The letter raises concerns about three design features of a new elementary school project that unnecessarily increase wildfire risk. The features are: 1) A critical west-side fire access road that could be blocked in a wildfire. 2) Elimination of grass fields as a buffer and moving buildings close to surrounding woods. 3) An east-side fire access road design that could become blocked during evacuations. The letter requests the Division of the State Architect to carefully review these issues and ensure fire safety for students. Exhibits providing additional analysis of wildfire risks are included.

1. 7 May 2020
sent by email
Danijela Trubint
Supervising Architect/Fire & Life Safety
Division of State Architect
San Diego Office
10920 Via Frontera, Suite 300
San Diego, CA 92127
danijela.trubint@dgs.ca.gov
Application 119103, File 37-18
Del Mar Heights Elementary School
Dear Ms. Trubint:
I write regarding the application above, currently under review by DSA. Increment 1 and 2
plans have been submitted and a pre-application meeting was conducted with project owner
Del Mar Union School District (DMUSD) on February 24, 2020. I understand you are the
Supervising Architect for Fire & Life Safety on this project. If not, please forward this to the
right person.
Many citizens in the immediate area of this elementary school project in Del Mar have voiced
serious concerns in the CEQA project review process about wildfire urban interface (WUI) risk
from three particular design features currently under review by DSA. These three features -
based upon our detailed factual analysis and consultation with experts - unnecessarily
increase the occupant risk from wildfire from the heavily wooded Torrey Pines Nature
Reserve Extension that surrounds the school site by more than 180º. DMUSD leadership said
in its April 14, 2020 CEQA board meeting that DSA is the “final word” on all fire safety and
evacuation issues and that - if DSA has no concerns - DMUSD will move the project forward
despite the public’s concerns. That is why I am writing this letter.
The 197 acre Torrey Pines Nature Reserve Extension presents a heavily wooded, dying, un-
clearable fuel source of protected species with a southern aspect, substantial upslopes leading
to the school, and prevailing westerly winds that would drive any wildland fire up the slopes
directly to the new school. Prior fires in the Reserve have been particularly difficult, some
requiring multiple helicopters, air tankers, and days to control - due to the terrain, density of
fuel, and wispy wind conditions in the canyons. The entire area including the entire school site
is in a very high fire hazard severity zone.
1
The State of California Department of Parks and Recreation (State Parks or CSP), which owns
and controls the Reserve, recently filed wildfire-related comments with DMUSD during the
See Exhibit B pages 29-39 for wildfire details on the Reserve.1
490 Pine Needles Drive
Del Mar, CA 92014
619.517.1010
john@playoutsidedelmar.org

2. project’s ongoing environmental review (CEQA). CSP voiced concerns that the planned
movement of structures closer to the Reserve would require fuel buffers and made clear to
DMUSD that State Parks would not remove fuel from the Reserve to create defensible space.
(CSP’s comments are attached as Exhibit A).
The three primary features of this school design that concern us regarding wildland fire are:
1. West-Side Fire Access Road - critical and yet blockable by fire
As can be seen above (page G0.5.1 from Increment 2), the new design depends solely upon a
west-side fire access road for entry of fire and other emergency vehicles to the core of the
site, which is the “area of safe dispersal” shown on G0.4.1. If that west-side road is blocked
Page of2 5

3. by a wildland fire, then no emergency vehicles can gain access into (or out of) the site core and
area of safe dispersal. This critical west-side fire access road, however, is literally inches from
a steep eroding wooded slope that drops precipitously (up to 50 feet) into what the plans admit
are “dense trees” and “dense brush” - first on the west edge of school property and then
continuing west into the 197 acre Reserve that starts only a few feet from the school property
line.
G0.5.1 above shows the proximity of the fire road to the edge of the steep drop-off into dense
woods and the Reserve to the west. C3.1 shows additional detail of the “dense woods” and
“dense brush.”
We fear any substantial wildland fire in the Reserve will overwhelm that west-side edge fire
road and silo the site core and area of safe dispersal, especially since apparently no
consideration has been given to maintaining proper defensible space. As noted earlier, CSP
itself recognized the need for buffering in the proposed design, saying it will not remove fuel
from the Reserve - understandably, because the Reserve contains many protected plant and
animal species. They also cautioned that any attempt at buffering in the wildland transition
zone between the developed portion of the site and the edge of the Reserve would be
considered by them to be significant from an environmental viewpoint absent proper
mitigation.
An independent issue is the steep slope edge itself, which is deteriorating substantially from
erosion and weathering. We fail to see how this slope can be depended upon for decades to
support the 75,000 pound load required for a fire access road that - for long stretches - is less
than a foot away. Measures taken to prevent long term slope deterioration may conflict with
fire buffering.
This aggressive aspect of the design - placing the critical fire access road actually as close as
possible to the steep edge of the developed portion of the site and the Reserve -
unnecessarily increases occupant risk. It is not a feature of the current school, which allows
emergency vehicles to access the site core from the east. LS1.02.
2. Reduction of grass field buffer … and buildings scooted up against the Reserve.
The new school eliminates 82,000 square feet of rich grass playfields on the south and west of
the site (see LS1.0.1) - replacing that fuel buffer with buildings and structures that are all
moved much closer to the Reserve. In fact, some building overhangs are less than 20’ from
the drop into the “dense trees”, “dense brush”, and Reserve - on buildings that rise 27’ 7” next
to the very most fire-exposed western edge of the site. (See A1.1.1 and the DMUSD architect
rendering at Exhibit B page 46).
Because of the proximity of the buildings to the very edge of the developed site, we are
concerned that reasonable defensible space conditions cannot be met in the current design.
3. East-Side Fire Access Road - a likely mess in any emergency.
The east-side fire access road (also shown above) combines a fire access lane with three lanes
for student drop-off and pick-up. All vehicles entering the site are inescapably captured until
they reach the far south turnaround and must then exit over nearly the entire length of the
lane reserved for inbound fire and emergency vehicles. To make matters worse, 45
perpendicular parking spaces are directly adjacent to the fire access lane, so if even a single
Page of3 5

4. car exits a parking space, it also will back out directly into the fire access lane and then once
again exit over nearly the entire length of the lane reserved for inbound fire and
emergency vehicles.
We’ve all become acutely aware - through wildland fires like those in Poway that caused
panicked school evacuations - of how parents and others will rush in their cars into a site no
matter what to extricate their kids, and how teachers and others will drive cars off the site no
matter what to get themselves and other kids out. It’s unrealistic, in our view, to believe the
inbound fire access lane won’t be blocked by parents and other evacuees scrambling to
escape the site in a fast approaching wildland fire.
This is a particularly severe problem for this school site because there are only two unfenced
pedestrian access points. As designed, everyone will indeed be trying to get out by
automobiles.
DMUSD has offered no study of their U-turn overlap design that would show it could perform
under the pressure of a fire or other emergency, nor has it offered an evacuation plan or a
wildfire evacuation time study for the school. Since the site already suffers from having a
single vehicle entry point to the site (North on Boquita Drive), we believe it is imperative to get
these emergency evacuation issues correct in the school design, right now - for the safety of
the children as well as other occupants on the site. According to state records, the school has
16% disabled students. There is simply no justification for cutting corners or making close
calls on fire safety.
I’m sure you know that the California State Legislature amended the state environmental law
(CEQA) to require an analysis of wildland fire risk during environmental project review, effective
December 28, 2018. As a result, several organizations have commented on the substantial
wildfire risk in the ongoing environmental review of this project, including my organization Play
Outside Del Mar. I have included some important comments as exhibits to my letter.
Thank you for taking the time to review these issues that we believe are vital to the safety of the
children and our community.
Best,
John Gartman
President
Play Outside Del Mar
copy by email to:
Karen Gibb, Supervising Architect/Project Services, karen.gibb@dgs.ca.gov
Ron Laplante, Supervising Structural Engineer, ron.laplante@dgs.ca.gov
Nathan Larson, nathan.larson@dgs.ca.gov
Page of4 5

5. Exhibits:
A - California State Parks CEQA comments (see page 3 )
also available here: https://www.slideshare.net/JohnGartman1/state-parks-ceqa-comments
B - Play Outside Del Mar CEQA comments (see pages 26-48)
also available here: https://www.slideshare.net/JohnGartman1/play-outside-del-mar-ceqa-
comments-on-dmusd-mnd
C - Sierra Club CEQA comments (see page 5)
also available here: https://www.slideshare.net/JohnGartman1/sierra-club-ceqa-comments
D - Save the Field CEQA comments (see pages 13, 16-17)
also available here: https://www.slideshare.net/JohnGartman1/save-the-field-ceqa-comments
Page of5 5