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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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,
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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.