially lessen a significant adverse effect that the activity may have on the environment@ See Mountain Lion Foundation v. Fish & Game Commission (1997) 16 Cal.4th 105, 123; City of Poway v. City of San Diego (1984) 155 Cal.App.3d 1037, 1045-1046; CA Public Res. Code '' 21002, 21081.) Because feasible alternatives exist and have not been considered, the project should not be approved as proposed.
For all of the foregoing reasons, SDMGA submits that the Phase I parking lot improvements either be rejected in their current form, or conditioned on restrictions on greens fees that keep Torrey Pines a low-cost coastal recreational facility or that any decision be delayed until the entire Clubhouse Project can be considered as a whole and until the feasible alternative of not paving the pine straw area or moving the Torrey Pines in that area has been adequately considered.
Respectfully submitted.,
Paul J. Spiegelman, as Attorney for
John Beaver, Joe Burwell, myself and SDMGA