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HomeMy WebLinkAboutPRE 2025-0054; 2470 FARADAY AVENUE; Admin Decision LetterOctober 10, 2025 ROB SOLOMON BLT ENTERPRISES 1714 16TH STREET SANTA MONICA, CA 90404 {city of Carlsbad VIA EMAIL AND MAIL SUBJECT: PRE 2025-0054 (DEV2025-0072) -2470 FARADAY AVENUE APN 209-041-26-00 Thank you for submitting a preliminary review application covering two (2) industrial development concepts proposed at 2470 Faraday Avenue. The project site, an approximately 19.4 gross acre property, is partially developed with an existing industrial use on the easterly two-thirds. The westerly one-third is undeveloped. Both development concepts propose demolition of the existing industrial use on the site. The two proposed development concepts are generally described as follows: Single Industrial Building Concept: • Warehouse Distribution • 215,280 square feet GFA • 728 parking spaces provided • 3-stories, 35 feet max. ht. • 42 loading docks • 2 drive-in doors Three Industrial Buildings Concept: The three building concept proposes subdividing the parcel into two lots. Lot 1 is orient towards the intersection of Palmer Avenue and Faraday Avenue and proposes one building, while Lot 2 is oriented towards the intersection of Orion Street and the Faraday Avenue and proposes two buildings (described below}. Reciprocal access is proposed across the two lots. All three buildings include a mezzanine. Lot 1 5.32 acres (gross) Warehouse Distribution 118 parking spaces provided Lot 2 14.08 acres (gross) Warehouse Distribution 324 parking spaces provided • BLDG #1 • BLDG #2A • BLDG #2B • 95,640 SF GFA* • 107,460 SF GFA* • 107,460 SF GFA* • Mezzanine: 5,000 SF • Mezzanine: 5,400 SF • Mezzanine: 5,400 SF • 3-stories, 35 feet max. ht. • 3-stories, 35 feet max. ht. • 3-stories, 35 feet max. ht. • 12 loading docks • 20 loading docks • 20 loading docks • 2 drive-in doors • 2 drive-in doors • 2 drive-in doors *GFA includes proposed mezzanine area. Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025-0072)-2470 FARADAY AVENUE October 10, 2025 Pa e 2 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 ofthe date ofthis 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 designations for the property are as follows: a. General Plan : Planned Industrial (Pl) b. Zoning: Industrial Zone with a Qualified Development Overlay (M -Q) 2. The project requires the following permits: a. Minor Subdivision {MS) A Minor Subdivision shall be required for any subdivision of land or airspace resulting in four (4) or fewer lots or units. Not enough information is provided with this preliminary review to understand how the subject site plans and/or buildings are proposing to be subdivided. b. Tentative Tract Map (CT) A Tentative Tract Map (CT), also categorized as a Major Subdivision on the city's Land Use Review Application, shall be required for the subdivision of land or airspace resulting in five (5) or more lots or units. Not enough information is provided with this preliminary review to understand how the subject site plans and/or buildings are proposing to be subdivided. c. Nonresidential Planned Development {PUD) A Nonresidential Planned Development {PUD) shall be required for the subdivision of nonresidential units (CMC Chapter 21.47). Further information will be required regarding the proposed division of land and/or airspace. If the division of land and/or airspace warrants a Minor Subdivision {MS) as discussed above, then the PUD would be taken in at the Planning Division counter as a Minor PUD. Alternatively, if the division of land and/or airspace warrants a Tentative Tract Map (CT) as discussed above, then the PUD would be taken in at the Planning Division counter as a Major PUD. d. Site Development Plan (SDP) Pursuant to Section 21.06.030, unless specifically exempted from the requirements of this chapter, no building permit or other entitlement shall be issued for any development or use in Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025-0072)-2470 FARADAY AVENUE October 10, 2025 Pa e 3 the Q zone unless there is a valid minor site development plan or site development plan approved for the property. A Minor Site Development Plan would be required according to this preliminary review unless the project proposes to increase building height above 45-feet. Further details and requirements regarding this process can be found in Section 21.32.050 of the Carlsbad Municipal Code. e. Habitat Management Plan Permit (HMP) A major or minor Habitat Management Plan Permit (HMP) may be required depending on the results of a Biological Resources Technical Report. A minor permit has an administrative (City Planner) review and approval process unless other permits require the decision to be elevated to the Planning Commission or City Council. In these instances, all permits are elevated to the Planning Commission or City Council for decision according to procedures outlined in Section 21.54.040 of the Carlsbad Municipal Code. 3. Warehouse is a permitted use in the M zone. While not specifically called out, CMC Section 21.32.010.D, Table A, does state that "any use permitted in the C-M zone is permitted in the M zone". Referring down to the C-M zone, more specifically, CMC Section 21.30.010, we find "wholesale businesses, storage buildings and warehouse" are listed as permitted uses. Distribution would be permitted together with a warehouse use as discussed herein. Office uses, as shown on the two site plan options, would need to be determined ancillary to the primary warehouse use. Office type uses by themself are not permitted. Manufacturing, by itself, is not specifically called out as a permitted use in the M zone as it is in P-M zone. Any proposed industrial type manufacturing use would m~ed to be discussed and determined acceptable by the City Planner where it states pursuant to CMC Section 21.32.010.D, Table A that "any industrial use not specifically permitted herein may be considered by the City Planner." 4. The subject parcel is located within the McClellan-Palomar Airport Influence Area (AIA). New development within the AIA must be reviewed for consistency with the adopted land use compatibility plan for the airport, in this case the McClellan-Palomar Airport Land Use Compatibility Plan (ALUCP), adopted on January 25, 2010 and later amended on March 4, 2010 and December 1, 2011. Please see the link below for review of the McClellan-Palomar Airport Land Use Compatibility Plan: https://www.carlsbadca.gov/home/showpublisheddocument/226/637446617757230000 Preliminary review of the proposed project options against the ALUCP revealed the following: a. Exhibit 111-1-Compatibility Policy Map: Noise. The subject parcel is located outside of the 60 db CNEL noise exposure range per Exhibit 111-1. Pursuant to the ALUCP Section 3.3.3(a) on page 3-19: "The threshold for evaluation is the projected 60 dB CNEL contour. This contour defines the noise impact area of the Airport. All land uses located outside of this noise contour are consistent with the noise compatibility policies." Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025-0072) -2470 FARADAY AVENUE October 10, 2025 Pa e 4 b. Exhibit 111-2 -Compatibility Policy Map: Safety. Pursuant to Exhibit 111-2, the subject parcel is located in Zone 6 (Traffic Pattern Zone). Pursuant to Table 111-2 (Pgs. 3-45 through 3-52), office, manufacturing, and warehouse uses are considered compatible within Safety Zone 6 with no Floor Area Ratio (FAR) restrictions. c. Exhibit 111-3 -Compatibility Policy Map: Part 77 Airspace Protection. The subject parcel is located within the Horizontal Surface associated with the typical Part 77 obstruction surfaces as outlined in Exhibit 111-3. Any formal submittal of a project under the ALUCP would require compliance with the Federal Aviation Administration's (FAA) Federal Aviation Regulations (FAR) Part 77, Objects Affecting Navigable Airspace. With any formal application submittal and before city staff could consider an application complete, submittal of FAA aeronautical studies in accordance with the FAA's FAR Part 77, Subpart C, shall be submitted indicating the FAA's issuance of a "determination of no hazard to air navigation". d. Exhibit 111-4 -Compatibility Policy Map: Overflight. The subject parcel is located within the Overflight Notification Area. However, pursuant to the McClellan-Palomar Airport Land Use Compatibility Plan (ALUCP) Policy 3.6.3{c), "recordation of an overflight notification document is not required for non-residential development." e. Exhibit 111-5 -Compatibility Policy Map: Airport Influence Area. The project site is located within Review Area #1 of the Airport Influence. f. Exhibit 111-6 -Compatibility Policy Map: Avigation Easement Area and Overflight Notification Areas. The project site is located outside of the Avigation Easement Area but is located within the Airport Overflight Notification Area. However, as noted in subsection d) above, an overflight notification document is not required for nonresidential development. 5. As it relates to off-street required parking, the site plans associated with the two proposed site plan/building design options have identified the correct parking ratios for office, manufacturing and warehouse uses. However, the calculations associated with the required parking allotments are unclear and will need to be further clarified with a formal application submittal. Please remember that the individual parking ratios for each use are based on the gross floor area of the building. In the case of multiple uses in a building or on a lot, the total requirements for off-street parking facilities shall be the sum of the requirements for the various uses computed separately. When calculating the required number of parking spaces, if the calculation results in a fractional parking space, the required number of parking spaces shall always be rounded up to the nearest whole number. 6. As it relates to off-street parking standards, the site plans associated with the two proposed site plan/building design options are utilizing the correct parking stall area and dimensional standards, along with drive-aisle width for 90-degree parking aisles, except for Fire Lanes (see Fire Department comments below). Please remember that compact parking, if there are any spaces proposed, shall (1) be limited to a maximum of 25%; (2) shall be located in separate parking aisles from standard sized parking spaces; (3) aisles for compact car spaces shall be clearly marked with permanent pole signs denoting "Compact Cars Only"; and (4) compact car spaces shall be located in close proximity to the facility they are intended serve, so as to encourage their maximum usage. Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025-0072)-2470 FARADAY AVENUE October 10, 2025 Pa e 5 7. This preliminary review application did not include preliminary landscape exhibits; and thus, it was not routed for landscape review. Please note with a formal application submittal, conceptual landscape exhibits are required and shall be prepared in accordance with the General Requirements listed in Section 3 of the City of Carlsbad Landscape Manual (February 2016). The exhibit package shall include a Conceptual Landscape Plan; Conceptual Water Conservation Plan; Conceptual Fire Protection Plan; and a Conceptual Landscape Maintenance Responsibility Exhibit (private or common). The city's Landscape Manual may be found on the city's website at: https://www.carlsbadca.gov/home/showpublisheddocument/234/637425974086270000 8. Please be sure to review all the landscape requirements for parking lots as outlined in Section 3.C.13 of the Landscape Manual. Be sure to address parking lot perimeter landscape border and tree planting requirements. Design parking lot end aisles and tree wells to comply. Long rows of parking should be broken up with landscaped islands. Landscaped islands should be provided at intervals of one island for approximately every 12 to 15 parking spaces. 9. Interior areas of the site adjacent to proposed buildings, please consider use of tall decorative architectural screen walls, combined with mounding and evergreen type landscaping, to help reduce line of sight views into the proposed truck loading docks from Palmer Way, Faraday Avenue and Orion Street. 10. At the perimeter of the site, please utilize a combination of landscape and mounding in strategic locations to help break up line sight corridors into the truck loading docks and parked cars. As it relates specifically to parking areas, the landscape manual requires screening from adjacent property or streets through the use of planting or any combination of planting, mounding, and decorative walls, with screening elements having a total height of at least three (3) feet. 11. Please consider ways to incorporate architectural features into the proposed building designs to provide architectural relief to large unarticulated building facades. 12. A formal submittal of the project is subject to City Council Policy Statement No. 84, Development Project Public Involvement. The city has prepared an Informational Bulletin (IB), IB-184, to assist project applicants with this process. IB-184, Council Policy 84 Implementation Guide, can be found on the city's website at: https ://www .ca rls ba dca .gov /ho me/s howpu blis heddocu m ent/ 19417 /638 7 4167 5682 230000 Please be aware that it is the project applicant's responsibility to fully implement the requirements of Policy 84 and the IB-184 guidance document. Failure to comply shall cause the formal application to be deemed incomplete pursuant to Carlsbad Municipal Code §21.54.0lO(F). Community Development Department Planning Divi sion I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025-0072)-2470 FARADAY AVENUE October 10, 2025 Pa e 6 13. 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 Climate Action Plan 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 Carlsbad Municipal Code Chapters 18.21, 18.30 and 18.51 which is 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. 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/planning. You may also access the General Plan Land Use Element and the Zoning Ordinance online at the website address shown. Please review all information carefully before submitting. Land Development Engineering: 1. Please 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 per the most recent Transportation Impact Analysis Guidelines. 2. After the scoping agreement has been approved or deemed not necessary by the Transportation Division, please submit a completed Transportation Analysis Need Statement Form P-42 to Land Development Engineering at LandDev@carlsbadca.gov. This must be completed prior to this initial submittal of the project's discretionary application. If an LMA has been deemed not necessary by the Transportation Division, please provide correspondence from the Transportation Division indicating that one is not required. Community Development Department Plann ing Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025-0072)-2470 FARADAY AVENUE October 10, 2025 Pa e 7 3. A Transportation Demand Management (TOM) plan may be required depending on the number of employee vehicle trips the project will generate. Please calculate the gross employee ADT using the generation rates from Table 2-2 of the TOM Handbook. The TOM Handbook can be found on the city's website at: https://www.carlsbadca.gov/home/showpublisheddocument/310/637425981338370000. Please show calculations on the Climate Action Plan checklist, Form P-30. If applicable, submit a TOM plan with your application for discretionary permits. 4. Depending on the CEQA determination, which is determined after the application for discretionary permits are submitted, a Vehicle Miles Traveled (VMT) analysis may be required per the Vehicles Miles Traveled Analysis Guidelines. The VMT Analysis Guidelines can be found on the city's website at: https://www.carlsbadca.gov/home/showdocument?id=312 5. Please complete a Storm Water 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. 6. 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. Please submit a Storm Water Quality Management Plan. Review the Hydromodification Exemption Map and Potential Critical Coarse Sediment Yield Area Map on the City website to see 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. 7. Based on this project's general plan land use designation of Planned Industrial (Pl), this project is subject to the City of Carlsbad trash capture requirements. Please incorporate trash capture measures on the project plans. Please also incorporate trash capture measures into Storm Water Quality Management Plan, Form E-35. 8. Please provide a Preliminary Title Report (current within the last six (6) months). 9. Please 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. 10. A Preliminary Hydrology Study, including map and calculations, is required to demonstrate capacity/sizing of proposed and existing storm drain infrastructure. Please show 100-year storm hydrologic calculations before and after development for each drainage basin. 11. 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. Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025-0072) -2470 FARADAY AVENUE October 10, 2025 Pa e 8 12. Per CMC Section 15.16.060 this project will require a grading permit and grading plan. 13. A separate improvement plan for work within the right-of-way may be required for this project. 14. 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. 15. Please delineate and annotate the limits of grading. 16. Please delineate and annotate approximate topographic contours for existing and proposed condition. Provide one-foot (1') contours for slopes less than 5%; two-foot (2') intervals for slopes between 5% and 10%, and five-foot (5') intervals for slopes over 10%. Extend contours a minimum 25 feet beyond the project boundary. 17. On the site plan, please show and identify all existing surface improvements screened back (curb, gutter, sidewalk, paving, manholes, inlets, street lights, adjacent driveways, vaults, transformers, etc.) at the project site, project frontage and within 25 feet of the boundary. 18. Please delineate location of all existing and proposed buildings, walls, fences and permanent structures onsite and within 25 feet of the site. 19. Please indicate the earthwork quantities (cut, fill, import, export, and remedial) that are proposed for the project in cubic yards. 20. Please provide spot elevations at the corners of each pad in the proposed condition. Include finish pad and floor elevations. 21. Please 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. 22. Please delineate all retaining walls that will be utilized on the project site and show top of wall and bottom of wall elevations, including at the highest and lowest points. Please indicate maximum height of all retaining walls measured from bottom of footing to top of wall and maximum height measured from finish surface to top of wall. 23. Please show existing lot line bearing and distance. 24. Please provide typical street cross sections for existing frontage streets. Provide existing right-of-way width and existing improvements and proposed improvements and dedications. 25. Please delineate and annotate all proposed driveways and driveway widths. Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025-0072)-2470 FARADAY AVENUE October 10, 2025 Pa e 9 26. Driveways that exceed more than 150-feet in length shall have a turnaround designed for a three- point turn of a passenger vehicle. Additionally, please coordinate with the Fire Department to ensure width and grade of driveway meets Fire Department requirements. 27. Please show truck turning radii. Plot turning radii per Caltrans figure 404.5B and/or 404.5F. 28. Please provide five-foot (5') minimum back-up clearance at the last stall of the row of parking spaces. 29. Please show all existing and proposed utilities and callout size for: water, sewer, storm drain, underground dry utilities, overhead lines, traffic signals, and street lights in Palmer Way, Faraday Avenue and Orion Street and laterals affecting the property. 30. All transformers and electrical facilities solely serving this project site shall be located onsite and outside of the public right-of-way 31. Please 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 all existing and proposed dry utilities and the services that will supply power to the proposed transformer. 32. Please provide a Sewer Study for new development based on City of Carlsbad Sewer Master Plan Update 2019, Section 4.2 Design Criteria. 33. Please provide a Water Study for the new development based on City of Carlsbad Potable Water Master Plan 2019, Section 4.2 Design Criteria. 34. Public potable water and sewer mains along project frontages must meet minimum design diameter and material as specified in City of Carlsbad Engineering Standards Vol. 2 Section 3.2.2 for water and Volume 1 Section 6.2 for sewer. Utility replacement and/or upsizing may be required as a condition of development. 35 . Please locate fire service, backflows, potable and recycled water services, meters, landscape irrigation services, and sewer laterals for the new development in compliance with City of Carlsbad Engineering Standards requirements. 36. Please ensure the trash enclosure design is consistent with the City of Carlsbad and Republic Services standards, see Building Department Form B-76. 37. Please 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. 38. 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.) Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025-0072) -2470 FARADAY AVENUE October 10, 2025 Page 10 39. Please plot stopping sight distance at all driveways and corner sight distance at all street intersections. 40. Please address the comments on the attached red lined plan. Option 2 Comments: 41. All the above comments also apply to option 2 in addition to the following: 42. Please show proposed parcel lines on the site plan. Provide proposed parcel areas. This project is proposing a subdivision to create two (2) parcels. A Tentative Parcel Map is required. 43. Please be advised that a more in-depth review of the proposed development will occur with the discretionary permit application once a more complete design of the project is provided. Public Works -Utilities: 1. Existing parcel (APN 209-041-26-00) contains an existing public 12-inch (12") ACP water main and an existing public 8-inch (8") VCP sewer main, each within existing, on-site 15-foot-wide easements (Rec #79-155545 and Rec #87-234258, respectively). The existing sewer alignment is located beneath a landscape easement along the Faraday Avenue frontage and has significant root intrusion from the plantings. a. The existing onsite water and sewer mains shall be relocated into the Faraday Avenue ROW and the easements vacated as part of the site redevelopment. b. Alternately, the existing onsite water and sewer mains shall be replaced with PVC pipe and 20-foot-wide easements provided for each per current Engineering Standards. All trees and invasive root plant species shall be removed from the existing landscape easement to avoid future root damage to sewer piping in conformance with easement requirements. 2. A water study analysis will be required for the proposed development to support relocation of the existing 12-inch (12") water main off the project site. Existing water usage and potential future water demands shall also be analyzed to assess proposed domestic meter and fire service sizing, and for hydraulic modeling of the public distribution system per the current Carlsbad Engineering Standards and applicable NFPA fire flow requirements. a. The existing fire service for this property has a single-check backflow device which does not comply with State and Carlsbad Municipal Water District regulations and shall be replaced with a device that meets current Engineering Standards (see Std Dwg W-9). b. The existing water service is provided via a 4-inch (4") meter with a maximum safe operating capacity of 1,100gpm. Records indicate the monthly water usage to range from 324 units (242,350 gallons) to 700 units (523,600 gallons) per month. The construction of tenant improvements in the proposed shell buildings will require engineering review by the Utilities Department and evaluation of water demands exceeding the current meter capacity. Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025-0072) -2470 FARADAY AVENUE October 10, 2025 Page 11 3. The existing public sewer collection systems in Faraday Avenue and Palmer Way are at capacity and additional sewer demands or new sewer connections shall require submittal of a sewer study for the proposed use(s) prior to building occupancy or new sewer connections. a. Currently, all sewer loading discharges into the existing onsite private 8-inch (8") sewer lateral connecting to the public sewer in Faraday Avenue. The sewer study shall evaluate the existing and proposed sewer loading from the development and the need for off-site sewer capacity improvements. b. The proposed IND BLDG 1 may require its sewer lateral connection to be made in Palmer Way. The sewer study shall evaluate the proposed sewer loading from the development and the need for off-site sewer capacity improvements. 4. Project Plans shall be developed to identify all utilities along Plamer Way and Faraday Avenue frontages. Existing and proposed utility connections shall be located and sized for proposed demands and shall be labeled with current standard detail references in accordance with approved Water and Sewer Studies and the Carlsbad Engineering Standards. 5. Site irrigation for landscaping of the proposed site(s) shall be supplied by existing reclaimed water mains (elevation 550-foot pressure zone) in Faraday Avenue or Palmer Way. 6. Each legal lot shall have its own potable water and recycled water services. Public Works -Transportation, Planning & Mobility: 1. Either site plan option will require preparation of a Local Mobility Analysis (traffic study). Please submit a Scoping Agreement in accordance with the City of Carlsbad Transportation Impact Analysis Guidelines to determine the appropriate study parameters and assumptions. For coordination, please contact Nathan Schmidt at nathan.schmidt@carlsbadca.gov. Public Works -Transportation 1. No comments. Fire & Life Safety: 1. A Fire Master Plan shall be required. The Fire Master Plan shall include, at a minimum, the following elements: a. Fire Department access roads and dimensions, road surface material, weight capacity, and access gates. b. Show the circulation route for emergency vehicles through the property. c. Hose-pull dimensions to all structures. d. Hydrant locations. 2. Fire Apparatus Access Roads must extend to within 150 feet of all portions of the exterior of the first floor of any structure. Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025 -0072) -2470 FARADAY AVENUE October 10, 2025 Page 12 3. A secondary access point is required for commercial projects of more than 62,000 square feet in building area. Where two (2) apparatus access roads are required, they shall be placed a distance apart not equal to less than ½ the length of the overall diagonal dimension of the property (CFC, Appendix D106.2). 4. Aerial Fire Apparatus Access Roads shall be provided for buildings greater than 30 feet in height. Minimum width of such access road shall be 26 feet unobstructed width and located at a distance of not less than 15 feet and not more than 30 feet from the building. Aerial access shall be provided on one full side of each building. 5. Please show the circulation path for emergency vehicles around buildings and through the site. Please note that the site plan options included with this preliminary review are indicating the Fire Lane minimum widths as 24 ft. These should be a minimum of 26 feet where buildings are taller than 30 feet. 6. Please submit a completed Form P99F to determine fire flow requirements, and to determine the number and location of required hydrants. Please note this form must be completed prior to submittal of a formal application for the project. A completed, city-reviewed Form P99F, shall accompany the formal project application to the Planning Division. Building: 1. Compliance with the 2025 edition of the building code will be required. Please review updated regulations (recent changes) for foundation anchoring and framing seismic techniques, new energy efficiency improvement requirements, and changes to accessibility and EV infrastruct ure. 2. Refer to the Trash Enclosure Guidelines (form B-76 -linked below). When designing a trash enclosure, ensure compliance with size, and placement requirements. https ://www .ca rlsba dca .gov /horn e/s howpu bl is h eddocu m ent/ 19315/6386880642313 70000 Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2025-0054 (DEV2025-0072) -2470 FARADAY AVENUE October 10, 2025 Page 13 If you would like to schedule a meeting to discuss this letter with the commenting departments, please contact Jason Goff at the number below. You may also contact each department individually as follows: • Planning: Jason Goff, Senior Planner, at (442) 339-2643 • Land Development Engineering: Jose Sanchez, Project Engineer, at (442) 339-5486 • Public Works-Transportation: John Kim, City Traffic Engineer, at (442) 339-2757 • Public Works-Transportation Planning & Mobility: Nathan Schmidt, at (442) 339-2734 • Public Works-Utilities: Markus Mohrle, Utilities Senior Engineer, at (442) 339-2322 • Fire & Life Safety: Darcy Davidson, at (442) 339-2662 • Building: Mike Strong, Acting Building Official, at (442)-339-5413 Sincerely, ffrc ~ ERIC LARDY, AICP City Planner EL:JG:cf c: KG Patel, Beckman Coulter, Inc., 250 S. Kraemer Boulevard, Brea, CA 92821 Eric Raby, BLT Enterprises, 1714 16th Street, Santa Monica, CA 90404-4402 Jose Sanchez, Project Engineer Darcy Davidson, Fire & Life Safety Laserfiche/File Copy Data Entry Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 ATTACHMENT {PRE 2025-0054) Project Description: Please see two attached PDF versions of concept site plans. In one version, a single speculative industrial building and parking field are developed in place of the undeveloped area and existing 136,431 SF facility. Potential modifications to the submitted plan might include additional office mezzanine up to 40,000 SF, subdividing the existing building into two units, widening the proposed driveway for truck traffic off of Palmer Way, and/or adding an additional driveway off of Faraday Ave. In the second version, three speculative industrial buildings are developed in place of the undeveloped area and existing 136,431 SF facility. Potential modifications to the submitted plan might include subdividing the two 102,060 SF buildings into two units, widening the proposed driveway off of Palmer Way, and/or adding an additional driveway off of Faraday Ave. Minor Site Development Plan: If all buildings are under 45 feet, please confirm that the project will require a Minor Site Development Plan ("MSDP"), rather than a Site Development Plan, and that an MSDP may be approved by the City Planner. City Response: A Minor Site Development Plan would be required unless Developer proposes to increase building height above 45-feet. Further details and requirements regarding this process can be found in Section 21.32.050 of the Carlsbad Municipal Code. AM inor Site Development Plan permit has an administrative (City Planner) review and approval process unless other permits require the decision to be elevated to the Planning Commission or City Council. In these instances. all permits are elevated to the Planning Commission or City Council according to procedures outlined in Section 21.54.040 of the Carlsbad Municipal Code. Tentative Parcel Map: Please confirm that a Tentative Parcel Map, approved by the City Planner, may be used to subdivide the site into two parcels. City Response: Please see Preliminary Review Letter. California Environmental Quality Act ("CEQA") Review: Please confirm that the project is eligible for a CEQA exemption/streamlining under Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183, as it is consistent with the General Plan and corresponding Environmental Impact Report. What studies will the City require to certify this exemption? Are there other CEQA exemptions that may be applicable to the project? City Response: Use of section 15183 under CEQA Guidelines can allow discretionary actions when substantial evidence shows that the project is consistent with the information included in the 2015 General Plan Environmental Impact Report and 2024 Supplemental Environmental Impact Report. Documentation of this finding would be required in a Notice of Exemption or Determination with substantial evidence in the form of a checklist by CEQA topic area. Studies are likely going to be needed for impacts to Transportation, Air Quality, and Greenhouse Gas emissions . Documentation would be ATTACHMENT {PRE 2025-0054) needed to determine that the project meets noise standards in the General Plan. A CEQA finding of 15183 would need to also include evidence the project complies with all existing laws, including AB 98 and the city's general plan. Due to the size of the proposed buildings, and preliminary review of the supporting materials provided, the project may also be eligible for a Class 32 -Infill Exemption, if the development site is less than 5 acres. Please consult the advice of a professional environmental consulting firm and provide justification of use of one or more the specified tiering or exemptions listed in this response. The information you provide may be submitted on the city's EIA Information Form (Form P-10) as part of a formal project application submittal. The city will formally initiate CEQA review after the land use development application is determined to be "complete" for processing and final action. This includes making determinations and decisions on exemptions, all within specified time periods. Permitted Uses: Please confirm that distribution is a permitted use in the M zone. City Response: "Distribution" would be considered a permitted use together with the proposed "Warehouse" use that is the subject of discussion in the M zone. AB 98 Issues: Given that (a) the site is zoned for industrial use, and (b) each of the proposed buildings are under 250,000 SF, please confirm that (1) the project will have to satisfy the requirements under subsection (d) of Section 65098.1 of the Government Code, and not the requirements under subsection (a) of Section 65098.1 of the Government Code, and (2) the buildings would not be subject to the additional requirements of the "Tier 1 21 st Century Warehouse" standards. We believe this is the correct result since AB 98 defines a logistics use as specific to "a building". A proposed new or expanded logistics use is subject to AB 98 where the loading bay is withing 900 feet of a sensitive receptor. Is the "loading bay" the face of the dock door or something else? Is the 900 feet measured from the property line of the sensitive receptor or the building wall of the sensitive receptor closet to the loading bay? City Response: Pursuant to AB 98, developments of 250,000 square feet or more must comply with Tier 1 21st Century Warehouse design elements. The single-building option proposes a total of 215,280 square feet. The three-building option appears to exceed 250,000 square feet. which involves the demolition of an existing industrial building and construction of "Building 2A" and "Building 2B." To qualify for a "development that is less than 250,000 square feet and be subject to Section 65098.l(d). the three-building project would have to be defined as two separate developments (Building 1 as one development; and Buildings 2A/2B as another independent development), have separate and independent utility, and be processed as two separate land use applications. Regarding the spatial separation of the proposed use(s) and a sensitive receptors, "loading bay" is not defined in the legislation on where to include the measurement. However the Government Code includes references to "Loading Bays", "Truck Loading Bays" and requirements to "Provides conduits and ATTACHMENT (PRE 2025-0054) electrical hookups at all loading bays serving cold storage." Therefore, it would be reasonable to include that the loading bay is both the face of the door dock and the area where a standard vehicle would be parked to measure potential impacts. It is commonly referred to as the general area of where shipping and receiving happens. If the State Legislature intended it to mean something different or more precise, "loading docks" would have been the word utilized to describe where the truck connects to in order to load or unload. Despite defining "sensitive receptors" in Section 65908(e). the State Legislature did not define where the measurement was taken from or if it was inclusive of a property line. It should be measured with a direct line method from the first point the use, building, activity or otherwise geographic feature of the sensitive receptor. If that remains unclear, it should be measured from the area that is expected to have associated persons within. This may or may not be the property line depending upon specific situations. "Property line" is referenced in a few locations of AB 98. In all cases, the language is directory to locate truck loading bays a certain distance from the nearest property line to a sensitive receptor; or to locate truck movement away from the sides of the building that are directly adjacent to a sensitive receptor property line. Under Section 65098.2, subsection (1 ), the buffer shall be 50 feet in width measured from the property line of all adjacent sensitive receptors. If there is a street or another parcel between the project and the sensitive receptor, please confirm that no buffer is required. City Response: The buffer would need to be calculated in distance to meet the requirements of 65098.2 and 65098.1. Based upon our review of the law, the road could be included within that measurement, but that the requirement in various sections of 25098.1 to "Include buffering and screening to mitigate for light and noise, as described in Section 65098.2." must also be met regardless of the numerical standard of SO or 100 feet, dependent upon the criteria. We have identified possible sensitive receptors -please confirm there are no additional sensitive receptors that may impact the project, other than those noted here: 1) Skate Park located at 2560 Orion Way, Carlsbad, CA 92010 2) Personal Residence located at 5850 Sunny Creek Rd ., Carlsbad, CA 92010. City Response: Developer's professional environmental consultant will need to identify all possible sensitive receptors as part of a formal environmental review included with a future project. Based upon our review, those both appear to be sensitive receptors. In the case of a "publicly owned park," which is one of the sensitive receptors identified in Section 65098(e), the definition includes "playgrounds and recreational areas or facilities used by children." The boundaries of this skate park can be mapped according to the area that is expected to have associated persons within. For a "residence," Section 65098(el specifies that it includes "but not limited to" a private home, apartment, condo, group home, dormitory unit. or retirement home. The personal residence at 5850 Sunny Creek qualifies under this definition. The building on this property is more than 900 feet from the face of the dock doors. Please confirm t herefore it is not within 900 feet of a loading bay. ATTACHMENT (PRE 2025-0054) City Response: Please see response above about the definition of "loading bay". We will need additional information to confirm. Developer's professional environmental consultant will need to address as part of a formal environmental review included with a future project. The scope of research requested herein exceeds the city's Preliminary Review process. 3) Catholic Charities La Posada located at 2476 Impala Dr., Carlsbad, CA 92010 Given that the use is transitional/temporary housing rather than permanent residence, would the City consider this a sensitive receptor? City Response: Yes, the city would consider the subject shelter, located at 2476 Impala Drive, as a "sensitive receptor." The shelter provides living quarters in a dormitory fashion for anywhere between 50 to 100 people per night. 4) Concentra Urgent Care located at 5810 El Camino Real, Carlsbad, CA 92008 Please confirm this is not a sensitive receptor since it is not a hospital, as defined in Section 128700 of the Health and Safety Code. Concentra Urgent Care appears to be licensed as a Primary Care Clinic (PCCs) under Chapter 1 (commencing with Section 1200) of Division 2 of the California . Health and Safety Code. This classification applies to outpatient health facilities that provide direct medical services to patients who remain less than 24 hours. Concentra does not fall under the definition of a "health facility" as outlined in Section 1250 of the Health and Safety Code, which pertains to facilities providing 24-hour inpatient care. City Response: The city would consider the operation at 5810 El Camino Real as a "hospital" if it meets the definition of Section 128700 of the Health and Safety Code, which is referenced in AB 98 . 5) Cortica Carlsbad located at 5870 El Camino Real, Carlsbad, CA 92008. Please confirm this is not a sensitive receptor. Cortica provides medical, therapeutic, and early intervention services for children with neurodevelopmental conditions. We do not believe it is a school or daycare facility under AB 98 . City Response: The city would consider the operation at 5870 El Camino Real as a "hospital" if it meets the definition of Section 128700 of the Health and Safety Code, which is referenced in AB 98 . Subsection (d) of Section 65098.1 of the Government Code requires truck loading bays to be oriented on the opposite side of the logistics use development away from sensitive receptors, to the extent feasible. If there are sensitive receptors to the north of the property, are we required to orient truck loading facing Faraday? City Response: The legislation uses the phrase "Orient truck loading bays on the opposite side of the logistics use development away from sensitive receptors to the extent feasible." 65098.1. (d)(l) If orientation is not proposed away from all sensitive receptors, we would need evidence of infeasibility of that orientation. ATTACHMENT (PRE 2025-0054} Noting that one of the AB 98 requirements is to locate truck/entry and exit and internal circulation away from sensitive receptors to the extent feasible, does the City see an issue with truck entry/exit coming off of Palmer Way? City Response: As part of the Local Mobility Analysis, the applicant should verify the locations of any potential sensitive receptors within 900 ft. of the proposed loading bays or truck circulation areas to ensure consistency with AB-98 design and buffer requirements. The city will evaluate truck access and on-site circulation in further detail as part of the Local Mobility Analysis . Can you confirm Palmer Way meets the definition of a "local road that predominately serves commercial uses" vis a vis truck routes? City Response: Yes. Palmer Way meets the intent of a "local road that predominately serves commercial uses". It is designated as an "Industrial Street" by the City's General Plan Mobility Element with a primary purpose to connect people to businesses within the city's industrial parks and designed to safely move all modes travel. Planning Moratorium: Please confirm that the site and project will not be impacted by the City's planning moratorium under Carlsbad Municipal Code section 21.49.01 0(a). City Response: There is no moratorium that applies to this site, Public Works Utilities will need to review and sign off on all applications related to sewer capacity. Airport Regulations: The Property is situated in Review Area 1 of the McClellan-Palomar Airport Influence Area ("AIA") and is subject to the corresponding Airport Land Use Compatibility Plan ("ALUCP"). (ALUCP, Exhibit 111-5.) Please confirm that the City's General Plan is consistent with the ALUCP and Airport Land Use Commission review of the Project will not be required. City Response: We would only refer to the Airport Land Use Commiss ion (ALUC) in the cases of proposed land use changes. The type of proposed use, warehouse, is a permitted use in the M zone. No land use change appears to be proposed. The General Plan provides that new development in the AIA must obtain "approval of a site development plan or other development permit." (General Plan Land Use Element, p. 2-44.) Please confirm that an MSDP will satisfy the General Plan's development permit requirement for projects in the AIA . City Response: Review of a future SDP, whether minor or major, will include review and analysis of the project's compliance/conformance with the McClellan Palomar Airport Land Use Compatibility Plan (ALUCP). Please refer to the preliminary review letter for a cursory review of project against the ALUCP. Additional studies as it relates to FAA FAR Part 77 will need to be submitted with a formal project application. ATTACHMENT {PRE 2025-0054) Offsite Improvements: Will the project trigger any offsite improvements, such as street widenings, signalization of intersection, addition of turn lanes, or the installation of sidewalks on Palmer Way or Orion Street? City Response: The project is required to submit a Local Mobility Analysis (LMA) in accordance with the City of Carlsbad's Transportation Impact Analysis Guidelines. This analysis will determine the need for any offsite improvements associated with the project. As requested by the Transportation Department, please submit a scoping agreement to initiate your traffic analysis and confirm the appropriate study parameters.