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HomeMy WebLinkAboutPRE 2026-0004; HIGHLAND VISTA; Admin Decision LetterMarch 18, 2026 CHRIS ELSEY THE PRIME COMPANY 2021 VANESTA PLACE, STE. A MANHATTAN, KS 66503-0381 SUBJECT: Dear Mr. Elsey, PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA APN: 206-192-14-00 {city of Carlsbad VIA EMAIL AND MAIL 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 10 single-family residential lots with 10, 1,750-square foot, two-story single-family units with attached two-car garages on a vacant parcel generally located northeast of the intersection of Highland Drive and Adams Street. Access is proposed to be provided by a 20 -foot-wide private driveway off Highland Drive. The subject property is approximately 0.76-acres (33,105 square feet), is currently undeveloped, and is adjacent to residential development to the north and south with protected sensitive upland habitat to the east. Topographically, the site slopes from northwest to southeast with approximately 10 feet of elevation fall from Highland Drive to the southeast corner of the site(151 ft AMSL to 161 ft AMSL). The average floor area of the 10 units equates to 1,750 square feet. In response to your application, the Planning Division has prepared this comment letter. Please note that the purpose of a prelim inary 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) b. Zoning: One-family Residential with minimum 15,000 square foot lot sizes (R-1-15,000). Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Pa e 2 2. 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. Applicability of SB-684 and/or SB-1123 in the California Coastal Zone. The City of Carlsbad has a certified Housing Element and the Planning Division within Community Development Department 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, based on review of the state law, it is not clear 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 Costa I Development Permit without hearings is required, but similarly that language is not included in this statue. 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. Currently, the gross/net project density for the proposed project, at 13.1 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 seven units and the R-1-15,000 Zoning designation which requires a minimum lot size of 15,000 square feet. Therefore, the current proposal is noncompliant as presented. The maximum number of units proposed on fee simple lots that could be constructed on the subject 0.76-acre lot {33,029 square feet) is two units. Further, 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 Mello II Segment of the LCP can be found on the City of Carlsbad Community Development Department's website at: LCP: https://www .ca rlsbadca .gov /home/showpu blisheddocu ment/236/63 7 42597 4089530000 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 several objective standards within the city's regulatory framework that the project Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012)-HIGHLAND VISTA March 18, 2026 Pa e 3 does not comply with and are included in the body of this letter. Compliance with these objective standards is allowed pursuant to Government Code 65858.28. Notwithstanding the above, staff is required to accept an application 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 and Planned 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. In addition to what is discussed in Comment No. 2 above, this project site is ineligible for a SB- 1123 small lot subdivision for the following reasons: a. Eight of the 10 parcels do not have frontage along a public street and access is proposed via private driveway aisle. Since a driveway is proposed to access the units, the project would be subject to Carlsbad Municipal Code (CMC} Chapter 21.45, the Planned Development Ordinance, which includes a list of objective standards which can be applied to a project. The subject site is zoned R-1. Pursuant to Table A of CMC Section 21.45.040 (see screenshot below), Permitted Residential Uses, one-family dwellings on small lots (i.e., no condominiums) can only be permitted in the R-1 zone if the site is either contiguous to a higher intensity land use designation or zone or an existing project of comparable or higher density or if the site has sensitive biological resources (see Notes 1 and 4 in table below). Neither of these scenarios apply. Therefore, the project cannot be designed as fee simple lots. If a common interest development is proposed, such as condominiums, the units cannot be attached since the site does not contain sensitive biological resources (see Note 4 in Table A below). If the project were to be redesigned so that there were two or more detached condominium units on one lot (see "One-family dwellings", Note 3), the project would qualify for a Planned Development permit but would still be required to comply with all applicable objective standards of the Planned Development Ordinance (see Comment 9 below). In summary, the only option is to design the project as detached condominiums. Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Page 4 Table A Permitted Residentii.'11 Uses Legend: P = Permilled. (II) Number within parentheses = Permitted only in certain circumstances. X = Not pennilted. Zone R-2 R-3 RD-M R-W R-P llMHP P-C V-B Accessory Uses Notes: Residential Use One Family Dwelling or Tw111 Home on Small lol..5 (one unit per lot) (l) or 4 p p p X (s) p (7) (8) (9) Con ornm1um P101ect One family dwe1hngs • (3) or (4) Two-family dwellings -(1 or~) Mull iple-famrly dwellings -(4) One-family or two-family dwellinbJS -P Multiple-fumily dwellings -(2) or (4) p p p (6) p (7) (8) (9) (1) 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. (2) Permitted when the proposed project site is contiguous lo a lot or lots zone R-3, R-T, R·P, C-1, C-2, C-M or M, but in no case shall the project site consist of more than one lot nor be more than 90 feet in width, whichever is less. (3) Pennitted when developed as t\'/0 or more detached units on one lot. (4) Permitted when the project site cont.tins sensitive biological resources as identified in the Carlsbad Habitat Management Plan. In the case of a condominium project, attached or detached units may be permitted when the site contains sensitive biologic.ti resources. (s) Permitted when 1he R-P zone implements the R-15 land use designation. (6) Permitted when the R-P zone implements the R•1s or R-23 land use design;;ilions. (7) Permitted uses shall be consistent with the master plan. (8) Refer to the Village and Barrio master plan for permitted uses. (9) Refer to Table F for permitted accessory uses. (Ord. NS-834 §II, 2007; O1d. CS-099 §II, 2010; Ord. CS-334 § 10, 2018; Ord. CS-432, 9/27/2022) c. It is not clea r whether a 24-foot-wide drive aisle would be provided as the two site plan exhibits (not drawn to scale) note a proposed width of 20 feet and 26 feet. The Fire Department requ ires requirements a 24-foot-wide drive aisle. This is an objective standard which the project will be required to comply with. d. The project does not provide a 60-foot-wide fire buffer from the eastern property line as required by the Fire Department. 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 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 pe rmitting steps shall apply to processing a Coastal Development Permit (CDP) for eligible lots within the Coastal Zone . Community Development Department Pl anning Division [ 1635 Faraday Avenue [ Carlsbad, CA 92008-7314 [ 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Pa e 5 5. • 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-l(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. b. Tentative Tract (CT) Map. This permit is required for the subdivision of the property into five or more lots. 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 .ca rlsbadca .gov /ho me/showpubl isheddocument/20580/638912915136600000 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-l(B)). Please see link to P-2 application below: P-1: https://www.carlsbadca.gov/home/showpublisheddocument/13872/63849648061150000 0 P-2 : https://www .ca rlsbadca .gov /home/showpublisheddocument/197 22/63873 7 56624217211 2 • 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. This project requires a Coastal Development Permit. As such, the proposed project involves an approval that contains a discretionary action and, pursuant to CEQA Guidelines §15268(d), the project is NOT ministerial and is subject to the requirements of CEQA. Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Page 6 6. Habitat Management Plan (HMP) and Local Coastal Program (LCP) Requirements. The project site is adjacent to sensitive upland habitat to the east. 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: HM P: https://www .ca rlsbadca .gov /home/showpubl isheddocume nt/224/63 7 446616709600000 LCP: https://www.carlsbadca.gov/home/showpublisheddocument/236/637425974089530000 7. Conceptual Landscape Plans. 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. 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.ca rlsbadca .gov/ civicax/fi le ban k/blo bd I oa d .a spx? Blob I D=24086 As part of this submittal, please be sure to include a Fire Protection Plan and address all applicable Fire Protection Policies. 8. The subject parcel is located within the McClellan-Palomar Airport Influence Area (AIA). New development within the AIA must be reviewed for consistency with the adopted land use compatibility plan for the airport, in this case the McClellan-Palomar Airport Land Use Compatibility Plan (ALUCP), adopted on January 25, 2010 and later amended on March 4, 2010 and December 1, 2011. Review of ALUCP can be found on the City of Carlsbad Community Development Department's website at: https://www .ca rlsbadca .gov /home/showpublisheddocu me nt/226/63 7 4466177 5 7230000 Preliminary review of the prnposed project against the ALUCP revealed the following: a. Exhibit 111-1-Compatibility Policy Map: Noise. The subject parcel is located outside of the 60 db CNEL noise exposure range per Exhibit 111-1. Pursuant to the ALUCP Section 3.3.3(a) on page 3-19: "The threshold for evaluation is the projected 60 dB CNEL contour. This contour defines the noise impact area of the Airport. All land uses located outside of this noise contour are consistent with the noise compatibility policies." Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Pa e 7 b. Exhibit 111-2 -Compatibility Policy Map: Safety. Pursuant to Exhibit 111-2, the subject parcel is located outside and beyond the respective safety zones 1-6; and thus, the residential use is considered compatible. c. Exhibit 111-3 -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 111-3. 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 111-4 -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 111-5 -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 111-6 -Compatibility Policy Map: Avigation Easement Area and Overflight Notification Areas . The project site is located outside of the Avigation Easement Area but is located within the Airport Overflight Notification Area. Recordation of an overflight notification document is a condition of new residential development located within the Airport Overflight Notification Area. 9. The following comments will apply if it is determined by the state that SB 1123 supersedes the city's Local Coastal Program land use density of 0-4 dwelling units per acre AND the project is redesigned as detached condominiums. Please be advised, the concept project proposal conflicts with the following objective standards of the Planned Development Ordinance, CMC Chapter 21.45: Table C: a. The drive aisle shall be enhanced with decorative pavers (C.5) b. The minimum width of the drive aisle shall be 24 feet pursuant to comments from the Fire Department (C.5) Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Page 8 c. A total of 480 cubic feet of storage is required; can be satisfied by a two-car garage with a minimum dimension of 20 feet wide x 20 feet deep, free and clear (walls excluded) {C.13) Table E: a. The design of the units shall comply with City Council Policy No. 84, Neighborhood Architectural Guidelines (E.1): https://www .ca rlsbadca .gov /ho me/showpu blisheddocument/260/638417044 776730000 b. The front yard setback off Highland is 10 feet if there is no direct garage entry or 20 feet if garage entry off the street. Setbacks shall be taken from property line, after any ROW dedication. From the drive aisle, the house shall be setback S feet and the garage 3 feet {E.4) c. 400 square feet of private recreation space per detached condominium unit (E.7) 10. Building height. The maximum building height in the Coastal Zone is 30 feet with a minimum 3:12 pitch and 24 feet if less than 3:12 roof pitch. Please be advised, building height is measured from existing or proposed grade, whichever is lower. If fill is required for construction, the height of the fill shall be added to the building height measurement. In addition, building height is measured to the tallest point of the roof. Please include multiple cross sections with the formal submittal. 11. 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.geode.us/ codes/ ca rlsbad/view. ph p ?topic= 18&fra m es=on To the extent that new GHG reduction requirements are in effect at the time of application for grading or building permits, the project will be required to comply with the effective requirements even if different than what is proposed in the project's planning approvals. GHG reduction requirements may impact, but are not limited to, site design and local building code requirements. If incorporating new GHG reduction requirements results in substantial modifications to the project after planning approvals are obtained, then prior to issuance of grading or building permits, the applicant may be required to submit and receive approval of a Consistency Determination or an Amendment application for the project through the Planning Division. All necessary application forms, submittal requirements, and fee information are available at the Planning counter located in the Faraday Building at 1635 Faraday Avenue or online at https://www.carlsbadca.gov/departments/community-development/planning. You may also access the General Plan Land Use Element and the Zoning Ordinance online at the website address shown. Please review all information carefully before submitting. Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Page 9 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 available at: https://www.carlsbadca .gov/home/showdocument?id=312. 2. Complete a Stormwater Standards Questionnaire Form E-34, https://www.carlsbadca .gov/home/showpublisheddocument/604/638683035715330000. This questionnaire will guide you and the city in determining what type of reports and storm water mitigation must be completed to satisfy state and City storm water quality requirements. The questionnaire is located on the City of Carlsbad website. 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. 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. 8. A preliminary geotechnical report is required to evaluate the feasibility of the project. Provide recommendations for infiltration and remedial excavation requirements. Guidelines for preliminary geotechnical studies are available on the City of Carlsbad Engineering website, https ://www .ca rlsbadca .gov /home/showpublished docu ment/326/6380540067 4 7270000 9. Per CMC15.16.060 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. Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Page 10 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. Delineate and annotate the limits of grading. 13. Delineate and annotate approximate topographic contours for existing and proposed condition. Provide a conceptual grading and drainage plan with 1-foot contours for slopes less than 5%; 2' . intervals for slopes between 5% and 10%, and 5' intervals for slopes over 10%. Extend contours a minimum 25 feet beyond the project boundary. 14. On the site plan, show and identify all existing surface improvements screened back (curb, gutter, sidewalk, paving, manholes, inlets, streetlights, adjacent driveways, vaults, transformers, etc.) at the project site, project frontage and within 25 feet of the boundary. 15. Delineate location of all existing and proposed buildings, walls, fences and permanent structures onsite and within 25 feet of the site. 16. Indicate the earthwork quantities (cut, fill, import, export, remedial) proposed for the project in cubic yards. 17. Provide spot elevations at the corners of each pad in the proposed condition. Include finish pad and floor elevations. 18. 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. 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. 20. The project frontage has been identified in the city's inventory as a vacant planting site. Coordinate with the parks and recreation department for planting requirements per Section 11.12 of the Carlsbad Municipal Code for additional information. 21. Show existing lot line bearing and distance and identify the frontage street. 22. Provide proposed parcel/lot areas on the site plan. This project is proposing a subdivision to create 10 lots/parcels. A tentative map is required. 23. Provide typical street cross sections for Highland Drive. Provide existing right-of-way width and existing improvements and proposed improvements and dedications. 24. Show all existing and proposed utilities and callout size for: water, sewer, storm drain, underground dry utilities, overhead lines, traffic signals, streetlights in Highland Drive and Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Page 11 laterals affecting the property. 25. 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. 26. Sewer services shall be shown for each lot. If a private sewer service will be utilized to service parcels 3-10, this will need to be constructed prior to/concurrent with map approval, additionally private covenants of easement for sewer will be required along with a mechanism to assess proportional payment. 27. Provide a Sewer Study for new development based on City of Carlsbad Sewer Master Plan Update 2019, Section 4.2 Design Criteria. 28. Provide a Water Study for the new development based on City of Carlsbad Potable Water Master Plan 2019, Section 4.2 Design Criteria. 29. 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. 30. 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. 31. 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. 32. Dedications and frontage improvements are required per CMC20.16. A 5 foot wide public street and utility easement shall be dedicated. Frontage improvements are not required at this time, as this street is an alternative design street. 33. 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. Public improvements shall include, but are not limited to paving, base, sidewalks, curbs and gutters, grading, clearing and grubbing, undergrounding or relocation of utilities, sewer, water, fire hydrants, streetlights, and reclaimed water. 34. Meet with the Fire Department to identify the necessary fire protection measures required for this project (access, fire hydrants, sprinkler system, on-site circulation, emergency access, etc.) Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Page 12 35. Although SB-1123 provides streamlining the approval process, the proposed subdivision shall still conform to all applicable objective requirements of the Subdivision Map Act and Carlsbad Municipal Code, Title 20. a. CMC20.16.010(C) Every lot of the subdivision shall front on a dedicated street unless otherwise authorized by Title 21 for the zone in which the lot is located at the time the final map is approved. The 26-foot wide drive aisle width as shown on the site plan meets the minimum requirement as identified in the PUD; however, the fire department may require additional width. b. CMC20.16.040 Required improvements provided by the subdivider, include easements and rights-of-way for access (this includes the drive aisle) as well as installing the driveway, backbone sewer improvements, post construction BMPs and drainage structures necessary to support the subdivision prior to map approval. c. CMC20.16.040(D) All new electrical facilities to service the subdivision shall be underground. 36. 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: Habitat Management Plan {HMP) Comments 1. The project site is on a disturbed lot adjacent to mature, high quality coastal sage scrub, located east of the property. Coastal sage scrub is a protected habitat type. This habitat is not an HMP Existing Hardline, Proposed Hardline or Standards Area, but is General Plan Open Space Type 1. 2. The project site is located within the coastal zone and subject to HMP Coastal Zone Standards, including but not limited to: o Coastal sage scrub and other native habitat types require a 20-foot buffer between the habitat and any development or impact. o If the buffer does not currently support native plants, the buffer must be planted with natives. 3. Because the property is adjacent to habitat, it must be consistent with HMP Adjacency Standards. 4. The project site is not located within a moderate, high or very high fire hazard zone; however, pursuant to comments received from the Fire Department, a 60-foot-wide, onsite Fuel Modification Zone (FMZ) is required around the structures. Any such FMZ is an impact and must not overlap with the adjacent habitat offsite. The FMZ may overlap with the required 20-foot upland habitat buffer. 5. Please submit a biology report consistent with the city's most current guidelines (https://www.carlsbadca.gov/home/showpublisheddocument/1604/637819050500430000). Specifically, the report must: o Include vegetation mapping of the project property plus 100 feet Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Page 13 o Show the 20-foot upland buffer on a biological resources figure o Show any required Fuel Modification Zones o Show the Open Space Type 1 on adjacent properties o Address HMP Coastal Zone Standards and Adjacency Standards Public Works -Utilities: 1. A water study shall be required for the proposed project that includes domestic water service meters and fire flow sizing criteria per the applicable NFPA fire flow requirements and the current City of Carlsbad Engineering Standards. 2. A sewer study shall be required for the project analyzing the existing and proposed sewer demands on the public sewer main in accordance with the current City of Carlsbad Engineering Standards. 3. Updated Civil Site Plans shall identify and detail proposed water and sewer connections in compliance with current Carlsbad Engineering Design Standards. a. CMWD's preference is to serve the project site's water demand through a single master meter. Alternatively, each separately owned parcel shall have a dedicated service and meter at the Highland Dr property line and adequately spaced per current Engineering Standards. b. A single private 6-inch sewer lateral shall be provided to serve all private parcels within the proposed lot and connect into the existing public main in Highland Dr. 4. Show and identify all utilities in the right-of-way along parcel frontage, including existing 8" PVC public water main and existing 8" PVC public sewer main. 5. Identify any existing easements or required right-of-way dedication on updated site plan. Fire & Life Safety: 1. Parcel is in a fire suppression zone as mapped by the city of Carlsbad. The project shall meet the 60-feet defensible space requirements in accordance with the Landscape Manual. The required landscape plan shall include the fuel modification zones overlayed. 2. The private drive aisle required for shall be a minimum width of 24 feet for fire access. 3. All dwellings shall be sprinklered. 4. 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 submitting a formal project application. A completed, city-reviewed, Form P-99F shall Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600 PRE 2026-0004 (DEV2026-0012) -HIGHLAND VISTA March 18, 2026 Page 14 accompany a formal 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 Housing & Homeless Services: 1. Project is subject to Carlsbad Municipal Code Chapter (CMC) 21.85, requiring purchase of affordable housing credit (City Council Policy No. 157). Please see link below for additional information: https://www.carlsbadca.gov/home/showpublisheddocument/9634/638938058103500000 Building: No comments provided. If you would like to schedule a meeting to discuss this letter with the commenting departments, please contact Shannon Harker at the number below. You may also contact each department individually as follows: • Planning: Shannon Harker, Senior Planner, at (442) 339-2621 • 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: Nicole Piano Jones, Senior Program Manager, at (442) 339-2191 • Building: Jesse Sanchez, Building Official, at jesse.sanchez ctr@carlsbadca.gov Sincerely, ~~- ERIC LARDY, AICP Assistant Director of Community Development EL:SH:cf c: Roger and Karen Newman, 1546 El Nido Drive, Fallbrook, CA 92028 Laserfiche/File Copy Data Entry Community Development Department Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008-7314 I 442-339-2600