HomeMy WebLinkAbout2025-04-22; City Council; 04; Fiscal Year 2023-24 Growth Management Program Monitoring ReportDocusign Envelope ID: C5C5E5E3-DAC0-4C3A-8AD5-16FE71DBA309
Meeting Date:
To:
From:
Staff Contact:
April 22, 2025
Mayor and City Council
Geoff Patnoe, City Manager
Jennifer Jesser, Senior Planner
jennifer.jesser@carlsbadca.gov, 442-339-2637
CA Review CKM
Subject: Fiscal Year 2023-24 Growth Management Program Monitoring Report
Districts: All
Recommended Action
1. Hold a public hearing; and
2. Adopt a resolution accepting the Fiscal Year 2023-24 Growth Management Program
Monitoring Report and finding that it satisfies the city's monitoring requirements.
Executive Summary
The city's Growth Management Program has guided the growth of Carlsbad since the 1980s.
This report on the city's Growth Management Program is presented to the City Council each
year in accordance with Carlsbad Municipal Code Chapter 21.90 -Growth Management,
Section 21.90.130(d). The report includes the status of development activity, the adequacy of
public facilities and public facility financing.
This year's report shows that all public facilities identified in the Fiscal Year 2023-24 Growth
Management Program Monitoring Report meet the required facility performance standards for
FY 2023-24. Regarding the Circulation performance standard, the report includes the status of
the vehicle mode of travel. The status of the pedestrian, bicycle and transit travel modes will be
addressed separately at a later date.
Exhibit 1 is a resolution accepting the Fiscal Year 2023-24 Growth Management Program
Monitoring Report and finding that it satisfies the city monitoring requirements, as established
in Section 21.90.130(d). The monitoring report is included as Attachment A to Exhibit 1.
Explanation & Analysis
Background
The City Council approved an ordinance in 1986 that established a growth management
program with a requirement that new development construct and pay for the public facilities
needed to serve the development. Developers either build the improvements themselves or
pay fees to the city so the city can construct the facilities.
Carlsbad voters affirmed the general principles of Carlsbad's Growth Management Program
when they passed Proposition E in November 1986. Proposition E also established limits, or
caps, on the number of homes in the city. However, as described in the monitoring report, state
housing laws preempt the city's ability to require compliance with the housing caps.
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Also in 1986, the City Council approved a Citywide Facilities and Improvements Plan that
included performance standards for the following eleven public facilities:
City administration
Library
Parks
Drainage
Fire
Open space
Schools
Sewer col lection
Water distribution
Wastewater treatment Circulation
These performance standards are applied citywide, by city quadrant, by local facility
management zone or by project site, depending on the facility. New development must comply
with the public facility performance standards.
FY 2023-24 Growth Management Program Monitoring Report (Exhibit 1, Attachment A)
The report includes:
• An analysis of the public facility performance standards, including the current status of
each facility and the projected status for when the community is built out (i.e., fully
developed). This analysis shows:
o All public facilities identified in the report met the required performance
standards during fiscal year 2023-24. The report also identifies that when the city
is built out, additional facilities will be needed to meet the standard for city
administrative facilities, libraries, parks, drainage, circulation, open space, sewer
collection and water distribution.
o The previous year's report did not identify that additional facilities would be
needed for administrative facilities or parks. However, the Housing Element
Rezone Program approved in January 2024, described below, resulted in more
future dwellings and an increased population at buildout. This increased
population results in the need for additional future administrative facilities, as
well as additional future park acres in the northeast quadrant, to meet standards
at buildout.
o The status of the circulation performance standard shows the vehicle mode of
travel currently meets the performance standard, except where streets have
been exempted from the standard. The status of the pedestrian, bicycle and
transit travel modes will be addressed separately at a later date.
• A summary of development activity during the reporting period
o Building permits were issued for 500 new dwelling units (427 primary dwelling
units and 73 accessory dwelling units).
o Building permits were issued for 181,758 square feet of new non-residential
space.
• An updated resident population and existing dwelling unit inventory
o The total existing dwelling units in Carlsbad, as of June 30, 2024, is 47,714 and
the existing population estimate is 117,322.
• An analysis of the Proposition E residential dwelling unit caps
o As described in the report, state housing laws preempt the city's ability to
require compliance with the Proposition E dwelling unit caps. The report
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analyzes the Proposition E dwelling unit caps for reference purposes only and
shows that the existing and planned unbuilt dwellings during fiscal year 2023-24
exceed the dwelling unit caps in the northwest and northeast quadrants, as well
as the citywide cap.
• A description of the 2024 Housing Element Rezone Program
o The City Council approved the rezoning of properties around Carlsbad on Jan. 30,
2024. The rezone program was necessary to meet state housing requirements.
The program resulted in an increase in the number of future dwellings, which at
buildout will exceed the Proposition E dwelling unit caps in the northwest and
northeast quadrants, and citywide. The tables below show the estimated
dwellings at buildout comparing the dwelling caps for the previous reporting
period (FY 2022-23) and for this reporting period (FY 2023-34), which includes
the additional future dwellings resulting from the rezone program. The buildout
analysis for each public facility performance standard addresses the future
dwellings from the rezone program.
FY 2022-23
Estimated dwellings at buildout compared to Proposition E dwelling caps
Northwest Northeast Southwest Southeast Citywide Quadrant Quadrant Quadrant Quadrant
Proposition E 15,370 9,042 12,859 17,328 54,599 dwelling caps
Estimated dwellings 15,334 8,940 11,924 17,022 53,220 at buildout
Above/ below 36 102 934 306 1,379
dwelling caps below below below below below
FY 2023-34
Estimated dwellings at buildout compared to Proposition E dwelling caps
Northwest Northeast Southwest Southeast Citywide Quadrant Quadrant Quadrant Quadrant
Proposition E 15,370 9,042 12,859 17,328 54,599 dwelling caps
Estimated dwellings 17,215 9,608 12,260 17,270 56,353 at buildout
Above/ below 1,845 566 599 58 1,754
dwelling caps above above below below above
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Carlsbad Tomorrow Growth Management Citizens Committee
To address state housing laws and evaluate other issues affecting Carlsbad's growth, the City
Council established a goal in fiscal year 2021-2022 to "engage the community through a citizens
committee to create a new plan to manage growth in Carlsbad in a way that maintains an
excellent quality of life." The City Council approved the formation of the Carlsbad Tomorrow:
Growth Management Citizens Committee on March 8, 2022.
The committee met from March 2022 to April 2023 to review and identify key elements of a
new plan to manage growth in a way that maintains excellent quality of life and ensures
compliance with state laws. The committee's recommendations are provided in a report titled
"Carlsbad Tomorrow: Growth Management Citizens Committee Final Report April 2023." The
report was presented to the City Council on July 18, 2023.1
On Nov. 19, 2024, the City Council approved a plan to implement the committee's
recommendations (Exhibit 2). While changes to the Growth Management Program to
implement the committee's recommendations are pending City Council action, this report
provides information on the city's progress in 2023-2024 in implementing the existing Growth
Management Program.
Fiscal Analysis
There is no fiscal impact associated with this action.
Next Steps
The Fiscal Year 2023-24 Growth Management Program Monitoring Report will be kept on file
and posted on the city's website.
Environmental Evaluation
The proposed action is not a "project" as defined by California Environmental Quality Act
Section 21065 and CEQA Guidelines Section 15378(b)(5) and does not require environment
review under CEQA Guidelines Section 15060(c)(3) and 15061(b)(3), because the proposed
action to report on adherence to the city's Growth Management Program and the facility
performance standards contained in the program is an organizational or administrative
government activity that does not involve any commitment to any specific project which may
result in a potentially significant physical impact on the environment. Any subsequent action or
direction stemming from the proposed action may require preparation of an environmental
document in accordance with CEQA or the CEQA Guidelines.
Exhibits
1.City Council resolution
2.Staff report dated Nov. 19, 2024 (On file in the Office of the City Clerk)
1 More information about the committee's work and a link to the committee's report can be found at
carlsbadca.gov/city-hall/meetings-agendas/boards-commissions/growth-management-committee
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RESOLUTION NO. 2025-086
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD,
CALIFORNIA, ACCEPTING THE FISCAL YEAR 2023-24 GROWTH
MANAGEMENT PROGRAM MONITORING REPORT AND FINDING THAT IT
SATISFIES THE CITY'S MONITORING REQUIREMENTS
Exhibit 1
WHEREAS, in 1986, the Carlsbad City Council adopted the Growth Management Program to
ensure that adequate public facilities are provided concurrent with growth; and
WHEREAS the Growth Management Program is implemented through Carlsbad Municipal Code
Chapter 21.90 and the Citywide Facilities and Improvements Plan; and
WHEREAS Carlsbad Municipal Code Section 21.90.130{d) requires the City Planner to provide
to the City Council an annual Growth Management Program monitoring report that includes
information on development activity, public facilities and improvements, and public facility financing;
and
WHEREAS the Fiscal Year 2023-24 Growth Management Program Monitoring Report
(Attachment A) addresses the status of all public facility performance standards, except the status of
the Circulation performance standard for the pedestrian, bicycle, and transit travel modes, which will
be addressed separately.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as
follows:
1. That the above recitations are true and correct.
2. The proposed action is not a "project" as defined by CEQA Section 21065 and CEQA
Guidelines Section 15378(b)(5) and does not require environment review under CEQA
Guidelines Section 15060{c){3) and 15061{b){3), because the proposed action to report
on adherence to the city's Growth Management Program and the facility performance
standards contained in the program is an organizational or administrative government
activity that does not involve any commitment to any specific project which may result
in a potentially significant physical impact on the environment. Any subsequent action
or direction stemming from the proposed action may require preparation of an
environmental document in accordance with CEQA or CEQA Guidelines.
3. That the Fiscal Year 2023-24 Growth Management Program Monitoring Report satisfies
Carlsbad Municipal Code Section 21.90.130{d) by providing information to the City
Council regarding the status of the Carlsbad Growth Management Program for the fiscal
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year covering July 1, 2023 to June 30, 2024, except for the status of the Circulation
performance standard for the pedestrian, bicycle and transit travel modes, which will
be addressed separately.
4. That the Fiscal Year 2023-24 Growth Management Program Monitoring Report
(Attachment A) is accepted, and the City Planner shall file the report and post it to the
city website.
PASSED, APPROVED AND ADOPTED at a Regular Meeting of the City Council of the City
of Carlsbad on the 22nd day of April, 2025, by the following vote, to wit:
AYES:
NAYS:
ABSTAIN :
ABSENT:
April 22, 2025
Blackburn, Bhat-Patel, Acosta, Burkholder, Shin.
None.
None.
None.
KEITH BLACKBURN, Mayor
~ ~ ~
SHERRY FREISINGER, City Clerk
(SEAL)
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April 2025
CITY OF CARLSBAD
Fiscal Year 2023-24
Growth Management Program Monitoring Report
July 1, 2023 through June 30, 2024
Carlsbad City Council
Mayor Keith Blackburn
Mayor Pro Tern Priya Bhat-Patel, District 3
Council Member Melanie Burkholder, District 1
Council Member Kevin Shin, District 2
Council Member Teresa Acosta, District 4
Attachment A
Report prepared in cooperation with the following City of Carlsbad district and departments:
Carlsbad Municipal Water District
Community Development
Community Services
Fire
Library & Cultural Arts
Parks & Recreation
Public Works
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Introduction
This Growth Management Program Monitoring report for fiscal year (FY) 2023-24 (July 1, 2023 -June 30,
2024), is provided in accordance with Carlsbad Municipal Code Section 21.90.130(d), which requires the
preparation of an annual monitoring report on the Growth Management Program.
GROWTH MANAGEMENT PROGRAM OVERVIEW
The principle behind the Growth Management Program is to ensure that new development and growth
does not outpace the performance standards established for public facilities such as circulation facilities,
libraries, parks, open space, and facilities to provide water and sewer services. The City of Carlsbad's
Growth Management Program was created in 1986 and is comprised of:
• The Growth Management Ordinance (Carlsbad Municipal Code Chapter 21.90);
• The Citywide Facilities and Improvements Plan; and
• Proposition E, passed by voters in November 1986, established a cap on the number of residential
dwelling units in the city. The dwelling unit cap is no longer enforceable due to state law (see
"Impacts of State Law," below).
• Local Facility Management Plans for 25 local facility management plans
The Citywide Facilities and Improvements Plan specifies the performance standards for 11 public facilities,
as listed in Table 1. To ensure that the public facility performance standards could be achieved, the
Growth Management Program directed the development of financing and management plans describing
how/when the public facilities would be developed. The subsections below provide additional
information.
CARLSBAD TOMORROW: GROWTH MANAGEMENT CITIZENS COMMITTEE
The city's Growth Management Program was created in the 1980s and is largely credited with maintaining
the city's excellent quality of life, well-planned infrastructure, and financial health over the past 35+ years.
However, in recent years, state laws have suspended the ability of cities to establish or implement any
provision that limits housing development or population (see "Impacts of State Law," below).
To address state housing laws and evaluate the issues affecting Carlsbad's growth, the City Council
established a goal (fiscal year 2021-2022) to "engage the community through a citizens committee to
create a new plan to manage growth in Carlsbad in a way that maintains an excellent quality of life." The
City Council approved the formation of the Carlsbad Tomorrow: Growth Management Citizens Committee
on March 8, 2022.
The committee met from March 2022 -April 2023 to review and identify key elements of a new plan to
manage growth in a way that maintains excellent quality of life and ensures compliance with state laws.
The committee's recommendations are provided in a report titled "Carlsbad Tomorrow: Growth
Management Citizens Committee Final Report April 2023." The report was presented to the City Council
on July 18, 2023, at which time the council directed staff to return in 2024 with a work plan to implement
the committee's recommendations. The work plan was approved by the City Council on November 19,
2024.
2
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While changes to the Growth Management Program to implement the committee's recommendations
are pending City Council action, this report provides information on the city's progress in 2023-2024 in
implementing the existing Growth Management Program.
Table 1: Citywide Facilities and Improvements Plan Public Facility Performance Standards
Public Performance Status
Facility Standard on Page
City 1,500 sq . ft. per 1,000 population must be scheduled for construction 11
Administrative within a five-year period or prior to construction of 6,250 dwelling units,
Facilities1 beginning at the time the need is first identified.
800 sq. ft. (of library space) per 1,000 population must be scheduled for 13
Library1 construction within a five-year period or prior to construction of 6,250
dwelling units, beginning at the time the need is first identified.
Wastewater Sewer plant capacity is adequate for at least a five-year period. 14
Treatment
3.0 acres of Community Park or Special Use Area per 1,000 population 15
Parks1 within the Park District must be scheduled for construction within a five-
year period beginning at the time the need is first identified. The five-year
period shall not commence prior to August 22, 2017.
Drainage Drainage facilities must be provided as required by the city concurrent 17
with development.
Implement a comprehensive livable streets network that serves all users 18
of the system -vehicles, pedestrians, bicycles, and public transit.
Circulation Maintain LOS Dor better for all modes that are subject to this multi-
modal level of service (MM LOS) standard, as identified in Table 3-1 of the
General Plan Mobility Element, excluding LOS exempt intersections and
streets approved by the City Council.
Fire No more than 1,500 dwelling units outside of a five-minute response 27
time.
Fifteen percent of the total land area in the Local Facility Management 28
Open Space2 Zone {LFMZ) exclusive of environmentally constrained non-developable
land must be set aside for permanent open space and must be available
concurrent with development.
School capacity to meet projected enrollment within the Local Facility 33
Schools2 Management Zone {LFMZ) as determined by the appropriate school
district must be provided prior to projected occupancy.
Sewer Trunk-line capacity to meet demand, as determined by the appropriate 34
Collection
System sewer districts, must be provided concurrent with development.
Water Line capacity to meet demand as determined by the appropriate water 36
Distribution district must be provided concurrent with development. A minimum of
System 10-day average storage capacity must be provided prior to any
development.
1 The performance standards for city administrative facilities, library facilities, and parks are stated in terms of population, which
is discussed in the subsection below entitled "Population."
2 The performance standards for open space and schools are based on a "Local Facility Management Zone," which is discussed in
the subsection below entitled "Facility and Improvement Plans."
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LOCAL FACILllY AND IMPROVEMENT PLANS
To develop a road map for how the above standards could be met, a
Citywide Facilities and Improvements Plan was created in 1986 that
detailed how compliance with the performance standards will be
achieved, how the necessary public facilities will be provided, and
what financing mechanisms will be used for the facilities. Because
planned development and growth varies throughout the city and at
different levels, Carlsbad is divided into twenty-five local facilities
management zones (Figure 1). Each Local Facility Management Zone
has an adopted Local Facilities Management Plan . Consistent with the
Growth Management Program and the Citywide Facilities and
Improvements Plan, each Local Facility Management Plan must
describe how the Local Facility Management Zone will be developed,
how the required public facilities will be provided, and how those
facilities will be funded.
FAILURE TO MEET A PERFORMANCE STANDARD
Figure 1
The Growth Management Ordinance, Carlsbad Municipal Code Section 21.90.080, states:
"If at any time after preparation of a local facilities management plan the performance standards
established by a plan are not met then no development permits or building permits shall be issued within
the [affected] local zone until the performance standard is met or arrangements satisfactory to the city
council guaranteeing the facilities and improvements have been made."
As described in the following subsection, the city's ability to stop development due to lack of compliance
with a growth management performance standard has been largely preempted by recent state law.
IMPACTS OF STATE LAW
According to the Growth Management Program, development activity cannot proceed if either the
residential growth caps or public facility performance standards are not met. However, updates to state
law and the city's Housing Element have modified these components of the Growth Management
Program.
In 2017 the California Legislature passed SB 166, known as the No Net Loss Law, which requires local
jurisdictions to ensure that their housing element inventories can accommodate, at all times throughout
the planning period, their remaining unmet share of the regional housing need. The California
Department of Housing and Community Development (HCD) has taken the following positions with
respect to Carlsbad: that failure to meet the GMP performance standards cannot be used as a basis for
implementing a moratorium that precludes meeting Carlsbad's share of the regional housing need, and
that the GMP residential unit caps could not prevent the city from achieving consistency with the Housing
Element inventory and SB 166. In 2019, the legislature passed SB 330, the Housing Crisis Act of 2019,
which prohibits local jurisdictions from imposing moratoriums on housing development and using
residential housing caps or other limits to regulate the number of housing units built within a jurisdiction.
As noted in the City's May 5, 2020, staff report, Item 12,3 Senate Bill 166 of 2017 states that "Each city,
county, or city and county shall ensure that its housing element inventory ... can accommodate, at all times
3 City Council May 5, 2020 Staff Report, Item 12 available at: https://carlsbadca.swagit.com/play/05052020-1021#full-agenda
4
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throughout the planning period, its remaining unmet share of the regional housing need allocated
pursuant to Section 65584." Furthermore, where housing is an allowable use, Senate Bill 330 (2019)]
prohibits a city from enacting a "development policy, standard or condition" that would have the effect
of "imposing a moratorium or similar restriction or limitation on housing development ... other than to
specifically protect against an imminent threat to the health and safety of persons residing in, or within
the immediate vicinity of, the area subject to the moratorium ... "
The following state laws limit the city's ability to stop development:
• Senate Bill 166 (2017) states that "Each city, county, or city and county shall ensure that its housing
element inventory ... can accommodate, at all times throughout the planning period, its remaining
unmet share of the regional housing need allocated pursuant to Section 65584." The California
Department of Housing and Community Development has taken the position that exceedances of
the city's growth management standards cannot constitute a basis for implementing a moratorium
that precludes attainment of the city's regional housing need allocation.
• Senate Bill 330 (2019) prohibits a city from enacting a "development policy, standard or condition"
that would have the effect of "imposing a moratorium or similar restriction or limitation on housing
development ... other than to specifically protect against an imminent threat to the health and safety
of persons residing in, or within the immediate vicinity of, the area subject to the moratorium ... " On
April 17, 2020, the city received an opinion from the California Department of Housing and
Community Development, which states in part that a "housing moratorium adopted pursuant to the
City's [Growth Management Program] would be impermissible under Government Code section
66300 [Senate Bill 330]."
On April 17, 2020, the city received an opinion from the California Department of Housing and Community
Development regarding the city's ability to implement a moratorium under the City's Growth
Management Plan where vehicular deficiencies exist (CMC §§ 21.90.080 and 21.90.130) in light of SB 330.
The department's opinion concludes that "the housing moratorium adopted pursuant to the city's GMP
would be impermissible under Government Code section 66300." "HCD does not consider, however, that
general concerns about the health and welfare of the citizenry-including traffic conditions that cause
minor delays-present an imminent threat to health and safety." In City Council Resolutions No. 2020-104,
No 2020-105, No 2020-106, No 2020-208, the City Council similarly concluded that "The City finds that
Gov. Code § 65863(a) (SB 166 [2017]) and Gov. Code, § 66300(b)(l)(B)(i) (SB 330 [2019]) preempt the City
from implementing a moratorium pursuant to Carlsbad Municipal Code§§ 21.90.080 and 21.90.130 and
[Growth Management Program] regulations."
The city also reached similar conclusions with the adoption of its Housing Element in April 2021
(Resolution No. 2021-074.). That resolution states "Consistent with Updated Housing Element Program
2.2, the City Council finds that Government Code Sections 65583(a)(3) and 65863(a) (SB 166 [2017]) and
Government Code Section 66300(b)(l)(D) (SB 330 [2019]) preempt the city from implementing residential
growth management plan caps, residential quadrant limits, and residential control points. Consequently,
the City finds that it cannot and will not enforce these residential caps, quadrant limits, and control points,
including but not limited to those contained in the General Plan (including, but not limited to the Land
Use and Community Design Element Table 2-3, Section 2.6, Policy 2-P.8(a) and (b), Policy 2-P.16(d), and
Policy 2-P.57), Growth Management Plan (Proposition E); City Council Policy Statement No. 43, Carlsbad
Municipal Code Chapter 21.90 including but not limited to CMC §§ 21.90.030 (b), 21.90.045 and
21.90.185."
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SUMMARY STATUS OF PUBLIC FACILITY PERFORMANCE STANDARDS
As further detailed in this report and summarized in Table 2, during FY 2023-24 the city met the Growth
Management Program performance standards for the 11 public facilities.
Table 2: Public Facility Adequacy Status
Public Facility FY 2022-23 Adequacy Status Buildout Adequacy Status
(Meets performance standard?) (Meets performance standard?)
City Administrative Yes Additional facilities to be provided
Facilities
Library Yes Additional facilities to be provided
Wastewater Treatment Yes Yes
Capacity
Parks Yes Additional facilities to be provided
Drainage Yes Additional facilities to be provided
Circulation Yes* Additional facilities to be provided
Fire Yes Yes
Open Space Yes Additional facilities to be provided
Schools Yes Yes
Sewer Collection System Yes Additional facilities to be provided
Water Distribution System Yes Additional facilities to be provided
* The information on the status of the Circulation performance standard is provided in part by this report
(status ofthe vehicle travel mode). The status of the pedestrian, bicycle and transit travel modes will be
addressed separately.
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FY 2023-24 DEVELOPMENT ACTIVITY
Residential Development Activity
During FY 2023-24, building permits were issued for 500 new dwelling units (427 primary dwellings and
73 accessory dwellings). Table 3 indicates where the residential development activity occurred.
Table 3: FY 2023-24 Building Permits Issued -Dwelling Units
Quadrant Local Facility Management Zone Primary Dwellings Accessory Dwellings
1 168 44
Northwest 3 0 3
8 0 1
Total NW 168 48
Northeast 2 0 5
7 0 1
Total NE 0 6
4 0 1
5 259 0
Southwest 6 0 2
20 0 4
Total SW 259 7
6 0 9
Southeast 11 0 1
12 0 2
Total SE 0 12
Total Citywide 427 73
Figure 2 shows the recent five-year trend of building permits issued for dwelling units and shows that the
permits issued in FY 2023-243 were 107% more than the permits issued in FY 2019-20, 99% higher than
FY 2020-21, 342% higher than FY 2021-22, and 81% higher than FY 2022-23.
Figure 2 -Five Year Trend of Building Permits Issued for Dwelling Units
600 -0 ~ 500 V)
V)
-;;; 400 ..... • E 300 ,_
QJ
o.. 200
0.0
.!: 100 32 ·3 0 al
#
April 22, 2025
2019-20
500
2020-21 2021-22 2022-23 2023-24
Fiscal Year
Item #4
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Non-Residential Development Activity
During FY 2023-24, building permits were issued for 16,925 square feet of new commercial construction
and 164,833 square feet of new industrial construction. Table 4 provides a breakdown by quadrant and
Local Facility Management Zone, excluding the zones that had no building permit activity. Figure 3 shows
the recent five-year trend of building permits issued for non-residential construction. The amount of non-
residential square feet permitted in FY 2023-24 was 51% less than FY 2019-20, 16% less than FY 2020-21,
68% more than FY 2021-22, and 38% less than FY 2023-24.
Table 4 -FY 2023-24 Non-Residential Development
Quadrant Local Facility Commercial (SF) Industrial (SF) Combined (SF) Management Zone
3 3,427 -3,427
Northwest
Total NW 3,427 3,427
16 -164,833 164,833 Northeast 25 13,498 13,498 -
Total NE 13,498 164,833 178,331
Total Citywide 16,925 164,833 181,758
Figure 3 -FY 2023-24 Non-Residential Square Feet Permitted
April 22, 2025
400,000
350,000
"U El 300,000 ..... • E
,.._ 250,000
(!) c.. tti 200,000
(!)
LL e 1so,ooo
ro ~ 100,000 Vl
50,000
0
2019-20 2020-21 2021-22
Fiscal Year
2022-23 2023-24
Item #4
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Growth Management Program (Proposition E) Dwelling Unit Cap Analysis
In 1986, through Proposition E, voters limited the number of dwelling units in the city to the 54,599
dwelling units, and limited units in each quadrant, as shown in Table 5. However, as described in the
"Impacts of State Law" section above, state housing laws preempt the city's ability to require compliance
with the Proposition E dwelling unit caps. Table 5 shows the Proposition E dwelling unit caps for reference
purposes only and reflects the Housing Element Rezone Program that was approved by City Council on
January 30, 2024 (see section below).
Table 5 represents the number of existing dwellings and the number of future dwelling units ("unbuilt
planned dwellings"), as of June 30, 2024, that could be built (based on the applicable growth management
control point density) on all parcels that have a residential land use designation according to the General
Plan Land Use Map. The "total existing and unbuilt planned dwellings", as shown in Table 5, assumes all
parcels with a residential land use designation will be developed with residential dwellings, including land
that is currently developed with non-residential uses (e.g., churches and professional care facilities).
Table 5: FY 2023-24 Residential Dwelling Status Per Quadrant
As of June 30, 2024
Northwest Northeast Southwest Southeast Citywide
Quadrant Quadrant Quadrant Quadrant Total
Proposition E Dwelling Cap4 15,370 9,042 12,859 17,328 54,599
Existing Dwellings5 12,803 7,460 10,276 16,492 47,031
Unbuilt Planned Dwellings6 4,412 2,148 1,984 778 9,322
Total Existing and Unbuilt Planned Dwellings 17,215 9,608 12,260 17,270 56,353
Units below or above dwelling cap7 1,845 566above 599 below SB below 1,754above above
4 Proposition E dwelling caps are not enforceable and are shown here for reference purposes only (see the "Impacts of State
Law" section of this report.
5 Existing dwellings exclude accessory dwelling units and commercial living units. The number of accessory dwelling units and
commercial living units (professional care facilities) are shown in Table 7 for purposes of population estimates. Table 5
compares existing dwellings to the Proposition E dwelling unit caps, and for purposes of the dwelling caps, accessory dwellings
and commercial living units are excluded. California Government Code Section 65852.2 states that accessory dwelling units
shall not be considered in the application of any local ordinance, policy or program that limits residential growth. Regarding
commercial living units (e.g., professional care facilities, hotels, and time-shares), Carlsbad Municipal Code Section 21.04.093
states that such units are not considered dwelling units due to the assistance/services provided in conjunction with the living
unit and/or the use of the living unit for temporary lodging.
6 All quadrants except the Village -includes unbuilt approved projects, as well as vacant and underdeveloped property
designated for residential use by the General Plan.
7 For reference purposes only.
April 22, 2025 Item #4
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HOUSING ELEMENT REZONE PROGRAM
On Jan. 30, 2024, the City Council voted to approve the rezoning of properties around Carlsbad, as shown
below. The rezone program was necessary to meet state housing requirements, as required by Housing
Element Program 1.1.
April 22, 2025
Figure 4-Housing Sites Approved for Rezoning
@ Housing Sites Approved for Rezoning
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9
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The rezone program resulted in an increased number of future dwellings. Table 6 shows the net increase
in future dwellings that resulted from the rezone program.
Table 6 -Rezone Program Net Increase in Future Dwellings
Quadrant Rezone Program Net Increase in Future Dwellings
Northwest 1,746
Northeast 668
Southwest 336
Southeast 248
Citywide 2,998
As shown in Table 5 above, the approval of the rezone program resulted in an increase in future dwelling
units that exceed the Growth Management dwelling caps in the northwest and northeast quadrants, as
well as citywide. As described in the "Impacts of State Law" section below, state housing laws preempt
the city's ability to require compliance with the Growth Management (Proposition E) dwelling unit caps.
Although the city is no longer able to enforce the dwelling unit caps, future development must still comply
with the Growth Management Program's public facility performance standards, which will ensure
adequate public facilities are provided concurrent with growth.
POPULATION
Existing Population (as of June 30, 2024)
The performance standards for city administrative facilities, library facilities, and parks are stated in terms
of population. The demand for these facilities is based on each new dwelling unit built and the estimated
number of new residents it adds to the city, which is determined using the average number of persons
per dwelling unit. Utilizing data from the 2020 Federal Census (total population divided by total number
of dwelling units), the average for Carlsbad is 2.44 persons per dwelling unit.
As shown in Table 7, as of June 30, 2024, the city's population is estimated to be 117,322, which is
calculated by multiplying 2.44 persons per dwelling unit by the number of dwelling units and accessory
dwelling units and adding population in commercial living units (professional care facilities). The
population estimates are based on the 2020 Census population estimate and the city's dwelling unit
estimates and may vary from estimates of other agencies.
The city's population estimate is higher when compared to the population estimates from the California
Department of Finance (DOF) and the San Diego Association of Governments (SANDAG); both agencies
are estimating a decline in population since the 2020 Census. The Department of Finance (DOF) estimates
that Carlsbad's population, as of January 1, 2024, was 114,319 (230 less than the DOF January 1, 2023,
estimate). SANDAG's current population estimates are consistent with the DOF. City staff will continue to
monitor projected population estimates from the DOF and SAN DAG.
The city updates its population estimate methodology after each decennial census; the next will be in
2030. The city's method ensures a consistent methodology over a 10-year period, which provides stable
population projections for public facility planning purposes. If other agencies continue to estimate a
declining population, the city's population estimates will remain conservatively high and will be adjusted
after the 2030 Census.
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Table 7: Existing Population (as of June 30, 2024)
Existing Existing Total Dwelling Population in Population in
Quadrant Dwelling Accessory Existing Unit Professional Professional Total
Units Dwelling Dwelling Population Care Facilities Care Facilities Population
Units Units 2020 Census After 2020
NW 12,803 339 13,139 32,061 172 -32,240
NE 7,460 63 7,523 18,357 179 270 18,806
SW 10,276 61 10,337 25,223 139 -25,362
SE 16,492 223 16,715 40,787 127 -40,914
TOTAL 47,028 686 47,714 116,428 617 270 117,322
Buildout Population (as of June 30, 2024)
Table 8 estimates the number of dwellings that will exist at buildout based on current (June 30, 2024)
General Plan residential land use designations.
Table 8: Estimated Buildout Population (as of June 30, 2024)
Quadrant Dwelling Units8 Population9
NW 17,215 43,153
NE 9,608 24,085
SW 12,260 30,732
SE 17,270 43,291
Total 56,353 141,261
8 Includes existing accessory dwellings.
9 Includes population in group quarters (e.g., professional care facilities)-an additional 0.86% of household population.
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CITY ADMINISTRATIVE FACILITIES
Performance Standard
1,500 sq. ft. per 1,000 population must be scheduled for construction within a five-year period or prior
to construction of 6,250 dwelling units, beginning at the time the need is first identified.
FY 2023-24 Facility Adequacy Analysis
Based on the estimated June 30, 2024, population estimate of 117,322, the current demand for
administrative facilities is 175,983 square feet. To date, city administrative facilities exceed the
performance standard. The existing inventory of City of Carlsbad and Carlsbad Municipal Water District
buildings (leased and owned) occupied for administrative services are included in Table 9:
Table 9: Existing Administrative Facilities (as of June 30, 2024)
Facility Address Square Feet
City Hall Complex 1200 Carlsbad Village Drive 16,000
Faraday Administration Building 1635 Faraday Ave. 68,000
Fleet Service Center 2480 Impala Drive 10,540
Water District (Maintenance & Operations) 5950 El Camino Real 18,212
Parks Yard (Maintenance & Operations) 1166 Carlsbad Village Drive 4,012
Public Works Operations 405 Oak Ave. 9,950
Safety Center (Police and Fire administration) 2560 Orion Way 55,027
First Responder Safety Training Center 5750 Orion Way 15,090
Senior Center (Parks & Recreation administration) 799 Pine Ave. 5,770
Harding Community Center (Parks & Recreation
administration) 3096 Harding St. 1,335
Total Existing Square Feet of Administrative Facilities 203,936
Square Feet Required by Performance Standard 175,983
Square Feet that Exceed Standard 27,953
Buildout Facility Adequacy Analysis
Based on the General Plan residential land use designations in effect June 30, 2024, including the Housing
Element rezone program sites approved January 30, 2024, the projected buildout population is 141,261,
the demand for city administrative facilities will be 211,892 square feet. The estimated demand at
buildout will exceed the existing 203,936 square feet of administrative facilities. The facility standard
requires that the city schedule additional facilities for construction within five years after the demand is
first identified. The city annually monitors development and demand for public facilities and will report
when there is a demand for additional facilities, based on population increases resulting from new housing
development. The city is currently planning additional administrative facilities, as described below.
Analysis of how the Housing Element rezone program (approved January 30, 2024) affects the City
Administrative Facilities performance standard at buildout is included in Exhibit 11, starting on page 768
of 780, of the Planning Commission Staff Report, dated October 18, 2023, for the Housing Element
Implementation and Public Safety Element Update.
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New Orion Center Project
A development proposal is underway for the Orion Center project, which will centralize the city's
maintenance and operations functions into a single location on Orion Way. The goal for the facility is to
accommodate the existing and future needs for Public Works (Facilities and Streets Maintenance) and
Parks & Recreation (Parks Maintenance). The proposed project will make two existing city facilities
available for redevelopment: 405 Oak Street, and 1166 Carlsbad Village Drive. The Orion Center project
will provide 25,000 square feet of administrative space (among other uses), which will be a net increase
of 11,000 square feet over the two existing sites. The Planning Commission approved a Conditional Use
Permit for the project in April 2023.
New City Hall Project
On Aug. 16, 2022, the City Council received an update on a new City Hall and directed staff to pursue a
new approximately 40,000 square foot City Hall to be built on the site of the current City Hall Complex
(16,500 square feet). After the August 2022 City Council update report, city staff refined the plans for the
City Hall Complex and determined the facility will be approximately 34,000 square feet, which is an
increase of 17,500 square feet compared to the existing facility. The new facility will include administrative
facilities for existing City Hall Complex staff. Additionally, the New City Hall Project will likely also include
the planning efforts for a new Cole Library facility, see "Library Facilities" in the next section.
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LIBRARY FACILITIES
Performance Standard
800 sq. ft. (of library space) per 1,000 population must be scheduled for construction within a five-year
period or prior to construction of 6,250 dwelling units, beginning at the time the need is first identified.
Note: library space is used as a standard library measurement of customer use and includes collection space,
seating, meeting rooms, staff areas, technology, and other public facility needs. The performance standard
was originally developed based on surveys of other libraries of comparable size and based on related standards
(such as volumes per capita) set by the American Library Association.
FY 2023-24 Inventory and Adequacy of Facilities
The current inventory of library facilities (city-owned) is shown in Table 10:
Table 10: Existing Library Facilities (as of June 30, 2024)
Facility Square Feet
Dove Library 64,000
Cole Library 24,600
Learning Center 11,393
Total Existing Library Square Feet 99,993
Square Feet Required by Performance Standard 93,858
Square Feet that Exceed Standard 6,307
Based on the June 30, 2024, population estimate of 117,322, the growth management standard requires
93,858 square feet of public library space. The city's current 99,993 square feet of library facilities
adequately meets the growth management standard.
Facility Adequacy at Buildout
Based on the General Plan residential land use designations in effect June 30, 2024, including the Housing
Element rezone program sites approved January 30, 2024, the projected buildout population is 141,261,
the demand for library facilities will be 113,009 square feet. The existing 99,993 square feet of library
facilities will fall short of the growth management standard at buildout. The facility standard requires that
the city schedule additional library facilities for construction within five years after the demand is first
identified. The city annually monitors development and demand for public facilities and will report when
there is a demand for additional facilities, based on population increases resulting from new housing
development.
Analysis of how the Housing Element rezone program (approved January 30, 2024) affects the Library
Facilities performance standard at buildout is included in Exhibit 11, starting on page 768 of 780, of the
Planning Commission Staff Report, dated October 18, 2023, for the Housing Element Implementation and
Public Safety Element Update.
In 2015-16, the city completed major maintenance and renovation for both the Cole and Dove facilities
that addresses current Americans with Disabilities Act requirements and allows delivery of modern library
services and technology, while extending the life of the Cole Library by 10 to 15 years.
Built in 1967, the design of the Cole Library did not contemplate modern library services, such as delivery
of electronic resources, automated materials handling, and media formats. The library's role as a
community gathering space has also evolved.
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With an already maximized building footprint and infrastructure constraints, the Cole Library will not
expand further to meet these changing needs. Complete replacement and expansion of the Cole facility
is included in the Capital Improvement Program budget between the years 2023 and buildout, as part of
the new City Hall project (see "Administrative Facilities" in the preceding section). The City Hall project
will most likely inform the timing, impact and opportunities for a new Cole library facility.
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WASTEWATER TREATMENT CAPACITY
Performance Standard
Sewer plant capacity is adequate for at least a five-year period.
FY 2023-24 Facility Adequacy Analysis
The Encina Water Pollution Control Facility currently provides adequate capacity in excess of the
performance standard. Carlsbad's FY 2023-24 annual daily average dry weather sewer flow was 5.92
million gallons per day (MGD) representing 58% ofthe city's 10.26 MGD capacity rights. The city's annual
daily average sewage flow to the Encina Water Pollution Control Facility for the previous five years is
shown in Table 11:
Table 11: Five-Year Annual Daily Average Sewage Flow
Fiscal Year Annual daily average flow
FY 2019-20 6.31 MGD
FY 2020-21 6.31 MGD
FY 2021-22 5.72 MGD
FY 2022-23 6.22 MGD
FY 2023-24 5.92 MGD
Buildout Facility Adequacy Analysis
The Encina Water Pollution Control Facility Phase V Expansion provides adequate sewer treatment
capacity through buildout (year 2040) of the Carlsbad sewer service area.
The City of Carlsbad 2019 Sewer Master Plan contains an analysis of annual daily average sewer flow
through buildout of the city based on the Carlsbad General Plan land use projections (not including the
Housing Element rezone program approved January 30, 2024). The master plan's analysis indicates that
the city's projected ultimate buildout flow is approximately 8.31 MGD. The city has purchased capacity
rights to 10.26 MGD in the Encina Water Pollution Control Facility and provides adequate wastewater
treatment capacity.
Analysis of how the Housing Element rezone program (approved January 30, 2024) affects the Wastewater
Treatment Capacity performance standard at buildout is included in Exhibit 11, starting on page 768 of
780, of the Planning Commission Staff Report. dated October 18, 2023, for the Housing Element
Implementation and Public Safety Element Update.
The next sewer master plan update is in progress and will evaluate the potential impacts of development
projects and population estimates for the study period (through year 2050) including the sites and
development densities proposed in the 2024 Housing Element rezone program.
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PARKS
Performance Standard
3.0 acres of Community Park or Special Use Area per 1,000 population within the Park District10 must
be scheduled for construction11 within a five-year period beginning at the time the need is first
identified 12. The five-year period shall not commence prior to August 22, 2017.
FY 2023-24 Facility Adequacy Analysis
As shown in Table 12, all quadrants were in compliance with the park standard during FY 2023-24.
Table 12: Existing Park Inventory and Required Park Acreage (as of June 30, 2024)
Quadrant Park acreage inventory existing Park acreage required by Standard
NW 131.7 96.7
NE 68.7 56.4
SW 93.6 76.1
SE 138.3 122.7
Total 432.4 351.9
The existing park acreage inventory in each quadrant meets the current park acreage required by the
performance standard.
Veterans Memorial Park
The existing park acreage inventory in Table 12 includes 23.425 acres allocated to each quadrant for
Veterans Memorial Park. On July 26, 2022, the City Council adopted the Veterans Memorial Park Master
Plan. The Veterans Memorial Park site has been selected, a financing plan for the construction of the park
has been approved, and the adoption of the master plan signified completion of the park design.
Therefore, the park has been "scheduled for construction."
Veterans Memorial Park is a 93.7-acre park located approximately 350 feet east of Cannon Road and
Faraday Avenue. Because of its size, relatively centralized location, and citywide significance, the park will
help fulfill citywide park facility needs. The city's intention for the park to be a citywide park facility, and
for the total park acreage to be allocated equally to all city quadrants, dates to the Citywide Facilities and
Improvements Plan (CFIP) approved in 1986 (See Resolution 8797, adopted September 23, 1986, Exhibit
A at pp. 33-35 [allocating 25 acres from the Macario Canyon park to each quadrant]). Additionally, the
following documents reaffirmed the acreage allocation of Veterans Memorial Park for citywide benefit:
• Community Facilities District No . 1 (CFD}, established in 1991, finances public facilities of citywide
benefit, including Veterans Memorial Park.
• 2015 General Plan Open Space, Conservation and Recreation Element credits equal acreage from
Veterans Memorial Park to each quadrants future park inventory.
10 "Park District" ="quadrant". There are four park districts within the city, corresponding to the four quadrants.
11 "Scheduled for construction" means that the improvements have been designed, a site has been selected, and a financing
plan for construction of the facility has been approved (See Resolution 2017-170.) An identical definition was adopted in the
Citywide Facilities and Improvements Plan in September 1986 (pages 14 and 32).
12 The threshold for triggering the construction of a new park is as follows: Once a deficit of park acreage in a quadrant is
identified, a new park must be scheduled for construction within the time frame of five years.
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Buildout Facility Adequacy Analysis
Based on the General Plan residential land use designations in effect June 30, 2024, including the Housing
Element rezone program sites approved January 30, 2024, the projected buildout population and building
required park acreage is shown in Table 13. Based on the FY 2023-24 Capital Improvement Program list of
projects, Veterans Memorial Park is proposed to be constructed prior to buildout. The scheduling of
construction of this community park results in the projected park inventory for all city quadrants
exceeding the projected required acreage at buildout, as shown in Table 13:
Table 13: Projected Park Inventory at Buildout
Quadrant Buildout Buildout Current Projected
Population Required Acreage Inventory Inventory
NW 43,153 129.5 131.7 131.7
NE 24,085 72.3 68.7 68.71
SW 30,732 92.2 93.6 93.6
SE 43,291 129.9 138.3 138.3
Total 141,261 423.8 432.4 432.4
1 See information about Robertson Ranch Park in the Additional Parks Acreage section, below.
The current park inventory is sufficient to meet the buildout demand for park acres, except in the
northeast quadrant, where an additional 3.5 acres is estimated to be needed in the future. The facility
standard requires that the city schedule additional park facilities for construction within five years after
the demand is first identified. The city annually monitors development and demand for public facilities
and will report when there is a demand for additional facilities, based on population increases resulting
from new housing development.
Analysis of how the Housing Element rezone program (approved January 30, 2024) affects the Parks
performance standard at buildout is included in Exhibit 11, starting on page 768 of 780, of the Planning
Commission Staff Report, dated October 18, 2023, for the Housing Element Implementation and Public
Safety Element Update.
Additional Parks Acreage
The projected park acreage numbers in Table 13 do not include park projects listed in the CIP as "partially
funded" or "unfunded". Should additional funding mechanisms be found, and these parks are built, the
additional park acreage would further aid in meeting/exceeding the growth management parks
performance standard.
• Partially funded -In the FY 2023-24 CIP, $614,000 has been appropriated to the Robertson
Ranch Park project (NE -11.2 acres), which continued its status as "partially funded". The
park master plan was approved by the City Council in FY 2023-24, and staff was directed to
proceed with the necessary environmental permitting and entitlements for this park project.
Upon the 11.2-acre Robertson Ranch Park being "scheduled for construction," the projected
buildout need of 3.5 acres of park inventory would be more than satisfied.
• Unfunded-Zone 5 Business Park Recreational Facility (NW-9.3 acres) and Cannon Lake Park
(NW -6.8 acres).
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DRAINAGE
Performance Standard
Drainage facilities must be provided as required by the city concurrent with development.
FY 2023-24 Facility Adequacy Analysis
All areas of the city currently (as of June 30, 2024) meet the growth management drainage performance
standard because required drainage facilities have been provided concurrent with development.
Drainage facility needs are best assessed as specific development plans for individual projects are
finalized. Therefore, the drainage performance standard was written to allow the city to require
appropriate drainage facilities as development plans are finalized and approved.
The construction of drainage facilities related development projects is addressed during the review of
individual project proposals. Maintenance, repair, and replacement drainage projects are identified on an
ongoing basis and are incorporated in the Capital Improvement Program as a part of the Storm Drain
Condition Assessment Program, the Citywide Storm Drain Rehabilitation and Replacement Program, or as
individual/stand-alone projects.
Master planned drainage facilities are identified in the city's 2008 Drainage Master Plan. The associated
Planned Local Drainage Area fee program finances the construction of these facilities. The goal of the
Drainage Master Plan is to assess the performance of existing drainage infrastructure, identify anticipated
improvements and identify a funding mechanism to ensure construction of the planned facilities. The
Drainage Master Plan is updated periodically to reflect changes in the general plan, city growth,
construction costs, drainage standards and environmental regulations. At the present, the Public Works
Branch is updating the 2008 Drainage Master Plan to ensure these larger/master planned facilities will be
adequately funded.
Buildout Facility Adequacy Analysis
As development occurs in the future, including on the Housing Element rezone program sites approved
January 30, 2024, additional drainage facilities will be required consistent with the performance standard.
The 2008 Drainage Master Plan proposes the construction of new facilities to reduce the flooding risk
from potential storm events. Construction of the proposed drainage facilities will provide the backbone
system to maintain the drainage performance standard through buildout of the city. The current update
to the Drainage Master Plan will address funding availability for the construction of needed flood control
facilities. The estimated costs for these facilities and the programming of Planned Local Drainage Area
funds are included in the annual Capital Improvement Program.
Analysis of how the Housing Element rezone program (approved January 30, 2024) affects the Drainage
performance standard at buildout is included in Exhibit 11, starting on page 768 of 780, of the Planning
Commission Staff Report, dated October 18, 2023, for the Housing Element Implementation and Public
Safety Element Update.
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CIRCULATION
The information on the status of the Circulation performance standard for the vehicle travel mode is
provided by this report. The status of the pedestrian, bicycle and transit travel modes will be addressed
separately.
Performance Standard
Implement a comprehensive livable streets network that serves all users of the system -vehicles,
pedestrians, bicycles and public transit. Maintain level of service (LOS) Dor better for all modes that are
subject to this multi-modal level of service (MM LOS) standard, as identified in Table 3-1 of the General
Plan Mobility Element, excluding LOS exempt intersections and streets approved by the City Council.
Background
The following Circulation information discusses the service levels for each travel mode, which are
represented as a letter "grade" ranging from LOS A to LOS F. LOS A reflects a high level of service for a
travel mode (e.g., outstanding characteristics and experience for that mode) and LOS F would reflect an
inadequate level of service for a travel mode (e.g., excessive congestion for vehicles or inadequate
facilities for bicycle, pedestrian or transit users).
The performance standard for the circulation system is guided by the following:
General Plan Mobility Element Goals and Policies
Goal 3-G.1: Keep Carlsbad moving with livable streets that provide a safe, balanced, cost-effective, multi-
modal transportation system (vehicles, pedestrians, bikes, transit), accommodating the mobility needs of
all community members, including children, the elderly and the disabled.
The California Complete Streets Act (2008) requires cities in California to plan for a balanced,
multi-modal transportation system that meets the needs of all travel modes. Accomplishing this
state mandate requires a fundamental shift in how the city plans and designs the street system -
recognizing the street as a public space that serves all users of the system (elderly, children,
bicyclists, pedestrians, etc.) within the urban context of that system (e.g., account for the adjacent
land uses).
• Prior to adoption of the General Plan Mobility Element on Sept. 22, 2015, the growth
management circulation performance standard was based on the circulation needs of a single
mode of travel -the automobile.
• The General Plan Mobility Element identifies a new livable streets strategy for mobility within
the city.
• The livable streets strategy focuses on creating a 'multi-modal' street network that supports
the mobility needs of pedestrians, bicyclists, transit users and vehicles.
• Providing travel mode options that reduce dependence on the vehicle also supports the city's
Climate Action Plan in achieving its goals of reducing greenhouse gas emissions within the
city.
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Implementing Policy 3-P.3: Apply and update the city's multi-modal level of service (MM LOS) methodology
and guidelines that reflect the core values of the Carlsbad Community Vision related to transportation and
connectivity. Utilize the MM LOS methodology to evaluate impacts of individual development projects and
amendments to the General Plan on the city's transportation system.
Implementing Policy 3-P.4: Implement the city's MMLOS methodology and maintain LOS D or better for
each mode of travel for which the MM LOS standard is applicable, as identified in Table 3-1 and Figure 3-
113.
General Plan Mobility Element Street Typology
The city's approach to provide livable streets recognizes that improving the LOS for one mode of
transportation can sometimes degrade the LOS for another mode. For example, pedestrian-friendly
streets are designed to encourage pedestrian uses and typically have amenities that slow vehicle travel
speeds (e.g., short-distance pedestrian crossings that restrict vehicle mobility). The "street typology" is
defined in the General Plan Mobility Element and determines which travel modes are subject to the
MMLOS D standard, as summarized in Table 14. For example, the vehicular mode of travel is subject to
the MMLOS D standard on the following street typologies: freeways, arterial streets, arterial connector
streets and Industrial streets.
Table 14: Street Typology and MM LOS Standard
STREET TYPOLOLOGY Modes subject to the MMLOS D Standard
Vehicular Transit Pedestrian Bicycle
Freeways Yes Yes No No
Arterial Streets Yes Yes No No
Identity Streets No No Yes Yes
Village Streets No No Yes Yes
Arterial Connector Streets Yes No Yes Yes
Neighborhood Connector Streets No No Yes Yes
Coastal Streets No No Yes Yes
School Streets No No Yes Yes
Employment/Transit Connector Streets No Yes Yes Yes
Industrial Streets Yes Yes No No
Local/Neighborhood Streets No No Yes Yes
All Streets Located Within Half Mile of a Transit Center No Yes Yes Yes
Bicycle/Pedestrian Pathways No No Yes Yes
13 Table 3-1 and Figure 3-1 are found in the General Plan Mobility Element.
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Methods to Measure Service to Different Transportation Modes
MM LOS for Pedestrian, Bicycle and Transit -History
The City of Carlsbad's 2015 General Plan included a novel way to measure how well streets meet the
needs of the people who use them. Called multimodal level of service (MMLOS), this approach became
more widely considered after a 2008 state law known as the Complete Streets Act (Assembly Bill 1358)
was signed into law requiring cities to plan streets for walking, biking and transit, not just cars. Over the
past 10 years, City Council policies in the General Plan have been effective in bringing many local streets
up to new standards for safety and accessibility.
MM LOS for Pedestrian, Bicycle and Transit-Methodology and Analysis Approach
Staff will present a proposed approach to the MM LOS methodology (for pedestrian, bicycle, and transit)
separately to the City Council for policy direction. This presentation will include recommendations and
facilitate a focused discussion on any potential policy adjustments needed to align with the objectives of
the city's General Plan Vision and Mobility Element. This separate review process will allow the City
Council to ensure that the methodology aligns with the city's goals and policies while addressing identified
limitations of the MM LOS methodology.
How vehicular LOS is measured
The city monitors facilities that are subject to the vehicular LOS standard according to that street's
typology as defined in Table 14. This section of the report summarizes the vehicular LOS methodology
used for monitoring purposes. For the fiscal year (FY) 2023-24 monitoring report all the street facilities
required to meet the vehicular LOS standard were monitored including the arterial, arterial connector,
and industrial street typologies.
The city evaluates the roadway network at the "facility" level according to Chapter 16 of the Highway
Capacity Manual. A facility is defined as one direction of travel along a length of road that has similar
travel and geometric characteristics, and it typically extends between multiple signalized intersections.
Each facility has an associated capacity that is defined in the Highway Capacity Manual as "the ability of a
transportation facility or service to meet the quantity of travel demanded of it." For Growth Management
Plan monitoring purposes, travel demand on a roadway is measured by the volume of vehicles using the
facility during the peak hours of operation. A volume threshold is established for each LOS grade according
to the Highway Capacity Manual. The vehicular LOS is determined by comparing the traffic volume against
these thresholds. For example, a LOS D is recorded when a traffic volume exceeds the LOS C threshold but
is below the LOS D threshold.
A street "facility" is comprised of smaller and contiguous "segments" that typically extend between two
adjacent signalized intersections. Per the Highway Capacity Manual, an entire facility is reported as failing
if the volume along any one of its segments exceeds its capacity, which defines LOS F. When a facility has
been monitored and found to operate at LOS D, each segment of that facility will be evaluated the
following monitoring cycle and the LOS will be reported as follows:
a. If the volume of any one segment of the facility exceeds the reported capacity for that
segment, the facility will be reported as LOS F; or
b. If none of the segment volumes exceeds its reported capacity for that segment, the facility
will be reported as LOS D (or the new level if it has changed).
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As noted above, travel demand is assumed to equal the traffic volume measured during the peak hour of
operation. Vehicular LOS is determined based on one mid-block traffic count collected for each facility (or
segment) being evaluated. The data is collected while school is in session in either the spring or fall. The
morning and afternoon (a .m./p.m.) peak hours' LOS is reported for each facility or segment. Each street
evaluated will have separate LOS results reported for the a.m. and p.m. peak hour conditions with
independent grades reported for each direction of travel. This approach to data collection is consistent
with industry standards.
Exemptions to the Vehicle LOS D Standard
General Plan Mobility Element Policy 3-P.9 requires the city to develop and maintain a list of street
facilities where specified modes of travel are exempt from the LOS standard (LOS-exempt street facilities),
as approved by the City Council.
Regarding vehicular LOS standards, the City Council has the authority to exempt a street facility from the
vehicular LOS standard if the street facility meets one or more of the following criteria from General Plan
Mobility Element Policy 3-P.9:
a. Acquiring the rights of way is not feasible; or
b. The proposed improvements would significantly impact the environment in an unacceptable way
and mitigation would not contribute to the nine core values ofthe Carlsbad Community Vision; or
c. The proposed improvements would result in unacceptable impacts to other community values or
General Plan policies; or
d. The proposed improvements would require more than three through travel lanes in each
direction.
General Plan Mobility Element Policy 3-P.11 requires new development that adds vehicular traffic to
street facilities that are exempt from the vehicle LOS D standard to implement:
• Transportation Demand Management (TDM) strategies that reduce the reliance on single-
occupant automobiles and assist in achieving the city's livable streets vision; and
• Transportation System Management (TSM) strategies that improve traffic signal coordination and
improve transit service.
Each of the previously exempt street facilities were monitored this cycle and evaluated against the
vehicular LOS standard. The results of this evaluation are summarized in Table 15 below. No changes have
occurred since the adoption of these resolutions that would warrant lifting exemptions for these street
facilities.
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FY 2023-24 Facility Adequacy Analysis
The following vehicular LOS and MM LOS results (Table 15) are based on the data reported in the City of
Carlsbad Roadway Level of Service Analysis Report {January 2025).
Vehicular LOS
The vehicular LOS grades reflect traffic data gathered in spring of 2024. The traffic data represents typical
weekday traffic conditions. Counts were collected at each midblock location for three consecutive
weekdays. For each roadway segment, the highest one-hour AM and one-hour PM volume of the three
days were determined for each direction of travel.
The LOS results for the vehicular mode are illustrated in Figure 5. All the deficient roadway facilities
identified above were previously determined by City Council to be deficient and exempt per General Plan
Mobility Policy 3-P.10.
Table 16 lists the street facilities which were previously reported as LOS D in the FY 2022-23 monitoring
report. The facilities were further studied at the segment level as part of the FY 2023-24 report to
determine the operating LOS of the facility at the segment level. The results of this analysis show that all
facilities that have not been previously exempted will still meet the LOS D standard.
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Table 15: Vehicle LOS Exempt Street Facilities
Street Facility From To LOS Meets LOS Date of
(AM/PM) Standard? Exemption
1. la Costa Avenue lnterstate-5 El Camino Real B/C Yes
2. la Costa Avenue El Camino Real lnterstate-5 F/B No
3. El Camino Real Palomar Airport Road Camino Vida Roble D/C Yes
4. El Camino Real Camino Vida Roble Poinsettia lane C/C Yes
5. El Camino Real Poinsettia lane Aviara C/C Yes
Parkway/Alga Road
6. El Camino Real Aviara Parkway/Alga la Costa Avenue F/C No
Road
7. El Camino Real la Costa Avenue Aviara C/C Yes
Parkway/Alga Road Exempted
8. El Camino Real Aviara Parkway/Alga Poinsettia lane C/C Yes with
Road adoption of
9. El Camino Real Poinsettia lane Camino Vida Roble C/C Yes the
10. El Camino Real Camino Vida Roble Palomar Airport C/C Yes General
Plan Road Mobility 11. Palomar Airport Road Avenida Encinas Paseo del Norte F/F No Element on 12. Palomar Airport Road Paseo del Norte Armada Drive D/C Yes Sept. 22, 13. Palomar Airport Road Armada Drive College Boulevard/ C/C Yes 2015 Aviara Parkway
14. Palomar Airport Road College Boulevard/ Armada Drive C/C Yes
Aviara Parkway
15. Palomar Airport Road Armada Drive Paseo del Norte C/D Yes
16. Palomar Airport Road Paseo del Norte Avenida Encinas F/F No
17. Palomar Airport Road El Camino Real El Fuerte Street C/C Yes
18. Palomar Airport Road El Fuerte Street Melrose Drive B/C Yes
19. Palomar Airport Road Melrose Drive El Fuerte Street C/C Yes
20. Palomar Airport Road El Fuerte Street El Camino Real C/C Yes
21. El Camino Real Oceanside city limits Marron Road F/E No
22. El Camino Real Marron Road Oceanside city E/E No Dec. 17, limits 2019 23. Melrose Drive Vista city limits Palomar Airport F/E No
Road
24. El Camino Real Cannon Road College Boulevard F/C No
25. El Camino Real College Boulevard Cannon Road B/C Yes Jun. 9,
26. Cannon Road El Camino Real College Boulevard D/E No 2020
27. Cannon Road College Boulevard El Camino Real E/D No
28. El Camino Real Tamarack Avenue Cannon Road C/C Yes Nov. 3,
2020
29. College Boulevard Carlsbad Village Drive Oceanside City C/D Yes
limits Jan. 12,
30. Cannon Road Avenida Encinas Paseo del Norte D/D Yes 2021*
31. Cannon Road Paseo del Norte Avenida Encinas D/D Yes
32. Aviara Parkway/Alga Road Manzanita Street El Camino Real F/F No July 12,
33. Aviara Parkway/Alga Road El Camino Real Manzanita Street F/F No 2022
*On January 12, 2021 City Council also exempted the remaining facility of Palomar Airport Road between Avenida Encinas to
Paseo def Norte.
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Figure 5: Vehicular Level of Service (LOS) Results
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27
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Table 16: Roadway Facilities that were LOS D in FY 2022-23
City limits to C D C C D D C Carlsbad Village Drive
College Carlsbad Village Drive to C D D C C D D C Boulevard Cannon Road
El Camino Real to C D D C C D D C Aston Avenue
Aviara Parkway Palomar Airport Road to D D D D D D D D Poinsettia Lane
Melrose Drive Palomar Airport Road to D D D D C C C C Poinsettia Lane
Rancho Santa Fe Olivenhain Road to D D D D D D D D Road Calle Acervo
Olivenhain Road Rancho Santa Fe Road to B D C B B C C B City limits
Cannon Road El Camino Real to D D D D D College Boulevard
Palomar Airport Paseo del Norte to Armada D C C D D C C D Road Drive
Carlsbad Village 1-5 to Valley Street C D D C C D D C Drive
Poinsettia Lane to D D D D D D D D Kestrel Drive
Black Rail Road to D D D D D D D D Aviara Resort Drive
Aviara Parkway/ Kingfisher Lane to
Alga Road Batiquitos Drive/ Baccharis D D D D D D D D
Avenue
Batiquitos Drive/Baccharis D D D D D D D D Avenue to Ambrosia Lane
Mimosa Drive to D D D D D D D D Manzanita Street
Rutherford Faraday Avenue to C D D C C C C C Road Priestly Drive
Priestly Drive Faraday Avenue to C D D C C D D C La Place Court
Lionshead Melrose Drive to City limits D D D D D D D D Avenue
Palomar Oaks Way to C D D D D C D D Camino Vida Palomar Airport Road
Roble Palomar Airport Road to C D D D D C D D El Camino Real
Eagle Drive Lionshead Avenue to C D C C C C C C Palomar Airport Road
Palomar Oaks Palomar Airport Road to D C C D C C C C Way End
Aston Avenue College Boulevard to C C C D D C C C Rutherford Road
Corte De La Pina Yarrow Drive to C C C D C C C C Cosmos Court
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Buildout Facility Adequacy Analysis
The 2015 General Plan EIR evaluated how buildout of the land uses planned by the General Plan will
impact the vehicle, pedestrian, bicycle and transit levels of service, and identified that additional
circulation facilities may need to be constructed to meet the GMP performance standard at buildout. The
following summary provides the results of that evaluation. Analysis of how the Housing Element rezone
program (approved January 30, 2024) affects the Circulation performance standard at buildout is included
in Exhibit 11, starting on page 768 of 780, of the Planning Commission Staff Report, dated October 18,
2023, for the Housing Element Implementation and Public Safety Element Update.
Vehicular Level of Service at Buildout
• Additional future road segments (extensions of College Boulevard and Camino Junipero) needed
to accommodate the city's future growth were identified as part of the General Plan update. The
General Plan Mobility Element identifies these needed future road segments as "Planned City of
Carlsbad Street Capacity Improvements."
• The General Plan also called out the need to implement the scheduled lnterstate-5 North Coast
Project and lnterstate-S/lnterstate-78 Interchange Improvement Project that are needed to
accommodate future growth.
• The CIP funds projects that will upgrade the LOS including several roadway widenings along El
Camino Real near College Boulevard (northbound), La Costa Avenue (southbound) and Cassia
Road (northbound).
• The General Plan EIR identifies TDM and TSM as mitigation measures for roadway sections that
have been determined to be LOS-exempt.
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FIRE
Performance Standard
No more than 1,500 dwelling units outside of a five-minute response time.
FY 2023-24 Facility Adequacy Analysis
As of June 30, 2024, the city's fire facilities comply with the performance standard. There are no more
than 1,500 dwelling units outside of a five-minute response distance from any of the city's seven fire
stations.
The intent of the performance standard, as applied to fire facilities, is to establish the distribution of
station locations, based upon response distances. At the time the performance standard was developed,
scientific fire behavior information and recognized best practices supported the position that a response
time of five minutes would result in effective fire incident intervention. The performance standard
provides no other mechanism for the installation of additional fire stations. It states that up to 1,500
dwelling units could exist outside the five-minute reach of the closest fire station for an indeterminate
length of time without violating the standard. The five-minute response distance measure was selected
exclusively as a means of geographically positioning fire stations throughout the city. Therefore, the
standard is applied as a means of measuring compliance with locating fire facilities, not the performance
of the Fire Department in meeting service responsibilities.
To determine if the standard is met for FY 2023-24, the city refers to the response time analysis conducted
for buildout of the number and location of dwellings planned by the General Plan, which is more dwellings
than currently exist. See "buildout" section below, which concludes that the existing fire stations are
adequate to meet the standard at buildout (i.e., adequate to serve more dwellings than currently exist).
Buildout Facility Adequacy Analysis
At buildout, the established threshold of more than 1,500 units that exist outside of a five-minute
response distance will not be exceeded for any of the fire stations.
To determine if fire facilities comply with the Fire performance standard at buildout, the city's Geographic
Information System Department mapped a five-minute response time from each fire station, based on
the drivetime attributes of each roadway, and identified the number of estimated dwelling units at
buildout that are outside the five-minute drivetime.
Table 17: Number of Dwellings Outside Five Minute Response Time (as of June 30, 2024)
Fire Station Number Total number of dwelling units outside of five minutes
1,3 & 4 (aggregated) 1,198
2 0
5 3
6 16
7 0
Analysis of how the Housing Element rezone program (approved January 30, 2024) affects the Fire
performance standard at buildout is included in Exhibit 11, starting on page 768 of 780, of the Planning
Commission Staff Report. dated October 18, 2023, for the Housing Element Implementation and Public
Safety Element Update.
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OPEN SPACE
Performance Standard
Fifteen percent of the total land area in the zone [Local Facility Management Zone] exclusive of
environmentally constrained non-developable land must be set aside for permanent open space and
must be available concurrent with development.
Note: Pursuant to the Citywide Facilities and Improvements Plan, the Open Space standard is
applicable in Local Facilities Management Zones 11-15 and 17 -25 . The standard does not apply in
Zones 1-10 and 16 because these zones were either fully built out or had previously approved
master plans which would provide sufficient open space at full build out. For more information, see
the "Background Summary" below.
FY 2023-24 Facility Adequacy Analysis
As of June 30, 2024, adequate open space has been provided concurrent with new development to comply
with the performance standard. Local Facility Management Plans have been adopted for all Local Facility
Management Zones where the standard applies (Zones 11-15 and 17-25). Each Local Facility
Management Plan (LFMP) identifies how the open space standard will be met within the zone. Within the
applicable zones, approved development projects have been, and future development projects will be
required to be, consistent with the open space required for the applicable Local Facility Management
Zone.
Buildout Facility Adequacy Analysis
All Local Facilities Management Zones, except for Zone 22, have provided the required growth
management open space as identified in the applicable Local Facility Management Plans, which address
required open space through buildout of the zones. Future projects in Zone 22 must provide their
proportionate share of required open space in compliance with the standard.
Analysis of how the Housing Element rezone program (approved January 30, 2024) affects the Open Space
performance standard at buildout is included in Exhibit 11, starting on page 768 of 780, of the Planning
Commission Staff Report. dated October 18, 2023, for the Housing Element Implementation and Public
Safety Element Update.
Background
The history of the open space standard helps to clarify its applicability today. It should be noted that the
open space provided to meet the open space standard does not represent all the open space in Carlsbad.
Open space to the meet standard is provided within the applicable Local Facility Management Zones and
is in addition to constrained open space, such as protected habitat and slopes greater than 40 percent.
The city utilizes other methods to protect all the open space resources and amenities throughout the city,
including the Habitat Management Plan (protects the city's natural open space preserve system), Growth
Management Parks standard (parks are a source of recreational open space in the city), and the Trails
Master Plan (trails are another source of recreational open space).
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Citizens Committee for the Review of the Land Use Element (1985)
In 1985, a citizen's committee made recommendations to the City Council regarding changes to the city's
General Plan Land Use Element. The committee's recommendations were used as the basis for developing
the growth management facility standards. The committee recommended that future open space would
be provided by future master planned areas (15 percent of the master plan area), as required by the
Zoning Ordinance at that time (and today).
Public Facility Standards (July 1986) and Citywide Facilities and Improvements Plan (Sept. 1986)
In 1986, the City Council adopted the Growth Management Ordinance (Carlsbad Municipal Code Chapter
21.90) and the public facility standards for the Growth Management Program. The Citywide Facilities and
Improvements Plan specified that the open space standard applies in some Local Facility Management
Zones (Zones 11-15 and 17-25), but not others (Zones 1-10 and 16) because those zones were
determined to have already been developed or to have already met the standard. (i.e., subject to
previously adopted master and/or specific plans). Some previously adopted master and/or specific plans
found that full build-out under the plans would provide sufficient open space required at the time these
plans were approved, specifically, 15% of all areas (regardless of any constraints such as slope).
Accordingly, the CFIP found these zones did not need to meet the later-adopted open space performance
standard of 15% of non-constrained land. The CFIP exemption for these zones was recognized in the
individual Local Facility Management Plans decades ago. This methodology is consistent with traditional
land use methodology which applies new standards prospectively. (See 2020/2021 Growth Management
Program Monitoring Report p. 27; Friends of H Street v. City of Sacramento (1993) 20 Cal.App.4th 152,
169 [California's planning statutes "address future growth, and do not require local governments to bring
existing neighborhoods and streets into compliance with the general plan."].)
The following are some key facts during the development of the open space standard:
• As part of the development of the Growth Management Program, the city identified areas that
were, at the time, "urbanized" (developed areas) "urbanizing" (some development or some level
of planning completed, such as an existing master plan) and "future urbanizing" (very little to no
development and no existing master plan).
• A comparison of the Local Facilities Management Zones map and the 1986 Development Status
Map shows that the zones where the open space standard is applicable (Zones 11-15 and 17 -
25) align, for the most part, with the areas identified in 1986 as "future urbanizing," which is
where future master plans would be required (e.g., Aviara, Bressi Ranch and Quarry Creek master
plans) and is consistent with the 1985 committee recommendation for master plans to provide
additional future open space.
o The "urbanized" areas were already developed, and the "urbanizing" areas had previously
approved development or master plans. Although the open space standard was not applied
to the "urbanizing" areas, the existing approved master plans within these areas provided
open space as required by city regulations in place at the time. Prior to the Growth
Management Program and the open space standard, the city's zoning ordinance required 15
percent of the total area of any master plan to be designated as open space. This 15 percent
standard differs from the Growth Management open space standard because it applies to the
total land area of a master plan and does not exclude environmentally constrained non-
developable land.
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Figure 6
Where Open Space Standard
Local Facility Management Zones 1986 0 1 S M A 1· (adopted 1986) eve opment tatus ap pp res
Developmental Status Map
■cATE_GOAY I: URBANIZED
§cATeGOAY II: UAIIANIZINO
£DcATEOOAY 111: ,uTURE UABANIZINO
Common Questions About the Open Space Standard
Is there a 40 percent open space requirement?
(adopted 1986)
Note: OS standard applies to gray areas
It is a misconception that there is a standard that requires the city to provide 40 percent open space.
There is no requirement or standard that requires 40 percent open space per individual projects or on a
citywide basis.
Neither Proposition E nor the Citywide Facilities and Improvements Plan (CFIP) performance standards
required 40 percent open space. Proposition E states "emphasis shall be given to ensuring good traffic
circulation, schools, parks, libraries, open space, and recreational amenities." The CFIP open space
standard states "Fifteen percent of the total land area in the zone, exclusive of environmentally
constrained non-developable land ... concurrent with development." The CFIP also states that Local
Facilities Management Zones 1-10 and 16 "are already developed or meet or exceed the requirement"
and are not subject to the CFIP open space standard . This methodology predates Proposition E, and was
included in the CFIP, adopted by the City Council on September 23, 1986, by Resolution 8797.
A July 8, 1986, City Council staff report on the facility standards states: "compliance with this [open space]
standard should result in approximately 35 to 40% of the total land area in the city being open space when
the city is fully built out." A couple years later, a June 27, 1988, staff report to an open space committee,
stated that "staff has estimated that approximately 10,000 acres or 38.5% of the total land area in the city
is projected to be set aside for open space uses."
The shorthand estimate of 40% was simply derived by adding the 25 percent estimated constrained lands
to the 15 percent GMP open space set-aside. However, this shorthand calculation did not consider that
the standard only applied to 14 of the 25 Local Facility Management Zones (CFIP, p. 46), rather than the
entire city. The reference to 40 percent open space was an estimate, not a standard or goal. Today, 38
percent of Carlsbad is dedicated as open space.
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Why doesn't the open space standard apply to Local Facilities Management Zone 9?
Local Facilities Management Zone 9 (Zone 9) is a good example of one of the "urbanizing" areas in 1986
where the open space standard was not applied. Zone 9 includes part of the Ponto area and the majority
of the zone is subject to the Poinsettia Shores Master Plan. This is an area where the city has received
community comments stating that the zone does not meet the open space standard and more open space
is needed. In 1986 the City Council determined that the open space needs for Zone 9 had been met and
therefore the open space standard does not apply to Zone 9.
Zone 9 was an "urbanizing" area when the Growth Management Program was being developed. A master
plan was approved for the area (Batiquitos Lagoon Educational Park Master Plan). The master plan met
the open space standard required at the time (Zoning Ordinance), which is 15 percent of the total area of
the master plan.
The following is a summary of actions related to Zone 9 that relate to the open space planned in that area :
• Oct. 1, 1985 -Batiquitos Lagoon Educational Park Master Plan approved by City Council and, as
required by the zoning ordinance at the time, was required to provide a minimum 15 percent of
the total master plan area as open space.
• May 6, 1986 -City Council staff report on development of the Growth Management Program:
o City council directed staff, working in conjunction with the developer of Zone 9, to finalize a
pilot local facility management program to serve as a format model for programs for the other
zones. The Batiquitos Lagoon Educational Park Master Plan for Zone 9 had been approved the
year before and it was a recent development plan to use as a model.
• June 24, 1986 -Growth Management Ordinance approved (Zoning Ordinance Chapter 21.90):
o Section 21.90.030(g) allowed development of phase I of the Batiquitos Lagoon Educational
Park Master Plan to proceed prior to approval of a Local Facility Management Plan for Zone
9, subject to certain conditions including that the developer agree to participate in the
restoration of a significant lagoon and wetland resource area and make any open space
dedications of property necessary to accomplish the restoration. The master plan developer
did make the open space land dedications that were needed for the restoration of Batiquitos
Lagoon .
• Sept. 16, 1986 -City Council approves the Citywide Facilities and Improvements Plan, including
the open space standard with the clarification that the standard is not applicable in Zones 1-10
and 16.
• July 11, 1989 -City Council approves the Local Facilities Management Plan for Zone 9. Other than
noting the existing open space within the zone, open space was not further analyzed in the plan,
as the open space standard does not apply to Zone 9.
• Jan. 18, 1994 -City Council adopts an ordinance approving Poinsettia Shores Master Plan, which
replaced the Batiquitos Lagoon Educational Park Master Plan. The related Planning Commission
staff report (Oct. 20, 1993) evaluates open space in the master plan as follows:
"The Poinsettia Shores Master Plan will not adjust or modify any existing General Plan designated
open space areas or boundaries. Of the project's 162.8 total acres, approximately 34.8 acres are
natural lagoon/wetland habitat which have Open Space General Plan designations (planning areas
"I", "K", and "L") and have already been dedicated in fee title to the State of California, State Lands
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Commissions in accordance with previous BLEP [Batiquitos Lagoon Educational Park] approvals.
The master plan has additional open space totaling approximately 11 acres comprised of a
community recreation center (planning area "M") and open space areas consisting of blufftop and
roadway setbacks. The total master plan open space (approximately 46 acres) represents 28% of
the entire master plan area. This exceeds the [Zoning Ordinance] requirement of at least 15% of
the master plan area (24.4 acres) to be set aside as open space. As outlined in the Citywide
Facilities Improvement Plan and the Zone 9 Local Facility Management Plan, this master plan has
complied with all open space requirements. The project is also consistent with the Open Space
and Conservation Resource Management Plan and incorporates master plan trails and links with
the Citywide Trails System as required. The master plan's frontage on the east side of Carlsbad
Boulevard (planning areas "G" and "H") is the location for linkage with the Citywide Trails System.
These planning areas will be required to provide for the trail link within the required 40-foot
structural setback from Carlsbad Boulevard .... On August 26, 1993, the master plan's open space
program was reviewed by the City's Open Space Advisory Committee and unanimously
supported ... "
While the open space standard is not applicable to Zone 9, open space has been provided for the area,
including private recreation areas, trail linkages and a significant natural open space dedication that
helped in the restoration of Batiquitos Lagoon1.
1 City of Carlsbad Planning Commission Staff Report dated Oct. 20, 1993, for MP 175{D)/GPA 91-05/LCPA 91-02/LFMP 87-09{A)
Poinsettia Shores Master Plan.
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SCHOOLS
Performance Standard
School capacity to meet projected enrollment within the Local Facility Management Zone (LFMZ) as
determined by the appropriate school district must be provided prior to projected occupancy.
Note: public school facilities are not planned, funded, or constructed by the city.
FY 2023-24 Facility Adequacy Analysis
All new residential development is required to verify that school capacity can meet the projected
enrollment from the school district serving the development. As of June 30, 2023, all school districts
serving Carlsbad have verified they have capacity to serve development in the city.
Buildout Facility Adequacy Analysis
Compliance with the school facility standard is verified at the time of development. The facility
standard requires that there be adequate school capacity at the time of development (prior to
occupancy), and residential development is required to verify that school capacity can meet the
projected enrollment.
Analysis of how the Housing Element rezone program (approved January 30, 2024) affects the Schools
performance standard at buildout is included in Exhibit 11, starting on page 768 of 780, of the Planning
Commission Staff Report, dated October 18, 2023, for the Housing Element Implementation and Public
Safety Element Update.
April 22, 2025 Item #4
36
Page 42 of 47
Docusign Envelope ID: C5C5E5E3-DAC0-4C3A-8AD5-16FE71DBA309
SEWER COLLECTION SERVICES
Performance Standard
Trunk-line capacity to meet demand, as determined by the appropriate sewer districts, must be
provided concurrent with development.
FY 2023-24 Facility Adequacy Analysis
The evaluation of conformance with the performance standard requires sewer master plan updates be
conducted on an interval that is commensurate with development activity. As part of the updates, sewer
flow monitoring is necessary to evaluate whether the sewer flow generation factors used to estimate
sewer flows and system capacity adequately reflect actual conditions or require revision. The city
conducts sewer master plan updates on a 5-year interval to evaluate trunk line capacity and requires
sewer studies during discretionary project review for sewer system sizing.
Sewer collection system improvements are provided on a project-by-project basis concurrent with
development. Currently, the City of Carlsbad's sewer service area pipelines comply with the performance
standard. The agencies that provide sewer collection service and systems within the city include: Carlsbad,
Leucadia Wastewater District and Vallecitos Water District. Each agency indicates that they currently have
adequate conveyance capacity in place to meet Carlsbad's sewer collection demands.
The City of Carlsbad is served by the following six major sewer interceptor systems in four of these
interceptor systems, wastewater flow capacity is shared with other agencies as listed in Table 18. For
both the Vista/Carlsbad Interceptor and the Buena Interceptor, Carlsbad's capacity rights increase in the
downstream direction as they flow to the Encina Water Pollution Control Facility. Capacity rights increase
from 3.3% to 50% for the Vista/Carlsbad Interceptor and from 18% to 35% in the Buena Interceptor.
Carlsbad has sufficient capacity rights in these interceptors to transport wastewater to EWPCF.
Table 18: Carlsbad Sewer Interceptors
Interceptor System Sewer Districts Served Carlsbad Capacity Rights1 FY 2023-24
Average Daily Flows
Vista/Carlsbad City of Carlsbad Ranges from 3.20 MGD4
Interceptor City of Vista 1.0 MGD up to 41.8 MGD {3.3% -50%)
City of Carlsbad Ranges from Buena Interceptor City of Vista 0.59 MGD
Buena Sanitation Dist. 1.2 MGD up to 3.6 MGD {18% -35%)
City of Carlsbad
Vallecitos Interceptor Buena Sanitation Dist. 5 MGD {24%) 1.62 MGD
Vallecitos Water Dist.
City of Carlsbad
Occidental Sewer3 City of Encinitas 8.5 MGD {40%) 0.24 MGD
Leucadia Wastewater Dist.
1 Million gallons per day {MGD)
2 Buena Sanitation District and the City of Carlsbad are negotiating the transfer of this facility to the City of Carlsbad upon
City of Vista's commissioning of their Buena Outfall Force Main, Phase Ill project.
3 The downstream sections {NB8 and NB9) of the North Batiquitos Sewer, often referred to as Ponto Sewer and originally
termed the Occidental Sewer
4 Flows conveyed via Vista Carlsbad Interceptor to EWPCF
April 22, 2025 Item #4
37
Page 43 of 47
Docusign Envelope ID: C5C5E5E3-DAC0-4C3A-8AD5-16FE71DBA309
North Agua Hedionda City of Carlsbad 6 MGD (100%) 1.27 MGD Interceptor
South Agua Hedionda City of Carlsbad 4.7 MGD (100%) 0.91 MGD Interceptor
Buildout Facility Adequacy Analysis
The City of Carlsbad 2019 Sewer Master Plan Update evaluated the sewer infrastructure needs of the
Carlsbad sewer service area and identified facilities required to accommodate future sewer flows at
buildout. The master plan identified the Vista/Carlsbad Interceptor and Buena Interceptor as requiring
improvements to accommodate build-out demand (see below). The next master plan update is in
progress and will evaluate the potential impacts of development projects and population estimates for
the study period (through year 2050) including the 2024 Housing Element rezone program sites.
Sewer trunk main adequacy is estimated by comparing wastewater flow projections to the capacity of the
sewer system using a computer model. Sewer flow monitoring is used to assess actual flows and to
evaluate the need for sewer capacity improvements.
Collection system improvements to meet buildout conditions in Kelly Drive were completed in 2024. Other
improvements are identified in Faraday Avenue, El Camino Real and Poinsettia Avenue. These projects
are programmed in the Capital Improvement Program.
Capacity considerations for major sewer facilities for buildout conditions is summarized as follows:
Vista/Carlsbad Interceptor: The City's 2019 Sewer Master Plan Update indicates that portions of the
Vista/Carlsbad (VC) Interceptor do not satisfy buildout system flows. Hydraulic model results indicate
that the 36-inch diameter gravity mains of Reach VC-3 are insufficient to convey buildout flows from
the city of Vista. Most of reach VC-3 consists of 36-inch diameter gravity main and is scheduled for
upsizing to 42 inches as a joint Capital Improvement Program project by Carlsbad and Vista to meet
buildout flows.
Buena Interceptor: The Buena Interceptor is currently shared by Vista and Carlsbad and, although
the Carlsbad flows are within its capacity rights, the combined flows of Buena Sanitation District and
City of Carlsbad during peak wet weather periods exceed the design capacity criterion. As a result,
Buena Sanitation District has constructed a parallel trunk sewer which will allow Buena Sanitation
District flow to be diverted to the parallel trunk sewer. Buena Sanitation District plans to divert flow
to their new sewer in 2025, which will reduce flow conveyed by the Buena Interceptor and satisfy the
design capacity requirement for buildout flows.
Carlsbad initiated the next Sewer Master Plan Update in summer 2024, which will evaluate land use and
zoning and revised projections for population, development type and density for the next 25-year period.
These criteria will serve as the basis for flow projections and related sewer system improvements for the
study period. Commercial and industrial properties which were rezoned to multi-family residential or
mixed-use zoning in the Housing Element rezone program (approved January 30, 2024) will also be studied
for potential impacts to the sewer collection system, either in the Sewer Master Plan Update or
individually as development project applications are submitted for review.
April 22, 2025 Item #4
38
Page 44 of 47
Docusign Envelope ID: C5C5E5E3-DAC0-4C3A-8AD5-16FE71DBA309
WATER DISTRIBUTION SERVICES
Performance Standard
Line capacity to meet demand as determined by the appropriate water district must be provided
concurrent with development. A minimum of 10-day average storage capacity must be provided prior
to any development.
FY 2023-24 Facility Adequacy Analysis
Carlsbad's water distribution is provided by three agencies: Carlsbad Municipal Water District (CMWD),
which is a subsidiary district of the City of Carlsbad, serving 32 .32 square miles (82. 7 percent of the city),
Olivenhain Municipal Water District (OMWD) serving 5.28 square miles (13.5 percent of the city), and
Vallecitos Water District (VWD) serving 1.48 square miles (3.8 percent of the city). These districts indicate
that they have adequate pipeline and storage capacity to meet the water distribution performance
standard.
Water distribution demand requirements are estimated using a computer model to simulate the following
water distribution scenarios: 1) average daily demand; 2) maximum day demand plus a fire event; and 3)
peak hour demand. This computer model was calibrated using actual flow measurements collected in the
field to verify it sufficiently represents the actual water system.
Existing (2014 baseline year) and buildout (2040) daily demand as calculated in the CMWD 2019 Potable
Water Master Plan are 24.1 MGD and 29.6 MGD, respectively. These were based on average daily
demands of 15.1 MGD and 18.5 MGD and a peaking factor of 1.6. Within the CMWD service area, the
actual existing average daily potable water demand has been much less than this for the previous five
years as shown in Table 19:
Table 19: Water Distribution Average Daily Demand
Fiscal Year MGD
2019-20 11.9
2020-21 12.8
2021-22 12.5
2022-23 11.4
2023-24 11.4
Water conservation by CMWD customers has resulted in an overall reduction in per capita consumption.
Factors leading to this reduction include (1) an expansion of CMWD's recycled water system beginning in
2008, (2) in 2009, a campaign was initiated to reduce customer consumption by the wholesale water
agencies, (3) implementation of a new tiered water rate structure to encourage water conservation, and
(4) voluntary and mandatory conservation measures in 2015 in response to drought conditions.
The CMWD 2019 Potable Water Master Plan identified water system improvements for reliability,
expansion of facilities, and/or additional capacity, and the identified projects are programmed in the
Capital Improvement Program. If necessary, the projects are required to be constructed commensurate
with development to ensure compliance with the performance standard.
The 10-day storage requirement is part of the water distribution performance standard and a planning
criterion to accommodate pipeline maintenance recommended by the San Diego County Water Authority.
To meet the requirement, CMWD needs approximately 130 MG of storage capacity based on the average
April 22, 2025 Item #4
39
Page 45 of 47
Docusign Envelope ID: C5C5E5E3-DAC0-4C3A-8AD5-16FE71DBA309
water demand and 185 MG for buildout conditions. CMWD has a total storage capacity of 242.5 MG
which consists of 195 MG of storage capacity at Maerkle Reservoir and 47.5 MG of storage capacity in
various storage tanks throughout the distribution system as shown in Table 20.
Table 20: Storage Tanks and Capacity
Facility Name Year Built Capacity (MG)
Santa Fe II Tank 1986 9
La Costa Tank 1985 6
Maerkle Tank 1991 10
TAP Tank 1985 6
D-3 Tank 1995 8.5
Ellery Tank 1972 5
Elm Tank 1972 1.5
Skyline Tank 1972 1.5
Maerkle Reservoir 1962 195
CMWD also has interagency agreements with OMWD, VWD and Oceanside to provide additional supply
if needed. In 2004, the OMWD completed construction of a water treatment facility at the San Diego
County Water Authority Emergency Storage Reservoir, which provides the storage necessary to meet the
10-day storage criterion for OMWD. VWD's average day demand is 13.3 MGD with an existing storage
capacity of 120.5 MG. Through interagency sharing arrangements, VWD can obtain additional water
supplies to meet a 10-day restriction on imported water supply.
Buildout Facility Adequacy Analysis
As proposed land development projects are reviewed by the city, each water purveyor within the city is
consulted to review facility capacities to verify adequacy to support the water needs of the project and
city. To comply with water master plan requirements, land development projects may be required to
construct a master plan water project or other specific water improvements concurrent with construction
of the development project.
The CMWD 2019 Potable Water Master Plan identifies new pipelines and pipeline rehabilitation projects
that are programmed into the Capital Improvement Program, some of which may be constructed
concurrently with new development projects in the northeastern portion of the city. Line capacity is
deemed adequate to serve the buildout water demands within the CMWD service area.
The 2019 Potable Water Master Plan identified that no additional storage is required to meet the future
storage requirements, due in part to conservation measures and expansion of CMWD's recycled water
system . An update to the Potable Water Master Plan is in progress.
Analysis of how the Housing Element rezone program (approved January 30, 2024) affects the Water
Distribution Services performance standard at buildout is included in Exhibit 11, starting on page 768 of
780, of the Planning Commission Staff Report, dated October 18, 2023, for the Housing Element
Implementation and Public Safety Element Update.
April 22, 2025 Item #4
40
Page 46 of 47
April 22, 2025 Item #4 Page 47 of 47
TO: CITY CLERK
DATE OF PUBLIC HEARING:
SUBJECT: (j-y a;:\-a'f
AFFIDAVIT OF MAILING
NOTICE OF PUBLIC HEARING
d,i""'_±Ji vncim±. ~
LOCATION: ~200 Carlsbad Village Drive, Carlsbad, CA 92008
D Other: _________________ _
DATE posTED To c1TY wEBs1TE iLic/4,ws
DATE NOTICES MAILED TO PROPERTY OWNERS: ----------
NUMBER. MAILED:
I declare under penalty of perjury under the laws of the State of California that I ~m employed by
the City of Carlsbad and the foregoing is true and correct.
DEPARTMENT: ~TY CLERK'S OFFICE □OTHER _______ _
Signature Date
SENT TO FOR PUBLICATION VIA E-MAIL TO: □ Union Tribune on ___ _
. ~ Coa.st News ~n ::/3J/as-
PUBLICATION DATE: Union Tribune ------'-----------
Coast News ___ 'f...J...#-/ ___ 1-//~d:'""'"'C=--9S"......._ _____ _
I declare under penalty of perjury under the laws of the State of California that I am employed by
the City of Carlsbad and the foregoing is true and correct.
DEPARTMENT: ~CLERK'S OFFICE □ OTHER _______ _
.;;):3.1/c9-o~
Signature Date
Attachments: 1) Mailing Labels
2) Notice w/ attachments
NOTICE OF PUBLIC HEARING
NOTICE IS HEREBY GIVEN to you, because your interest may be affected, that the City Council of the City
of Carlsbad will hold a public hearing at the Council Chamber, 1200 Carlsbad Village Drive, Carlsbad,
California, at 5 p.m. on Tuesday, April 22, 2025, to accept the Fiscal Year 2023-24 Growth Management
Program Annual Monitoring Report and find that is satisfies the city's monitoring requirements.
The monitoring report includes analysis of development activity during Fiscal Year 2023-24, including
compliance with the Citywide Public Facilities and Improvements Plan performance standards for
administrative facilities, libraries, wastewater treatment capacity, parks, drainage, circulation, fire open
space, schools, sewer collection systems, and water distribution systems.
Those persons wishing to speak on this proposal are cordially invited to attend the public hearing. Copies
of the staff report will be available on and after Friday, April 18, 2025, or on the city's website at
https://www.carlsbadca .gov/city-hall/meetings-agendas. If you have any questions, please contact
Jennifer Jesser in the Planning Division at (442) 339 -2637 or jennifer.jesser@carlsbadca.gov. The meeting
can be viewed online at https://www.carlsbadca .gov/city-hall/communication-engagement/city-tv-
channel or on the city's cable channel. In addition, written comments may be submitted to the City
Council at or prior to the hearing via U.S. Mail to the attention of Office of the City Clerk, 1200 Carlsbad
Village Drive, Carlsbad, CA 92008, or via email to clerk@carlsbadca.gov.
If you challenge the Fiscal Year 2023-24 Growth Management Program Annual Monitoring Report in court,
you may be limited to raising only those issues you or someone else raised at the public hearing described
in this notice or in written correspondence delivered to the City of Carlsbad, Attn: City Clerk's Office, 1200
Carlsbad Village Drive, Carlsbad, CA 92008, at or prior to the public hearing.
PUBLISH: FRIDAY, APRIL 11, 2025
CITY OF CARLSBAD
CITY COUNCIL
Cln' OF CAIUSBAD
NQTJCEQEPJIBIICBEJ.RING
N011CB IS HEJtDY GIVEN to yon, becauee )'OUJ' intueat may be affecw:I, that tM City
Council o( the City o(Carl,bad will hold a public hearing at the C<>uncil Ch,mber, 1200 Carls-
bad VIDap Omo, Cart.bad, Callromia, at 5 p.m. on Tuaday, April 22, 2025, ID -th,
Macal Var 2023-H Growth Management Program Annual Monitoring Report and find that is
amdi.m the city'• monitoring tt.qtlirernenla.
The monitoring report includes analysis oC devaopmmit activity dlllinc F'IIC&I Year 2023·24,
includingoomp)iance with the C~ Public Facilities and Improvement.a Plan perf'orm.ance
standanll for adminiltntiYe facilities, libnrie,, wastewater treatmeo.t cap,c::ity. parka:, drain-
age, circulation. flire opui apace, schools. sewer collection SJl~ms, and waler dirtribution sys• ......
Those persons wishing to speak on this proposal are cordially invilm to 1.ttend the public hear-
ing. C.Opis of the sta1f report will be availabk on and after Friday, .-\pril 181 2025, or on the
city'• website at bttps·/'wwwc1dsberlc1 gnv/CUJ-baHtrnertinp-ageod■s If you have anyquPA•
tiona, please contact Jennifer Jess.er in the Planning Divis.ion at (442) 339 •2637 or jenni.fet.
jtsstc@carlsbedca r,w The meeting can be viewed onJine al http5·{/wwwcarlsbadca grnr/clt>··
baJl(mrnrnunication:-eng1gcrnent(cit,)'-rx-cb1onel or on the city's cable channel. In addition,
written comments may be submitted to the City Council at or prior to the hearing via U.S. Mail
to the atkntion of Oftloe of the City Cerk, 1200 Carlsbad Village Driwe, Carlsbad, CA 92008,
or via ema.il to clerk@cackbadca gov
IC you cballenp the Filc&l Year 2023·24 Growth Managrment Program Annual Monitoring
Report in court, you may be limited to raising oaJy 'Chea! UISuel!J you or aomeone die railed at
the pub&~ deecribed in thia notice or in written conespoodence delMl'l!ld to the City
of Carkbacl, ""'1: City CIOlk'I Qffi.,._, 1200 Ca,l,bad VUlap Dri,,e, Cart.bad, CA 90008, at or
prior ID the public hearina-
PUBUSH: FRIDAY, APR1L 11, 2025
CITY OF CARI.'lBAD
CITY COUNCIL
04/ll/20"J5 CN 30362
3ailx4.75"
14,75" X $15,50
$220,88
All Receive -Agenda Item # _i
For the Information of the:
Ana Alarcon
~l~UN~L _/ Date 2A CA CC
c¥ L e , 4?CM 131 vi
From:
Sent:
To:
Steve Linke <splinke@gmail.com>
Friday, April 18, 2025 12:09 PM
City Clerk; Keith Blackburn; Priya Bhat-Patel; Teresa Acosta; Melanie Burkholder; Kevin
Shin
Subject: Public comment 4/22/2025 Item #4 (FY 2023-24 GMP Monitoring Report)
Carlsbad City Council:
You are being asked to adopt a resolution making a finding that staff's Growth Management Program
(GMP) Monitoring Report for Fiscal Year 2023-24 satisfies the city's monitoring requirements. The staff
report contains the claim that: "This year's report shows that all public facilities identified in the Fiscal
Year 2023-24 Growth Management Program Monitoring Report meet the required facility performance
standards for FY 2023-24."
These findings are untrue. This is now the ninth consecutive year that staff has failed to present the
required monitoring of pedestrian, bicycle, and transit multi modal level of service (MM LOS). You should
NOT accept yet another legally deficient annual monitoring report. I pointed this out each year while
on the traffic commission (2019 to 2022) and each subsequent year, when the annual monitoring reports
come up for review.
Year after year, staff has made the same empty promises that the MM LOS monitoring will be presented
"within a year" or "later this year" as a supplemental report. For example, the staff report for the last
monitoring report, presented to you in June 2024, stated:
Staff will present the FY2022-23 draft MM LOS analysis, including the proposed draft
methodology developed by the Traffic Safety and Mobility Commission subcommittee, and
the draft findings and recommendations, to City Council as a separate item later this year.
[emphasis added]
Appended below is a brief history of all nine years of failures, which has seemingly become some sort of
recurring joke. This failure to satisfy the city's legal monitoring requirements is a clear violation of the
GMP and General Plan.
From the time the GMP went into effect nearly 30 years ago, circulation LOS monitoring has been a farce.
Staff devised their own custom vehicular LOS method that was designed to virtually never fail, so they
would virtually never have to report that any streets in Carlsbad were congested. That went on for the
first couple of decades of the GMP. I complained about this frequently, and my findings that the Carlsbad
vehicular LOS methods do not reflect reality were later confirmed by multiple professional traffic
consultants hired by the city.
When the General Plan underwent its major revision in 2015, I pressed hard to abandon Carlsbad's
corrupt custom vehicular LOS methods. The city agreed to use valid vehicle LOS methods for monitoring
going forward, but they simultaneously re -prioritized nearly all of the streets in Carlsbad to not be subject
to vehicle LOS monitoring, and, for the streets that remained, they introduced the concept of exempting
them when they fail.
1
Shortly after my service on the traffic commission and GMP update committee ended in 2023, I was
asked by an environmental group to testify in a GMP non-compliance lawsuit against the city. Here is part
of the judge's 10/9/2023 ruling in that case:
The city has, in practice, taken the position that if ... roads and intersections become too
congested to meet the ... [Growth Management] performance standard ... then [they] can
modifythe ... standard and/or choose to exempt any [streets] that do not meet [it]. The court
doubts that this is what the citizens had in mind when they voted to approve [Growth
Management] ...
The court believes that the city is not adhering to the spirit of Growth Management ... From
the court's perspective, the city has implemented a purported growth management plan
that is largely illusory because the city simply changes the plan or exempts itself from
compliance whenever it cannot comply.
It is also alarming that staff has continued to use the corrupt Carlsbad methods (even after the new
General Plan went into effect) to make false claims to decision-makers about LOS grades on several
street projects.
And for the last nine years, the city was supposed to be monitoring MM LOS on all of those streets that
were re-prioritized to non-vehicular modes, but they have effectively "exempted" all of those streets, as
well, with their failure to finalize a methodology or include any results in the annual monitoring reports.
Here is a brief history with actual text related to MM LOS monitoring extracted from the last nine GMP
Monitoring Reports (emphasis added for promised completion times).
FY 2015-16
Measuring the performance of non-vehicle modes of travel is a new requirement for the city ... Following
the adoption of the General Plan and the new MM LOS standard, city staff immediately began the process
of revising the MMLOS method ... The revised MMLOS method is expected to be completed within next 12
months; therefore, this report does not include [MM LOS] for the pedestrian, bicycle and transit travel
modes.
FY 2016-17
This report does not include circulation facility adequacy analysis ... New traffic and mobility monitoring
methodologies are being defined in the Evaluation and Monitoring (E&M) Manual that was under
development at the time this report was being prepared. The E&M Manual is expected to be completed in
the Summer of 2018 ... monitoring results are expected to be available shortly after the E&M Manual is
finalized.
Linke note: No E&M Manual or MM LOS monitoring methodologies were ever finalized.
FY 2017-18
Linke note: No MMLOS data was reported.
FY 2018-19
2
Staff will initiate a task order with a consultant to update and revise the pedestrian, bicycle and transit
MM LOS methodologies ... Once the refined MM LOS Tool has been applied to the bicycle and pedestrian
travel modes (and possibly to the transit travel mode) of the FY 2018-19 street typologies, staff will report
those MM LOS results to the City Council later this year.
FY 2019-20
Staff will finalize the updates to the pedestrian, bicycle and transit MM LOS methodologies ... Once City
Council has approved the refined MM LOS Tool, staff will apply it to the city streets monitored in FY 2019-
20 and present the MM LOS results to City Council later this year.
FY 2020-21
Traffic Commission testimony: Transportation Director Frank said his department was working diligently
on MM LOS, and that he expected completion within 6 to 12 months.
[S]taff will update the MM LOS methodologies, apply the revised MM LOS Tool on the street typologies for
the FY 2020-21 GMP Monitoring Report, and then return to the Traffic & Mobility Commission to present
the updated MM LOS monitoring results ...
The Traffic and Mobility Commission considered this item on June 6, 2022 ... [and voted to] ... Appoint Vice-
Chair Linke to represent the Traffic & Mobility Commission at the City Council meeting to speak to the
commission's concerns for the need for multimodal level of service monitoring.
Linke note: This topic was then not included on the council agenda, so the City Attorney would not allow
any action to be taken.
FY 2021-22
Staff will continue to work with the Traffic & Mobility Commission to finalize the update and revise the
pedestrian, bicycle and transit MM LOS methodologies and report the MM LOS results ... The status of the
pedestrian, bicycle and transit travel modes will be reported separately in Summer 2023 ...
FY 2022-23
The FY 2022-23 Growth Management Program Monitoring Report is being presented to City Council with
the status of the Vehicular LOS Standard, but not the status of the other modes because the proposed
draft MM LOS methodology for those modes is still being vetted and has not been approved by City
Council. Staff will present the FY2022-23 draft MM LOS analysis, including the proposed draft
methodology developed by the Traffic Safety and Mobility Commission subcommittee, and the draft
findings and recommendations, to City Council as a separate item later this year.
FY 2023-24 (current report under review)
The status of the pedestrian, bicycle and transit travel modes will be addressed separately at a later
date.
3
Nine straight years of false promises--when will you put an end to this?
Best regards,
Steve Linke
Carlsbad
splinke@gmail.com
CAUTION: Do not open attachments or click on links unless nize the sender and know the content i
safe.
4
Ana Alarcon
From:
Sent:
To:
Subject:
Carlsbad City Council:
Steve Linke <splinke@gmail.com>
Friday, April 18, 2025 3:12 PM
City Clerk; Keith Blackburn; Priya Bhat-Patel; Teresa Acosta; Melanie Burkholder; Kevin
Shin
Public comment 4/22/2025 Item #4 (FY 2023-24 GMP Monitoring Report--Parks)
As a companion to my comment on the Circulation component of the GMP Monitoring Report, I also
would like to remind council that the Parks component is only allegedly meeting its GMP acreage-based
performance standard by including extensive acreage of contiguous inaccessible habitat areas, and
because the future Veterans Memorial Park acreage in the northwest quadrant is being split equally
among all four quadrants (23.4 acres each). This masks park deficiencies in the southwest, northeast,
and southwest quadrants (note that the GMP standard is 3 acres per 1,000 residents in each quadrant).
Inaccessible "park" areas
There is substantial acreage in at least five of our larger parks that is unusable by people, because it is
protected habitat or otherwise restricted, including Poinsettia, La Costa Canyon, Carillo, Hidden Valley,
and the future Veterans Memorial Parl<. This acreage is certainly "open space," but it is also being called
"park" acreage with the justification that it is contiguous with the actual parks, and that some of it is
"visible" to people in the parks and on trails, even though it is inaccessible.
Veterans Memorial Park division
The justification to divide Veterans Memorial Park (formerly Macario Canyon Park) equally among all four
quadrants was made in 1986, when the plan was to create a huge (~500-acre) regional-scale park that
was to stretch from the strawberry fields on the west to what is now College Boulevard on the east (see
the map below). Planned amenities included an amphitheater, a conference center, an interpretive
center, an artisans village, an athletic center, tennis courts, baseball/softball fields, soccer fields, a
cultural arts center, a boating facility, beach access at the lagoon, a botanical center, an agricultural
preserve, and/or restaurant and concession areas. It was likened at the time to be Carlsbad's version of
"Balboa Park in San Diego and Golden Gate Park in San Francisco."
The sheer size of the territory and the scope of the amenities and activity areas were what justified the
proposed park's classification as a "regional" park worthy of citywide treatment for growth management
purposes. However, over time, multiple parcels that were going to be leased (the SDG&E, HUB, and Kelly
properties to the west) were eliminated, and a large portion south of Faraday Avenue was converted to
the golf course. The final ~94-acre portion shaded in red (only about half of which is accessible for active
use) largely only includes picnic and hiking areas, a playground, and a bike park-none of the previously
planned major amenities listed above.
In the transportation study, staff concluded that the park will not really generate new general park use
trips. Rather, it will essentially just redistribute some existing trips from other nearby parks. The Planning
Commission concurred, concluding that the substantially downsized plan has far fewer amenities and
1
much smaller planned activities than even several of Carlsbad's other "community" parks, like Alga
Norte, Poinsettia, Stagecoach, etc. Note that the acreage for these latter parks is only assigned to their
quadrant.
Thus, splitting the acreage of Veterans Memorial Park between all four quadrants is a major cheat to
satisfy the park GMP standard, because it clearly did not end up being a regional (or even citywide) park
relative to Carlsbad's other parks. It is more of a neighborhood park, or, at best, a small community park
(smaller than Alga Norte, Poinsettia, Stagecoach, etc.), which should be assigned exclusively to the
northwest quadrant, which would make the other three quadrants GMP deficient for park acreage.
Best regards,
Steve Linke
Carlsbad, CA
2
Ana Alarcon
From:
Sent:
To:
Cc:
Subject:
Attachments:
Lance Schulte <meyers-schulte@sbcglobal.net>
Tuesday, April 22, 2025 4:06 AM
Council Internet Email; City Clerk; CarlsbadLCPA@coastal.ca.gov; Eric Lardy; Jennifer
Jesser
Geoff Patnoe; Erin .Prahler@coastal.ca.gov; Ross, Toni@Coastal;
info@peopleforponto.com
4-22-25 Carlsbad Council meeting #4 on Ponto Growth Management -FW: Protect
Ponto Petition Letter
Carlsbad 2019 proposed Draft LCP Amendment -People for Ponto 2023-Jul Updated
Public Comments -Coastal Recreation.pdf; History of Open Space at Ponto -
2023 -7-15.pdf; 2025-3-24 -2-page Ponto Park-Open Space -20 facts and 5 asks.pdf
Dear Carlsbad City Council & CA Coastal Commission :
Please consider and responsibly and accountably address the facts and 8-years of the most significant Citizen input
reflected in this email for the 4-22-25 Council meeting agenda item# Item #4 (FY 2023-24 GMP Monitoring Report, and
for all the Local Coastal Program & Local Facilities Management Plan Amendments impacting Ponto.
This email is one of over 7,200 similar Carlsbad Citizen petitions to the Council with documented facts and a formal
requests to provide a true and significant Ponto Park and also to address the documented fraudulent (the City knew it
used 2 false statements as rational for a) False Exemption the City provided (as is still providing) Ponto Developers from
complying with the Growth Management Open Space Standard of 15% of the Unconstrained land with a LFMP as
Unconstrained/Useable Open Space.
The documented need for a true Ponto Park was the most Citizen requested item during the entire Growth
Management Committee process.
The attached data files that were submitted then and are being resubmitted to the New Council document (using the
City's own data) the clear an obvious need for "Public Park" at Ponto per Carlsbad's Local Coastal Program Policy
requirements, and also the concurrent/integrated need to address the current Fraudulent False Exemption of the GM
Open Space Standard in Local Facility Management Plan Zone 9 given Ponto developers.
As the Carlsbad Citizen asks the Council below in one of the 7,200 plus petitions -Council "listen and do the right thing".
Thank you. Please listen and do the right thing.
Lance Schulte
From: People for Ponto Petition [mailto:info@peopleforponto.com]
Sent: Tuesday, July 18, 2023 8:52 AM
To: petition@peopleforponto.com
Subject: Protect Ponto Petition Letter
1
Protect Ponto Petition:
Dear Carlsbad Growth Management Committee, City Council, and California Coastal
Commission:
Since 2017 the City received over 5,000 petitions, written and verbal testimony
regarding the need for Ponto Park and the Park and Useable Open Space unfairness
at Ponto and Coastal South Carlsbad. The City staff should provide the Growth
Management Committee all that citizen input since 2017.
-The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres
of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of
Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General
Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider
this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are
needed to address the 32+ acre loss AND increased population/visitor demand for
"High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate
requirements for unlimited population growth that will need even more City and
Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal
Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space
deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse
as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.
Accordingly, I am making my position known and requesting that
I want the Growth Management Committee, City Council and CA Coastal Commission
2
to:
1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acre Park to
serve minimal neighborhood needs based on Ponto buildout and City's current
minimal Park Standard). Ponto Park should be an appropriately wide, viable, flat and
fully useable multi-use grassed field -allow kids space to play informal sports. No thin
strip of non-park land.
2) Address loss of 32+ acres of Coastal Open Space Land from sea level rise by
providing for Non-neighborhood City and State buildout-population and visitor
demands for both Coastal Recreation land use and the loss of the Campground.
Provide sufficient Coastal Recreation and Low-cost Visitor Accommodation land use to
address the CA Coastal Act and City/State 'unlimited buildout population/visitor
demand', and planned loss of current supply due to planned sea level rise.
3) Disclose and address 2017 CA Coastal Commission direction to City on Ponto
Vision Plan and Planning Area F Existing LCP in the PCH Project.
4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &
Commission relative to the State's recent requirement for unlimited City and State
population growth. Document, plot the Seal Level Rise inundation and coastal
erosion/bluff hazard areas in Carlsbad's General Plan including the Land Use Map,
PCH Relocation Project maps, and in the PCH Project replace all 32+ acres of high-
priority Coastal land use that will be lost to sea level rise and coastal erosion, and
increase the supply of these high-priority Coastal land uses to address State required
unlimited increases in City/State population and visitor demands.
5) Fully disclose and consider the 2022-June General Comparative tax-payer
Costs/Benefits Analysis of Ponto Park-PCH completion-proposed PCH Relocation, to
assure tax-payers (City and/or State) are getting the best and most sustainable value
for their tax-payer dollars. The City should use tax-payer money wisely.
3
6) Incorporate the 5,000+ written/emailed petitions to the Council & CA Coastal
Commission, and the Letters from Carlsbad visitor industry, Surfrider Foundation, and
Batiquitos Lagoon Foundation.
7) Within the Local Facilities Management Plan Zone 9 portion fully provide the 30-
acers of documented missing Unconstrained Growth Management Open Space that
developers were supposed to provide. Also fully disclose and incorporate the Ponto
Open Space recommendations from North County Advocates per City's lawsuit
settlement.
Fully preserve or mitigate sensitive habitat areas within and adjacent to the PCH
Project area.
8) Fully provide required storm water quality purification and dentition basins in the
PCH Project before project waters and waters passing through the project area are
discharged into the ocean and Batiquitos Lagoon.
9) I am concerned about the PCH Modification Project more than doubling traffic
congestion along Coast Highway for an extremely costly walkway, when the same
walkway and other needed Coastal land uses can be provided for a fraction of the cost
along existing Coast Highway. It is not appropriate to try to pass off a walkway as
"linear park".
10) Lastly as requested since 2017, directly engage and specifically involve the San
Pacifico Community Association and Ponto Community in that portion of the City's
PCH Project of planning and design of land use in that community.
11) We request the above 11 citizen issues be fully addressed by the Growth
Management Committee, City Council, and CA Coastal Commission regarding Park-
Useable
Open Space and Coastal Land Use issues and City Capital Improvement Projects at
Ponto and Coastal South Carlsbad.
4
Additional Comments
We have made our views clear over and over tlu·ough petitions and meetings.
Please listen and do the right thing!
Name
Je1mifer Philion
Email
j bphi lion@yahoo .com
City
Carlsbad
State
CA
Sent from Peonle fo1 Pcn,o
CAUTION: Do not o en attachments or click on links unless ou reco nize the sender and know the content i
5
History of the false exemption of the Growth Management Open Space Standard provided Ponto
developers in Local Facility Management Plan Zone 9 (LFMP-9):
The history of how required Growth Management Open Space (i.e. unconstrained/developable land)
that should have been dedicated Open Space was, and is now being proposed to be, inappropriately
converted to Residential land use by a Perpetuating a False Exemption of the Open Space Standard
provided Ponto Developers. This False Exemption needs correction and restitution. Ponto's False
Exemption of the Open Space Standard and the 'amendment shell-game' GM Open Space history is a
critical warning sign to the Carlsbad Tomorrow Growth Management Committee, Planning Commission
and City Council. Ponto is a critical warning that a strong, accountable and accurate Open Space
Standard needs to be established for Carlsbad Tomorrow, AND a Growth Management Open Space
restitution plan needs to be established and funded that corrects the False Exemption for Ponto
Developers. If Ponto Developers were required like other similar developers at the time (Aviara and
Poinsettia Shores, "urbanizing La Costa Zones 11 & 12, etc.} to provide the required Growth
Management Open Space some of the critical Coastal Recreation and Coastal Park issues and extensive
Carlsbad Citizen needs/demands/desires at Ponto could likely have already been addressed.
How citizens found out about the False Exemption provided Ponto Developers:
In 2017 for the 1st time the city provided the GIS maps/data base accounting of Open Space in the City.
The City did this a part of settlement to a North County Advocates citizens' lawsuit. The City Open Space
maps/data base allowed Carlsbad Citizens for the 1st time the ability to see and confirm what Open
Space was produced by Growth Management (GM). The City's Open Space map/data based for Ponto
(LFMP-9) documented that about 30-acres of GM Open Space was missing (see; Carlsbad Official Public
Records Request -PRR 2017-164). As required by GM, and as Staff has said, to count as GM Open Space
it must be dedicated and 'unconstrained/developable land' to meet the GM Open Space Standard.
Being able to see for the 1st time the missing GM Open Space was one of the key awakenings that
started People for Ponto Carlsbad Citizens. Below is the City's Open Space Map for LFMP-9, with notes.
We have the City's parcel-based Open Space data base that confirms all the numerical data in the notes.
Page 1 of 20
• City GIS map of Ponto's (LFMP Zone 9)
Open Space:
• Light green areas meet the City's 15%
unconstrained Growth Management
Program Open Space Standard
• Most Ponto Open Space (pink hatch &
blue [water] on map) is "Constrained"
and does not meet the Standard
• Aviara -Zone 19, Ponto -Zone 9 and
Hanover/Poinsettia Shores -Zone 22
all developed around the same time
and had similar vacant lands.
• City required Aviara -Zone 19 east of
Ponto to provide the 15% Standard
Open Space. Why not Ponto? Aviara
had the same lagoon waters.
• City required Hanover & Poinsettia
Shores area Zone 22 just north of
Ponto to provide the 15% Standard
Open Space. Why not Ponto?
• Why Ponto developers were never
required to comply with the 15%
Standard Open Space is subject to
current litigation
• Below is City GIS data from this map
City GIS map data summary of the 15% Growth Management Standard Open Space at Ponto
472 Acres
(197 Acres)
275 Acres
X 15%
41 Acres
(11 Acres)
30 Acres
Total land in LFMP Zone 9 [Ponto]
Constrained land excluded from GMP Open Space
Unconstrained land in LFMP Zone 9 [Ponto]
GMP Minimum Unconstrained Open Space requirement
GMP Minimum Unconstrained Open Space required
GMP Open Space provided & mapped per City GIS data
Missing Unconstrained Open Space needed in LFMP Zone 9 [Ponto] to meet the City's
minimum GMP Open Space Standard per City's GIS map & data
73% of the City's minimum 15% required Open Space Standard is missing due to over
development of LFMP Zone 9 [Ponto]
So were did the missing GM Open Space go?
In early 1985 prior to the Ponto's developer (SAMMIS) annexing Ponto into the City of Carlsbad, San
Diego County's LAFCO (local agency formation commission) General Planned and pre-zoned, Ponto's
Batiquitos Lagoon waters and the lagoon bluff slopes as Open Space. This Open Space was "Constrained
Open Space" -State jurisdictional waters, and steep slopes with Coastal Sage Scrub (CSS) habitat. These
already pre-zoned constrained/non-developable Open Spaces were accounted for as part of the City's
25% pre-Growth Management Plan Open Space, and per Growth Management can't be counted in
meeting the 15% Growth Management Open Space Standard. The pre-zoned Open Space is shown in
the City's Open Space map and properly marked as "Preservation of Natural Resources" Open Space
land. This already pre-zoned Constrained (non-developable, aka 'Preservation of Natural Resources')
Open Space land at Ponto was documented in the proposed SAMMIS Batiquitos Lagoon Educational
Park (BLEP) Master Plan MP-175 as Areas N, 0, and Pin the Land Use Summary below.
On Oct, 11985 Carlsbad approved SAMIS's Master Plan and EIR to develop Ponto. SAMIS's BLEP Master
Plan MP-175. Following are BLEP MP-175's General Plan & Land Use Summary maps:
GENERAL PLAN
p
PRIVATE
40,3 AC
TS/C
TRAVEL SERVICE COMN ERCIAL
22.6 AC
EXHIBIT 1-C
_B_A_JI_Q_U_IT_O_S_L_A_GO_O_N_E_Dl_JC_A_J_IO_N_A_L_P_A_RK ___ -=-,= ff8
.SAMMIS: PROPER!ItS ' ~-~-• :·:;~~:.. ~W
Page 3 of 20
CONCEPTUAL LAND USE SUMMARY i=f.7:~
I If.II tH,µ,i:o
1~ I t j u !u4noo/1w._j
jU.:.h / 11 I _ ,,,_1 « I
1-..-oQI "I 10! I I ~==~.....,,;,.,.;..;.,,.,-4fb.,,;,,,.,.:..,,,,..;,..;=~e;=-====:!.1.~-J .. _~_:-__ f-···""I O I .... I I I ;;.---...;;.;.~.,.J~~~~~J~::'.~==:'.=::'.~'.:::::::::::;::;;::·;:·· :~---t,.,,,,~1 • I "' I I I o=, t<m.t. I~~ l.bH;!'lt m~
The BLEP MP-175 did include a variety of GM compliant Open Space.
EXHIBIT 111-8
• 12.8 acre Recreation Commercial land use (Area 1) that was playfields and Coastal Recreation
site for MP-175 and South Carlsbad. This is a Critical GM Open Space that was never dedicated.
• A minimum 30' wide landscaped Open Space on both sides of Wind rose Circle (along Areas A, B,
C, E, F, 1, G and H) that circled Area A. Windrose Circle was bordered on each side by 30' of
landscaped Open Space.
• Additional minimum 30' wide landscaped setbacks between buildings in Area A
• 2.8 acres of private recreation open space for the maximum amount of residential units
• 45' to 50' landscaped setbacks from the Batiquitos Lagoon Bluff edge (this was later developed
with Residential land use in some areas of Ponto).
• 75' landscaped separation between Areas C and D
• 70' landscaped separation between Areas D and E
• 25' landscaped setback along Avenida Encinas for Area E
• 30' to 80' landscape setback between Lakeshore Gardens and Area F
• 25' landscaped setback along Avenida Encinas for Area F
• 50' landscaped setback between Areas F and I
• 75' landscaped separation between Areas G and H
Page 4 of 20
• SO' to 80' landscape setback for Area I between Lakes ho re Gardens and between Area F
So, prior to Ponto being annexed into the City of Carlsbad in the mid-1980's and prior to Growth
Management the Batiquitos Lagoon and lagoons bluff slopes (constrained and unusable due to habitat
and slope constraints) were already pre-zoned Open Space and General Planned as Constrained Habitat
Open Space. This constrained Open Space did not and cannot meet the 15% GM Open Space Standard.
In 1986 Citizens voted for the City's version of Growth Management that included at New Standard for
Useable Open Space. The new standard was that 15% of all unconstrained useable/developable land
within a Local Facility Management Zone was to be dedicated as Open Space. Once the vote was in the
City adopted the Growth Management Ordinance 21.90 of Carlsbad's Municipal Code {City Council
Ordinance No. 9791. {Ord. 9829 § 1, 1987; Ord. 9808 § 1, 1986)).
In adopting the Growth Management Ordinance 21.90.010 the Council Clearly stated:
(b) The city council of the city has determined despite previous city council actions, including
but not limited to, amendments to the land use, housing, and parks and recreation elements of
the general plan, amendments to city council Policy No. 17, adoption of traffic impact fees, and
modification of park dedication and improvement requirements, that the demand for facilities
and improvements has outpaced the supply resulting in shortages in public facilities and
improvements, including, but not limited to, streets, parks, open space, schools, libraries,
drainage facilities and general governmental facilities. The city council has further determined
that these shortages are detrimental to the public health, safety and welfare of the citizens of
Carlsbad.
(c) This chapter is adopted to ensure the implementation of the policies stated in subsection
(a), to eliminate the shortages identified in subsection (b), to ensure that no development
occurs without providing for adequate facilities and improvements, ... "
The Citizens and Council recognized that prior City plans were not adequate to address the current (and
future) needs for facilities. Upon adoption of the New Growth Management Standards certain facilities
were already below-Standard simply based on the existing development and population. Growth
Management required additional facilities simply to bring the then current development/population up
to the New Minimum Standards. I am personally familiar with 3 GM Standards in LFMP-6 {old La Costa)
that I worked on -Library, Fire, and Park where already below-Standard i.e. existing
development/population in Old La Costa required more facilities to meet the new Growth Management
Standards. We worked to provide these new facilities for the existing development/population (i.e. fix
the Standard deficits) and then to also plan even more additional facilities at a ratio that met the New
Standards for the additional future development in Old La Costa. I can provide you some interesting
stories on that.
Page 5 of 20
I also recall working on the surrounding La Costa LRMP Zones 11 & 12 that Like Ponto/FMP-9 were
considered "Cat II: Urbanizing" yet Unlike Ponto/LFMP-9 LFMP Zone 11 & 12 were not falsely exempted
for the GMP Open Space Standard and had to provide the GM Open Space Standard of 15% of the
unconstrained/developable lands as dedicated Useable Open Space.
The Citizens vote on Proposition E and the subsequent Growth Management Ordinance 21.90 are the
rules on which the Growth Management Plans (both Citywide and 25 Local Facility Plans) are required to
follow.
To create the Citywide and the Local plans (Zones 1-6) for the largely developed areas the City needed
to temporarily pause development activity to allow time for city staff to Draft the Growth Management
Plan (my work as a city planner at the time was re-directed to draft growth management plans). So the
Growth Management Ordinance 21.90.030, established a Temporary Development Moratorium to
pause development processing activity while the Growth Management Plan was being Drafted.
Following is that language of 21.90.030. Notes are shown as italicized text within [example]:
"21.90.030 General prohibition-Exceptions.
(a) Unless exempted by the provisions of this chapter, no application for any building
permit or development permit shall be accepted, processed or approved until a city-wide
facilities and improvements plan has been adopted and a local facilities management plan for
the applicable local facilities management zone has been submitted and approved according
to this chapter. [Clearly indicates the exemptions in 21.90.030 are only from the temporary
development moratorium created by 21.90.J
(b) No zone change, general plan amendment, master plan amendment or specific plan
amendment which would increase the residential density or development intensity established
by the general plan in effect on the effective date of this chapter shall be approved unless an
amendment to the citywide facilities management plan and the applicable local facilities
management plan has first been approved. {FYI, this provision of 21.90.030 has direct
implications with respect of currently City/developer proposed General Plan/Zoning
code/local Coastal Program Amendments now being pursued by the City at Ponto Planning
Area F and Ponto Site 18. The City did not and has not yet amended the CFMP and LFMP-9 to
increase the City/developer proposed residential density or development intensity at Ponto]
(c) The classes of projects or permits listed in this subsection shall be exempt from the
provisions of subsection (a). Development permits and building permits for these projects
shall be subject to any fees established pursuant to the city-wide facilities and improvement
plan and any applicable local facilities management plan. [Then lists various exemptions from
the temporary development processing/building permit moratorium in 21.90. The BLEP MP's
exemption from the temporary moratorium is (g)]
(g) The city council may authorize the processing of and decision making on building
permits and development permits for a project with a master plan approved before July 20,
Page 6 of 20
1986, subject to the following restrictions [this only applies to the "approved before July 20,
1986" BLEP MP, and NOT to any subsequent Master Plan Amendment]:
(1) The city council finds that the facilities and improvements required by the master plan
are sufficient to meet the needs created by the project and that the master plan developer
has agreed to install those facilities and improvements to the satisfaction of the city council.
[The Ponto developer needed to provide the 12.8 acre Recreation Commercial land use and
install the GM compliant Open Space required in the 1986 MP175 but did not]
(2) The master plan developer shall agree in writing that all facilities and improvement
requirements, including, but not limited to, the payment of fees established by the city-wide
facilities and management plan and the applicable local facilities management plan shall be
applicable to development within the master plan area and that the master plan developer
shall comply with those plans. [this required the LFMP-9/BLEP MP to have 1) already been
fully developed or 2} have already have dedicated 15% of the LFMP-9 as Growth Management
compliant Open Space (i.e. Unconstrained and deve/opable) to qualify for the Open Space
exemption later falsely noted in the city-wide facilities and management plan. As clearly
documented the BLEP MP did not meet the requirements to qualify for Open Space Standard
Exemption in the city-wide facilities and management plan. The section also requires "all
facilities" (including Open Space) requirements in the Citywide Growth Management Standard
to apply to BLEP MP, not provide a means for a false exemption of the Open Space Standard]
(3) The master plan establishes an educational park and all uses within the park comprise
an integral part of the educational facility. ["all uses" including the 12.8 acre Recreation
Commercial land use and all the other GM compliant Open Spaces are an integral part.
However the 12.8 acre open space land use was never built and the BLEP MP GM compliant
Open Space never dedicated.]
(4) Building permits for the one hundred twenty-nine [129] unit residential portion of
Phase I of the project may be approved provided the applicant has provided written evidence
that an educational entity will occupy Phase I of the project which the city council finds is
satisfactory and consistent with the goals and intent of the approved master plan. {Clearly
indicates the 21.90.030 exemption is only for building permits for Phase I of the BLEP MP. Of the
129 units only the 75 unit Rosalena development applied for and received building permits under
this exemption. There are some very interesting issues related to this Rosalena Phase I
development relative to GM complaint Open Space along the bluff edge that can be expanded on
later if the CTGMC has questions.]
(5) Prior to the approval of the final map for Phase I the master plan developer shall have
agreed to participate in the restoration of a significant lagoon and wetland resource area and
made any dedications of property necessary to accomplish the restoration. [Again clearly notes
the exemption only allows a final map for Phase I to be processed. The "lagoon and wetland
Page 7 of 20
resource area" are part of the same constrained/undevelopable lands already pre-zoned prior
to the BLEP MP being incorporated into the City of Carlsbad]"
The Aviara Master Plan (directly adjacent and east of Ponto} and was also being developed at the same
time as Ponto/BLEP MP. 21.90.030 also provided the Aviara Master Plan a similar exemption (h) and
similar lagoon related quid-pro-quo for that exemption. But Aviara did not receive a GM Open Space
Standard Exemption. :
"(iv} Prior to any processing on the [Aviara] master plan the applicant shall grant an easement
over the property necessary for the lagoon restoration and the right-of-way necessary for the
widening of La Costa Avenue and its intersection with El Camino Real. (Ord. NS-63 § 1, 1989;
Ord. 9837 § 1, 1987; Ord. 9808 § 1, 1986}"
Some City staff have incorrectly stated to the City Council that they believe 21.90.030 exempts
Ponto/LFMP-9 from the Growth Management Ordinance/Program or Growth Management Open Space
Standard. RESOLUTION NO. 8666-A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD,
CALIFORNIA APPROVING TWO AGREEMENTS FOR BATIQUITOS LAGOON EDUCATIONAL PARK also shows
the 21.90.030 exemption was only for development permits during the temporary building moratorium.
In 1986 the City falsely exempted in the Citywide Facilities Plan all Ponto developers from providing 15%
of their useable/developable land as GM required Open Space. The City's documented/adopted rational
in the Citywide Plan was that Ponto/LFMP-9 was 1} in 1986 already developed, or 2} in 1986 the
developer had already met the GM Open Space Standard by having already dedicated 15% of the
useable land as Open Space. Both situations were/are false. Any air photo map or even the 1986 LFMP-
9 clearly states Ponto was NOT developed in 1986, as only the Lakeshore Gardens existed and the
Ralphs Center was just starting construction. Also the City's GIS Open Space mapping (see above) shows
that SAMMIS the Ponto developer (BLEP Master Plan MP-175} in 1986 had Not dedicated as Open Space
15% of the useable land as Growth Management compliant Open Space as shown/described in the BLEP
MP (i.e. the 12.8 Acre Recreation Commercial site and all the landscaped open space setbacks required
in the BLEP MP-175. If that 15% was dedicated in 1986 it would show-up on the City's inventory of
Dedicated Open Space now. So how did this occur?
How Ponto's planned GM Open Space was eliminated and replaced with Residential land use:
In late 1980's SAMMIS the BLEP MP-175 developer started building the 75-home Rosalena Development
as the first part of Phase I of the BLEP MP. The City (based on my recollection was very desirous to
develop the BLEP MP} and required special time limits on the BLEP MP to actually advance building the
'Educational Park' with all the "integrated" land uses (including GM compliant Open Space} within a
certain period of time. SAMIS was having financial issues and difficulty delivering the BLEP MP land
uses. Amendments (A, B, and C} to BLEP MP reflected on these difficulties:
Page 8 of 20
• MP 175(A) to allow minor accessory structures within the rear yards of all Phase I single family
lots located in Planning Area "C". [This is the Rosalena development that was part of Phase I for
BLEP MP. This amendment has implications on the landscaped Open Space setback along the
Batiquitos Lagoon bluff top, and the required Coastal access trail required by the Coastal
Development Permit for Rosa/ena. This is an interesting history that can be explained later if the
CTGMC would like.]
• MP 175(8) to realign Carlsbad Blvd., between North Batiquitos Lagoon and west of 1-5 to
accommodate the Sammis Development was WITHDRAWN January 12, 1990, and
• MP 175(C) a request for 5-year extension of time for Master Plan approval related to
educational uses on this project was Approved Planning Commission Resolution No. 2841, April
19, 1989 and approved City Council Ordinance No. NS-83, September 5, 1990.
SAMMIS went bankrupt around 1990 and Kaiza Development purchased the BLEP MP. Kaiza completed
the Rosalena development started by SAMMIS. Kaiza then sought to completely change the planned
land uses on all the remaining unconstrained/developable land in the BLEP MP.
General Plan and Master Plan Amendments eliminated/reduced BLEP's Growth Management compliant
Open Space and replace with Residential uses in the "amended" Poinsettia Shores Master Plan:
When Kaiza acquired the BLEP MP-175 and its vacant land only the State Campground, Lakeshore
Gardens, Ralphs Center, and now Rosalena were approved/existing developments at Ponto. Kaiza
proposed a Master Plan Amendment to delete the BLEP MP-175 and all its developable land uses,
except for the only portion of Phase I developed -the 75 unit Rosalena subdivision. The pre-BLEP MP
pre-zoned (and General Planned) constrained/undevelopable Lagoon waters and lagoon bluff Open
Spaces and the CA Coastal Act (LCP) required bluff top setbacks were the only Open Spaces retained in
Kaiza's proposed General Plan land use and Master Plan Amendments.
Most all ofthe BLEP MP-175 (and Ponto/LFMP-9) land area was still undeveloped at the time Kaiza
proposed changing all the General Plan land uses at Ponto and eliminating the usable Open Space in
BLEP MP.
Kaiza's General Plan land use and Master Plan 'Amendments' made radical land use changes that
converted some critical Useable GM Open Space to residential land use and also reduced some GM
Open Space provided in BLEP MP. Following is Kaiza's Amended General Plan land use map and bullet
summary of the major Open Space changes without getting into a very detailed forensic analysis:
• Eliminated the 12.8 acre Recreation Commercial land use.
• Eliminated the minimum 30' wide landscaped Open Space on both sides of Wind rose Circle for
the large unbuilt portions of Wind rose Circle
• Reduced by 10' the landscaped Open Space on the smaller built portion of Wind rose Circle
• Eliminated on 40.3 acres the additional minimum 30' wide landscaped setbacks between
buildings
Page 9 of 20
• Reduced BLEP's 2.8 acres of private recreation open space to 2.3 acres
• Except for the Rosalena (BLEP Area C) and (PSMP Area J), maintained the 45' to 50' landscaped
setbacks from the Batiquitos Lagoon Bluff edge
• Eliminated the 75' landscaped separation between BLEP MP Areas C and D
• Eliminated the 70' landscaped separation between BLEP MP Areas D and E
• Maintained the 25' landscaped setback along Avenida Encinas. [However new Master Plan
Amendments MP-175L propose reducing the setback to 10' on the undeveloped frontage of
Avenida between PCH and the railroad tracks]
• Placed a road in most of the 80' landscape setback between Lakeshore Gardens
• Eliminated the 50' landscaped setback between BLEP MP Areas F and I
• Eliminated the 75' landscaped separation between BLEP MP Areas G and H
• Added a 20' wide by 1,000' long landscaped strip for an HOA trail
Al'PRU-'.
GROSS AC.
9.8
13.5
l0.2
14.7
20.9
2.9
11.2
4.4
0.9
11.l
8.4
].7
11.9
13.8
18.3
4.6
2.3
Kaiza's Master Plan Amendment MP 175 (D) eliminated the 12.8 acre Open Space land use (with an
associated General Plan Amendment to add more residential land use) and reduced the other useable
Open Spaces required in the BLEP MP. When the 1994 Kaiza MP 175 (D) General Plan Amendments
were proposed, it seemed they voided the '1986 GM Open Space exemption' that was clearly specific
Page 10 of 20
only to the 1986 BLEP MP land uses and regulation. Although this was a false exempted, the exemption
only applied to the complete/integrated land use and open space provided in the 1986 BLEP MP. The
1986 exemption specific to BLEP MP could not apply to a different and later 1994 General Plan land use
plan that eliminated the 12.8 acre Recreation Commercial (Open Space) site to add residential land use
and that also reduced the GM compliant Open Space provided in the 1986 BLEP MP. 21.90.030(b) notes
that:
"(b) No zone change, general plan amendment, master plan amendment or specific plan
amendment which would increase the residential density or development intensity established by
the general plan in effect on the effective date of this chapter shall be approved unless an
amendment to the citywide facilities management plan and the applicable local facilities
management plan has first been approved."
The 1994 Kaiza General Plan land use and Master Plan (MP 175(D)) Amendments removed 12.8 acres of
Recreation Commercial (GM compliant Open Space) to add residential land use. This violated
21.90.030(b) by doing so without a first providing a Citywide Facilities Plan Amendment that analyzed
the actual amount of GM compliant Open Space being proposed in the 1994 Kaiza MP 175(D) relative to
the 1986 BLEP MP on which the 1986 GM Open Space exemption for LFMP-9 was based. MP 175(D) is
noted in the MP as follows:
• "MP 175 (D) Kaiza Poinsettia Master Plan To replace educational uses with residential land uses
And rename to Poinsettia Shores Master Plan (was) Approved Planning Commission Resolution
No. 3552, November 3, 1993, Approved City Council Ordinance No. NS-266, January 18, 1994."
Kaiza's MP 175(D) inaccurately and bizarrely claimed BLEP MP's prior false exemption from the GM
Open Space Standard as the justification that Kaiza's new 1994 Open Space land use changes that seem
to reduce the amount of GM complaint Open Space in the 1986 BLEP MP are also exempt from the GM
Open Space Standard. Kaiza's MP 17S(D) claims the pre-Growth Management and pre-BLEP MP
Constrained/Undevelopable lagoon waters and bluff habitat that per the 15% Growth Management
Open Space Standard CAN NOT be counted as meeting the 15% GM Open Space Standard can be
magically counted as meeting the 15% GM Open Space Standard. The GM Open Space Standard
specifically states that only Unconstrained/Developable lands CAN BE counted as meeting the GM
Open Space Standard. The stated principles of Growth Management, the Growth Management
Ordnance 21.90 and the Growth Management Open Space Standard DO NOT allow a developer or the
City to count already documented Constrained and unbuildable habitat (and water) as Unconstrained
and developable land. You can't just turn 'an apple into a banana by saying it', or turn
'Constrained/Undevelopable land into Unconstrained/Developable land by just saying it.
Compliance with the law in this Open Space issue is a part of a current lawsuit by North County
Advocates a group of Citizens watchdogs. The City has unsuccessfully tried to diminish this lawsuit. A
judge/jury will determine the outcome.
Additional MP 175 Amendments have been proposed by and approved to further modify land use and
regulatory limitations at Ponto. These include:
Page 11 of 20
• MP 175(E) Poinsettia Shores Master Plan, Redefinition of minor amendment to provide a
flexible regulatory procedure to encourage creative and imaginative planning of coordinated
communities, WITHDRAWN November 1, 1994
• MP 175(F) Poinsettia Shores Master Plan minor amendment to actualize off-site option for
provision of 90 affordable housing dwelling units, Approved Planning Commission Resolution
No. 3774, April 19, 1995
• MP 175(G) Poinsettia Shores Master Plan minor amendment to adopt Coastal Commission
Suggested modifications, Approved Planning Commission Resolution No. 3922, June 5, 1996
Approved City Council July 16, 1996, NS-367
• MP 175(H) Poinsettia Shores Master Plan -major amendment FOR HOTEL AND TIMESHARE
USES, WITHDRAWN January 16, 2003
• MP 175(1) Poinsettia Shores Master Plan -Rosalena Trail Amendment, WITHDRAWN January
8,2002
• MP 175(J) Poinsettia Shores Master Plan major amendment for Carlsbad Coast Residential
project to allow RM land use on Poinsettia Shores, WITHDRAWN January 8, 2002
• MP 175 (K) Poinsettia Shores Master Plan -Ponto Area Specific Plan Mixed use consisting of
residential, commercial and retail uses, WITHDRAWN August 19, 2004
• MP 175(L) Poinsettia Shores Master Plan -Major amendment for commercial and residential
development on Planning Area F, Still being proposed by developers and being processed by
the City.
The false exemption for the BLEP MP based LFMP-9 should never have occurred. However,
completely eliminating BLEP MP's OpenSpace land use (12.8 acre Recreation Commercial) and
reducing BLEP MP's required Open Space while at the same time claiming the false BLEP MP Open
Space Exemption is a violation of common sense, 21.90, and the very founding principles Growth
Management.
The CA Coastal Commission in MP 175 (G) in part recognized the elimination of the 12.8 acre Recreation
Commercial land use and maybe some of the Open Space land use changes and added the following
land use regulations for 11.1 acre Planning Area Fin the Carlsbad's Local Coastal Program LCP). The LCP
as per State Law and referenced in Carlsbad's General Plan is the controlling land use regulation over the
General Plan, Poinsettia Shores Master Plan and in the Coastal Zone:
"PLANNING AREA F: Planning Area Fis located at the far northwest corner of the Master Plan
area west of the AT&SF Railway right-of-way. This Planning Area has a gross area of 11 acres and
a net developable area of 10.7 acres. Planning Area F carries a Non-Residential Reserve (NRR)
General Plan designation. Planning Area Fis an "unplanned" area, for which land uses will be
determined at a later date when more specific planning is carried out for areas west of the
railroad right-of-way. A future Major Master Plan Amendment will be required prior to further
development approvals for Planning Area F, and shall include an LCP Amendment with
associated environmental review, if determined necessary.
Page 12 of 20
The intent of the NRR designation is not to limit the range of potential future uses entirely to
nonresidential, however, since the City's current general plan does not contain an "unplanned"
designation, NRR was determined to be appropriate at this time. In the future, if the Local
Coastal Program Amendment has not been processed, and the City develops an "unplanned"
General Plan designation, then this site would likely be redesignated as "unplanned." Future
uses could include, but are not limited to: commercial, residential, office, and other uses,
subject to future review and approval.
As part of any future planning effort, the City and Developer must consider and document the
need for the provision of lower cost visitor accommodations or recreational facilities (i.e.
public park) on the west side of the railroad."
In 2010 the CA Coastal Commission in 2010 rejected the Ponto Beachfront Village Vision Plan on which
MP 175(K) was based. MP 175(K) was withdrawn.
On July 3, 2017 the CA Coastal Commission provided direction to the City of Carlsbad regarding MP
175(G), Carlsbad's 2015 General Plan Update, Carlsbad proposed Local Coastal Program Amendment
Land Use Plan (LUP) . CA Coastal Commission wrote to the City the following. Notes on the context of
communication are in bracketed italics [example]:
"The existing LUP includes policies that require certain visitor-serving developments and/or
studies relevant to the Ponto ... area. For example, Planning Area F requires the city and
developer to "consider and document the need for the provision of lower cost visitor
accommodations or recreational facilities (i.e., public park) on the west side of the railroad ....
this study should be undertaken as a part of the visitor serving use inventory analysis described
above. [the discussion of the need for the City to conduct a citywide analysis of the location and
amount of these uses in the Coastal Zone to assure the City General Plan within the Coastal Zone
is providing the adequate amounts and locations of these land uses to fulfill the long-term
population/visitor needs for these uses according to the CA Coastal Act] If this analysis
determines that there is a deficit of low cost visitor accommodations or recreation facilities in
this area, then Planning Area F should be considered as a site where these types of uses could
be developed."
In 2017 the City conducted the first Sea Level Rise (SLR) Vulnerability Assessment
https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?Blob1D=33958 . That first initial analysis,
shows significant SLR impacts that will reduce existing Ponto Open Space -the State beach and
Campground and along the Batiquitos Lagoon. The City identified SLR impacts on Ponto Open Space are
summarized in the next section of this history.
In 2023 the CA Coastal Commission will consider the data and public input and decide the appropriate
land use for 11.1 acre Planning Area F based the CA Coastal Act and Coastal Act land use policies.
You can determine the Open Space and Park Quality of Life Standards that will be applied to this and
other future land uses.
Page 13 of 20
City assessment of Sea Level Rise impacts on reducing Ponto Open Space
The City's 2017 SLR assessment shows SLR will significantly reduce or eliminate only existing Open Space
land at Ponto. The City's assessment quantifies the speratic/episodic loss of Ponto/Coastal South
Carlsbad Open Space land and land uses being at the State Campground, Beaches, and Batiquitos
Lagoon shoreline -about 32 acres by the year 2100, this would be an average loss of 17,000 square feet
of Open Space per year. Following (within quotation marks) is a description, quantification and images
of the City's projected loss of Ponto/Coastal South Carlsbad Open Space land and land use due to SLR.
[Italicized text within brackets] is added data based on review of aerial photo maps in the Assessment.
"Planning Zone 3 consists of the Southern Shoreline Planning Area and the Batiquitos Lagoon. Assets
within this zone are vulnerable to inundation, coastal flooding and bluff erosion in both planning
horizons (2050 and 2100). A summary of the vulnerability assessment rating is provided in Table 5. A
discussion of the vulnerability and risk assessment is also provided for each asset category.
5.3.1. Beaches
Approximately 14 acres of beach area is projected to be impacted by inundation/erosion in 2050 ....
Beaches in this planning area are backed by unarmored coastal bluffs. Sand derived from the natural
erosion of the bluff as sea levels rise may be adequate to sustain beach widths, thus, beaches in this
reach were assumed to have a moderate adaptive capacity. The overall vulnerability rating for beaches
is moderate for 2050.
Vulnerability is rated moderate for the 2100 horizon due to the significant amount of erosion expected
as the beaches are squeezed between rising sea levels and bluffs. Assuming the bluffs are unarmored in
the future, sand derived from bluff erosion may sustain some level of beaches in this planning
area. A complete loss of beaches poses a high risk to the city as the natural barrier from storm waves is
lost as well as a reduction in beach access, recreation and the economic benefits the beaches provide.
5.3.3. State Parks
A majority of the South Carlsbad State Beach day-use facilities and campgrounds (separated into
four parcels) were determined to be exposed to bluff erosion by the 2050 sea level rise scenario
(moderate exposure). This resource is considered to have a high sensitivity since bluff erosion
could significantly impair usage of the facilities. Though economic impacts to the physical structures
within South Carlsbad State Beach would be relatively low, the loss of this park would be significant
since adequate space for the park to move inland is not available (low adaptive capacity). State
parks was assigned a high vulnerability in the 2050 planning horizon. State park facilities are recognized
as important assets to the city in terms of economic and recreation value as well as providing low-cost
visitor serving amenities. This vulnerability poses a high risk to coastal access, recreation, and
tourism opportunities in this planning area.
Page 14 of 20
In 2100, bluff erosion of South Carlsbad State Beach day-use facilities and campgrounds become
more severe and the South Ponto State Beach day-use area becomes exposed to coastal flooding
during extreme events. The sensitivity of the South Ponto day-use area is low because impacts to usage
will be temporary and no major damage to facilities would be anticipated. Vulnerability and risk to State
Parks remains high by 2100 due to the impacts to South Carlsbad State Beach in combination
with flooding impacts to South Ponto.
Table 5: Planning Zone 3 Vulnerability Assessment Summary [condensed & notated]:
Asset
Category
Beaches
Public Access
State Parks
{Campground -
Low-cost Visitor
Accommodations]
See Figure 5.]
Transportation
Horizon
[time] Hazard Type Impacted Assets
2050 Inundation/Erosion, Flooding 14 acres (erosion)
2100 Inundation/Erosion, Flooding 54 acres (erosion)
2050 Inundation, Flooding
2100 Inundation, Flooding
6 access points
4,791 feet of trails
10 access points
14,049 feet of trails
Vulnerability
Rating
Moderate
Moderate
Moderate
Moderate
2050 Flooding, Bluff Erosion 4 parcels {<18 Acres} High
2100 Flooding, Bluff Erosion 4 parcels [>18 Acres] High
[loss of over 50% of
the campground &
its Low-cost Visitor
Accommodations,
2050 Bluff Erosion 1,383 linear feet Moderate
Page 15 of 20
(Road, Bike, 2100 Flooding, Bluff Erosion 11,280 linear feet High
Pedestrian)
Environmentally 2050 Inundation, Flooding 572 acres Moderate
Sensitive 2100 Inundation, Flooding 606 acres High
Lands
Figwe 7: sou un Sh« ine Planning Area-v~r 2050
Page 16 of 20
(_ ,il y ol'
Carlsbad
( ~, I I f O I' n I ,)
EXHIBITB6
Figure 5: CoSMoS Bluff Erosion Projections by 2100
{CoSMoS-COAST 2015)
Page 17 of 20
[Figure 5 show the loss of over 50% of the campground and campground sites with a minimal .2 meter
Sea Level Rise (SLR), and potentially the entire campground (due to loss of access road) in 2 meter SLF.]"
This 2017 SLR data and quantified losses of Ponto/Coastal South Carlsbad Open Space land and land
uses was not considered in the City's rejected (by CCC) Ponto Beachfront Village Vision Plan. The Ponto
Vision Plan is the basis for the City's 2015 General Plan Update that is now being proposed in the City's
Local Coastal Program Amendment now before the CA Coastal Commission.
Summary:
LFPM-9 was clearly not developed in 1986, and did not then or now dedicate 15% of the
unconstrained/developable land as Open Space as required by the Growth Management Open Space
Standard. These two reasons for the City to "exempt" LFMP-9 from Open Space Standard were/are
False. Saying Constrained/undevelopable land can be counted as Unconstrained/developable land is also
false and clearly not allowed according to the Growth Management Ordinance, Standards, principles,
and common-sense honesty to Carlsbad Citizens. LFMP-9, as the City's own maps/data base show is
clearly missing 30-acres of GM Open Space. In addition in 2017 we learned that Ponto/Coastal South
Carlsbad will lose about 32 acres of existing Open Space due to SLF.
Closing thoughts:
Growth Management is based on the type/amount/location of General Plan land use designations, the
development potential of those land use designations in creating the demand for the
type/amount/location of facilities, and supply of the type/amount/distribution of facilities -like Open
Space and Parks. If the type/amount/location of supply of facilities does not meet the demand for those
facilities then growth management fails and Quality of Life is reduced.
Quality of Life Standards are used to assure supply and demand for facilities is properly balanced with
respect to type/amount/location.
Ponto is clearly unbalanced. The Ponto Census Track is at a 40% higher population density than the rest
of Carlsbad, yet is Ponto is NOT meeting the Open Space Standard and has NO Park (see City Open Space
maps and Park Master Plan). Ponto and all South Carlsbad have higher population demand for Parks
and Open Space facilities yet Ponto (that is the only place to provide Coastal Park and Open Space needs
for South Carlsbad) has lower or none of those two most critical GM Facilities needed to balance and
mitigate the 40% higher population density at Ponto and also the higher residential density in South
Carlsbad.
Ponto and Coastal South Carlsbad also have additional State and regional responsibilities to provide
Coastal Recreation and Open Space for populations of people and visitors from outside of Ponto and
Carlsbad.
Page 18 of 20
This failure to honestly and adequately balance the type/amount/location higher population density by
providing higher levels of Parks and Open Space in those areas will lead to a slow and but eventual
reduction of the Quality of Life for those areas.
Common sense and the Carlsbad's Growth Management law say if you change the land use (like what
was done and is still being proposed at Ponto) you change the type/amount/location of potential
development and population and the Growth Management impacts. Land use changes require and
honest/accurate/balanced update to Citywide and Local Growth Management Plans to accurately reflect
those changes and provide an updated plan to provide facilities that meet the Standards for those land
use changes. This is the fundamental heart of any Growth Management.
The Carlsbad Tomorrow Growth Management Committee, and City Commissions and Council are all
now facing the same issues and responsibility that we faced in the 1980's at the beginning of Growth
Management. We established New Quality of Life Standards -for Open Space and Parks -that required
New investments in Parks and Open Space by both the City and developers.
Open Space and Parks have always been identified as most critical for Carlsbad's quality of life. The
Carlsbad Tomorrow Growth Management Committee, and City Commissions and Council, and Carlsbad
Citizens are all at a critical crossroad.
• Do we, or don't we, enforce and set new standards that achieve the quality of life we desire?
• Do we or don't we, fix existing past errors and below desired standard situations?
• Do we or don't we, roll-up our sleeves a work together to a better Quality of Life?
As a long-time Carlsbad Citizen I am extremely disappointed by some who say we can't fulfill our
Community Vision, we can't fix things, can't make things better, and can't add more Parks and Useable
Open Space. This can't attitude is not out Community Vision. We can and we did before, and we can do
it again and better.
Great cities for hundreds of years have Upgraded their Quality of Life Facility Standards, made and
implemented/funded facilities to fix things up to those Standards. A City is just like a business or person
-If you don't improve you decline. Examples of Upgrading and funding to New Parks and Open Space
are many but include -Carlsbad's Buena Vista Reservoir Park, additions to Pine Park, Village H Park, and
Aura Circle Open Space acquisition; and SDSU's major new Park at the redeveloped Qualcomm Stadium
site.
Now like at the beginning of Carlsbad Growth Management the City can "despite previous city council
actions" make improvements to its Growth Management and Quality of Life Standards to address past
and future needs. Following illustrates existing R-23 (up to 23 dwellings per acre) development in
Carlsbad -most of our future residential development will be required to be like this or more dense.
Page 19 of 20
High-density housing can be great, but it requires MORE Parks and MORE useable Open Space within
walking distance to balance the density and provide large places for families and kids to really play. In
Carlsbad's high-density residential future with no backyards and stacked flat multi-family homes the
need for both more Parks and Useable Open Space is much greater than in 1980's.
The time to fix the Parks and Useable Open Space problems at Ponto (LFMP-9) is now. Already Ponto is
developed at a density that is 40% great than the rest of Carlsbad. New proposed and even higher-
density developments (developer driven Amendments) propose to make Ponto even more dense, yet
there are not Parks at Ponto and Ponto is missing 30-acres of Useable Open Space past developers
should have provided.
A doable, time-tested, accountable, tax-payer saving, strongly citizen desired, accountable, and honest
way to fix this was presented to you in 8/8/22 and 12/27 /22 emails with attached "CTGMP Key Issues
and Suggestions -2022-12-6". Over 5,000 petitions expressing the need to fix the Park and Open Space
problems at Ponto have been sent to the City and the City should have provided these to you in
considering Park and Open Space issues.
Ponto Park and Open Space needs your help fixing NOW. If not Carlsbad Tomorrow will be less than it is
today, and tragically will have failed our Community Vision .
Page 20 of 20
Since 2017 People for Ponto Carlsbad Citizens have provided documented facts and over 7,200 citizen
petitions requesting: Carlsbad's City Council and/or CA Coastal Commission (CCC) honestly look at the
facts and work with Citizens to provide a much needed Ponto Park.
20 Facts, documented by over 70 official Carlsbad Public Records Requests:
1. A 12.8 acre Commercial Recreation land use (Useable Growth Management Open Space) was
planned at Ponto (BLEP MP/LCP) in mid-1980s. In early 1990s developers, City, and CA Coastal
Commission (CCC) replaced it with 11.1 acre Planning Area F "Non-Residential Reserve" land use
that requires the City to consider/document the need for "Coastal Recreation (i.e. Pubic Park)"
and/or the State Campground "Low-Cost Visitor Accommodations (L-CVA)" at Ponto.
2. Developer's/City's 2005 Ponto Vision Plan tried changing Planning Area F to high-density residential.
In 2010 the CCC rejected the Ponto Vision Plan Local Coastal Program Amendment (LCPA) for failing
to comply with LCP Ponto Planning Area F regulations consider a "Public Park, et. al."
3. In 2016-7 the CCC informed the City their Developer's/City's proposed Ponto Vision and Planning
Area F land use changes may not be approved based on the need for "Coastal Recreation (i.e. Public
Park) and/or L-CVA land uses". In 2025 the CCC will decide on Planning Area F and Ponto LCPA.
4. The City did not consider Sea Level Rise impacts on providing Coastal Recreation and reducing
existing Low-Cost Visitor Accommodation land uses in the City's Ponto Vision Plan, current 2015
proposed General Plan, and Draft LCPA. Only in 2017 did the City first conduct a Sea Level Rise
Impact Assessment that showed the loss of 32 acres of beach and L-CVA (Campground) land use at
Ponto in 70 years. In 2023 State Parks started to consider Sea Level Rise Impacts. Due to the
Campground's road configuration sea level rise and erosion will eliminate the Campground use
(Carlsbad's only L-CVA) by 2100. Current demand at the Campground and L-CVA is very high, and
will only grow in the future. A clear and fully funded plan in Carlsbad's LCPA to move the
Campground inland and increase the number of campsites is needed and logical.
5. Most of Carlsbad's Visitor Accommodations and hotel taxes are in South Carlsbad; yet visitors have
no Coastal Park in South Carlsbad. South Carlsbad Visitor industry has supported Ponto Park.
6. Most of Carlsbad's Low-Cost Visitor Accommodations (Campground) are in South Carlsbad. There's
no grassy Day-Use Park at the Campground, or in Coastal South Carlsbad.
7. Since 2012 there has been a 6.5 acre City Park deficit in the SW Quadrant area that includes Ponto.
That City Park deficit is now over well 7 acres due to new development. The City GM Park Standard
requires Parks to be provided concurrent with development and within the Quadrant where Park
demand is created. This Standard has not been, and still is not being complied with.
8. The CA Coastal Act supports equitable distribution of land uses such as High-Priority Public Park
uses. Carlsbad provides 37 Park acres in 10 Coastal Parks in/for North Carlsbad (38% of the City; and
0 (zero) Park acres and O (zero) Coastal Parks in/for South Carlsbad (62% of Carlsbad Citizens).
9. The City's 2015 Park Master Plan maps Park locations and Park service areas, and documents that
the Ponto area and much of the SW Quadrant is 'unserved by Parks' and that 'unserved areas'
should be locations to provide future City Parks (pp 86-88).
10. The Trust for Public Land's ParkServe data documents Carlsbad is the worst Southern CA Coastal city
in providing 10-minute walk access to Parks. Carlsbad is the worst of 29 cities from Santa Barbara to
Imperial Beach. Carlsbad is the worst City for over 250 miles of So. CA coastline and 5 million
residents in providing Parks with a 10-minute walk. The Trust for Public land supports a Ponto Park.
11. Carlsbad has one park per 2,797 residents and 2.95 acres of Park land per 1,000 residents. National
Recreation and Park Association (NRPA) data show that nationally Carlsbad is 20% below what is
typical in providing the number of parks, and Carlsbad is 72% below what is typical in providing the
amount of Park acres. The Trust for Public Land data base shows that Carlsbad's total Park land
ace rs (including counting State Park land acres) is 26% below the Median for the TPL's 100
2025-3-24 -Ponto Park-Open Space -20 facts & 5 asks Page 1 of 2
ParkScore® cities, and 7% below the Median for the 14,000 cities and towns in the TPL ParkServe®
database of USA cities.
12. Encinitas and Oceanside require/provide 5 acres of Park per 1,000 population that is 67% more than
Carlsbad requires/provides (only 3 acre/1,000). Encinitas and Oceanside also plan/require their
Parks to be accessible and within a 10-mintue walk to their citizens and families -Carlsbad doesn't
13. Every 8-year Housing Element Carlsbad will add even more population in high-density
developments. High-density homes create demand for more City Parks, and these developers
should provide Parkland as their required Park obligations, not pay an 'in-lieu-fee'. For almost 20-
years the City failed to update (to account for 20-years of increased land costs) the Park-in-lieu-fees
the City charges developers. Millions of free Park dollars were lost by undercharging developers.
14. Ponto is in the center of a 6-mile length San Diego County coastline (8% of the County's coast)
without a Coastal Park west of the rail/I-5 corridors. Inland of these 6-miles are likely over 150,000
Carlsbad and San Diego County residents and visitors that do not have a Coastal Park.
15. Ponto is the last remaining vacant land (Planning Areas F, G, & H) for a true and viable Coastal Park
in this 6-mile length of coast. The cost to buy these vacant lands saves tax-payers tens of millions of
dollars. 11.1 acre Planning Area F recently sold for under $8 million or about$ 720,000 per acre. 15
acre Planning Area G & H was listed for $38 million or about $2.5 million per acre. The City's 2001
URS and ERA PCH Studies identified 3 "Surplus Areas" totaling about 15 existing acres of
narrow/constrained PCH roadway median land south of Island Way that could be converted to other
uses. The City's stated conversion cost is $65 to $160 million, or$ 4.3 to $10.6 million per acre of
narrow land. The City's 2001 ERA PCH Relocation Finance Study said funding is problematic.
16. Past Carlsbad Councils Falsely "exempted" Ponto developers from providing 15% Unconstrained and
Useable Growth Management Open Space other developers were required to provide. City data,
maps, and City testimony in court confirm this. Ponto (LFMP Zone 9) needs 30 more acres of
Unconstrained/Useable Open Space to meet the Standard. The False "Exemption" is why Ponto is
already developed at 40% higher density than the rest of Carlsbad. And why Ponto has no Park.
17. People for Ponto Citizens continue to try to work with multiple Ponto land owners to affect a land
swap with the city, similar to the successful Poinsettia 61/Buena Vista Reservoir Park solution. The
City has unused misplaced Park/surplus !Land/Buildings it is working on selling. A building/land-
swap with Ponto land owners is an All-win solution, if the Council would lead this opportunity.
18. Ponto Park 501c3 can help the City or State Parks in acquiring donations /funding for Ponto Park.
19. People for Ponto Carlsbad Citizens provided the City Council with "6 Growth Management Issues
and Suggestions" summarizing logical, doable, cost-effective, sustainable, and collaborative
solutions to address these facts.
20. People for Ponto citizens will help State and Carlsbad's New Mayor/Council succeed for our future.
Since 2017 over 7,200 petitions from Carlsbad citizens and other People for Ponto are still asking the
Carlsbad City Council and/or State of California to:
• Provide a 6-7 acre Ponto Park for the minimal neighborhood needs of Ponto's population.
• Provide more Ponto Park acres for State/Regional Coastal Recreation (i.e. Public Park) needs (ex.
South Carlsbad: 64,000 pop. & 62% of City) per Carlsbad Local Coastal Program & CA Coastal Act
• Ponto Park must be wide, flat and fully useable. A multi-use grassed area to allow kids/families
space to informally play/picnic at the coast is what is needed. No thin/leftover strips along PCH.
• Replace 32+ acres of State Coastal Open Space (State beach/campground) to be lost by sea level
rise within 70-years by allowing the Campground (Carlsbad's main Low-cost Visitor
Accommodations) to move/expand inland. Allow bluff erosion for sand to preserve the beach.
• Use People for Ponto Citizens' GM Plan to help replace Ponto's missing 30 acres of Useable
Open Space, fund Ponto Park, and at the same time saving tax-payers tens of millions of dollars.
2025-3-24 -Ponto Park-Open Space -20 facts & 5 asks Page 2 of 2
AFFIDAVIT OF MAILING
NOTICE OF PUBLIC HEARING
TO: CITY CLERK
DATE OF PUBLIC HEARING: Li/;);;). /:20:;J~
SUBJECT: :±Y -a;:>,-a:i.. (k"".±6 vr?,5d-~
LOCATION: ~200 Carlsbad Village Drive, Carlsbad, CA 92008
D Other: _______________ _
DATE POSTED TO CITY WEBSITE 'iLi c/,2,,y;)S
DATE NOTICES MAILED TO PROPERTY OWNERS: _________ _
NUMBER_ MAILED:
I declare under penalty of perjury under the laws of the State of California that I am employed by
the City of Carlsbad and the foregoing is true and correct.
DEPARTMENT: uJ,6'TY CLERK'S OFFICE □OTHER _______ _
Signature Date
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SENT TO FOR PUBLICATION VIA E-MAIL TO: □ Union Tribune on ___ _
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PUBLICATION DATE: Union Tribune --------------------
Coast News ___ 4_,___/-'-", t~/~d~D~&S~· ..,,_._ ___ _
I declare under penalty of perjury under the laws of the State of California that I am employed by
the City of Carlsbad and the foregoing is true and correct.
DEPARTME~T: ~CLERK'SOFFICE □ OTHER _______ _
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Signature Date
Attachments: 1) Mailing Labels
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NOTICE OF PUBLIC HEARING
NOTICE IS HEREBY GIVEN to you, because your interest may be affected, that the City Council of the City
of Carlsbad will hold a public hearing at the Council Chamber, 1200 Carlsbad Village Drive, Carlsbad,
California, at 5 p.m. on Tuesday, April 22, 2025, to accept the Fiscal Year 2023-24 Growth Management
Program Annual Monitoring Report and find that is satisfies the city's monitoring requirements.
The monitoring report includes analysis of development activity during Fiscal Year 2023-24, including
compliance with the Citywide Public Facilities and Improvements Plan performance standards for
administrative facilities, libraries, wastewater treatment capacity, parks, drainage, circulation, fire open
space, schools, sewer collection systems, and water distribution systems.
Those persons wishing to speak on this proposal are cordially invited to attend the public hearing. Copies
of the staff report will be available on and after Friday, April 18, 2025, or on the city's website at
https://www.carlsbadca.gov/city-hall/meetings-agendas. If you have any questions, please contact
Jennifer Jesser in the Planning Division at (442) 339 -2637 or jennifer.jesser@carlsbadca.gov. The meeting
can be viewed online at https://www.carlsbadca .gov/city-hall/communication-engagement/city-tv-
channel or on the city's cable channel. In addition, written comments may be submitted to the City
Council at or prior to the hearing via U.S. Mail to the attention of Office of the City Clerk, 1200 Carlsbad
Village Drive, Carlsbad, CA 92008, or via email to clerk@carlsbadca .gov.
If you challenge the Fiscal Year 2023-24 Growth Management Program Annual Monitoring Report in court,
you may be limited to raising only those issues you or someone else raised at the public hearing described
in this notice or in written correspondence delivered to the City of Carlsbad, Attn: City Clerk's Office, 1200
Carlsbad Village Drive, Carlsbad, CA 92008, at or prior to the public hearing.
PUBLISH: FRIDAY, APRIL 11, 2025
CITY OF CARLSBAD
CITY COUNCIL
CITY OF CAIWlllAD
N<>TICE OF PIIBTJC BEARING
NOTICE IS HDPJIY GIVl!N 14 you, becau6e yau, mwut "'"!' be alfttt,,d, that the City
Council of the City oCCarlobod will hold• public h,oriag at the Council Chamber, 1200 Carls-
bod vi11.,. Drive, Carl,bod, C&lifomla. at • p.m. on Tueod&y, April 22, 0025, to ocxept the Filcal Year 2023-2-1 Growth Management Prognm Annual Monitoring Report and find that ia
-.. thec:11y, monitoring~
The monitoring report include11 analysis of d.evu>pment activity during Fiscal Year 2023·24,
including comp]iance with the Citywide Public Facilities and Improwments Plan performance
ataDdarda for administratiw f'acilitiea, librariea, wastewater treatment c.apaclty, parks, dn.in-
ap. circulation, fire open space. achoo1s. aewe, coUection sysU:ms, and waler disbibution ll)'S• ......
Those persons wishing to speak on this propo6a) en cordially invited to attend the public hear-
ing. Copim of the sta1f report will be available on and after Friday, April 18, 2025, or on the
city's websitr: at bttps·/'wwwcarlshldc1 p/ci~•b1Ulrnertings-1geod1s If you have any ques-
tion.,, please contact Jennifer Jesstt in the Planning Division at (442) 339 •2637 or j.ennii:r..
iesser@carlsbadca gm: The meeting can be viewed onJine at bttps· /lwww cadsbadca p:w(cicy:-
baHfrommnnk:atioo-engagr:rncnt/cit,a£-bH:baooeJ or on Lhe city's cable channel. In addition,
written comment& may be submitted to the City Council at OI' prior to the hearing via. US. Mail
to the &!1entiou ofOflia,oftheCity Clerk, 1200 CadJbad Wlage Dri~, Culshad, CA92008,
or via email tt>clerk@cadsbadca gov
lf yvu dwlmp the Fl,cal Yeaz 0025·2' -Mu-t Program Annual Monilering
Report in court. )'OU may be limited to ruioa ooly thosie iaeuee you or aomeone elle ni&ed at
the public heuing cleocribed in thi, noa,, or in wriu.n """""pondenoe cleliverod 14 the City
of Carlobod, Attn, aty a..t', Office, 1200 c..J.bod vm.,. Om., Carl,bad, CA 92000, at or
prior 14 the publie he&ring.
PUBUSH:FRIDAY, APRIL 11, 2025
CTlY OF CARLSBAD
Cl1Y COUNCIL
04/11/0025 CN 30362
3 CXJlx4.75"
14,75" X $15,50
$220.88
FY 2023-24 Growth Management
Program Monitoring Report
Eric Lardy, City Planner
Community Development Department
April 22, 2025
{city of
Carlsbad
INTRODUCTION
•Annual report required by Municipal Code
•Zoning Code Section 21.90.130(d)
•Provide status on Performance standards
to ensure public facilities are provided
concurrent with growth
•State Laws and Resolutions suspended
portions of Growth Management Program
{city of
Carlsbad
PUBLIC FACILITY STATUS
Public Facility FY 2023-24
compliance Public Facility FY 2023-24
compliance
Admin Yes Circulation (vehicle)Yes
Library Yes Drainage Yes
Fire Yes Sewer Yes
Schools Yes Water Yes
Parks Yes Wastewater Yes
Open Space Yes
HOUSING ELEMENT
REZONE PROGRAM
FUTURE DWELLINGS INCREASED
•January 2024 – City Council approved rezoning of 16 sites through the city
•Increased number of future dwellings by
2,998
•Estimated dwellings at buildout exceed
growth caps in NW, NE quadrants & citywide
•FY 2023-24 is first annual monitoring report
to show dwelling caps exceeded at buildout
4 it. 8
0 ;;:
0 ct
[ @ Housing Sites Approved for Rezoning
I
Previous Report - FY 2022-23
Estimated Dwellings at Buildout Compared to Proposition E Dwelling Caps
Northwest
Quadrant
Northeast
Quadrant
Southwest
Quadrant
Southeast
Quadrant Citywide
Proposition E
Dwelling Caps 15,370 9,042 12,859 17,328 54,599
Estimated Buildout
Dwellings 15,334 8,940 11,924 17,022 53,220
Above/ Below
Dwelling Caps
36
below
102
below
934
below
306
below
1,379
below
FY 2023-24 – with Rezone Program
Estimated Dwellings at Buildout Compared to Proposition E Dwelling Caps
Northwest
Quadrant
Northeast
Quadrant
Southwest
Quadrant
Southeast
Quadrant Citywide
Proposition E
Dwelling Caps 15,370 9,042 12,859 17,328 54,599
Estimated Buildout
Dwellings 17,215 9,608 12,260 17,270 56,353
Above/ Below
Dwelling Caps
1,845
above
566
above
599
below
58
below
1,754
above
HOUSING ELEMENT
REZONE PROGRAM
FUTURE POPULATION INCREASED
•Increase in future dwellings = increase in
future population
•Increases future need for additional Administrative Facilities, Libraries, and Parks
•Staff monitors facility demand and will report
when there is need for additional facilities
•Updates to facility master plans
•Rezoned sites included in on-going updates to
drainage, water and sewer master plans
Housing Sites Approved for Rezonin~
RECOMMENDED ACTION
•Support staff’s recommendation to:
–Receive and file the Fiscal Year 2023-24 Growth
Management Program Monitoring Report, prepared
pursuit to Carlsbad Municipal Code (CMC 21.9.130)
{ City of
Carlsbad