June 22, 2026

President (acting) Skip Atkins, Board of Directors Rancho Santa Fe Association, PO Box A, Rancho Santa Fe, CA 92067-0359

Subject:  Cautious Review and Postponed Vote of the Proposed Silvergate Development

Dear President (acting) Atkins and Members of the Board:

Protect Rancho Santa Fe is a nonprofit public benefit corporation organized under Section 501(c)(4) of the Internal Revenue Code exclusively for the promotion of social welfare. Our ongoing efforts are supported by over 500 Rancho Santa Fe Association members and residents of other homeowners’ associations within the San Dieguito River Valley area. We are working to preserve the area’s rural character and to oppose commercial development outside the downtown area of Rancho Santa Fe.

We are extremely concerned about the proposed Silvergate high-density rental project at the corner of Calzada del Bosque and Via de la Valle, and that the Rancho Santa Fe Association Board might consider taking action on the project before its significant environmental, land use, and public safety impacts have been adequately studied, disclosed, and vetted through a transparent public process.

To assist decision-makers and the community in understanding the scope of these concerns, PRSF retained an expert environmental consultant to prepare an Initial Study (Attachment A). That analysis concludes that the proposed project has the potential to result in numerous significant and potentially unmitigable environmental impacts. These findings raise serious questions regarding the appropriateness of any project approval absent comprehensive environmental review.

The California Environmental Quality Act (CEQA) was enacted to ensure that public agencies and decision-makers fully understand the environmental consequences of proposed actions before approvals are granted. CEQA requires environmental review that:

1. Informs decision-makers and the public of the significant environmental effects of proposed projects;
2. Identifies feasible measures to avoid or substantially lessen environmental harm;
3. Prevents avoidable environmental damage through project modifications, alternatives, or mitigation measures; and
4. Fully discloses the rationale for project approvals where significant environmental effects may occur.

The findings of the Initial Study strongly suggest that the Silvergate proposal warrants preparation of a full Environmental Impact Report (EIR). Accordingly, PRSF intends to advocate before the County of San Diego and all relevant agencies that no approvals be granted until a legally adequate EIR has been completed, circulated for public review, and subjected to meaningful community input.

The Initial Study identified a range of potentially significant environmental impacts, including but not limited to the following areas:

• Aesthetics
• Agricultural and Forest Resources
• Biological Resources
• Cultural Resources
• Geology and Soils
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Paleontological Resources
• Population and Housing
• Public Services
• Transportation
• Tribal Cultural Resources
• Utilities and Service Systems
• Wildfire
• Mandatory Findings of Significance

As documented in the Initial Study, the project would introduce an intensive, high-density residential development that is fundamentally at odds with the established community character, planning framework, and historic identity of Rancho Santa Fe. The proposed scale, massing, building intensity, and nighttime illumination would permanently transform a landscape currently defined by open space, agricultural uses, equestrian properties, and low-profile residential development. The visual impacts would extend well beyond the project boundaries, degrading scenic vistas, diminishing the setting of a State Historic Landmark, and compromising the dark-sky conditions that have long distinguished Rancho Santa Fe from surrounding urbanized communities.

Equally troubling are the project’s broader environmental and public safety implications. The proposal threatens the loss of important agricultural lands, creates potential conflicts with existing farming operations, and risks adverse impacts to wetlands, wildlife movement corridors, and habitat supporting sensitive species. The project’s proximity to the San Dieguito River, combined with known floodplain and drainage constraints, raises substantial concerns regarding flooding, stormwater management, and long-term water quality degradation.

The project also presents significant unresolved issues relating to wildfire exposure, emergency evacuation capacity, hazardous materials, traffic congestion, noise generation, geologic hazards, and the potential presence of tribal cultural resources. These concerns are particularly acute given the vulnerable population the project is intended to serve and the unique constraints of the surrounding roadway network and rural infrastructure.

Furthermore, the Silvergate project is potentially the largest development application ever submitted in Rancho Santa Fe’s nearly 100-year history. Its unprecedented scale and intensity would fundamentally alter the community’s rural character, development pattern, and visual landscape.

If approved, less than one-third of one percent (0.33%) of Rancho Santa Fe’s land area would contain nearly five percent (5%) of the community’s total developed building area, which is an extraordinary concentration of development that is inconsistent with Rancho Santa Fe’s historic planning principles and preservation objectives.

The sketch below vividly illustrates the incompatibility: Each yellow circle represents an existing single-family dwelling within the Rancho Santa Fe Covenant, while the dense cluster of circles symbolizes the number of units proposed for the Silvergate senior living project – visually underscoring its stark incompatibility with the community’s rural, estate-lot character.

Even without a planning degree, it should be simple common sense that such an institutional employee-intensive, multi-building senior living/care facility is not compatible with a rural, large-lot, single-family estate community such as Rancho Santa Fe.

Because of its unprecedented size and potential long-term impacts, this project should not be subjected to a routine review process. Instead, it warrants heightened scrutiny and a thorough evaluation based on a complete factual record. Any formal position or recommendation should be deferred until the County of San Diego completes its environmental review and issues its findings. Premature conclusions risk misinforming residents, stakeholders, and decision-makers before all relevant facts and impacts have been fully analyzed.

The project currently before the Rancho Santa Fe Association consists of only two of the four parcels that comprise the overall development proposal. In contrast, the application submitted to the County encompasses all four parcels, totaling approximately 28.7 acres.

Because the proposed development is functionally and physically integrated across all four parcels, it should be evaluated in its entirety rather than as a piecemeal project. Reviewing only a portion of the development would prevent the Association from fully assessing the project’s cumulative impacts, overall intensity, site design, circulation, environmental effects, and consistency with Rancho Santa Fe’s planning objectives and rural character.

Accordingly, it would be premature and inappropriate for the Association to take action on only a partial project description. Any vote or recommendation should be postponed until a complete development proposal encompassing all four parcels is presented and available for comprehensive review by the Rancho Santa Fe Association.

Taken together, these impacts demonstrate that the Silvergate proposal represents far more than a routine land use decision. It is a project with the potential to irreversibly alter the environmental character, visual identity, public safety profile, and long-term planning objectives of Rancho Santa Fe and the surrounding communities. Proceeding toward approval without a comprehensive Environmental Impact Report and supporting technical studies would deprive decision-makers and the public of the information necessary to make an informed determination and could expose the approval process to significant legal and procedural challenges.

For these reasons, PRSF strongly urges the Rancho Santa Fe Association Board of Directors to refrain from taking any action that could reasonably be construed as project approval or endorsement until a full Environmental Impact Report has been prepared, publicly circulated, and thoroughly reviewed. The potential consequences of this project are too significant – and too permanent – to be adequately addressed through a standard review process. The project’s unprecedented scale and potential impacts demand a rigorous, comprehensive, and transparent evaluation, including full consideration of the County’s environmental analysis, before any recommendation or decision is made.

Given its unprecedented mass and density, the Silvergate proposal represents a significant departure from Rancho Santa Fe’s historical precedent. It is not simply another development application and therefore warrants an elevated level of scrutiny and consideration. An early decision – based on incomplete information and without full community consideration of the totality of Silvergate’s impacts on Rancho Santa Fe and its neighboring communities – could yield negative and likely irreversible consequences. Accordingly, we respectfully request that the Rancho Santa Fe Association Board of Directors postpone any vote, recommendation, endorsement, or other formal action regarding the project until the Environmental Impact Report has been completed, publicly circulated, and reviewed by the Association and the community. Only after the Association has had a full opportunity to evaluate the findings and conclusions of the EIR should any position be considered on a project of this magnitude and consequence.

Sincerely,

Protect Rancho Santa Fe Board of Directors and Rancho Santa Fe Association Members 

Courtesy copy provided to:

Terra Lawson-Remer, Chair, County of San Diego Board of Supervisors

Monica Montgomery Steppe, Vice Chair, County of San Diego Board of Supervisors Paloma Aguirre, Chair Pro Tem, County of San Diego Board of Supervisors

Joel Anderson, Supervisor, District 2 Jim Desmond, Supervisor, District 5

Andrew Potter, Clerk of the Board of Supervisors, County of San Diego

Dahvia Lynch, Deputy Chief Administrative Officer, Land Use & Environment Group (LUEG) Vince Nicoletti, Director, Planning & Development Services (PDS)

Douglas Dill, Chair, San Dieguito Community Planning Group Dan Silver, Executive Director, Endangered Habitats League Jimmy Ukegawa, President, San Diego County Farm Bureau

Jonathan Snyder, Acting Field Supervisor, U.S. Fish & Wildlife Service

Erinn Wilson-Olgin, Regional Manager, California Department of Fish and Wildlife Julianne Polanco, State Historic Preservation Officer, DPR

Shannon Pries, Local Government & Project Review Supervisor, DPR Jody Brown, Tribal Liaison, California Office of Historic Preservation Michael Hogan, President, Board of Directors, Santa Fe Irrigation District

U.S. Army Corps of Engineers, Regulatory Division (South Coast Branch, San Diego jurisdiction)

San Diego Regional Water Quality Control Board, Region 9 Mike Lewis, California Stewardship Fund

Tom Gonzalez, California Stewardship Fund