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HomeMy WebLinkAboutPRE 2025-0065; ADAMS ST SMALL LOT; Admin Decision Letter Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 January 22, 2026 VIA EMAIL AND MAIL JESSE LEON PRO-CAL DESIGN AND ENGINEERING 10245 CASA CT SANTEE, CA 92071-4900 SUBJECT: PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT APN: 206-192-07-00 Dear Mr. Leon, Thank you for submitting a preliminary review application for a small lot subdivision pursuant to Senate Bill 1123 (SB-1123), commonly referred to as the Starter Home Revitalization Act of 2021. Included with this proposal is a subdivision of land consisting of nine (9) single-family residential lots with nine (9) single- family units on a vacant parcel generally located two (2) parcels east of the intersection at Highland Drive and Adams Street. The subject property is approximately 0.88-acres (38,332 square feet), is currently undeveloped, and is substantially surrounded by residential development. Topographically the site is sloping from north to south with approximately 58 feet of elevation fall from Highland Drive to Adams Street (118 ft AMSL to 60 ft AMSL). Of the nine (9) units proposed, three (3) are detached and six (6) are attached. The unit types include two (2) and three (3) story construction with living areas consisting of 1,500, 1,600, and 2,150 square feet. The average floor area of the nine (9) units equates to 1,750 square feet. The proposed three (3) story units include roof decks of an undisclosed usable area. Proposed site sections show proposed pad grades above existing grade supported by large retaining walls. In response to your application, the Planning Division has prepared this comment letter. Please note that the purpose of a preliminary review is to provide you with direction and comments on the overall concept of your project. This preliminary review does not represent an in-depth analysis of your project. It is intended to give you feedback on critical issues based upon the information provided in your submittal. This review is based upon the plans, policies, and standards in effect as of the date of this review. Please be aware that at the time of a formal application submittal, new plans, policies, and standards may be in effect and additional issues of concern may be raised through a more specific and detailed review. Planning: General 1. General Plan land use and zoning designations for the property are as follows: a. General Plan: R-4 Residential (0-4 du/ac) PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 2 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 b. Zoning: One-family Residential with minimum 15,000 square foot lot sizes (R-1-15,000). c. Coastal Land Use and Zoning: The subject property is located within the Coastal Zone and subject to the Mello II Segment of the Local Coastal Program. The Coastal land use and zoning designations for the subject property are the same as the General Plan land use and zoning designations listed above. 2. This project site is ineligible for a SB-1123 small lot subdivision: The City of Carlsbad has documentation showing that almost half (0.39-acres) of the 0.88-acre property supported Coastal Sage Scrub in 2024, but recent ariel photos now show evidence that the site may have been cleared. (For more information regarding this issue, please review the Habitat Management Division’s section of the letter below, beginning on page 13). • Government Code §66499.41(a)(9)(A) through (J) Dictates that a major urban lot split cannot be located on any site identified in (A) through (J). (This is the same list as SB-35. Please be aware that coastal sage scrub is habitat for the federally threatened California gnatcatcher. Evidence of coastal sage scrub on-site and in the Coastal Zone requires no net loss of habitat and also preservation per the city’s Local Coastal Program, which was adopted by the California Coastal Commission.) • Government Code §66499.41(a)(9)(H) Land identified for conservation in an adopted natural community conservation plan pursuant to the Natural Community Conservation Planning Act (Chapter 10 (commencing with Section 2800) of Division 3 of the Fish and Game Code), habitat conservation plan pursuant to the federal Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.), or another adopted natural resource protection plan. • Government Code §66499.41(a)(9)(I) Habitat for protected species identified as candidate, sensitive, or species of special status by state or federal agencies, fully protected species, or species protected by the federal Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.), the California Endangered Species Act (Chapter 1.5 (commencing with Section 2050) of Division 3 of the Fish and Game Code), or the Native Plant Protection Act (Chapter 10 (commencing with Section 1900) of Division 2 of the Fish and Game Code). Notwithstanding the above, staff is required to accept an application to process if made by the applicant, with approval from the property owner. If an application were to be submitted, city staff will accept and review the application. However, if the application does not meet the requirements of the statue, we would process for denial of either the ministerial action or Coastal Development Permit. A decision of the City Planner could be appealed under Carlsbad Municipal Code to the Planning Commission, and a decision of the Planning Commission could be appealed to the City Council. 3. Applicability of SB-684 and/or SB-1123. in the California Coastal Zone. PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 3 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 The City of Carlsbad has a certified Housing Element and the Planning Division within Community Development strenuously reviews all projects and laws to ensure implementation of all applicable local and state laws. For Small Lot Subdivisions, the city has prepared and posted an Informational Bulletin (IB-166) and application material related to the processes of those laws. There are certain standards in implementation of these laws that are identified clearly by statue. However, it is not clear on whether the maximum density approved by the Land Use Map in the Local Coastal Program supersedes the maximum density allowed by SB-684 or SB-1123. Government Code Sections 65852.28, 66499.41 and 65913.4.5, as amended by SB-684 and SB-1123, never explicitly reference the California Coastal Act and it remains unclear how potential conflicts would be resolved in instances where two different maximum densities are presented. Additionally, it is not explicitly stated that a Coastal Development Permit as required by the California Coastal Act, and the city’s Local Coastal Program, including Title 21 of the Carlsbad Municipal Code is not allowed. Certain sections of state law state a Costal Development Permit without hearings is required, but similarly that language is not included in this statue. During an earlier conversation with representatives of the applicant, this issue was raised as a potential one on this site. It was mentioned there was guidance on this topic. To date, we have not been sent any or been able to find any specific guidance on this topic. Based upon a review of other jurisdictions, it appears several are taking the position that the Local Coastal Program land use densities are not modified by these statues. Clarification from the California Department of Housing and Community Development (HCD) is available through the Accountability Unit Portal, and can be submitted by a city or applicant. We do not see how this conflict would be resolved until HCD issues guidance, and even then, potential opinions from the Coastal Commission may provide further guidance. As such, please be aware that project density based on net developable acreage is how the Carlsbad Municipal Code, Title 21, calculates density. The entirety of Title 21 is adopted as part of the City’s Local Coastal Program Implementation Plan. For more specifics, please see Carlsbad Municipal Code (CMC) §21.53.230. For constraints mapping analysis, see CMC §21.95.130. For preservation of steep slopes and vegetation see CMC §21.203.040. Currently, the gross project density for the proposed project, at 10.2 du/ac, is exceeding both the R-4 Residential (0-4 du/ac) City-wide and Local Coastal Program land use designations for the site by approximately seven units. It is important to note, any development in the Coastal Zone will need to be found consistent with the Mello II Segment of the city’s Local Coastal Program. The current proposal is noncompliant as presented. Community Development is willing to review any correspondence or legal opinions on this topic and will consult with the City Attorney’s office on any reviews or submissions. Setting aside this topic, there are a number of objective standards within the city’s regulatory framework that the project does not comply with and are included in the body of this letter. Compliance with these standards is allowed under Government Code 65858.28. 4. The project requires the following permits: a. Coastal Development Permit (CDP). Any development in the Coastal Zone requires a Coastal Development Permit (CDP) consistent with Chapter 21.201 of the Carlsbad Municipal Code (CMC). Please be aware that the city may impose conditions in these areas to ensure projects PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 4 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 provide public access and recreation, enhance existing scenic views, and protect sensitive habitat and coastal resources consistent with the Coastal Act (Chapter 3) and the city’s Local Coastal Program. These conditions may assist the city in making the necessary findings to approve required Coastal Development Permits (CMC §21.201.080.C). The following permitting steps shall apply to processing a Coastal Development Permit (CDP) for eligible lots within the Coastal Zone. • Properties located within the Coastal Zone are required to submit a completed Development Permit Application (P-2). Please include “SMALL LOT SUBDIVISION” in the Project Description Statement (Form P-1(B)) with a formal application submittal. • SB-1123 projects will follow the same permit processing steps set forth in CMC §21.201, with the exception that a public hearing shall not be required. Neighboring property owners will still be notified of the permit application pursuant to city code but permit approval will be done administratively by the city planner, whose decision can be appealed. 5. Development Permit Application. The following outlines the required permit application and general processing steps to secure necessary approvals for streamlined small lot subdivisions. • A completed Development Permit Application (P-2) is required. Please include “SMALL LOT SUBDIVISION” in the Project Description Statement (Form P-1(B)). • Applications for streamlined subdivisions shall follow the same permit processing steps set forth in CMC Chapter 20.24, with the following exceptions. o A public hearing shall not be required to approve tentative and final maps for a proposed subdivision of 10 or fewer parcels. o Pursuant to Government Code §66499.41(a), a subdivision resulting in 10 or fewer parcels is considered a ministerial action. Pursuant to CEQA Guidelines §15268(a), ministerial projects are exempt from CEQA. Because this project requires a Coastal Development Permit (CDP) as discussed in Comment 4 above, the proposed project involves an approval that contains a discretionary action, and thereby, pursuant to CEQA Guidelines §15268(d), the project is NOT ministerial, and is thus, subject to the requirements of CEQA. 6. For additional information regarding Comments 3 and 4 above, please review Information Bulletin IB- 166 Streamlined Small Lot Subdivisions, which can be found on the City of Carlsbad Community Development Department’s website at: https://www.carlsbadca.gov/home/showpublisheddocument/20580/638912915136600000 PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 5 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 7. Hillside Development. The property contains slopes over 15 percent and an elevation differential greater than 15 feet in height. Formal submittal of an application to the City’s Planning Division for a Coastal Development Permit, as discussed above in Section 2, will need to demonstrate compliance with the city’s Hillside Development Regulations and Hillside Development & Design Guidelines. As part of that formal application submittal, please be sure that proposed project exhibits address all requirements listed under CMC §21.95.130 – Hillside Mapping Procedures and CMC §21.95.140 – Hillside Development and Design Standards. Review of city’s Hillside Development & Design Guidelines can be found on the City of Carlsbad Community Development Department’s website at: https://www.carlsbadca.gov/home/showpublisheddocument/270/637425976541270000 8. Habitat Management Plan (HMP) and Local Coastal Program (LCP) Requirements. The city has an adopted Habitat Management Plan that is approved by U.S Fish and Wildlife Services, California Department of Fish and Wildlife, and the California Coastal Commission as part of the Local Coastal Program. This plan implements the Endangered Species Act, California Endangered Species Act, the Natural Community Conservation Program, and the California Coastal Act. Please review the following and revise your formal project application appropriately. Additional notes related to the habitat on the site are included in comments from the Habitat Management Division. The HMP (please make sure to review the specific measures for properties located within the Coastal Zone on pages D-114 through D-120) and the Mello II Segment of the LCP can be found on the City of Carlsbad Community Development Department’s website at: HMP: https://www.carlsbadca.gov/home/showpublisheddocument/224/637446616709600000 LCP: https://www.carlsbadca.gov/home/showpublisheddocument/236/637425974089530000 9. Conceptual Landscape Plans. Formal submittal of an application to the City’s Planning Division for a Coastal Development Permit, as discussed above in Section 2, will need to include conceptual landscape plans. Landscape plans shall be designed in accordance with the City of Carlsbad’s Landscape Manual Policies and Requirements. Review of City of Carlsbad’s Landscape Manual can be found on the City of Carlsbad Community Development Department’s website at: http://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=24086 As part of this submittal, please be sure to include a Fire Protection Plan and address all applicable Fire Protection Policies. 10. No conceptual landscape exhibits were included with this preliminary review submittal; therefore, no comments regarding compliance with the City of Carlsbad’s Landscape Manual Policies and Requirements have been provided. 11. The subject parcel is located within the McClellan-Palomar Airport Influence Area (AIA). New development within the AIA must be reviewed for consistency with the adopted land use compatibility plan for the airport, in this case the McClellan-Palomar Airport Land Use Compatibility PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 6 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 Plan (ALUCP), adopted on January 25, 2010 and later amended on March 4, 2010 and December 1, 2011. Review of ALUCP can be found on the City of Carlsbad Community Development Department’s website at: https://www.carlsbadca.gov/home/showpublisheddocument/226/637446617757230000 Preliminary review of the proposed project against the ALUCP revealed the following: a. Exhibit III-1 – Compatibility Policy Map: Noise. The subject parcel is located outside of the 60 db CNEL noise exposure range per Exhibit III-1. Pursuant to the ALUCP Section 3.3.3(a) on page 3-19: “The threshold for evaluation is the projected 60 dB CNEL contour. This contour defines the noise impact area of the Airport. All land uses located outside of this noise contour are consistent with the noise compatibility policies.” b. Exhibit III-2 – Compatibility Policy Map: Safety. Pursuant to Exhibit III-2, the subject parcel is located outside and beyond the respective safety zones 1-6; and thus, the residential use is considered compatible. c. Exhibit III-3 – Compatibility Policy Map: Part 77 Airspace Protection. The subject parcel is located within the 20:1 Conical Surface area associated with the Typical Part 77 Obstruction Surfaces as outlined in Exhibit III-3. As such, any formal submittal of a project under the ALUCP requires compliance with the Federal Aviation Administration’s (FAA) Federal Aviation Regulations (FAR) Part 77, Objects Affecting Navigable Airspace. With any formal application submittal, and before city staff could consider an application complete, submittal of FAA aeronautical studies in accordance with the FAA’s FAR Part 77, Subpart C, shall be submitted indicating the FAA’s issuance of a “determination of no hazard to air navigation”. These documents shall be included with an initial discretionary application submittal. d. Exhibit III-4 – Compatibility Policy Map: Overflight. The subject parcel is located within the Airport Overflight Notification Area. Recordation of an overflight notification document is a condition of new residential development located within the Airport Overflight Notification Area. e. Exhibit III-5 – Compatibility Policy Map: Airport Influence Area. The project site is located within Review Area 2 of the Airport Influence Area. Review Area 2 consists of locations beyond Review Area 1, but within the airspace protection and/or overflight notification areas depicted on the associated maps of the ALUCP. Limits on the heights of structures, particularly in areas of high terrain, are the only restrictions on land uses within Review Area 2. Recordation of overflight notification documents is required for new residential development located within Review Area 2. f. Exhibit III-6 – Compatibility Policy Map: Avigation Easement Area and Overflight Notification Areas. The project site is located outside of the Avigation Easement Area but is located within the Airport Overflight Notification Area. Recordation of an overflight notification document is a condition of new residential development located within the Airport Overflight Notification Area. PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 7 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 12. The project proposal is in conflict with the following objective zoning standards: a. Every lot shall front on a dedicated street or a street offered for dedication unless otherwise authorized by Title 21 for the zone in which the lot is located at the time the final map is submitted to the City Council for its approval. (CMC §20.16.010.C) Staff Comment: All subdivision lots must front the public right-if-way unless a Planned Unit Development (PUD) permit is obtained pursuant to Chapter 21.45 of the Carlsbad Municipal Code. A PUD application for One-Family Dwellings on Small Lots located in an R-1 Zone are only permitted in the following two (2) cases: • Permitted when the project site is contiguous to a higher intensity land use designation or zone, or an existing project of comparable or higher density (CMC §21.45.040, Table A, Note 1); or • Permitted when the project site contains sensitive biological resources as identified in the Carlsbad Habitat Management Plan (CMC §21.45.040, Table A, Note 4). Pursuant to the existing land uses surrounding the subject property, which consists of one single-family home on one lot; and the preliminary review application submittal documents, which indicate an absence of biological resources, neither of the above two (2) cases outlined in Notes 1 and 4 exist to allow for the processing of a PUD application for a small lot subdivision that is not fronting on a dedicated street. However, if the project site was found to contain sensitive biological resources per Note 4, an application for PUD would still not allow for the wholesale development of the site as proposed, but instead, would provide a method for clustering development in a manner that recognizes the impacts of environmentally and topographically constrained land per the policies of Habitat Management Plan (HMP) and the City’s Local Coastal Program (LCP). b. The design of the subdivision shall be consistent with the provisions of Chapter 21.95 of this code relating to hillside development. Areas which are determined to be undevelopable pursuant to the applicable provisions of Chapter 21.95 of this code shall be preserved as open space areas. (CMC §20.16.010.M) c. In the R-1 zone no building shall exceed a height of 30 feet and 2 stories if a minimum roof pitch of 3:12 is provided or 24 feet and 2 stories if less than a 3:12 roof pitch is provided for lots under 20,000 square feet. (CMC §21.10.050) Staff Comment: Proposal shows three-story homes where two-stories is the maximum allowed. The proposed cross sections show two- and three-story homes situated on elevated pads with building heights that do not consider the existing grade elevation, which in this case is the lowest point for which building height in measured. The proposed homes with flat roofs appear to exceed the 24-foot maximum height limit and the proposed homes with pitched roof (degree of pitch is undetermined) also appear to exceed the 30-foot maximum height limit as defined in CMC §21.04.065. PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 8 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 d. "Building height" is limited to the vertical distance measured from "existing grade" (defined: Section 21.04.160) or "finished grade" (defined: §21.04.161), whichever is lower, at all points along the "building coverage" (defined: §21.04.061) up to a warped plane located at a height, above all points along the "building coverage," that is equal to the height limit of the underlying zone. All portions of the building shall be located at or below the building height limit. (CMC §21.04.065) Staff Comment: Proposed cross sections show two- and three-story homes situated on elevated pads with building heights that do not consider the existing grade elevation, which in this case is the lowest point for which building height in measured. When preparing architectural exhibits for discretionary application submittal, please refer to the city’s Guide for Measuring Building Height. This guide can be found on the City of Carlsbad Community Development Department’s website at: https://www.carlsbadca.gov/home/showpublisheddocument/268/637425976538130000 e. No one-family dwelling unit, whether it be conventionally built, modular or a mobile home, shall be located on a lot in this zone [R-1] unless such dwelling unit complies with the following development standards: • Garage(s), which are provided to meet the parking requirements for dwellings pursuant to Section 21.44.020 of this title; (CMC §21.10.120.A.1) Staff Comment: Proposed floor plans show garages that do not meet the interior dimensional requirements; or two-car garage requirement. f. One-family dwellings require two spaces per unit, provided as either: • A two-car garage (minimum interior 20 feet x 20 feet); or • Two separate one-car garages (minimum interior 12 feet x 20 feet each). (CMC §21.44.020.B.Table A) Staff Comment: Proposed floor plans show garages that do not meet the interior dimensional requirements for a two-car garage. g. In any "R" zone, no fence, wall or hedge over forty-two inches in height shall be permitted in any required front yard setback. In the required side yard or street side of either a corner lot or reversed corner lot, a six-foot high fence may be permitted when approved by the City Planner when the safety and welfare of the general public are not imposed upon. The issuing of a permit upon the approval of the City Planner shall be subject to special conditions which may vary due to the topography, building placement and vehicular or pedestrian traffic. On an interior lot, a wall or fence not more than six feet in height may be located anywhere to the rear of the required front yard. (CMC §21.46.130) Staff Comment: Project section details are showing large retaining walls in exceedance of standards. PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 9 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 h. Slope edge building setbacks shall be sufficient to eliminate or significantly reduce views of vertical building forms which would be visually incompatible with hillside landforms. Notwithstanding the building setback requirements of the underlying zone, all main and accessory buildings that are developed on hilltops and/or pads created on downhill perimeter slopes of greater than fifteen feet in height shall be set back so that the building does not intrude into a 0.7 foot horizontal to one foot vertical imaginary diagonal plane that is measured from the edge of slope to the building. For all buildings which are subject to this slope edge building setback standard, a profile of the diagonal plane shall be submitted with all other development application requirements. (CMC §21.95.140) Staff Comment: Cross sections show proposed homes near top of manufactured slopes that appear to be located within the applicable slope edge building setback. 13. The Housing Crisis Act of 2019 (SB 330) established a preliminary streamline application process for housing projects. It is not mandatory unless applicants seek the vesting and processing benefits offered under SB 330. Participation in the SB 330 streamline process would occur first, followed by the formal development application process required under Government Code (Gov. Code) §§65940, 65941, 65941.5, and CMC §21.42.050. Acceptance by the city of a complete SB 330 Streamline Application (Form P-32) and fee will vest the project for 180 days in accordance with the ordinances, policies and standards in effect at the time the SB 330 Application is accepted. 14. Per the Housing Crisis Act of 2019 (SB 330), any project that includes the removal or demolition of a "protected unit" is required to provide the occupants with 1) relocation benefits (Gov. Code §7260 et seq.), and 2) right of first refusal for a comparable unit available in the new housing development. (Gov. Code §66300 (d)(2)(D).) "Protected units" are generally defined by Gov. Code §66300(d)(2)(E)(ii) as including residential units subject to affordability restrictions, price controls, or occupied by low income households. The formal submittal of the project will need to include documentation regarding any existing “protected units.” 15. New requirements related to the city’s goals to reduce greenhouse gas (GHG) emissions will likely impact development requirements of this project. A formal application submittal will need to include a completed Climate Action Plan Checklist (Form P-30) to determine what requirements will apply to the project. New GHG reduction requirements are related to energy efficiency, photovoltaic, electric vehicle charging, water heating and traffic demand management requirements, as set forth in the California Green Building Standards Code and in CMC Chapters 18.21, 18.30 and 18.51 which is available on the city’s website at the following address: http://www.qcode.us/codes/carlsbad/view.php?topic=18&frames=on To the extent that new GHG reduction requirements are in effect at the time of application for grading or building permits, the project will be required to comply with the effective requirements even if different than what is proposed in the project’s planning approvals. GHG reduction requirements may impact, but are not limited to, site design and local building code requirements. If incorporating new GHG reduction requirements results in substantial modifications to the project after planning approvals are obtained, then prior to issuance of grading or building permits, the applicant may be PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 10 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 required to submit and receive approval of a Consistency Determination or an Amendment application for the project through the Planning Division. All necessary application forms, submittal requirements, and fee information are available at the Planning counter located in the Faraday Building at 1635 Faraday Avenue or online at https://www.carlsbadca.gov/departments/community-development/planning. You may also access the General Plan Land Use Element and the Zoning Ordinance online at the website address shown. Please review all information carefully before submitting. Land Development Engineering: 1. Depending on the CEQA determination, which is determined after the application for discretionary permits is submitted, a Vehicle Miles Traveled (VMT) analysis may be required per the Vehicles Miles Traveled Analysis Guidelines, which can be found on the City of Carlsbad Community Development Department’s website at: https://www.carlsbadca.gov/home/showdocument?id=312. 2. Please complete a Stormwater Standards Questionnaire, Form E-34. This questionnaire will guide you and the city in determining what type of reports and storm water mitigation must be completed to satisfy state and City storm water quality requirements. The questionnaire can be found on the City of Carlsbad Community Development Department’s website at: https://www.carlsbadca.gov/home/showpublisheddocument/604/638683035715330000 3. Based on a preliminary analysis it appears that this project is a Priority Development Project (PDP). All impervious surfaces being created or replaced (onsite and offsite) shall be included for treatment. Submit a Storm Water Quality Management Plan. Review the Hydromodification Exemption Map and Potential Critical Coarse Sediment Yield Area Map on the City website to see if this criterion applies to your project. The post construction stormwater treatment BMPs shall be shown on a conceptual grading plan and drainage plan with the discretionary application. 4. Drainage management areas (DMA’s) shall drain to a common pollutant control BMP to be maintained by the property owners in an equitable manner via CC&Rs, an agreement recorded on property title or other acceptable means. The post construction BMP shall be constructed prior to final map approval. 5. Provide a Preliminary Title Report (current within the last six (6) months). 6. Please annotate and delineate all existing easements and encumbrances listed in the Preliminary Title Report on the site plan. If any vacations or quitclaims are planned with this development annotate on the site plan. 7. A Preliminary Hydrology Study including map and calculations is required to demonstrate capacity/sizing of proposed and existing storm drain infrastructure. Show 100-year storm hydrologic calculations before and after development for each drainage basin. PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 11 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 8. A Preliminary Geotechnical Report is required to evaluate the feasibility of the project. Please provide recommendations for infiltration and remedial excavation requirements. Technical guidelines for preliminary geotechnical reports can be found on the City of Carlsbad Community Development Department’s website at: https://www.carlsbadca.gov/home/showpublisheddocument/326/638054006747270000 9. Please be aware, per Section 15.16.060 of the Carlsbad Municipal Code, this project will require a grading permit and grading plan. 10. A separate improvement plan for work within the right-of-way is required for this project. 11. This project shall utilize City of Carlsbad Survey Control Network established on Record of Survey Map 17271, NAD83, Zone VI, 1991.35 Epoch for horizontal control and NGVD 29 datum for vertical control per City of Carlsbad Engineering Standards. 12. Please delineate and annotate the limits of grading. 13. Please delineate and annotate approximate topographic contours for existing and proposed condition. Provide 1-foot (1’) contours for slopes less than five percent (5%); two-foot (2’) intervals for slopes between five percent (5%) and ten percent (10%), and five-foot (5’) intervals for slopes over ten percent (10%). Extend contours a minimum 25 feet beyond the project boundary. 14. On the site plan, please show and identify all existing surface improvements screened back (curb, gutter, sidewalk, paving, manholes, inlets, street lights, adjacent driveways, vaults, transformers, etc.) at the project site, project frontage and within 25 feet of the boundary. 15. Please delineate location of all existing and proposed buildings, walls, fences and permanent structures onsite and within 25 feet of the site. 16. Please indicate the earthwork quantities (cut, fill, import, export, remedial) proposed for the project in cubic yards. 17. Please provide spot elevations at the corners of each pad in the proposed condition. Include finish pad and floor elevations. 18. Please provide the method of draining each lot. Unless otherwise specified by a geotechnical engineer, method of drainage shall comply with California Building Code (latest version) Section 1804.4. 19. Please delineate all retaining walls that will be utilized on the project site and show top of wall and bottom of wall elevations, including at the highest and lowest points. Indicate maximum height of retaining wall measured from bottom of footing to top of wall and maximum height measured from finish surface to top of wall. PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 12 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 20. Please provide D-75, Type ‘B’ brow ditch behind and at the top of the sloping backfill retaining wall. Show how storm water from the ditch will be conveyed to the storm drains on site. 21. Please show existing lot line bearings and distances. 22. Please show proposed parcel/lot lines on the site plan. Provide proposed parcel/lot areas. This project is proposing a subdivision to create ten (10) lots/parcels. A tentative map is required. 23. All subdivision lots must front on public right-of-way unless a planned unit development (PUD) permit can and will be obtained. 24. Water meters and services shall be located in the city right-of-way or within a proposed CMWD easement adjacent to the right-of-way. 25. Sewer services shall be shown for each lot. If a private sewer service will be utilized to service the interior lots, this will need to be constructed prior to map approval, additionally private covenants of easement for sewer will be required along with a mechanism to assess proportional payment. 26. Please provide typical street cross sections for Highland Drive and Adams Street and any proposed streets. Provide existing right-of-way width and existing improvements and proposed improvements and dedications. 27. Please delineate and annotate all proposed driveways and driveway widths. 28. Please show the driveway grade on the conceptual grading and drainage plan. Be aware that grades over 14% require City Engineer approval. 29. Please show all existing and proposed utilities and callout size for: water, sewer, storm drain, underground dry utilities, overhead lines, traffic signals, street lights in Highland Drive and Adams Street and laterals affecting the property. 30. Please provide a Sewer Study for new development based on City of Carlsbad Sewer Master Plan Update 2019, Section 4.2 Design Criteria. 31. Please provide a Water Study for the new development based on City of Carlsbad Potable Water Master Plan 2019, Section 4.2 Design Criteria. 32. Public potable water and sewer mains along project frontages must meet minimum design diameter and material as specified in City of Carlsbad Engineering Standards Vol. 2 Section 3.2.2 for water and Volume 1 Section 6.2 for sewer. Utility replacement and/or upsizing may be required as a condition of development. Engineering Codes, Standards & Policies can be found on the City of Carlsbad Community Development Department’s website at: https://www.carlsbadca.gov/departments/community-development/land-development- engineering/engineering-codes-standards-policies PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 13 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 33. Please locate fire service, backflows, potable and recycled water services, meters, landscape irrigation services, and sewer laterals for the new development in compliance with City of Carlsbad Engineering Standards requirements. 34. Please provide multiple cross-sections of the site to demonstrate differences in grade from adjacent properties, existing and proposed grades on-site, fences and location of structures on-site and on adjacent properties. 35. Dedications and frontage improvements are required per Chapter 18.40 and Chapter 20.16 of the Carlsbad Municipal Code. A five-foot-wide (5’) public street and utility easement shall be dedicated on both Highland Drive and Adams Street. Public frontage improvements along Adams Street shall include curb, gutter, pavement widening and any utility relocation per Adams Street Alignment Study Drawing 331-5. 36. Required improvements provided by the subdivider, include installing all the driveway, post- construction BMPs and drainage structures, as well as any trunk private sewer service necessary to support the subdivision prior to map approval. 37. Highland Drive is designated as an alternative design street. Therefore, this development is not subject to installing street frontage improvements at this time. The property owner will be required to enter into a Neighborhood Improvement Agreement (NIA) with the city. The Agreement will be recorded with San Diego County Recorder’s Office. 38. Please meet with the Carlsbad Fire Department to identify the necessary fire protection measures required for this project (access, fire hydrants, sprinkler system, on-site circulation, emergency access, etc.) 39. Please plot stopping sight distance at all driveways and corner sight distance at all street intersections. 40. Please address the comments on the attached redlined plan. 41. Please be advised that a more in-depth review of the proposed development will occur with the discretionary permit application when a more complete design of the project is provided. Habitat Management Division: 1. When conducting the preliminary review for this site, Habitat Management Division staff reviewed past assessments and communications for this site. Habitat Management Division staff communicated with the landowner/landowner representative in May and June of 2024. Staff provided a Habitat Management Plan (HMP) constraints assessment, which was based on a biological resources memo prepared by Blackhawk Environmental (June 2024). The report showed that there was coastal sage scrub onsite, and staff notified the landowner/representative that any removal of coastal sage scrub vegetation was subject to permits and mitigation. See attached HMP Constraints Assessment. PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 14 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 As part of the current review, staff looked at current and historic aerial maps. It appears that there was some unpermitted take of coastal sage scrub habitat on the property as shown in the figures below. 2. The 2024 HMP Constraints analysis is still valid for this site. Any development of this property requires the submittal of a biological resources technical report consistent with the city’s Guidelines for Biological Studies (2022)(see link below). The report must analyze all impacts and demonstrate consistency with the HMP, including the coastal zone standards. Because protected native vegetation was removed without permit, the previous vegetation mapping boundaries for coastal sage scrub shown in the Blackhawk Environmental (June 2024) report will be considered the current boundary for this vegetation type. However, the biology report must include current mapping and species surveys. Guidelines for Biological Studies (2022): • https://www.carlsbadca.gov/home/showpublisheddocument/1604/637819050500430000 3. Any required Fuel Modification Zone will be counted as an impact and must be contained within this parcel. Public Works – Utilities: 1. Water Study. A water study shall be required for the proposed project that includes domestic meter and fire sizing criteria, as well as modeling of the public distribution system in response to on-site water demands (domestic, irrigation, and fire) per the applicable NFPA fire flow requirements and the current City of Carlsbad Engineering Standards. 2. Sewer Study. A sewer study shall be required for the project analyzing the existing and proposed demands on the public sewer main in accordance with the current City of Carlsbad Engineering Standards. Hydraulic modeling of the existing sewer system may also be required to identify any potential off-site impacts from the additional sewer load being proposed. PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 15 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 3. Updated Civil Site Plans shall be required that identify and detail proposed fire service, water, irrigation, and sewer connections at property line for the development in compliance with current Carlsbad Engineering Design Standards. a. Each separately owned parcel of property shall have a dedicated service and meter by public right-of-way (ROW) or public water easement along existing ROW. b. Proposed sewer laterals design shall conform with City’s design standards, including but not limited to Eng Std. Vol 1, Chap 6.3. If proposing a privately owned sewer main to serve proposed residences and connect to the exiting public sewer main along the parcel frontage, proposed maintenance responsibility of the private sewer main and enforcement mechanism should be specified and clarified. 4. Five feet (5’) dedication of easement for public street and public utility purposes shall be required along both Highland Drive and Adams Street. See recently recorded adjacent easement (Rec. No. 2023-0119267) for info and reference. 5. Please show and identify all utilities in the right-of-way along both parcel frontages, including existing public water mains eight-inch (8”) PVC (Pressure Zone 330) along Highland Drive and ten-inch (10”) ACP (Pressure Zone 241) along Adams Street; and existing eight-inch (8”) VCP sewer mains in Highland Drive and Adams Street. Fire & Life Safety: 1. Fire Access Road. Please address the following as it relates: a. Fire access roadways shall be designed, constructed, and maintained to support the imposed loads of Carlsbad fire apparatus with a total weight of 75,000 pounds. The surface shall be designed, constructed, and maintained to provide all-weather driving capabilities. Approved road surfaces include asphalt and concrete. b. Fire access roadways shall be a minimum of 24 feet (24’) clear width. Width of fire apparatus access road is sufficient to meet Carlsbad standards but there is not sufficient space provided for any street parking of any kind. c. Fire lane identification will be required per an acceptable method of marking that shall be approved prior to installation. Acceptable markings include marked with red curbs painted OSHA safety red and marked with “FIRE LANE – NO PARKING” painted on top of curb in three- inch (3”) white lettering at a spacing of thirty feet (30’) on center or portion thereof and “Fire Lane—No Parking” signs shall be posted immediately adjacent to the fire lane and at intervals not to exceed 50 feet (50’). d. The grade for fire apparatus access roads shall not exceed ten percent (10%) or 5.7 degrees. The grade may be increased to a maximum of fifteen percent (15%) or 8.5 degrees for approved lengths of access roadways, when approved by the Fire Marshal. Cross-slope shall not be greater than two percent (2%) for paved access roadways. With a formal application submittal, please confirm road grade and cross slope. 2. Please submit a completed Form P-99F (Project Facility Availability – Fire) to determine fire flow requirements, and to determine number and location of required hydrants. Please note this form must be completed and signed by appropriate Carlsbad Fire Department (CFD) staff prior to submittal of a formal project application. A completed, city-reviewed, Form P-99F shall accompany a formal PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 16 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 project application to the Planning Division. Form P-99F can be found on the City of Carlsbad Community Development Department’s website at: https://www.carlsbadca.gov/home/showpublisheddocument/12256/638809084383000000 3. All structures shall be sprinklered per NFPA 13D. Housing & Homeless Services: 1. The project is required to provide one (1) affordable unit: • 9 units x 15% = 1.35 units rounds down to 1. Additionally, per CMC Section 21.85.040 – inclusionary units shall be reasonably consistent or compatible with the design of the total project in terms of appearance, materials, and finished quality. Additionally, the affordable unit bedroom counts should be commensurate with the market-rate unit bedroom counts. 2. The plans need to identify where the affordable unit will be in relation to the project. If the location is not known at this time, the Housing and Homeless Services Department will need to review and approve for identification, prior to the execution of the Affordable Housing Agreement. 3. This project may have Credit Purchase Eligibility. Building: 1. No comments provided. PRE 2025-0065 (DEV2025-0101) – ADAM STREET SMALL LOT January 21, 2026 Page 17 __________________ Community Development Department Planning Division 1635 Faraday Avenue  Carlsbad, CA 92008-7314  442-339-2600 If you would like to schedule a meeting to discuss this letter with the commenting departments, please contact Jason Goff at the number below. You may also contact each department individually as follows: •Planning: Jason Goff, Senior Planner, at (442) 339-2643 •Land Development Engineering: Nicole Fine, Project Engineer, at (442) 339-2744 •Fire & Life Safety: Darcy Davidson, Fire Marshal at (442) 339-2662 •Public Works - Utilities: Belle Chou, Project Engineer, at (442) 339-2324 •Habitat Management: Rosanne Humphrey, Senior Program Manager, at (442) 339-2689 •Housing & Homeless Services: Christian Gutierrez, Housing Services Manager, at (442) 339-2299 •Building: Jesse Sanchez, Building Official, at jesse.sanchez_ctr@carlsbadca.gov Sincerely, ERIC LARDY, AICP City Planner EL:JG:cf Enclosures: 1.Redlined Plans - Land Development Engineering Division c: Nichole Fine, Land Development Engineering Darcy Davidson, Fire & Life Safety Belle Chou, Public Works – Utilities Rosanne Humphrey, Habitat Management Christian Gutierrez, Housing & Homeless Services Jesse Sanchez, Building Laserfiche/File Copy Data Entry