Larkspur Landing Circle, Larkspur, CA 94939

Marin IJ: November 1, 2016

Marin Voice: High school stadium project needs greater scrutiny

Marin’s top-ranked schools are among the county’s greatest assets. They deserve strong support from residents throughout the community.

At the same time, plans to expand school facilities can create the potential for all kinds of negative environmental impacts. When they do, they should get the same scrutiny that any large development project deserves.

A case in point is the current plan to add night lighting to Marin Catholic High School’s stadium project on Sir Francis Drake Boulevard.

The school wants to install four 80-foot-tall poles to provide lights for nighttime football games and other athletic activities.

The Kentfield Planning Advisory Board recently held a public meeting to address the environmental impacts of the proposal. Supporters understandably used the meeting to promote their views on the value of the project to the school’s athletic programs.

Fortunately, the board redirected the conversation back to environmental issues.

This was important for several reasons.

Night lighting was part of the school’s original stadium renovation project several years ago. It was taken out, however, when the school recognized it might subject the project to review under the California Environmental Quality Act.

Without lighting, the school could argue that the project was simply a renovation of existing facilities, did not enable any new use of those facilities, and therefore was categorically exempt from CEQA review.

Based on these arguments, the county approved the project without undertaking the environmental assessment that otherwise would be required by law.

The same arguments cannot be made for the current proposal.

Artificially illuminated night games and practices constitute an entirely new use that necessarily will subject the project to CEQA review.

There are two options for this.

The first is preparation of a full environmental impact report that acknowledges the significance of the project’s potential impacts. The second is a negative declaration, which assumes that impacts will be insignificant at the outset or can be mitigated to insignificance later on.

Unfortunately, project advocates appear to be leaning toward the second option — a limited mitigated negative declaration. That would be a problem.

The environmental studies that have been conducted to date — regarding illumination and glare, noise, traffic and parking — generally reject any suggestion that project impacts could be significant. Those studies rely on assumptions that are highly speculative, however, and in some cases are just wrong.

For example, the traffic study assumes that parking demand can fully be accommodated by onsite capacity at Marin Catholic. However, as the study also acknowledges, onsite capacity (280 spaces) is less than projected demand (331 spaces), which can only be met through reliance on off-site facilities.

This conflicts with provisions of the county code, which requires that parking spaces be “provided on the same site as the use to which they relate.”

The analysis of biological resource impacts is also troubling.

It generally characterizes those impacts as “minimal” and “discountable,” but (notably) not insignificant.

It also acknowledges that noise from stadium use may have permanent, adverse impacts on birds and other wildlife. It dismisses those impacts, however, on the grounds that affected species would simply “adapt,” even though their ability do so is “generally unknown and very difficult to assess.”

This approach just won’t work.

Yes, we should support our local schools, but we should do that in a way which respects the environmental values that make our county such a special place to live.

In the case of Marin Catholic’s lighted stadium project, this will require at a minimum the preparation of a full and robust environmental impact report under CEQA.

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