HomeMy WebLinkAboutPRE 2025-0039; EL FUERTE HOMES; Admin Decision Letter
Community Development Department
Planning Division 1635 Faraday Avenue Carlsbad, CA 92008 442-339-2600
August 28, 2025
Kirk Moeller
Kirk Moeller Architects
2888 Loker Avenue E, #317
Carlsbad, CA 92020
SUBJECT: PRE 2025-0039 (DEV2025-0048) – EL FUERTE HOMES
APN: 215-370-30, -31, -32
Thank you for submitting a preliminary review for the construction of 12 detached condominium units on
three properties totaling 1.42-acres, on the south side of El Fuerte, and north of the intersection of El
Fuerte Street and Cacatua Street . The proposed density is 8.45 dwelling units per acre (please see
Comment No. 3 below for lot size and density discussion). Retaining walls up to 12 feet are proposed to
develop the site. Access to Units 1-4 and 7-12 is proposed to be provided by a 24-foot-wide driveway off
El Fuerte Street and access to Units 5 and 6 is proposed by a second 24-foot-wide driveway off El Fuerte
Street.
In response to your application, the Planning Division has prepared this comment letter. Please note that
the purpose of a preliminary review is to provide you with direction and comments on the overall concept
of your project. This preliminary review 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:
1. General Plan and zoning designations for the property are as follows:
a. General Plan: R-4, Residential 0-4 du/ac for Parcels 1-3
b. Zoning: R-1, One- Family Residential for Parcels 1-3
*Please see discussion in Comment No. 3 below for additional information regarding Parcel 4
2. The project requires the following permits, which require approval by the Planning Commission .
a. Tentative Tract Map (CT) for the development of 12 detached air-space condominiums
b. Planned Development Permit (PD) for the development of 12 detached airspace
condominiums
c. Hillside Development Permit (HDP) for development on a site that has slopes with a gradient
of 15% or more and an elevation differential greater than 15 feet
C cityof
Carlsbad
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d. Habitat Management Plan Permit (HMP) for the removal of any sensitive upland habitat and
any indirect impacts to the adjacent protected open space, which is designated as “Proposed
Hardline Area” in the city’s Habitat Management Plan.
e. Variance (V) (or density bonus waiver, if applicable) for the construction of walls greater than
42 inches and/or 6 feet in height (varies based on location)
3. Proposed Density. The city’s two-foot topographical contour map indicates an approximate grade
change of 50 feet across Parcels 1-3 with slopes potentially exceeding 40% around the rear
perimeter of the site. Pursuant to Carlsbad Municipal Code (CMC) Section 21.53.230, the city uses
net acreage to determine density/allowable number of units. Specifically, natural slopes with an
inclination greater than 40% cannot be developed (i.e. area required to be excluded from density
calculation) and no more than 50% of the portion of a site containing 25% to 40% slopes may be
utilized for calculating allowable residential density. Please see screenshot of the site’s topography
and slopes and link to CMC Section 21.53.230 below for additional information.
https://ecode360.com/44013119
65/Jo. 6549
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In addition, please be advised the density analysis below is based on a total site acreage of 1.42 and
comprises Parcels 1-3 of Parcel Map No. 21931 (MS 2018-0010), recorded on May 12, 2022.
It also assumes the property is flat. Given the presence of steep slopes on the site, please be aware
that the maximum number of units that can be constructed on the site will likely be reduced.
However, if a density bonus is requested, this comment will not apply.
Further, Parcel 4 of the same recorded map is designated Open Space (OS) in the city’s General Plan
and is zoned OS. The OS designation does not have an assigned density. Therefore, it cannot be
developed, and the area of the lot cannot be included in the density calculation. Please see
screenshot below for reference.
The lot sizes of Parcels 1-3 of Parcel Map No. 21931 are as follows:
Parcel 1: 0.584 acres
Parcel 2: 0.492 acres
Parcel 3: 0.345 acres
Total area: 1.42 acres
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The maximum density for the R-4 General Plan Land Use designation is 4 dwelling units per acre.
For the subject site, and exclusive of a density bonus, a total of 5 units (on a relatively flat site) could
be constructed on the 1.42-acre site (4 x 1.42 = 5.68, rounds down to 5 units per CMC Section
21.53.230, Table E). The conceptual proposal to construct 12 residential units exceeds the
maximum allowable number of units by 7 units. To construct 12 residential units, a density bonus
is required.
4. Density Bonus. State density bonus law (SDBL) allows a developer to increase density allowed on a
property above the maximum allowed in the General Plan. In exchange for the increase in density,
a certain percentage of units are required to be restricted to lower income households. Further,
SDBL utilizes gross instead of net acreage to determine the allowable number of units and, pursuant
to Government Code Section 65915(c)(5), all density calculations resulting in fractional units are
required to be rounded up to the next whole number.
As discussed in Comment No. 3 above, exclusive of a density bonus, the base maximum number of
units that can be constructed for the subject property is 5 units. The concept project includes 12
units. Pursuant to the calculation provided by the Housing and Homeless Services Department
below, the maximum number of units that could be constructed pursuant to SDBL is 12 units.
Please refer to the links to Informational Bulletin No. 112, Density Bonus, and Form P-1(H) below
for additional information regarding the number of lower income units required as well as the
process and findings for incentives/concessions and waivers.
IB 112: https://www.carlsbadca.gov/home/showpublisheddocument/8169/638600078695630000
P-1(H), Density Bonus Report:
https://www.carlsbadca.gov/home/showpublisheddocument/16609/638561251975170000
5. Inclusionary Housing. Please see comments from the Housing & Homeless Services Department for
information regarding the requirements.
6. Hillside Development. The project will be subject to the provisions of the Hillside Development
Ordinance, CMC Chapter 21.95. To assist with determining the allowable number of units pursuant
to CMC Section 21.53.230, please submit a slope analysis consistent with CMC Section 21.95.130,
Hillside Mapping Procedures, with the application. Please see link to CMC Chapter 21.95 below for
reference.
https://ecode360.com/44014187
Due to the preliminary nature of the submittal, compliance with the requirements of the Hillside
Development Regulations cannot be verified. However, please be aware of the following standards
in CMC Chapter 21.95:
a. CMC Section 21.95.130, Hillside mapping procedures- guidance/requirements for slope
analysis and slope profiles
b. CMC Section 21.95.140, Hillside development and design standards- development of
natural slopes, volume of grading, slope height, contour grading
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7. Retaining walls. Pursuant to CMC Section 21.46.130, fences and walls cannot exceed 42 inches in
the front yard setback and 6 feet for any area outside the front yard setback. As currently designed,
retaining walls exceeding 6 feet in height are proposed in the front yard setback and around the
rear perimeter of the site. Please redesign the project to comply with the height limitations or
submit a Variance to exceed the allowable height. Alternatively, if a density bonus is pursued and if
the requesting findings can be made, you may consider requesting a waiver to this standard.
However, please make every effort to reduce the height of the retaining wall facing El Fuerte Street
since it is retaining fill and impacts public views from the street. In addition, please ensure that there
is a minimum 15-foot-wide planter in front of the wall so landscape can be installed to soften the
appearance of the wall.
8. Compliance with Habitat Management Plan.
a. Parcels 1-3 of Map No. 21931. Parcels 1-3 are adjacent to a “Proposed Hardline Area” (i.e.,
Parcel 4 Parcel Map No. 21931) of the city’s HMP. The vegetation includes Diegan coastal
sage scrub, a native sensitive upland habitat. To analyze the project’s compliance with the
HMP, please submit a Biological Resources Report prepared by a registered professional.
Please note, any sensitive vegetation required to be removed because of the required fire
buffer shall be counted as an impact. In addition, the project is required to comply with the
Adjacency Standards of the HMP (see page F-16). Please see screenshot and links below for
additional information.
HMP:
https://www.carlsbadca.gov/home/showpublisheddocument/224/637446616709600000
Guide to Preparing Biological Resources Report:
https://www.carlsbadca.gov/home/showpublisheddocument/1604/63781905050043
0000
b. Parcel 4 of Map No. 21931-Status of Restrictive Covenant. Parcel 4 is in a “Proposed
Hardline Area” of the HMP and requires the recordation of a restrictive covenant to
ensure it remains protected open space in perpetuity. As part of the restrictive covenant,
a preserve management plan, management agreement with an approved land manager
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and endowment are required to fund and manage the open space in perpetuity. Please
be advised, the application for the proposed development project will not be accepted
until the restrictive covenant process is completed, including fully funding the
endowment. Please see comments from the city’s HMP manager, Rosanne Humphrey,
below for additional information.
9. Noise Analysis. Please submit a noise analysis analyzing the project’s consistency with the General
Plan and Noise Guidelines Manual. The Noise Guidelines Manual can be found online at:
https://www.carlsbadca.gov/home/showpublisheddocument/238/637425974092370000
10. Cultural Resources Assessment. Please submit a cultural and paleontological resources assessment
prepared by a qualified professional. The study shall comply with the city’s Tribal, Cultural and
Paleontological Resources Guidelines. Please be advised the Guidelines require a Luiseno Native
American monitor to be present for any field survey or work conducted by an archaeologist. Please
see the link below for additional information.
https://www.carlsbadca.gov/home/showpublisheddocument/254/637425976516870000
11. Very High Fire Hazard Severity Zone. The project is within the Very High Fire Hazard Severity Zone
(VHFHSZ). Please see Fire comments below for more information and discussion regarding the
requirement for 100 feet of defensible space . Since the project site is adjacent to protected open
space, no offsite clearance of habitat can be supported, and the 100-foot buffer shall be
accommodated onsite.
12. Planned Development Ordinance Setbacks. Pursuant to CMC Section 21.45.060, Table C (front yard
setback) and CMC Section 21.45.080, Table E (side and rear yard setbacks), the condominium
project is subject to the following setbacks:
Front: 30 feet off El Fuerte (secondary arterial). In addition, the following standards apply:
• 50% of the required setback shall be fully landscaped
• A minimum of one, 24-inch box tree shall be planted for every 30 lineal feet of street
frontage
• The setback shall be commonly owned and maintained
• Walls greater than 42 inches in height shall not be allowed in required landscaped portion
unless it is a required noise wall
Side: 10 feet (10% the width of the lot, not to exceed 10 feet)
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Rear: 20 feet (twice the side yard setback)
13. Planned Development/Condominiums. Detached single-family dwellings designed as airspace
condominiums require the approval of a Planned Development Permit pursuant to CMC Chapter
21.45, Planned Development Ordinance. Specifically, the proposed condominium project shall
comply with Table C, General Development Standards, and Table E, Condominium Projects. Please
see comments below for a Planned Development compliance analysis and staff recommendations.
Planned Development Ordinance. Pursuant to CMC Chapter 21.45, Tables C and E, please be aware
of the following requirements. Please be advised that the comments are not all-inclusive. Please
refer to CMC Chapter 21.45 to ensure the project complies.
Table C, General Development Standards
a. Drive aisles. Unless otherwise specified/required by the Fire Department, the minimum drive
aisle width between the garages shall be 20 feet and the minimum back-up space required
between garages is 24 feet. Please ensure there is a five-foot deep kicker space at the end of
each drive aisle for vehicles back into when exiting the garage. In addition, the drive aisle
shall be enhanced with decorative pavement.
b. Visitor parking. 0.30 spaces per unit. Please ensure the parking spaces are located outside
the drive aisle width and dimensioned so staff can verify compliance with the dimension
standards.
c. Compact parking: Up to 25% of the visitor parking (or spaces) can be compact spaces. Please
confirm how many compact spaces are proposed. The minimum dimension for compact stalls
is 8 feet by 15 feet. No overhang is permitted into any required setback or sidewalks less than
6 feet in width.
d. Screening of parking. Open parking areas shall be screened from adjacent residences and
public ROW by either a wall or landscaping or combination thereof. Please ensure the
landscape plan submitted with the project addresses this requirement.
e. Community recreational space. 200 square feet per unit. Community recreational space shall
be provided for 11 or more units. Preliminarily, community recreational space will not be
required since the maximum number of units that can be granted with a 100% density bonus
is 10 units.
f. Storage space. 480 cubic feet per unit. If two-car garages are proposed with a minimum
dimension of 20’ x 20’, the requirement is satisfied. Please ensure the width and depth of the
garages are dimensioned and do not include the walls of the garage.
Table E, Condominium Projects
a. Lot coverage. 60% of the developable acreage.
b. Building height. Same as required in R-1 zone, which has a maximum allowable height of 35
feet and two stories per CMC Section 21.10.050, no building shall exceed a height of 30 feet
and two stories if a minimum 3:12 roof pitch is provided or 24 feet if less than a 3:12 roof
pitch is provided.
c. Setbacks. Please see Comment No. 12 above.
d. Building Separation. The minimum separation between buildings is 10 feet. As currently
designed the project does not comply.
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e. Resident parking. Two covered spaces per unit; two-car garages shall have a minimum
dimension of 20’ x 20’. Additional space outside of this area shall be included for trash
receptacles and a water heater.
f. Private recreational space. Please see Table E.7 in CMC Section 21.45.080 for additional
details.
• One-family dwellings: 400 square feet per unit
• If provided at ground level, the minimum dimension is 15 feet x 15 feet; if provided above
ground level, the minimum dimension is 6 feet x 6 feet, with a minimum area of 60 square
feet ,
• Please ensure the floor plans and site plan include dimensions for the
decks/balconies/porches.
14. Climate Action Plan (CAP). New requirements related to the city’s goals to reduce greenhouse
gas (GHG) emissions will likely impact development requirements of this project. A formal
application submittal will need to include a completed CAP Checklist (Form P-30) to determine
what requirements will apply to the project. New GHG reduction requirements are related to
energy efficiency, photovoltaic, electric vehicle charging, water heating and traffic demand
management requirements, as set forth in the California Green Building Standards Code and in
CMC Chapters 18.21, 18.30 and 18.51 which are available on the city’s website at the following
address:
http://www.qcode.us/codes/carlsbad/view.php?topic=18&frames=on
To the extent that new GHG reduction requirements are in effect at the time of application for
grading or building permits, the project will be required to comply with the effective requirements
even if different than what is proposed in the project’s planning approvals. GHG reduction
requirements may impact, but are not limited to, site design and local building code
requirements. If incorporating new GHG reduction requirements results in substantial
modifications to the project after planning approvals are obtained, then prior to issuance of
grading or building permits, the applicant may be required to submit and receive approval of a
Consistency Determination or an Amendment application for the project through the Planning
Division.
15. Stakeholder Outreach. Since Planning Commission approval is required, the project will be subject
to City Council Policy Statement No. 84, Development Project Public Involvement. A notice sign is
required to be posted onsite by the applicant and an early public notice is required to be prepared
by the applicant and mailed to all owners located within a 600-foot radius of the property. In
addition, enhanced stakeholder outreach and a follow-up summary report are required. Please
see attached Policy for details.
https://www.carlsbadca.gov/home/showpublisheddocument/19411/638693435056900000
All necessary application forms, submittal requirements, and fee information are available at the Planning
counter located in the Faraday Building at 1635 Faraday Avenue or online at
https://www.carlsbadca.gov/departments/community-development/permits-applications-forms
you may also access the General Plan Land Use Element and the Zoning Ordinance online at the website
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address shown; select Department Listing; select Planning Home Page. Please review all information
carefully before submitting.
Land Development Engineering:
Land Development Engineering Division staff has completed a preliminary review of the above-referenced
project. Prior to formal application for the project permit submittal, the following items must be
adequately resolved/addressed, unless otherwise noted:
1. Contact Nick Gorman in the Transportation Division at Nick.Gorman@carlsbadca.gov, a division
of the Public Works Department, to determine if a Scoping Agreement is required. Scoping
Agreements are used to determine if a Local Mobility Analysis (LMA) is required and the scope of
analysis. If an LMA is deemed necessary, first, work with Transportation Division staff to obtain
an approved scoping agreement. After the scoping agreement has been approved, submit the
approved Scoping Agreement as an appendix within the LMA that is to be prepared by the most
recent Transportation Impact Analysis Guidelines.
2. After the scoping agreement has been approved or deemed not necessary by the Transportation
Division, submit a completed Transportation Analysis Need Statement Form P-42 to Land
Development Engineering at LandDev@carlsbadca.gov prior to discretionary application
submittal. If an LMA has been deemed not necessary by the Transportation Division, please
provide correspondence from the Transportation Division indicating one is not required.
3. Depending on the CEQA determination, which is determined after the application for
discretionary permits is submitted, a Vehicle Miles Traveled (VMT) analysis may be required per
the Vehicles Miles Traveled Analysis Guidelines available
at https://www.carlsbadca.gov/home/showdocument?id=312.
4. Complete a Stormwater Standards Questionnaire Form E-34. This questionnaire will guide you
and the city in determining what type of reports and storm water mitigation must be completed
to satisfy state and City storm water quality requirements. The questionnaire is located on the
City of Carlsbad website.
5. Based on a preliminary analysis it appears that this project is a Priority Development Project (PDP).
All impervious surfaces being created or replaced (onsite and offsite) shall be included for
treatment. Submit a Storm Water Quality Management Plan. The project site appears to be
subject to hydromodification requirements but void of any Critical Coarse Sediment. Review the
Hydromodification Exemption Map and Potential Critical Coarse Sediment Yield Area Map on the
City website to confirm if this criterion applies to your project. The post construction stormwater
treatment BMPs shall be shown on a conceptual grading plan and drainage plan with the
discretionary application.
6. Provide a Preliminary Title Report (current within the last six (6) months).
7. Annotate and delineate all existing easements and encumbrances listed in the Preliminary Title
Report on the site plan. If any vacations or quitclaims are planned with this development
annotate on the site plan. No structures shall encroach into easements without the easement
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holder’s permission. The retaining walls proposed in the existing public sewer easement and
utility drainage easement will not be supported by the city. Please redesign the plan so that the
walls are located outside these easements.
8. A Preliminary Hydrology Study including map and calculations is required to demonstrate
capacity/sizing of proposed and existing storm drain infrastructure. Show 100-year storm
hydrologic calculations before and after development for each drainage basin.
9. A preliminary geotechnical report is required to evaluate the feasibility of the project. Guidelines
for preliminary geotechnical studies are available on the City of Carlsbad Engineering website.
10. Per CMC15.16.060 this project will require a grading permit and grading plan. Indicate the
earthwork quantities (cut, fill, import, export, remedial) proposed for the project in cubic yards.
11. A separate improvement plan for work within the right-of-way is required for this project.
12. This project shall utilize City of Carlsbad Survey Control Network established on Record of Survey
Map 17271, NAD83, Zone VI, 1991.35 Epoch for horizontal control and NGVD 29 datum for vertical
control per City of Carlsbad Engineering Standards.
13. Delineate and annotate the limits of grading.
14. Delineate and annotate approximate topographic contours for the existing and proposed
condition. Provide 1-foot contours for slopes less than 5%; 2’ intervals for slopes between 5% and
10%, and 5’ intervals for slopes over 10%. Extend contours a minimum 25 feet beyond the project
boundary.
15. On the site plan, show and identify all existing surface improvements screened back (curb, gutter,
sidewalk, paving, manholes, inlets, streetlights, adjacent driveways, vaults, transformers, etc.) at
the project site, project frontage and within 25 feet of the boundary.
16. Provide spot elevations at the corners of each pad in the proposed condition. Include finish pad
and floor elevations.
17. Provide the method of draining each lot. Unless otherwise specified by a geotechnical engineer,
method of drainage shall comply with California Building Code (latest version) section 1804.4.
18. Show top of wall and bottom of wall elevations, including at the highest and lowest points, on all
retaining walls that will be utilized on the project site. Indicate maximum height of retaining wall
measured from bottom of footing to top of wall and maximum height measured from finish
surface to top of wall. Note that the height of the wall between units 1 through 4 is labeled 12
feet high. Consult with the planner as this height at this location will likely not be supported.
19. Provide a cross section to show the existing and proposed ground, the proposed wall, the footing
and any remedial excavation along the front property line where the highest retaining wall height
is located, likely between Unit 1 and Unit 12 near the water quality basin.
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20. Provide D-75, Type ‘B’ brow ditch behind and at the top of the sloping backfill retaining wall. Show
how storm water from the ditch will be conveyed to the storm drains on site.
21. The trees along the El Fuerte Street frontage are included in the city’s street tree inventory.
Indicate on the site plan if any trees are to remain or be removed. Proposed removal of street
trees will require approval per Section 11.12.090 of the Carlsbad Municipal Code. Also, the
previous development had processed requests for tree removals through the parks and recreation
department. Coordinate with the Parks and Recreation Department for additional information
and status of that request and if approved for removal, whether such approval has an expiration
date and/or can be transferred to a new property owner. If removal of the trees is not currently
approved or can no longer be obtained, the required new sidewalk may need to be routed around
the trees further from the curb to be preserved, leading to additional grading and the need for a
public pedestrian easement dedication.
22. Show proposed lot lines on the site plan and the removal of any lot lines. This project appears to
be proposing a subdivision to create one common residential lot with 12 condominium units. A
tentative map is required if this is the case.
23. Show location and dimensions of all accessways and pathways as required for compliance with
Title 24- State Accessibility Requirements.
24. Provide typical street cross sections for existing frontage streets and proposed streets. Plot
existing right-of-way width and existing improvements and any proposed improvements and
dedications.
25. Driveways that exceed more than 150’ length shall have a turnaround designed for a 3-point turn
of a passenger vehicle. Additionally, the applicant shall coordinate with the fire department to
ensure width and grade of driveway meets fire department requirements.
26. Relocate the driveway serving unit 6 to connect with the proposed common private driveway
rather than El Fuerte Street, a neighborhood connector street. The number of driveways fronting
a neighborhood connector street shall be minimized where feasible per Table B in Volume 1 of
the Carlsbad Engineering Standards.
27. Show truck turning radii if a trash truck or fire truck is expected to use the driveway. Plot turning
radii per Caltrans figure 404.5F. Clarify whether trash pickup will be for individual bins at curbside
or larger community bins. If community bins, ensure the trash enclosure design is consistent with
the City of Carlsbad and Republic Services standards, see building department Form B-76.
28. Show all existing and proposed utilities and callout size for: water, sewer, storm drain,
underground dry utilities, streetlights, etc. in El Fuerte Street affecting the property.
29. All transformers and electrical facilities solely serving this project site shall be located on site and
outside of the public right-of-way.
30. Obtain a letter from SDG&E confirming their approval of the proposed transformer location and
stating that no additional off-site facilities will be necessary for this project. Please also include
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all existing and proposed dry utilities and the services that will supply power to the proposed
transformer.
31. Provide multiple cross-sections of the site to demonstrate differences in grade from adjacent
properties, existing and proposed grades on-site, fences and location of structures on-site and on
adjacent properties.
32. Frontage improvements are required per Carlsbad Municipal Code Section 18.40 and 20.16.040.
Standards for public improvements are available in these code sections and the Carlsbad
Engineering Standards available on the city web site. Public street frontage improvements shall
include new sidewalk, driveway approach, streetlight, new private water main and services and
sewer main and laterals to service the twelve units. See DWG 522-8, the approved improvement
plan for further reference. Construction of these improvements are currently under contract
between the city and the current property owner. Per the contract, the city has the right to
construct the improvements in the event the property owner refuses or fails to install the
improvements. If the property ownership changes, the contract may be transferred to the new
owner via processing of a novation agreement. Otherwise, the obligations of the contract remain
with the person who signed the agreement (current property owner).
DWG 522-8:
https://records.carlsbadca.gov/WebLink/DocView.aspx?id=6262688&dbid=0&repo=CityofCarlsb
ad
33. This project requires an encroachment agreement for any proposed private utilities or
nonstandard driveway finishes crossing the existing city utility and drainage easement.
34. A two to three inch AC grind and overlay is required between utility trench work on El Fuerte
Street.
35. Coordinate with Vallecitos Water District since the proposed development is located within their
district, property or easement. This project will require written approval from Vallecitos Water
District.
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36. Meet with the Fire Department to identify the necessary fire protection measures required for
this project (access, fire hydrants, sprinkler system, on-site circulation, emergency access, etc.)
37. Plot stopping sight distance at the driveway. El Fuerte Street is classified as a Neighborhood
Collector Street with a posted 30 mph speed limit and a stopping sight distance of 200 feet.
38. Address the comments on the attached redlined plan.
39. Please be advised that a more in-depth review of the proposed development will occur with the
discretionary permit application when a more complete design of the project is provided.
Public Works- Utilities:
1. Proposed project site is within the Vallecitos Water District (VWD) service area. All potable
water services and requirements shall be coordinated with and approved by VWD.
2. Provide sewer analysis based on current Engineering Standards (Volume 1 – Chapter 6) to
approximate sewer loading on public collection system based on project design.
3. Provide Civil Site Plan identifying existing public utilities in right of way and locating all existing
and proposed utility service connections along project frontage. See Attachment 1 with additional
comments.
Housing and Homeless Services:
Housing & Homeless Services staff have completed a review of the above-referenced Preliminary
Application for completeness and accuracy. The Housing & Homeless Services team has found that the
application needs to revisit site acreage and density bonus calculations so staff may review the project.
Additionally, the density bonus calculations are incorrect and need to be revised.
1) Total Units & Affordability – The project is subject to two affordability requirements. Those
requirements are summarized in the table and further described below.
A Acreage 1.42
B Max Density per Acre 4
C Base Density (A x B) 1.42 x 4 = 5.68 rounds up to 6 units
D Requested Bonus (50% x C) 50% x 6 Base
Units
E Total Allowable (C + D) Base + Bonus 9
F Required Affordable Units per GC
65915 (C x 15%)
6 x 15% = 0.9 rounds up to 1 very
low-income unit
G Required Affordable Units Per CMC
21.85 (6 x 12.5%)
6 x 12.5% = .75 units, rounds up to 1
very low-income unit
H Total Affordable Unit Count
(The higher of F or G)
1 very low-income unit
Additional 50% Density Bonus Stacking
I Additional 50% stacking requested 6 x 50% = 3 units I I
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(C x 50%)
J Total Units + Additional Bonus (E + I) 9 + 3 = 12 units
K Required Affordable Units per GC
65915 (C x 15%)
6 x 15% = 0.9 rounds up to 1
moderate-income unit
L Total Affordable Unit Count (H + K) 1 + 1 = 2 units; 1 very low-income
unit and one moderate-
income unit
Affordability
Requirement
Basis for
Requirement
Determination Required affordable units
Density
Bonus
Government Code
Section 65915
15% of base units
for primary bonus,
15% of base units
for secondary
bonus
One (1) very low-income unit
and one (1) moderate-income
unit
Applicant is providing one (1)
very low-income unit and must
provide one (1) additional
moderate-income unit to satisfy
this requirement
Inclusionary
Housing
Carlsbad Municipal
Code 21.85, City
Council Policy 57
12.5% of base units One (1) very low-income
inclusionary unit
Applicant is providing one (1)
very low-income unit to satisfy
this requirement
Affordable housing cost for the affordable units is determined by California Health and Safety
Code Section 50052.5.
2) Density Bonus: Applicant is applying for incentives, and waivers in accordance with density bonus
provisions found in Government Code §65915 and Carlsbad Municipal Code Chapter 21.86.
Applicant is providing one (1) very low-income unit, and must also provide one (1) moderate-
income unit to satisfy this requirement
Additionally, Density Bonus law requires that the affordable for-sale units must be provided in the
same tenure as market-rate units. This project is providing for-sale housing, therefore the
affordable units must also be for-sale.
3) Inclusionary: The project is also subject to Carlsbad Municipal Code 21.85. Because the project
proposes to provide the inclusionary unit at the very low-income level, the 12.5% affordability
requirement applies. The project has proposed 1 very low-income unit onsite which satisfies
satisfy Carlsbad Municipal Code Chapter 21.85. The applicant has asked if they may as an option,
purchase an Inclusionary Housing Credit, per City Council Policy 57, which is not necessary as the
Inclusionary Requirement is satisfied with the provision of one on-site very low-income unit.
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Other inclusionary housing requirements:
Per 21.85.040. D.…. Affordable units shall be provided in the same tenure as the market rate units,
consistent with California Civil Code 714.7.
Per 21.85.040. E. …. inclusionary ownership units shall remain affordable to subsequent income
eligible buyers pursuant to a resale restriction with a term of thirty years…
Per 21.85.040. G., internal and external design of affordable units shall be reasonably consistent
or compatible with the design of the total project development in terms of appearance, materials
and finished quality. Interior finishes and amenities may differ from those provided in the market-
rate units, but neither the workmanship nor the products may be of substandard or inferior
quality as determined by the city.
Per 21.85.040. H., bedroom count and unit sizes of affordable units to be commensurate with
market-rate units. Project is proposing 11, 3-bd units, and 1, 2-bd unit, which does not satisfy this
requirement. If all market rate units are 3-bd units, the affordable units must also be 3-bd unit.
Per 21.85.140. A., the development must execute an affordable housing agreement.
4) Affordable Unit Distribution - Applicant should be aware that State law (Health and Safety Code
Section 17929 (“AB 491”)) requires the affordable units to be distributed equitability throughout
the project.
Parks Department:
Any comments received from the Parks Department will be provided under separate cover.
Public Works- Traffic:
1. Please submit a Scoping Agreement pursuant to the latest city of Carlsbad Transportation Impact
Analysis Guidelines.
2. Project Trip Generation- provide average daily and peak hour traffic generated by the project. For
the proposed land use trip generation, please utilize SANDAGs Not-So-Brief Guide of Vehicular
Traffic Generation Rates.
Fire Prevention:
1. This property is mapped in the Very High Fire Hazard Severity Zone and is bound on the west and
south sides by vegetation, including habitat. Structures shall meet ignition-resistant construction
features and defensible space requirements in compliance with the California Building Code and
California Fire Code (or California Wildland-Urban Interface Code, if building plans are submitted
after Jan. 1, 2026).
a. Defensible space of 100 feet is required around all new structures, in accordance with the
requirements of CFC Chapter 49. The applicant shall develop a landscape plan/fuel
modification plan that meets the defensible space and vegetation management
requirements of California Fire Code (CFC Chapter 49).
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Page 16
2. Roadways must extend to within 150 feet of all portions of the exterior of the first floor of any
structure and must meet specified criteria for width, pavement characteristics, roadway gradient,
turning radius, etc.
a. Fire access roadways shall be a minimum of 24 feet in width and designed, constructed, and
maintained to support the imposed loads of Carlsbad fire apparatus with a total weight of
75,000 pounds. The surface shall be designed, constructed, and maintained to provide all-
weather driving capabilities. If fire access road will be constructed from an engineered
surface other than cement or asphalt (i.e., pavers), an AM&M for alternative engineered
surface shall be submitted to Fire & Life Safety Division for review and approval.
b. Hose pull maximum distance is 150 feet.
c. Fire apparatus access cannot be taken from El Fuerte. The drive aisle into the development
shall serve as the fire department access road and shall meet all requirements of the CFD
Fire Access and Water Supply Guideline, which is available on the city website.
d. Confirm that the turnaround shown on the plans is of adequate size for fire apparatus to
effectively turn around. Turnaround requirements can be found in the CFD Access and
Water Supply Guideline.
3. Fire Master Plan
a. To facilitate the review process, upon project submittal, please include a Fire Master Plan
for review. The plan shall include, at a minimum, the following elements:
i. Square footage, height/stories, construction type, occupancy type.
ii. Fire department access roads and dimensions, road surface material, weight capacity,
and access gates (if any).
iii. Hose-pull dimensions to all structures
iv. Hydrant locations. Hydrants shall be provided along the length of the fire access
roadway in the quantities and up to the maximum distances prescribed in CFC Table C
102.1.
4. Fire Flow Requirements
a. Submit completed P99F form to determine fire flow requirements, and to determine
number and location of required hydrants. Please note this must be completed prior to
submittal of a formal application for the city for the project. A completed, city-reviewed
P99F, shall accompany a formal project application to the Planning Division.
Habitat Management Plan:
HMP-Related Issues of Concern
***This project is located on the former El Fuerte View Project site. There are still outstanding
requirements for El Fuerte View project that have not been satisfied. The project application to develop
Lots 1-3 will not be accepted until the previous requirements have been met.
Once these items have been completed, the application should include a biology report, consistent with
the city’s Guidelines for Biological Studies (2022).
a) The project must demonstrate consistency with the Habitat Management Plan (HMP).
PRE 2025-0039 (DEV2025-0048) – EL FUERTE HOMES
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Page 17
b) The project site is in a very high fire hazard zone; therefore, the report must include a figure
showing the required Fuel Modification Zone located onsite, which will be counted as an impact.
An encroachment into Parcel 4 cannot be supported.
c) The biology report must address HMP Adjacency Standards since it is located adjacent to a habitat
preserve.
Status on the remaining requirements for El Fuerte View.
1. Restrictive Covenant:
• Signed by applicant and submitted to City Attorney’s Office for signature and routing to city
clerk for recordation.
2. Installation of fencing and signage for preserves.
• Not complete
3. Land Management Funding: inquiry sent to applicant 3/26/2025
• Start-up Funding for Years 1-3 must be paid to Urban Corps ($11.969.11). As of 4/17/2025
this has not been done
• Endowment funding paid to The San Diego Foundation ($91,680.71). As of 4/17/2025 this
has not been done
4. Land Management Agreement: inquiry sent to Urban Corps (land manager) and applicant
3/26/2025
• As of 4/17/2025, the management agreement has not been signed yet, as they require the
following first:
(a) Installation of fencing and signage – remains outstanding
(b) Payment of endowment and start-up funds directly to Urban Corps must be done
before Urban Corps will sign the agreement- has not been done
Building:
No comments.
EL FUERTE HOMES PRELIMINARY REVIEW QUESTIONS SUBMITTED WITH APPLICATION:
Planning:
1. Please confirm if policy 44 and 66 will apply to this project or if the new Objective Design
Standards will apply.
Planning response: The project, consisting of detached condominiums, will be subject to the
Planned Development Ordinance, which requires compliance with City Council Policy No. 44.
Please see link to policy below.
City Council Policy No. 44:
https://www.carlsbadca.gov/home/showpublisheddocument/260/638417044776730000
PRE 2025-0039 (DEV2025-0048) – EL FUERTE HOMES
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Page 18
2. Please confirm all required studies that will need to be provided for project approval.
Planning response: Studies that will be required include the following:
a. Noise Analysis
b. Biological Resources Technical Report
c. Cultural Resources Report- Tribal and Paleontological
d. Fire Master Plan
e. Hydrology Study
f. Stormwater Quality Management Plan
g. Sewer Analysis
h. Preliminary Geotechnical Report
i. Local Mobility Analysis- pending the Traffic Division’s review of Scoping Agreement
j. Vehicle Miles Traveled (VMT) Analysis if the project is not exempt from CEQA
3. Confirm what permits are required and the corresponding authoritative document(s) in the City's
zoning/municipal ordinance (e.g., TTM, SDBL, etc.)
Planning response: Please refer to Comment No. 2 and comments throughout the letter with
applicable code references.
4. What is the City's process for determining CEQA exemptions?
Planning response: Please refer to the city’s informational bulletin IB-150 for additional
information regarding the CEQA process, including exemptions. Once the project is deemed
complete, the city will make a determination if the project qualifies for an exemption and what
studies are needed, or if an initial study is required to be prepared, consistent with the timeline in
the CEQA Guidelines. Information from your application may help identify the criteria if certain
exemptions apply, such as location within the city's VMT maps, fire hazard severity zone, and
habitat on site.
IB-150:
https://www.carlsbadca.gov/home/showpublisheddocument/10415/638600231368430000
5. What are the applicable impact fees, and when are they updated?
Planning response: Once the scope of the project is known, please submit a request for a fee
estimate through the Building Division.
6. Please confirm if we can purchase 1 in-lieu fee credit to satisfy the City of Carlsbad affordable
housing requirements. Note: the required density bonus very low income unit will be provided
on site.
Planning response: Please see Housing and Homeless Services Department Comment No. 3.
7. Please provide an anticipated entitlement submittal fee estimate.
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Page 19
Planning response: The current discretionary permit fees are listed below. The fees are subject to
change every year on September 1.
a. Tentative Tract Map: $14,074
b. Planned Development Permit: $16,454
c. Hillside Development Permit: $6,939
d. Habitat Management Plan Permit: $6,543
e. Variance (if no density bonus waiver is requested): $5,146
f. Noticing fees- TBD
g. Environmental Impact Assessment- TBD
8. Are there any known environmental constraints that we should be aware of that may trigger
unique study requirements?
Planning response: Please refer to Planning’s response to Question No. 2 above, Fire and HMP-
related comments in letter.
Engineering:
1. Please confirm if ROW improvements will be required. If not, will there be any financial obligation
to the developer for future ROW improvements.
Planning response: Please see Engineering Comment No. 32.
2. Please confirm where to find off-site improvement guidelines if required.
Planning response: Please see Engineering Comment No. 32.
3. Please confirm if any issues exist with the proposed approximate retaining wall heights.
Planning response: Planning staff do not support the concept proposal for retaining walls up to
10 feet in height in the front yard setback. The maximum allowable height is 42 inches. Please
reduce the height of the wall and ensure there is a minimum 15-foot-wide landscape planter in
front of the wall along the frontage.
4. Please confirm if both proposed driveway curb cuts are acceptable.
Planning response: Please see Engineering Comment No. 26.
5. Are there any outstanding bonds or financial assurances related to infrastructure completion that
might affect the building process?
Planning response: Please see Engineering Comment No. 32.
Fire:
1. Please confirm if any site access issues exist with the conceptual site plan.
PRE 2025-0039 (DEV2025-0048) – EL FUERTE HOMES
August 28, 2025
Page 20
Planning response: Please refer to comments from the Fire Department above.
2. Please confirm what high fire severity zone requirements will apply to the proposed project.
Planning response: Please refer to comments from the Fire Department above. The site is located
within the Very High Fire Hazard Severity Zone and will be subject to the corresponding
requirements.
3. Please confirm other fire requirements that may apply to this site.
Planning response: Please refer to comments from the Fire Department above.
Public Utilities:
1. Please confirm that there is existing water and sewer capacity for the proposed project and
whether any studies will be required by the developer or whether those will be completed in-
house by the City. Also, given the identified existing deficiency in the Poinsettia Ave sewer main
west of El Fuerte, can you please provide a schedule for the upsizing of that main and guidance
on when this project would be allowed to connect.
Utilities response:
Water capacity will need to be determined and coordinated with VWD.
A sewer analysis will be required by the developer to estimate the sewer loading on the local
wastewater collection system and verify conformance with current Carlsbad Engineering
Standards design criteria. Recent sewer modeling of SBA H did not identify any off-site deficiencies
in this sewer catchment outside of those in Poinsettia Lane that were identified in the 2019 Sewer
Master Plan. Design is underway for the upsizing in Poinsettia and construction is planned to begin
June 2026. Currently there is nothing foreseen to delay sewer connection for this development,
but that needs to be confirmed with a Sewer Analysis.
PRE 2025-0039 (DEV2025-0048) -EL FUERTE HOMES
August 28, 2025
Page 21
If you would like to schedule a meeting to discuss this letter with the commenting departments, please
contact Shannon Harker at the number below. You may also contact each department individually as
follows:
• Planning Division: Shannon Harker, Senior Planner, at (442) 339-2621
• Land Development Engineering: David Rick, Project Engineer, at (442) 339-2781
• Public Works-Utilities: Markus Mohrle, Associate Engineer, at (442) 339-2305
• Fire Department: Darcy Davidson, Fire Division Chief, at (442) 339-2662
Sincerely,
uvc~
ERIC LARDY, AICP
City Planner
EL:SH:CF
Enc: Engineering redlines
Utilities redlines
c: C2 Fuerte Holdings, 1056 Quartz Ct., San Marcos, CA 92078-2833
David Rick, Project Engineer
Laserfiche/File Copy
Data Entry
Public Works
Utilities Department
5950 El Camino Real Carlsbad, CA 92008 442-339-2722 760-431-2658 fax
Memorandum
DATE 8/1/2025
To: Shannon Harker
From: Markus Mohrle
Via Planning Division Request for Preliminary Review
Re: PRE2025-0039 – El Fuerte Homes
Issues of Concern:
1. Proposed project site is within the Vallecitos Water District (VWD) service area. All potable
water services and requirements shall be coordinated with and approved by VWD.
2. Provide sewer analysis based on current Engineering Standards (Volume 1 – Chapter 6) to
approximate sewer loading on public collection system based on project design.
3. Provide Civil Site Plan identifying existing public utilities in right of way and locating all existing
and proposed utility service connections along project frontage. See Attachment 1 with
additional comments.
Please provide the following information and/or document(s) with the requested number of copies
as specified.
Attachments: 1- Site Plan Option 1 Markup
2- KMA Questions Pg 2
Information/Document # of
Copies
Submittal
Form
Admin.
Purposes
Only
Sewer Analysis 1 PDF
Civil Site Plan 1 PDF
C cityof
Carlsbad
I Attachment 2 -KMA Questions Pg 2 I
Fire:
1. Please confirm if any site access issues exist with the conceptual site plan.
2. Please confirm what high fire severity zone requirements will apply to the proposed project.
3. Please confirm other fire requirements that may apply to this site.
Public Utilities:
1. Please confirm that there is existing water and sewer capacity for the proposed project and
whether any studies will be required by the developer or whether those will be completed in-house
by the City. Also, given the identified existing deficiency in the Poinsettia Ave sewer main west of
El Fuerte, can you please provide a schedule for the upsizing of that main and also guidance on
when this project would be allowed to connect.
Water capacity will need to be determined and coordinated with VWD.
A sewer analysis will be required by the developer to estimate the sewer loading on the local
wastewater collection system and verify conformance with current Carlsbad Engineering Standards
design criteria. Recent sewer modeling of SBA H did not identify any off-site deficiencies in this
sewer catchment outside of those in Poinsettia Lane that were identified in the 2019 Sewer Master
Plan. Design is underway for the upsizing in Poinsettia and construction is planned to begin June
2026. Currently there is nothing foreseen to delay sewer connection for this development, but that
needs to be confirmed with a Sewer Analysis.
Please feel free to reach out if you have any questions.
Thank you,
Kirk Moeller
Kirk Moeller Architects, Inc.