Environmental Impact Reports (EIRs)
Time-Sensitive Links
Key Contacts Related to Proposed School Construction
Key Documents Related to Proposed School Construction
School Reports
Naylor Act
Mitigation Banking Resources
County Scenic Corridors / Fallbrook Community Trails
Implied Covenants, Conservation Easements, Wildlife Corridors
Monserate Winery Sept 2018
Donation Appeal

Environmental Impact Reports (EIRs)

IMPORTANT: As required by law under the California Environmental Quality Act (CEQA), a Draft Environmental Impact Report (DEIR) is in process for Bonsall Unified School Districts’s (BUSD) proposal to build a 1500-student high school in Fallbrook’s Gird Valley, a project that has been rejected by the voters fully five times since 1978. We have the DEIR documents here.  In September 2018, the Village News reported that BUSD will recirculate the DEIR documents for a 45-day public review soon. With a school Board election (four out of the five Board seats are up for election) on November 6 and Ballot Measure EE in play plus the Thanksgiving holiday, has asked, out of courtesy to the community, for a longer comment period. volunteers previously submitted lengthy comments in 2017 on the Notice of Preparation (NOP) of this EIR. Additionally, because of the environmental values present on the site, a joint letter was submitted in June 2017 by the US Fish & Wildlife Service and California Department of Fish and Wildlife. This was followed by a 45-day public comment period, ending March 22, 2018. Even after this period, it is not too late to submit your comments. Send them to William Pickering at and to Bill Dos Santos at the San Diego County Office of Education at Send a copy to us at Thanks! 

Here are some of the comments submitted on the Draft EIR:

SAVEGIRDVALLEY.COM: Environmental attorney Kevin Johnson submitted detailed comments on behalf of Key takeaways? Corrupted baseline due to clearing of the property by goats before the EIR process began. Also, a federal biologist found an arroyo toad adjacent to the site so it’s very difficult to argue that there is no habitat but BUSD tries anyway. Traffic will be a major issue and, for safely, the proposed designed should include two exits/entrances since Gird Valley is in a HIGH WILDFIRE HAZARD ZONE. With just 24.6 usable acres, how will the site meet California Department of Education’s minimum requirement of 38.7 usable acres required for 1,401 to 1,600 students?  So much more! You’ll want to read this letter. volunteers also previously submitted lengthy comments in 2017 on the Notice of Preparation (NOP) of this EIR.

ENDANGERED HABITATS LEAGUE (EHL): EHL submitted comments, stating, “…the consulting biologist did not conduct protocol level surveys as requested by USFWS/CDFW for the arroyo toad or focused/protocol level surveys for gnatcatchers.” EHL stated that the proposed development is in conflict with San Diego County’s Multiple Species Conservation Program (MSCP) and its San Luis Rey River Park Plan. EHL stated, “The DEIR may have used an improper baseline in connection with biological impacts. It is our understanding that before biological surveys were conducted, the district cleared the property by using goats which likely removed sensitive plant species and impacted sensitive animal habitat. This issue should be candidly addressed in the DEIR and biological reports and the appropriate baseline should be employed. The project site’s pre-clearing status should have been used to assess biological impacts and mitigation and avoidance strategies. An applicant cannot avoid the environmental review process by preemptively clearing the property of all environmental sensitivity.”

CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE (CDFW): Submitted these comments. Previously, because of the environmental values present on the site, CDFW and the US Fish & Wildlife Service submitted a joint letter in June 2017.

DEPARTMENT OF TRANSPORTATION, STATE OF CALIFORNIA: Submitted these comments, caught several errors in the DEIR and commented on Level of Service (LOS) (which runs from A=freeflow to F=gridlock). “According to these Caltrans standards, LOS D is not an acceptable LOS, any volume added to a facility currently operating at LOS D is consider[ed] a significant impact. The following intersections are considered to be significantly impacted from the project and need to be mitigated accordingly.: Year 2025 + Project: a. SR-76/Old River Road/East Vista Way, b. SR 76/North River Road, c. SR-76/Olive Hill Road/Camino Del Rey, d. SR-76/ South Mission Road.”


PLANNING & DEVELOPMENT SERVICES, COUNTY OF SAN DIEGO: Submitted these comment noting, “The project site is located within the Fallbrook Community Planning Group (CPG) area. The project proponents should coordinate with the CPG for adequate public participation regarding the Project.” On Transportation/Traffic, they commented, “It is unclear why the Project proposes only one driveway (with no traffic signal or roundabout). Additional consultation with the local Fire Authority and the County must be conducted to ensure adequate access, particularly emergency access, is provided for the proposed high school. It should be noted that there does not appear to be any other similarly sized high school within the region that has only one driveway (without a traffic signal or roundabout) entering mid-block on a Mobility Element roadway.”


FALLBROOK COMMUNITY PLANNING GROUP (FCPG): FCPG met on March 19, 2018 and submitted its minutes as formal comments on the project. We also transcribed comments made during the March 19 meeting. Vice Chair Jack Wood stated,  “There are a number of reasons why this property is not suitable for a school. … I strongly oppose the development of a high school on this location.” Chairman Jim Russell noted BUSD greatly understated the parking needs, stating, ““They will have parking for less than 10% of the student body… I think [this development] would totally devastate Gird Valley with all the students trying to park out on Gird Road and I seriously question the logic of the folks who put those numbers in the EIR and think that is an appropriate thing to do.” … I think a major egregious error in this EIR is the fact that the property is not centrally located where a high school should be so folks can feed in from all around. This is the very extreme edge of the school district,” “on the very extreme edge, the northern edge, of the district and in my opinion is not an appropriate place for a high school.” See map

FIRE CHIEF BOB ROPER: Per the San Diego County Office of Emergency Services’ Know Your Hazards mapping tool, Gird Road is in a VERY HIGH WILDFIRE HAZARD LEVEL zone (7350 W. Lilac Road, where the current BUSD high school is located, is rated MODERATE) and Gird Valley has been evacuated twice in the last decade. Fires in 2017 ran just south of the proposed school property on Gird Road yet BUSD includes only one entrance/exit in its proposed high school design. Fire Chief (ret.) Bob Roper submitted excellent comments related to fire safety for the proposed 1,500-student Bonsall High School. He recommends the project incorporate two entrances/exits (not one). We agree! Children’s safety is not negotiable!

FYI: Know Your Hazards mapping tool from the San Diego County Office of Emergency Services reveals 3800 Gird Road has a VERY HIGH WILDFIRE HAZARD LEVEL; 7350 W. Lilac Rd has a MODERATE WILDFIRE HAZARD LEVEL. [Gird Valley has been evacuated twice in the last decade.] Earthquake Level of Shaking at Gird Rd. is fairly low and Lilac Rd is several increments lower, near the bottom. Neither site has a flooding or tsunami hazard.

TERESA PLATT: A number of individuals submitted last-minute input so we incorporated these into this comment letter by Teresa Platt. The corrupted baseline was brought up again (goats!), along with traffic (73% increase), noise, arroyo toads, burrowing owls and more.

JULIAN TORRES: Disabled veteran Julian Torres, who lives across the street from the proposed site comments DEIR Julian Torres, “My wife and I are fully opposed to a school being sited in Gird Valley as it is too far north in the district to serve most of the district residents. The noise and increased number of people walking and parking around my house would be exhausting with my injuries. It is an inappropriate site and has been rejected by the voters 5 times! From my vantage point it seems that BUSD is trying to have the community serve the district Instead of the district serving the community. I have served this country honorably and ended up leaving both my legs in Afghanistan, all I am respectfully requesting for is that BUSD return the effort and honor and please choose a different location. Why is BUSD ignoring the will of it’s voters?”

TERRENCE BURKE: Mr. Burke, a 100% permanently disabled veteran, golfs regularly at Golf Club of California adjacent to the proposed site. He noted concerns about loss of views from the clubhouse and fairways, traffic, noise and school bells ringing all day long and their impact on the wedding venue and golf course. BUSD’s Draft EIR makes no mention of school bells or noise at all. How close is the site to the Golf Course? Here’s a video: 

and a map:

Screen Shot 2018-04-12 at 11.34.22 AMThis is what the Gird Road site looked like after hundreds of goats ate everything, just before the EIR process began. Did BUSD corrupt its baseline?  goats on Gird

Here’s the site in April 2018. You can see how close it is to the Golf Club of California’s fairways. Imagine trying to golf or get married with school bells ringing all day long!


Final critical habitat for the Coastal California Gnatcatcher within jurisdiction of the Carlsbad Fish and Wildlife Office.

Arroyo Toad occurrence data, Carlsbad USFWS, Oct 7, 2015.

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Time-Sensitive Links

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Key Contacts Related to School Construction

San Diego County Office of Education’s Educational Facility Solutions Group “provides support, current information and guidance to the 42 school districts of San Diego County in all aspects school facilities” from acquisition through , planning, financing, modernization, construction and maintenance. Key contact is Bill Dos Santos, Senior Director, 858.292.3680. As of March 2018, BUSD has never asked for this assistance.

State of California’s Department of General Services’ (DGS)  Office of Public School Construction (OPSC) is tasked with determining need for a school along with its Division of the State Architect’s (DSA) office (South Team/Ron Laplante, Supervising Structural Engineer, 858-674-5461, The DSA reviews construction plans, when they are finally submitted, for compliance with the building code in three specific areas: structural, fire and access.

California Department of Education (CDE) sets standards for school sites with which the District must comply if it expects to receive any funding from California taxpayers via the CDE. (See Table 6.) To serve 1,500 students, BUSD is required to provide 38.7 acres at the minimum.

Department of Public Works (DPW), Nael Areigat, Manager, 858-694-2815,

Fair Political Practices Division, California government. For filing a complaint with the Enforcement Division of the FPPC.

San Diego County Planning and Development Services, Dag Bunnemeyer, 858.694.2581, oversees school construction related to traffic, utilities, compliance with grading and more.

County of San Diego Parks and Recreation, Mark Massen, Senior Park Project Manager, San Luis Rey River Valley Park, 858.966.1351, 619.318.6929/cell,

County Supervisor Bill Horn’s Office, Melanie WilsonLand Use Advisor, (District 5 staff),

California Department of Fish and Wildlife: Warren Wong, 858.627.3997, Also Marilyn Fluharty,

US Fish and Wildlife Service: Emily Cate,

San Diego County Public Works Traffic Section. Kenton R. Jones, PE, MSCE, Chief of Safety and Loss Mitigation, DPW Traffic Engineering (O-334). (858) 694-3843.

Bond expert Dale Scott’s November 2017 Must read report advising BUSD to NOT attempt a bond in 2018 due to lack of community support.

BUSD’s 2005 Bonds, debt of $17M plus interest, as of March 2018.

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Key Documents Related to School Construction

Bonsall New High School schematic design Bonsall New High School schematic design, June 2, 2017 (revised June 22, 2017).

The San Diego County Office of Emergency Services Know Your Hazards mapping tool reveals 3800 Gird Road has a VERY HIGH WILDFIRE HAZARD LEVEL; 7350 W. Lilac Rd has a MODERATE WILDFIRE HAZARD LEVEL. [Gird Valley has been evacuated twice in the last decade.] Earthquake Level of Shaking at Gird Rd. is fairly low and Lilac Rd is several increments lower, near the bottom. Neither site has a flooding or tsunami hazard.

San Diego County General Plan includes the Fallbrook Community Planning Group’s General Plan. See also Fallbrook Design Guidelines, Fallbrook Planning Area, County of San Diego, 1989; and Fallbrook Community Plan, County of San Diego General Plan update, as amended May 4, 2016.

Guidelines for Determining Significance and Report Format and Content Requirements: Dark Skies and Glare. Land Use and Environment Group, County of San Diego, July 30, 2007, modified Jan. 15, 2009.

Fallbrook Community Planning Area map, San Diego County.

Title 5, California Code of Regulations. Excerpt relating to school facilities construction. Title 5 Webinar transcript, November 2016.

Gird Valley, from ridgeline to ridgeline, is home to 3,402 people living in 1,283 housing units. The western side of Gird Valley has a population of 1,771 in 709 housing units. Average home value is $882,991. Average household income is $158,556. The eastern side of Gird Valley has a population of 1,631 in 674 housing units. Average home value is $757,692. Average household income is $139,394.

Our HISTORY: A Tale of Two School Districts from the 1880s to present day includes lots of fascinating detail, with all the pertinent links, about Fallbrook and Bonsall school districts!

Bonsall Unified School District (BUSD) Meeting Schedule, Agendas and Minutes and contact info for BUSD’s Board.

Fallbrook Union High School District (FUHSD Agendas and Minutes and contact info for FUHSD’s Board.

2017, June: BUSD’s 2017-2018 Budget states 229 high school students enrolled for 2016/2017, projects 337 high school students for 2017/2018 (with the addition of grade 12),  2018/2019 unchanged with 337 high school students and 352 high school students for 2019/2020, along with dangerously low reserves.

2017, January: Professional Services Agreements related to design work and environmental/CEQA on the Gird Road site.

2016, December 8: and its CATE Report: NEEDS VERSUS WANTS IN THE BONSALL UNIFIED SCHOOL DISTRICT. CATEs projections see only an estimated 115 new high school students by the year 2021.

SUPERINTENDENT’S ADVISORY COMMITTEE (SAC) established November 2017 to review building sites for a high school. See details in the Site Advisory Committee Guidelines. Their Report was released January 8. Here is our analysis of the Report. 

Must-reading: Interim Property Summary and Evaluation for BUSD High School: In early January 2017, members of the community began to research high school building sites that would be acceptable to both local residents and the District. Over the next 5 months, many hours were spent meeting with BUSD administration and researching properties within the District boundaries. This interim report details the findings, all or in part, and was released to the BUSD Board on June 8, 2017, officially accepted at the July 13, 2017 BUSD Board Meeting. Additionally, volunteers created a video of the main properties under discussion, the Gird Road and Ocean Breeze Ranch parcels.

BUSD sought comments on its new Superintendent search at a meeting on June 6, 2017 and online by June 12, 2017. New Superintendent David Jones was hired in 2017 with a contract totaling approximately $165k plus benefits. See Contract.  For more on salaries at BUSD, visit TransparentCalifornia. For comparison purposes, the previous Superintendent Justin Cunningham signed a 3 year contract in 2015 for approximately $170k plus benefits. However, TransparentCalifornia reveals he was paid a shocking $281k in 2016, more than the Governor of California!

2016, December 8: After BUSD loses its funding Measure DD in the November 2016 elections, BUSD approves a $20M Lease-Leaseback construction contract which was then challenged in court by February 8, 2017, quickly rescinded by BUSD board Feb. 9, 2017. Lease-Leaseback contracts have long been controversial, resulting is a key lawsuit (Davis v. Fresno Unified School District) in 2012 which stated that Lease-Leaseback contracts violated a longstanding common law prohibition against self dealing in public contracts (in other words, conflict of interest). The court’s decision resulted in changes, effective January 1, 2017, to California State law.

2016, October 28: Initial CEQA Study by School Site Solutions for BUSD’s  Proposed New Bonsall High School includes info on federally designated critical habitat for the endangered arroyo toad (16.14 acres on the eastern side of Gird Road site) along with several unnamed tributaries leading to the San Luis Rey River Valley and ultimately to the Pacific Ocean.” The hilly site, which has never been farmed or ranched, is “underlain by young alluvial and older alluvial materials at depth. A thin veneer of topsoil fill mantles the site.” There is no mention in this report that Gird Valley is also part of a San Diego County Scenic Corridor system.

The arroyo toad “occurs along the south and south-central coasts. The lack of a stripe down the middle of the back, non-enlarged toe pads, horizontal pupils, enlarged parotoid glands, and usually a light mark on the head between the eyes, will help you distinguish this toad from other frogs, toads, and spadefoots occurring in the same area.” The federal government listed the arroyo toad as an endangered species in 1994. California also lists the arroyo toad as endangered under its California Endangered Species Act (CESA). The Global Amphibian Assessment lists the it as endangered (IUCN, Conservation International, and NatureServe 2008) and Mexico listed it as endangered in 2010.

US Geological Survey map shows the Sullivan School on bedrock and the Gird Road parcel on “Older alluvial flood plain deposits (Pleistocene, younger than 500,000 years) – Mostly moderately well consolidated, poorly sorted, permeable flood plain deposits.”

2016, October: BUSD’s high school Biological Resources Assessment for Bonsall High School and Performing Art Center completed by Hernandez Environmental Services states that “development of the project will impact approximately 24.6 of the 48-acre site” (p.14) even though 19.8 acres are to be set aside for recreation fields.  This report details the overwhelming scope of the proposed project. With 150,000 sq. ft. of buildings and 200,000 sq. ft. of parking, it details what is the largest development in Gird Valley’s history, perhaps in all of Fallbrook.

2016, July: BUSD Superintendent Justin Cunningham sends a second letter to the County Supervisors stating,”our District strongly urges your Board to approve the Lilac Hills Ranch project.”

2016, June:  Kunzman traffic study for proposed 1500-student high school on Gird Road site: 50% increase from approximately 4,000 vehicles per day to 6,000.

2015, July: Dr. Cunningham sends a letter to the County Board of Supervisors stating “We strongly support the Lilac Hills ranch development…” [A second letter on behalf of the BUSD Board is sent, also supportive, on July 13, 2016.]

2014, April 27: Blueprints for Sullivan Middle School conversion to classes for Bonsall High School. In “Bonsall High to be county’s first New Tech School,” by Gary Warth, San Diego Union-Tribune, Apr. 27, 2014.

Documents BUSD submitted to the State Department of Education (DOE) regarding building the high school on the Sullivan Middle School campus, 2016 as a modification to the Sullivan Middle School (SMS). Documents note housing for 1,107 children before the addition of 270-student Bonsall High School (BHS) for housing total of 1,377 students at the at SMS campus.

2012, July: The CDE recommends that the SBE adopt the Negative Declaration …. which finds that there is no substantial evidence that the project (proposed unification) will have a significant effect on the environment. The State Board of Education issues a report stating, “With a new high school located in the core Bonsall area, high school students residing in Oceanside and east of Interstate 15 would have a shorter commute than they currently have to Fallbrook High School….” Attachment 1 concludes: “Real Property and Personal Property Normally Situated thereat (Operating School Sites): The County Committee Study reports that the Fallbrook Union HSD has no school sites or facilities within the territory of the Bonsall Union ESD, but owns a 50-acre undeveloped parcel of land (Gird Road property) located in the Bonsall Union ESD. Because the parcel is undeveloped and has never been a school site, this study recommends the districts negotiate the value and disposition of the parcel. (At a meeting December 12, 2011, the Fallbrook Union HSD Board of Trustees declared the Gird Road property surplus.) Source:, downloaded April 3, 2017

2011, December 12: FUHSD Board of Trustees declares “District’s Gird Road Property as Surplus (A 3): On motion of Mr. O’Connor, with second by Mr. Cerda, the Board declared the District’s Gird Road property as surplus. CARRIED UNANIMOUSLY. …Disposition of Gird Road Property (A 4) Options related to the disposition of the Gird Road Property were discussed. The Board will be asked to take formal action regarding the property at a future meeting date.”

2011, November 14: Real Property Advisory Committee (RPAC) (Co-chaired by BUSD Board Member Lou Riddle) report to the FUHSD Board of Trustees states, “Findings: The RPAC voted 8-0 to recommend to the Board of Trustees that the property be declared surplus, and acknowledges the site is not needed for school facilities” and “The topography would make it very expensive to build a school on the property. There is a huge concern about the future use of the property for building a school due to environmental obstacles and traffic issues….” “The current maximum capacity within the [Fallbrook Union High School] District includes 4,249 available seats and a current enrollment of 2,964. …The RPAC also reviewed information from the past long range facilities master plan developed by PJHM Architects.” Exhibit H includes Section II of a PJHM Architects report, the FUHSD 2004 Facilities Master Plan and states, “site inspections and field investigations were completed” at various sites, including Gird Road. It suggests trading the property “for an alternative site upon which to build new educational facilities.” Fred Good was the key consultant on the PJHM report. The RPAC Report’s Exhibit C is an appraisal by Tucker Appraisal Services with an estimated value of $2.2M as of May 23, 2011. The RPAC’s August 16, 2011 minutes state, “D. Real Property Profile — Gird Road site: … Currently, the District is paying a non-use assessment to the State of $50,000 annually for the property. The topography would make it very expensive to build a school on the property. There is a huge concern about the future use of the property for building a school due to environmental obstacles and traffic issues….” 

2010, September: Fallbrook Union High School District’s (FUHSD) finding that the Gird Valley site is “not suitable” for a high school for three reasons: the current costs to modify the topography of the land, environmental impact mitigation, and proximity to the Sycamore Ranch development.Screen Shot 2017-06-06 at 8.30.29 PMThe Gird Road site, approximately 50 acres, Assessor’s Parcel Number (APN) 124-340-34-00 is zoned A70: “Limited Agriculture. Intended for crop or animal agriculture. Number of animals allowed are specified by neighborhood regulations.” For residential development, the lot is located in an area where 2 acres per house are allowed. With a 75% yield after roads and improvements, the lot could support about 19 houses.

The parcel is located within the map for the County’s San Luis Rey River Valley Park Master Plan which means the County would be interested in acquisition.

2007, December: Caldwell Flores Winters report to the County of San Diego Committee on School District Organization regarding the proposed unification of BUSD recommends Gird Road be sold: “[T]he Fallbrook UHSD does own a 49.78-acre parcel, Assessor Parcel Number (APN) 124-340-34-00, which for the purposes of this study is considered an asset of real property and subject to valuation and division as an asset. Should the proposed reorganization occur, the parties could negotiate the ultimate disposition of this asset.”

2007, February: The Field Act and Public School Construction: A 2007 Perspective. State of California, Alfred E. Alquist Seismic Safety Commission.

2004: FUHSD commissions an $80,000 FUHSD Facilities Master Plan from PJHM Architects focusing on plans 20-25 years into the future. This must-read report includes mentions of the Gird Road property and discussions about enrollment doubling over 20-25 years. Enrollment at FUHSD peaked in 2004-05 at 3,176 and is now about 2,071 in a school built for easily twice that number.  The report states, “The District’s ownership of the Gird Road property remains an extremely valuable asset. Development of this site for educational facility purposes may be difficult given the site’s relative adjacency to Highway 76 and the sole access to the Site off of Gird Road. However, the opportunity may exist to utilize the site as a potential ‘trade’ for an alternative site upon which to build new educational facilities.” “The District is fortunate that it owns the approximate 50- acre parcel on Gird Road. This is a beautiful and extremely valuable asset for the District. However, development of this site for educational purposes in 2004 may not be as viable as it likely appeared when the site was purchased in the 1960’s. The site’s location and proximity to the intersection of Highway 76 and Gird Road and sole access point off of Gird Road are problematic from a traffic perspective and, potentially, from an ‘approvability’ perspective through the required California Department of Education’s School Facilities Planning Division site review and approval process. It is strongly suggested efforts continue with the County of San Diego and the California Department of Education to fully assess these issues and their resultant impacts upon the “build ability” upon this site for educational purposes. Alternative GR-2 Given the beauty and location of the District’s Gird Road property it would seem short-sighted to not consider the potential ‘trade value’ of this property if the District seeks an additional site for future educational facilities. In essence, perhaps this property could be used to exchange for land elsewhere within District boundaries that may be more suitable for development as FUHSD educational facilities. It is strongly suggested that the District initiate a preliminary development review process with and through the County of San Diego’s Department of Planning and Land Use to help assess the potential value of this site for purposes other than educational.” “Gird Road Property – Tom Tooker ranked this site as a “2” – in essence, this means that he is fairly comfortable with the site and would suggest that further study and analysis be completed. Issues that caused him to rank this site less than a ‘1’ were: • concerns over relative proximity to Hwy 76 and the future potential realignment of this road. • single point of access off of Gird Road is a concern, as is the general nature of Gird Road relative to suitability for servicing the vehicular needs associated with a potential 2,000 student high school. • irregular topography on the existing site and the likely requirement for fairly extensive grading in order to fully maximize the approximate 50 gross acres. • potential for sensitive environmental approval issues, i.e., presence of oaks, etc.”

March 2016: School facilities needs analysis. Prepared for BUSD by Schoolhouse Services and says enrollment capacity is 2,839 students. Also reports on special needs students noting, “The District has 59 SDC students. This equals 2.6% of students.” 2.19% of these are in high school. BUSD’s 2015/2016 Student Accountability Report Card (SARC) report states that 17.5% of its high school students have disabilities (far higher than FUHSD and the average school population, both at 13%). As of 2017, the SARC report states that 22.3% of Bonsall High School’s students are categorized as disabled.

October 2017: School facilities needs analysis. Prepared for BUSD by Schoolhouse Services and says enrollment capacity is 2,939 students. Total students enrolled in the district as of September 2017 is  2,554. In simplest terms, district enrollment was 87% of capacity, with room for 385 more students. Average Daily Attendance, ADA, numbers tell another story. K-3 enrollment peaked in 2013-14 at 1,134 and dropped to 1,054 in 2016-17 but actual K-3 Average Daily Attendance, ADA, dropped to just 938 and attendance for grades 4-6 has fallen substantially since 2014.  Total ADA for the entire district was just 2,240.48 or just 76% of capacity. We do know that high school student enrollment rose in 2017-2018 (with the addition of grade 12) and, if we give BUSD the benefit of the doubt and say all 328 enrolled high school students attended school every day, then that would be ADA for 2017-2018 of 2,350.11 or about 80% of capacity. 

Screen Shot 2018-04-20 at 12.38.13 PMSource:

San Diego County schools location and performance map.

April 2016: APN: 124-340-34-00 Fallbrook, San Diego County, California, prepared by Leighton Consulting, Inc..

Groundwater and Surface Water

No standing or surface water was observed on the site at the time of our field exploration. Groundwater was encountered during this investigation at a depth of 28.2 feet (EL ~ 237) in LB-1 and 10.5 feet (EL ~ 230) in LB-3. Historic groundwater data, as indicated on the Department of Water Resources website for well number 333156N1171969W001, located approximately 1⁄4 mile southwest of the site adjacent the San Luis Rey River, reflect a maximum groundwater elevation of 203 feet (about 11 feet deep) in July 2012.

Dynamic Settlement (Liquefaction and Dry Settlement)

Based on County of San Diego Data maps, the property is adjacent a liquefaction susceptibility area (see Figure 5). Liquefaction-induced settlement is considered a geologic hazard at this site due to the presence of shallow groundwater (>50 feet). Additionally, based on our dry-settlement analysis using the peak ground acceleration (0.51g) and moment magnitude of 7.8, the total dynamic settlement resulting from a design level earthquake is expected to be approximately than 21⁄4 inches on this site. The dynamic- induced differential settlement is expected to be less 1 inch in a 40-foot horizontal distance

3.2.1 Undocumented Fill

Approximately 2.5 feet of undocumented fill soil was encountered in boring LB-1 located in the northeast portion of the site. As encountered, the fill soil consisted of moist, silty sand. Undocumented fill was not encountered in the remainder of our geotechnical borings; however areas of undocumented fill may be present throughout the site. This unit is not considered suitable for the support of structures or engineered fill and should be removed and recompacted in accordance with the recommendations of this report.

3.2.2 Young Alluvium

Quaternary-age young alluvial soils were encountered in our borings located in the lower elevation portions of the site (LB-1, LB-3, LB-5 and LB-10) to depths ranging from 5.0 feet (LB-5) to the maximum depth of exploration, 51.5 feet, (LB-1) below ground surface (BGS). As encountered, these alluvial soils consist of dry to wet, loose to dense, silty sands and sandy clays with varying amounts of gravel.

2015, December 1: Measuring elementary school capacity. School Planning and Management, .

February 6, 2017: sues BUSD over its lease-leaseback construction contract, the fact that plans were not approved by the DSA’s Office before contracting and that no EIR had been completed on the Gird Road property: Complaint for reverse validation, declaratory and injunctive relief, California Taxpayers Action Network v. Erickson-Hall Construction Co., Bonsall Unified School District, et al., Superior Court of California.

March 2017:‘s analysis of the Request for Proposals for Lease-Leaseback related services.

June 2017: CATE’S Interim Property Summary and Evaluation for BUSD High School.

June 2016:  Bonsall Unified School District (BUSD) continuing disclosure report, financial statements, for fiscal year ending June 30, 2016 and BUSD’s Annual Financial Report, year ending June 30,2016 states, “In 2016-17, the high school’s enrollment reached 226 in 9th to 11th grade.” The report explains the BUSD is pursuing strategies designed increase enrollment, “The District has the opportunity for growth at the high school if it can retain more of the 8th graders. About 40% of the 8th grades continue on with the District and articulate on to the high school. The District is addressing this with its course offerings. Bonsall High School now offers sports, STEM classes, and college classes through a partnership with one of the local community colleges.” The report also noted, “Unfortunately the District has also experienced a decrease in enrollment over the last three years in the transitional-kindergarten to 3rd grade span. This has been attributed to troop downsizing at the nearby military base of Camp Pendleton and its demographic profile of young families.” K-3 enrollment peaked in 2013-14 at 1,134 and dropped to 1,054 in 2016-17.

Screen Shot 2018-01-09 at 11.39.24 AM

Financial Reports: See reports at bottom of this page.

July 2017: Agenda for July 13, 2017 BUSD Board Meeting states, “The District has been deficit spending since the 2011/12 fiscal year, a total of six years; this structural imbalance of revenues versus expenses (unrestricted and special education combined) is an unsustainable trend. The year prior in 2010/11, the District had an unrestricted ending balance available for reserves of $4.0 million and total expenses of $13.1 million or 30.8%. In the transpiring six years, the ending balance available for reserves has eroded down to 5.3% which is above the legally required 3%. The multi-year projections show the District ending the 2019/20 fiscal year with an ending balance available for reserves of 0.4%, far below the legally required 3%. The District is in need of budget reductions of approximately $150,000 in 2017/18 and possibly another $100,000 in 2018/19.” A BUSD Budget Reduction presentation on the situation outlines the dire financial situation.  The presentation includes this chart:

Screen Shot 2017-07-14 at 2.53.56 PM

ENROLLMENT/ATTENDANCE: BUSD’s high school enrollment declined from 235 students reported to the press in September 2016 to its website reporting 228 students (grades 9, 10 and 11) housed in a new 18,000 sq. ft. building (350 student capacity) located at the Sullivan campus. Including ten classrooms in the new building, BUSD has a total of 18 classrooms dedicated to the high school. At 27 students per classroom, that is a capacity of 486. According to reports related to BUSD’s debt obligations filed March 2017, total attendence is/was as follows: Screen Shot 2017-03-27 at 5.47.47 PM

Therefore, average daily attendance for the new high school was 31.74 in 2014-2015, 133.12 in 2015-2016 and 218.37 in 2016-2017. BUSD;s 2017-2018 Budget projects a total of 352 high school students for 2019/2020 and reports, “Typically 40% of our 8th grade population articulates (SIC) to BHS…THIS YEAR 45%” Total enrollment reported at 2,464 (down from 2,554 reported in the fall of 2017) with Average Daily Attendance of 2,240 out of a capacity of 2,939.


53094. (a) Notwithstanding any other provision of this article, this article does not require a school district to comply with the zoning ordinances of a county or city unless the zoning ordinance makes provision for the location of public schools and unless the city or county has adopted a general plan.


District Organization. Reference for procedures and responsibilities for all parties involved in the school district organization process.


Procedures / Guidelines

Learn from planners how school sprawl contributes to urban sprawl.

Ocean_Breeze_report, downloaded from Planning and Development Services, LUEG GIS, County of San Diego.

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School Reports

Find a SARC (School Accountability Report Card). California Department of Education.

Official State Enrollment Records.

Fiscal Health, Fiscal Oversight and Intervention (County and State).

Percentage of property taxes (45.6%) going to schools, FY 2017-18. San Diego County.

Test results for English language arts/literacy and mathematics. Department of Education, State of California. See overall achievement, all grades, 2017, for Bonsall High and Fallbrook High.

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Naylor Act

The Naylor Act allows other agencies of government to acquire surplus developed school grounds and keep it available for playground, playing field or other outdoor recreational and open-space purposes. Naylor does not apply to sites that have not been developed or built out as community assets (playgrounds, schools, etc).  Defined in Section 17489 and Section 17490 of the California State Education Code.

Checklist for sale or lease of school district surplus property. By Lozano Smith, attorneys at law. Revised July 2016.

The Naylor Act, Citizens for Responsible Development, Cypress, CA.

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Mitigation Banking Resources

Mitigation Banking Factsheet, created by Section 404 of the CWA. Environmental Protection Agency.

Library Meeting presentation at the Fallbrook Library, given by, January 2016, updated March 2016.

The Presidential Memorandum and Interior Department Policy on Mitigation: Their Content and Implications. By Thomas Jensen, Bailey Schreiber and Sandra Snodgrass, Holland & Hart, Nov. 9, 2015.

Public access is banned on mitigation bank land. “The California multi-agency Project Delivery Team developed this general outline to assist in the development of the Long-term Management Plan for mitigation banks. (Template Version Date: May 2008)” See p.10, “B. Security, Safety, and Public Access: The Bank will be fenced and shall have no general public access, nor any regular public or private use.”

Project Manager for the San Luis Rey Downs Golf Course mitigation land project, Shanti Abichandani Santulli, Acting Team Lead, Carlsbad Field Office, South Coast Branch, U.S. Army Corps of Engineers, Regulatory Branch,, (760) 602-4834, explains:

“To answer your question regarding if mitigation bank land would be accessible to the public for hiking and other uses, in short, areas preserved for compensatory mitigation for impacts associated with Corps-authorized permits (per the Corps current regulations on mitigation) should be preserved for habitat/aquatic resource conservation purposes and preservation mechanisms required for these sites should prohibit incompatible uses. These incompatible uses can include hiking and other recreational uses. However, there are mitigation sites that have trails and other recreation uses alongside the conserved mitigation areas, so such uses can be considered directly adjacent to a mitigation area, but not within the preserved areas. I hope this helps clarify.”

Panel defends, explains mitigation, conservation land. By Debbie Ramsey, The Village News, Feb. 25, 2016.

There’s a lawsuit in San Diego that began in 1951. Fight for water between military and Fallbrook spurs county’s oldest, active civil case. By Kristina Davis, San Diego Union-Tribune, Feb. 20, 2016.

San Luis Rey Wetland Restoration / Mitigation Bank Project. Final Mitigated Negative Declaration. Prepared by HELIX Environmental Planning for City of Oceanside Planning Department, June 2014.

“‘Mitigation bankers’ see profit in turning developed land back into natural habitat.” Looks at San Luis Rey River Valley, including info on the golf course. KPBS, Feb. 12, 2015.

The Singh family was reluctant to let go of even this small part of the land it has farmed for so long. But Brian Monaghan, vice president with Wildlands, said the company was able to offer a strong incentive, because restoring wetlands generates millions of dollars in mitigation credits.

“My guess is that they’ll probably be about half a million dollars per acre, so not cheap,” he said. “So we would sell these wetlands to third parties that have permits from either the Army Corps or the California Department of Fish and Wildlife. That could be your local highway department, it could be the City of Oceanside, it could be a developer who’s developing somewhere here in the region.”

Monaghan would not reveal how much Wildlands, a private, for-profit company, offered the Singh family for the land. Krishna Singh, the owner’s son, said it was a difficult decision for the family, but they support the goals of the mitigation bank, and agreed to grant the company an easement for the project. The farm will continue to grow vine-ripe tomatoes in the fields around the recreated riverbed.

Opinion: Why locals shouldn’t be upset over a mitigation bank moving in. By William Coleman, Ecosystem Marketplace, Dec. 30, 2014. NOTE: includes chart showing average price per acre for mitigation credits/land in San Diego County is booming, at $380,000/acre!

“Golfers bristle as San Luis Rey ‘Drowns’. Bonsall’s San Luis Rey Downs could be turned into wetlands.” San Diego Union Tribune, Feb. 16, 2014.

The immediate demand for mitigation land is expected to come in part from state road-widening projects and from San Diego Gas & Electric’s work on transmission lines.

The U.S. Marine Corps Base Camp Pendleton has also indicated it may need a number of credits for wetland, stream, and species mitigation.

Over the long term, the company said it expects overall demand for credits to grow as cities such as San Marcos and Escondido expand and the local real estate market improves.

New paper offers guidance on wetland mitigation banking risks. By Kelli Barrett, Ecosystem Marketplace, Jan. 23, 2014.

Legislation would steer DOT wetlands money to private industry with poor track record. By Craig Pittman, Tampa Bay Times, Feb. 8, 2012.

“Mitigation banks” for wetland conservation: A major success or an unmitigated disaster? By Shelley Burgin, Wetlands Ecology and Management, February 2009.

Special Report: Vanishing Wetlands. St. Petersburg Times [Florida], 2006. Extensive investigative series on booming gold rush in mitigation land banking, fueled by unlimited tax dollars and the Clean Water Act agency Guidance. Includes criticism of land banks selling credits for land that is dry, fraud, lack of oversight.

Wetland mitigation banking. By Robin Meadows, Ecosystem Marketplace, 2005.

Conservationists’ biggest criticism of mitigation banking is that it has historically emphasized acreage over ecosystem services. Notably, wetland mitigation was slammed for failing to meet the federal goal of no net loss of wetland function by the 2001 National Academy of Sciences report Compensating for Wetland Losses Under the Clean Water Act, which found that “the area of a wetland type is often used as a proxy for wetland functions” and cautioned that “the establishment of wetland structure does not necessarily restore all the functions of a wetland ecosystem.”

Wetlands. USDA Natural Resources Conservation Service.

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County Scenic Corridors / Fallbrook Community Trails

County Scenic Corridors. Established under CEQA, of the County Scenic Highway System. Gird Road/Live Oak Park/Mission Road.

Early County Scenic Highway/Corridor documents.

Guidelines for Determining Significance and Report Format and Content Requirements, Dept. of Planning and Land Use, Dept. of Public Works, County of San Diego, July 30, 2007. Subchapter 2.1: Visual Resources.

Section 4.1, Aesthetics and Visual Resources. San Diego Forward: The Regional Plan, Program Environmental Impact Report.

Legal Notices, the Coast News Group, April 3, 2015.

“School Sprawl” by Edward T. McMahon, Planning Commissioners Journal, summer 2000.

Fallbrook Community Trails and Pathways Plan.

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Conservation Easements, Wildlife Habitat

Gird Valley was homesteaded in the late 1800s. It has been home to cattle ranchers, beekeepers and avocado farmers who created the course on the agricultural land below the frost line in the 1960s. Neighborhoods were built around this Open Space which serves as the cornerstone of Gird Valley. In more recent years, vineyards have been developed. Fallbrook Winery, the largest winery in San Diego County, is situated on the western ridge of Gird Valley.

The historical zoning of the Monserate Winery property is Agricultural with special use permits for operation. The parcel consists of 116 acres made up of 9 tax assessors’ parcels but it is only 2 legal parcels. The owners, Fallbrook residents Jade and Julie Work and family, have committed to preserving the land from development via the use of conservation easements.

Next door to Monserate Winery is the Gird Valley Preserve, 47.74-acre Open Space valued for its wildlife habitat and owned by the Fallbrook Land Conservancy which has done a Habitat Assessment. A substantial population of birds and wildlife species are resident on the preserve, the vineyard, the Golf Club of California at the southern end of Gird Valley, in Live Oak Creek and in the ponds in the valley. The area is a wildlife corridor and is resplendent with many ancient live oaks, sycamores and other native species. Gird Road is also home to many historically significant structures.

Benefits for landowners of conservation easements. Land Trust Alliance.

Income tax incentives for land conservation. Land Trust Alliance.

Private lands conservation: Conservation easements. The Nature Conservancy.

Trump’s golf courses expose conservation quagmire. By James Moorhead, LandThink, Mar. 28, 2016.

IRS tees off on golf courses’ green tax claims. By Richard Rubin, The Wall Street Journal, Jan. 4, 2016.

Kiva Dunes Conservation LLC et al. v Commissioner of Internal Revenue. Memorandum findings of fact and opinion, June 22, 2009. See also: Conservation Easement and Declaration of Restrictions and Covenants, Dec. 31, 2002.

Avian diversity on golf courses and surrounding landscapes in Italy. By Alberto Sorace and Marta Visentin, Landscape and Urban Planning, 81 (2007) 81-90.

Inter-reserve distance. By Craig L. Shafer, Biological Conservation 100 (2001) 215-227.

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Donation Appeal

Download and print our donation appeal here.

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Past election results for San Diego County Register of Voters.

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