HomeMy WebLinkAbout2025-10-28; City Council; 04; Request to Convert Former Inns of America Building to Apartment Complex: Coastal Development Permit Amendment, Conditional Use Permit and Planned Development Permit (AMENCA Review CDS
Meeting Date: Oct. 28, 2025
To: Mayor and City Council
From: Geoff Patnoe, City Manager
Staff Contact: Lauren Yzaguirre, Senior Planner
lauren.yzaguirre@carlsbadca.gov, 442-339-2634
Subject: Request to Convert Former Inns of America Building to Apartment
Complex: Coastal Development Permit Amendment, Conditional Use
Permit and Planned Development Permit (AMEND 2024-0008 / CUP
2024-0009 / PUD 2024-0009 / DEV99017)
District: 2
Recommended Action
1)Hold a public hearing; and
2)Adopt a resolution approving a California Environmental Quality Act exemption
determination and approving a coastal development permit amendment, conditional
use permit and planned development permit to allow for the conversion of an existing
three-story, 98-guest room hotel into a 98-unit multi-family rental project on a 3.12-
acre site located at 5010 Avenida Encinas, within the Mello II Segment of the Local
Coastal Program and within Local Facilities Management Zone 3 (Exhibit 1)
Executive Summary
This is a request to convert an existing 98-unit hotel at 5010 Avenida Encinas into a 98-unit
apartment complex. The developer is seeking four waivers under California’s Density Bonus Law
to deviate from certain city development standards to accommodate the conversion of the
exiting building from transient occupation to permanent housing. The Density Bonus Law allows
developers to build more housing units than local zoning would normally permit when a project
includes a certain percentage of affordable units, as detailed below.
An increase in the project’s density, that is, how many units it will contain, is not being
proposed.
For the reasons explained in this staff report, city staff and the Planning Commission have
concluded that all required findings can be made to approve this request and are
recommending the City Council approve of the project, in keeping with local and state laws.
This item is being brought before the City Council because the property is located within the
Planned Industrial (P-M) zone, which requires City Council review and approval of any proposed
residential development.
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Explanation & Analysis
Project description
The project site consists of a 3.12-acre lot on the southeast corner of Cannon Road and Avenida
Encinas. The lot contains an existing three-story, 65,763-square-foot, 98-guest room hotel and
123 space surface parking lot. The parcel is generally flat, sloping slightly upward from Cannon
Road and Avenida Encinas. The subject site is surrounded by a mix of uses, including a gas
station and convenience store Cannon Road and offices, a parking lot and industrial and office
uses along Avenida Encinas. The site is adjacent to and just west of the interstate 5 southbound
entry ramp at Cannon Road.
The developer proposes:
•Converting the existing 98-unit hotel into a multi-family residential building. Interior
renovations throughout the building will be completed to meet California Building Code
requirements for residential units. The project will include studios and one-bedroom
apartments.
•Retaining the existing 123 uncovered surface parking spaces, with 98 spaces designated
for residents and 25 spaces reserved for visitors, loading and mail delivery
•Retaining the existing outdoor swimming pool and spa
•Developing new active recreation areas, including a dog run and pickleball courts
•Making exterior updates and renovations, including repainting the structure and
rehabilitating the landscaping
A complete summary of the proposed development and the zoning requirements for the
project can be found in the Planning Commission staff report provided as Exhibit 3.
Residential uses in the P-M Zone
The Carlsbad Municipal Code Section 21.34.020 allows for residential uses in the P-M zone up
to a density of 40 dwelling units per acre subject to the issuance of a conditional use permit and
specific findings established in Municipal Code Section 21.42.140(B)(135). The development
project and recommendation balances the intent of these requirements and state laws, such as
the state’s Density Bonus Law and Senate Bill 330, which provide methods to waive certain
development requirements in exchange for providing affordable housing.
These bills also require that the maximum density allowed in either the city’s General Plan or
Zoning Ordinance be allowed in a housing development project. The findings included with the
project recommendation relate to:
•Concurrent processing of a development plan
•Aesthetic and functional integration with surrounding industrial land uses
•Maximum residential density
Generally, integrating residential land uses in the P-M zone is challenging because many areas
of the zone are industrially homogenous, and retail or medical uses are not allowed. The P-M
industrial lands in the city consist of buildings that are similar to each other or feature the same
business types – with similar manufacturing, processing, or storage operations. There has been
a recent trend in which the office market is changing along transportation corridors designed
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for planned industrial development to bring in more customer-serving businesses, such as
restaurants or athletic facilities that are allowed with conditional use permits. The industrially
zoned property in the immediate vicinity of the project site already contains a variety of office
and athletic facility uses, and there are additional commercial and residential uses beyond the
area designated as planned industrial development (P-M).
California Density Bonus Law
Definition
California’s Density Bonus Law gives a developer the legal right to increase the total number of
homes allowed on a property above a city’s maximum limits by as much as 100% in exchange
for making some of those units affordable to lower-income families. The law also allows
developers to reduce or exceed city established development standards such as building
setback requirements and building height limitations when those standards prevent them from
achieving the increased density allowed under state density bonus law.
Application – Density increase
Under the city’s General Plan, the designation for this site is Planned Industrial (PI) which does
not designate a density for the site. However, the site’s zoning, the P-M zone as designated in
the city’s Zoning Ordinance, allows for a maximum residential density of 40 dwelling units per
acre if specific findings are met and the project is approved by the City Council. That allows for
a maximum of 125 dwelling units on this 3.12-acre property.
To qualify the project under the state Density Bonus Law, California Government Code
Section 65915 et seq.,1 the developer will make 5% of the base dwelling units – seven of the 98
units – affordable to very low-income households.2 Restrictions will be placed on the property’s
deed requiring the affordable units to continue to be priced and rented to qualifying individuals
as affordable units for 55 years. This would entitle the developer to increase the density of the
project by 20%, which allows for an additional 25 units.3 However, the developer has chosen to
convert the existing 98 guest rooms into 98 residential units, rather than construct the 150
units allowed under state law.
Projects proposing certain percentages of affordable units can request incentives or
concessions from specific development standards, when modifying such standards would
provide “identifiable and actual cost reductions” to provide for affordable housing costs and
rents. Developers can also have development standards waived when such deviations are
needed to achieve the density allowed under state law.4
1 Et seq, or et sequentes, means all of the codes in the section cited, not just the single one cited.
2 The U.S. Department of Housing and Urban Development defines a very low-income household family as one whose income
does not exceed 50% of the average area median income for the region and a moderate-income household as one whose
income does not exceed 120% of the average area median income for the region. In 2024, HUD reported that the average area
median income for the San Diego County region is $119,500, so a very low-income family of four makes no more than $75,750
annually and a moderate-income family of four makes no more than $143,400 annually.
3 “Base density” unit yields are calculated based on provisions in Carlsbad Municipal Code Chapter 21.53, under which dwelling
units may be rounded up or down to the next whole number. However, in the context of state density bonus law, fractional units for “base density” and “total density” are rounded up to the next whole number. Therefore, the proposed project’s “total
allowed density” is 150 dwelling units.
4 Refer to Exhibit 7 for an informational bulletin that provides more information on how the state Density Bonus Law works and
is applied in the City of Carlsbad.
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Requested waivers
The application requests four density bonus waivers from the Carlsbad Municipal Code’s
development standards:
•Waiver of the inclusionary housing standard established in Carlsbad Municipal Code
Section 21.85.030(C), which requires developments that provide 10 or more units
affordable to lower-income households to provide at least 10% of the lower-income
units as three or more bedrooms. All the units in the proposed project, including the
market-rate units, are studios or one-bedrooms. The proposed project involves the
conversion of an existing hotel building to residential units, requesting minimal building
design changes. The building already contains numerous suitable features such as
established rooms and sleeping areas, communal spaces and multiple plumbing,
mechanical and electrical systems, which all can be leveraged when converting the
building to apartments or other uses. Since the project only consists of interior
renovations throughout the existing building, the proposed density, the number of
units, would not be achieved if existing studios and one-bedroom hotel units had to be
reconfigured to include three-bedroom units. Under the Density Bonus Law, should the
city fail to grant the waiver, such action would have “the effect of physically precluding
the construction of a development” that meets the criteria of the law.
•Waiver of residential planned development standard established in Carlsbad Municipal
Code Section 21.45.060 (Table C, C.2) requiring dwelling units adjacent to any arterial
road shown in the Circulation Element of the General Plan, the element focused on
transportation, to have a fully landscaped setback of 40 feet from prime arterial roads.
For this project, that would require a 40-foot setback from Cannon Road, while the
project proposes no setback for the area proposed for active community recreational
space. The waiver of standards for setbacks is necessary to accommodate the project’s
proposed pickleball courts and dog run.
•Waiver of the planned development standard established in Carlsbad Municipal Code
Section 21.45.060 (Table C, C.9), which requires community recreation space of 200
square feet per unit. For this project, 19,600 square feet would be required and 15,518
square feet is proposed. The property is mostly built out, lacking certain adaptive site
design elements. The applicant would be unable to convert the existing building to
apartments or other uses if the property had to be reconfigured to allow for the
required community recreation space. And, if the project were not built, housing units
for lower-income households would not be built and the intent of the Density Bonus
Law to encourage such development would not be achieved.
•Waiver of the planned industrial zone development standard established in Carlsbad
Municipal Code Section 21.34.070(A), which sets a maximum building height of 35 feet
with architectural projections permitted up to a maximum height of 45 feet. For this
project, the roof ridge is 36.9 feet high, the existing north tower is 45.6 feet and the
existing south tower 45.5 feet. The current project was constructed with a coastal
development permit (CDP 99-06) that was approved for the hotel that authorized a
height up to 45 feet, with architectural protrusions, consistent with the Municipal Code.
The building already contains numerous suitable features such as established floor-to-
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ceiling heights and tower elements. Since the project only consists of interior
renovations throughout the existing building, the applicant seeks to exceed previously
established limits on the height of structures or improvements on the property. Should
the city fail to grant the waiver, such action would have “the effect of physically
precluding the construction of a development” meeting the criteria of the density bonus
law.
Carlsbad Inclusionary Housing Ordinance
Definition
To help address the ongoing need for affordable housing, the city adopted an Inclusionary
Housing Ordinance (Carlsbad Municipal Code Chapter 21.85) in 1993 that established the legal
basis for requiring affordable – or inclusionary – housing units in new residential development
in the city. The law, which applies to all proposed development projects that include residential
units, requires that at least 15% of the base density units within a project be affordable to
lower-income households.
Application
In keeping with the Inclusionary Housing Ordinance, 15% of the base units, or 15 units, shall be
constructed and restricted both as to occupancy and affordability to lower-income households.
(For this project, 98 units X 15% = 15 units, or 14.7 rounded up). Under the Density Bonus Law,
affordable units required under a jurisdiction’s inclusionary regulations also satisfy the
affordable units required under the state density bonus. The application proposes that seven
units be reserved for very low-income families, which satisfies both density bonus and
inclusionary requirements and an additional five units be reserved for low-income families and
three units for moderate-income families, which satisfies the inclusionary housing
requirements, for a total of 15 proposed affordable units.5
State housing laws and limits to local control
Overview
Over the past decade, the California Legislature has amended state law to expand and
strengthen measures intended to create more affordable housing, in recognition of the
critically low volumes of housing stock across the state and the belief that local jurisdictions are
not doing enough to address the need for more affordable housing. In response, most bills
passed by the Legislature have made it easier and faster for housing projects to be approved
while limiting a local government’s ability to deny, reduce the density of or make infeasible
those housing projects.
5 Consistent with City Council Policy 57, applicants are allowed some flexibility in how the inclusionary units are
distributed across income categories, provided the overall requirement is met and the average income restriction
does not exceed 80% of the region’s area median income. This approach recognizes that housing needs span
various income levels and encourages projects to provide a mix that better reflects community needs. The
proposed composition of income levels is an average of 74% of area median income, which meets the requirement
(average not to exceed 80% low-income affordability level) allowable under the city’s alternatives identified in
Council Policy 57.
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The specific housing laws that are being applied to the proposed development project and are
worth highlighting are:
State Density Bonus Law
As stated above, under state law projects that restrict a percentage of units as affordable are
entitled to a density increase above a city’s density maximums. Local jurisdictions cannot deny
or limit the density increase, nor can the city require the applicant to submit an amendment to
the city's General Plan to reflect the increase in housing units. This is a developer right under
state law.
The Density Bonus Law also allows applicants concessions or incentives from certain
requirements and waivers of development standards. State law does give local cities the ability
to deny waivers, but the findings are, by design, extremely difficult to make.
•To deny a waiver, the city must make a written finding, based on substantial evidence,
that the concession or incentive would have a specific adverse impact on public health
and safety and conclude that there is no feasible method to satisfactorily mitigate or
avoid the impact.
•A specific adverse impact means a significant, quantifiable, direct and unavoidable
impact based on objective, identified written public health or safety standards, policies
or conditions as they existed on the date the application was deemed complete.
This is a high bar to overcome and both cities and community groups have previously tried to
challenge such waivers, only to be denied in court. For example, in 2022, the state Court of
Appeal ruled in the case of Bankers Hill 150 v. City of San Diego that the developers of density
bonus projects are entitled to waive development standards that would prevent the project
from being built as designed – even if the project could be redesigned to comply with the
relevant standards. In other words, the courts have held that a city cannot redesign a qualifying
density bonus project on the theory that, if the project were configured differently, it would not
need the requested waivers.
State Housing Accountability Act
The Housing Accountability Act, Government Code Section 65589.5, limits a local government’s
decision-making authority over certain housing development projects. The legislature first
enacted the act in 1982 and has amended the law over the years. It now involves a multitude of
interconnected and overlapping Government Code sections. Many of the most significant
amendments were added in the past seven years.
Most notably, the Housing Accountability Act states that when a proposed housing
development project for very low, low, or moderate income households complies with the
applicable general plan, zoning, subdivision standards and objective design criteria that were in
effect at the time that the application was deemed complete, cities cannot disapprove the
housing development project or impose a condition which would render the project infeasible
unless the city finds, based on a preponderance of evidence, that:
•The project would have a specific, adverse impact on public health and safety, unless
disapproved or approved at a lower density; and
•There is no feasible method to satisfactorily mitigate or avoid the adverse impact.
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A “specific, adverse impact” means a significant, quantifiable, direct and unavoidable impact,
based on objective, identified written public health or safety standards, policies, or conditions
as they existed on the date the application was deemed complete. For the proposed
application, city staff found no “specific, adverse impact” that could not be mitigated or
adequately addressed.
State Housing Crisis Act
The Housing Crisis Act of 2019, commonly referred to as Senate Bill 330, amended the Housing
Accountability Act, with several pro-housing provisions that further limited a city’s ability to
deny an application for a housing project that meets established development requirements.
The Housing Crisis Act also placed limits on permit processing.
The law:
•Allows certain projects to establish vesting rights that limit the city to only applying
those codes, requirements and fees that were in place at the time the application was
filed
•Shortened the timelines allowed to review applications
•Limits the number of public meetings to five, which includes any required community
meetings
•Requires that any new requirement established must be objective, meaning clear and
measurable, or provides specific direction for how to apply requirements, criteria or
standards
•Prohibits a city from “downzoning” properties, that is, reducing residential density,
through land use designations or other development standards unless a city
concurrently “upzones” another location to ensure there is no net loss in residential
capacity
•Prohibits a city from imposing housing caps or moratoriums on housing developments
Planning Commission
The Planning Commission considered the project on Aug. 20, 2025. No community members
provided comments at the hearing. The Planning Commission voted unanimously with the six
commissioners present to recommend approval of the project to the City Council. The minutes
of the meeting are provided as Exhibit 4.
Public notification
Public notice of this meeting, as well as for the Planning Commission hearing, was mailed to
property owners within 600 feet and occupants within 100 feet of the project site and posted in
accordance with the requirements of the Ralph M. Brown Act, California’s open meeting law.
Information regarding public notification of this item such as mailings, public hearing notices
posted in a newspaper of general circulation and on the city’s website are available in the Office
of the City Clerk.
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The project is also subject to City Council Policy No. 84 - Development Project Public
Involvement Policy. 6 As required by that policy, the developer completed the enhanced
stakeholder outreach program. In this case, the developer mailed an information packet to all
owners of property located within a 600-foot radius and all residents within a 100-foot radius of
the project site. The information packet included a detailed description of the project, along
with the site plan, topographic survey, colored elevations and a colored rendering. The
developer also included a pre-paid stamped envelope and a comment card. In compliance with
that policy:
•A notice of the project application was initially mailed on Dec. 22, 2024, to all owners of
property located within a 600-foot radius.
•A two-foot-tall by three-foot-wide yellow sign was also posted at the project site on
Dec. 22, 2024.
•A total of 37 property owners were notified through the notice of project application.
All comment letters received during the processing of this project have been compiled and are
included in Exhibit 8. Some comments are duplicated from the Planning Commission staff
report but are included separately to make sure a complete record of comments are accessible
in one place. Any comments received after the publishing of this report will be posted by the
City Clerk and distributed to the City Council.
The public comments received raised concerns regarding noise caused by the proposed
pickleball courts, the number of units proposed and the lack of kitchen appliances in the
existing guestrooms. A response to the concerns can be found in the staff report presented to
the Planning Commission, Exhibit 3.
Fiscal Analysis
There is no direct fiscal impact associated with the proposed project aside from the loss of
transit occupancy tax revenues from the hotel, which is estimated between $150,000-$250,000
per year for a hotel like this one.
Next Steps
If the project is approved, the next steps for development would be the design development
phase, with construction drawings. Construction drawings, such as grading and building plans
would need to be reviewed and approved by the city before it would authorize construction
work. The specific schedule would be determined by the applicant. Grading and building
permits typically take between six and twelve months to process. If approved, the coastal
development permit amendment, conditional use permit and planned development permit will
expire in two years unless construction commences and could be extended for up to six
additional years.
6 This project was submitted before recent updates to City Council Policy No. 84.
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Environmental Evaluation
The proposed action to convert a 98-guestroom hotel into a 98-unit multi-family dwelling is
categorically exempt from environmental review under CEQA Guidelines section 15332 (Class
32 – Infill Development Projects) because it is consistent with the General Plan and Zoning
Ordinance. The project site is within the city limits, is less than five acres in size and is
surrounded by urban uses. There is no evidence that the site has value as habitat for
endangered, rare, or threatened species. Approval of the project will not result in significant
effects relating to traffic, noise, air quality, or water quality. The site can be adequately served
by all required utilities and public services. No exceptions to the categorical exemption as set
forth in CEQA Guidelines Section 15300.2 or Carlsbad Municipal Code Section 19.04.070(C)
apply. The notice of exemption will be filed with the Recorder/County Clerk within five days
after project approval by the decision-making body.
Exhibits
1.City Council resolution
2.Location map
3.Staff Report from Aug. 20, 2025, Planning Commission Meeting (on file in the Office of the
City Clerk)
4.Minutes from Aug. 20, 2025, Planning Commission Meeting (on file in the Office of the City
Clerk)
5.Planning Commission Resolution No. 7548 (on file in the Office of the City Clerk)
6.Draft notice of California Environmental Quality Act exemption
7.Informational Bulletin IB-112 – State Density Bonus Law
8.Correspondence received through Wednesday, Oct. 22, 2025, at noon
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Exhibit 1 RESOLUTION NO. 2025-238 .
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD,
CALIFORNIA, APPROVING A CALIFORNIA ENVIRONMENTAL QUALITY ACT
EXEMPTION DETERMINATION AND APPROVING A COASTAL DEVELOPMENT
PERMIT AMENDMENT, CONDITIONAL USE PERMIT, AND PLANNED
DEVELOPMENT PERMIT TO ALLOW FOR THE CONVERSION OF AN EXISTING
THREE-STORY, 98-GUEST ROOM HOTEL INTO A 98-UNIT MULTI-FAMILY
RENTAL PROJECT ON A 3.12-ACRE SITE LOCATED AT 5010 AVENIDA
ENCINAS, WITHIN THE MELLO II SEGMENT OF THE LOCAL COASTAL
PROGRAM AND WITHIN LOCAL FACILITIES MANAGEMENT ZONE 3.
CASE NAME: INNS OF AMERICA
CASE NO.: AMEND 2024-0008/CUP 2024-0009/PUD 2024-0009
(DEV99017)
WHEREAS, the City Council of the City of Carlsbad, California has determined that pursuant to
the provisions of the Municipal Code, the Planning Commission did, on Aug. 20, 2025, hold a duly
noticed public hearing as prescribed by law to consider Coastal Development Permit Amendment,
AMEND 2024-0008, Conditional Use Permit, CUP 2024-0009, and Planned Development Permit, PUD
2024-0009, as referenced in Planning Commission adopted Resolution No. 7548 recommending to the
City Council that it be approved; and
WHEREAS the City Council of the City of Carlsbad held a duly noticed public hearing to consider
said coastal development permit amendment, conditional use permit, and planned development
permit; and
WHEREAS, at said public hearing, upon hearing and considering all testimony and arguments, if
any, of all persons desiring to be heard, the City Council considered all factors relating to the coastal
development permit amendment, conditional use permit, and planned development permit.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as
follows:
1.That the above recitations are true and correct.
2.Compliance with California Environmental Quality Act. The proposed action to convert
a 98-guestroom hotel into a 98-unit multi-family dwelling is categorically exempt from environmental
review under CEQA Guidelines section 15332 (Class 32 – Infill Development Projects) because it is
consistent with the General Plan and Zoning Ordinance. The project site is within the city limits, is less
than five acres in size and is surrounded by urban uses. There is no evidence that the site has value as
habitat for endangered, rare, or threatened species. Approval of the project will not result in significant
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effects relating to traffic, noise, air quality, or water quality. The site can be adequately served by all
required utilities and public services. No exceptions to the categorical exemption as set forth in CEQA
Guidelines Section 15300.2 or Carlsbad Municipal Code Section 19.04.070(C) apply. The notice of
exemption will be filed with the Recorder/County Clerk within five days after project approval by the
decision-making body.
3.That the recommendation of the Planning Commission for the approval of Coastal
Development Permit Amendment, AMEND 2024-0008, Conditional Use Permit, CUP 2024-0009, and
Planned Development Permit, PUD 2024-0009, is adopted and approved, and that the findings and
conditions of the Planning Commission contained in the Planning Commission adopted Resolution No.
7548 on file with the City Clerk and incorporated herein by reference, are the findings and conditions
of the City Council.
4.That the following conditions are also adopted:
a.Prior to obtaining and securing building permits, the Developer shall submit a
written declaration from the seller/hotel operator to the Housing & Homeless
Services Director attesting that any person who has occupied a unit in the existing
hotel for more than 30 consecutive days and will be temporarily or permanently
displaced by the project received advanced notice to vacate the premises and
information regarding potential rights that may be required or afforded under
California Government Code Section 66300.6 or other state law intended to assure
replacement and/or ongoing affordability of existing residential units to the extent
such state law is applicable.
b.Prior to obtaining and securing building permits, the Developer shall submit a
written declaration from the seller/hotel operator to the Housing & Homeless
Services Director attesting that any person who has occupied a unit in the existing
hotel for more than 30 consecutive days and will be temporarily or permanently
displaced by the project received advanced notice to vacate the premises and
information regarding potential rights that may be required or afforded under
California Government Code Section 66300.6 or other state law intended to assure
replacement and/or ongoing affordability of existing residential units to the extent
such state law is applicable.
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5. This action is final the date this resolution is adopted by the City Council. The Provisions
of Chapter 1.16 of the Carlsbad Municipal Code, “Time Limits for Judicial Review” shall apply:
“NOTICE”
The time within which judicial review of this decision must be sought is governed by Code of Civil
Procedure, Section 1094.6, which has been made applicable in the City of Carlsbad by Carlsbad
Municipal Code Chapter 1.16. Any petition or other paper seeking review must be filed in the
appropriate court not later than the ninetieth day following the date on which this decision becomes
final; however, if within ten days after the decision becomes final a request for the record is filed with
a deposit in an amount sufficient to cover the estimated cost or preparation of such record, the time
within which such petition may be filed in court is extended to not later than the thirtieth day following
the date on which the record is either personally delivered or mailed to the party, or his attorney of
record, if he has one. A written request for the preparation of the record of the proceedings shall be
filed with the City Clerk, City of Carlsbad, 1200 Carlsbad Village Drive, Carlsbad, CA 92008.
PASSED, APPROVED AND ADOPTED at a Regular Meeting of the City Council of the City of
Carlsbad on the 28th day of October, 2025, by the following vote, to wit:
AYES: Blackburn, Bhat-Patel, Acosta, Burkholder, Shin.
NAYS: None.
ABSTAIN: None.
ABSENT: None.
______________________________________
KEITH BLACKBURN, Mayor
______________________________________
SHERRY FREISINGER, City Clerk
(SEAL)
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AMEND 2024-0008/CUP 2024-0009/ PUD 2024-0009 (DEV99017)
INNS OF AMERICA
SITE MAP
J
SITE
Map generated on: 7/11/2025
Exhibit 2
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Exhibit 3
Staff Report from Aug. 20, 2025,
Planning Commission Meeting
(on file in the Office of the City Clerk)
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Exhibit 4
Minutes from Aug. 20, 2025,
Planning Commission Meeting
(on file in the Office of the City Clerk)
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Exhibit 5
Planning Commission Resolution No. 7548
(on file in the Office of the City Clerk)
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NOTICE OF EXEMPTION
To: Assessor/Recorder/County Clerk From: CITY OF CARLSBAD
Attn: Fish and Wildlife Notices Planning Division
1600 Pacific Highway, Suite 260 1635 Faraday Avenue
San Diego CA 92101 Carlsbad, CA 92008
MS: A-33 (442) 339-2600
Subject: Filing of this Notice of Exemption is in compliance with Section 21152b of the Public Resources
Code (California Environmental Quality Act).
Project Number and Title: AMEND 2024-0008/CUP 2024-0009/ PUD 2024-0009 (DEV99017) - INNS OF
AMERICA
Project Location - Specific: 5010 Avenida Encinas, Carlsbad, CA 92008 (APN 210-090-52-00)
Project Location - City: Carlsbad Project Location - County: San Diego
Description of Project: The Project Applicant seeks a Conditional Use Permit (CUP) and Planned
Development Permit (PUD) to convert an existing 98-room hotel into a 98-unit multi-family apartment
building on 3.12 acres, 15 of which (or 15 percent of the total units) will be restricted as affordable units
(51-80% AMI) to meet the city’s inclusionary housing requirements. The Project proposes providing seven
(7) very low, five (5) low and three (3) moderate income deed restricted units among the 98 units
proposed.
The existing structure is three stories and 36.8-feet tall, with two architectural towers at 45.5-feet tall and
a third architectural tower at 45.6-feet tall. The Project site includes 123 uncovered surface parking
spaces, 98 of which will be assigned to the residential units. The remaining 25 parking spaces will be used
as visitor spaces, loading spaces and mail delivery spaces.
The Project includes the following exterior site improvements: two pickleball courts (4,290 square-foot
total), surrounded by a six-foot-tall fence, a 989 square-foot dog run area enclosed by a four foot-tall
fence, a 308 square-foot bicycle and surfboard storage and maintenance shed, and new landscaping
including the restoration and replacement, as needed, of existing plantings.
The Project site is designated as PI, Planned Industrial (PI) in the General Plan and is Zoned Planned
Industrial (P-M). Multifamily residential uses which serve to house the employees of businesses located
in the P-M Zone, may be conditionally permitted subject to the approval of a Major CUP and Major PUD
by the City Council. The Project site is within the Commercial/Visitor-Serving Overlay Zone, and the Mello
II Segment of the Coastal Zone. It is located outside of the California Coastal Commission appeal area. The
adjacent property to the north is designated for Visitor Commercial (VC); Interstate-5 (I-5), which is east
of the Project site, is designated Transportation Corridor (TC); the property to the south is designated for
Planned Industrial (PI); and the site to the west is designated for Residential (R-30, 26.5-30 dwelling units
per acre [du/ac]).
The project site is located approximately 1.8 miles from the Poinsettia Train Station and approximately
0.36 miles from the Pacific Ocean. The property has frontage on Cannon Road to the north and Avenida
Encinas to the west. It is surrounded by a variety of urban uses, including a gas station and convenience
Exhibit 6
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store across Cannon Road to the north, the southbound I-5 entrance ramp to the east, an office building
to the south, and a vehicle storage parking lot across Avenida Encinas to the west.
The proposed earthwork quantities consist of an excavation of 180 cubic yards (cy) of cut material, 20 cy
of fill material with 160 cy of material exported from the site. Anticipated maximum excavation cut depth
will be approximately 1.5 feet and anticipated maximum fill depth will be 0.5 feet.
The Project proposes the following density bonus waivers:
• Carlsbad Municipal Code (CMC) § 21.85.030(C), developments which provide 10 or more units
affordable to lower-income households shall provide at least 10% of the lower-income units as
three or more bedrooms. The Project proposes 73 studios and 25 one-bedroom units. The Project
is the conversion of an existing hotel; retention of the existing unit types is proposed to avoid a
reduction in the total number of units. The existing hotel consists of a mixture of studio and one-
bedroom guest rooms and does not contain any three-bedroom guest rooms, therefore none are
proposed a part of the proposed conversion to residential.
• CMC § 21.45.060, Table C, Ref. No. C.2: 40-foot landscape setback from Major Arterial Roads
(Cannon Road). The Project proposes to install Project amenities in the setback, specifically the
dog run, pickleball courts, and bicycle/surf board storage and maintenance shed.
• CMC § 21.45.060, Table C, Ref. No. C.9: 200 square feet of community recreational space per unit
(19,600 square feet). The Project proposes a total of 15,518 square feet of community recreational
space, which equates to 158 square feet of community recreational space per unit.
• CMC § 21.34.070: Maximum building height of 45 feet. The Project includes two existing
architectural towers at 45.5-feet tall and a third architectural tower at 45.6-feet tall.
Name of Public Agency Approving Project: City of Carlsbad
Name of Person or Agency Carrying Out Project: Alliance Development Services
Name of Applicant: Jim McMenamin
Applicant’s Address: 17828 Villamoura Drive, Poway, CA 92064
Applicant’s Telephone Number: (858) 705-0242
Name of Applicant/Identity of person undertaking the project (if different from the applicant above):
Exempt Status: Exemption: Class 32, Section 15332 (In-Fill Development Projects)
Reasons why project is exempt: The Project qualifies for a Class 32 categorical exemption under the
California Environmental Quality Act (CEQA). Pursuant to CEQA Guidelines Section 15332, Class 32
categorical exemptions can be used for projects characterized as in-fill development meeting the
following conditions: (1) general plan and zoning consistency; (2) project is within city limits on a site of
no more than 5 acres and is substantially surrounded by urban uses; (3) project site has no value as habitat
for endangered, rare, or threatened species; (4) project would not result in significant effects to traffic,
noise, air quality, or water quality; and (5) the site can be adequately served by all required utilities and
public services. Additionally, in order to qualify for a categorical exemption, a project cannot meet any of
the "exceptions to exemptions" enumerated in CEQA Guidelines Section 15300.2.
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A. General Plan and Zoning Consistency: The Project is consistent with the applicable General Plan
designation and all applicable General Plan policies, as well as with the applicable zoning designation and
regulations.
A1. City of Carlsbad General Plan
The City General Plan sets forth goals and policies that guide both citywide and community specific goals
and policies to guide the physical, social, and economic growth of the city.
A1(a). Land Use and Community Design Element
The Land Use and Community Design Element establishes general policies and the vision for the future of
the City. Land use, housing, urban form and neighborhood design, open space, economic development,
transportation, and infrastructure and public services are all addressed in the context of accommodating
future development.
The Project is consistent with the applicable Land Use and Community Design Element's goals and policies.
• Goal G.2 Promote a diversity of compatible land uses throughout the city, to enable people to live
close to job locations, adequate and convenient commercial services, and public support systems
such as transit, parks, schools, and utilities.
• Goal G.3. Promote infill development that makes efficient use of limited land supply, while
ensuring compatibility and integration with existing uses. Ensure that infill properties develop with
uses and development intensities supporting a cohesive development pattern.
• Goal G.6. Allow a range of mixed-use centers in strategic locations that maximize access to
commercial services from transit and residential areas.
• Goal G.30. Encourage the provision of lower and moderate-income housing to meet the objectives
of the Housing Element.
• Goal G.4 Provide balanced neighborhoods with a variety of housing types and density ranges to
meet the diverse demographic, economic and social needs of residents, while ensuring a cohesive
urban form with careful regard for compatibility.
• Goal G.1 New housing developed with diversity of types, prices, tenures, densities, and locations,
and in sufficient quantity to meet the demand of anticipated city and regional growth and to meet
or exceed the city’s established Regional Housing Needs Allocation (RHNA).
• Goal P.6 Encourage medium to higher density residential uses located in close proximity to
commercial services, employment opportunities and major transportation corridors.
And the Project is consistent with the following General Plan policies:
• P.1: Maintain consistency between the General Plan and Title 21 of the CMC (Zoning Ordinance
and map).
• P.6: Encourage the provision of lower and moderate-income housing to meet the objectives of the
Housing Element.
• P.13: Encourage medium to higher density residential uses located in close proximity to
commercial services, employment opportunities and major transportation corridors.
• P.3: Provide alternative housing opportunities by encouraging adaptive reuse of older commercial
or industrial buildings.
The Project site and adjacent properties are highly developed; surrounding land uses include a mix of
office commercial and industrial park uses. Specifically, a gas station and convenience store are located
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across Cannon Road to the north, the southbound I-5 entrance ramp to the east, an office building to the
south, and a vehicle storage parking lot across Avenida Encinas to the west. Additionally, The Project is
the conversion of an existing 98-room hotel into a 98-unit multi-family apartment building, 15 of which
(or 15 percent of the total units) will be restricted as affordable units (51-80% AMI) to meet the City’s
inclusionary housing requirements. The Project proposes providing seven (7) very low, five (5) low and
three (3) moderate income deed restricted units among the 98 units proposed.
The General Plan designates the Property as Planned Industrial (PI) and the site is zoned Planned Industrial
(P-M). The PI designation, which “is intended to provide and protect industrial lands primarily for
corporate office, research and development (R&D) and manufacturing uses”, permits ancillary
commercial uses, but it does not allocate density to the site. Rather, the implementing zoning district, the
P-M Zone (CMC Chapter 21.34), “allow[s] the location of business and light industries engaged primarily
in research and/or testing, compatible light manufacturing, and business and professional offices; allow
certain commercial/ retail uses which cater to, support, or are accessory to the uses allowed in this zone;
and allow[s] flexibility for other select uses (i.e., athletic clubs/gyms, churches, daycare centers, recreation
facilities, etc.) when found to be compatible with the P-M Zone through the issuance of a CUP.” Residential
uses are permitted in the P-M Zone with a CUP and subject to specific distance requirements. The
maximum allowable density is 40 dwelling units per acre. Recognizing this, the Project can be found
consistent with the standards and criteria of the Land Use Element portion of the General Plan for the site
and the zoning standards of the P-M Zone. Under the provisions of CMC Section 21.42.140 (Development
standards and special regulations), the maximum permitted number of units conditionally permitted on
the Project site is 124 dwelling units (40 dwelling units per acre).
State Density Bonus law (California Government Code Sections 65915 – 65918) entitles a property owner
or developer to build more housing units than a local zoning ordinance would otherwise allow, if they
reserve a share of the units for lower, very low, senior or moderate-income households. Applying this
state law allowance, the developer proposes a Project with a density of 31.4 dwelling units per acre, which
is below the city’s maximum density for this site, 23 dwelling units per acre. (The Project proposes 27
fewer dwelling units than the maximum number permitted in the density range. The Project, as built,
therefore, shall not exceed the maximum allowable density of 40 dwelling units per acre.) Under State
Density Bonus Law, in return, at least 15% of the proposed units will be deed-restricted as affordable.
Density bonus and related incentives/concessions, waivers/reductions of development standards, or
reduced parking ratios shall not be grounds for an inconsistency determination. As part of the application,
four (4) waivers from certain city development standards and objective design standards are requested
to accommodate the density bonus.
The Project includes a CUP and PDP, pursuant to the applicable zoning code provisions. The Project is
located at the northwest corner of Avenida Encinas and Cannon Road within a large industrial area
occupied by a variety of uses consistent with the PM – Planned Industrial Zone. The Project was originally
built and designed to serve the long-term accommodation needs of the adjacent businesses located in the
industrial park to provide convenience and home-like amenities for visiting employees. As such, the
converted hotel will transition seamlessly and remain an integral part of the existing industrial park.
Over 25 locally serving businesses are located within 5,900 feet of the Project site along Avenida Encinas.
The nearby businesses encompass a wide range of goods and commercial and professional services
including insurance providers, realtors, medical, dental and professional offices, design and marketing
firms, professional consultants, tax preparation and accounting, employment firms, mortgage companies,
and home health services. A credit union is located within 2.7 miles (or a ten-minute drive) and 15
restaurants are situated within a one-mile radius.
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The Project, which includes 27,533 square feet of landscaping in compliance with the P-M Zone, will
provide visual relief to the future residents of the apartments, buffering from adjacent commercial/light
industrial uses and an enhanced outlook to the existing industrial park. The Project also includes an
enclosed swimming pool, and two pickleball courts (approximately 2,000 square feet each, surrounded
by 6-foot-tall fencing), an approximately 990 square foot dog run area enclosed by 4-foot-tall fencing, and
a 308 square foot bike and surfboard storage enclosure located on the northerly side of the main building
to provide additional buffering from surrounding uses. The Project’s existing structure, which will remain
intact, is characterized by a contemporary southwestern style architecture. The Project, therefore, has
been designed to be compatible with the surrounding business park.
The Project site is in close proximity to I-5, is served by two arterial streets, Cannon Road and Palomar
Airport Road, and is located along a Neighborhood Connector Street, Avenida Encinas. It is located within
2 miles of the Poinsettia Train Station. Pursuant to the General Plan, Avenida Encinas, as a Neighborhood
Connector Street, is designed to safely move all modes of travel while enhancing mobility for pedestrians
and bicyclists. As part of the Coastal Rail Trail, it is a public transit corridor which features buffered Class
II bike lanes, delineated by pavement striping and signs, non-contiguous sidewalks, and adjacent
landscaping to provide bicycle and pedestrian access between the residential and nearby commercial
services and employment uses.
The Project includes a secure bicycle storage/maintenance shed with twenty-four (24) long term bicycle
parking spaces, four (4) bicycle charging outlets, a bicycle maintenance station, and motion sensor LED
lighting. The shed will be located in a secure location in the northwest portion of the lot. Access though
a 3’6” wide metal gate will require a resident key fob. Additionally, the Project is adjacent to a future
enhanced intersection at Cannon Road and Avenida Encinas. It is a component of the Terramar Area
Coastal Improvements Project. The Project and its residents shall benefit from convenient and efficient
vehicular, bicycle, and pedestrian transportation modalities.
A1(b). Noise Element Consistency
The Noise Element of the City's General Plan includes policies that are designed to ensure protection from
noise for sensitive uses. The Noise Element provides acceptable limits of noise for various land uses for
both exterior and interior environments from transportation. Table 5-2 indicates acceptable limits of noise
for various land uses for both exterior and interior environments from transportation sources. While Table
5-1 establishes standards to help the city determine the appropriateness of locating specific uses in noise-
prone environments, Table 5-2 provides standards that development shall attain through noise
attenuation measures.
General Plan Policy 5-99.2 requires a noise analysis to be conducted for all discretionary development
proposals (except for developments of single-family homes with four (4) units or fewer) located where
projected noise exposure would be other than “normally acceptable.” The Project is located within the
70+ CNEL noise contour line of the Noise Contour Map as part of the Carlsbad General Plan. Pursuant to
Table 5-1, noise levels between 70 and 75 dBA DNL are normally unacceptable, and should only proceed
if a detailed analysis of the noise reduction requirements are made and needed noise insulation features
are included in the design. As the project noise exposure would be other than “normally acceptable”, a
Noise Analysis was prepared by dBA Associates, Inc. (Attachment 1). The Noise Analysis assesses potential
noise impacts that could occur under the Project. The Noise Analysis includes the following components:
documentation of existing noise conditions, discussion of noise modeling methodology and procedure,
and analysis of land use compatibility, traffic noise, and on-site Project generated noise sources (e.g.,
outdoor-pickle ball courts).
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Exterior Noise
Table 5-2 of the Noise Element indicates that the normal allowable exterior noise exposure is 60 dBA CNEL
for residential uses. However, footnote 4 of Table 5-2 clarified that exterior noise exposure level of 65
dBA CNEL is allowable for residential uses within the McClellan-Palomar Airport Area of Influence,
pursuant to the noise compatibility policies contained in the Airport Land Use Compatibility Plan (ALUCP).
The project site is within the Airport Area of Influence, therefore exterior noise exposure levels of 65 dBA
CNEL is acceptable. The Project as built includes outdoor usable space: a swimming pool, dog run, pickle
ball courts, and a bicycle and surfboard storage and maintenance shed. These exterior use areas will not
be subject to noise exposure levels that exceed the City's 65 decibel (dBA) Community Noise Equivalent
Level ( CNEL) standard. Noise levels at the outdoor use areas would range from roughly 55-63 dBA CNEL.
The Project complies with the exterior noise exposure levels and policies of the General Plan Noise
Element.
Interior Noise
Pursuant to Table 5-2 of the Noise Element allowed noise exposure for interior spaces of residential land
uses is 45 dBA CNEL. The Acoustical Analysis for the original project building [Brown-Buntin Associates,
Inc. 2000] indicated that the windows facing I-5 were Sound Transmission Class (STC) 35, and all others
were (STC) 34. This analysis conducted for the Project corroborated this design requirement with field
testing measurements. As the building envelope demonstrably provides 35.8 dBA of noise reduction, the
interior noise level within any residential room would be a maximum of roughly 37 dBA CNEL.
Moreover, pursuant to CMC Section 18.04.080, any new residence or addition of one or more habitable
rooms to an existing residence located within the noise impact boundary of an airport or freeway must
be designed to ensure that internal noise levels due to airport or freeway operations do not exceed 45
dB. This standard may be satisfied by performing acoustical analysis or by employing the prescribed
construction methods described in this code section. The Project would not be built without adequately
demonstrative compliance with the California Building Code, as locally amended. The Project complies
with the interior noise exposure levels and policies of the General Plan Noise Element.
Airport Noise
There are no airports or private airstrips within the vicinity of the Project. As noted above, the Project site
is located within the McClellan-Palomar Airport Influence Area (AIA). The General Plan allows for an
exterior noise exposure level of 65 dBA CNEL for residential uses within the AIA, pursuant to the noise
compatibility policies contained in the ALUCP Airport Land Use Compatibility Plan. Therefore, the Project
is consistent with the applicable policies included in the Noise Element of the General Plan.
A1(c). Housing Element Consistency
The Housing Element of the City's General Plan provides the City with long-term goals, policies and
programs for promoting the production and conservation of safe, decent, and affordable housing within
the community. The Project is consistent with the applicable goals and policies of the Housing Element:
• Goal G.l. Housing Opportunities. New housing developed with diversity of types, prices, tenures,
densities, and locations, and in sufficient quantity to meet the demand of anticipated city and
regional growth and to meet or exceed the city's established RHNA).
• Policy P.4. Encourage increased integration of housing with nonresidential development where
appropriate and where residential development can be implemented in a way that is compatible
with existing and planned uses.
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• Policy P.7. Encourage distribution of development of affordable housing throughout the city to
avoid over concentration in a particular area, excluding areas lacking necessary infrastructure or
services.
• Goal G.2. Housing Implementation. Sufficient new, affordable housing opportunities in all
quadrants of the city to meet the needs of current lower- and moderate-income households and
those with special needs, and a fair share proportion of future lower- and moderate-income
households.
• Policy P.16. Address the unmet housing needs of the community through new development and
housing that is set aside for lower- and moderate income households consistent with priorities set
by the Housing Services Division, in collaboration with the Planning Division, and as set forth in
the city's Consolidated Plan.
The Project will add 98 new dwelling units to this area, including 15 affordable units with the following
mix of affordable housing categories:
Count Very Low Low Moderate
AMI 50% 80% 120% Total
Studios 6 3 2 11
1BRs 1 2 1 4
Total 7 5 3 15
The Project delivers affordable and workforce housing to serve the employees of the diverse range of
commercial services and employment uses in the existing job center in which it is located and the
surrounding community.
A measure of compliance with State Housing Element Law is the ability of a jurisdiction to accommodate
its share of the region's housing needs. The State Department of Housing and Community Development
(HCD) projected a need for 171,685 new housing units in the San Diego County region for an 8.8-year
projection period between June 30, 2020 and April 15, 2029.
The city's share of the region's RHNA allocation is 3,873 units and is broken down among the following
income distribution:
• Very Low-income: 1,311 units (34 percent)
• Low-income: 784 units (20 percent)
• Moderate Income: 749 units (19 percent)
• Above Moderate Income: 1,029 units (27 percent)
The Project would convert an existing 98-room hotel to a 98-unit multifamily project including 7 very low-
income units, 5 low-income units and 3 moderate income units, which help the city make progress
towards reaching its RHNA annual production goals for the planning cycle. This satisfies the requirements
of both State Density Bonus Law and the city’s Inclusionary Housing Ordinance. The Project has a proposed
density of approximately 32 dwelling units per acre. Under State Density Bonus Law, Projects proposing
certain percentages of affordable units can request incentives or concessions from specific requirements,
when modifying such regulations would provide “identifiable and actual cost reductions” to provide for
affordable housing costs and rents. Developers can also have development standards waived or revised
when such deviations are needed to achieve the density allowed under State law. The project proposes
four (4) density bonus waivers from CMC development standards.
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A2. City of Carlsbad Zoning Standards
As discussed earlier, multi-family use is allowed in the P-M Zone, subject to CUP and PUD approvals. The
Project proposes for rent market-rate and affordable housing on a site at an entry point to the city
surrounded by development with multiple existing employment options, east of a single-family
neighborhood zoned as R-4 and adjacent to the I-5.
The CMC further states in Section 21.42.140 that one-family dwellings, two-family dwellings and multiple-
family dwellings or a combination thereof, which serve to house the employees of businesses located in
the P-M Zone, may be conditionally permitted subject to the following findings:
a. A Planned Development Permit for the project has been approved, or is approved concurrently
with the conditional use permit, by the City Council.
b. The residential development is an integral part of an industrial park or large industrial use.
c. The residential development is designed to be compatible with the industrial use it serves by
means of landscaping, open space separations, etc.
d. The industrial development served by the residential development shall provide for convenient
and efficient vehicular, bicycle or pedestrian transportation to and from the residential
development.
e. The maximum allowable density for the residential development shall be established by the City
Council but in no event shall the density exceed 40 dwelling units per acre.
The Project would convert an existing 98-room hotel to a 98-unit multifamily project including 7 very low-
income units, 5 low-income units and 3 moderate income units, which help the city make progress
towards reaching its RHNA annual production goals for the planning cycle. This satisfies the requirements
of both State Density Bonus Law and the city’s Inclusionary Housing Ordinance. The Project has a proposed
density of approximately 32 dwelling units per acre.
Under the Housing Accountability Act, the standards and criteria determined to apply to the Project must
facilitate and accommodate development at the density allowed the general plan/zoning on the Project
site and as proposed by the Project. Moreover, California law requires that local jurisdictions provide
housing developers with density bonuses and other concessions or incentives when the developers agree
to provide a certain percentage of affordable housing, consistent with State Density Bonus Law (California
Government Code Sections 65915 – 65918). As discussed above, the Project would be developed
consistent with the Planned Industrial (P-M) Zone, the Commercial/Visitor-Serving Overlay Zone, and the
Mello II Segment of the Coastal Zone. Therefore, the proposed Project would meet this criterion.
B. Site Size and Location/Surrounding Land Uses: The proposed development occurs within city limits on
a Project site of no more than 5 acres substantially surrounded by urban uses.
The Project site is located on a 3.12-acre site located at 5010 Avenida Encinas (Assessor Parcel Number
210-090-52-00) within the Planned Industrial (PI) General Plan designator and the Planned Industrial (P-
M) Zone. Therefore, the Project is located entirely within the city. The Project site has been previously
developed and is surrounded by a variety of urban uses, including a gas station and convenience store
across Cannon Road to the north, the southbound I-5 entrance ramp to the east, an office building to the
south, and a vehicle storage parking lot across Avenida Encinas to the west.
As demonstrated, the Project site is substantially surrounded by urban uses and therefore meets the
criteria for site size and location.
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C. Habitat: The Project site has no value as habitat for endangered, rare, or threatened species.
The Project site and adjacent properties are highly developed; surrounding land uses include a mix of
office commercial and industrial park uses. The site is completely covered with existing pavement,
structures, and ornamental landscaping. It is developed with a hotel, swimming pool, and surface parking
lot. Vegetation on the site is limited to ornamental landscaping scattered throughout the Project site. No
native habitat is located on the Project site or on adjacent properties. Furthermore, the site is not within
mapped areas of potential critical habitat as depicted in the City's General Plan on Figure 4-2 Habitat
Management Plan Preserve Area in the Open Space, Conservation and Recreation Element. Based on the
urbanized nature of the Project site and adjacent properties, in conjunction with a lack of suitable habitat
for special-status species, the Project site has no value as habitat for endangered, rare, or threatened
species.
D. Traffic, Noise, Air Quality, & Water Quality: Approval of the Project would not result in any significant
effects relating to traffic, noise, air quality, or water quality.
D1. Traffic
The city's Vehicle Miles Traveled (VMT) Analysis Guidelines (Guidelines; City of Carlsbad May 2023)
provide a VMT analysis screening criteria for development projects, and identify the level of VMT analysis
methodology, level of significance, and mitigation based on the development's trip generation, the type
of development, the location of development within a transit priority area, and other elements. A CEQA
VMT Analysis (Screening Only) (Attachment 2) was prepared by Linscott, Law, and Greenspan Engineers
in compliance with CEQA Guidelines Section 15064.3 and the city's Guidelines.
VMT Screening Criteria
The city’s guidelines provide CEQA significance thresholds, screening criteria, and methodology for
conducting the transportation VMT analyses for a variety of land uses. Per city guidelines, the
requirements to prepare a detailed transportation VMT analysis apply to all land development projects,
except those that meet at least one of the City’s screening criteria.
Meeting screening criteria indicates that a project may be presumed to have a less than significant impact
unless substantial evidence suggests otherwise. A VMT analysis may still be required to ensure the
screening criteria are applicable.
Table 1 summarizes the City VMT screening criteria and applicability to the Project.
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The screening criteria applicable to the proposed Project as shown in Table 1 are discussed in further
detail below:
Screening Criteria 6: Redevelopment Projects That Result in a Net Reduction of VMT: Projects are
considered to have a less than significant impact if they result in a net reduction in the relevant
performance measure (in this case VMT). Therefore, redevelopment projects in the City of Carlsbad that
generate less VMT than the existing project they are replacing would be considered to have a less than
significant impact on VMT.
Analysis
To calculate the net change in total VMT, the total VMT to be generated by the proposed Project land
uses was deducted from the total VMT generated by the existing hotel.
D1(a). Project Total VMT
Total Project VMT was calculated by multiplying average daily trips (ADT) by average trip length (ATL).
Estimated trip generation rates and average trip lengths were both obtained from the default values for
“Apartments, Low Rise” provided by the California Emissions Estimator Model (CalEEMod), version
2022.1.1.29. Table 2 summarizes the total VMT calculations. As shown in Table 2, the Project is estimated
to generate approximately 6,105 daily VMT.
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Existing Site Total VMT (to be removed)
The total VMT for the existing hotel was also calculated using the default values from CalEEMod for the
“Hotel” land use type. Table 2 also shows the existing site total VMT. As shown in Table 2, the existing
hotel is estimated to generate 8,430 daily VMT.
Result
The existing hotel is estimated to generate 8,430 daily VMT. The proposed Project is estimated to generate
6,105 daily VMT. This is a reduction of 2,325 daily VMT compared to the existing site. Per City of Carlsbad
VMT Analysis Guidelines, redevelopment projects that generate less VMT than the existing project they
are replacing would be considered to have a less than significant impact on VMT. No mitigation is required.
D2. Project-Generated Noise Levels
The Noise Analysis, prepared by dBA Associates, Inc. (Attachment 1), anlayzed Project generated noise
sources (e.g., outdoor-pickle ball courts). The Project is surrounded by roadways and office commercial
uses. The closest noise-sensitive receptors are the West Inn & Suites roughly 525 feet north beyond
Cannon Road, and single-family residences roughly 650 feet west beyond a primary rail corridor and
Avenida Encinas. There is an office building roughly 475 feet south of the pickleball courts. Noise
measurements of pickleball court usage were conducted at the Lake San Marcos facility. Average sound
levels at the edge of the courts were as high as 67 dBA Leq. The Datakustik Cadna/A industrial noise
prediction model was used to estimate pickleball noise levels. It was assumed that activity would occur
continuously within the court boundaries. No noise reduction related to ground effects, atmospheric
absorption, or intervening topography was included in the model.
Additionally as documented in the VMT analysis summarized in the traffic section, the conversion of the
existing hotel to a multi-family residential use would reduce ADT and would not result in an increase in
noise attributed to Project generated traffic.
Pickleball noise levels would be as high as 35 dBA Leq at the single-family residences, 38 dBA Leq at the
hotel, and 40 dBA at the office building.
Exterior noise levels at outdoor use areas would be roughly between 55-63 dBA CNEL, which is below the
maximum exterior noise exposure level of 65 dBA CNEL as established by the Noise Element, and
therefore, the Project adheres to the General Plan noise exposure standards. The maximum interior noise
level within any residential unit would not exceed 45 dBA CNEL, and therefore, the existing Project
building is in compliance with city and State of California sound level limits (California Building Code (CBC),
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Chapter 12: Interior Environment, Section 1206) as built. Project-generated noise levels would not
exceed 45 dBA Leq at sensitive land uses, and therefore, the Project adheres to the General Plan noise
generation standards.
For these reasons, the Noise Analysis concludes that noise impacts related to Project traffic, and operation
would be less than significant.
D3. Air Quality
An air quality technical memorandum (AQ memo) has been prepared by Bluescape Environmental
(Attachment 3). It includes construction and operational analyses for the Project.
The Project will convert the existing hotel into a 98-unit multi-family apartment building and
update/improve current on-site amenities, such as the fitness room, public restrooms and pool area. New
Project elements consist of a bike/surfboard maintenance and storage shed and a trash enclosure, two
pickleball courts, a dog run, landscaping and architectural coatings. Most Project construction will occur
indoors, so emissions due to construction will be minimal. The 123-space parking lot will remain on-site
as it exists.
The California Emissions Estimator Model (CalEEMod), version 2022.1.1.29 was used. This version of
CalEEMod is the latest version that includes the U.S. Environmental Protection Agency (USEPA)-approved
EMFAC2021 emission factors for mobile sources. The model was used to estimate criteria pollutant
emissions for both the construction and operational phases of the Project. The existing hotel’s operational
emissions were also analyzed using CalEEMod to calculate net operational emissions between the new
land usage and the current land usage.
Air Quality Thresholds of Significance
The City relies on the CEQA guidelines that the County has published for the air quality thresholds that
determine whether or not a project is considered “significant.” These County guidelines refer to the San
Diego Air Pollution Control District (APCD)’s significance thresholds in SDAPCD Regulation II, Rule 20.2,
Table 20.2-1, Air Quality Impact Analysis (AQIA) Trigger Levels. Table C below lists the County’s/SDAPCD’s
screening-level thresholds used to determine air quality impacts.
TABLE C
COUNTY OF SAN DIEGO SCREENING-LEVEL THRESHOLDS
Pollutant
Total Emissions
Lbs per Day Tons per Year
Respirable Particulate Matter (PM10) 100 15
Fine Particulate Matter (PM2.5) 55* 10
Oxides of Nitrogen (NOX) 250 40
Oxides of Sulfur (SOX) 250 40
Carbon Monoxide (CO) 550 100
Volatile Organic Compounds (VOC) 75** 13.7***
* Environmental Protection Agency (EPA) “Proposed Rule to Implement the Fine Particle National Ambient
Air Quality Standards” published September 8, 2005. Also used by the South Coast Air Quality Management
District ( SCAQMD).
** Threshold for VOCs based on the threshold of significance for VOCs from the SCAQMD for the Coachella
Valley.
*** 13.7 Tons per Year threshold based on 75 lbs/day multiplied by 365 days/year and divided by 2000
lbs/ton.
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Consistency with Air Quality Plan
The proposed Project is on a site that is designated as Planned Industrial (PI) in the General Plan and zoned
Planned Industrial (P-M). The Project requires a CUP, pursuant to CMC Section 21.42.071, for residential
uses in the P-M Zone. With the CUP, the Project is consistent with the General Plan and zoning
designations. Because the proposed Project activities and associated vehicle trips are lower than the
current land use of “Hotel”, as shown above due to the reduction in trips based upon the conversion of
the hotel use to a multi-family residential use (refer to the Traffic section of this memo), Project emissions
are anticipated in local air quality plans and the proposed Project would be consistent at a regional level
with the underlying growth forecasts in the Regional Air Quality Strategy (RAQS) and State
Implementation Plan (SIP).
Construction Criteria Pollutant Emissions
The AQ Memo compares the modeled estimated daily emission results for construction of the Project to
the significance thresholds listed in Table C. The construction is limited to tenant improvements, the
resurfacing of the parking lot, and construction of the dog run, pickleball courts, and the bicycle/surfboard
storage/maintenance shed. The AQ Memo demonstrates that daily and annual emissions of criteria
pollutants from construction activities are below the approved significance thresholds.
Operational Criteria Pollutant Emissions
The AQ Memo shows the estimated annual emission results for operation of the Project and operation of
the current hotel. The net operational emissions (Project minus Hotel) are compared to the significance
thresholds listed in Table C. The daily and annual emissions of criteria pollutants associated with Project
operation decrease from the current hotel operational emissions. All operational emissions due to the
Project are below the approved significance thresholds.
This analysis demonstrates that AQ emissions due to construction and operation of the Project are lower
than significance threshold levels approved by the City of Carlsbad for CEQA analyses. No Air Quality
impacts would result from Project implementation.
D4. Water Quality
The Project is not anticipated to have a substantial adverse effect on water quality. CEQA threshold
questions pertaining to water quality (from Appendix G of the CEQA Guidelines) are addressed below.
Would the Project violate any water quality standards or waste discharge requirements or otherwise
substantially degrade surface or ground water quality?
Project Operation
The Project would not introduce any significant industrial discharges, and therefore, would not violate
any water quality standards or waste discharge requirements related to non-stormwater discharges.
Under current conditions, the Project site produces nonpoint source pollutants associated with
stormwater runoff. The primary stormwater pollutants that may occur under existing conditions are
spilled or leaked petroleum products from parked vehicles on the site, household hazardous materials
used for maintenance and cleaning at the existing hotel, and sediment from landscaping planters.
Upon Project implementation, the site would be converted from a 98-room hotel to a 98-unit multifamily
residential building with amenities and landscaped areas. The stormwater collected onsite would continue
to be directed to onsite stormwater treatment Best Management Practices (BMP)s in accordance with the
City's BMP Design Manual and would comply with the City's stormwater regulations.
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Would the Project substantially alter the existing drainage pattern of the site or area, including through
the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner
which would result in substantial erosion or siltation on- or off-site or create or contribute runoff water
which would exceed the capacity of existing or planned stormwater drainage systems or provide
substantial additional sources of polluted runoff?
A Preliminary Drainage Study was prepared by Van Ryn Engineering (Attachment 4). The Project site is
117,738 square feet, or 2.703 net acres (net of the Avenida Encinas right-of-way), and consists of the
existing hotel, parking areas, and landscape areas. The focus of the analysis is the northern portion of the
site along Cannon Road. This portion of the site exists as primarily pervious landscape area, except for the
existing utility enclosure and concrete wall. This northern portion of the site is the only area where
exterior improvements are to be made; the remainder of the lot will remain unchanged. The drainage
basin has a total area of 9,244 square feet, or 0.212 acres, and consists of 685 square feet (or 7.41%) of
impervious surfaces.
The Project proposes the construction of a new recreational space on the northern portion of the lot. The
proposed hardscape consists of two concrete pickleball courts, along with a room for bike and surfboard
storage/maintenance. The existing utility enclosure will remain undisturbed, but portions of the concrete
wall will be removed to accommodate the proposed hardscape. The proposed conditions introduce 4,821
square feet of new/replaced impervious area, resulting in the percentage of impervious surfaces
increasing to 59.56%.
To account for the increase in impervious areas, a bioretention basin is proposed on the western side of
the hardscape. Runoff from the new pickleball courts will be collected in a landscape drain, which
discharges directly into the proposed basin. Therefore, the Project will not negatively affect the
downstream facilities or adjacent properties. The proposed storm drain system is adequate to intercept,
contain and convey Q100 and will not create negative impacts to the downstream system from the
velocity, volume, or surface flows.
The Project site does not contain any streams, rivers, or waterbodies. Upon compliance with regulatory
requirements the proposed Project is not anticipated to result in substantial erosion or siltation, to
increase the rate or amount of surface runoff from the site or create runoff that would exceed the capacity
of the stormwater drainage system. Due to the developed nature of the Project site and required
compliance with existing regulations, on the Project would not result in significant, adverse stormwater
impacts.
Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable
groundwater management plan?
In 2014, California enacted the Sustainable Groundwater Management Act (SGMA) to bring the state's
groundwater basins into a more sustainable regime of pumping and recharge. The legislation provides for
the sustainable management of groundwater through the formation of local groundwater sustainability
agencies and the development and implementation of Groundwater Sustainability Plans (GSPs). In San
Diego County, the State has designated three of the County's groundwater basins as medium- or high-
priority and subject to SGMA, including the Borrego Valley, San Luis Rey Valley, and San Pasqual Valley
(San Diego County Planning and Development Services 2021), none of which underlie the Project site.
As noted above, the Project is not expected to violate any water quality standards, and measures would
be taken during throughout operation to prevent potential contaminants from leaving the site by runoff.
Through compliance with Regional Water Quality Control Board requirements, the Project would not
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conflict with or obstruct implementation of a water quality plan or the San Diego Sustainable
Groundwater Management Act.
In conclusion, development of the proposed Project has been evaluated for its potential to result in
significant effects relating to traffic, noise, air quality, and water quality. No significant effects were
identified, as described above and further substantiated in the attached memoranda. As such, the Project
meets the Class 32 categorical exemption criteria for not having significant impacts to traffic, air quality,
noise, or water quality.
E. Utilities & Public Services: The Project site can be adequately served by all required utilities and public
services.
The Project is located in an infill urban area served by existing public utilities and services and is situated
on a site developed with a hotel use. The Project would convert the existing hotel to a multi-family
residential use.
A Water Demand Study (Water Study) was prepared by Van Ryn Engineering, Inc. (Attachment 5). Water
service to the Project will be provided by the Carlsbad Municipal Water District. The City of Carlsbad:
Potable Water Master Plan - 2019 identified that the proposed Project site is supplied by the Skyline Tank
Storage Facility, which is monitored by the Pressure Regulation Stations in Zone 446. Specifically, the
Water Study demonstrates that the Project can utilize the existing plumbing infrastructure with no
required updates to the water demand currently required by the site. The existing, offsite 10” Asbestos
Cement Pipe (ACP) water line within Avenida Encinas has adequate capacity to convey the proposed water
demands, and the onsite, existing three, 3” service lines and meters will satisfy the proposed conversion
of the hotel to a multi-family residential use.
A Sewer Capacity Study (Sewer Study) was prepared by Van Ryn Engineering (Attachment 6). Existing
public sewer service to the site is provided by the city.
The Project proposes new hardscape areas on the northwestern end of the site with new landscaping
scattered in and around the proposed hardscaping. The existing structure on-site will remain undisturbed
when the use is converted into a 98-unit multi-family residential building. The land use change will modify
the sewer generation rates and densities. The Sewer Study demonstrates that the existing 8” vitrified clay
pipe (VCP) sewer main in Avenida Encinas and the existing 8” sewer lateral are adequately sized to
accommodate the Project. The Sewer Study also indicates that the proposed sewer flows generated with
the construction of the tenant improvements, pickleball courts, and the bicycle and surfboard
maintenance shed are less than the City of Carlsbad: Sewer Master Plan Update - 2019 flows allocated to
the site. Based on the site’s equivalent population of average daily flow less than 100,000 gallons pr day
(gpd), a Peak Factor of 2.5 was determined. Per design sewer criteria in the City of Carlsbad: Sewer Master
Plan Update – 2019 (and the equivalent dwelling unit (EDU) factoring of the Hotel Units to Multi-Family
Units (Table 13.10.020(c)), the gpd per EDU remained the same, and the proposed change in building use
should have no new impacts on the existing sewer main or interceptor system.
The approved City of Carlsbad: Sewer Master Plan Update - 2019 identified the Project site as flowing into
the Vista/Carlsbad Interceptor, and ultimately, the Encina Water Pollution Control Facility. The proposed
Project has an anticipated total flow rate of 49,000 gpd, same as the existing use. The existing, offsite 8”
sewer main has adequate capacity to convey the proposed wastewater flow rate of 49,000 gpd.
Therefore, the Project can and will be served by all public utilities and services.
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Exceptions to Exemptions
CEQA Section 15300.2 – Exceptions
Planning staff evaluated all the potential exceptions to the use of Categorical Exemptions for the proposed
project (in accordance with CEQA Guidelines Section 15300.2) and determined that none of these
exceptions apply as explained below:
a. Location. “Classes 3, 4, 5, 6, and 11 are qualified by consideration of where the project is to be located
- a project that is ordinarily insignificant in its impact on the environment may in a particularly sensitive
environment be significant. Therefore, these classes are considered to apply in all instances, except
where the project may impact on an environmental resource of hazardous or critical concern where
designated, precisely mapped, and officially adopted pursuant to law by federal, state, or local
agencies.”
Response – The location exception is not applicable to Class 32 Exemptions for In-Fill Development
Projects.
b. Cumulative Impact - “All exemptions for these classes are inapplicable when the cumulative impact of
successive projects of the same type in the same place, over time is significant.”
Response – There is no evidence to conclude that significant impacts will occur based on past project
approvals or that the proposed Project's impacts are cumulatively considerable when evaluating any
cumulative impacts associated with air quality, noise, transportation, or water quality in the area
surrounding the proposed Project. Accordingly, the Project’s incremental impacts, when considered
together with the impacts of the related projects, would not result in a cumulatively considerable
contribution to a significant cumulative impact. Implementation of the General Plan would not
significantly alter the subregional or regional growth rates projected by SANDAG. The city’s growth
levels would remain generally consistent with SANDAG’s forecast for 2050. The Project, and all future
projects, will be required to comply with all applicable local, regional, and state laws, regulations, and
guidelines, and as described above, any potential impact cause by the Project's operation would be
less than significant and would not contribute significantly to a regional cumulative impact in the
broader Project region. The city’s comprehensive modeling for impacts on the site assumed the
existing hotel as baseline, a more intensive use, cumulatively and on a per unit basis, than the
proposed residential use. Further, the city’s policies and implementation actions are designed to best
manage and accommodate the city’s growth. Thus, implementation of the General Plan would
adequately meet the housing needs of the anticipated population growth so contribution to the
potential for cumulative inducement of population growth would not be cumulatively considerable.
c. Significant Effect - “A categorical exemption shall not be used for any activity where there is a
reasonable possibility that the activity will have a significant effect on the environment due to unusual
circumstances.”
Response – The Project proposes the conversion of a 98-room hotel to a 98-unit multi-family
residential use. The Project proposes for rent market-rate and affordable housing on a site at an entry
point to the city surrounded by multiple existing employment options, east of a single-family
neighborhood zoned as R-4 and adjacent to the I-5. The Project will not modify the existing
development footprint; modifications will be limited to painting the building, enhancing the current
landscaping and upgrading the outdoor amenities, which will have a negligible effect on the property
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and the neighboring developments. The surrounding area is developed with a mixture of residential
and commercial uses; as such, the proposed Project is not unusual in character for the area. The
Project site is 3.12 acres and almost entirely covered by impervious surfaces. Moreover, development
of the Project would result in a net reduction in VMT. As described above, the proposed Project has
been studied for its potential to cause environmental impacts in a variety of categories, including air
quality, noise, traffic, and water quality. No significant effects were identified in those categories.
The circumstances of the Project, which involve the conversion of an existing 98 room hotel to a 98-
unit multi-family residential project and addition of recreational amenities, are no different than the
general circumstances of other development projects particularly because the majority of the
construction work will occur inside the existing structure. There are no distinguishing features that
give rise to the reasonable possibility that the Project's size, density and intensity, bulk and mass, and
use will impact the environment as compared to other projects. Thus, there are no unusual
circumstances which may lead to a significant effect on the environment, and this exception does not
apply.
d.Scenic Highway - “A categorical exemption shall not be used for a project which may result in damage
to scenic resources, including but not limited to, trees, historic buildings, rock outcroppings, or similar
resources, within a highway officially designated as a state scenic highway. This does not apply to
improvements which are required as mitigation by an adopted negative declaration or certified EIR.”
Response – Cannon Road and Avenida Encinas are not considered a historical and scenic corridor
throughout Carlsbad, is not a highway officially designated as a State Scenic Highway, nor is it visible
from a Carlsbad historical or scenic corridor or State Scenic Highway. The project site is also
surrounded by existing commercial and office structures and exterior modifications involve additions
of outdoor amenity areas. Therefore, implementation of the Project will result in similar visual
conditions compared with the current conditions.
e.Hazardous Waste Site - “A categorical exemption shall not be used for a project located on a site which
is included on any list compiled pursuant to Section 65962.5 of the Government Code.”
Response – The Project site is not identified on the Department of Toxic Substance Control geoportal
map as a Cleanup, Hazardous Waste, or Inspection site. Furthermore, there is no indication that the
site has had any previous uses associated with hazardous materials, such as dry-cleaning or gas station.
f.Historical Resources - “A categorical exemption shall not be used for a project which may cause a
substantial adverse change in the significance of a historical resource.”
Response – The existing 98-room hotel proposed for conversion to a 98-unit multifamily residential
project was constructed in 2000. As the structure is less than 50 years old, the structure is not listed
or eligible to be listed in any national, state, or local landmark or historic district programs, nor is it
eligible for listing in the Local Register. As such, development of the Project would not cause a
substantial adverse change in the significance of a historical resource, and this exception does not
apply. The property is not known to have any other special circumstances that would make the
property a historic resource.
Carlsbad Municipal Code Section 19.04.070(C) - Exceptions
Exceptions. Even though a project may otherwise be eligible for an exemption, no exemption shall apply
in the following circumstances:
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1. Grading and clearing activities affecting sensitive plant or animal habitats, which disturb, fragment or
remove such areas as defined by either the California Endangered Species Act (Fish and Game
Code Sections 2050 et seq.), or the Federal Endangered Species Act (16 U.S.C. Section 15131 et seq.);
sensitive, rare, candidate species of special concern; endangered or threatened biological species or
their habitat (specifically including sage scrub habitat for the California Gnatcatcher); or
archaeological or cultural resources from either historic or prehistoric periods;
Or
2. Parcel maps, plot plans and all discretionary development projects otherwise exempt but which affect
sensitive, threatened, or endangered biological species or their habitat (as defined above),
archaeological or cultural resources from either historic or prehistoric periods, wetlands, stream
courses designated on U.S. Geological Survey maps, hazardous materials, unstable soils, or other
factors requiring special review, on all or a portion of the site. (Ord. NS-593, 2001)
Response – The Project site is located in a developed part of the city and is surrounded by commercial,
office and industrial uses. The Project site contains an existing building, parking lot and landscaping,
and contains only non-natives and ornamental vegetation with no value as habitat for endangered,
rare, or threatened species. Furthermore, the site is not within mapped areas of potential critical
habitat as depicted in the city’s General Plan.1 Based on the urbanized nature of the Project site and
adjacent properties, in conjunction with a lack of suitable habitat for special-status species, the Project
site has no value as habitat for endangered, rare, or threatened species and thus meets the Class 32
categorical exemption criteria for lack of habitat. Furthermore, the site is not within mapped areas of
potential critical habitat as depicted in the City's General Plan. For these reasons, the Project has no
value as habitat for endangered, rare, or threatened species.
The Project site was graded and developed in 2000. Grading associated with the original structure
consisted of 1,900 cubic yards of cut and 2,300 cubic yards of fill. It is located in an urbanized area
adjacent to I-5 and is surrounded by development. The likelihood, therefore, that intact archaeological
or cultural resources exist on the Project site is low due to previous site disturbance. Further, the
Project is the conversion of an existing hotel to multifamily residential use; it proposes only minor
exterior site improvements and minimal grading (cut of 180 yards of material with a maximum 2-foot
cut). Therefore, Project implementation would not affect archaeological or cultural resources from
either historic or prehistoric periods and this exception does not apply.
Biological Resources
As discussed above, the proposed Project would not affect sensitive, threatened, or endangered
biological species or their habitat. This exception does not apply.
Cultural Resources
As discussed above, the Project would not affect known archaeological or cultural resources from
either historic or prehistoric period. This exception does not apply.
Wetlands and Streams
As described above, no evidence of vernal pool or wetland features are present on site or in adjacent
area. Further, no streams are located within the vicinity of the site. Thus, this exception does not apply.
1 City of Carlsbad. 2015 City of Carlsbad General Plan – Open Space, Conservation, and Recreation Element. Adopted
September 2015. https://www.carlsbadca.gov/home/showpublisheddocument/3424/637434861099030000
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Hazardous Materials
Based on the hazardous materials record searches, the Project site is not identified as a hazardous
waste site and no hazardous materials with an "open" cleanup case are located on or in the immediate
vicinity of the Project site.
The Project will be conditioned to comply with all existing standard applicable regulatory requirements
related to hazardous materials. Therefore, this exception does not apply.
Unstable Soils
A review of the City's General Plan Safety Element and California Geological Survey's Earthquake Zones
of Required Investigation concluded that the Project site is not located in an area with potential for
seismic hazards.
Lead Agency Contact Person: Lauren Yzaguirre Telephone: 442-339-2634
ERIC LARDY, City Planner Date
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MEMORANDUM
N:\3961 - 5010 Avenida Encinas\Memo\VMT Memo.3961 June 2025.docx
To: Jim McMenamin Alliance Development Services, Inc.
Date: June 10, 2025
From: John A. Boarman, PE LLG
LLG Ref: 3-24-3961
Subject: 5010 Avenida Encinas Redevelopment, VMT Assessment
Linscott, Law & Greenspan, Engineers has prepared this Vehicle Miles Traveled (VMT) assessment for the proposed 5010 Avenida Encinas Redevelopment project (“Project”) consistent with the City of Carlsbad VMT Analysis Guidelines (May 2023).
PROJECT LOCATION & DESCRIPTION
The Project is located on approximately 3.12 acres at 5010 Avenida Encinas, west of
Interstate 5 and south of Cannon Road.
Figure 1 shows the vicinity map. Figure 2 shows a more detailed Project area map.
The Project proposes converting the existing 98-suite Studio 6 hotel to 98 apartments, utilizing the existing building and parking. The Project includes fifteen (15) income-restricted affordable units among the 98 units proposed. The Project proposes using the
existing building with minor changes. The exterior will be updated with new paint,
enhanced landscaping, and upgraded and expanded exterior common areas. The interior of the building will be updated and upgraded with no major structural revisions.
Figure 3 shows the Project site plan. The Project’s anticipated Opening Year is 2027.
Additional project information and developer profile are included in Attachment A.
VEHICLE MILES TRAVELED (VMT) ASSESSMENT
In compliance with Senate Bill 743 (SB 743), a project is required to evaluate
transportation impacts under the California Environmental Quality Act (CEQA) and CEQA Guideline Section 15064.3. For the purposes of this VMT assessment the methods and thresholds from the City of Carlsbad’s VMT Analysis Guidelines (May 2023) were used.
VMT Screening Criteria
The City’s guidelines provide CEQA significance thresholds, screening criteria, and methodology for conducting the transportation VMT analyses for a variety of land uses. Per City guidelines, the requirements to prepare a detailed transportation VMT analysis apply to all land development projects, except those that meet at least one of the City’s screening criteria.
Meeting screening criteria indicates that the project may be presumed to have a less than significant impact unless substantial evidence suggests otherwise. A VMT analysis may still be required to ensure the screening criteria are applicable.
Table 1 summarizes the City VMT screening criteria and applicability to the Project.
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TABLE 1 VMT SCREENING CRITERIA – PROJECT APPLICABILITY
Screening Criteria a Applicable to the Project?
Project screen out?
1. Small Project No N/A
2. Projects Located Near Transit No N/A
3. Local-Serving Retail and Similar Land Uses No N/A
4. Local-Serving Public Facility No N/A
5. Affordable Housing No N/A
6. Redevelopment Project That Result in a Net Reduction of
VMT Yes Yes
Footnotes:
a. Source: City of Carlsbad VMT Analysis Guidelines (May 2023).
The screening criteria applicable to the proposed Project as shown in Table 1 are discussed in further detail below:
Screening Criteria 6:
Redevelopment Projects That Result in a Net Reduction of VMT: Projects are considered to have
a less than significant impact if they result in a net reduction in the relevant performance measure (in this case VMT). Therefore, redevelopment projects in the City of Carlsbad that generate less VMT than the existing project they are replacing would be considered to have a less than significant impact on VMT.
Analysis
To calculate the net change in total VMT, the total VMT to be generated by the proposed Project land uses was deducted from the total VMT generated by the existing hotel.
Project Total VMT Total Project VMT was calculated by multiplying daily trip generation (ADT) by average trip length (ATL). Estimated trip generation rates and average trip lengths were both obtained from the
default values for “Apartments, Low Rise” provided by the California Emissions Estimator Model (CalEEMod), version 2022.1.1.29. Table 2 summarizes the total VMT calculations. As shown in Table 2, the Project is estimated to generate approximately 6,105 daily VMT.
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TABLE 2 REDEVELOPMENT VMT
Type Land Use Quantity Daily Volumes (ADT) a ATL a Total VMT Rate Volume
Project Apartments (Low Rise) 98 DU 7.32 /DU 717 8.51 6,105
Existing (to be removed) Hotel 98 rooms 8.36 /room 819 10.29 8,430
Net Change in VMT -2,325
Footnotes: a. Average daily trip rates and average vehicle trip length values from CalEEMod. California Air Pollution Control Officers Association, 2022.
Existing Site Total VMT (to be removed) The total VMT for the existing hotel was also calculated using the default values from CalEEMod
for the “Hotel” land use type. Table 2 also shows the existing site total VMT. As shown in Table
2, the existing hotel is estimated to generate 8,430 daily VMT.
Result As shown in this memo, the existing hotel is estimated to generate 8,430 daily VMT. The proposed
Project is estimated to generate 6,105 daily VMT. This is a reduction of 2,325 daily VMT
compared to the existing site. Per City of Carlsbad VMT Analysis Guidelines, redevelopment
projects that generate less VMT than the existing project they are replacing would be considered
to have a less than significant impact on VMT. Given that the Proposed Project VMT has been
calculated to be quantifiably lower than the existing hotel VMT, no significant VMT impact is
triggered.
CONCLUSION
In conclusion, a quantitative VMT analysis demonstrates that the Proposed Project VMT is
calculated to be lower than the existing hotel VMT, concluding that no significant VMT impact is
calculated consistent with Criteria 6: Redevelopment Project That Results in a Net Reduction
of VMT. This evaluation substantiates the presumptions of a less than significant VMT impact.
Figures: 1 Project Vicinity Map
2 Project Area Map 3 Project Site Plan cc: File
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ATTACHMENT A
DEVELOPER PROFILE & PROJECT INFORMATION
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3129 Tiger Run Court, Suite 202
Carlsbad, CA 92010
619-609-0712
March 4, 2025
Jim McMenamin
Alliance Development Services, Inc.
17828 Villamora Drive
Poway, CA 92064
Re: The Flats at Terramar
5010 Avenida Encinas, Carlsbad
Noise Evaluation
Mr. McMenamin:
At your request, we conducted an evaluation of noise produced by and affecting the
subject project. The purpose of the evaluation was to assess compliance with City of
Carlsbad and State of California noise level limits.
The project building is currently a Studio 6 hotel. The project is the conversion of the
building for multifamily residential use.
Exterior noise levels at outdoor use areas would not exceed 65 dBA CNEL, and would be
in compliance with City of Carlsbad noise level limits.
Interior noise levels within residences would not exceed 45 dBA CNEL, and would be in
compliance with City of Carlsbad and State of California noise level limits.
Project-generated noise levels would not exceed 45 dBA Leq at sensitive land uses and
would be in compliance with City of Carlsbad noise level limits.
Noise Background
Noise is generally defined as loud, unpleasant, unexpected, or undesired sound typically
associated with human activity and that interferes with or disrupts normal activities. The
human environment is characterized by a certain consistent noise level which varies with
each area. This is called ambient noise. Although exposure to high noise levels has been
demonstrated to cause hearing loss, the principal human response to environmental noise
is annoyance. The response of individuals to similar noise events is diverse and
influenced by the type of noise, perceived importance of the noise and its appropriateness
in the setting, time of day and type of activity during which the noise occurs, and
sensitivity of the individual.
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March 4, 2025
Page 2
Sound is a physical phenomenon consisting of minute vibrations that travel through a
medium, such as air, and are sensed by the human ear. Sound is generally characterized
by several variables, including frequency and intensity. Frequency describes the sound’s
pitch and is measured in cycles per second, or hertz (Hz), whereas intensity describes the
sound’s loudness and is measured in decibels (dB). Decibels are measured using a
logarithmic scale. A sound level of 0 dB is approximately the threshold of human hearing
and is barely audible under extremely quiet listening conditions. Normal speech has a
sound level of approximately 60 dB. Sound levels above about 120 dB begin to be felt
inside the human ear as discomfort and eventually as pain at still higher levels. Studies
have shown that the smallest perceptible change in sound level for a person with normal
hearing sensitivity is approximately 3 dBA. A change of at least 5 dBA would be
noticeable and would likely evoke a community reaction. A 10-dBA increase is
subjectively heard as a doubling in loudness and would cause a community response.
Sound levels of typical noise sources and environments are provided in Table 1.
Because of the logarithmic nature of the decibel unit, sound levels cannot be added or
subtracted directly and are somewhat cumbersome to handle mathematically. A simple
rule is useful, however, in dealing with sound levels. If a sound’s intensity is doubled, the
sound level increases by 3 dB, regardless of the initial sound level. Thus, for example, 60
dB + 60 dB = 63 dB, and 80 dB + 80 dB = 83 dB. The normal human ear can detect
sounds that range in frequency from about 20 Hz to 20,000 Hz.
However, all sounds in this wide range of frequencies are not heard equally well by the
human ear, which is most sensitive to frequencies in the range of 1,000 Hz to 4,000 Hz.
This frequency dependence can be taken into account by applying a correction to each
frequency range to approximate the human ear’s sensitivity within each range. This is
called A-weighting and is commonly used in measurements of community environmental
noise. The A-weighted sound pressure level (abbreviated as dBA) is the sound level with
the “A-weighting” frequency correction. In practice, the level of a noise source is
conveniently measured using a sound level meter that includes a filter corresponding to
the dBA curve.
Because community noise fluctuates over time, a single measure called the Equivalent
Sound Level (Leq) is often used to describe the time-varying character of community
noise. The Leq is the energy-averaged A-weighted sound level during a measured time
interval, and is equal to the level of a continuous steady sound containing the same total
acoustical energy over the averaging time period as the actual time-varying sound.
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March 4, 2025
Page 3
Table 1. Sound Levels of Typical Noise Sources and Noise Environments
Noise Source
(at Given Distance) Noise Environment A-Weighted
Sound Level
Human Judgment
of Noise Loudness
(Relative to Reference
Loudness of 70
Decibels*)
Military Jet Takeoff
with Afterburner (50 ft) Carrier Flight Deck 140 Decibels 128 times as loud
Civil Defense Siren (100 ft) 130 64 times as loud
Commercial Jet Take-off (200 ft) 120 32 times as loud
Threshold of Pain
Pile Driver (50 ft)
Rock Music Concert
Inside Subway Station
(New York)
110 16 times as loud
Ambulance Siren (100 ft)
Newspaper Press (5 ft)
Gas Lawn Mower (3 ft)
100 8 times as loud
Very Loud
Food Blender (3 ft)
Propeller Plane Flyover (1,000 ft)
Diesel Truck (150 ft)
Boiler Room
Printing Press Plant 90 4 times as loud
Garbage Disposal (3 ft) Noisy Urban Daytime 80 2 times as loud
Passenger Car, 65 mph (25 ft)
Living Room Stereo (15 ft)
Vacuum Cleaner (10 ft)
Commercial Areas 70 Reference Loudness
Moderately Loud
Normal Speech (5 ft)
Air Conditioning Unit (100 ft)
Data Processing Center
Department Store 60 1/2 as loud
Light Traffic (100 ft) Large Business Office
Quiet Urban Daytime 50 1/4 as loud
Bird Calls (distant) Quiet Urban Nighttime 40 1/8 as loud
Quiet
Soft Whisper (5 ft) Library and Bedroom at Night
Quiet Rural Nighttime 30 1/16 as loud
Broadcast and Recording
Studio 20 1/32 as loud
Just Audible
0 1/64 as loud
Threshold of Hearing
Source: Compiled by dBF Associates, Inc.
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March 4, 2025
Page 4
The Community Noise Equivalent Level (CNEL) is an adjusted average sound level for a
24-hour day. It is calculated by adding a 5-dB adjustment to sound levels during evening
hours (7:00 p.m. to 10:00 p.m.) and a 10-dB adjustment to sound levels during nighttime
hours (10:00 p.m. to 7:00 a.m.). These adjustments compensate for the increased
sensitivity to noise during the typically quieter evening and nighttime hours. CNEL is
used by the City of Carlsbad and State of California to evaluate land-use compatibility
with regard to noise.
The Day-Night Level (DNL or Ldn) is an adjusted average sound level for a 24-hour day.
It is calculated by adding a 10-dB adjustment to sound levels during nighttime hours
(10:00 p.m. to 7:00 a.m.). This adjustment compensates for the increased sensitivity to
noise during the typically quieter nighttime hours. DNL is used by the City of Carlsbad to
evaluate land-use compatibility with regard to noise. CNEL and DNL are generally
considered interchangeable.
Regulatory Environment
City of Carlsbad General Plan Section 5: Noise provides noise standards.
The City of Carlsbad indicates acceptable noise limits in the Noise Element of its General
Plan [City of Carlsbad 2015]. At Multiple Family Residential uses, noise levels up to
65 dBA DNL are considered Normally Acceptable. Noise levels between 60-70 dBA
DNL are considered Conditionally Acceptable: “New construction or development
should be undertaken only after a detailed analysis of the noise reduction requirements is
made and needed noise isolation features included in the design.”
Table 5-2 of the Noise Element indicates that the normal allowable noise exposure is
60 dBA CNEL for residential uses. However, footnote 4 of Table 5-2 states “An exterior
noise exposure level of 65 dBA CNEL is allowable … for residential uses within the
McClellan-Palomar Airport Area of Influence (AoI), pursuant to the noise compatibility
policies contained in the ALUCP (Airport Land Use Compatibility Plan).” A review of
Exhibit III-5 of the McClellan-Palomar ALUCP shows that the project site is within the
AoI.
Within interior spaces of residential land uses, the allowable noise exposure is
45 dBA CNEL [City of Carlsbad 2015].
California Building Code (CBC), Chapter 12: Interior Environment, Section 1206: Sound
Transmission regulates noise levels in buildings with multiple habitable units [State of
California 2019]. Section 1206.4: Allowable interior noise levels states:
Interior noise levels attributable to exterior sources shall not exceed 45 dB in any
habitable room. The noise metric shall be either the day-night average sound
level (Ldn) or the community noise equivalent level (CNEL), consistent with the
noise element of the local general plan.
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Page 5
Table 5-3 of the Noise Element limits project-generated noise at sensitive uses to
55 / 45 dBA Leq during daytime / nighttime hours.
Sound Level Measurements
Sound level measurements were conducted on Wednesday, September 11, 2024. The
measurements were conducted at the third (top) floor facing Interstate 5 (I-5), near the
north end of the building.
The interior measurement was conducted near the center of room 336. A RION Model
NL-31 American National Standards Institute (ANSI) Type 2 Integrating Sound Level
Meter was used as the data-collection device. The meter was mounted to a tripod roughly
five feet above floor level to simulate the average height of the human ear. The
microphone was fitted with a windscreen. The sound level meter was calibrated before
and after the measurement period. The measured sound level was 34.3 dBA Leq.
The exterior measurement was conducted roughly five feet from the façade, by using a
microphone attached to an extension pole through the window of room 334. A RION
Model NA-28 ANSI Type 1 Integrating meter was used as the data-collection device. The
microphone was fitted with a windscreen. The sound level meter was calibrated before
and after the measurement period. The measured sound level was 70.1 dBA Leq.
The building envelope, which includes double dual-glazed windows, provides
approximately 35.8 dBA of noise reduction (70.1 – 34.3). It is our understanding that the
envelope configuration is identical at all habitable rooms.
The Acoustical Analysis for the original project building [Brown-Buntin Associates, Inc.
2000] indicated that the windows facing I-5 were STC 35, and all others were STC 34.
Our field testing measurements, described above, corroborate this design requirement.
Free-flowing traffic on I-5 was the primary observed noise source during the
measurements. Traffic counts were obtained from the Caltrans Freeway Performance
Measurement System (PeMS) website. The source data was from Vehicle Detector
Stations (VDS) 1108659 and 1108661. During the 15-minute measurement period, 1,874
northbound vehicles and 1,422 southbound vehicles passed by on I-5.
Future Exterior Noise Exposure
On Wednesday, November 13, 2024, sound level measurements were conducted at the
project outdoor use areas. At the pool deck, the sound level was approximately 54 dBA
Leq. At the northeast pickleball court / dog run location, the sound level was
approximately 62 dBA Leq. At the northwest pickleball court location, the sound level
was approximately 59 dBA Leq. At all locations, I-5 traffic was the dominant noise
source.
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Page 6
As described above, I-5 noise is expected to increase by roughly 1 dBA in the future. As
such, noise levels at the outdoor use areas would range from roughly 55-63 dBA CNEL.
Future Interior Noise Exposure
The peak hour traffic noise level was considered equivalent to the CNEL [24 CFR
§51.106]. The peak hour traffic volume was considered to be 10% of the average daily
traffic (ADT) volume. Interstate 5, including high-occupancy vehicle lanes, is projected
to carry a future (year 2050) ADT volume of 177,500 vehicles past the project site
[SANDAG 2024]. The speed limit and traffic mix on Interstate 5 are not expected to
change in the future.
To determine the maximum exterior noise level from I-5, the measured noise level and
simultaneous traffic counts were compared to the future traffic volume. Refer to Table 2
for details.
Table 2. Maximum Noise Level
Location Measured
Leq
Hourly-
Equivalent
Vehicles
Counted
Future
Hourly
Vehicle
Volume
Traffic
Noise
Increase
Resultant
Maximum
CNEL
East exterior façade 70.1 dBA 13,184 17,750 + 1.3 dBA 71.4 dBA
The south end of the building is approximately 280 feet from the centerline of I-5,
whereas the measurements were conducted near the north end, which is approximately
375 feet away. Sound levels from line sources such as roadways increase at a minimum
rate of 3 dBA per halving of distance. Accordingly, the exterior noise level at the south
end of the building could be as much as 1.3 dBA higher than at the north end. Therefore,
the worst-case noise level at any project building façade would be 72.7 dBA CNEL.
As the building envelope demonstrably provides 35.8 dBA of noise reduction, the interior
noise level within any residential room would be a maximum of roughly 37 dBA CNEL.
Project-Generated Noise Levels
The project is surrounded by roadways and commercial uses. The closest noise-sensitive
receptors are the West Inn & Suites roughly 525 feet north beyond Cannon Road, and
single-family residences roughly 650 feet west beyond a primary rail corridor and
Avenida Encinas. There is an office building roughly 475 feet south of the pickleball
courts location.
Noise measurements of pickleball court usage were conducted at the Lake San Marcos
facility. Average sound levels at the edge of the courts were as high as 67 dBA Leq.
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Page 7
The Datakustik Cadna/A industrial noise prediction model was used to estimate
pickleball noise levels. It was assumed that activity would occur continuously within the
court boundaries. No noise reduction related to ground effects, atmospheric absorption, or
intervening topography was included in the model.
Pickleball noise levels would be as high as 35 dBA Leq at the single-family residences,
38 dBA Leq at the hotel, and 40 dBA at the office building.
Conclusions
Because exterior noise levels at outdoor use areas would be Normally Acceptable and
allowable, the project adheres to the General Plan noise exposure standards.
Because the maximum interior noise level within any habitable residential room of the
project would not exceed 45 dBA CNEL, the existing project building is in compliance
with City of Carlsbad and State of California sound level limits as built.
Because project-generated noise levels would not exceed 45 dBA Leq at sensitive land
uses, the project adheres to the General Plan noise generation standards.
This concludes the evaluation. Please contact me at 619-609-0712 ×102 if you have any
questions.
Sincerely,
dBF ASSOCIATES, INC.
Steven Fiedler, INCE
Principal
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16870 West Bernardo Drive, Suite 400, San Diego, CA 92127 | 858.695.9200 | www.bluescapeinc.com
Memorandum
To: Jim McMenamin, Alliance Development Services
From: James Westbrook, BlueScape Environmental
Date: May 22, 2025
Subject: Air Quality Study Findings for Proposed Conversion of 98-Unit
Studio 6 Hotel to Multi-Family Apartment Rental Housing Project,
Located at 5010 Avenida Encinas in Carlsbad, California
This memo outlines the air quality (AQ) study performed for the proposed
conversion of a 98-Unit Studio 6 Hotel to a Multi-Family Apartment Rental
Housing Project (Project) at 5010 Avenida Encinas in Carlsbad, California. The
Project site is proposed to be constructed on an approximately 2.7-acre parcel
of land, where the Studio 6 Hotel currently operates. The Project developer
has filed for a Class 32 categorical infill exemption from California
Environmental Quality Act (CEQA) review requirements. The Class 32
exemption requires that a project would not result in any significant effects
related to air quality. This analysis demonstrates that AQ emissions due to
construction and operation of the Project are lower than significance threshold
levels approved by the City of Carlsbad for CEQA analyses.
Project Description
The proposed Project site consists of an approximately 2.7-acre parcel located
at 5010 Avenida Encinas. The Project consists of the conversion of the existing
hotel into a 98-unit multi-family apartment building and the
updating/improvement of current on-site amenities, such as the fitness room,
public restrooms and pool area. New Project elements consist of bike and trash
enclosures, two pickleball courts, a dog run, landscaping and architectural
coatings. Most of the Project construction will occur indoors, so emissions due
to construction will be minimal. The 123-space parking lot will remain on-site
as it exists.
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Flats at Terramar Project Air Quality Study
BlueScape Environmental 2 May 22,2025
Air Quality Study Methodology
The California Emissions Estimator Model (CalEEMod), version 2022.1.1.29
was used. This version of CalEEMod is the latest version that includes the U.S.
Environmental Protection Agency (USEPA)-approved EMFAC2021 emission
factors for mobile sources. The model was used to estimate criteria pollutant
emissions for both the construction and operational phases of the Project. The
existing hotel’s operational emissions were also analyzed using CalEEMod to
calculate net operational emissions between the new land usage and the
current land usage.
Air Quality Thresholds of Significance
The City of Carlsbad (City) refers to the CEQA guidelines that the County of
San Diego (County) has published for the thresholds that determine whether
or not a project is considered “significant.” These County guidelines refer to
the San Diego APCD’s significance thresholds in SDAPCD Regulation II, Rule
20.2, Table 20.2-1, Air Quality Impact Analysis (AQIA) Trigger Levels. Table 1
below lists the County’s/SDAPCD’s screening-level thresholds used to
determine air quality impacts which are listed in the County’s guidelines.1
TABLE 1
COUNTY OF SAN DIEGO SCREENING-LEVEL THRESHOLDS
Pollutant
Total Emissions
Lbs per Day Tons per Year
Respirable Particulate Matter (PM10) 100 15
Fine Particulate Matter (PM2.5) 55* 10
Oxides of Nitrogen (NOX) 250 40
Oxides of Sulfur (SOX) 250 40
Carbon Monoxide (CO) 550 100
Volatile Organic Compounds (VOC) 75** 13.7***
* EPA “Proposed Rule to Implement the Fine Particle National Ambient Air Quality Standards” published
September 8, 2005. Also used by the SCAQMD. ** Threshold for VOCs based on the threshold of significance for VOCs from the SCAQMD for the Coachella
Valley.
*** 13.7 Tons per Year threshold based on 75 lbs/day multiplied by 365 days/year and divided by 2000 lbs/ton.
Air Quality Study Assumptions
Construction Scenario
Construction of the Project would generate temporary criteria pollutant
emissions primarily from vehicles transporting construction workers to and
from the site, and diesel-powered equipment usage during the phases of
construction that will occur outdoors (e.g. paving and architectural coating).
Since the construction activities that will occur outdoors consist of grading and
construction of the new pickleball courts, bike shed, trash enclosure and
1 Guidelines for Determining Significance and Report Format and Content Requirements, Air Quality, County of San Diego Land Use and Environment Group, March 18, 2007.
https://www.sandiegocounty.gov/content/dam/sdc/pds/ProjectPlanning/docs/AQ-Guidelines.pdf
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landscaping, the land use type selected in CalEEMod was “Recreational” with a
subtype “City Park.” The total square footage of the pickleball courts and dog
run (5,433 square feet) was entered in CalEEMod as “Special Landscape Area.”
No outdoor demolition is to occur, but the existing hotel interior and exterior
will be repainted. To account for emissions from repainting of the existing
structure, the estimated square footage of the existing interior painting area
(136,017 square feet) and exterior painting area (22,440 square feet) was
input into CalEEMod. Construction is assumed to commence in October 2025
and to take approximately 2 - 3 months to complete. Default values for
construction equipment types and amounts and hours per day were assumed.
For the grading of the Project site for the new pickleball courts, bike shed,
trash enclosure and landscaping/hardscape installations, the area of
disturbance is 3,200 square feet and the construction site was assumed to be
watered 2 times per day to control fugitive dust emissions. An estimated 160
cubic yards (cy) of fill soil will be exported. New building square footage is
approximately 470 square feet (for the bike shed and trash enclosure) and
new landscaping area is approximately 3,407 square feet.
Operational Scenario (Existing Hotel)
The land use types selected in CalEEMod were “Recreational” with a subtype
“Hotel” (98 rooms, 66,699 square feet) with landscaping area of 35,034 square
feet and a “Parking Lot” area of 0.52 acre. Default values for population were
assumed. The traffic study calculated a trip generation rate of 882 average
daily trips (ADTs).2 It was also assumed that the hotel rooms do not include
fireplaces or woodstoves, but that there is currently one natural gas
fireplace in the lobby of the hotel, which operates 8 hours per day for 250 days
per year.
Operational Scenario (Proposed Multi-Family Apartments)
The first full year of Project operations was assumed to be 2027. The land use
types selected in CalEEMod were “Residential” with a subtype “Apartments Mid
Rise” (98 dwelling units, 67,169 square feet) with landscaping area of 38,447
square feet and a “Parking Lot” area of 0.52 acre. Default values for population
were assumed. The traffic study calculated a trip generation rate of 588
average daily trips (ADTs).3 It was also assumed that the Project would not
include the installation of fireplaces or woodstoves, but it was assumed that
the fireplace currently located in the lobby will remain in place and operate for
8 hours per day for 250 days per year.
Air Quality Study Results
Consistency with Air Quality Plan
The proposed Project is on a site that is designated as Planned Industrial (PI)
2 Trip Generation Comparison Table found on Sheet 2 of 3 of the Topographic Survey for The
Flats @ Terramar – 5010 Avenida Encinas, Carlsbad, CA 92008.
3 Ibid
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in the Planned Industrial (P-M) zone in the City’s General Plan.4 The Project
requires a Conditional Use Permit (CUP), pursuant to Carlsbad Municipal Code
(CMC) 21.42.071, Process 3 for residential uses in the P-M zone. With the CUP,
the proposed Project is consistent with the General Plan and zoning
designations. Because the proposed Project activities and associated vehicle
trips are lower than the current land use of “Hotel”, they are anticipated in
local air quality plans and the proposed Project would be consistent at a
regional level with the underlying growth forecasts in the RAQS and SIP.
Construction Criteria Pollutant Emissions
Table 2 shows the modeled estimated daily emission results and Table 3 shows
the estimated annual emission results for construction of the Project, with a
comparison to the significance thresholds listed in Table 1. CalEEMod results
are attached to this report.
TABLE 2
ESTIMATED PROJECT CONSTRUCTION EMISSIONS (DAILY)
Maximum Peak Daily Emissions
(lbs/day)
VOC/
ROG NOx CO SO2 PM10 PM2.5
2025 Peak Day Construction Emissions 17.7 10.5 10.5 0.018 5.92 3.04
2026 Peak Day Construction Emissions 17.6 0.89 1.51 <0.005 0.11 0.04
Significance Threshold 75 250 550 250 100 55
Threshold Exceeded? No No No No No No
Source: CalEEMod v. 2022.1.1.29, output attached in Attachment A. The higher value of summer or winter
mitigated daily emissions are shown.
TABLE 3
ESTIMATED PROJECT CONSTRUCTION EMISSIONS (ANNUAL)
Maximum Annual Emissions (tons/yr)
VOC/
ROG NOx CO SO2 PM10 PM2.5
2025 Construction Emissions 0.15 0.09 0.12 <0.005 0.019 0.010
2026 Construction Emissions 0.04 <0.005 <0.005 <0.005 <0.005 <0.005
Significance Threshold 13.7 40 100 40 15 10
Threshold Exceeded? No No No No No No
Source: CalEEMod v. 2022.1.1.29, output attached in Attachment A. The higher value of summer or winter
mitigated daily emissions are shown.
4 Carlsbad General Plan, City of Carlsbad California, September 2015.
https://www.carlsbadca.gov/home/showpublisheddocument/3416/637434861085570000
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Tables 2 and 3 show that daily and annual emissions of criteria pollutants from
construction activities are all well below the approved significance thresholds.
Operational Criteria Pollutant Emissions
Table 4 shows the modeled estimated daily emission results and Table 5 shows
the estimated annual emission results for operations of the Project and the
operations of the current land use (Hotel). The net operational emissions
(Project minus Hotel) are compared to the significance thresholds listed in
Table 1. CalEEMod results are attached to this report.
TABLE 4
ESTIMATED PROJECT OPERATIONAL EMISSIONS (DAILY)
Maximum Peak Daily Emissions (lbs/day)
VOC/
ROG NOx CO SO2 PM10 PM2.5
Operational Emissions
(Project) 4.34 1.99 22.8 0.044 3.83 1.01
Operational Emissions
(Current Hotel) 5.87 4.03 33.4 0.076 6.14 1.65
Net Operational Emissions
(Project – Current) -1.51 -2.04 -10.6 -0.032 -2.31 -0.64
Significance Threshold 75 250 550 250 100 55
Threshold Exceeded? No No No No No No
Source: CalEEMod v. 2022.1.1.29, output attached in Attachment A. The higher value of summer or
winter mitigated daily emissions are shown.
TABLE 5
ESTIMATED PROJECT OPERATIONAL EMISSIONS (ANNUAL)
Annual Emissions (tons/yr)
VOC/
ROG NOx CO SO2 PM10 PM2.5
Operational Emissions
(Project) 0.73 0.36 3.46 0.008 0.69 0.18
Operational Emissions
(Current Hotel) 1.00 0.73 5.48 0.013 1.10 0.30
Net Operational Emissions
(Project – Current) -0.26 -0.37 -2.02 -0.005 -0.41 -0.12
Significance Threshold 13.7 40 100 40 15 10
Threshold Exceeded? No No No No No No
Source: CalEEMod v. 2022.1.1.29, output attached in Attachment A.
Tables 4 and 5 show that net daily and annual emissions of criteria pollutants
due to operation of the Project actually decrease when netted against the
current hotel operational emissions. Additionally, all operational emissions due
to the Project are well below the approved significance thresholds.
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BlueScape Environmental 6 May 22,2025
Conclusions
The air quality study shows that criteria pollutant emissions due to construction
and operation of the Project are well below the City-approved significance
thresholds. No significant air quality effects are expected for this Project. The
Project qualifies for the Class 32 categorical exemption from CEQA.
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ATTACHMENT A
CALEEMOD RESULTS
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Flats at Terramar Construction AQ Analysis_052225 Custom Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
3. Construction Emissions Details
3.1. Grading (2025) - Unmitigated
3.3. Building Construction (2025) - Unmitigated
3.5. Paving (2025) - Unmitigated
3.7. Architectural Coating (2025) - Unmitigated
3.9. Architectural Coating (2026) - Unmitigated
5. Activity Data
5.1. Construction Schedule
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5.2. Off-Road Equipment
5.2.1. Unmitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
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5.18.2.1. Unmitigated
8. User Changes to Default Data
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name Flats at Terramar Construction AQ Analysis_052225
Construction Start Date 10/7/2025
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s)2.20
Precipitation (days)21.8
Location 5010 Avenida Encinas, Carlsbad, CA 92008, USA
County San Diego
City Carlsbad
Air District San Diego County APCD
Air Basin San Diego
TAZ 6223
EDFZ 12
Electric Utility San Diego Gas & Electric
Gas Utility San Diego Gas & Electric
App Version 2022.1.1.29
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft)Landscape Area (sq
ft)
Special Landscape
Area (sq ft)
Population Description
City Park 0.13 Acre 0.13 0.00 3,407 5,433 ——
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1.3. User-Selected Emission Reduction Measures by Emissions Sector
No measures selected
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Un/Mit.TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Winter
(Max)
———————————
Unmit.17.7 17.7 10.5 10.5 0.02 0.47 5.45 5.92 0.43 2.60 3.04
Average Daily
(Max)
———————————
Unmit.0.86 0.85 0.50 0.65 < 0.005 0.02 0.08 0.10 0.02 0.04 0.06
Annual (Max)———————————
Unmit.0.16 0.15 0.09 0.12 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01
2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily -
Summer
(Max)
———————————
Daily - Winter
(Max)
———————————
2025 17.7 17.7 10.5 10.5 0.02 0.47 5.45 5.92 0.43 2.60 3.04
2026 17.7 17.6 0.89 1.51 < 0.005 0.02 0.08 0.11 0.02 0.02 0.04
Average Daily ———————————
2025 0.86 0.85 0.50 0.65 < 0.005 0.02 0.08 0.10 0.02 0.04 0.06
2026 0.21 0.21 0.01 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005Oct. 28, 2025 Item #4 Page 62 of 131
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Annual ———————————
2025 0.16 0.15 0.09 0.12 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01
2026 0.04 0.04 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005
3. Construction Emissions Details
3.1. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Onsite ———————————
Daily, Summer
(Max)
———————————
Daily, Winter
(Max)
———————————
Off-Road
Equipment
1.29 1.09 10.1 10.0 0.02 0.46 —0.46 0.43 —0.43
Dust From
Material
Movement
——————5.31 5.31 —2.57 2.57
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily ———————————
Off-Road
Equipment
0.02 0.01 0.14 0.14 < 0.005 0.01 —0.01 0.01 —0.01
Dust From
Material
Movement
——————0.07 0.07 —0.04 0.04
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual ———————————
Off-Road
Equipment
< 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
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0.010.01—0.010.01——————Dust From
Material
Movement
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite ———————————
Daily, Summer
(Max)
———————————
Daily, Winter
(Max)
———————————
Worker 0.03 0.03 0.03 0.30 0.00 0.00 0.06 0.06 0.00 0.01 0.01
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.02 0.01 0.39 0.14 < 0.005 0.01 0.07 0.08 0.01 0.02 0.03
Average Daily ———————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005
Annual ———————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005
3.3. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Onsite ———————————
Daily, Summer
(Max)
———————————
Daily, Winter
(Max)
———————————
Off-Road
Equipment
0.62 0.52 5.14 6.94 0.01 0.22 —0.22 0.20 —0.20Oct. 28, 2025 Item #4 Page 64 of 131
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Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily ———————————
Off-Road
Equipment
0.02 0.02 0.20 0.27 < 0.005 0.01 —0.01 0.01 —0.01
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual ———————————
Off-Road
Equipment
< 0.005 < 0.005 0.04 0.05 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite ———————————
Daily, Summer
(Max)
———————————
Daily, Winter
(Max)
———————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily ———————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual ———————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.5. Paving (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
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Onsite ———————————
Daily, Summer
(Max)
———————————
Daily, Winter
(Max)
———————————
Off-Road
Equipment
0.61 0.51 4.37 5.31 0.01 0.19 —0.19 0.18 —0.18
Paving 0.00 0.00 —————————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily ———————————
Off-Road
Equipment
0.02 0.01 0.12 0.15 < 0.005 0.01 —0.01 < 0.005 —< 0.005
Paving 0.00 0.00 —————————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual ———————————
Off-Road
Equipment
< 0.005 < 0.005 0.02 0.03 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Paving 0.00 0.00 —————————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite ———————————
Daily, Summer
(Max)
———————————
Daily, Winter
(Max)
———————————
Worker 0.08 0.07 0.06 0.71 0.00 0.00 0.15 0.15 0.00 0.03 0.03
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily ———————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
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Annual ———————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.7. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Onsite ———————————
Daily, Summer
(Max)
———————————
Daily, Winter
(Max)
———————————
Off-Road
Equipment
0.15 0.13 0.88 1.14 < 0.005 0.03 —0.03 0.03 —0.03
Architectural
Coatings
17.5 17.5 —————————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily ———————————
Off-Road
Equipment
0.01 0.01 0.04 0.05 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Architectural
Coatings
0.79 0.79 —————————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual ———————————
Off-Road
Equipment
< 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Architectural
Coatings
0.14 0.14 —————————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite ———————————Oct. 28, 2025 Item #4 Page 67 of 131
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Daily, Summer
(Max)
———————————
Daily, Winter
(Max)
———————————
Worker 0.04 0.04 0.03 0.41 0.00 0.00 0.08 0.08 0.00 0.02 0.02
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily ———————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual ———————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.9. Architectural Coating (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Onsite ———————————
Daily, Summer
(Max)
———————————
Daily, Winter
(Max)
———————————
Off-Road
Equipment
0.15 0.12 0.86 1.13 < 0.005 0.02 —0.02 0.02 —0.02
Architectural
Coatings
17.5 17.5 —————————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily ———————————Oct. 28, 2025 Item #4 Page 68 of 131
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Off-Road
Equipment
< 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Architectural
Coatings
0.21 0.21 —————————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual ———————————
Off-Road
Equipment
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Architectural
Coatings
0.04 0.04 —————————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite ———————————
Daily, Summer
(Max)
———————————
Daily, Winter
(Max)
———————————
Worker 0.04 0.04 0.03 0.38 0.00 0.00 0.08 0.08 0.00 0.02 0.02
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily ———————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual ———————————
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
5. Activity Data
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5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description
Grading Grading 10/7/2025 10/13/2025 5.00 5.00 —
Building Construction Building Construction 11/4/2025 11/21/2025 5.00 14.0 —
Paving Paving 11/25/2025 12/8/2025 5.00 10.0 —
Architectural Coating Architectural Coating 12/9/2025 1/6/2026 5.00 21.0 —
5.2. Off-Road Equipment
5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
Grading Graders Diesel Average 1.00 6.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 6.00 367 0.40
Grading Tractors/Loaders/Back
hoes
Diesel Average 1.00 7.00 84.0 0.37
Building Construction Cranes Diesel Average 1.00 4.00 367 0.29
Building Construction Forklifts Diesel Average 2.00 6.00 82.0 0.20
Building Construction Tractors/Loaders/Back
hoes
Diesel Average 2.00 8.00 84.0 0.37
Paving Tractors/Loaders/Back
hoes
Diesel Average 1.00 7.00 84.0 0.37
Paving Cement and Mortar
Mixers
Diesel Average 4.00 6.00 10.0 0.56
Paving Pavers Diesel Average 1.00 7.00 81.0 0.42
Paving Rollers Diesel Average 1.00 7.00 36.0 0.38
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48
5.3. Construction Vehicles
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5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix
Grading ————
Grading Worker 7.50 12.0 LDA,LDT1,LDT2
Grading Vendor —7.63 HHDT,MHDT
Grading Hauling 4.00 20.0 HHDT
Grading Onsite truck ——HHDT
Building Construction ————
Building Construction Worker 0.00 12.0 LDA,LDT1,LDT2
Building Construction Vendor 0.00 7.63 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck ——HHDT
Paving ————
Paving Worker 17.5 12.0 LDA,LDT1,LDT2
Paving Vendor —7.63 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck ——HHDT
Architectural Coating ————
Architectural Coating Worker 10.0 12.0 LDA,LDT1,LDT2
Architectural Coating Vendor —7.63 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck ——HHDT
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.
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5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 0.00 0.00 136,017 22,440 —
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Cubic
Yards)
Material Exported (Cubic
Yards)
Acres Graded (acres)Material Demolished (sq. ft.)Acres Paved (acres)
Grading 0.00 160 3.75 0.00 —
Paving 0.00 0.00 0.00 0.00 0.10
5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.
5.7. Construction Paving
Land Use Area Paved (acres)% Asphalt
City Park 0.10 0%
5.8. Construction Electricity Consumption and Emissions Factors
kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2025 0.00 589 0.03 < 0.005
2026 0.00 589 0.03 < 0.005
5.18. Vegetation
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5.18.1. Land Use Change
5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year)Natural Gas Saved (btu/year)
8. User Changes to Default Data
Screen Justification
Land Use Per client: Outdoor construction activities consist of grading for and construction of the
pickleball courts, dog run, trash enclosure and bike shed. New landscaping area is 3,407
square feet.
Construction: Construction Phases Per client: Demolition activities are mostly indoors and there is no site prep. phase for exterior
construction. Grading of areas for pickleball courts, dog run, new bike shed and trash enclosure
to take approx. 5 days. Interior/exterior improvements to take approximately 2 weeks. Paving to
take approx. 10 days. Arch. coating to take approx. 1 week for exterior painting (added 2 more
weeks for interior painting.
Construction: Trips and VMT Added 10 trips for arch. coating phase to account for interior/exterior painting of the buildings.
Construction: Architectural Coatings Painting of the exterior and interior of the current building onsite is part of the Project.
Construction: Paving Paving of pickleball courts
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Flats at Terramar Operations AQ Analysis_052225 Custom Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.3. Area Emissions by Source
4.3.1. Unmitigated
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4.4. Water Emissions by Land Use
4.4.1. Unmitigated
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
5. Activity Data
5.9. Operational Mobile SourcesOct. 28, 2025 Item #4 Page 75 of 131
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5.9.1. Unmitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire PumpsOct. 28, 2025 Item #4 Page 76 of 131
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5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
8. User Changes to Default Data
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name Flats at Terramar Operations AQ Analysis_052225
Operational Year 2027
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s)2.20
Precipitation (days)21.8
Location 5010 Avenida Encinas, Carlsbad, CA 92008, USA
County San Diego
City Carlsbad
Air District San Diego County APCD
Air Basin San Diego
TAZ 6223
EDFZ 12
Electric Utility San Diego Gas & Electric
Gas Utility San Diego Gas & Electric
App Version 2022.1.1.29
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft)Landscape Area (sq
ft)
Special Landscape
Area (sq ft)
Population Description
Apartments Mid
Rise
98.0 Dwelling Unit 2.18 67,169 38,447 —273 —
Parking Lot 0.52 Acre 0.52 0.00 0.00 ———Oct. 28, 2025 Item #4 Page 78 of 131
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1.3. User-Selected Emission Reduction Measures by Emissions Sector
No measures selected
2. Emissions Summary
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Un/Mit.TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Unmit.4.59 4.34 1.88 22.8 0.04 0.05 3.78 3.83 0.05 0.96 1.01
Daily, Winter
(Max)
———————————
Unmit.4.04 3.81 1.99 16.2 0.04 0.05 3.78 3.82 0.05 0.96 1.00
Average Daily
(Max)
———————————
Unmit.4.26 4.02 1.98 19.0 0.04 0.05 3.72 3.77 0.05 0.94 0.99
Annual (Max)———————————
Unmit.0.78 0.73 0.36 3.46 0.01 0.01 0.68 0.69 0.01 0.17 0.18
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Mobile 2.51 2.30 1.61 17.2 0.04 0.03 3.78 3.81 0.03 0.96 0.99
Area 2.06 2.03 0.10 5.58 < 0.005 0.01 —0.01 0.01 —0.01
Energy 0.02 0.01 0.18 0.07 < 0.005 0.01 —0.01 0.01 —0.01
Water ———————————
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Waste ———————————
Refrig.———————————
Total 4.59 4.34 1.88 22.8 0.04 0.05 3.78 3.83 0.05 0.96 1.01
Daily, Winter
(Max)
———————————
Mobile 2.47 2.26 1.77 16.1 0.04 0.03 3.78 3.81 0.03 0.96 0.99
Area 1.55 1.54 0.04 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Energy 0.02 0.01 0.18 0.07 < 0.005 0.01 —0.01 0.01 —0.01
Water ———————————
Waste ———————————
Refrig.———————————
Total 4.04 3.81 1.99 16.2 0.04 0.05 3.78 3.82 0.05 0.96 1.00
Average Daily ———————————
Mobile 2.44 2.23 1.74 16.1 0.04 0.03 3.72 3.75 0.03 0.94 0.97
Area 1.80 1.78 0.06 2.76 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Energy 0.02 0.01 0.18 0.07 < 0.005 0.01 —0.01 0.01 —0.01
Water ———————————
Waste ———————————
Refrig.———————————
Total 4.26 4.02 1.98 19.0 0.04 0.05 3.72 3.77 0.05 0.94 0.99
Annual ———————————
Mobile 0.45 0.41 0.32 2.94 0.01 0.01 0.68 0.69 0.01 0.17 0.18
Area 0.33 0.33 0.01 0.50 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Energy < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Water ———————————
Waste ———————————
Refrig.———————————
Total 0.78 0.73 0.36 3.46 0.01 0.01 0.68 0.69 0.01 0.17 0.18
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4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Apartments
Mid Rise
2.51 2.30 1.61 17.2 0.04 0.03 3.78 3.81 0.03 0.96 0.99
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 2.51 2.30 1.61 17.2 0.04 0.03 3.78 3.81 0.03 0.96 0.99
Daily, Winter
(Max)
———————————
Apartments
Mid Rise
2.47 2.26 1.77 16.1 0.04 0.03 3.78 3.81 0.03 0.96 0.99
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 2.47 2.26 1.77 16.1 0.04 0.03 3.78 3.81 0.03 0.96 0.99
Annual ———————————
Apartments
Mid Rise
0.45 0.41 0.32 2.94 0.01 0.01 0.68 0.69 0.01 0.17 0.18
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 0.45 0.41 0.32 2.94 0.01 0.01 0.68 0.69 0.01 0.17 0.18
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5TOct. 28, 2025 Item #4 Page 81 of 131
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Daily, Summer
(Max)
———————————
Apartments
Mid Rise
———————————
Parking Lot ———————————
Total ———————————
Daily, Winter
(Max)
———————————
Apartments
Mid Rise
———————————
Parking Lot ———————————
Total ———————————
Annual ———————————
Apartments
Mid Rise
———————————
Parking Lot ———————————
Total ———————————
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Apartments
Mid Rise
0.02 0.01 0.18 0.07 < 0.005 0.01 —0.01 0.01 —0.01
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00
Total 0.02 0.01 0.18 0.07 < 0.005 0.01 —0.01 0.01 —0.01
Daily, Winter
(Max)
———————————
Apartments
Mid Rise
0.02 0.01 0.18 0.07 < 0.005 0.01 —0.01 0.01 —0.01
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Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00
Total 0.02 0.01 0.18 0.07 < 0.005 0.01 —0.01 0.01 —0.01
Annual ———————————
Apartments
Mid Rise
< 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00
Total < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
4.3. Area Emissions by Source
4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Hearths 0.01 < 0.005 0.04 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Consumer
Products
1.44 1.44 —————————
Architectural
Coatings
0.10 0.10 —————————
Landscape
Equipment
0.52 0.49 0.05 5.56 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Total 2.06 2.03 0.10 5.58 < 0.005 0.01 —0.01 0.01 —0.01
Daily, Winter
(Max)
———————————
Hearths 0.01 < 0.005 0.04 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Consumer
Products
1.44 1.44 —————————
Architectural
Coatings
0.10 0.10 —————————
Total 1.55 1.54 0.04 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
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Annual ———————————
Hearths < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Consumer
Products
0.26 0.26 —————————
Architectural
Coatings
0.02 0.02 —————————
Landscape
Equipment
0.05 0.04 < 0.005 0.50 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Total 0.33 0.33 0.01 0.50 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Apartments
Mid Rise
———————————
Parking Lot ———————————
Total ———————————
Daily, Winter
(Max)
———————————
Apartments
Mid Rise
———————————
Parking Lot ———————————
Total ———————————
Annual ———————————
Apartments
Mid Rise
———————————
Parking Lot ———————————
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Total ———————————
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Apartments
Mid Rise
———————————
Parking Lot ———————————
Total ———————————
Daily, Winter
(Max)
———————————
Apartments
Mid Rise
———————————
Parking Lot ———————————
Total ———————————
Annual ———————————
Apartments
Mid Rise
———————————
Parking Lot ———————————
Total ———————————
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
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Daily, Summer
(Max)
———————————
Apartments
Mid Rise
———————————
Total ———————————
Daily, Winter
(Max)
———————————
Apartments
Mid Rise
———————————
Total ———————————
Annual ———————————
Apartments
Mid Rise
———————————
Total ———————————
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipment
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Total ———————————
Daily, Winter
(Max)
———————————
Total ———————————
Annual ———————————
Total ———————————
4.8. Stationary Emissions By Equipment Type
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4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipment
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Total ———————————
Daily, Winter
(Max)
———————————
Total ———————————
Annual ———————————
Total ———————————
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipment
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Total ———————————
Daily, Winter
(Max)
———————————
Total ———————————
Annual ———————————
Total ———————————
4.10. Soil Carbon Accumulation By Vegetation Type
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4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Vegetation TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Total ———————————
Daily, Winter
(Max)
———————————
Total ———————————
Annual ———————————
Total ———————————
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Total ———————————
Daily, Winter
(Max)
———————————
Total ———————————
Annual ———————————
Total ———————————
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
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Avoided ———————————
Subtotal ———————————
Sequestered ———————————
Subtotal ———————————
Removed ———————————
Subtotal ———————————
————————————
Daily, Winter
(Max)
———————————
Avoided ———————————
Subtotal ———————————
Sequestered ———————————
Subtotal ———————————
Removed ———————————
Subtotal ———————————
————————————
Annual ———————————
Avoided ———————————
Subtotal ———————————
Sequestered ———————————
Subtotal ———————————
Removed ———————————
Subtotal ———————————
————————————
5. Activity Data
5.9. Operational Mobile Sources
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5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year
Apartments Mid
Rise
588 588 588 214,620 5,345 5,345 5,345 1,950,846
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise —
Wood Fireplaces 0
Gas Fireplaces 1
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 98
5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
136017.225 22,440 0.00 0.00 1,359
5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 180Oct. 28, 2025 Item #4 Page 90 of 131
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5.11. Operational Energy Consumption
5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr)
Land Use Electricity (kWh/yr)CO2 CH4 N2O Natural Gas (kBTU/yr)
Apartments Mid Rise 332,305 589 0.0330 0.0040 693,687
Parking Lot 19,842 589 0.0330 0.0040 0.00
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Land Use Indoor Water (gal/year)Outdoor Water (gal/year)
Apartments Mid Rise 3,443,041 702,238
Parking Lot 0.00 0.00
5.13. Operational Waste Generation
5.13.1. Unmitigated
Land Use Waste (ton/year)Cogeneration (kWh/year)
Apartments Mid Rise 72.4 —
Parking Lot 0.00 —
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg)Operations Leak Rate Service Leak Rate Times Serviced
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10.02.502.50< 0.0052,088R-410AApartments Mid Rise Average room A/C &
Other residential A/C
and heat pumps
Apartments Mid Rise Household
refrigerators and/or
freezers
R-134a 1,430 0.12 0.60 0.00 1.00
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor
5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr)Daily Heat Input (MMBtu/day)Annual Heat Input (MMBtu/yr)
5.17. User Defined
Equipment Type Fuel Type
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final AcresOct. 28, 2025 Item #4 Page 92 of 131
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5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year)Natural Gas Saved (btu/year)
8. User Changes to Default Data
Screen Justification
Land Use Total lot square footage = 2.7 acres
Operations: Vehicle Data Estimated 588 ADTs.
Operations: Hearths No fireplaces or hearths will be installed as part of the project. Assume the existing fireplace in
the lobby operates 8 hrs/day, 250 days/year.
Operations: Architectural Coatings Per client: Exterior painting area is approx. 22,440 square feet.
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Current Studio6 Hotel Operations_052025 Custom Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.3. Area Emissions by Source
4.3.1. Unmitigated
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4.4. Water Emissions by Land Use
4.4.1. Unmitigated
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
5. Activity Data
5.9. Operational Mobile SourcesOct. 28, 2025 Item #4 Page 95 of 131
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5.9.1. Unmitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire PumpsOct. 28, 2025 Item #4 Page 96 of 131
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5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
8. User Changes to Default Data
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name Current Studio6 Hotel Operations_052025
Operational Year 2025
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s)2.20
Precipitation (days)21.8
Location 5010 Avenida Encinas, Carlsbad, CA 92008, USA
County San Diego
City Carlsbad
Air District San Diego County APCD
Air Basin San Diego
TAZ 6223
EDFZ 12
Electric Utility San Diego Gas & Electric
Gas Utility San Diego Gas & Electric
App Version 2022.1.1.29
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft)Landscape Area (sq
ft)
Special Landscape
Area (sq ft)
Population Description
Hotel 98.0 Room 2.18 66,699 35,034 ———
Parking Lot 0.52 Acre 0.52 0.00 0.00 ———
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1.3. User-Selected Emission Reduction Measures by Emissions Sector
No measures selected
2. Emissions Summary
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Un/Mit.TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Unmit.6.32 5.87 3.77 33.4 0.08 0.12 6.02 6.14 0.12 1.53 1.65
Daily, Winter
(Max)
———————————
Unmit.5.72 5.31 4.03 28.6 0.07 0.12 6.02 6.14 0.12 1.53 1.64
Average Daily
(Max)
———————————
Unmit.5.92 5.49 3.99 30.0 0.07 0.12 5.93 6.05 0.12 1.50 1.62
Annual (Max)———————————
Unmit.1.08 1.00 0.73 5.48 0.01 0.02 1.08 1.10 0.02 0.27 0.30
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Mobile 4.19 3.83 2.91 29.8 0.07 0.06 6.02 6.07 0.05 1.53 1.58
Area 2.04 1.99 0.07 2.92 < 0.005 0.01 —0.01 0.01 —0.01
Energy 0.09 0.04 0.79 0.67 < 0.005 0.06 —0.06 0.06 —0.06
Water ———————————
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Waste ———————————
Refrig.———————————
Total 6.32 5.87 3.77 33.4 0.08 0.12 6.02 6.14 0.12 1.53 1.65
Daily, Winter
(Max)
———————————
Mobile 4.11 3.74 3.19 27.9 0.07 0.06 6.02 6.07 0.05 1.53 1.58
Area 1.52 1.52 0.04 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Energy 0.09 0.04 0.79 0.67 < 0.005 0.06 —0.06 0.06 —0.06
Water ———————————
Waste ———————————
Refrig.———————————
Total 5.72 5.31 4.03 28.6 0.07 0.12 6.02 6.14 0.12 1.53 1.64
Average Daily ———————————
Mobile 4.06 3.70 3.15 27.9 0.07 0.06 5.93 5.99 0.05 1.50 1.56
Area 1.77 1.75 0.04 1.44 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Energy 0.09 0.04 0.79 0.67 < 0.005 0.06 —0.06 0.06 —0.06
Water ———————————
Waste ———————————
Refrig.———————————
Total 5.92 5.49 3.99 30.0 0.07 0.12 5.93 6.05 0.12 1.50 1.62
Annual ———————————
Mobile 0.74 0.67 0.58 5.09 0.01 0.01 1.08 1.09 0.01 0.27 0.28
Area 0.32 0.32 0.01 0.26 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Energy 0.02 0.01 0.14 0.12 < 0.005 0.01 —0.01 0.01 —0.01
Water ———————————
Waste ———————————
Refrig.———————————
Total 1.08 1.00 0.73 5.48 0.01 0.02 1.08 1.10 0.02 0.27 0.30
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4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Hotel 4.19 3.83 2.91 29.8 0.07 0.06 6.02 6.07 0.05 1.53 1.58
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 4.19 3.83 2.91 29.8 0.07 0.06 6.02 6.07 0.05 1.53 1.58
Daily, Winter
(Max)
———————————
Hotel 4.11 3.74 3.19 27.9 0.07 0.06 6.02 6.07 0.05 1.53 1.58
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 4.11 3.74 3.19 27.9 0.07 0.06 6.02 6.07 0.05 1.53 1.58
Annual ———————————
Hotel 0.74 0.67 0.58 5.09 0.01 0.01 1.08 1.09 0.01 0.27 0.28
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 0.74 0.67 0.58 5.09 0.01 0.01 1.08 1.09 0.01 0.27 0.28
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
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Hotel ———————————
Parking Lot ———————————
Total ———————————
Daily, Winter
(Max)
———————————
Hotel ———————————
Parking Lot ———————————
Total ———————————
Annual ———————————
Hotel ———————————
Parking Lot ———————————
Total ———————————
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Hotel 0.09 0.04 0.79 0.67 < 0.005 0.06 —0.06 0.06 —0.06
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00
Total 0.09 0.04 0.79 0.67 < 0.005 0.06 —0.06 0.06 —0.06
Daily, Winter
(Max)
———————————
Hotel 0.09 0.04 0.79 0.67 < 0.005 0.06 —0.06 0.06 —0.06
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00
Total 0.09 0.04 0.79 0.67 < 0.005 0.06 —0.06 0.06 —0.06
Annual ———————————
Hotel 0.02 0.01 0.14 0.12 < 0.005 0.01 —0.01 0.01 —0.01
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00Oct. 28, 2025 Item #4 Page 102 of 131
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Total 0.02 0.01 0.14 0.12 < 0.005 0.01 —0.01 0.01 —0.01
4.3. Area Emissions by Source
4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Hearths 0.01 < 0.005 0.04 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Consumer
Products
1.43 1.43 —————————
Architectural
Coatings
0.09 0.09 —————————
Landscape
Equipment
0.52 0.48 0.02 2.90 < 0.005 0.01 —0.01 < 0.005 —< 0.005
Total 2.04 1.99 0.07 2.92 < 0.005 0.01 —0.01 0.01 —0.01
Daily, Winter
(Max)
———————————
Hearths 0.01 < 0.005 0.04 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Consumer
Products
1.43 1.43 —————————
Architectural
Coatings
0.09 0.09 —————————
Total 1.52 1.52 0.04 0.02 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Annual ———————————
Hearths < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
Consumer
Products
0.26 0.26 —————————
Architectural
Coatings
0.02 0.02 —————————
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< 0.005—< 0.005< 0.005—< 0.005< 0.0050.26< 0.0050.040.05Landscape
Equipment
Total 0.32 0.32 0.01 0.26 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Hotel ———————————
Parking Lot ———————————
Total ———————————
Daily, Winter
(Max)
———————————
Hotel ———————————
Parking Lot ———————————
Total ———————————
Annual ———————————
Hotel ———————————
Parking Lot ———————————
Total ———————————
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
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———————————Daily, Summer
(Max)
Hotel ———————————
Parking Lot ———————————
Total ———————————
Daily, Winter
(Max)
———————————
Hotel ———————————
Parking Lot ———————————
Total ———————————
Annual ———————————
Hotel ———————————
Parking Lot ———————————
Total ———————————
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Hotel ———————————
Total ———————————
Daily, Winter
(Max)
———————————
Hotel ———————————
Total ———————————
Annual ———————————
Hotel ———————————Oct. 28, 2025 Item #4 Page 105 of 131
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Total ———————————
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipment
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Total ———————————
Daily, Winter
(Max)
———————————
Total ———————————
Annual ———————————
Total ———————————
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipment
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Total ———————————
Daily, Winter
(Max)
———————————
Total ———————————
Annual ———————————
Total ———————————Oct. 28, 2025 Item #4 Page 106 of 131
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4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipment
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Total ———————————
Daily, Winter
(Max)
———————————
Total ———————————
Annual ———————————
Total ———————————
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Vegetation TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Total ———————————
Daily, Winter
(Max)
———————————
Total ———————————
Annual ———————————
Total ———————————
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land Use TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Total ———————————
Daily, Winter
(Max)
———————————
Total ———————————
Annual ———————————
Total ———————————
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T
Daily, Summer
(Max)
———————————
Avoided ———————————
Subtotal ———————————
Sequestered ———————————
Subtotal ———————————
Removed ———————————
Subtotal ———————————
————————————
Daily, Winter
(Max)
———————————
Avoided ———————————
Subtotal ———————————
Sequestered ———————————
Subtotal ———————————
Removed ———————————Oct. 28, 2025 Item #4 Page 108 of 131
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Subtotal ———————————
————————————
Annual ———————————
Avoided ———————————
Subtotal ———————————
Sequestered ———————————
Subtotal ———————————
Removed ———————————
Subtotal ———————————
————————————
5. Activity Data
5.9. Operational Mobile Sources
5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year
Hotel 882 882 882 321,930 8,518 8,518 8,518 3,108,924
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Hotel —
Wood Fireplaces 0
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Gas Fireplaces 1
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 0
5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
0 0.00 100,049 33,350 1,359
5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 180
5.11. Operational Energy Consumption
5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr)
Land Use Electricity (kWh/yr)CO2 CH4 N2O Natural Gas (kBTU/yr)
Hotel 783,602 589 0.0330 0.0040 2,953,067
Parking Lot 19,842 589 0.0330 0.0040 0.00
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Land Use Indoor Water (gal/year)Outdoor Water (gal/year)
Hotel 2,485,943 523,554Oct. 28, 2025 Item #4 Page 110 of 131
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Parking Lot 0.00 0.00
5.13. Operational Waste Generation
5.13.1. Unmitigated
Land Use Waste (ton/year)Cogeneration (kWh/year)
Hotel 53.7 —
Parking Lot 0.00 —
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg)Operations Leak Rate Service Leak Rate Times Serviced
Hotel Household
refrigerators and/or
freezers
R-134a 1,430 0.00 0.60 0.00 1.00
Hotel Other commercial A/C
and heat pumps
R-410A 2,088 1.80 4.00 4.00 18.0
Hotel Walk-in refrigerators
and freezers
R-404A 3,922 < 0.005 7.50 7.50 20.0
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
Oct. 28, 2025 Item #4 Page 111 of 131
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Current Studio6 Hotel Operations_052025 Custom Report, 5/20/2025
19 / 20
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor
5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr)Daily Heat Input (MMBtu/day)Annual Heat Input (MMBtu/yr)
5.17. User Defined
Equipment Type Fuel Type
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year)Natural Gas Saved (btu/year)
8. User Changes to Default Data
Screen JustificationOct. 28, 2025 Item #4 Page 112 of 131
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Current Studio6 Hotel Operations_052025 Custom Report, 5/20/2025
20 / 20
Land Use Total developed lot size is 2.7 acres.
Operations: Vehicle Data Estimated 882 ADTs.
Operations: Hearths Assume one natural gas fireplace in the hotel lobby.
Oct. 28, 2025 Item #4 Page 113 of 131
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Community Development Department | 1635 Faraday Ave. | Carlsbad, CA 92008 | www.carlsbadca.gov
Density Bonus
IB-112This bulletin outlines the development allowances
provided under Govt. Code §65915, commonly
referred to as state density bonus law. The bulletin is
only intended to summarize the key provisions of
state law rather than cite them in total. The
document has been updated to include recent state
legislation, including AB 1287, the “middle-income
homes density bonus law,” which became effective
January 1, 2024.
BACKGROUND
State density bonus law allows a developer to
increase density (total number of homes) allowed on
a property above the maximum set under a city’s local land use plan (Carlsbad General Plan) by as
much as 100%. In addition, qualifying applicants can
also receive reductions in required development
standards such as setbacks and height limits when
those standards prevent the applicant from achieving the density allowed under state law. Other tools
include reduced or no parking requirements for
certain project types.
In exchange for these benefits, a certain number of
the new dwelling units within the development
project must be reserved for lower-income
households, seniors, or the other eligible affordable
housing projects.
Pursuant to Government Code §65915(a)(1), each
jurisdiction must adopt an ordinance that specifies
how compliance with density bonus law will be
implemented. Failure to adopt an ordinance does not
relieve the city from complying with state density
bonus law. As such, the city’s adopted ordinance,
Carlsbad Municipal Code §21.86, references state
mandates where appropriate (as opposed to
repeating state code requirements) and focuses more
on the permit processing requirements for density
bonus applications.
ELIGIBILITY
Any housing development that proposes five or more
units and incorporates at least one of the following is
eligible for a density bonus. Note: Accessory Dwelling
Units (ADUs) may be included as part of a single-family
or multi-family development, but ADUs do not count
towards/against the total density allowed under state
density bonus. Refer to info-bulletin IB-111 for more
on ADUs.
•At least 5% of the housing units are restricted to
very low-income residents.
•At least 10% of the housing units are restricted to
low-income residents.
•At least 10% of the units in a for-sale housing
development are restricted for moderate-
income.
•100% of the housing units (other than manager’s
units) are restricted affordable with a maximum
of 20% of the units being moderate.
•At least 10% of the housing units are rent
restricted at the very low-income level for
transitional foster youth, disabled veterans, or
homeless persons.
•At least 20% of the housing units are for low-
income college students in housing dedicated for
full-time students at accredited colleges.
•The project donates at least one acre of land to
the city for very low-income units, and the land
Exhibit 7
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has the appropriate permits and approvals and
access to needed public facilities.
•The project is a senior citizen housing
development; in which case, no affordable units
are required.
•The project is a mobile home park that is age-
restricted to senior citizens; in which case, no
affordable units are required.
AFFORDABILITY DURATION
State density bonus law establishes how long an
affordable unit must stay affordable.
•Affordable rental units must be restricted at the
targeted income level group for at least 55 years.
•Affordable for-sale units must be restricted at the
targeted income level group for at least 30 years,
which starts after the initial sale of the affordable
unit. Affordable units may be sold at a market
price to other than targeted households provided
that the sale results in an equity sharing
agreement with the city.
DENSITY BONUS CALCULATIONS
Despite the city’s rounding requirements under CMC
§21.53.230 (Table A), for projects utilizing density
bonus, Government Code §65915(q) requires that
each component of any density calculation resulting in
fractional units shall be separately rounded up to the
next whole number. In other words, all density related
calculations must be rounded up.
Base Density Calculation
Step one in calculating density bonus is to calculate
the project’s base density, which represents the
number of dwelling units allowed under the city’s
General Plan, per acre of property. Calculating base
density under density bonus is no different from how
the city calculates density for standard residential
development projects, with the following exceptions:
•While the city uses developable (or net) acreage
in determining density, density bonus law
requires cities to use gross acreage. This
allowance was clarified in an HCD technical
assistance letter dated July 26, 2023.
•While the city utilizes a “mid-range” density
calculation for determining the allowable number
of units on a property, state law requires that
density bonus be calculated based upon the
maximum density allowed under the city’sGeneral Plan and zoning ordinance for the
subject property.
•Pursuant to SB-330 (Housing Crisis Act of 2019),
the city is prohibited from enforcing housing
caps. As such, the housing caps in the city’s
Growth Management Plan (GMP) cannot be
applied to new housing development projects.
Refer to IB-132 for more information on SB-330
and Reso No. 2021-074 for the city’s suspension
of the GMP cap limits and performance standard
moratorium provisions.
Density Bonus Calculation
Step two in calculating density bonus is to calculate
the project’s density increase, which represents the
number of units allowed in addition to the base
density units. These additional dwelling units are set
per a sliding scale, based upon two primary factors:
•The percentage of units in the project that will be
set aside (reserved) as affordable; and,
•The household income category of those
affordable units (i.e., very low, low, or moderate
income).
For convenience, a Density Bonus Table is included on
page six of the city’s Density Bonus Report (Form
P-1(H)). As you will see from the table, the number of
affordable units (far left column) and the level of
affordability (top row) greatly influence the number of
density bonus units that can be granted.
For example, a project that reserves 10% of its units as affordable for very low-income families is eligible for a
32.5% density bonus, as opposed to a density bonus of
only 20% if those same affordable units were reserved
for low-income families. Refer to info-bulletin IB-137
(Carlsbad’s Housing Plan) for more information on
household income and affordability.
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INCLUSIONARY HOUSING CALCULATIONS
To help provide local affordable housing, the city in
1993 adopted an inclusionary housing ordinance
(§21.85), which established the legal basis for
requiring affordable (inclusionary) housing units in
new residential development in the city.
For more information, refer to info-bulletin IB-157
(Inclusionary Housing Program). While the city’s
inclusionary regulations are separate from density
bonus law, there are a few important provisions in the
city’s inclusionary ordinance that directly affect
density bonus projects, as reflected below.
•The city’s inclusionary requirements apply to all
proposed development projects that include
residential units. This means that projects
subject to the state density bonus law/city’s
density bonus ordinance (§21.86), must also
comply with the city’s inclusionary housingordinance (§21.85).
•Projects proposing seven or more housing units
are required to restrict at least 15% of the total
proposed units for low-income households. The
total proposed units include base density and
density bonus units.
•When calculating inclusionary requirements,
fractional units resulting in less than 0.5 are
rounded down to the next whole number.
•The required affordable inclusionary units satisfy
the required affordable density bonus units.
The city’s application of its inclusionary code is
consistent with AB 2345 and the Department of
Housing & Community Development’s (HCD)
technical assistance letter dated September 2, 2022 to the City of West Hollywood.
THEORETICAL EXAMPLE
Sometimes showing the math helps folks better
understand how density bonus works. The following is
a theoretical example on how these different density
calculations are applied.
SECONDARY DENSITY BONUS
AB 1287 (Alvarez, 2023) amended state density bonus
law by requiring jurisdictions to award an additional
(or second) density bonus for projects that have
allocated a certain amount of affordable housing for
very-low income, low-income, or moderate-income
units, as summarized in the section below.
Minimum Eligibility
The proposed density bonus project must comply with
one of the following affordability requirements to be
eligible for an additional density bonus.
•A minimum of 15% of the base units are reserved
for very low-income households; or
•A minimum of 24% of the base units are reserved
for low-income households; or
•A minimum of 44% of the base units are reserved
for moderate-income households.
A property 1.003 net acres in size has a zoning
designation of R-15 (11.5 to 15 dwelling units per
acre). Under density bonus, this results in a maximum
base density of 15.05 units for this site (1.003 acres
multiplied by 15 units per acre), which rounds up to 16
units.
The applicant proposes that 3 of the 16 units will be
reserved for low-income households. This results in
18.7% of the units that will be reserved as affordable
housing (3 affordable units divided by 16 base density
units), which rounds up to 19%.
Based on the sliding scale found in the Density Bonus
Table in the Density Bonus Report (Form P-1(H)), with
19% of the affordable units reserved for low-income
families, the project’s base density can increase by
33.5% or 5.36 units (16 base density units multiplied by
33.5%), which rounds up to 6 density bonus units for a
total of 22 units for this project.
To satisfy the city’s inclusionary ordinance, a total of
3.3 affordable low-income units are required for this
project (15% inclusionary requirement multiplied by 22
total units), which rounds down to 3 units.
In this example, the 3 affordable low-income units
satisfy the requirements under state density bonus law
as well as the city’s inclusionary housing ordinance.
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Density Increase
Under state law, the city must grant the developer an
additional density bonus if additional units are set
aside for either very low or moderate-income
households. Like traditional density bonus calculations,
the secondary density bonus is also on a sliding scale,
based on the project’s base density.
For reference, the secondary density bonus allowances
have been included in the Density Bonus Table found
on page six of the city’s Density Bonus Report (Form P-
1(H)). To help illustrate how this secondary density
bonus is applied, let us relook at the previous
theoretical example.
It is important to highlight that AB 1287 caps the
affordable set aside at 50%. For projects that allocate
the maximum of moderate-income units (44%), they
would only be eligible to set aside another 6% of very-
low income or moderate-income units to receive an
additional bonus of 23.75% or 22.5%, respectively.
REMOVAL OF EXISTING RENTAL UNITS
Under density bonus law, projects that include the
demolition or removal of affordable rental units are
ineligible for density bonus unless the units are
replaced concurrent with the development of the
project. This provision applies to the following types of
rental units:
• Units subject to recorded restrictions
• Units subject to rent control
• Units occupied by very low- or low-income
households
If household rental income cannot be determined, the
city may assume households are occupied by low-
income households in the same proportion as low-
income renters in the city, consistent with AB 2556.
Additionally, under state law the affordable units
required under density bonus may also be used to
satisfy any replacement unit requirements. This
allowance was clarified in an HCD technical assistance
letter dated December 14, 2023.
DEVELOPMENT STANDARD DEVIATIONS
Traditional development projects must be designed to
comply with city established development standards
and design regulations such as building height
limitations, setback requirements, minimum parking
ratios, and on-site open space directives.
However, under state density bonus law, applicants
can deviate from these development standards when
found that the standards prevent the applicant from
achieving the density allowed under the state law.
There are two types of tools available to applicants:
• Incentives & Concessions
• Waivers
Instead of 3 units, the applicant now proposes
that 5 of the 16 units will be reserved for low-
income households. This results in 31.2% of the
units that will be reserved as affordable housing,
which rounds up to 32%.
With 32% of the affordable units reserved for
low-income households, the project’s base
density can increase by 50% or 8.0 units (16 base
density units multiplied by 50%), for a total of 24
units.
Since more than 24% of the base units are being
reserved for low-income households (31.2%, specifically), this project is eligible for a second
density bonus. In this example, the applicant
proposes to reserve an additional 15% of the
base units for moderate-income households,
which results in 2.4 units (16 base density units
multiplied by 15%) that rounds up to 3 units.
With 15% of the affordable units reserved for
moderate-income households, the project’s base
density can increase by an additional 50% or 8.0
units (16 base density units multiplied by 50%).
As a result, the total project size increases to 32
total units, 8 of which will be restricted
affordable.
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Incentives & Concessions
Incentives and concessions, as defined under state
density bonus law, allow a developer to deviate from
those requirements when modifying such regulations
would provide “identifiable and actual cost
reductions” to provide for affordable housing costs
and rents. This requirement was clarified in the court
decision of Schreiber v. City of Los Angeles (later
codified as part of the passage of AB 1287) and the
sections below reflect the holdings in that case.
Application
A few key considerations regarding the application of
incentives or concessions:
• Under the government code, the terms
“incentives” and “concessions” are used
interchangeably. As such, the city considers them
one in the same (“incentives/concessions”).
• A density bonus project is entitled to
incentives/concessions even without a request
for a density bonus --- if a developer provides the
affordable housing specified under density bonus
law, they are eligible for incentives/concessions.
• The city applies incentives/concessions to the
development standards or design regulations
requiring deviation, not to the individual
situation.
For example, say a project proposes three
separate buildings with each building requiring
an increase in the city’s maximum building
height standard. In this example, the city would
require one incentive/concession for this
deviation, even though the deviation applies to
three separate buildings.
If that same project requires a deviation from
the building height and rear yard setback
standards, the city will require two
incentives/concessions since these are
considered two different development
standards.
• Pursuant to the Schreiber case, which was later
codified as part of the passage of AB 1287, a
developer is not required to provide financial
evidence (i.e., pro forma) documenting that a
requested incentive/concession will result in
actual cost reductions. However, applicants need
to reasonably document “why” the requested
incentive/concession will reduce affordable
housing development costs. As such, the city
requires applicants to provide reasonable
documentation to show that a requested
incentive/concession will result in identifiable
cost reductions to provide for affordable housing
costs or rents.
Number Authorized
The number of incentives/concessions that can be
requested by a developer varies by the amount and
type of affordable units being proposed, as reflected
below.
INCOME % OF AFFORDABLE UNITS1
Very Low 5% 10% 15% 16% ≥80%
Low 10% 17% 24% --- ≥80%
Moderate 10% 20% 30% 45% 20%
Student2 20% --- --- --- ---
Incentives 1 2 3 4 53
1 The % of a project’s affordable units must be at least equal to the listed %.
2 Lower-income student in a dedicated student housing development.
3 To qualify for 5 incentives, a project must reserve at least 80% of the units for lower income households (very low, low, or combination thereof). The
remaining 20% may be reserved for moderate income households. The
applicant shall also receive a height increase of up to three additional stories, or 33 feet.
As noted in footnote #1, when determining the
appropriate number of incentives/concessions, a
project’s percentage of affordable units must be “at
least” equal to the percentages shown in the table
above (§65915(d)(2)). In other words, the percentages
in the table are minimums.
So, in the case of the theoretical example project that
reserved 19% of the units for low-income, the
applicant is eligible to receive two
incentives/concessions. If affordable units are
provided to satisfy the city’s inclusionary housing
obligation above required density bonus affordable
units, the total number of affordable units count
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when determining the number of
incentives/concessions allowed.
Grounds for Denial
Under the Schreiber case, the city must grant a
requested incentive/concession unless it finds, under
a preponderance of evidence, the following:
• The incentive/concession does not result in
identifiable and actual cost reductions to provide
for affordable housing costs or rents.
• Granting the incentive/concession would have a
specific adverse impact on public health or safety
or on property listed on the California historical
register, which cannot be mitigated, or would be
contrary to state or federal law.
Waivers
Density bonus law offers another form of assistance to
developers, separate from concessions/waivers, in the
form of “waivers.” A waiver is a modification or
reduction to established development standards or
design regulations when those requirements
potentially cause the construction of the development
project physically infeasible, if not approved.
Application
A few key considerations regarding waivers.
• Waivers do not count as an incentive/concession
and can be used in concert (combined) with
incentives/concessions.
• The developer must provide sufficient
documentation justifying why the city’s
established development standard(s) or design
regulation(s) physically preclude construction of
the project and why the waiver(s) is necessary.
Sufficient documentation may include a written
explanation of the physical constraints
accompanied with an exhibit showing the site
and developable envelope.
Number Authorized
Unlike concessions/incentives, applicants are
entitled to waive any established development
standards or design regulations that would physically
preclude the development from achieving the
allowances authorized under density bonus law. In
other words, there is no limit in the number of
waivers an applicant can request.
Grounds for Denial
The city is not required to grant or otherwise
authorize a waiver if it finds that the requested
deviation or modification causes a specific adverse
impact on public health or safety and cannot be
mitigated, would have an adverse impact on property
listed on the California historical register, or would
otherwise violate state or federal law.
Like incentives/concessions, the city must include a
showing of substantial evidence when making a
finding of denial on a waiver request.
PARKING ALLOWANCES
Despite the city’s parking requirements under CMC
§21.44, the city may not require more than the
following parking ratios for a density bonus project
(including parking for persons with disabilities):
Unit Type Required Parking
Studio 1 space
One Bedroom 1 space
Two Bedroom 1.5 spaces
Three Bedroom 1.5 spaces
Four Bedroom 2.5 spaces
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State law further limits parking requirements for
specified projects as reflected below.
• 0.5 spaces per unit for projects with at least 11%
very low income, 20% lower income, or 40%
moderate income, when located within ½ mile of
accessible major transit stop, which in the city is
the Carlsbad Village Coaster Station or Poinsettia
Coaster Station.
• No parking spaces are required for projects
meeting the following:
o 100% affordable to lower income residents,
within ½ mile of a major transit stop, which
in the city is the Carlsbad Village Coaster
Station or Poinsettia Coaster Station.
o 100% senior or special needs rental project
affordable to lower income, either with
paratransit service or within ½ mile of an
accessible bus route that operates at least
eight times per day.
o Rental supportive housing development
that is 100% affordable to lower income households.
Parking requirements may be satisfied by providing
individual parking stalls or in tandem, so long as the
stalls are provided onsite.
Requesting these parking standards does not count as
an incentive/concession or waiver; however, an
applicant may request further parking standard
reductions using the incentive/concession or waiver
allowances.
DENSITY BONUS APPLICATIONS
The city’s Density Bonus Ordinance can be found in
CMC §21.86 and applicants should follow the permit
submittal requirements and processes set forth in the
Land Use Review Application (Form P-1).
Pursuant to changes in state density bonus law that
went into effective in 2019, the city developed a
supplemental form outlining the information that
must be submitted for a complete density bonus
application; referred to as the Density Bonus Report
Form P-1(H). This includes project location, property
description, project description, density calculations,
and information on any requested
incentives/concessions or waivers.
Once a development application is determined to be
complete, the city, under state law, will notify the
applicant of the level of density bonus and parking
ratio the development is eligible to receive.
PROJECTS IN THE COASTAL ZONE
When a density bonus project is proposed in the
coastal zone, legislation that went into effect in 2019
attempted to strike a balance between the state goals
of promoting housing and protecting the coast.
Density bonuses, incentives/concessions, waivers, and
parking reductions are to be permitted so that they
are consistent with both density bonus law and the
California Coastal Act. Granting of a density bonus or
an incentive does not require a general plan, zoning, or
local coastal plan amendment.
YOUR OPTIONS FOR SERVICE
To schedule an appointment to submit an application
or to learn more about density bonus, please contact
the Planning Division at 442-339-2600 or via email at
Planning@carlsbadca.gov.
NOTE: State density bonus law is regularly updated
and revised by the state legislature and the city may
not be able to timely update this bulletin to reflect
the most current provisions. Please refer to current
state law (§65915 et seq.).
Oct. 28, 2025 Item #4 Page 120 of 131
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PRE-PABD STAMPED ENVELOPE MAIL TO:
Alliance Development Services,Inc.
17828 Villamoura Drive
Poway,CA 92064
liif yDate:
5010 Avenida Encinas -Proposed Conversion of Existing Hotel Building to Multifamily
Use -Apartments (AMEND 2024-0008 /CUP 2024-0009 /PUD 2024-0009 (DEV99017)
Re:
IN FAVOR
OPPOSE
COMMENTS:
Thank you for your response
/X Cl^
Exhibit 8
Oct. 28, 2025 Item #4 Page 121 of 131
Docusign Envelope ID: F7BA3FB4-2FAB-47B0-A7A6-64B020650B0E
From:Wickham, Kurt
To:Lauren Yzaguirre
Subject:RE: Proposed Development 5010 Avenida Encinas (DEV99017)
Date:Friday, January 17, 2025 8:43:17 AM
Attachments:image001.gifimage002.png
It doesn’t change my overall comment. This is an atrocity.
From: Lauren Yzaguirre <lauren.yzaguirre@carlsbadca.gov>
Sent: Friday, January 17, 2025 7:47 AM
To: Wickham, Kurt <kwickham@westdevllc.com>
Subject: [ES] RE: Proposed Development 5010 Avenida Encinas (DEV99017)
CAUTION: [This email originated from outside of the organization. Do not click links or openattachments unless you recognize the sender and know the content is safe.]
Hi Kurt,
All units will be required to meet the building code for residential dwellings, which includes having a kitchen with
cooking facilities.
Thanks,
Lauren Yzaguirre
Community Development Department
Lauren Yzaguirre, Associate Planner
1635 Faraday Ave.
Carlsbad, CA 92008
442-339-2634 direct | Lauren.Yzaguirre@carlsbadca.gov
Development or Planning-related Inquiries
The Planning Team is here to assist you with resources online, by phone (442) 339-2610, by email
planning@carlsbadca.gov, or in-person by appointment.
Appointment-Based Submittals
Appointments for new projects can be made online.
Application Resubmittals
Please contact your planner directly to schedule a resubmittal drop-off appointment.
Facebook | Twitter | You Tube | Flickr | Pinterest | Enews
Oct. 28, 2025 Item #4 Page 122 of 131
Docusign Envelope ID: F7BA3FB4-2FAB-47B0-A7A6-64B020650B0E
From: Wickham, Kurt <kwickham@westdevllc.com>
Sent: Thursday, January 16, 2025 3:18 PM
To: Lauren Yzaguirre <lauren.yzaguirre@carlsbadca.gov>
Subject: RE: Proposed Development 5010 Avenida Encinas (DEV99017)
Wow! If I’m reading this right, the larger units are <700 SQF and the smaller units are about 315 SQF with no
kitchen appliances. If that’s right, that seems totally ridiculous to me.
From: Lauren Yzaguirre <lauren.yzaguirre@carlsbadca.gov>
Sent: Tuesday, January 14, 2025 9:49 AM
To: Wickham, Kurt <kwickham@westdevllc.com>
Subject: [ES] RE: Proposed Development 5010 Avenida Encinas (DEV99017)
CAUTION: [This email originated from outside of the organization. Do not click links or open
attachments unless you recognize the sender and know the content is safe.]
Hi Kurt,
Please see the attached plans and project description for the Inns of America Project located at the corner of
Cannon and Avenida Encinas.
Please let me know if you have any questions.
Thanks,
Lauren Yzaguirre
Community Development Department
Lauren Yzaguirre, Associate Planner
1635 Faraday Ave.
Carlsbad, CA 92008
442-339-2634 direct | Lauren.Yzaguirre@carlsbadca.gov
Development or Planning-related Inquiries
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planning@carlsbadca.gov, or in-person by appointment.
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Oct. 28, 2025 Item #4 Page 123 of 131
Docusign Envelope ID: F7BA3FB4-2FAB-47B0-A7A6-64B020650B0E
From: Wickham, Kurt <kwickham@westdevllc.com>
Sent: Wednesday, January 8, 2025 1:09 PM
To: Lauren Yzaguirre <lauren.yzaguirre@carlsbadca.gov>
Subject: Proposed Development 5010 Avenida Encinas (DEV99017)
Lauren,
I represent the Cannon Court Owners Association and West Real Estate, owners of the West Village
shopping center located between 4960-4990 Avenida Encinas (other than the West Inn & Suites, which is a
different owner). We received a letter from Alliance Development Services notifying us of their pending
application to convert the Motel 6 into apartments, inviting us to contact you for additional information about
their application if we wish.
We were surprised to see the number of units proposed equaled the same number as the number of current
hotel rooms. How can we obtain whatever information from the application that is publicly available,
including the floor plans for the project?
Thank you in advance,
Kurt
Kurt K. Wickham | Executive Vice President
o: 760-602-5827 m: 858-945-7618
a: 4960 Avenida Encinas, Carlsbad, CA 92008
w: www.westdevllc.com e: kwickham@westdevllc.com
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Oct. 28, 2025 Item #4 Page 124 of 131
Docusign Envelope ID: F7BA3FB4-2FAB-47B0-A7A6-64B020650B0E
PRE-PAID STAMPED ENVELOPE MAIL TO:
Alliance Development Services,Inc.
17828 Villamoura Drive
Poway,CA 92064
Date:
5010 Avenida Encinas -Proposed Conversion of Existing Hotel Building to Multifamily
Use -Apartments (AMEND 2024-0008 /CUP 2024-0009 /PUD 2024-0009 (DEV99017)
Re:
IN FAVOR
OPPOSE
COMMENTS:
r h)6'kf^k ^[I iOA
r^A [y 5 V ^^rLryjp \np/VA^cr~
7T
I
Thank you for your response
Oct. 28, 2025 Item #4 Page 125 of 131
Docusign Envelope ID: F7BA3FB4-2FAB-47B0-A7A6-64B020650B0E
PRE-PAID STAMPED ENVELOPE MAIL TO:
Alliance Development Services,Inc.
17828 Villa moura Drive
Poway,CA 92064
Date:
5010 Avenida Encinas -Proposed Conversion of Existing Hotel Building to Multifamily
Use -Apartments (AMEND 2024-0008 /CUP 2024-0009 /PUD 2024-0009 (DEV99017)
Re:
IN FAVOR
OPPOSE
COMMENTS:
03^p\clc\€baiv>Coor-\>SJUY\
Thank you for your response
Oct. 28, 2025 Item #4 Page 126 of 131
Docusign Envelope ID: F7BA3FB4-2FAB-47B0-A7A6-64B020650B0E
PRE-PAID STAMPED ENVELOPE MAIL TO:
Alliance Development Services,Inc.
17828 Villamoura Drive
Poway,CA 92064
Date;&\
5010 Avenida Encinas -Proposed Conversion of Existing Hotel Building to Multifamily
Use -Apartments (AMEND 2024-0008 /CUP 2024-0009 /PUD 2024-0009 (DEV99017)Re:
IN FAVOR
OPPOSE
COMMENTS:
Co,?>Xs\>aA—S
3
Thank you for your response
Oct. 28, 2025 Item #4 Page 127 of 131
Docusign Envelope ID: F7BA3FB4-2FAB-47B0-A7A6-64B020650B0E
PRE-PAID STAMPED ENVELOPE MAIL TO:
Alliance Development Services,Inc.
17828 Villamoura Drive
Poway,CA 92064
Date:
5010 Avenida Encinas -Proposed Conversion of Existing Hotel Building to Multifamily
Use -Apartments (AMEND 2024-0008 /CUP 2024-0009 /PUD 2024-0009 (DEV99017)
Re:
IN FAVOR
OPPOSE
COMMENTS:
7J TO T(h^u 1
■i^axir
Thank you for your response
Oct. 28, 2025 Item #4 Page 128 of 131
Docusign Envelope ID: F7BA3FB4-2FAB-47B0-A7A6-64B020650B0E
August 15, 2025
Jeff E. Johnson, Esq.
15055 Paso del Sol Del Mar, CA 92014
858.353.2397 JeffJca622@gmail.com
Re: Project proposed at 5010 Avenida Encinas, Carlsbad, 92008 (APN 210-090-52-00)
AMEND 2024-0008/CUP 2024-0009/ PUD 2024-0009 (DEV99017) -INNS OF
AMERICA
Dear Chair and Planning Commission Members:
As a property owner in the City of Carlsbad, I write in support of this project. Not only
will it renovate and repurpose the property, this plan will add 98 much needed units of
workforce housing to our community. I see nothing but a win-win in this ingenious
transformation of an underutilized motel property into a robust source of housing without
adding density to the community.
I hope that you will agree and I urge you vote to approve this attractive and important
proposal.
Page 1 of1
Item 1 - Correspondence Received by 3pm, 8-18-2025
Oct. 28, 2025 Item #4 Page 129 of 131
Docusign Envelope ID: F7BA3FB4-2FAB-47B0-A7A6-64B020650B0E
1
Eric Lardy
From:Melanie Burkholder
Sent:Tuesday, October 14, 2025 11:06 AM
To:City Clerk
Subject:FW: Motel 6 conversion
Follow Up Flag:Follow up
Flag Status:Flagged
Please include for the October 28th meeƟng.
Dr. Melanie Burkholder
City Council Member, District 1
City of Carlsbad
1200 Carlsbad Village Drive
Carlsbad, CA 92008
www.carlsbadca.gov
442-339-2830 (City Hall)
442-637-2853 (mobile/text)
-----Original Message-----
From: Dawn Sheals <dsheals@icloud.com>
Sent: Monday, September 8, 2025 12:25 PM
To: Keith Blackburn <keith.blackburn@carlsbadca.gov>; Priya Bhat-Patel <priya.bhat-patel@carlsbadca.gov>; Mum Cell
<jeansheals@icloud.com>
Cc: Melanie Burkholder <melanie.burkholder@carlsbadca.gov>; Kevin Shin <kevin.shin@carlsbadca.gov>; Teresa Acosta
<teresa.acosta@carlsbadca.gov>; Manager Internet Email <manager@carlsbadca.gov>
Subject: Motel 6 conversion
Dear Mayor Blackburn, the City Council, and City Manager Patnoe,
First, thank you for your service to our city. I was raised in Carlsbad, and returned here as soon as I could as a working
adult.
I am wriƟng to you about Motel 6 becoming the Flats at Terramar. I’m excited about work proceeding to alleviate the
housing crunch that we as a city are experiencing. We definitely need more housing opƟons at different price points.
I do have a couple of quesƟons, though. Can the low income housing be allocated to people who already work in our
community? I am thinking of junior teachers (beginning salary approximately $29,000), first responders, librarians and
people who work to make our community beƩer and stronger, but who may be just starƟng out and need the
affordability this might provide?
The City of Carlsbad in the past has had a program that helped these groups to purchase their first home in Carlsbad, and
I was just hoping that we might help this group as well.
Oct. 28, 2025 Item #4 Page 130 of 131
Docusign Envelope ID: F7BA3FB4-2FAB-47B0-A7A6-64B020650B0E
2
Is the number of units designated for low income set, or can it be increased?
Finally, will we be able to suggest changes to the design (like how about a futsal court in addiƟon to a pickle ball court?)
Thank you for your Ɵme and again for what you do of the city of Carlsbad,’
Dawn Sheals
Carlsbad Resident
CAUTION: Do not open aƩachments or click on links unless you recognize the sender and know the content is safe.
Oct. 28, 2025 Item #4 Page 131 of 131
Docusign Envelope ID: F7BA3FB4-2FAB-47B0-A7A6-64B020650B0E
Inns of America
Lauren Yzaguirre, Senior Planner
Community Development
October 28, 2025
AMEND 2024-0008/CUP 2024-0009/ PUD 2024-0009
1
C cityof
Carlsbad
PROCEDURES
1.Staff Presentation
2.City Council questions on staff
presentation
3.Applicant presentation (10 Min.)
4.City Council opportunity to ask questions of applicant
5.Open public testimony
6.Close public testimony
7.Staff and Applicant response (if
necessary)
8.City Council discussion
9.City Council vote
2
{city of
Carlsbad
Project Location
3
•5010 Avenida Encinas
•3.12 acres
•65,763 sf 98-guestroom
hotel
•Pool/spa
•123 parking spaces
INNS OF AMERICA
AMEND 2024-0008/CUP 2024-0009/ PUD 2024-0009 (DEV99017)
0
0 30 60 120 180
(City of
Carlsbad
4
General Plan Zoning
{city of
Carlsbad
Project Features
98 apartment units
15 affordable units
123 parking spaces
2 pickleball courts
1,070 SF dog run
288 SF storage
INNS OF AMERICA
5
Ex. Hotel/Prop.
98-Unit Multi-
Family Dwelling
Prop.
Dog Run
Prop.
Pickleball
Courts
Ext. Pool/BBQ
Area
Prop.
Storage
6Al<6EGIUE (,RILL
EXISTII-I:'> UTILITIES -----"&~":""'\r-~-'--"~~-REFER TO CIVIL
PLANS TYP
EXISTl>G RECYCLED
WATER METER FOR
IRRIGATION
PTUAL
CAPE
EXISTIN:", RECYQ.ED
6ACKFlOUJ Fa;?
IRRIGATION
PLAN
EXISTIN:", 6' ~16~ C~INLINK FENCE TO
f<fMAINTYP.
'\
'\
'\
'\
'\
'\
'\
'\
'\
{city of
Carlsbad
INNS OF AMERICA
6
{city of
Carlsbad
INNS OF AMERICA
7
Ca
n
n
o
n
R
d
.
(city of
Carlsbad
INNS OF AMERICA
Government Code §65915:
Allows a developer to increase density
Allows reductions in development standards
Percentage of units must be reserved as affordable
housing
8
STATE DENSITY BONUS LAW
1111111
C cityof
Carlsbad
INNS OF AMERICA
99
Density Bonus Calculation
Base Density
125 units
Density Bonus
5% of base density = 7 very low-income units
20% density bonus allowed = 150 units max
Inclusionary Calculation
15% of total units = 15 units
1111111
{city of
Carlsbad
INNS OF AMERICA
10
Market Rate Quantity Affordable Quantity Total
83 15 98 Total Units Proposed
Very Low Low Moderate Total
7 5 3 15 affordable units
Affordable Units by Income Level
Affordability
{city of
Carlsbad
Waiver 1
INNS OF AMERICA
1111
•Inclusionary Housing Standard 21.85.030(C): at least 10% of the lower-income
units provided as 3 or more bedrooms.
STATE DENSITY
BONUS LAW
Waiver 2
INNS OF AMERICA
1212
•Residential Planned Development Standard 21.45.060 (Table C) (C.2): 40-foot
setback from Cannon Road
STATE DENSITY
BONUS LAW
6’ fence
LOCK WAL L
1111111
...
/ ..
... _.,,,,---.. / _.,,,,---_.,,,,---
_.,,,,---
Waiver 3
INNS OF AMERICA
1313
•Planned Development Standard 21.45.060 (Table C) (C.9):
200 square feet of community recreation space per unit
(19,600 square feet)
STATE DENSITY
BONUS LAW
~"i'o~s-~~~-'<-~~ ~=
!Xl&II>() MCYQ.!C> ~~~~W,
IIIAIPl:MEIE!t>OR
R<l6All()H
OPEN SPACE LEGEND
~ NOTES
E:;;;;;;;J ru"" AREA
~MPOOL· eea AREA ACTIVE
~DOC, RUN AREA ACTIVE
111111111111 llt-'ICl<LEBALL COURT AREA ACTIVE
RECREATIONAL OPEN SPACE AREA
AREA AREA TYPE
PICKLEBALL AREA ACTIVE
DOG RUN AREA ACTIVE
POOL AREAi BBQ AREA ACTIVE
GRASS ALONG ENCINAS PASSIVE
TOTAL
REQU~ED RECREATIONAL SPACE
TOTAL NEEDED f
TOT .AL ACTIVE LANDSCAPE AREA: 70% *
TOTAL F'ASIVc LANDSCAPE AREA ~
QTY.
4,290 SF
989 SF
5,589 SF
4 ,650 SF
15,518 SF
19,600 SF
(4,082) SF
PERCENT OF
TOTAL AREA
280/c
6o/c
36o/c
:Vic
tlXJ'l/c
Waiver 4
INNS OF AMERICA
1414
•Planned Industrial Zone Development Standard 21.34.070(A): 35-foot max.
building height with architectural projections up to a max. height of 45 feet
STATE DENSITY
BONUS LAW
45.6’43.3’
36.9’45.5’
INNS OF AMERICA
15
Public Notice & Stakeholder Outreach
•Early public notice
•Information packet with survey
{city of
Carlsbad
INNS OF AMERICA
16
Public Comments
•7 comments in support
•2 comment in opposition
•1 comment in response to opposition
{city of
Carlsbad
INNS OF AMERICA
17
Recommended Condition 1
Prior to obtaining and securing building permits, the
Developer shall submit a written declaration from the
seller/hotel operator to the Housing & Homeless
Services Director attesting that any person who has
occupied a unit in the existing hotel for more than 30
consecutive days and will be temporarily or
permanently displaced by the project received
advanced notice to vacate the premises and
information regarding potential rights that may be
required or afforded under California Government
Code Section 66300.6 or other state law intended to
assure replacement and/or ongoing affordability of
existing residential units to the extent such state law is
applicable.
INNS OF AMERICA
18
Recommended Condition 2
If a third party makes a binding determination any of
the units in the existing hotel are occupied by tenants,
or were occupied by tenants in the five years
preceding the development application, the Developer
must notify the Housing & Homeless Services Director
of the third party’s binding determination and must
agree to amend the Affordable Housing Agreement as
the Housing & Homeless Services Director determines
is necessary to ensure the development replaces the
subject units and contains affordable units at the
percentages required under state law, including but
not limited to California Government Code Sections
65590 and 65915(c)(3)(A).
INNS OF AMERICA
19
Residential Uses in the P-M Zone
REQUIREMENT COMPLIES
Conditional Use Permit
Planned Development Permit
Integral part of an industrial park or large industrial
use
Compatible with industrial use
Efficient vehicular, bicycle or pedestrian
transportation
40 du/ac max density (31.4 du/ac proposed)✓
{city of
Carlsbad
Project Consistency
General Plan (PI)
Zoning Ordinance (P-M)
Planned Development Ordinance
Mello II Segment of the LCP
Inclusionary Housing Ordinance
State Density Bonus Law/Density Bonus
Ordinance
INNS OF AMERICA
20
C cityof
Carlsbad
INNS OF AMERICA
CEQA §15332 – Infill Development Projects
≤ 5 acres in urbanized areas
21
California Environmental Quality Act
C cityof
Carlsbad
Recommended Action
INNS OF AMERICA
22
Adopt the resolution APPROVING a CEQA Determination
of Exemption, Coastal Development Permit Amendment,
Conditional Use Permit and Planned Development
Permit.
C cityof
Carlsbad