HomeMy WebLinkAbout2025-10-15; Planning Commission; 01; 2647 Jefferson St. Homes - Demolition of an existing single-family residence and the development of a 12-unit, three-story residential condominium project on a 0.34-acreMeeting Date: Oct. 15, 2025 Item
To: Planning Commission
Staff Contact: Kyle Van Leeuwen, Associate Planner; 442-339-2611;
kyle.vanleeuwen@carlsbadca.gov
Subject: 2647 Jefferson St.Homes - Demolition of an existing single-family residence and
the development of a 12-unit, three-story residential condominium project on a
0.34-acre site.
Location: 2647 Jefferson St. / 155-170-24-00 / District 1
Numbers: CT 2024-0006 / PUD 2024-0007 / CDP 2024-0036 (DEV2024-0094)
Applicant/Representative: Jonathan Frankel, Rincon Homes, 925-708-3638, jfrankel@rincongrp.com
CEQA Recommendation: ☐ Not a Project ☒ Exempt ☐ IS/ND or IS/MND ☐ EIR☐Other:
Permit Type(s): ☐SDP ☐ CUP ☒ CDP ☒ TM/TPM ☐ GPA ☐ REZ ☐ LCPA☒Other: PUD
Commission Action: ☒Decision ☐ Recommendation to City Council ☐ Informational (No Action)
Recommended Actions
That the Planning Commission ADOPT the Planning Commission Resolution (Exhibit 1) APPROVING a CEQA
exemption and APPROVING Tentative Tract Map CT 2024-0006, Planned Development Permit PUD 2024-0007,
and Coastal Development Permit CDP 2024-0036, based on the findings and subject to the conditions contained
therein.
Existing Conditions & Project Description
Existing Setting
The subject site consists of one parcel totaling 0.34
acres, 15,006 square feet, located at 2647 Jefferson St.,
north of Laguna Drive (Exhibit 2), and is within the Mello
II segment of the city’s Local Coastal Program and Local
Facilities Management Zone 1. The property is currently
developed with an existing single-family residence and
attached single-car garage. Topographically, the site is
flat and currently takes vehicle access from Jefferson
Street. The project site is bordered on three sides by
multi-family developments with single and multi-family
developments across Jefferson Street.
Site Map
1
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Table “A” below includes the General Plan and Zoning designations, Village & Barrio Master Plan (VBMP) land use
district(s), and current land uses of the subject site and surrounding properties.
TABLE A – SITE AND SURROUNDING LAND USE
Location General Plan Designation Zoning Designation Current Land Use
Site Residential, 19-23 dwelling
units per acre (R-23)
Multiple-Family Residential (R-3) Single-family residence
North Residential, 19-23 dwelling
units per acre (R-23)
Multiple-Family Residential (R-3) Multifamily residences
South Residential, 19-23 dwelling
units per acre (R-23)
Multiple-Family Residential (R-3) Multifamily residences
East Residential, 11.5-15 dwelling
units per acre (R-15)
Multiple-Family Residential (R-3) Single-family residences &
Multifamily residences
West Residential, 19-23 dwelling
units per acre (R-23)
Multiple-Family Residential (R-3) Multifamily residences
General Plan Designation(s) Zoning Designation(s)
Proposed Project
The applicant proposes demolishing an existing single-family residence at 2647 Jefferson St. (APN 155-170-24-00)
and the construction of a 12-unit, residential condominium project on one lot totaling 0.34 acres (15,006 square
feet). This project is considered an in-fill site located within the Mello II Segment of the Local Coastal. The
development of the proposed condominium project requires the approval of a Tentative Tract Map (CT 2024-
0006), a Planned Development Permit (PUD 2024-0007), and a Coastal Development Permit (CDP 2024-0036). The
Tentative Tract Map Subdivision is considered major as it involves the division of land into five or more
condominiums.
The project’s base density, which represents the number of dwelling units allowed under the city’s R-23 General
Plan land use designation, is 19-23 dwelling units per acre. Under the base density, 8 dwelling units are allowed.1
1 Potential unit yield are calculations are based on CMC provisions (Chapter 21.53). Under the R-15 General Plan land use designation, 7.9
dwelling units are allowed, which is normally rounded down. However, in the context of State Density Bonus Law, fractional units are
rounded up to the next whole number. Therefore, the proposed project’s base density is 9 dwelling units.
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An application for a density bonus is a request by an applicant proposing to include affordable units to build
more units than the General Plan and Zoning designations allow. The applicant is seeking a density bonus under
State law, which would entitle the developer to increase the density of the project by 38.75% in return for
designating at least 12% of the base dwelling units (1 unit of 8 units) affordable to very low-income households.
The density bonus that is authorized by State law (Gov. Code §65915 et seq.) is set on a sliding scale based upon
the percentage of affordable units in the project, ranging from 5% to 50% additional units over the base number
of units permitted pursuant to the General Plan.
With the 38.75% density bonus, the maximum number of residential units allowed on the site is 12 units, with
one of those required to be restricted as affordable to very low-income households (per State Density Bonus
Law). The developer has chosen to build all 12 residential units allowed under State law. State law also entitles
the developer to other incentives intended to help make the development of affordable housing economically
feasible, including but not limited to reduced parking requirements and concessions and waivers such as
reduced setback and minimum square footage requirements. The project is proposing one density bonus
incentive/concession and eight density bonus waivers that are discussed in Exhibits 4 and 5.
In addition to the affordable unit provided for the project to be granted a density bonus under State law, the
developer is required to comply with Carlsbad’s Inclusionary Housing Ordinance. Under the inclusionary
ordinance, developments proposing a total of seven or more units must provide at least 15% of the
development's base density units as affordable to lower income households. This project is required to provide
one (1) unit deed restricted to lower-income households; 8 units X 15% = 1 unit (1.2 rounded down). The one (1)
very low-income unit proposed satisfies both the State Density Bonus Law and Inclusionary Housing Ordinance
requirements.
The proposed 12-unit condominium project is designed as four triplex condominium structures creating 12
residential units, with all units being approximately 1,670 square feet in size. Each of the units will include two or
three bedrooms, a roof deck, and an attached single-car garage designed to accommodate two cars with the use
of a parking lift system, accessed from a common drive isle.
As condominiums are proposed, the underlying lot will be held in common interest between the 12 property
owners. The common areas include a private drive aisle, guest parking, and common landscaped areas. All
buildings are three stories with a building height of 34 feet, 1.625 inches, with roof deck guard rails extending an
additional 3.5 feet and architectural features extending an additional 5.5 feet. Access to each of the units will be
provided by a 24-foot drive isle off Jefferson Street, and the project will provide two uncovered visitor parking
spaces.
The architectural design of the project is a contemporary style featuring rectangular massing, balconies off the
second floors and flat roofs with a protruding architectural corner element to provide visual interest. Primary
building materials include sand finish stucco, and composite wood siding. The primary colors proposed are white
and grey, with black accents for garages, window frames, and guardrails. Renderings of the project are included
as exhibit 11.
Grading quantities include zero cubic yards of cut, 1,200 cubic yards of fill, and 1,700 cubic yards of remedial
grading. A grading permit will be required for the project. The proposed project will provide frontage
improvements along Jefferson Street, including a curb, gutter, and sidewalk.
Public Outreach & Comment
The Developer has completed the Early Public Notice procedures pursuant to City Council Policy No. 84
(Development Project Public Involvement Policy). A notice of project application was mailed on Oct. 8, 2024, to
all owners of property located within a 600-foot radius and all residents within a 100-foot radius of the project
site. A two-foot-tall by three-foot-wide yellow sign was also posted at the project site on Oct. 7, 2024, notifying
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all pass-by traffic of the project, which provides project name, application numbers, description, as well as both
Developer and city staff contact information. A total of 658 property owners and occupant notifications were
mailed the notice of project application.
A total of two comments were received as a result of the early public notice. Comments received listed concerns
regarding parking availability and loss of village character from new taller buildings. All comments submitted are
documented in the administrative record and are attached to the staff report (Exhibit 8). To summarize these
public comments, the comments and staff responses, along with references to reports or documents with
respect to each issue, are provided below.
• Availability of street parking: Parking for residents of the project is provided as required by the Carlsbad
Municipal Code. The project will provide a garage designed to accommodate two vehicles for each unit
and will also provide two on-site visitor spaces. In total the project requires three (3) visitor parking
spaces. Consistent with CMC provisions (Chapter 21.45, Table C), on-street visitor parking is permitted
on public streets when specific requirements are met. The additional visitor parking space required is
identified as on-street, parallel parking spaces, consistent with those requirements. As the site currently
has two separate ten-foot driveways, and the project proposes one 20-foot vehicle entrance to the site,
the development of the site will not physically decrease the amount of available street parking.
• Building Height: The building height complies with the 35-foot maximum height limit of the Multiple-
Family Residential (R-3) Zone. A density bonus waiver of height limits is not requested.
Project Analysis
General Plan Consistency
The project site has a General Plan Land Use designation of R-23 Residential which allows for the
development of residential units at a density of 19 to 23 dwelling units per acre (du/ac). The City of Carlsbad
General Plan includes several goals and policies that guide development and land use within the city. A
discussion of how the project is consistent with the applicable General Plan policies is summarized in Exhibit
4.
Municipal Code Consistency
The City of Carlsbad Municipal Code (CMC), most notably Tile 21 Zoning Code, includes requirements and
provisions that guide development and land use within the city, consistent with the General Plan. The project is
required to comply with all applicable regulations and development standards of the CMC including those for
the Multiple-Family Residential (R-3) zone (CMC Chapter 21.16) and Planned Developments (CMC Chapter
21.45). Specific compliance with these relevant requirements is described in Exhibit 4.
Local Coastal Program Consistency
The project site is in the Coastal Zone and requires a Coastal Development Permit. The project complies with the
Local Coastal Program (Mello II Segment), including all goals and policies of the General Plan and all zoning code
standards, as referenced above. Additional information on the Coastal Development Permit and Local Coastal
Program findings is included in Exhibit 4.
The project’s discretionary applications are all within the purview of the Planning Commission per the Carlsbad
Municipal Code. The Planning Commission’s action on the project will be an approval or denial, with appeal
available to City Council. The project site is also located with the appeals jurisdiction of the California Coastal
Commission; and therefore, the CDP is appealable to the State
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State Density Bonus
The Developer is seeking an increase in the allowable density of the project under Gov. Code §65915 et seq., the
State Density Bonus Law. This law allows a developer to increase the density on a property above the maximum
limit set by a city’s general plan in exchange for reserving a certain number of the new dwelling units as
affordable or other qualifying housing for at least 55 years. 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 waved or revised when such deviations are needed to achieve the density
allowed under State law.2 The 0.34-acre site is located in the R-23 General Plan Land Use Designation, which
permits a density range of 19 to 23 dwelling units per acre (stated as a minimum to maximum density range).
This results in a maximum base density of 7.9 units (0.34 acres multiplied by 23 units per acre), which rounds up
to 8 units for this site (pursuant to Density Bonus Law, all density calculations are rounded up.) The density
bonus that is authorized by State law is set on a sliding scale based upon the percentage of affordable units in
the project, ranging from 5% to 50% additional units over the number ordinarily permitted.
The Developer is requesting a density bonus of up to 38.75% allowed under State law, for a total of 4 additional
units (8 units multiplied by 38.75%, rounded up). In exchange for the 38.75% density bonus, the Developer is
required to designate 12% of the 8 base maximum density units, or one (1) unit, as affordable density bonus
units. The affordable density bonus units are required to be affordable to “very low-income households” for a
period of 55 years. The developer is proposing to construct 12 units at a density of 35.3 dwelling units per acre.
The project is requesting incentives, concessions or waivers as allowed under State Density Bonus Law. Pursuant
to CMC Section 21.86.060, the Density Bonus Ordinance, a project can request incentives, concessions and
waivers as defined in State Density Bonus Law, based on the percentage of affordable units.
Specifically, the Developer is requesting two concessions/incentives and eight waivers from development
standards of the Carlsbad Municipal Code as listed below and included in Exhibit 5. Pursuant to State Density
Bonus Law, the project is entitled to two concessions or incentives as long as the concession/incentive or waiver
does not cause a specific adverse impact on public health or safety, an adverse impact on property listed on the
California Historical Register or would violate state or federal law; and there is no limit to the number of waivers
an applicant can request.
Concession/Incentive
1. Incentive request to forgo full frontage improvements along Jefferson Street. Specifically, to retain the
current five-foot sidewalk width opposed to installing a six-foot sidewalk, which is the current standard
width for new sidewalks.
2. Incentive request to forgo replacing all existing 14-inch ACP water main along the entire 100-foot street
frontage with new 14” PVC water main. Only the section where new connections will be made to the
water main will be replaced (approximately 20 feet).
Waivers
1. Waiver of CMC Planned Development Standard 21.45.080 (Table E)(E.4) requiring buildings to observe a
setback of 10 feet from any public street (10 feet setback from east property line required –6 feet
proposed).
2 Refer to Exhibit 6 for an info-bulletin that provides more information on how State Density Bonus Law works. Oct.. 15, 2025 Item #1 5 of 343
2. Waiver of CMC R-3 Standard 21.16.050(A)(1) requiring a side yard setback which has a width not less
than ten percent of the width of the lot (10 feet setback from north and south property lines required – 5
feet proposed).
3. Waiver of CMC R-3 Standard 21.16.060(A)(1)(b) requiring he rear property line the equivalent of twice
the required side yard (20 feet rear-yard setback from east property line required – 10 feet proposed for
main structures, 7 feet, 7 inches proposed for allowed intrusions, and three feet proposed for trash
enclosure).
4. Waiver of CMC Planned Development Standard 21.45.080 (Tabel E) (E.7) requiring a minimum dimension
of six feet for a patio, porch, or balcony that fulfills the private recreation space requirement (six feet
minimum required – 4.5 feet proposed)
5. Waiver of CMC Planned Development Standard 21.45.060 (Table C) (C.9) requiring community recreation
space of 150 square feet per unit (1,800 square feet required – 0 square feet proposed).
6. Waiver of CMC Planned Development Standard 21.45.080(Tabel E) (E.2) limiting the maximum lot
coverage to 60% (61.7% lot coverage proposed)
7. Waiver of CMC Planned Development Standard 21.45.080 (Table E) (E.6) requiring a minimum interior
dimension for a single-car garage to be 12 feet by 20 ft (11 feet by 20 feet proposed).
8. Waiver of CMC Planned Development Standard 21.45.080 (Table E) (E.5) requiring a minimum building
separation of 10 feet (A separation of 7.5 feet is proposed to allow for fire riser room, main building
maintains 10-foot separation).
Inclusionary Housing Ordinance
Pursuant to CMC Chapter 21.85, Inclusionary Housing Ordinance, 15% of the base units, or one (1) unit, shall be
constructed and restricted both as to occupancy and affordability to lower-income households; 8 units X 15% = 1
unit (1.2 rounded down). The one (1) very low-income unit proposed to satisfy State Density Bonus
requirements also satisfies the Inclusionary Housing Ordinance requirements.
Housing Crisis Act of 2019 (HCA)
This project is subject to California Gov. Code §65589.5(j)(1), which states when a proposed housing
development project complies with the applicable, objective general plan, zoning, and subdivision standards and
criteria that were in effect at the time that the application was deemed complete, cities shall not disapprove the
project or impose a condition requiring lower density unless the city finds based on a preponderance of
evidence that the project would have a specific, adverse impact on public health and safety, or there is no
feasible method to satisfactorily mitigate or avoid such adverse 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; and
there is no feasible method to satisfactorily mitigate or avoid the adverse impact, other than the disapproval of
the project or the approval of the project upon the condition that it be developed at a lower density.
There is not a preponderance of the evidence that the project would have a specific, adverse impact on public
health and safety. The design of the site development and the types of improvement would not cause serious
public health or safety problems since the project would not degrade the levels of service on the adjoining
streets, drainage system, public facilities, and city sewer and water is available to the site or can be provided.
The project’s proposed street alignments, grades, and widths; drainage and sanitary facilities and utilities,
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including alignments and grades thereof; location and size of all required easements and right-of-way; lot size
and configuration; and traffic and emergency response access were all reviewed for compliance to relevant city
policies and codes. The proposed deviations (i.e., waivers requested as part of the proposed density bonus,
which are permitted pursuant to State Density Bonus Law), supplement the Developer’s land use application to
avoid restrictive zoning limitations that would preclude the project as it has been designed and submitted to the
city.
Discretionary Actions & Findings
In addition to the Coastal Development Permit required for development within the Coastal Zone, the following
discretionary actions are requested. Additional information on the Coastal Development Permit and Local
Coastal Program findings is included in Exhibit 4.
Tentative Tract Map CT 2024-0006
Pursuant to CMC Section 21.45.050, Planned Developments, approval of a Major Subdivision Map (Tentative
Tract Map) is required with the processing of a Major Planned Development Permits (five or more dwelling
units). Staff finds that the required findings for this application can be met (Exhibit 1).
Planned Development Permit PUD 2024-0007
Pursuant to Section 21.45.050, Planned Developments application and permit, approval of a Major Planned
Development Permit is required for a project proposing five or more dwelling units. Staff finds that the required
findings for this application can be met (Exhibit 1).
Environmental Review
Prior to final action by the decision-making body on the project, an environmental determination shall be made
by the appropriate decision-makers as part of the approval action to ensure agency compliance with the California
Environmental Quality Act (CEQA).
Staff has reviewed the scope of the project and applicable studies provided by the applicant and finds that the
project belongs to a class of projects that the State Secretary for Resources has found do not have a significant
impact on the environment, and it is therefore categorically exempt from the requirement for the preparation of
environmental documents pursuant to CEQA in accordance with CEQA Guidelines §15332 (In-Fill Development
Projects):
• The project is consistent with the General Plan as well as the zoning ordinance in terms of land use,
density, and development standards.
• The project is within the city limits, is less than five acres in size, and is surrounded by urban uses.
• Because the site contains only non-native and ornamental vegetation, the site has no value as habitat for
endangered, rare, or threatened species.
• Approval of the project would not result in any significant effects relating to traffic (as verified by the
Vehicle Miles Traveled Analysis prepared by LOS Engineering dated May 13, 2025), noise (as verified by
the Noise Study prepared by Birdseye Planning Group dated June 2024), air quality (as verified by the Air
Quality/Greenhouse Gas Study by Birdseye Planning Group dated July 2024), or water quality.
• The subject site is served by public and private utilities, including the city’s water, sewer, and electrical
utilities. The subject site has access and is served directly from Jefferson St. which is an existing developed
roadway with existing utilities. Water infrastructure in the vicinity of the project site is maintained and
operated by CMWD. Sewer service is currently provided by the City of Carlsbad to the project site via the
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existing public sewer system in the vicinity of the project. Water service for domestic and fire protection
uses would be provided via the existing water connections to the existing public water system.
Furthermore, the project would pay the required water connection fees to help offset the project’s
contribution to the city’s water collection infrastructure needs. For sewer, according to City of Carlsbad
Utilities Department staff, the sewer lines adjacent to the site need to be upsized along the project’s flow
path (in pipes downstream of the project site, north of Laguna Dr.) to accommodate the project’s addition
of 12 residential units and other future growth in the area. Utilities staff indicated that facilities to service
the proposed project are reasonably expected to be available within the next five years. Therefore, the
site can be adequately served by all required utilities and public services.
A draft Notice of Exemption is included as Exhibit 9. This must be reviewed and considered prior to approval of
the project. The draft Notice of Exemption demonstrates that the project qualifies for the exemption – and that
none of the exceptions to categorical exemptions listed in the CEQA Guidelines Section 15300.2 or CMC Chapter
19.04 have been triggered. As part of an additional and optional public disclosure, the draft Notice of Exemption
was posted on the city’s website on September 10, 2025, and an email was sent to all interested parties that
have expressed interest in this project or have signed up to receive environmental notices.
Conclusion
Considering the information above and in the referenced Exhibits, staff has found that the proposed project is
consistent with all applicable policies of the General Plan, Local Coastal Program, provisions of the Municipal
Code, and Local Facilities Management Zone 1. All required public improvements and utilities are available to
serve the proposed development. In addition, there are no environmental issues associated with the project.
The project is conditioned to ensure the proposed project’s compatibility with the surrounding properties and
that the public health, safety, and welfare of the community are maintained. The project would be required to
comply with all applicable California Building Standards Codes and engineering standards through the standard
building permit and civil improvement plan checking process. Staff recommends the Planning Commission adopt
the resolution approving the project, as described in this staff report.
Exhibits
1.Planning Commission Resolution (CT/PUD/CDP)
2.Location Map
3.Disclosure Statement
4.Project Analysis (General Plan, Zoning Ordinance)
5.Supplemental Application - Density Bonus Checklist
6.Informational Bulletin IB-112 – State Density Bonus Law
7.Informational Bulletin IB-157 – Inclusionary Housing Program
8.Public Comments
9.Draft Notice of CEQA Exemption and Exhibits
10.List of Acronyms and Abbreviations
11.Project Renderings
12.Reduced Plans (Full Size Exhibit(s) “A” – T” dated OCT. 15, 2025 on file in the Planning Division.)
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Exhibit 1
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Docusign Envelope ID: 170CA876-DFEA-4E30-86D6-71F97F581 BAS
PASSED, APPROVED, AND ADOPTED at a regular meeting of the Planning Commission of the City of Carlsbad,
California, held on Oct. 15, 2025, by the following vote, to wit:
AYES: Meenes, Burrows, Foster, Hubinger, Merz, Fitzgerald.
NAYES: Lafferty.
ABSENT: None.
ABSTAIN: None.
ROY MEENES, Chairperson
CARLSBAD PLANNING COMMISSION
ATTEST:
ERIC LARDY
City Planner
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Exhibit 2
2647 JEFFERSON STREET HOMES
CT 2024-0006 / PUD 2024-0007 / CDP 2024-0036
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APPLICATION AND ACKNOWLEDGEMENT INFORMATION
This submittal form (Part A through Part F) must be completed as part of your application with the City
of Carlsbad. Your project cannot be reviewed until this information is completed.
PART A. Owner Authorization and Consent
NOTE: This Consent and Disclosure Form must list the name of the principal owners (10% or greater) and
attach a copy of the current corporate articles, partnership agreement, or trust document, as applicable.
Provide name(s) of the person(s) authorized to sign on behalf of the organization. (A separate page may
be attached if necessary.) IF NO INDIVIDUALS OWN MORE THAN 10% OF THE SHARES, PLEASE INDICATE
NOT-APPLICABLE (N/A) IN THE SPACE BELOW.
This is to certify under penalty of perjury that the undersigned is/are the record owner(s) of the
property known as:
Assessor’s Map Book, Page and Parcel (APN/APNs): ___________________________________________
________________________________________________________________________________ ; and
Street Address (if applicable): ____________________________________________________________.
that I/we (full legal name of all record owners) consent to the filing of the Land Use Review Application
on our property for processing by the City of Carlsbad Planning Division. I/We declare under penalty of
perjury that I/we have reviewed this Affidavit and the information is true and correct.
Name: __________________________________________________________________
Signature: _______________________________________________________________
Name: __________________________________________________________________
Signature: _______________________________________________________________
Name: __________________________________________________________________
Signature: _______________________________________________________________
(For additional names, please use a separate sheet of paper)
Exhibit 3
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IMPORTANT: A Grant Deed is required if the ownership does not match city records. Ownership on the
deed must correspond exactly with the ownership listed. If the owner noted on the Grant Deed does not
match the person signing as Property Owner, provide paperwork documenting the person signing is
authorized to sign as a Property Owner.
Whenever any excavation, fill, or other project-related improvement requires entry onto adjacent
property for any reason, the Land Use Review Application shall include the written consent or legal
easements or other property rights of the adjacent property owner or their authorized representative,
and shall include such consent with the application package. The application will not be deemed
complete unless and until all necessary consent documents are so filed. The consent shall be in a form
acceptable to the City Planner. If the proposed improvements on the adjacent property change the
nature of the property’s development rights (or implied bundle of rights), the city might require
recordation of a Covenant and Agreement for Offsite Improvements and Release of Liability as a
condition of project approval.
Does the project’s limits of disturbance encroach on property not owned by the Property Owner?
☐ Yes ☐ No If yes, attach adjacent owner authorization.
PART B. Owner Declarations (to be signed by Property Owner)
I/We hereby certify under penalty of perjury that I have read the information below and that:
1. I/We understand that it is the responsibility of the Applicant to substantiate the request through
the requirements of the application.
2. I/We understand that if there is a zoning violation on the property, application review may be
delayed. Any unpermitted structures or uses must either be removed or legalized at part of this
application.
3. I/We understand that if this application is approved, I/we may be required to record a covenant
with the County Recorder’s Office, the form and content that is satisfactory to the City and its
City Attorney, to notify future owners of the project approval and restrictions.
4. If this Land Use Review Application is approved or conditionally approved, I/we hereby certify
that I/we will comply with all conditions attached to the approval action. I/We understand that
the failure to comply with any conditions shall constitute grounds for the revocation or
modification of the approval, permit, or other authorizations provided.
5. Prior to any use of the project site pursuant to the permit issued, all conditions of approval (if
any) will be completed or secured in the manner as stated or required.
Property Owner Signature(s): _________________________________________________________
Name(s): __________________________________________________ Date: __________________
Jonathan Frankel 9/4/24
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PART C. Project Team Information (complete all applicable fields)
Applicant: ☐ Same as Owner ☐ Different from Owner
Name (if different from Owner): __________________________________________________________
Company or Firm: ______________________________________________________________________
Contact Address: _______________________________________________________________________
City: ___________________________ State: ___________________________ Zip Code: _____________
Agent or Representative: ☐ Same as Applicant ☐ Different from Applicant ☐ N/A
Name (if different from Applicant): ________________________________________________________
Company or Firm: ______________________________________________________________________
Contact Address: _______________________________________________________________________
City: ___________________________ State: ___________________________ Zip Code: _____________
Other (specify Architect, Engineer, CEQA Consultant, etc.): ____________________________________
Name: ______________________________________________________________________________
Company or Firm: ______________________________________________________________________
Contact Address: _______________________________________________________________________
City: ___________________________ State: ___________________________ Zip Code: _____________
NOTE: A Letter of Authorization (LOA) from the Property Owner empowering a person or persons to act
on the behalf of the Property, is required if anyone other than the Property Owner signs the Land Use
Review Application as the Applicant or Agent. The authorized person (Applicant or Agent) on the LOA
must correspond with the name and signature, above.
PART D. Single “Point of Contact” Designation
A single “point of contact” is an individual that handles all communications with the city and its review
team for the purposes of sending and receiving application materials, information, reports, etc. The
point of contact is to be the single individual elected on the Land Use Review Application form for all
communications and to remain as the primary contact for all status updates relating to the Land Use
Review Application.
Single Point of Contact: ☐ Applicant ☐ Property Owner ☐ Agent ☐ Other ____________________
Oct.. 15, 2025 Item #1 30 of 343
PART E. Contribution Disclosure
Has the Property Owner, Applicant, or Agent had more than $900 worth of business transacted with any
member of city staff, Boards, Commissions, Committees and/or Council within the past 12 months?
☐ Yes ☐ No If yes, indicate person(s): ______________________________________________
NOTE: Attach additional sheets if necessary.
PART F. Applicant Declarations (to be signed by Applicant)
I hereby certify under penalty of perjury that I have read the information below and that:
1. I have carefully reviewed and prepared the application and plans in accordance with the
instructions.
2. I understand that the specific information needed to initiate planning case processing
corresponds to those items listed in the application form’s “Minimum Submittal Intake
Requirements Checklist.” I also understand that even if the application is duly filed and
accepted for intake processing, each application submitted to the Planning Division is
required to have specified information included in the application packet before it is
determined to be complete. The specific information to determine completeness is in
“Completeness Determination Requirements Checklist.”
3. The Planning Division has developed policies to help ensure that discretionary permit
applications are timely processed. The Permit Streamlining Act shot clock starts on the intake
date the Planning staff accepts a duly filed application.
4. I understand that once an application is determined to be complete, project or design changes
that will increase the number of units, add uses that were not previously listed, substantially
change the site plan, or other changes that trigger the need for additional discretionary
approvals will require a new application, or the filing of other application permit types, which
would restart the review “clock” and extend processing timelines.
5. I understand that upon city review, additional information, documents, reports, entitlements
and fees might be required, including any referral fees. I understand that all fees and deposits
submitted with this application will be refunded only as provided for by the ordinances,
regulations, or policies in effect at the time of the application submittal.
6. I understand that it is my responsibility to ensure that statements are true, that discrepancies do
not exist between the project’s description on the application, the architectural plans and the
structural plans. If discrepancies exist between the architectural plans and the structural plans,
the architectural plans shall take precedence. Ultimately, the scope of work, as described on the
permit that authorizes construction, takes precedence over the plans. If there is a discrepancy
between the plans and the description on the permit, the permit governs.
Oct.. 15, 2025 Item #1 31 of 343
7. I understand that all materials submitted in connection with this application might become
public record subject to inspection and copying by the public. I acknowledge and understand
that the public might inspect and copy these materials and that some or all of the materials
might be posted on the city website or elsewhere online, outside of the city’s control.
8. I understand there are no assurances at any time, implicitly or otherwise, whether provided to
me in writing or by oral communications regarding final staff recommendations to the decision-
making body about this application or the determination of any decision-making body.
9. If the project is approved or conditionally approved, the approved plan set of project drawings,
civil plans/grading, sections, site plans, floor plans, architectural elevations, and landscape plans
shall not be altered without express authorization by the City Planner. Once a permit has been
issued, the Applicant may request permit modifications. “Minor" modifications might be granted
if found by the City Planner to be in substantial conformity with the approved plan set, including
all exhibits and permit conditions. Modifications beyond the scope described in the approved
plan set might require submittal of an amendment to the permit and approval by the authorized
review body.
10. Should any proponent of the project fail to file a timely and valid appeal of the permit within the
applicable appeal period, such inaction shall be deemed to constitute acceptance of the permit
by the Applicant; and agreement by the Applicant to be bound by, to comply with, and to do all
things required of or by the Applicant pursuant to all of the terms, provisions, and conditions of
the issued permit or other approval.
11. As part of this application, the Applicant hereby agrees to defend, indemnify, and hold harmless
the City of Carlsbad, its Council, boards and commissions, officers, employees, volunteers, and
agents from any claim, action, or proceeding against the City of Carlsbad, its Council, boards and
commissions, officers, employees, volunteers and agents, to attack, set aside, void or annul an
approval of the application or related decision, including environmental documents, or to
challenge a denial of the application or related decisions. This indemnification shall include, but
not be limited to, damages awarded against the city, if any, costs of suit, attorneys’ fees, and
other expenses incurred in connection with such claim, action, causes of action, suit or
proceeding whether incurred by Applicant, city, and/or the parties initiating or bringing such
proceeding. The Applicant shall indemnify the city for all of the city’s costs, attorneys’ fees, and
damages that the city incurs in enforcing the indemnification provisions set forth herein. The
Applicant shall pay to the city upon demand any amount owed to the city pursuant to the
indemnification requirements prescribed.
Oct.. 15, 2025 Item #1 32 of 343
By signing below, I hereby agree to defend, indemnify and hold harmless the city and I certify that the
application I am submitting, including all additional required information, is complete and accurate to
the best of my knowledge. I understand that any misstatement or omission of the requested
information or of any information subsequently requested might be grounds for rejecting the
application, deeming the application incomplete, denying the application, suspending or revoking a
permit issued on the basis of these or subsequent representations, or for the seeking of such other and
further relief as deemed by the City of Carlsbad. Applicant Signature: _________________________________________________________________
Name: ____________________________________________________ Date: __________________
This form must be stapled/attached to the application and shall be effective until replaced or
revoked in writing.
Oct.. 15, 2025 Item #1 33 of 343
PROJECT ANALYSIS
The project is subject to the following regulations:
A.General Plan (Residential 23) Land Use Designation and Density Bonus Ordinance (CMC Chapter
21.86)
B.Multiple-Family Residential (R-3) Zone and Planned Development Regulations (CMC Chapter 21.16,
21.45)
C.Local Coastal Program (Mello II Segment)
D.Tentative Tract Map (Title 20)
E.Inclusionary Housing Ordinance (Chapter 21.85)
F.Growth Management Ordinance (CMC Chapter 21.90) and Local Facilities Management Plan Zone 1
The recommendation for approval of this project was developed by analyzing the project’s consistency
with the applicable regulations and policies. The project’s compliance with each of the above regulations
is discussed in detail within the sections below.
A.R-23 Residential General Plan Land Use Designation and Density Bonus Ordinance (CMC Chapter
21.86)
The General Plan Land Use designation for the property is R-23 Residential, which allows residential
development at a density range of 19 to 23 dwelling units per acre (du/ac). With a net developable
acreage of 0.34-acres the land use designation of R-23 allows a density of six to seven units on the site.
Table A below identifies the permissible density range for properties located within the R-23 General
Plan Land Use designation.
TABLE A – PROPOSED DENSITY
Gross Acres Net Acres
Allowable Density Range;
Min/Max Dwelling Units per
R-23 Designation*
Project Density;
Proposed Dwelling Units
0.34 0.33 19-23 du/ac
Minimum: 6 dwelling units
Maximum: 8 dwelling units
35.29 du/ac
12 dwelling units
*For density bonus projects fractional units shall be rounded up per CMC Section 21.86.050.
The proposed project entails a request to construct a 12-unit, three-story, residential condominium
project. As summarized above, the maximum base number of units for a 0.34-acre parcel at 23 du/ac is
seven dwelling units (which is rounded up to eight dwelling units under State Density Bonus Law). In
order to construct 12 units, the Developer is requesting approval of a density bonus pursuant to CMC
Chapter 21.86, the Density Bonus Ordinance, and California (hereinafter referred to as “State”) Density
Bonus Law (Government Code Sections 65915 to 65918). CMC Chapter 21.86 was established as a
means to implement California Government Code Sections 65915 et seq. (State Density Bonus Law) and
the goals, objectives and policies of the Housing Element of the General Plan, which includes the
provision to provide housing affordable to lower- and moderate-income households.
Exhibit 4
Oct.. 15, 2025 Item #1 34 of 343
State Density Bonus Law requires cities and counties to grant density bonuses to developers who
propose to construct a specified percentage of housing affordable to very low-, low-, or moderate-
income households or who propose to construct senior housing or housing available for transitional
foster youth, disabled veterans, homeless persons, or lower income students. Cities and counties must
provide all requirements for density bonuses and the amount of density bonus or
incentives/concessions that developers may be eligible. The legislative intent of State Density Bonus Law
is to increase the production of affordable housing by requiring local agencies to grant an increase to the
maximum allowable residential density over the otherwise maximum eligible density. The density bonus
that is authorized is set on a sliding scale based upon the percentage of affordable units in the project,
ranging from 5% to 50% additional units over the number ordinarily permitted. Likewise, State Density
Bonus Law provides for a progressive approach to incentives or concessions, allowing up to four
incentives or concessions in some cases. It also includes incentivization in the form of waivers from
development standards, which do not count as incentives or concessions, and are unlimited.
In this instance, to support the implementation of the project, the Developer is requesting a 38.75%
density bonus pursuant to State Density Bonus Law. In exchange for the 38.75% density bonus, the
Developer is required to designate 12% of the base maximum density units, or one unit, as an affordable
density bonus unit. The affordable density bonus unit is required to be affordable to “very low-income
households” for a period of 55 years. Very low-income households are those earning up to 50% of the
area median income (AMI). The developer has chosen to build all 12 allowed units.
In addition to the affordable unit provided for the project to be granted a density bonus under State law,
the developer is required to comply with Carlsbad’s Inclusionary Housing Ordinance. Under the
inclusionary ordinance, developments proposing a total of seven or more units must provide at least
15% of the development's base density units as affordable to lower income households. This project is
required to provide one (1) unit deed restricted to lower-income households; 8 units X 15% = 1 unit (1.2
rounded down). The one (1) very low-income unit proposed satisfies both the State Density Bonus Law
and Inclusionary Housing Ordinance requirements.
Density bonus law stipulates that a request for a density bonus does not constitute a valid basis on
which to find a proposed housing development project is not compliant with a general plan. In addition,
State Density Bonus Law explicitly requires the city to consider “the density allowed under the land use
element of the general plan” in determining maximum allowable residential density. Therefore, the
proposed density of the Project complies with the R-23 General Plan Land Use Designation.
Incentives, Concessions or Waivers
The project is requesting incentives, concessions or waivers as allowed under State Density Bonus Law1
and implemented by CMC Chapter 21.86 – Density Bonus Ordinance. A project can request incentives
and concessions as defined in State Density Bonus Law, based on the percentage of affordable units.
Incentives or Concessions
An incentive or concession may include any of the following:
• A reduction in site development standards or a modification of zoning code or architectural design
1 Refer to Exhibit 6 for an info-bulletin that provides more information on how State Density Bonus Law works.
Oct.. 15, 2025 Item #1 35 of 343
requirements (excluding State Building Standards), that results in identifiable, financially sufficient
and actual cost reductions. A reduction/modification to standards or requirements may include, but
is not limited to, a reduction in minimum lot size, setback requirements, and/or in the ratio of
vehicular parking spaces that would otherwise be required.
• Other regulatory incentives or concessions that result in identifiable, financially sufficient and actual
cost reductions.
• The city council may, but is not required to, provide direct financial incentives, including the provision
of publicly owned land, or the waiver of fees or dedication requirements.
In order to deny the requested incentive or concession, the city would have to make any of the following
findings in writing based upon substantial evidence:
• The concession or incentive does not result in identifiable and actual cost reductions, consistent
with those defined above, to provide for affordable housing costs.
• The concession or incentive would have a specific, adverse impact, based upon public health and
safety or on any real property that is listed in the California Register of Historical Resources and for
which there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact
without rendering the development unaffordable to low-income and moderate-income households.
• The concession or incentive would be contrary to state or federal law.
The Developer is requesting two concession, the elimination of full frontage improvements along
Jefferson Street (maintaining a five-foot sidewalk opposed to installing a six-foot sidewalk) and relief
from the requirement to replace the 14-inch ACP water main equal to the entire street frontage of the
project. This is further discussed in Exhibit 5. Staff has found no substantial evidence that any of the
above findings apply in this case.
Waivers
In addition to incentives or concessions, waiver or reduction of development standards that would
“have the effect of physically precluding the construction of a density bonus housing development at
the density or with the incentives or concessions permitted by” can also be considered. There is no limit
on the number of waivers or reductions of development standards that may be granted, and the
granting of a waiver or reduction shall neither increase nor decrease the number of incentives or
concessions to which the project is entitled. Waivers or reductions of development standards shall be
granted by the city unless certain findings can be made. In order to deny the requested waivers or
reductions, the city would have to make any of the following findings in writing based upon substantial
evidence:
• The standard(s) requested to be waived or reduced will not have the effect of physically precluding
the construction of a housing development at the densities or with the incentives or concessions
permitted by this chapter.
• The requested waiver or reduction of development standards would have a specific adverse impact
Oct.. 15, 2025 Item #1 36 of 343
(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) upon public health and safety or on any real property that is listed in the
California Register of Historical Resources, and for which there is no feasible method to satisfactorily
mitigate or avoid the specific adverse impact.
• The waiver or reduction of development standards would be contrary to state or federal law.
The Developer is requesting eight waivers as discussed in Exhibit 5. These waivers include requests for
reduced street-front setbacks, side-yard, and rear setbacks, and a reduction in minimum patio width,
garage dimension standards and building separation requirements, as well as requests to increase lot
coverage and elimination of requirements to provide community recreational space for the
development. Staff has found no substantial evidence that any of the above findings apply in this case.
General Plan Compliance
In addition to the above, the project also complies with the other Elements of the General Plan as
outlined in Table “B” below:
TABLE B – GENERAL PLAN COMPLIANCE
Element Use, Classification, Goal, Objective, or
Program Proposed Uses & Improvements Comply?
Land Use Goal 2-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.
Policy 2-P.7
Do not permit residential development
below the minimum of the density
range except in certain circumstances.
The proposed 12-unit residential infill
development makes efficient use of
the existing lot in that it increases the
number of units from one (1) to 12. A
12-unit development is compatible
with the surrounding development.
The 12-unit residential project density
of 35.29 du/ac is above the minimum
R-23 Residential density of 19 dwelling
units per acre.
Yes
Mobility Policy 3-P.5 The proposed project has been
designed to meet all circulation
Yes
Oct.. 15, 2025 Item #1 37 of 343
Element Use, Classification, Goal, Objective, or
Program Proposed Uses & Improvements Comply?
Require developers to construct or pay
their fair share toward improvements
for all travel modes consistent with the
Mobility Element, the Growth
Management Plan, and specific impacts
associated with their development.
requirements, including vehicular
access to and from Jefferson Street. In
addition, the applicant will be required
to pay any applicable traffic impact
fees, prior to issuance of a building
permit, that will go toward future road
improvements.
The proposed project includes the
improvement of curb, gutter and
sidewalk along the frontage of
Jefferson Street. The project will
update the frontage to current
development standards, except for
the sidewalk width standard.
Noise Goal 5-G.2
Ensure that new development is
compatible with the noise
environment, by continuing to use
potential noise exposure as a criterion
in land use planning.
Policy 5.P.2
Require a noise study analysis be
conducted for all discretionary
development proposals located where
projected noise exposure would be
other than “normally acceptable.”
The project consists of 12 residential
condominiums configured in four
triplexes. A noise study prepared for
the project (Birdseye Planning Group
in June 2024) concluded that the
project complies with the Noise
Guidelines Manual and applicable
General Plan policies. No project-
specific conditions are required.
Yes
Housing Program 2.1
The Inclusionary Housing Ordinance
requires that a minimum of 15 percent
of all ownership projects of seven units
or more be restricted and affordable to
lower income households.
Under the inclusionary ordinance,
developments proposing a total of
seven or more units must provide at
least 15% of the development's base
density units as affordable to lower
income households. This project is
required to provide one (1) unit deed
restricted to lower-income
households; 8 units X 15% = 1 unit (1.2
Yes
Oct.. 15, 2025 Item #1 38 of 343
Element Use, Classification, Goal, Objective, or
Program Proposed Uses & Improvements Comply?
Goal 10-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).
rounded down). The one (1) unit
designated as affordable to very low-
income households for 55 years,
earning up to 50% of the area median
income (AMI) satisfies both the State
Density Bonus Law and Inclusionary
Housing Ordinance requirements.
This housing development will help
ensure the city achieves its goal of
contributing housing 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).
Per Government Code Section 65863
(aka No Net Loss Law) a city cannot
approve new housing at significantly
lower densities or at different income
categories than was projected in the
RHNA of the Housing Element without
making specific findings and
identifying other sites that could
accommodate these units and
affordability levels “lost” as a result of
the approval. The so-called “no net
loss” provisions apply when a site is
included in the jurisdiction’s Housing
Element’s inventory of sites and is
either rezoned to a lower residential
density or is approved at a lower
residential density than shown in the
Housing Element.
Oct.. 15, 2025 Item #1 39 of 343
Element Use, Classification, Goal, Objective, or
Program Proposed Uses & Improvements Comply?
The project site is not identified in the
City’s General Plan Housing Element
Residential Sites Inventory. Because
the provision of “no net loss” applies
to housing located on any site listed in
the City’s Housing Element, the City
does not need to determine if this
project or a decision related to this
project would be subject to No Net
Loss Law and its remedies.
Public
Safety
Goal 6-G.1
Minimize injury, loss of life, and
damage to property resulting from fire,
flood, hazardous material release, or
seismic disasters.
Policy 6-P.6
Enforce the requirements of Titles 18,
20, and 21 pertaining to drainage and
flood control when reviewing
applications for building permits and
subdivisions.
Policy 6-P.34
Enforce the Uniform Building and Fire
codes, adopted by the city, to provide
fire protection standards for all existing
and proposed structures.
Policy 6-P.39
Ensure all new development complies
with all applicable regulations
regarding the provision of public
utilities and facilities.
The proposed structural
improvements will be required to be
designed in conformance with all
seismic design standards. In addition,
the proposed project is consistent
with all the applicable fire safety
requirements including fire sprinklers.
The proposed location and size of the
right-of-way, sanitary facilities and
utilities, traffic access, and grading
were all reviewed for compliance with
relevant city policies and codes.
Furthermore, the project has been
conditioned to develop and
implement a program of “best
management practices” for the
elimination and reduction of
pollutants which enter into and/or are
transported within storm drainage
facilities. Therefore, the proposed
project has been designed to meet the
requirements of the city and other
service agency standards. All
necessary public facilities and services
are in place or can be extended to
serve the project, which comes with
support from fire, water, sewer, and
school service providers, indicating
Yes
Oct.. 15, 2025 Item #1 40 of 343
Element Use, Classification, Goal, Objective, or
Program Proposed Uses & Improvements Comply?
that existing facilities are available to
service the project.
Removal of Existing Housing
Under State Density Bonus Law, projects that include the demolition or removal of affordable rental
units are ineligible for Density Bonus unless the units are replaced concurrently with the development of
the project. The project applicant has provided a housing declaration affirming that neither of the
existing single-family residences were protected units.
B. Multiple-Family Residential (R-3) Zone and Planned Development Regulations (CMC Chapter
21.16, 21.45)
The proposed project is required to comply with all applicable land use and development standards of the
Carlsbad Municipal Code (CMC) including the Multiple-Family Residential (R-3) Zone (CMC Chapter 21.16)
and Planned Developments (CMC Chapter 21.45). Table “C” below shows how the project complies with
the applicable requirements of the R-3 zone and Planned Development standards.
TABLE C – R-3 ZONE DEVELOPMENT STANDARDS
STANDARD REQUIRED/ALLOWED PROPOSED
Street Yard Setback
(Jefferson St.)** 10 feet minimum* 6 feet***
Side Yard Setback 10 feet minimum 5 feet***
Rear Yard Setback 20 feet minimum 10 feet**
Building Height 35 feet maximum 34 feet, 1.6 inches
Lot Coverage 60 percent 61.7 percent**
Parking Two spaces per unit Garages (with car lifts)
*12.45.080, Planned Development Standards (Table E (E.5))
**An additional 6 feet is being dedicated to Jefferson St. right-of-way.
***State Density Bonus Law waiver
Oct.. 15, 2025 Item #1 41 of 343
C. Coastal Development Regulations for the Mello II Segment of the Local Coastal Program (CMC
21.201) and the Coastal Resource Protection Overlay Zone (CMC 21.203)
The project site is located within the appeals area of the Coastal Zone and within the Mello II Segment
of the Local Coastal Program (LCP). The site is also located within and subject to the Coastal Resources
Protection Overlay Zone (Chapter 21.203). The project’s compliance with each of these programs and
ordinances is discussed below:
1. Mello II Segment of the Certified Local Coastal Program and all applicable policies
The proposed site is in the Mello II Segment of the Local Coastal Program (LCP) and is within the
appealable area of the California Coastal Commission. The project site has an LCP Land Use
designation of R-23 Residential, which are consistent with the city’s General Plan and Zoning. The
project’s consistency with the R-23 Residential General Plan Land Use designation is analyzed in
Section “A,” Table “A” and “B” above.
The project consists of the demolition of an existing residential unit and the construction of a 12-
unit condominium project. The proposed project is compatible with the surrounding development
of single-family and multi-family residential structures. The three-story structures will not
obstruct views of the coastline as seen from public lands or the public right-of-way, nor otherwise
damage the visual beauty of the Coastal Zone. No agricultural uses currently exist on the
previously developed site, nor are there any sensitive resources located on-site. The proposed
project is not located in an area of known geologic instability or flood hazard. Since the site does
not have frontage along the coastline, no public opportunities for coastal shoreline access are
available from the subject site. Furthermore, the residentially designated site is not suited for
water-oriented recreation activities.
2. Coastal Resource Protection Overlay Zone
The project is consistent with the provisions of the Coastal Resource Protection Overlay Zone
(CMC Chapter 21.203 of the Zoning Ordinance) in that the project will adhere to the city’s Master
Drainage Plan, Grading Ordinance, Storm Water Ordinance, BMP Design Manual and Jurisdictional
Runoff Management Program (JRMP) to avoid increased urban run-off, pollutants and soil
erosion. The subject property does not include steep slopes (equal to or greater than 25 percent
gradient) nor native vegetation. In addition, the site is not located in an area prone to landslides,
or susceptible to accelerated erosion, floods, or liquefaction.
D. Subdivision Ordinance (Title 20)
The Land Development Engineering Division has reviewed the proposed Major Subdivision and has
found that the subdivision complies with all applicable requirements of the Subdivision Map Act and the
city’s Subdivision Ordinance (Title 20) for Major Subdivisions. The subdivision is considered major
because it involves the division of land into five or more condominiums (12 condominiums proposed).
The proposed project will improve the frontage infrastructure along Jefferson Street, including a curb,
gutter, and sidewalk. The project has been conditioned to install all infrastructure-related improvements
Oct.. 15, 2025 Item #1 42 of 343
(except for full water main replacement) and the necessary easements for these improvements
concurrent with the development.
E. Inclusionary Housing Ordinance (CMC Chapter 21.85)
Pursuant to CMC Chapter 21.85, Inclusionary Housing Ordinance, 15% of the base units, or one (1) unit,
shall be constructed and restricted both as to occupancy and affordability to lower-income households;
8 units X 15% = 1 unit (1.2 rounded down). The one (1) very low-income unit proposed to satisfy State
Density Bonus Law requirements also satisfies the city’s Inclusionary Housing Ordinance requirements.
F. Growth Management
The proposed project is located within Local Facilities Management Zone 1 in the Northwest Quadrant
of the city. The impacts on public facilities created by the project, and its compliance with the adopted
performance standards, are summarized in Table “F” below.
TABLE D – GROWTH MANAGEMENT COMPLIANCE
Standard Impacts/Demand Compliance
City Administration 35.37 sq. ft./du Yes
Library 18.86 sq. ft./du Yes
Wastewater Treatment 11 EDU = 2,200 GPD Yes
Parks 0.07acre Yes
Drainage 0.63 CFS Yes
Circulation 52 ADT Yes
Fire Station No. 1 Yes
Open Space N/A N/A
Schools Carlsbad (E=1.287/M=0.68/HS = 0.87) Yes
Sewer Collection System 8.6 EDU Yes
Water 4,300 GPD Yes
Oct.. 15, 2025 Item #1 43 of 343
1
2647 Jefferson Street Homes
CT 2024-0006 / PUD 2024-0007/ CDP 2024-0036 (DEV2024-0094)
Supplemental Density Bonus Report P(1)-H
The proposed project is requesting the following incentives and waivers of development
standards pursuant to California Government Code Section §65915(e)(1):
Incentive #1
Proposed incentive: Incentive request to forgo frontage improvements along Jefferson
Street. The existing sidewalk will be removed and replaced at its current width. This
incentive results in actual, identiflable cost savings to provide for affordable housing costs.
The funds that would be expended on parkway and sidewalk widening will reduce the
subsidy required to provide the onsite affordable housing unit. This incentive does not
result in a speciflc, adverse impact upon public health or safety or historic property. Nor is
the incentive contrary to state or federal law.
Incentive #2
Proposed incentive: Incentive request to forgo replacing all existing 14” ACP water main
with new 14” PVC water main along the project frontage. As demonstrated by the offsite
water study prepared by Dexter Wilson Engineering, the existing 14” ACP water main has
sufficient capacity to serve the proposed project. A change in pipe material is not required
to service the project and no existing deflciencies with the existing 14” ACP main have been
identifled. This incentive results in actual, identiflable cost savings to provide for onsite
affordable housing. This incentive does not result in a speciflc, adverse impact upon
public health or safety or historic property. Nor is the incentive contrary to state or federal
law.
Waiver #1
Code/Policy Number: CMC 21.45.080 (Table E (E.5))
Required Standard: Minimum building setback from the public street of 10 feet.
Proposed Deviation: Proposed building setback from the public street of 6’.
Reason for Waiver Request: Providing a front setback from the public street of 10’ would
reduce the available lot area capable of supporting the construction of housing units and
the remaining lot area would not be sufficiently large to accommodate 12 housing units as
proposed. Accordingly, imposition of this standard would physically preclude
development of the proposed project at the densities permitted by state law. This waiver
Exhibit 5
Supplemental Application
Oct.. 15, 2025 Item #1 44 of 343
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Waiver #2
Code/Policy Number: CMC 21.16.050(A)(1)
Required Standard: Minimum side yard setback of 10 feet.
Proposed Deviation: Proposed side yard setback of 5 feet.
Reason for Waiver Request: Providing a side yard setback of 10’ would reduce the available
lot area capable of supporting the construction of housing units and the remaining lot area
would not be sufficiently large to accommodate 12 housing units as proposed.
Accordingly, imposition of this standard would physically preclude development of the
proposed project at the densities permitted by state law. The proposed 5’ side yard
setback meets minimum requirements for flre access and does not result in an impact to
health or safety or the physical environment.
Waiver #3
Code/Policy Number: CMC 21.16.060(A)(1)
Required Standard: Minimum rear yard setback of 20 feet.
Proposed Deviation: Proposed rear yard setback of 10 feet.
Reason for Waiver Request: Providing a side yard setback of 20’ would reduce the available
lot area capable of supporting the construction of housing units and the remaining lot area
would not be sufficiently large to accommodate 12 housing units as proposed.
Accordingly, imposition of this standard would physically preclude development of the
proposed project at the densities permitted by state law. The proposed 10’ rear yard
setback meets minimum requirements for flre access and does not result in an impact to
health or safety or the physical environment.
Waiver #4
Code/Policy Number: CMC 21.45.080 (Table E (E.7).)
Required Standard: Minimum dimension of patio, porch, or balcony to be 6 feet.
Proposed Deviation: Proposed minimum second fioor balcony dimension of 4’-6”.
Reason for Waiver Request: Providing a 6-foot minimum patio dimension would reduce the
size of the conditioned fioor space in the interior of each unit, preventing the provision of
interior amenities as proposed. Furthermore, expansion of the deck areas would increase
does not result in an impact to health or safety or the physical environment.
Oct.. 15, 2025 Item #1 45 of 343
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construction of the 12 housing units as proposed. Accordingly, imposition of this standard
would physically preclude development of the proposed project at the densities permitted
by state law. The project provides a minimum of 389 SF of private open space per unit,
which is more than six times . This waiver does not result in an impact to health or safety or
the physical environment.
Waiver #5
Code/Policy Number: CMC 21.45.060 (Table C (C.9)).
Required Standard: Minimum community recreational space of 150 SF per unit.
Proposed Deviation: No community recreation space is proposed. The project meets all
requirements for private recreational amenities.
Reason for Waiver Request: Providing 150 SF of community recreational space would
reduce the size of the lot area available for the construction of the proposed housing units
by 1,800 SF. The 12 proposed units could not physically flt within the reduced lot area.
Accordingly, imposition of this standard would physically preclude development of the
proposed project at the densities permitted by state law. The project provides a minimum
of 389 SF of private open space per unit, more than six times the amount of space than is
otherwise required. This waiver does not result in an impact to health or safety or the
physical environment.
Waiver #6
Code/Policy Number: CMC 21.45.080 (Table E (E.7)).
Required Standard: Minimum one car garage dimension by 12’ x 20’.
Proposed Deviation: Proposed one car garage dimension of 11’ x 22’ 6”
Reason for Waiver Request: The project includes a single car garage with lift for all units,
providing parking for two vehicles. Providing a 12’ wide single car garage would expand the
building footprint beyond the current limits of the project site, physically precluding the
construction of 12 dwelling units. 12 dwelling units could not flt within the project site with
a 12’ wide garage. Accordingly, imposition of this standard would physically preclude
development of the proposed project at the densities permitted by state law. This waiver
does not result in an impact to health or safety or the physical environment.
Waiver #7
the total impervious area within the project, triggering the requirement to provide
stormwater treatment facilities that would reduce the available lot area for the
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Proposed Deviation: Proposed lot coverage of 60.4%
Reason for Waiver Request: The development of 12 units on the project site results in a lot
coverage of 60.4%, exceeding the requirement by 4/10th of 1%. Adherence to the 60% lot
coverage standard would reduce the available lot area that could accommodate the
construction of the 12 proposed housing units. Accordingly, imposition of this standard
would physically preclude development of the proposed project at the densities permitted
by state law. This waiver does not result in an impact to health or safety or the physical
environment.
Waiver #8
Code/Policy Number: CMC 21.45.080 (Table E (E.5)).
Required Standard: Minimum building separation of 10’
Proposed Deviation: Minimum building separation of 7’-6”
Reason for Waiver Request: The project includes flre suppression systems in all units.
Such systems require a dedicated flre riser room for each building to house equipment,
control valves, and fiow switches. This room is located at the rear or side of each proposed
building. Adherence to the 10’ standard would reduce the lot area available to
accommodate the residential units. Accordingly, imposition of this standard would
physically preclude development of the proposed project at the densities permitted by
state law. This waiver does not result in an impact to health or safety or the physical
environment.
Code/Policy Number: CMC 21.45.080 (Table E (E.3)).
Required Standard: Maximum lot coverage not to exceed 60%
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This 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 6
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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 & COST
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.
•Affordability cost is calculated pursuant to
California Health and Safety Code Section 50053
(for-rent) and 50052.5 (for-sale).
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’s
General 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-330and 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
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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.
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 housing
ordinance (§21.85).
• Pursuant CA Attorney General Opinion No. 24-
501, local inclusionary housing requirements can
only be applied to base density units, not the
density bonus units. As such, irrespective of the
requirements set forth under §21.85.030.B,
projects proposing seven or more housing units
are required to restrict at least 15% of the base
density units, not the density bonus units, for
low-income households.
• 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.
A property 1.003 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
2.4 affordable low-income units are required for this
project (15% inclusionary requirement multiplied by
16 base units), which rounds down to 2 units.
In this example, the 3 affordable low-income units
satisfy the requirements under state density bonus
law as well as the two units required under the city’s
inclusionary housing ordinance.
Oct.. 15, 2025 Item #1 50 of 343
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.
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
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,
five at low-income, and three at moderate-income.
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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
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.
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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 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
Oct.. 15, 2025 Item #1 53 of 343
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.. 15, 2025 Item #1 54 of 343
When housing prices spiked in the 1990s, many cities
looked for ways to help make housing more affordable.
One such tool that many jurisdictions implemented was
INCLUSIONARY HOUSING REGULATIONS. Under these laws,
developers are required to set aside a certain number of
units within their residential development project and
make them affordable to lower income households.
As part of their inclusionary housing program, many
cities also included provisions that allow developers to
deviate from the strict adherence of the policy, so long
as it is found that the alternative means of compliance
meets the intent of the jurisdiction’s inclusionary
housing policies, and is consistent with the housing
affordability and fair housing choice goals specified in its
long-range housing plan.
This info-bulletin provides an overview of Carlsbad’s
Inclusionary Housing Program and describes how it helps
address affordable housing needs while advancing
equitable development goals consistent with the city’s
adopted Housing Element.
NEED FOR LOCAL INCLUSIONARY HOUSING
The state faces a serious housing problem that not only
threatens its economic security, the lack of access to
affordable housing can have a direct impact upon the
health, safety, diversity, and welfare of Carlsbad
residents. To retain a healthy livable environment and
meet state mandated housing goals, more needs to be done to accommodate locally available and affordable
housing stock.
To help address this need, the city’s inclusionary housing
ordinance, originally adopted in 1993, established the
legal basis for requiring affordable (inclusionary) housing
units in new residential development in the city. The law
applies to all proposed development projects that
include residential units and requires that a minimum of
15% of the units within a project be affordable to lower-
income households.
Since its implementation, the inclusionary housing
ordinance has proven to be extremely effective. From
1995 to 2020, the city produced 19,026 housing units, of
which roughly 13% were made affordable through this
program. And it is anticipated that the city will generate
over 500 additional affordable units over the next eight-
year period.
HOUSEHOLD INCOME & AFFORDABILITY
We hear this a lot --- How do we make housing more
affordable? The term “affordable housing” can be used
to describe housing that receives some form of
subsidy/restriction that forcibly keeps rents and
mortgages low. It can also mean housing that’s naturally
affordable simply because of market supply and demand.
In order to make a meaningful difference in providing
affordable housing, the solution should not be looked at
as an “either-or” approach between privately produced
housing and subsidized housing…it requires both.
To help understand what qualifies as affordable, the U.S.
Department of Housing and Urban Development (HUD)
establishes income ranges for different household types,
which they have grouped into five “income categories:”
extremely low, very low, low, moderate and above-
moderate household income. The household income for
each of these categories is based on a percentage of the
region’s Area Median Income or AMI.
Exhibit 7
Oct.. 15, 2025 Item #1 55 of 343
Carlsbad falls within the San Diego County region, which
has an AMI of $95,100 (2021) per year for a four-person
household. In comparison, the city’s actual median
income is closer to $108,000, but under state law the city
must use the county AMI. To help illustrate, the table
below shows the income levels for a family of four.
For housing costs to be considered affordable, a family’s
monthly rent/mortgage payment should generally not
exceed 30% of the gross annual household income of any
given income category. Affordable housing price is
determined by state law, defined in Health and Safety
Code sections 50053 (for-rent) and 50052.5 (for-sale).
For a rental unit, total housing costs include the monthly
rent payment as well as consideration for a utility
allowance. With for-sale units, total housing costs
include the mortgage payment, homeowner association
dues, property taxes, mortgage insurance and any other
related assessments.
To learn more about HCD and housing, please see our
Info-Bulletin: Carlsbad Housing Plan (IB-137).
INCLUSIONARY HOUSING REQUIREMENTS
The city’s Inclusionary Housing Ordinance (CMC §21.85)
was passed by the City Council in 1993, and established
the legal basis for requiring inclusionary housing in new
residential development in the city. The following
provides a summary of key standards required under the
ordinance for new residential development in the city.
Number of units required
• Pursuant CA Attorney General Opinion No. 24-501,
local inclusionary housing requirements can only be
applied to base density units, not the density bonus
units. As such, irrespective of the requirements set
forth under §21.85.030.B, projects proposing seven
or more housing units are required to restrict at
least 15% of the base density units, not the density
bonus units, for low-income households. For
projects proposing six or fewer units, refer to
Alternative #1 under the “Alternative Means of
Compliance” section of this info-bulletin.
• Inclusionary unit requirements apply to all
residential development projects (rental or for-sale
product), including mixed-use projects.
• When calculating, fractional units ≥0.5 must be
rounded up to the next whole number.
Example: An applicant proposes to satisfy its
inclusionary requirements for a 112-unit residential
development by reserving 15% of the units for low-
income households, or 17 units (112 X 0.15 = 16.8,
rounded up to 17). The remaining 95 units (112 units
minus 17) may be sold at market rate.
Duration units protected
• Inclusionary rental units shall remain restricted and
affordable to the designated income group for not
less than 55 years.
• Inclusionary for-sale units shall remain restricted and
affordable to the designated income group for not
less than 30 years.
Development standards
• Inclusionary units should be located throughout the
development rather than clustered in one area.
• The inclusionary units must be indistinguishable
from the market-rate units in the development, at
least outwardly.
• The inclusionary units must be constructed prior to
or concurrent with development of the market-rate
units, and prior to final building permit approval of
the market-rate units.
• Residents of the inclusionary units must have access
to the same amenities – such as pool, fitness center
and parking – as residents of the market-rate units.
• The inclusionary units must include a similar mix and
number of bedrooms as the market-rate units.
• When ten or more inclusionary units are required, at
least ten percent of those required units must
provide at least three bedrooms.
Oct.. 15, 2025 Item #1 56 of 343
• Inclusionary units must be provided in the same
tenure (for-rent or for-sale) as the market-rate units.
• Inclusionary units affordability cost is calculated
pursuant to California Health and Safety Code Section
50053 (for-rent) and 50052.5 (for-sale).
• To the extent possible, projects using for-sale units to
satisfy inclusionary requirements shall be designed to
be compatible with conventional mortgage financing
programs.
ALTERNATIVE MEANS OF COMPLIANCE
The city understands that various constraints may
frustrate a developer’s ability to meet the strict letter of
the city’s inclusionary housing regulations. As such, the
ordinance allows for the City Council to authorize
“alternative means of compliance” when it is found that
the alternative meets the intent of the city’s Inclusionary
Housing Ordinance (CMC §21.85) and the goals and
policies of the city’s 2021-2029 Housing Element.
Council Policy Statement No. 57 (Policy 57) lists those
alternatives that have been found to meet the intent of
the city inclusionary code and help address its affordable
housing needs. These alternative means of compliance
are summarized in the sections below, but please refer
to Policy 57 for the specific requirements.
Alternative #1: Payment of in-lieu fee
Rather than constructing the inclusionary unit as part of
the development project, applicants proposing ≤six units
may instead pay a fee.
• $8,529 for a new single-family detached home
• $15 per square foot of net building area for each
proposed market-rate unit.
The rates above are effective 2022. Please check the
city’s Fee Schedule for the most current rates.
“Net building area” means the aggregate gross floor area
of all the unrestricted dwelling units within a
development, excluding areas outside the dwelling unit’s
habitable space such as garages, carports, parking areas,
porches, patios, open space, and excluding common
areas such as lobbies, common hallways, stairways,
elevators and equipment spaces.
Collected in-lieu fees are deposited into the city’s
Housing Trust Fund, and applied towards the furthering
of the city’s affordable housing needs pursuant to
Council Policy Statement No. 90 (Policy 90).
Alternative #2: Varying housing affordability
In addition to providing more housing available for low
income families, the city also recognizes a need to
increase housing stock for other targeted and needed
housing affordability levels such as moderate, very low-
and extremely low-income households. As such, so long
as the total average gross income restriction for the
required inclusionary units does not exceed 80% of the
AMI, the makeup of the inclusionary units can be
comprised on any combination of income categories.
Alternative #3: Increases in residential density
While not specific to the city’s inclusionary housing
ordinance, sometimes there is a request from a property
owner to increase their residential density above what is
authorized under the city’s current land use plans. In
exchange for the increased density, the city will require
that any future development on the site meet the
following additional inclusionary housing requirements.
• At least 20% of the total residential units (including
Density Bonus units) are restricted for low-income
households; or,
Oct.. 15, 2025 Item #1 57 of 343
• A least 15% of the total residential units (including
Density Bonus units) are restricted for low-income
households and an additional 10% are restricted for
moderate-income households; or,
• At least 15% of the total residential units (including
Density Bonus units) are restricted for very low-
income households.
This has been applied to properties that received an
increase in residential density as part of the 2015
General Plan update and the 2021-29 Housing Element.
Alternative #4: Reduction credit
Residential development (for-sale or rental product) can
reduce its inclusionary housing obligations from 15% to
12.5%, under the following conditions.
• All affordable units must be made available to very
low- or extremely low-income households.
• Affordable units are located on the same site as the
market-rate units.
• No financial assistance from the city is provided.
• Example: “A 78-unit residential development is
proposed, which requires that 15% of the units be
reserved for low-income (12 units). If the developer
voluntarily agrees to make inclusionary units available
to very low-income households, then the developer
may receive an incentive reduction credit. Under this
scenario, 10 units in a 78-unit development projects
equates to 12.8%, which meets the minimum
inclusionary housing requirement.
Alternative #5: Use of accessory dwelling units
Pursuant to CMC §21.85.070.B, construction of up to 15
accessory dwelling units (ADU) can be used to satisfy
inclusionary housing requirements. Refer to our info-
bulletin on ADUs (IB-111) for additional information. The
standards below provide additional specifications for
when this allowance can be used.
• The project proposes ≥200 residential detached
dwelling units.
• The ADU may be an attached or detached product
type (Junior ADU prohibited) .
• The ADUs shall have an affordability term (≤80% AMI
with rents ≤70% AMI) of at least 30 years.
Notwithstanding the above, for projects proposing ≤six
units, the in-lieu fee may be waived if a detached or
attached ADU or Junior ADU is constructed concurrent
with construction of the market-rate unit, deed
restricted for low-income households for 30-years, and
occupied by income-qualified families.
Alternative #6: Off-site construction
Circumstances may arise in which the public interest
would be better served by allowing some or all of the
required inclusionary units to be developed at an
alternative site. This is referred to as a “Combined
Inclusionary Housing Project” or “Combined Project.” To qualify, the following requirements must be met.
• The inclusionary calculation requirements shall be
based on the total number of market-rate units to be
provided, as opposed to the total number of
residential units in the project. See example below.
Example: An applicant proposes to satisfy its
inclusionary requirements for a 112-unit project by
building 15% of the units for low-income households
off-site. This leaves 85% of the units for market rate, for a total residential unit count of 132 units (112 ÷ 0.85 =
131.8, rounded to 132). Using the total residential unit
count, the number of inclusionary units required is 20
(132 X 0.15 = 19.8, rounded to 20).
• The decision-making authority of the permit
application may approve a Combined Project subject
to the following findings.
o The site has not or will not receive a density
increase or density bonus.
o Site conditions make it physically infeasible to
accommodate the inclusionary units on-site.
o Significant price and product type disparities
make it financially infeasible to accommodate
the inclusionary units on-site.
Oct.. 15, 2025 Item #1 58 of 343
o There is a documented lack of development
capacity to deliver affordable housing on-site.
o The off-site option provides greater financial
feasibility/cost effectiveness than the on-site.
o The off-site option provides better access to
jobs, schools, transit, and services.
o The off-site option supports housing goals and
policies in the city’s Housing Element.
Notwithstanding, the City Council shall retain final permit
approval authority, including approval of the Affordable
Housing Agreement, on any Combined Project that
requires financial assistance from the city.
Alternative #7: Inclusionary housing credit bank
For projects that build inclusionary units in excess of
code requirements, and where the city is financially participating in the project, the city can sell those excess
units in the form of credits to other developers to satisfy
their inclusionary requirement. The proceeds from the
credit sales are deposited into the city’s Housing Trust
Fund and redistributed pursuant to Policy 90.
• Bank Creation. The City Council may approve the
creation of an inclusionary housing credit bank,
subject to the following findings.
o The inclusionary units are in excess of the
minimum number of units required under the
city’s Inclusionary Housing Ordinance; or
o The inclusionary units are part of a 100%
affordable housing project; and
o The inclusionary units are constructed and
received final inspection; and
o The city financially contributed to the
construction of the project.
• Credit Purchase Eligibility. Projects proposing more
than seven, but no more than 50 residential units
are eligible to purchase credits.
• Credit Price. The price for each inclusionary unit
shall be determined by dividing the city’s financial
contribution by the total number excess
inclusionary units, subject to annual CPI adjustments.
• Credit Bank. Applicants must pay the credit price of
available credits from the oldest established
inclusionary housing bank that is located within the
same city quadrant in which the market-rate units
are located, or if none available, sites which are
contiguous to the quadrant in which the units are
proposed.
• Credit Purchase Ratio – The amount of credits to
be purchased shall be based on the following.
o 7 to 20 units: 1.0 credit/inclusionary unit
o 21 to 35 units: 1.5 credits/inclusionary unit
o 36 to 50 units: 2.0 credits/inclusionary unit
• Credit Purchase Approval. The decision-making
authority of the development project is authorized to approve credit purchases, so long as the findings
below are met. Should a request to purchase credits
occur after discretionary approval, the Community
Development Director or the Housing & Homeless
Services Director shall have the authority to approve
credits, subject to the same findings.
o The project site is located within the same
Growth Management Plan quadrant that the
housing credit is located, or if nonavailable, sites
which are contiguous (share a common boarder)
with the quadrant in which the units are
proposed.
o Sufficient housing credits available to purchase.
• Credit Price Payment. Payment of credit purchases
shall be due prior to recordation of the final map or
issuance of a building permit, in situations where the
project does not include a subdivision. If the project
entitlements expire, credits will be made available to
another eligible project(s).
Alternatives not listed, but may be considered
The City Council may approve other alternatives means
of compliance not listed in Policy 57 when evidence is
provided that the alternative helps achieve relevant
Oct.. 15, 2025 Item #1 59 of 343
Housing Element policies and goals and assists the city in
meeting its state housing requirements.
As part of the City Council’s consideration, the applicant
must also show why compliance with current
inclusionary housing regulations would be infeasible or
present unreasonable hardship in light of such factors as
project size, site constraints, market competition, price
and product type disparity, available financial subsidies,
and approved alternatives listed in Policy 57.
AFFORDABLE HOUSING AGREEMENTS
An Affordable Housing Agreement (AHA) is a legally binding agreement between the developer and the city
to ensure that the inclusionary requirements of a
residential development are satisfied. CMC §21.85.140
provides the specific requirements of the AHA, but the
more significant components are listed below.
•A project condition shall be added to projects
subject to the inclusionary ordinance and Policy 57
requiring that an AHA be reviewed, approved, and
recorded prior to Final Map or issuance of building
permits, whichever is first.
•Among other items, the AHA must include the
number of required inclusionary units, the unit sizes,
location, affordability tenure, required findings,
terms and conditions of affordability and unit
production schedule.
•The AHA and all relevant terms and conditions shall
be recorded against the entire development.
•The AHA shall bind all future owners and successors
in interest for the term of years specified therein.
APPROVAL AUTHORITY
The approval authority for the development project
subject to these standards is as follows:
•The decision-making authority for the underlying
permit application(s) shall have the authority to
approve projects found consistent with Policy 57.
•Development projects that propose an alternative
means of compliance that is not specifically provided
for in the CMC or Policy 57 shall be considered by the
Housing Commission for a recommendation to the
City Council.
•Approval authority of the AHA is as follows:
o AHA that are consistent with CMC §21.85 and
Policy 57 and do not request financial assistance
from the city shall first be considered by the
Affordable Housing Policy Team for a
recommendation to the H&HS Director.
o Affordable Housing Agreements that propose a
deviation(s) to Policy 57 or request financial
assistance shall first be considered by the Affordable Housing Policy Team and Housing
Commission for a recommendation to the City
Council, which has the authority to issue final
approval of the alternative.
YOUR OPTIONS FOR SERVICE
To schedule an appointment or to learn more about this
program, please contact the Planning Division at 442-339-
2600 or via email at Planning@carlsbadca.gov or the
Housing & Homeless Services Department at 442-339-
4721 or via email at Housing@carlsbadca.gov.
Oct.. 15, 2025 Item #1 60 of 343
From:Tai Huoh
To:Kyle Van Leeuwen
Subject:CT2024-0006/PUD2024-0007/CDP2024-0036
Date:Wednesday, October 23, 2024 5:59:19 AM
Re: 2647 Jefferson street condominiums project.
Hi Kyle,
All of these recently proposed condominium projects on Jefferson street don’t provide enough
onsite parking spaces. Each unit with only one parking is unrealistic. The condominiumresidents will end up parking their second cars on the already parking-crowded Jefferson street
and side streets.
We would like to see the City demand the investors of these condominium projects to providemore onsite parking to prevent the potential parking problem on Jefferson street. We need
street parking spaces for our guests, gardeners, and repairmen, not for the future condominiumresidents.
Thanks,
Tai Huoh2664 Jefferson Street, Carlsbad
310-999-1684
CAUTION: Do not open attachments or click on links unless you recognize the sender and
know the content is safe.
Exhibit 8
Public Comments
Oct.. 15, 2025 Item #1 61 of 343
From:brad. i.
To:Kyle Van Leeuwen
Subject:proposed 2647 jefferson st development.
Date:Friday, October 11, 2024 9:47:48 PM
hello,
my name is brad ingino & i have lived/rented in carlsbad village for 15-18 years now. the influx of 4 & 5 story
buildings have destroyed our skyline & threaten the very "village" aspect that makes this area so unique & special,
and worth preserving!! please, please, please, for the love of god & our lovely hamburg, deny this proposal & limit
future ones. Garfield street already looks like lil' Newport Beach. you can always build more, but you can never go
back.
thank you.
b.
(yes i know this is a silly act in futility, and there will be 4 story mini hotels from cbd blvd, to the 5, and the lagoon
to tamarack in 10 years, but i feel better at least saying something :) if you lived here you would understand.
CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe.
Oct.. 15, 2025 Item #1 62 of 343
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: CT 2024-0004 / PUD 2024-0007 / CDP 2024-0036 (DEV2024-0094) -
2647 JEFFERSON STREET HOMES
Project Location - Specific: 2647 Jefferson Street
Project Location - City: Carlsbad Project Location - County: San Diego
Description of Project: Demolition of an existing single-family residences followed by the construction of
four, three-story triplex structures creating 12 residential condominium units on one lot. Each structure
will be approximately 34 feet in height, with parapets, roof deck guardrails, and architectural features
extending to approximately 39.5 feet in height. The condominium units will be approximately 1,667
square feet in size. Each of the units will include a roof deck and an attached garage, which will
accommodate two cars with the use of an internal car lift, accessed from a common drive isle. A 38.75%
density bonus is requested with the dedication of 12% of the base density units to be designated for very
low-income households (1 unit). Two incentives/concession and seven waivers are requested to facilitate
the development. The incentives/concessions include requests to waive full right-of-way improvements,
and elimination of the requirement to replace the existing 14-inch water main for the entire length of
frontage of the parcel. The waivers requested are from (1) street yard setback requirements; (2) side yard
setback requirements; (3) rear yard setback requirements; (4) community recreation space requirements;
(5)minimum separation requirements between structures; (6) limits on lot coverage, and (7) minimum
interior single-car garage dimensions.
Name of Public Agency Approving Project: City of Carlsbad
Name of Person or Agency Carrying Out Project: JONATHAN FRANKEL, RINCON HOMES
Name of Applicant: RINCON HOMES
Applicant’s Address: 5315 AVENIDA ENCINAS, SUITE 200, CARLSBAD, CA, 92008
Applicant’s Telephone Number: (925) 708-3638
Name of Applicant/Identity of person undertaking the project (if different from the applicant above):
Exempt Status: Categorical Exemption: Class 32, Section 15332 (In-Fill Development Projects)
Exhibit 9
Oct.. 15, 2025 Item #1 63 of 343
Reasons why project is exempt: The project is consistent with the general plan as well as the zoning
ordinance in terms of land use, density, and development standards. The project is within the city limits,
is less than five acres in size, and is surrounded by urban uses. Because the site contains only non-native
and ornamental vegetation, the site has no value as habitat for endangered, rare, or threatened species.
Approval of the project would not result in any significant effects relating to traffic (as verified by the
Vehicle Miles Traveled Analysis prepared by LOS Engineering, Inc. dated May 13, 2025, Exhibit 1), noise
(as verified by the Noise Study prepared by Birdseye Planning Group dated June 2024, Exhibit 2), air quality
(as verified by the Air Quality/Greenhouse Gas Study by Birdseye Planning Group dated July 2024, Exhibit
3), or water quality.
Finally, the subject site is served by public and private utilities, including the city’s water, sewer, and
electrical utilities. The subject site has access and is served directly from Jefferson St., which is an existing
developed roadway with existing utilities. Water infrastructure in the vicinity of the Project site is
maintained and operated by Carlsbad Municipal Water District (CMWD). Sewer service is currently
provided by the City of Carlsbad to the Project site via the existing public sewer system in the vicinity of
the Project. Water service for domestic and fire protection uses would be provided via the existing water
connections to the existing public water system. Furthermore, the Project would pay the required water
connection fees to help offset the Project’s contribution to the city’s water collection infrastructure needs.
For sewer, according to City of Carlsbad Utilities Department staff, the sewer lines adjacent to the site
need to be upsized along the Project’s flow path (in pipes downstream of the Project site, north of Laguna
Dr.) to accommodate the Project’s addition of 11 units and other future growth in the area. Utilities staff
indicated that facilities to service the proposed Project are reasonably expected to be available within the
next five years. The city’s Capital Improvement Plan (CIP) will address this system deficiency and support
system reliability prior to Project occupancy. Wastewater generated by the proposed Project would be
conveyed to the Encina Water Pollution Control Facility (EWPCF), located in Carlsbad, for treatment and
then disposal through the ocean outfall or delivery to the adjacent Carlsbad Water Recycling Facility for
reuse. As the Project’s addition of 11 residences would represent a fraction of a percent of the population
served by the city, wastewater generated by the Project would represent a small fraction of the available
capacity of the city. The Developer would pay required sewer capacity and connection fees to help offset
the Project’s contribution to the city’s wastewater collection infrastructure needs and would require
approval of sewer permits prior to connection to the sewer system. (The Municipal Code includes
regulations that require the city to assure available sewer capacity for new projects and fees for
improvements to the infrastructure system.) Therefore, the proposed Project wastewater flows do not
exceed the capacity of existing or planned wastewater conveyance systems and there would be adequate
treatment capacity for the Project, prior to occupancy, in addition to existing commitments.
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
Oct.. 15, 2025 Item #1 64 of 343
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 – In identifying projects that may contribute to cumulative impacts, the CEQA Guidelines
allow the use of a list of past, present, and reasonably anticipated future projects, producing related
or cumulative impacts, including those that are outside of the control of the lead agency. The Project
is not considered to have a significant growth-inducement impact because it is located in a
predominantly developed portion of the city and is of the same form, size and scale of recent
development in the vicinity of the Project site, and of that which is permitted by the General Plan
and Zoning Ordinance. 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 construction 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.
The Project, and all future projects, will be required to comply with all applicable local, regional, and
state laws, regulations, and guidelines, and any significant conflicts would be mitigated or resolved
through the city discretionary review and approval. As described above, any potential impact cause
by the Project’s construction and operation would continue to be less than significant and would not
contribute significantly to regional cumulative impact in the broader project region. Therefore, this
exception does not apply.
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 – There are no unusual circumstances that would have a significant impact on the
environment due to the Project. The Project does not involve any unusual circumstances. Regarding
biological resources, the Project is not located within an existing or proposed Hardline Conservation
Areas or Standards Areas of the Habitat Management Plan.
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 – Jefferson Street is 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 on all sides by existing
residential structures. Therefore, implementation of the Project will result in similar visual conditions
compared with a no project scenario.
Oct.. 15, 2025 Item #1 65 of 343
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 – A Cultural Resources Reports for Historical Assessment by Kristi S. Hawthorne (Exhibit 4,
dated June 7, 2024), and an Archaeological Assessment (Exhibit 5, dated July 8, 2024) and
Paleontological Assessment (Exhibit 6 dated July 8, 2024) by BSFA Environmental Services were
provided to determine if the Project would impact any historical resources pursuant to CEQA. The
report concluded that none of the buildings on the project site are listed or eligible to be listed in any
national, state, or local landmark or historic district programs and that no archaeological or
paleontological resource were found on site. 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.
Carlsbad Municipal Code Section 19.04.070(B) - Exceptions
Exceptions. Even though a project may otherwise be eligible for an exemption, no exemption shall apply
in the following circumstances:
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 residential
uses. The Project site contains two existing buildings and landscaping with 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
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
Oct.. 15, 2025 Item #1 66 of 343
A Cultural Resources Reports for Historical Assessment by Kristi S. Hawthorne (Exhibit 4, dated June 7,
2024) concluded that none of the buildings on the Project site are listed or eligible to be listed in any
national, state, or local landmark or historic district programs. Although the likelihood that intact
archaeological or cultural resources exist on the Project site is low due to previous site disturbance, a
Phase 1 Archaeological Survey Report (BFSA Environmental Services, dated July 8, 2024, Exhibit 5) and
Paleontological Resource Assessment (BFSA Environmental Services, dated July 8, 2024, Exhibit 6) was
provided and found that no archeological resources or significant fossil material within the project
site. Nonetheless, the Project will be conditioned to require archaeological, Native American, and
paleontological monitoring of ground-disturbing activities during project construction in compliance
with standard city regulatory procedures outlined in the Carlsbad Tribal, Cultural, and Paleontological
Resources Guidelines (City of Carlsbad 2017). Therefore, earth-moving activities associated with the
Project would not affect archaeological or cultural resources from either historic or prehistoric periods.
Hazardous materials, unstable soils or other factors requiring special review do not apply or are not
found within this project location.
Lead Agency Contact Person: Kyle VanLeeuwen Telephone: 442-339-2624
Oct.. 15, 2025 Item #1 67 of 343
2647 Jefferson St (CT 2024-0006)
City of Carlsbad
May 13, 2025
Vehicle Miles Traveled Analysis
Prepared for:
Rincon Homes 5315 Avenida Encinas, Suite 200
Carlsbad, CA 92008
Prepared by:
LOS Engineering, Inc.
11622 El Camino Real, Suite 100, San Diego, CA 92130 Phone 619-890-1253
Job #2416
Oct.. 15, 2025 Item #1 68 of 343
LOS Engineering, Inc. 2647 Jefferson St (CT 2024-0006) VMT Analysis
Traffic and Transportation ii May 13, 2025
Table of Contents
1.0 Introduction ................................................................................................................................ 1 2.0 Vehicle Miles Traveled .............................................................................................................. 4
2.1 VMT Significance Thresholds ............................................................................................... 4 2.2 VMT Analysis ........................................................................................................................ 4 3.0 Conclusion .................................................................................................................................. 6
List of Figures
Figure 1: Project Location ...................................................................................................................... 2
Figure 2: Site Plan .................................................................................................................................. 3 Figure 3: City of Carlsbad Residential VMT Map ................................................................................ 5
List of Tables
Table 1: City of Carlsbad VMT Thresholds for Transportation Impacts .............................................. 4
Table 2: City of Carlsbad Residential VMT Thresholds for Transportation Impacts ........................... 5
Appendices
Appendix A ................................................................. City of Carlsbad VMT Map Analysis Template
Oct.. 15, 2025 Item #1 69 of 343
LOS Engineering, Inc. 2647 Jefferson St (CT 2024-0006) VMT Analysis
Traffic and Transportation 1 May 13, 2025
1.0 Introduction
A Vehicle Miles Traveled (VMT) analysis is required to satisfy the California Environmental Quality Act (CEQA) guidelines that utilize VMT as the measure of mobility effectiveness for determining transportation impacts.
The proposed project is located at 2647 Jefferson St Carlsbad, California. The project includes removing an existing home and constructing new homes as follows: Existing use to be removed: One (1) single family dwelling unit
Proposed project: Twelve (12) multi-family dwelling units The net increase is 11 dwelling units. The project parcel is approximately 0.344 acres resulting in a final density of approximately 34.9 dwelling units per acre (12 units/0.344 acres). The project is
anticipated to open in the year 2026 or 2027. The location of the project is shown in Figure 1. A site plan is shown in Figures 2. The format of this study includes the following chapters:
1.0 Introduction 2.0 Vehicle Miles Traveled 3.0 Conclusions
Oct.. 15, 2025 Item #1 70 of 343
LOS Engineering, Inc. 2647 Jefferson St (CT 2024-0006) VMT Analysis
Traffic and Transportation 2 May 13, 2025
Figure 1: Project Location
Source: LOS Engineering, Inc.
No Scale
Pine Valley
Boulder
Campo
Warner Springs
Santa Ysabel
Julian
La Mesa
San Diego
Imperial Beach
El Cajon
Chula Vista
United States
Fallbrook
Mexico
Riverside County
San Diego County
Camp Joseph Pendleton
Oceanside
Carlsbad
Encinitas
Escondido
Vista
San Marcos
Santee
Temecula
RamonaPoway
Pacific Ocean
Tecate
LegendExisting RoadwayProposed Roadway
PROJECT
LOCATION
N
Oct.. 15, 2025 Item #1 71 of 343
LOS Engineering, Inc. 2647 Jefferson St (CT 2024-0006) VMT Analysis
Traffic and Transportation 3 May 13, 2025
Figure 2: Site Plan
Source: Kirk Moeller Architects, Inc.
Oct.. 15, 2025 Item #1 72 of 343
LOS Engineering, Inc. 2647 Jefferson St (CT 2024-0006) VMT Analysis
Traffic and Transportation 4 May 13, 2025
2.0 Vehicle Miles Traveled
A VMT analysis is required to satisfy the CEQA guidelines that utilize VMT as the measure of
effectiveness for determining transportation impacts. The California Governor’s Office of Planning
and Research (OPR) Technical Advisory developed guidance on implementing Senate Bill 743 (SB 743) that shifts the transportation impact measure of effectiveness from Level of Service (LOS) to VMT. The OPR Transportation Technical Advisory on Evaluating Transportation Impacts in CEQA, December 2018 states on page 8 “As noted above, lead agencies have the discretion to set or apply
their own thresholds of significance”.
In compliance with SB 743 and OPR guidance, the City of Carlsbad has adopted the Vehicle Miles
Traveled (VMT) Analysis Guidelines, May 31, 2023 (“VMT Guidelines”) to evaluate impacts under CEQA using a VMT metric.
2.1 VMT Significance Thresholds
The VMT Guidelines documents significance thresholds for transportation VMT impacts based on the project type. As shown in Table 1, the significance threshold for a transportation VMT impact is based on 15% below the city average VMT/Capita.
TABLE 1: CITY OF CARLSBAD VMT THRESHOLDS FOR TRANSPORTATION IMPACTS
Project Type Metric Significance Thresholds
Residential VMT per Capita A significant transportation impact occurs if the project VMT/capita exceeds a level 15% below the city average VMT/capita
Source: VMT Guidelines.
2.2 VMT Analysis
The project does not meet any of the City’s current VMT screening criteria; therefore, the VMT analysis is based on the City’s VMT Analysis maps.
The project residential VMT was determined using the City of Carlsbad Vehicle Miles Traveled
map that is derived from SANDAG’s Series 14 growth forecast Activity Based Model 2 plus (AMB2+) analysis map. The Carlsbad VMT analysis map showing the project location and VMT/Capita is shown in Figure 3.
Oct.. 15, 2025 Item #1 73 of 343
LOS Engineering, Inc. 2647 Jefferson St (CT 2024-0006) VMT Analysis
Traffic and Transportation 5 May 13, 2025
Figure 3: City of Carlsbad Residential VMT Map
As shown in Figure 3, the project is forecasted to have a VMT/Capita at 78.3% of the city average
VMT/Capita, which is below the 85th percentile city average VMT; therefore, the project has a less than significant VMT transportation impact and VMT mitigation is not recommended. The findings are shown in Table 2.
TABLE 2: CITY OF CARLSBAD RESIDENTIAL VMT THRESHOLDS FOR TRANSPORTATION IMPACTS
City Average VMT/Capita for project location
City Wide Residential Average VMT/Capita
Project % Compared to City Average
Significant Transportation Impact (over 85%)?
18.9 24.0 78.5% No
Source: City of Carlsbad VMT Map.
To ensure compliance with the VMT Guidelines, the City of Carlsbad has VMT report templates. A
VMT map template for this project is included in Appendix A.
Oct.. 15, 2025 Item #1 74 of 343
LOS Engineering, Inc. 2647 Jefferson St (CT 2024-0006) VMT Analysis
Traffic and Transportation 6 May 13, 2025
3.0 Conclusion
A VMT analysis is required to satisfy the CEQA guidelines that utilize VMT as the measure of mobility effectiveness for determining transportation impacts. In compliance with SB 743 and OPR guidance, the City of Carlsbad has adopted the Vehicle Miles Traveled (VMT) Analysis Guidelines, May 31, 2023, to evaluate impacts under CEQA using a VMT metric.
The proposed project is located at 2647 Jefferson St Carlsbad, California. The project includes removing an existing home and constructing new homes as follows: Existing use to be removed: One (1) single family dwelling unit
Proposed project:
Twelve (12) multi-family dwelling units The net increase is 11 dwelling units. The project parcel is approximately 0.344 acres resulting in a final density of approximately 34.9 dwelling units per acre (12 units/0.344 acres). The project is
anticipated to open in the year 2026 or 2027.
The project did not meet any of the City’s current VMT screening criteria; therefore, the VMT analysis was prepared using the City’s VMT Analysis maps. The residential project with a net increase of 11 dwelling units is forecasted to have a VMT/Capita at 78.5% of the city average VMT/Capita,
which is below the 85th percentile city average VMT; therefore, the project has a less than significant
VMT transportation impact and VMT mitigation is not recommended.
Oct.. 15, 2025 Item #1 75 of 343
Appendix A
City of Carlsbad VMT Map Analysis Template
Oct.. 15, 2025 Item #1 76 of 343
VMT Report Template for
Land Development Projects – VMT Analysis Using VMT Maps
City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008
2
VMT Analysis Using VMT Maps Requirements
Submission Date: May 2025
SECTION I: Developer Profile
Developer Name: Rincon Homes
Property Manager Name: Mr. Jonathan Frankel
Developer Mailing Address: 5315 Avenida Encinas, Suite 200 Carlsbad, CA 92008
Primary Contact Name: Mr. Jonathan Frankel
Primary Contact Phone/Email: 925-708-3638 jfrankel@rincongrp.com
Developer Mailing Address: 5315 Avenida Encinas, Suite 200 Carlsbad, CA 92008
Transportation Consultant Firm: LOS Engineering, Inc. Transportation Consultant Representative: Mr. Justin Rasas, P.E.
Transportation Consultant Contact Phone/Email: 619-890-1253 justin@losengineering.com
Transportation Consultant Address: 11622 El Camino Real, Suite 100 San Diego, CA 92130
SECTION II: Project Information
Project Name: 2647 Jefferson St Permit Number: CT 2024-0006 Project Address: 2647 Jefferson St, Carlsbad CA 92008
Oct.. 15, 2025 Item #1 77 of 343
VMT Report Template for
Land Development Projects – VMT Analysis Using VMT Maps
City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008
3
SECTION III: Compliance Overview Checklist
Complete the appropriate sections of the checklist below to ensure compliance with the City of
Carlsbad’s VMT Analysis Guidelines.
CEQA VMT Analysis Using VMT Maps
Compliance Checklist
Satisfactory?
(completed by City)
YES NO
VMT Report documenting VMT screening and VMT analysis ☐ ☐
VMT Analysis performed using VMT maps ☐ ☐
VMT Impact Conclusion (significant or less than significant impact) ☐ ☐
Mitigation Measure Identification and Analysis (for significant impacts) ☐ ☐
SECTION IV: VMT Report Contents
The following provides the required contents of a VMT Analysis Using VMT Maps Report.
Page # or
Appendix:
(completed by
preparer)
CEQA VMT Analysis Using VMT Maps
Required Content
Satisfactory?
(completed by City)
YES NO
Executive Summary/Introduction:
• Purpose of VMT analysis and identification of type of
VMT report being prepared
• Regional vicinity map with project location
• Project screening results
• VMT analysis method (Carlsbad VMT maps)
• Significance of CEQA impacts
• Mitigation measures and significance after mitigation
☐
☐
Project Description, including:
• Proposed project description (land use type, intensity,
etc.)
☐ ☐
Oct.. 15, 2025 Item #1 78 of 343
VMT Report Template for
Land Development Projects – VMT Analysis Using VMT Maps
City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008
4
• VMT reduction measures that are part of the project
description
• Site plan
VMT Screening Assessment
• Table that displays all screening criteria and
demonstrates that the project does not meet the
criteria and a brief statement of why. To demonstrate
why a project doesn’t meet any of the screening
criteria, the following information may be necessary:
o Daily project trip generation (total, without
adjustments for existing land uses on the
site).
o A map showing the project’s lack of proximity
to a major transit stop, planned major transit
stop, or a stop/transit center along a high-
quality transit corridor.
o Statements that locally serving, affordable
housing, and redevelopment criteria are not
applicable.
• For projects with multiple land uses, perform a
screening assessment and create a screening
assessment table for each land use. Document the
conclusion of the screening assessment by land use. If
one land use meets the screening criteria and one
does not, only complete a VMT analysis for the
component that does not meet the screening criteria.
☐
☐
Identify VMT Calculation Methodology and VMT Metric
• Provide screenshot(s) of Carlsbad VMT maps with
project TAZ(s) highlighted and VMT data displayed
(for each metric that is applicable).
• For residential projects, VMT/Capita is applicable.
• For employment projects, VMT/Employee is
applicable.
• The VMT Analysis Using VMT Maps Report type is only
applicable to residential and employment projects.
☐
☐
Oct.. 15, 2025 Item #1 79 of 343
VMT Report Template for
Land Development Projects – VMT Analysis Using VMT Maps
City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008
5
Identify VMT Thresholds and Perform VMT Impact Analysis
• Refer to the Carlsbad VMT Analysis Guidelines to
determine the appropriate impact threshold to apply
to the analysis. Document the threshold and the
numerical value that represents the threshold. For
example, the threshold for residential projects is 15%
below the city-wide average VMT/capita, or currently
20.4 miles per resident.
• Determine the project’s VMT using the Carlsbad VMT
maps, and if applicable, apply any VMT reduction
measures that are part of the project description
(refer to VMT Analysis Guidelines Appendix F for
guidance on performing reduction calculations).
• Compare the project’s VMT to the City threshold and
document if the project has a significant or less than
significant impact.
Identify and Analyze Mitigation Measures (if the Impact is
Significant)
• If a significant impact is identified, refer to VMT
Analysis Guidelines Appendix F to identify potential
mitigation measures and analysis guidance.
• Analyze how much VMT reduction is associated with
the mitigation measures and determine if mitigation
reduces the impact to less than significant.
• If the impact is still significant after mitigation is
applied, document that the project has a significant
and unavoidable impact.
Oct.. 15, 2025 Item #1 80 of 343
2647 JEFFERSON STREET HOMES
PROJECT
NOISE STUDY
Prepared for: Rincon Real Estate Group
Prepared by:
June 2024
Oct.. 15, 2025 Item #1 81 of 343
2647 Jefferson Street Homes Project
Noise Study
City of Carlsbad
Table of Contents
Page
Project Description ..................................................................................................................................... 2
Setting .......................................................................................................................................................... 2
Overview of Sound Measurement ................................................................................................. 2
Sensitive Receptors .......................................................................................................................... 6
Project Site Setting ............................................................................................................................ 7
Regulatory Setting ............................................................................................................................ 8
Impact Analysis ........................................................................................................................................ 10
Methodology and Significance Thresholds ................................................................................ 10
Temporary Construction Noise .................................................................................................... 11
Temporary Construction-Related Vibration .............................................................................. 13
Long-Term Operational Noise Exposure .................................................................................... 13
References ................................................................................................................................................. 18
List of Figures
Figure 1 - Project Location ........................................................................................................................ 3
Figure 2 – Proposed Site Plan ................................................................................................................... 4
Figure 3 – Noise Monitoring Locations ................................................................................................... 9
Figure 4 – Sensitive Properties ............................................................................................................... 16
List of Tables
Table 1 – Sound Levels of Typical Noise Sources and Noise Environments ..................................... 6
Table 2 – Noise Monitoring Results......................................................................................................... 8
Table 3 – Typical Construction Equipment Noise Levels .................................................................. 11
Table 4 – Typical Maximum Construction Noise Levels at Various Distances from
Project Construction ................................................................................................................ 12
Table 5 – Vibration Source Levels for Construction Equipment ....................................................... 14
Table 6 – Modeled Noise Levels ............................................................................................................ 15
Appendices
Appendix A Noise Monitoring Data
Oct.. 15, 2025 Item #1 82 of 343
2647 Jefferson Street Project
Noise Study
2 City of Carlsbad
2647 JEFFERSON STREET PROJECT
CARLSBAD, CALIFORNIA
NOISE STUDY
This report is an analysis of the potential noise impacts associated with the construction and
operation of a new 12‐unit residential infill project (Jefferson Street Homes) at 2647 Jefferson
Street in the City of Carlsbad. The report has been prepared by Birdseye Planning Group, LLC,
under contract to the applicant to support the environmental review process and address
comments provided by the City of Carlsbad after review of the project entitlement submittal.
This study analyzes the potential for temporary impacts associated with construction activity
and long‐term impacts associated with operation of the proposed project.
PROJECT DESCRIPTION
The project site is located on the west side of Jefferson Street between Knowles Avenue and
Laguna Avenue. The project would replace a single‐family residence with 12 attached, two‐
story, 1,500 square foot multifamily units. Each unit would have a garage with a parking lift
system capable of accommodating two cars. The site would be accessed via a new driveway
from Jefferson Street. Jefferson Street is the primary contributor to ambient noise conditions.
Interstate 5 is located 1,340 feet to the east and contributes negligibly to ambient noise
conditions. The site is located approximately 0.6 miles east of the Atichson, Topeka and Santa Fe
Railroad (AT&SF) rail corridor. This segment of the Los Angeles – San Diego – San Luis Obispo
(LOSSAN) corridor is the second busiest passenger and freight rail corridor in the United States
and may contribute to ambient conditions. The City has requested an evaluation of potential
noise and vibration effects associated with construction, traffic and railroad corridor operation
consistent with the Noise Guidelines Manual (1995). Construction is anticipated to begin in
mid‐2025 and be completed in early 2026. Figure 1 provides a vicinity map; Figure 2 shows a
project site plan.
SETTING
Overview of Sound Measurement
Noise level (or volume) is generally measured in decibels (dB) using the A‐weighted sound
pressure level (dBA). The A‐weighting scale is an adjustment to the actual sound pressure levels
to be consistent with that of human hearing response, which is most sensitive to frequencies
around 4,000 Hertz (about the highest note on a piano) and less sensitive to low frequencies
(below 100 Hertz).
Oct.. 15, 2025 Item #1 83 of 343
Figure 1 - Vicinity Map - Project Site Oct.. 15, 2025 Item #1 84 of 343
Figure 2 - Site Plan
Oct.. 15, 2025 Item #1 85 of 343
2647 Jefferson Street Project
Noise Study
5 City of Carlsbad
Sound pressure level is measured on a logarithmic scale with the 0 dB level based on the lowest
detectable sound pressure level that people can perceive (an audible sound that is not zero
sound pressure level). Based on the logarithmic scale, a doubling of sound energy is equivalent
to an increase of 3 dBA, and a sound that is 10 dBA less than the ambient sound level has no
effect on ambient noise. Because of the nature of the human ear, a sound must be about 10 dBA
greater than the reference sound to be judged as twice as loud. In general, a 3 dBA change in
community noise levels is noticeable, while 1‐2 dB changes generally are not perceived. Quiet
suburban areas typically have noise levels in the range of 40‐50 dBA, while arterial streets are in
the 50‐60+ dBA range. Normal conversational levels are in the 60‐65 dBA range, and ambient
noise levels greater than 65 dBA can interrupt conversations. Noise levels typically attenuate (or
drop off) at a rate of 6 dBA per doubling of distance from point sources (i.e., industrial
machinery). Noise from lightly traveled roads typically attenuates at a rate of about 4.5 dBA per
doubling of distance. Noise from heavily traveled roads typically attenuates at about 3 dBA per
doubling of distance. Noise levels may also be reduced by intervening structures; generally, a
single row of buildings between the receptor and the noise source reduces the noise level by
about 5 dBA, while a solid wall or berm reduces noise levels by 5 to 10 dBA. The manner in
which older homes in California were constructed (approximately 30 years old or older)
generally provides a reduction of exterior‐to‐interior noise levels of about 20 to 25 dBA with
closed windows. The exterior‐to‐interior reduction of newer residential units and office
buildings is generally 30 dBA or more.
In addition to the actual instantaneous measurement of sound levels, the duration of sound is
important since sounds that occur over a long period of time are more likely to be an annoyance
or cause direct physical damage or environmental stress. One of the most frequently used noise
metrics that considers both duration and sound power level is the equivalent noise level (Leq).
The Leq is defined as the single steady A‐weighted level that is equivalent to the same amount
of energy as that contained in the actual fluctuating levels over a period of time (essentially, the
average noise level). Typically, Leq is summed over a one‐hour period. Lmax is the highest
RMS (root mean squared) sound pressure level within the measuring period, and Lmin is the
lowest RMS sound pressure level within the measuring period.
The time period in which noise occurs is also important since noise that occurs at night tends to
be more disturbing than that which occurs during the day. Community noise is usually
measured using Day‐Night Average Level (Ldn), which is the 24‐hour average noise level with
a 10‐dBA penalty for noise occurring during nighttime (10 p.m. to 7 a.m.) hours, or Community
Noise Equivalent Level (CNEL), which is the 24‐hour average noise level with a 5 dBA penalty
for noise occurring from 7 p.m. to 10 p.m. and a 10 dBA penalty for noise occurring from 10
p.m. to 7 a.m. Noise levels described by Ldn and CNEL usually do not differ by more than 1
dB. Table 1 shows sounds levels of typical noise sources measured using Leq.
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2647 Jefferson Street Project
Noise Study
6 City of Carlsbad
Sensitive Receptors
Noise exposure goals for various types of land uses reflect the varying noise sensitivities
associated with each of these uses. The City of Carlsbad General Plan Noise Element Update
(approved September 2015) includes a variety of land use and development types that are noise
sensitive including residences, schools, churches, hospitals and convalescent care facilities.
Sensitive receptors are located adjacent to and surrounding the project site. The closest is a
multifamily building located adjacent to and south of the site at 2659 Jefferson Street adjacent to
and south of the site and at 2614 Jefferson Street adjacent to and north of the siter. Single‐ and
multifamily residences are the dominant land use in the area.
Table 1. Sound Levels of Typical Noise Sources and Noise Environments
Noise Source
(at Given Distance)
Noise Environment
A-Weighted
Sound Level (Decibels)
Human Judgment of Noise Loudness
(Relative to Reference
Loudness of 70
Decibels*)
Military Jet Takeoff
with Afterburner
(50 ft)
Carrier Flight Deck 140 128 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
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2647 Jefferson Street Project
Noise Study
7 City of Carlsbad
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., 2016
Project Site Setting
The most common and primary sources of noise in the project site vicinity are motor vehicles
(e.g., automobiles, buses, trucks, and motorcycles) along Jefferson Streety. Motor vehicle noise
can be a concern when it is characterized by a high number of individual events that can create
a sustained noise level in proximity to noise sensitive uses. Interstate 5 is located approximately
1,300 feet to the east. It is audible as background noise but contributes negligibly to overall
noise levels at the project site.
The Atichson, Topeka and Santa Fe Railroad (AT&SF) rail corridor is located approximately 0.4
miles west of the site. This segment of the Los Angeles – San Diego – San Luis Obispo
(LOSSAN) corridor is the second busiest passenger and freight rail corridor in the United States.
According to the rail timetables, up to 50 trains (40 passenger and 10 freight trains) use the
corridor segment daily between Oceanside and the Santa Fe Depot in downtown San Diego.
Existing wheel‐rail noise and engine noise is not audible at the project site. The warning
horns/bells that are used when trains are approaching or departing the Carlsbad Village Drive
station are audible as background noise but overall, rail operations contribute negligibly to the
ambient noise environment in the study area. McClellan‐Palomar Airport is located
approximately 4.3 miles southeast of the site. The site is outside the airport influence area;
however, aircraft operations (airplanes and helicopters) are audible and contribute to existing
noise levels in the project area. No other noise sources are near the project site.
The City of Carlsbad General Plan Update Noise Element (2015) provides noise contours
associated with transportation corridors (i.e., roadways, railroad and airport). This provides a
graphic illustration of sound levels near road corridors, but typically does not include effects of
landforms and adjacent structures. Generally, barriers between a source and receiver absorb or
reflect noise resulting in a quieter environment. Where barriers or landforms do not interrupt
the noise transmission path from source to receiver, the contours prove to be reasonable
estimates of typical noise levels from roadway traffic. In areas where barriers or landforms
interrupt the sound transmission, the noise contours overestimate the extent to which a source
intrudes into neighboring areas. The noise contour distances describe worst‐case conditions
because they do not account for any obstructions to the noise path, such as walls, berms, or
buildings. As noted, railroad noise is audible when train pass‐by events occur. The contours
Oct.. 15, 2025 Item #1 88 of 343
2647 Jefferson Street Project
Noise Study
8 City of Carlsbad
provided in the General Plan Update Noise Element provide a reasonable prediction of rail
noise levels at the site. Under existing conditions as shown in Noise Element Figure 5‐2, the
project site is within the 60‐65 dBA CNEL contour intervals for I‐5 and outside the 60‐65 contour
for the railroad track. As shown in Noise Element Figure 5‐3, the project site would remain
within the 60‐65 dBA future contour for I‐5 and outside the contour for the railroad track at
build out which is anticipated to occur in 2040. The dominant noise source at the project site is
traffic on Jefferson Street.
To gather data on the general noise environment at the project site, one weekday 15‐minute
noise measurement were acquired in proximity to the project site on June 7, 2024, using an
ANSI Type II integrating sound level meter. The predominant noise source in the area during
monitoring was traffic on Jefferson Street. Aircraft overflights and train pass by events
contributed negligibly to ambient conditions. During monitoring, a total of 264 cars/light trucks
and four medium trucks (i.e., two axles, four‐wheels) passed the site on Jefferson Street. Table 2
identifies the noise measurement location and measured noise levels. The monitoring location
is shown in Figure 3. Monitoring data is provided as Appendix A.
Table 2 Noise Monitoring Results
Measurement Location Primary Noise Source Sample Time Leq (dBA)
Project site located at 2647 Jefferson Street Traffic Weekday afternoon 65.8
Source: Field visit using ANSI Type II Integrating sound level meter.
Regulatory Setting
In 1976, the California Department of Health, State Office of Noise Control published a
recommended noise/land use compatibility matrix which many jurisdictions have adopted as a
standard in their general plan noise elements. This matrix indicates that residential land uses
and other noise sensitive receptors preferentially should be located in areas where outdoor
ambient noise levels do not exceed 65 to 70 dBA (CNEL or Ldn).
Municipal Code and Noise Guideline Manual
The City of Carlsbad has established noise guidelines in Table 2 of General Plan Noise Element
(City of Carlsbad, 2015) that are applicable for transportation noise sources. The noise
guidelines identify compatible exterior noise levels for various land use types. Residential land
uses are considered normally acceptable up to 60 dB CNEL. Commercial land uses are
considered normally acceptable up to 65 dB CNEL and conditionally acceptable up to 75 dB.
Interior spaces within commercial buildings are limited to 50 dBA CNEL.
The City of Carlsbad Municipal Code regulates construction noise by limiting the hours of
operation (City of Carlsbad 2003). Construction activities are allowed to occur Monday through
Oct.. 15, 2025 Item #1 89 of 343
Figure 3 - Noise Monitoring LocaƟon - Project Site
M1
Oct.. 15, 2025 Item #1 90 of 343
2647 Jefferson Street Project
Noise Study
10 City of Carlsbad
Friday between the hours of 7 a.m. to sunset; and on Saturdays from 8 a.m. to sunset, excluding
legal holidays. The City does not have quantitative noise level limits (i.e., based on sound
levels) for general nuisance noise such as that associated with stationary equipment located on
private property. For the purpose of this study, the residential standard of 60 dB CNEL is used
to evaluate potential exterior noise impacts associated with the proposed project traffic at
neighboring receivers. An interior noise standard of 45 dBA CNEL is used herein as referenced
in the City of Carlsbad Noise Guidelines Manual (1995).
Vibration Standards
Vibration is a unique form of noise as the energy is transmitted through buildings, structures
and the ground whereas audible noise energy is transmitted through the air. Thus, vibration is
generally felt rather than heard. The ground motion caused by vibration is measured as peak
particle velocity (PPV) in inches per second and is referenced as vibration decibels (VdB) for the
purpose of evaluating the potential for adverse construction‐related impacts. The vibration
velocity level threshold of perception for humans is a PPV of approximately 0.01 inches/second
which equates to 65 VdB. A vibration velocity of 75 VdB is the approximate dividing line
between barely perceptible and distinctly perceptible levels.
With respect to potential ground‐borne vibration impacts on structures, the FTA states that
ground‐borne vibration levels in excess of PPV 0.2 inches/second (100 VdB) could damage
fragile buildings and levels in excess of PPV 0.12 inches/second (95 VdB) could damage
extremely fragile historic buildings. No historic buildings occur on the site or are known to
occur near the site. Adjacent buildings are all relatively modern structure constructed
consistent with applicable California Building Code and seismic standards. However, to
conservatively estimate potential vibration impacts on neighboring residences, a PPV of 0.2
inches per second (100 VdB) is used herein.
IMPACT ANALYSIS
Methodology and Significance Thresholds
Construction noise estimates are based upon noise levels reported by the Federal Transit
Administration, Office of Planning and Environment, and the distance to nearby sensitive
receptors. Reference noise levels from that document were used to estimate noise levels at
nearby sensitive receptors based on a standard noise attenuation rate of 6 dB per doubling of
distance (line‐of‐sight method of sound attenuation).
The site is currently developed with one single‐family residence. Noise levels associated with
existing and future traffic were based on the difference in trip volumes between existing
volumes counted during monitoring and the proposed use less traffic generated by the existing
use. A doubling of traffic volumes would be required to cause a noticeable increase (3 dBA) in
traffic noise. Thus, the two numbers were calculated to determine whether the project would
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2647 Jefferson Street Project
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11 City of Carlsbad
generate enough traffic to increase noise levels by 3 dBA or more. Further, rail noise levels at
the site were estimated based on methodologies approved by the Federal Rail Administration.
Specific assumptions used in the analysis are described below.
As noted, a noise increase greater than 3 dBA is readily perceptible to the average human ear;
and thus, is the level considered a substantial noise increase related to traffic operations.
However, within the City of Carlsbad, noise impacts are also considered significant if noise
levels would exceed 60 dBA CNEL. For the purpose of this evaluation, the peak hour Leq is
used for traffic noise as it provides a more conservative estimate of potential noise levels. The
CNEL is used within the rail noise discussion. Existing noise levels at the site currently exceed
60 dBA as shown in Table 2. Thus, the determination of impact is based on whether existing
exterior noise levels would noticeably change with project operation. A noticeable change is +/‐
3 dBA and requires that the sound energy either double or decrease by one‐half. Thus, for
existing conditions at the site to noticeably increase, the project would need to double existing
traffic volumes while maintaining the same travel speed.
Temporary Construction Noise
The main sources of noise during construction activities would include heavy machinery used
during demolition, grading, and clearing the site, as well as equipment used during building
construction and paving. Table 3 shows typical noise levels associated with heavy construction
equipment. As shown, average noise levels associated with the use of heavy equipment at
construction sites can range from 81 to 91 dBA at 25 feet from the source, depending upon the
types of equipment in operation at any given time and phase of construction.
Table 3 Typical Maximum Construction Equipment Noise Levels
Equipment Onsite
Typical Maximum Level (dBA) 25 Feet from the Source
Typical Maximum Level (dBA) 50 Feet from the Source
Typical Maximum Level (dBA) 100 Feet from the Source
Air Compressor 86 80 74
Backhoe 86 80 74
Bobcat Tractor 86 80 74
Concrete Mixer 91 85 79
Loader 86 80 74
Bulldozer 91 85 79
Jack Hammer 94 88 82
Pavement Roller 91 85 79
Street Sweeper 88 82 76
Man Lift 81 75 69
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Table 3 Typical Maximum Construction Equipment Noise Levels
Equipment Onsite
Typical Maximum Level (dBA) 25 Feet from the Source
Typical Maximum Level (dBA) 50 Feet from the Source
Typical Maximum Level (dBA) 100 Feet from the Source
Dump Truck 90 84 78
Mobile Crane 89 83 77
Excavator/Scraper 91 85 79
Source: FTA Noise and Vibration Impact Assessment Manual (September 2018), Table 7-1.
Noise levels are based on actual maximum measured noise levels at 50 feet (Lmax).
Noise levels are based on a noise attenuation rate of 6 dBA per doubling of distance.
As noted, there are residential properties adjacent to the site and construction noise will be
audible at these properties. Table 4 shows typical maximum construction noise levels at various
distances from construction activity, based on a standard noise attenuation rate of 6 dBA per
doubling of distance. The noise level used to estimate the maximum noise level that could occur
is based on use of a bobcat tractor as it is likely to be the noisiest type of equipment used over a
sustained period of time during demolition and site preparation activities. Actual noise levels
will fluctuate throughout the day and may periodically exceed 84 dBA at the property line
depending on the type and location of equipment used and whether multiple pieces of
equipment are operating simultaneously in the same area.
Table 4 Typical Maximum Construction Noise Levels at Various Distances from Project Construction
Distance from Construction
Maximum Noise Level at Receptor (dBA)
25 feet 84
50 feet 78
100 feet 72
250 feet 66
500 feet 60
1,000 feet 54
Construction noise levels at neighboring residences could be as high as 84 dBA. However,
temporary construction noise is not restricted if it occurs between the hours specified in the
noise ordinance referenced herein.
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Temporary Construction‐Related Vibration
Activities associated with commercial projects do not generate vibration. Thus, this discussion
will focus on temporary vibration caused by construction. As referenced, the closest residence
to the site is located adjacent to and south of the site. However, residences surround the project
site on all sides. Based on the information presented in Table 5, vibration levels from operation
of a large bulldozer would be approximately 87 VdB (0.089 inches/second) or less at 25 feet
(Caltrans 2013). Grading within 25 feet of the nearest residential structures would be required.
As discussed, a PPV of 0.2 inches/second (100 VdB) is the vibration energy required to damage
fragile historic buildings. While vibration from grading may be perceived at neighboring
residences, the vibration energy would be well below that required to cause structural damage.
Table 5 Vibration Source Levels for Construction Equipment
Equipment Approximate VdB
25 Feet 50 Feet 60 Feet 75 Feet 100 Feet
Large Bulldozer 87 81 79 77 75
Loaded Trucks 86 80 78 76 74
Jackhammer 79 73 71 69 67
Small Bulldozer 58 52 50 48 46
Source: Federal Railroad Administration, 1998
Vibration levels at residential buildings adjacent to the project site may exceed the groundborne
velocity threshold level of 72 VdB for residences and/or buildings where people sleep as
discussed above. Maximum vibration levels would range from 58 to 87 VdB depending on the
type of equipment used. However, provided construction occurs within the prescribed hours,
any temporary impact would be less than significant.
Long‐Term Operational Noise Exposure
Exterior Traffic Noise. Traffic is the primary noise source that would be generated by the
proposed project. Thus, whether a traffic‐related noise impact would occur is based on whether
the project would double peak hour traffic volumes relative to existing conditions or cause
noise levels to exceed 60 dBA. The peak hour is defined as the one‐hour period between 7:00 am
and 9:00 am and 4:00 pm and 6:00 pm when the highest volumes occur. As referenced, the
existing structure is a single‐family residence which generate approximately 10 daily trips (San
Diego Association of Governments, Not So Brief Guide of Vehicular Traffic Generation Rates for the
San Diego Region, April 2002). The proposed project would provide 12 multi‐family units which
generate 6 daily trips per unit. The project could generate up to 72 daily trips. The existing uses
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generate 10 daily trips. The project would result in a net increase of 62 daily trips over existing
conditions.
Noise levels generated by traffic on Jefferson Street were modeled using the Federal Highway
Administration Traffic Noise Model (TNM) version 2.5 software (see Appendix A). The model
calculates traffic noise at receiver locations based on traffic volumes, travel speed, mix of vehicle
types operating on the roadways (i.e., cars/trucks, medium trucks and heavy trucks) and related
factors. Traffic volumes and vehicle mix used to calibrate TNM were based on vehicle counts
obtained during the monitoring period. The 15‐minute counts were multiplied by four to obtain
hourly traffic counts. The model was calibrated to calculate noise levels that are +/‐ 2 dBA those
measured on‐site and reported in Table 2.
Noise levels were calculated at the following receivers and are intended to represent conditions
at multiple receivers within proximity to these locations:
1. Multi‐family residence at 2659 Jefferson Street;
2. Multi‐family residences at 2615 Jefferson Street; and
3. Single‐family residences at 2644 Jefferson Street.
The receiver locations are shown in Figure 4. As shown in Table 6, the daytime hourly average
(Leq) exceeds the 60‐dBA standard at the receivers modeled under baseline conditions. The
addition of 62 daily (six peak hour) trips with the project would reduce noise levels as shown.
Thus, long term traffic operation associated with the project would have no adverse effect on
noise levels at sensitive properties within proximity to the site. Project impacts with respect to
exterior traffic noise would be less than significant.
Table 6 Modeled Noise Levels
Receptor Existing Leq Exceed Standard? With Project Leq dBA Change Significant Impact Site 1 66.6 No 66.7 +0.1 No Site 2 66.5 No 66.6 +0.1 No
Site 3 65.6 No 65.5 +0.1 No
Interior Traffic Noise. Current development is designed to meet or exceed California Energy
Code Title 24 standards which specify construction methods and materials that result in energy
efficient structures and up to a 30 dBA reduction in exterior noise levels (assuming windows are
closed). Older residences typically provide a 20‐25 dBA reduction in exterior noise levels. When
windows are open the insertion loss drops to about 10 dBA. Assuming windows are closed,
interior noise levels within the adjacent residences would be reduced from 66.6 dBA (baseline)
to a high of 46.6 dBA. This exceeds the 45 dBA interior standard under baseline conditions. As
stated, the project is anticipated to remain within the 60‐65 dBA future year (2040) noise
contour. Assuming a baseline noise level of 66.6 dBA, a 30 dBA reduction in noise levels
associated with current construction methods and materials, would result in an interior noise
Oct.. 15, 2025 Item #1 95 of 343
Figure 4 - Noise Receiver LocaƟons - Project Site
R1
R2
R3
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2647 Jefferson Street Project
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level of approximately 36.6 dBA within the proposed building. This would be within the 45
dBA standard for residential uses.
Exterior Railroad Noise. The AT&SF corridor is located approximately 0.4 miles to the west of
the site and is used by Amtrak and the North County Transit District Coaster to provide
passenger rail service. It is also used by freight trains during the late evening and nighttime
hours. Based on the timetables, approximately 50 trains operate daily within this segment.
Train volumes vary throughout the day but are generally higher during the morning and
evening commute hours and reflect the dominant use of this corridor by commuter rail and
passenger trains.
Train noise is generated by a combination of factors including the number of locomotives, rail
cars, speed, volume distribution over the day and nighttime hours and whether train horns are
used. The existing rail noise levels at the project site were calculated using a proprietary
software program based on Federal Rail Administration methodology. It was assumed the
average speed through the area is 50 miles per hour and that each passenger train has one
locomotive and 10 rail cars. For freight trains it was assumed they have two locomotives and 50
cars. Train warning horns were audible during monitoring as a distant source; thus, it was
conservatively assumed that train operators do use the warning horn when passing by the site.
Of the 50 train pass by events each day, five freight operations were assumed to occur during
the nighttime (10:00 p.m. to 7:00 a.m.) hours. Based on these assumptions, the exterior CNEL at
the project site (3,168 feet west of the rail corridor) is approximately 49.1 dBA when both
passenger and freight rail operations are combined. The estimated CNEL is less than measured
background noise and generally appears consistent with CNEL contours provided in the 2015
General Plan Update Noise Element for residential areas within the City of Carlsbad. Rail
operation would not exceed the recommended CNEL (60‐dBA) for residential uses.
Interior Railroad Noise. The existing exterior CNEL at the site exceeds the standard
recommended by the City of Carlsbad for residential uses. However, the project would have no
impact on noise levels. Design features associated with the project would reduce interior noise
levels to at least 45 dBA CNEL as specified in the City of Carlsbad Noise Guidelines Manual for
sensitive land uses (i.e., residences). As noted above, the proposed project would be designed to
meet or exceed California Energy Code Title 24 standards which specify construction methods
and materials that result in energy efficient structures and up to a 30 dBA reduction in exterior
noise levels (assuming windows are closed). Assuming windows are closed, the CNEL
associated with rail noise would be well below background noise levels. No measures in
addition to compliance with Title 24 design requirements would be necessary to reduce interior
rail noise.
Rail Vibration. As noted, the proposed project would be constructed approximately 3,168 feet
east of the rail corridor. The distance between a conventional commuter railroad and Category 2
(i.e., residential) land use where the potential for a vibration impact to occur is 200 feet as
defined in Table 6.8 within the FTA noise and vibration impact assessment methodology. The
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screening distances include a 5‐decibel safety factor. The proposed project site is located outside
the 200‐foot screening distance; thus, no rail related vibration impacts would occur at the site.
Heating, Ventilation and Air Conditioning. The HVAC system proposed for use on the site
has not been specified and noise levels vary depending on the size of the system. However, it is
assumed that a total of 12 HVAC units, one for each unit, will be located on the roof of each
unit. Reference noise levels for the project are based on noise measurements made at similar
facilities. HVAC noise levels can be expected to range from 60 to 70 dBA at 5 feet from the
equipment and ventilation openings. To conservatively evaluate HVAC noise levels, the Leq
was predicted at northern and southern property line based on the distance between the
sources and the buildings adjacent to and north/south of the site. It is assumed the six HVAC
units would be an average of 30 feet north and south of the adjacent property lines. The sound
level generated by the six HVAC units would be approximately 77.8 dBA 5 feet from the source.
This would attenuate to 62.2 dBA at the property line which is less than measured ambient
conditions shown above in Table 2. Each HVAC unit would be installed within a noise shroud
which typically provides 5‐10 dBA of attenuation. Conservatively, HVAC noise levels at the
eastern property line would be approximately 57.2 dBA which is less than the 60 dBA
residential standard. A building parapet would provide an additional 5 dBA of attenuation for
the first and second floor residential units. If constructed, the parapet would further reduce
HVAC noise to 52.2 dBA. While noise levels were estimated north and south of the project site,
based on the building configuration, noise levels to the west would be similar. Noise levels at
properties to the east would be less because the attenuation distance across Jefferson Street
would be greater than to the north/south and west.
Parking Lift System. The proposed project would utilize a total of 12 lift systems, one in each
unit, to park up to two vehicles in each garage. The type of system has not been specified;
however, this type of system typically use either a 7 or 10 horsepower electric motor to operate
the hydraulic lift. The mechanisms used in most automated parking systems do not exceed 52
dBA at a distance of 6 feet from the lift. Based on ambient noise levels generated by traffic on
Jefferson Street, noise from the lifts would be inaudible off‐site. The building structure would
provide a minimum of 30 dBA of attenuation as discussed above which would ensure interior
noise levels within each unit would meet City of Carlsbad interior residential noise standards.
Impacts from operation of the parking lift system would be less than significant.
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References
City of Carlsbad. General Plan Update Noise Element. 2015.
City of Carlsbad. Noise Guidelines Manual. September 1995.
San Diego Association of Governments Not So Brief Guide of Vehicular Traffic Generation
Rates for the San Diego Region, April 2002
Federal Highway Administration. Roadway Construction Noise Model. 2006. Users Guide Table 1.
Federal Highway Administration, Transportation Noise Model Version 2.5, 2004.
Federal Transit Administration. Transit Noise and Vibration Impact Assessment Manual. September
2018.
Federal Rail Administration (FRA) Guidelines (Report Number 293630‐1), December 1998.
Oct.. 15, 2025 Item #1 99 of 343
Appendix A
Appendix A
Monitoring Data Sheet
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Site 1 Start Date 6/7/2024
Start Time 1:03:10 PM
End Time 1:18:09 PM
Duration 00:14:59
Meas Mode Single
Input Range Low Input Type Mic
SPL Time Weight Fast
LN% Freq Weight dBA
Overload No
UnderRange No
Sensitivity 18.44mV/Pa
LZeq 73.9
LCeq 72.3
LAeq 65.8
LZFmax 91.1
LCFmax 90.7 LAFmax 82.3
LZFmin 60.4
LCFmin 57.5
LAFmin 45.2
LZE 103.4
LCE 101.8 LAE 95.3
LZpk 98.3
LCpk 97.2
LApk 93.3
LAF1% 74.1
LAF2% 71.7 LAF5% 70.2
LAF8% 69.3
LAF10% 69.0
LAF25% 66.8
LAF50% 64.1
LAF90% 54.3 LAF95% 51.9
LAF99%49.1
Oct.. 15, 2025 Item #1 102 of 343
RESULTS: SOUND LEVELS <Project Name?>
<Organization?> 14 June 2024
<Analysis By?> TNM 2.5
Calculated with TNM 2.5
RESULTS: SOUND LEVELS
PROJECT/CONTRACT: <Project Name?>
RUN: 2637 Jefferson Street Existing
BARRIER DESIGN: INPUT HEIGHTS Average pavement type shall be used unless
a State highway agency substantiates the use
ATMOSPHERICS: 68 deg F, 50% RH of a different type with approval of FHWA.
Receiver
Name No.#DUs Existing No Barrier With Barrier
LAeq1h LAeq1h Increase over existing Type Calculated Noise Reduction
Calculated Crit'n Calculated Crit'n Impact LAeq1h Calculated Goal Calculated
Sub'l Inc minus
Goal
dBA dBA dBA dB dB dBA dB dB dB
Receiver1 1 1 0.0 66.6 66 66.6 10 Snd Lvl 66.6 0.0 8 -8.0
Receiver2 2 1 0.0 66.5 66 66.5 10 Snd Lvl 66.5 0.0 8 -8.0
Receiver3 3 1 0.0 65.6 66 65.6 10 ----65.6 0.0 8 -8.0
Dwelling Units # DUs Noise Reduction
Min Avg Max
dB dB dB
All Selected 3 0.0 0.0 0.0
All Impacted 2 0.0 0.0 0.0
All that meet NR Goal 0 0.0 0.0 0.0
C:\TNM25\Program\2647 Jefferson Street Existing 1 14 June 2024
Oct.. 15, 2025 Item #1 103 of 343
RESULTS: SOUND LEVELS <Project Name?>
<Organization?> 14 June 2024
<Analysis By?> TNM 2.5
Calculated with TNM 2.5
RESULTS: SOUND LEVELS
PROJECT/CONTRACT: <Project Name?>
RUN: 2637 Jefferson Street Existing
BARRIER DESIGN: INPUT HEIGHTS Average pavement type shall be used unless
a State highway agency substantiates the use
ATMOSPHERICS: 68 deg F, 50% RH of a different type with approval of FHWA.
Receiver
Name No.#DUs Existing No Barrier With Barrier
LAeq1h LAeq1h Increase over existing Type Calculated Noise Reduction
Calculated Crit'n Calculated Crit'n Impact LAeq1h Calculated Goal Calculated
Sub'l Inc minus
Goal
dBA dBA dBA dB dB dBA dB dB dB
Receiver1 1 1 0.0 66.7 66 66.7 10 Snd Lvl 66.7 0.0 8 -8.0
Receiver2 2 1 0.0 66.5 66 66.5 10 Snd Lvl 66.5 0.0 8 -8.0
Receiver3 3 1 0.0 65.6 66 65.6 10 ----65.6 0.0 8 -8.0
Dwelling Units # DUs Noise Reduction
Min Avg Max
dB dB dB
All Selected 3 0.0 0.0 0.0
All Impacted 2 0.0 0.0 0.0
All that meet NR Goal 0 0.0 0.0 0.0
C:\TNM25\Program\2637 Jefferson w-Project 1 14 June 2024
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2647 JEFFERSON STREET HOMES
PROJECT
AIR QUALITY/GREENHOUSE GAS STUDY
Prepared for: Rincon Homes
5315 Avenida Encinas, Suite 200 Carlsbad, CA 92008
Prepared by:
July 2024
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2647 Jefferson Street Homes Project Air Quality and Greenhouse Gas Study
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2647 JEFFERSON STREET HOMES PROJECT
CARLSBAD, CALIFORNIA
AIR QUALITY and GREENHOUSE GAS STUDY
Table of Contents
Page
PROJECT DESCRIPTION ..................................................................................................................... 1
SETTING ................................................................................................................................................. 4
Air Pollution Regulation .......................................................................................................... 4
California Air Resources Board .............................................................................................. 5
San Diego Air Polution Control District ................................................................................ 6
Air Quality Management Plans .............................................................................................. 6
SDAPCD Rules and Regulations ............................................................................................ 8
Regional Climate and Local Air Quality ............................................................................... 9
Pollutants ................................................................................................................................... 10
Sensitive Receptors ................................................................................................................... 13
Monitored Air Quality ............................................................................................................. 13
AIR QUALITY IMPACT ANALYSIS .................................................................................................. 14
Methodology and Significance Thresholds ........................................................................... 14
Construction Emissions ............................................................................................................ 18
Operational Impacts ................................................................................................................. 20
GREENHOUSE GAS EMISSION ASSESSMENT .............................................................................. 24
REFERENCES ......................................................................................................................................... 29
List of Figures
Figure 1 Vicinity Map ............................................................................................................. 2
Figure 2 Site Plan ..................................................................................................................... 3
List of Tables
Table 1 Current Federal and State Ambient Air Quality Standards .............................. 5
Table 2 San Diego County Attainment Status ................................................................. 11
Table 3 Ambient Air Quality Data .................................................................................... 14
Table 4 SDAPCD Air Emission Significance Thresholds ............................................... 16
Table 5 Estimated Maximum Daily Construction Emissions With Dust Control
Measures.................................................................................................................. 19
Table 6 Estimated Operational Emissions ........................................................................ 21
Table 7 Estimated Construction Greenhouse Gas Emissions ........................................ 25
Table 8 Estimated Annual Energy-Related Greenhouse Gas
Emissions ................................................................................................................. 26
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Table 9 Estimated Annual Solid Waste and Water Use Greenhouse Gas Emissions . 27
Table 10 Estimated Annual Mobile Emissions of Greenhouse Gases ............................ 27
Table 11 Combined Annual Greenhouse Gas Emissions ................................................. 27
Appendices
Appendix A CalEEMod Air Quality and Greenhouse Gas Emissions Model Results –
Summer/Annual Emissions
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2647 JEFERRSON STREET HOMES PROJECT
CARLSBAD, CALIFORNIA
AIR QUALITY and GREENHOUSE GAS STUDY
This report is an analysis of the potential air quality and greenhouse gas impacts associated
with the 2647 Jefferson Street Homes Project, a multifamily development proposed for
construction in the City of Carlsbad. The report has been prepared by Birdseye Planning
Group, LLC, under contract to the applicant to support the environmental review process and
address comments provided by the City of Carlsbad after review of the initial project
entitlement submittal. This study analyzes the potential for temporary impacts associated with
construction activity and long‐term impacts associated with operation of the proposed project.
PROJECT DESCRIPTION
The project site is located on the west side of Jefferson Street between Knowles Avenue and
Laguna Avenue. The project would replace a single‐family residence with 12 attached, two‐
story, 1,500 square foot multifamily units. Each unit would have a garage with a parking lift
system capable of accommodating two cars. The site would be accessed via a new driveway
from Jefferson Street. The site is approximately 0.34 acres. The site is zoned Residential 3 (R‐3),
Multifamily Residential. The site is surrounded by existing single‐ and multi‐family residences.
The project would be permitted outright in the R‐3 zone. Construction would require the
demolition and removal of one existing residence. Construction is anticipated to begin in mid‐
2025 and be completed in late 2025. The following scope of work is intended to demonstrate
that the project meets the conditions for a Class 32 categorical exemption for air quality. While
not required for a Class 32 exemption, for informational purposes, this report also analyzes the
Projectʹs contribution to GHG emissions. The site is shown in Figure 1. The proposed site plan
is shown in Figure 2.
The following measures are intended to demonstrate compliance with statewide regulations;
and thus, have been incorporated into the the air emissions modeling
The project will provide recycling bins in the trash enclosure areas;
The project will install drought‐tolerant vegetation and water‐efficient irrigation
systems;
The project will install low‐water use appliances and fixtures;
The project will install Energy Star, or equivalent, dishwashers, clothes washers,
refrigerators, and fans;
The project will be compliant with San Diego Air Pollution Control District (SDAPCD)
Rule 67.0.1 (d) which requires the use of low Volitile Organic Compound (VOC) paint
Oct.. 15, 2025 Item #1 108 of 343
Figure 1 - Vicinity Map - Project Site Oct.. 15, 2025 Item #1 109 of 343
Figure 2 - Site Plan
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(no greater than 50 grams/Liter) for use on buildng interior and exterior surface and 100
grams/Liter for traffic marking coatings; and
The project will install bicycle parking facilities.
Dust Control Methods
The project would implement various construction dust control strategies as design features to
be compliant with SDAPCD Rule 55. Compliance with these dust control measures are listed as
follows and would be identified on grading plan approvals:
During clearing, grading, earth‐moving, excavation, or transportation of cut or fill
materials, water trucks or sprinkler systems shall be used to prevent dust from leaving
the site and to create a crust after each day’s activities cease;
During construction, water trucks or sprinkler systems shall be used to keep all areas of
vehicle movement damp enough to prevent dust from leaving the site. At a minimum,
this would include wetting down such areas later in the morning, after work is
completed for the day, and whenever winds exceed 15 mph during active operations.
Watering of active disturbance areas, including active grading areas and unpaved roads,
would occur approximately every 2 hours of active operations, approximately three
times per work day (at a minimum):
All grading and excavation operations shall be halted when wind speeds exceed 25
miles per hour;
Dirt and debris spilled onto paved surfaces at the project site and on the adjacent
roadways shall be swept, vacuumed, and/or washed at the end of each workday; and
All trucks hauling dirt, sand, soil, or other loose material to and from the construction
site shall be covered and/or a minimum 2 feet of freeboard shall be maintained.
REGULATORY SETTING
Air Pollution Regulation
Air pollutants are regulated at the national, State, and air basin level; each agency has a
different degree of control. The United States Environmental Protection Agency (USEPA)
regulates at the national level; the California Air Resources Control Board (CARB) regulates at
the State level; and the SDAPCD regulates air quality in San Diego County.
The federal and state governments have been empowered by the federal and state Clean Air
Acts to regulate the emission of airborne pollutants and have established ambient air quality
standards for the protection of public health. The USEPA is the federal agency designated to
administer national air quality regulations, while CARB is the state equivalent in the California
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Environmental Protection Agency. Local control over air quality management is provided by
CARB through multi‐county and county‐level Air Pollution Control Districts (APCDs) (also
referred to as Air Quality Management Districts). CARB establishes statewide air quality
standards and is responsible for the control of mobile emission sources, while the local APCDs
are responsible for enforcing standards and regulating stationary sources. CARB has
established 15 air basins statewide. The City of Carlsbad is located in the San Diego Air Basin
(SDAB), which is under the jurisdiction of the SDAPCD.
California Air Resources Board
CARB, which became part of the California EPA (CalEPA) in 1991, is responsible for ensuring
implementation of the California Clean Air Act (CCAA), meeting state requirements of the
federal Clean Air Act and establishing California Ambient Air Quality Standards (CAAQSs). It
is also responsible for setting emission standards for vehicles sold in California and for other
emission sources such as consumer products and certain off‐road equipment. CARB also
established passenger vehicle fuel specifications and oversees the functions of local air pollution
control districts and air quality management districts, which in turn administer air quality
activities at the regional and county level. The CCAA is administered by CARB at the state level
and by the Air Quality Management Districts at the regional level. Both state and federal
standards are summarized in Table 1. The federal ʺprimaryʺ standards have been established to
protect the public health. The federal ʺsecondaryʺ standards are intended to protect the nationʹs
welfare and account for air pollutant effects on soil, water, visibility, materials, vegetation, and
other aspects of the general welfare.
Table 1
Ambient Air Quality Standards
Pollutant Average Time California Standards National Standards
Ozone
(O3)
1 hour 0.09 ppm --
8 hours 0.070 ppm 0.070 ppm
Carbon Monoxide
(CO)
8 hours 9.0 ppm 9 ppm
1 hour 20 ppm 35 ppm
Nitrogen Dioxide
(NO2)
Annual Average 0.030 ppm 0.053 ppm
1 hour 0.18 ppm 100 ppb
Sulfur Dioxide
(SO2)
Annual Average -- 0.03 ppm
24 hours 0.04 ppm 0.14 ppm
1 hour 0.25 ppm 75 ppb
Respirable Particulate Matter
(PM10)
24 hours 50 mg/m3 150 mg/m3
Annual Arithmetic Mean 20 mg/m3 --
Fine Particulate Matter
(PM2.5)
Annual Arithmetic Mean 12 mg/m3 12 mg/m3
24 hours -- 35 mg/m3
Sulfates 24 hours 25 mg/m3 --
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Pollutant Average Time California Standards National Standards
Lead 30-day Average 1.5 mg/m3 --
Calendar Quarter -- 1.5 mg/m3
3-month Rolling Average -- 0.15 mg/m3
Hydrogen Sulfide 1 hour 0.03 ppm --
Vinyl Chloride 24 hours 0.010 ppm --
Notes:
ppm = parts per million
ppb – parts per billion
mg/m3 = micrograms per cubic meter
mg/m3 = milligrams per cubic meter
Source: California Air Resources Board 2016
San Diego Air Pollution Control District
The SDAPCD was created to protect the public from the harmful effects of air pollution, achieve
and maintain air quality standards, foster community involvement and develop and implement
cost‐effective programs that meet state and federal mandates while considering environmental
and economic impacts.
Specifically, the SDAPCD is responsible for monitoring air quality and planning, implementing,
and enforcing programs designed to attain and maintain state and federal ambient air quality
standards in the district. Programs developed include air quality rules and regulations that
regulate stationary source emissions, including area sources, point sources, and certain mobile
source emissions. The SDAPCD is also responsible for establishing permitting requirements for
stationary sources and ensuring that new, modified or relocated stationary sources do not
create net emissions increases; and thus, are consistent with the regionʹs air quality goals. The
SDAPCD provides significance thresholds in Regulation II, Rule 20.2, Table 20‐2‐1. “AQIA
Trigger Levels.” These trigger levels were established for stationary sources of air pollution and
are commonly used for environmental evaluations. The SDAPCD enforces air quality rules and
regulations through a variety of means, including inspections, educational or training
programs, or fines, when necessary. The project site is within the SDAB; and thus, is subject to
SDAPCD rules and regulations.
State Implementation Plan/Air Quality Management Plan/Regional Air Quality Strategy
The federal Clean Air Act Amendments (CAAA) mandate that states submit and implement a
State Implementation Plan (SIP) for areas not meeting air quality standards. SIPs are
comprehensive plans that describe how an area will attain national and state ambient air quality
standards. SIPs are a compilation of new and previously submitted plans, programs (i.e.,
monitoring, modeling and permitting programs), district rules, state regulations and federal
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controls and include pollution control measures that demonstrate how the standards will be
met through those measures.
State law makes CARB the lead agency for all purposes related to the SIP. Local air districts and
other agencies prepare SIP elements and submit them to CARB for review and approval. CARB
forwards SIP revisions to the USEPA for approval and publication in the Federal Register.
Thus, the Regional Air Quality Strategy (RAQS) and Air Quality Management Plan (AQMP)
prepared by SDAPCD and referenced herein become part of the SIP as the material relates to
efforts ongoing in San Diego County to achieve the national and state ambient air quality
standards. The most recent SIP element for San Diego County was submitted in December
2016. The document identifies control measures and associated emission reductions necessary
to demonstrate attainment of the 2008 Federal 8‐hour ozone standard by July 20, 2018.
The San Diego RAQS was developed pursuant to California Clean Air Act (CCAA)
requirements. The RAQS was initially adopted in 1991 and was updated in 1995, 1998, 2001,
2004, 2009 and 2016. The 2022 RAQS update is under development. Until it is adopted, the 2016
is applicable and can be found at the following:
https://www.sdapcd.org/content/dam/sdapcd/documents/grants/planning/2016%20RAQS%20(1
).pdf
The RAQS identifies feasible emission control measures to provide progress in San Diego
County toward attaining the State ozone standard. The pollutants addressed in the RAQS are
volatile organic compounds (VOC) (also referred to as Reactive Organic Gases (ROG)) and
oxides of nitrogen (NOx), precursors to the photochemical formation of ozone (the primary
component of smog). The RAQS was initially adopted by the SDAPCD on June 30, 1992, and
amended on March 2, 1993, in response to ARB comments. At present, no attainment plan for
particulate matter less than 10 microns in diameter (PM10) or particulate matter less than 2.5
microns in diameter (PM2.5) is required by the state regulations; however, SDAPCD has adopted
measures to reduce particulate matter in the SDAB. These measures range from regulation
against open burning to incentive programs that introduce cleaner technology. These measures
can be found in a report titled “Measures to Reduce Particulate Matter in San Diego County,
December 2005: https://www.sdapcd.org/content/dam/sdapcd/documents/grants/planning/PM‐
Measures.pdf
The RAQS relies on information from CARB and SANDAG, including mobile and area source
emissions, as well as information regarding projected growth in the County, to estimate future
emissions and then determine strategies necessary for the reduction of emissions through
regulatory controls. CARB mobile source emission projections and SANDAG growth
projections are based on population and vehicle trends as well as land use plans developed by
the cities and the County as part of the development of the individual General Plans. As such,
projects that propose development consistent with the growth anticipated by the general plans
would be consistent with the RAQS. In the event that a project would propose development
which is less dense than anticipated within the General Plan, the project would likewise be
consistent with the RAQS. If a project proposes development that is greater than that
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anticipated in the General Plan and SANDAG’s growth projections, the project might conflict
with the RAQS and SIP; and thus, have a potentially significant impact on air quality.
Under state law, the SDAPCD is required to prepare an AQMP for pollutants for which the
SDAB is designated non‐attainment. Each iteration of the SDAPCD’s AQMP is an update of the
previous plan and has a 20‐year horizon. Currently the SDAPCD has implemented the 2020
Plan for Attaining the National Ambient Air Quality Standard for Ozone in San Diego County
(October 2020) and a 2004 Carbon Monoxide Plan. The 2020 ozone plan was submitted to
CARB on October 20, 2020. It was adopted and submitted to the USEPA for review on
December 28, 2020. Comments from the USEPA are pending. This plans is available for
download on the ARB website located at the following URL:
https://www.sdapcd.org/content/dam/sdapcd/documents/grants/planning/Att%20A%20(Attain
ment%20Plan)_ws.pdf
SDAPCD Rules and Regulations
As stated above, SDAPCD is responsible for planning, implementing, and enforcing federal and
state ambient standards in the SDAB. The following rules and regulations apply to all sources in
the jurisdiction of SDAPCD, and would apply to the project.
SDAPCD Regulation IV: Prohibitions; Rule 50: Visible Emissions. Prohibits discharge into
the atmosphere from any single source of emissions whatsoever any air contaminant for a
period or periods aggregating more than 3 minutes in any period of 60 consecutive minutes that
is darker in shade than that designated as Number 1 on the Ringelmann Chart, as published by
the United States Bureau of Mines, or of such opacity as to obscure an observer’s view to a
degree greater than does smoke of a shade designated as Number 1 on the Ringelmann Chart
(SDAPCD 1997).
SDAPCD Regulation IV: Prohibitions; Rule 51: Nuisance. Prohibits the discharge, from any
source, of such quantities of air contaminants or other materials that cause or have a tendency to
cause injury, detriment, nuisance, annoyance to people and/or the public, or damage to any
business or property (SDAPCD 1976).
SDAPCD Regulation IV: Prohibitions; Rule 55: Fugitive Dust. Regulates fugitive dust
emissions from any commercial construction or demolition activity capable of generating
fugitive dust emissions, including active operations, open storage piles, and inactive disturbed
areas, as well as track‐out and carry‐out onto paved roads beyond a project site (SDAPCD
2009b).
SDAPCD Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. Requires
manufacturers, distributors, and end users of architectural and industrial maintenance coatings
to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC
content of various coating categories (SDAPCD 2015).
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SDAPCD Regulation XII: Toxic Air Contaminates; Rule 1200: Toxic Air Contaminants – New
Source Review. Requires new or modified stationary source units with the potential to emit
Toxic Air Contaminatnts (TACs) above rule threshold levels to either demonstrate that they will
not increase the maximum incremental cancer risk above 1 in 1 million at every receptor
location, or demonstrate that toxics best available control technology (T‐BACT) will be
employed if maximum incremental cancer risk is equal to or less than 10 in 1 million, or
demonstrate compliance with SDAPCD’s protocol for those sources with an increase in
maximum incremental cancer risk at any receptor location of greater than 10 in 1 million but
less than 100 in 1 million (SDAPCD 2017b).
SDAPCD Regulation XII: Toxic Air Contaminates; Rule 1210: Toxic Air Contaminant Public
Health Risks – Public Notification and Risk Reduction. Requires each stationary source that is
required to prepare a public risk assessment to provide written public notice of risks at or above
the following levels: maximum incremental cancer risks equal to or greater than 10 in 1 million,
or cancer burden equal to or greater than 1.0, or total acute noncancer health hazard index equal
to or greater than 1.0, or total chronic non‐cancer health hazard index equal to or greater than
1.0 (SDAPCD 2017c).
Regional Climate and Local Air Quality
The weather of San Diego County is influenced by the Pacific Ocean and its semi‐permanent
high‐pressure systems that result in dry, warm summers and mild, occasionally wet winters.
The average minimum temperature for January ranges from the mid‐40s to the high‐50s degrees
Fahrenheit (4 to 15 degrees Celsius) across the county. July maximum temperatures average in
the mid‐80s to the high‐90s degrees Fahrenheit (high‐20s to the high‐30s degrees Celsius). Most
of the county’s precipitation falls from November to April, with infrequent (approximately 10
percent) precipitation during the summer. The average seasonal precipitation along the coast is
approximately 10 inches (254 millimeters); the amount increases with elevations as moist air is
lifted over the mountains.
The interaction of ocean, land, and the Pacific High‐Pressure Zone maintains clear skies for
much of the year and drives the prevailing winds. Local terrain is often the dominant factor
inland and winds in inland mountainous areas tend to blow upwards in the valleys during the
day and down the hills and valleys at night.
In conjunction with the onshore/offshore wind patterns, there are two types of temperature
inversions (reversals of the normal decrease of temperature with height), which occur within
the region that affect atmospheric dispersive capability and that act to degrade local air quality.
In the summer, an inversion at about 1,100 to 2,500 feet (335 to 765 meters) is formed over the
entire coastal plain when the warm air mass over land is undercut by a shallow layer of cool
marine air flowing onshore. The prevailing sunny days in this region further exacerbate the
smog problem by inducing additional adverse photochemical reactions. During the winter, a
nightly shallow inversion layer (usually at about 800 feet or 243 meters) forms between the
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cooled air at the ground and the warmer air above, which can trap vehicular pollutants. The
days of highest Carbon Monoxide (CO) concentrations occur during the winter months.
The predominant onshore/offshore wind pattern is sometimes interrupted by so‐called Santa
Ana conditions, when high pressure over the Nevada‐Utah region overcomes the prevailing
westerly wind direction. This draws strong, steady, hot, and dry winds from the east over the
mountains and out to sea. Strong Santa Ana winds tend to blow pollutants out over the ocean,
producing clear days. However, at the onset or breakdown of these conditions or if the Santa
Ana is weak, prevailing northwesterly winds are reestablished which send polluted air from the
Los Angeles basin ashore in the SDAB. “Smog transport from the South Coast Air Basin (the
metropolitan areas of Los Angeles, Orange, San Bernardino, and Riverside counties) is a key
factor on more than half the days San Diego exceeds clean air standards” (San Diego Air
Pollution Control District, 2010).
Pollutants
The SDAPCD is required to monitor air pollutant levels to ensure that air quality standards are
met and, if they are not met, to develop strategies to meet the standards. Depending on whether
the standards are met or exceeded, the local air basin is classified as being in “attainment” or
“non‐attainment.” San Diego County is listed as a federal non‐attainment area for ozone (eight
hour) and a state non‐attainment area for ozone (one hour and eight‐hour standards), PM10 and
PM2.5. As shown in Table 2, the SDAB is in attainment for the state and federal standards for
nitrogen dioxide, carbon monoxide, sulfur dioxide and lead. Characteristics of ozone, carbon
monoxide, nitrogen dioxide, and suspended particulates are described below.
Ozone. Ozone is produced by a photochemical reaction (triggered by sunlight) between
nitrogen oxides (NOX) ROG1. Nitrogen oxides are formed during the combustion of fuels, while
reactive organic compounds are formed during combustion and evaporation of organic
solvents. Because ozone requires sunlight to form, it mostly occurs in concentrations considered
serious between the months of April and October. Ozone is a pungent, colorless, toxic gas with
direct health effects on humans including respiratory and eye irritation and possible changes in
lung functions. Groups most sensitive to ozone include children, the elderly, people with
respiratory disorders, and people who exercise strenuously outdoors.
Carbon Monoxide. Carbon monoxide (CO) is a local pollutant that is found in high
concentrations only near the source. The major source of carbon monoxide, a colorless, odorless,
poisonous gas, is automobile exhaust. Elevated CO concentrations; therefore, are usually only
found near areas of high traffic volumes operating in congested conditions. Carbon monoxide
health effects are related to blood hemoglobin. At high concentrations, carbon monoxide
1 Organic compound precursors of ozone are routinely described by a number of variations of three terms: hydrocarbons (HC),
organic gases (OG), and organic compounds (OC). These terms are often modified by adjectives such as total, reactive, or volatile,
and result in a rather confusing array of acronyms: HC, THC (total hydrocarbons), RHC (reactive hydrocarbons), TOG (total organic
gases), ROG (reactive organic gases), TOC (total organic compounds), ROC (reactive organic compounds), and VOC (volatile
organic compounds). While most of these differ in some significant way from a chemical perspective, from an air quality perspective
two groups are important: non-photochemically reactive in the lower atmosphere, or photochemically reactive in the lower
atmosphere (HC, RHC, ROG, ROC, and VOC).
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reduces the amount of oxygen in the blood, causing heart difficulties in people with chronic
diseases, reduced lung capacity and impaired mental abilities.
Nitrogen Dioxide. Nitrogen dioxide (NO2) is a by‐product of fuel combustion, with the primary
source being motor vehicles and industrial boilers and furnaces. The principal form of nitrogen
oxide produced by combustion is nitric oxide (NO), but NO reacts rapidly to form NO2, creating
the mixture of NO and NO2 commonly called NOX. Nitrogen dioxide is an acute irritant. A
relationship between NO2 and chronic pulmonary fibrosis may exist and an increase in
bronchitis in young children at concentrations below 0.3 parts per million (ppm) may occur.
Nitrogen dioxide absorbs blue light and causes a reddish‐brown cast to the atmosphere and
reduced visibility. It can also contribute to the formation of PM10 and acid rain.
Table 2 San Diego County Attainment Status
Criteria Pollutant Federal Designation State Designation
Ozone (one hour) Attainment* Non-Attainment
Ozone (eight hour) Moderate Non-Attainment Non-Attainment
Carbon Monoxide Attainment Attainment
PM10 Unclassifiable** Non-Attainment
PM2.5 Attainment Non-Attainment
Nitrogen Dioxide Attainment Attainment
Sulfur Dioxide Attainment Attainment
Lead Attainment Attainment
Sulfates No Federal Standard Attainment
Hydrogen Sulfide No Federal Standard Unclassified
Visibility No Federal Standard Unclassified
* The federal 1-hour standard of 12 ppm was in effect from 1979 through June 1, 2005. The revoked standard is referenced
here because it was used for such a long period and because this benchmark is addressed in State Implementation Plans
(SIPs).
** At the time of designation, if the available data does not support a designation of attainment or non-attainment, the area is
designated as unclassifiable.
Source: San Diego Air Pollution Control District. June 2016. http://www.sandiegocounty.gov/content/sdc/apcd/en/air-quality-
planning/attainment-status.html
Suspended Particulates. PM10 is particulate matter measuring no more than 10 microns in
diameter, while PM2.5 is fine particulate matter measuring no more than 2.5 microns in
diameter. Suspended particulates are mostly dust particles, nitrates and sulfates. Both PM10 and
PM2.5 are by‐products of fuel combustion and wind erosion of soil and unpaved roads and are
directly emitted into the atmosphere through these processes. Suspended particulates are also
created in the atmosphere through chemical reactions. The characteristics, sources, and
potential health effects associated with the small particulates (those between 2.5 and 10 microns
in diameter) and fine particulates (PM2.5) can be very different. The small particulates generally
come from windblown dust and dust kicked up from mobile sources. The fine particulates are
generally associated with combustion processes as well as being formed in the atmosphere as a
secondary pollutant through chemical reactions. Fine particulate matter is more likely to
penetrate deeply into the lungs and poses a health threat to all groups, but particularly to the
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elderly, children, and those with respiratory problems. More than half of the small and fine
particulate matter that is inhaled into the lungs remains there. These materials can damage
health by interfering with the body’s mechanisms for clearing the respiratory tract or by acting
as carriers of an absorbed toxic substance.
Lead. Lead in the atmosphere occurs as particulate matter. Sources of lead include leaded
gasoline; the manufacturing of batteries, paints, ink, ceramics, and ammunition; and secondary
lead smelters. Prior to 1978, mobile emissions were the primary source of atmospheric lead.
Between 1978 and 1987, the phaseout of leaded gasoline reduced the overall inventory of
airborne lead by nearly 95%. With the phaseout of leaded gasoline, secondary lead smelters,
battery recycling, and manufacturing facilities are becoming lead‐emissions sources of
greater concern. Prolonged exposure to atmospheric lead poses a serious threat to human
health. Health effects associated with exposure to lead include gastrointestinal disturbances,
anemia, kidney disease, and, in severe cases, neuromuscular and neurological dysfunction. Of
particular concern are low‐level lead exposures during infancy and childhood. Such exposures
are associated with decrements in neurobehavioral performance, including intelligence quotient
performance, psychomotor performance, reaction time, and growth. Children are highly
susceptible to the effects of lead.
Sulfates. Sulfates are the fully oxidized form of sulfur, which typically occur in combination
with metals or hydrogen ions. Sulfates are produced from reactions of SO2 in the atmosphere.
Sulfates can result in respiratory impairment, as well as reduced visibility.
Vinyl Chloride. Vinyl chloride is a colorless gas with a mild, sweet odor, which has been
detected near landfills, sewage plants, and hazardous waste sites, due to the microbial
breakdown of chlorinated solvents. Short‐term exposure to high levels of vinyl chloride in air
can cause nervous system effects, such as dizziness, drowsiness, and headaches. Long‐term
exposure through inhalation can cause liver damage, including liver cancer.
Hydrogen Sulfide. Hydrogen sulfide is a colorless and flammable gas that has a characteristic
odor of rotten eggs. Sources of hydrogen sulfide include geothermal power plants, petroleum
refineries, sewers, and sewage treatment plants. Exposure to hydrogen sulfide can result in
nuisance odors, as well as headaches and breathing difficulties at higher concentrations.
Visibility‐Reducing Particles. Visibility‐reducing particles are any particles in the air that
obstruct the range of visibility. Effects of reduced visibility can include obscuring the viewshed
of natural scenery, reducing airport safety, and discouraging tourism. Sources of visibility‐
reducing particles are the same as for PM2.5 described above.
Toxic Air Contaminants/Diesel Particulate Matter. Hazardous air pollutants, also known as
TACs or air toxics, are those pollutants that are known or suspected to cause cancer or other
serious health effects, such as reproductive effects or birth defects, or adverse environmental
effects. Examples of toxic air pollutants include:
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1. benzene, which is found in gasoline;
2. perchloroethylene, which is emitted from some dry‐cleaning facilities; and
3. methylene chloride, which is used as a solvent.
Transportation related emissions are focused on particulate matter constituents within diesel
exhaust and TAC constituents that comprise a portion of total organic gas (TOG) emissions
from both diesel and gasoline fueled vehicles. Diesel engine emissions are comprised of exhaust
particulate matter and TOGs which are collectively defined as Diesel Particulate Matter (DPM).
DPM and TOG emissions from both diesel and gasoline fueled vehicles is typically composed of
carbon particles and carcinogenic substances including polycyclic aromatic (i.e., odorous)
hydrocarbons, benzene, formaldehyde, acetaldehyde, acrolein, and 1,3‐butadiene. Diesel
exhaust also contains gaseous pollutants, including volatile organic compounds and NOx.
Sensitive Receptors
Land uses considered to be sensitive receptors include residential, school, childcare centers,
acute care hospitals, and long‐term health care facilities. Sensitive receptors are determined
based upon special factors which may include the age of the users or occupants, the frequency
and duration of the use or occupancy, continued exposure to hazardous substances as defined
by federal and state regulations, and the user’s ability to evacuate a specific site in the event of a
hazardous incident. Ambient air quality standards have been established to represent the levels
of air quality considered sufficient, with an adequate margin of safety, to protect public health
and welfare. They are designed to protect that segment of the public most susceptible to
respiratory distress, such as children; the elderly; persons engaged in strenuous work or
exercise and people with cardiovascular and chronic respiratory diseases. Recreational uses can
be considered moderately sensitive to air pollution. Exercise can place a high demand on
respiratory functions, which can be impaired by air pollution even though exposure periods
during exercise are generally short. Residential uses are considered most sensitive to air
pollution while Industrial and commercial areas are considered the least sensitive to air
pollution. Exposure periods are relatively short and intermittent, as the majority of the workers
tend to stay indoors most of the time. The Project is surrounded on all sides by single‐ and
multi‐family apartments/condominums.
Monitored Air Quality
The SDAPCD monitors air quality conditions at locations throughout the SDAB. For this
analysis, data from the Camp Pendleton monitoring station north of the site were used to
characterize existing ozone and PM2.5 conditions in the vicinity of the project site. A summary of
PM10 data recorded at the 533 First Street El Cajon monitoring station is presented in Table 3.
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Table 3
Measured Air Quality Data
Averaging Time Unit Agency/ Method
Ambient Air Quality Standard
Measured Concentration by Year Exceedances by Year
2020 2021 2022 2020 2021 2022
Ozone (O3) – Camp Pendleton
Maximum 1-hour concentration ppm State 0.09 0.094 0.074 0.076 0 0 0
Maximum 8-hour concentration ppm State 0.070 0.074 0.059 0.067 3 0 0
Federal 0.070 0.074 0.059 0.067 3 0 0
Nitrogen Dioxide (NO2) – Camp Pendleton
Maximum 1-hour concentration ppm State 0.18 53 59 50 0 0 0
Federal 0.100 53 59 50 0 0 0
Coarse Particulate Matter (PM10)a – El Cajon – Lexington Elementary School, 533 First Street
Maximum 24-hour concentration µg/m3
State 50 -- -- - - -
Federal 150 _ -- - - -
Annual concentration µg/m3 State 20 -- -- -- -- -- --
Fine Particulate Matter (PM2.5)a – El Cajon – Lexington Elementary School, 533 First Street
Maximum 24-hour concentration µg/m3 Federal 35 38.2 30.2 26.4 2 0 0
Annual concentration µg/m3
State 12.0 11.6 10.4 - 0 0 -
Federal 12.0 10.3 9.7 9.4 0 0 0
1 – Federal O3 standard reduced from 75 ppm to 70 ppm in October 2015 *Insufficient data to determine number of exceedances
Ozone and Nitrogen Oxide data from the Camp Pendleton Monitoring Station. PM10 and PM2.5 data from 533 First Street in El
Cajon.
Source: California Air Resources Board, 2020, 2021 and 2022 Air Quality Data Summaries available at:
http://www.arb.ca.gov/adam/topfour/topfourdisplay.php Accessed May 1, 2024.
AIR QUALITY IMPACT ANALYSIS
Methodology and Significance Thresholds
Air quality modeling was performed in general accordance with the methodologies outlined in
the SDAPCD 2016 RAQS to identify both construction and operational emissions associated
with each phase and the cumulative total of all project phases at build out. All emissions were
calculated using the California Emissions Estimator Model (CalEEMod) software version 2022.1
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which incorporates current air emission data, planning methods and protocol approved by
CARB.
Construction activities would include removal of the existing residences and out buildings, site
clearing and grading to install the buildng foundation and utility connections; construction of
the new buildings and related improvements as well as painting the interior and exterior
building surfaces and minor pavement work for the entrance/exit. Construction activities would
require the use of equipment that would generate criteria air pollutant emissions. For modeling
purposes, it was assumed that all construction equipment used would be diesel‐powered.
Construction emissions associated with development of the proposed project were quantified
by estimating the types of equipment, including the number of individual pieces of equipment,
that would be used on‐site during each of the construction phases as well as off‐site haul trips to
remove demolition debris. Construction emissions are analyzed using the regional thresholds
established by the SDAPCD and published under Rule 20‐2. No soil import/export would be
required.
Operational emissions include mobile source emissions, energy emissions, and area source
emissions. Mobile source emissions are generated by motor vehicle trips associated with
operation of the project. Emissions attributed to energy use include electricity and natural gas
consumption for space and water heating. Area source emissions are generated by landscape
maintenance equipment, consumer products and architectural coatings (i.e., paints). To
determine whether a regional air quality impact would occur, the increase in emissions are
compared with the SDAPCD recommended regional thresholds for operational emissions.
Regional Thresholds. Based on Appendix G of the CEQA Guidelines (2022), a project would have
a significant air quality impact if it would:
a. Conflict with or obstruct implementation of the applicable air quality plan;
b. Result in a cumulatively considerable net increase of any criteria pollutant for which the
project region is in non‐attainment under an applicable federal or state ambient air
quality standard;
c. Expose sensitive receptors to substantial pollutant concentrations;
d. Result in other emissions (such as those leading to odors) adversely affecting a substantial
number of people.
Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.) indicates that, where available, the
significance criteria established by the applicable air quality management district or pollution
control district may be relied upon to determine whether the project would have a significant
impact on air quality. As part of its air quality permitting process, SDAPCD has established
thresholds in Rule 20.2 requiring the preparation of Air Quality Impact Assessments for
permitted stationary sources. SDAPCD establishes quantitative emission thresholds for
stationary sources. Although these trigger levels do not generally apply to mobile sources or
general land development projects, for comparative purposes these levels may be used to
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evaluate the increased emissions that would be emitted into the SDAB from proposed land
development projects. Project‐related air quality impacts estimated in this environmental
analysis would be considered significant if any of the applicable significance thresholds
presented below in Table 4 are exceeded.
The thresholds listed in Table 4 are screening‐level thresholds used to evaluate whether
proposed‐project‐related emissions could cause a significant impact to air quality. Emissions
below the screening‐level thresholds would not cause a significant impact. The emissions‐based
thresholds for ozone precursors (ROG and NOx) are intended to serve as the threshold for
ozone. This approach is used because ozone is not emitted directly; thus, ozone concentrations
Table 4
SDAPCD Air Emission Significance Thresholds
Construction Emissions
Pollutant Total Emissions (pounds per day)
Reactive Organic Gas (ROG) 75
Nitrogen Oxides (NOx) 250
Carbon Monoxide (CO) 550
Sulfur Oxides (SOx) 250
Respirable Particulate Matter (PM10) 100
Fine Particulate Matter (PM2.5) 55
Operational Emissions
Total Emissions
Pounds per Hour Pounds per Day Tons per Year
Reactive Organic Gas (ROG) -- 75 13.7
Nitrogen Oxides (NOx) 25 250 40
Carbon Monoxide (CO) 100 550 100
Sulfur Oxides (SOx) 25 250 40
Respirable Particulate Matter (PM10) -- 100 15
Fine Particulate Matter (PM2.5) -- 55 10
Lead and Lead Compounds -- 3.2 0.6
associated with individual projects precursor (ROG and NOx) emissions cannot be determined
through air quality models or other quantitative methods. For nonattainment pollutants, if
emissions exceed the thresholds shown in Table 4, the project has the potential to result in a
cumulatively considerable net increase in these pollutants; and thus, could have a significant
impact on the ambient air quality.
With respect to odors, SDAPCD Rule 51 (Public Nuisance) prohibits emission of any material
that causes nuisance to a considerable number of persons or endangers the comfort, health, or
safety of any person. A project that involves a use that would produce objectionable odors
would be deemed to have a significant odor impact if it would affect a considerable number of
off‐site receptors.
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a. Would the project conflict with or obstruct implementation of the applicable air
quality plan?
As stated, under state law, the SDAPCD is required to prepare an AQMP for pollutants for
which the SDAB is designated non‐attainment. Each iteration of the SDAPCD’s AQMP is an
update of the previous plan and has a 20‐year horizon. A project may be deemed inconsistent
with the AQMP if it would generate population, housing, or employment growth exceeding
forecasts used in the development of the AQMP. Currently the SDAPCD has implemented the
2020 Plan for Attaining the National Ambient Air Quality Standard for Ozone in San Diego County
(October 2020) and a 2004 Carbon Monoxide Plan. The AQMP incorporates local city General
Plans and the San Diego Association of Governments socioeconomic forecast projections of
regional population, housing and employment growth.
The proposed project involves the construction of 12 new two‐story multifamily townhome
units. The site is approximately 0.34 acres in size with General Plan designation of R‐23 and a
zoning designation of R‐3. The intent of the R‐3 zoning designation is to accommodate high
density residential at a density not to exceed that allowed by the General Plan (i.e., 23 units per
acre).
According to the 2021‐2029 Regional Housing Needs Assessment (RHNA) 6th cycle, the City of
Carlsbad will need to accommodate a total of 3,873 units at varying income levels (City of
Carlsbad, April 2022). Of the total, 1,778 units are allocated to the moderate and above
moderate‐income categories. The project would provide 12 units or just over one percent of
Carlsbad’s housing allocation within the 2021‐2029 RHNA.
The San Diego APCD and San Diego Association of Governments are responsible for
developing and implementing the clean air plans for attainment and maintenance of the
ambient air quality standards in the basin, specifically, the SIP and RAQS. The federal O3
maintenance plan, which is part of the SIP, was adopted in 2012. The most recent O3 attainment
plan was adopted in 2020. The SIP includes a demonstration that current strategies and tactics
will maintain acceptable air quality in the basin based on the NAAQS. The RAQS was initially
adopted in 1991 and is updated on a triennial basis (most recently in 2016). The RAQS outlines
SDAPCD’s plans and control measures designed to attain the state air quality standards for O3.
The SIP and RAQS rely on information from CARB and SANDAG, including mobile and area
source emissions as well as information regarding projected growth in the County and the cities
in the County, to project future emissions and determine the strategies necessary for the
reduction of emissions through regulatory controls.
CARB mobile source emission projections and SANDAG growth projections are based on
population, vehicle trends and land use plans developed by the County and the cities in the
County as part of the General Plan development process. If a project proposes development that
is greater than that anticipated in the local plan and SANDAG’s growth projections, the project
might be in conflict with the SIP and RAQS and may contribute to a potentially significant
cumulative impact on air quality.
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As stated, the R‐3 zoning designation is intended to support multifamily uses. Thus, the project
is consistent with City’s General Plan the land use designation/zoning; and therefore, has been
factored into SANDAG’s growth projections. Furthermore, the estimated increase in
population, employment and housing generated by the project was compared to SANDAG’s
Regional Plan population, employee population, and housing estimates including the years
2025 and 2035. The number of housing units in the City was projected to be 49,299 in 2025 and
51,552 in 2035, or an increase in 2,253 housing units over the 10‐year period. Furthermore, the
City’s population was projected to be 118,068 residents in 2025 and 118,719 residents in 2035, or
increase of 651 residents over the period as shown in the SANDAG Series 14 Regional Forecast
and Baseline Subregional Allocation. The average household size is 2.82 people per dwelling unit.
The project would construct 12 dwelling units, which would have the potential to house
approximately 33 residents. Both the units and population are within the growth projections.
The employee population in the City was projected to be 88,373 in 2025 and 98,168 in 2035, or
increase of 9,795 employees over the period. Because the project is consistent with the General
Plan; and thus, SANDAG’s growth projections, project emissions would not conflict with the
SIP and RAQS. The project would not conflict with or obstruct implementation of the AQMP.
Impacts would be less than significant.
b. Would the project result in a cumulatively considerable net increase of any criteria
pollutant for which the project region is in non‐attainment under an applicable federal
or state ambient air quality standard?
Construction Emissions
Project construction would generate temporary air pollutant emissions. These impacts are
associated with fugitive dust (PM10 and PM2.5) and exhaust emissions from heavy construction
vehicles, work crew vehicle trips in addition to ROG that would be released during the drying
phase upon application of paint and other architectural coatings. Construction would generally
consist of demolition (i.e., removal of the temporary buildings), site preparation
(clearing/grubbing), excavation/grading, construction of the proposed buildings, architectural
coating (i.e., paint) application and paving.
Emissions from the construction phase of the project were estimated using CalEEMod 2022.1.
Construction scenario assumptions, including phasing, equipment mix, and vehicle trips, were
based on information provided by the project applicant and CalEEMod default values when
project specifics were not known.
For purposes of estimating project emissions, it is assumed that construction of the project
would occur five days per week and commence in mid‐2025 and would be complete in early
2026. The schedule is an estimate calculated by CalEEMod 2022.1. The duration of phases are
approximated:
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• Demolition: 2 weeks
• Site Prepartion: 1 week
Grading: 1 week
• Building Construction: 20 weeks
• Paving: 1 weeks
• Architectural Coating: 1 weeks
Construction‐worker and vendor trips estimates by construction phase were based on
CalEEMod default data. Mass grading would include the entire project site. Approximately 5
total trips would be required to remove demolition material. No fill import is anticipated
during the site preparation or grading phases. CalEEMod default trip length values were used
for the distances for all construction‐related trips. Defaults for the construction equipment mix
and vehicle trips used for estimating the project‐generated construction emissions were used
and are provided in Appendix A.
As discussed, the project would implement dust control strategies as a project design feature.
To reflect implementation of proposed dust control strategies, the following was used in
CalEEMod:
Water exposed area two times per day (55% reduction in PM10 and PM2.5); and
Limit equipoment idling to 5 minutes.
Daily construction emissions are shown in Table 5.
Table 5 Estimated Maximum Daily Construction Emissions with Dust Control Measures
Construction Phase
Maximum Emissions (lbs/day)
ROG NOx CO SOx PM10 PM2.5
2025 Maximum lbs/day 14.5 10.1 10.4 0.02 2.3 1.4
SDAPCD Regional
Thresholds 75 250 550 250 100 55
Threshold Exceeded 2022 No No No No No No
As shown in Table 5, construction of the proposed project would not exceed the SDAPCD daily
thresholds. With SDAPCD Rule 55 compliance, federal, state and local construction emission
thresholds would be met. Construction emissions would not result in a cumulatively
considerable net increase of any criteria pollutant for which the project region is in non‐
attainment under an applicable federal or state ambient air quality standard. Impacts will be
less than significant.
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Operational Impacts
Emissions from the operational phase of the project were estimated using CalEEMod version
2022.1. Operational year 2025 was assumed consistent with completion of project construction.
Area Sources. CalEEMod was used to estimate operational emissions from area sources,
including emissions from consumer product use, architectural coatings, and landscape
maintenance equipment. Emissions associated with space heating and water heating are
calculated in the building energy use module of CalEEMod.
Consumer products are chemically formulated products used by household and institutional
consumers, including detergents; cleaning compounds; polishes; floor finishes; cosmetics;
personal care products; home, lawn, and garden products; disinfectants; sanitizers; aerosol
paints; and automotive specialty products. Other paint products, furniture coatings, or
architectural coatings are not considered consumer products. Consumer product VOC
emissions are estimated in CalEEMod based on the floor area of buildings and on the default
factor of pounds of VOC per building square foot per day. The CalEEMod default values for
consumer products were used.
VOC off‐gassing emissions result from evaporation of solvents contained in surface coatings
such as paints and primers used during building maintenance. CalEEMod calculates the VOC
evaporative emissions from application of surface coatings based on the VOC emission factor,
the building square footage, the assumed fraction of surface area, and the reapplication rate.
VOC emissions were estimated based on compliance with SDAPCD Rule 67.0.1 which limits the
VOC concentrations of various coatings sold and used in San Diego County. Rule 67.0.1, Table
1, lists numeous types of coatings and the allowable VOC concentrations in grams/litre
(g/L).The three general coating categories are 50 grams per liter (g/L) VOC for flat coatings, 100
g/L VOC for non‐flat coatings and 150 g/L VOC for non‐flat high gloss coatings. Consistent with
typical construction practices, it is anticipated that interior and exterior paint would not exceed
non‐flat coating limits, exterior paint would not exceed non‐flat coating limits and a small
portion of exterior paint and finishes (trim and other minor finishes) would not exceed non‐flat
high‐gloss coatings limits. The interior and exterior coatings were estimated to have 50 g/L VOC
while the traffic marking coatings were estimated to be limited to 100 g/L VOC. The default
values in CalEEMod 2022.1 rely on compliance with SDAPCD Rule 67.0.1 referenced above.
Energy Sources. Energy sources include emissions associated with building electricity and
natural gas use. Electricity use would contribute indirectly to criteria air pollutant emissions;
however, the emissions from electricity use are only quantified for GHGs in CalEEMod, since
criteria pollutant emissions occur at the site of the power plant, which is typically off site. The
Project will install Energy Star, or equivalent, dishwashers, clothes washers, refrigerators, and
fans; bicycle parking facilities and electric vehicle charging station.
Mobile Sources. CalEEMod default data, including trip characteristics, trip lengths, variable
start information and emissions factors were used for the model inputs. Project‐related traffic
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includes the mixture of vehicles consistent with CalEEMod default vehicle fleet assumptions.
Emission factors for 2026 (the first full year of project operation) were used to estimate
emissions associated with full buildout of the project. Trip data used are 7.3 daily trips per unit.
Based on proximity to transit, these data likely provide a conservative estimate of daily trips.
Table 6 summarizes area, energy and mobile source emissions associated with operation
of the proposed project. As shown in Table 6, daily emissions would not exceed the
SDAPCD thresholds for ROG, NOX, CO, SOX, PM10 or PM2.5. Therefore, the project’s air
quality emissions(including impacts related to criteria pollutants, sensitive receptors and
violations of air quality standards) would not result in a cumulatively considerable net
increase of any criteria pollutant for which the project region is in non‐attainment under
an applicable federal or state ambient air quality standard. Impacts will be less than
significant.
c. Would the project expose sensitive receptors to substantial pollutant concentrations?
Construction‐Related Toxic Air Contaminant Impacts
Certain construction projects can create the potential for toxic air contaminant emissions related
to diesel particulate emissions associated with heavy equipment operations during
construction. According to South Coast Air Quality Management District (SCAQMD)
methodology, health effects from carcinogenic air toxics are usually described in terms of
“individual cancer risk”. A cancer risk greater than 10 cases per 1,000,000 people exposed
Table 6 Estimated Operational Emissions
Estimated Emissions (lbs/day)
ROG NOX CO SOX PM10 PM2.5
Proposed Project
Maximum lbs/day - 2026 0.59 0.22 2.66 0.005 0.42 0.11
SDAPCD Thresholds 75 250 550 250 100 55
Threshold Exceeded? No No No No No No
Maximum lbs/hour -- 0.009 0.11 0.0002 -- --
SDACPD Thresholds -- -- --
Threshold Exceeded? No No No No No No
Maximum tons/year 0.1 0.04 0.48 0.0009 0.07 0.02
SDAPCD Thresholds 13.7 40 100 40 15 10
Threshold Exceeded? No No No No No No
See Appendix for CalEEMod version. 2022.1 computer model output - summer emissions shown
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would be considered a significant impact. The California Office of Environmental Health
Hazard Assessment (OEHHA) health risk guidance states that a residential receptor should be
evaluated based on a 30‐year exposure period. “Individual Cancer Risk” is the likelihood that a
person exposed to concentrations of toxic air contaminants over a 70‐year lifetime will contract
cancer, based on the use of standard risk‐assessment methodology. The estimated construction
schedule duration would be approximately 6‐7 months; however, only a portion of the overall
construction work would require the use of diesel‐powered equipment. The proposed project
would not result in a long‐term (i.e., 30 or 70 year) exposure to a substantial source of toxic air
contaminant emissions; and thus, neighboring residents would not be exposed to the related
individual cancer risk. Further, existing and planned land use within the project area is focused
on residential uses. Thus, existing and future residents would not be exposed to neighboring
development that generates TACs. Therefore, the project would not expose sensitive receptors
to substantial concentrations of TACs. Impacts would be less than signficant.
Carbon Monoxide Hotspots
As discussed, carbon monoxide is a colorless, odorless, poisonous gas that may be found in
high concentrations near areas of high traffic volumes. CO emissions are a function of vehicle
idling time, meteorological conditions, and traffic flow. The SDAB is in attainment of state and
federal CO standards; thus, CO data is no longer collected and not all monitoring stations have
CO data available. The East Valley monitoring station in Escondido is the closest monitoring
station to the site that collected CO data. The maximum 8‐hour average CO level recorded in
2015, was 2.0 parts per million (ppm). Concentrations at that time were below the 9‐ppm state
and federal 8‐hour standard.
Numerous factors are related to the formation of CO hotspots. The potential for CO hotspots in
the SDAB is steadily decreasing because of the continued improvement in vehicular emissions
at a rate faster than the rate of vehicle growth and/or congestion and the already very low
ambient CO concentrations. Furthermore, CO transport is extremely limited and disperses
rapidly with distance from the source. Under certain extreme meteorological conditions,
however, CO concentrations near a congested roadway or intersection may reach unhealthy
levels.
Typically, high CO concentrations are associated with roadways or intersections operating
under congested conditions. Projects contributing to adverse traffic conditions may contribute
to the formation of CO hotspots. Because the City of Carlsbad does not have CO hotspot
guidance, the guidance recommended by the County of San Diego was applied to evaluate the
potential for CO hotspots to occur as a result of the project. As indicated in the County of San
Diego Guidelines for Determining Significance and Report Format and Content Requirements
Air Quality (County of San Diego 2007), a site‐specific CO hotspot analysis should be
performed if a proposed development would cause road intersections to operate at or below a
LOS E with intersection peak‐hour trips exceeding 3,000.
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The proposed project screened out of preparation of a traffic study per the Vehicle Miles
Traveled (VMT) Analysis Guidelines (May 2023); thus, it is not expected to advsersly impact
traffic volumes or traffic operation proximal to the site or otherwise result in CO hot spots that
could expose sensitive receptors to substantial pollutant concentrations. Impacts would be less
than significant.
Indoor Air Quality
CARB has stated that the control measures it has approved for reducing indoor emissions
associated with the use of composite wood products, including formaldehyde, provides a level
of control that protects health and safety. The first emission standards (Phase 1) went into effect
in 2009 and more stringent Phase 2 standards are now in effect for all composite wood panels
and finished goods sold in California. CARB regulations include provisions for no‐added
formaldehyde and ultra‐low emitting formaldehyde‐based resins, to encourage the use of these
lower‐emitting resins in composite wood products. Further, the project would be constructed
using the most current ventilation requirements found in the Title 24 standards, including the
requirement that new developments use MERV 13 or higher air filters and include mandatory
compliance with the stringent CARB Phase 2 emission standards. Thus, the use of composite
wood project will have no adverse impact on indoor air quality.
d. Would the project result in other emissions (such as those leading to odors) adversely
affecting a substantial number of people?
The State of California Health and Safety Code, Division 26, Part 4, Chapter 3, Section 41700,
SDAPCD Rule 51, and City of Carlsbad Municipal Code Section 6.16.010, commonly referred to
as public nuisance law, prohibits emissions from any source whatsoever in such quantities of air
contaminants or other material that cause injury, detriment, nuisance, or annoyance to the
public health or damage to property. Projects required to obtain permits from SDAPCD are
evaluated by SDAPCD staff for potential odor nuisance, and conditions may be applied (or
control equipment required) where necessary to prevent occurrence of public nuisance.
SDAPCD Rule 51 also prohibits emission of any material that causes nuisance to a considerable
number of persons or endangers the comfort, health, or safety of any person. A project that
involves a use that would produce objectionable odors would be deemed to have a significant
odor impact if it would affect a considerable number of off‐site receptors. Odor issues are
subjective by the nature of odors themselves and due to the fact that their measurements are
difficult to quantify. As a result, this guideline is qualitative and will focus on the existing and
potential surrounding uses and location of sensitive receptors.
The occurrence and severity of potential odor impacts depends on numerous factors. The
nature, frequency, and intensity of the source; the wind speeds and direction; and the sensitivity
of receiving location each contribute to the intensity of the impact. Although offensive odors
seldom cause physical harm, they can be annoying and cause distress among the public and
generate citizen complaints. Odors would be potentially generated from vehicles and
equipment exhaust emissions during construction of the project. Potential odors produced
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during construction would be attributable to exhaust emissions, architectural coatings, and
asphalt pavement application. Such odors would disperse rapidly from the project site and
generally occur at magnitudes that would not affect substantial numbers of people. Therefore,
project construction activities would not result in other emissions (such as those leading to
odors) adversely affecting a substantial number of people. Impacts would be less than
significant.
Land uses that typically are associated with odor complaints include agricultural uses,
wastewater treatment plants, food processing plants, chemical plants, industrial activities,
composting, refineries, landfills, dairies, and fiberglass molding facilities. The project would
construct and operate 12 multifamily residential units and related infrastructure improvements.
The project would not include land uses that typically result in emissions (such as those leading
to odors) that adversely affect a substantial number of people; thus, impacts would be less than
significant.
GREENHOUSE GAS EMISSIONS ASSESSMENT
The purpose of this report is to demonstrate that the Project meets the conditions for a Class 32
categorical exemption for air quality. The following analysis provides GHG emissions from
construction and operational activities for informational purposes only.
Methodology
GHG emissions associated with construction and operation of the proposed project and existing
development have been estimated using California Emissions Estimator Model (CalEEMod)
version 2022.1.
Construction Emissions
Construction of the proposed project would generate temporary GHG emissions primarily
associated with the operation of construction equipment, worker trips and truck trips required
for hauling excavation spoils, materials and equipment. Site preparation and grading typically
generate the greatest emission quantities because the use of heavy equipment is greatest during
this phase of construction. Emissions associated with the construction period were estimated
based on the projected maximum amount of equipment that would be used on‐site at one time.
Air districts such as the SDAPCD have recommended amortizing construction‐related
emissions over a 30‐year period to calculate annual emissions. Complete CalEEMod results and
assumptions can be viewed in the Appendix.
Operational Emissions
Default values used in CalEEMod version 2022.1 are based on the CEC sponsored California
Commercial End Use Survey (CEUS) and Residential Appliance Saturation Survey (RASS) studies.
CalEEMod provides operational emissions of CO2, N2O and CH4. This methodology has been
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subjected to peer review by numerous public and private stakeholders, and in particular by the
CEC; and therefore, is considered reasonable and reliable for use in GHG impact analysis pursuant
to CEQA. It is also recommended by CAPCOA (January 2008).
Emissions associated with area sources (i.e., consumer products, landscape maintenance, and
architectural coating) were calculated in CalEEMod based on standard emission rates from CARB,
USEPA, and district supplied emission factor values (CalEEMod User Guide, 2022). Emissions
from waste generation were also calculated in CalEEMod and are based on the IPCC’s methods for
quantifying GHG emissions from solid waste using the degradable organic content of waste
(CalEEMod User Guide, April 2022). Waste disposal rates by land use and overall composition of
municipal solid waste in California was primarily based on data provided by the California
Department of Resources Recycling and Recovery (CalRecycle).
Emissions from water and wastewater usage calculated in CalEEMod were based on the default
electricity intensity from the CEC’s 2006 Refining Estimates of Water‐Related Energy Use in
California using the average values for Northern and Southern California. Emissions from mobile
sources were quantified based on trip generation rates in the Local Transportation Analysis (March
2022).
Construction Emissions. Construction activity analysis is based on the anticipated construction
period beginning in mid 2025 and ending late 2025. Based on CalEEMod results, construction
activity for the project would generate an estimated 75 metric tons of carbon dioxide equivalent
(CO2E) in 2025 as shown in Table 7. Amortized over a 30‐year period (the assumed life of the
project), construction of the proposed project would generate 3 metric tons of CO2E per year.
Table 7 Estimated Construction Related Greenhouse Gas Emissions
Year Annual Emissions (metric tons CO2E)
2025 75
Total 75
Amortized over 30 years 3
See Appendix for CalEEMod software program output
Operational Indirect and Stationary Direct Emissions. Operational emissions relate to energy use,
solid waste, water use, and transportation. Each source is discussed below and includes the
emissions associated with existing development and the anticipated emissions that would result
from the proposed project.
Energy Use. CalEEMod default values for electricity use and natural gas consumption for each
land use type were applied for the proposed land use designation. The energy use from
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residential and commercial land uses is calculated in CalEEMod based on the Commercial End‐
Use Survey. Energy use in buildings (both natural gas and electricity) is divided by CalEEMod
into end‐use categories subject to Title 24 requirements (end uses associated with the building
envelope, such as the HVAC system, water heating system, and integrated lighting) and those
not subject to Title 24 requirements (such as appliances, electronics, and miscellaneous“plug‐in”
uses).
Operational GHG emissions from energy sources include natural gas combustion for appliances
and space and water heating. The current Title 24, Part 6 standards, referred to as the 2022 Title
24 Building Energy Efficiency Standards, became effective on January 1, 2023. The current
version of CalEEMod calculates electricity and natural gas emissions based on consumption
estimates and Title 24 2019 Building Energy Efficiency Standards (CalEEMod Users Guide,
2022). CalEEMod default energy intensity factors (CO2, CH4, and N2O mass emissions per
kilowatt hour) for SDG&E were based on the value for SDG&E’s energy mix in 2021. As shown
in Table 8, the overall emissions associated with electrical energy use at the project site would
be approximately 11 metric tons of CO2E per year. An additional 5 MT CO2E would be
attributable to natural gas.
Table 8 Estimated Annual Energy-Related Greenhouse Gas Emissions
Emission Source Annual Emissions (CO2E)
Proposed Project
Electricity 11 metric tons
Natural Gas 5 metric tons
Total 16 metric tons
See Appendix for CalEEMod software program output.
Water Use Emissions. Based on the amount of electricity generated to supply and convey this
amount of water, as shown in Table 8, the project would generate approximately 1 metric ton of
CO2E per year. Emissions related to water consumption would be reduced by 20% per Senate
Bill X7‐7, by implementing measures that include the installation of low flow plumbing fixtures
(i.e., faucets, toilets, show heads) and water efficient irrigation systems.
Solid Waste Emissions. Implementation of a municipal recycling program that would achieve a
75% diversion rate statewide is required for residential uses per the California Integrated Waste
Management Act of 1989 (AB 939). The CalEEMod results indicate that the project would result
in approximately 1 metric ton of CO2E per year associated with solid waste disposed within
landfills provided 75% of solid waste is recycled (Table 9).
Transportation Emissions. Mobile source GHG emissions were estimated using the trip
generation rates provided in CalEEMod 2022.1 (i.e., Institute of Transportation Engineers, Trip
Generation Manual 11th Edition). Table 10 shows the estimated mobile emissions of GHGs for
the project based on the estimated annual VMT of 203,442 as estimated by CalEEMod 2022.1
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(see Appendix A) As shown in Table 10, the project would generate approximately 105 metric
tons of CO2E associated with new vehicle trips.
Table 9 Estimated Annual Solid Waste and Water Use Greenhouse Gas Emissions
Emission Source Annual Emissions (CO2E)
Water 1 metric tons
Solid Waste 1 metric tons
Total Water and Solid Waste 2 metric tons
See Appendix for CalEEMod software program output.
.
Table 10 Estimated Annual Mobile Emissions of Greenhouse Gases
Emission Source Annual Emissions (CO2E)
Proposed Project
Mobile Emissions (CO2 & CH4) 75 metric tons
Total 75 metric tons
See Appendix for CalEEMod software program output.
Combined Construction, Stationary and Mobile Source Emissions
Table 11 combines the net new construction, operational, and mobile GHG emissions associated
with the proposed project. As discussed above, temporary emissions associated with
construction activity (approximately 75 metric tons CO2E) are amortized over 30 years (the
anticipated life of the project).
Table 11 Combined Annual Greenhouse Gas Emissions
Emission Source Annual Emissions (CO2E)
Construction 3 metric tons
Operational Energy Solid Waste Water Area Source
16 metric tons 1 metric tons 1 metric tons 1 metic tons
Mobile 75 metric tons
Total 97 metric tons
See Appendix for CalEEMod software program output.
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For the proposed project, the combined annual emissions would total approximately 97 metric
tons per year of CO2E.
Conclusion
As stated herein, the project is new construction of 12 new multifamily units with 24 garage
parking spaces and related improvements. Each unit would be wired for EV charging.
Would the project conflict with or obstruct implementation of the applicable air
quality plan?
The project is consistent with the R‐3 zoning designation and is anticipated in the local
plans and SANDAG’s population and employment growth projections. Thus, the project
would be within SANDAG’s population growth forecast and would not conflict with the
SIP and RAQS.
Would the project result in a cumulatively considerable net increase of any criteria
pollutant for which the project region is in non‐attainment under an applicable
federal or state ambient air quality standard?
Project construction and operational emissions would not exceed the SDAPCD
thresholds. Thus, the project would not result in a cumulatively considerable net
increase of any criteria pollutant for which the project region is in non‐attainment under
an applicable federal or state ambient air quality standard.
Would the project expose sensitive receptors to substantial pollutant concentrations?
The project would not cause or contribute to CO hot spots or otherwise expose receptors
to substantial pollutant concentrations during construction or operations.
Would the project result in other emissions (such as those leading to odors) adversely
affecting a substantial number of people?
The project would provide 12 residential units, associated garage parking and related
infrastructure improvements. These uses would not result in other emissions (such as
those leading to odors) adversely affecting a substantial number of people.
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2014.
Office of the California Attorney General. The California Environmental Quality Act, Addressing
Global Warming Impacts at the Local Agency Level. Updated May 21, 2008.
http://ag.ca.gov/globalwarming/pdf/GW_mitigation_measures.pdf
United States Environmental Protection Agency (U.S. EPA). Inventory of U.S. Greenhouse Gas
Emissions and Sinks: 1990‐2010. U. S. EPA #430‐R‐11‐005. April 2012.
http://www.epa.gov/climatechange/emissions/usinventoryreport.html
United States Environmental Protection Agency (U.S. EPA). Inventory of U.S. Greenhouse Gas
Emissions and Sinks: 1990‐2015. U. S. EPA #430‐P‐17‐001. April 2017.
https://www.epa.gov/ghgemissions/inventory‐us‐greenhouse‐gas‐emissions‐and‐sinks‐
1990‐2015
United States Environmental Protection Agency (U.S. EPA). Inventory of U.S. Greenhouse Gas
Emissions and Sinks: 1990‐2019, U. S. EPA #430‐R‐21‐001. February 2021
Oct.. 15, 2025 Item #1 137 of 343
Appendix A
CalEEMod Air Quality and Greenhouse Gas Emissions Model Results –
Summer/Annual
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2647 Jefferson Street Detailed 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
2.3. Construction Emissions by Year, Mitigated
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
2.6. Operations Emissions by Sector, Mitigated
3. Construction Emissions Details
3.1. Demolition (2025) - Unmitigated
3.2. Demolition (2025) - Mitigated
3.3. Site Preparation (2025) - Unmitigated
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3.4. Site Preparation (2025) - Mitigated
3.5. Grading (2025) - Unmitigated
3.6. Grading (2025) - Mitigated
3.7. Building Construction (2025) - Unmitigated
3.8. Building Construction (2025) - Mitigated
3.9. Paving (2025) - Unmitigated
3.10. Paving (2025) - Mitigated
3.11. Architectural Coating (2025) - Unmitigated
3.12. Architectural Coating (2025) - Mitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.1.2. Mitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.2. Electricity Emissions By Land Use - Mitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
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4.3. Area Emissions by Source
4.3.1. Unmitigated
4.3.2. Mitigated
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
4.4.2. Mitigated
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
4.5.2. Mitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.6.2. Mitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.7.2. Mitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
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4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.9.2. Mitigated
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
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated
4.10.6. Avoided and Sequestered Emissions by Species - Mitigated
5. Activity Data
5.1. Construction Schedule
5.2. Off-Road Equipment
5.2.1. Unmitigated
5.2.2. Mitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
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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
5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.9.2. Mitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.1.2. Mitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
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5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.11.2. Mitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.12.2. Mitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.13.2. Mitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.14.2. Mitigated
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
5.15.2. Mitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
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5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1.2. Mitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.1.2. Mitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
5.18.2.2. Mitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
6.2. Initial Climate Risk Scores
6.3. Adjusted Climate Risk Scores
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
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7.2. Healthy Places Index Scores
7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
8. User Changes to Default Data
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name 2647 Jefferson Street
Construction Start Date 4/1/2025
Operational Year 2026
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s)1.90
Precipitation (days)21.8
Location 33.1662158269893, -117.34871666632597
County San Diego
City Carlsbad
Air District San Diego County APCD
Air Basin San Diego
TAZ 6228
EDFZ 12
Electric Utility San Diego Gas & Electric
Gas Utility San Diego Gas & Electric
App Version 2022.1.1.26
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
12.0 Dwelling Unit 0.32 11,520 1,000 —33.0 —
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1.3. User-Selected Emission Reduction Measures by Emissions Sector
Sector #Measure Title
Construction C-2*Limit Heavy-Duty Diesel Vehicle Idling
Water W-7 Adopt a Water Conservation Strategy
Waste S-1/S-2 Implement Waste Reduction Plan
* Qualitative or supporting measure. Emission reductions not included in the mitigated emissions results.
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.ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 14.6 10.1 10.4 0.02 0.46 2.14 2.60 0.43 1.02 1.44 — 1,785 1,785 0.07 0.07 1.17 1,792
Mit. 14.6 10.1 10.4 0.02 0.46 2.14 2.60 0.43 1.02 1.44 — 1,785 1,785 0.07 0.07 1.17 1,792
%
Reduced
— — — — — — — — — — — — — — — — —
Average
Daily
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 0.38 1.70 2.35 < 0.005 0.07 0.05 0.12 0.06 0.01 0.08 — 451 451 0.02 0.01 0.06 454
Mit. 0.38 1.70 2.35 < 0.005 0.07 0.05 0.12 0.06 0.01 0.08 — 451 451 0.02 0.01 0.06 454
%
Reduced
— — — — — — — — — — — — — — — — —
Annual
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 0.07 0.31 0.43 < 0.005 0.01 0.01 0.02 0.01 < 0.005 0.01 — 74.7 74.7 < 0.005 < 0.005 0.01 75.2
Mit. 0.07 0.31 0.43 < 0.005 0.01 0.01 0.02 0.01 < 0.005 0.01 — 74.7 74.7 < 0.005 < 0.005 0.01 75.2Oct.. 15, 2025 Item #1 148 of 343
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%
Reduced
— — — — — — — — — — — — — — — — —
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 ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — —
2025 14.6 10.1 10.4 0.02 0.46 2.14 2.60 0.43 1.02 1.44 — 1,785 1,785 0.07 0.07 1.17 1,792
Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
2025 0.38 1.70 2.35 < 0.005 0.07 0.05 0.12 0.06 0.01 0.08 — 451 451 0.02 0.01 0.06 454
Annual — — — — — — — — — — — — — — — — —
2025 0.07 0.31 0.43 < 0.005 0.01 0.01 0.02 0.01 < 0.005 0.01 — 74.7 74.7 < 0.005 < 0.005 0.01 75.2
2.3. Construction Emissions by Year, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Year ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — —
2025 14.6 10.1 10.4 0.02 0.46 2.14 2.60 0.43 1.02 1.44 — 1,785 1,785 0.07 0.07 1.17 1,792
Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
2025 0.38 1.70 2.35 < 0.005 0.07 0.05 0.12 0.06 0.01 0.08 — 451 451 0.02 0.01 0.06 454Oct.. 15, 2025 Item #1 149 of 343
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Annual — — — — — — — — — — — — — — — — —
2025 0.07 0.31 0.43 < 0.005 0.01 0.01 0.02 0.01 < 0.005 0.01 — 74.7 74.7 < 0.005 < 0.005 0.01 75.2
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.ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 0.59 0.22 2.66 < 0.005 0.01 0.41 0.42 0.01 0.10 0.11 5.52 584 590 0.58 0.02 1.71 612
Mit. 0.59 0.22 2.66 < 0.005 0.01 0.41 0.42 0.01 0.10 0.11 1.82 583 585 0.21 0.02 1.71 598
%
Reduced
— — — — — — — — — — 67% < 0.5% 1% 63% — — 2%
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 0.53 0.23 1.86 < 0.005 0.01 0.41 0.42 0.01 0.10 0.11 5.52 561 566 0.58 0.02 0.12 587
Mit. 0.53 0.23 1.86 < 0.005 0.01 0.41 0.42 0.01 0.10 0.11 1.82 560 562 0.21 0.02 0.12 573
%
Reduced
— — — — — — — — — — 67% < 0.5% 1% 63% — — 2%
Average
Daily
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 0.54 0.22 2.10 < 0.005 0.01 0.39 0.39 0.01 0.10 0.10 5.52 542 547 0.58 0.02 0.75 569
Mit. 0.54 0.22 2.10 < 0.005 0.01 0.39 0.39 0.01 0.10 0.10 1.82 541 543 0.21 0.02 0.75 555
%
Reduced
— — — — — — — — — — 67% < 0.5% 1% 64% — — 2%
Annual
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 0.10 0.04 0.38 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 0.91 89.7 90.6 0.10 < 0.005 0.12 94.2
Mit. 0.10 0.04 0.38 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 0.30 89.5 89.8 0.04 < 0.005 0.12 91.9
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2%—2%64%1%< 0.5%67%——————————%
Reduced
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 ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Mobile 0.27 0.19 1.97 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 485 485 0.02 0.02 1.63 492
Area 0.33 0.01 0.68 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 1.82 1.82 < 0.005 < 0.005 — 1.83
Energy < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 92.9 92.9 0.01 < 0.005 — 93.2
Water — — — — — — — — — — 0.81 4.79 5.60 0.08 < 0.005 — 8.27
Waste — — — — — — — — — — 4.71 0.00 4.71 0.47 0.00 — 16.5
Refrig. — — — — — — — — — — — — — — — 0.08 0.08
Total 0.59 0.22 2.66 < 0.005 0.01 0.41 0.42 0.01 0.10 0.11 5.52 584 590 0.58 0.02 1.71 612
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Mobile 0.26 0.21 1.85 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 463 463 0.02 0.02 0.04 469
Area 0.27 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00
Energy < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 92.9 92.9 0.01 < 0.005 — 93.2
Water — — — — — — — — — — 0.81 4.79 5.60 0.08 < 0.005 — 8.27
Waste — — — — — — — — — — 4.71 0.00 4.71 0.47 0.00 — 16.5
Refrig. — — — — — — — — — — — — — — — 0.08 0.08
Total 0.53 0.23 1.86 < 0.005 0.01 0.41 0.42 0.01 0.10 0.11 5.52 561 566 0.58 0.02 0.12 587
Average
Daily
— — — — — — — — — — — — — — — — —
Mobile 0.24 0.20 1.76 < 0.005 < 0.005 0.39 0.39 < 0.005 0.10 0.10 — 443 443 0.02 0.02 0.67 450
Area 0.30 < 0.005 0.34 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.90 0.90 < 0.005 < 0.005 — 0.90Oct.. 15, 2025 Item #1 151 of 343
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Energy < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 92.9 92.9 0.01 < 0.005 — 93.2
Water — — — — — — — — — — 0.81 4.79 5.60 0.08 < 0.005 — 8.27
Waste — — — — — — — — — — 4.71 0.00 4.71 0.47 0.00 — 16.5
Refrig. — — — — — — — — — — — — — — — 0.08 0.08
Total 0.54 0.22 2.10 < 0.005 0.01 0.39 0.39 0.01 0.10 0.10 5.52 542 547 0.58 0.02 0.75 569
Annual — — — — — — — — — — — — — — — — —
Mobile 0.04 0.04 0.32 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 — 73.4 73.4 < 0.005 < 0.005 0.11 74.5
Area 0.05 < 0.005 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.15 0.15 < 0.005 < 0.005 — 0.15
Energy < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.4 15.4 < 0.005 < 0.005 — 15.4
Water — — — — — — — — — — 0.13 0.79 0.93 0.01 < 0.005 — 1.37
Waste — — — — — — — — — — 0.78 0.00 0.78 0.08 0.00 — 2.73
Refrig. — — — — — — — — — — — — — — — 0.01 0.01
Total 0.10 0.04 0.38 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 0.91 89.7 90.6 0.10 < 0.005 0.12 94.2
2.6. Operations Emissions by Sector, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Sector ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Mobile 0.27 0.19 1.97 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 485 485 0.02 0.02 1.63 492
Area 0.33 0.01 0.68 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 1.82 1.82 < 0.005 < 0.005 — 1.83
Energy < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 92.9 92.9 0.01 < 0.005 — 93.2
Water — — — — — — — — — — 0.65 3.83 4.48 0.07 < 0.005 — 6.62
Waste — — — — — — — — — — 1.18 0.00 1.18 0.12 0.00 — 4.12
Refrig. — — — — — — — — — — — — — — — 0.08 0.08
Total 0.59 0.22 2.66 < 0.005 0.01 0.41 0.42 0.01 0.10 0.11 1.82 583 585 0.21 0.02 1.71 598
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—————————————————Daily,
Winter
(Max)
Mobile 0.26 0.21 1.85 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 463 463 0.02 0.02 0.04 469
Area 0.27 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00
Energy < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 92.9 92.9 0.01 < 0.005 — 93.2
Water — — — — — — — — — — 0.65 3.83 4.48 0.07 < 0.005 — 6.62
Waste — — — — — — — — — — 1.18 0.00 1.18 0.12 0.00 — 4.12
Refrig. — — — — — — — — — — — — — — — 0.08 0.08
Total 0.53 0.23 1.86 < 0.005 0.01 0.41 0.42 0.01 0.10 0.11 1.82 560 562 0.21 0.02 0.12 573
Average
Daily
— — — — — — — — — — — — — — — — —
Mobile 0.24 0.20 1.76 < 0.005 < 0.005 0.39 0.39 < 0.005 0.10 0.10 — 443 443 0.02 0.02 0.67 450
Area 0.30 < 0.005 0.34 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.90 0.90 < 0.005 < 0.005 — 0.90
Energy < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 92.9 92.9 0.01 < 0.005 — 93.2
Water — — — — — — — — — — 0.65 3.83 4.48 0.07 < 0.005 — 6.62
Waste — — — — — — — — — — 1.18 0.00 1.18 0.12 0.00 — 4.12
Refrig. — — — — — — — — — — — — — — — 0.08 0.08
Total 0.54 0.22 2.10 < 0.005 0.01 0.39 0.39 0.01 0.10 0.10 1.82 541 543 0.21 0.02 0.75 555
Annual — — — — — — — — — — — — — — — — —
Mobile 0.04 0.04 0.32 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 — 73.4 73.4 < 0.005 < 0.005 0.11 74.5
Area 0.05 < 0.005 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.15 0.15 < 0.005 < 0.005 — 0.15
Energy < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.4 15.4 < 0.005 < 0.005 — 15.4
Water — — — — — — — — — — 0.11 0.63 0.74 0.01 < 0.005 — 1.10
Waste — — — — — — — — — — 0.20 0.00 0.20 0.02 0.00 — 0.68
Refrig. — — — — — — — — — — — — — — — 0.01 0.01
Total 0.10 0.04 0.38 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 0.30 89.5 89.8 0.04 < 0.005 0.12 91.9
3. Construction Emissions Details
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3.1. Demolition (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.47 4.33 5.65 0.01 0.16 — 0.16 0.14 — 0.14 — 852 852 0.03 0.01 — 855
Demoliti
on
— — — — — 0.28 0.28 — 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 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.01 0.12 0.15 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 23.3 23.3 < 0.005 < 0.005 — 23.4
Demoliti
on
— — — — — 0.01 0.01 — < 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.02 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 3.87 3.87 < 0.005 < 0.005 — 3.88
Demoliti
on
— — — — — < 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 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — — — — — — — — — — — —
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—————————————————Daily,
Summer
(Max)
Worker 0.04 0.03 0.46 0.00 0.00 0.08 0.08 0.00 0.02 0.02 — 94.9 94.9 < 0.005 < 0.005 0.36 96.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 0.49 0.18 < 0.005 0.01 0.10 0.10 0.01 0.03 0.03 — 374 374 0.02 0.06 0.81 392
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.48 2.48 < 0.005 < 0.005 < 0.005 2.51
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 10.2 10.2 < 0.005 < 0.005 0.01 10.7
Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.41 0.41 < 0.005 < 0.005 < 0.005 0.42
Vendor 0.00 0.00 0.00 0.00 0.00 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 — 1.70 1.70 < 0.005 < 0.005 < 0.005 1.78
3.2. Demolition (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.47 4.33 5.65 0.01 0.16 — 0.16 0.14 — 0.14 — 852 852 0.03 0.01 — 855
Demoliti
on
— — — — — 0.28 0.28 — 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 0.00 0.00 0.00 0.00 0.00
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Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.01 0.12 0.15 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 23.3 23.3 < 0.005 < 0.005 — 23.4
Demoliti
on
— — — — — 0.01 0.01 — < 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.02 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 3.87 3.87 < 0.005 < 0.005 — 3.88
Demoliti
on
— — — — — < 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 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.04 0.03 0.46 0.00 0.00 0.08 0.08 0.00 0.02 0.02 — 94.9 94.9 < 0.005 < 0.005 0.36 96.3
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 0.49 0.18 < 0.005 0.01 0.10 0.10 0.01 0.03 0.03 — 374 374 0.02 0.06 0.81 392
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.48 2.48 < 0.005 < 0.005 < 0.005 2.51
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 10.2 10.2 < 0.005 < 0.005 0.01 10.7
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Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.41 0.41 < 0.005 < 0.005 < 0.005 0.42
Vendor 0.00 0.00 0.00 0.00 0.00 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 — 1.70 1.70 < 0.005 < 0.005 < 0.005 1.78
3.3. Site Preparation (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.47 4.16 5.57 0.01 0.21 — 0.21 0.20 — 0.20 — 859 859 0.03 0.01 — 862
Dust
From
Material
Movement
— — — — — 0.21 0.21 — 0.02 0.02 — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.35 2.35 < 0.005 < 0.005 — 2.36
Dust
From
Material
Movement
— — — — — <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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
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0.39—< 0.005< 0.0050.390.39—< 0.005—< 0.005< 0.005—< 0.005< 0.005< 0.005< 0.005< 0.005Off-Road
Equipment
Dust
From
Material
Movement
— — — — — <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 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.02 0.02 0.23 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 47.4 47.4 < 0.005 < 0.005 0.18 48.2
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.12 0.12 < 0.005 < 0.005 < 0.005 0.13
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.02 0.02 < 0.005 < 0.005 < 0.005 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 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 0.00 0.00 0.00 0.00 0.00
3.4. Site Preparation (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —Oct.. 15, 2025 Item #1 158 of 343
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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.47 4.16 5.57 0.01 0.21 — 0.21 0.20 — 0.20 — 859 859 0.03 0.01 — 862
Dust
From
Material
Movement
— — — — — 0.21 0.21 — 0.02 0.02 — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.35 2.35 < 0.005 < 0.005 — 2.36
Dust
From
Material
Movement
— — — — — <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 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 — 0.39 0.39 < 0.005 < 0.005 — 0.39
Dust
From
Material
Movement
— — — — — <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 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
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Worker 0.02 0.02 0.23 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 47.4 47.4 < 0.005 < 0.005 0.18 48.2
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.12 0.12 < 0.005 < 0.005 < 0.005 0.13
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.02 0.02 < 0.005 < 0.005 < 0.005 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 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 0.00 0.00 0.00 0.00 0.00
3.5. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
1.09 10.1 10.0 0.02 0.46 — 0.46 0.43 — 0.43 — 1,714 1,714 0.07 0.01 — 1,720
Dust
From
Material
Movement
— — — — — 2.07 2.07 — 1.00 1.00 — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
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—————————————————Daily,
Winter
(Max)
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.01 0.06 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 9.39 9.39 < 0.005 < 0.005 — 9.42
Dust
From
Material
Movement
— — — — — 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.55 1.55 < 0.005 < 0.005 — 1.56
Dust
From
Material
Movement
— — — — — <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 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.03 0.02 0.35 0.00 0.00 0.06 0.06 0.00 0.01 0.01 — 71.2 71.2 < 0.005 < 0.005 0.27 72.2
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.37 0.37 < 0.005 < 0.005 < 0.005 0.38Oct.. 15, 2025 Item #1 161 of 343
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Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.06 0.06 < 0.005 < 0.005 < 0.005 0.06
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
3.6. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
1.09 10.1 10.0 0.02 0.46 — 0.46 0.43 — 0.43 — 1,714 1,714 0.07 0.01 — 1,720
Dust
From
Material
Movement
— — — — — 2.07 2.07 — 1.00 1.00 — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.01 0.06 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 9.39 9.39 < 0.005 < 0.005 — 9.42
Dust
From
Material
Movement
— — — — — 0.01 0.01 — 0.01 0.01 — — — — — — —
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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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.55 1.55 < 0.005 < 0.005 — 1.56
Dust
From
Material
Movement
— — — — — <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 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.03 0.02 0.35 0.00 0.00 0.06 0.06 0.00 0.01 0.01 — 71.2 71.2 < 0.005 < 0.005 0.27 72.2
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.37 0.37 < 0.005 < 0.005 < 0.005 0.38
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.06 0.06 < 0.005 < 0.005 < 0.005 0.06
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
3.7. Building Construction (2025) - Unmitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.52 5.14 6.94 0.01 0.22 — 0.22 0.20 — 0.20 — 1,305 1,305 0.05 0.01 — 1,309
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.14 1.41 1.90 < 0.005 0.06 — 0.06 0.05 — 0.05 — 357 357 0.01 < 0.005 — 359
Onsite
truck
0.00 0.00 0.00 0.00 0.00 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
0.03 0.26 0.35 < 0.005 0.01 — 0.01 0.01 — 0.01 — 59.2 59.2 < 0.005 < 0.005 — 59.4
Onsite
truck
0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — —
Worker 0.03 0.03 0.40 0.00 0.00 0.07 0.07 0.00 0.02 0.02 — 82.0 82.0 < 0.005 < 0.005 0.31 83.2
Vendor < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 32.1 32.1 < 0.005 < 0.005 0.08 33.6
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
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Average
Daily
— — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.10 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 21.4 21.4 < 0.005 < 0.005 0.04 21.7
Vendor < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 8.80 8.80 < 0.005 < 0.005 0.01 9.19
Hauling 0.00 0.00 0.00 0.00 0.00 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 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.54 3.54 < 0.005 < 0.005 0.01 3.59
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.46 1.46 < 0.005 < 0.005 < 0.005 1.52
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
3.8. Building Construction (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.52 5.14 6.94 0.01 0.22 — 0.22 0.20 — 0.20 — 1,305 1,305 0.05 0.01 — 1,309
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.14 1.41 1.90 < 0.005 0.06 — 0.06 0.05 — 0.05 — 357 357 0.01 < 0.005 — 359
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
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59.4—< 0.005< 0.00559.259.2—0.01—0.010.01—0.01< 0.0050.350.260.03Off-Road
Equipment
Onsite
truck
0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — —
Worker 0.03 0.03 0.40 0.00 0.00 0.07 0.07 0.00 0.02 0.02 — 82.0 82.0 < 0.005 < 0.005 0.31 83.2
Vendor < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 32.1 32.1 < 0.005 < 0.005 0.08 33.6
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.10 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 21.4 21.4 < 0.005 < 0.005 0.04 21.7
Vendor < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 8.80 8.80 < 0.005 < 0.005 0.01 9.19
Hauling 0.00 0.00 0.00 0.00 0.00 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 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.54 3.54 < 0.005 < 0.005 0.01 3.59
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.46 1.46 < 0.005 < 0.005 < 0.005 1.52
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
3.9. Paving (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
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Off-Road
Equipment
0.51 4.37 5.31 0.01 0.19 — 0.19 0.18 — 0.18 — 823 823 0.03 0.01 — 826
Paving 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 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.01 0.06 0.07 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 11.3 11.3 < 0.005 < 0.005 — 11.3
Paving 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.87 1.87 < 0.005 < 0.005 — 1.87
Paving 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 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.07 0.05 0.81 0.00 0.00 0.15 0.15 0.00 0.03 0.03 — 166 166 0.01 0.01 0.62 169
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.17 2.17 < 0.005 < 0.005 < 0.005 2.20Oct.. 15, 2025 Item #1 167 of 343
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Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.36 0.36 < 0.005 < 0.005 < 0.005 0.36
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
3.10. Paving (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.51 4.37 5.31 0.01 0.19 — 0.19 0.18 — 0.18 — 823 823 0.03 0.01 — 826
Paving 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 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.01 0.06 0.07 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 11.3 11.3 < 0.005 < 0.005 — 11.3
Paving 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.87 1.87 < 0.005 < 0.005 — 1.87
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Paving 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 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.07 0.05 0.81 0.00 0.00 0.15 0.15 0.00 0.03 0.03 — 166 166 0.01 0.01 0.62 169
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.17 2.17 < 0.005 < 0.005 < 0.005 2.20
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.36 0.36 < 0.005 < 0.005 < 0.005 0.36
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
3.11. 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 ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
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134—< 0.0050.01134134—0.03—0.030.03—0.03< 0.0051.140.880.13Off-Road
Equipment
Architect
ural
Coatings
14.4 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.83 1.83 < 0.005 < 0.005 — 1.84
Architect
ural
Coatings
0.20 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 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 — 0.30 0.30 < 0.005 < 0.005 — 0.30
Architect
ural
Coatings
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 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.08 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 16.4 16.4 < 0.005 < 0.005 0.06 16.6
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
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—————————————————Daily,
Winter
(Max)
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.21 0.21 < 0.005 < 0.005 < 0.005 0.22
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.04 0.04 < 0.005 < 0.005 < 0.005 0.04
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
3.12. Architectural Coating (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.13 0.88 1.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 134 134 0.01 < 0.005 — 134
Architect
ural
Coatings
14.4 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
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Off-Road
Equipment
< 0.005 0.01 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.83 1.83 < 0.005 < 0.005 — 1.84
Architect
ural
Coatings
0.20 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 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 — 0.30 0.30 < 0.005 < 0.005 — 0.30
Architect
ural
Coatings
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 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.08 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 16.4 16.4 < 0.005 < 0.005 0.06 16.6
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.21 0.21 < 0.005 < 0.005 < 0.005 0.22
Vendor 0.00 0.00 0.00 0.00 0.00 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 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.04 0.04 < 0.005 < 0.005 < 0.005 0.04
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Oct.. 15, 2025 Item #1 172 of 343
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
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
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
0.27 0.19 1.97 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 485 485 0.02 0.02 1.63 492
Total 0.27 0.19 1.97 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 485 485 0.02 0.02 1.63 492
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
0.26 0.21 1.85 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 463 463 0.02 0.02 0.04 469
Total 0.26 0.21 1.85 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 463 463 0.02 0.02 0.04 469
Annual — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
0.04 0.04 0.32 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 — 73.4 73.4 < 0.005 < 0.005 0.11 74.5
Total 0.04 0.04 0.32 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 — 73.4 73.4 < 0.005 < 0.005 0.11 74.5
4.1.2. Mitigated
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Land
Use
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
0.27 0.19 1.97 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 485 485 0.02 0.02 1.63 492
Total 0.27 0.19 1.97 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 485 485 0.02 0.02 1.63 492
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
0.26 0.21 1.85 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 463 463 0.02 0.02 0.04 469
Total 0.26 0.21 1.85 < 0.005 < 0.005 0.41 0.42 < 0.005 0.10 0.11 — 463 463 0.02 0.02 0.04 469
Annual — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
0.04 0.04 0.32 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 — 73.4 73.4 < 0.005 < 0.005 0.11 74.5
Total 0.04 0.04 0.32 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 — 73.4 73.4 < 0.005 < 0.005 0.11 74.5
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
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — 65.7 65.7 < 0.005 < 0.005 — 65.9
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Total — — — — — — — — — — — 65.7 65.7 < 0.005 < 0.005 — 65.9
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — 65.7 65.7 < 0.005 < 0.005 — 65.9
Total — — — — — — — — — — — 65.7 65.7 < 0.005 < 0.005 — 65.9
Annual — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — 10.9 10.9 < 0.005 < 0.005 — 10.9
Total — — — — — — — — — — — 10.9 10.9 < 0.005 < 0.005 — 10.9
4.2.2. Electricity Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — 65.7 65.7 < 0.005 < 0.005 — 65.9
Total — — — — — — — — — — — 65.7 65.7 < 0.005 < 0.005 — 65.9
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — 65.7 65.7 < 0.005 < 0.005 — 65.9
Total — — — — — — — — — — — 65.7 65.7 < 0.005 < 0.005 — 65.9
Annual — — — — — — — — — — — — — — — — —
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10.9—< 0.005< 0.00510.910.9———————————Apartme
nts
Total — — — — — — — — — — — 10.9 10.9 < 0.005 < 0.005 — 10.9
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
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
< 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 <0.005 — < 0.005 — 27.2 27.2 < 0.005 < 0.005 — 27.3
Total < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 27.2 27.2 < 0.005 < 0.005 — 27.3
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
< 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 <0.005 — < 0.005 — 27.2 27.2 < 0.005 < 0.005 — 27.3
Total < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 27.2 27.2 < 0.005 < 0.005 — 27.3
Annual — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 4.51 4.51 < 0.005 < 0.005 — 4.52
Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 4.51 4.51 < 0.005 < 0.005 — 4.52
4.2.4. Natural Gas Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
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—————————————————Daily,
Summer
(Max)
Apartme
nts
Mid Rise
< 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 <0.005 — < 0.005 — 27.2 27.2 < 0.005 < 0.005 — 27.3
Total < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 27.2 27.2 < 0.005 < 0.005 — 27.3
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
< 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 <0.005 — < 0.005 — 27.2 27.2 < 0.005 < 0.005 — 27.3
Total < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 27.2 27.2 < 0.005 < 0.005 — 27.3
Annual — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 4.51 4.51 < 0.005 < 0.005 — 4.52
Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 4.51 4.51 < 0.005 < 0.005 — 4.52
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 ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00
Consum
er
Products
0.25 — — — — — — — — — — — — — — — —
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————————————————0.02Architect
ural
Coatings
Landsca
pe
Equipme
nt
0.06 0.01 0.68 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.82 1.82 < 0.005 < 0.005 — 1.83
Total 0.33 0.01 0.68 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 1.82 1.82 < 0.005 < 0.005 — 1.83
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00
Consum
er
Products
0.25 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
0.02 — — — — — — — — — — — — — — — —
Total 0.27 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00
Annual — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00
Consum
er
Products
0.04 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
< 0.005 — — — — — — — — — — — — — — — —
Landsca
pe
Equipme
nt
0.01 < 0.005 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.15 0.15 < 0.005 < 0.005 — 0.15
Total 0.05 < 0.005 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.15 0.15 < 0.005 < 0.005 — 0.15
4.3.2. Mitigated
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Source ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00
Consum
er
Products
0.25 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
0.02 — — — — — — — — — — — — — — — —
Landsca
pe
Equipme
nt
0.06 0.01 0.68 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.82 1.82 < 0.005 < 0.005 — 1.83
Total 0.33 0.01 0.68 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 1.82 1.82 < 0.005 < 0.005 — 1.83
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00
Consum
er
Products
0.25 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
0.02 — — — — — — — — — — — — — — — —
Total 0.27 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00
Annual — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00
Consum
er
Products
0.04 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
< 0.005 — — — — — — — — — — — — — — — —
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Landsca
Equipment
0.01 < 0.005 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.15 0.15 < 0.005 < 0.005 — 0.15
Total 0.05 < 0.005 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.15 0.15 < 0.005 < 0.005 — 0.15
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
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — 0.81 4.79 5.60 0.08 < 0.005 — 8.27
Total — — — — — — — — — — 0.81 4.79 5.60 0.08 < 0.005 — 8.27
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — 0.81 4.79 5.60 0.08 < 0.005 — 8.27
Total — — — — — — — — — — 0.81 4.79 5.60 0.08 < 0.005 — 8.27
Annual — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — 0.13 0.79 0.93 0.01 < 0.005 — 1.37
Total — — — — — — — — — — 0.13 0.79 0.93 0.01 < 0.005 — 1.37
4.4.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
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CO2eRN2OCH4CO2TNBCO2BCO2PM2.5TPM2.5DPM2.5EPM10TPM10DPM10ESO2CONOxROGLand
Use
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — 0.65 3.83 4.48 0.07 < 0.005 — 6.62
Total — — — — — — — — — — 0.65 3.83 4.48 0.07 < 0.005 — 6.62
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — 0.65 3.83 4.48 0.07 < 0.005 — 6.62
Total — — — — — — — — — — 0.65 3.83 4.48 0.07 < 0.005 — 6.62
Annual — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — 0.11 0.63 0.74 0.01 < 0.005 — 1.10
Total — — — — — — — — — — 0.11 0.63 0.74 0.01 < 0.005 — 1.10
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
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — 4.71 0.00 4.71 0.47 0.00 — 16.5
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Total — — — — — — — — — — 4.71 0.00 4.71 0.47 0.00 — 16.5
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — 4.71 0.00 4.71 0.47 0.00 — 16.5
Total — — — — — — — — — — 4.71 0.00 4.71 0.47 0.00 — 16.5
Annual — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — 0.78 0.00 0.78 0.08 0.00 — 2.73
Total — — — — — — — — — — 0.78 0.00 0.78 0.08 0.00 — 2.73
4.5.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — 1.18 0.00 1.18 0.12 0.00 — 4.12
Total — — — — — — — — — — 1.18 0.00 1.18 0.12 0.00 — 4.12
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — 1.18 0.00 1.18 0.12 0.00 — 4.12
Total — — — — — — — — — — 1.18 0.00 1.18 0.12 0.00 — 4.12
Annual — — — — — — — — — — — — — — — — —
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0.68—0.000.020.200.000.20——————————Apartme
nts
Total — — — — — — — — — — 0.20 0.00 0.20 0.02 0.00 — 0.68
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
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — — — — — 0.08 0.08
Total — — — — — — — — — — — — — — — 0.08 0.08
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — — — — — 0.08 0.08
Total — — — — — — — — — — — — — — — 0.08 0.08
Annual — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — — — — — 0.01 0.01
Total — — — — — — — — — — — — — — — 0.01 0.01
4.6.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
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CO2eRN2OCH4CO2TNBCO2BCO2PM2.5TPM2.5DPM2.5EPM10TPM10DPM10ESO2CONOxROGLand
Use
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — — — — — 0.08 0.08
Total — — — — — — — — — — — — — — — 0.08 0.08
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — — — — — 0.08 0.08
Total — — — — — — — — — — — — — — — 0.08 0.08
Annual — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — — — — — 0.01 0.01
Total — — — — — — — — — — — — — — — 0.01 0.01
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)
Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
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—————————————————Daily,
Winter
(Max)
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
4.7.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
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)
Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
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Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
4.8.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
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)
Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
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— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
4.9.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
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(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)
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CO2eRN2OCH4CO2TNBCO2BCO2PM2.5TPM2.5DPM2.5EPM10TPM10DPM10ESO2CONOxROGVegetatio
n
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
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(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
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
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 ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
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Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — —
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— — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
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— — — — — — — — — — — — — — — — —
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— — — — — — — — — — — — — — — — —
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— — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Sequest
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— — — — — — — — — — — — — — — — —
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Subtotal — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — —
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Vegetatio
n
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
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4.10.6. Avoided and Sequestered Emissions by Species - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Species ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
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— — — — — — — — — — — — — — — — — —
5. Activity Data
5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description
Demolition Demolition 4/1/2025 4/15/2025 5.00 10.0 —
Site Preparation Site Preparation 4/16/2025 4/17/2025 5.00 1.00 —
Grading Grading 4/18/2025 4/20/2025 5.00 2.00 —
Building Construction Building Construction 4/21/2025 9/8/2025 5.00 100 —
Paving Paving 9/9/2025 9/16/2025 5.00 5.00 —
Architectural Coating Architectural Coating 9/17/2025 9/24/2025 5.00 5.00 —
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
Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Demolition Rubber Tired Dozers Diesel Average 1.00 1.00 367 0.40
Demolition Tractors/Loaders/Back
hoes
Diesel Average 2.00 6.00 84.0 0.37
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Site Preparation Tractors/Loaders/Back Diesel Average 1.00 8.00 84.0 0.37
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 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
Paving Tractors/Loaders/Back
hoes
Diesel Average 1.00 7.00 84.0 0.37
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48
5.2.2. Mitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Demolition Rubber Tired Dozers Diesel Average 1.00 1.00 367 0.40
Demolition Tractors/Loaders/Back
hoes
Diesel Average 2.00 6.00 84.0 0.37
Site Preparation Graders Diesel Average 1.00 8.00 148 0.41
Site Preparation Tractors/Loaders/Back
hoes
Diesel Average 1.00 8.00 84.0 0.37
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
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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 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
Paving Tractors/Loaders/Back
hoes
Diesel Average 1.00 7.00 84.0 0.37
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48
5.3. Construction Vehicles
5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix
Demolition ————
Demolition Worker 10.0 12.0 LDA,LDT1,LDT2
Demolition Vendor —7.63 HHDT,MHDT
Demolition Hauling 5.20 20.0 HHDT
Demolition Onsite truck ——HHDT
Site Preparation ————
Site Preparation Worker 5.00 12.0 LDA,LDT1,LDT2
Site Preparation Vendor —7.63 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck ——HHDT
Grading ————
Grading Worker 7.50 12.0 LDA,LDT1,LDT2
Grading Vendor —7.63 HHDT,MHDT
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Grading Hauling 0.00 20.0 HHDT
Grading Onsite truck ——HHDT
Building Construction ————
Building Construction Worker 8.64 12.0 LDA,LDT1,LDT2
Building Construction Vendor 1.28 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 1.73 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
5.3.2. Mitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix
Demolition ————
Demolition Worker 10.0 12.0 LDA,LDT1,LDT2
Demolition Vendor —7.63 HHDT,MHDT
Demolition Hauling 5.20 20.0 HHDT
Demolition Onsite truck ——HHDT
Site Preparation ————
Site Preparation Worker 5.00 12.0 LDA,LDT1,LDT2
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Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck ——HHDT
Grading ————
Grading Worker 7.50 12.0 LDA,LDT1,LDT2
Grading Vendor —7.63 HHDT,MHDT
Grading Hauling 0.00 20.0 HHDT
Grading Onsite truck ——HHDT
Building Construction ————
Building Construction Worker 8.64 12.0 LDA,LDT1,LDT2
Building Construction Vendor 1.28 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 1.73 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.
5.5. Architectural Coatings
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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 23,328 7,776 0.00 0.00 —
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy)Material Exported (cy)Acres Graded (acres)Material Demolished (Building
Square Footage)
Acres Paved (acres)
Demolition 0.00 0.00 0.00 4,500 —
Site Preparation ——0.50 0.00 —
Grading ——1.50 0.00 —
Paving 0.00 0.00 0.00 0.00 —
5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day)PM10 Reduction PM2.5 Reduction
Water Exposed Area 2 61%61%
Water Demolished Area 2 36%36%
5.7. Construction Paving
Land Use Area Paved (acres)% Asphalt
Apartments Mid Rise —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
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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
Apartments Mid
Rise
65.3 58.9 49.1 22,651 586 529 441 203,442
5.9.2. Mitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year
Apartments Mid
Rise
65.3 58.9 49.1 22,651 586 529 441 203,442
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 0
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 0
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0
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5.10.1.2. Mitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise —
Wood Fireplaces 0
Gas Fireplaces 0
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 0
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 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)
23328 7,776 0.00 0.00 —
5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 180
5.10.4. Landscape Equipment - Mitigated
Season Unit Value
Snow Days day/yr 0.00
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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 40,690 589 0.0330 0.0040 84,941
5.11.2. Mitigated
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 40,690 589 0.0330 0.0040 84,941
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Land Use Indoor Water (gal/year)Outdoor Water (gal/year)
Apartments Mid Rise 421,597 18,265
5.12.2. Mitigated
Land Use Indoor Water (gal/year)Outdoor Water (gal/year)
Apartments Mid Rise 337,278 14,612
5.13. Operational Waste Generation
5.13.1. Unmitigated
Land Use Waste (ton/year)Cogeneration (kWh/year)
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5.13.2. Mitigated
Land Use Waste (ton/year)Cogeneration (kWh/year)
Apartments Mid Rise 2.19 —
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
Apartments Mid Rise Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
Apartments Mid Rise Household
refrigerators and/or
freezers
R-134a 1,430 0.12 0.60 0.00 1.00
5.14.2. Mitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg)Operations Leak Rate Service Leak Rate Times Serviced
Apartments Mid Rise Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
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
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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 Acres
5.18.1.2. Mitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
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5.18.1.2. Mitigated
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)
5.18.2.2. Mitigated
Tree Type Number Electricity Saved (kWh/year)Natural Gas Saved (btu/year)
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which
assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.
Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 8.12 annual days of extreme heat
Extreme Precipitation 2.70 annual days with precipitation above 20 mm
Sea Level Rise —meters of inundation depth
Wildfire 0.00 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from
observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if
received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and
consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with
extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters
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Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data
of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The
four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of
different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score
Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the
greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5
representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction
measures.
6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score
Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/AOct.. 15, 2025 Item #1 204 of 343
2647 Jefferson Street Detailed Report, 7/16/2024
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The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the
greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5
representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction
measures.
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1.CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 29.9
AQ-PM 44.7
AQ-DPM 87.8
Drinking Water 10.4
Lead Risk Housing 46.8
Pesticides 23.2
Toxic Releases 14.1
Traffic 85.7
Effect Indicators —
CleanUp Sites 0.00
Groundwater 59.6
Haz Waste Facilities/Generators 80.2
Impaired Water Bodies 77.3
Solid Waste 0.00
Sensitive Population —
Asthma 10.6
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2647 Jefferson Street Detailed Report, 7/16/2024
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Cardio-vascular 30.4
Low Birth Weights 11.8
Socioeconomic Factor Indicators —
Education 51.2
Housing 45.6
Linguistic 18.1
Poverty 66.4
Unemployment 37.7
7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
Indicator Result for Project Census Tract
Economic —
Above Poverty 43.59040164
Employed 47.8121391
Median HI 35.63454382
Education —
Bachelor's or higher 53.18875914
High school enrollment 3.028358784
Preschool enrollment 11.35634544
Transportation —
Auto Access 33.27345053
Active commuting 58.38573078
Social —
2-parent households 22.80251508
Voting 60.81098422
Neighborhood —
Alcohol availability 33.06813807Oct.. 15, 2025 Item #1 206 of 343
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Park access 56.25561401
Retail density 80.14885153
Supermarket access 72.16732965
Tree canopy 38.05979725
Housing —
Homeownership 10.75324009
Housing habitability 43.65456179
Low-inc homeowner severe housing cost burden 94.44373155
Low-inc renter severe housing cost burden 62.20967535
Uncrowded housing 34.55665341
Health Outcomes —
Insured adults 20.10778904
Arthritis 29.1
Asthma ER Admissions 76.3
High Blood Pressure 63.5
Cancer (excluding skin)24.3
Asthma 46.1
Coronary Heart Disease 23.5
Chronic Obstructive Pulmonary Disease 29.1
Diagnosed Diabetes 58.5
Life Expectancy at Birth 70.8
Cognitively Disabled 39.7
Physically Disabled 49.3
Heart Attack ER Admissions 87.2
Mental Health Not Good 44.5
Chronic Kidney Disease 35.4
Obesity 54.6
Pedestrian Injuries 43.7
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Physical Health Not Good 49.1
Stroke 34.3
Health Risk Behaviors —
Binge Drinking 10.6
Current Smoker 43.7
No Leisure Time for Physical Activity 51.7
Climate Change Exposures —
Wildfire Risk 0.6
SLR Inundation Area 54.1
Children 69.7
Elderly 26.2
English Speaking 38.1
Foreign-born 29.6
Outdoor Workers 36.9
Climate Change Adaptive Capacity —
Impervious Surface Cover 25.2
Traffic Density 95.7
Traffic Access 23.0
Other Indices —
Hardship 54.8
Other Decision Support —
2016 Voting 71.6
7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a)30.0
Healthy Places Index Score for Project Location (b)29.0
Project Located in a Designated Disadvantaged Community (Senate Bill 535)NoOct.. 15, 2025 Item #1 208 of 343
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Project Located in a Low-Income Community (Assembly Bill 1550)Yes
Project Located in a Community Air Protection Program Community (Assembly Bill 617) No
a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
7.4. Health & Equity Measures
No Health & Equity Measures selected.
7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.
7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.
8. User Changes to Default Data
Screen Justification
Operations: Hearths No hearths/fireplaces or woodstoves would be installed.
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CULTURAL RESOURCES REPORT
FOR
THE HISTORICAL ASSESSMENT FOR
2647 JEFFERSON STREET
CARLSBAD, CALIFORNIA
Prepared by: Kristi S. Hawthorne 601 S. Ditmar Street Oceanside CA 92054
(760) 390-4192
kristihawthorne@cox.net
June 7, 2024
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TABLE OF CONTENTS
Introduction 1
Project Description 1
Historical Cultural Environment 4
Historical Overview 4
Methods and Results 7
Description of Resource 7
History of Ownership 7
Analysis of Subject Resource 12
Eligibility Criteria 13
Application of Criteria 15
Integrity 15
Conclusion 17
Resources 18
Building Forms 20
Chain of Title 22
Additional Views 22
Attachments 23
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June 7, 2024 City of Carlsbad
Community Development Department
Planning Division 1635 Faraday Ave. Carlsbad, CA 92008
REFERENCE:
RESULTS OF THE HISTORICAL CULTURAL ASSESSMENT FOR 2647
JEFFERSON STREET, CARLSBAD, CALIFORNIA, 92008 I. INTRODUCTION This report details the findings of the historical assessment conducted for a single-family
residence located at 2647 Jefferson Street in the City of Carlsbad, California 92008
(Figures 1 and 2). This study was conducted to assess the building’s potential for historical and architectural significance as defined by the California Environmental Quality Act and the impact of the proposed project. It was not included in the City of Carlsbad Cultural Resources Survey done in 1990 by Roth and Associates, adopted by
the Carlsbad City Council as the Historic Resources Inventory (HRI) in 1991.
The property description is: That portion of Lot 1 (Northeast Quarter of Northeast Quarter) of Section 1, Township 12 South, Range 5 West, San Bernardino Meridian in the County of San Diego, State of California, according to United States Government
Survey described as follows:
BEGINNING at the northeast corner of said Lot 1, thence South 0°15’ West along the Easterly Line of said Lot 918 to the TRUE POINT OF BEGINNING; thence continuing South 0°5’ West 100 feet; thence North 89°55’ West 50 feet; thence North 0°05’ East
100 feet; thence South 89°55’ East 150 feet to the TRUE POINT OF BEGINNING.
The Assessor Parcel Number is: 155-170-24-00
II. PROJECT DESCRIPTION The project plans are for demolition of the existing structure to make way for new development.
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Figure 1 Project Location, Carlsbad, San Diego County, California
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Figure 2 Project Location on USGS 7.5 San Luis Rey Quadrangle
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III. HISTORICAL CULTURAL ENVIRONMENT
The subject property is on the west side of Jefferson Street, located south of the Buena
Vista Lagoon and west of Interstate 5. The immediate area was unimproved or used for agriculture until the postwar years and gradually developed into a residential neighborhood. After Interstate 5 was built in
1953/1954, the Las Flores exit/entrance to the freeway was constructed, but even in the
1960s there were large areas of unimproved lots. By the 1970s Jefferson Street was widened and has become a busy artery into Carlsbad.
HISTORICAL OVERVIEW
In 1881 John Frazier settled on 160 acres just south of the Buena Vista Lagoon and established a small settlement known as "Frazier's Station." In search of water, he drilled a well and in 1883 found what he claimed to have cured him of illnesses relating to stomach
and kidney problems. This water was "analyzed" and reported to have the same qualities as
water found in Karlsbad, Bohemia. Gerhard Schutte and D. D. Wadsworth purchased the water rights, and together with other investors, formed the Carlsbad Land and Water Company and laid out a town site which they called Carlsbad.
Schutte built a home that later became the Twin Inns, a long-standing landmark located on
Carlsbad Boulevard. By about 1888 a Santa Fe train depot and several stores were built, and the small village grew to a population of about 300. The San Bernardino Daily Courier described Carlsbad on April 14, 1888: “The town of
Carlsbad was laid out a year ago by a company composed of Messrs. Shutte, Smith,
Wadsworth and Frazier, who have spared neither time or money in beautifying this famous
resort. On arriving at Carlsbad one can see at a glance what the town is; four of the finest residences in Southern California adorn the beautiful hill, sloping as it does gently to the beach, and forming a picturesque sight, which must be seen to be appreciated."
The promotional article also described the hotel at Carlsbad: “It is one of the finest
constructed hotels on the coast, supplied with all the latest conveniences as to the comfort of the guests. The billiard room on the lower floor is a model of elegance and one of the largest in Southern California. A banking company has been formed and will soon build a
two-story brick, marble front, to be used also as an opera house; also a fine church edifice,
to cost $5000. The company has fresh water piped all over town free of charge and are
going ahead with other improvements regardless of expense. The business houses are located on the gently sloping hills overlooking the placid waters of the Pacific, which, together with the surrounding scenery, make it a charming spot to while away the long and
dreamy hours of summer days.”
With all the hope and fanfare, Carlsbad’s modest population diminished near the turn of the century and stayed a small coastal village with a population of just 1,660 persons in 1930.
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In a historical overview in 1949 Dick Carboneau wrote: “By the turn of the century, houses
were being tom down, moved, deserted, and surrendered for debt or taxes. The population
of Carlsbad was reduced to such a pitiful handful of families that the school threatened to
close. R. G. Chase, father of Mrs. Dewey McClellan, recalls that there were only about 8 families in Carlsbad when he came to the community in the early 1900's. Tax titles were for the taking—for anyone who had any money—and lots anywhere on the beach could be had
for about $100.”
In 1914, the South Coast Land Company purchased the properties of the then-defunct water company, and the community became largely farming. The flower industry began in the early 1920’s. Sam Thompson, owner of the first avocado orchard in Carlsbad, was largely
responsible for making Carlsbad “The Home of the Avocado” which was advertised as
such. The main business district was located on First Street, now known as State Street. It was one of only two paved roads. For many years the Twin Inns, purchased by E. G. Kentner in 1919, was one of the most
popular stops along the Coast highway in North County and was famous for its chicken
dinners. Its large plaster statues of chickens were iconic landmarks. In 1925 Roy G. Chase built the Los-Diego Hotel on the southwest corner of State and Grand. The name referred to the two large cities north and south of Carlsbad, Los Angeles,
and San Diego, and was “the logical stopping place on the main coast highway between
these two cities.” Managed by Mr. and Mrs. C. T. McKeehan, this two-story Spanish-style structure offered guests amenities that included private baths, hot water, and steam heat. The California Highway Commission applied to the Railroad Commission for permission to
construct an overpass over the tracks of the Atchison Topeka and Santa Fe Railway
Company at Carlsbad. Construction of the crossing began in April 1927 and was completed in August. With this new alignment Highway 101 bypassed State Street and ran directly along Lincoln Street, or present-day Carlsbad Boulevard. New businesses such as the Sea Auto Inn and the Carlsbad Mineral Springs Hotel were soon constructed along the new route
to take full advantage of the increasing traffic through the city.
The Red Apple Inn, built in 1927 by Alfred G. Blair and designed by Robert Baird, was situated on Carlsbad Boulevard. The roadside inn featured 20 guest rooms and a restaurant, decorated with an apple motif. In 1936 the Red Apple Inn was purchased by A. C. Anderson
and later became a part of the Army Navy Academy when the institution relocated from
Pacific Beach. The Carlsbad Theater opened in 1927, built and owned by R. E. Struve, who also built Oceanside's Palomar Theater three years earlier. However, shortly after opening Clark sold
his interest to Rudolph Sonnemonn and Ernest Sutton. Its named was changed to the Iris
Theater in 1939 and it continued to change both names and ownership over the years.
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Fred Mitchell became the publisher of the Carlsbad Journal newspaper in 1928 after he took over the Carlsbad Champion.
Dick Carboneau, columnist and editor of the Oceanside Blade Tribune, noted a significant change when the high was rerouted: “The highway was moved in 1929, making a good many changes in the community. It ruined the business of the Los Diego Hotel. The old route went right past the Twin Inns, turned left onto State Street, and then proceeded north to
Oceanside. What had originally been the side entrance of the Twin Inns, and was being used
as the front entrance, became the side entrance again; and the original rear of the house
became the new front in keeping with the rerouting of the highway.” One of Carlsbad’s most famous residents, actor Leo Carrillo, purchased the Los Kiotes
homestead in 1937, a small portion of which became a city park.
By 1950, downtown street names changed from First to State with the remaining numbered streets changing to Roosevelt, Madison, Jefferson, and Harding, respectively. (Elm Street was later renamed Carlsbad Village Drive.)
The City of Carlsbad was incorporated in 1952 to avoid being annexed to the City of Oceanside. Dewey McClellan served as the first mayor. For decades high school students living in Carlsbad attended the Oceanside-Carlsbad Union High School in Oceanside. In 1957 Carlsbad opened a new high school for its residents.
Palomar Airport opened in 1959. Built by Young and Arrieta Construction Co., it was located southeast of the Carlsbad city limits, before it was annexed by the City of Carlsbad in 1978 and eventually renamed McClellan-Palomar Airport.
In 1969 a large shopping mall, Plaza Camino Real, was built. By 1982 the mall doubled in
size to over a million square feet and 140 stores. Indoor malls changed the way most American consumers shopped for decades but shopping has trended away due to online retail and the trend to "open air lifestyle centers."
Carlsbad is home to many large companies such ViaSat and Calloway Golf. Other golf
manufacturers include TaylorMade-Adidas, Cobra Golf, Titleist, and Odyssey Golf, dubbing Carlsbad as “Titanium Valley”. Carlsbad’s Aviara Golf Club was designed by Arnold Palmer. Carlsbad welcomed Legoland California Resort, LLC, in 1999. It was the first Legoland theme park outside of Europe. A hotel was added in 2018.
In 2021, Carlsbad’s economy grew by $1 billion to $14.6 billion, second only to the City of San Diego, according to a report presented to the City Council.
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IV. METHODS AND RESULTS
Background studies consisting of research from the Carlsbad Library, San Diego County
Master Property Records, a field check of the property, subdivision maps, historical photographs, census records, research of various newspapers, and recorded deeds were conducted as part of the project. Primary, Continuation and Building, Structure and Object forms for the resource were completed and appear in this report as Appendix A.
DESCRIPTION OF RESOURCE
The subject resource at 2647 Jefferson Street is a one-story single-family home.
Asymmetrical in shape, this wood framed home can be best described as a Ranch-style
home. The house, which sits on a large lot, has a three-hipped roof; one over the main structure, one over the single-car garage, and one over the smaller "wing" and the eaves are boxed, commonly found in Ranch-style homes. A circular cement driveway leads to the entrance of the garage which faces north, rather than to the street. The east facing elevation
of the garage has a slatted or jalousie window with a casement. The single-entry doorway is
deeply recessed off center of the front façade. A small double-casement window is followed by a larger one to the left of the entrance and a narrow brick planter sits below these windows. A set of two double-hung windows is to the right of the entrance. All appear to be original. The exterior of the house is divided horizontally with a stucco finish beginning just
under the window sills to the roofline, and below it is covered in a horizontal wood siding.
This wood siding along the garage was replaced with stucco by April 2016. A brick chimney is situated on the south elevation near the rear of the home. The west facing façade has a covered patio. A pergola-type porch covering is located on the north façade of the house, which appears to have been added in the 1980s.
A view of the resource is shown in Figure 4A with additional views in Appendix C. The resource is in fair condition.
HISTORY OF OWNERSHIP
History of ownership was determined through newspaper records, San Diego County Master Property Records and Recorded Deeds through the San Diego County Assessor/Recorder’s Office.
The subject property, Lot 1, Section 1, Township 12 South, Range 5 West, was owned by John A. and Mary C. McCulloh. John McCulloch applied for a land claim for the property in 1889. The South Oceanside Diamond newspaper published the legal notice:
LAND OFFICE AT LOS ANGELES, CAL., January 18th. 1889.
Notice is hereby given that the following named settler has filed notice of his intention to make final proof in support of his claim, and that said proof will he made before the
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Superior Judge at San Diego Cal., on March 9th, 1889, viz; JOHN A. MCCULLOCH, Homestead entry No. 4719, for lot 1, see I, twp 12 s, r 5 w, S B M.
He names the following witnesses to prove his continuous residence upon and cultivation
of said land, -viz.: Charles H. Patterson, Robert A. Patterson, William A. Patterson, Frank E. Patterson, all of Carlsbad, San Diego county, Calif. H. W. Patton, Register.
John Alonzo McCulloch was born in 1842 in Platte, Missouri. By 1860 he had moved to
Kansas. He served in the Civil War with an enlistment date of 1861 and was "mustered out" in 1865. However, he was wounded during the war, shot in his left arm and chest, for which he received a monthly pension of $18.
While in Kansas, John married Mary C. Barrows in 1873. She was born in 1851 and a
native of Canada. By 1880 the couple was living in Santa Rosa, Sonoma County, California. Mary gave birth to five children, four who lived to adulthood: Albert, George, Lenora and Gertrude. In around 1888 the McCullochs relocated to San Diego County and settled in the DeLuz area, which is near Fallbrook. By 1900 the couple had moved to
Eaglepoint, Jackson County, Oregon. John A. McCulloch died in 1907 in Vera Cruz,
Mexico. Mary McCulloch died in 1920 in Lodi, California.
In May of 1898 John and Mary McCulloch sold the subject property, which was listed as 25 acres, to George H. Brodie of Oceanside for $500. Brodie was born in London in 1836
and came to America in 1856. Before coming to California, he and his wife Mary lived in
Kansas. The Brodies came to Oceanside in 1886.
The following month Brodie sold the same property to Charles Kreutzkamp for a loss at $170.
Charles C. Kreutzkamp was a native of Germany, born in 1851 and immigrated to the United States in 1871. He settled in New Jersey, working as a shoemaker and in 1876 married Magdalena Rodiger. By the late 1890s they had settled in Carlsbad. The couple had 15 children, 9 of whom lived to adulthood, four sons and five daughters. The
daughters married into notable pioneer families such as the Schutte and Carpenter
families of Carlsbad. Charles Kreutzkamp operated a salt company from the nearby lagoon and was appointed Carlsbad postmaster in 1904. Magdalena Kreutzkamp died in 1928 and Charles Kreutzkamp died in 1932. Both are buried in Glen Abby Memorial Park in San Diego.
The subject property remained in the Kreutzkamp family until the early 1950s.
By the early 1950s John R. and Ruth A. Warden had purchased the subject property. The Wardens lived in a home at 2637 Jefferson Street. Both were natives of California. John
Warden was a salesman for the Arrowhead Water Company. Ruth and John resided in Oceanside on North Pacific Street before moving to Carlsbad in about 1952. They had two children Nancy and Dennis, born in the Oceanside hospital.
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The Wardens sold the property to Finis A. and Pauline S. Johnson in 1953.
In March 1953 Finis and Pauline Johnson entered into a contract with Edward and Patrick
Zahler, local contractors at 1288 Elm Avenue in Carlsbad, to build a home of a "frame two bedroom and den house with attached garage at 2647 Jefferson St." An aerial from that year show the house under construction.
Finis Albin Johnson was a local educator and principal at the Oceanside-Carlsbad Union
High School. Born in Colorado in 1897, Finis married Pauline Louise Sites in about 1924. Pauline, a native of Indiana, born 1898, was a local schoolteacher in Arapahoe County, Colorado along with her husband. They had one son, Paul Finis Johnson born 1927 in Colorado.
The Johnsons moved to Oceanside, California in about 1935 where Finis was employed worked at the local high school and later junior college. The couple made their home at 2647 Jefferson Street nearly 20 years before they sold it to John E and Eliza Garcia in 1972.
John Edward Garcia was born in Imperial, California in 1924. By 1942 he was living in Oceanside with his parents Felix and Ruth Garcia. In about 1945 he married Eliza Acuna and the couple had three children, Joanne, Jean and Ray. In 1950 the family was living at 3724 Roosevelt Street in Carlsbad where Garcia was working as a carpenter. By 1958 the
family moved to a home at 1015 Buena Vista Avenue. Garcia was then a fireman for the City of Carlsbad, where he worked for several years, attaining the position of captain. Eliza Garcia owned and operated a daycare center at 2518 Jefferson Street.
John and Eliza Garcia sold the residence at 2647 Jefferson Street to Theodore S. and
Mary Virga in 1974.
Theodore Sebastian Virga was born in 1903 in Italy. He came to the United States in 1912 and was living in Los Angeles in 1920 with his parents. He married Mary Krall in Los Angeles on April 26, 1927. Theodore was a truck driver and fruit wholesaler. In 1940
the Virgas moved to Sacramento where Theodore continued to work in the produce market. By 1950 Mary, Theodore and their two children Rose Marie and Richard had returned to Los Angeles where they continued to live for several more years before moving to San Diego County.
The subject property was transferred to a family trust, and after, Mary's death in 1995, it was transferred to Rose Marie Virga Dvorak and her father Theodore Virga. After Theodore's death in 1996 the property remained in the family until 2024 when it was sold to the current owner.
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Figure 3
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ANALYSIS OF SUBJECT RESOURCE ARCHITECTURE
The house at 2647 Jefferson Street is a Ranch-style house. The modern Ranch house was
one of the small house types financed by the Federal Housing Administration (FHA) after WWII, with the increased need to produce housing for veterans and their families with limited budgets. In the 1950s a ranch home became symbolic of the American dream and was one of the most popular housing types built in the US.
Cliff May is considered the architect of the original ranch design. In 1944, Sunset magazine featured May in several articles about the ranch house, and in 1946 the magazine published a collaboration issue with May, called "Sunset Western Ranch Houses." May is attributed with 17 of the 43 designs featured in the book. Four printings
and 50,000 copies later, the book could be considered a success and May's national
stature rose as a result. As famed California historian Kevin Starr noted, "No single Sunset book before or since has had such a profound effect on the architectural environment of the Far West as it was being so rapidly actualized."
House Beautiful, another prominent magazine, also celebrated May's vision with a 26-
page article in 1946. In 1948 the publishers actually built one of May's ranch homes, calling it the "Pace Setter House," and devoted an entire issue to the May-inspired home. As a result of such glowing publicity and attention, May secured twenty commissions to build his home design all over the nation.
Ranch-style homes built by developers were so popular they became massed produced in a variety of sizes and designs, including the “Ranchero” which was a “Rambling Ranch” design. While at times modest in size, the front porch area and back patio were considered extensions of living space, especially in Southern California.
This style of home, particularly in the 1950s and 1960s, were “laid out” horizontally, often asymmetrical in shape, with an off-center entrance. Homes were of one-story, featuring a low-pitched gabled roof and deep-set eaves with roof overhang. Exteriors were a mix of wood siding, brick or stone, and included a large picture window as well as
irregular windows throughout. Other elements include a brick or stone fireplace, attached,
front facing garage, long or full-length porch and patio with sliding glass door.
The residence at 2647 Jefferson Street has many of the elements of a ranch-style home, but lacking others, most notably a large picture window which many consider a
quintessential element to Ranch-style architecture.
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V. ELIGIBILITY CRITERIA
CALIFORNIA ENVIRONMENTAL QUALITY ACT
Under the California Environmental Quality Act (CEQA), a significant historic resource is one that is eligible for listing in the California Register of Historical Resources/National Register of Historic Places or other local historic register or is
deemed significant in a historical resource survey (Section 5024.1(g) of the Public
Resources Code).
To be eligible for listing under the California Register/National Register (the standards of which are both very similar), a resource must be significant within a historic context and
must also meet one or more of the following criteria:
Criterion A: Be associated with an event, or series of events, that have made a significant contribution to the broad pattern of history.
Criterion B: Have an unequivocal association with the lives of people
significant in the past.
Criterion C: Embody the distinctive characteristics of a type, period, or method of construction, or represents the work of a master, or possesses high artistic values, or
represents a significant, distinguishable entity whose components lack individual
distinction.
Criterion D: Have yielded or may be likely to yield information important in local, state or national prehistory or history.
VI. REGISTER STANDARDS
CALIFORNIA REGISTER CRITERIA
When evaluated within its historic context, under CEQA a property must be shown to be significant for one or more of the four Criteria for Evaluation – A, B, C, or D. The Criteria describe how properties are significant for their association with important events or persons, for their importance in design or construction, or for their information
potential. In addition, a property must not only be shown to be significant under the
California Register criteria, but it also must have integrity.
Criterion A: Event. To be considered for listing under Criterion A, a property must be associated with one or more events important in the defined historic context. The event
or trends must clearly be important within the associated context. Mere association with
historic events or trends is not enough, in and of itself, to qualify under Criterion A – the property’s specific association must be considered important as well.
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Criterion B: Person. Criterion B applies to properties associated with individuals whose specific contributions to history can be identified and documented. Persons “significant in
our past” refers to individuals whose activities are demonstrably important within a local,
state or national historic context. The criterion is generally restricted to those properties that illustrate (rather than commemorate) a person’s important achievements. The persons associated with the property must be individually significant within a historic event. Significant individuals must be directly associated with the nominated property.
Properties eligible under Criterion B are usually those associated with a person’s productive life, reflecting the time period when he or she achieved significance. Speculative associations are not acceptable. Documentation must make clear how the nominated property represents an individual’s significant contributions. A property must
retain integrity from the period of its significant historic associations Architects are often
represented by their works, which are eligible under Criterion C. Their homes, however, can be eligible for consideration under Criterion B, if these properties were personally associated with the individual.
Criterion C: Design/Construction: Properties may be eligible under Criterion C if they
embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction. Properties which embody the distinctive characteristics of a type, period, or method of
construction refer to the way in which a property was conceived, designed, or fabricated
by a people or culture in past periods of history. Distinctive characteristics are the physical features or traits that commonly recur in individual types, periods, or methods of construction. To be eligible, a property must clearly contain enough of those characteristics to be considered a true representative of a particular type, period, or
method of construction.
A master is a figure of generally recognized greatness in a field, a known craftsman of consummate skill, or an anonymous craftsman whose work is distinguishable from others by its characteristic style and quality. The property must express a particular phase in the
development of the master’s career, an aspect of his or her work, or a particular them in
his or her craft.
Criterion D: Information Potential. Properties may be eligible under Criterion D if they have yielded, or may be likely to yield, information important in prehistory or
history.
Integrity. Integrity is the ability of a property to convey and maintain its significance. A property must not only be shown to be significant under the California Register criteria, but it also must have integrity. To retain historic integrity, a property will always
possess several, and usually most, of the aspects. The seven key aspects of integrity
include: location, design, setting, materials, workmanship, feeling and association.
Oct.. 15, 2025 Item #1 225 of 343
VII.APPLICATION OF CRITERIA FOR 2647 JEFFERSON STREET
Criterion A (association with a significant historical event): No known significant event
occurred on the property before or after the resource was. The property is not significant under Criterion A.
Criterion B (association with a historic person or persons): No historical evidence was
found to indicate that the residence at 2647 Jefferson Street is associated with any
person(s) or event(s) significant in local, state, or national history. The property does not qualify under Criterion B.
Criterion C (represents a significant design or style of construction): The subject
residence is a Ranch-style home but lacks defining elements and is not the best or good
example of Ranch-style architecture. The dwelling is not considered a valuable example of the use of indigenous materials or craftsmanship, or a defining example of its architectural style.
A resource must express a particular phase in the development of a master builder's
career, an aspect of his/her work, or a particular idea or theme in the craft. The work of an unidentified craftsman is eligible if it rises above the level of workmanship of the other properties encompassed by the historic context. In addition, the property is not eligible under Criterion C simply because it was designed by a prominent architect,
builder, etc. but must be the work of a master. Criterion C requires that the resource be a
notable work of a Master, and that must be clearly demonstrated in the nomination. The resource is not significant under Criterion C.
Criterion D (ability to yield further information): It is unlikely that any further
information of importance would be revealed with additional study. The resource is not
significant under Criterion D.
VIII. INTEGRITY
Integrity is the ability of a property to convey and maintain its significance. A property must not only be shown to be significant under the California Register criteria, but it also must have integrity. To retain historic integrity, a property will always possess several, and usually most, of the aspects. The seven key aspects of integrity include: location,
design, setting, materials, workmanship, feeling, and association.
Location. Location is the place where the historic property was constructed or the place where the historic event occurred.
FINDING: The location of the dwellings has not changed and therefore the property
retains the location element for integrity purposes.
Oct.. 15, 2025 Item #1 226 of 343
Design. Design is the combination of elements that create the form, plan, space, structure, and style of a property. It results from conscious decisions made during the original
conception and planning of a property (or its significant alteration) and applies to
activities as diverse as community planning, engineering, architecture, and landscape architecture. Design includes such elements as organization of space, proportion, scale, technology, ornamentation, and materials.
FINDING: The resource at 2647 Jefferson Street retains sufficient design elements from
its original, although the exterior has been changed along a portion of the house, namely the garage.
Setting. Setting is the physical environment of a historic property. Whereas location
refers to the specific place where a property was built or an event occurred, setting refers
to the character of the place in which the property played its historical role. It involves how, not just where, the property is situated and its relationship to surrounding features and open space.
FINDING: The setting at 2647 Jefferson Street has changed considerably since it was
first constructed. The immediate area was largely residential with single family homes. Today the area, while still residential, has newer, larger properties with multi-family homes. The biggest change is Jefferson Street itself, which is a busy artery into downtown Carlsbad from the Las Flores on/off ramp to Interstate 5. The subject property
lacks integrity of its original setting.
Materials. Materials are the physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form a historic property.
FINDING: The building retains sufficient original materials for integrity purposes.
Workmanship. Workmanship is the physical evidence of the crafts of a particular culture or people during any given period in history or prehistory. It can be expressed in
vernacular methods of construction and plain finishes or in highly sophisticated
configurations and ornamental detailing. It can be based on common traditions or innovative period techniques. Workmanship is important because it can furnish evidence of the technology of a craft, illustrate the aesthetic principles of a historic or prehistoric period, and reveal individual, local, regional, or national applications of both
technological practices and aesthetic principles.
FINDING: There is no evidence of a crafts of a particular culture or people, nor a quality of workmanship demonstrated in the construction of either resource. The house was built by Edward Zahler, a local Carlsbad contractor/builder. The dwelling does not exhibit or
reflect a quality of workmanship element for integrity purposes.
Feeling. Feeling is a property's expression of the aesthetic or historic sense of a particular period of time.
Oct.. 15, 2025 Item #1 227 of 343
FINDING: The residence does not evoke or express an historic sense of a particular
period of time.
Association. Association is the direct link between an important historic event or person and a historic property.
FINDING: The house is not linked to or associated with any historic important event or
person in the development or history of Carlsbad or the State of California.
For a building to be identified as architecturally significant, it must retain as much of the original structural and architectural integrity. The building does not retain integrity of
setting, feeling, workmanship, or association.
IX.CONCLUSION
No historical evidence was found to support or establish that the residence at 2647 Jefferson Street exemplifies or reflects a special or unique aspect of Carlsbad’s general historical development. The house is not associated with any person important to the city's history. It does not represent the work of a master builder, craftsman or architect.
The dwelling is not eligible for listing under any Criterion, and therefore is not eligible
for listing in the California Register of Historical Resources, the California Historic Resources Inventory, or the National Register of Historic places. The building does not rise to or meet any level of significance, and therefore mitigation measures are not required.
Sincerely,
Kristi S. Hawthorne
Oct.. 15, 2025 Item #1 228 of 343
Kristi S. Hawthorne
Qualifications and Experience
Since 2020 I have researched, written and submitted no less than seventeen
Cultural Assessments submitted to the City of Carlsbad which include the following:
180 Cherry Avenue
260 Normandy Lane 270 Juniper
354 Oak Avenue
395 Carlsbad Village Drive
507 Grand Avenue
2502 Jefferson Street
2518 Jefferson Street 2668 Ocean Street
2669 Garfield Street
2747 Roosevelt Street
2785 Roosevelt Street
3374 Carlsbad Boulevard
3580 Madison
3940 Garfield Street
3950 Garfield Street
4080 Sunnyhill
5511 Los Robles
2002-2008 hired by Archaeos, Inc. to research and write historic content for
Historical Assessments
2005 approved by City of Oceanside to research and write Historical Assessments
(over 20, which all have been accepted by the Oceanside Planning Commission
and Oceanside Historic Preservation Advisory Commission)
2007 hired by ASM Affiliates to supply historic content for Historical Assessment
Hired by City of Oceanside in 2015 to conduct Historical Assessments on the
following resources:
Oceanside Pier
Bandshell
Comfort Station
Beach community Center
2019 submitted an extensive Cultural and Historic Assessment to the City of San
Diego (approved)
2021-2023 Completed Cultural Assessments for 4 homes and buildings to qualify
Oct.. 15, 2025 Item #1 229 of 343
for Mills Act in Oceanside, which have all been accepted and approved
I have over 35 years of experience in collecting, maintaining, organizing and
preserving historical documents, photos, ephemera and memorabilia for the
Oceanside Historical Society
Appointed archivist 1987
Served as President 2002-2021
Board Member of the Old Mission San Luis Rey Historic Foundation 2012-2015
Director 2021 to present
I have a thorough knowledge of existing records and have compiled my own
database in order to effectively study and provide a comprehensive record of early
residents of North San Diego County.
I developed a computer database to include over 8,000 biographies of local
persons; over 500 different subjects pertaining to the history of Oceanside,
Carlsbad, Camp Pendleton, Rancho Santa Margarita, Buena Vista Lagoon,
Cemeteries, Schools, etc.; Conducted over 50 oral histories
Completed research for history book, “Oceanside, Crest of the Wave” by Langdon
Sully and Taryn Bigelow, Windsor Publications, 1988.
Provided background research on people, buildings and homes for the 1992
Cultural Resource Survey, "Oceanside, California's Pride", prepared for the City of
Oceanside by Kathleen Flanigan, Susan H. Carrico, Richard L. Carrico.
Author of “Oceanside, Where Life if Worth Living” (Hawthorne) Donning Co.,
2000. A comprehensive history of Oceanside and notable people from 1880s to 2000. (Completed all research, photos, captions, interviews, and index)
In 2005 completed two studies on Highway 101 for the Highway 101 Association
which included research, conducting oral histories, writing history of the road from
Oceanside to Del Mar.
Author of "100 Years of Photos" (Hawthorn) ProStar Publications, Inc. 2016, (a
pictorial history of Oceanside by decade)
Author of "The History of Oceanside" (Hawthorne), L+L Printers, 2022, (an
updated and revamped history of Oceanside with new photos, design and layout)
Writer for the Best of Oceanside and The Osider Magazine (historical articles)
Author of blog: HistoriesandMysteries.blog providing non-fiction, historical
backgrounds on people, buildings and events.
Oct.. 15, 2025 Item #1 230 of 343
2018, conducted research for "Tropic of Football: The Long and Perilous Journey
of Samoans to the NFL" By Rob Ruck, Two Rivers Distribution, 2018
2019, conducted research and credited as "Historian" for City of Oceanside's Alta
Oceanside Environmental Impact Report, December 2019
2023, wrote and co-produced "Generational Black Pioneers – Featuring Oceanside
Entrepreneurs” (directed by Linda Bisesti) a live performance at Oceanside
Theatre Company, based on the real lives of Oceanside's earliest Black Residents.
2024, wrote and co-produced "Generational Black Pioneers – Featuring Oceanside
Firsts” (directed by Linda Bisesti) a live performance at Oceanside Theatre
Company, based on the real lives of Oceanside's earliest Black Residents.
Collaborated with Oceanside Public Library for over 30 decades on numerous
programs and workshops including Oceanside's historic Eastside Neighborhood,
Vietnam War (local impact), and most recently "Visual Analogies" (2023) to gather
photos and stories of different cultures and People of Color
Collaborated with John Sheehan, FAIA Principal, Studio E Architects on
researching of architect Irving J. Gill
Collaborated with Seth Mallios, University History Curator, Director, South Coastal
Information Center to research local cemeteries for book "Cemeteries of San
Diego", Seth Mallios and David M. Caterino, Arcadia Publishing, 2007
Provided research on the history of gliding in North County for Gary Fogel, PhD,
for book "Wind & Wings, the History of Soaring in San Diego", Rock Reef
Publishing, 2000
Oct.. 15, 2025 Item #1 231 of 343
X. RESOURCES
A Field Guide to American Houses, by Virginia Savage McAlester, 2013, New York, Penguin Random House
Carlsbad Historical Society https://www.carlsbadhistoricalsociety.com/ Carlsbad Journal (Carlsbad, California) November 30, 1928
Ducy's 1968 Oceanside-Carlsbad Directory
https://www.historicaerials.com/ Google Street View 2008-2022
"History of Carlsbad" by Fred W. Mitchell, Editor, Carlsbad Journal; "History of San Diego
County", Published by San Diego Press Club, 1936 Home Directory Service, Oceanside-Carlsbad Criss-Cross City Directory, 1954
https://ranchostyle.com/cliffnotes.html Luskey's Official Oceanside-Carlsbad Criss-Cross City Directory, 1959
Oceanside Blade (Oceanside, California), May 28, 1898 Oceanside Blade (Oceanside, California), June 11, 1898 Oceanside Blade Tribune (Oceanside, California), June 29, 1931
Oceanside Blade Tribune (Oceanside, California), August 1, 1958 Oceanside Blade Tribune (Oceanside, California), October 15, 1958 Oceanside Blade Tribune (Oceanside, California), August 22, 1960
San Diego County Master Property Records San Diego Union Tribune (San Diego, California), June 7, 1889
San Diego Union Tribune (San Diego, California), March 12, 1896 San Diego Union Tribune (San Diego, California), June 15, 1940
Oct.. 15, 2025 Item #1 232 of 343
Seekers of the Spring: A History of Carlsbad, by Marje Howard-Jones. Carlsbad, California: The Friends of the Carlsbad Library, 1982
South Oceanside Diamond (Oceanside, California) February 15, 1889 Windows on the Past, An Illustrated History of Carlsbad, California, by Susan Schnebelen Gutierrez, The Donning Company Publishers, 2002
www.ancestry.com (various vital records) www.library.ucsb.edu/geospatial/finding-airphotos
www.zillow.com/homedetails/2647-Jefferson-St-Carlsbad-CA-92008/
Oct.. 15, 2025 Item #1 233 of 343
APPENDIX A
BUILDING FORMS
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Page 1 of 4 *Resource Name or #: (Assigned by recorder) 2647 Jefferson Street, Carlsbad
P1. Other Identifier: *P2. Location: Not for Publication Unrestricted
*a. County San Diego and (P2c, P2e, and P2b or P2d. Attach a Location Map as necessary.)
*b. USGS 7.5' Quad __ Date T ; R ; __¼ of __ ¼ of Sec ; SB B.M.
*c. Address 2647 Jefferson Street City Carlsbad Zip 92008
d. UTM: (Give more than one for large and/or linear resources) Zone , mE/ mN
e. Other Locational Data: (e.g., parcel #, directions to resource, elevation, etc., as appropriate) The subject property is on the west side of Jefferson Street, located south of the Buena Vista Lagoon and west of Interstate 5. The property description is: That portion of Lot 1 (Northeast Quarter of Northeast Quarter) of Section 1, Township 12 South, Range 5 West, San Bernardino Meridian in the County of San Diego, State of California, according to United States Government Survey described as follows: BEGINNING at the northeast corner of said Lot 1, thence South 0°15’ West along the Easterly Line of said Lot 918 to the TRUE POINT OF BEGINNING; thence continuing South 0°5’ West 100 feet; thence North 89°55’ West 50 feet; thence North 0°05’ East 100 feet; thence South 89°55’ East 150 feet to the TRUE POINT OF BEGINNING. The Assessor Parcel Number is: 155-170-24-00 *P3a. Description: (Describe resource and its major elements. Include design, materials, condition, alterations, size, setting, and
boundaries) The subject resource at 2647 Jefferson Street is a one-story single-family home. Asymmetrical in shape, this wood framed home can be best described as a Ranch-style home. The house, which sits on a large lot, has a three-hipped roof; one over the main structure, one over the single-car garage, and one over the smaller "wing" and the eaves are boxed, commonly found in Ranch-style homes. A circular cement driveway leads to the entrance of the garage which faces north, rather than to the street. The east facing elevation of the garage has a slatted or jalousie window with a casement. The single-entry doorway is deeply recessed off center of the front façade. A small double-casement window is followed by a larger one to the left of the entrance and a narrow brick planter sits below these windows. A set of two double-hung windows is to the right of the entrance. All appear to be original. The exterior of the house is divided horizontally with a stucco finish beginning just under the window sills to the roofline, and below it is covered in a horizontal wood siding. This wood siding along the garage was replaced with stucco by April 2016. A brick chimney is situated on the south elevation near the rear of the home. The west facing façade has a covered patio. A pergola-type porch covering is located on the north façade of the house, which appears to have been added in the 1980s.
P3b. Resource Attributes: HP2 – single family residence
*P4. Resources Present:
Building Structure Object Site District
Element of District Other (Isolates, etc.)
P5b. Description of Photo: East elevation, 05/27/2024
*P6. Date Constructed/Age and Source: Historic
Prehistoric Both Constructed 1953
*P7. Owner and Address: 2647 Jefferson LLC 5315 Avenida Encinas Suite 200 Carlsbad, CA 92008
*P8. Recorded by: (Name, affiliation, and address) Kristi S. Hawthorne, 601 South Ditmar Street Oceanside CA 92054
*P9. Date Recorded: 6/07/2024
*P10. Survey Type: (Describe) Intensive *P11. Report
Citation: (Cite survey report and other sources, or enter "none.") Results of the Historical Building Assessment for 2647 Jefferson Street, Carlsbad CA 92008 *Attachments: NONE Location Map Continuation Sheet Building, Structure, and
Object Record Archaeological Record District Record Linear Feature Record Milling Station Record Rock Art
Record Artifact Record Photograph Record Other (List):
State of California — The Resources Agency Primary# ____________________________________________ DEPARTMENT OF PARKS AND RECREATION HRI#________________________________________ _______________ PRIMARY RECORD Trinomial ___
NRHP Status Code Other Listings __
Review Code Reviewer Date _______
Oct.. 15, 2025 Item #1 235 of 343
Page 2 of 4 *Resource Name or # (Assigned by recorder) 2647 Jefferson Street, Carlsbad CA
*Recorded by: Kristi S. Hawthorne *Date 6/07/2024 Continuation Update History of ownership was determined through newspaper records, San Diego County Master Property Records and Recorded Deeds through the San Diego County Assessor/Recorder’s Office. The subject property, Lot 1, Section 1, Township 12 South, Range 5 West, was owned by John A. and Mary C. McCulloh. John McCulloch applied for a land claim for the property in 1889. The South Oceanside Diamond newspaper published the legal notice:
LAND OFFICE AT LOS ANGELES, CAL., January 18th. 1889.
Notice is hereby given that the following named settler has filed notice of his intention to make final proof in support of his
claim, and that said proof will he made before the Superior Judge at San Diego Cal., on March 9th, 1889, viz; JOHN A.
MCCULLOCH, Homestead entry No. 4719, for lot 1, see I, twp 12 s, r 5 w, S B M.
He names the following witnesses to prove his continuous residence upon and cultivation of said land, -viz.: Charles H.
Patterson, Robert A. Patterson, William A. Patterson, Frank E. Patterson, all of Carlsbad, San Diego county, Calif. H. W. Patton,
Register. John Alonzo McCulloch was born in 1842 in Platte, Missouri. By 1860 he had moved to Kansas. He served in the Civil War with an enlistment date of 1861 and was "mustered out" in 1865. However, he was wounded during the war, shot in his left arm and chest, for which he received a monthly pension of $18. While in Kansas, John married Mary C. Barrows in 1873. She was born in 1851 and a native of Canada. By 1880 the couple was living in Santa Rosa, Sonoma County, California. Mary gave birth to five children, four who lived to adulthood: Albert, George, Lenora and Gertrude. In around 1888 the McCullochs relocated to San Diego County and settled in the DeLuz area, which is near Fallbrook. By 1900 the couple had moved to Eaglepoint, Jackson County, Oregon. John A. McCulloch died in 1907 in Vera Cruz, Mexico. Mary McCulloch died in 1920 in Lodi, California. In May of 1898 John and Mary McCulloch sold the subject property, which was listed as 25 acres, to George H. Brodie of Oceanside for $500. Brodie was born in London in 1836 and came to America in 1856. Before coming to California, he and his wife Mary lived in Kansas. The Brodies came to Oceanside in 1886. The following month Brodie sold the same property to Charles Kreutzkamp for a loss at $170. Charles C. Kreutzkamp was a native of Germany, born in 1851 and immigrated to the United States in 1871. He settled in New Jersey, working as a shoemaker and in 1876 married Magdalena Rodiger. By the late 1890s they had settled in Carlsbad. The couple had 15 children, 9 of whom lived to adulthood, four sons and five daughters. The daughters married into notable pioneer families such as the Schutte and Carpenter families of Carlsbad. Charles Kreutzkamp operated a salt company from the nearby lagoon and was appointed Carlsbad postmaster in 1904. Magdalena Kreutzkamp died in 1928 and Charles Kreutzkamp died in 1932. Both are buried in Glen Abby Memorial Park in San Diego. The subject property remained in the Kreutzkamp family until the early 1950s. By the early 1950s John R. and Ruth A. Warden had purchased the subject property. The Wardens lived in a home at 2637 Jefferson Street. Both were natives of California. John Warden was a salesman for the Arrowhead Water Company. Ruth and John resided in Oceanside on North Pacific Street before moving to Carlsbad in about 1952. They had two children Nancy and Dennis, born in the Oceanside hospital. The Wardens sold the property to Finis A. and Pauline S. Johnson in 1953.
State of California — The Resources Agency Primary# _____________________________________
DEPARTMENT OF PARKS AND RECREATION HRI# _ _ CONTINUATION SHEET Trinomial _
Oct.. 15, 2025 Item #1 236 of 343
Page 3 of 4 *Resource Name or # (Assigned by recorder) 2647 Jefferson Street, Carlsbad CA
*Recorded by: Kristi S. Hawthorne *Date 6/07/2024 Continuation Update In March 1953 Finis and Pauline Johnson entered into a contract with Edward and Patrick Zahler, local contractors at 1288 Elm Avenue in Carlsbad, to build a home of a "frame two bedroom and den house with attached garage at 2647 Jefferson St." An aerial from that year show the house under construction. Finis Albin Johnson was a local educator and principal at the Oceanside-Carlsbad Union High School. Born in Colorado in 1897, Finis married Pauline Louise Sites in about 1924. Pauline, a native of Indiana, born 1898, was a local schoolteacher in Arapahoe County, Colorado along with her husband. They had one son, Paul Finis Johnson born 1927 in Colorado. The Johnsons moved to Oceanside, California in about 1935 where Finis was employed worked at the local high school and later junior college. The couple made their home at 2647 Jefferson Street nearly 20 years before they sold it to John E and Eliza Garcia in 1972. John Edward Garcia was born in Imperial, California in 1924. By 1942 he was living in Oceanside with his parents Felix and Ruth Garcia. In about 1945 he married Eliza Acuna and the couple had three children, Joanne, Jean and Ray. In 1950 the family was living at 3724 Roosevelt Street in Carlsbad where Garcia was working as a carpenter. By 1958 the family moved to a home at 1015 Buena Vista Avenue. Garcia was then a fireman for the City of Carlsbad, where he worked for several years, attaining the position of captain. Eliza Garcia owned and operated a daycare center at 2518 Jefferson Street. John and Eliza Garcia sold the residence at 2647 Jefferson Street to Theodore S. and Mary Virga in 1974. Theodore Sebastian Virga was born in 1903 in Italy. He came to the United States in 1912 and was living in Los Angeles in 1920 with his parents. He married Mary Krall in Los Angeles on April 26, 1927. Theodore was a truck driver and fruit wholesaler. In 1940 the Virgas moved to Sacramento where Theodore continued to work in the produce market. By 1950 Mary, Theodore and their two children Rose Marie and Richard had returned to Los Angeles where they continued to live for several more years before moving to San Diego County. The subject property was transferred to a family trust, and after, Mary's death in 1995, it was transferred to Rose Marie Virga Dvorak and her father Theodore Virga. After Theodore's death in 1996 the property remained in the family until 2024 when it was sold to the current owner.
State of California — The Resources Agency Primary# _____________________________________
DEPARTMENT OF PARKS AND RECREATION HRI# _ _ CONTINUATION SHEET Trinomial _
Oct.. 15, 2025 Item #1 237 of 343
Page 4 of 4
*Resource Name or # (Assigned by recorder) 2647 Jefferson Street Carlsbad, California B1. Historic Name: B2. Common Name:
B3. Original Use: residential B4. Present Use: residential
*B5. Architectural Style: Ranch
*B6. Construction History: (Construction date, alterations, and date of alterations) The resource was constructed in 1953
*B7. Moved? No Yes Unknown Date: Original Location:
*B8. Related Features:
B9a. Architect: unknown b. Builder: Edward Zahler_____
*B10. Significance: Theme ____ Area
Period of Significance none Property Type residential Applicable Criteria n/a
(Discuss importance in terms of historical or architectural context as defined by theme, period, and geographic scope. Also address integrity.) The house at 2647 Jefferson Street is a Ranch-style house. The modern Ranch house was one of the small house types financed
by the Federal Housing Administration (FHA) after WWII, with the increased need to produce housing for veterans and their
families with limited budgets. In the 1950s a ranch home became symbolic of the American dream and was one of the most
popular housing types built in the US. Ranch-style homes built by developers were so popular they became massed produced in
a variety of sizes and designs, including the “Ranchero” which was a “Rambling Ranch” design. While at times modest in size,
the front porch area and back patio were considered extensions of living space, especially in Southern California. This style of
home, particularly in the 1950s and 1960s, were “laid out” horizontally, often asymmetrical in shape, with an off-center
entrance. Homes were of one-story, featuring a low-pitched gabled roof and deep-set eaves with roof overhang. Exteriors were
a mix of wood siding, brick or stone, and included a large picture window as well as irregular windows throughout. Other
elements include a brick or stone fireplace, attached, front facing garage, full-length porch and patio with sliding glass door.
The residence at 2647 Jefferson Street has many of the elements of a ranch-style home, but lacking others, most notably a large
picture window which many consider a quintessential element to Ranch-style architecture. No evidence was found to support
that the residence at 2647 Jefferson Street exemplifies or reflects a special or unique aspect of Carlsbad’s general historical
development. The house is not associated with any person important to the city's history. It does not represent the work of a
master builder, craftsman or architect. The dwelling is not eligible for listing under any Criterion, and therefore is not eligible for
listing in the California Register of Historical Resources, the California Historic Resources Inventory, or the National Register of
Historic places.
B11. Additional Resource Attributes: (List attributes and codes) none
*B12. References: Oceanside Blade Tribune newspaper; Seekers of the Spring:
A history of Carlsbad, by Marje Howard-Jones. Carlsbad, California; Windows
on the Past, An Illustrated History of Carlsbad, California, by Susan Schnebelen
Gutierrez, 2002;
B13. Remarks:
*B14. Evaluator: Kristi S. Hawthorne 601 South Ditmar Street, Oceanside, California 92054
Date of Evaluation: 6/07/2024 NORTH
State of California — The Resources Agency Primary# _____________________________________
DEPARTMENT OF PARKS AND RECREATION HRI# _____ _______________________ BUILDING, STRUCTURE, AND OBJECT RECORD *NRHP Status Code
(This space reserved for official comments.)
Oct.. 15, 2025 Item #1 238 of 343
APPENDIX B
CHAIN OF TITLE
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Chain of Title 2647 Jefferson Street
1. Deed Grantor: John R. Warden and Ruth A. Warden Grantee: Finis A. Johnson and Pauline S. Johnson Recorded: September 10, 1953, Book 4979, Page 96 of Official Records
2. Deed Grantor: Finis A. Johnson and Pauline S. Johnson Grantee: John E. Garcia and Eliza Garcia Recorded: March 24, 1972, Document # 1972-0070156 of Official Records
3. Deed Grantor: John E. Garcia and Eliza Garcia Grantee: Theodore S. Virga and Mary Virga
Recorded: July 15, 1974, Document # 1974-0188244 of Official Records 4. Affidavit Grantor: Mary Virga Estate
Grantee: Rose Marie Dvorak and Theodore S. Virga Recorded: March 18, 1996, Document # 1996-0130338 of Official Records 5. Decree of Distribution
Grantor: Theodore S. Virga Grantee: Rose Marie Dvorak, Executor of Theodore S. Virga Estate Recorded: September 22, 1999, Document # 1999-0647440 of Official Records
6. Intrafamily Transfer & Dissolution Grantor: Rose Marie Dvorak Grantee: Sidney E. Dvorak and Rose Marie Dvorak Recorded: April 21, 2003, Document # 2003-0457301 of Official Records
7. Grant Deed Grantor: Sidney E. Dvorak and Rose Marie Dvorak and Donald Rudolph Dvorak Grantee: Janet Marie Virga and Keith Allen Virga Recorded: April 4, 2024, Document # 2024-0083764 of Official Records
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8. Deed Grantor: Janet Marie Virga and Keith Allen Virga
Grantee: 2674 Jefferson LLC
Recorded: May 31, 2024, Document # 2024-0136820 of Official Records
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APPENDIX C
ADDITIONAL VIEWS OF 2647 JEFFERSON STREET
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Above: East eleva�on of residence
Below: East and north eleva�ons looking southwest
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Above: Google view November 2011
Below: Google View June 2015
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Above: Google View April 2016
Below: Google View June 2017
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Above: Google View February 2022
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East and North eleva�ons and views of recessed entry
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Above: North eleva�on with porch covering
Below: North eleva�on with view of garage door
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Zillow views of 2647 Jefferson
Below: West eleva�on
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ATTACHMENTS
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2647 Jefferson under construction in 1953
Historicalaerials.com
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2647 Jefferson Street in 1964
Historicalaerials.com
Oct.. 15, 2025 Item #1 254 of 343
PHASE I ARCHAEOLOGICAL ASSESSMENT
FOR THE
2647 JEFFERSON STREET HOMES PROJECT
CITY OF CARLSBAD, CALIFORNIA
APN 155-170-24
Submitted to:
City of Carlsbad
Planning Department
1635 Faraday Avenue Carlsbad, California 92008 Prepared for:
Rincon Homes 5315 Avenida Encinas, Suite 200 Carlsbad, California 92008
Prepared by:
BFSA Environmental Services, a Perennial Company 14010 Poway Road, Suite A Poway, California 92064
July 8, 2024
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Archaeological Database Information
Authors: Kathleen Krogh, B.A. and Andrew J. Garrison, M.A., RPA
Consulting Firm: BFSA Environmental Services, a Perennial Company 14010 Poway Road, Suite A
Poway, California 92064
(858) 484-0915
Report Date: July 8, 2024
Report Title: Phase I Archaeological Assessment for the 2647 Jefferson Street
Homes Project, City of Carlsbad, California (APN 155-170-24)
Submitted to: City of Carlsbad
Planning Department
1635 Faraday Avenue
Carlsbad, California 92008
Prepared for: Rincon Homes
5315 Avenida Encinas, Suite 200
Carlsbad, California 92008
USGS Quadrangle: Section 1, Township 12 South, Range 5 West, of the San
Bernardino Baseline and Meridian on the USGS San Luis Rey,
California topographic quadrangle (7.5-minute) map
Key Words: Archaeological survey; City of Carlsbad; USGS San Luis Rey,
California topographic quadrangle (7.5-minute); negative survey;
monitoring recommended.
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Table of Contents
Page
1.0 MANAGEMENT SUMMARY/ABSTRACT .............................................................1.0–1
2.0 INTRODUCTION ........................................................................................................2.0–1
3.0 PROJECT SETTING ...................................................................................................3.0–1
3.1 ENVIRONMENTAL SETTING ...........................................................................3.0–1
3.1.1 Geology .......................................................................................................3.0–1
3.1.2 Soils .............................................................................................................3.0–2
3.1.3 Biology ........................................................................................................3.0–2
3.2 CULTURAL SETTING ........................................................................................3.0–2
3.2.1 The San Dieguito Complex/Paleo Indian ...................................................3.0–2
3.2.2 The La Jolla Complex/Encinitas Tradition/Milling Stone Horizon ............3.0–3
3.2.3 The Late Prehistoric Period ........................................................................3.0–5
3.2.4 Historic Period............................................................................................3.0–8
4.0 METHODOLOGY .......................................................................................................4.0–1
4.1 Archaeological Records Search ............................................................................4.0–1
4.2 Field Methodology ................................................................................................4.0–1
4.3 Report Preparation and Recordation .....................................................................4.0–1
4.4 Native American Consutation ...............................................................................4.0–2
4.5 Applicable Regulations .........................................................................................4.0–2
4.5.1 California Enviornmental Quality Act ........................................................4.0–2
5.0 RESULTS .....................................................................................................................5.0–1
5.1 Records Search Results .........................................................................................5.0–1
5.2 Field Investigation .................................................................................................5.0–2
6.0 RECOMMENDATIONS .............................................................................................6.0–1
7.0 CERTIFICATION ........................................................................................................7.0–1
8.0 REFERENCES CITED ................................................................................................8.0–1
Appendices
Appendix A – Qualifications of Key Personnel
Appendix B – Archaeological Records Search Results*
Appendix C – NAHC Sacred Lands File Search*
*Deleted for public review and bound separately in the Confidential Appendix
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List of Figures
Page
Figure 2.0–1 General Location Map .................................................................................2.0–2
Figure 2.0–2 Project Location Map ...................................................................................2.0–3
Figure 2.0–3 Site Plan .......................................................................................................2.0–4 List of Plates
Page
Plate 3.2–1 From left to right: John Frazier, his wife and daughter, Gerhard Schutte,
Samuel Church Smith, and D.D. Wadsworth standing at the platform in
front of Wadsworth’s mansion (left) and the Carlsbad Hotel (right) ...........3.0–11
Plate 3.2–2 1896 map of the Kelly Grant division of Rancho Agua Hedionda ..............3.0–12
Plate 5.2–1 Overview of the project from the southeast corner, facing northwest .........5.0–3
Plate 5.2–2 Overview of the project from the southwest corner of the backyard,
facing northeast ............................................................................................5.0–4
Plate 5.2–3 Overview of the project from the rear of the residence, facing east ............5.0–4
Plate 5.2–4 Overview from the northeast corner of the backyard, facing east ...............5.0–5
List of Tables
Page
Table 5.1–1 Previously Recorded Archaeological Sites Within a One-Half Mile of
the Project .................................................................................................. 5.0–1
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1.0 MANAGEMENT SUMMARY/ABSTRACT
In response to a request from the applicant, BFSA Environmental Services, a Perennial
Company (BFSA), conducted a Phase I archaeological assessment of the 2647 Jefferson Street
Homes Project in the city of Carlsbad, northern San Diego County, California. The project is
located southwest of the intersection of Jefferson Street and Knowles Avenue at 2647 Jefferson
Street. The project includes Assessor’s Parcel Number (APN) 155-170-24 and is situated within
Section 1, Township 12 South, Range 5 West, San Bernardino Baseline and Meridian, as shown
on the San Luis Rey, California U.S. Geological Survey (USGS) topographic quadrangle (7.5-
minute). As designed, the existing residence and landscaping would be removed in order to
develop multistoried residential units with associated hardscape and landscape.
This assessment was conducted as part of the environmental clearance required for
proposed redevelopment of the subject property. The survey program was conducted in
accordance with the California Environmental Quality Act (CEQA), Section 15064.5, and the City
of Carlsbad’s cultural resource guidelines to determine the presence of any archaeological
resources that may be affected by the proposed project and whether these resources meet the
eligibility requirements for the California Register of Historical Resources (CRHR).
A records search was reviewed from the South Coastal Information Center (SCIC) at San
Diego State University (SDSU) to identify previously discovered cultural resources within one-
half mile of the project. The SCIC search results identified 21 cultural resources and eight historic
addresses within one-half mile of the project, none of which are located within the project
boundaries. The search also determined that two previous studies overlap the project, but both
studies are large overviews that do not directly address the subject property (Seeman 1982; Byrd
and O’Neill 2002). In addition, a Sacred Lands File (SLF) search was requested from the Native
American Heritage Commission (NAHC) to list potentially sacred or ceremonial sites or landforms
on or near the project. The SLF search has been returned with positive results for potential sites
or locations of Native American importance in the project vicinity (see Appendix C).
Field archaeologist David Grabski conducted the archaeological survey of the project on
June 21, 2024, with assistance from Aleshawnee Ventura, a San Luis Rey Band of Mission Indians
Native American monitor representing Saving Sacred Sites. The subject property is partially
developed, containing a single-family residence that was constructed between 1953 and 1956.
Although historic in age, the applicant has indicated the building will be evaluated separately from
the current study. No additional archaeological resources were identified during the current
survey.
While the proposed project will not affect any known archaeological resources, based upon
the project location, records search results, limited ground visibility, and prior development, there
remains the potential for buried resources to be present on the property. The current property
development and surrounding area were constructed starting in 1947, prior to CEQA and the
implementation of modern environmental laws necessitating cultural resource studies. Therefore,
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the level of disturbance to the natural soil beneath the current building and hardscape is unknown.
For these reasons, it is recommended that a qualified archaeologist and Native American
representative be present for earthmoving activities to facilitate the identification and review of
any subsurface cultural resources that may be potentially exposed during grading pursuant to the
City’s cultural resource requirements.
A copy of this report will be permanently filed with the SCIC at SDSU. All notes and
other materials related to this project will be curated at the archaeological laboratory of BFSA in
Poway, California.
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2.0 INTRODUCTION
BFSA conducted the Phase I archaeological survey for the 2647 Jefferson Street Homes
Project in response to a requirement by the City of Carlsbad for the environmental assessment of
a proposed development, in conformance with CEQA and the City’s environmental guidelines.
The decision to request this investigation was based upon cultural resource sensitivity of the
locality, as suggested by known site density and predictive modeling. Sensitivity for cultural
resources in a given area is usually indicated by known settlement patterns, which in the Carlsbad
area center around freshwater resources and a food supply.
The project is located southwest of the intersection of Jefferson Street and Knowles Avenue
at 2647 Jefferson Drive in the city of Carlsbad, northern San Diego County, California (Figure
2.0–1). The project includes APN 155-170-24 and is situated within Section 1, Township 12
South, Range 5 West, San Bernardino Baseline and Meridian, as shown on the USGS San Luis
Rey, California topographic quadrangle (7.5-minute) (Figure 2.0–2). Currently, the 0.34-acre
property is partially developed with a single-family residence, paved driveway, and surrounding
landscaping. The project development proposed the removal of the existing residence in order to
develop multistoried residential units with associated hardscape and landscape (Figure 2.0–3).
Principal Investigator Tracy A. Stropes, M.A., RPA directed the cultural resources study
for the project with assistance from field archaeologist David Grabski on June 21, 2024.
Aleshawnee Ventura, a San Luis Rey Band of Mission Indians Native American monitor
representing Saving Sacred Sites, participated in the survey. Kathleen Krogh and Andrew J.
Garrison prepared the technical report, Emily T. Soong prepared the graphics, and Elena C.
Goralogia conducted technical editing and report production. Qualifications of key personnel are
provided in Appendix A.
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3.0 PROJECT SETTING
The project setting consists of the natural physical, geological, and biological contexts
within the proposed project, as well as the cultural setting of prehistoric human activities in the
region. The following sections discuss both the environmental and cultural settings of the subject
property, the relationship between the two, and the relevance of that relationship to the current
project.
3.1 Environmental Setting
3.1.1 Geology
The 2647 Jefferson Street Homes Project is located between Buena Vista Lagoon and Agua
Hedionda Lagoon within the Coastal Plains Physiographic Province of San Diego County. The
project is approximately one-half mile northeast of the coastline and near the southern shore of
Buena Vista Lagoon. Geomorphically, the property occupies an elevated (emergent) marine
terrace, with the project parcel at an average elevation of approximately 58 feet above mean sea
level (AMSL). Geologically, multiple marine terraces in the project area terrace complex have
truncated the older, underlying Eocene-aged (43 to 46 million years old) Santiago Formation, and
refer to the terrace sediments, including their overlying alluvial and colluvial deposits, as
Pleistocene “old paralic deposits” (Kennedy and Tan 2007). The project is mapped as being
underlain by younger old paralic deposits, where Kennedy and Tan (2007) grouped deposits of the
“Bird Rock terrace” (approximately 80,000 years old) with deposits of the older (higher and
slightly farther inland) “Nestor terrace” (approximately 120,000 years old) (Wirths 2024).
San Diego County lies in the Peninsular Ranges Geologic Province of southern California.
The mountainous zone, which extends from northwest to southeast through the county, ranges to
a maximum height of 6,533 AMSL (Beauchamp 1986). Foothills and valleys, which comprise the
cismontane region, extend west from the mountains. This region typically receives more rainfall
than the mesas and less than the mountainous region. Between the foothills and the coast lies the
coastal mesa region, which is cut by several large drainages originating in the mountains and
foothills. The coast is characterized by large bays and lagoons, where the major rivers empty into
the sea, and mesas, which terminate at the ocean in the form of bluffs (Beauchamp 1986).
During the late Holocene, the eastern extent of Agua Hedionda Lagoon was most likely
characterized by shallow saltwater marsh and mud flats. However, several millennia ago, the
lagoon was considerably deeper and provided different habitat. The lagoon was created as the sea
level rose rapidly following the last glacial sequence, filling a deep canyon cut by Hedionda Creek
during a long period of lower sea levels. The deeply entrenched lagoon provided a variety of
marine food resources (e.g., mollusks, crustaceans, and fishes) used in the subsistence routine of
early and middle Holocene La Jolla Complex peoples. Evidence from Batiquitos Lagoon, south
of Agua Hedionda Lagoon, indicates that approximately 3,500 years before the present (YBP), a
rapid, cataclysmic sedimentation event occurred that closed the lagoon off to the coast and
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significantly altered the lagoon environment (Gallegos 1992; Masters et al. 1988; Miller 1966).
The event was followed by a stabilization of sea levels and development of sand bars, sand flats,
and mud flats in the lagoons along the central San Diego County coast. The sedimentation process
resulted in the decline of mollusk populations, particularly Pectinids, which greatly reduced human
activity in the area. Decline in occupancy of the Batiquitos Lagoon area following the siltation
event is evidenced by the paucity of sites post-dating 3,500 YBP (Gallegos 1987).
3.1.2 Soils
Soils in the area fall within the Marina-Chesterton Association, characterized by somewhat
excessively drained to moderately well-drained, loamy, coarse sands and fine sandy loams
(Bowman et al. 1973). Specifically, the soil at the project is mapped as Marina loamy coarse sand,
2 to 9 percent slopes (MlC) (NRCS 2019).
3.1.3 Biology
Vegetation on the property primarily consists of residential landscaping in the front and
back yards and along the perimeter. The prehistoric biological community was dominated by the
coastal sage scrub ecosystem, which included sage shrubs and a variety of grasses and cacti. A
diversity of faunal resources was available in the surrounding ecosystem including deer, Leporids
(Lepus and Sylvilagus), and a variety of waterfowl, rodents, and reptiles.
3.2 Cultural Setting
San Diego County has a very rich and extensive record of prehistoric activity. The
recognized archaeological time periods include the San Dieguito Complex/Paleo Indian, Milling
Stone Horizon, La Jolla Complex, and Late Prehistoric (Luiseño and Kumeyaay) Period. Below
is a discussion of these cultural elements within the region of the current project.
3.2.1 The San Dieguito Complex/Paleo Indian
The term “San Dieguito Complex” is a cultural distinction used to describe a group of
people that occupied sites in the region between 11,500 and 7,000 YBP and appear to have been
related to or were contemporaneous with the Paleo Indian groups in the Great Basin area and the
Midwest. Initially believed to have been big game hunters, the San Dieguito are better typified as
wide-ranging hunter gatherers. The earliest evidence of San Dieguito Complex sites is known
from San Diego County, the Colorado Desert, and farther north along the California coast. These
people abandoned the drying inland lakes of the present California desert and arrived in San Diego
County circa 9,000 YBP, as documented at the Harris (SDI-149) (Warren 1966), Rancho Park
North (SDI-4392) (Kaldenberg 1982), and Agua Hedionda (SDI-210/UCLJ-M-15 and SDI-
10,965/SDM-W-131) sites (Moriarty 1967; Gallegos and Carrico 1984; Gallegos 1991). A San
Dieguito component appears to have been present in the lower strata at the Malago Cove site in
Redondo Beach, Los Angeles County (Walker 1951). Although radiocarbon dates were not
obtained from these levels, the lack of ground stone tools and presence of crude flaked tools
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suggests similarities to the San Dieguito Complex.
Diagnostic San Dieguito artifacts include finely crafted scraper planes, choppers, scrapers,
crescentics, elongated bifacial knives, and intricate leaf-shaped points (Rogers 1939; Warren
1967). This tool assemblage resembles those of the Western Lithic Co-Tradition (Davis et al.
1969) and the Western Pluvial Lakes Tradition (Bedwell 1970; Moratto 1984). Typical San
Dieguito sites lack ground stone tools. Tools recovered from San Dieguito Complex sites and the
pattern of the site locations indicate they were a wandering hunter-gatherer society (Moriarty 1969;
Rogers 1966). Faunal data from the Malago Cove site, which included mollusks, fish, birds, and
terrestrial and marine mammals, suggests a diverse and broad-based strategy (Walker 1951).
The San Dieguito Complex is the least understood of the cultures that occupied the
southern California region. This is primarily due to the fact that San Dieguito sites rarely contain
stratigraphic information or datable material. Debate continues as to whether the San Dieguito
sites are actually different activity areas of the early Encinitas Tradition peoples (Bull 1987;
Gallegos 1987), or whether the San Dieguito Complex peoples had a separate origin and culture
from the Encinitas Tradition (Hayden 1987; Moriarty 1987; Smith 1987). According to the second
scenario, the San Dieguito Complex peoples may have been assimilated into the dominant
Encinitas Tradition culture (Kaldenberg 1982; Moriarty 1967). A third possibility is that the San
Dieguito Complex gave rise to the Encinitas Tradition (Koerper et al. 1991). The issue of shared
or separate origins of the San Dieguito Complex and Encinitas Tradition may be resolved with
continued collection of archaeological data and collection of systematic radiocarbon dates.
3.2.2 The La Jolla Complex/Encinitas Tradition/Milling Stone Horizon
Between 9,000 and 8,000 YBP, a widespread complex was established in the southern
California region, primarily along the coast (Warren and True 1961). The complex is locally
known as the La Jolla Complex (Rogers 1939; Moriarty 1966), which is regionally associated with
the Encinitas Tradition (Warren 1968), and shared cultural components with the widespread
Milling Stone Horizon (Wallace 1955). The coastal expression of the La Jolla Complex, with a
focus upon coastal resources and development of deeply stratified shell middens located primarily
around bays and lagoons, appeared in the southern California coastal areas. The older sites
associated with the expression are located at Topanga Canyon, Newport Bay, Agua Hedionda
Lagoon, and some of the Channel Islands. Radiocarbon dates from sites attributed to this complex
span a period of more than 7,000 years in the region, beginning over 9,000 YBP.
The Encinitas Tradition is best recognized for its pattern of large coastal sites characterized
by shell middens, grinding tools closely associated with the marine resources of the area, cobble-
based tools, and flexed human burials (Shumway et al. 1961; Smith and Moriarty 1985). While
ground stone tools and scrapers are the most recognized tool types, coastal Encinitas Tradition
sites also contain numerous utilized flakes, which may have been used to pry open shellfish.
Artifact assemblages at coastal sites indicate a subsistence pattern focused upon shellfish
collection and nearshore fishing, suggesting an incipient maritime adaptation with regional
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similarities to more northern sites of the same period (Koerper et al. 1986). Other artifacts
associated with Encinitas Tradition sites include stone bowls, doughnut stones, discoidals, stone
balls, and stone, bone, and shell beads.
The coastal lagoons in northwestern San Diego County supported large Milling Stone
Horizon populations circa 6,000 YBP, as demonstrated by numerous radiocarbon dates from the
many sites adjacent to the lagoons. The ensuing millennia were not stable environmentally and by
3,000 YBP, many of the coastal sites in central San Diego County had been abandoned (Gallegos
1987, 1992), which is usually attributed to the sedimentation of coastal lagoons and the resulting
deterioration of fish and mollusk habitats, a situation well-documented at Batiquitos Lagoon
(Miller 1966; Gallegos 1987). Over a 2,000-year period at Batiquitos Lagoon, dominant mollusk
species occurring in archaeological middens shifted from deep-water mollusks (Argopecten sp.)
to species tolerant of tidal flat conditions (Chione sp.), indicating water depth and temperature
changes (Miller 1966; Gallegos 1987).
This situation likely occurred for other small drainages (Buena Vista, Agua Hedionda, San
Marcos, and Escondido creeks) along the central San Diego coast, where low flow rates did not
produce sufficient discharge to flush the lagoons they fed (Buena Vista, Agua Hedionda,
Batiquitos, and San Elijo lagoons) (Byrd 1998). Drainages along the northern and southern San
Diego coastline were larger and flushed the coastal hydrological features they fed, keeping them
open to the ocean and allowing for continued human exploitation (Byrd 1998). Los Peñasquitos
Lagoon and Sorrento Valley exhibit dates as late as 2,355 YBP (Smith and Moriarty 1985; Carrico
and Taylor 1983; Carrico and Gallegos 1988; Gallegos et al. 1989; Smith and Moriarty 1983;
WESTEC Services, Inc. 1975). San Diego Bay showed continuous occupation until the close of
the Milling Stone Horizon (Gallegos et al. 1988). Additionally, data from several drainages in
Marine Corps Base Camp Pendleton indicate a continued occupation of shell midden sites until
the close of the period, showing that coastal sites were not entirely abandoned during this time
(Byrd 1998).
By 5,000 YBP, an inland expression of the La Jolla Complex, which exhibits influences
from the Campbell Tradition from the north, is evident in the archaeological record. These inland
Milling Stone Horizon sites have been termed “Pauma Complex” (True 1958; Warren et al. 1961;
Meighan 1954). By definition, Pauma Complex sites share a predominance of grinding
implements (manos and metates), lack mollusk remains, have a greater tool variety including atlatl
dart points, quarry-based tools, and crescentics, and seem to express a more sedentary lifestyle
with a subsistence economy based upon the use of a broad variety of terrestrial resources.
Although originally viewed as a separate culture from the coastal La Jolla Complex (True 1980),
it appears these inland sites may be part of a subsistence and settlement system used by the coastal
peoples. Evidence from the 4S Ranch Project in inland San Diego County suggests these inland
sites may represent seasonal components within an annual subsistence round by La Jolla Complex
populations (Raven-Jennings et al.1996). Including both coastal and inland sites of this time
period in discussions of the Encinitas Tradition provides a more a complete appraisal of the
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settlement and subsistence system exhibited by this cultural complex.
3.2.3 The Late Prehistoric Period
Approximately 1,300 YBP, a Shoshonean-speaking group from the Great Basin region
moved into San Diego County, marking the transition into the Late Prehistoric Period. The period
is characterized by higher population densities and elaborations in social, political, and
technological systems. Economic systems diversified and intensified with the continued
elaboration of trade networks, the use of shell-bead currency, and the appearance of more labor-
intensive, yet effective, technological innovations. Technological developments during the period
include the introduction of the bow and arrow between A.D. 400 and 600. Atlatl darts were
replaced by smaller arrow darts, including the Cottonwood series points. Other hallmarks of the
Late Prehistoric Period include extensive trade networks as far reaching as the Colorado River
Basin, and cremation of the dead. The period is divided into two phases, San Luis Rey I and San
Luis Rey II, based upon the introduction of pottery (Meighan 1954). Through radiocarbon dating,
the introduction of pottery and the initiation of San Luis Rey II began circa A.D. 1300. San Luis
Rey I is characterized by the use of portable shaped or unshaped slab metates and non-portable
bedrock milling features. Manos and pestles may also be shaped or unshaped. Cremations, bone
awls, and stone and shell ornaments are also prominent in the material culture. The later San Luis
Rey II assemblage is augmented by pottery cooking and storage vessels, cremation urns, and
polychrome pictographs. The fluorescence of rock art likely appeared as the result of increased
population sizes and increased sedentism (True et al. 1974). Flaked stone dart points are
dominated by the Cottonwood Triangular series, but Desert Side-notched, Dos Cabazas Serrated,
leaf-shaped, and stemmed styles also occur. Subsistence is thought to have been focused upon the
use of acorns, a storable species that allowed for relative sedentism and increased population sizes.
Ethnohistoric and ethnographic evidence indicates the Shoshonean-speaking group that
occupied the northern portion of San Diego County was the Luiseño. Along the coast, the Luiseño
made use of marine resources by fishing and collecting mollusks for food. Seasonally available
terrestrial resources, including acorns and game, were also sources of nourishment for Luiseño
groups. The elaborate kinship and clan systems between the Luiseño and other groups facilitated
a wide-reaching trade network that included trade of Obsidian Butte obsidian, resources from the
eastern deserts, and steatite from the Channel Islands.
When contacted by the Spanish in the sixteenth century, the Luiseño occupied a territory
bounded on the west by the Pacific Ocean, on the east by the Peninsular Ranges mountains
(including Palomar Mountain to the south and Santiago Peak to the north), on the south by Agua
Hedionda Lagoon, and on the north by Aliso Creek in present-day San Juan Capistrano. The
Luiseño were a Takic-speaking people more closely related linguistically and ethnographically to
the Cahuilla, Gabrielino, and Cupeño to the north and east than to the Kumeyaay, a Yuman-
speaking group, who occupied territory to the south. The Luiseño differed from their neighboring
Takic speakers in having an extensive proliferation of social statuses, a system of ruling families
Oct.. 15, 2025 Item #1 269 of 343
that provided ethnic cohesion within the territory, a distinct world view that stemmed from use of
the hallucinogen datura, and an elaborate religion that included ritualized sand paintings of the
sacred being “Chingichngish” (Bean and Shipek 1978; Kroeber 1976). The following is a
summary of ethnographic data regarding this group.
Subsistence and Settlement
The Luiseño occupied sedentary villages, most often located in sheltered areas in valley
bottoms, along streams, or along coastal strands near mountain ranges. Villages were located near
water sources to facilitate acorn leaching and in areas that offered thermal and defensive
protection. Villages were composed of areas that were both publicly and privately (or family)
owned. Publicly owned areas included trails, temporary campsites, hunting areas, and quarry sites.
Inland groups had fishing and gathering sites along the coast that were used, particularly from
January to March, when inland food resources were scarce. During October and November, most
of the village would relocate to mountain oak groves to harvest acorns. For the remainder of the
year, the Luiseño remained at village sites, where food resources were within a day’s travel (Bean
and Shipek 1978; Kroeber 1976).
The most important food source of the Luiseño was acorns, of which six different species
were used (Quercus californica, Quercus agrifolia, Quercus chrysolepis, Quercus dumosa,
Quercus engelmannii, and Quercus wislizeni). Seeds, particularly grasses (Gramineae), flowering
plants (Compositae), and mints (Labiatae), were also heavily used. Seed-bearing species were
encouraged through controlled burns, which were conducted at least every third year, and a variety
of other stems, leaves, shoots, bulbs, roots, and fruits were also utilized. Hunting augmented the
vegetal diet. Animal species taken included deer, rabbit, hare, woodrat, ground squirrel, antelope,
quail, duck, freshwater fish from mountain streams, and marine mammals, fish, crustaceans, and
mollusks, particularly abalone (Haliotis sp.), from the coast. A variety of snakes, small birds, and
rodents were also taken (Bean and Shipek 1978; Kroeber 1976).
Social Organization
Social groups within the Luiseño nation consisted of patrilineal families or clans, which
were politically and economically autonomous. Several clans comprised a religious party, or nota,
which was headed by a chief who organized religious ceremonies and controlled economics and
warfare. The chief had assistants who specialized in particular aspects of ceremonial or
environmental knowledge and who, with the chief, were part of a cultic social group with special
access to supernatural power, particularly that of Chingichngish. The positions of chief and
assistants were hereditary, and the complexity and multiplicity of these specialists’ roles likely
increased in coastal villages and larger inland villages (Bean and Shipek 1978; Kroeber 1976;
Strong 1929).
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Marriages were arranged by the parents; these arrangements were often made to forge
alliances between lineages. Useful alliances included those between groups of differing ecological
niches and those that resulted in territorial expansion. Residence was patrilocal (Bean and Shipek
1978; Kroeber 1976).
Women were primarily responsible for plant gathering while men were responsible for
hunting; however, at times, particularly during acorn and marine mollusk harvests, there was no
division of labor. Elderly women cared for children, while elderly men were active participants in
rituals, ceremonies, and political affairs and were responsible for manufacturing, hunting, and
ritualistic implements. Children were taught subsistence skills at the earliest age possible (Bean
and Shipek 1978; Kroeber 1976).
Material Culture
House structures were conical, partially subterranean, and thatched with reeds, brush, or
bark. Ramadas were rectangular and protected workplaces for domestic chores, including cooking.
Ceremonial sweathouses, which were important in purification rituals, were round, partially
subterranean, thatched structures covered with a layer of mud. Another ceremonial structure was
the wámkis, which was located in the center of the village and was the place of rituals such as sand
painting and associated with the Chingichngish cult (Bean and Shipek 1978; Kroeber 1976).
Clothing was minimal. Women wore a cedar-bark and netted twine double apron and men
a waist cord. In cold weather, cloaks or robes of rabbit fur, deerskin, or sea otter fur were worn by
both sexes. Footwear included sandals fashioned from yucca fibers and deerskin moccasins.
Adornments included bead necklaces and pendants made from bone, clay, stone, shell, bear claws,
mica sheets, deer hooves, and abalone shell. Men wore ear and nose piercings made of cane or
bone, which were sometimes decorated with beads. Adornments were commonly decorated with
semiprecious stones including quartz, topaz, garnet, opal, opalite, agate, and jasper (Bean and
Shipek 1978; Kroeber 1976).
Hunting implements included the bow and arrow. Arrows were tipped with either a carved,
fire-hardened wood tip or a lithic point, usually fashioned from locally available felsite or quartz.
Throwing sticks fashioned from wood were used in hunting small game, while deer head decoys
were used during deer hunts. Coastal groups fashioned dugout canoes for nearshore fishing and
harvested fish with seines, nets, traps, and hooks made of bone or abalone shell (Bean and Shipek
1978; Kroeber 1976).
The Luiseño had a well-developed basket industry; baskets were used in resource
gathering, food preparation, storage, and food serving. Pottery containers, which were shaped by
paddle and anvil and fired in shallow, open pits, were used for food storage, cooking, and serving.
Other utensils included wood implements, steatite bowls, and ground stone manos, metates,
mortars, and pestles (Bean and Shipek 1978; Kroeber 1976). Tools included knives, scrapers,
choppers, awls, and drills. Shamanistic items included soapstone or clay smoking pipes and
crystals made of quartz or tourmaline (Bean and Shipek 1978; Kroeber 1976).
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3.2.4 Historic Period
Exploration Period (1530 to 1769)
The historic period around San Diego Bay began with the landing of Juan Rodriguez
Cabrillo and his men in 1542 (Chapman 1921). Sixty years after the Cabrillo expeditions (1602
to 1603), an expedition under Sebastian Vizcaíno made an extensive and thorough exploration of
the Pacific coast. Although his voyage did not extend beyond the northern limits of the Cabrillo
track, Vizcaíno had the most lasting effect upon the nomenclature of the coast. Many of the names
Vizcaíno assigned to various locations throughout the region have survived to the present time,
whereas nearly every one of Cabrillo’s has faded from use. For example, Cabrillo gave the name
“San Miguel” to the first port at which he stopped in what is now the United States; 60 years later,
Vizcaíno changed the port name to “San Diego” (Rolle 1969).
Spanish Colonial Period (1769 to 1821)
The Spanish occupation of the claimed territory of Alta California took place during the
reign of King Carlos III of Spain (Engelhardt 1920). Jose de Gálvez, a powerful representative of
the king in Mexico, conceived the plan to colonize Alta California and thereby secure the area for
the Spanish Crown (Rolle 1969). The effort involved both military and religious components,
where the overall intent of establishing forts and missions was to gain control of the land and the
native inhabitants through conversion. Actual colonization of the San Diego area began on July
16, 1769, when the first Spanish exploring party, commanded by Gaspar de Portolá (with Father
Junípero Serra in charge of religious conversion of the native populations), arrived by the overland
route to San Diego to secure California for the Spanish (Palou 1926). The natural attraction of the
harbor at San Diego and the establishment of a military presence in the area solidified the
importance of San Diego to the Spanish colonization of the region and the growth of the civilian
population.
Missions were constructed from San Diego to as far north as San Francisco. The mission
locations were based upon important territorial, military, and religious considerations. Grants of
land were made to those who applied, but many tracts reverted back to the government due to lack
of use. As an extension of territorial control by the Spanish Empire, each mission was placed so
as to command as much territory and as large a population as possible. While primary access to
California during the Spanish Period was by sea, the route of El Camino Real served as the land
route for transportation, commercial, and military activities within the colony. This route was
considered the most direct path between the missions (Rolle 1969; Caughey 1970). As increasing
numbers of Spanish and Mexican peoples, as well as the later Americans during the Gold Rush,
settled in the area, the Native American populations diminished as they were displaced or
decimated by disease (Carrico and Taylor 1983).
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Mexican Period (1821 to 1846)
On September 16, 1810, the priest Father Miguel Hidalgo y Costilla started a revolt against
Spanish rule. He and his untrained Native American followers fought against the Spanish, but his
revolt was unsuccessful and Father Hidalgo was executed. After this setback, Father José Morales
led the revolutionaries, but he too failed and was executed. These two men are still symbols of
Mexican liberty and patriotism. After the Mexican-born Spanish and the Catholic Church joined
the revolution, Spain was finally defeated in 1821. Mexican Independence Day is celebrated on
September 16 of each year, signifying the anniversary of the start of Father Hidalgo’s revolt.
The revolution had repercussions in the northern territories, and by 1834, all of the mission
lands had been removed from the control of the Franciscan Order under the Acts of Secularization.
Without proper maintenance, the missions quickly began to disintegrate, and after 1836,
missionaries ceased to make regular visits inland to minister to the Native Americans (Engelhardt
1920). Large tracts of land continued to be granted to persons who applied for them or who had
gained favor with the Mexican government. Grants of land were also made to settle government
debts and the Mexican government was called upon to reaffirm some older Spanish land grants
shortly before the Mexican-American War of 1846 (Moyer 1969).
Anglo-American Period (1846 to Present)
California was invaded by United States troops during the Mexican-American War from
1846 to 1848. The acquisition of strategic Pacific ports and California land was one of the principal
objectives of the war (Price 1967). At the time, the inhabitants of California were practically
defenseless, and they quickly surrendered to the United States Navy in July 1847 (Bancroft 1886).
The cattle ranchers of the “counties” of southern California prospered during the cattle
boom of the early 1850s. Cattle ranching soon declined, however, contributing to the expansion
of agriculture. With the passage of the “No Fence Act,” San Diego’s economy changed from stock
raising to farming (Rolle 1969). The act allowed for the expansion of unfenced farms, which was
crucial in an area where fencing material was practically unavailable. Five years after its passage,
most of the arable lands in San Diego County had been patented as either ranchos or homesteads,
and growing grain crops replaced raising cattle in many of the county’s inland valleys (Blick 1976;
Elliott 1883 [1965]). By 1870, farmers had learned to dry farm and were coping with some of the
peculiarities of San Diego County’s climate (San Diego Union 1868; Van Dyke 1886). Between
1869 and 1871, the amount of cultivated acreage in the county rose from less than 5,000, to more
than 20,000 acres (San Diego Union 1872). Large-scale farming in San Diego County was limited
by a lack of water and the small size of arable valleys, and the small urban population and poor
roads restricted commercial crop growing. Nevertheless, cattle continued to be grazed in inland
San Diego County (Gordinier 1966).
During the first two decades of the twentieth century, the population of San Diego County
continued to grow. The population of the inland county declined during the 1890s, but between
1900 and 1910, it rose by about 70 percent. The pioneering efforts were over, the railroads had
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broken the relative isolation of southern California, and life in San Diego County became similar
to other communities throughout the west. After World War I, the history of San Diego County
was primarily determined by the growth of San Diego Bay. During this time period, the history
of inland San Diego County was subsidiary to that of the city of San Diego, which became a Navy
center and an industrial city (Heiges 1976). In inland San Diego County, agriculture became
specialized and recreational areas were established in the mountain and desert areas.
General History of Carlsbad
Mission San Luis Rey de Franca was constructed in 1798 near present-day Oceanside. The
mission lands encompassed present-day Carlsbad north to the current location of Marine Corps
Base Camp Pendleton, east to Santa Ysabel, and south past Encinitas. The establishment of the
mission had detrimental effects upon the Native American communities in the area, as the fathers
focused upon religious conversion and utilization of Native American labor to develop and
maintain the cattle ranches, orchards, and water systems necessary for the mission’s operation
(Carlsbad Historical Society n.d.).
In 1821, Mexico gained independence from Spain and the missions were soon secularized.
As a result of the secularization, mission lands were divided up and granted to prominent Mexican
families by the Mexican government (Stropes and Gallegos 2005). Juan María Marrón II was
granted 13,311 acres in 1842, naming the land grant Rancho Agua Hedionda. The grant included
present-day Carlsbad and Carlsbad Ranch. After Marrón’s death in 1853, the ranch was divided
up among his family; however, financial troubles eventually led to the land being sold to Francis
Hinton in 1865. Hinton then hired Robert Kelly, who later inherited the ranch from Hinton
(Stropes and Gallegos 2005).
In 1880, Kelly granted the Southern California Railway a coastal right-of-way that allowed
for a connection between San Diego and Los Angeles. In 1883, John Frazier and his family settled
on 160 acres near the railroad line, just south of Buena Vista Lagoon. Unfortunately, a lack of
potable water made it difficult for Frazier to farm the land. As a result, he hired expert well borers,
the Mull Brothers, to dig a well on his property in 1885. The boring for the well resulted in the
discovery of both mineral and artesian water at 245 feet, which increased the value of the land by
50 percent. After discovering the water, Frazier constructed a platform near the rail line, called
Frazier’s Station, and gave water to passengers (Carlsbad Historical Society n.d.).
The water from Frazier’s well was tested and found to match the mineral content of Well
Number Nine in the Karlsbad Bohemia Spas. After hearing about Frazier’s well, Gerhard Schutte,
D.D. Wadsworth, Henry Nelson, and Samuel Church Smith came to the area in 1886 and formed
a real estate investment group (the Carlsbad Land and Water Company) in order to associate the
land with the famous Karlsbad Bohemia Spas. Once formed, the Carlsbad Land and Water
Company purchased 270 acres of land from Frazier and 130 acres of coastal lands, all located
outside of the Kelly Rancho Agua Hedionda Land Grant. The company drilled additional wells
and water was piped throughout the newly purchased lands, which Schutte and Wadsworth platted
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as a new townsite. They also built the Carlsbad Hotel in 1888, which was destroyed by a fire in
1896 (Carlsbad Historical Society n.d.) (Plate 3.2–1).
Despite Frazier’s well and the efforts of the Carlsbad Land and Water Company, during
the late 1890s, drought forced farmers in the region to implement dry farming as the primary
method of agriculture. When Robert Kelly died in 1890, Rancho Agua Hedionda passed to his
brother Matthew’s nine children, who subsequently divided up the land among themselves (Plate
3.2–2) (Moyer 1969). The Kelly heirs raised livestock and dry-farmed beans, corn, and hay
(Stropes and Gallegos 2005). Not only did the drought necessitate a change in agricultural
practices, but it also resulted in a land bust. The population of Carlsbad dwindled to nearly 150
people and even Samuel Church Smith and his family left Carlsbad for National City. Alexander
Shipley purchased the Smith home in the 1890s, relocating to the area with his family from
Calistoga (Carlsbad Historical Society n.d.).
Plate 3.2–1: From left to right: John Frazier, his wife and daughter, Gerhard Schutte, Samuel Church Smith, and D.D. Wadsworth standing at the platform in front of Wadsworth’s mansion (left) and the Carlsbad Hotel (right).
(Photograph courtesy of the San Diego History Center)
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Plate 3.2–2: 1896 map of the Kelly Grant division of Rancho Agua Hedionda.
(Map courtesy of the Carlsbad History Room, Carlsbad City Library)
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In 1906, the waterworks sourced by Frazier’s well were no longer operational and Shipley
paid to get the pipelines back up and running. In 1914, the South Coast Land Company drilled
wells in the San Luis Rey Valley and began piping water to Carlsbad. The South Coast Land
Company had also purchased all of the Carlsbad Land and Water Company lands. The new
availability of water caused Carlsbad to once again grow. People, particularly farmers, began
arriving in Carlsbad in great numbers and in 1916, the first avocado grove was planted. The
avocado did so well in the area that the South Coast Land Company began selling larger tracts of
land for the new owners to use for agriculture (Carlsbad Historical Society n.d.).
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4.0 METHODOLOGY
The Phase I cultural resource survey of the 2647 Jefferson Street Homes Project consisted
of institutional records searches, a pedestrian archaeological survey of the project, and preparation
of this report. This study was conducted in conformance with City of Carlsbad guidelines (City
of Carlsbad 2017) and CEQA Section 15064.5 criteria. Specific definitions for archaeological
resource type(s) used in this report are those established by the State Historic Preservation Office
(SHPO 1995). The report format follows the Archaeological Resource Management Report
guidelines. The results of the assessment are discussed in detail in Section 5.0.
4.1 Archaeological Records Search
BFSA requested a records search from the SCIC at SDSU for an area of one-half mile
surrounding the project in order to determine the presence of any previously recorded
archaeological sites. The complete results of the records search are provided in Appendix B and
discussed in Section 5.1. The SCIC search also included a standard review of the National Register
of Historic Places (NRHP) and the Office of Historic Preservation (OHP) Built Environment
Resources Directory (BERD). Land patent records, held by the Bureau of Land Management
(BLM) and accessible through the BLM General Land Office website, were also reviewed for
pertinent project information. In addition, the BFSA research library was consulted for any
relevant historical information.
4.2 Field Methodology
BFSA field archaeologist David Grabski conducted the survey of the 2647 Jefferson Street
Homes Project on June 21, 2024, with the assistance of Aleshawnee Ventura, a San Luis Rey Band
of Mission Indians Native American monitor from Saving Sacred Sites. Parallel survey transects
spaced at approximately five- to 10-meter intervals were utilized throughout the entire project and
photographs were taken to document project conditions (see Section 5.2). The subject property is
developed with a single-family residence and associated hardscape and landscaping.
4.3 Report Preparation and Recordation
This report contains information regarding previous studies, statutory requirements for the
project, a brief description of the setting, research methods employed, and the overall results of
the survey. The report includes all appropriate illustrations and tabular information needed to
make a complete and comprehensive presentation of these activities, including the methodologies
employed and the personnel involved. A copy of this report will be placed at the SCIC at SDSU.
Any newly recorded sites or sites requiring updated information will be recorded on the
appropriate Department of Parks and Recreation site forms, which will be filed at the SCIC.
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4.4 Native American Consultation
A SLF search request was reqested from the NAHC to determine if the proposed project
would affect any known Native American cultural resources. This request is not part of any
Assembly Bill (AB) 52 Native American consultation. The SLF search has been returned with
positive results for potential sites or locations of Native American importance in the vicinity of the
project. The NAHC suggested contacting local Native American groups, specifically the La Jolla
Band of Luiseño Indians and the San Luis Rey Band of Mission Indians, for further information.
During the archaeological survey of the property, Aleshawnee Ventura from the San Luis Rey
Band of Mission Indians was present to monitor and participate. Documentation of
correspondence may be found in Appendix C.
4.5 Applicable Regulations
Resource importance is assigned to districts, sites, buildings, structures, and objects that
possess exceptional value or quality illustrating or interpreting the heritage of Carlsbad in history,
architecture, archaeology, engineering, and culture. Specifically, criteria outlined in CEQA
provide the guidance for making such a determination.
4.5.1 California Environmental Quality Act
According to CEQA, (§15064.5a), the term “historical resource” includes the following:
1) A resource listed in, or determined to be eligible by, the State Historical Resources
Commission, for listing in the CRHR (Public Resources Code [PRC] SS5024.1, Title
14 CCR. Section 4850 et seq.).
2) A resource included in a local register of historical resources, as defined in Section
5020.1(k) of the PRC or identified as significant in a historical resource survey meeting
the requirements of Section 5024.1(g) of the PRC, shall be presumed to be historically
or culturally significant. Public agencies must treat any such resource as significant
unless the preponderance of evidence demonstrates that it is not historically or
culturally significant.
3) Any object, building, structure, site, area, place, record, or manuscript, which a lead
agency determines to be historically significant or significant in the architectural,
engineering, scientific, economic, agricultural, educational, social, political, military,
or cultural annals of California may be considered a historical resource, provided the
lead agency’s determination is supported by substantial evidence in light of the whole
record. Generally, a resource shall be considered by the lead agency to be “historically
significant” if the resource meets the criteria for listing on the CRHR (PRC SS5024.1,
Title 14, Section 4852), including the following:
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a) Is associated with events that have made a significant contribution to the broad
patterns of California’s history and cultural heritage;
b) Is associated with the lives of persons important in our past;
c) Embodies the distinctive characteristics of a type, period, region, or method of
construction, or represents the work of an important creative individual, or
possesses high artistic values; or
d) Has yielded, or may be likely to yield, information important in prehistory or
history.
4) The fact that a resource is not listed in, or determined eligible for listing in, the CRHR,
not included in a local register of historical resources (pursuant to Section 5020.1[k] of
the PRC), or identified in a historical resources survey (meeting the criteria in Section
5024.1[g] of the PRC) does not preclude a lead agency from determining that the
resource may be a historical resource as defined in PRC Section 5020.1(j) or 5024.1.
According to CEQA, Section 15064.5(b), a project with an effect that may cause a
substantial adverse change in the significance of a historical resource is a project that may have a
significant effect upon the environment. CEQA defines a substantial adverse change as:
1) Substantial adverse change in the significance of a historical resource means physical
demolition, destruction, relocation, or alteration of the resource or its immediate
surroundings such that the significance of a historical resource would be materially
impaired.
2) The significance of a historical resource is materially impaired when a project:
a) Demolishes or materially alters in an adverse manner those physical
characteristics of a historical resource that convey its historical significance and
that justify its inclusion in, or eligibility for, inclusion in the CRHR; or
b) Demolishes or materially alters in an adverse manner those physical
characteristics that account for its inclusion in a local register of historical
resources pursuant to Section 5020.1(k) of the PRC or its identification in a
historical resources survey meeting the requirements of Section 5024.1(g) of
the PRC, unless the public agency reviewing the effects of the project
establishes by a preponderance of evidence that the resource is not historically
or culturally significant; or,
c) Demolishes or materially alters in an adverse manner those physical
characteristics of a historical resource that convey its historical significance and
that justify its eligibility for inclusion in the CRHR as determined by a lead
agency for purposes of CEQA.
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Section 15064.5(c) of CEQA applies to effects upon archaeological sites and contains the
following additional provisions regarding archaeological sites:
1. When a project will impact an archaeological site, a lead agency shall first determine
whether the site is a historical resource, as defined in subsection (a).
2. If a lead agency determines that the archaeological site is a historical resource, it shall
refer to the provisions of Section 21084.1 of the PRC, Section 15126.4 of the
guidelines, and the limits contained in Section 21083.2 of the PRC do not apply.
3. If an archaeological site does not meet the criteria defined in subsection (a) but does
meet the definition of a unique archaeological resource in Section 21083.2 of the PRC,
the site shall be treated in accordance with the provisions of Section 21083.2. The time
and cost limitations described in PRC Section 21083.2(c-f) do not apply to surveys and
site evaluation activities intended to determine whether the project location contains
unique archaeological resources.
4. If an archaeological resource is neither a unique archaeological nor historical resource,
the effects of the project upon those resources shall not be considered a significant
effect upon the environment. It shall be sufficient that both the resource and the effect
upon it are noted in the Initial Study or Environmental Impact Report, if one is prepared
to address impacts upon other resources, but they need not be considered further in the
CEQA process.
Sections 15064.5(d) and (e) contain additional provisions regarding human remains.
Regarding Native American human remains, paragraph (d) provides:
(d) When an Initial Study identifies the existence of, or the probable likelihood of, Native
American human remains within the project, the lead agency shall work with the
appropriate Native Americans as identified by the NAHC, as provided in PRC
SS5097.98. The applicant may develop an agreement for treating or disposing of, with
appropriate dignity, the human remains and any items associated with Native American
burials with the appropriate Native Americans as identified by the NAHC. Action
implementing such an agreement is exempt from:
1) The general prohibition on disinterring, disturbing, or removing human remains
from any location other than a dedicated cemetery (Health and Safety Code
Section 7050.5).
2) The requirements of CEQA and the Coastal Act.
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5.0 RESULTS
5.1 Records Search Results
An archaeological records search for the project and the surrounding area within a one-
half-mile radius was conducted by the SCIC at SDSU (Appendix B). The search results identified
21 cultural resources and eight historic addresses within one-half mile of the project, none of which
are located within the project boundaries. Of the previously recorded resources, six are prehistoric,
two are multicomponent, and 13 are historic (Table 5.1–1). The prehistoric sites include two
campsites, two shell middens, one shell scatter, and one isolate. The multicomponent sites consist
of one site containing a historic trash scatter and a prehistoric shell scatter and one site containing
a historic road and prehistoric shell scatter. The historic sites consist of 12 built resources and one
trash deposit.
Table 5.1–1
Previously Recorded Archaeological Sites Within One-Half Mile of the Project
Site Number(s) Site Description
SDI-626 and SDI-627 Prehistoric campsite
SDI-628 and SDI-17,672 Prehistoric shell midden
SDI-8455 Prehistoric shell scatter
P-37-033873 Prehistoric isolate
SDI-21,274 Historic road and prehistoric shell scatter
SDI-22,605 Historic trash scatter and prehistoric shell scatter
P-37-037183 Historic multifamily residence
P-37-037182 and P-37-037187 Historic single-family residence
P-37-029985 Historic government building
P-37-037178 Historic bridge
P-37-037179 Historic motel building
P-37-037180, P-37-037181, P-37-037184 P-37-037188, and P-37-037191 Historic commercial building
P-37-037185 Historic railroad depot
SDI-21,704 Historic trash deposit
The results of the SCIC records search also indicate that 31 archaeological investigations
have been conducted within one-half mile of the subject property, two of which are mapped as
overlapping the current study area (Seeman 1982; Byrd and O’Neill 2002). The previous studies
consist of a Draft Environmental Impact Report for the City of Carlsbad Parks and Recreation
Element (Seeman 1982) and a study pertaining to improvements to Interstate 5 (Byrd and O’Neill
2002). As such, both are large overviews and do not directly address the subject property.
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Regardless, no cultural resources were identified within the project boundaries as a result of either
study.
The following historic resources were also consulted:
• The NRHP index
• The OHP Archaeological Determinations of Eligibility
• The OHP BERD
• 1938 to 2023 aerial photographs
• 1893, 1898, 1901, and 1942 Oceanside, California topographic maps (15-minute)
• 1948, 1949, 1968, and 1997 San Luis Rey, California topographic maps (7.5-minute)
None of these sources identified any potential archaeological resources. The 1938 aerial
photograph shows the property as vacant agricultural land with some surrounding residential
development. By 1947, the property is still undeveloped with buildings on properties directly to
the north and south. By 1953 the subject property had been cleared, and by 1956, the current 2647
Jefferson Street residence had been constructed on the eastern half of the subject property. From
1938 to 1978, aerial images demonstrate the existence of a grove of trees on the western half of
the property until their clearance by 1978. Subsequent photographs show increased development
in the surrounding neighborhood but little to no change to the subject property.
The NAHC SLF search was requested to identify any potentially sacred or ceremonial sites
or landforms on or near the project. This request is not part of any AB 52 Native American
consultation. The SLF search has been returned with positive results for potential sites or locations
of Native American importance within the vicinity. The NAHC suggested contacting local Native
American groups, specifically the La Jolla Band of Luiseño Indians and the San Luis Rey Band of
Mission Indians, for further information. This additional outreach will be conducted by the City
of Carlsbad during AB 52 consulation. During the archaeological survey of the property,
Aleshawnee Ventura from the San Luis Rey Band of Mission Indians was present to monitor and
participate. Documentation of correspondence may be found in Appendix C.
5.2 Field Investigation The archaeological survey was completed on June 21, 2024, by field archaeologist David
Grabski with participation by Aleshawnee Ventura, a San Luis Rey Band of Mission Indians
Native from Saving Sacred Sites. Aerial photographs, maps, and a mobile Trimble Global
Positioning System unit permitted orientation and location of the project boundaries. The entire
0.34-acre property was surveyed by employing five- to 10-meter transects. A survey form, field
notes, and photographs documented the survey work undertaken.
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The eastern half of the property is developed with a single-family residence and a concrete
driveway. The western half includes the backyard, which contains a maintained lawn, several
trees, and covered storage areas (Plates 5.2‒1 to 5.2‒4). Given the current residential development
within the project, visibility was limited to the landscaped areas found in the front and back yards.
The various planters surrounding the residence and disturbed soil from rodent burrows were
carefully inspected. The single-family residence was constructed between 1953 and 1956.
Although the building is historic in age, the applicant has indicated it will be evaluated separately
from the current study as part of a historic structure analysis. No archaeological resources were
identified during the current survey but the ability to identify archaeological resources on the
property was partially limited by the current development.
Plate 5.2‒1: Overview of the project from the southeast corner, facing northwest.
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Plate 5.2‒3: Overview of the project from the rear of the residence, facing east.
Plate 5.2‒2: Overview of the project from the southwest corner of the backyard, facing northeast.
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Plate 5.2‒4: Overview from northeast corner of the backyard, facing east.
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6.0 RECOMMENDATIONS
The archaeological study of the 2647 Jefferson Street Homes Project consisted of a survey
program and research of available archaeological records. An analysis of archaeological
information concerning this property indicates no previously recorded cultural resources are
located within the project boundaries. Further, no archaeological artifacts, features, or darkened
midden soils were observed during the survey. While the investigation of the 0.34-acre property
did not identify any archaeological resources, the extant residence and surrounding area were
constructed prior to CEQA and the implementation of environmental laws necessitating cultural
resource studies. When land is cleared or otherwise disturbed, evidence of surface artifact scatters
is typically lost. As such, whether any archaeological resources ever existed within the project
prior to the development of the current single-family residence is unclear.
As a result of the prior development of the property, the level of disturbance to the natural
soil beneath the current building and hardscape is unknown. When conisdered along with the
project location and the records search and NAHC SLF results, it is recommended that the project
be conditioned with archaeological and Native American monitoring for the initial ground
disturbances associated with the redevelopment of the subject parcel. The monitoring program
should follow the protocols and standard treatment options outlined in the Carlsbad Tribal,
Cultural, and Paleontological Resources Guidelines (City of Carlsbad 2017) to facilitate the
identification and review of any subsurface cultural resources that may be potentially exposed
during grading.
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7.0 CERTIFICATION
I hereby certify that the statements furnished above and in the attached exhibits present the
data and information required for this archaeological report, and that the facts, statements, and
information presented are true and correct to the best of my knowledge and belief, and have been
compiled in accordance with CEQA criteria as defined in Section 15064.5 and City of Carlsbad
cultural resource criteria.
July 8, 2024
Andrew J. Garrison Date
Project Archaeologist
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8.0 REFERENCES CITED
Bancroft, Hubert Howe
1886 History of California (Volume V; 1846-1848). The History Company, San Francisco, California.
Beauchamp, R. Mitchel 1986 A Flora of San Diego County, California. Sweetwater River Press, National City,
California.
Bean, Lowell John and Florence C. Shipek
1978 Luiseño. In Handbook of North American Indians, Volume 8: California, edited by
R.F. Heizer. Smithsonian Institution, Washington, D.C.
Bedwell, S.F.
1970 Prehistory and Environment of the Pluvial Fort Rock Area of South-central Oregon. Ph.D. dissertation. Department of Anthropology, University of Oregon, Eugene.
Blick, J.D. 1976 Agriculture in San Diego County. In San Diego–An Introduction to the Area. Edited
by Philip Pryde. Kendall/Hunt Publishing Company, Dubuque, Iowa
Bowman, R.H., A.A. House, G. Kester, D.D. Estrada, J.K. Wachtell, G.L. Anderson, and P.V.
Campo
1973 Soil Survey of the San Diego Area, California. Part I. Soil Conservation Service, U.S. Department of Agriculture, Washington, D.C.
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Strong, William Duncan 1929 Aboriginal Society in Southern California. University of California Publications in
American Archaeology and Ethnology 26 (1). Stropes, Tracy A. and Dennis R. Gallegos 2005 Cultural Resource Data Recovery and Indexing and Preservation Program for the Grand Pacific Resorts Site CA-SDI-8797 Area A, City of Carlsbad, California. Gallegos & Associates. Unpublished report on file at the South Coastal InformationCenter at San Diego State University, San Diego, California. True, D.L. 1958 An Early Complex in San Diego County, California. American Antiquity 23(3). 1980 The Pauma Complex in Northern San Diego County: 1978. Journal of New World
Archaeology 3(4). Institute of Archaeology, University of California, Los Angeles. True, D.L., C.W. Meighan, and Harvey Crew 1974 Archaeological Investigations at Molpa, San Diego County, California. University of
California Publications in Anthropology (11), Berkeley. Van Dyke, Theodore 1886 Southern California. Fords, Howard and Hulbert. Wallace, William J. 1955 A Suggested Chronology for Southern California Coastal Archaeology. Southwestern
Journal of Anthropology 11(3). Albuquerque, New Mexico. Walker, E.F. 1951 Five Prehistoric Sites in Los Angeles County, California. Publications of the Frederick
Webb Hodge Anniversary Publication Fund 6:1–116 Warren, Claude N. 1966 The San Dieguito Type Site: Malcolm J. Rogers’s 1938 Excavation on the San Dieguito River. San Diego Museum Papers (6). 1967 The San Dieguito Complex: A Review and Hypothesis. American Antiquity, 2(2). Salt Lake City, Utah. 1968 Cultural Tradition and Ecological Adaptation on the Southern California Coast. In
Archaic Prehistory in the Western United States. Edited by C. Irwin-Williams.
Eastern New Mexico Contributions in Anthropology 1(3). Warren, Claude N. and D.L. True 1961 The San Dieguito Complex and Its Place in California Prehistory. Archaeological
Survey Annual Report 1960-1961:246–337. University of California, Los Angeles.
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WESTEC Services, Inc. 1975 Rimbach Property Archaeological Report. Unpublished report on file at the South Coastal Information Center at San Diego State University, San Diego, California. Wirths, Todd A. 2024 Paleontological Assessment for the 2647 Jefferson Street Project, Carlsbad, San Diego County, California. BFSA Environmental Services, a Perennial Company (BFSA). Report on file at BFSA, Poway, California.
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APPENDIX A
Resumes of Key Personnel
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Education
Master of Arts, Public History, University of California, Riverside 2009
Bachelor of Science, Anthropology, University of California, Riverside 2005
Bachelor of Arts, History, University of California, Riverside 2005
Professional Memberships
Register of Professional Archaeologists Society for California Archaeology
Society for American Archaeology
California Council for the Promotion of History
Society of Primitive Technology Lithic Studies Society
California Preservation Foundation
Pacific Coast Archaeological Society
Experience
Project Archaeologist June 2017–Present BFSA Environmental Serives, A Perennial Company Poway, California
Project management of all phases of archaeological investigations for local, state, and federal
agencies including National Register of Historic Places (NRHP) and California Environmental Quality Act (CEQA) level projects interacting with clients, sub-consultants, and lead agencies. Supervise and
perform fieldwork including archaeological survey, monitoring, site testing, comprehensive site records
checks, and historic building assessments. Perform and oversee technological analysis of prehistoric lithic assemblages. Author or co-author cultural resource management reports submitted to private clients and lead agencies.
Senior Archaeologist and GIS Specialist 2009–2017 Scientific Resource Surveys, Inc. Orange, California
Served as Project Archaeologist or Principal Investigator on multiple projects, including archaeological
monitoring, cultural resource surveys, test excavations, and historic building assessments. Directed
projects from start to finish, including budget and personnel hours proposals, field and laboratory direction, report writing, technical editing, Native American consultation, and final report submittal.
Oversaw all GIS projects including data collection, spatial analysis, and map creation.
Preservation Researcher 2009 City of Riverside Modernism Survey Riverside, California
Completed DPR Primary, District, and Building, Structure and Object Forms for five sites for a grant-
funded project to survey designated modern architectural resources within the City of Riverside.
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Information Officer 2005, 2008–2009 Eastern Information Center (EIC), University of California, Riverside Riverside, California
Processed and catalogued restricted and unrestricted archaeological and historical site record forms.
Conducted research projects and records searches for government agencies and private cultural
resource firms.
Reports/Papers
2019 A Class III Archaeological Study for the Tuscany Valley (TM 33725) Project National Historic
Preservation Act Section 106 Compliance, Lake Elsinore, Riverside County, California. Contributing author. Brian F. Smith and Associates, Inc.
2019 A Phase I and II Cultural Resources Assessment for the Jack Rabbit Trail Logistics Center Project,
City of Beaumont, Riverside County, California. Brian F. Smith and Associates, Inc.
2019 A Phase I Cultural Resources Assessment for the 10575 Foothill Boulevard Project, Rancho
Cucamonga, California. Brian F. Smith and Associates, Inc.
2019 Cultural Resources Study for the County Road and East End Avenue Project, City of Chino, San
Bernardino County, California. Brian F. Smith and Associates, Inc.
2019 Phase II Cultural Resource Study for the McElwain Project, City of Murrieta, California. Contributing author. Brian F. Smith and Associates, Inc.
2019 A Section 106 (NHPA) Historic Resources Study for the McElwain Project, City of Murrieta,
Riverside County, California. Brian F. Smith and Associates, Inc.
2018 Cultural Resource Monitoring Report for the Sewer Group 818 Project, City of San Diego. Brian F.
Smith and Associates, Inc. 2018 Phase I Cultural Resource Survey for the Stone Residence Project, 1525 Buckingham Drive, La
Jolla, California 92037. Brian F. Smith and Associates, Inc.
2018 A Phase I Cultural Resources Assessment for the Seaton Commerce Center Project, Riverside
County, California. Brian F. Smith and Associates, Inc.
2017 A Phase I Cultural Resources Assessment for the Marbella Villa Project, City of Desert Hot Springs, Riverside County, California. Brian F. Smith and Associates, Inc.
2017 Phase I Cultural Resources Survey for TTM 37109, City of Jurupa Valley, County of Riverside. Brian
F. Smith and Associates, Inc.
2017 A Phase I Cultural Resources Assessment for the Winchester Dollar General Store Project,
Riverside County, California. Brian F. Smith and Associates, Inc.
2016 John Wayne Airport Jet Fuel Pipeline and Tank Farm Archaeological Monitoring Plan. Scientific
Resource Surveys, Inc. On file at the County of Orange, California.
2016 Historic Resource Assessment for 220 South Batavia Street, Orange, CA 92868 Assessor’s Parcel Number 041-064-4. Scientific Resource Surveys, Inc. Submitted to the City of Orange as part of
Mills Act application.
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2015 Historic Resource Report: 807-813 Harvard Boulevard, Los Angeles. Scientific Resource Surveys, Inc. On file at the South Central Coastal Information Center, California State University, Fullerton.
2015 Exploring a Traditional Rock Cairn: Test Excavation at CA-SDI-13/RBLI-26: The Rincon Indian
Reservation, San Diego County, California. Scientific Resource Surveys, Inc.
2014 Archaeological Monitoring Results: The New Los Angeles Federal Courthouse. Scientific
Resource Surveys, Inc. On file at the South Central Coastal Information Center, California State
University, Fullerton.
2012 Bolsa Chica Archaeological Project Volume 7, Technological Analysis of Stone Tools, Lithic
Technology at Bolsa Chica: Reduction Maintenance and Experimentation. Scientific Resource
Surveys, Inc.
Presentations
2017 “Repair and Replace: Lithic Production Behavior as Indicated by the Debitage Assemblage from
CA-MRP-283 the Hackney Site.” Presented at the Society for California Archaeology Annual Meeting, Fish Camp, California.
2016 “Bones, Stones, and Shell at Bolsa Chica: A Ceremonial Relationship?” Presented at the Society
for California Archaeology Annual Meeting, Ontario, California.
2016 “Markers of Time: Exploring Transitions in the Bolsa Chica Assemblage.” Presented at the Society
for California Archaeology Annual Meeting, Ontario, California. 2016 “Dating Duress: Understanding Prehistoric Climate Change at Bolsa Chica.” Presented at the
Society for California Archaeology Annual Meeting, Ontario, California.
2014 “New Discoveries from an Old Collection: Comparing Recently Identified OGR Beads to Those
Previously Analyzed from the Encino Village Site.” Presented at the Society for California
Archaeology Annual Meeting, Visalia, California.
2012 Bolsa Chica Archaeology: Part Seven: Culture and Chronology. Lithic demonstration of experimental manufacturing techniques at the April meeting of The Pacific Coast
Archaeological Society, Irvine, California.
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APPENDIX B
Archaeological Records Search Results
(Deleted for Public Review; Bound Separately)
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APPENDIX C
NAHC Sacred Lands File Search
(Deleted for Public Review; Bound Separately)
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PALEONTOLOGICAL ASSESSMENT
FOR THE 2647 JEFFERSON
STREET HOMES PROJECT
CARLSBAD, SAN DIEGO COUNTY, CALIFORNIA
APN 155-170-24
Lead Agency:
City of Carlsbad Planning Department 1635 Faraday Avenue
Carlsbad, California 92008
Preparer:
BFSA Environmental Services,
a Perennial Company
14010 Poway Road, Suite A
Poway, California 92064
Project Proponent:
Rincon Homes 5315 Avenida Encinas, Suite 200 Carlsbad, California 92008 July 8, 2024
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Paleontological Database Information
Author: Todd A. Wirths, M.S., Senior Paleontologist, California Professional Geologist No. 7588
Consulting Firm: BFSA Environmental Services, a Perennial Company 14010 Poway Road, Suite A Poway, California 92064
(858) 484-0915
Report Date: July 8, 2024 Report Title: Paleontological Assessment for the 2647 Jefferson Street Homes
Project, Carlsbad, San Diego County, California
Prepared for: Rincon Homes 5315 Avenida Encinas, Suite 200 Carlsbad, California 92008
Submitted to: City of Carlsbad Planning Department 1635 Faraday Avenue Carlsbad, California 92018
USGS Quadrangle: Section 1, Township 12 South, Range 5 West of the San
Luis Rey, California (7.5-minute) Quadrangle Study Area: 0.34 acre
Assessor’s Parcel Number: 155-170-24 Key Words: Paleontological assessment; Pleistocene old paralic deposits; high sensitivity; City of Carlsbad; monitoring recommended.
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Table of Contents
Section Page
I. INTRODUCTION AND LOCATION .........................................................................1
II. REGULATORY SETTING .........................................................................................1
State of California ......................................................................................................1
III. GEOLOGY .................................................................................................................4
IV. PALEONTOLOGICAL RESOURCES ......................................................................6
Definition ....................................................................................................................6
Fossil Locality Search .................................................................................................6
V. PALEONTOLOGICAL SENSITIVITY ....................................................................6
Overview .....................................................................................................................6
Professional Standard .................................................................................................7
City of Carlsbad Assessment .......................................................................................7
VI. CONCLUSIONS AND RECOMMENDATIONS .....................................................8
VII. CERTIFICATION ......................................................................................................9
VIII. REFERENCES ..........................................................................................................9
Appendices
Appendix A – Qualifications of Key Personnel
List of Figures
Figure Page
Figure 1 General Location Map .................................................................................2
Figure 2 Project Location Map ...................................................................................3
Figure 3 Geologic Map...............................................................................................5
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I. INTRODUCTION AND LOCATION
A paleontological resource assessment has been completed for the 2647 Jefferson Street
Project, located on the west side of Jefferson Street between Knowles Avenue and Laguna Drive
in the northwest corner of the city of Carlsbad, San Diego County, California (Figures 1 and 2).
The project consists of one 0.34-acre parcel (Assessor’s Parcel Number [APN] 155-170-24) west
of Interstate 5. On the U.S. Geological Survey (USGS) (7.5-minute) 1:24,000-scale San Luis Rey,
California topographic quadrangle map, the project is located in Section 1, Township 12 South,
Range 5 West of the San Bernardino Baseline and Meridian. The project includes plans to
construct two three-story residential buildings totaling 12 units, garages, and associated hardscape
and landscape. Currently, a single-family residential building occupies the parcel and is proposed
to be demolished.
As the lead agency, the City of Carlsbad has required the preparation of a paleontological
assessment to evaluate the project’s potential to yield paleontological resources. The
paleontological assessment of the project included a review of paleontological literature and fossil
locality records in the area, a review of the underlying geology, and recommendations to monitor
for impacts to potential paleontological resources, if necessary. The project parcel was not
surveyed, since the entire property has been graded and developed with the existing structure.
II. REGULATORY SETTING
The California Environmental Quality Act (CEQA), which is patterned after the National
Environmental Policy Act, is the overriding environmental regulation that sets the requirement for
protecting California’s paleontological resources. CEQA mandates that governing permitting
agencies (lead agencies) set their own guidelines for the protection of nonrenewable
paleontological resources under their jurisdiction.
State of California
Under “Guidelines for Implementation of the California Environmental Quality Act,” as
amended in December 2018 (California Code of Regulations [CCR] Title 14, Division 6, Chapter
3, Sections 15000 et seq.), procedures define the types of activities, persons, and public agencies
required to comply with CEQA. Section 15063 of the CCR provides a process by which a lead
agency may review a project’s potential impact to the environment, whether the impacts are
significant, and provide recommendations, if necessary.
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In CEQA’s Environmental Checklist Form, a question to respond to is, “Would the project
directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?”
(Appendix G, Section VII, Part f). This is to ensure compliance with California Public Resources
Code Section 5097.5, the law that protects nonrenewable resources including fossils, which is
paraphrased below:
a) A person shall not knowingly and willfully excavate upon, or remove, destroy,
injure, or deface, any historic or prehistoric ruins, burial grounds,
archaeological or vertebrate paleontological site, including fossilized
footprints, inscriptions made by human agency, rock art, or any other
archaeological, paleontological or historical feature, situated on public lands,
except with the express permission of the public agency having jurisdiction over
such lands.
b) As used in this section, “public lands” means lands owned by, or under the
jurisdiction of, the state, or any city, county, district, authority, or public
corporation, or any agency thereof.
c) A violation of this section is a misdemeanor.
III. GEOLOGY
The project is approximately one-half mile northeast of the coastline and near the southern
shore of Buena Vista Lagoon (see Figure 2). Geomorphically, the project property occupies an
elevated (emergent) marine terrace, with the project parcel at an elevation of about 60 feet
(approximately 18 meters). Geologically, as shown on Figure 3 after Kennedy and Tan (2007),
multiple marine terraces in the project area’s terrace complex have truncated the older, underlying
Eocene-aged (43 to 46 million years old) Santiago Formation (brown areas labeled as “Tsa” on
Figure 3), and refer to the terrace sediments, including their overlying alluvial and colluvial
deposits, as Pleistocene “old paralic deposits” (symbolized as “Qop2-4” and “Qop6-7” on Figure
3). As shown on Figure 3, the project is mapped as underlain by younger old paralic deposits
(Qop6-7), where Kennedy and Tan (2007) grouped deposits of the “Bird Rock terrace”
(approximately 80,000 years old) with deposits of the older (higher and slightly farther inland)
“Nestor terrace” (approximately 120,000 years old).
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IV. PALEONTOLOGICAL RESOURCES
Definition
Paleontological resources are the remains of prehistoric life that have been preserved in
geologic strata. These remains are called fossils and include bones, shells, teeth, and plant remains
(including their impressions, casts, and molds) in the sedimentary matrix, as well as trace fossils
such as footprints and burrows. Fossils are considered older than 5,000 years of age (Society of
Vertebrate Paleontology 2010), but may include younger remains (subfossils) when viewed in the
context of local extinction of the organism or habitat, for example. Fossils are considered a
nonrenewable resource under state and local guidelines (Sections II and V of this report).
Fossil Locality Search
A literature search and an examination of museum and university fossil collections and/or
locality records of the San Diego Society of Natural History (SDSNH) revealed a number of nearby
fossil localities assigned to upper Pleistocene terrace and estuarine deposits, all located north of
the project along the northern edge of Buena Vista Lagoon. The closest is SDSNH locality (loc.)
4007, located less than one mile to the north, which yielded a partial mammoth tusk. Several
additional SDSNH localities, rich with late Pleistocene marine invertebrate fossils, were recovered
at the Pacific Coast Plaza Project that borders State Route 78 in Oceanside (SDSNH locs. 4024
through 4033). These localities represent a diverse assemblage of mollusks, shark teeth, and
unidentified mammal remains (Deméré and Riney 2000) and represent marine high-stand
conditions of approximately 300,000 to 400,000 years ago (Kennedy and Browne 2007).
More late Pleistocene invertebrate fossils were reported by Peska (1976), indicating the
presence of eight species of bivalves and one gastropod species just over one and a half miles east
of the project, near where El Camino Real crosses Buena Vista Creek. A project west of Vine
Street and north of Oceanside Avenue and Loma Alta Creek in Oceanside yielded a small
molluscan fauna (SDSNH loc. 7569) from fossiliferous, muddy clay beds of unmapped late
Pleistocene estuarine deposits (Wirths and Kennedy 2019). A Pleistocene whale rib was
discovered about 25 feet deep at the Oceanside Beachfront Resort project, approximately two and
a half miles up the coast (Wirths 2020). Several localities from the Oligocene-aged Sespe-
Vaqueros Formation are known just south of Agua Hedionda Lagoon, and about two miles north
at the Oceanside Mesa Project. V. PALEONTOLOGICAL SENSITIVITY
Overview
The degree of paleontological sensitivity of any particular area is based on a number of
factors, including the documented presence of fossiliferous resources on a site or in nearby areas,
the presence of documented fossils within a particular geologic formation or lithostratigraphic unit,
and whether or not the original depositional environment of the sediments is one that might have
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been conducive to the accumulation of organic remains that may have become fossilized over time.
Pleistocene terrace deposits are known to yield important marine fossils, such as bivalve and
gastropod mollusks, and vertebrates, such as sharks, rays, and, more rarely, camel and horse bones.
These Pleistocene sediments are thus accorded a moderate to high paleontological resource
sensitivity (Deméré and Walsh 1993). The Santiago and Sespe-Vaqueros formations have proven
records for yielding significant fossils in northwestern San Diego County (Walsh 1996; Randall et
al. 2004).
Professional Standard
The Society of Vertebrate Paleontology (2010) has drafted guidelines that include four
categories of paleontological sensitivity for geologic units (formations) that might be impacted by
a proposed project, as listed below:
● High Potential: Rock units from which vertebrate or significant invertebrate, plant, or
trace fossils have been recovered.
● Undetermined Potential: Rock units for which little information is available
concerning their paleontological content, geologic age, and depositional environment,
and that further study is needed to determine the potential of the rock unit.
● Low Potential: Rock units that are poorly represented by fossil specimens in
institutional collections or based upon a general scientific consensus that only preserve
fossils in rare circumstances.
● No Potential: Rock units that have no potential to contain significant paleontological
resources, such as high-grade metamorphic rocks and plutonic igneous rocks.
Using these criteria, based on the geologic formations at the project, the Pleistocene old paralic
deposits can be considered to have a high potential to yield significant paleontological resources.
City of Carlsbad Assessment
The City of Carlsbad has assigned sensitivity ratings of paleontological potential to
geologic formations within the city limits (City of Carlsbad 2017). The geologic unit mapped
within the project, the Pleistocene old paralic deposits, is assigned a high paleontological
sensitivity. Geologic units assigned a high sensitivity are said by the City of Carlsbad (2017) to
“…have the highest potential to produce unique invertebrate fossil assemblages or unique
vertebrate fossil remains.”
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VI. CONCLUSIONS AND RECOMMENDATIONS
Due to the potential to encounter buried significant paleontological resources, the
preparation of a Paleontological Monitoring Plan (PMP) is recommended if earth disturbance
activities are planned, in accordance with Section 10.4.2 of the City’s paleontological resource
guidelines (City of Carlsbad 2017:105). The PMP should be submitted to and approved by the
City of Carlsbad as a condition of approval prior to the issuance of grading permits by the City of
Carlsbad’s Planning Department. In a PMP, the City specifies the following information, “as
applicable and appropriate”:
• The level of monitoring (spot checks, part-time, or full-time), protocols and
authorization for work stoppages, and safety procedures
• The need for contractor awareness training for all earthmoving personnel for any
projects where a monitor will not be present full time
• A research design listing the research questions and the data requirements for those
questions
• The level and type of assistance from the contractor needed by the paleontologist to
take bulk samples and place them into a safe area for processing
• The methods for fossil collection, fossil preparation, fossil identification, conducting
stratigraphic profiles, and curation
• The types of progress reports that will be provided to the project proponent and the City
(weekly or monthly)
• The schedule for reporting
• A recommendation for updating the paleontology sensitivity model, which takes into
consideration the presence or absence of paleontological resources, the amount of
ground disturbance, and the potential for future discoveries
• The identity of the financially responsible party
All mitigation programs should be performed by a qualified professional (project)
paleontologist, defined as an individual with a master’s degree or doctorate. in paleontology or
geology who has proven experience in San Diego County paleontology and who is knowledgeable
in professional paleontological procedures and techniques. Fieldwork may be conducted by a
qualified paleontological monitor, defined as an individual who has experience in the collection
and salvage of fossil materials. The paleontological monitor shall always work under the direction
of a qualified paleontologist.
Oct.. 15, 2025 Item #1 312 of 343
VII. CERTIFICATION
I hereby certify that the statements furnished above and in the attached exhibits present the
data and information required for this paleontological report, and that the facts, statements, and
information presented are true and correct to the best of my knowledge and belief and have been
compiled in accordance with CEQA criteria.
July 8, 2024
Todd A. Wirths Date
Senior Paleontologist
California Professional Geologist No. 7588 VIII. REFERENCES
City of Carlsbad. 2017. Carlsbad Tribal, Cultural, and Paleontological Resources Guidelines.
Prepared for the City of Carlsbad, California, by ECORP Consulting, Inc.
Deméré, T.A. and Riney, B.O. 2000. Paleoenvironments, paleoecology, and molluscan
paleontology of a late Pleistocene bay, Oceanside, San Diego County, California. Western
Society of Malacologists, Annual Report, 32:13–14.
Deméré, T.A. and Walsh, S.L. 1993. Paleontological resources – County of San Diego. Report
prepared for the San Diego County Department of Public Works, San Diego, by the
Department of Paleontology, San Diego Natural History Museum. Pp. i-iii + 1-68, figs. 1-
3, 8 maps.
Kennedy, G.L. and Browne, I.D. 2007. Paleontology and geochronology of the middle and upper
Pleistocene marine record in the downtown San Diego area, San Diego County, southern
California. Western Society of Malacologists, Annual Report, 36: 13-34, fig. 1, tables 1-2.
Kennedy, M.P. and Tan, S.S. 2007. Geologic map of the Oceanside 30' x 60' quadrangle,
California. California Geological Survey, Regional Geologic Map Series, 1:100,000 scale,
Map No. 2.
Peska, F.J. 1976. A day’s digging in San Diego County. Paleontological News; Bulletin of the
Southern California Paleontological Society, vol. 8, no. 5, 6, and 7 (July).
Oct.. 15, 2025 Item #1 313 of 343
Randall, K.A., Wagner, H.M., Riney, B.O., and Roeder, M.A. 2004. A Late Pleistocene
(Rancholabrean) vertebrate assemblage from Oceanside, San Diego County, California.
Southern California Academy of Sciences, Abstracts of Papers, v.103:2(suppl.), p. 18.
Society of Vertebrate Paleontology. 2010. Standard procedures for the assessment and mitigation
of adverse impacts to paleontological resources; by the SVP Impact Mitigation Guidelines
Revision Committee. https://vertpaleo.org/wp-content/uploads/2021/01/SVP_Impact_
Mitigation_Guidelines-1.pdf.
Walsh, S.L. 1996. Middle Eocene mammal faunas of San Diego County, California. In Prothero,
D.R., and Emry, R.J., eds., The terrestrial Eocene-Oligocene transition in North America.
Cambridge University Press, Cambridge, UK. Pp. 75-119, figs. 1-7, tables 1-9.
Wirths, T.A. 2020. Paleontological Monitoring Report for the Oceanside Beachfront Resort
Project, Oceanside, California. Unpublished paleontological monitoring report prepared
for S.D. Malkin Properties, San Diego, California, by Brian F. Smith and Associates, Inc.,
Poway, California.
Wirths, T.A. and Kennedy, G.L. 2019. Paleontological Monitoring Report, Oceanside 2 (The
Tides), Oceanside, San Diego County, California, City of Oceanside Development Plan
No. D15-00010. Unpublished paleontological monitoring report prepared for City
Ventures LLC, Irvine, California, by Brian F. Smith and Associates, Inc., Poway,
California.
Oct.. 15, 2025 Item #1 314 of 343
APPENDIX A
Qualifications of Key Personnel
Oct.. 15, 2025 Item #1 315 of 343
Education
Master of Science, Geological Sciences, San Diego State University, California 1995
Bachelor of Arts, Earth Sciences, University of California, Santa Cruz 1992
Professional Certifications
California Professional Geologist #7588, 2003
Riverside County Approved Paleontologist San Diego County Qualified Paleontologist
Orange County Certified Paleontologist
OSHA HAZWOPER 40-hour trained; current 8-hour annual refresher
Professional Memberships
Board member, San Diego Geological Society
San Diego Association of Geologists; past President (2012) and Vice President (2011)
South Coast Geological Society
Southern California Paleontological Society
Experience
Mr. Wirths has more than a dozen years of professional experience as a senior-level paleontologist
throughout southern California. He is also a certified California Professional Geologist. At BFSA, Mr. Wirths conducts on-site paleontological monitoring, trains and supervises junior staff, and performs all
research and reporting duties for locations throughout Los Angeles, Ventura, San Bernardino, Riverside,
Orange, San Diego, and Imperial Counties. Mr. Wirths was formerly a senior project manager
conducting environmental investigations and remediation projects for petroleum hydrocarbon-impacted sites across southern California.
Selected Recent Reports 2019 Paleontological Assessment for the 10575 Foothill Boulevard Project, City of Rancho Cucamonga, San Bernardino County, California. Prepared for T&B Planning, Inc. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2019 Paleontological Assessment for the MorningStar Marguerite Project, Mission Viejo, Orange County, California. Prepared for T&B Planning. Report on file at Brian F. Smith and Associates, Inc., Poway, California.
Oct.. 15, 2025 Item #1 316 of 343
2019 Paleontological Monitoring Report for the Nimitz Crossing Project, City of San Diego. Prepared for Voltaire 24, LP. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2019 Paleontological Resource Impact Mitigation Program (PRIMP) for the Jack Rabbit Trail Logistics Center Project, City of Beaumont, Riverside County, California. Prepared for JRT BP 1, LLC. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Monitoring Report for the Oceanside Beachfront Resort Project, Oceanside, San
California. Prepared for S.D. Malkin Properties. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Resource Impact Mitigation Program for the Nakase Project, Lake Forest, Orange County, San California. Prepared for Glenn Lukos Associates, Inc. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Resource Impact Mitigation Program for the Sunset Crossroads Project, Banning,
Riverside County. Prepared for NP Banning Industrial, LLC. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Assessment for the Ortega Plaza Project, Lake Elsinore, Riverside County. Prepared for Empire Design Group. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Resource Record Search Update for the Green River Ranch III Project, Green River Ranch Specific Plan SP00-001, City of Corona, California. Prepared for Western Realco. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Assessment for the Cypress/Slover Industrial Center Project, City of Fontana, San Bernardino County, California. Prepared for T&B Planning, Inc. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Monitoring Report for the Imperial Landfill Expansion Project (Phase VI, Segment C-2), Imperial County, California. Prepared for Republic Services, Inc. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2021 Paleontological Assessment for the Manitou Court Logistics Center Project, City of Jurupa Valley,
Riverside County, California. Prepared for Link Industrial. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2021 Paleontological Resource Impact Mitigation Program for the Del Oro (Tract 36852) Project, Menifee, Riverside County. Prepared for D.R. Horton. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2021 Paleontological Assessment for the Alessandro Corporate Center Project (Planning Case PR-2020-
000519), City of Riverside, Riverside County, California. Prepared for OZI Alessandro, LLC. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2021 Paleontological Monitoring Report for the Boardwalk Project, La Jolla, City of San Diego. Prepared for Project Management Advisors, Inc. Report on file at Brian F. Smith and Associates, Inc., Poway, California.
Oct.. 15, 2025 Item #1 317 of 343
This is a list of acronyms and abbreviations (in alphabetical order) that are commonly used in staff
reports.
Acronym Description Acronym Description
APA American Planning Association LCPA Local Coastal Program Amendment
APN Assessor Parcel Number LOS Level of Service
AQMD Air Quality Management District MND Mitigated Negative Declaration
BMP Best Management Practice NCTD North County Transit District
CALTRANS California Department of Transportation ND Negative Declaration
CC City Council PC Planning Commission
CCR Conditions, Covenants and Restrictions PDP Planned Development Permit
CEQA California Environmental Quality Act PEIR Program Environmental Impact Report
CFD Community Facilities District PUD Planned Unit Development
CIP Capital Improvement Program ROW Right of Way
COA Conditions of Approval RWQCB Regional Water Quality Control Board
CofO Certificate of Occupancy SANDAG San Diego Association of Governments
CT Tentative Parcel Map SDP Site Development Plan
CUP Conditional Use Permit SP Specific Plan
DIF Development Impact Fee SWPPP Storm Water Pollution Prevention Program
DISTRICT City Council Member District Number TM Tentative Map
EIR Environmental Impact Report VBMP Village & Barrio Master Plan
EIS Environmental Impact Statement (federal) ZC Zone Change
EPA Environmental Protection Agency
FEMA Federal Emergency Management Agency
GP General Plan
GPA General Plan Amendment
GIS Geographic Information Systems
HCA Housing Crisis Act 2019
IS Initial Study
Exhibit 10
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Exhibit 11
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VICIIITYMAP
\
IEATPl.l,IPWATERIEATER-0NEEAT"ER30Rl«)HER "8.E�CTRl:"9ilCI.EClfAAGJtO "'"'
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RESIDENTIAL DEVELOPMENT
2647 JEFFERSON STREET
CARLSBAD, CALIFORNIA
DEVElOPMENT ANALYSIS '°'-���LOT(GROSS�
RES.OEHTW.UNITTI· ���l
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CT 2024--0006 PUD 2024--0007 CDP 2024--0036
... ,. COVER SHEET
A0.1
Exhibit 12Full Size Exhibits “A” – “T” dated October 15, 2025 (on file in the Planning Department)
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Kyle Van Leeuwen, Senior Planner
Planning Division
October 15, 2025
2647 Jefferson Street Homes
CT 2024-0006/PUD 2024-0007/CDP 2024-0036
ITEM 1 - Project Site
2647 Jefferson St.
•0.34 AC (15,006 SF)
•Single-Family Residence
•R-23 GP Land Use
•R-3 Zoning (Multi-Family)
•Coastal: Mello II Segment
ITEM 1 – Project Proposal
•Demolition: Single-Family Residence
•Construct 4 New Structures
•12 Three-Story Condominiums
•Density Bonus: 4 Additional Units
1 Unit Very-Low Income
•2 Concessions / 8 Waivers
ITEM 1 - Site Plan
4 New Structures
•4 Triplexes
•3 Stories (34’)
•One Floor Plan
•1,670 SF
•Car Lifts in Garages
•Roof Decks
•2 Guest Parking Spaces
•Street Trees
•6-Foot Dedication
(Jefferson)
Density Bonus Calculation
ITEM 1 – Project Proposal
55
•Base Density:
23 DU/AC X 0.34 AC = 8 Units (7.9)
•1 Unit Very-Low-Income = 12% of Base Units
•12% Very-Low Dedication = 38.75% Bonus Density
•38.75% of 8 Units = Up to 4 Additional Units
•12 Total Units allowed – 12 Units Proposed
STATE DENSITY
BONUS LAW
Concessions/Incentives
ITEM 1 – Project Proposal
66
1.Forgo full frontage improvements; retain 5-
foot sidewalk where 6 feet is standard.
2.Forgo full replacement of ACP water main for
entire street frontage; 20-foot segment
replaced for new main connections
STATE DENSITY
BONUS LAW
Waivers of Dev. Standards
ITEM 1 – Project Proposal
77
1. 10 feet street setback (east PL)
– 5 feet proposed
2. 10 feet side setback ( north and south PL)
– 5 feet proposed
3. 20 feet rear setback (west PL)
- 10 feet proposed (main structure)
4. 6 feet min. dimension for private rec. space
- 4.5 feet proposed
STATE DENSITY
BONUS LAW
Waivers of Dev. Standards (con’t)
ITEM 1 – Project Proposal
88
5.Community Recreation Space
– 1,800 SF waived
6. 60% max. lot coverage
– 61.7% proposed
7. 12 ft X 20 ft min. size single-car garage
– 11 ft V 20 ft proposed
8. 10 feet minimum building separation
- 7.5 feet proposed (fire riser room only)
STATE DENSITY
BONUS LAW
ITEM 1 - Elevation
ITEM 1 – Renderings
ITEM 1 – CEQA Exemption
Staff has reviewed the scope of the project and
applicable studies and finds that the project
belongs to a class of projects that categorically
exempt from the requirement for the preparation
of environmental documents (CEQA §15332 - In-
Fill Development Projects)
ITEM 1 – CEQA Exemption
Analysis in Support of Exemption:
1.Vehicle Miles Traveled (VMT)
2.Noise Study
3.Air Quality
4.Historical Assessment
5.Archaeological Survey
6.Paleontological Assessment
ITEM 1
Sewer Capacity on Jefferson Street
•Sewer Lateral replacement & upsizing
is in the pipeline
•Cost to be reimbursed by projects
connecting to new sewer line
•Condition needed to ensure entitled
projects pay their fair share
ITEM 1
Additional Condition
#59: Prior to the issuance of building permits, the developer shall pay a special (or separate) sewer connection fee for the development project’s proportionate share of sewer capacity (in Equivalent Dwelling Units) to be constructed for the Jefferson Street Sewer Replacement project, Capital Improvement Program Project No. 2615.
ITEM 1 – RECOMMENDATION
ADOPT a resolution APPROVING a CEQA
exemption and APPROVING the Tentative Tract
Map, Planned Development Permit, and Coastal
Development Permit, with the addition of
condition #59 as recommended by staff, based on
the findings and subject to conditions.
ITEM 1
Back-up Slides
ITEM 1
ZONING General Plan
ITEM 1
ITEM 1
ITEM 1
ITEM 1
Item 1
Government Code §65915:
Allows a developer to increase density (total # homes)
allowed per GP
Allows reductions in development standards (e.g. height
limits, setbacks, etc.) when standards prevent achieving
density allowed per state law
Specifies a certain number of the new dwelling units must
be reserved as affordable housing
22
STATE DENSITY BONUS LAW