Yesterday, Friday June 10th, the State Clearinghouse published a Notice of Preparation (NOP) for an Environmental Impact Report (EIR) on the proposed Creekside Middle School. What this means is:

• San Juan Unified School District is quickly moving ahead with its proposed Middle School
• The EIR is a document by which the school board can comply with state law by learning about the effect on the environment of building the school
• There is a 30 day period from June 10th to comment on what the EIR should cover
• State and local agencies learn about the proposal from the NOP (if they are watching) and now, Dear Reader, so do you

The most effective comments involve what the courts call a "fair argument", backed up by evidence. So while "I'm worried about the traffic" works as a comment, "My car has been hit three times in the last 2 years by trucks trying to squeeze by the cars parked on both sides of Elvyra" works even better. One of the typical ways that public comments are belittled is for the project proponent to say that one-time traffic counts and engineers' formulas for projected trips don't equal traffic to be concerned about. Thing is, formulas and bean counts do not take behavior (like speeding or distracted driving) into account. You can be impressed by spreadsheets and technical data all you like, but it is a different story if your kid is hit by a speeding car on El Camino.

And in case any of you are confused by the title of our post, we remind you that this project is very much an instance of cart-before-the-horse; the project has been done backwards so far. The claimed need for 3 middle schools within a 3-mile radius has not been convincing during a time of declining enrollment. The school district's Strategic Plan and Facilities Plan say nothing about the need to move the middle school kids away from Encina, nor do they discuss alternative sites, and they don't explain how the district will pay the $50 million dollars it needs for the project. The school board made a decision and now they are trying to get the decision to fit the narrative - using "community meetings" and "environmental analysis" as after-the-fact cover. State law and regulations about how public policy-making bodies are supposed to make decisions are not intended to work that way. State law and regulations are meant for such decisions to be made in the sunshine, with transparency in order for the public to weigh in and so the final decision will be shaped by the public.

There is also a question of how the "project" is defined. Is the "project" the removal of middle school students away from the Encina High School campus? Is it re-purposing a designated surplus school site from an old elementary school and temporary adult education center into a middle school of more than twice the population of the former elementary school? Or is it both of those things? Beyond that, how was the site selected for the new use? In the profession of architecture, the constraints of a site are supposed to inform the design of the building(s). What the school district has done instead is pick the buildings for its campus before getting information about the site - including information from the public and other public agencies. Why did they do that? Because they have a slick cookie-cutter design for both the Arcade Middle School and Creekside Middle School campuses. That let's them focus on the relationships of the classroom spaces with the other middle school functions - the total "learning experience" - without being bothered much by the silly constraints of the site and its setting in the community. It was so, so convenient that there were about 8 acres of "under utilized" school property handy at Creekside. The result is the Creekside campus plan just barely skates past the state's regulations for middle school size and features. In other words, "the kids" the school district claims to value so much wind up getting something less at Creekside than they would at an adequately-sized campus. And the community? Well, isn't it obvious the community doesn't really matter? Still, that's why it is important for the public to engage. Remember, it's your children, your future labor force, your tax dollars, your property values, your streets, your creek, your community that is at stake here. Do those things matter to you? The comment clock is ticking.