HomeMy WebLinkAboutEA 2022-0022; DRAINAGE MASTER PLAN UPDATE - CIP 6623; Admin Decision LetterMemorandum
Oct. 12, 2022
To:
From:
Scott Lyle, Senior Engineer
Scott Donnell, Senior Planner
Eric Lardy, City Planner
C cityof
Carlsbad
Via
Re: EA 2022-0022 (PUB 2022-009) -Drainage Master Plan Update (CIP 6623)
Thank you for submitting an Early Assessment for a proposed update to the city's Drainage Master Plan
(draft DMP), last revised in 2008. The draft DMP includes an existing drainage infrastructure assessment
to identify and prioritize drainage infrastructure CIP projects. The update identifies and refines a list of 11
total CIP projects deemed the most critical to address current storm drain conveyance deficiencies. At the
same time, the update considers the effects of future development activity in the city (based on General
Plan Land Use data), which is anticipated to increase the volume and/or velocity of storm water runoff.
The draft DMP recommends improvements in each of the city's four drainage basins with most
improvements concentrated in basins "A" and "B" located north of Palomar Airport Road.
Further, the EA application notes that due to changes in construction costs and environmental regulations
an increasing number of projects included in the 2008 DMP are not fully funded and/or the scope of work
is not permittable. The City council authorized a DMP update in 2019 to recalibrate the PLDA fee schedule
based on present day environmental regulations and economic conditions, revise the project scope as
necessary and add and delete new/old projects. The PLDA, or Planned Local Drainage fee program,
generates fees that are used to fund CIP projects or reimburse developers that construct master planned
facilities.
In response to your application, the Planning Division has prepared this comment letter. The comments
primarily concern the 11 sites deemed most critical to address current deficiencies as well as Appendix D
to the draft DMP. Appendix Dis a screen check draft of an Addendum to the Final EIR certified for the
2008 DMP Update. Please note that the purpose of an Early Assessment is to provide you with direction
and comments on the overall concept of your project. This Early Assessment does not represent an in-
depth analysis of your project. It is intended to give you feedback on critical issues based upon the
information provided in your submittal. This review is based upon the plans, policies, and standards in
effect as of the date of this review. Please be aware that at the time of a formal application submittal,
new plans, policies, and standards may be in effect and additional issues of concern may be raised
through a more specific and detailed review.
Planning:
General
1. General Plan and zoning information for the project is as follows:
Community Development
Planning Division
1635 Faraday Avenue / Carlsbad, CA 92008 I 442-339-2600
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a. General Plan land use designations for the 11 CIP projects vary. In some cases, no land use
designations apply as projects are partially or completely within street right of way. Project
components not in the right of way are General Plan designated as either Residential or
Residential/Open Space (BJ-1) or Open Space (projects BasinA-410, BasinA_1700, BL-L, BR,
C2, and DFA). The Open Space designation may indicate the presence of sensitive habitat.
b. Zoning: Zoning designations for the CIP projects vary and include Limited-Control (project
BR), Open Space, Planned Community (project DFA), Residential, and public right of way.
c. Some CIP projects are or may be partially or wholly in the Coastal Zone. The Coastal land use
designation and zone are the same as the general plan and zoning above.
d. Specific or Master Plan: A few of the projects are or may be in master or specific plans, such
as the Village and Barrio Master Plan (project BasinA_6628), Aviara Master Plan (Project DFA),
and Sunny Creek Specific Plan (project BR). Given that DMP update proposes generally in-
ground improvements, these documents should have little bearing.
2. Permit requirements will vary depending on project specifics, such as location (e.g., Coastal Zone,
floodplain) and presence of habitat. Permits that may be required include a coastal development
permit, habitat management plan permit, hillside development permit, and special use permit
(floodplain). For projects BasinB_2500 and BasinA_1700, a coastal development permit issued by the
Coastal Commission may be necessary.
3. Specific determinations of applicable land use and zoning designations as well as permitting
requirements can be made upon submittal of plans for each project.
4. The following are comments on the draft DMP:
General
a. Table 2-1: More recent files for some data presented here, such as land use and parcels, are
available. The city's GIS division should be able to assist with that. Also, it may be helpful to
include a data file for City Council districts.
b. Table 2-6: Some of the terms are not readily obvious, such as "other transportation and
maintenance." It might be helpful to define some of them. Also, it would help to explain why
there is 0% area of vacant and undeveloped land and so little "water" area when Carlsbad
has three lagoons. If water is categorized as part of open space it would be helpful to clarify.
c. Figure 3-1: Selecting a different color coding for drainage basins B or C would help as these
basins are difficult to distinguish.
d. Page 13: The second full sentence in the first paragraph is incomplete.
Project text descriptions
e. Global comment: Please clarify if projects BJ-1, BL-Land BR would be analyzed as part of the
environmental review of the College Blvd. extension and if these projects or portions of them
would be permitted and constructed only with the extension. Without the street extension,
it would seem construction of the three projects would be unlikely or would require
modification from how they are currently presented in the draft DMP. Furthermore, if
project construction were to proceed independently, it would seem the street extension
would itself be a constraint or require project modification.
f. Section 5.1.3 BasinA_ 410, project considerations:
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i. This project could have wetlands/habitat impacts as it appears to impact basins on
either side of Monroe St. where it intersects Jefferson St.
ii. An additional constraint to identify is cultural resources, which are likely here
because of proximity to the lagoon.
g. Section 5.1.4 BasinA_1700 (Marron and Jefferson Multi-benefit Basin) project
considerations:
i. The intersection of Jefferson and Marron (all sides) as well as all of Buena Vista
Lagoon are in the jurisdiction of the Coastal Commission. In addition to city required
permits, it will be necessary to obtain a permit from the Coastal Commission if it so
determines necessary.
ii. Besides being potentially subject to Coastal Commission permitting, improvements
proposed at the northwest corner of Marron Rd. and Jefferson St. (APN 156-301-03)
are on state-owned property and within hardline preserve. As part of plan
preparation for this CIP project, submittal of an Early Assessment should be
considered to evaluate permitting and environmental review requirements.
iii. An additional constraint is cultural resources, which are possible because of
proximity to the lagoon.
iv. Under "right of way requirements," it notes the project is within the right of way.
Isn't work potentially occurring on state land?
g. Section 5.2.1 BJ-1 (Rancho Carlsbad Detention Basin) project considerations:
i. Under existing location and facility, the site is described as "vacant with minimal
vegetation." The site includes a RV storage yard, community garden, an access road,
eucalyptus trees and native habitat. It is also bisected by a creek. Please correct as
necessary.
ii. Additional constraints to identify include the existing improvements and site
features noted above as well as cultural resources. If the entire property were
developed as a detention basin, it appears native habitat would be removed.
iii. Project improvements west of the College Blvd. intersection encroach into the
floodplain. A special use permit to allow development in the floodplain may be
required pursuant to CMC Chapter 21.110.
• iv. The BJ-1 site (APN 168-050-36) is designated for high density residential and open
space (R-30/OS). The site was so designated by the City Council as part of the 2015
General Plan Update. Below is a map of the site and its land use designations. The
area designated OS is approximately four acres.
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The city's adopted Housing Element sites inventory identifies the site as providing, if
developed, 155 units of lower income housing. These units help the city demonstrate
to the state compliance with state housing law, including the Regional Housing
Needs Assessment. RHNA is the estimate of housing units needed to accommodate
projected growth through 2029 for all income groups; most units needed are in the
lower income category.
Approval of the Capital Improvement Program requires the City Council to make a
finding of General Plan consistency. It is likely Project BJ-1 would be found
inconsistent with the General Plan based on land use and the site's inclusion in the
Housing Element sites inventory. Removal of the site from the inventory to enable
BJ-l's development would require identification of another property that could
accommodate the 155 lower income units lost. State law (SB 166 (2017) and SB 330
(2019)) prevent localities from decreasing the housing capacity of any site if such a
decrease would preclude the jurisdiction from meeting its RHNA housing target. If
such a decrease occurs, the city must either (1) identify, and rezone if necessary, an
adequate substitute site or (2) demonstrate that the land inventory already contains
an adequate substitute site. This substitute site would need to meet specific
requirements and be designated for high density residential. Sites at this designation
are often the most challenging to find.
Detention basin development, since it apparently would impact the entire site, may
also trigger inconsistency with the type of open space (OS) identified on the property
by the General Plan. The Open Space and Conservation Element identifies the BJ-1
site as "Category 4" open space, defined as:
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• Category 4: Open Space for Aesthetic, Cultural and Educational Purposes
(lands with scenic, historical and cultural value; land use buffers; open
space that marks entries to the city frori1 surrounding communities and
to major developments and ne1ghborhoods within the city; greenbelts
providing separation from surrounding communities; and museums,
arboreta, zoos, and botanical gardens)
Furthermore, the Habitat Management Plan designates the entire site as a
"standards area," or an area of open space to be planned in accordance with the
Habitat Management Plan. It is likely this designation applies to the portion of
property already identified as Open Space by the General Plan. Development of the
Open Space designated area with the detention basin may preclude the city's habitat
preservation objectives.
Should your department wish to pursue development of project BJ-1, filing of an
Early Assessment is strongly recommended.
h. Section 5.2.2 BL-L, project considerations:
i. Another potential constraint is cultural resources due to the project's proximity to
the creek.
i. This project is in a floodplain, and a special use permit to allow development in the
floodplain may be required pursuant to CMC Chapter 21.110.
j. Section 5.2.3 BR, project considerations:
i. Another potential constraint is cultural resources due to the project's proximity to
the creek.
ii. This project is in a floodplain, and a special use permit to allow development in the
floodplain may be required pursuant to CMC Chapter 21.110.
j. Section 5.2.4 Basin 8_2500, project considerations:
i. The project is within the Agua Hedionda segment of the city's Local Coastal Program,
a segment in which the city does not have permitting authority. Accordingly, the
Commission determines whether a coastal development permit is required. If a
coastal development permit is required, it would be necessary to obtain it from the
commission after first obtaining any other required permits from the city.
Appendix A: Project Fact Sheets
a. Global comment: Please identify what the heavy dashed black line represents. The line's
purpose becomes confusing for some projects like BJ-1 where project boundaries are
uncertain.
b. Project BA_1700: Project description notes a retrofit of approximately 1.5 acres to
increase storage and conveyance. The text description of the project, however (page 25),
notes the basin bottom will increase to 1.7 acres. Please correct as necessary.
c. Project BJ-1:
i. Graphically, it appears two detention basins are proposed that encompass only portions
of the project parcel. However, the proposed detention basin size stated in the project
description is 11.7 acres, which is the approximate size of the entire parcel. Please correct
as necessary.
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ii. Per Section 5.2.1, the triple RCB culvert is 360-feet, not 200 linear feet, long.
Appendix D: Environmental Assessment (Addendum)
a. Overall, staff believes use of an Addendum is appropriate for this project.
b. Global comment: Project components in the Coastal Zone should be reviewed for
consistency with the 2019 Local Coastal Program (LCP), available at:
https://www.carlsbadca.gov/home/showpublisheddocument/236/63742597408953000
Q.
In 2021, the City Council approved an update to the LCP. The update is still considered
draft since it also requires Coastal Commission approval, which may occur next year.
Depending on the timing of the draft DMP, it may be necessary to show compliance with
the Coastal Commission-approved LCP instead. For now, the LCP update as approved by
City Council is available at 637854622120370000 (carlsbadca.gov).
c. Table B:
i. Project DFA (Batiquitos Lagoon Stormwater Treatment System): What would this
treatment system be like in the range of project types identified in Section 3.3.2
of the 2008 DMP Update EIR (pages 3-11 to 3-12)?
d. Section 3.1, Findings: The second listing of "noise" in the sentence describing less than
significant impacts should be deleted as noise is already identified as a significant but
mitigable impact.
e. Table E: The name of Project BL-L should reference College Blvd., not Carlsbad Blvd.
f. Table F: It would be helpful if an "as of" date(s) for the attainment status of the criteria
pollutants were provided.
g. Section 3.6: As level of service is no longer the metric used to evaluate impacts associated
with transportation as when the 2008 DMP Update EIR was certified, it is probably
appropriate to delete discussion throughout this section that regards level of service
compliance and perhaps revise the conclusion (Section 3.6.4) to be more VMT-centric.
For this reason, deletion of the following paragraph in Section 3.6.3 is recommended:
The proposed project is not anticipated to result in any level of service (LOS) or operational deficiencies
to the surrounding circulation system based on the project description, location, and nominal trip
generation for temporary construction and typical operations. Therefore, the proposed project would
not conflict with any congestion management program, standards, or travel demand measures for roads
or highways and no mitigation is required.
h. Section 3.7.2.1: The second paragraph explains the 2008 DMP Update EIR contained no
project consistency analysis with applicable air quality plans. It would be helpful if the
Addendum explained why.
i. Table L: The checkmarks may be reversed as text indicates the one sensitive animal
species was recorded in Basin C only.
j. Section 3.13.2: In the last paragraph on page 3-46, the following is an incomplete
sentence: "Determinations of significance and eligibility for listing in the CRHR/or NRHP
typically based on site testing, including intensive survey and excavation."
k. Section 3.13.3: AB 52 consultation is not required for an Addendum.
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Land Development Engineering:
Land Development Engineering staff has completed a review of the above-referenced project for
application completeness and engineering issues of concern. All items needed for engineering review
are provided for determining the application as complete. Engineering issues which need to be resolved
or adequately addressed prior to staff making a determination on the proposed project are as follows:
1. On page 1, third paragraph, 2nd sentence, change "will" to was.
2. On page 2, Drainage Master Plan should reference new City of Carlsbad Engineering Standards,
2022 edition.
3. Were any conversions made to adjust datum, since LiDar generated contour GIS data is in
NAVD88, whereas storm drain infrastructure and invert elevations are in NGVD29 per City of
Carlsbad Engineering Standards?
4. Subcatchment Delineation and Flow Path Exhibit on page 15, does not match the exhibits
provided in Appendix A for line color and weight as well as legend description, be consistent
between exhibits.
5. Results to existing condition analysis through link on page 16 requires username and log in
credentials from Rick Engineering, this should be available to public at the very least should be
downloaded by City staff and reviewed for consistency.
6. Recommend in section 5.0 a discussion of which projects from DMP2008 were omitted (and not
constructed) from new DMP and clarify why.
7. Provide PCSWMM excerpts and data file summaries associated with each CIP project proposed.
8. Recommend changing the verbiage of "hot spot" for reference to BasinA_ 410 and Basin A_1700
throughout the master plan document to documented significant surface flooding location or
something similar.
9. In Appendix A on the project descriptions, update so that the project description does not cut
off on the page, typical for all exhibits.
10. Recommend on all exhibit's re-label "delineations" in the legend to be sub-catchment boundary
or similar language.
11. Project AAA-There appears to be 3~1811 RCP laterals at the intersection of Jefferson and Laguna.
It is assumed, but please clarify that the lateral that restricts flow and requires re-alignment to
the 36" storm drain, is the lateral on the NE corner only.
12. Project BJ-1-Review the study completed by Chang Consultants for Engineering Analyses of
Detention Basin BJ, dated 10/4/2005. Clarify if the 84" RCP Storm Drain that has been
constructed per City of Carlsbad Dwg. 433-6 was modeled in the PCSWMM analyses. Please
review and determine if this 12-million-dollar infrastructure is still required based on this
information.
13. On the Exhibit for Basin BJ-1 in Appendix A, update the yellow linework on the plan to show the
6'x3' box culvert constructed under future College Boulevard extension as shown in the project
description.
14. Provide attachment to an overall drainage basin map for the City of Carlsbad, with sub-areas for
the entire network not just to the CIP project excerpt. The drainage basin map should match
the input for the PCSWMM analysis.
15. Provide updated GIS maps similar to the infrastructure maps provided in Appendix D of the 2008
DMP showing streets, storm drain facilities and sizes, highlighting the new CIP project proposed
or alternatively include this information on the overall drainage basin map in Item #14.
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16. In Appendix C, the PCSWMM analysis utilizes the sub-catchment parameters in the 2019 County
of San Diego Manual, utilize City of City of Carlsbad BM P Manual 2021.
17. Section 1.3 of draft EIR, add City contact information
Public Works -Utilities:
Utilities notes its comments on the draft DMP update were provided to you directly.
City Attorney:
No comments were received.
Finance:
No comments were received.
All necessary application forms and submittal requirements are available at the Planning counter located
in the Faraday Building at 1635 Faraday Avenue or online at http://www.carlsbadca.gov. You may also
access the General Plan Land Use Element and the Zoning Ordinance on line at the website address shown;
select Department Listing; select Planning Home Page. Please review all information carefully before
submitting.
If you would like to schedule a meeting to discuss this letter with the commenting departments, please
contact Scott Donnell at the number below. You may also contact each department individually as
follows:
• Planning Division comments: Scott Donnell, Senior Planner, at (442) 339-2618
• Land Development Engineering comments: Nichole Fine, Associate Engineer, at (442) 339-2744
• Public Works Utilities: Danny Zimny, Senior Engineer, at (442) 339-2551
SD:JC
c: Eric Lardy, City Planner
Nichole Fine, Associate Engineer
Danny Zimny, Senior Engineer
Engineering Manager
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