Del Mar Horsepark

Current Status of Equestrian Activity

In December 2020, all equestrian activity at Horsepark, including horse shows, boarding, and training, were paused in order to allow public input into the process of evaluating further the necessary investment to meet Regional Water Quality Control Board requirements for equestrian activities while simultaneously considering the needs of the community.

In January 2021, the 22nd DAA board appointed an ad-hoc committee whose sole purpose is to gather the community input and work with staff to identify possible resolutions that would result in equestrian activity resuming at Horsepark in 2022.

Over the past several months, the Horsepark Ad-hoc Committee has been working with staff and the community to develop a better understanding of the range of cost estimates for the water quality improvements, historic profit and loss of the operation, past capital investments and improvements, estimated costs for needed future capital investments and improvements, consideration for the potential changes in requirements associated with RWQCB permits, and funding opportunities.

Below is a timeline and summary of significant information and action taken to date.

Proposals for RFP #21-04 Equestrian Center Operator (Horsepark) are due October 14, 2021.

Brief History on the 22nd DAA Acquisition of Horsepark:

The 22nd DAA’s 1985 Master Plan and Environmental Impact Report (EIR) identified the need to mitigate parking impacts through the acquisition of an off-site parcel that could be used for parking during the Fair. In 1991, the Showpark of San Diego became available for purchase and thus began the process to purchase the facility including an appraisal of the facility. After two years of negotiations, a purchase price of $4.2 million was agreed upon and escrow closed on November 15, 1993. Shortly thereafter, the previous owner was compensated for personal property and ongoing business and immediate improvements were made to the facility, bringing the total purchase price to $4.9 million, funded by the Race Track Authority/Race Track Leasing Commission (RTA/RTLC).

The name of the facility has since been changed to Horsepark.

In 2005, the 22nd DAA went before the California Coastal Commission to permit essentially all of the structures on the site. Unbeknownst, the previous owner never sought Coastal Development Permits for the property. Ultimately, the permit approved the structures after-the-fact and provided for plumbing all wash racks and the existing restroom to sewer, relocation of the existing water tower, and the provision of a buffer between the facility and the wetland resources of the San Dieguito River.

Timeline of Events

2015: State Water Resources Control Board adopted a new Industrial General Permit (IGP) that included equestrian facilities greater than 499 horses (Large CAFO – Concentrated Animal Feeding Operation – see explanation below). This applied to the 22nd DAA’s main campus due to horse racing and eventually led to the Water Quality Improvement project currently underway.
May 2019: The Regional Water Quality Control Board (RWQCB) adopted Conditional Waiver for Low Threat Discharges which requires enrollment for equestrian facilities of between 150 to 499 horses (Medium CAFOs).
September 2019: The 22nd DAA submitted its notice of intent to enroll in the Conditional Waiver. The notice of enrollment included a commitment to cease hosting horse shows in excess of 499 horses, thereby avoiding the Large CAFO classification. The 22nd DAA estimated that the cost of the remediation necessary to comply with the Conditional Waiver would be approximately $3 million.
January 2020: The 22nd DAA ceased hosting large horse shows in excess of 499 horses at Horsepark.
March 2020: The 22nd DAA obtained coverage for Horsepark under the Low Threat Conditional Waiver and agreed to a schedule of the previous mentioned improvements estimated to cost approximately $3 million.
April 10, 2020: San Diego Regional Board (Regional Board) notified two similar Medium CAFOs in Orange County that they are required to obtain coverage under the Industrial General Permit (IGP) unless they can demonstrate that there are no “Discharges pollutants (including manure or process wastewater) into waters of the United States through a man-made ditch, pipe, or similar device. (40 C.F.R. § 122.23, subd. (b)(6).)”.
November 11, 2020: Equestrian Services, another similar Medium CAFO in Orange County, entered into a consent decree requiring it to enroll in the IGP and develop a Nutrient Management Plan that includes a 10 year/24-hour retention standard to address the requirements of the Low Threat Waiver. The consent decree was reviewed and approved by District Court and the Department of Justice. The Regional Board did not voice any objections.
December 2020: The 22nd DAA announced a pause of equestrian activity at Horsepark.
January 1, 2021: Rancho Sierra Vista, another similar Medium CAFO in Orange County, entered into a consent decree requiring it to enroll in the IGP and develop a Nutrient Management Plan that includes a 10 year/24-hour retention standard to address the requirements of the Low Threat Waiver. The consent decree was reviewed and approved by the District Court and the Department of Justice. The Regional Board did not voice any objections.
Given the similarity of Horsepark to the previous mentioned facilities in Orange County, the 22nd DAA took the responsible course of action to protect itself from possible third party civil actions and paused equestrian activities at Horsepark in 2021 while seeking answers to these latest developments in order to determine if the 22nd DAA will be subject to enrolling Horsepark in the IGP.The estimate to address the requirements of the IGP or to demonstrate non-discharge to a Water of the United States is in the range of an additional $3 to $5 million in addition to costs to address the requirements of the Low Threat Waiver – for a total of $6-8 million.
January 29, 2021: The Horsepark Ad-hoc Committee hosted a public workshop to allow a fuller and further discussion about regulatory requirements, fundraising interests, etc. View meeting here.
March 1, 2021: The 22nd DAA sent a letter to the Regional Board to directly address the uncertainty regarding what may be required at Horsepark so that the 22nd DAA Board can make an informed decision on a path forward.
March 25, 2021: The Regional Board officially responded to the inquiry and confirmed that in order to have coverage under the Waiver permit, the 22nd DAA must continue implementation of the waste management measures identified in the Waiver. If the storm water management measures/best management practices required by the Waiver are not being implemented, the 22nd DAA would not be covered by the Waiver. Additionally, the response confirmed that the 22nd DAA will need to enroll Horsepark in the Industrial General Permit (IGP) for Medium CAFOs (150 to no more than 499 horses). Estimates for compliance with the IGP at this level is $3 – $4 million, Waiver plus IGP (85th percentile Storm Event (.65″).
June 8, 2021: The Committee presented three potential scenarios for the 22nd DAA Board’s consideration and ultimate determination of the path forward in resuming equestrian activity at Horsepark in 2022, including:

  • The 22nd DAA continues to operate Horsepark
  • The 22nd DAA enters into a public/private partnership to invest in and operate Horsepark
  • The 22nd DAA contracts with an operator to make the investment into Horsepark

Staff was authorized to draft a request an RFP for a lease to return equestrian activities and other traditional uses to Horsepark, noting the lease should:

  1. provide that the lessee pay for any required regional water quality control board water quality improvements;
  2. that if the strategic planning process requires it, the lease would allow the board of the 22nd DAA to terminate the least after no less than five years and depending on that lease term, accommodate the possibility of a reimbursement to the lessee of a pro rata portion of the water quality improvement costs; and
  3. maximize revenue opportunities to the 22nd DAA.
September 3, 2021 22nd DAA posted RFP #21-04 Equestrian Center Operator (Horsepark); proposals due October 14, 2021.

Concentrated Animal Feeding Operation (CAFO)

The National Pollutant Discharge Elimination System (NPDES) regulations define a Concentrated Animal Feeding Operation (CAFO) as any Animal Feeding Operation (AFO) that either meets a certain animal population threshold, or, regardless of population, is determined to be a significant contributor of pollutants to waters of the United States by the appropriate authority [40 C.F.R. § 122.23(b)(2)].  CAFOs apply to all types of animals including cattle, swine, chicken, and dairy cows, and are the best fit for equestrian uses. For the purposes of equestrian uses, there are three CAFO classifications:

  • Small – up to 149 horses
  • Medium – 150 to 499 horses
  • Large – more than 499 horses


The primary reason for the large differences in costs are related to several different potential scenarios. The 22nd DAA based its costs off the implementation of the Waiver permit, plus these scenarios. As a reminder, the original estimate for the Waiver is approximately $3 million.

  • Compliance with the existing Waiver: ~$3 million
  • Waiver + IGP at a 85th percentile Storm Event (.65″), Medium CAFO only: $3-$4 million
  • Waiver + IGP at a 10-year Storm Event (2.5″), Medium CAFO only: $4-$6 million
  • Waiver + IGP at a 25-year Storm Event (3.25″), Large CAFO permissible: $6-$8 million

Additionally, these costs could change based on the design and layout of the facility. Current estimates are based on continuance of 2020 operations of 499 or less horses with all stabling, both permanent and temporary, in their historic locations. A design that consolidated stabling areas could potentially reduce costs.

About the Horsepark Facility

Del Mar Horsepark

Del Mar Horsepark is a 64-acre equestrian facility located about three miles east of the Del Mar Fairgrounds, at the corner of El Camino Real and Via de la Valle in the San Dieguito River Valley. Nestled in a serene tree-lined setting, this facility includes RV hook-ups and plenty of parking.

Download Building Diagram

  • Adjoining Restrooms

  • ATM

  • Audio System

  • Box Office

  • Built-in Concession Stands

  • Electricity

  • Offices

  • Public Phones

  • Storage

  • Water

  • WiFi


covered lighted arena


SeatingTwo Grass Jumping Stadiums


permanent show stalls


show rings


training rings


dressage ring


per day


Square Feet

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