Del Mar is preparing another round of comments on an updated Notice of Preparation for the proposed multi–billion dollar project to move a 2-mile stretch of rail off the city’s eroding bluffs by 2035.

The deadline for the public and government agencies to submit public comments to the San Diego Association of Governments, which is managing the project, is June 30.

SANDAG now has four new alignments and one no-build option, which would require reinforcing the current alignment.

The city’s comments address “concerns regarding the vague and incomplete project objectives, project description, and the insufficient level of detail provided for the four alternative alignments,” according to an agenda report.

The council also discussed the city’s chances of becoming the lead agency on the project. Ralph Hicks, a city attorney, said “we feel we meet every one of those criteria” to be lead agency under the California Environmental Quality Act.

Hicks also said there are challenges the city can pursue if SANDAG rejects Del Mar as lead agency.

“I think there are multiple judicial pathways, but there is first the administrative pathway if we consult with SANDAG,” he said. “Assuming a negative response from SANDAG, then we would take it to the Land Use and Climate Innovation agency, and have them arbitrate it and we would go from there.”

SANDAG released an initial Notice of Preparation last year that listed three routes: two different tunnel options through Del Mar and a tunnel that would start farther north in Solana Beach and the Del Mar Fairgrounds.

None of those options were well-received by those nearby. Del Mar residents have been opposed to any tunneling under the city, and the city has still not officially endorsed any particular alignment. Solana Beach and the Del Mar Fairgrounds were caught off guard by the relatively sudden inclusion of the third option.

In response, SANDAG reconsidered the possible routes, leading to the most recent Notice of Preparation released last month with the four options: two tunnel options through Del Mar, an Interstate 5 alignment that avoids both cities and the fairgrounds, and a double track reinforced option that keeps the current alignment in place.

Councilmember Dan Quirk said he thinks nothing will be built, citing ridership numbers.

“We can continue to go down this process and we will,” he said, “but we should also advocate for an economic analysis, a cost-benefit analysis, at some point in this multi-year environmental review process, because as soon as those numbers come to light, this project will be killed.”