HomeMy WebLinkAbout2026-02-12; Housing Commission; 01; Affordable Housing Development Activity Meeting Date: Feb. 12, 2026
To: Housing Commission
From: Mandy Mills, Housing & Homeless Services Director
Staff Contact: Mandy Mills, Housing & Homeless Services Director
mandy.mills@carlsbadca.gov, 442-339-2907
Subject: Affordable Housing Development Activity
District: All
Recommended Action
Receive a presentation regarding current affordable housing development activity.
Executive Summary
Carlsbad Municipal Code Sections 21.85 (Inclusionary Housing) and 21.86 (Density Bonus)
require the production of affordable housing. This report provides an overview of the
ordinances and report on recent affordable housing development activity in Carlsbad.
Explanation & Analysis
The private market generally provides housing for above moderate-income households, but not
enough housing supply for households of moderate income and below. To help address the
housing need for all income levels, the City of Carlsbad has two local ordinances that ensure
that housing is created and accessible to low- and moderate-income households. Such
ordinances are explained below.
Inclusionary Housing
The city adopted the Inclusionary Housing Ordinance in 1993 to ensure that all residential
development provide a range of housing opportunities for all economic segments of the
population, including households of lower and moderate income. The ordinance established
the legal basis for requiring affordable housing units in new residential development in the city,
known as inclusionary housing. The law applies to all proposed development projects that
include seven (7) or more residential units and requires that a minimum of 15% of the units
within a project be affordable to lower income households. Applicants proposing six (6) or
fewer units pay a fee rather than constructing the inclusionary unit as part of the development
project. Revenue from the collected fees are deposited into the Housing Trust Fund to help
further the development of affordable housing in the city. An Informational Bulletin describing
the inclusionary housing requirements and alternatives for the provision of affordable housing
is included as Exhibit 1.
HOUSING COMMISSION
Feb. 12, 2026 Item #1 Page 1 of 19
Since its implementation, the inclusionary housing ordinance has proven to be an effective tool
in providing housing for lower-income households. From 1995 to 2020, approximately 19,000
total housing units were produced in the city, of which roughly 13% (2,400) were made
affordable through this program. And it is anticipated that the city will generate approximately
500 additional affordable units over the next eight-year period.
While no changes to the city’s ordinance occurred in 2025, an Opinion Letter issued by the
State Attorney General (No. 24-501) was published on April 2, 2025, which impacted the
implementation of the city’s Inclusionary Housing Ordinance in relationship to projects pursuing
State Density Bonus. In summary, the opinion requires that the city use the base density, prior
to adding the bonus units, for determining a project’s affordability requirements, not the total
number of units, as was the city’s practice. The new calculation results in a reduction in
required affordable units.
Density Bonus
A state law known as State Density Bonus Law (SDBL) found in Government Code §65915, was
enacted in 1979, and provides another tool in the development of affordable housing. The city
of Carlsbad’s implementing ordinance is found in Carlsbad Municipal Chapter 21.86. This law
allows a developer to increase their residential density above what is authorized under the
city’s current land use plans in exchange for reserving a certain percentage of the project as
affordable. SDBL also allows developers to request waivers to the city’s development standards
when such deviations are needed to achieve the density allowed pursuant to SDBL and when
such waivers do not result in any health or safety impacts, do not have an adverse impact on
property listed on the California historical register, and do not violate state or federal law. An
Informational Bulletin describing the density bonus requirements and alternatives for the
provision of affordable housing is included as Exhibit 2.
While the Density Bonus program requires the provision of on-site affordable housing, it does
not significantly increase the amount of affordable housing provided in Carlsbad because the
City of Carlsbad already requires affordable housing through the Inclusionary Housing
Ordinance. Medium-to-large size projects are already required to provide affordable housing as
a part of their development. However, because SDBL requires that the affordable unit(s) be
built on site as opposed to an alternative option such as an in-lieu fee or affordable unit credit
purchase, more affordable units will be built in small projects that would have traditionally
opted out of providing a unit on-site.
Current Development Activity with Affordable Units
New residential development activity has been steady in the last few years. Exhibit 3 provides a
list of all projects with affordable units that were completed, under construction, or approved
during calendar year 2025. Four (4) projects were completed in 2025 that produced a total of
72 new affordable units, and 576 market-rate units.
Fiscal Analysis
There is no direct fiscal impact associated with receiving the presentation.
Feb. 12, 2026 Item #1 Page 2 of 19
Environmental Evaluation
The proposed action is not a “project” as defined by CEQA Section 21065 and CEQA Guidelines
Section 15378(b)(5) and does not require environment review under CEQA Guidelines Section
15060(c)(3) and 15061(b)(3), because the proposed action to report out is an organizational or
administrative government activity that does not involve any commitment to any specific
project which may result in a potentially significant physical impact on the environment. Any
subsequent action or direction stemming from the proposed action may require preparation of
an environmental document in accordance with CEQA or CEQA Guidelines.
Exhibits
1. Inclusionary Housing Info Bulletin
2. Density Bonus Info Bulletin
3. Current Development Activity with Affordable Units
Feb. 12, 2026 Item #1 Page 3 of 19
Community Development Department | 1635 Faraday Ave. | Carlsbad, CA 92008 | www.carlsbadca.gov
Inclusionary Housing Program
IB-157
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 1
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Page 2 of 6 Inclusionary Housing Program IB-157 (September 2025)
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.
Feb. 12, 2026 Item #1 Page 5 of 19
Inclusionary Housing Program IB-157 (September 2025) Page 3 of 6
• 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,
Feb. 12, 2026 Item #1 Page 6 of 19
Page 4 of 6 Inclusionary Housing Program IB-157 (September 2025)
• 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.
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Inclusionary Housing Program IB-157 (September 2025) Page 5 of 6
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
Feb. 12, 2026 Item #1 Page 8 of 19
Page 6 of 6 Inclusionary Housing Program IB-157 (September 2025)
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.
Feb. 12, 2026 Item #1 Page 9 of 19
Community Development Department | 1635 Faraday Ave. | Carlsbad, CA 92008 | www.carlsbadca.gov
Density Bonus IB-112
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 2
Feb. 12, 2026 Item #1 Page 10 of 19
Page 2 of 8 IB-112_State Density Bonus Law_Updated: September 2025
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-330
and Reso No. 2021-074 for the city’s suspension
of the GMP cap limits and performance standard
moratorium provisions.
Density Bonus Calculation
Step two in calculating density bonus is to calculate
the project’s density increase, which represents the
number of units allowed in addition to the base
density units. These additional dwelling units are set
per a sliding scale, based upon two primary factors:
• The percentage of units in the project that will be
set aside (reserved) as affordable; and,
• The household income category of those
affordable units (i.e., very low, low, or moderate
income).
For convenience, a Density Bonus Table is included on
page six of the city’s Density Bonus Report (Form P-
1(H)). As you will see from the table, the number of
affordable units (far left column) and the level of
affordability (top row) greatly influence the number of
density bonus units that can be granted.
For example, a project that reserves 10% of its units as
affordable for very low-income families is eligible for a
32.5% density bonus, as opposed to a density bonus of
Feb. 12, 2026 Item #1 Page 11 of 19
IB-112_State Density Bonus Law_Updated: September 2025 Page 3 of 8
only 20% if those same affordable units were reserved
for low-income families. Refer to info-bulletin
https://www.carlsbadca.gov/home/showpublishedd
ocument/9634/637897580094270000 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
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.
Feb. 12, 2026 Item #1 Page 12 of 19
Page 4 of 8 IB-112_State Density Bonus Law_Updated: September 2025
allocated a certain amount of affordable housing for
very-low income, low-income, or moderate-income
units, as summarized in the section below.
Minimum Eligibility
The proposed density bonus project must comply with
one of the following affordability requirements to be
eligible for an additional density bonus.
• A minimum of 15% of the base units are reserved
for very low-income households; or
• A minimum of 24% of the base units are reserved
for low-income households; or
• A minimum of 44% of the base units are reserved
for moderate-income households.
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
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.
Feb. 12, 2026 Item #1 Page 13 of 19
IB-112_State Density Bonus Law_Updated: September 2025 Page 5 of 8
ineligible for density bonus unless the units are
replaced concurrent with the development of the
project. This provision applies to the following types of
rental units:
• Units subject to recorded restrictions
• Units subject to rent control
• Units occupied by very low- or low-income
households
If household rental income cannot be determined, the
city may assume households are occupied by low-
income households in the same proportion as low-
income renters in the city, consistent with AB 2556.
Additionally, under state law the affordable units
required under density bonus may also be used to
satisfy any replacement unit requirements. This
allowance was clarified in an HCD technical assistance
letter dated December 14, 2023.
DEVELOPMENT STANDARD DEVIATIONS
Traditional development projects must be designed to
comply with city established development standards
and design regulations such as building height
limitations, setback requirements, minimum parking
ratios, and on-site open space directives.
However, under state density bonus law, applicants
can deviate from these development standards when
found that the standards prevent the applicant from
achieving the density allowed under the state law.
There are two types of tools available to applicants:
• Incentives & Concessions
• Waivers
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.
Feb. 12, 2026 Item #1 Page 14 of 19
Page 6 of 8 IB-112_State Density Bonus Law_Updated: September 2025
Number Authorized
The number of incentives/concessions that can be
requested by a developer varies by the amount and
type of affordable units being proposed, as reflected
below.
INCOME % OF AFFORDABLE UNITS1
Very Low 5% 10% 15% 16% ≥80%
Low 10% 17% 24% --- ≥80%
Moderate 10% 20% 30% 45% 20%
Student2 20% --- --- --- ---
Incentives 1 2 3 4 53
1 The % of a project’s affordable units must be at least equal to the listed %.
2 Lower-income student in a dedicated student housing development.
3 To qualify for 5 incentives, a project must reserve at least 80% of the units
for lower income households (very low, low, or combination thereof). The
remaining 20% may be reserved for moderate income households. The
applicant shall also receive a height increase of up to three additional
stories, or 33 feet.
As noted in footnote #1, when determining the
appropriate number of incentives/concessions, a
project’s percentage of affordable units must be “at
least” equal to the percentages shown in the table
above (§65915(d)(2)). In other words, the percentages
in the table are minimums.
So, in the case of the theoretical example project that
reserved 19% of the units for low-income, the
applicant is eligible to receive two
incentives/concessions. If affordable units are
provided to satisfy the city’s inclusionary housing
obligation above required density bonus affordable
units, the total number of affordable units count
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
Feb. 12, 2026 Item #1 Page 15 of 19
IB-112_State Density Bonus Law_Updated: September 2025 Page 7 of 8
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
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
Feb. 12, 2026 Item #1 Page 16 of 19
Page 8 of 8 IB-112_State Density Bonus Law_Updated: September 2025
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.).
Feb. 12, 2026 Item #1 Page 17 of 19
Exhibit 3
Current Development Activity with Affordable Units
The following list of projects only reflects projects with an affordable unit(s) on site. Smaller projects
typically pay a fee or purchase an affordable unit credit rather than constructing the inclusionary unit as
part of the development project. Revenue from those fees are deposited into the Housing Trust Fund to
help further the development of affordable housing in the city. Affordable unit acronyms are: Extremely
Low Income (EL), Very Low-Income (VL), Low Income (L), and Moderate Income (M).
Projects completed in 2025
Project
Name
Location Quadrant Rent/
Own
Affordable Units Total
units
Affordable
Developer
Market
Rate Developer EL1 VL L M Aff2
Vista
Azul3
1380
Laurel
Tree Ln.
SW Rent 7 7 55 - 69 704 BRIDGE
Housing
Wermers
Lucia at
Aviara
1205
Aviara
Pkwy.
SW Rent - - - 12 12 2594 N/A Wermers
Vintage
@ Marja
Acres
4901 El
Camino
Real
NW Rent 5 36 5 - 46 2954 USA
Properties
KB
Homes
Tower 24
Ponto
Beach
7294
Ponto Dr.
SW Rent - - 13 - 13 86 N/A HG
Fenton
Roosevelt
9
2660-
2684
Roosevelt
St.
NW Own - 1 - - 1 9 N/A Tommy
Crudo
Totals 12 44 73 12 141 719
1 These affordable units were underwritten by the Housing Trust Fund to achieve deeper affordability
2 Total affordable units may include an unrestricted manager’s unit
3 Residents moved into Vista Azul in the prior year, however because there were infrastructure elements
dependent on Lucia at Aviara, its final completion date is registered in 2025.
4 These projects are a component of a larger combined project
Projects Under Construction in 2025
Project
Name
Location Quadrant Rent
/
Own
Affordable Units Total
units
Affordable
Developer
Market
Rate
Developer
VL L M Aff
Hope Apts.
Hope/
Grand
Ave.
NW Rent 16 - - 16 156 N/A Wermers
La Costa
Town Square
Family Apts.
3592 Via
Nido
SE Rent - 19 - 19 951 Mirka
Investments Woodside
Homes
Totals 16 19 0 35 251
1 This project is a component of a larger combined project
Feb. 12, 2026 Item #1 Page 18 of 19
Projects Approved in 2025
Project
Name
Location Quadrant Rent/
Own
Affordable Units Total
units
Affordable
Developer
Market
Rate
Developer
VL L M Aff
Carlsbad
Village
Mixed Use
945-1065
Carlsbad
Village Dr.
NW Rent 22 - - 22 218 N/A GRT
Carlsbad
Village, LLC
The
Roosevelt
2621
Roosevelt
St.
NW Rent 2 - 2 4 21 N/A FABRIC
2621
Roosevelt
LLC
Inns of
America
5010
Avenida
Encinas
SW Rent 7 5 3 15 99 N/A MULTI-
FAMILY
INVESTME
NT
PARTNERS
4, LP
Juniper
Coast
Homes1
270
Juniper
Ave.
NW Own 1 - - 1 21 N/A Rincon
Jefferson
Street
Homes
2647
Jefferson
NW Own 1 - - 1 12 N/A Rincon
2502-
2518
Jefferson
2502-
2518
Jefferson
NW Own 1 - - 1 12 N/A Rincon
Totals 34 5 5 44 383
1 In addition to providing one (1) on-site affordable housing unit, the project is conditioned to purchase two
(2) inclusionary housing credits.
Feb. 12, 2026 Item #1 Page 19 of 19
Affordable Housing Development
Mandy Mills, Director
Housing & Homeless Services
February 12, 2026
1
Affordable Housing Development
2
City of Carlsbad plans for
adequate sites that could
accommodate higher density
housing
•2,400 affordable units built since 1995
•Approx. 13% of new housing
•Historically due to Inclusionary Housing and
Housing Trust Fund
Affordable Housing Development
3
More Affordable Housing Every Year
Affordable Housing Development
4
Inclusionary Housing and
Density Bonus are two tools
utilized to create new affordable
housing
Affordable Housing Development
5
Inclusionary Housing
Options Proposed
Units
Percent Yield Rounded
Units
Low 58 X 15%= 8.7 9
Very Low 58 X 12.5%=7.25 7
Affordable Housing Development
6
Density Bonus law offers an
increase in otherwise allowable
density as well as waivers from
development standards in
exchange for the development of
affordable housing.
Affordable Housing Development
7
Sample
Options
Base
Density
Affordable Increase Total
Units
Low 58 58 x 13%=8 58 x 24.5%=15 73
Very Low 58 58 x 13%=8 58 x 42.5%=25 83
VL & Mod 58 58 x 15%=9
+
58 x 15%=9
18
58 x 50%=29
+
58 x 50%=29
58
116
Affordable Housing Development
8
Options Proposed
Units
Inclusionary DB
Affordable
Density
Increase
Total
Units
Low 58 58 x 15%=9 58 x 13%=8 58 x 24.5%=15 73
Very Low 58 58 x 12.5%=7 58 x 13%=8 58 x 42.5%=25 83
VL & Mod 58 58 x 12.5%=7 58 x 15%=9
+
58 x 15%=9
18
58 x 50%=29
+
58 x 50%=29
58
116
Inclusionary Housing compared to Density Bonus
Affordable Housing Development
9
Projects completed in 2025
Project Name Location Quadrant Rent/ Own Affordable Units Total units Affordable Developer Market Rate
Developer EL1 VL L M Aff2
Vista
Azul3
1380
Laurel
Tree Ln.
SW 7 7 55 70 704 BRIDGE
Housing
Wermers
Lucia at
Aviara
1205
Aviara
Pkwy
SW Rent - - - 12 12 2594 N/A Wermers
Vintage
@ Marja
Acres
4901 El
Camino
Real
NW Rent 5 36 5 - 47 2954 USA
Properties
KB
Homes
Tower 24
Ponto
Beach
7294
Ponto Dr.
SW Rent - - 13 - 13 86 N/A HG
Fenton
Roosevelt
9
2660-
2684
Roosevelt
St.
NW Own - 1 - - 1 9 N/A Tommy
Crudo
Totals 12 44 73 12 143 719
1 These affordable units were underwritten by the Housing Trust Fund to achieve deeper affordability
2 Total affordable units may include an unrestricted manager’s unit
3 Residents moved into Vista Azul in the prior year, however because there were infrastructure elements
dependent on Lucia at Aviara, its final completion date is registered in 2025.
4 These projects are a component of a larger combined project
Affordable Housing Development
10
Affordable Housing Development
11
Projects Under Construction in 2025
Project
Name
Location Quadrant Rent/
Own
Affordable Units Total
units
Affordable
Developer
Market
Rate
Developer VL L M Aff
Hope Apts.
Hope/
Grand
Ave.
NW Rent 16 - - 16 156 N/A Wermers
La Costa
Town Square
Family Apts.
3592 Via
Nido
SE Rent - 19 - 19 951 Mirka
Investments
Woodside
Homes
Totals 16 19 0 35 251
1 This project is a component of a larger combined project
Affordable Housing Development
12
Affordable Housing Development
13
Projects Approved in 2025
Project
Name
Location Quadrant Rent/
Own
Affordable Units Total
units
Affordable
Developer
Market
Rate
Developer
VL L M Aff
Carlsbad
Village
Mixed
Use
945-
1065
Carlsbad
Village
Dri.
NW Rent 22 --22 218 N/A GRT
Carlsbad
Village,
LLC
The
Roosevelt
2621
Roosevelt
St.
NW Rent 2 -2 4 21 N/A FABRIC
2621
Roosevelt
LLC
Inns of
America
5010
Avenida
Encinas
SW Rent 7 5 3 15 99 N/A MULTI-
FAMILY
INVESTME
NT
PARTNERS
4, LP
Juniper
Coast
Homes1
270
Juniper
Ave.
NW Own 1 --1 21 N/A Rincon
Jefferson
Street
Homes
2647
Jefferson
NW Own 1 --1 12 N/A Rincon
2502-
2518
Jefferson
2502-
2518
Jefferson
NW Own 1 --1 12 N/A Rincon
Totals 34 5 5 44 383
1 In addition to providing one (1) on-site affordable housing unit, the project is conditioned to purchase
two (2) inclusionary housing credits.
Affordable Housing Development
14
Where to find information?
https://www.carlsbadca.gov
Affordable Housing Development
15
Where to find information?
https://www.carlsbadca.gov
Questions?
Affordable Housing Development
16