HomeMy WebLinkAbout2026-06-03; Planning Commission; 01; Salk Avenue Apartments ProjectMeeting Date: June 3, 2026 1
To: Planning Commission
Staff Contact: Kyle Van Leeuwen, Senior Planner, 442-339-2611,
kyle.vanleeuwen@carlsbadca.gov
Subject:
Location:
Case Numbers:
Applicant:
CEQA Determination: ☐Not a Project ☐ Exempt ☒ IS/ND or IS/MND ☐ EIR
Permit Type(s): ☒SDP ☐ CUP ☐ CDP ☐ TM/TPM ☐ GPA ☐ REZ ☐ LCPA
☐Other:
Commission Action: ☒Decision ☐ Recommendation to City Council ☐ Informational (No Action)
Recommended Actions
That the Planning Commission 1) ADOPT the Planning Commission Resolution (Exhibit 1) ADOPTING an SB 131
Focused Initial Study and Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program; and
2)ADOPT the Planning Commission Resolution (Exhibit 2) APPROVING a Site Development Plan SDP 2025-0004
based upon the findings and subject to the conditions contained therein.
Existing Conditions & Project Description
Existing Setting
The subject property consists of Housing Element Site
7, adopted by the City Council on January 30, 2024,
effectively re-designating this site from commercial to
residential with the intent of developing a multiple-
family housing unit project at a high density.
The 9.78-acre site is located along Salk Ave. between
College Blvd. and El Camino Real. Adjacent to the site
are existing light industrial buildings to the east and
south, and a private driving range and golf facility to the
west. A Scripps medical office building is located to the
north with open space areas around the development.
The site has previously graded development “pad” of
approximately 6.3 acres, with an area in the northwest
corner that slopes down to a basin. Site access is via a
driveway in the northeast corner. The site is located
within the Fenton Carlsbad Center Specific Plan.
June 3, 2026 Item #1 1 of 417
Table “A” below includes the General Plan designations, zoning, and current land uses of the subject site and
surrounding properties.
TABLE A – SITE AND SURROUNDING LAND USE
Site R-30, Residential (26.5-30
dwelling units per acre)
Residential Density - Multiple
(RD-M) Vacant Site (Graded)
North Open Space (OS) &
Office (O)
Open Space & Office
(OS & O)
Open Space (Conservation)
and Medical Offices
South Planned Industrial (PI) Light Industrial and Office
East Office (O) Office (O) Light Industrial and Office
West Open Space (OS) &
Planned Industrial (PI)
Open Space & Heavy Commercial
(OS & C-M)
Private Driving Range and
Golf Facilities (TaylorMade)
General Plan Designation(s)
Zoning Designation(s)
Background
The approval of the city’s Housing Element in 2021 details how Carlsbad is planning to accommodate projected
housing needs through 2029. In addition to updating housing policies, Carlsbad was required to designate space
for about 3,900 new housing units. Of these new housing units, units need to be affordable for people with
lower incomes. On Jan. 30, 2024, the City Council voted to approve a rezoning of 16 properties around Carlsbad
to meet state requirements. This action will help the city maintain control over where future housing can be
built in the city, and at what density. The subject property is one of these 16 housing sites identified as Housing
Element Site 7. The Fenton Carlsbad Center Specific Plan was amended in 2024 to change the land use
designation of the project site to R-30 (Residential 26.5-30 du/ac), consistent with the Housing Element program
1.1.
June 3, 2026 Item #1 2 of 417
Proposed Project
The project developer, Hanover R.S. Limited Partnership, herein referred to as “Developer,” has submitted
application for the development of a multi-family residential development on an approximately 9.8-acre vacant
site located on Salk Avenue consisting of 397 multi-family residential dwelling units within one five-story
building and one five-story above-grade parking garage attached to the apartment building. The project is
proposing a residential density of 40.5 dwelling units per acre.
The Developer is seeking a density bonus under State law, which would entitle the Developer to increase the
density of the project by 35% in return for designating at least 20% of the 294 base dwelling units as affordable
to low-income households (59 units). The density bonus that is authorized by State law (Gov. Code §65915) is
set on a sliding scale based upon the percentage of affordable units in the project, ranging from 5% to 50%
additional units over the base number of units permitted pursuant to the General Plan and Specific Plan. With
the 35% density bonus, the maximum number of residential units allowed on the site is 397 units, with 59 of
those required to be restricted as affordable to low-income households (per State Density Bonus Law).
In addition to the affordable units provided for the project to be granted a density bonus under State law, the
Developer is required to comply with Carlsbad’s Inclusionary Housing Ordinance. Under the inclusionary
ordinance, developments proposing a total of seven or more units must provide at least 15% of the
development's base density units as affordable to lower income households. In addition, the Fenton Carlsbad
Center Specific Plan requires any residential project on this site to provide a minimum of 20% of the development's
base density units as affordable units. The 59 units that are deed restricted to low-income households (80% of
the area median income) satisfies the State Density Bonus Law, the Inclusionary Housing Ordinance, and the
specific plan requirements. The project is proposing 12 density bonus waivers that are discussed in Exhibit 7.
Pursuant to the Residential Density-Multiple (RD-M) Zone, a maximum height limit of 45 feet applies to the site.
The project will utilize a density bonus waiver to allow a maximum building height limit of 59 feet in height.
Parapets, elevator equipment area, and architectural features, such as tower elements, up to 74.5 feet tall are
also proposed. No roof structures or any other space projecting above the roof top provides additional usable
floor space beyond its purpose.
The residential building design incorporates stucco as the primary building material with stone base tiles, metal
guardrails, and concrete roof tiles. Accents include metal coping, vinyl windows and “dark bronze” aluminum
storefronts.
A general breakdown of the apartment unit types is summarized in Table “B” below.
TABLE B – DETAILS FOR UNIT TYPE
To address open space requirements and provide amenities for the residential project, a total of 26,955 square
feet of common recreation space is proposed. Common open space includes three (3) interior courtyard areas
on the ground level, which include a pool and spa and outdoor grill areas. The 26,955 square feet of common
recreation space is less than the 39,700 square feet of common recreation space required by the City-Wide
Unit Type Total
Studio 628 SF 3 1 4
One-Bedroom 741 SF 213 40 253
Two-bedroom 1,107 SF 98 14 112
Three-bedroom 1,371 SF 24 4 28
June 3, 2026 Item #1 3 of 417
Objective Design Standards (ODS). The project will utilize a density bonus waiver to allow this reduction in
otherwise required recreational space. The project also proposed other amenities, such as a club room, fitness
center, media room, and a golf simulator for common use among the tenants, but these spaces do not count
toward common recreational space as they are not outdoors.
Pursuant to State Density Bonus Law (Gov. Code §65915(p)(1)), the residential project is required to provide one
(1) parking spaces per studio or one-bedroom unit and 1.5 parking spaces per two-bedroom and three-bedroom
unit. This requirement results in a minimum requirement of 467 parking stalls. However, the project will
provide a total of 542 parking stalls at grade surrounding the residential buildings and within an attached five-
story a parking structure.
Grading for the proposed project includes 10,151 cubic yards of fill and 18,567 cubic yards of cut. As a result, a
total of 8,416 cubic yards of material is proposed to be exported from the site. Plans are attached to the staff
report (Exhibits 12 and 13).
Public Outreach & Comment
The Developer has completed the Early Public Notice procedures pursuant to City Council Policy No. 84
(Development Project Public Involvement Policy). A notice of project application was mailed on Oct. 27, 2025, to
all property owners and occupants located within a 900-foot radius of the project site (expanded from 600-foot
radius to reach at least 30 unique owners). A two-foot-tall by three-foot-wide yellow sign was also posted at the
project site on Nov. 3, 2025, notifying all pass-by traffic of the project, which provides project name, application
numbers, description, as well as both Developer and city staff contact information. A total of 95 property
owners and occupants were notified through the notice of project application.
In addition to the above, the Developer also completed the Enhanced Stakeholder Outreach Program pursuant
to City Council Policy No. 84 (Development Project Public Involvement Policy). In this case, the Developer
created a project website and held a public outreach meeting. The notice that was mailed on Oct. 27, 2025,
included a URL to a project website (www.salkaveapartments.com) for those interested in learning more about
the project and/or providing feedback. The Project website included information about the project, conceptual
project images, and a fillable form to provide feedback. A public outreach meeting was held on Monday, Nov.
10, 2025, from 5:30 p.m. to 7:00 p.m. at the Residence Inn at 2000 Faraday Ave. No member of the public
attended the outreach meeting. A copy of the outreach report is included as Exhibit 10.
Response to Public Comment & Project Issues
Only one comment on the project was received as part of the Enhanced Stakeholder Outreach report, included
in Exhibit 10. This comment did not raise concerns with the project proposal, and instead asked questions of the
Developer regarding the inclusion of affordable units and timing of project construction and completion.
June 3, 2026 Item #1 4 of 417
Project Analysis
General Plan Consistency
The City of Carlsbad General Plan includes several goals and policies that guide development and land use
within the city. A discussion of how the project is consistent with the applicable General Plan policies is
summarized in Exhibit 5.
Fenton Carlsbad Center Specific Plan and Municipal Code Consistency
The Fenton Carlsbad Center Specific Plan as well as requirements and provisions in Title 21 of the Municipal
Code (Zoning Ordinance) guide development and land use within the city, consistent with the General Plan.
Specific compliance with these relevant requirements is described in Exhibit 5.
City-Wide Objective Design Standards
The City-Wide Objective Design Standards (ODS) grants local authority over the design of future multi-family
housing and mixed-use developments within the City, outside of the Village and Barrio Master Plan area. These
standards help the city preserve the unique character of the city while adhering to state housing laws aimed at
accelerating housing production. Specific compliance with these relevant standards is described in Exhibit 5.
State Density Bonus
The Developer is seeking an increase in the allowable density of the project under Gov. Code §65915, the State
Density Bonus Law. This law allows a developer to increase the density on a property above the maximum limit
set by a city’s general plan in exchange for reserving a certain number of the new dwelling units as affordable or
other qualifying housing for at least 55 years. Developers can also have development standards waived or
revised when such deviations are needed to achieve the density allowed under State law.1 The 9.78 acre site is
has a General Plan Land Use dedication of R-30, Residential, which permits a density range of 26.5 to 30 dwelling
units per acre (stated as a minimum to maximum density range). This results in a maximum base density of
293.4 units (9.78 acres multiplied by 30 units per acre), which rounds up to 294 units for this site (pursuant to
Density Bonus Law, all density calculations are rounded up.) The density bonus that is authorized by State law is
set on a sliding scale based upon the percentage of affordable units in the project, ranging from 5% to 50%
additional units over the number ordinarily permitted. The Developer is requesting a 35% density bonus allowed
under State law, for a total of 103 additional units (294 units multiplied by 35% rounded up). In exchange for the
35% density bonus, the Developer is required to designate 20% of the 294 base maximum density units, or 59
units, as affordable density bonus units. The affordable density bonus units are required to be affordable to
“low-income households” for a period of 55 years. At the maximum 35% density bonus, a total of 397 units could
be constructed, and the Developer is proposing to construct the maximum 397 units at a density of 40.6 dwelling
units per acre. The project requests incentives, concessions or waivers as allowed under State Density Bonus
Law. Pursuant to Carlsbad Municipal Code (CMC) Section 21.86.060 of the Density Bonus Ordinance, a project
can request incentives, concessions and waivers as defined in State Density Bonus Law, based on the percentage
of affordable units.
Specifically, the Developer is requesting 12 waivers from development standards as listed below and included in
Exhibit 7. Pursuant to State Density Bonus Law, there is no limit to the number of waivers an applicant can
request as long as the waiver does not cause a specific adverse impact on public health or safety, an adverse
impact on property listed on the California historical register or would violate state or federal law.
1 Refer to Exhibit 8 for an info-bulletin that provides more information on how State Density Bonus Law works.
June 3, 2026 Item #1 5 of 417
Waivers
• Waiver of Objective Design Standard 2.A.2 requiring an on-site common recreational space located
outdoors and adjacent or visible from the primary street (applicable to project with 50 units or more).
• Waiver of Objective Design Standard 2.B requiring parking within 15 feet of a residential unit to be
located within a structure or be screened.
• Waiver of Objective Design Standard 2.D requiring 100 sf/unit of common recreational space (39,700 sf).
• Waiver of Objective Design Standard 2.F.1 requiring a landscape buffer of minimum five feet be located
adjacent to all ground-level residential space.
• Waiver of Objective Design Standard 3.A.2 requiring a two-foot variation in depth of wall plane for every
40 feet of building façade that is visible from a primary street.
• Waiver of Objective Design Standard 3.A.2.a limiting upper floors to a maximum of 90% of the ground
floor total area.
• Waiver of Objective Design Standard 3.A.4 limiting the horizontal distance of a roofline to more than 40
feet without a prominent change.
• Waiver of CMC 21.21.030 limiting the height of a structure in the RD-M zone to 35 feet.
• Waiver of CMC 21.44.060 (Table D) requiring parking spaces within a garage be 8.5’ x 20’.
• Waiver of Objective Design Standard 2.E requiring each unit be provided private recreation space
(balcony or patio).
• Waiver of CMC 21.85.030.C requiring at least 10% of provided lower income units have three bedrooms
or more.
• Waiver of CMC 21.46.130 limiting walls and fencing outside of setback areas to six feet in height.
Inclusionary Housing Ordinance
In addition to the affordable units provided for the project to be granted a density bonus under State law, the
Developer is required to comply with Carlsbad’s Inclusionary Housing Ordinance. Under the inclusionary
ordinance, developments proposing a total of seven or more units must provide at least 15% of the
development's base density units as affordable to lower income households. However, sites that were rezoned
or identified as a housing site to implement the Housing Element are required to provide a minimum of 20% of
the development’s base density units as inclusionary (City Council Resolution No. 2024-016). In addition, the
Fenton Carlsbad Center Specific Plan requires any residential project on this site to provide a minimum of 20% of
the development's base density units as affordable units. This project is required to provide 59 units as deed
restricted to low-income households (80% of the area median income), which satisfies the State Density Bonus
Law, the Inclusionary Housing Ordinance, and the specific plan requirements. The project is proposing 12 density
bonus waivers that are discussed in Exhibit 7.
June 3, 2026 Item #1 6 of 417
Summary of density bonus request and calculations
No. of Units (Requested/Proposed) 397 units
* As approved by Resolution 2024-016, the site is included in the Housing Element Rezone program and is required to provide 20 percent of Inclusionary
Housing for Low-Income Households.
**Inclusionary units also count as Density Bonus Affordable Units
Housing Crisis Act of 2019 (HCA)
This project is subject to California Gov. Code §65589.5(j)(1), which states when a proposed housing
development project complies with the applicable, objective general plan, zoning, and subdivision standards and
criteria that were in effect at the time that the application was deemed complete, cities shall not disapprove the
project or impose a condition requiring lower density unless the city finds based on a preponderance of
evidence that the project would have a specific, adverse impact on public health and safety, or there is no
feasible method to satisfactorily mitigate or avoid such adverse impact. A “specific, adverse impact” means a
significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or
safety standards, policies, or conditions as they existed on the date the application was deemed complete; and
there is no feasible method to satisfactorily mitigate or avoid the adverse impact, other than the disapproval of
the project or the approval of the project upon the condition that it be developed at a lower density.
There is no preponderance of evidence that the project would have a specific, adverse impact on public health
and safety. The design of the site development and the types of improvement would not cause serious public
health or safety problems since the project would not degrade the levels of service on the adjoining streets,
drainage system, public facilities, and city sewer and water is available to the site or can be provided with the
sewer collection system improvements required for the project. The project’s proposed street alignments,
grades, and widths; drainage and sanitary facilities and utilities, including alignments and grades thereof;
location and size of all required easements and right-of-way; lot size and configuration; and traffic and
emergency response access were all reviewed for compliance to relevant city policies and codes. The proposed
deviations (i.e., waivers requested as part of the proposed density bonus, which are permitted pursuant to State
Density Bonus Law), supplement the Developer’s land use application to avoid restrictive zoning limitations that
would preclude the project as it has been designed and submitted to the city.
McClellan-Palomar Airport Land Use Compatibility Plan Consistency
The project site is within the Airport Influence Area (AIA) boundaries of the McClellan-Palomar Airport Land Use
Compatibility Plan (ALUCP). The project complies with all requirements and provisions of the ALUCP. Specific
compliance with these relevant requirements is described in Exhibit 5.
June 3, 2026 Item #1 7 of 417
Discretionary Actions & Findings
The proposed project requires the approval of a Site Development Plan, which is discussed below.
Site Development Plan, SDP 2025-0004
Pursuant to CMC section 21.53.120 (A)(1) no building permit or other entitlement shall be issued for any multi-
family residential development having more than four dwelling units or an affordable housing project of any size
unless a site development plan has been approved for the project. Staff finds that the required findings for this
application can be met (Exhibits 2 & 5).
Environmental Review
A draft Focused Initial Study and Mitigated Negative Declaration (IS/MND) was issued in accordance with
applicable local and state laws to address potential environmental effects associated with the proposed
Project. The Draft IS/MND is a focus solely on effects related to Biology that might be potentially significant.
However, design and minimization measures, construction methods, and/or mitigation measures would provide
mitigation to a point where potential impacts are reduced to less than a significant level.
A Notice of Intent (NOI) to adopt the IS/MND and Mitigation Monitoring and Reporting Program (MMRP) was
published in the newspaper and sent to the State Clearinghouse (SCH No. 2026030432) for public review. The
requisite 30-day public review period for the Draft IS/MND occurred from Feb. 25, 2026, to April 9, 2026. The
draft IS/MND was available for review electronically on the State Clearinghouse’s CEQAnet website and
published on the city’s website. The city received two comment letters on the draft IS/MND during the 30-day
public comment period. City staff and the consultants prepared a Response to Comments (RTC) document to
respond to all comment letters received. None of the comments resulted in changes to the proposed Project.
City staff and consultants also prepared an Errata Sheet (Errata), which incorporated minor modifications made
to the IS/MND as a result of those responses to comments; and a Mitigation, Monitoring and Reporting Program
(MMRP), which includes all of the mitigation measures identified in the IS/MND as clarified in the RTC and
Errata. All potential impacts to Biological Resources associated with the Project were found to be less than
significant with incorporation of relevant mitigation measures, where applicable. Therefore, the Project would
not result in any significant unavoidable impacts and an IS/MND, in accordance with CEQA, is the appropriate
environmental document for the Project.
The whole record of the combined Draft IS/MND, RTC, and Errata constitutes the Final IS/MND (Exhibit 1,
Attachment “A”). Upon approving the Project, the Planning Commission must also adopt the MMRP to ensure
compliance with the required mitigation measures or project revisions during project implementation. These
documents, which are provided as Attachments “A” and “B” to Exhibit 1, would be used by the city, in
conjunction with other information developed in the city’s formal administrative record, to act on and
implement the proposed Project. Refer to the attached resolution for additional support and justification.
(Exhibit 1).
Conclusion
Considering the information above and in the referenced Exhibits, staff has found that the proposed project is
consistent with all applicable policies of the General Plan, Fenton Carlsbad Center Specific Plan, provisions of the
Municipal Code and Local Facilities Management Zone 5. With improvements to sewer facilities to increase
capacities required in conjunction to the project, all required public improvement and utilities are available to
serve the proposed development. In addition, all potential environmental impacts associated with the project are
less than significant with incorporation of relevant mitigation measures.
The project is conditioned to ensure the proposed project’s compatibility with the surrounding properties and
June 3, 2026 Item #1 8 of 417
that the public health, safety, and welfare of the community are maintained. The project would be required to
comply with all applicable California Building Standards Codes and engineering standards through the standard
building permit and civil improvement plan checking process. Staff recommend the Planning Commission adopt
the resolutions, adopting a Mitigated Negative Declaration and approving of the proposed project, as described
in this staff report.
Exhibits
1.Planning Commission Resolution (IS/MND)
2.Planning Commission Resolution (SDP)
3.Location Map
4.Disclosure Statement
5.Project Analysis
6.City Wide Objective Design Standards
7.Supplemental Application - Density Bonus Waivers
8.Informational Bulletin IB-112 – State Density Bonus Law
9.Informational Bulletin IB-157 – Inclusionary Housing Program
10.Enhanced Stakeholder Public Outreach Report
11.List of Acronyms and Abbreviations
12.Reduced Exhibits (Architectural Plans, Civil Plans, Landscape Plans)
June 3, 2026 Item #1 9 of 417
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF
CARLSBAD, CALIFORNIA, ADOPTING AN SB 131 FOCUSED INITIAL
STUDY AND MITIGATED NEGATIVE DECLARATION AND
MITIGATION MONITORING AND REPORTING PROGRAM TO ALLOW
FOR THE DEVELOPMENT OF A 397-UNIT, FIVE- STORY,
MULTIFAMILY RESIDENTIAL STRUCTURE WITH 548 VEHICULAR
PARKING SPACES BOTH AT GRADE AND WITHIN AN ATTACHED,
FIVE-STORY PARKING STRUCTURE ON A 9.78-ACRE SITE LOCATED
ON SALK AVENUE BETWEEN COLLEGE BLVD AND EL CAMINO REAL
(ASSESSOR PARCEL NO. 212-021-04-00), WITHIN THE FENTON
CARLSBAD CENTER SPECIFIC PLAN, IN THE NORTHWEST
QUADRANT OF THE CITY, THE RD-M ZONE, AND LOCAL FACILITIES
MANAGEMENT ZONE 5
CASE NAME: SALK AVENUE APARTMENTS
CASE NO.: SDP2025-0004 (DEV2025-0001)
WHEREAS,Hanover R.S. Limited Partnership, “Developer”, has filed a verified
application with the City of Carlsbad regarding property owned by Scripps Health, “Owner,”
described as
LOT 4 OF CARLSBAD TRACT NO. 00-20 FOX MILLER PROPERTY IN
THE CITY OF CITY OF CARLSBAD, COUNTY OF SAN DIEGO, STATE
OF CALIFORNIA, ACCORDING TO MAP THEREOF NO. 15253, FILED
IN THE OFFICE OF THE COUNTY RECORDER OF SAN DIEGO
COUNTY, JANUARY 30, 2006.
(“the Property”); and
WHEREAS, pursuant to the California Environmental Quality Act (CEQA, Public
Resources Code section 21000 et. seq.) and its implementing regulations (the State CEQA
Guidelines), Article 14 of the California Code of Regulations section 15000 et. seq., the city is the
Lead Agency for the project, as the public agency with the principal responsibility for approving
the proposed project; and
WHEREAS, the project qualifies for the statutory exemption under Public Resource
Code section 21080.66, except for the single condition of the project site containing habitat for
protected species; and
PLANNING COMMISSION RESOLUTION NO.7578_
June 3, 2026 Item #1 10 of 417
Exhibit 1
WHEREAS, pursuant to Public Resource Code section 21080.1, a housing
development project that fails to qualify for certain CEQA exemptions due to a single
disqualifying condition may carry out a focused CEQA review limited to only those environmental
effects caused by the single disqualifying condition and waive the need for analysis of project
alternatives and growth-inducing effects; and
WHEREAS, the city prepared a single-condition Focused Initial Study/Mitigated
Negative Declaration, dated February 2026, to consider, identify and analyze the potential
environmental impacts to biological resources associated with the proposed Salk Avenue
Apartment Project (State Clearinghouse No. 2026030432, City Planning Case No. SDP 2025-0004).
The Draft IS/MND concluded that the project could result in potentially significant impacts to
Biological Resource and that all the potentially significant impacts of the project can be avoided
or reduced to insignificance with implementation of mitigation measures; and
WHEREAS, the city provided notice of the availability of the Draft IS/MND and its
intent to adopt an IS/MND to and sought comments from all interested individuals and agencies
on the Draft IS/MND as required by CEQA:
x Publishing “Notice of Intent to Adopt a Mitigated Negative Declaration” in San
Diego Union Tribune newspaper on February 25, 2026.
x Submitting a notice to the County Clerk of the County of San Diego and the
State Clearinghouse for posting.
x Providing copies of the notice to individuals and organizations that previously
submitted written requests for the notice.
x Posting of the notice and Draft IS/MND on the City of Carlsbad Planning
Department webpage; and
June 3, 2026 Item #1 11 of 417
WHEREAS, the Draft IS/MND was issued for a minimum 30-day public review
period, which began on Feb. 25, 2026, and ended on April 10, 2026, in conformance with Public
Resources Code section 21091(b) and CEQA Guidelines sections 15072 and 15105(b). The city
received two comment letters during the 30-day public comment period, one of which was
submitted by a member of the public and one from an environmental law firm. A Response to
Comments (RTC) document was prepared and responds to all of the comment letters received
on the Draft IS/MND. An Errata Sheet (Errata) incorporates minor modifications made to the
Draft IS/MND as a result of those responses to comments. The Draft IS/MND, as revised by the
Errata section, together with the RTC, are collectively referred to herein as the Final IS/MND
(State Clearinghouse No. 2026030432) (Attachment “A”); and
WHEREAS, upon approving a project for which an IS/MND is adopted, the Lead
Agency must also adopt a Mitigation, Monitoring or Reporting Program (MMRP) pursuant to
Public Resources Code section 21081.6 and CEQA Guidelines section 15074(d); and
WHEREAS, the city duly noticed a public hearing of the Salk Avenue Apartments
Project on June 3, 2026, to consider adoption of the Final IS/MND and MMRP, and the
project. Evidence was submitted to and considered by the Planning Commission, including,
without limitation:
x Written information including all application materials and other written and
graphical information posted on the project website.
x Oral testimony from city staff, interested parties, and the public.
x dŚĞථPlanning CommissionථƐƚĂĨĨ report, dated June 3, 2026, which along with
its attachments, is incorporated herein by this reference as though fully set
forth herein.
x Additional information submitted during the public hearing; and
June 3, 2026 Item #1 12 of 417
WHEREAS, CEQA Guidelines section 15074(b) states that prior to approving a
project, the Lead Agency must consider the proposed IS/MND together with any comments
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WHEREAS, the Record of Proceedings upon which the Planning Commission bases
its decision includes, but is not limited to: (1) the Final IS/MND and the appendices and technical
reports cited in and/or relied upon in preparing the Final IS/MND and MMRP; (2) the staff reports,
city files and records and other documents, prepared for and/or submitted to the city relating to
the Final IS/MND, MMRP, and the project itself; (3) the evidence, facts, findings and other
determinations set forth in herein; (4) the General Plan and the Carlsbad Municipal Code; (5) all
designs, plans, studies, data and correspondence submitted to the city in connection with the
Final IS/MND, the MMRP, and the project itself; (6) all documentary and oral evidence received
at public workshops, meetings, or hearings or submitted to the city during the comment period
relating to the Final IS/MND and MMRP and/or elsewhere during the course of the review of the
project itself; (7) all other matters of common knowledge to the to the city, including, but not
limited to, city, state, and federal laws, policies, rules, regulations, reports, records and
projections related to development within the city and its surrounding areas.
NOW, THEREFORE, /dZ ^K>s ďLJƚŚĞථPlanning CommissionථŽĨƚŚĞŝƚLJŽĨ
Carlsbad as follows:
1.ZĞĐŽƌĚĂŶĚĂƐŝƐĨŽƌĐƚŝŽŶ͘ථdŚĞථPlanning CommissionථŚĂƐĐŽŶƐŝĚĞƌĞĚƚŚĞĨƵůů
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recitals set forth above are found to be true and correct and material to this
resolution; and are incorporated herein by reference.
2.The Draft IS/MND prepared for the project identifies potentially significant effects
on the environment, but (A) revisions in the project plans or proposals made by,
or agreed to by, the Applicant before the proposed IS/MND were released for
public review would avoid the effects or mitigate the effects to a point where
clearly no significant effect on the environment would occur, and (B), there is no
June 3, 2026 Item #1 13 of 417
substantial evidence, in light of the whole record before the lead agency, that the
project as reviewed may have a significant effect on the environment.
3. Revisions were made to clarify information presented in the Draft IS/MND, and
only minor technical changes or additions have been made. These changes and
additions to the Draft IS/MND do not raise new important issues related to
significant effects on the environment. The modifications made to the Draft
IS/MND in the RTC and Errata simply provide minor clarifications and do not
amount to substantial revisions requiring recirculation of the IS/MND pursuant to
Section 15073.5 of CEQA Guidelines.
4. A Final IS/MND has been prepared in compliance with all requirements contained
in CEQA, CEQA Guidelines, and Carlsbad Municipal Code.
5. In determining whether the proposed project has a significant effect on the
environment, the Planning Commission is able to base its decision on substantial
evidence and has complied with Public Resources Code section 21082.2 and
CEQA Guidelines section 15091(b). Mitigation measures were developed to
reduce potential impacts to Biological Resources. The project Applicant has
agreed to implement all mitigation measures identified in the Final IS/MND in
order to reduce all potentially significant environmental impacts to a less-than-
significant level, in accordance with the MMRP (Attachment “B”). Mitigation
measures incorporated as part of the project’s conditions of approval reduce
impacts to a level less than significant, therefore an IS/MND is appropriate for
adoption. The Planning Commission hereby finds that after considering the
public comments received and the evidence and testimony before it, that the
Final IS/MND reflects the independent judgement of the city as the Lead Agency.
The IS/MND, inclusive of the RTC and Errata, has been prepared in accordance
and full compliance with CEQA and CEQA Guidelines, has been made available
and circulated for review and comment by interested members of the public and
relevant agencies as required by law, and has been presented to, reviewed and
considered by this Planning Commission prior to the decision on the project.
Therefore, the Planning Commission does hereby find that on the basis of the
whole record before it, that there is no substantial evidence that the project, as
revised and conditioned, will have a significant effect on the environment. The
Planning Commission adopts the Final IS/MND (Attachment “A”) and MMRP
(Attachment “B”), as the valid environmental review for this project. The
Planning Commission further finds that the Record of Proceedings has been
completed in compliance with CEQA and the State CEQA Guidelines, and that the
findings related to the Final IS/MND, taken together, reflect the independent
judgment of the Planning Commission.
6. The custodian of the documents and other materials which constitute the record
of proceedings upon which this decision is based is the Office of the City Clerk of
the City of Carlsbad, 1200 Village Drive, Carlsbad, CA 92008.
June 3, 2026 Item #1 14 of 417
BE IT FURTHER RESOLVED that the Planning Commission directs the Director of
Community Development, or their designee, to file the notice of determination required by
Public Resources Code section 21152(a) within five days after project approval.
June 3, 2026 Item #1 15 of 417
NOTICE TO APPLICANT
An appeal of this decision to the City Council must be filed with the City Clerk at 1200 Carlsbad
Village Drive, Carlsbad, California, 92008, within ten (10) calendar days of the date of the Planning
Commission’s decision. Pursuant to Carlsbad Municipal Code Chapter 21.54, section 21.54.150,
the appeal must be in writing and state the reason(s) for the appeal. The City Council must make
a determination on the appeal prior to any judicial review.
PASSED, APPROVED, AND ADOPTED at a regular meeting of the Planning
Commission of the City of Carlsbad, California, held on June 3, 2026, by the following vote, to wit:
AYES: Hubinger, Lafferty, Fitzgerald, Foster, Meenes.
NAYES: None.
ABSENT: Burrows, Merz.
ABSTAIN: None.
ROY MEENES, Chair
Carlsbad Planning Commission
ATTEST:
______________________________
ERIC LARDY, Assistant Director of
Community Development
June 3, 2026 Item #1 16 of 417
Salk Avenue Apartments Project
AB 130/SB 131 – Final Focused Initial Study/Mitigated
Negative Declaration
SCH No. 2026030432
May 2026
Lead Agency: Prepared by:
City of Carlsbad
Community Development Department
1635 Faraday Avenue
Carlsbad, CA 92008
5050 Avenida Encinas, Suite 260
Carlsbad, CA 92008
JN 205484
Attachment A
June 3, 2026 Item #1 23 of 417
Final Focused Initial Study/Mitigated Negative Declaration
Salk Avenue Apartments Project Page i
Table of Contents
1.0 Introduction ....................................................................................................................... 1-1
1.1 AB 130 and SB 131 Applicability ................................................................................. 1-1
1.2 Format of this Focused IS/MND .................................................................................. 1-2
2.0 Project Information ........................................................................................................... 2-1
3.0 Determination.................................................................................................................... 3-1
4.0 Environmental Impact Analysis ...................................................................................... 4-1
5.0 List of Preparers ............................................................................................................... 5-1
6.0 References ........................................................................................................................ 6-1
List of Figures
Figure 1. Regional Vicinity Map ............................................................................................... 2-5
Figure 2. Project Vicinity .......................................................................................................... 2-6
Figure 3. Conceptual Site Plan ................................................................................................ 2-7
Figure 4a. Biological Resources/Impacts ................................................................................ 4-10
Figure 4b. Biological Resources/Impacts - Off-Site Sewer Line .............................................. 4-11
Figure 5. Plans and Policies .................................................................................................. 4-12
Appendices
Appendix A Assembly Bill 130 Statutory Exemption Checklist
Appendix B Senate Bill 131 Exclusions of Certain Types of Housing Development
Projects Checklist
Appendix C Biological Resources Technical Letter Report
June 3, 2026 Item #1 24 of 417
List of Acronyms and Abbreviations
AB California Assembly Bill
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
FCCSP Fenton Carlsbad Center Specific Plan
HMP Habitat Management Plan
IS Initial Study
MM Mitigation Measure
MND Mitigated Negative Declaration
ND Negative Declaration
PRC Public Resources Code
SB California Senate Bill
USFWS United States Fish and Wildlife Service
June 3, 2026 Item #1 25 of 417
1.0 INTRODUCTION
The City of Carlsbad (City) has prepared this single-condition Focused Initial Study/Mitigated
Negative Declaration (Focused IS/MND) to address the potential environmental impacts
associated with the proposed Salk Avenue Apartments Project (project). This single-condition
Focused IS/MND is prepared in accordance with the California Environmental Quality Act (CEQA)
(California Public Resources Code [PRC] Section 21000, et seq., as amended), its implementing
guidelines (California Code of Regulations, Title 14, Section 15000, et seq., 2026), and the CEQA
provisions in California Assembly Bill (AB) 130 and California Senate Bill (SB) 131 (codified in
PRC Sections 21080.66 and 21080.1).
1.1 AB 130 and SB 131 Applicability
AB 130
AB 130 (codified in PRC Section 21080.66) establishes a statutory exemption from CEQA for
qualifying housing development projects that meet certain criteria and requirements. An AB 130
Statutory Exemption Checklist was prepared for the proposed project (refer to Appendix A). Based
on the checklist, the project would have qualified for the statutory exemption established by AB 130, except for the single condition of the project site containing habitat for protected species.
Specifically, the northwestern portion of the project site contains habitat suitable for protected
species, including coastal California gnatcatcher (Polioptila californica californica, federally
threatened, state species of concern), Crotch’s bumble bee (CBB; Bombus crotchii; state
candidate endangered), and thread-leaved brodiaea (Brodiaea filifolia; federally threatened, state
endangered, California Rare Plant Rank 1B.1).
SB 131
SB 131 (codified in PRC Section 21080.1) applies to housing development projects that fail to
qualify for certain CEQA exemptions due to a single disqualifying condition. In such “near-miss”
instances, SB 131 limits CEQA review to those environmental effects caused solely by that single
condition and waives the need for analysis of project alternatives and growth-inducing effects.
However, these “near miss” provisions do not apply to projects with multiple disqualifying
conditions, or to projects involving distribution centers, oil and gas infrastructure or on protected land, etc. Refer to Appendix B, SB 131 Exclusions of Certain Types of Housing Development
Projects, for a complete analysis of the project’s eligibility for the SB 131 housing development
project statutory exemption. As shown in Appendix B, none of the SB 131 exclusions apply to the
project.
The Combined Effect of AB 130 and SB 131
The “near-miss” rule introduced by AB 130 and SB 131 allows for streamlined review of residential projects that meet all but one condition for a CEQA exemption. Any CEQA review for the proposed
project should focus only on the environmental impacts related to the missed criterion. In this
instant, the “near miss” provision is where the proposed project meets all aspects of the new infill
exemption (AB 130), except that the project would impact habitat for protected species. In such
case, any CEQA review would focus only on the environmental impacts related to potential
biological impacts (SB 131).
June 3, 2026 Item #1 26 of 417
1.2 Format of this Focused IS/MND
This single-condition Focused IS/MND is organized in the following manner:
•Section 1.0, Introduction, provides an introduction and overview of this single-condition
Focused IS/MND, including the content and format, as well as the applicability of AB 130and SB 131 to the proposed project.
•Section 2.0, Project Information, provides a detailed description of the proposed project,
its location, surrounding land uses and setting, and required discretionary actions.
•Section 3.0, Environmental Impact Analysis, contains an analysis of the single
condition of AB 130 that was not met by the proposed project—habitat for protected
species (i.e., biological resources).
•Section 4.0, List of Preparers, lists the persons, firm, and lead agency preparing this
single-condition Focused IS/MND.
•Section 5.0, References, lists the source material for the information presented in this
single-condition Focused IS/MND.
June 3, 2026 Item #1 27 of 417
2.0 PROJECT INFORMATION
1. Project Title: Salk Avenue Apartments
2. Lead Agency Name and Address: City of Carlsbad Community Development Department
1635 Faraday Avenue
Carlsbad, California 92008
3. Contact Person and Phone Number:
442-339-2611
4. Project Sponsor’s Name and Address:
11611 San Vicente Boulevard, Suite 740 Los Angeles, California 90049
5. Project Location:
located on vacant, undeveloped land
south of Salk Avenue, west of El Camino
north of Faraday Avenue in
Carlsbad, California
Number 212-021-04-00). Refer to Figure 1, Regional Vicinity Map, and Figure 2,
Project Vicinity.
6. General Plan Designation:
Residential, 23-30 Dwelling
Acre (du/ac) (R-30) and is located in the
Fen(FCCSP)
General Plan.
7. Zoning:
of Residential Density-Multiple (RD-M).
8. Description of Project:
vacant site located on Salk Avenue, east of College Boulevard and west of El Camino
Real within the FCCSP area of the City (Assessor’s Parcel Number 212-021-04-00). The
site currently consists of a vacant graded pad.
The project proposes 397 multi-family residential dwelling units (Figure 3, Conceptual
Site Plan). The project site has a General Plan land use designation of Residential (R-30), which allows between 23 and 30 du/ac. The R-30 land use designation would allow
up to 294 units on the project site (i.e., 294 units is the base density). However, the project
June 3, 2026 Item #1 28 of 417
65915(f)(2) and Carlsbad Municipal Code (CMC) Chapter 21.86, because 59 units (or 20
percent of the base density) of the total dwelling units would be restricted to low-income
households. As such, a density bonus of 103 units was applied to the base density of 294 units, for a total of 397 dwelling units proposed by the project. This equates to a proposed
on-site density of 40.5 du/ac.
The breakdown of the proposed 397 residential apartment units is as follows:
Unit Types Number of Unit Types Average Square Footage
Studio 4 643
1-Bedroom 253 744
2-Bedroom 112 1,110
3-Bedroom 28 1,371
Total 397 --
The proposed residential complex would be Type III-A construction (i.e., would be built with non-combustible materials) and would include one 5-story building with
a maximum building height of 59 feet, with allowed architectural projections up to 74 feet,
7 inches. The gross building area would total approximately 416,152 square feet. The
residential complex would include approximately 27,000 square feet of outdoor open space areas, including courtyards, private balconies, and residential amenities such as a
swimming pool and pool deck courtyard, and interior courtyards.
Interior amenities would include fitness facilities, co-working space, and a media room.
Landscaping would occur throughout the development and would include drought-
resistant and ignition-resistant trees, shrubs, vines, plants, and groundcover. Additionally,
retaining walls ranging from approximately 4 to 9 feet in height would be erected along
the perimeter of the proposed development.
Parking
A total of 541 vehicular parking spaces is proposed both at-grade and within a five-level
aboveground parking structure with rooftop parking. The parking structure footprint would
total approximately 107,300 square feet. The parking structure would include 70 electric
vehicle charging stations. An additional five spaces are proposed as drop-off, delivery, and
van accessible spaces near the main entrance of the residential complex.
Utilities
The project would include off-site tie-in connections to existing water (including dedicated
pipelines extension for potable, recycled, and fire), sewer, storm water,
natural gas in Salk Avenue adjacent to the project site. Once utility tie-ins are completed,
Salk Avenue would be repaved.
June 3, 2026 Item #1 29 of 417
Other off-site improvements would include replacement of approximately 875 linear feet
of sewer pipeline beneath College Boulevard between El Camino Real and Sunny Creek
Road.
Fire Safety
In addition to the proposed Type III-A construction, the project would include drought-
resistant and ignition-resistant landscaping. A 60-foot-wide fuel modification area would
encompass the proposed residential building
Manual (2016). Fuel modification zones would be maintained during routine landscape
maintenance. The City Fire Department has reviewed and preliminarily
proposed fuel modification zones for the project. Further, the proposed project driveway and internal access road width would meet the requirements for fire apparatus. As such,
it is anticipated that the project would meet fire safety requirements pursuant to the City
Fire Department and the CMC. A final fire protection plan is required to be approved under
approval by the City Fire Department would ensure that the proposed fire protection and
suppression systems meet the necessary safety and performance standards as required
by applicable law and code.
Construction
The main phases of construction would include site preparation and grading, foundations
and building construction, and finishing. The total construction duration is anticipated to
be 22 months. Cut and fill (site grading) would be balanced on the site (23,500 cubic yards
of cut and fill, resulting in no soil export or import).
9. Surrounding Land Uses and Setting:
Figure 2, Project Vicinity
project site to the east and south, and a private driving range and golf facility are adjacent
to the west. A Scripps medical office building borders the project site to the north, opposite
Salk Avenue. The site is within the FCCSP, which was developed to address the need for
a full mix of office and medical facilities in the City, to serve both residents and the daily
workforce, as well as providing
lower-income households.
Surrounding land uses near the proposed off-site sewer line within College Boulevard
include a residential community immediately east of College Boulevard and a planned
residential community will be constructed in a currently vacant, graded area immediately
west of College Boulevard.
June 3, 2026 Item #1 30 of 417
10
.
Agency Discretionary Action
Lead Agency
City of Carlsbad
Adoption of the Focused IS/MND project
Issuance of a Site Development Permit
Trustee Agency
California Department of Fish and Wildlife (CDFW)
Consultation and potential issuance of an Incidental Take
Species Act if Crotch’s bumble bee occur on-site
Responsible Agency
San Diego Regional Water Quality Control Board System Permit Construction General Permit and approval of Stormwater Pollution Prevention Plan
determinatio
regarding confidentiality, etc.?
The City mailed US Postal Service-certified mail and emailed letters to the Desert Cahuilla
Indians, Mesa Grande Band of Diegueñ
Indians, and San Luis Rey Band of Mission Indians on January 5, 2026, to initiate the
AB 52 notification process, in accordance with AB 52 tribal notification requirements.
Consultation was requested by the Rincon Band of Luiseño Indians. The City coordinated
monitoring during ground-disturbing construction activities associated with the project (as
part of the Conditions of Approval for the project). As such, AB 52 consultation has
concluded.
June 3, 2026 Item #1 31 of 417
Project Site
Project Location
°
Source: Esri, ArcGIS Online, USGS, San Diego County
Regional Vicinity Map
Figure 1
FOCUSED IS/MND
SALK AVENUE APARTMENTS PROJECT
1/
1
5
/
2
0
2
6
J
N
2
0
5
4
8
4
0 52.5
Miles
June 3, 2026 Item #1 32 of 417
°0 600300
Feet
Project Site
Limits of Disturbance
College Blvd Sewer Replacement Limits of Disturbance
FOCUSED IS/MND
SALK AVENUE APARTMENTS PROJECT
Source: Esri, ArcGIS Online, San Diego County, 2026 Nearmap Imagery
CollegeBlvd
Faraday
A
v
e
ElCaminoReal
Legend
1/
1
5
/
2
0
2
6
J
N
2
0
5
4
8
4
Figure 2
SalkAve
Project Vicinity
Pries
t
l
y
D
r
Residential Community
(Under Construction)
Residential
Community
CommercialTaylorMade
Golf Facility
Commercial
Commercial
College Blvd -
Sewer Replacement Location
June 3, 2026 Item #1 33 of 417
°
Source: Fuscoe Engineering, November 2025
Conceptual Site Plan
Figure 3
FOCUSED IS/MND
SALK AVENUE APARTMENTS PROJECT
1/
1
5
/
2
0
2
6
J
N
2
0
5
4
8
4
NOT TO SCALE
June 3, 2026 Item #1 34 of 417
3.0 DETERMINATION
On the basis of this initial evaluation:
☐ I find that the proposed project COULD NOT have a significant effect on the environment,
and a NEGATIVE DECLARATION will be prepared.
☒ I find that although the proposed project could have a significant effect on the environment,
there will not be a significant effect in this case because revisions in the project have been
made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION
will be prepared.
☐ I find that the proposed project MAY have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.
☐ I find that the proposed project MAY have a "potentially significant impact" or "potentially
significant unless mitigated" impact on the environment, but at least one effect 1) has been
adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on
attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze
only the effects that remain to be addressed.
☐ I find that although the proposed project could have a significant effect on the environment,
because all potentially significant effects (a) have been analyzed adequately in an earlier
EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been
avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including
revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.
Signature Date
June 3, 2026 Item #1 35 of 417
4.0 ENVIRONMENTAL IMPACT ANALYSIS
The environmental evaluation below is limited to the Biological Resources thresholds from
Appendix G of the CEQA Guidelines, as habitat on-site is the “near-miss” single condition that
was identified in evaluating AB 130 / SB 131 statutory exemption applicability (see Appendix A).
For the evaluation of potential impacts to biological resources, the questions in the Initial Study
(IS) Checklist are stated and a determination and explanation are provided. The analysis
considers short-term (construction) and long-term (operation), direct and indirect impacts of the
project.
To each question, there are four possible responses:
• No Impact. The project would not have any measurable environmental impact on the
environment.
• Less Than Significant Impact. The project would have the potential for impacting the
environment, although this impact would be below established thresholds that are
considered to be significant.
• Less Than Significant Impact with Mitigation Incorporated. The project would have the potential to generate impacts which may be considered a significant effect on the
environment, although measures or changes to the development’s physical or operational
characteristics can reduce these impacts to levels that are less than significant.
• Potentially Significant Impact. The project would have impacts which are considered
significant, and additional analysis is required to identify measures that could reduce these
impacts to less than significant levels.
June 3, 2026 Item #1 36 of 417
Final Focused Initial Study/Mitigated Negative Declaration
Salk Avenue Apartments Project Page 4-2
Evaluation of Environmental Impacts
Potentially Significant
Impact
Less Than Significant Impact with Mitigation
Incorporated
Less Than Significant
Impact
No
Impact
BIOLOGICAL RESOURCES:
Would the project:
a) Have a substantial adverse effect, either directly or
through habitat modifications, on any species
identified as a candidate, sensitive, or special status
species in local or regional plans, policies, or
regulations, or by the California Department of Fish
and Wildlife or U.S. Fish and Wildlife Service?
☐ ☒ ☐ ☐
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations or by the California Department of Fish
and Wildlife or U.S. Fish and Wildlife Service?
☐ ☐ ☐ ☒
c) Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.) through
direct removal, filling, hydrological interruption, or
other means?
☐ ☐ ☐ ☒
d) Interfere substantially with the movement of any
native resident or migratory fish or wildlife species
or with established native resident or migratory
wildlife corridors, or impede the use of native wildlife
nursery sites?
☐ ☐ ☐ ☒
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
☐ ☐ ☒ ☐
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?
☐ ☐ ☒ ☐
Discussion
The discussion section below is based on the Biological Resources Technical Letter Report for
the Salk Avenue Apartments Project in Carlsbad, San Diego County, California, prepared by
Michael Baker International and dated April 30, 2026, which is included as Appendix C.
a) Would the project have a substantial adverse effect, either directly or through habitat
modifications, on any species identified as a candidate, sensitive, or special status
June 3, 2026 Item #1 37 of 417
species in local or regional plans, policies, or regulations, or by the California
Department of Fish and Wildlife or US Fish and Wildlife Service?
Less Than Significant Impact with Mitigation Incorporated. There is one special-status plant species, thread-leaved brodiaea (federally threatened, state endangered, California Rare Plant
Rank 1B.1), and one special-status wildlife species, Crotch’s bumble bee (CBB; state candidate
endangered), that have potential to occur on a portion of the project site or within close proximity.
Additionally, one special-status wildlife species, coastal California gnatcatcher (federally
threatened, state species of concern), was detected on the project site during the general
biological field survey conducted by Michael Baker International on January 24, 2025 (see
Appendix C). It is noted that a coastal California gnatcatcher observation was also made in 2000 / 2001 in association with the Fox Miller Project focused surveys, but this special-status species
was not detected during the 2003 focused surveys.
Special-Status Plant Species
One special-status plant species has the potential to occur on the project site: thread-leaved
brodiaea. Additionally, the US Fish and Wildlife Service (USFWS) mapped designated critical
habitat for thread-leaved brodiaea in the vicinity of the project site, including within the
northwestern portion of the project site (see Figure 4a, Biological Resources/Impacts). However, the special-status plant species was not observed on the project site as part of the 2000
/ 2001 focused studies conducted in 2003 (RECON 2024), or the field survey conducted in 2025.
The project site was graded in 2007, resulting in primarily disturbed vegetation, and is mowed on
an annual basis.
A 0.33-acre patch of Diegan Coastal Sage Scrub in the northwest corner of the project site that is
designated as critical habitat for thread-leaved brodiaea is located approximately 100 feet beyond
the proposed development footprint. Project construction activities would not result in impacts to this isolated patch of Diegan Coastal Sage Scrub, which is the only suitable habitat on the project
site for thread-leaved brodiaea. Therefore, no impact would occur to thread-leaved brodiaea or
its habitat.
The off-site sewer line would be located in paved areas of College Boulevard (Study Area-Off-
Site Sewer Line). The proposed construction footprint for the off-site sewer line does not contain
natural habitat or vegetation that could support special-status plant species. This area is fully
developed (paved roadway) and does not contain natural habitat or vegetation.
Special-Status Wildlife Species
Coastal California Gnatcatcher and Other Nesting Birds
One coastal California gnatcatcher was observed in the 0.33-acre patch of Diegan coastal sage
scrub in the northwest corner of the project site during the 2025 biological survey (Figure 4a, Biological Resources/Impacts). As noted above, the habitat is approximately 100 feet beyond
the construction footprint of the proposed project and would not be disturbed. Accordingly, no
direct impacts to coastal California gnatcatcher would occur.
Several non-listed, sensitive bird species could potentially nest and/or forage over the site,
although the potential is low. There is potential for other nesting bird species to occur on-site in
the two on-site non-native, invasive fig trees to be removed, as well as in the isolated patch of
June 3, 2026 Item #1 38 of 417
Diegan coastal sage scrub. Nesting birds may also potentially occur in trees adjacent to the
project site and the College Boulevard sewer replacement location (Study Area-Off-Site Sewer
Line).
Removal of the two fig trees could potentially directly affect nesting birds, while construction noise
has potential to indirectly affect nesting birds in the isolated patch of Diegan coastal sage scrub
and off-site trees. Implementation of mitigation measure (MM) BIO-1 would reduce impacts to
nesting birds, including coastal California gnatcatcher, to less than significant levels.
Crotch’s Bumble Bee
The closest location of the species is documented in the California Natural Diversity Database
(CNDDB), with two occurrences of CBB in 2024 noted approximately 2.5 miles north of the project site at Lake Calavera Preserve. However, no individuals or nests of CBB were observed on or
adjacent to the project site during the general biological survey for the project on January 24,
2025. Because of (1) the presence of nectaring sources (i.e., food sources) present on and near
the project site, (2) the presence of other bumble bees on the project site during the January 24,
2025 biological survey (a yellow-faced bumble bee [Bombus vosnesenskii]), and (3) two known
CNDDB identifications of CBB within approximately 2.5 miles of the project site, there is moderate
potential for CBB to occur on the project site, although likely only within the 0.33-acre patch of Diegan coastal sage scrub in the northwest corner of the project site. This limited area of habitat
supports nectaring sources that may be used by foraging CBB and soils that could provide nesting
and overwintering habitat. The project’s proposed off-site sewer line replacement would be
located in paved areas of College Boulevard and does not contain natural habitat or vegetation
that could support CBB.
Although no direct impacts to CBB individuals or nests are expected from the project due to lack
of suitable nectaring sources for foraging and lack of nesting habitat, there is a potential for indirect effects if the species is present in the 0.33-acre patch of Diegan Coastal Sage Scrub in the
northwest corner of the project site. Indirect impacts to CBB could occur from fugitive dust during
ground-disturbing construction activities. Such indirect impacts to CBB would be potentially
significant. However, implementation of MM BIO-2 would reduce potential indirect impacts to CBB
to less than significant levels.
Mitigation Measures:
MM BIO-1 Pre-Construction Nesting Bird Surveys, Avoidance, and Notification. If construction activities are initiated during the bird nesting season (February 1–
August 31) involving removal of vegetation or other nesting bird habitat, including
abandoned structures and other man-made features, a pre-construction nesting
bird survey shall be conducted no more than three days prior to initiation of ground
disturbance and vegetation removal activities. The nesting bird pre-construction
survey shall be conducted on foot and shall include a 300-foot survey buffer around
the construction site. The survey shall be conducted by a biologist familiar with the identification of avian species known to occur in southern California coastal
communities (i.e., qualified biologist). If active nests are found, an avoidance buffer
shall be determined by a qualified biologist in coordination with the City. The
avoidance buffer width will depend upon the species, the proposed work activity,
and existing disturbances associated with land uses outside of the site, which shall
June 3, 2026 Item #1 39 of 417
be demarcated by the biologist with bright orange construction fencing, flagging,
construction lathe, or other means to demarcate the boundary. All construction
personnel shall be notified as to the existence of the buffer zone and to avoid entering the buffer zone during the nesting season. No ground-disturbing activities
shall occur within the buffer until the biologist has confirmed that breeding/nesting
is completed, and the young have fledged the nest. Encroachment into the buffer
shall occur only at the discretion of the qualified biologist on the basis that the
encroachment will not be detrimental to an active nest. A report summarizing the
pre-construction survey(s) shall be prepared by a qualified biologist and shall be
submitted to the City prior to the commencement of construction activities.
If an active coastal California gnatcatcher nest is found during pre-construction
surveys, a minimum 500-foot no-disturbance buffer shall be established around
the nest. The buffer shall be clearly marked (e.g., with fencing or flagging) and
maintained until a qualified biologist confirms that the young have fledged, the nest
is no longer active, or that construction noise levels can be maintained below
60 dBA Leq at the nest site with a smaller buffer. In no circumstances shall a buffer
of less than 100 feet be used even with noise attenuation measures. Any reduction in the 500-foot buffer must be supported by site-specific analysis by the qualified
biologist and approved by the City in consultation with the US Fish and Wildlife
Service.
Note: To mitigate the potential impact to California gnatcatcher or other nesting
birds, this mitigation measure shall be applied to land use and activities occurring
at the project site. No Pre-Construction Nesting Bird Surveys, Avoidance, and
Notification mitigation is required to implement the Study Area-Off-Site Sewer Line
portion of the project.
MM BIO-2 Crotch’s Bumble Bee Avoidance and Clearance Survey
• Focused Survey. Three on-site surveys for Crotch’s bumble bee (CBB) shall be conducted
prior to initiation of ground disturbing project activities to identify if the CBB is present
within the project site. This survey shall be conducted simultaneously with the blooming
period of the species’ recognized food plants, when the CBB is most active. Each survey
shall be spaced at least 2 weeks but no more than 4 weeks apart, corresponding with the
Colony Active Season for Bombus species (April–August). The surveying biologist shall be familiar with the primary identification characteristics of the CBB and be proficient in
the methodology produced by the Xerces Society. The qualified biologist shall utilize a
telephoto lens or a sufficiently long macro lens to obtain high-quality photos of bumble
bees, sufficient for species identification, without having to capture and potentially harm
the bumble bees.
• Absence of Species. If no CBB are detected during the focused surveys, no further
measures shall be necessary.
• Presence of Species. If CBB are detected, then site-specific measures shall be
implemented to avoid take unless an Incidental Take Permit (ITP) for the species is obtained from CDFW. Such avoidance measures shall include:
June 3, 2026 Item #1 40 of 417
o If vegetation removal activities and initial ground-disturbing activities (i.e., clearing,
grubbing, and initial site grading) occur during the Queen and Gyne Flight Period
and Colony Active Period for these species (February–October), a qualified
biologist shall conduct daily biological monitoring. During monitoring, the qualified
biologist shall inspect suitable habitat for CBB activity within the day’s work area.
If the species is not detected, then project activities can proceed without further
biological monitoring that day.
o If the CBB is detected using nectar sources, then a no-disturbance buffer of at least
25 feet around the individual(s) shall be established, and the individual(s) shall be
monitored by a biological monitor until the CBB are confirmed to have left the area
on their own.
o If a CBB nest is detected where ground disturbance is proposed to occur, then a
minimum 30-foot no-disturbance buffer (with a buffer of up to 60 feet if disturbance
is substantial) around the nest shall be established. This buffer shall remain in
place until the nest senesces, which would occur after no nest activity observations
for three sequential days. The qualified biologist shall discuss the buffer with the
contractor to ensure that work areas, including ingress and egress routes, avoid
the CBB.
o If the project cannot avoid the established no-disturbance buffer(s) identified
above, the project applicant shall halt work within the buffer area and shall consult
with CDFW on appropriate avoidance actions and obtain an Incidental Take Permit
if necessary.
Note: To mitigate the potential impact to Crotch’s Bumble Bee (CBB), this
mitigation measure shall be applied to land use and activities occurring at the
project site. No CBB Avoidance and Clearance Survey mitigation is required to
implement the Study Area-Off-Site Sewer Line portion of the project.
b) Would the project have a substantial adverse effect on any riparian habitat or other
sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
No Impact. The project site consists of the following vegetation communities/land cover types:
Diegan Coastal Sage Scrub, Disturbed Habitat, and Urban/Developed Land (Figure 4a,
Biological Resources/Impacts). The off-site improvement areas (including abutting the project
site in Salk Avenue and the off-site sewer line in College Boulevard) contain Disturbed Habitat
and Urban/Developed Land (Figure 4b, Biological Resources/Impacts – Off-Site Sewer Line).
Of these vegetation communities/land cover types, Diegan Coastal Sage Scrub is the only sensitive vegetation community on the project site or off-site improvement areas, and it occurs in
an isolated 0.33-acre area in the northwest corner of the project site. However, as shown on
Figure 4a, this isolated patch of Diegan Coastal Sage Scrub is approximately 100 feet from the
proposed development footprint. Therefore, the project, and its limits of disturbance will avoid any
impact to this plant species. Furthermore, there is no riparian habitat on or near the project site
June 3, 2026 Item #1 41 of 417
or off-site improvement areas. Therefore, no impact to riparian habitat and other sensitive natural
communities would occur.
Mitigation Measures: None
c) Would the project have a substantial adverse effect on state or federally protected
wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through
direct removal, filling, hydrological interruption, or other means?
No Impact. There are no state or federally protected wetlands on or near the project site or off-
site improvement areas. Therefore, no impact to state or federally protected wetlands would
occur.
Mitigation Measures: None
d) Would the project interfere substantially with the movement of any native resident or
migratory fish or wildlife species or with established native resident or migratory
wildlife corridors, or impede the use of native wildlife nursery sites?
No Impact. As the project site is surrounded by urban uses, including Salk Avenue, commercial
buildings, and the TaylorMade golf facility, there are no landscape features or vegetative cover
that would support wildlife movement or native wildlife nursery sites within the project site. The
project site is further characterized by open, exposed areas that lack suitable cover and resources that are typically associated with wildlife movement areas. Additionally, the off-site improvement
areas occur within developed roadways (Salk Avenue and College Boulevard) with no landscape
features or vegetative cover that would support wildlife movement or native wildlife nursery sites.
Common birds and mammals might move through the site to forage and during dispersal
activities; however, they would not be expected to use the site as a wildlife corridor, linkage, or
specific travel route to and from nursery sites or other important resources.
The project site, off-site improvement areas, and project vicinity do not support wildlife movement or native wildlife nursery sites. Accordingly, the project would not interfere substantially with the
movement of any native resident or migratory fish or wildlife species or with established native
resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. Thus, no
impacts to wildlife movement or native wildlife nursery sites would occur.
Mitigation Measures: None
e) Would the project conflict with any local policies or ordinances protecting biological
resources, such as a tree preservation policy or ordinance?
Less Than Significant Impact. CMC Section 11.12.140, Heritage Trees, and Section 11.12.090,
Permits Required for Tree Removal and Maintenance, regulates trees located on public streets,
trees with notable historic interest, and trees of unusual species or size. There are no City
protected trees on the project site or off-site improvement areas.
There are two non-native, invasive fig trees within the proposed project footprint that would be
removed; however, neither fig tree is in the public right-of-way, of notable historic interest, or of
an unusual species or size, pursuant to CMC Section 11.12.140. Therefore, these fig trees are
June 3, 2026 Item #1 42 of 417
not considered protected trees. No trees would be impacted by the construction of the off-site
sewer line in College Boulevard. Thus, the project would not conflict with any local policies or
ordinances protecting biological resources, and impacts would be less than significant.
Mitigation Measures: None
f) Would the project conflict with the provisions of an adopted habitat conservation
plan, natural community conservation plan, or other approved local, regional, or state
habitat conservation plan?
Less Than Significant Impact. The project site and off-site improvement areas are within the
boundaries of the City’s Habitat Management Plan (HMP) in Special Resource Area (SRA) 1;
however, the project site is not within the HMP Hardline Conservation Area or HMP Proposed Hardline Conservation Area, which is identified in the HMP for conservation. The northernmost
approximately 40 feet of the existing driveway that provides access to the project site, which would
be improved as part of the proposed project and serve as egress/ingress for the project site, is
within 100 feet of a HMP Proposed Hardline Conservation Area (Figure 5, Plans and Policies).
The HMP includes Adjacency Standards that are designed to prevent negative effects to urban
wildlife preserve systems and include fire management; erosion control; landscaping restrictions;
fencing, signs, and lighting; and predator and exotic species control (pursuant to Section F.3 of the HMP). The following describes the project’s adherence to the HMP Adjacency Standards, as
required by the City’s conditions of approval for the project:
• Fire Management: Proposed improvements associated with the northernmost
approximately 40 feet of the existing driveway would be subject to applicable fuel
modification zone requirements for fire management. The City’s Fire Department has
reviewed and preliminarily approved the proposed fuel modification zones for the project.
Additionally, it is noted that the fuel modification area required for the proposed project
would not encroach into a HMP Proposed Hardline Conservation Area. As such, the project would adhere to the HMP Adjacency Standards.
• Erosion Control: Construction of the project shall include implementation of standard
construction best management practices, as well as implementation of a project-specific
Storm Water Pollution Prevention Plan, which would minimize erosion during construction.
The project landscape plan shall ensure that project site slopes are stabilized after
construction is completed. As such, the project would not result in increased storm water
runoff volume or velocity into the preserve, and the project would adhere to the HMP
Adjacency Standards.
• Landscaping Restrictions: The project landscape plan shall be reviewed by the City Planning Division prior to issuance of a grading permit to ensure that no non-native,
invasive plant species are proposed. Drought-tolerant plant species shall also be used on-
site to minimize irrigation runoff potential. The project shall limit the amount of fertilization
of ornamental plants on the project site that could drain toward the HMP Proposed
Hardline Conservation Area to the north of Salk Avenue. As such, the project would adhere
to the HMP Adjacency Standards.
June 3, 2026 Item #1 43 of 417
• Fencing, Signs, and Lighting: The Project shall not include fencing within the HMP
Preserve, and as such, the project would not impede wildlife movement within the
preserve. No signs prohibiting entrance into the preserve would be required on the project
site, as Salk Avenue is located in between the project site and the closest HMP Proposed
Hardline Conservation Area. However, future project residences shall receive educational
brochures upon moving in to deter human and pet access into the preserve. Streetlighting
currently exists along Salk Avenue. The project shall include security lighting along the driveway; however, proposed lighting would be low pressure sodium, directed downward,
and shielded away from the HMP Proposed Hardline Conservation Area. As such, the
project would adhere to the HMP Adjacency Standards.
• Predator and Exotic Species Control: As previously stated, future project residences
shall receive educational brochures upon moving in regarding the nearby HMP Preserve to deter human and pet access into the preserve. As such, the project would adhere to the
HMP Adjacency Standards.
With adherence to these standards, the proposed project would not conflict with the provisions of
the HMP, including its Adjacency Standards, and impacts would be less than significant.
Mitigation Measures: None
June 3, 2026 Item #1 44 of 417
°
Source: Esri, ArcGIS Online, San Diego County, 2026 Nearmap Imagery
Biological Resources/Impacts
Figure 4a
FOCUSED IS/MND
SALK AVENUE APARTMENTS PROJECT
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Coastal California Gnatcatcher
Study Area (100-ft Buffer)
On-Site Limits of Disturbance
Off-Site Limits of Disturbance
Critical Habitat
Thread-leaved Brodiaea(Brodiaea filifolia)
Vegetation/Land Uses (Project Site)
32530 Diegan Coastal Sage Scrub (0.33 Acres)
11300 Disturbed Habitat (6.76 Acres)
12000 Urban/Developed (2.69 Acres)
Vegetation/Land Uses (100-ft Study Area)
32500 Coastal Sage Scrub (0.29 Acres)
32530 Diegan Coastal Sage Scrub (0.62 Acres)
11300 Disturbed Habitat (2.62 Acres)
79100 Eucalyptus Woodland (0.19 Acres)
12000 Urban/Developed (3.56 Acres)
0 200100
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TaylorMade Golf
Facility
June 3, 2026 Item #1 45 of 417
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Source: Esri, ArcGIS Online, San Diego County, 2026 Nearmap Imagery
Biological Resources/Impacts - Off-Site Sewer Line
Figure 4b
FOCUSED IS/MND
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Sewer
College Blvd Sewer Replacement Limits of Disturbance
Study Area (25-ft Buffer from Limits of Disturbance)
Vegetation Communities/Land Uses (20-ft Study Area)
12000 Urban/Developed (0.85 Acres)
0 200100
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ElCaminoReal
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Community
June 3, 2026 Item #1 46 of 417
°0 600300
Feet
Sewer Line
Project Site
Limits of Disturbance
Coastal Zone
City of Carlsbad Habitat Management Plan
Existing Hardline
Standards Area
Proposed Hardline
FOCUSED IS/MND
SALK AVENUE APARTMENTS PROJECT
Source: Esri, ArcGIS Online, USFWS (02/2025), City of Carlsbad (04/2024), City of Carlsbad (08/2024), San Diego County, 2026 Nearmap Imagery
CollegeBlvd
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SalkAve
Plans and Policies
Pries
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(Under Construction)
Residential
Community
CommercialTaylorMade
Golf Facility
Commercial
Commercial
June 3, 2026 Item #1 47 of 417
5.0 LIST OF PREPARERS
Lead Agency – City of Carlsbad
Community Development Department 1635 Faraday Avenue
Carlsbad, CA 92008
Kyle Van Leeuwen, Senior Planner
442-339-2611
Michael Baker International, Inc.
Bob Stark, AICP, Principal-in-Charge
Melissa Whittemore, Project Manager
Audrey Tamayo, Environmental Planner Ryan Henry, Principal Biologist
Marisa Flores, Senior Biologist
Samantha Martinez, Biologist
Connor Lance, GIS Specialist Ana Cotham, Technical Editor
June 3, 2026 Item #1 48 of 417
Final Focused Initial Study/Mitigated Negative Declaration
Salk Avenue Apartments Project Page 6-1
6.0 REFERENCES
Carlsbad, City of. 1999. Habitat Management Plan for Natural Communities in the City of
Carlsbad.
Carlsbad, City of. 2016. Landscape Manual – Policies and Requirements.
Carlsbad, City of. 2017. City of Carlsbad General Plan Open Space, Conservation, and
Recreation Element.
Carlsbad, City of. 2023. Housing Element Implementation and Public Safety Element Update
Supplemental Environmental Impact Report.
Michael Baker International. 2026. Biological Resources Technical Letter Report for the Salk
Avenue Apartments Project in Carlsbad, San Diego County, California.
RECON. 2001. Revised Biological Technical Report for the Fox Property, Carlsbad, California.
RECON. 2004. Biological Resources Survey Update and Project Impact Revisions for Fox-Miller
Property, Carlsbad, California.
June 3, 2026 Item #1 49 of 417
{city of
Carlsbad Focused Initial Study/Mitigated Negative Declaration
APPENDIX A:
Assembly Bill 130
Housing Development Project
CEQA Exemption
Evaluation Checklist
Salk Avenue Apartments Project Appendices June 3, 2026 Item #1 50 of 417
City of Carlsbad
PRC Section 21080.66 (AB 130)
Housing Development Project CEQA Exemption Evaluation Checklist
CITY OF CARLSBAD
PUBLIC RESOURCES CODE SECTION 21080.66 (ASSEMBLY BILL 130)
HOUSING DEVELOPMENT PROJECT CEQA EXEMPTION EVALUATION CHECKLIST
SALK AVENUE APARTMENTS
February 2026
California Assembly Bill (AB) 130, signed into law by Governor Gavin Newsom on June 30, 2025,
and codified in Public Resources Code (PRC) Section 21080.66, establishes a statutory
exemption from the California Environmental Quality Act (CEQA) for qualifying "housing
development projects" that meet certain criteria and requirements. This Exemption Evaluation
Checklist documents the eligibility of the proposed Salk Avenue Apartments Project (project) for
this CEQA exemption.
PROJECT INFORMATION
1. Project Title
Salk Avenue Apartments
2. Lead Agency Name and Address
City of Carlsbad
Community Development Department
1635 Faraday Avenue
Carlsbad, California 92008
3. Contact Person and Phone Number
Kyle Van Leeuwen, Senior Planner
City of Carlsbad, Community Development Department
442-339-2611
Kyle.vanleeuwen@carlsbadca.gov
4. Project Sponsor's Name and Address
Hanover RS. Limited Partnership
Joe Gambill
11611 San Vicente Blvd. Suite 740
Los Angeles, CA 90049
5. Project Location
The approximately 9.8-acre project site is located on vacant, undeveloped land in the City of
Carlsbad (City), California, south of Salk Avenue, west of El Camino Real, east of College
Boulevard, and north of Faraday Avenue (Assessor's Parcel Number 212-021-04-00). The project
occurs within Township 12 South, Range 04 West of the San Luis Rey 7.5-minute United States
Geological Survey (USGS) topographic quadrangle map.
Salk Avenue Apartments Project June 3, 2026 Item #1 51 of 417
City of Carlsbad
PRC Section 21080.66 (AB 130)
Housing Development Project CEQA Exemption Evaluation Checklist
6. General Plan Designation
The project site is designated as Residential, 23-30 Dwelling Units Per Acre (du/ac) (R-30) and is
located in the Fenton Carlsbad Center Specific Plan (FCCSP) under the City of Carlsbad General
Plan.
7. Zoning
The project site is zoned as Residential Density-Multiple (RD-M).
8. Description of Project
The project proposes a multi-family residential development on an approximately 9.8-acre vacant
site located on Salk Avenue, east of College Boulevard and west of El Camino Real within the
FCCSP area of the City (Assessor's Parcel Number is 212-021-04-00). The site currently consists
of a vacant graded pad.
The project proposes 397 multi-family residential dwelling units. The project site has a General
Plan land use designation of Residential (R-30), which allows between 23 and 30 du/ac. The R-
30 land use designation would allow up to 294 units on the project site (i.e., 294 units is the base
density). However, the project qualifies for a 35 percent density bonus, pursuant to California
Government Code Section 65915 and Carlsbad Municipal Code Chapter 21.86, because 59 units
(or 20 percent of the base density) of the total dwelling units would be restricted to low-income
households. As such, a density bonus of 103 units was applied to the base density of 294 units,
for a total of 397 dwelling units proposed by the project. This equates to a proposed density of
40.5 du/ac.
The breakdown of the proposed 397 residential apartment units is as follows:
Unit Types Number of Unit Types Average Square Footage
Studio 4 643
1-Bedroom 253 744
2-Bedroom 112 1,110
3-Bedroom 28 1,371
Total 397 --
The proposed residential complex would be Type Ill-A construction (i.e., exterior walls would be
built with non-combustible materials) and would include one 5-story building with a maximum
building height of 59 feet, with allowed architectural projections up to 74 feet, 7 inches. The gross
building area would total approximately 416,152 square feet. The residential complex would
include approximately 27,000 square feet of outdoor open space areas, including courtyards,
private balconies, and residential amenities such as a swimming pool and pool deck courtyard,
and interior courtyards.
Interior amenities would include fitness facilities, co-working space, and a media room.
Landscaping would occur throughout the development and would include drought-resistant and
ignition-resistant trees, shrubs, vines, plants, and groundcover. Additionally, retaining walls
ranging from approximately 4 to 9 feet in height would be erected along the perimeter of the
proposed development.
Salk Avenue Apartments Project 2 June 3, 2026 Item #1 52 of 417
City of Carlsbad
Parking
PRC Section 21080.66 (AB 130)
Housing Development Project CEQA Exemption Evaluation Checklist
A total of 541 vehicular parking spaces are proposed both at-grade and within a five--level above
ground parking structure with rooftop parking. The parking structure would total approximately
107,300 square feet. The parking structure would include 70 electric vehicle charging stations. An
additional five spaces are proposed as drop-off, delivery, and van accessible spaces near the
main entrance of the residential complex.
Utilities
The project would include off-site tie-in connections to existing water (including dedicated
pipelines for potable, recycled, and fire), sewer, storm water, electricity, and natural gas in Salk
Avenue adjacent to the project site. Once utility tie-ins are completed, Salk Avenue would be
repaved.
Other off-site improvements would include replacement of approximately 875 linear feet of sewer
pipeline beneath College Boulevard between El Camino Real and Sunny Creek Road.
Fire Safety
In addition to the proposed Type Ill-A construction, the project would include drought-resistant
and ignition-resistant landscaping. A 60-foot-wide fuel modification area would encompass the
proposed residential building in accordance with the City's Landscape Manual (2016). Fuel
modification zones would be maintained during routine landscape maintenance. The City Fire
Department has reviewed and preliminarily approved the proposed fuel modification zones for the
project.
Further, the proposed project driveway and internal access road width would meet the
requirements for fire apparatus. As such, it is anticipated that the project would meet fire safety
requirements pursuant to the City Fire Department and the City Municipal Code. A final fire
protection plan is required to be approved under the California Fire Code before building permit
issuance. The plan's final review and approval by the City Fire Department would ensure that the
proposed fire protection and suppression systems meet the necessary safety and performance
standards as required by applicable law and code.
Construction
The main phases of construction would include site preparation and grading, foundations and
building construction, and finishing. The total construction duration is anticipated to be 22 months.
Cut and fill (site grading) would be balanced on the site (23,500 cubic yards of cut and fill, resulting
in no soil export or import).
9. Surrounding Land Uses and Setting
Light industrial buildings are adjacent to the project site to the east and south, and a private driving
range and golf facility are adjacent to the west. A Scripps medical office building borders the
project site to the north, opposite Salk Avenue. The site is within the FCCSP, which was developed
to address the need for a full mix of office and medical facilities in the City, to serve both residents
and the daily workforce, as well as provide housing close to jobs, including housing affordable to
lower-income households.
Salk Avenue Apartments Project 3 June 3, 2026 Item #1 53 of 417
City of Carlsbad
PRC Section 21080.66 (AB 130)
Housing Development Project CEQA Exemption Evaluation Checklist
Surrounding land uses near the proposed off-site sewer line within College Boulevard include a
residential community immediately east of College Boulevard and a planned residential
community will be constructed in a currently vacant, graded area immediately west of College
Boulevard.
10. Agency Approvals
Agency Discretionary Action
Lead Agency
City of Carlsbad Adoption of the Focused IS/MND and approval of the project
Issuance of a Site Development Permit
Trustee Agency
California Department of Fish Consultation and potential issuance of an Incidental Take Permit for
and Wildlife (CDFW) species protected by the state Endangered Species Act if Crotch's
bumble bee occur on-site
Responsible Agency
San Diego Regional Water Issuance of National Pollutant Discharge Elimination System Permit
Quality Control Board Construction General Permit and approval of Stormwater Pollution
Prevention Plan
DETERMINATION
Based on the evaluation included in this checklist, the subject project does not qualify for a
statutory exemption from CEQA pursuant to PRC Section 21080.66. The proposed project
narrowly fails to qualify for the AB 130 CEQA exemption due to a single disqualifying condition.
EVALUATION OF EXEMPTION CRITERIA AND REQUIREMENTS
The table on the following pages identifies the criteria and requirements that a project must meet
to qualify for a statutory exemption from CEQA pursuant to PRC Section 21080.66, along with an
evaluation of the project's compliance with all such criteria and requirements.
Salk Avenue Apartments Project 4 June 3, 2026 Item #1 54 of 417
City of Carlsbad
PRC Section 21080.66 (AB 130)
Housing Development Project CEQA Exemption Evaluation Checklist
PRC Section 21080.66 Housing Development Project CEQA Exemption Evaluation Checklist
Criteria and Requirements Evaluation
21080.66(a)
Without limiting any other statutory or categorical exemption, this
division [CEQAJ does not apply to any aspect of a housing
development project, as defined in subdivision (b) of Section 65905.5
of the Government Code, including any permits, approvals, or public
improvements required for the housing development project, as may
be required by this division, if the housing development project meets
all of the following conditions [see rows 21080.66(a)(1-8), below]:
Additional Description/Referenced Code Section(s)
Government Code Section 65905.S(b) reads in relevant part:
... (3) (A) "Housing development project" has the same meaning as defined
in paragraph (2J of subdivision (hJ of Section 65589.5. [see below]
(BJ "Housing development project" includes, but is not limited to, projects
that involve no discretionary approvals and projects that involve both
discretionary and nondiscretionary approvals.
(CJ "Housing development project" includes a proposal to construct a single
dwelling unit. This subparagraph shall not affect the interpretation of the
scope of paragraph (2J of subdivision (hJ of Section 65589. 5. [see below]
Government Code Section 65589.5(h)(2) reads:
"Housing development project" means a use consisting of any of the
following:
(AJ Residential units only.
(BJ Mixed-use developments consisting of residential and nonresidential
uses that meet any of the following conditions:
(i) At least two-thirds of the new or converted square footage is
designated for residential use.
(ii) At least 50 percent of the new or converted square footage is
designated for residential use and the project meets both of the
following:
(IJ The project includes at least 500 net new residential units.
Salk Avenue Apartments Project
The project would consist of only residential use, and therefore,
would meet the provision that at least two-thirds of new square
footage is designated for residential use, pursuant to Government
Code Section 65589.5(h)(2)(B)(i).
5 June 3, 2026 Item #1 55 of 417
City of Carlsbad
PRC Section 21080.66 (AB 130)
Housing Development Project CEQA Exemption Evaluation Checklist
PRC Section 21080.66 Housing Development Project CEQA Exemption Evaluation Checklist
Criteria and Requirements Evaluation
(II) No portion of the project is designated for use as a hotel,
motel, bed and breakfast inn, or other transient lodging, except a
portion of the project may be designated for use as a residential
hotel, as defined in Section 50519 of the Health and Safety Code.
(iii) At least 50 percent of the net new or converted square footage is
designated for residential use and the project meets all of the following:
(I) The project includes at least 500 net new residential units.
(II) The project involves the demolition or conversion of at least
100,000 square feet of nonresidential use.
(Ill) The project demolishes at least 50 percent of the existing
nonresidential uses on the site.
(IV) No portion of the project is designated for use as a hotel,
motel, bed and breakfast inn, or other transient lodging, except a
portion of the project may be designated for use as a residential
hotel, as defined in Section 50519 of the Health and Safety Code.
(C) Transitional housing or supportive housing.
(D) Farmworker housing, as defined in subdivision (h) of Section 50199. 7
of the Health and Safety Code.
21080.66(a)(1)
(A) Except as provided in subparagraph (B), the project site is not
more than 20 acres.
(B) The project site or the parcel size for a builder's remedy project, as
defined in paragraph (11) of subdivision (h) of Section 65589.5 of the
Government Code, or the project site or the parcel size for a project
that applied pursuant to paragraph (5) of subdivision (d) of Section
65589.5 of the Government Code as it read before January 1, 2025, is
not more than five acres.
21080.66(a)(2)
The project site meets either of the following criteria:
(A) Is located within the boundaries of an incorporated municipality.
Salk Avenue Apartments Project
The project site is 9. 78 acres and as such, satisfies the condition of
not being more than 20 acres. The project is not a builder's remedy
project. Therefore, the project site meets the criteria set forth in
Section 21080.66(a)(1 )(A) and (B).
The project is located within the boundaries of the City. Therefore,
the project site meets the criteria set forth in Section
21080.66(a)(2)(A).
6 June 3, 2026 Item #1 56 of 417
City of Carlsbad
PRC Section 21080.66 (AB 130)
Housing Development Project CEQA Exemption Evaluation Checklist
PRC Section 21080.66 Housing Development Project CEQA Exemption Evaluation Checklist
Criteria and Requirements Evaluation
(B) Is located within an urban area, as defined by the United States
Census Bureau.
21080.66(a)(3)
The project site meets any of the following criteria:
(A) Has been previously developed with an urban use.
(B) At least 75 percent of the perimeter of the site adjoins parcels that
are developed with urban uses.
(C) At least 75 percent of the area within a one-quarter mile radius of
the site is developed with urban uses.
(D) For sites with four sides, at least three out of four sides are
developed with urban uses and at least two-thirds of the perimeter of
the site adjoins parcels that are developed with urban uses.
Additional Description/Referenced Code Section(s}
Per 21080.66 (f)(3):
(3) "Urban use" means any current or previous residential or commercial
development, public institution, or public park that is surrounded by other
urban uses, parking lot or structure, transit or transportation passenger
facility, or retail use, or any combination of those uses.
21080.66(a)(4)
(A) The project is consistent with the applicable general plan and
zoning ordinance, as well as any applicable local coastal program as
defined in Section 30108.6. For purposes of this section, a housing
development project shall be deemed consistent with the applicable
general plan and zoning ordinance, and any applicable local coastal
program, if there is substantial evidence that would allow a
reasonable person to conclude that the housing development project
is consistent.
(B) If the zoning and general plan are not consistent with one another,
a project shall be deemed consistent with both if the project is
consistent with one.
Salk Avenue Apartments Project
The project site is located in the FCCSP and is bounded by a
private driving range and golf facility to the west and office
buildings to the south and east, all of which qualify as "Urban Uses"
per Section 21080.66(f)(3). At least 75 percent of the project site is
thus adjacent to urban uses and within one-quarter mile of urban
uses, and the project site is surrounded on three sides by urban
uses. Therefore, the project site meets the criteria set forth in
Section 21080.66(a)(3)(8), (C), and (D).
The project site is not located within the coastal zone. The project
site has a General Plan land use designation of Residential (R-30),
which allows between 23 and 30 du/ac, and a zoning designation
of Residential Density-Multiple (RD-M), which implements the R-8
(Residential 4-8 du/ac), R-15 (Residential 11 .5-15 du/ac), R-23
(Residential 19-23 du/ac), R-30 (Residential 26.5-30 du/ac), R-35
(Residential 32.5-35 du/ac, and R-40 (Residential 37.5-40 du/ac)
land use designations of the General Plan. The R-30 land use
designation would allow up to 294 units on the project site (i.e., 294
units is the base density). However, the project qualifies for a 35
percent density bonus, pursuant to California Government Code
Section 65915 and Carlsbad Municipal Code Chapter 21.86,
because 59 units ( or 20 percent of the base density) of the total
dwelling units would be restricted to low-income households (i.e.,
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(C) The approval of a density bonus, incentives or concessions,
waivers or reductions of development standards, and reduced parking
ratios pursuant to Section 65915 of the Government Code shall not be
grounds for determining that the project is inconsistent with the
applicable general plan, zoning ordinance, or local coastal program.
21080.66(a)(5)
The project will be at least one-half of the applicable density specified
in subparagraph (B) of paragraph (3) of subdivision (c) of Section
65583.2 of the Government Code.
Additional Description/Referenced Code Section(s)
Government Code Section 65583.2(c)(3)(B):
The following densities shall be deemed appropriate to accommodate
housing for lower income households:
(i) For an incorporated city within a nonmetropolitan county and for a
nonmetropolitan county that has a micropolitan area: sites allowing at
least 15 units per acre.
Salk Avenue Apartments Project
60 percent of AMI). As such, a density bonus of 103 units was
applied to the base density of 294 units, for a total of 397 dwelling
units proposed by the project. This equates to a proposed on-site
density of 40.5 du/ac. Under State Density Bonus Law
(Government Code Section 65915(f)(5)), the granting of a density
bonus shall not require, or be interpreted, in and of itself, to require
a General Plan amendment. The amount of density bonus a project
is eligible for is determined based on the amount of on-site
affordable units and the income level of affordable units provided in
the project pursuant to State Density Bonus Law. Therefore, the
project site meets the criteria set forth in Section
21080.66(a)(4)(A), (B), and (C).
References:
City of Carlsbad, General Plan Land Use Map,
https:llwww. carlsbadca. qov/home/showpublisheddocument/18761 I
638639185832030000, updated July 2024.
City of Carlsbad, General Plan Zoning Map,
https:llwww.carlsbadca.gov/home/showpublisheddocument/246/63
8636302563818331. updated July 2024.
City of Carlsbad, Local Coastal Program, published 2019.
The project site is in the City, which is located within San Diego
County, a metropolitan county. The project would provide 397 units,
which would result in 40.5 units per acre. Therefore, the project
meets the criterium set forth in 21080.66(a)(5)(iv).
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(ii) For an unincorporated area in a nonmetropolitan county not included
in clause (i): sites allowing at least 10 units per acre.
(iii) For a suburban jurisdiction: sites allowing at least 20 units per acre.
(iv) For a jurisdiction in a metropolitan county: sites allowing at least 30
units per acre.
Government Code Section 65583.2(d)defines metropolitan county,
nonmetropolitan county, and nonmetropolitan county with a micropolitan
area as follows:
(d) For purposes of this section, a metropolitan county, nonmetropolitan
county, and nonmetropolitan county with a micropolitan area shall be as
determined by the United States Census Bureau. A nonmetropolitan
county with a micropolitan area includes the following counties: Del Norte,
Humboldt, Lake, Mendocino, Nevada, Tehama, and Tuolumne and other
counties as may be determined by the United States Census Bureau to
be nonmetropolitan counties with micropolitan areas in the future.
21080.66(a)(6)
The project satisfies the requirements specified in paragraph (6) of
subdivision (a) of Section 65913.4 of the Government Code.
Additional Description/Referenced Code Section(s)
Government Code Section 65913.4(a)(6):
The development is not located on a site that is any of the following:
[See rows A-K, below.]
(A) [Coastal Zone]
(i) An area of the coastal zone subject to paragraph ( 1) or (2) of subdivision
(a) of Section 30603 of the Public Resources Code.
(ii) An area of the coastal zone that is not subject to a certified local coastal
program or a certified land use plan.
(iii) An area of the coastal zone that is vulnerable to five feet of sea level
rise, as determined by the National Oceanic and Atmospheric
Administration, the Ocean Protection Council, the United States Geological
Salk Avenue Apartments Project
See items A-K, below.
The project site is not located in the coastal zone.
Reference:
City of Carlsbad, Local Coastal Program, published 2019,
accessed November 18, 2025.
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Survey, the University of California, or a local government's coastal hazards
vulnerability assessment.
(iv) In a parcel within the coastal zone that is not zoned for multifamily
housing.
(v) In a parcel in the coastal zone and located on either of the following:
(I) On, or within a 100-foot radius of, a wetland, as defined in Section
30121 of the Public Resources Code.
(II) On prime agricultural land, as defined in Sections 30113 and 30241 of
the Public Resources Code.
(B) [Prime Farmland or Farmland of Statewide Importance]
Either prime farmland or farmland of statewide importance, as defined
pursuant to the United States Department of Agriculture land inventory and
monitoring criteria, as modified for California, and designated on the maps
prepared by the Farmland Mapping and Monitoring Program of the
Department of Conservation, or land zoned or designated for agricultural
protection or preservation by a local ballot measure that was approved by
the voters of that jurisdiction.
(C) [Wetlands]
Wetlands, as defined in the United States Fish and Wildlife Service Manual,
Part 660 FW 2 (June 21, 1993).
(D) [Very High Fire Hazard Severity Zone]
Within a very high fire hazard severity zone, as determined by the
Department of Forestry and Fire Protection pursuant to Section 51178. or
within the state responsibility area, as defined in Section 4102 of the Public
Resources Code. This subparagraph does not apply to sites that have
adopted fire hazard mitigation measures pursuant to existing building
standards or state fire mitigation measures applicable to the development,
Salk Avenue Apartments Project
The project site is not located on a site that is classified as Prime
Farmland or Farmland of Statewide Importance.
Reference:
California Department of Conservation, California Important
Farmland Finder, https:llmaps. conservation. ca. qov/DLRPICIFFI.
accessed November 18, 2025.
There are no state or federally protected wetlands as defined in the
United States Fish and Wildlife Service Manual on or near the
project site or off-site improvement areas.
Reference:
Biological Resources Technical Letter Report for the Salk Avenue
Apartments Project in Carlsbad, San Diego County, Michael Baker
International, February 5, 2026.
The project site is not located within a Very High Fire Hazard
Severity Zone.
Reference:
CAL FIRE, Fire Hazard Severity Zones Maps, Fire Hazard Severity
Zone Viewer, https:llfire-hazard-severity-zones-rollout-calfire
forestry. hub. arcqis. com/pages/access-map, accessed November
18, 2025.
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including, but not limited to, standards established under all of the following
or their successor provisions:
(i) Section 4291 of the Public Resources Code or Section 51182. as
applicable.
(ii) Section 4290 of the Public Resources Code.
(iii) Chapter 7 A of the California Building Code (Title 24 of the California
Code of Regulations).
(E) [Hazardous Waste Sites]
A hazardous waste site that is listed pursuant to Section 65962. 5 or a
hazardous waste site designated by the Department of Toxic Substances
Control pursuant to Section 25356 of the Health and Safety Code, unless
either of the following apply:
(i) The site is an underground storage tank site that received a uniform
closure letter issued pursuant to subdivision (g) of Section 25296. 10 of
the Health and Safety Code based on closure criteria established by the
State Water Resources Control Board for residential use or residential
mixed uses. This section does not alter or change the conditions to
remove a site from the list of hazardous waste sites listed pursuant to
Section 65962. 5.
(ii) The State Department of Public Health, State Water Resources
Control Board, Department of Toxic Substances Control, or a local
agency making a determination pursuant to subdivision (c) of Section
25296. 10 of the Health and Safety Code, has otherwise determined that
the site is suitable for residential use or residential mixed uses.
(F) [Earthquake Fault Zone]
Within a delineated earthquake fault zone as determined by the State
Geologist in any official maps published by the State Geologist, unless the
development complies with applicable seismic protection building code
standards adopted by the California Building Standards Commission under
the California Building Standards Law (Part 2.5 (commencing with Section
18901) of Division 13 of the Health and Safety Code), and by any local
Salk Avenue Apartments Project
The project site is not listed as a hazardous waste site by the
Department of Toxic Substances Control pursuant to Section
25356 of the Health and Safety Code.
Reference:
Department of Toxic Substances Control (DTSC), Envirostor
Online Database, https:llwww. envirostor. dtsc. ca. gov/public/map/.
reviewed November 20, 2025.
California State Water Resources Control Board, Geo Tracker,
https:l/qeotracker. waterboards.ca.qovlmap/, reviewed November
20, 2025.
The project site is not mapped in an earthquake fault zone.
Reference:
California Geological Survey, Earthquake Zones of Required
Investigation Map,
https:llmaps. conservation. ca. qovlcqslinformationwarehouseleqzap
Qi, accessed November 18, 2025.
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building department under Chapter 12.2 (commencing with Section 8875)
of Division 1 of Title 2.
(G) [Special Flood Hazard Area]
Within a special flood hazard area subject to inundation by the 1 percent
annual chance flood (100-year flood) as determined by the Federal
Emergency Management Agency in any official maps published by the
Federal Emergency Management Agency If a development proponent is
able to satisfy all applicable federal qualifying criteria in order to provide
that the site satisfies this subparagraph and is otherwise eligible for
streamlined approval under this section, a local government shall not deny
the application on the basis that the development proponent did not comply
with any additional permit requirement, standard, or action adopted by that
local government that is applicable to that site. A development may be
located on a site described in this subparagraph if either of the following are
met:
(i) The site has been subject to a Letter of Map Revision prepared by the
Federal Emergency Management Agency and issued to the local
jurisdiction.
(ii) The site meets Federal Emergency Management Agency
requirements necessary to meet minimum flood plain management
criteria of the National Flood Insurance Program pursuant to Part 59
(commencing with Section 59. 1) and Part 60 (commencing with Section
60. 1) of Subchapter B of Chapter I of Title 44 of the Code of Federal
Regulations.
(H) [Regulatory Floodway]
Within a regulatory floodway as determined by the Federal Emergency
Management Agency in any official maps published by the Federal
Emergency Management Agency, unless the development has received a
no-rise certification in accordance with Section 60. 3(d)(3) of Title 44 of the
Code of Federal Regulations. If a development proponent is able to satisfy
all applicable federal qualifying criteria in order to provide that the site
satisfies this subparagraph and is otherwise eligible for streamlined
approval under this section, a local government shall not deny the
Salk Avenue Apartments Project
The project site is not within a special flood hazard area.
Reference:
FEMA, Flood SeNice Map SeNice Area (FIRM Map No.
06073C0769G), https:l/msc.fema.gov/portal/home. effective date
May 16, 2012, accessed November 20, 2025.
The project site is not mapped within a regulatory floodway.
Reference:
FEMA, Flood Insurance Rate Map (FIRM Map No. 06073C0769G),
https:llmsc.fema.govlportallhome .. effective date May 16, 2012,
accessed November 20, 2025.
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application on the basis that the development proponent did not comply
with any additional permit requirement, standard, or action adopted by that
local government that is applicable to that site.
(I) [Conservation Lands in a Natural Community Conservation Plan]
Lands identified for conservation in an adopted natural community
conservation plan pursuant to the Natural Community Conservation
Planning Act (Chapter 10 (commencing with Section 2800) of Division 3 of
the Fish and Game Code), habitat conservation plan pursuant to the federal
Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.), or other
adopted natural resource protection plan.
(J) [Habitat for Protected Species]
Habitat for protected species identified as candidate, sensitive, or species
of special status by state or federal agencies, fully protected species, or
species protected by the federal Endangered Species Act of 1973 (16
U.S.C. Sec. 1531 et seq.), the California Endangered Species Act (Chapter
1. 5 ( commencing with Section 2050) of Division 3 of the Fish and Game
Code), or the Native Plant Protection Act (Chapter 10 (commencing with
Section 1900) of Division 2 of the Fish and Game Code).
Salk Avenue Apartments Project
The project site is covered by the City of Carlsbad Habitat
Management Plan, which serves as the Natural Community
Conservation Plan for the City. However, the project site is not
within a HMP Conservation Area, HMP Proposed Hardline
Conservation Area, Standards area, or otherwise identified for
conservation, which are identified in the Habitat Management Plan
for conservation.
Reference:
City of Carlsbad, City of Carlsbad Habitat Management Plan,
https:llwww.carlsbadca.gov/home/showpublisheddocument/1600/6
38366818940500000. amended December 1999.
Habitat for protected species is present on the project site. The
northwestern portion of the project site contains habitat suitable for
protected species including coastal California gnatcatcher
(Polioptila californica californica, federally threatened, state species
of concern), Crotch's bumble bee (Bombus crotchii; state candidate
endangered), and thread-leaved brodiaea (Brodiaea filifolia;
federally threatened, state endangered, California Rare Plant Rank
1 8.1 ). However, the entirety of this potential habitat lies outside of
the development footprint.
Because the proposed project is unable to satisfy this qualifying
condition, the AB 130 CEQA exemption cannot be granted. An
initial study must be prepared to study the environmental
consequences of the project, limited to evaluating the effects upon
the environment that are caused solely by this single condition.
Reference:
Biological Resources Technical Letter Report for the Salk Avenue
Apartments Project in Carlsbad, San Diego County, Michael Baker
International, February 5, 2026.
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(K) [Conservation Easement]
Lands under conservation easement.
21080.66(a)(7)
The project does not require the demolition of a historic structure that
was placed on a national, state, or local historic register before the
date a preliminary application was submitted for the project pursuant
to Section 65941.1 of the Government Code.
21080.66(a)(8)
For a project that was deemed complete pursuant to paragraph (5) of
subdivision (h) of Section 65589.5 of the Government Code on or after
January 1, 2025, no portion of the project is designated for use as a
hotel, motel, bed and breakfast inn, or other transient lodging. For the
purposes of this section, "other transient lodging" does not include
either of the following:
(A) A residential hotel, as defined in Section 50519 of the Health and
Safety Code.
(B) After the issuance of a certificate of occupancy, a resident's use
or marketing of a unit as short-term lodging, as defined in Section
17568.8 of the Business and Professions Code, in a manner
consistent with local law.
21080.66(b) Tribal Notification/Consultation and Measures for Tribal
Cultural Resources
PRC section 21080.66(b) requires the local government to complete a
notification/consultation process with each California Native American
tribe traditionally and culturally affiliated with the project site. PRC
section 21080.66(b) also requires that certain measures and additional
enforceable agreements be made binding conditions of project
approval. PRC section 21080.66(b) is provided in its entirety in the
"Additional Subsections of PRC Section 21080.66" portion of this
document for reference.
Salk Avenue Apartments Project
The project site is not under a conservation easement.
The are no existing structures on the project site.
The project does not contain hotel, motel, bed and breakfast inn, or
other transient lodging components.
Because the project site contains habitat for protected species
(refer to item J), tribal consultation is occurring via the AB 52
process undertaken with preparation of a project-specific Focused
IS/MND. The City mailed US Postal Service-certified mail and
emailed letters to the Desert Cahuilla Indians, Mesa Grande Band
of Diegueno Mission Indians, Rincon Band of Luiselio Indians, and
San Luis Rey Band of Mission Indians on January 5, 2026 to
initiate the AB 52 notification process. Consultation, if requested by
a tribe, will occur concurrently with public and agency review of the
Focused IS/MND. The City will not adopt the IS/MND until any
requested consultations are complete or otherwise closed.
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21080.66(c)(1)
(AJ The local government shall, as a condition of approval for the
development, require the development proponent to complete a phase
I environmental assessment, as defined in Section 78090 of the Health
and Safety Code.
(BJ If a recognized environmental condition is found, the development
proponent shall complete a preliminary endangerment assessment, as
defined in Section 78095 of the Health and Safety Code, prepared by
an environmental assessor to determine the existence of any release
of a hazardous substance on the site and to determine the potential
for exposure of future occupants to significant health hazards from
any nearby property or activity.
(CJ If a release of a hazardous substance is found to exist on the site,
the release shall be removed or any effects of the release shall be
mitigated to levels required by current federal and state statutory and
regulatory standards before the local government issues a certificate
of occupancy.
(DJ If a potential for exposure to significant hazards from surrounding
properties or activities is found to exist, the effects of the potential
exposure shall be mitigated to levels required by current federal and
state statutory and regulatory standards before the local government
issues a certificate of occupancy.
21080.66(c)(2)
For any housing on the site located within 500 feet of a freeway, all of
the following shall apply:
(AJ The building shall have a centralized heating, ventilation, and air
conditioning system.
(BJ The outdoor air intakes for the heating, ventilation, and air
conditioning system shall face away from the freeway.
(CJ The building shall provide air filtration media for outside and
return air that provides a minimum efficiency reporting value of 16.
Salk Avenue Apartments Project
A Phase I Environmental Site Assessment was conducted for the
project site and no recognized environmental conditions,
hazardous substances, or potential for exposure to significant
hazards from surrounding properties were found to exist.
Reference:
Phase I Environmental Site Assessment Report, Assessor's Parcel
Number 212-021-04, Carlsbad CA, Verdantas Inc., March 10,
2025.
The project site is not within 500 feet of a freeway.
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(D) The air filtration media shall be replaced at the manufacturer's
designated interval.
(E) The building shall not have any balconies facing the freeway.
21080.66(d)(1)
Notwithstanding any other law, all construction workers employed in
the execution of a housing development project exempt from this
division pursuant to this section where 100 percent of the units within
the development project are dedicated to lower income households,
as defined by Section 50079.5 of the Health and Safety Code, shall be
paid at least the general prevailing rate of per diem wages for the type
of work and geographic area, as determined by the Director of
Industrial Relations pursuant to Sections 1773 and 1773.9 of the Labor
Code, except that apprentices registered in programs approved by the
Chief of the Division of Apprenticeship Standards may be paid at least
the applicable apprentice prevailing rate, regardless of whether the
housing development project is a public work.
21080.66(d)(2)
Notwithstanding any other law, the labor standards of paragraph (8) of
subdivision (a) of Section 65913.4 of the Government Code shall apply
to buildings over 85 feet in height above grade in any housing
development project exempt from this division pursuant to this
section.
21080.66(d)(3)
(A) Notwithstanding any other law, the labor standards of Article 4
(commencing with Section 65912.130) of Chapter4.1 of Division 1 of
Title 7 of the Government Code shall apply for projects of 50 units or
greater in the City and County of San Francisco that are not covered
by paragraph (2), for any construction craft where at least 50 percent
of the units in market-rate multifamily housing projects that received
their certificate of occupancy between 2022 and 2024, inclusive, were
built by workers that were paid not less than the general prevailing
rate of per diem wages.
Salk Avenue Apartments Project
Not applicable, as the proposed residential units are not 100
percent dedicated to lower income households.
The maximum height of the project is 59 feet, with corner elements
up to approximately 75 feet. As project height would not exceed 85
feet, the labor standards do not apply.
Not applicable, as the project site is not within the City or County of
San Francisco.
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(B) For purposes of this section, "market-rate multifamily housing
development project" means a housing development project of
greater than 10 units where less than 95 percent of the units are
dedicated to lower income households, as defined by Section 50079.5
of the Health and Safety Code.
(C) (i) The eligibility of this subparagraph, by classification, will be
determined by the Department of Industrial Relations and published
on its internet website by January 1, 2026.
(ii) In making a determination of eligibility pursuant to this
subparagraph, the Director of Industrial Relations shall obtain and
consider data from the labor organizations and employers or
employer associations concerned no later than October 1, 2025.
(iii) To determine the number of market-rate multifamily housing
projects that received their certificate of occupancy in a given year,
the Department of Industrial Relations shall use the annual progress
report data as reported by the jurisdiction pursuant to Section 65400
of the Government Code.
Salk Avenue Apartments Project 17 June 3, 2026 Item #1 67 of 417
{city of
Carlsbad Focused Initial Study/Mitigated Negative Declaration
APPENDIX B:
Senate Bill 131
Exclusions of Certain Types of
Housing Development Projects
CEQA Exemption Evaluation
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PRC Section 21080.1 (SB 131)
Exclusions of Certain Types of Housing Development Projects CEQA Exemption Evaluation
CITY OF CARLSBAD
PUBLIC RESOURCES CODE SECTION 21080.1 (SENATE BILL 131)
EXCLUSIONS OF CERTAIN TYPES OF HOUSING DEVELOPMENT PROJECTS
CEQA EXEMPTION EVALUATION
SALK AVENUE APARTMENTS
February 2026
California Senate Bill (SB) 131, signed into law by Governor Gavin Newsom on June 30, 2025,
and codified in Public Resources Code (PRC) Section 21080.1, establishes a statutory exemption
from the California Environmental Quality Act (CEQA) for qualifying "housing development
projects" that meet certain criteria and requirements. This SB 131 Exclusion of Certain Types of
Housing Development Projects CEQA Exemption Evaluation Checklist documents the eligibility
of the proposed Salk Avenue Apartments Project (project) for this CEQA exemption.
Criteria and Requirements Evaluation
PRC Section 21080.1(4) See Rows (A) through (D), below.
This subdivision does not apply to any of the
following housing development projects:
(A) A proposed housing development project that The project is similar in kind to the projects that
is not similar in kind to the projects listed in the would qualify for an Assembly Bill (AB) 130
statutory or categorical exemption. housing development project statutory exemption.
The project includes 397 residential units; no
commercial or institutional uses are proposed. As
the project designates greater than two-thirds of
the new square footage for residential use, it is a
housing development project that satisfies
Government Code Section 65589.5(h)(2)(B)(i).
Therefore, SB 131 applies to the project.
(B) A proposed housing development project that The project would have qualified for the housing
is ineligible for the statutory exemption or development project statutory exemption
categorical exemption due to two or more established by AB 130 except for the single
conditions. condition of the project site potentially being
habitat for protected species (refer to the project-
specific AB 130 Housing Development Project
CEQA Exemption Evaluation Checklist; Appendix
A). Therefore, SB 131 applies to the project.
(C) A proposed housing development project that The project does not include a distribution center
includes a distribution center or oil and gas or oil and gas infrastructure. Therefore, SB 131
infrastructure. applies to the project.
(D)(i) A proposed housing development project The project is not located on natural and protected
located on natural and protected lands, as lands, as further discussed in rows (a) through (p),
defined pursuant to PRC Section 21067.5. below. Therefore, SB 131 applies to the project.
(ii) The definition of "natural and protected
lands" described in clause (i) does not include
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the lands described in subdivision (o) of PRC
Section 21067.5.
Additional Descri12tion/Referenced Code
Section(s)
PRC Section 21067.5:
"Natural and protected lands" means sites located
within any of the following locations:
[See Rows (a) through (p), below. Please note
that per PRC Section 21081 .1 (D)(ii) above, PRC
Section 21067.5(0) is not included in the
conditions for SB 131 .)
(a) The state park system, as described in Article The project site is not included in the state park
1 (commencing with PRC Section 5001) of system. The project site is privately owned and
Chapter 1 of Division 5. has a City of Carlsbad (City) General Plan land
use designation of Residential, 23-30 Dwelling
Units Per Acre (du/ac) (R-30) within the Fenton
Carlsbad Center Specific Plan (FCCSP) and a
zoning designation of Residential Density-Multiple
(RD-M).
Reference:
California State Parks, Find a California State
Park, htt12.s:llwww.12.arks.ca. g_ov/Find-a-Park,
accessed January 13, 2026.
(b) A wilderness area, as defined in Section The project site is not located in a wilderness
5093.32. area. The U.S. Department of Agriculture (USDA)
Forest Service map of the wilderness study areas
did not identify any official boundaries of
wilderness areas in the immediate vicinity of the
project site.
Reference:
USDA Forest Service, Wilderness & Wild and
Scenic Rivers & Wilderness Study Areas,
htt12.s:l/data. fs. usda. g_ov/g_eodata/other fslwilderne
ss/stateMa12..12.h12.?statelD=CA, accessed January
12, 2026.
(c) A marine protected area, as defined in Section The project site is not located in a marine
2852 of the Fish and Game Code. protected area. Additionally, the project site is not
located in any marine or estuarine area or near
the mouth of a coastal river.
Reference:
California Department of Fish and Wildlife,
California Marine Protected Areas (MPAs),
htt12.s:llwildlife. ca. g_ov/Conservation/Marine/MPAs,
, accessed January 13, 2026.
(d) The national park system, as defined in The project site is not included in the national park
Section 100102 of Title 54 of the United States system. The project site is privately owned and
Code. has a General Plan land use designation of
Residential, 23-30 Dwelling Units Per Acre (du/ac)
Salk Avenue Apartments Project 2 June 3, 2026 Item #1 70 of 417
City of Carlsbad
PRC Section 21080.1 (SB 131)
Exclusions of Certain Types of Housing Development Projects CEQA Exemption Evaluation
Criteria and Requirements Evaluation
(R-30) within the FCCSP and a zoning
designation of Residential Density-Multiple (RD-
M).
Reference:
National Park Service, California Parks,
htt12.s:llwww. n12.s. g_ovlstate/calindex. htm, accessed
January 12, 2026.
(e) A national recreation area. The project site is not designated as a national
recreation area. A review of National Park Service,
Bureau of Land Management, and Bureau of
Reclamation websites did not identify any national
recreation areas in the immediate vicinity of the
project site.
Reference:
Bureau of Land Management, California National
Conservation Lands,
htt12.s:llwww.blm.g_ovl12.rog_ramslnational-
conservation-lands/california, accessed January
12, 2026.
Bureau of Reclamation, Recreation: National
Recreation Areas at Bureau of Reclamation
Federal Water Projects,
htt12.s:llwww. usbr. g_ovlrecreationlrecreationAreas. h
t!1lJ., accessed January 12, 2026.
National Park Service, California Parks,
htt12.s:llwww.n12.s. g_ov/state/calindex. htm, accessed
January 12, 2026.
(f) A national monument. The project site is not designated as a national
monument. A review of National Park Service,
Bureau of Land Management, U.S. Forest
Service, and Bureau of Reclamation websites did
not identify any national monuments in the
immediate vicinity of the project site.
Reference:
Bureau of Land Management, California National
Conservation Lands,
htt12.s:llwww. blm. g_ov/12.rog_rams/national-
conservation-lands/california, accessed January
12, 2026.
Bureau of Reclamation, Recreation: National
Recreation Areas at Bureau of Reclamation
Federal Water Projects,
htt12.s:llwww. usbr. g_ovlrecreationlrecreationAreas. h
t!1lJ., accessed January 12, 2026.
National Park Service, California Parks,
htt12.s:llwww.n12.s. g_ov/state/calindex. htm accessed
January 12, 2026.
Salk Avenue Apartments Project 3 June 3, 2026 Item #1 71 of 417
City of Carlsbad
PRC Section 21080.1 (SB 131)
Exclusions of Certain Types of Housing Development Projects CEQA Exemption Evaluation
Criteria and Requirements Evaluation
USDA Forest Service, USDA Forest Service
Managed National Monuments,
htt12.s:llwww. fs. usda.g_ovlvisitlnational-monuments,
accessed January 12, 2026.
(g) The national wild and scenic rivers system, as The project site is not located in national wild and
defined in Section 1273 of Title 16 of the United scenic rivers system. The USDA Forest Service
States Code. map of the wild and scenic rivers did not identify
any such rivers in the immediate vicinity of the
project site.
Reference:
USDA Forest Service, Wilderness & Wild and
Scenic Rivers & Wilderness Study Areas,
htt12.s:l/data. fs. usda. g_ov/g_eodata/other fslwilderne
ss/stateMa12..12.h12.?statelD=CA, accessed January
7, 2026.
(h) Any ecological reserve or wildlife management The project site is covered by the City of Carlsbad
area acquired and managed by the Department of Habitat Management Plan, which serves as the
Fish and Wildlife pursuant to Article 2 Natural Community Conservation Plan for the
(commencing with Section 1525) or Article 4 City. However, the project site is not within a HMP
(commencing with Section 1580) of Chapter 5 of Conservation Area, HMP Proposed Hardline
Division 2 of the Fish and Game Code. Conservation Area, Standards area, or otherwise
identified for conservation, which are identified in
the Habitat Management Plan for conservation.
Additionally, the land is in private ownership.
Reference:
City of Carlsbad, 1999, City of Carlsbad Habitat
Management Plan,
htt12.s:llwww. carlsbadca. g_ov/home/show12.ublished
document/1600/638366818940500000.
(i) A hazardous waste site that is listed pursuant to The project site is not listed as a hazardous waste
Section 65962. 5 of the Government Code or a site by the California Department of Toxic
hazardous waste site designated by the Substances Control pursuant to Section 25356 of
Department of Toxic Substances Control pursuant the Health and Safety Code. In addition, a Phase I
to Section 25356 of the Health and Safety Code, Environmental Site Assessment was completed
unless either of the following apply: for the project site and did not identify the project
(1) The site is an underground storage tank site site as a hazardous waste site.
that received a uniform closure letter issued References:
pursuant to subdivision (g) of Section 25296.10 California Department of Toxic Substances
of the Health and Safety Code based on closure Control (DTSC), Envirostor Online Database,
criteria established by the State Water htt12.s:llwww. envirostor. dtsc. ca. g_ovl12.ublic/ma12.I.
Resources Control Board for the use proposed accessed November 20, 2025.
by the project. This paragraph does not alter or California State Water Resources Control Board, change the conditions to remove a site from the Geo Tracker, list of hazardous waste sites listed pursuant to htt12.s:I /g_eotracker. waterboards. ca. g_ovlma12.I. Section 65962. 5 of the Government Code. accessed November 20, 2025.
(2) The State Department of Public Health, Verdantas Inc., 2025, Phase I Environmental Site State Water Resources Control Board, Assessment Report, Assessor's Parcel Number Department of Toxic Substances Control, or a 212-021-04, Carlsbad CA. local agency making a determination pursuant
Salk Avenue Apartments Project 4 June 3, 2026 Item #1 72 of 417
City of Carlsbad
PRC Section 21080.1 (SB 131)
Exclusions of Certain Types of Housing Development Projects CEQA Exemption Evaluation
Criteria and Requirements Evaluation
to subdivision (c) of Section 25296. 10 of the
Health and Safety Code has otherwise
determined that the site is suitable for the use
proposed by the project.
(j) Within a regulatory f/oodway as determined by The project site is not located within a regulatory
the Federal Emergency Management Agency in floodway.
any official maps published by the Federal Reference:
Emergency Management Agency, unless the FEMA, National Flood Hazard Layer (NFHL) development has received a no-rise certification in Viewer, accordance with Section 60.3(d)(3) of Title 44 of httgs:l/msc. fem a. g_ov/gortal/search? AddressQuect. the Code of Federal Regulations. =salk%20avenue%2C%20carlsbad, accessed
November 26, 2025.
(k) Lands under conservation easement. The project site is not under a conservation
easement.
Reference:
California Natural Resource Agency, National
Conservation Easement Database (CCED)
Viewer, httgs:l/g_is. cnra. ca. g_ov/aggs/cced/,
accessed January 12, 2026.
(I) On, or within a 300-foot radius of, a wetland, as The project development limits are not within a
defined in the United States Fish and Wildlife 300-foot radius of any wetlands, as defined in the
Service Manual, Part 660 FW 2 (June 21, 1993). United States Fish and Wildlife Service Manual.
Reference:
Michael Baker International, Biological Resources
Technical Letter Report for the Salk Avenue
Apartments Project in Carlsbad, San Diego
County, February 5, 2026.
(m) An environmentally sensitive area within the No portion of the project site is located in the
coastal zone, as defined in PRC Section 30107.5. coastal zone.
Reference:
California Coastal Commission, Critical Coastal
Areas Map,
httgs:l/exgerience. arcg_is. comlexgerience/268e 7 af
00a90451 0bac 77312e0f39fc0/gag_e/Pag_e,
accessed January 12, 2026,.
(n) Lands identified for conservation in an adopted The project site is covered by the City of Carlsbad
natural community conservation plan pursuant to Habitat Management Plan, which serves as the
the Natural Community Conservation Planning Act Natural Community Conservation Plan for the
(Chapter 10 (commencing with Section 2800) of City. However, the project site is not within a HMP
Division 3 of the Fish and Game Code) or habitat Conservation Area, HMP Proposed Hardline
conservation plan pursuant to the federal Conservation Area, Standards area, or otherwise
Endangered Species Act of 1973 (16 U.S. C. Sec. identified for conservation, which are identified in
1531 et seq.), or other adopted natural resource the Habitat Management Plan for conservation.
protection plan. Reference:
Michael Baker International, Biological Resources
Technical Letter Report for the Salk Avenue
Salk Avenue Apartments Project 5 June 3, 2026 Item #1 73 of 417
City of Carlsbad
PRC Section 21080.1 (SB 131)
Exclusions of Certain Types of Housing Development Projects CEQA Exemption Evaluation
Criteria and Requirements Evaluation
(p) Either prime farmland or farmland of statewide
importance, as defined pursuant to the United
States Department of Agriculture land inventory
and monitoring criteria, as modified for California,
and designated on the maps prepared by the
Farmland Mapping and Monitoring Program of the
Department of Conservation, or land zoned or
designated for agricultural protection or
preservation by a local ballot measure that was
approved by the voters of that jurisdiction.
Salk Avenue Apartments Project
Apartments Project in Carlsbad, San Diego
County, February 5, 2026.
City of Carlsbad, 1999, City of Carlsbad Habitat
Management Plan,
https:llwww. carlsbadca. govlhomelshowpublished
document/1600/638366818940500000.
The project site is not located on a site that is
classified as Prime Farmland or Farmland of
Statewide Importance. The project site is
classified as Urban and Built-Up Land.
Reference:
California Department of Conservation, California
Important Farmland Finder,
https:llmaps. conservation. ca. gov/DLRPICI FF/.
accessed January 12, 2026.
6 June 3, 2026 Item #1 74 of 417
Final Focused Initial Study/Mitigated Negative Declaration
Salk Avenue Apartments Project Appendices
APPENDIX C:
Biological Resources
Technical Letter Report
June 3, 2026 Item #1 75 of 417
April 30, 2026 JN 205484
JOE GAMBILL
Hanover Company
11611 San Vicente Boulevard, Suite 740
Los Angeles, California 90049
SUBJECT: Biological Resources Technical Letter Report for the Salk Avenue Apartments Project in Carlsbad, San Diego County, California
Dear Mr. Gambill,
Michael Baker International is pleased to submit this technical letter report documenting the
results of a biological resources assessment for the proposed Salk Avenue Apartments Project
(the project), which proposes the development of multifamily residential units in the City of
Carlsbad, California. This report is intended to satisfy the requirements of the California
Environmental Quality Act (CEQA) and the City of Carlsbad Habitat Management Plan (HMP).
1.0 PROJECT LOCATION
The 9.8-acre project site is located in the City of Carlsbad, California, south of Salk Avenue, west
of El Camino Real, east of College Boulevard, and north of Faraday Avenue (Assessor’s Parcel
Number 212-021-04-00). The project occurs within Township 12 South, Range 04 West of the
San Luis Rey 7.5-minute United States Geological Survey (USGS) topographic quadrangle map
(Attachment A, Figure 1, Regional and Project Vicinity). The project site is within the boundaries
of the City of Carlsbad HMP and must be in compliance with the plan.
2.0 PROJECT DESCRIPTION
The applicant proposes the construction and occupation of a 397-dwelling unit apartment complex
on the approximately 9.8-acre project site (refer to Attachment 2a, Project Site). The residential
building would be five stories with a maximum building height of 59 feet, with allowed architectural
projections up to 74 feet, 7 inches. The building configuration would result in several outdoor
courtyard areas with landscaping and hardscape amenities such as seating areas. A five-level
aboveground parking garage would be constructed to the south of the residential building. Surface
parking would also be provided along the perimeter of the residential building. Site ingress/egress
would occur via a new driveway from Salk Avenue.
The property was previously graded around 2007 to create a development pad for the Fox Miller
Project but otherwise remains undeveloped. The proposed project would develop 6.35 acres of
the project site (Limits of Disturbance) (refer to Attachment A, Figure 2a, Project Site). Off-site
improvements for the proposed project would replace approximately 875 linear feet of sewer
June 3, 2026 Item #1 76 of 417
pipeline beneath College Boulevard between El Camino Real and Sunny Creek Road (refer to
Attachment A, Figure 2b, College Blvd Sewer Line Extension Location).
3.0 EXISTING SITE CONDITIONS
The project site and a 100-foot buffer (the study area) were evaluated for the proposed project
site (refer to Attachment A, Figure 4a, Study Area). A 25-foot study area buffer was applied to the
College Boulevard sewer line improvement (off-site improvement area; refer to Attachment A,
Figure 4b, Study Area-Off-Site Sewer Line). Elevations on-site range from approximately 170 feet
in the northwest along Salk Avenue to 275 feet along the southeastern portion of the project site.
Elevations for the off-site improvement area range from 80 feet to 110 feet. Refer to Attachment
B for representative photographs taken throughout the project site.
Soils on-site consist of the following types (USDA NRCS 2025; see Attachment A, Figure 3a,
USDA Soils):
• AtC: Altamont Clay, 5 to 9 percent slopes
• AtE: Altamont Clay, 15 to 30 percent slopes, warm MAAT, MLRA 20
Soil properties in the off-site improvement area (Study Area-Off-Site Sewer Line) consist of the
following types (USDA NRCS 2025; see Attachment A, Figure 3b, USDA Soils-Off-Site Sewer
Line):
• Altamont clay, 9 to 15 percent slopes, warm MAAT, MLRA 20
• Altamont clay, 15 to 30 percent slopes, warm MAAT, MLRA 20
• Salinas clay, 2 to 5 percent slopes
• Tujunga sand, 0 to 5 percent slopes
3.1 Project Site History
The project site was previously evaluated as part of a larger property known as the Fox Miller
Property II (for the Fox Miller Project). In 2001, a Biological Technical Report was prepared by
RECON. Additionally, focused studies for thread-leaved brodiaea (Brodiaea filifolia) and coastal
California gnatcatcher (Polioptila californica californica) were conducted in 2003 (RECON 2004).
A Mitigated Negative Declaration was also prepared and adopted by the City of Carlsbad in 2002.
After approval of the Fox Miller Project, the Salk Avenue Apartments Project site was filled and
graded (circa. 2007) to create a development pad but has remained vacant and undeveloped.
The approval of the Fox Miller Project included mitigation for impacts on thread-leaved brodiaea.
During the 2003 focused surveys for the Fox Miller Project, a total of 19,100 thread-leaved
brodiaea plants were counted; however, none of these plants occurred within the Salk Avenue
Apartments Project study area. A coastal California gnatcatcher observation was made in
2000/2001, but this species was not detected during the 2003 RECON focused surveys.
June 3, 2026 Item #1 77 of 417
3.2 City of Carlsbad Habitat Management Plan
The HMP provides a comprehensive, citywide, program to identify how the City of Carlsbad, in
cooperation with federal and state wildlife agencies, preserves the diversity of habitat and protect
sensitive biological resources in some areas, while allowing for development in other areas. The
City of Carlsbad’s HMP maps the distribution of vegetation communities and sensitive species
through the use of Focus Planning Areas – which are further broken down into HMP cores,
linkages and Special Resource Areas.
Certain naturally vegetated areas in the City of Carlsbad are too small, edge-effected, or isolated
to be considered biological cores or linkage areas but are nonetheless important to preserve
design or the conservation of particular species. These areas are described here as Special
Resource Areas (SRAs). SRA 1 lies between El Camino Real, Faraday Avenue, and College
Boulevard within Zone 5. It comprises slopes covered by grasslands and small patches of coastal
sage scrub. This area is known to support a major population of a Narrow Endemic plant species
(Brodiaea filifolia) and may support additional Narrow Endemic species. Although SRA 1 is
isolated from biological core and linkage areas, conservation of Narrow Endemic plant
populations within the SRA is considered important for species conservation.
The project site is a covered activity under the City of Carlsbad HMP and is located in SRA 1.
However, the project site is not within a HMP Hardline Conservation Area or HMP Proposed
Hardline Conservation Area. There is no HMP Hardline Conservation Area located within or
between the El Camino Real, Faraday Avenue, and College Boulevard area. There is a HMP
Proposed Hardline Conservation Area located to the north of the project site, across Salk Avenue
(refer to Attachment A, Figure 6, Plans and Policies). The northernmost 40 feet of the existing
driveway that provides access to the project site and would be improved as part of the proposed
project and serve as egress/ingress for the project is within 100 feet of a Proposed Hardline area
(Attachment A, Figure 6, Plans and Policies) and may be subject to the HMP Adjacency
Standards. The HMP Adjacency Standards ensure that the project addresses potential indirect
effects and incorporates measures for fire management, erosion control, landscaping,
fencing/signs/lighting, and predator/exotic species control.
4.0 METHODS
4.1 Literature Review
Prior to conducting the field survey, Michael Baker conducted a thorough literature review and
records search to characterize existing site conditions and assess the potential for special-status1
biological resources to occur that might pose a constraint to implementation of the project. A query
of the California Natural Diversity Database (CNDDB) (CNDDB 2025) and California Native Plant
Society (CNPS) Online Inventory of Rare and Endangered Plants of California (CNPS 2025) was
conducted to obtain a list of special-status plant and wildlife species occurrence records within
1 Special-status refers to plant and wildlife species that are federal or state-listed, proposed, or candidates; plant
species that have been designated a California Rare Plant Rank by the California Native Plant Society; wildlife species that are designated by the California Department of Fish and Wildlife as Fully Protected, or Species of Special Concern; and other state or locally rare vegetation communities.
June 3, 2026 Item #1 78 of 417
the following USGS 7.5-minute quadrangle maps: San Luis Rey, Las Pulgas Canyon, Morro Hill,
Bonsall, Oceanside, San Marcos, Encinitas, and Rancho Santa Fe.
The U.S. Fish and Wildlife Service (USFWS) IPaC online database was also reviewed to identify
special-status species and other resources, such as Critical Habitat, known or expected to occur
on the project site or within the immediate vicinity (USFWS 2025). Due to the results listed in the
IPaC report, the USFWS Critical Habitat for Threatened & Endangered Species mapping tool
(USFWS 2025) was accessed to determine the location of designated Critical Habitat in relation
to the project site. Other sources of information about the project site and surrounding area include
the U.S. Department of Agriculture (USDA), Natural Resources Conservation Service (NRCS)
Web Soil Survey (USDA NRCS 2025) and the USFWS National Wetlands Inventory (USFWS
2025).
All the information obtained informed the understanding of the project site and assisted with the
field survey and subsequent analysis. The results presented in this report provide a detailed
assessment of the suitability of the habitat on-site to support special-status plant and wildlife
species and other sensitive natural resources.
4.2 Habitat Assessment/Field Survey
Michael Baker biologists Marisa Flores and Samantha Martinez conducted a field assessment on
January 24, 2025, between 8:15 a.m. and 10:15 a.m. to document existing conditions, conduct a
habitat assessment for special-status plant and wildlife species and sensitive natural
communities, and determine the presence of aquatic resources within the project site. Weather
conditions were generally sunny and calm with temperatures ranging from 56 to 69 degrees
Fahrenheit.
The project site and a 100-foot buffer (the study area) was evaluated. Classification of the on-site
vegetation communities and other land uses is based on the descriptions of terrestrial vegetation
classification systems described in the Draft Vegetation Communities of San Diego County
(Oberbauer et al. 2008) which is based on Holland (1993) classifications. In addition, site
characteristics such as soil condition, topography, hydrology, anthropogenic disturbances,
indicator species, condition of on-site vegetation communities, and the presence of potentially
regulated jurisdictional features were noted. A formal aquatic resources delineation was not
conducted. Michael Baker used geographic information systems (GIS) software to digitize the
mapped vegetation communities and overlayed the data onto an aerial photograph to further
analyze existing conditions and quantify the acreages of each vegetation community on-site.
All plant and wildlife species observed during the field survey were recorded in a field notebook.
Plant species observed were identified by visual characteristics and morphology in the field while
unusual and less familiar plant species were photographed and later identified using taxonomic
guides. Plant species nomenclature and taxonomy follows The Jepson Manual: Vascular Plants
of California, second edition (Baldwin et al. 2012) and scientific names are provided immediately
following common names of plant species (first reference only). Wildlife detections were made
through aural and visual detection, as well as observation of signs including scat, trails, tracks,
burrows, and nests.
June 3, 2026 Item #1 79 of 417
Field guides used to assist with identification of species during the field survey included The Sibley
Guide to Birds (Sibley 2014) for birds, A Field Guide to Western Reptiles and Amphibians
(Stebbins 2003) for herpetofauna, and A Field Guide to Mammals of North America (Reid 2006)
for mammals. Wildlife species taxonomy follows the North American Butterfly Association (NABA)
(NABA 2025) for butterflies, the Society for the Study of Amphibians and Reptiles (Crother et al.
2017) for herpetofauna, the American Ornithological Society for birds (Chesser et al. 2023), and
Mammal Species of the World (Wilson et al. 2005) for mammals. Scientific names are provided
immediately following common names of wildlife species (first reference only).
The potential for special-status species to occur in the study area was evaluated based on each
species’ known geographic distribution and elevation range; species-specific habitat requirements
(e.g., vegetation communities/land covers, soils, hydrology, slope/aspect, and other
requirements); life history traits (e.g., disturbance tolerance); and Michael Baker biologists’
expertise, knowledge, and best professional judgement. Current and historic records of species
identified during the literature review were also considered during the analysis; however, a
species’ potential to occur determination was not solely based on the age or location of these
previously documented records. The potential to occur categories used in this analysis are
defined as follows:
• Present: The species was observed or detected within the study area.
• Expected: The study area is within the known geographic distribution and elevation range
of the species, there is high quality suitable habitat present (considering vegetation, soils,
and other factors), and there is viable landscape connectivity to a local, known extant
population(s) or sighting(s) within the study area.
• Moderate: The study area is within the known geographic distribution and elevation range
of the species, there is moderate to low quality suitable habitat present (considering
vegetation, soils, and other factors), and there is limited or no landscape connectivity to a
local, known, extant population.
• Not Expected: The study area is outside the known geographic distribution and elevation
range of the species, there is marginal to no suitable habitat, and there is no connectivity
to known, extant populations.
• Absent: The species was not detected during focused or agency-approved protocol
surveys.
5.0 RESULTS
5.1 Vegetation Communities and Land Covers
The project site supports the following land cover types: Diegan Coastal Sage Scrub, Disturbed
Habitat, and Urban/ Developed as summarized in Table 1, Vegetation Communities and Land
Cover Types, and depicted in Attachment A, Figure 5a, Vegetation Communities/Land Uses and
Figure 5b, Vegetation Communities/Land Uses – Off-Site Sewer Line.
June 3, 2026 Item #1 80 of 417
TABLE 1. VEGETATION COMMUNITIES AND LAND COVER TYPES
Vegetation Community/ Land Cover Type Project Site (Acres)
Project Site + 100-foot Study Area (Acres)
Off-site Sewer Improvement Area LOD (Acres)
Off-site Sewer Improvement Area LOD + 25-foot Study Area (Acres)
32530 Diegan Coastal Sage Scrub 0.33 0.95 - -
1130 Disturbed Habitat 6.76 9.38 - 0.07
12000 Urban/ Developed 2.69 6.25 0.85 2.78
32500 Coastal Sage Scrub - 0.29 - -
79100 Eucalyptus Woodland - 0.19 - -
TOTAL 9.78 17.06 0.85 2.85
Notes:
LOD = Limits of Disturbance
32530 Diegan Coastal Sage Scrub
The Diegan Coastal Sage Scrub land cover mapping unit is located along the northwestern corner
of the project site compromising of a basin vegetated with coyote brush scrub. An undisturbed
area of Diegan Coastal Sage Scrub was also present south of the project site within the study
area.
Diegan Coastal Sage Scrub land cover is not impacted by the College Boulevard sewer line
extension (Study Area-Off-Site Sewer Line). This area is fully developed (paved roadway) and
does not contain natural habitat or vegetation.
1130 Disturbed Habitat
The disturbed habitat is primarily escaped ornamentals, scattered coyote brush (Baccharis
pilularis), and non-native grasses within the rough graded pad. This area is routinely mowed and
grass species were not identifiable during the site visit. Additional Disturbed Habitat was observed
within the study area west of the project site and was comprised of non-native grasses and
artichoke thistle (Cynara cardunculus).
The disturbed habitat is also within the off-site study area, west of the off-site improvement area
limits of disturbance (Study Area-Off-Site Sewer Line).
12000 Urban/Developed
This land cover consists of irrigated ornamental landscaping around the perimeter of the project
site and developments to the east and west.
June 3, 2026 Item #1 81 of 417
The urban/ developed land cover also includes the off-site limits of disturbance along College
Boulevard between El Camino Real and Sunny Creek Road (Study Area-Off-Site Sewer Line).
79100 Eucalyptus Woodland
The eucalyptus woodland is located just southwest of the project site, within the study area. It is
comprised of a woodland area dominated by gum trees (Eucalyptus spp.) and may provide
suitable nesting habitat for large birds and raptors.
Eucalyptus Woodlands is not impacted by the College Boulevard sewer line extension (Study
Area-Off-Site Sewer Line). This area is fully developed (paved roadway) and does not contain
natural habitat or vegetation.
5.2 General Floral Inventory
A total of 22 species of native or naturalized plants, 7 native (32 percent) and 15 non-native
(68 percent), were recorded on-site. Attachment C, Species Compendiums, contains a list of
observed plant species.
General native or naturalized plants are not impacted by the College Boulevard sewer line
extension (Study Area-Off-Site Sewer Line). This area is fully developed (paved roadway) and
does not contain natural habitat or vegetation.
5.3 General Wildlife Inventory
A total of 23 wildlife species were observed during the field survey, 21 native (91 percent) and
2 non-native (9 percent). The most commonly occurring birds during the field survey included
California towhee (Melozone crissalis), American crow (Corvus brachyrhynchos), and house finch
(Haemorhous mexicanus). Attachment C contains a full list of wildlife species detected on the
project site.
General wildlife species are not impacted by the College Boulevard sewer line extension (Study
Area-Off-Site Sewer Line). This area is fully developed (paved roadway) and does not contain
natural habitat or vegetation.
5.4 Special-Status Biological Resources
Sensitive Natural Communities
Eleven natural communities considered sensitive by the CDFW were reported in the CNDDB from
the eight USGS 7.5-minute quadrangle map regions surrounding and including the San Luis Rey
map. These include:
• Coastal Brackish Marsh
• Maritime Succulent Scrub
• San Diego Mesa Claypan Vernal Pool
June 3, 2026 Item #1 82 of 417
• San Diego Mesa Hardpan Vernal Pool
• Southern Coastal Salt Marsh
• Southern Cottonwood Willow Riparian Forest
• Southern Maritime Chaparral
• Southern Riparian Forest
• Southern Riparian Scrub
• Southern Sycamore Alder Riparian Woodland
• Southern Willow Scrub
The project site consists of Diegan Coastal Sage Scrub, Disturbed Habitat, and Urban/Developed
land cover types. The Diegan Coastal Sage Scrub is located in the northwest corner of the project
site and outside the limits of disturbance. There are no natural communities considered sensitive
by the CDFW within the project site.
There are no sensitive natural communities impacted by the College Boulevard sewer line
extension (Study Area-Off-Site Sewer Line). This area is fully developed (paved roadway) and
does not contain natural habitat or vegetation.
Special-Status Plant Species
A total of 68 special-status plant species were reported in the CNDDB and CNPS Online Inventory
of Rare and Endangered Plants of California from the nine USGS 7.5-minute quadrangle map
regions surrounding and including the San Luis Rey map. After a review of specific habitat
preferences, known distributions, and elevation ranges, one special-status plant species has the
potential to occur within the study area: thread-leaved brodiaea. However, Attachment D contains
a summary of special-status species with their potential to occur on the project site.
There are no sensitive natural communities impacted by the College Boulevard sewer line
extension (Study Area-Off-Site Sewer Line). This area is fully developed (paved roadway) and
does not contain natural habitat or vegetation.
Special-Status Wildlife Species
Sixty-four special-status wildlife species were reported in the CNDDB from the eight USGS
7.5-minute quadrangle map regions surrounding and including the San Luis Rey map. A California
gnatcatcher (Polioptila californica californica; FT, SSC, Covered) was observed within the
northwest corner of the project site during the survey (Attachment A, Figure 5a, Vegetation
Communities and Other Land Uses). The closest location of Crotch’s bumble bee (Bombus
crotchii; SCE) is documented in the CNDDB, with two occurrences of the species in 2024 noted
approximately 2.5 miles north of the project site at Lake Calavera Preserve. Therefore, because
of (1) the presence of nectaring sources (i.e., food sources) present on and near the project site,
(2) the presence of other bumble bees on the project site during the January 24, 2025 biological
survey (a yellow-faced bumble bee [Bombus vosnesenskii]), and (3) two known CNDDB
identifications of Crotch’s bumble bee within approximately 2.5 miles of the project site, there is
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moderate potential for Crotch’s bumble bee to occur on the project site, although likely only within
the 0.33-acre patch of Diegan coastal sage scrub in the northwest corner of the project site.
No other special-status wildlife species were observed during the field survey and are not
expected to occur on the project site due to a lack of suitable habitat and a review of specific
habitat preferences, known distributions, and elevation ranges. Attachment D contains a summary
of the special-status species with their potential to occur on the project site.
There are no special-status wildlife species impacted by the College Boulevard sewer line
extension (Study Area-Off-Site Sewer Line). This area is fully developed (paved roadway) and
does not contain natural habitat or vegetation.
Critical Habitat
Under the federal Endangered Species Act (ESA), Critical Habitat may be established for species
listed as threatened or endangered. Critical Habitat refers to specific areas within the geographical
range of a species that were occupied at the time it was listed that contain the physical or
biological features that are essential to the survival and eventual recovery of that species and that
may require special management considerations or protection, regardless of whether the species
is still extant in the area. Areas that were not known to be occupied at the time a species was
listed can also be designated Critical Habitat if they contain one or more of the physical or
biological features that are essential to that species’ conservation and if the other areas that are
occupied are inadequate to ensure the species’ recovery.
In the event that a project may result in take or adverse modification to a listed species’ designated
Critical Habitat, a project proponent may be required to engage in suitable mitigation. However,
consultation for impacts to Critical Habitat is only required when a project has a federal nexus.
This may include projects that occur on federal lands, require federal permits (e.g., Clean Water
Act [CWA] Section 404 permit), or receive any federal oversight or funding. If there is a federal
nexus, then the federal agency that is responsible for providing funds or permits would be required
to consult with the USFWS under the ESA.
The USFWS has mapped designated Critical Habitat for thread-leaved brodiaea (Brodiaea
filifolia) within the northwestern portion of the project site (Attachment A, Figure 7a, Biological
Resource Impacts). Soils on the project site are comprised of fill dirt brought in around 2007 for
the Fox Miller Project. Although some clay soils were observed on the margins of the project site,
soils within the majority of the project site appeared to be comprised of loam. Based on the
focused studies conducted by RECON in 2003, the species was not present on the project site
when habitat and soils would have been more suitable for the species. Routine soil and vegetation
disturbances also occur on the landscaped slopes and pad. Based on the historic and current site
disturbances the project site does not display the physical and biological characteristics for Critical
Habitat.
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State and Federal Jurisdictional Aquatic Features
Four key agencies regulate activities within coastal streams, wetlands, and riparian areas in
California. The U.S. Army Corps of Engineers (USACE) Regulatory Branch regulates activities
that result in the discharge of dredged or fill material into waters of the U.S., including wetlands,
pursuant to Section 404 of the CWA and Section 10 of the Rivers and Harbors Act. Of the state
agencies, the Regional Water Quality Control Board (RWQCB) regulates discharges to waters of
the State, including wetlands, pursuant to Section 401 of the CWA, Section 13263 of the California
Porter-Cologne Water Quality Control Act, and State Wetland Definition and Procedures for
Discharges of Dredged or Fill Material to Waters of the State; the CDFW regulates alterations to
lakes, streambeds, and associated riparian habitat pursuant to Section 1600 et seq. of the CFGC;
and the California Coastal Commission (CCC) regulates land use in the coastal zone pursuant to
the California Coastal Act (CCA).
Based on a review of aerial photographs, USGS 7.5-minute quadrangle maps, USFWS National
Wetland Inventory maps, and observations made during the field survey, there is one potential
jurisdictional aquatic resource in the project site. A vegetated basin, created during initial site
grading in 2007, was present at the northwest corner of the project site. A jurisdictional delineation
was not conducted as part of the 2025 biological investigations since there would be no effects
from the proposed project.
5.5 Wildlife Corridors and Habitat Linkages
Wildlife corridors link areas of suitable habitat that are otherwise separated by areas of
non-suitable habitat such as rugged terrain, changes in vegetation, or human disturbance. Wildlife
corridors are essential to the regional ecology of a species because they provide avenues of
genetic exchange and allow animals to access alternative territories as dictated by fluctuating
population densities. Fragmentation of open space areas by urbanization creates “islands” of
wildlife habitat that are more or less isolated from each other. Corridors mitigate the effects of this
fragmentation by (1) allowing animals to move between remaining habitats, thereby permitting
depleted populations to be replenished and promoting genetic exchange; (2) providing escape
routes from fire, predators, and human disturbances, thus reducing the risk of catastrophic events
(such as fire or disease) that could lead to local extinction; and (3) serving as travel routes for
individual animals as they move within their home ranges in search of food, water, mates, and
shelter.
Wildlife corridors are usually bounded by urban land areas or other areas unsuitable for wildlife.
The corridor generally contains suitable cover, food, and/or water to support species and facilitate
movement while in the corridor. Larger, landscape-level corridors (often referred to as “habitat or
landscape linkages”) can provide both transitory and resident habitat for a variety of species.
Although it is commonly used as a synonym for wildlife corridor, a habitat linkage refers to a more
substantial, or wider, land connection between two habitat areas. Habitat linkages allow for the
periodic exchange of animals between habitat areas, which is essential to maintain adequate
gene pools.
The project site is located within an SRA, which is documented in the City of Carlsbad HMP as
an area that is too small, edge-effected, or isolated to be considered biological Cores or linkage
June 3, 2026 Item #1 85 of 417
areas. No known wildlife corridors or linkage areas are mapped as occurring on or in the
immediate vicinity of the project site. The project site is surrounded by a road to the north,
commercial buildings to the east and south, and a golf course to the west. There are no landscape
features or vegetative cover that would support wildlife movement across the landscape. Thus,
the project site does not serve as a habitat linkage or wildlife corridor.
6.0 IMPACT ANALYSIS
The following discussion examines the impacts to biological resources that may occur as a result
of the proposed project. The determination of impacts is based on both the features of the
proposed project and the biological values of the habitat and sensitivity of plant and wildlife
species potentially affected. Based on the project description in Section 2.0 and architecture data
provided by the project applicant, Michael Baker conducted an impact analysis using GIS
technology.
Impacts to biological resources are assessed using impact significance threshold criteria, which
mirror the policy statement contained in the CEQA, Section 21001(c) of the California Public
Resources Code. The questions below model those included in the checklist of questions listed
in Appendix G of the CEQA guidelines and that are considered to determine if the project would
have significant impacts to biological resources.
6.1 Impacts to Special-Status Species
a) Would the project have a substantial adverse effect, either directly or through habitat
modifications, on any species identified as a candidate, sensitive, or special status species in
local or regional plans, policies, or regulations, or by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service?
Less Than Significant Impact with Mitigation Incorporated. In general, special-status that are
known to the region were not expected to be observed found during surveys on the project site
due to general lack of suitable habitat. None of the special-status animal species known to the
region have a high potential to occur within the project site due primarily to the isolation of the site
from undeveloped habitat blocks in the region and disturbances associated with the highly
urbanized setting. The site does not support the constituent elements required by many of the
special-status animals known to the region for nesting/breeding, foraging, dispersal, and other life
history requirements.
However, a coastal California gnatcatcher was observed within the northwest corner of the project
site during the 2025 survey of the project study area. It is noted that a coastal California
gnatcatcher observation was also made in 2000/2001 in association with the Fox Miller Project
focused surveys, but this species was not detected during the 2003 focused surveys. Even though
there is no suitable habitat for coastal California gnatcatcher within the project limits of
disturbance, implementation of Mitigation Measure BIO-1 (refer to Section 7.0, Mitigation
Measures, below), would ensure that no indirect effects to coastal California gnatcatcher would
occur.
June 3, 2026 Item #1 86 of 417
No other special-status wildlife species were observed during the 2025 survey and are not
expected to occur on the project site due to a lack of suitable habitat and a review of specific
habitat preferences, known distributions, and elevation ranges. The closest location of another
type of special-status species is documented in the California Natural Diversity Database
(CNDDB), with two occurrences of Crotch’s bumble bee in 2024 noted approximately 2.5 miles
north of the project site at Lake Calavera Preserve. However, no individuals or nests of Crotch’s
bumble bee were observed on or adjacent to the project site during the general biological survey
for the project on January 24, 2025. Because of (1) the presence of nectaring sources (i.e., food
sources) present on and near the project site, (2) the presence of other bumble bees on the
project site during the January 24, 2025 biological survey (a yellow-faced bumble bee), and (3)
two known CNDDB identifications of Crotch’s bumble bee within approximately 2.5 miles of the
project site, there is moderate potential for Crotch’s bumble bee to occur on the project site,
although likely only within the 0.33-acre patch of Diegan coastal sage scrub in the northwest
corner of the project site. This limited area of habitat supports nectaring sources that may be used
by foraging Crotch’s bumble bee and soils that could provide nesting and overwintering habitat.
Although no direct impacts to Crotch’s bumble bee individuals or nests are expected from the
project due to lack of suitable nectaring sources for foraging and lack of nesting habitat, there is
a potential for indirect effects if the species is present in the 0.33-acre patch of Diegan coastal
sage scrub in the northwest corner of the project site. Indirect impacts to Crotch’s bumble bee
could occur from fugitive dust during ground-disturbing construction activities. Such indirect
impacts to Crotch’s bumble bee would be potentially significant. However, implementation of
Mitigation Measure BIO-2 would reduce potential indirect impacts to Crotch’s bumble bee to less
than significant levels.
Several non-listed, sensitive bird species could potentially nest and/or forage over the site,
although the potential is low. These species are relatively common to the region. Construction
activities associated with the project could potentially result in significant impacts to nesting birds
if project activities cause a nest(s) to fail. However, with implementation of Mitigation Measure
BIO-1 (refer to Section 7.0, Mitigation Measures, below), project impacts to nesting birds would
be less than significant.
No special-status plant species were observed during the field survey; however, as discussed in
Section 4.3, Biological Resources, of the Housing Element Update SEIR, thread-leaved brodiaea
has a high potential to occur in the Diegan Coastal Sage Scrub in the northwest corner of the
project site, which would not be impacted by development of the proposed project. The project
site was also subject to focused surveys for the species in 2001 and 2003 associated with the
Fox Miller Project. During the 2003 focused surveys, a total of 19,100 thread-leaved brodiaea
plants were counted on the Fox Miller Property II; however, none of these plants were observed
on the project site. Additionally, the 2002 Fox Miller Project MND concluded that implementation
of the Fox Miller Project could potentially result in significant impacts to thread-leaved brodiaea.
The required mitigation for impacts to thread-leaved brodiaea due to development of the Fox
Miller Property II, which included the project site, was previously conducted under the Fox Miller
Project. The proposed project would not introduce new areas of disturbance or result in a
substantial increase in the severity of the previously identified significant effects to thread-leaved
brodiaea included in the 2002 MND. The anticipated environmental impacts to thread-leaved
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brodiaea were adequately analyzed in the prior environmental analysis, and that impact analysis
did not indicate impact on or from the project site, requiring no additional environmental review.
The project site was graded in 2007, resulting in primarily developed and disturbed vegetation.
Per correspondence with the project applicant, the project site is maintained (mowed) on an
annual basis. The isolated 0.33-acre patch of Diegan Coastal Sage Scrub in the northwest corner
of the project site is located outside the proposed development footprint. Therefore,
implementation of the proposed project would not impact special-status species habitat.
Additionally, the project includes an off-site limits of disturbance area associated with installation
of a sewer line within the existing developed roadway on College Boulevard (Study Area-Off-Site
Sewer Line). This area is fully paved and does not contain natural habitat or vegetation that could
support special-status species. Therefore, construction within this off-site improvement area
would have no impact on candidate, sensitive, or special-status species.
6.2 Impacts to Sensitive Natural Communities
b) Would the project have a substantial adverse effect on any riparian habitat or other sensitive
natural community identified in local or regional plans, policies, regulations or by the California
Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
No Impact. The project site supports the following vegetation communities/land cover types:
Diegan Coastal Sage Scrub, Disturbed Habitat, and Urban/Developed. Of these, Diegan Coastal
Sage Scrub is a sensitive vegetation community and is habitat for sensitive species. The Diegan
Coastal Sage Scrub is limited to an isolated 0.33-acre patch in the northwest corner of the project
site. However, the isolated 0.33-acre patch of Diegan coastal sage scrub is located outside the
proposed limits of disturbance. Further, there is no riparian habitat within the project site, off-site
improvement area, or adjacent areas. Therefore, the project would result in no impact on riparian
habitat and other sensitive natural communities.
6.3 Impacts to State or Federal Wetlands
c) Would the project have a substantial adverse effect on state or federally protected wetlands
(including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling,
hydrological interruption, or other means?
No Impact. There are no State or Federally protected wetlands on the project site or the off-site
improvement area. Therefore, implementation of the project would result in no impact to State or
Federally protected wetlands.
June 3, 2026 Item #1 88 of 417
6.4 Impacts to Wildlife Movement or Wildlife Corridors
d) Would the project interfere substantially with the movement of any native resident or migratory
fish or wildlife species or with established native resident or migratory wildlife corridors, or
impede the use of native wildlife nursery sites?
No Impact. The project site is surrounded by a road to the north, commercial buildings to the east
and south, and a golf course to the west. The project site is further characterized by open,
exposed areas that lack suitable cover and resources that are typically associated with wildlife
movement areas. There are no landscape features or vegetative cover that would support wildlife
movement or native wildlife nursery sites across the landscape in the project area. Common birds
and mammals might move through the site to forage and during dispersal activities; however, they
would not be expected to use the site as a wildlife corridor, linkage, or specific travel route to and
from nursery sites other important resources
Additionally, the off-site limits of disturbance area (Study Area-Off-Site Sewer Line) is a fully
developed road with no landscape features or vegetative cover that would support wildlife
movement or native wildlife nursery sites. Thus, the project site, off-site improvement area (Study
Area-Off-Site Sewer Line) and immediately adjacent areas do not support wildlife movement or
native wildlife nursery sites. Accordingly, the project would not interfere substantially with the
movement of any native resident or migratory fish or wildlife species or with established native
resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites, and no
impact would occur.
6.5 Conflicts with Local Policies or Ordinances
e) Would the project conflict with any local policies or ordinances protecting biological resources,
such as a tree preservation policy or ordinance?
Less Than Significant Impact. There are no regulated trees on the project site or the off-site
improvement area (Study Area-Off-Site Sewer Line) that would be subjected to the provisions of
City of Carlsbad Municipal Code Section 11.12.140, Heritage Trees, and Section 11.12.090,
Permits Required for Tree Removal and Maintenance. These ordinances regulate trees located
on public streets, trees with notable historic interest, and trees of unusual species or size. There
are two non-native, invasive fig trees within the proposed project footprint that would be removed;
however, neither fig tree is in the public right-of-way, of notable historic interest, or of an unusual
species or size, pursuant to Carlsbad Municipal Code Section 11.12.140. Therefore, these fig
trees are not considered protected trees. No trees would be impacted by the construction of the
off-site sewer line in College Boulevard. Thus, the project would not conflict with any local policies
or ordinances protecting biological resources, and impacts would be less than significant.
June 3, 2026 Item #1 89 of 417
6.6 Conflicts with Adopted Habitat Conservation Plan
f) Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural
Community Conservation Plan, or other approved local, regional, or state habitat conservation
plan?
Less Than Significant Impact. As mentioned in Section 3.2 above, the project site and the off-
site improvement area (Study Area – Off-Site Sewer Line) are within the boundaries of the City of
Carlsbad HMP and is located in SRA 1. However, the project site is not within a HMP Hardline
Conservation Area or HMP Proposed Hardline Conservation Area, which is identified for
conservation. The northernmost approximately 40 feet of the existing driveway that provides
access to the project site and would be improved as part of the proposed project and serve as
egress/ingress for the project. This area is within 100 feet of a HMP Proposed Hardline
Conservation Area (Attachment A, Figure 6, Plans and Policies). The Proposed Hardline
Conservation Areas are specific zones within the HMP that are designated for conservation. The
HMP Adjacency Standards are designed to prevent negative effects to urban wildlife preserve
system and include fire management; erosion control; landscaping restrictions; fencing, signs,
and lighting; and predator and exotic species control (pursuant to Section F.3 of the HMP). Even
though the proposed improvements associated with the proposed project are not within a
designated HMP Proposed Hardline Conservation Area, the project would be required to adhere
to the HMP Adjacency Standards, as part of the City’s conditions of approval for the project.
Proposed improvements associated with the northernmost appropriately 40 feet of the existing
driveway would be subject to applicable fuel modification zone requirements for fire management;
the City Fire Department has reviewed and preliminary approved the proposed fuel modification
zones for the project. Additionally, it is noted that the fuel modification area required for the project
would not encroach into a HMP Proposed Hardline Conservation Area. Construction of the project
would include implementation of standard construction best management practices (BMPs), as
well as implementation of a project-specific Storm Water Pollution Prevention Plan (SWPPP),
which would minimize erosion during construction.
The project landscape plan would ensure project site slopes are stabilized after construction is
completed. Additionally, the project landscape plan would be reviewed by the City Planning
Division prior to issuance of a grading permit to ensure that no non-native, invasive plant species
are proposed. Drought-tolerant plant species would also be used on-site to minimize irrigation
runoff potential. The project would limit the amount of fertilization of ornamental plants on the
project site that could drain towards the Proposed Hardline area to the north of Salk Avenue.
The project would not include fencing within the HMP Preserve, and as such, the project would
not impede wildlife movement within the Preserve. No signs prohibiting entrance into the preserve
would be required on the project site, as Salk Avenue is located in between the project site and
the closest HMP Proposed Hardline Conservation Area. However, to minimize any potential
indirect impact, future project residences would receive educational brochures regarding the
nearby HMP Preserve to deter human and pet access into the Preserve. Streetlighting currently
June 3, 2026 Item #1 90 of 417
exists along Salk Avenue. The project would include security lighting along the driveway; however,
proposed lighting would be low pressure sodium, directed downward, and shielded away from the
HMP Proposed Hardline Conservation Area.
Accordingly, the proposed project would not conflict with the provisions of the Carlsbad HMP or
Adjacency Standards, and impacts would be less than significant.
7.0 MITIGATION MEASURES
With implementation of Mitigation Measure BIO-1 and Mitigation Measure BIO-2, project
impacts to biological resources would be less than significant. No other mitigation is required.
Mitigation Measure BIO-1 (Pre-Construction Nesting Bird Surveys, Avoidance, and
Notification). If construction activities are initiated during the bird nesting season (February 1–
August 31) involving removal of vegetation or other nesting bird habitat, including abandoned
structures and other man-made features, a pre-construction nesting bird survey shall be
conducted no more than three days prior to initiation of ground disturbance and vegetation
removal activities. The nesting bird pre-construction survey shall be conducted on foot and shall
include a 300-foot survey buffer around the construction site. The survey shall be conducted by a
biologist familiar with the identification of avian species known to occur in southern California
coastal communities (i.e., qualified biologist). If active nests are found, an avoidance buffer shall
be determined by a qualified biologist in coordination with the City. The avoidance buffer width
will depend upon the species, the proposed work activity, and existing disturbances associated
with land uses outside of the site, which shall be demarcated by the biologist with bright orange
construction fencing, flagging, construction lathe, or other means to demarcate the boundary. All
construction personnel shall be notified as to the existence of the buffer zone and to avoid entering
the buffer zone during the nesting season. No ground-disturbing activities shall occur within the
buffer until the biologist has confirmed that breeding/nesting is completed, and the young have
fledged the nest. Encroachment into the buffer shall occur only at the discretion of the qualified
biologist on the basis that the encroachment will not be detrimental to an active nest. A report
summarizing the pre-construction survey(s) shall be prepared by a qualified biologist and shall be
submitted to the City prior to the commencement of construction activities.
If an active coastal California gnatcatcher nest is found during pre-construction surveys, a
minimum 500-foot no-disturbance buffer shall be established around the nest. The buffer shall be
clearly marked (e.g., with fencing or flagging) and maintained until a qualified biologist confirms
that the young have fledged, the nest is no longer active, or that construction noise levels can be
maintained below 60 dBA Leq at the nest site with a smaller buffer. In no circumstances shall a
buffer of less than 100 feet be used even with noise attenuation measures. Any reduction in the
500-foot buffer must be supported by site-specific analysis by the qualified biologist and approved
by the City in consultation with the US Fish and Wildlife Service.
June 3, 2026 Item #1 91 of 417
Note: To mitigate the potential impact to California gnatcatcher or other nesting birds, this
mitigation measure shall be applied to land use and activities occurring at the project site. No Pre-
Construction Nesting Bird Surveys, Avoidance, and Notification mitigation is required to
implement the Study Area-Off-Site Sewer Line portion of the project.
Mitigation Measure BIO-2 (Crotch’s Bumble Bee [CBB] Avoidance and Clearance Survey).
• Focused Survey. Three on-site surveys for Crotch’s bumble bee (CBB) shall be conducted
prior to initiation of ground disturbing project activities to identify if the CBB is present
within the project site. This survey shall be conducted simultaneously with the blooming
period of the species’ recognized food plants, when the CBB is most active. Each survey
shall be spaced at least 2 weeks but no more than 4 weeks apart, corresponding with the
Colony Active Season for Bombus species (April–August). The surveying biologist shall
be familiar with the primary identification characteristics of the CBB and be proficient in
the methodology produced by the Xerces Society. The qualified biologist shall utilize a
telephoto lens or a sufficiently long macro lens to obtain high-quality photos of bumble
bees, sufficient for species identification, without having to capture and potentially harm
the bumble bees.
• Absence of Species. If no CBB are detected during the focused surveys, no further
measures shall be necessary.
• Presence of Species. If CBB are detected, then site-specific measures shall be
implemented to avoid take unless an Incidental Take Permit (ITP) for the species is
obtained from CDFW. Such avoidance measures shall include:
o If vegetation removal activities and initial ground-disturbing activities (i.e., clearing,
grubbing, and initial site grading) occur during the Queen and Gyne Flight Period
and Colony Active Period for these species (February–October), a qualified
biologist shall conduct daily biological monitoring. During monitoring, the qualified
biologist shall inspect suitable habitat for CBB activity within the day’s work area.
If the species is not detected, then project activities can proceed without further
biological monitoring that day.
o If the CBB is detected using nectar sources, then a no-disturbance buffer of at least
25 feet around the individual(s) shall be established, and the individual(s) shall be
monitored by a biological monitor until the CBB are confirmed to have left the area
on their own.
o If a CBB nest is detected where ground disturbance is proposed to occur, then a
minimum 30-foot no-disturbance buffer (with a buffer of up to 60 feet if disturbance
is substantial) around the nest shall be established. This buffer shall remain in
place until the nest senesces, which would occur after no nest activity observations
for three sequential days. The qualified biologist shall discuss the buffer with the
June 3, 2026 Item #1 92 of 417
contractor to ensure that work areas, including ingress and egress routes, avoid
the CBB.
o If the project cannot avoid the established no-disturbance buffer(s) identified
above, the project applicant shall halt work within the buffer area and shall consult
with CDFW on appropriate avoidance actions and obtain an Incidental Take Permit
if necessary.
Note: To mitigate the potential impact to Crotch’s Bumble Bee (CBB), this mitigation measure
shall be applied to land use and activities occurring at the project site. No CBB Avoidance and
Clearance Survey mitigation is required to implement the Study Area-Off-Site Sewer Line
portion of the project.
8.0 CONCLUSIONS
With implementation of Mitigation Measure BIO-1 and Mitigation Measure BIO-2, the proposed
Salk Avenue Apartments Project’s impacts to biological resources would to less than significant.
Please do not hesitate to contact Marisa Flores at (858) 614-5052 or
marisa.flores@mbakerintl.com should you have any questions or require further information.
Sincerely,
Marisa Flores
Associate
Natural Resources Technical Manager
Attachments
A. Figures
B. Site Photographs
C. Species Compendium
D. Special-Status Species Potential to Occur Tables
Marisa Flores
June 3, 2026 Item #1 93 of 417
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NABA (North American Butterfly Association). 2025. Checklist of North American Butterflies,
Butterflies Occurring North of Mexico, Edition 2.3. https://naba.org/butterfly-names-
checklist/.
Oberbauer, Thomas, Meghan Kelly, and Jeremy Buegge. March 2008. Draft Vegetation
Communities of San Diego County. Based on “Preliminary Descriptions of the Terrestrial
Natural Communities of California,” Robert F. Holland, Ph.D., October 1986.
June 3, 2026 Item #1 94 of 417
RECON. 2001. Revised Biological Technical Report for the Fox Property, Carlsbad, California.
April.
RECON. 2004. Biological Resources Survey Update and Project Impact Revisions for Fox-Miller
Property, Carlsbad, California.
Reid, F.A. 2006. A Field Guide to Mammals of North America, Fourth Edition. Houghton Mifflin
Company, New York, New York.
Sibley, D.A. 2014. The Sibley Guide to Birds, Second Edition. Alfred A. Knopf, Inc., New York,
New York.
Stebbins, R.C. 2003. A Field Guide to Western Reptiles and Amphibians, Third Edition. Houghton
Mifflin Company, New York, New York.
USDA NRCS (U.S. Department of Agriculture, Natural Resources Conservation Service). 2025.
Web Soil Survey. https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx
[accessed April 5, 2024].
USFWS. 2025. Critical Habitat for Threatened & Endangered Species.
https://fws.maps.arcgis.com/home/webmap/viewer.html?webmap=9d8de5e265ad4fe098
93cf75b8dbfb77 [accessed January 22, 2025].
USFWS (U.S. Fish and Wildlife Service). 2025. Information for Planning and Consultation (IPaC).
https://ipac.ecosphere.fws.gov/location/index [accessed January 22, 2025].
USFWS. 2025. National Wetlands Inventory. Website
https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/ [accessed January 22,
2025].
Wilson, D.E., and D.M. Reeder, eds. 2005. Mammal Species of the World: A Taxonomic and
Geographic Reference. 3rd ed. Online version. Baltimore, Maryland: Johns Hopkins
University Press. Accessed August 17, 2010. http://www.bucknell.edu/msw3/.
June 3, 2026 Item #1 95 of 417
ATTACHMENT A
Figures
June 3, 2026 Item #1 96 of 417
t ~ I 12 I,. ____ _
Legend
I 1 1 J Project Site
Michael Baker
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT
0.5
Mi 0 0 Regional and Project Vicinity
INTERNATIONALt-------------------------------------------------------------Source: USGS 7.5-Minute topographic quadrangle maps: Rancho Santa Fe, California (2021), Encinitas, San Luis Rey, and San Marcos, California (2022) Figure 1 June 3, 2026 Item #1 97 of 417
Legend
EB Reference Point
I 1 1 J Project Site
c:::J On-Site Limits of Disturbance
c:::J Off-Site Limits of Disturbance
Michael Baker 125 250
F
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT 0 0 Project Site
INTERNATIONAL1-------------------------------------------
Source: Esri, ArcGIS Online, San Diego County, 2026 Nearmap Imagery Figure 2a June 3, 2026 Item #1 98 of 417
Legend
EB Reference Point
--Sewer Line
,-_-, College Blvd Sewer Replacement Limits of Disturbance
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT 0 0 College Blvd Sewer Replacement Location
INTERNATIONAL!----------------=----------....:...-----------
Michael Baker 100 200
F
Source: Esri, ArcGIS Online, San Diego County, 2026 Nearmap Imagery Figure 2b June 3, 2026 Item #1 99 of 417
Legend
EB Reference Point
I 1 1 J Project Site
c:::J Limits of Disturbance
Michael Baker
11181 Altamont clay, 5 to 9 percent slopes
~tE Altamont clay, 15 to 30 percent slopes, warm MAAT, MLRA 20
100 200
US Feet
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT
USDA Soils oo
INTERNATIONAL1--------------------------------------
Source: Esri, ArcGIS Online, San Diego County, 2026 Nearmap Imagery Figure 3a June 3, 2026 Item #1 100 of 417
Legend
EB Reference Point
-Sewer Line
r .J College Blvd Sewer Replacement Limits of Disturbance
Michael Baker 100 200
US Feet
Altamont clay, 9 to 15 percent slopes, warm MAAT, MLRA 20
Altamont clay, 15 to 30 percent slopes, warm MAAT, MLRA 20
ScB Salinas clay, 2 to 5 percent slopes
I TCiBI Tujunga sand, 0 to 5 percent slopes
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT
USDA Soils -Off-Site Sewer Line oo
INTERNATIONAL1----------------------------------------
Source: Esri, ArcGIS Online, San Diego County, 2026 Nearmap Imagery Figure 3b June 3, 2026 Item #1 101 of 417
Legend
EB Reference Point
I 1 1 J Project Site
,-_-, Study Area (100-ft Buffer)
Michael Baker 125 250
F
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT 0 0 Study Area
INTERNATIONAL 1---------------------------------------------
Source: Esri, ArcGIS Online, San Diego County, 2026 Nearmap Imagery Figure 4a June 3, 2026 Item #1 102 of 417
Legend
EB Reference Point
--Sewer Line
Michael Baker
,-_., College Blvd Sewer Replacement Limits of Disturbance
[1 11 Study Area (25-ft Buffer from Limits of Disturbance)
100 200
F
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT 0 0 Study Area -Off-Site Sewer Line
INTERNATIONAL t---------------------------------------
Source: Esri, ArcGIS Online, San Diego County, 2026 Nearmap Imagery figure 4b June 3, 2026 Item #1 103 of 417
Legend
EB Reference Point
e Coastal California Gnatcatcher
I= I Project Site
f" .J Study Area (100-ft Buffer)
Michael Baker
Vegetation Communities/Land Uses (Project Site) Vegetation Communities/Land Uses (100-ft Study Area)
-32530 Diegan Coastal Sage Scrub (0.33 Acres)
11300 Disturbed Habitat (6.76Acres)
-12000 Urban/Developed (2.69Acres)
32500 Coastal Sage Scrub (0.29 Acres)
-32530 Diegan Coastal Sage Scrub (0.62Acres)
11300 Disturbed Habitat (2.62Acres)
79100 Eucalyptus Woodland (0.19 Acres)
-12000 Urban/Developed (3.56Acres)
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT
100 200
us 0 0 Vegetation Communities/Land Uses
INTERNATI0NAL1-------------------=-------------------------
Source: Esri, ArcGIS Online, San Diego County, 2026 Nearmap Imagery Figure Sa June 3, 2026 Item #1 104 of 417
Legend
EB Reference Point
--Sewer Line
,-_-, Study Area (25-ft Buffer from Limits of Disturbance)
100
Vegetation Communities/Land Uses
11300 Disturbed Habitat (0.07 Acres)
1111 12000 Urban/Developed (1.93 Acres)
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT
Michael Baker 200
F 0 0
Vegetation Communities/Land Uses -Off-Site Sewer Line INTERNATIONAL t-----------------------------------------
Source: Esri, ArcGIS Online, San Diego County, 2026 Nearmap Imagery Figure Sb June 3, 2026 Item #1 105 of 417
Residential Community
(Under Construction)
~Ne---
Legend
--Sewer Line ~ Coastal Zone City of Carlsbad Habitat Management Plan
11 11 Project Site □ Special Resource Area 1 (SRA 1) -Existing Hardline
c:J On-Site Limits of Disturbance Standards Area
c:J Off-Site Limits of Disturbance Proposed Hardline
Michael Baker 300 600
Feet
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT
Plans and Policies oo
INTERNATIONAL1-----------------------------------------
Source: Esri, ArcGIS Online, USFVVS (02/2025), City of Carlsbad (04/2024), City of Carlsbad (08/2024), San Diego County, 2026 Nearmap Imagery Figure 6 June 3, 2026 Item #1 106 of 417
Legend
EB Reference Point
e Coastal California Gnatcatcher
-sewerline
8 Project Site
c:J Limits of Disturbance
Michael Baker
Crlttcal Habitat
EZJ Thread-leaved Brodiaea
(Brodiaea fififofia)
100 200
F
Vegetation Communities/Land Uses (Project Site)
-32530 Diegan Coastal Sage Scrub (0.33Acres)
11300 Disturbed Habitat (6. 76 Acres)
-12000 Urban/Developed (2.69 Acres)
Vegetation Communities/Land Uses (Off-Site Limits of Disturbance)
-12000 Urban/Developed (0.19Acres)
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT 0 0 Biological Resource Impacts
INTERNATIONAL t----------------------------------------------------------
Source: Esri, ArcGIS Online, USFVVS (02/2025), San Diego County, 2026 Neam,ap Imagery Figure 7a June 3, 2026 Item #1 107 of 417
Legend
EB Reference Point
-Sewerline
f" .J College Blvd Sewer Replacement Limits of Disturbance
Michael Baker 100 200
F
Critical Habitat
EZJ Thread-leaved Brodiaea
(Brodiaea filifolia)
Vegetation Communities/Land Uses (20-ft Buffer)
-12000 Urban/Developed (0.85Acres)
SALK AVENUE APARTMENTS PROJECT
BIOLOGICAL RESOURCES TECHNICAL LETTER REPORT 0 0
Biological Resource Impacts -Off-Site Sewer Line INTERNATIONAL1------------------------------------------------
Source: Esri, ArcGIS Online, USFVVS (02/2025), San Diego County, 2026 Neam,ap Imagery Figure 7b June 3, 2026 Item #1 108 of 417
ATTACHMENT B
Site Photographs
June 3, 2026 Item #1 109 of 417
Attachment B -Site Photographs ......................................................................................................................................................................................................................................................
Photograph 1: View looking southwest from the northeast corner of graded pad.
Photograph 2. Looking west across north end of project site with Salk Avenue in view (right side).
Biological Resources Technical Letter Report
Salk Avenue Residential Project B-1 June 3, 2026 Item #1 110 of 417
Attachment B -Site Photographs ......................................................................................................................................................................................................................................................
Photograph 3: View west of catch basin at northwest corner of graded pad.
Photograph 4: View northwest at corner of Project site. Salk Avenue in background.
Biological Resources Technical Letter Report
Salk Avenue Residential Project B-2 June 3, 2026 Item #1 111 of 417
Attachment B -Site Photographs ......................................................................................................................................................................................................................................................
Photograph 5: View southwest of the driveway within the project site.
Photograph 6: View northwest of study area.
Biological Resources Technical Letter Report
Salk Avenue Residential Project B-3 June 3, 2026 Item #1 112 of 417
Attachment B -Site Photographs ......................................................................................................................................................................................................................................................
Photograph 7: View east of the southern portion of the project site.
Biological Resources Technical Letter Report
Salk Avenue Residential Project B-4 June 3, 2026 Item #1 113 of 417
ATTACHMENT C
Species Compendiums
June 3, 2026 Item #1 114 of 417
Michael Baker
INTERNATIONAL
VASCULAR SPECIES
EUD/COTS
PLANT COMPENDIUM
APIACEAE-Carrot Family
Foeniculum vu/gore-fennel*
ASTERACEAE-Sunflower Family
Baccharis pilularis-coyote brush
Baccharis salicifo/ia-mulefat
Cynara cardunculus-cardoon*
Encelia californica-California brittle bush
Helminthotheca echioides-bristly oxtongue*
Cirsium sp. -thistle sp.
BATACEAE-Saltwort Family
Batis maritima-turtleweed
BRASSICACEAE-Mustard Family
Brassica nigra-black mustard*
Hirschfeldia incana-shortpod mustard*
Rosmarinus officina/is-rosemary*
CHENOPODIACEAE-Goosefoot Family
Sa/sofa austra/is-Russian thistle*
FABACEAE-Legume Family
Acacia redo/ens-bank catclaw*
LAMIACEAE-Mint Family
Salvia me//ifera-black sage
MORACEAE-Mulberry Family
Ficus macrophyl/a-moreton bay fig *
SALICACEAE-Willow Family
Salix /asio/epis-arroyo willow
MONOCOTS
AGAVACEAE-Agave Family
Agave americana-American century plant*
ARECACEAE-Palm Family
Phoenix dactylifera-date palm*
Washingtonia robusta-Washington fan palm*
POACEAE-Grass Family
Cortaderia se//oana-Uruguayan pampas grass*
Cynodon dactylon-Bermudagrass*
STRELITZIACEAE-No Common Name
Strelitzia nicolai-giant bird of paradise *
* signifies introduced (non-native) species
Biological Resources Technical Letter Report
Salk Avenue Residential Project
Attachment C -Species Compendiums
C-1 June 3, 2026 Item #1 115 of 417
Michael Baker Attachment C -Species Compendiums
INTERNATIONAL
BIRDS
WILDLIFE COMPENDIUM
ACCIPITRIDAE-HAWKS, KITES, EAGLES, & ALLIES
Buteo jamaicensis-red-tailed hawk
PASSERELLIDAE-NEW WORLD SPARROWS
Melospiza melodia-song sparrow
Me/ozone crissalis-California towhee
Pipi/o maculatus-spotted towhee
CORVIDAE-CROWS & JAYS
Aphelocoma californica-California scrub-jay
Corvus brachyrhynchos-American crow
TROCHILIDAE-HUMMINGBIRDS
Calypte costae-Costa's hummingbird
Selasphorus sasin-Allen's hummingbird
TROGLODYTIDAE-WRENS
Salpinctes obsoletus-rock wren
PARULIDAE-WOOD-WARBLERS
Geothlypis trichas-common yellowthroat
Setophaga coronata-yellow-rumped warbler
FRINGILLIDAE-FRINGILLINE & CARDUELINE FINCHES & ALLIES
Haemorhous mexicanus-house finch
Spinus psaltria-lesser goldfinch
PICIDAE-WOODPECKERS & ALLIES
Dryobates nuttal/ii-Nuttall's woodpecker
COLUMBIDAE-PIGEONS & DOVES
Zenaida macroura-mourning dove
TYRANNIDAE-TYRANT FLYCATCHERS
Sayornis nigricans-black phoebe
ESTRILDIDAE-WAXBILLS
lonchura punctulata-scaly-breasted munia*
MIMIDAE-MOCKINGBIRDS & THRASHERS
Mimus polyglottos-northern mockingbird
POLIOPTILIDAE-GNATCATCHERS
Po/ioptila californica californica-coastal California gnatcatcher
INVERTEBRATES
Apidae-BUMBLEBEES
Bombus vosnesenskii-yellow-faced bumble bee
Apidae-HONEY BEES & BUMBLEBEES
Apis mellifera-western honey bee*
MAMMALS
LEPORIDAE-HARES & RABBITS
Sylvilagus audubonii-desert cottontail
GEOMYIDAE-POCKET GOPHERS
Thomomys bottae-Botta's pocket gopher
* signifies introduced (non-native) species
Biological Resources Technical Letter Report
Salk Avenue Residential Project C-2 June 3, 2026 Item #1 116 of 417
ATTACHMENT D
Special-Status Species Potential to Occur Tables
June 3, 2026 Item #1 117 of 417
IMM@l:fflffl
I NTERNA TION AL
Scientific Name I Common Name I Status (Federal/State/Other)
Abronio villoso var. None/None/1B.1/BLM-S, USFS-
aurita chaparral sand-verbena S
Acanthomintha
ilicifolia San Diego thorn-mint
Acmispon prostratus Nuttall's acmispon
Ado/phia co/ifornica California adolphia
Agave shawii var.
shawii Shaw's agave
Allium morvinii Yucaipa onion
Ambrosia pumila San Diego ambrosia
Aphanisma blitoides aphanisma
Aphyllon parishii ssp.
brachylabum short-lobed broomrape
Arctostaphylas
glandulasa ssp.
crassifolia Del Mar manzanita
Arctostaphylas
rainbowensis Rainbow manzanita
Artemisia palmeri San Diego sagewort
Astraga/us tener var. coastal dunes milk-
titi vetch
A triplex coulteri Coulter's saltbush
A triplex pacifica south coast saltscale
BlologJcal Resources Technical Letter Report
Salk Avenue Apartments Project
FT/SE/1B.1/None
None/None/1B.1/None
None/None/2B.1/None
None/None/2B.1/None
None/None/1B.2/BLM-S, USFS-
s
FE/None/1B.1/None
None/None/1B.2/None
None/None/4.2/None
FE/None/1B.1/None
None/None/1B.1/BLM-S, USFS-
s
None/None/4.2/None
FE/SE/1B.1/None
None/None/1B.2/None
None/None/1B.2/None
I
Attachment D -Special-Status Species Potential to Occur Tables
PLANTS
HCP/NCCP Protection I Habitats/ Life Form/ Blooming Period/ Elevation Range (feet) I Potential to Occur in BSA
Not expected to occur. The study area is outside of
Chaparral, Coastal scrub, Desert dunes; Sandy/annual the species' known elevation range and there is no
None herb/(Jan)Mar-Sep/24S-S2S0 suitable habitat present.
Chaparral, Coastal scrub, Valley and foothill grassland,
List 2; Narrow Vernal pools; Clay, Openings/annual
Endemic herb/ Apr-June/35-3150 Not expected to occur.
Not expected to occur. The study area is outside of
Coastal dunes, Coastal scrub (sandy)/annual the species' known elevation range and there is no
None herb/Mar-June(July)/0-35 suitable habitat present.
Chaparral, Coastal scrub, Valley and foothill grassland;
None Clay/perennial deciduous shrub/Dec-May/35-2430 Not expected to occur.
Coastal bluff scrub, Coastal scrub/perennial
None leaf/Sep-May/10-395 Not expected to occur. No suitable habitat is present.
Not expected to occur. The study area is outside of
Chaparral (clay, openings)/perennial bulbiferous the species' known elevation range and there is no
None herb/ Apr-May/2495-3495 suitable habitat present.
Chaparral, Coastal scrub, Valley and foothill grassland,
Vernal pools; Alkaline (sometimes), Clay (sometimes),
Disturbed areas (often), Loam (sometimes), Sandy
List 2; Narrow (sometimes)/perennial rhizomatous
Endemic herb/ Apr-Oct/65-1360 Not expected to occur.
Coastal bluff scrub, Coastal dunes, Coastal scrub; Gravelly
(sometimes), Sandy (sometimes)/annual
None herb/Feb-June/5-1000 Not expected to occur. No suitable habitat is present.
Coastal bluff scrub, Coastal dunes, Coastal scrub;
Sandy/annual/perennial herb
None (parasitic)/ Apr-Oct/10-1000 Not expected to occur. No suitable habitat is present.
List 3; Narrow Chaparral (maritime, sandy)/perennial evergreen
Endemic shrub/June-Apr/0-1200 Not expected to occur. No suitable habitat is present.
Not expected to occur. The study area is outside of
Chaparral/perennial evergreen the species' known elevation range and there is no
None shrub/Dec-Mar/675-2200 suitable habitat present.
Chaparral, Coastal scrub, Riparian forest, Riparian scrub,
Riparian woodland; Mesic, Sandy/perennial deciduous
None shrub/(Feb)May-Sep/15-3000 Not expected to occur. No suitable habitat is present.
Coastal bluff scrub (sandy), Coastal dunes, Coastal prairie Not expected to occur. The study area is outside of
(mesic); Mesic (often), Vernally Mesic (often)/annual the species' known elevation range and there is no
None herb/Mar-May/5-165 suitable habitat present.
Coastal bluff scrub, Coastal dunes, Coastal scrub, Valley
and foothill grassland; Alkaline (sometimes), Clay
None (sometimes)/perennial herb/Mar-Oct/10-1510 Not expected to occur.
Coastal bluff scrub, Coastal dunes, Coastal scrub,
None Playas/annual herb/Mar-Oct/D-460 Not expected to occur. No suitable habitat is present.
D-1
June 3, 2026 Item #1 118 of 417
IMM@l:fflffl
I NTERNA TION AL
Scientific Name I Common Name
Baccharis vanessae Encinitas baccharis
Blaomeria clevelandii San Diego goldenstar
Brodiaea filifolia thread-leaved brodiaea
Brodiaea orcuttii Orcutt's brodiaea
Ceanothus cyaneus Lakeside ceanothus
wart-stemmed
Ceanothus verrucasus ceanothus
Centromadia parryi
ssp. australis southern tarplant
Centromadia pungens
ssp. /aevis smooth tarplant
Chaenactis
g/abriuscu/a var.
orcuttiana Orcutt's pincushion
Chorizanthe
orcuttiana Orcutt's spineflower
Chorizanthe
po/ygonoides var. long-spined
longispina spineflower
Comarostaphy/is
diversifo/ia ssp.
diversifolia summer holly
Corethrogyne
filaginifolia var. Del Mar Mesa sand
linifolia aster
Cryptantha wigginsii Wiggins' cryptantha
Dud/eya b/ochmaniae
ssp. b/ochmaniae Blochman's dudleya
BlologJcal Resources Technical Letter Report
Salk Avenue Apartments Project
I Status (Federal/State/Other) I
FT /SE/1B.1/None
None/None/1B.1/BLM-S
FT/SE/1B.1/None
None/None/1B.1/BLM-S, USFS-
s
None/None/1B.2/BLM-S, USFS-
s
None/None/2B.2/None
None/None/1B.1/None
None/None/1B.1/None
None/None/1B.1/None
FE/SE/1B.1/None
None/None/1B.2/BLM-S
None/None/1B.2/BLM-S
None/None/1B.1/None
None/None/1B.2/None
None/None/1B.l/None
Attachment D -Special-Status Species Potential to Occur Tables
HCP/NCCP Protection I Habitats/ Life Form/ Blooming Period/ Elevation Range (feet) I Potential to Occur in BSA
Chaparral (maritime), Cismontane woodland;
List 3; Narrow Sandstone/perennial deciduous
Endemic shrub/ Aug-Nov/19S-2360 Not expected to occur. No suitable habitat is present.
Chaparral, Coastal scrub, Valley and foothill grassland,
Vernal pools; Clay/perennial bulbiferous
Narrow Endemic herb/Apr-May/165-1525 Not expected to occur.
Chaparral (openings), Cismontane woodland, Coastal Moderate. Previous surveys have documented
scrub, Playas, Valley and foothill grassland, Vernal pools; species within study area, however development of
List 3; Narrow Clay (often)/perennial bulbiferous Fox-Miller Property II and routine site disturbances
Endemic herb/Mar-June/80-3675 reduce potential.
Chaparral, Cismontane woodland, Closed-cone
coniferous forest, Meadows and seeps, Valley and foothill
grassland, Vernal pools; Clay, Mesic/perennial bulbiferous
Narrow Endemic herb/May-July/100-5550 Not expected to occur.
Not expected to occur. The study area is outside of
Chaparral, Closed-cone coniferous forest/perennial the species' known elevation range and there is no
None evergreen shrub/ Apr-June/770-2475 suitable habitat present.
Chaparral, Coastal scrub/perennial evergreen
List 2 shrub/Dec-May/5-1245 Not expected to occur. No suitable habitat is present.
Marshes and swamps (margins), Valley and foothill
grassland (vernally mesic), Vernal pools/annual
None herb/May-Nov/0-1575 Not expected to occur.
Chenopod scrub, Meadows and seeps, Playas, Riparian
woodland, Valley and foothill grassland; Alkaline/annual
None herb/ Apr-Sep/0-2100 Not expected to occur.
Coastal bluff scrub (sandy), Coastal dunes/annual
None herb/Jan-Aug/0-330 Not expected to occur. No suitable habitat is present.
Chaparral (maritime), Closed-cone coniferous forest,
List 1; Narrow Coastal scrub; Openings, Sandy/annual
Endemic herb/Mar-May/lo-410 Not expected to occur. No suitable habitat is present.
Chaparral, Coastal scrub, Meadows and seeps, Valley and
foothill grassland, Vernal pools; Clay (often)/annual
None herb/Apr-July/100-5020 Not expected to occur.
Chaparral, Cismontane woodland/perennial evergreen
List 3 shrub/ Apr-J une/100-2590 Not expected to occur. No suitable habitat is present.
List 3; Narrow Chaparral (maritime, openings), Coastal bluff scrub,
Endemic Coastal scrub; Sandy/perennial herb/May-Sep/15-490 Not expected to occur. No suitable habitat is present.
Coastal scrub; Clay (often)/annual
None herb/Feb-June/65-900 Not expected to occur. No suitable habitat is present.
Chaparral, Coastal bluff scrub, Coastal scrub, Valley and
foothill grassland; Clay (often), Rocky,
Narrow Endemic Serpentine/perennial herb/ Apr-J une/15-1475 Not expected to occur.
D-2 June 3, 2026 Item #1 119 of 417
IMM@l:fflffl
I NTERNA TION AL
Scientific Name I Common Name
many-stemmed
Dudleya multicaulis dudleya
Dudleya variegata variegated dudleya
Dudleya viscida sticky dudleya
Ericameria palmeri
var. palmeri Palmer's goldenbush
Eryngium aristulatum San Diego button-
var. parishii celery
Eryngium Pendleton button-
pendletanense celery
Erysimum
ammo phi/um sand-loving wallflower
Euphorbia misera cliff spurge
Ferocactus viridescens San Diego barrel cactus
Harpagonel/a palmeri Palmer's grapplinghook
Hazardia orcuttii Orcutt's hazardia
Heterotheca
sessiliflora ssp.
sessiliflora beach goldenaster
Horkelia truncata Ramona horkelia
BlologJcal Resources Technical Letter Report
Salk Avenue Apartments Project
I Status (Federal/State/Other)
None/None/1B.2/USFS-S
None/None/1B.2/BLM-S
None/None/1B.2/BLM-S, USFS-
s
None/None/1B.1/None
FE/SE/1B.1/None
None/None/1B.1/None
None/None/1B.2/None
None/None/2B.2/None
None/None/2B.1/None
None/None/4.2/None
None/ST /1B.1/None
None/None/1B.1/None
None/None/1B.3/BLM-S, USFS-
s
Attachment D -Special-Status Species Potential to Occur Tables
I HCP/NCCP Protection I Habitats/ Life Form/ Blooming Period/ Elevation Range (feet) I Potential to Occur in BSA
Chaparral, Coastal scrub, Valley and foothill grassland;
None Clay (often)/perennial herb/Apr-July/50-2590 Not expected to occur.
Chaparral, Cismontane woodland, Coastal scrub, Valley
and foothill grassland, Vernal pools; Clay/perennial
None herb/ Apr-June/10-1905 Not expected to occur.
Chaparral, Cismontane woodland, Coastal bluff scrub,
List 2 Coastal scrub; Rocky/perennial herb/May-June/35-1805 Not expected to occur. No suitable habitat is present.
Chaparral, Coastal scrub; Mesic/perennial evergreen
None shrub/(July)Sep-Nov/100-1970 Not expected to occur. No suitable habitat is present.
List 3; Narrow Coastal scrub, Valley and foothill grassland, Vernal pools;
Endemic Mesic/annual/perennial herb/ Apr-J une/65-2035 Not expected to occur.
Coastal bluff scrub, Valley and foothill grassland, Vernal
pools; Clay, Vernally Mesic/perennial
None herb/ Apr-June(J uly)/50-360 Not expected to occur.
Chaparral (maritime), Coastal dunes, Coastal scrub; Not expected to occur. The study area is outside of
Openings, Sandy/perennial the species' known elevation range and there is no
None herb/Feb-June(July-Aug)/0-195 suitable habitat present.
Coastal bluff scrub, Coastal scrub, Mojavean desert
List 1 scrub; Rocky/perennial shrub/(Oct)Dec-Aug/35-1640 Not expected to occur. No suitable habitat is present.
Chaparral, Coastal scrub, Valley and foothill grassland,
List 2 Vernal pools/perennial stem/May-June/10-1475 Not expected to occur.
Chaparral, Coastal scrub, Valley and foothill grassland;
None Clay, Openings/annual herb/Mar-May/65-3135 Not expected to occur.
Not expected to occur. The study area is outside of
List 1; Narrow Chaparral (maritime), Coastal scrub; Clay the species' known elevation range and there is no
Endemic (often)/perennial evergreen shrub/Aug-Oct/260-280 suitable habitat present.
Chaparral (coastal), Coastal dunes, Coastal
None scrub/perennial herb/Mar-Dec/G-4020 Not expected to occur. No suitable habitat is present.
Not expected to occur. The study area is outside of
Chaparral, Cismontane woodland; Clay, the species' known elevation range and there is no
None Gabbroic/perennial herb/May-June/131G-4265 suitable habitat present.
D-3
June 3, 2026 Item #1 120 of 417
IMM@l:fflffl
I NTERNA TION AL
Scientific Name I Common Name
/socomo menziesii var.
decumbens decumbent golden bush
Iva hayesiana San Diego marsh-elder
Lasthenia g/abrata
ssp. cou/teri Coulter's goldfields
Lepidium virginicum Robinson's pepper-
var. robinsanii grass
Leptosyne maritima sea dahlia
Monardel/a hypo/euca
ssp. lanata felt-leaved monardella
Myosurus minimus
ssp. opus little mousetail
Noma stenocarpa mud nama
Navarretia fossalis spreading navarretia
Nemacau/is denudata
var. denudata coast woolly-heads
Nemacau/is denudata
var. gracilis slender cottonheads
Nalina cismantana chaparral nolina
Orcuttia californica California Orcutt grass
Phace/ia stellaris Brand's star phacelia
Pogogyne abramsii San Diego mesa mint
Pseudognaphalium
leucocephalum white rabbit-tobacco
BlologJcal Resources Technical Letter Report
Salk Avenue Apartments Project
I Status (Federal/State/Other)
None/None/1B.2/BLM-S
None/None/2B.2/None
None/None/1B.1/BLM-S
None/None/4.3/None
None/None/2B.2/None
None/None/1B.2/BLM-S, USFS-
s
None/None/3.1/None
None/None/2B.2/None
FT /None/1B.1/None
None/None/1B.2/None
None/None/2B.2/None
None/None/1B.2/USFS-S
FE/SE/1B.1/None
None/None/1B.1/None
FE/SE/1B.1/None
None/None/2B.2/None
Attachment D -Special-Status Species Potential to Occur Tables
I HCP/NCCP Protection I Habitats/ Life Form/ Blooming Period/ Elevation Range (feet) I Potential to Occur in BSA
Chaparral, Coastal scrub (often disturbed areas,
None sandy)/perennial sh rub/ Apr-Nov/35-820 Not expected to occur. No suitable habitat is present.
Marshes and swamps, Playas/perennial
List 3 herb/ Apr-Oct/0-1640 Not expected to occur. No suitable habitat is present.
Marshes and swamps (coastal salt), Playas, Vernal
None pools/annual herb/Feb-June/5-4005 Not expected to occur. No suitable habitat is present.
None Chaparral, Coastal scrub/annual herb/Jan-July/5-2905 Not expected to occur. No suitable habitat is present.
Coastal bluff scrub, Coastal scrub/perennial
None herb/Mar-May/15-490 Not expected to occur. No suitable habitat is present.
Not expected to occur. The study area is outside of
Chaparral, Cismontane woodland/perennial rhizomatous the species' known elevation range and there is no
None herb/J une-Aug/985-5170 suitable habitat present.
List 3; Narrow Valley and foothill grassland, Vernal pools
Endemic (alkaline)/annual herb/Mar-June/65-2100 Not expected to occur.
Marshes and swamps (lake margins,
None riverbanks)/annual/perennial herb/Jan-July/15-1640 Not expected to occur. No suitable habitat is present.
Chenopod scrub, Marshes and swamps (shallow
List 3; Narrow freshwater), Playas, Vernal pools/annual
Endemic herb/ Apr-June/100-2150 Not expected to occur. No suitable habitat is present.
None Coastal dunes/annual herb/ Apr-Sep/0-330 Not expected to occur. No suitable habitat is present.
Coastal dunes, Desert dunes, Sonoran desert
None scrub/annual herb/(Mar)Apr-May/-165-1310 Not expected to occur. No suitable habitat is present.
Chaparral, Coastal scrub; Gabbroic (sometimes), Not expected to occur. The study area is outside of
Sandstone (sometimes)/perennial evergreen the species' known elevation range and there is no
None shrub/(Mar)May-July/460-4185 suitable habitat present.
List 3; Narrow
Endemic Vernal pools/annual herb/ Apr-Aug/50-2165 Not expected to occur. No suitable habitat is present.
Coastal dunes, Coastal scrub/annual
None herb/Mar-June/5-1310 Not expected to occur. No suitable habitat is present.
Not expected to occur. The study area is outside of
the species' known elevation range and there is no
None Vernal pools/annual herb/Mar-July/295-655 suitable habitat present.
Chaparral, Cismontane woodland, Coastal scrub, Riparian
woodland; Gravelly, Sandy/perennial
None herb/(July)Aug-Nov(Dec)/0-6890 Not expected to occur. No suitable habitat is present.
,,.. June 3, 2026 Item #1 121 of 417
IMM@l:fflffl
I NTERNA TION AL
Scientific Name I Common Name
Quercus dumosa Nuttall's scrub oak
Salvia munzii Munz's sage
Senecio aphanactis chaparral ragwort
salt spring
Sidalcea neomexicana checkerbloom
Sphaerocarpos
drewiae bottle liverwort
Sphenopholis
interrupta ssp.
californica prairie false oat
Stemodia durantifolia purple stemodia
Suaeda esteroa estuary seablite
BlologJcal Resources Technical Letter Report
Salk Avenue Apartments Project
I Status (Federal/State/Other) I
None/None/1B.1/BLM-S, USFS-
s
None/None/2B.2/None
None/None/2B.2/None
None/None/2B.2/USFS-S
None/None/1B.1/None
None/None/1B.1/None
None/None/2B.1/None
None/None/1B.2/None
Attachment D -Special-Status Species Potential to Occur Tables
HCP/NCCP Protection I Habitats/ Life Form/ Blooming Period/ Elevation Range (feet) I Potential to Occur in BSA
Chaparral, Closed-cone coniferous forest, Coastal scrub;
Clay, Loam, Sandy/perennial evergreen
List 1 shrub/Feb-Apr(May-Aug)/S0-1310 Not expected to occur. No suitable habitat is present.
Not expected to occur. The study area is outside of
Chaparral, Coastal scrub/perennial evergreen the species' known elevation range and there is no
None shrub/Feb-Apr/37S-349S suitable habitat present.
Chaparral, Cismontane woodland, Coastal scrub; Alkaline
None (sometimes)/annual herb/Jan-Apr(May)/50-262S Not expected to occur. No suitable habitat is present.
Chaparral, Coastal scrub, Lower montane coniferous
forest, Mojavean desert scrub, Playas; Alkaline,
None Mesic/perennial herb/Mar-June/SO-S020 Not expected to occur. No suitable habitat is present.
Not expected to occur. The study area is outside of
Chaparral, Coastal scrub; Openings/ephemeral the species' known elevation range and there is no
None liverwort//29S-1970 suitable habitat present.
Not expected to occur. The study area is outside of
the species' known elevation range and there is no
None Chaparral (coastal); Clay/annual herb/Apr/SO-SO suitable habitat present.
Not expected to occur. The study area is outside of
Sonoran desert scrub (often mesic, sandy)/perennial the species' known elevation range and there is no
None herb/(Jan)Apr-Dec/S90-98S suitable habitat present.
Not expected to occur. The study area is outside of
Marshes and swamps (coastal salt)/perennial the species' known elevation range and there is no
None herb/(Jan-May)July-Oct/0-15 suitable habitat present.
D-5
June 3, 2026 Item #1 122 of 417
IMM@l:fflffl Attachment D -Special-Status Species Potential to Occur Tables
I NTERNATIONAL
Scientific Name !Common Name I Status (Federal/State/Other) I HCP/NCCP Protection I Habitats/ Life Form/ Blooming Period/ Elevation Range (feet) I Potential to Occur in BSA
Chaparral, Coastal scrub/perennial deciduous
Tetracoccus dioicus Parry's tetracoccus
None/None/1B.2/BLM-S, USFS
S None shrub/Apr-May/540-3280
Status Legend:
Federal
FE: Federally listed as endangered
FT: Federally listed as threatened
FPE: Federally proposed for listing as endangered
FPT: Federally proposed for listing as threatened
FC: Federal candidate species (former Category 1 candidates)
None: No federal listing
FOL: Delisted
State
SE: State listed as endangered
ST: State listed as threatened
SR: State rare
SCE: State candidate for listing as endangered
SCT: State candidate for listing as threatened
None: No state listing
SOL: State delisting
C.llfornla Rare Plant Rank (CRPR)
CRPR lA: Plants presumed extirpated in California and either rare or extinct elsewhere
CRPR 1B: Plants rare, threatened, or endangered in California and elsewhere
CRPR 2A: Plants presumed extirpated in California but common elsewhere
CRPR 2B: Plants rare, threatened, or endangered in California but more common elsewhere
CRPR 3: Review List: Plants about which more information is needed
CRPR 4: Watch List: Plants of lim~ed distribution
.1 Seriously threatened in California (over 80% of occurrences threatened/ high degree and immediacy of threat)
.2 Moderately threatened in California (20-80% occurrences threatened/ moderate degree and immediacy of threat)
Special-Status Plant Species Designations
.3 Not very threatened in California (<20% of occurrences threatened/ low degree and immediacy of threat or no current threats known)
BlologJcal Resources Technical Letter Report
Salk Avenue Apartments Project
Not expected to occur. The study area is outside of
the species' known elevation range and there is no
suitable habitat present.
D-6
June 3, 2026 Item #1 123 of 417
l1t@tttffll:fflffl
INTER N ATI O NAL
Scientific Name Common Name
Amphibians
Anaxyrus californicus arroyo toad
Spea hammondii western spadefoot
Birds
Accipiter cooperii Cooper's hawk
Agelaius tricolor tricolored blackbird
southern california rufous-
Aimophila ruficeps canescens crowned sparrow
Aquila chrysaetos golden eagle
Buteo swainsoni Swainson's hawk
Campylorhynchus
brunneicapillus sandiegensis coastal cactus wren
Charadrius nivosus nivosus western snowy plover
Circus hudsonius northern harrier
Coccyzus americanus
occidentalis western yellow-billed cuckoo
£/anus /eucurus white-tailed kite
southwestern willow
Empidonax trail/ii extimus flycatcher
lcteria virens yellow-breasted chat
/xobrychus exilis least bittern
lateral/us jamaicensis
coturniculus California black rail
Passerculus sandwichensis
beldingi Belding1s savannah sparrow
Plegadis chihi white-faced ibis
Polioptila californica
ca/ifornica coastal california gnatcatcher
Biological Resources Technical Letter Report
Salk Avenue Apartments Project
Staws (Federal/State/Other)
FE/ None/ CDFW-SSC
FPT /None/ BLM-S, CDFW-SSC
None/ None/ None
None/ ST/ BLM-S, CDFW-SSC
None/ None/ None
None/ None/ BLM-S, CDFW-FP
None/ ST/ BLM-S
None/ None/ CDFW-SSC, USFS-S
FT/ None/ CDFW-SSC
None/ None/ CDFW-SSC
FT/ SE/ BLM-S, USFS-S
None/ None/ BLM-S, CDFW-FP
FE/ SE/ None
None/ None/ CDFW-SSC
None/ None/ CDFW-SSC
None/ ST/ BLM-S, CDFW-FP
None/ SE/ None
None/ None/ None
FT/ None/ CDFW-SSC
Attachment D -Special-Status Species Potential to Occur Tables
WILDLIFE
HCP/NCCP Protection Habitats Potential to Occur in BSA
Desert wash I Riparian scrub I Riparian woodland I South coast flowing
waters I South coast standing waters; Semi-arid regions near washes or
intermittent streams, including valley-foothill and desert riparian, desert
NE wash, etc. Not expected to occur. No suitable habitat is present.
Cismontane woodland I Coastal scrub I Valley & foothill grassland I
Vernal pool I Wetland; Occurs primarily in grassland habitats, but can be
None found in valley-foothill hardwood woodlands. Not expected to occur. No suitable habitat is present.
Cismontane woodland I Riparian forest I Riparian woodland I Upper
montane coniferous forest; Woodland, chiefly of open, interrupted or
Covered marginal type. Not expected to occur. No suitable habitat is present.
Freshwater marsh I Marsh & swamp I Swamp I Wetland; Highly colonial
species, most numerous in Central Valley and vicinity. Largely endemic to
None California. Not expected to occur. No suitable habitat is present.
Chaparral I Coastal scrub; Resident in Southern California coastal sage
Covered scrub and sparse mixed chaparral. Not expected to occur. No suitable habitat is present.
Broadleaved upland forest I Cismontane woodland I Coastal prairie I
Great Basin grassland I Great Basin scrub I Lower montane coniferous
forest I Pinon & juniper woodlands I Upper montane coniferous forest I
Valley & foothill grassland; Rolling foothills, mountain areas, sage-juniper
None flats, and desert. Not expected to occur. No suitable habitat is present.
Great Basin grassland I Riparian forest I Riparian woodland I Valley &
foothill grassland; Breeds in grasslands with scattered trees, juniper-sage
flats, riparian areas, savannahs, and agricultural or ranch lands with
None groves or lines of trees. Not expected to occur. No suitable habitat is present.
None Coastal scrub; Southern California coastal sage scrub. Not expected to occur. No suitable habitat is present.
Great Basin standing waters I Sand shore I Wetland; Sandy beaches, salt
None pond levees and shores of large alkali lakes. Not expected to occur. No suitable habitat is present.
Coastal scrub I Great Basin grassland I Marsh & swamp I Riparian scrub
I Valley & foothill grassland I Wetland; Coastal salt and freshwater
marsh. Nest and forage in grasslands, from salt grass in desert sink to
None mountain cienagas. Not expected to occur. No suitable habitat is present.
Riparian forest; Riparian forest nester, along the broad, lower flood-
None bottoms of larger river systems. Not expected to occur. No suitable habitat is present.
Cismontane woodland I Marsh & swamp I Riparian woodland I Valley &
foothill grassland I Wetland; Rolling foothills and valley margins with
scattered oaks and river bottomlands or marshes next to deciduous
None woodland. Not expected to occur. No suitable habitat is present.
Covered Riparian woodland; Riparian woodlands in Southern California. Not expected to occur. No suitable habitat is present.
Riparian forest I Riparian scrub I Riparian woodland; Summer resident;
inhabits riparian thickets of willow and other brushy tangles near
Covered watercourses. Not expected to occur. No suitable habitat is present.
Marsh & swamp I Wetland; Colonial nester in marshlands and borders of
None ponds and reservoirs which provide ample cover. Not expected to occur. No suitable habitat is present.
Brackish marsh I Freshwater marsh I Marsh & swamp I Salt marsh I
Wetland; Inhabits freshwater marshes, wet meadows and shallow
None margins of saltwater marshes bordering larger bays. Not expected to occur. No suitable habitat is present.
Marsh & swamp I Wetland; Inhabits coastal salt marshes, from Santa
Covered Barbara south through San Diego County. Not expected to occur. No suitable habitat is present.
Covered Marsh & swamp I Wetland; Shallow freshwater marsh. Not expected to occur. No suitable habitat is present.
Coastal bluff scrub I Coastal scrub; Obligate, permanent resident of
Covered coastal sage scrub below 2500 ft in Southern california. Present. Species was observed within study area.
D-7
June 3, 2026 Item #1 124 of 417
l1tfM@l:fflfti
IN TE RN ATI O NAL
Scientific Name Common Name
Rallus obsoletus levipes light-footed Ridgway's rail
Riparia riparia bank swallow
Setophaga petechia yellow warbler
Sternula antillarum browni California least tern
Vireo be/Iii pusil/us least Bell's vireo
Fishes
Eucyclogobius newberryi tidewater goby
Gila orcuttii arroyo chub
Invertebrates
Bombus crotchii Crotch's bumble bee
Bronchinecta sandiegonensis San Diego fairy shrimp
monarch -California
Danous plexippus plexippus overwintering population
Streptocephalus woottoni Riverside fairy shrimp
Mammals
Antrozous pallidus pallid bat
Chaetodipus californicus
femoralis Dulzura pocket mouse
northwestern San Diego
Chaetodipus fa/lax fa/lax pocket mouse
Choeronycteris mexicana Mexican long-tongued bat
Biological Resources Technical Letter Report
Salk Avenue Apartments Project
Status {Federal/State/Other)
FE/ SE/ CDFW-FP
None/ ST/ BLM-S
None/ None/ CDFW-SSC
FE/ SE/ CDFW-FP
FE/ SE/ None
FE/ None/ CDFW-SSC
None/ None/ CDFW-SSC, USFS-S
None/ SCE / None
FE/ None/ None
FPT /None/ USFS-S
FE/ None/ None
None/ None/ BLM-S, CDFW-SSC, USFS-
s
None/ None/ CDFW-SSC
None/ None/ CDFW-SSC
None/ None/ CDFW-SSC
Attachment D -Special-Status Species Potential to Occur Tables
HCP/NCCP Protection Habitats Potential to Occur In BSA
Marsh & swamp I Salt marsh I Wetland; Found in salt marshes traversed
by tidal sloughs, where cordgrass and pickleweed are the dominant
Covered vegetation. Not expected to occur. No suitable habitat is present.
Riparian scrub I Riparian woodland; Colonial nester; nests primarily in
None riparian and other lowland habitats west of the desert. Not expected to occur. No suitable habitat is present.
Riparian forest I Riparian scrub I Riparian woodland; Riparian plant
associations in close proximity to water. Also nests in montane shrubbery
None in open conifer forests in Cascades and Sierra Nevada. Not expected to occur. No suitable habitat is present.
Alkali piaya I Wetland; Nests along the coast from San Francisco Bay
Covered south to northern Baja California. Not expected to occur. No suitable habitat is present.
Riparian forest I Riparian scrub I Riparian woodland; Summer resident of
Southern California in low riparian in vicinity of water or in dry river
Covered bottoms; below 2000 ft. Not expected to occur. No suitable habitat is present.
Aquatic I Klamath/North coast flowing waters I Sacramento/San Joaquin
flowing waters I South coast flowing waters; Brackish water habitats
along the california coast from Agua Hedionda Lagoon, San Diego County
None to the mouth of the Smith River. Not expected to occur. No suitable habitat is present.
Aquatic I South coast flowing waters; Native to streams from Malibu
Creek to San Luis Rey River basin. Introduced into streams in Santa Clara,
None Ventura, Santa Ynez, Mojave and San Diego river basins. Not expected to occur. No suitable habitat is present.
Open grassland and scrub communities supporting suitable floral
resources. ; Coastal California east to the Sierra-Cascade crest and south Moderate potential to occur. Suitable habitat (Diegan Coastal Sage
None into Mexico. Scrub) is present.
Chaparral I Coastal scrub I Vernal pool I Wetland; Endemic to San Diego
Covered (List 3), NE and Orange County mesas. Not expected to occur. No suitable habitat is present.
Closed-cone coniferous forest; Winter roost sites extend along the coast
None from northern Mendocino to Baja California, Mexico. Not expected to occur. No suitable habitat is present.
Coastal scrub I Valley & foothill grassland I Vernal pool I Wetland;
Endemic to Western Riverside, Orange, and San Diego counties in areas
Covered (List 3), NE of tectonic swales/earth slump basins in grassland and coastal sage scrub. Not expected to occur. No suitable habitat is present.
Chaparral I Coastal scrub I Desert wash I Great Basin grassland I Great
Basin scrub I Mojavean desert scrub I Riparian woodland I Sonoran
desert scrub I Upper montane coniferous forest I Valley & foothill
grassland; Deserts, grasslands, shrublands, woodlands and forests. Most
None common in open, dry habitats with rocky areas for roosting. Not expected to occur. There is marginal to no suitable habitat.
Chaparral I Coastal scrub I Valley & foothill grassland; Variety of habitats
including coastal scrub, chaparral, and grassland primarily in San Diego
None County. Not expected to occur. No suitable habitat is present.
Chaparral I Coastal scrub; Coastal scrub, chaparral, grasslands,
sagebrush, etc. in western San Diego, Riverside, San Bernardino, and Los
None Angeles Counties, inclusive of Orange County. Not expected to occur. No suitable habitat is present.
Pinon & juniper woodlands I Riparian scrub I Sonoran thorn woodland;
Occasionally found in San Diego County, which is on the periphery of
None their range. Not expected to occur. No suitable habitat is present.
D-8
June 3, 2026 Item #1 125 of 417
l1t@tttffll:fflffl
INTE RN ATIONA L
Scientific Name Common Name
Corynorhinus townsendii Townsend's big-eared bat
Dipodomys stephensi Stephens• kangaroo rat
Eumops perotis californicus western mastiff bat
Leptonycteris yerbabuenae lesser long-nosed bat
Myotis yumanensis Yuma myotis
Neotoma lepida intermedia San Diego desert woodrat
Nyctinomops femorosaccus pocketed free-tailed bat
Perognathus Jongimembris
pacificus Pacific pocket mouse
Taxidea taxus American badger
Reptiles
Actinemys pa/Iida southwestern pond turtle
Southern California legless
Annie/la stebbinsi lizard
Arizona elegans occidentalis California glossy snake
Aspidosce/is hyperythra orange-throated whiptail
Aspidoscelis tigris stejnegeri coastal whiptail
Crotalus ruber red-diamond rattlesnake
Biological Resources Technical Letter Report
Salk Avenue Apartments Project
Status {Federal/State/Other)
None/ None/ BLM-S, CDFW-SSC, USFS-
s
FT/ ST/ None
None/ None/ BLM-S, CDFW-SSC
FD/ None/ CDFW-SSC
None/ None/ BLM-S
None/ None/ CDFW-SSC
None/ None/ CDFW-SSC
FE/ SCE / CDFW-SSC
None/ None/ CDFW-SSC
FPT /None/ BLM-S, CDFW-SSC, USFS-S
None/ None/ CDFW-SSC, USFS-S
None/ None/ CDFW-SSC
None/ None/ USFS-S
None/ None/ CDFW-SSC
None/ None/ CDFW-SSC, USFS-S
Attachment D -Special-Status Species Potential to Occur Tables
HCP/NCCP Protection Habitats Potential to Occur In BSA
Broadleaved upland forest I Chaparral I Chenopod scrub I Great Basin
grassland I Great Basin scrub I Joshua tree woodland I Lower montane
coniferous forest I Meadow & seep I Mojavean desert scrub I Riparian
forest I Riparian woodland I Sonoran desert scr; Throughout California in
None a wide variety of habitats. Most common in mesic sites. Not expected to occur. No suitable habitat is present.
Coastal scrub I Valley & foothill grassland; Primarily annual and perennial
grasslands, but also occurs in coastal scrub and sagebrush with sparse
None canopy cover. Not expected to occur. No suitable habitat is present.
Chaparral I Cismontane woodland I Coastal scrub I Valley & foothill
grassland; Many open, semi-arid to arid habitats, including conifer and
None deciduous woodlands, coastal scrub, grasslands, chaparral, etc. Not expected to occur. No suitable habitat is present.
Mojavean desert scrub I Sonoran desert scrub I Upper Sonoran scrub;
Arid regions such as desert grasslands and shrub land. Suitable day roosts
(caves, mines) and suitable concentrations of food plants (columnar cacti,
agaves) are critical resources. No maternity roosts known from California;
None may only be vagrant. Not expected to occur. No suitable habitat is present.
Lower montane coniferous forest I Riparian forest I Riparian woodland I
Upper montane coniferous forest; Optimal habitats are open forests and
None woodlands with sources of water over which to feed. Not expected to occur. There is marginal to no suitable habitat.
Coastal scrub; Coastal scrub of Southern California from San Diego
None County to San Luis Obispo County. Not expected to occur. No suitable habitat is present.
Joshua tree woodland I Pinon & juniper woodlands I Riparian scrub I
Sonoran desert scrub; Variety of arid areas in Southern California; pine-
juniper woodlands, desert scrub, palm oasis, desert wash, desert riparian,
None etc. Not expected to occur. No suitable habitat is present.
Coastal scrub; Inhabits the narrow coastal plains from the Mexican
NE border north to El Segundo, Los Angeles County. Not expected to occur. No suitable habitat is present.
Alkali marsh I Alkali playa I Alpine I Alpine dwarf scrub I Bog & fen I
Brackish marsh I Broadleaved upland forest I Chaparral I Chenopod
scrub I Cismontane woodland I Closed-cone coniferous forest I Coastal
bluff scrub I Coastal dunes I Coastal prairie; Most abundant in drier open
None stages of most shrub, forest, and herbaceous habitats, with friable soils. Not expected to occur. No suitable habitat is present.
None Not expected to occur. No suitable habitat is present.
Broadleaved upland forest I Chaparral I Coastal dunes I Coastal scrub;
Generally south of the Transverse Range, extending to northwestern Baja
California. Occurs in sandy or loose loamy soils under sparse vegetation.
Disjunct populations in the Tehachapi and Piute Mountains in Kern
None County. Not expected to occur. No suitable habitat is present.
Arid scrub, rocky washes, grasslands, chaparral, open areas with loose
soil; Patchily distributed from the eastern portion of San Francisco Bay,
southern San Joaquin Valley, and the Coast, Transverse, and Peninsular
None ranges, south to Baja California. Not expected to occur. No suitable habitat is present.
Chaparral I Cismontane woodland I Coastal scrub; Inhabits low-elevation
Covered coastal scrub, chaparral, and valley-foothill hardwood habitats. Not expected to occur. No suitable habitat is present.
Hot and dry areas with sparse foliage, including chaparral, woodland, and
riparian areas.; Found in deserts and semi-arid areas with sparse
None vegetation and open areas. Also found in woodland and riparian areas. Not expected to occur. No suitable habitat is present.
Chaparral I Mojavean desert scrub I Sonoran desert scrub; Chaparral,
woodland, grassland, and desert areas from coastal San Diego County to
None the eastern slopes of the mountains. Not expected to occur. No suitable habitat is present.
1).9
June 3, 2026 Item #1 126 of 417
l1t@tttffll:fflffl
IN TE RN ATI O N AL
Scientific Name Common Name
Diadophis punctatus similis San Diego ringneck snake
Phrynosoma blainvillii coast horned lizard
Plestiodon skiltonianus
interparietalis Coronado skink
Salvadora hexalepis virgultea coast patch-nosed snake
Thamnophis hammondii two-striped gartersnake
Thamnophis sirtalis pop. 1 south coast gartersnake
StatU$ Lecend·
Federal
FE: Federally listed as endangered
FT: Federally listed as threatened
FPE: Federally proposed for listing as endangered
FPT: Federally proposed for listing as threatened
FC: Federal candidate species (former Category 1 candidates)
None: No federal listing
FOL: Delisted
State
SE: State listed as endangered
ST: State listed as threatened
SR: State rare
SCE: State candidate for listing as endangered
SCT: State candidate for listing as threatened
None: No state listing
SOL: State delisting
Other
BCC: U.S. Fish and Wildlife Service Bird of Conservation Concern
BLM-S: Bureau of Land Management Sensitive Species
CDFW-FP: California Fully Protected Species
CDFW-SSC: California Species of Special Concern
USFS-S: U.S. Forest Service Sensitive Species
Biological Resources Technical Letter Report
Salk Avenue Apartments Project
Attachment D -Special-Status Species Potential to Occur Tables
Status {Federal/State/Other) HCP/NCCP Protection Habitats Potential to Occur In BSA
Moist habitats including wet meadows, rocky hillsides, gardens, farmland
grassland, chaparral, mixed-conifer forest, and woodland habitats; Open,
fairly rocky areas. Use boards, flat rocks, woodpiles, stable talus, rotting
None/ None/ USFS-S None logs and small ground holes for cover. Not expected to occur. No suitable habitat is present.
Chaparral I Cismontane woodland I Coastal bluff scrub I Coastal scrub I
Desert wash I Pinon & juniper woodlands I Riparian scrub I Riparian
woodland I Valley & foothill grassland; Frequents a wide variety of
habitats, most common in lowlands along sandy washes with scattered
None/ None/ BLM-S, CDFW-SSC None low bushes. Not expected to occur. No suitable habitat is present.
Chaparral I Cismontane woodland I Pinon & juniper woodlands;
Grassland, chaparral, pinon-juniper and juniper sage woodland, pine-oak
None/ None/ BLM-S None and pine forests in Coast Ranges of Southern California. Not expected to occur. No suitable habitat is present.
Coastal scrub; Brushy or shrubby vegetation in coastal Southern
None/ None/ CDFW-SSC None California. Not expected to occur. No suitable habitat is present.
Marsh & swamp I Riparian scrub I Riparian woodland I Wetland; Coastal
None/ None/ BLM-S, CDFW-SSC, USFS-California from vicinity of Salinas to northwest Baja California. From sea
s None to about 7,000 ft elevation. Not expected to occur. No suitable habitat is present.
Artificial standing waters I Marsh & swamp I Riparian scrub I Riparian
woodland I South coast flowing waters I South coast standing waters I
Wetland; Southern California coastal plain from Ventura County to San
None/ None/ CDFW-SSC None Diego County, and from sea level to about 850 m. Not expected to occur. No suitable habitat is present.
Special-Status Wildlife Species Designations
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June 3, 2026 Item #1 127 of 417
Salk Avenue Apartments Project
Comment Leers and Responses to Comments
SCH No. 2026030432
May 2026
Lead Agency: Prepared by:
Community Development Department
1635 Faraday Avenue
5050 Avenida Encinas, Suite 260
Carlsbad, CA 92008
JN 205484
June 3, 2026 Item #1 128 of 417
Table of Contents
1.0 Introduction ....................................................................................................................... 1-1
2.0 Comment Letters Received and Responses to Comments .......................................... 2-1
Letter 1 ................................................................................................................................... 2-2
Letter 2 ................................................................................................................................. 2-26
June 3, 2026 Item #1 129 of 417
1.0 INTRODUCTION
The City of Carlsbad (City) prepared a Focused Initial Study/Mitigated Negative Declaration (IS/MND) for the Salk Avenue Apartments Project (proposed project). Pursuant to Sections 15072
and 15073 of the California Environmental Quality Act (CEQA) Guidelines, the IS/MND and Notice
of Intent (NOI) to adopt the MND were circulated for a 31-day public review period that began on
February 25, 2026, and ended on March 27, 2026.
The NOI was filed with the County of San Diego County Clerk on February 25, 2026. Additionally,
the IS/MND and NOI were posted on the City’s website throughout the duration of the public
review period and hard copies were made available for public review at the City’s Planning Division Counter.
A total of two comment letters were received during the public review period. The letters are
included herein in their entirety and are followed by the City’s written responses. Refer to
Section 2.0, Comment Letters Received and Responses to Comments.
Pursuant to Section 15074(b) of the CEQA Guidelines, the lead agency (City) is required to
consider the MND along with any comments received during the public review period. While
written responses to comments submitted on MNDs are not required, responses are provided herein to each written comment received for the record, with particular regard for environmental
concerns related to CEQA issues.
Based on the whole of the record, the City finds that the comments received do not raise any new
potentially significant impacts, do not identify an increase to the severity of any impacts disclosed
in the IS/MND, and do not require substantial revision of the IS/MND. Pursuant to Section 15073.5
of the CEQA Guidelines, recirculation of the IS/MND is not required. Further, preparation of an
Environmental Impact Report is not required as all potentially significant environmental impacts that may result from the proposed project have been mitigated to less than significant levels.
June 3, 2026 Item #1 130 of 417
2.0 COMMENT LETTERS RECEIVED AND RESPONSES TO
COMMENTS
June 3, 2026 Item #1 131 of 417
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Page 1 of 11
Re: Comment on Focused Initial Study/Mitigated Negative Declaration for the Salk
Avenue Apartments Project (SCH No. 2026030432); AB 130/SB 131 CEQA Exemption
Evaluation (Appendices A and B)
Dear Mr. Van Leeuwen:
I am submitting the following comments on the Focused Initial Study/Mitigated Negative
Declaration (“Focused IS/MND”) and the associated AB 130 Housing Development Project
CEQA Exemption Evaluation Checklist (Appendix A) and SB 131 Exclusions of Certain Types
of Housing Development Projects CEQA Exemption Evaluation (Appendix B) prepared for
the Salk Avenue Apartments Project (“Project”) in the City of Carlsbad (“City”). The Project
proposes 397 multi-family residential dwelling units in a ve-story building on an
approximately 9.78-acre site located on Salk Avenue within the Fenton Carlsbad Center
Specic Plan area.
The Project claims entitlement to a 35 percent density bonus under Government Code
Section 65915 and relies on the SB 131 near-miss pathway under Public Resources Code
Section 21080.1 to limit CEQA review to biological resources, asserting that habitat for
protected species under Government Code Section 65913.4(a)(6)(J) is the sole
disqualifying condition preventing full AB 130 exemption. Under CEQA Guidelines Section
15064(f)(2) and Public Resources Code Section 21082.2, an Environmental Impact Report
is required whenever substantial evidence supports a fair argument that a project may have
a signicant eƯect on the environment, regardless of whether other substantial evidence
supports a contrary conclusion. (No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 75.)
As detailed below, the administrative record raises two independent grounds for challenge:
(1) the Project does not qualify for SB 131 near-miss treatment because it fails the AB 130
statutory exemption due to multiple disqualifying conditions, not a single condition; and (2)
even accepting the City’s single-condition framework arguendo, the Focused IS/MND’s
biological resources analysis is substantively inadequate because it fails to analyze well-
documented impact pathways identied by the U.S. Fish and Wildlife Service as threats to
the survival and recovery of species conrmed on-site. Each ground independently
requires preparation of an Environmental Impact Report.
I. THE SB 131 NEAR-MISS PATHWAY IS UNAVAILABLE BECAUSE THE RECORD
IDENTIFIES MULTIPLE DISQUALIFYING CONDITIONS
The Project’s entire CEQA compliance strategy depends on a single premise: that habitat
for protected species under Section 65913.4(a)(6)(J) is the only condition disqualifying the
Project from the AB 130 statutory exemption. PRC Section 21080.1(4)(B) expressly provides
that SB 131’s streamlined review does not apply to “[a] proposed housing development
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Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Page 2 of 11
project that is ineligible for the statutory exemption or categorical exemption due to two or
more conditions.” The administrative record identies multiple disqualifying conditions
through two independent analytical pathways.
A. Three Species Under Three Regulatory Frameworks Constitute Multiple Conditions
Under Section 21080.66(a)(6)(J)
Section 21080.66(a)(6)(J) disqualies sites containing “[h]abitat for protected species
identied as candidate, sensitive, or species of special status by state or federal agencies,
fully protected species, or species protected by the federal Endangered Species Act of
1973 . . . , the California Endangered Species Act . . . , or the Native Plant Protection Act.”
The statute does not treat these as synonyms. It enumerates distinct legal categories with
distinct regulatory consequences.
The Project’s own biological consultant identies habitat or conrmed presence for three
distinct species operating under at least three separate regulatory frameworks:
Coastal California gnatcatcher (Polioptila californica californica): Federally listed as
threatened under the ESA; California Species of Special Concern. Conrmed present on-
site during the January 24, 2025 biological survey. The site includes USFWS-designated
critical habitat. This species has its own recovery plan, recovery implementation strategy,
and critical habitat designation rule, all administered by the Carlsbad Fish and Wildlife
OƯice, the same USFWS oƯice with jurisdiction over this Project site. The gnatcatcher
triggers federal Section 7 consultation requirements.
Crotch’s bumble bee (Bombus crotchii): State candidate endangered under CESA, with
protections equivalent to a fully listed species under Fish and Game Code Section 2085.
The Focused IS/MND acknowledges “moderate potential” for occurrence and identies
CDFW as a trustee agency that may need to issue an Incidental Take Permit, a separate
discretionary action under an entirely diƯerent statutory framework than the ESA.
Thread-leaved brodiaea (Brodiaea lifolia): Federally threatened under the ESA; state
endangered under CESA; California Rare Plant Rank 1B.1; additionally protected under the
Native Plant Protection Act. USFWS has designated critical habitat on the Project site. This
single species is subject to protection under three separate statutory frameworks - the
ESA, CESA, and NPPA - each independently referenced in Section 21080.66(a)(6)(J).
PRC Section 21080.1 denes “condition” as “a physical or regulatory feature of the project
or its setting or eƯect on the environment caused by the project.” Each of these three
species involves distinct physical and regulatory features. The gnatcatcher is an obligate
coastal sage scrub species with specic territory requirements, noise sensitivity
1 1
(cont.)
June 3, 2026 Item #1 133 of 417
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Page 3 of 11
ground-nesting pollinator with entirely diƯerent habitat use patterns requiring nectaring
sources and specic soil conditions for nesting and overwintering, triggering a separate
CESA regulatory pathway. Thread-leaved brodiaea is an edaphic specialist dependent on
specic clay soil moisture regimes, with diƯerent sensitivity to altered hydrology; a distinct
impact pathway not shared with the other two species.
The presence of three biologically distinct species, three separate listing statutes, three
independent regulatory pathways, and three diƯerent impact mechanisms constitutes
multiple “physical or regulatory feature[s]” of the Project’s setting. The City’s conation of
these into a single “condition” is inconsistent with the statutory text.
B. The HMP Special Resource Area Designation Creates an Independent Second
Disqualifying Condition
The Project’s own biological technical report states that the site is “not within a . . . Special
Resource Area.” In the same section, the report quotes the Carlsbad Habitat Management
Plan description of Special Resource Area 1 as lying “between El Camino Real, Faraday
Avenue, and College Boulevard within Zone 5.” The Project site is located south of Salk
Avenue, west of El Camino Real, east of College Boulevard, and north of Faraday Avenue,
within the geographic boundaries the HMP describes for SRA 1. The document quotes the
description and then denies the site falls within it, without explanation or reconciliation.
The HMP describes SRA 1 as supporting “a major population of a Narrow Endemic plant
species (Brodiaea lifolia)” and states that “conservation of Narrow Endemic plant
populations within the SRA is considered important for species conservation.” This
language, “identied” in an adopted NCCP as “important for species conservation” maps
directly onto the disqualifying condition in Section 65913.4(a)(6)(I): lands identied for
conservation in an adopted natural community conservation plan.
This reading is reinforced by SB 158, signed October 11, 2025, which revised the denition
of “natural and protected lands” in PRC Section 21067.5 to expressly include lands
identied for conservation in an adopted NCCP. The Carlsbad HMP is an NCCP. The SRA
designation, which the HMP itself describes as important for species conservation,
constitutes identication for conservation under the post-SB 158 framework.
If SRA 1 constitutes land identied for conservation under Section 65913.4(a)(6)(I), the
Project has at minimum two disqualifying conditions: (a)(6)(J) for protected species habitat
and (a)(6)(I) for NCCP conservation lands. Two conditions defeat the near-miss pathway
under Section 21080.1(4)(B). The consequence is the collapse of the focused IS/MND
framework, requiring full CEQA review of all environmental topics.
1 1
(cont.)
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Comment Letters and Responses to Comments
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Page 4 of 11
C. The Two Analytical Pathways Are Independent and Cumulative
The multi-species argument (Section I.A) and the SRA 1 argument (Section I.B) are
independent. Either alone establishes multiple disqualifying conditions. Together, they
demonstrate that the Project’s claimed single condition is, at minimum, two conditions
and potentially several more. The City must prevail on both arguments to sustain the near-
miss pathway. If either succeeds, full CEQA review is required for all environmental topics
including the disciplines the SB 131 framework currently excludes: air quality, traƯic, noise,
hydrology, geology, aesthetics, greenhouse gas emissions, and land use.
II. EVEN IF THE NEAR-MISS PATHWAY IS AVAILABLE, THE FOCUSED BIOLOGICAL
ANALYSIS IS INDEPENDENTLY INADEQUATE
Independent of whether the Project satises the statutory criteria for the SB 131 near-miss
pathway, the IS/MND contains signicant analytical deciencies that independently
require preparation of an EIR. Under the SB 131 framework, the biological analysis is the
only environmental analysis required. The adequacy of that analysis is therefore the central
question for the entire environmental document. The deciencies identied below
demonstrate that the analysis does not satisfy CEQA’s requirements.
A. Deferred Baseline Investigations for Listed and Candidate Species
The IS/MND adopts less-than-signicant ndings for two listed or candidate species
without rst establishing whether those species are present on the project site. The
signicance determinations are contingent on information that does not yet exist in the
record.
Crotch’s bumble bee. MM BIO-2 defers the presence/absence determination to
preconstruction focused surveys conducted after project approval. If the species is
detected, avoidance buƯers are required; if avoidance is not feasible, an ITP must be
obtained from CDFW. The IS/MND concludes less than signicant with mitigation without
knowing whether the species is present, what the extent of use is, or whether avoidance is
feasible. The focused surveys required by MM BIO-2 are the analysis necessary to
determine signicance and should have been conducted during CEQA review. (Sundstrom
v. County of Mendocino (1988) 202 Cal.App.3d 296.)
The deferral is compounded by a facial inconsistency. The biological technical report states
that the 0.33-acre CSS patch “supports nectaring sources that may be used by foraging
Crotch’s bumble bee and soils that could provide nesting and overwintering habitat.” The
IS/MND then states that “no direct impacts to CBB individuals or nests are expected from
the project due to lack of suitable nectaring sources for foraging and lack of nesting
es suitable habitat as the basis for a moderate occurrence
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potential and then denies the existence of that same habitat to support a less-than-
signicant determination. This internal contradiction undermines the reliability of the
signicance conclusion.
Thread-leaved brodiaea
The IS/MND concludes no impact based on focused surveys conducted in 2001 and 2003 -
twenty-two to twenty-four years before the current document - and a January 2025 survey
conducted outside the species’ March-through-June blooming period. Thread-leaved
brodiaea is a geophyte reliably detectable only during bloom. The 0.33-acre CSS patch
overlapping USFWS-designated critical habitat was not graded in 2007 and remains intact.
The document’s own Attachment D assigns “Moderate” potential. No current-year focused
botanical survey during the blooming period has been conducted. The CDFW 2018
Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations
require oristic surveys timed to the blooming period of target species.
Foundational baseline deciency
Both species-specic failures are symptomatic of a broader problem. The entire biological
resources analysis rests on a single two-hour habitat assessment conducted on January
24, 2025, from 8:15 a.m. to 10:15 a.m. January is outside the primary blooming period for
most special-status plant species in coastal San Diego County, outside the breeding
season for gnatcatcher, and outside the colony active season for Crotch’s bumble bee. The
document uses this single winter visit to inform the dismissal of 64 special-status wildlife
species and 67 of 68 special-status plant species as “not expected to occur.” Where the SB
131 framework concentrates the entire CEQA document on biological resources, the
adequacy of the biological baseline is paramount.
B. Conrmed Federally Threatened Species: Inadequate Analysis and Unenforceable
Mitigation
A coastal California gnatcatcher was conrmed present on the project site during the
January 2025 survey. The IS/MND’s treatment of this species is decient in four
independent respects.
1. No Protocol Survey
No protocol-level focused survey was conducted. The USFWS Coastal California
Gnatcatcher Presence/Absence Survey Protocol requires a minimum of six breeding-
season visits between March 15 and June 30 with taped vocalization playback. Without
protocol data on territory boundaries, pair status, and nesting locations, the document
cannot evaluate whether the 100-foot buƯer between the CSS patch and the development
1-4
(cont.)
1-5
1-6
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June 3, 2026 Item #1 136 of 417
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footprint is adequate. USFWS guidance recommends a minimum 500-foot buƯer from
active nests or demonstration that construction noise will not exceed 60 dB(A) Leq at the
nest. The IS/MND evaluates the project against neither standard.
2. Unenforceable Mitigation
MM BIO-1 defers the determination of avoidance buƯer width to the discretion of a
qualied biologist “in coordination with the City” without establishing minimum buƯer
distances or noise thresholds. While discretionary buƯer determination is accepted
practice for common nesting birds, it is insuƯicient for a federally threatened species with
established noise sensitivity thresholds. A mitigation measure that defers the critical
protective determination for a federally listed species to post-approval discretion without
minimum enforceable criteria does not constitute enforceable mitigation under CEQA
Guidelines Section 15126.4.
3. Omission of Indirect Impact Analysis
The IS/MND concludes “No Impact” to sensitive natural communities under threshold (b)
based solely on avoidance of direct impacts to the 0.33-acre CSS patch. This
determination fails to analyze indirect impacts from a 397-unit, ve-story residential
complex approximately 100 feet away. The document’s own analysis under threshold (f)
acknowledges the need for HMP Adjacency Standards to address lighting, erosion, invasive
species, and predator control - the same categories of indirect eƯects that must be
analyzed under threshold (b). The document cannot simultaneously acknowledge indirect
eƯects under one threshold and deny them under another.
4. Failure to Address Federal Recovery Framework
The IS/MND’s indirect impact analysis and mitigation measures are inconsistent with the
federal recovery planning framework for the species conrmed on-site. The USFWS
completed the Recovery Implementation Strategy for the Coastal California Gnatcatcher in
July 2025, prepared by the same Carlsbad Fish and Wildlife OƯice with jurisdiction over the
Project site. The USFWS also published the Draft Recovery Plan for the species in 2025.
These documents identify specic threats and recovery priorities that the IS/MND fails to
address:
Predation. The USFWS critical habitat designation rule (68 Fed. Reg. 20228, April 24, 2003)
identies predation as the most common cause of nest failure, accounting for 30 to 60
percent of nest failures in some areas, and specically identies domestic or feral cat as a
recognized predator of gnatcatcher eggs and nestlings. (Citing Atwood 1990; Braden et al.
1997; Grishaver et al. 1998.) The 1993 listing rule recognized the “synergistic eƯects” of
1-7
(cont.)
1-8
1-9
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Gnatcatchers nest at approximately three feet above ground in coastal sage scrub, well
within reach of domestic cats. The Project will introduce potentially hundreds of domestic
cats within 100 feet of conrmed gnatcatcher habitat. The IS/MND’s sole response is
“educational brochures” to future residents, characterized as an HMP adjacency standard
rather than analyzed as a species impact. Educational brochures are not an enforceable
mitigation measure and would not satisfy requirements under ESA Section 7 or Section 10.
Brown-headed cowbird brood parasitism. The Focused IS/MND contains no analysis of
cowbird brood parasitism despite the fact that cowbird parasitism was identied in the
1993 listing rule as a contributing threat. The July 2025 Recovery Implementation Strategy
makes cowbird control a Priority 3 recovery action (Action 7), including monitoring
occupied areas for cowbird presence and trapping where necessary. A 397-unit residential
complex will generate food subsidies - trash, pet food, bird feeders, landscaping with seed-
producing ornamentals - that attract cowbirds into adjacent habitat. The complete
absence of cowbird analysis is a signicant deciency.
Habitat connectivity and fragmentation. The IS/MND makes a “No Impact” nding on
wildlife movement, asserting that the site does not support wildlife corridors. This nding is
directly contradicted by the federal recovery framework. The Draft Recovery Plan states
that gnatcatchers require “connected habitat patches of adequate area and quality” for
population viability. The Recovery Implementation Strategy identies restoring areas to
“enhance connectivity of areas occupied by coastal California gnatcatcher” as a Priority 2
action (Activity 4-6), noting this is “particularly important where open areas may be
fragmented by development.” Activity 4-7 specically targets the gnatcatcher corridor
identied in the MHCP, the conservation planning framework under which Carlsbad’s HMP
operates. The USFWS 2024 ve-year status review notes the gnatcatcher “is likely to be
sensitive to further increases in fragmentation and isolation of habitat within the northern
portion of its range.” The 0.33-acre CSS patch with a conrmed gnatcatcher is likely
functioning as stepping-stone habitat within the broader HMP preserve network. A ve-
story building with perimeter retaining walls will permanently sever any connectivity
function.
Articial lighting. The IS/MND addresses lighting only as an HMP adjacency design
standard (low-pressure sodium, directed downward, shielded). It entirely ignores the
aggregate lighting from a ve-story, 397-unit residential building with windows, balconies,
common areas, a swimming pool, a ve-level parking structure with rooftop parking, and
27,000 square feet of outdoor open space. The building itself is a massive permanent light
source that will alter the light environment of adjacent CSS habitat, aƯecting avian
1 10
(cont.)
1 11
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Page 8 of 11
behavior, predator-prey dynamics, and insect foraging patterns relevant to both
gnatcatcher prey availability and bumble bee foraging.
Invasive species. The Recovery Implementation Strategy identies control of nonnative
vegetation as a Priority 2 recovery action (Action 5). The IS/MND addresses invasive species
solely through a landscape plan review commitment. It does not analyze the invasive
species introduction pathway from a 397-unit development: irrigation overspray, garden
escapees, ornamental seed dispersal, and nutrient inputs via fertilizer runoƯ. These are
standard impact pathways at the urban-wildland interface.
Altered hydrology and thread-leaved brodiaea critical habitat. The Project will convert
approximately 9.78 acres to largely impervious surface, including a 416,152-square-foot
building and 107,300-square-foot parking structure. Thread-leaved brodiaea is an edaphic
specialist dependent on specic soil moisture conditions in clay soils. USFWS designated
critical habitat on-site because the physical and biological features essential for the
species’ conservation are present. The IS/MND contains no analysis of whether altered
drainage patterns, inltration rates, or soil moisture regimes from the Project will aƯect
designated critical habitat 100 feet away. The stormwater discussion is limited to
construction-phase erosion BMPs.
C. Internal Inconsistencies Undermine Signicance Determinations
The IS/MND contains internal inconsistencies where the document simultaneously
identies and denies the existence of habitat conditions.
As discussed above, the Crotch’s bumble bee habitat characterization is facially
contradictory: suitable habitat is identied as the basis for moderate occurrence potential
and then denied to support a less-than-signicant determination.
The SRA 1 geographic inconsistency is similarly irreconcilable: the report quotes an HMP
description that places the site within SRA 1 and then denies the site is within an SRA. If the
site is within SRA 1, the HMP consistency analysis must address SRA-specic conservation
objectives, including the protection of narrow endemic plant populations—specically
thread-leaved brodiaea.
D. The 0.33-Acre CSS Patch: Convergence of Analytical Deciencies
The deciencies identied above converge on a single feature: the 0.33-acre patch of
Diegan Coastal Sage Scrub in the northwest corner of the site. This patch was not graded in
2007 and remains intact. It overlaps USFWS-designated critical habitat for thread-leaved
brodiaea. It falls within the geographic boundaries described for HMP Special Resource
Area 1. A coastal California gnatcatcher was conrmed present. The biological technical
1 11
(cont.)
1 12
1 13
1 14
1 15
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report identies it as supporting nectaring sources and soils suitable for Crotch’s bumble
bee. The HMP describes SRA 1 as designated specically to protect the narrow endemic
plant species that this critical habitat was designated to conserve.
The document’s treatment of this feature exhibits the full range of analytical deciencies:
baseline characterization based on a single out-of-season survey and decades-old
focused studies; no protocol survey for a conrmed federally listed bird; a signicance
determination for a candidate species that contradicts the document’s own habitat
characterization; a “No Impact” nding for indirect eƯects to a sensitive natural community
that the document elsewhere acknowledges will experience indirect eƯects; denial of SRA
status contradicted by the document’s own quoted HMP description; mitigation measures
lacking enforceable performance standards; and complete omission of impact pathways
identied by the species’ own federal recovery framework. The systematic minimization of
this feature’s signicance across multiple analytical dimensions is not the product of
independent professional judgments reaching consistent conclusions.
III. THE CDFW INCIDENTAL TAKE PERMIT ISSUE IS UNRESOLVED
The Focused IS/MND identies CDFW as a trustee agency that may need to issue an
Incidental Take Permit for Crotch’s bumble bee. MM BIO-2 provides that if the Project
“cannot avoid the established no-disturbance buƯer(s),” the applicant “shall consult with
CDFW on appropriate avoidance actions and obtain an Incidental Take Permit if
necessary.”
If an ITP is required, CDFW must make its own CEQA ndings as a responsible agency
before issuing the permit. The Focused IS/MND does not address whether this document -
limited by SB 131 to the environmental eƯects of a single condition - provides adequate
CEQA coverage for CDFW’s independent responsible agency obligations. This procedural
gap creates uncertainty about whether the document can serve its intended function if
CDFW determines that a discretionary ITP action is required.
IV. SYSTEMATIC PATTERN OF MINIMIZATION
The individual deciencies documented above are not isolated analytical errors. They form
a unidirectional pattern. Across the biological resources analysis—the sole discipline
reviewed under the SB 131 framework, every analytical choice trends toward a less-than-
signicant determination and in favor of project approval:
Reliance on a single two-hour winter survey as the sole current eld eƯort; use of twenty-
two-year-old focused surveys in lieu of current blooming-period surveys for a federally
listed plant with critical habitat on-site; failure to conduct protocol surveys for a federally
rmed present; internal inconsistency in habitat characterization for a state
1 16
(cont.)
1 17
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candidate endangered species; deferral of species presence/absence determinations to
post-approval mitigation; omission of indirect impact analysis for a sensitive natural
community that the document elsewhere acknowledges will experience indirect eƯects;
complete omission of predation, cowbird parasitism, habitat connectivity, altered
hydrology, and invasive species impact pathways identied in the species’ own federal
recovery framework; denial of SRA status contradicted by the document’s own quoted HMP
description; and mitigation measures lacking enforceable performance standards for listed
species.
No counterdirectional nding was identied. No instance was found where the document
overstated an impact, applied a more protective standard than warranted, or erred in a
direction that disfavored the project.
This unidirectional pattern is independently signicant under Sierra Club v. County of
Fresno (2018) 6 Cal.5th 502, 515–516, as it demonstrates that the IS/MND does not serve
CEQA’s informational purpose. The pattern is particularly consequential here because the
SB 131 near-miss framework concentrates the entire CEQA analysis on biological
resources, the single discipline where the pattern of minimization is most pronounced. The
document that was supposed to provide rigorous, focused biological analysis as the
tradeoƯ for exempting every other environmental topic from review has instead produced
the least reliable analysis in the record.
V. CONCLUSION AND REQUESTED ACTIONS
The administrative record contains substantial evidence supporting a fair argument that
the Project may have signicant eƯects on biological resources. The record also
demonstrates that the Project does not satisfy the statutory eligibility criteria for the SB 131
near-miss pathway, given (a) the presence of three species under three regulatory
frameworks constituting multiple conditions under Section 21080.66(a)(6)(J), and (b) the
potential second disqualifying condition of NCCP conservation lands under Section
65913.4(a)(6)(I).
I respectfully requests that the City:
1. Withdraw the Focused IS/MND and conduct full CEQA review through a comprehensive
Initial Study or Environmental Impact Report addressing all environmental topics, on the
grounds that the Project fails the AB 130 exemption due to multiple conditions and does
not qualify for SB 131 near-miss treatment;
1 18
(cont.)
1 19
June 3, 2026 Item #1 141 of 417
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Page 11 of 11
2. In the alternative, if the City maintains the single-condition framework, substantially
revise the Focused IS/MND to include: (a) protocol-level gnatcatcher surveys per the
USFWS protocol; (b) current blooming-period surveys for thread-leaved brodiaea within the
designated critical habitat; (c) pre-approval focused surveys for Crotch’s bumble bee; (d)
analysis of all indirect impact pathways identied in this letter, including predation,
cowbird parasitism, articial lighting, altered hydrology, invasive species, and habitat
connectivity, with reference to the USFWS Recovery Implementation Strategy and Draft
Recovery Plan; and (e) enforceable mitigation measures with minimum performance
standards for all listed and candidate species; and
3. Refrain from adopting the Focused IS/MND until all tribal consultations under AB 52 are
complete and CDFW has conrmed whether an Incidental Take Permit will be required for
Crotch’s bumble bee.
This letter is submitted for inclusion in the administrative record for the Project.
Respectfully submitted,
Jim
jkmiller7@proton.me
1-20
1-21
June 3, 2026 Item #1 142 of 417
Responses to Comments from Jim Miller
Response to Comment 1-1
The City acknowledges that the project site contains, or could support, three special-status
species or habitats, all of which have been thoroughly evaluated in the IS/MND. According to
CEQA exemption criteria, these are considered collectively as “habitat for protected species,”
which is a single disqualifying factor under Government Code Section 65913.4(a)(6)(J). Pursuant
to AB 130, the City evaluated whether these biological conditions constitute more than one
disqualifying factor. The City does not agree that these three special-status species/habitats
should be viewed as “multiple conditions” within the law; instead, it is a single environmental topic (biological resources) with several components included, each fully addressed. Therefore, the AB
130/SB 131 Focused IS/MND remains valid, and the project’s biological impacts have been
avoided or minimized to less than significant levels with implementation of the identified mitigation measures.
Response to Comment 1-2
The City’s HMP designates three Special Resource Areas (SRAs) citywide, and the project site is
located in SRA 1. Importantly, SRA 1 is not a hardline preserve or conservation easement
designated for permanent conservation; rather, it is an area recognized for biological importance
but largely comprised of private lands where development can occur as a covered activity under
the HMP, subject to certain requirements. The Biological Resources Technical Report explicitly
states, “The project site is a covered activity under the City of Carlsbad HMP and is located in
SRA 1. However, the project site is not within a HMP Hardline Conservation Area or HMP
Proposed Hardline Conservation Area.” This is also illustrated on Figure 5, Existing Hardline
Conservation Areas, and Figure 6, Proposed Hardline Conservation Areas, of Section D, Conservation Strategy, of the City HMP. Further, as illustrated on HMP Figure 28, Habitat
Management Plan, the project site is designated as a “Development Area,” not a “Conservation
Area.”1 This means that while the general area is known to have high biological value, the project
site, as well as areas located east, south, and west of the project site, were not set aside solely
for conservation under the HMP. In fact, the site is anticipated for development by the City (it was
previously graded in 2007 for a prior project and is also identified for residential development as
Site 7 in the City’s Housing Element; see also HMP Figure 28), and thus it is included as part of the HMP’s “covered projects” with specific mitigation obligations. Moreover, as stated in the City
HMP Appendix B, Section 2, Definitions, “Proposed Hardline Areas” is defined as, “Properties
whose conservation and development areas have been planned as part of the HMP, as depicted
on Figure 6… These areas have been agreed-upon in coordination with the landowners, the City,
U.S. Fish and Wildlife Service, and the California Department of Fish and Game [now known as
the California Department of Fish and Wildlife or CDFW].” In summary, the project site is not
identified in the HMP as a Core Area, Linkage Area, or Hardline Conservation Area and is not proposed for preservation by the City.
Therefore, the City does not consider the presence of an SRA designation – absent inclusion in
a preserve – to be equivalent to “lands identified for conservation” in the context of SB 131,
1 City of Carlsbad. Habitat Management Plan for Natural Communities in the City of Carlsbad. Final approved December 1999; as amended and approved November 2004. https://www.carlsbadca.gov/home/showpublisheddocument/1600/638366818940500000.
June 3, 2026 Item #1 143 of 417
especially since development within SRAs is allowed with mitigation. Since the project site is not
designated for conservation in the HMP, the near-miss eligibility condition under Government
Code Section 65913.4(a)(6)(I) is not triggered.
Response to Comment 1-3
As stated above, the City does not concur with the assertion that there are two (or more) separate
disqualifying conditions. Both the presence of multiple special-status species and the HMP SRA
context fall under the singular “biological resources” category for SB 131 purposes. Each of the
commenter’s concerns has been addressed through the focused biological analysis.
Neither the multi-species presence nor the SRA context creates a scenario where the project
would cause unmitigated significant impacts or where an Environmental Impact Report (EIR) would be required for biological resources. As stated in Response to Comment 1-2, a property
within an SRA does not automatically equate to a property being within a hardline preserve or
conservation easement designated for permanent conservation; rather, an SRA is an area
comprised of private lands where development can occur as a covered activity under the HMP,
subject to certain requirements. As stated in the project-specific Biological Resources Technical
Report, “The project site is a covered activity under the City of Carlsbad HMP and is located in
SRA 1. However, the project site is not within a HMP Hardline Conservation Area or HMP Proposed Hardline Conservation Area.”
As such, the SB 131 near-miss approach is appropriate for this project, given that all other CEQA
exemption criteria are met and the biological resources impacts have been reduced to a less than
significant level with mitigation.
Response to Comment 1-4
The IS/MND baseline was established through multiple steps: comprehensive literature and
database review, field habitat assessment, and analysis of focused surveys from previous projects. The IS/MND did not “conclude no significant impact” simply due to lack of data; rather,
it used all available data (including historical surveys and current habitat conditions) to inform its
significance determinations. In cases of uncertainty, the analysis erred on the side of caution by
assuming presence and built in appropriate mitigation measures accordingly. The City does not
consider this an inappropriate deferral, but a CEQA-compliant strategy to deal with potential
species presence.
Regarding Crotch’s bumble bee, a site-specific three-survey protocol design was approved by CDFW in April 2026. The three subsequent surveys were conducted in April and May 2026.
Crotch’s bumble bee was not detected in any of the three surveys and the negative findings were
reported to CDFW.
Response to Comment 1-5
The IS/MND’s determination of no significant impact regarding thread-leaved brodiaea is
supported by substantial evidence: (a) focused surveys conducted during the species’ bloom
period in 2001 and 2003 yielded negative results on what is now the project site; (b) the only
potential habitat—the 0.33-acre Diegan coastal sage scrub area—remains undeveloped and
would not be subject to grading; and (c) regional mitigation for brodiaea impacts under the Fox
Miller project has already been implemented. The City, however, acknowledges that the January
2025 survey was conducted outside the March-through-June blooming period and therefore
June 3, 2026 Item #1 144 of 417
cannot be solely relied upon for presence/absence determination. However, comprehensive
surveys from 2001 and 2003 did not detect thread-leaved brodiaea on what is now the project
site.
Moreover, grading and fill activities on site in 2007 likely removed or buried any suitable clay soils
required by this edaphic specialist species. According to the Biological Resources Technical
Report, the current site soils primarily consist of imported fill and loam, rather than the native clay
subsoil necessary for brodiaea viability.
Although the IS/MND considered the potential for occurrence as high within the Diegan coastal
sage scrub patch due to habitat characteristics and historical records, no significant impacts to
thread-leaved brodiaea was concluded based on the absence of documented individuals, the age of the critical habitat record, and preservation of the Diegan coastal sage scrub patch from project
disturbance. The current project does not affect areas known to host or conserve thread-leaved
brodiaea under the HMP.
Response to Comment 1-6
The commenter’s concern about the two-hour January 2025 survey is acknowledged. A single
survey would not typically show the use in all seasons; however, the City’s biologists relied on
evidence from current conditions, historical data, habitat suitability, and professional judgment. Most special-status species were excluded from further review in the IS/MND because the site
lacks suitable habitat or is outside their range—not just due to absence during one survey. The
Biological Resources Technical Report appendix lists these species with reasons for their
expected absence or low likelihood. The SB 131 review focused on resources likely present:
coastal California gnatcatcher, Crotch’s bumble bee, thread-leaved brodiaea, and the Diegan
coastal sage scrub habitat. The baseline characterization is considered sufficient as it highlights
the key issues addressed by mitigation and further study. As noted above in Response to Comment 1-4, subsequent protocol surveys for Crotch’s bumble bee were negative.
Response to Comment 1-7
A protocol survey was not conducted prior to finalizing the IS/MND. The January 2025 habitat
assessment confirmed the presence of at least one gnatcatcher on site, which established the
need for protective measures regardless of the precise number of individuals or nests. The City
acknowledges the USFWS Coastal California Gnatcatcher Presence/Absence Survey Protocol,
which generally recommends a minimum of six breeding-season survey visits between March 15
and June 30 to document territory boundaries, pair status, and nesting activity. However, it is
important to note that Carlsbad is within an area covered by a Natural Communities Conservation
Program (i.e., the City HMP) that covers coastal California gnatcatcher, and as such, only three
breeding-season survey visits would be required, rather than six. While protocol surveys provide
valuable data on territory boundaries, pair status, and nesting locations, confirmation of species
presence is sufficient to trigger protective mitigation under CEQA. Accordingly, the City is
assuming presence of coastal California gnatcatcher on-site. As stated in revised MM BIO-1 (refer
to Response to Comment 1-8), site-specific measures shall be implemented to avoid and
minimize impacts.
MM BIO-1 establishes clear performance standards to avoid and minimize indirect impacts to
gnatcatchers, including protection of active nests and limitation of construction-related
disturbance. The mitigation measure requires installation of a 500-foot no-disturbance buffer
June 3, 2026 Item #1 145 of 417
around any active coastal California gnatcatcher nest identified by a qualified biologist and
implementation of construction controls to ensure disturbance levels remain below thresholds that
could adversely affect nesting behavior. Consistent with USFWS guidance, these performance standards are intended to meet or exceed commonly recommended buffers and construction
noise limits during the breeding season, unless a qualified biologist determines that site-specific
conditions support an alternative protective distance or additional measures. The City
acknowledges that USFWS guidance commonly recommends a minimum 500-foot buffer around
active gnatcatcher nests and includes construction noise thresholds intended to limit disturbance during the breeding season. USFWS guidance also allows these buffers and noise controls to be
refined based on site-specific conditions, nest location, topography, intervening screening, and
the nature of construction activities. In no circumstances shall a buffer of less than 100 feet be
used even with noise attenuation measures. Any reduction in the 500-foot no-disturbance buffer
must be supported by site-specific analysis by the qualified biologist and approved by the City in consultation with USFWS. As a result, MM BIO-1 ensures that protective measures consistent
with USFWS recovery objectives will be implemented, and the absence of a pre-approval protocol
survey will not result in any unmitigated significant impact. Because the coastal California gnatcatcher is a covered species by the City HMP, the HMP holistically addresses species
concerns on a broader ecosystem scale. By establishing a citywide preserve system with core
areas interconnected with wildlife movement corridors, the City is protecting the gnatcatcher at
buildout and in perpetuity, while allowing development in appropriate places.
For other nesting bird species (other than the coastal California gnatcatcher), if active nests are
observed during the pre-construction nesting bird survey, an avoidance buffer shall be determined
by a qualified biologist in coordination with the City. The avoidance buffer width will depend upon the species, the proposed work activity, and existing disturbances associated with land uses
outside of the project site.
Response to Comment 1-8
MM BIO-1 was originally formulated to be flexible, recognizing that appropriate buffer distances
can depend on factors such as avian behavior, location of the nest, existing ambient noise, and
the nature of construction activity.
To directly address the concern raised, the City has updated MM BIO-1 (Pre-Construction Nesting Bird Surveys, Avoidance, and Notification) to require that, if a gnatcatcher nest is found during
pre-construction surveys, a minimum 500-foot wide no-disturbance buffer be established around
the nest and maintained until a qualified biologist confirms that the young have fledged, the nest
is no longer active, or that construction noise levels can be maintained below 60 dBA Leq at the
nest site with a smaller buffer. For purposes of this mitigation measure, a “qualified biologist” is
defined as a professional biologist with demonstrated experience conducting nesting bird surveys
in southern California coastal habitats and familiarity with the identification, behavior, and nesting ecology of avian species known to occur in the region, including federally listed species such as
the coastal California gnatcatcher. By incorporating these specifics – a numeric distance, noise
criteria, and biologist qualifications—MM BIO-1 would have clear performance standards.
Specifically, MM BIO-1 from the public review IS/MND stated:
MM BIO-1 Pre-Construction Bird Surveys, Avoidance, and Notification. If construction
activities are initiated during the bird nesting season (February 1–August 31)
involving removal of vegetation or other nesting bird habitat, including abandoned
June 3, 2026 Item #1 146 of 417
structures and other man-made features, a pre-construction nesting bird survey
shall be conducted no more than 14 days prior to initiation of ground disturbance
and vegetation removal activities. The nesting bird pre-construction survey shall be conducted on foot and shall include a 300-foot survey buffer around the
construction site. The survey shall be conducted by a biologist familiar with the
identification of avian species known to occur in southern California coastal
communities (i.e., qualified biologist). If active nests are found, an avoidance buffer
shall be determined by a qualified biologist in coordination with the City. The
avoidance buffer width will depend upon the species, the proposed work activity,
and existing disturbances associated with land uses outside of the site, which shall be demarcated by the biologist with bright orange construction fencing, flagging,
construction lathe, or other means to demarcate the boundary. All construction
personnel shall be notified as to the existence of the buffer zone and to avoid
entering the buffer zone during the nesting season. No ground-disturbing activities
shall occur within the buffer until the biologist has confirmed that breeding/nesting
is completed, and the young have fledged the nest. Encroachment into the buffer
shall occur only at the discretion of the qualified biologist on the basis that the encroachment will not be detrimental to an active nest. A report summarizing the
pre-construction survey(s) shall be prepared by a qualified biologist and shall be
submitted to the City prior to the commencement of construction activities.
Note: To mitigate the potential impact to California gnatcatcher or other nesting
birds, this mitigation measure shall be applied to land use and activities occurring
at the project site. No Pre-Construction Bird Surveys, Avoidance, and Notification
mitigation is required to implement the Study Area-Off-Site Sewer Line portion of the project.
MM BIO-1 has been revised as follows (the preconstruction survey window has been modified to
no sooner than three days prior to ground disturbance, and the second paragraph is newly added
text):
MM BIO-1 Pre-Construction Nesting Bird Surveys, Avoidance, and Notification. If
construction activities are initiated during the bird nesting season (February 1–
August 31) involving removal of vegetation or other nesting bird habitat, including abandoned structures and other man-made features, a pre-construction nesting
bird survey shall be conducted no more than three days prior to initiation of ground
disturbance and vegetation removal activities. The nesting bird pre-construction
survey shall be conducted on foot and shall include a 300-foot survey buffer around
the construction site. The survey shall be conducted by a biologist familiar with the
identification of avian species known to occur in southern California coastal
communities (i.e., qualified biologist). If active nests are found, an avoidance buffer
shall be determined by a qualified biologist in coordination with the City. The
avoidance buffer width will depend upon the species, the proposed work activity,
and existing disturbances associated with land uses outside of the site, which shall
be demarcated by the biologist with bright orange construction fencing, flagging,
construction lathe, or other means to demarcate the boundary. All construction
personnel shall be notified as to the existence of the buffer zone and to avoid
entering the buffer zone during the nesting season. No ground-disturbing activities shall occur within the buffer until the biologist has confirmed that breeding/nesting
June 3, 2026 Item #1 147 of 417
is completed, and the young have fledged the nest. Encroachment into the buffer
shall occur only at the discretion of the qualified biologist on the basis that the
encroachment will not be detrimental to an active nest. A report summarizing the pre-construction survey(s) shall be prepared by a qualified biologist and shall be
submitted to the City prior to the commencement of construction activities.
If an active coastal California gnatcatcher nest is found during pre-construction
surveys, a minimum 500-foot no-disturbance buffer shall be established around
the nest. The buffer shall be clearly marked (e.g., with fencing or flagging) and
maintained until a qualified biologist confirms that the young have fledged, the nest
is no longer active, or that construction noise levels can be maintained below 60 dBA Leq at the nest site with a smaller buffer. In no circumstances shall a buffer of
less than 100 feet be used even with noise attenuation measures. Any reduction
in the 500-foot buffer must be supported by site-specific analysis by the qualified
biologist and approved by the City in consultation with the US Fish and Wildlife
Service.
Note: To mitigate the potential impact to California gnatcatcher or other nesting
birds, this mitigation measure shall be applied to land use and activities occurring
at the project site. No Pre-Construction Nesting Bird Surveys, Avoidance, and
Notification mitigation is required to implement the Study Area-Off-Site Sewer Line
portion of the project.
It is also noted that such clarification to MM BIO-1 does not represent “significant new information”
as defined in CEQA Guidelines Section 15088.5. The revised MM BIO-1 is more effective than
that presented in the Draft IS/MND. Therefore, recirculation of the IS/MND prior to adoption is not
required (CEQA Guidelines Sections 15073.5[c][1] and 15074.1).
Response to Comment 1-9
The 0.33-acre Diegan coastal sage scrub patch located in the northwest corner of the site is
classified as a sensitive natural community. The IS/MND determined there was no impact on this
community because the project avoids any direct removal or disturbance of this Diegan coastal
sage scrub patch. Indirect impacts addressed in Threshold (f) included potential edge effects on
adjacent habitats according to the Carlsbad HMP Adjacency Standards. These standards apply
to any project next to a preserve or sensitive area and require actions to limit indirect effects like lighting, invasive species, noise, human activity, predator management, erosion, and hydrology.
These measures were built into the project’s design pursuant to the City’s HMP, Objective Design
Standards, and Landscape Manual and are detailed in the IS/MND, especially in the analysis of
HMP policy compliance and standard features. As a result, indirect impacts were not ignored—
rather, they were managed through commitments to protective measures.
To further clarify this issue, the City has updated the IS/MND so that Threshold (b) references the
HMP Adjacency Standards and related protective measures. Because these protections are part
of the project and would be enforced, the “no significant impact” finding remains valid: the project
would not significantly harm the nearby Diegan coastal sage scrub habitat, either directly or
indirectly. The habitat would be preserved, with adjacency protective measures guarding against
edge effects and preventing major degradation of this sensitive community.
June 3, 2026 Item #1 148 of 417
Response to Comment 1-10
Refer to Response to Comment 1-7. The City has carefully reviewed each of the commenter’s
cited potential indirect impacts to the gnatcatcher. One coastal California gnatcatcher was observed in 2025 in the 0.33-acre Diegan coastal sage scrub patch located in the northwest
corner of the site, which would be avoided by the project. The consulting biologist concluded that
the individual was transient, most likely residing in the more abundant and established habitat
opposite Salk Avenue and using the patch for foraging.
It is important to note that the coastal California gnatcatcher is a covered species by the City HMP,
and the HMP holistically addresses species concerns on a broader ecosystem scale. By
establishing a citywide preserve system with core areas interconnected with wildlife movement corridors, the City is protecting the gnatcatcher at buildout and in perpetuity, while allowing
development in appropriate places.
We provide responses to each point below:
• Predation by Domestic Cats: The risk of pet (particularly cat) predation on wildlife,
including to birds, is a known issue in urban-wildland interfaces. Coastal California
gnatcatchers primarily occupy coastal sage scrub characterized by dense, low-growing
shrub cover, where nests are typically placed several feet above ground within intact vegetation, limiting exposure to urban predators. Predation pressure documented for the
species is primarily associated with avian predators and habitat fragmentation, and
domestic cats are not identified by USFWS as a common or significant source of
gnatcatcher mortality.2 Additionally, predation by domestic cats on birds and other wildlife
is a recognized issue primarily associated with single-family residential development,
where cats can freely exit homes and roam yards and adjacent open space. In contrast,
a multi-level apartment building is inherently not conducive to free-roaming cats, as pets
cannot independently open doors or access elevators to enter or exit units. As a result,
cats residing in multi-family developments are predominantly, if not entirely, indoor pets,
substantially reducing the likelihood of access to adjacent habitat. Moreover, the HMP
Adjacency Standards explicitly require that projects adjacent to preserves implement
measures to manage pets and potential predators of developments adjacent to preserve
area. Consistent with these requirements, the project would include provisions to further minimize any already low potential for pets entering the adjacent habitat, including the
following:
o Resident Education: In compliance with the City’s HMP Adjacency standards, the
project applicant would provide educational materials (e.g., brochures or handbook
provisions) to all new residents informing them of the nearby sensitive habitat and
requiring cats be kept indoors, with outdoor access permitted only if leashed and
under direct supervision.
o Landscape Management: The project’s landscape plan would avoid planting
features that might inadvertently attract domestic animals to the habitat edge (e.g.,
no litter boxes near open space, no features that encourage house pets to roam
2 US Fish and Wildlife Service (USFWS). Coastal California Gnatcatcher Species Profile. https://www.fws.gov/story/coastal-california-gnatcatcher.
June 3, 2026 Item #1 149 of 417
near the preserve boundary). Additionally, it is noted that the habitat patch is
relatively small and bordered on two sides by existing development or roads. While
the City can manage pet-related risks through project design and adherence to the
City’s HMP, the project’s incremental contribution to domestic cat presence near
the preserve would be negligible.
• Brown-Headed Cowbird Brood Parasitism: Cowbirds (Molothrus ater) are known brood
parasites that can affect songbirds like the gnatcatcher by laying eggs in their nests. The
City acknowledges that the USFWS 1993 listing rule for the gnatcatcher identified cowbird
parasitism as a contributing threat, and the July 2025 Recovery Implementation Strategy,
which serves as an adaptable, action-oriented document under the USFWS’s three-part
framework, focusing on specific implementation actions to recover listed threatened or
endangered species, includes cowbird control as a Priority 3 recovery action (Action 7).
However, no substantial evidence supports the assertion that construction of an apartment
complex in the urbanized Carlsbad environment would measurably increase brown-headed cowbird brood parasitism on species (and specifically, the coastal California
gnatcatcher) in the on-site Diegan coastal sage scrub habitat. Neither the City’s HMP nor
the North County Multiple Habitat Conservation Program identifies cowbird predation as
a significant threat to gnatcatcher populations in this region. In fact, the HMP only mentions
cowbird control as a general preserve-wide management guideline alongside broader
edge-effect provisions—not as a species-specific threat for gnatcatcher in the plan area.
The commenter has provided no site-specific data—no cowbird abundance counts, nest parasitism rates, or monitoring results—to substantiate a causal link between the project
and a “substantial increase” in cowbird parasitism. Cowbird concentrations require large-
scale food subsidies (e.g., livestock feed, open agriculture, extensive lawns, etc.). Per project design, the proposed apartment complex in an urbanized area with fully enclosed
trash rooms, regularly scheduled trash removal, and no dumpsters accessible from the
outside would not create these conditions. As such, potential impacts under Threshold (f)
would remain less than significant.
• Habitat Connectivity and Fragmentation: The Focused IS/MND concluded that the project would have no impact on wildlife movement or migration corridors. This conclusion
was based on site-specific conditions: the project site is isolated by existing development
and roads, and is not part of any large, continuous wildlife corridor. The City acknowledges
the commenter’s citation to the USFWS Draft Recovery Plan for the Coastal California
Gnatcatcher (2025) and the Recovery Implementation Strategy. However, the HMP
describes SRA 1 (which includes the site) as “too small, edge-effected, or isolated to be
considered biological cores or linkage areas,” which supports the conclusion that the area
is not a critical transit corridor for wildlife. The Draft Recovery Plan (2025) emphasizes
maintaining connectivity between habitat patches for long-term species viability. The City
agrees that habitat connectivity is important at a landscape scale. However, in this case
the on-site habitat is extremely limited (0.33 acres) and bordered by existing urban
development. It is not part of a larger open space continuum; to the north is Salk Avenue
and a designated Hardline Preserve (from which it is separated by the road), and to the
south and east are developed parcels. To the west lies a golf course (maintained turf is not suitable gnatcatcher habitat). In essence, the project site’s Diegan coastal sage scrub
patch is an isolated “island” of habitat. As noted in the Biological Resources Technical
Report, “there are no landscape features or vegetative cover that would support wildlife
June 3, 2026 Item #1 150 of 417
movement... the site does not serve as a habitat linkage or wildlife corridor.” Further, as
previously stated in Responses to Comments 1-2 and 1-3, the project site is not identified
in the HMP as a Core Area, Linkage Area, or Hardline Conservation Area and is not proposed for preservation by the City.
Additionally, the project would not introduce new barriers such as wide roads or fencing
across any natural habitat that would impede wildlife movement. The building and
hardscape would be largely confined to the already graded pad. A final point of clarification
is that the broad north-south corridor identified in the MHCP regional framework is
associated with larger patches of habitat in the vicinity (e.g., around Lake Calavera,
riparian corridors, etc.), not with the SRA 1 patch at the project site. The USFWS Recovery Implementation Strategy Priority 2 actions that address enhancing connectivity in North
County are aimed at regional planning (connecting larger preserves), rather than
maintaining every minor fragment. By complying with the HMP, the City is contributing to
that larger connectivity goal through established preserves and mitigation banks.
Therefore, the IS/MND’s finding remains sound: the project would not significantly interfere
with wildlife movement or fragment an existing corridor. The on-site habitat patch will
maintain any limited role it has in connectivity. No additional mitigation is necessary because the project’s footprint does not intersect any identified corridor and because
standard HMP adjacency requirements (fencing, sensitive lighting, etc.) would ensure the
new development does not create undue edge effects that could exacerbate regional
fragmentation.
Response to Comment 1-11
The IS/MND addressed lighting through design commitments pursuant to the City’s Objective
Design Standards: all project outdoor light fixtures will be fully shielded, downward-facing, and directed away from the adjacent habitat, consistent with HMP requirements. Energy-efficient
fixtures incorporating light emitting diode (LED) lamps or equivalent energy-efficient fixtures would
be used for outdoor lights near the habitat. The project site is located within an urbanized area of
the City where existing nighttime conditions already include nighttime lighting associated with
nearby roadways and commercial/industrial development. As such, a five-story building with
windows and traditional light sources would not introduce lighting in an undisturbed natural
environment. With respect to building-related lighting and window glow, illumination would be consistent with other residential developments in the City. Lighting would be shielded, directed
downward, and limited to the minimum necessary for safety and security, reducing light spill and
skyglow. Vehicle headlights within the parking structure would be intermittent, contained within
the structure, and similar to conditions already present in other multi-story residential and
mixed-use developments. Given the urban context of the site, the absence of adjacent conserved
habitat, and compliance with applicable City development standards consistent with the HMP,
project lighting would not substantially alter existing nighttime conditions or result in adverse effects to wildlife. Accordingly, lighting impacts would be less than significant.
Response to Comment 1-12
The prevention of invasive non-native plant and animal introduction is another aspect of the HMP
Adjacency Standards that the project must follow. The project’s landscape plans will be reviewed
and approved by the City to ensure the plans meet the requirements set forth in the City’s
June 3, 2026 Item #1 151 of 417
Landscape Manual. No invasive plant species (as listed by California Invasive Plant Council or
the Carlsbad HMP) would be planted adjacent to the on-site open space. The project would use
only native or drought-tolerant, non-invasive landscaping for the areas near the habitat. The comment mentions irrigation overspray and fertilizer runoff as potential issues; the City’s standard
Storm Water Best Management Practices will address those concerns, requiring efficient irrigation
design (preventing overspray) and integrated pest management to avoid chemical runoff.
Additionally, the on-site 0.33-acre habitat patch would be buffered from the development by open
space and any necessary physical barriers, which reduces the chance of direct encroachment by
invasive plants.
Response to Comment 1-13
The project avoids direct impacts to the 0.33-acre patch of Diegan coastal sage scrub that
overlaps designated critical habitat for thread-leaved brodiaea, and no individuals of the species
have been observed on-site in past or current surveys. Additionally, the State Water Resources
Control Board has adopted General Permit No. CAS000002 – Waste Discharge Requirements
for Discharges of Storm Water Runoff Associated with Construction Activity (General Permit) for
California, which applies to most construction-related stormwater discharges within California.
The General Permit requires that projects disturbing greater than one acre develop and implement a Stormwater Pollution Prevention Plan that specifies best management practices (BMPs) to be
used during project construction. Implementation of the BMPs would ensure runoff and
discharges during the project construction phase would not violate any water quality standards.
Additionally, the project would be required to implement a project-specific Water Quality
Management Plan that identifies BMPs for the management of urban stormwater runoff, including
design criteria for treatment control. Compliance with the project-specific Stormwater Pollution
Prevention Plan and Water Quality Management Plan would ensure that construction-related and operational impacts on water quality would be less than significant.
Response to Comment 1-14
With regard to Crotch’s bumble bee habitat, the 0.33-acre area located in the northwest corner of
the site is the only place with any potential bumble bee habitat present, and that small area is not
being developed as part of the project. When the IS/MND refers to “lack of suitable nectaring and
nesting habitat” in the context of direct impacts, it is referring to the fact that within the project’s
construction footprint (i.e., the areas to be graded or built upon), there are no high-quality nectar sources or intact soils for bumble bees. All such resources are in the small 0.33-acre area to be
left untouched. Thus, no direct mortality or physical destruction of a bumble bee nest is anticipated
from construction, supporting the statement that direct impacts are not expected. Additionally, as
noted in Response to Comment 1-4, CDFW-approved protocol surveys were conducted in April
and May 2026 and Crotch’s bumble bee was not detected.
Response to Comment 1-15
The IS/MND and Biological Resources Technical Report are consistent in stating that the project
site lies within the geographical boundaries of SRA 1 but that the property itself is not an HMP
conservation area. The IS/MND and the Biological Resources Technical Report have been
revised to clarify this point. Refer also to Response to Comment 1-2. These changes would not
result in a new significant impact and do not represent “significant new information” as defined in
CEQA Guidelines Section 15088.5. Therefore, recirculation of the IS/MND prior to adoption is not
required (CEQA Guidelines Section 15073.5[c][1]).
June 3, 2026 Item #1 152 of 417
Response to Comment 1-16
The 0.33-acre Diegan coastal sage scrub patch is indeed a central feature in the project’s
biological considerations. Far from minimizing its importance, the City’s analysis recognized it as environmentally sensitive and made it the cornerstone of the mitigation strategy through
avoidance and protective measures. The following points highlight how the IS/MND addressed
the resources associated with this limited area:
• The site plan was deliberately designed to exclude the 0.33-acre Diegan coastal sage
scrub habitat from development. By not building on this area, the project would avoid direct
impacts to Diegan coastal sage scrub, gnatcatcher habitat, and any species using that
habitat. Avoidance is the most effective mitigation, and it was the first measure applied.
• One coastal California gnatcatcher was observed in 2025 in the 0.33-acre Diegan coastal
sage scrub patch located in the northwest corner of the site, which would be avoided by the project. The consulting biologist concluded that the individual was transient, most likely
residing in the more abundant and established habitat opposite Salk Avenue and using
the patch for foraging. The IS/MND requires seasonal avoidance of the area if nesting is
observed during preconstruction nesting bird surveys and buffering it from construction
disturbance (refer to MM BIO-1). The adequacy of the buffer and mitigation has been
addressed above in Response to Comment 1-7.
• The Diegan coastal sage scrub patch’s role as potential Crotch’s bumble bee habitat and
thread-leaved brodiaea critical habitat has been addressed in Responses to Comments 1-4, 1-5, and 1-14. The patch would not be disturbed. CDFW-approved protocol surveys
were conducted in April and May 2026 and Crotch’s bumble bee was not detected.
• The patch is within SRA 1; however, it is not designated in the City HMP as a permanent
conservation site. As illustrated on HMP Figure 28, Habitat Management Plan, the project site is designated as a “Development Area,” not a “Conservation Area.” The HMP
specifically calls out the importance of conserving Brodiaea filifolia in SRA 1; however, no
thread-leaved brodiaea populations are known to exist in the patch. Nevertheless, the
project’s avoidance would keep the habitat available.
• The presumed “no impact” finding for indirect effects on the patch is not a dismissal of
those effects, but rather a reflection that, with standard project design features in place
and adherence to the City’s development requirements, including the City HMP, City
Objective Design Standards, and City Landscape Manual, indirect effects would be rendered less than significant (see above). Responses to Comments 1-9 through 1-13
above detail how issues like lighting, noise, pets, and runoff are being managed for this
patch. The key protective City requirements built into project design include buffering,
shielding (for light), controlling human and pet access, and monitoring.
In summary, the City does not agree that there was a “systematic minimization” of this feature’s
importance. On the contrary, a primary focus of the analysis relates to the 0.33-acre patch and
the species it may support. Further, the mitigation measures (MM BIO-1 and MM BIO-2) are aimed at protecting the resources in or adjacent to this area. The project’s avoidance of the patch is a
strong protective step.
June 3, 2026 Item #1 153 of 417
Response to Comment 1-17
The City acknowledges CDFW’s role as a responsible agency with regard to a potential ITP for
Crotch’s bumble bee (which is currently a candidate species under the California Endangered Species Act). CDFW approved of a site-specific Crotch’s bumble bee survey protocol consisting
of three surveys spaced at least two weeks apart. The surveys were conducted in April and May
2026 with no bees detected.
Response to Comment 1-18
The City does not concur that there was a “systematic bias” in the analysis. On the contrary, the
approach was science-based and precautionary. When in doubt, the analysis presumed the
resource may be present or impacted and required mitigation accordingly. Additionally, as stated in Response to Comment 1-2, the site was previously graded in 2007 for a prior project and is
also identified for residential development as Site 7 in the City’s Housing Element (see also HMP
Figure 28), and thus was analyzed for environmental affects in the City’s Housing Element
Implementation and Public Safety Element Update Supplemental EIR. Further, the project site is
included as part of the HMP “covered projects” with specific mitigation obligations. The absence
of identified significant impacts in the project-specific IS/MND is a result of effective project design
and mitigation, not a failure to look for impacts. The City would carry forward all commitments made in the IS/MND and in these responses into the final project approval and monitoring
requirements. Therefore, an EIR is not warranted for biological resources, as the IS/MND provides
a complete and adequate analysis of potential impacts and mitigation measures for the site’s
biological issues.
Response to Comment 1-19
The City believes that a fully informed, good-faith revised analysis of the project’s biological
resources has been achieved without the need for an EIR. After implementing the avoidance and mitigation measures – many of which are built into the project by design and adhere to the City’s
development requirements, including the City HMP, City Objective Design Standards, and City
Landscape Manual – impacts on biological resources are not significant. For instance, no
sensitive habitat would be removed; listed species are either absent or would be protected in
place if present; and indirect effects from the new development on adjacent habitat are avoided
or reduced through proven measures (lighting controls, noise reduction, invasive species
management, etc.). Refer also to Responses to Comments 1-1 through 1-3.
Response to Comment 1-20
Please refer to Response to Comment 1-7 above for reasoning why protocol-level gnatcatcher
surveys are not required for the project. Refer to Response to Comment 1-5 for the explanation
why current blooming-period surveys for thread-leaved brodiaea within the designated critical
habitat is not necessary. See Response to Comment 1-4 regarding the comment about requiring
pre-approval focused surveys for Crotch’s bumble bee. Refer to Responses to Comments 1-9
through 1-13 regarding the analysis of indirect impacts related to predation, cowbird parasitism, artificial lighting, altered hydrology, invasive species, and habitat connectivity. See Response to
Comment 1-8 regarding the commenter’s previous comment on enforceable mitigation measures.
June 3, 2026 Item #1 154 of 417
Response to Comment 1-21
Tribal Consultation was initiated with all tribes consulting with the City under AB 52 on January 5,
2026. Consultation was requested by the Rincon Band of Luiseño Indians and conducted through a series of letters and meetings. The City coordinated with the tribe, and an agreement was made
that the tribe will provide tribal cultural monitoring during ground-disturbing construction activities
associated with the project. As such, AB 52 consultation has concluded. Refer to Response to
Comment 1-4 regarding Crotch’s bumble bee concerns.
June 3, 2026 Item #1 155 of 417
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
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June 3, 2026 Item #1 156 of 417
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
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FRQW
June 3, 2026 Item #1 157 of 417
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
5IHPQ!?7@@/1:!Q/N!5#.9!I=/13/!IA#$:@/1:>!8$7Y/%:!"#$%&!'()!'*'+!
8#;/!F!7B!J!
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FRQW
June 3, 2026 Item #1 158 of 417
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
5IHPQ!?7@@/1:!Q/N!5#.9!I=/13/!IA#$:@/1:>!8$7Y/%:!"#$%&!'()!'*'+!
8#;/![!7B!J!
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FRQW
June 3, 2026 Item #1 159 of 417
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
5IHPQ!?7@@/1:!Q/N!5#.9!I=/13/!IA#$:@/1:>!8$7Y/%:!"#$%&!'()!'*'+!
8#;/!G!7B!J!
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FRQW
June 3, 2026 Item #1 160 of 417
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
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FRQW
June 3, 2026 Item #1 161 of 417
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
Comment Letters and Responses to Comments
Salk Avenue Apartments Project
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1
Shawn Smallwood, PhD
3108 Finch Street
Davis, CA 95616
Attn: Kyle Van Leeuwen, Senior Planner
City of Carlsbad
Community Development Department
1635 Faraday Avenue
Carlsbad, California 92008
20 March 2026
RE: Salk Avenue Apartments Project
Dear Mr. Van Leeuwen,
I write to comment on potential impacts to biological resources that would result from
development of the proposed Salk Avenue Apartments Project. The project would add
397 apartment units within a 59-foot-tall, five-story building grossing 416,152 square
feet and 541 parking spaces on 9.8 acres on the south side of Salk Avenue in between
College Blvd and El Camino Real in Carlsbad, California. My comments that follow
address my concerns that the Focused Initial Study/Mitigated Negative Declaration
(IS/MND) supported by Michael Baker International (MBI 2026), mischaracterizes the
existing environmental setting, and that its impacts analysis is flawed and its mitigation
measures are inadequate.
My qualifications for preparing expert comments are the following. I hold a Ph.D.
degree in Ecology from University of California at Davis, where I also worked as a post-
graduate researcher in the Department of Agronomy and Range Sciences. My research
has been on animal density and distribution, habitat selection, wildlife interactions with
the anthrosphere, and conservation of rare and endangered species. I authored many
papers on these and other topics. I served as Chair of the Conservation Affairs
Committee for The Wildlife Society – Western Section. I am a member of The Wildlife
Society, and I’ve lectured part-time at California State University, Sacramento. I was
Associate Editor of wildlife biology’s premier scientific journal, The Journal of Wildlife
Management, as well as of Biological Conservation, and I was on the Editorial Board of
Environmental Management. I have performed wildlife surveys in California for thirty-
seven years. My CV is attached.
THE WILDLIFE COMMUNITY AS A BIOLOGICAL RESOURCE
Most environmental reviews pursuant to the California Environmental Quality Act
(CEQA) focus on special-status species because CEQA’s Checklist Evaluation of
Environmental Impacts specifies that such evaluation should prioritize potential
impacts to special-status species. However, an important policy of CEQA is “to prevent
the elimination of fish or wildlife species due to man’s activities, insure that fish and
wildlife populations do not drop below self-perpetuating levels, and preserve for future
generations representations of all plant and animal communities and examples of the
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major periods of California history.” Pub. Res. Code § 21001(c). Seemingly at odds with
the Checklist Evaluation’s specification, this policy is not restricted to special-status
species; it also applies to wildlife populations and plant and animal communities. In
fact, the CEQA Guidelines Section 21155.1 defines wildlife habitat as “the ecological
communities upon which wild animals, birds, plants, fish, amphibians, and
invertebrates depend for their conservation and protection.” This definition is consistent
with the scientific definition of habitat, which is that portion of the environment that is
used by members of a species for survival and reproduction (Hall et al. 1997). An
essential portion of the environment used by any special-status species is composed of
the collection of other species of plants and wildlife, because these species provide for
special-status species their forage, refugia and nest substrates, and some serve as
ecological mutualists; no special-status species can exist in a vacuum of other wildlife.
The CEQA Checklist Evaluation assigns priority to special-status species to balance
information and cost, but it does not exclude the need to evaluate environmental
impacts to other species, which, after all, are members of the very communities within
which special-status species inter-depend for survival and reproduction.
All wildlife species should be of concern in a CEQA review, but with priority directed to
special-status species. The species I consider to be special-status species are those listed
in California’s Special Animals List inclusive of threatened and endangered species
under the California and federal Endangered Species Acts, candidates for listing under
CESA and FESA, California’s Fully Protected Species, California species of special
concern, and California’s Taxa to Watch List (https://nrm.dfg.ca.gov/FileHandler.ashx?
DocumentID=109406), continental and region-specific US Fish and Wildlife Service
Birds of Conservation Concern (https://www.fws.gov/sites/default/files/documents/
birds-of-conservation-concern-2021.pdf), and naturally rare species such as raptors
protected by California’s Birds of Prey laws, Fish and Game Code Sections 3503, 3503.5,
3505 and 3513 (see https://wildlife.ca.gov/Conservation/ Birds/Raptors).
What follows is a summary of a site visit to detect as many of the species of wildlife as
possible within the short time available. The survey was also intended to detect as many
of the special-status species as possible, but with the understanding that most special-
status species are less readily detectable due to rarity and crypticity. Nonetheless, the
species detected can indicate the ecological integrity of the site and thus the likelihood of
occurrence of special-status species not yet detected.
SITE VISIT
On my behalf, Noriko Smallwood, a wildlife biologist with a Master of Science Degree
from California State University Los Angeles, visited the site of the proposed project for
3 hours of survey from 07:00 to 09:00 hours on 11 March 2026. Noriko walked the site’s
perimeter where accessible, stopping to scan for wildlife with use of binoculars. Noriko
recorded all species of vertebrate wildlife she detected, including those whose members
flew over the site or were seen just off the site. Animals of uncertain species identity
were either recorded to the Genus or higher taxonomic level.
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Conditions were sunny with 4 MPH north wind and temperatures of 51-64° F. The site
has been previously graded and contains annual grassland, coastal sage scrub, and
riparian vegetation (Photos 1 and 2)
Noriko saw Allen’s hummingbird and Anna’s hummingbird (Photos 3 and 4), red-
shouldered hawk and red-tailed hawk (Photos 5 and 6), double-crested cormorant and
ring-billed gull (Photos 7 and 8), American crow and Cassin’s kingbird (Photos 9 and
10), northern mockingbird (Photo 11), California scrub-jay and cedar waxwing (Photos
12 and 13), California towhee and spotted towhee (Photos 14 and 15), orange-crowned
warbler and house wren (Photos 16 and 17), wrentit and white-crowned sparrow (Photos
18 and 19), song sparrow (Photo 20), and lesser goldfinch and hooded oriole (Photos 21
and 22). Noriko detected 37 species of vertebrate wildlife at or adjacent to the project
site, including seven species with special status (Table 1).
Photos 1 and 2. Views of the project site, 11 March 2026. Photos by Noriko
Smallwood.
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Photos 3 and 4. Allen’s hummingbird (left), and Anna’s hummingbird (right) on the project site, 11 March 2026. Photos by Noriko Smallwood.
Photos 5 and 6. Red-shouldered hawk eating a prey item (left), and red-tailed hawk
(right) on the project site, 11 March 2026. Photos by Noriko Smallwood.
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Photos 7 and 8. Double-crested cormorant (left), and ring-billed gull (right) on the
project site, 11 March 2026. Photos by Noriko Smallwood.
Photos 9 and 10. American crow with nest material (left), and Cassin’s kingbird
(right) on the project site, 11 March 2026. Photos by Noriko Smallwood.
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Photo 11. Northern mockingbird on the project site, 11 March 2026. Photo by Noriko Smallwood.
Photos 12 and 13. California scrub-jay (left), and cedar waxwings (right) on the
project site, 11 March 2026. Photos by Noriko Smallwood.
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Photos 14 and 15. California towhees (left), and spotted towhee (right) on the project site, 11 March 2026. Photos by Noriko Smallwood.
Photos 16 and 17. Orange-crowned warbler (left), and house wren (right) on the project site, 11 March 2026. Photos by Noriko Smallwood.
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Photos 18 and 19. Wrentit (left), and white-crowned sparrow (right) on the project
site, 11 March 2026. Photos by Noriko Smallwood.
Photo 20. Song sparrow with a caterpillar on the project site, 11 March 2026. Photo
.
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Photos 21 and 22. Lesser goldfinch with nest material (top), and hooded oriole
(bottom) on the project site, 11 March 2026. Photos by Noriko Smallwood.
Noriko Smallwood certifies that the foregoing and following survey results are true and
accurately reported.
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Table 1. Wildlife that Noriko observed in 3 hours of survey on the project site, 11 March 2026.
Common name Species name Status1 Notes
Great Basin fence lizard
Sceloporus occidentalis
longipes
Eurasian collared-dove Streptopelia decaocto Non-native
Mourning dove Zenaida macroura
White-throated swift Aeronautes saxatalis Flock
Anna’s hummingbird Calypte anna
Allen’s hummingbird Selasphorus sasin BCC Foraged, displayed
Killdeer Charadrius vociferus
Ring-billed gull Larus delawarensis Flew over
Double-crested cormorant Nannopterum auritum WL, CSD2 Flew over
Great egret Ardea alba Flew over
Cooper’s hawk Accipiter cooperii WL, BOP, CSD1 Flew over just off site
Red-shouldered hawk Buteo lineatus BOP, CSD1 Ate prey item
Red-tailed hawk Buteo jamaicensis BOP
Cassin’s kingbird Tyrannus vociferans
Swinhoe’s white eye Zosterops simplex Non-native
California scrub-jay Aphelocoma californica
American crow Corvus brachyrhynchos Gathered nest material
Tree swallow Tachycineta bicolor Just off site
Bushtit Psaltriparus minimus Foraged
Wrentit Chamaea fasciata BCC Sang, foraged
Cedar waxwing Bombycilla cedrorum Many
California gnatcatcher Polioptila c. californica FT, SSC2, CSD1 Just off site
Bewick’s wren Thryomanes bewickii
Northern house wren Troglodytes aedon
Northern mockingbird Mimus polyglottos
House finch Haemorphous mexicanus
Lesser goldfinch Spinus psaltria Gathered nest material
Dark-eyed junco Junco hyemalis
White-crowned sparrow Zonotrichia leucophrys Foraged
Song sparrow Melospiza melodia Foraged
California towhee Melozone crissalis Copulated
Spotted towhee Pipilo maculatus Foraged
Hooded oriole Icterus cucullatus Foraged
Brown-headed cowbird Molothrus ater Flew over
Orange-crowned warbler Oreothlypis celata Just off site
Yellow-rumped warbler Setophaga coronata
Botta’s pocket gopher Thomomys bottae Burrows
1 Listed on CDFW’s Special Animals List (https://nrm.dfg.ca.gov/FileHandler.ashx?
DocumentID=109406) as FT = federal threatened; SSCi = California Species of Special Concern
with i = priorities 1, 2 and 3; WL = CDFW’s Taxa to Watch List; BCC = U.S. Fish and Wildlife
Service’s Bird of Conservation Concern (https://www.fws.gov/sites/default/files/documents/birds-
of-conservation-concern-2021.pdf); and BOP = protected by Birds of Prey (California Fish and
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Table 1. Wildlife that Noriko observed in 3 hours of survey on the project site, 11 March 2026.
Common name Species name Status1 Notes
Great Basin fence lizard
Sceloporus occidentalis longipes
Eurasian collared-dove Streptopelia decaocto Non-native
Mourning dove Zenaida macroura
White-throated swift Aeronautes saxatalis Flock
Anna’s hummingbird Calypte anna
Allen’s hummingbird Selasphorus sasin BCC Foraged, displayed
Killdeer Charadrius vociferus
Ring-billed gull Larus delawarensis Flew over
Double-crested cormorant Nannopterum auritum WL, CSD2 Flew over
Great egret Ardea alba Flew over
Cooper’s hawk Accipiter cooperii WL, BOP, CSD1 Flew over just off site
Red-shouldered hawk Buteo lineatus BOP, CSD1 Ate prey item
Red-tailed hawk Buteo jamaicensis BOP
Cassin’s kingbird Tyrannus vociferans
Swinhoe’s white eye Zosterops simplex Non-native
California scrub-jay Aphelocoma californica
American crow Corvus brachyrhynchos Gathered nest material
Tree swallow Tachycineta bicolor Just off site
Bushtit Psaltriparus minimus Foraged
Wrentit Chamaea fasciata BCC Sang, foraged
Cedar waxwing Bombycilla cedrorum Many
California gnatcatcher Polioptila c. californica FT, SSC2, CSD1 Just off site
Bewick’s wren Thryomanes bewickii
Northern house wren Troglodytes aedon
Northern mockingbird Mimus polyglottos
House finch Haemorphous mexicanus
Lesser goldfinch Spinus psaltria Gathered nest material
Dark-eyed junco Junco hyemalis
White-crowned sparrow Zonotrichia leucophrys Foraged
Song sparrow Melospiza melodia Foraged
California towhee Melozone crissalis Copulated
Spotted towhee Pipilo maculatus Foraged
Hooded oriole Icterus cucullatus Foraged
Brown-headed cowbird Molothrus ater Flew over
Orange-crowned warbler Oreothlypis celata Just off site
Yellow-rumped warbler Setophaga coronata
Botta’s pocket gopher Thomomys bottae Burrows
1 Listed on CDFW’s Special Animals List (https://nrm.dfg.ca.gov/FileHandler.ashx?
DocumentID=109406) as FT = federal threatened; SSCi = California Species of Special Concern
with i = priorities 1, 2 and 3; WL = CDFW’s Taxa to Watch List; BCC = U.S. Fish and Wildlife
Service’s Bird of Conservation Concern (https://www.fws.gov/sites/default/files/documents/birds-
of-conservation-concern-2021.pdf); and BOP = protected by Birds of Prey (California Fish and
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Game Code 3503.5, see https://wildlife.ca.gov/Conservation/Birds/Raptors); CSD1 = Group 1
species on County of San Diego Sensitive Animal List (County of San Diego 2010).
ANALYSIS OF RECONNAISSANCE SURVEY DATA
Noriko detected 37 species of vertebrate willdife, which was a large number for the
brevity of her survey effort. All the species in Table 1 would lose habitat as the result of
the project and its replacement of natural ground covers with impervious surfaces.
Smallwood and Smallwood (2023) confirmed this habitat loss by measuring the impacts
of similar developments on species richness and the abundances of wildlife. Smallwood
and Smallwood (2023) directly compared the species and the numbers of animals
observed prior to development to the those observed after development, while they did
the same at control sites. The measured losses of these species resulting from
development is indicative of habitat loss, because habitat is defined as that portion of
the environment that is used for survival and reproduction by members of a species
(Hall et al. 1997), and this use is inferred by observations of the presence of a species
(Smallwood 2002).
However, the species of wildlife Noriko detected at the project site were not the only
species that were present during her survey, as there are always species that are not
detected. To demonstrate this, I fit nonlinear regression models to Noriko’s
accumulation of first detections of vertebrate wildlife species with time into her daytime
surveys to predict the number of species that she would have detected with longer
surveys or perhaps with additional biologists available to assist her. The type of model is
a logistic growth model, which reaches an asymptote that corresponds with the
theoretical maximum number of vertebrate wildlife species that could have been
detected during the survey. The model fit to Noriko’s survey data from the morning of 11
March predicts 48 species of vertebrate wildlife were available to be detected, or 11 more
species than she detected that morning (Figure 1). Noriko’s rate of species detections
exceeded the upper bound of the 95% confidence interval estimated from many other
morning surveys we have completed in southcoast California environments.
Unknown are the identities of the species Noriko missed, but the species that Noriko did
and did not detect on composed only a fraction of the species that would occur at the
project site over the period of a year or longer. This is because many species are seasonal
in their occurrence, some require more survey effort because they are highly cryptic, and
the members of other species would visit the site only periodically while patrolling large
home ranges. Surveys on only two days cannot possibly detect all of the species of the
local wildlife community.
At least a year’s worth of surveys would be needed to more accurately report the number
of vertebrate species that occur at the project site, but I only have Noriko’s one survey.
However, by use of an analytical bridge, a modeling effort applied to a large, robust data
set from a research site can predict the number of vertebrate wildlife species that likely
make use of the site over the longer term. This analytical bridge draws inference from
the pattern of species detections more than it does from the research site, and I note
that the pattern, i.e., rate, of species detections is consistent from site to site.
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Figure 1. Actual and predicted
relationships
between the
numbers of
vertebrate wildlife
species detected
and the elapsed
survey time based on Noriko’s visual-
scan surveys on 11
March 2026. Note
the confidence
interval (orange)
applies only to the
morning survey
(red line).
As part of my research, I completed a much larger survey effort across 167 km2 of annual
grasslands of the Altamont Pass Wind Resource Area, where from 2015 through 2019 I
performed 721 1-hour visual-scan surveys, or 721 hours of surveys, at 46 stations. I used
binoculars and otherwise the methods were the same as the methods I and other
consulting biologists use for surveys at proposed project sites. At each of the 46 survey
stations, I tallied new species detected with each sequential survey at that station, and
then related the cumulative species detected to the hours (number of surveys, as each
survey lasted 1 hour) used to accumulate my counts of species detected. I used combined
quadratic and simplex methods of estimation in Statistica to estimate least-squares,
best-fit nonlinear models of the number of cumulative species detected regressed on
hours of survey (number of surveys) at the station: 𝑅�=������×(�����)� , where 𝑅�
represented cumulative species richness detected. The coefficients of determination, r2,
of the models ranged 0.88 to 1.00, with a mean of 0.97 (95% CI: 0.96, 0.98); or in other
words, the models were excellent fits to the data.
I projected the predictions of each model to thousands of hours to find predicted
asymptotes of wildlife species richness. The mean model-predicted asymptote of species
richness was 57 after 11,857 hours of visual-scan surveys among the 46 stations of my
research site. I also averaged model predictions of species richness at each incremental
increase of number of surveys, i.e., number of hours (Figure 2). On average I would have
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Minutes into survey
0
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Model prediction; r2 = 0.98
95% CI of morning surveys in region 2018‒2025
Actual count of species
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detected 12.7 species over my first 3 hours of diurnal surveys at my research site in the
Altamont Pass (3 hours to match the 3 hours Noriko surveyed during daylight hours at
the project site), which composed 22.3% of the predicted total number of species I
would detect with a much larger survey effort at the research site. Given the example
illustrated in Figure 2, the 37 diurnally active species Noriko detected after her 3 hours
of daylight survey at the project site likely represented 22.3% of the species to be
detected after many more visual-scan surveys over another year or longer. With many
more repeat surveys through the year, Noriko would likely detect 37 0.223� =166
species of vertebrate wildlife in daylight surveys at the site. Assuming Noriko’s ratio of
special-status to non-special-status species was to hold through the detections of all 166
predicted species, then continued daylight surveys would eventually detect 31 special-
status species of vertebrate wildlife.
Because my prediction of 166 species of vertebrate wildlife, including 31 special-status
species, is derived from daytime visual-scan surveys, and would detect few nocturnal
mammals such as bats, the true number of species composing the wildlife community of
the site must be larger. Noriko’s reconnaissance survey should serve only as a starting
point toward characterization of the site’s wildlife community, but it certainly cannot
alone inform of the inventory of species that use the site. More surveys are needed than
her one survey to produce an inventory the project site’s wildlife community.
Nevertheless, the large number of species I predict at the project site is indicative of a
relatively species-rich wildlife community that warrants a serious survey effort.
Figure 2. Mean (95% CI)
predicted wildlife species
richness, 𝑅�, as a nonlinear
function of hour-long
survey increments across
46 visual-scan survey
stations across the
Altamont Pass Wind
Resource Area, Alameda
and Contra Costa
Counties, 2015‒2019. Note
that the location of the
study is largely irrelevant
to the utility of the graph
to the interpretation of
survey outcomes at the
project site. It is the
pattern in the data that is
relevant, because the
pattern is typical of the
pattern seen elsewhere. 0 20 40 60 80 1000
10
20
30
40
50
Cumulative number of surveys (hours)
(9
5
%
C
I
)
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EXISTING ENVIRONMENTAL SETTING
The first step in analysis of potential project impacts to biological resources is to
accurately characterize the existing environmental setting, including the wildlife
community and any key ecological relationships and known and ongoing threats to
special-status species. A reasonably accurate characterization of the environmental
setting can provide the baseline from which to analyze potential project impacts. For
these reasons, characterization of the environmental setting, including the project site’s
regional setting, is one of the CEQA’s essential analytical steps. Methods to achieve this
first step typically include (1) surveys of the site for biological resources, and (2) reviews
of literature, occurrence databases and local experts to help predict the occurrences of
special-status species. In the case of the proposed project, these steps were taken,
though not with sufficient rigor, and not interpreted in furtherance of an accurate
characterization of the wildlife community.
Environmental Setting informed by Field Surveys
To CEQA’s primary objective to disclose potential environmental impacts of a proposed
project, the analysis should be informed of which biological species are known to occur
at the proposed project site, which special-status species are likely to occur, and the
limitations of the survey effort directed to the site. Analysts need this information to
characterize the environmental setting as a basis for opining on, or predicting, potential
project impacts to biological resources. In the case of this project, however, more
surveys were needed, as were more appropriate interpretations of the survey findings.
MBI (2026) conducted a reconnaissance survey on 24 January 2026 “to document
existing conditions, conduct a habitat assessment for special-status plant and wildlife
species and sensitive natural communities, and determine the presence of aquatic
resources within the project site.” MBI (2026) deployed two biologists who committed 4
person-hours starting at 08:30, and they detected 21 species of vertebrate wildlife.
In comparison to MBI’s 21 species detected in 4 person-hours, Noriko detected 37
species of vertebrate wildlife at or immediately adjacent to the project site in 3 hours.
MBI detected seven species that Noriko did not, and Noriko detected 23 species that
MBI did not. With Noriko Smallwood’s survey, the total number of vertebrate wildlife
species detected on the project site increases to 44, or more than twice the number
MBI’s biologists detected. Noriko’s additional species detections suggest that the project
site supports many more species yet to be detected. The accumulation of species
detections remains in the early growth phase.
MBI’s vertebrate wildlife species tally was slightly fewer than the average from among
consultants who survey for wildlife at project sites, whereas Noriko detected 7 more
than we average at project sites (Figure 3). MBI’s tally of special-status species of
vertebrate wildlife equaled the average among consultant surveys, whereas Noriko
detected one more than we average (Figure 3). This type of comparative analysis is
missing from MBI (2026), but it is needed to understand the meaning of the survey
results.
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Figure 3. Frequency distribution of the number of vertebrate wildlife species detected
by consulting biologists (left graph) and by me and Noriko (right graph) among
project sites that were surveyed in support of environmental reviews in California.
Figure 4. Frequency distribution of the number of special-status species of wildlife
detected by consulting biologists (left graph) and by me and Noriko (right graph)
among project sites that were surveyed in support of environmental reviews.
0 20 40 60 80 100 120 140 160 180 200
Vertebrate wildlife species detected
0
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e
c
t
s
i
t
e
s
= 22.8
= 30.3
Salk Ave Apts (21)
Salk Ave Apts (37)
Vertebrate wildlife species detected
0 5 10 15 20 25 30 35 400
20
40
60
80
100
Special-status species of vertebrate wildlife detected
Consultants
Nu
m
b
e
r
o
f
p
r
o
j
e
c
t
s
i
t
e
s
0 2 4 6 8 10 12 14 16 18 20 22 24 26 280
10
20
30
40
50
60
70
80
Special-status species of vertebrate wildlife detected
Smallwoods
Nu
m
b
e
r
o
f
p
r
o
j
e
c
t
s
i
t
e
s
= 4
= 6
Salk Ave Apts (4)Salk Ave Apts (7)
FRQW
June 3, 2026 Item #1 180 of 417
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16
Three comparative contexts are needed to fully disclose the meanings of survey findings
in the IS/MND. The first is to contextualize the survey findings relative to the survey
effort, because otherwise it is misleading to insinuate that the species detected were
definitive of the wildlife community. As Figures 1 and 2 demonstrate, additional surveys
contribute to greater accuracy in the characterization of the wildlife community,
eventually obtaining the species inventory. (An inventory may not be necessary, but it
helps to disclose the approximate number of species yet to be detected.) That Noriko
could survey briefly and still more than double the number of vertebrate wildlife species
from MBI’s 21 species means that there are many more species yet to be detected. As I
commented above, by analytically bridging Noriko’s survey data to a more extensive
research survey effort, I predict 166 species of vertebrate wildlife, inclusive of 31 special-
status species, and these are the tallies expected of only diurnal surveys. Adding
nocturnal surveys would increase these numbers substantially, as many mammals,
reptiles and amphibians and some birds are active mostly at night.
The second comparative context is to compare the survey findings on the project site to
survey findings from other sites of proposed projects or at sites that can serve as
reference sites. Figures 3 and 4 exemplify this comparative context, as do the confidence
intervals in Figures 1 and 2. Another example can be found in Figure 5, which compares
Noriko’s findings to hundreds of other survey results at other proposed project sites,
developed sites, and at relatively intact “references sites,” but it does so relative to the
survey effort. This approach is more informative than the other comparative contexts
because it factors in survey effort.
The third comparative context is to assess the probabilities of detection considering the
survey effort of each special-status species, whether detected or not. MBI (2026) reports
having failed to detect most special-status species that could conceivably occur on the
project site, but what do these failures to detect species really mean? Each species
presents survey personnel with a unique range of detection probabilities, but the
IS/MND fails to discuss this, and instead gives the false impression that field surveys
are equal in their ikelihoods to detect any and all species of vertebrate wildlife. For any
given species, the likelihood it would be detected varies with survey effort and distance
from known activity areas, among other factors. Many animals maintain home ranges
that are larger than most project sites, and they periodically shift their foraging activities
to various parts of their home range, hence occurring on a particular site only
periodically. To detect these species, survey personnel must be at the site on the same
date and time as the one or more members of the species. Therefore, the probability of
detection during any given survey is less than 100%.
FRQW
June 3, 2026 Item #1 181 of 417
Comment Letters and Responses to Comments
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Comment Letters and Responses to Comments
Salk Avenue Apartments Project 17
Figure 5. Noriko Smallwood’s survey findings at the Salk Ave Apartments Project site
relative to our survey findings at other project sites (red), at developed sites (black),
and at more pristine sites that we survey as reference sites (green). Noriko’s findings
exceed the upper bound of the 95% confidence interval based on the results of hundreds
of surveys at project sites, and they almost reach the lower bound of the 95% CI from
many surveys at reference sites.
For example, knowing that the nearest eBird occurrence record of white-tailed kite was
within 1.5 miles from the project site, Noriko’s survey effort of 3 hours afforded her a 9%
likelihood of detection of white-tailed kite (Figure 6). Noriko would have needed to
conduct another 9 surveys to accumulate a reasonable likelihood of detecting white-
tailed kite, but the model fit to the data indicates that with more surveys she would
eventually detect white-tailed kite on the project site. Assuming for the sake of argument
that the skills of MBI’s biologists were equal to Noriko’s, then the model predicts MBI’s
likelihood of detection of white-tailed kite is 11%, or not much greater than Noriko’s
detection probability. Both Noriko and MBI stood a low likelihood of detection of white-
tailed kite, but this does not mean that white-tailed kites are unlikely to occur on the
site. There is a fundamental difference between detection likelihood and occurrence
likelihood, but this difference is not mentioned or discussed in MBI (2026).
0 50 100 150 200 250 300
Minutes into survey
0
10
20
30
40
50
60 Early morning surveys for vertebrate wildlife
Reference sites
Proposed project sites
Developed sites
Me
a
n
(
9
5
%
C
I
)
c
u
m
u
l
a
t
i
v
e
s
p
e
c
i
e
s
d
e
t
e
c
t
e
d
Noriko’s morning tally of 37 vertebrate
wildlife species at Salk Ave
FRQW
June 3, 2026 Item #1 182 of 417
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Salk Avenue Apartments Project 18
Figure 6. Probability of
detection of white-
tailed kite as a
function of survey
effort and proximity
of occurrence records
to a project site, based
on hundreds of reconnaissance
surveys we completed
2019–2024.
This third comparative context is very important because it is the basis for the
formulation of detection survey protocols. Experienced biologists are aware of survey
limitations due to ranges of variation in the activity periods, levels of crypticity, and
periodic movement patterns of wildlife species, and due to variation in the skill and
commitment of survey personnel. This third comparative context acknowledges that the
occurrence likelihood of a species on a particular site is rarely if ever zero, so long as the
site is within the species’ geographic range and it provides habitat. This third
comparative context reveals that a determination of zero likelihood of occurrence is
typically indicative of insufficient survey effort. A common goal of detection survey
protocols is to support absence determinations with a survey effort that should have
resulted in a detection if the species had been present at the time of the surveys, but it
does not prove that the species is always absent from the site. This third comparative
context and its implications should not be neglected in CEQA review, but in the case of
the IS/MND prepared for this Project, it is entirely neglected.
As for detection surveys, none were implemented on the project site. No breeding-
season detection surveys were implemented for burrowing owl as recommended by
CDFW (2012), none were implemented for candidate species of bumble bee as
recommended by CDFW (2023), and none were implemented for rare plants as
Log10 Survey hours
-0.6 -0.2 0.2 0.6 1.0 1.4 1.8 2.2
0.2
0.4
0.6
0.8
1.0
0
Pr
o
b
a
b
i
l
i
t
y
o
f
d
e
t
e
c
t
i
o
n
1.5 and 40 miles
Within 1.5 miles
On site or adjacent
Nearest eBird records
White-tailed kite Elanus leucurus
California Fully Protected
0.4 158410 Hours1
P = 0.09
FRQW
June 3, 2026 Item #1 183 of 417
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Comment Letters and Responses to Comments
Salk Avenue Apartments Project 19
recommended by CDFW (2018). A meandering 2-hoour walk by two biologists could not
have effectively substituted for protocol-level detection surveys.
In summary, MBI detected the usual number of wildlife species that consultants detect
in surveys conducted in support of CEQA review, but Noriko’s survey brings the species
tally to 44 species of vertebrate wildlife, and it indicates many more occur there but have
yet to be documented. It is delinquent of MBI (2026) to have reported its findings
without any comparative context to aid in interpretation. At least a fair argument can be
made for the need to prepare an EIR so that a sufficient survey effort can be completed
and its results appropriately interpreted and reported.
Environmental Setting informed by Desktop Review
The purpose of literature and database reviews and of consulting with local experts is to
inform the field survey, and to augment interpretation of its outcome. Analysts need this
information to identify which species are known to have occurred at or near the project
site, and to identify which other special-status species could conceivably occur at the site
due to geographic range overlap and migration flight paths. In the case of this project,
the desktop review was incomplete, and the review that was completed was distorted to
minimalize the likelihoods of occurrence of special-status species.
To establish its pool of special-status species for assessment of occurrence likelihoods,
MBI (2026) queried the California Natural Diversity Data Base (CNDDB) for occurrence
records within eight USGS 7.5’ Quadrangles. However, the CNDDB is a volunteer
positive-sightings database, and as such it is useful for confirming presence but not for
confirming absence of species because such databases are not designed for this purpose.
As noted by the CNDDB, “The CNDDB is a positive sighting database. It does not
predict where something may be found. We map occurrences only where we have
documentation that the species was found at the site. There are many areas of the state
where no surveys have been conducted and therefore there is nothing on the map. That
does not mean that there are no special status species present.” MBI (2026) and hence
the IS/MND misuse the CNDDB.
The CNDDB relies entirely on volunteer reporting from biologists who were allowed
access to whatever properties they report from. Many properties have never been
surveyed by biologists. Many properties have been surveyed, but the survey outcomes
never reported to the CNDDB. Many properties have been surveyed multiple times, but
not all survey outcomes reported to the CNDDB. Furthermore, the CNDDB is interested
only in the findings of special-status species, which means that species more recently
assigned special status will have been reported many fewer times to the CNDDB than
were species assigned special status since the inception of the CNDDB. Therefore,
occurrence records in the CNDDB are most abundant for species assigned special status
decades ago, but fewest for species only recently assigned special status. And because
negative findings are not reported to the CNDDB, the CNDDB is also inappropriate as a
basis for weighting occurrence likelihoods such as absent, not expected, unlikely, low,
moderate or high. Whereas the CNDDB can be confirmatory of species presence, it
cannot support absence determinations or assignments of low likelihood of occurrence.
FRQW
June 3, 2026 Item #1 184 of 417
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And again, the screening out of a species due to lack of occurrence records in the
CNDDB is the same as an absence determination, and this step is being taken without
adequate support of field surveys.
In my assessment based on a database review and site visits, 143 special-status species
of wildlife are known to occur near enough to the site to warrant analysis of occurrence
potential (Table 2). Not all these species should be expected to occur at the project site,
but each of them should be given a closer look to determine occurrence likelihoods and
whether additional surveys are needed, or implementation of detection surveys, or
whether it would be reasonable to assume presence. Of these 143 species, 8 (6%) were
recorded on or just off the project site, and another 47 (33%) species have been
documented within 1.5 miles of the site (Very close), another 43 (30%) between 1.5 and
4 miles (Nearby), and another 39 (27%) between 4 to 30 miles (In region). Two thirds
(69%) of the species in Table 2 have been reportedly seen within 4 miles of the project
site. The site therefore supports at least eight special-status species of wildlife, and it
carries the potential for supporting many more special-status species of wildlife based
on the proximities of recorded occurrences. Evidence certainly suggests that habitat
assessments are needed for these species.
MBI (2026) considers the occurrence likelihoods of only 46 (32%) of the special-status
species listed in Table 2, which means that 97 (68%) of the special-status species in
Table 2 were screened out of the analysis in the first step of the desktop review. Of the
46 species considered, all but two were determined to be “not expected” to occur on the
project site. Of the species determined to be “not expected,” one of them, Cooper’s hawk,
was observed just off the project site, another 13 species have been documented within
1.5 miles of the project site, and another 12 species have been documented within 4
miles of the project site. In summary, MBI’s occurrence likelihood determinations
comport poorly with the data.
Mischaracterization of the Wildlife Community
MBI (2026) reports on a field survey and a desktop review having been performed, but
the field survey results are interpreted without any context to survey results from
elsewhere, and the desktop review starts with an inappropriately small pool of special-
status species after misusing the CNDDB. MBI (2026) often resorts to speculation in its
analyses of occurrence likelihoods, having not completed surveys appropriate to bats
and burrowing owls, and having committed too little survey effort overall. Speculated
habitat assessments are highly uncertain, which is inappropriate for precious or rare
resources such as special-status species (National Research Council 1986). The true
wildlife community remains to be described with sufficient accuracy. Without a more
accurate characterization of the wildlife community, the basis is inadequate for
predicting impacts and formulating appropriate mitigation strategies.
At least a fair argument can be made for the need to prepare and EIR to accurately
characterize the wildlife community of the projects site as a suitable baseline from which
to predict project impacts and to formulate an appropriate mitigation strategy.
FRQW
10 Table 1. Wildlife that Noriko observed in 3 hours of survey on the project site, 11 March 2026. Common name Species name Status1 Notes Great Basin fence lizard Sceloporus occidentalis longipes Eurasian collared-dove Streptopelia decaocto Non-native Mourning dove Zenaida macroura White-throated swift Aeronautes saxatalis Flock Anna’s hummingbird Calypte anna Allen’s hummingbird Selasphorus sasin BCC Foraged, displayed Killdeer Charadrius vociferus Ring-billed gull Larus delawarensis Flew over Double-crested cormorant Nannopterum auritum WL, CSD2 Flew over Great egret Ardea alba Flew over Cooper’s hawk Accipiter cooperii WL, BOP, CSD1 Flew over just off site Red-shouldered hawk Buteo lineatus BOP, CSD1 Ate prey item Red-tailed hawk Buteo jamaicensis BOP Cassin’s kingbird Tyrannus vociferans Swinhoe’s white eye Zosterops simplex Non-native California scrub-jay Aphelocoma californica American crow Corvus brachyrhynchos Gathered nest material Tree swallow Tachycineta bicolor Just off site Bushtit Psaltriparus minimus Foraged Wrentit Chamaea fasciata BCC Sang, foraged Cedar waxwing Bombycilla cedrorum Many California gnatcatcher Polioptila c. californica FT, SSC2, CSD1 Just off site Bewick’s wren Thryomanes bewickii Northern house wren Troglodytes aedon Northern mockingbird Mimus polyglottos House finch Haemorphous mexicanus Lesser goldfinch Spinus psaltria Gathered nest material Dark-eyed junco Junco hyemalis White-crowned sparrow Zonotrichia leucophrys Foraged Song sparrow Melospiza melodia Foraged California towhee Melozone crissalis Copulated Spotted towhee Pipilo maculatus Foraged Hooded oriole Icterus cucullatus Foraged Brown-headed cowbird Molothrus ater Flew over Orange-crowned warbler Oreothlypis celata Just off site Yellow-rumped warbler Setophaga coronata Botta’s pocket gopher Thomomys bottae Burrows 1 Listed on CDFW’s Special Animals List (https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=109406) as FT = federal threatened; SSCi = California Species of Special Concern with i = priorities 1, 2 and 3; WL = CDFW’s Taxa to Watch List; BCC = U.S. Fish and Wildlife Service’s Bird of Conservation Concern (https://www.fws.gov/sites/default/files/documents/birds-of-conservation-concern-2021.pdf); and BOP = protected by Birds of Prey (California Fish and FRQW
June 3, 2026 Item #1 185 of 417
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Table 2. Occurrence likelihoods of special-status species of wildlife at or near the proposed project site, according to eBird/iNaturalist records (https://eBird.org, https://www.inaturalist.org) and on-site survey findings, where ‘Very close’ indicates within 1.5 miles of the
site, “nearby” indicates within 1.5 and 4 miles, and “in region” indicates within 4 and 30 miles, and ‘in range’ means the species’
geographic range overlaps the site. MSCP cover refers to whether incidental take of the species is covered by the San Diego Multiple
Species Conservation Program. Entries in bold font identify species detected by Noriko Smallwood during her site visit.
Common name Species name Status1
MSCP
Vernal pool fairy shrimp Branchinecta lynchi FT In region
San Diego fairy shrimp Branchinecta sandiegonensis FE, CSD1 Yes Not expected In region
Riverside fairy shrimp Streptocephalus woottoni FE Yes Not expected In region
Wandering skipper Panoquina errans CSD1 Nearby
Quino checkerspot butterfly Euphydryas editha quino FE, CSD1 Yes In region
Monarch Danaus plexippus FC, CSD2 Not expected Very close
Crotch’s bumble bee Bombus crotchii CCE Moderate Very close
Western spadefoot Spea hammondii SSC, CSD2 Yes Not expected Nearby
Southwestern pond turtle Actinemys pallida FC, SSC Yes Not expected In region
San Diego banded gecko Coleonyx variegatus abbotti SSC, CSD1 In region
Coast horned lizard Phrynosoma blainvillii SSC, CSD2 Yes Not expected Nearby
Coronado skink Plestiodon skiltonianus
interparietalis
WL, CSD2 Not expected In region
Orange-throated whiptail Aspidoscelis hyperythra WL, CSD2 Yes Not expected In region
Coastal whiptail Aspidoscelis tigris stejnegeri SSC, CSD2 Not expected Very close
San Diegan legless lizard Anniella stebbinsi SSC Not expected Nearby
Coastal rosy boa Lichanura orcutti CSD2 Nearby
California glossy snake Arizona elegans occidentalis SSC, CSD2 Not expected In region
San Diego ringneck snake Diadophis punctatus similis CSD2 Nearby
Coast patchnose snake Salvadora hexalepis virgultea SSC, CSD2 Not expected In region
Two-striped gartersnake Thamnophis hammondii SSC, CSD1 Yes Not expected Nearby
South coast garter snake Thamnophis sirtalis pop. 1 SSC, CSD2 Not expected In region
Red diamond rattlesnake Crotalus ruber SSC, CSD2 Yes Not expected Very close
Brant Branta bernicla SSC2 Nearby
Cackling goose (Aleutian) Branta hutchinsii leucopareia WL Nearby
21
Table 2. Occurrence likelihoods of special-status species of wildlife at or near the proposed project site, according to eBird/iNaturalist
records (https://eBird.org, https://www.inaturalist.org) and on-site survey findings, where ‘Very close’ indicates within 1.5 miles of the
site, “nearby” indicates within 1.5 and 4 miles, and “in region” indicates within 4 and 30 miles, and ‘in range’ means the species’
geographic range overlaps the site. MSCP cover refers to whether incidental take of the species is covered by the San Diego Multiple
Species Conservation Program. Entries in bold font identify species detected by Noriko Smallwood during her site visit.
Common name Species name Status1
MSCP
cover
Occurrence likelihood
MBI (2026) Records, Surveys
Vernal pool fairy shrimp Branchinecta lynchi FT In region
San Diego fairy shrimp Branchinecta sandiegonensis FE, CSD1 Yes Not expected In region
Riverside fairy shrimp Streptocephalus woottoni FE Yes Not expected In region
Wandering skipper Panoquina errans CSD1 Nearby
Quino checkerspot butterfly Euphydryas editha quino FE, CSD1 Yes In region
Monarch Danaus plexippus FC, CSD2 Not expected Very close
Crotch’s bumble bee Bombus crotchii CCE Moderate Very close
Western spadefoot Spea hammondii SSC, CSD2 Yes Not expected Nearby
Southwestern pond turtle Actinemys pallida FC, SSC Yes Not expected In region
San Diego banded gecko Coleonyx variegatus abbotti SSC, CSD1 In region
Coast horned lizard Phrynosoma blainvillii SSC, CSD2 Yes Not expected Nearby
Coronado skink Plestiodon skiltonianus
interparietalis
WL, CSD2 Not expected In region
Orange-throated whiptail Aspidoscelis hyperythra WL, CSD2 Yes Not expected In region
Coastal whiptail Aspidoscelis tigris stejnegeri SSC, CSD2 Not expected Very close
San Diegan legless lizard Anniella stebbinsi SSC Not expected Nearby
Coastal rosy boa Lichanura orcutti CSD2 Nearby
California glossy snake Arizona elegans occidentalis SSC, CSD2 Not expected In region
San Diego ringneck snake Diadophis punctatus similis CSD2 Nearby
Coast patchnose snake Salvadora hexalepis virgultea SSC, CSD2 Not expected In region
Two-striped gartersnake Thamnophis hammondii SSC, CSD1 Yes Not expected Nearby
South coast garter snake Thamnophis sirtalis pop. 1 SSC, CSD2 Not expected In region
Red diamond rattlesnake Crotalus ruber SSC, CSD2 Yes Not expected Very close
Brant Branta bernicla SSC2 Nearby
Cackling goose (Aleutian) Branta hutchinsii leucopareia WL Nearby
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Common name Species name Status1 MSCP
Moffitt’s Canada goose Branta canadensis moffitti CSD2 In region
Redhead Aythya americana SSC2, CSD2 Very close
Western grebe Aechmophorus occidentalis BCC, CSD1 Nearby
Clark’s grebe Aechmophorus clarkii BCC Nearby
Western yellow-billed cuckoo Coccyzus americanus occidentalis FT, CE, CSD1 Not expected Very close
Black swift Cypseloides niger SSC3, BCC, CSD2 Very close
Vaux’s swift Chaetura vauxi SSC Very close
Calliope hummingbird Selasphorus calliope BCC Nearby
Rufous hummingbird Selasphorus rufus BCC Very close
Allen’s hummingbird Selasphorus sasin BCC Present Very close/
Light-footed Ridgway’s rail Rallus obsoletus levipes FE, CE, CFP Not expected Nearby
Mountain plover Charadrius montanus SSC2, BCC, CSD2 In region
Snowy plover Charadrius nivosus BCC Nearby
Western snowy plover Charadrius nivosus nivosus FT, SSC Not expected In region
Long-billed curlew Numenius americanus WL, CSD2 Nearby
Marbled godwit Limosa fedoa BCC Nearby
Red knot (Pacific) Calidris canutus BCC Nearby
Short-billed dowitcher Limnodromus griseus BCC Nearby
Willet Tringa semipalmata BCC Nearby
Laughing gull Leucophaeus atricilla WL, CSD2 Nearby
Heermann’s gull Larus heermanni BCC Nearby
Western gull Larus occidentalis BCC Very close
California gull Larus californicus BCC, WL, CSD2 Very close
California least tern Sternula antillarum browni FE, CE, CFP, CSD1 Not expected Very close
Gull-billed tern Gelochelidon nilotica BCC, SSC3 Nearby
Black tern Chlidonias niger SSC2, BCC, CSD2 Nearby
Elegant tern Thalasseus elegans BCC, WL, CSD1 Nearby
Black skimmer Rynchops niger BCC, SSC3, CSD1 Nearby
Common loon Gavia immer SSC, CSD2 Nearby
FRQW
22
Common name Species name Status1
MSCP
cover
Occurrence likelihood
MBI
(2026)
Records,
Surveys
Moffitt’s Canada goose Branta canadensis moffitti CSD2 In region
Redhead Aythya americana SSC2, CSD2 Very close
Western grebe Aechmophorus occidentalis BCC, CSD1 Nearby
Clark’s grebe Aechmophorus clarkii BCC Nearby
Western yellow-billed cuckoo Coccyzus americanus occidentalis FT, CE, CSD1 Not expected Very close
Black swift Cypseloides niger SSC3, BCC, CSD2 Very close
Vaux’s swift Chaetura vauxi SSC Very close
Calliope hummingbird Selasphorus calliope BCC Nearby
Rufous hummingbird Selasphorus rufus BCC Very close
Allen’s hummingbird Selasphorus sasin BCC Present Very close/On
site
Light-footed Ridgway’s rail Rallus obsoletus levipes FE, CE, CFP Not expected Nearby
Mountain plover Charadrius montanus SSC2, BCC, CSD2 In region
Snowy plover Charadrius nivosus BCC Nearby
Western snowy plover Charadrius nivosus nivosus FT, SSC Not expected In region
Long-billed curlew Numenius americanus WL, CSD2 Nearby
Marbled godwit Limosa fedoa BCC Nearby
Red knot (Pacific) Calidris canutus BCC Nearby
Short-billed dowitcher Limnodromus griseus BCC Nearby
Willet Tringa semipalmata BCC Nearby
Laughing gull Leucophaeus atricilla WL, CSD2 Nearby
Heermann’s gull Larus heermanni BCC Nearby
Western gull Larus occidentalis BCC Very close
California gull Larus californicus BCC, WL, CSD2 Very close
California least tern Sternula antillarum browni FE, CE, CFP, CSD1 Not expected Very close
Gull-billed tern Gelochelidon nilotica BCC, SSC3 Nearby
Black tern Chlidonias niger SSC2, BCC, CSD2 Nearby
Elegant tern Thalasseus elegans BCC, WL, CSD1 Nearby
Black skimmer Rynchops niger BCC, SSC3, CSD1 Nearby
Common loon Gavia immer SSC, CSD2 Nearby
FRQW
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Common name Species name Status1 MSCP
Wood stork Mycteria americana SSC1, CSD2 In region
Brandt’s cormorant Urile penicillatus BCC Nearby
Double-crested cormorant Phalacrocorax auritus WL, CSD2 Very close/
American white pelican Pelacanus erythrorhynchos SSC1, CSD2 Very close
Least bittern Ixobrychus exilis SSC2, CSD2 Not expected Nearby
Great blue heron Ardea herodias CSD2 Very close
Reddish egret Egretta rufescens CSD2 Nearby
Green heron Butorides striatus CSD2 Very close
White-faced ibis Plegadis chihi WL, CSD1 Yes Not expected Very close
Turkey vulture Cathartes aura BOP, CSD1 Very close
Osprey Pandion haliaetus WL, BOP, CSD1 Yes Very close
White-tailed kite Elanus leucurus CFP, BOP, CSD1 Not expected Very close
Golden eagle Aquila chrysaetos BGEPA, BOP, WL,
CFP, CSD1
Yes Not expected In region
Northern harrier Circus cyaneus SSC3, BCC, BOP, CSD1 Yes Not expected Very close
Sharp-shinned hawk Accipiter striatus WL, BOP, CSD1 Very close
Cooper’s hawk Accipiter cooperi WL, BOP, CSD1 Not expected Very
close/Just off
Bald eagle Haliaeetus leucocephalus CE, BGEPA, BOP CSD1 Nearby
Red-shouldered hawk Buteo lineatus BOP, CSD1 Very close/
Swainson’s hawk Buteo swainsoni CT, BOP, CSD1 Not expected Very close
Zone-tailed hawk Buteo albonotatus BOP Very close
Red-tailed hawk Buteo jamaicensis BOP Present Very close/
Ferruginous hawk Buteo regalis BOP, WL, CSD1 Nearby
American barn owl Tyto furcata BOP, CSD2 Very close
Western screech-owl Megascops kennicotti BOP Very close
FRQW
22
Common name Species name Status1
MSCP
cover
Occurrence likelihood
MBI
(2026)
Records,
Surveys
Moffitt’s Canada goose Branta canadensis moffitti CSD2 In region
Redhead Aythya americana SSC2, CSD2 Very close
Western grebe Aechmophorus occidentalis BCC, CSD1 Nearby
Clark’s grebe Aechmophorus clarkii BCC Nearby
Western yellow-billed cuckoo Coccyzus americanus occidentalis FT, CE, CSD1 Not expected Very close
Black swift Cypseloides niger SSC3, BCC, CSD2 Very close
Vaux’s swift Chaetura vauxi SSC Very close
Calliope hummingbird Selasphorus calliope BCC Nearby
Rufous hummingbird Selasphorus rufus BCC Very close
Allen’s hummingbird Selasphorus sasin BCC Present Very close/On
site
Light-footed Ridgway’s rail Rallus obsoletus levipes FE, CE, CFP Not expected Nearby
Mountain plover Charadrius montanus SSC2, BCC, CSD2 In region
Snowy plover Charadrius nivosus BCC Nearby
Western snowy plover Charadrius nivosus nivosus FT, SSC Not expected In region
Long-billed curlew Numenius americanus WL, CSD2 Nearby
Marbled godwit Limosa fedoa BCC Nearby
Red knot (Pacific) Calidris canutus BCC Nearby
Short-billed dowitcher Limnodromus griseus BCC Nearby
Willet Tringa semipalmata BCC Nearby
Laughing gull Leucophaeus atricilla WL, CSD2 Nearby
Heermann’s gull Larus heermanni BCC Nearby
Western gull Larus occidentalis BCC Very close
California gull Larus californicus BCC, WL, CSD2 Very close
California least tern Sternula antillarum browni FE, CE, CFP, CSD1 Not expected Very close
Gull-billed tern Gelochelidon nilotica BCC, SSC3 Nearby
Black tern Chlidonias niger SSC2, BCC, CSD2 Nearby
Elegant tern Thalasseus elegans BCC, WL, CSD1 Nearby
Black skimmer Rynchops niger BCC, SSC3, CSD1 Nearby
Common loon Gavia immer SSC, CSD2 Nearby
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Common name Species name Status1 MSCP
Great-horned owl Bubo virginianus BOP Very close
Burrowing owl Athene cunicularia CCE, BCC, SSC2, BOP,
CSD1
Yes Nearby
Long-eared owl Asio otus BCC, BOP, SSC3, CSD1 In region
Short-eared owl Asia flammeus BCC, SSC3, BOP, CSD2 Nearby
Lewis’s woodpecker Melanerpes lewis BCC, CSD1 Nearby
Nuttall’s woodpecker Picoides nuttallii BCC Present Very close/On
site (MB)
American kestrel Falco sparverius BOP Very close
Merlin Falco columbarius WL, BOP, CSD2 Very close
Peregrine falcon Falco peregrinus BOP, CSD1 Very close
Prairie falcon Falco mexicanus WL, BOP, CSD1 In region
Olive-sided flycatcher Contopus cooperi BCC, SSC2, CSD2 Very close
Willow flycatcher Empidonax trailii CE Very close
Southwestern willow flycatcher Empidonax traillii extimus FE, CE Yes Not expected In region
Vermilion flycatcher Pyrocephalus rubinus SSC2, CSD1 Very close
Least Bell’s vireo Vireo belli pusillus FE, CE, CSD1 Yes Not expected Very close
Loggerhead shrike Lanius ludovicianus SSC2, CSD1 Very close
Oak titmouse Baeolophus inornatus BCC Very close
California horned lark Eremophila alpestris actia WL, CSD2 Very close
Bank swallow Riparia riparia CT, CSD1 Not expected Nearby
Purple martin Progne subis SSC2, CSD1 Very close
Wrentit Chamaea fasciata BCC Very
close/Just off
California gnatcatcher Polioptila c. californica FT, SSC2, CSD1 Yes Present Very close/On
site
(MB)/Just
Clark’s marsh wren Cistothorus palustris clarkae SSC2 In range
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22
Common name Species name Status1
MSCP
cover
Occurrence likelihood
MBI
(2026)
Records,
Surveys
Moffitt’s Canada goose Branta canadensis moffitti CSD2 In region
Redhead Aythya americana SSC2, CSD2 Very close
Western grebe Aechmophorus occidentalis BCC, CSD1 Nearby
Clark’s grebe Aechmophorus clarkii BCC Nearby
Western yellow-billed cuckoo Coccyzus americanus occidentalis FT, CE, CSD1 Not expected Very close
Black swift Cypseloides niger SSC3, BCC, CSD2 Very close
Vaux’s swift Chaetura vauxi SSC Very close
Calliope hummingbird Selasphorus calliope BCC Nearby
Rufous hummingbird Selasphorus rufus BCC Very close
Allen’s hummingbird Selasphorus sasin BCC Present Very close/On
site
Light-footed Ridgway’s rail Rallus obsoletus levipes FE, CE, CFP Not expected Nearby
Mountain plover Charadrius montanus SSC2, BCC, CSD2 In region
Snowy plover Charadrius nivosus BCC Nearby
Western snowy plover Charadrius nivosus nivosus FT, SSC Not expected In region
Long-billed curlew Numenius americanus WL, CSD2 Nearby
Marbled godwit Limosa fedoa BCC Nearby
Red knot (Pacific) Calidris canutus BCC Nearby
Short-billed dowitcher Limnodromus griseus BCC Nearby
Willet Tringa semipalmata BCC Nearby
Laughing gull Leucophaeus atricilla WL, CSD2 Nearby
Heermann’s gull Larus heermanni BCC Nearby
Western gull Larus occidentalis BCC Very close
California gull Larus californicus BCC, WL, CSD2 Very close
California least tern Sternula antillarum browni FE, CE, CFP, CSD1 Not expected Very close
Gull-billed tern Gelochelidon nilotica BCC, SSC3 Nearby
Black tern Chlidonias niger SSC2, BCC, CSD2 Nearby
Elegant tern Thalasseus elegans BCC, WL, CSD1 Nearby
Black skimmer Rynchops niger BCC, SSC3, CSD1 Nearby
Common loon Gavia immer SSC, CSD2 Nearby
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Common name Species name Status1 MSCP
San Diego cactus wren Campylorhynchs brunneicapillus
sandiegensis
SSC1, CSD1 Yes Not expected Nearby
California thrasher Toxostoma redivivum BCC Very close
Western bluebird Sialia mexicana CSD2 Very close
Cassin’s finch Haemorhous cassinii BCC In region
Lawrence’s goldfinch Spinus lawrencei BCC Very close
Grasshopper sparrow Ammodramus savannarum SSC2, CSD1 Yes Nearby
Black-chinned sparrow Spizella atrogularis BCC In region
Bell’s sparrow Amphispiza b. belli WL, CSD1 Yes In region
Oregon vesper sparrow Pooecetes gramineus affinis SSC2 In range
Belding’s savannah sparrow Passerculus sandwichensis beldingi CE, BCC, CSD1 Not expected Nearby
Large-billed savannah sparrow Passerculus sandwichensis rostratus SSC2, CSD2 In region
Southern California rufous-
crowned sparrow
Aimophila ruficeps canescens WL, CSD1 Yes Not expected Very close
Yellow-breasted chat Icteria virens SSC3, CSD1 Yes Not expected Very close
Yellow-headed blackbird Xanthocephalus xanthocephalus SSC3 Very close
Bullock’s oriole Icterus bullockii BCC Very close
Tricolored blackbird Agelaius tricolor CT, BCC, SSC1, CSD1 Yes Not expected Nearby
Lucy’s warbler Leiothlypis luciae SSC3, CSD1 Very close
Virginia’s warbler Leiothlypis virginiae WL, BCC Nearby
Northern yellow warbler Setophaga aestiva SSC2, CSD2 Not expected Very close
Summer tanager Piranga rubra SSC1, CSD2 Very close
Pallid bat Antrozous pallidus SSC, WBWG H, CSD2 Yes Not expected In region
Townsend’s big-eared bat Corynorhinus townsendii SSC, WBWG:H, CSD2 Yes Not expected In region
Spotted bat Euderma maculatum SSC, WBWG H, CSD2 In region
California leaf nosed bat Macrotus californicus SSC, WBWG H, CSD2 In region
Western red bat Lasiurus blossevillii SSC, WBWG H, CSD2 In region
Hoary bat Lasiurus cinereus WBWG M Nearby
Western yellow bat Lasiurus xanthinus SSC, WBWG H In region
Small-footed myotis Myotis cililabrum WBWG M, CSD2 In region
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22
Common name Species name Status1
MSCP
cover
Occurrence likelihood
MBI
(2026)
Records,
Surveys
Moffitt’s Canada goose Branta canadensis moffitti CSD2 In region
Redhead Aythya americana SSC2, CSD2 Very close
Western grebe Aechmophorus occidentalis BCC, CSD1 Nearby
Clark’s grebe Aechmophorus clarkii BCC Nearby
Western yellow-billed cuckoo Coccyzus americanus occidentalis FT, CE, CSD1 Not expected Very close
Black swift Cypseloides niger SSC3, BCC, CSD2 Very close
Vaux’s swift Chaetura vauxi SSC Very close
Calliope hummingbird Selasphorus calliope BCC Nearby
Rufous hummingbird Selasphorus rufus BCC Very close
Allen’s hummingbird Selasphorus sasin BCC Present Very close/On
site
Light-footed Ridgway’s rail Rallus obsoletus levipes FE, CE, CFP Not expected Nearby
Mountain plover Charadrius montanus SSC2, BCC, CSD2 In region
Snowy plover Charadrius nivosus BCC Nearby
Western snowy plover Charadrius nivosus nivosus FT, SSC Not expected In region
Long-billed curlew Numenius americanus WL, CSD2 Nearby
Marbled godwit Limosa fedoa BCC Nearby
Red knot (Pacific) Calidris canutus BCC Nearby
Short-billed dowitcher Limnodromus griseus BCC Nearby
Willet Tringa semipalmata BCC Nearby
Laughing gull Leucophaeus atricilla WL, CSD2 Nearby
Heermann’s gull Larus heermanni BCC Nearby
Western gull Larus occidentalis BCC Very close
California gull Larus californicus BCC, WL, CSD2 Very close
California least tern Sternula antillarum browni FE, CE, CFP, CSD1 Not expected Very close
Gull-billed tern Gelochelidon nilotica BCC, SSC3 Nearby
Black tern Chlidonias niger SSC2, BCC, CSD2 Nearby
Elegant tern Thalasseus elegans BCC, WL, CSD1 Nearby
Black skimmer Rynchops niger BCC, SSC3, CSD1 Nearby
Common loon Gavia immer SSC, CSD2 Nearby
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Common name Species name Status1 MSCP
Long-eared myotis Myotis evotis WBWG M, CSD2 In region
Fringed myotis Myotis thysanodes WBWG H, CSD2 In region
Long-legged myotis Myotis volans WBWG H, CSD2 In region
Yuma myotis Myotis yumanensis WBWG LM, CSD2 Not expected In region
Western mastiff bat Eumops perotis SSC, WBWG H, CSD2 Not expected In region
Pocketed free-tailed bat Nyctinomops femorosaccus SSC, WBWG M, CSD2 Not expected In region
Big free-tailed bat Nyctinomops macrotis SSC, WBWG MH,
CSD2
In region
San Diego black-tailed
jackrabbit
Lepus californicus bennettii SSC, CSD2 Yes In region
Southern grasshopper mouse Onychomys torridus ramona SSC, CSD2 In range
Dulzura pocket mouse Chaetodipus californicus femoralis SSC, CSD2 Not expected In range
Pallid San Diego pocket mouse Chaetodipus fallax pallidus SSC, CSD2 In range
Northwestern San Diego pocket
mouse
Chaetodipus fallax fallax SSC, CSD2 Not expected Nearby
Los Angeles pocket mouse Perognathus longimembris
brevinasus
SSC, CSD2 In range
Stephens’ kangaroo rat Dipodomys stephensi FT, CT, CSD1 Yes Not expected In region
San Diego Bryant’s woodrat Neotoma bryanti intermedia SSC, CSD2 Not expected Nearby
1 Listed on CDFW’s Special Animals List (https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=109406) as FT or FE = federal
threatened or endangered; FC = federal candidate for listing; CT or CE = California threatened or endangered; CCT or CCE =
Candidate California threatened or endangered; CFP = California Fully Protected (California Fish and Game Code 3511); SSCi =
California Species of Special Concern with i = priorities 1, 2 and 3; WL = CDFW’s Taxa to Watch List; BGEPA = Bald and Golden
Eagle Protection Act; WBWG = Western Bat Working Group with priority rankings, of low (L), moderate (M), and high (H); BCC =
U.S. Fish and Wildlife Service’s Bird of Conservation Concern (https://www.fws.gov/sites/default/files/documents/birds-of-
conservation-concern-2021.pdf); BOP = protected by Birds of Prey (California Fish and Game Code 3503.5, see
https://wildlife.ca.gov/Conservation/Birds/Raptors); and as CSD1 and CSD2 = Group 1 and Group 2 species on County of San Diego
Sensitive Animal List (County of San Diego 2010).
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Common name Species name Status1
MSCP
cover
Occurrence likelihood
MBI
(2026)
Records,
Surveys
Moffitt’s Canada goose Branta canadensis moffitti CSD2 In region
Redhead Aythya americana SSC2, CSD2 Very close
Western grebe Aechmophorus occidentalis BCC, CSD1 Nearby
Clark’s grebe Aechmophorus clarkii BCC Nearby
Western yellow-billed cuckoo Coccyzus americanus occidentalis FT, CE, CSD1 Not expected Very close
Black swift Cypseloides niger SSC3, BCC, CSD2 Very close
Vaux’s swift Chaetura vauxi SSC Very close
Calliope hummingbird Selasphorus calliope BCC Nearby
Rufous hummingbird Selasphorus rufus BCC Very close
Allen’s hummingbird Selasphorus sasin BCC Present Very close/On
site
Light-footed Ridgway’s rail Rallus obsoletus levipes FE, CE, CFP Not expected Nearby
Mountain plover Charadrius montanus SSC2, BCC, CSD2 In region
Snowy plover Charadrius nivosus BCC Nearby
Western snowy plover Charadrius nivosus nivosus FT, SSC Not expected In region
Long-billed curlew Numenius americanus WL, CSD2 Nearby
Marbled godwit Limosa fedoa BCC Nearby
Red knot (Pacific) Calidris canutus BCC Nearby
Short-billed dowitcher Limnodromus griseus BCC Nearby
Willet Tringa semipalmata BCC Nearby
Laughing gull Leucophaeus atricilla WL, CSD2 Nearby
Heermann’s gull Larus heermanni BCC Nearby
Western gull Larus occidentalis BCC Very close
California gull Larus californicus BCC, WL, CSD2 Very close
California least tern Sternula antillarum browni FE, CE, CFP, CSD1 Not expected Very close
Gull-billed tern Gelochelidon nilotica BCC, SSC3 Nearby
Black tern Chlidonias niger SSC2, BCC, CSD2 Nearby
Elegant tern Thalasseus elegans BCC, WL, CSD1 Nearby
Black skimmer Rynchops niger BCC, SSC3, CSD1 Nearby
Common loon Gavia immer SSC, CSD2 Nearby
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BIOLOGICAL IMPACTS ASSESSMENT
The impacts analysis in CEQA review involves prediction. Predictions are necessary
because measuring a project’s impacts directly could not happen until after the impacts
occur, and the timing of this type of measurement would come too late for the
formulations of avoidance and minimization mitigation strategies that are prioritized by
the CEQA. Impact predictions are necessary as part of the environmental review. The
accuracy of the predictions of impacts and their significance ultimately relies on the
degree of accuracy in the characterization of the existing environmental setting (Figure
7).
Figure 7. General flow of information from the gathering stage through the
characterization of the existing environment to predictions of impacts and their
significance.
Impact predictions can derive from speculation or from experience (Figure 6).
Speculation is repeatedly discouraged in the CEQA Guidelines, because speculation is an
inconclusive guess or ponderance on a phenomenon without the benefit of data.
Prediction accuracy improves with experience, though the experience that can be
brought to bear on impact predictions ranges from anecdotes to careful use of scientific
inference. Inference is a conclusion derived logically from data that are available about a
phenomenon. Any type of experience is usually better than relying on speculation, but
careful scientific inference, especially inference drawn from experiments, has proven
most effective. An analogy would be predicting the boiling temperature of water at a
certain place with a known atmospheric pressure after having measured it hundreds of
times at other places under various atmospheric pressures. The experience of measuring
the boiling temperature at all these other places would certainly result in a more
accurate prediction of the boiling point as compared to a speculative prediction. We
know that use of inference in this example is certainly more predictive, and not
Assess species occurrence likelihoods
1. Desktop review
a. Species geographic range overlap or database occurrence records
b. Crosswalk habitat associations with mapped ground cover
2. Reconnaissance survey/Habitat assessment3. Detection surveys for special-status species
Outcomes5. Predict impacts6. Formulate mitigation strategy7. Determine significance of impacts
Characterize wildlife community4. Lists of species detected and of those expected butnot yet detected, and any known trends
Note: Impact predictions and significance determinations have been of unknown accuracy in the
absence of experimental
measurement
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potentially more predictive, because we have a long successful history with the
application of this type of experimentation to draw predictive inference.
The many projects that have undergone CEQA review provide a comparative basis for
drawing inferences needed to predict the impacts of the next proposed project (Figure
8). Reconnaissance survey results that are not compared to survey results from other
project sites miss the opportunity to interpret the results for the purpose of predicting
impacts. The same is true of CDNNB occurrence records. For example, it would be
helpful to know how often a species lacking CNDDB occurrence records on a site is
nevertheless detected onsite by reconnaissance survey(s). It would be helpful to know
how often the impact predictions of other projects are proven accurate, and how often
the required mitigation measures are proven effective. The comparative method enables
the use of scientific inference over speculation and the blind confidence of simply
repeating impact conclusions of unknown accuracy and mitigation strategies of
unknown efficacy.
Figure 8. A framework for arriving at predicted project impacts based on experience
with other project sites. Ideally, there is a pool of similar projects in similar
circumstances where predicted impacts were compared to realized impacts, and into
which the proposed project can also contribute to experience.
In the following, I analyze several types of impacts likely to result from the project, none
of which are analyzed adequately in the IS/MND, and some of which are not analyzed at
all.
Inference
Project site
Preconstruction
study
Predict
project impacts
Preconstruction
studies
Post-construction
studies
Pool of experience
Post-construction
study
Test predictions
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REDUCED PRODUCTIVE CAPACITY FROM HABITAT LOSS
Habitat loss results in a reduced productive capacity of affected wildlife species. The site
is proven to serve as habitat to at least 44 species of vertebrate wildlife which Noriko
and MBI observed on the site, but the number of avian nest sites remains unknown. The
surveys that have been conducted on the project site were unsuitable for detecting all
bird nests or estimating total nest density. The alternative method for estimating avian
productive capacity is to infer it from estimates of total nest density elsewhere. Noriko
and I completed studies to estimate total avian nest density in similar environments.
Noriko estimated 1.63 nests/acre in 1.23 acres of sage scrub in Murrieta, California.
Among three of her grassland study sites, one of my grassland study sites, and an
estimate from another grassland (Jorgensen et al. 2014), the average was 3.2 nests/acre.
However, I estimated 21.25 nests/acres at a study site composed of ornamentals grown
in hedges. Applying Noriko’s 1.63 nests/acre to the site’s 0.33 acres of Diegan sage scrub
predicts 0.54 nests/acre, or a nest every other year. To the 9.45 of the remainder of the
site, I will adjust my average 3.2 nests/acre for the inclusions of ornamentals to estimate
6.4 nests/acre. This density applied to the 9.45 acres of the project site would predict
60.5 nest sites. Altogether with the Diegan sage scrub, I estimate 61 nest sites on the
project site. Assuming 1.39 broods per nest site based on a review of 322 North
American bird species, which averaged 1.39 broods per year, then I estimate 85 nest
attempts per year on the project site. Assuming Young’s (1948) study site typifies bird
productivity of 2.9 fledged birds per nest attempt, then I predict 247 fledglings/year at
the project site.
The loss of 61 nest sites and 85 nest attempts per year would qualify as significant
impacts that have not been analyzed in the IS/MND. But the impacts would not end
with the immediate loss of nest sites. The reproductive capacity of the site would be lost.
The project would prevent the production of 247 fledglings per year. Assuming an
average bird generation time of 4 years, the lost capacity of both breeders and annual
fledgling production can be estimated from an equation in Smallwood (2022):
{(nests/year × chicks/nest × number of years) + (2 adults/nest × nests/year) × (number
of years ÷ years/generation)} ÷ (number of years) = 278 birds per year lost to California.
The loss of 278 birds per year would be a loss of significant habitat value that is
currently provided by the project site. Most if not all these birds are protected by the
federal Migratory Bird Treaty Act and by California’s Migratory Bird Protection Act,
both of which are intended to most strongly protect breeding migratory birds. The loss
of 278 birds per year would easily qualify as an unmitigated significant impact.
INTERFERENCE WITH WILDLIFE MOVEMENT
One of CEQA’s principal concerns regarding potential project impacts is whether a
proposed project would interfere with wildlife movement in the region. Unfortunately,
this concern has not motivated any serious analysis of whether or how the project would
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conclusory statements about how the project site is isolated and lacks vegetative cover of
the sort that would support wildlife movement. No sources are cited in support of the
IS/MND’s conclusions. However, contrary to the IS/MND’s characterization, the project
site is covered by ornamentals, scattered coyote brush (Baccharis pilularis), and
grassland, as well as a patch of Diegan sage scrub. Noriko saw and photographed birds
flying across the site, foraging and collecting nest materials. The isolated nature of the
site only increases its value to migratory wildlife in need of stopover opportunities for
forage, rest and cover. The evidence readily refutes the conclusory statements in the
IS/MND.
The IS/MND also resorts to the red-herring argument that a known wildlife movement
corridor needs to exist before any significant impact can be determined. However, the
CEQA standard expressed in Question (d) of CEQA’s App. G Checklist applies to all
types of movement and not just the movement channeled by corridors.
Moreover, MBI (2026) reports no survey objective to detect signs or patterns of wildlife
movement or roosting, and it implemented no study design or program of observation
to characterize wildlife movement or to detect roost sites. No data were collected that
would have supported the IS/MND’s conclusions regarding the site’s value to wildlife
movement or nursery value. The IS/MND’s conclusions are unfounded.
WILDLIFE DEPREDATION BY HOUSE CATS
Considering national trends, it is safe to assume that house cats would be introduced to
the project area by residents of the proposed residential units. This is significant
because house cats serve as one of the largest sources of avian mortality in North
America (Dauphiné and Cooper 2009, Blancher 2013, Loss et al. 2013, Loyd et al. 2017).
Loss et al. (2013) estimated 139 million cats in the USA in 2013 (range 114 to 164
million), which killed an estimated 16.95 billion vertebrate wildlife annually (range 7.6
to 26.3 billion). In 2012 there were 0.44 house cats per human in the USA, and 122
vertebrate animals were killed per cat, free-ranging members of which killed
disproportionately larger numbers of vertebrate wildlife. The IS/MND reports no
prediction of the number of new residents in the project, but assuming 2 residents per
apartment unit, then the project can be expected to support 794 new residents. This is
important because Ma and McLeod (2023) found that only 15% of apartment owners
allow their cats to roam free. The above rates of cat ownership applied to numbers of
new residents who would allow their cats to roam free would predict 52 new free-
ranging cats, which based on the findings of Loss et al. (2013) would kill 6,344
vertebrate wildlife per year.
House cats also contribute to downstream loading of Toxoplasma gondii. According to
a UC Davis wildlife health research program, “Toxoplasma gondii is a parasite that can
infect virtually all warm-blooded animals, but the only known definitive hosts are cats
– domesticated and feral house cats included. Cats catch the parasite through hunting
rodents and birds and they offload it into the environment through their feces… and
…rain that falls on cement creates more runoff than rain that falls on natural earth,
” (The
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original link is no longer active, but the quote came from the program described at:
https://whc.vetmed.ucdavis.edu/programs-projects/ca-conservation/sea-otter).
Impacts on wildlife from the introduction of house cats into the environment would be
highly significant, and yet these impacts are not considered in the IS/MND. An obvious
mitigation measure would be to constrain house cat ownership such as requiring cats to
remain indoors.
BIRD-WINDOW COLLISION MORTALITY
The IS/MND does not address one of the best-known impacts on wildlife from a
residential project, and that is bird-window collision mortality. The project would
introduce glass windows into an essential portion of avian habitat – that portion of the
gaseous atmosphere that is referred to as the aerosphere (Davy et al. 2017, Diehl et al.
2017). The aerosphere is where birds and bats and other volant animals with wings
migrate, disperse, forage, perform courtship and where some of them mate. Birds are
some of the many types of animals that evolved wings as a morphological adaptation to
thrive by moving through the medium of the aerosphere. The aerosphere is habitat, to
which an entire discipline of ecology has emerged to study this essential aspect of
habitat – the discipline of aeroecology (Kunz et al. 2008).
Many special-status species of birds have been recorded at or near the aerosphere of the
project site. My database review and our site visits indicate there are 101 special-status
species of birds with potential to use the site’s aerosphere (Table 2). All the birds
represented in Table 2 can quickly fly from wherever they have been documented to the
project site, so they would all be within brief flights to the proposed project’s windows.
We confirmed birds of 31 species on the project site, many of them flying across the site.
Window collisions are often characterized as either the second or third largest source or
human-caused bird mortality. The numbers behind these characterizations are often
attributed to Klem’s (1990) and Dunn’s (1993) estimates of about 100 million to 1 billion
bird fatalities in the USA, or more recently by Loss et al.’s (2014) estimate of 365-988
million bird fatalities in the USA or Calvert et al.’s (2013) and Machtans et al.’s (2013)
estimates of 22.4 million and 25 million bird fatalities in Canada, respectively. The
proposed project would impose windows in the airspace normally used by birds.
Glass-façades of buildings intercept and kill many birds, but they are differentially
hazardous to birds based on spatial extent, contiguity, orientation, and other factors. At
Washington State University, Johnson and Hudson (1976) found 266 bird fatalities of 41
species within 73 months of monitoring of a three-story glass walkway (no fatality
adjustments attempted). Prior to marking the windows to warn birds of the collision
hazard, the collision rate was 84.7 per year. At that rate, and by not attempting to adjust
the fatality estimate for the proportion of fatalities not found, 4,574 birds were likely
killed over the 54 years since the start of their study, and that’s at a relatively small
building façade. Accounting for the proportion of fatalities not found in searches, the
number of birds killed by this walkway over the last 54 years would have been about
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14,270. And this is just for one 3-story, glass-sided walkway between two college campus
buildings.
Klem’s (1990) estimate was based on speculation that 1 to 10 birds are killed per
building per year, and this speculated range was extended to the number of buildings
estimated by the US Census Bureau in 1986. Klem’s speculation was supported by
fatality monitoring at only two houses, one in Illinois and the other in New York. Also,
the basis of his fatality rate extension has changed greatly since 1986. Whereas his
estimate served the need to alert the public of the possible magnitude of the bird-
window collision issue, it was highly uncertain at the time and undoubtedly outdated
more than three decades hence. Indeed, by 2010 Klem (2010) characterized the upper
end of his estimated range – 1 billion bird fatalities – as conservative. Furthermore, the
estimate lumped species together as if all birds are the same and the loss of all birds to
windows has the same level of impact.
By the time Loss et al. (2014) performed their effort to estimate annual USA bird-
window fatalities, many more fatality monitoring studies had been reported or were
underway. Loss et al. (2014) incorporated many more fatality rates based on scientific
monitoring, and they were more careful about which fatality rates to include. However,
they included estimates based on fatality monitoring by homeowners, which in one
study were found to detect only 38% of the available window fatalities (Bracey et al.
2016). Loss et al. (2014) excluded all fatality records lacking a dead bird in hand, such as
injured birds or feather or blood spots on windows. Loss et al.’s (2014) fatality metric
was the number of fatalities per building (where in this context a building can include a
house, low-rise, or high-rise structure), but they assumed that this metric was based on
window collisions. Because most of the bird-window collision studies were limited to
migration seasons, Loss et al. (2014) developed an admittedly assumption-laden
correction factor for making annual estimates. Also, only two of the studies included
adjustments for carcass persistence and searcher detection error, and it was unclear how
and to what degree fatality rates were adjusted for these factors. Although Loss et al.
(2014) attempted to account for some biases as well as for large sources of uncertainty
mostly resulting from an opportunistic rather than systematic sampling data source,
their estimated annual fatality rate across the USA was highly uncertain and vulnerable
to multiple biases, most of which would have resulted in fatality estimates biased low.
In my review of bird-window collision monitoring, I found that the search radius
around homes and buildings was very narrow, usually 2 meters. Based on my experience
with bird collisions in other contexts, I would expect that a large portion of bird-window
collision victims would end up farther than 2 m from the windows, especially when the
windows are higher up on tall buildings. In my experience, searcher detection rates tend
to be low for small birds deposited on ground with vegetation cover or woodchips or
other types of organic matter. Also, vertebrate scavengers entrain on anthropogenic
sources of mortality and quickly remove many of the carcasses, thereby preventing the
fatality searcher from detecting these fatalities. Adjusting fatality rates for these factors
– search radius bias, searcher detection error, and carcass persistence rates – would
greatly increase nationwide estimates of bird-window collision fatalities.
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Buildings can intercept many nocturnal migrants as well as birds flying in daylight. As
mentioned above, Johnson and Hudson (1976) found 266 bird fatalities of 41 species
within 73 months of monitoring of a four-story glass walkway at Washington State
University (no adjustments attempted for undetected fatalities). Somerlot (2003) found
21 bird fatalities among 13 buildings on a university campus within only 61 days.
Monitoring twice per week, Hager at al. (2008) found 215 bird fatalities of 48 species, or
55 birds/building/year, and at another site they found 142 bird fatalities of 37 species
for 24 birds/building/year. Gelb and Delacretaz (2009) recorded 5,400 bird fatalities
under buildings in New York City, based on a decade of monitoring only during
migration periods, and some of the high-rises were associated with hundreds of
fatalities each. Klem et al. (2009) monitored 73 building façades in New York City
during 114 days of two migratory periods, tallying 549 collision victims, nearly 5 birds
per day. Borden et al. (2010) surveyed a 1.8 km route 3 times per week during 12-month
period and found 271 bird fatalities of 50 species. Parkins et al. (2015) found 35 bird
fatalities of 16 species within only 45 days of monitoring under 4 building façades. From
24 days of survey over a 48-day span, Porter and Huang (2015) found 47 fatalities under
8 buildings on a university campus. Sabo et al. (2016) found 27 bird fatalities over 61
days of searches under 31 windows. In San Francisco, Kahle et al. (2016) found 355
collision victims within 1,762 days under a 5-story building. Ocampo-Peñuela et al.
(2016) searched the perimeters of 6 buildings on a university campus, finding 86
fatalities after 63 days of surveys. One of these buildings produced 61 of the 86 fatalities,
and another building with collision-deterrent glass caused only 2 of the fatalities,
thereby indicating a wide range in impacts likely influenced by various factors. There is
ample evidence available to support my prediction that the proposed project would
result in many collision fatalities of birds.
Project Impact Prediction: By the time of these comments, I had reviewed and
processed results of bird collision monitoring at 213 buildings and façades for which
bird collisions per m2 of glass per year could be calculated and averaged (Johnson and
Hudson 1976, O’Connell 2001, Somerlot 2003, Hager et al. 2008, Borden et al. 2010,
Hager et al. 2013, Porter and Huang 2015, Parkins et al. 2015, Kahle et al. 2016,
Ocampo-Peñuela et al. 2016, Sabo et al. 2016, Barton et al. 2017, Gomez-Moreno et al.
2018, Schneider et al. 2018, Loss et al. 2019, Brown et al. 2020, City of Portland Bureau
of Environmental Services and Portland Audubon 2020, Riding et al. 2020). These
study results averaged 0.073 bird deaths per m2 of glass per year (95% CI: 0.042-0.102).
This average and its 95% confidence interval provide a robust basis for predicting
fatality rates at a proposed new project.
With the estimated average bird collision mortality above, all that is needed is an
estimate of the spatial extent of windows in the project, but the IS/MND reports no such
metric. However, the IS/MND reports the building would gross 416,152 square feet of
floor space, and I happen to have maintained an average extent of windows per square
foot in other apartment projects. The average was 0.01158 m2 of glass window per
square foot of floor space, which applied to the square footage of the project would
predict 4,819 m2 of windows in the project. This extent of windows multiplied against
the above-reported average bird collision deaths per m2 of glass per year predicts 352
(95% CI: 202–493) bird collision fatalities per year.
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The vast majority of these predicted deaths would be of birds protected under the
Migratory Bird Treaty Act and under the California Migratory Bird Protection Act, thus
causing significant unmitigated impacts that were not addressed in the IS/MND. Given
the predicted level of bird-window collision mortality, and the lack of any proposed
mitigation, it is my opinion that the proposed project would result in potentially
significant adverse biological impacts, including the unmitigated take of both terrestrial
and aerial habitat of birds and other sensitive species. Not only would the project take
habitat of rare and sensitive species of birds, but it would transform the project’s
airspace into a lethal collision trap to birds.
TRAFFIC IMPACTS ON WILDLIFE
The IS/MND neglects to address one of the project’s most obvious, substantial impacts
to wildlife, and that is wildlife mortality and injuries caused by project-generated traffic.
Project-generated traffic would endanger wildlife that must, for various reasons, cross
roads used by the project’s traffic (Photos 23―26), including along roads far from the
project footprint but which would nevertheless by traversed by automobiles head to or
from the project’s building. Vehicle collisions have accounted for the deaths of many
thousands of amphibian, reptile, mammal, bird, and arthropod fauna, and the impacts
have often been found to be significant at the population level (Forman et al. 2003).
Across North America traffic impacts have taken devastating tolls on wildlife (Forman et
al. 2003). In Canada, 3,562 birds were estimated killed per 100 km of road per year
(Bishop and Brogan 2013), and the US estimate of avian mortality on roads is 2,200 to
8,405 deaths per 100 km per year, or 89 million to 340 million total per year (Loss et al.
2014). Local impacts can be more intense than nationally.
Photo 23. A desert cottontail runs across the road just in Murietta, California. Such
road crossings are usually successful, but too often prove fatal to the animal.
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Photo 24. A great-tailed grackle crosses a road in the Imperial Valley.
Photos 25 and 26. Raccoon killed on Road 31 just east of Highway 505 in Solano
County (left; photo taken on 10 November 2018), and California kingsnake killed by a
vehicle on a rural road in El Dorado County in 2024.
The nearest study of traffic-caused wildlife mortality was performed along a 2.5-mile
stretch of Vasco Road in Contra Costa County, California. Fatality searches in this study
found 1,275 carcasses of 49 species of mammals, birds, amphibians and reptiles over 15
months of searches (Mendelsohn et al. 2009). This fatality number needs to be adjusted
for the proportion of fatalities that were not found due to scavenger removal and
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searcher error. This adjustment is typically made by placing carcasses for searchers to
find (or not find) during their routine periodic fatality searches. This step was not taken
at Vasco Road (Mendelsohn et al. 2009), but it was taken as part of another study next
to Vasco Road (Brown et al. 2016). Brown et al.’s (2016) adjustment factors for carcass
persistence resembled those of Santos et al. (2011). Also applying searcher detection
rates from Brown et al. (2016), the adjusted total number of fatalities was estimated at
9,462 animals killed by traffic on the road. This fatality number projected over 1.25
years and 2.5 miles of road translates to 3,028 wild animals per mile per year. In terms
comparable to the national estimates, the estimates from the Mendelsohn et al. (2009)
study would translate to 188,191 animals killed per 100 km of road per year, or 22 times
that of Loss et al.’s (2014) upper bound estimate and 53 times the Canadian estimate.
An analysis is needed of whether increased traffic generated by the project site would
similarly result in local impacts on wildlife.
For wildlife vulnerable to front-end collisions and crushing under tires, road mortality
can be predicted from the study of Mendelsohn et al. (2009) as a basis, although it
would be helpful to have the availability of more studies like that of Mendelsohn et al.
(2009) at additional locations. My analysis of the Mendelsohn et al. (2009) data
resulted in an estimated 3,028 animals killed per mile along a county road in Contra
Costa County. The estimated numbers of fatalities were 1.75% birds, 26.4% mammals
(many mice and pocket mice, but also ground squirrels, desert cottontails, striped
skunks, American badgers, raccoons, and others), 67.4% amphibians (large numbers of
California tiger salamanders and California red-legged frogs, but also Sierran treefrogs,
western toads, arboreal salamanders, slender salamanders and others), and 4.4%
reptiles (many western fence lizards, but also skinks, alligator lizards, and snakes of
various species). VMT is useful for predicting wildlife mortality because I was able to
quantify miles traveled along the studied reach of Vasco Road during the period of the
Mendelsohn et al. (2009), hence enabling a rate of fatalities per VMT that can be
projected to other sites, assuming similar collision fatality rates.
Predicting project-generated traffic impacts on wildlife
The IS/MND fails to report annual VMT that would be generated by the project.
However, I have maintained a database of predicted annual VMT from other apartment
projects on which I provided expert testimony. The average has been 26 annual VMT
per square foot of floor space, which applied to the project’s 416,152 sf would predict
10,819,952 annual VMT would be generated by the project.
During the Mendelsohn et al. (2009) study, 19,500 cars traveled Vasco Road in Contra
Costa County daily, so the vehicle miles that contributed to my estimate of non-volant
fatalities was 19,500 cars and trucks × 2.5 miles × 365 days/year × 1.25 years =
22,242,187.5 vehicle miles per 9,462 wildlife fatalities, or 2,351 vehicle miles per fatality.
This rate divided into the predicted annual VMT would predict 4,602 vertebrate wildlife
fatalities per year due to project-generated traffic.
However, some might argue that this prediction relies too much on a study along a road
through less-disturbed rangeland that likely supports more non-volant wildlife that is
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more vulnerable to collision mortality. I would argue that the project-generated traffic
would pass through similar rural environments with ample wildlife available to be
crushed under automobile tires. Nevertheless, to better represent those reaches of road
that are more urban than rural, or that would become more urban with the development
of the project, I recently completed my own study of wildlife mortality caused by
automobiles along roads that were urban and interfaced between urban and agricultural
land uses.
I completed one year of daily pedestrian surveys along 2.7 km (1.713 miles) of local,
collector and minor arterial roads in north Davis, California, where I tallied 314 fatalities
of 40 species of vertebrate wildlife. Most of the fatalities were small-bodied animals
such as Sierran treefrogs, western toads, western fence lizards, 10”- to 16”-long juvenile
Pacific gophersnakes, valley gartersnakes and California kingsnakes, as well as bushtits,
yellow-rumped warblers, deer mice and California ground squirrels. Most of the animals
I found would never have been detected from a moving vehicle, which is why people
often underestimate how many wild animals are killed by vehicle traffic.
The animals I found in my study did not include all the animals killed by vehicles on the
roads I searched. Many had been removed by scavengers before I could find and count
them. (American crows patrol the roads every morning, and so does a large flock of wild
turkeys.) Some of the animals are knocked off the road in places where I could never
find them, and some were undoubtedly caught and carried away in the grills of vehicles
or in tire treads. Most of the Sierran treefrogs disappeared from where I found them
within several hours, so daily searches missed many of the fatalities. To adjust for these
undetected fatalities, I fit a logit regression model to my fatality finds, all of which
transitioned to carcass detection trials after I initially found them. Starting with the first
day after each detection, I monitored the carcass trials for 30 days, and I assigned each a
body mass estimate based on typical body mass reported in the literature. Predictor
variables were days since detection and log10 body mass. The relationship between
carcass detection probability and the predictor variables is depicted in Figure 9. My
fatality finds adjusted by the model results in an estimate of 2,126 vertebrate wildlife
fatalities over 1.713 miles of roads in one year, or 1,241 vertebrate wildlife
fatalities/mile/year. This rate is 40.9% of the rate measured at Vasco Road, or an
estimated 5,748 vehicle miles per fatality. Applying this urban fatality rate to the VMT
that is predicted for the project would predict 1,882 vertebrate wildlife fatalities per year
in the area around the project that is traveled by project-generated traffic.
A reasonable range of predicted mortality is therefore 1,882 to 4,602 vertebrate wildlife
fatalities/year due to project-generated traffic.
Based on my analysis, the project-generated traffic would cause substantial, significant
impacts on wildlife. The IS/MND does not address this potential impact, let alone
propose to mitigate it. Mitigation measures to improve wildlife safety along roads are
available and are feasible, and they need exploration for their suitability with the
proposed project. Given the predicted level of project-generated traffic-caused
mortality, and the lack of any proposed mitigation, it is my opinion that the proposed
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27 BIOLOGICAL IMPACTS ASSESSMENT The impacts analysis in CEQA review involves prediction. Predictions are necessary because measuring a project’s impacts directly could not happen until after the impacts occur, and the timing of this type of measurement would come too late for the formulations of avoidance and minimization mitigation strategies that are prioritized by the CEQA. Impact predictions are necessary as part of the environmental review. The accuracy of the predictions of impacts and their significance ultimately relies on the degree of accuracy in the characterization of the existing environmental setting (Figure 7). Figure 7. General flow of information from the gathering stage through the characterization of the existing environment to predictions of impacts and their significance. Impact predictions can derive from speculation or from experience (Figure 6). Speculation is repeatedly discouraged in the CEQA Guidelines, because speculation is an inconclusive guess or ponderance on a phenomenon without the benefit of data. Prediction accuracy improves with experience, though the experience that can be brought to bear on impact predictions ranges from anecdotes to careful use of scientific inference. Inference is a conclusion derived logically from data that are available about a phenomenon. Any type of experience is usually better than relying on speculation, but careful scientific inference, especially inference drawn from experiments, has proven most effective. An analogy would be predicting the boiling temperature of water at a certain place with a known atmospheric pressure after having measured it hundreds of times at other places under various atmospheric pressures. The experience of measuring the boiling temperature at all these other places would certainly result in a more accurate prediction of the boiling point as compared to a speculative prediction. We know that use of inference in this example is certainly more predictive, and not Assess species occurrence likelihoods 1. Desktop reviewa. Species geographic range overlap or database occurrence recordsb. Crosswalk habitat associations with mapped ground cover2. Reconnaissance survey/Habitat assessment3. Detection surveys for special-status species Outcomes5. Predict impacts6. Formulate mitigation strategy7. Determine significance of impactsCharacterize wildlife community4. Lists of species detected and of those expected butnot yet detected, and any known trendsNote: Impact predictions and significance determinations have been of unknown accuracy in the absence of experimental measurement
38
project would result in potentially significant adverse biological impacts, and that these
impacts would be unmitigated.
Figure 9.
Wildlife
carcass
detection
probability
is a function of
the number
of days
since
discovery
and log10
body mass.
CUMULATIVE IMPACTS
One of CEQA’s principal concerns regarding potential project impacts is whether a proposed
project would contribute significantly to cumulative impacts of past, present and future projects,
or to multiple types of impacts that are cumulatively considerable. Unfortunately, the IS/MND
fails to analyze the project’s contribution to cumulative impacts on biological resources.
Noriko Smallwood and I performed an experiment to measure the efficacy of permitting
requirements and required mitigation measures at avoiding or minimizing project
impacts including cumulative impacts. We revisited the project sites we had surveyed as
experts to repeat the survey methods at the same time of year, the same start time in the
day, and the same methods and survey duration to control these sources of variation to
cleanly measure the effects of mitigated development on wildlife. We structured the
experiment in a before-after, control-impact experimental design, as some of the sites
had been developed since our initial survey and some had remained undeveloped. All
the developed sites had included mitigation measures to avoid, minimize or compensate
for impacts to wildlife. Nevertheless, we found that mitigated development resulted in a
66% loss of species on site, and 48% loss of species in the project area. Counts of
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27 BIOLOGICAL IMPACTS ASSESSMENT The impacts analysis in CEQA review involves prediction. Predictions are necessary because measuring a project’s impacts directly could not happen until after the impacts occur, and the timing of this type of measurement would come too late for the formulations of avoidance and minimization mitigation strategies that are prioritized by the CEQA. Impact predictions are necessary as part of the environmental review. The accuracy of the predictions of impacts and their significance ultimately relies on the degree of accuracy in the characterization of the existing environmental setting (Figure 7). Figure 7. General flow of information from the gathering stage through the characterization of the existing environment to predictions of impacts and their significance. Impact predictions can derive from speculation or from experience (Figure 6). Speculation is repeatedly discouraged in the CEQA Guidelines, because speculation is an inconclusive guess or ponderance on a phenomenon without the benefit of data. Prediction accuracy improves with experience, though the experience that can be brought to bear on impact predictions ranges from anecdotes to careful use of scientific inference. Inference is a conclusion derived logically from data that are available about a phenomenon. Any type of experience is usually better than relying on speculation, but careful scientific inference, especially inference drawn from experiments, has proven most effective. An analogy would be predicting the boiling temperature of water at a certain place with a known atmospheric pressure after having measured it hundreds of times at other places under various atmospheric pressures. The experience of measuring the boiling temperature at all these other places would certainly result in a more accurate prediction of the boiling point as compared to a speculative prediction. We know that use of inference in this example is certainly more predictive, and not Assess species occurrence likelihoods 1. Desktop reviewa. Species geographic range overlap or database occurrence recordsb. Crosswalk habitat associations with mapped ground cover2. Reconnaissance survey/Habitat assessment3. Detection surveys for special-status species Outcomes5. Predict impacts6. Formulate mitigation strategy7. Determine significance of impactsCharacterize wildlife community4. Lists of species detected and of those expected butnot yet detected, and any known trendsNote: Impact predictions and significance determinations have been of unknown accuracy in the absence of experimental measurement
39
vertebrate animals declined 90%. We found that “Development impacts measured by
the mean number of species detected per survey were greatest for amphibians (-100%),
followed by mammals (-86%), grassland birds (-75%), raptors (-53%), special-status
species (-49%), all birds as a group (-48%), non-native birds (-44%), and synanthropic
birds (-28%). Our results indicated that urban development substantially reduced
vertebrate species richness and numerical abundance, even after richness and
abundance had likely already been depleted by the cumulative effects of loss,
fragmentation, and degradation of habitat in the urbanizing environment,” and despite
all the mitigation measures and existing policies, regulations, and habitat plans.
Experimental evidence demonstrates the need to analyze a project’s potentially
significant contributions to cumulative impacts on wildlife. The environmental review
for this project needs to include a cumulative impacts analysis.
FLAWED MITIGATION STRATEGY
The mitigation strategy needs to be based on a sound understanding of the existing
wildlife community. It needs to be known which species occur or are likely to occur on
the project site as well as the nature of their occurrences. Are the occurrences of resident
species? Migratory? For special-status species, detection surveys should have been
performed to either detect the species or to obtain evidence of absence. Surveys should
have been performed to understand how wildlife use the site in their movement
patterns. And what was found of wildlife species needs to be carefully interpreted by
comparing the findings to the findings from other survey efforts at other sites. Failures
to detect species should be interpreted relative to the probabilities of their detections
given the survey effort. The mitigation strategy needs to follow the steps under Assess
species occurrence likelihoods and Characterize wildlife community, followed by Step 7:
Predict impacts (Figure 7). However, the IS/MND’s mitigation strategy does not follow
from these steps. This pointed out, my comments follow in regular font the summary of
each required mitigation measure in italics.
MM BIO-1 Pre-Construction Bird Surveys, Avoidance, and Notification. If
construction activities are initiated during the bird nesting season (February 1–August
31) involving removal of vegetation or other nesting bird habitat, including abandoned
structures and other man-made features, a pre-construction nesting bird survey shall
be conducted no more than 14 days prior to initiation of ground disturbance and
vegetation removal activities. ... The survey shall be conducted by a [qualified]
biologist ... If active nests are found, an avoidance buffer shall be determined by a
qualified biologist in coordination with the City. The avoidance buffer width will
depend upon the species, the proposed work activity, and existing disturbances
associated with land uses outside of the site, which shall be demarcated by the biologist
... No ground-disturbing activities shall occur within the buffer until the biologist has
confirmed that breeding/nesting is completed, ... A report summarizing the pre-
construction survey(s) shall be … submitted to the City prior to the commencement of
construction activities. …
If the project goes forward, preconstruction surveys for nesting birds should be
implemented, but this measure would not avoid the permanent loss of habitat nor the
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collision mortality with automobiles. Preconstruction, take-avoidance surveys should
consist of two steps, both of which are very difficult. First, the biologist(s) performing
the survey must identify birds that are breeding. Second, the biologist(s) must locate the
breeding birds’ nests. The first step is typically completed by observing bird behaviors
such as food deliveries and nest territory defense. To be successful, these types of
observations typically require many surveys on many dates spread throughout the
breeding season even for a single species. To identify and locate the birds of all species
nesting on a site would require a much greater survey effort than can be accomplished in
MM BIO-1’s allotted time. Many bird nests would be missed.
I predict the project site supports 61 nest sites in the average year, and this number does
not include those that would need to be located within the defined buffer area beyond
the project site’s boundary. Even assuming all these nests could be found (not likely),
the mitigation measure would apply only to the breeding season of the survey. After the
breeding season of the preconstruction survey, there would be no further production of
birds from the project site. The project’s impact on birds would be permanent and of
large magnitude. The conservation benefits of this measure would be de minimis
compared to the project’s potential impacts on breeding birds.
Furthermore, the mitigation language allows a single individual to make a subjective
decision, outside the public’s view, to determine the buffer area and buffer timing for
any given species. This measure lacks objective criteria, and it is therefore
unenforceable.
Lastly, the mitigation language includes the requirement that the preconstruction nest
survey shall be conducted by a qualified biologist, and this requirement carries over to
determinations of the buffer areas and buffer timing to avoid take caused by
construction activities. Undefined, however, is what qualifies as a “qualified biologist” in
these contexts, other than familiarity “with the identification of avian species known to
occur in southern California coastal communities.” As mentioned earlier in this letter,
Noriko Smallwood and I have been conducting surveys over the past several years to
estimate total nest density, which is relevant to a preconstruction, take-avoidance
survey because our surveys were likewise directed to all bird species that could be
concurrently nesting on a site. Searching for the nests of one species is difficult, but
searching for nests of all bird species at once is vastly more difficult. For this reason,
there are very few published estimates of total nest density, and there are very few
wildlife biologists who have experience with surveys for the nest attempts of all bird
species on a given site. A technical way to qualify a wildlife biologist for the tasks
outlined in this measure would be to obtain an agency Memorandum of Understanding
in which the biologist is named and said to be qualified for conducting the
preconstruction survey and for determining the take-avoidance buffer area and timing.
However, a more compelling means of qualifying the biologist would be to require that
the biologist has achieved demonstrable experience with nest surveys and avian nesting
behavior. Without a better definition of what is a qualified biologist in the contexts of
these tasks, BIO-1 lacks objective criteria, and it is therefore unenforceable.
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MM BIO-2 Crotch’s Bumble Bee (CBB) Avoidance and Clearance Survey … Three on-site surveys for Crotch’s bumble bee (CBB) shall be conducted prior to
initiation of ground disturbing project activities to identify if the CBB is present within
the project site. …
MM BIO-1 is inappropriate because it defers the appropriate detection survey to a time
when it would no longer achieve four of CEQA’s primary objectives to (1) accurately
characterize the existing environmental setting as part of the CEQA review, (2) disclose
potential project impacts to the public and decision-makers, and (3) foster public
participation with decision-making over proposed projects to (4) identify issues and
feasible alternative mitigation measures to minimize environmental impacts. The
appropriate timing of the survey is essential, not just biologically but also in terms of
achieving CEQA’s objectives. According to CDFW (2023:3), “On-site surveys provide the
most valuable information for determining potential impacts of proposed projects and
activities on the four candidate bumble bee species, and subsequently developing
measures to avoid or minimize take of these species.” This guidance obviously
recognizes the need to complete the detection surveys before the public circulation of
the CEQA review document; otherwise, it would not be possible to determine potential
impacts or formulate appropriate mitigation.
Crotch’s bumble bee is a candidate for listing under the California Endangered Species
Act. It is therefore important to implement the appropriate detection survey, which
should be consistent with CDFW (2023).
Furthermore, I found no evidence in the IS/MND that efforts have been made to obtain
an incidental take permit (ITP), nor that CDFW is inclined to issue and ITP for Crotch’s
bumble bee in this project.
NEEDED MITIGATION MEASURES
Compensatory Habitat Protection: The project would destroy the productive
capacity of the project site for birds and other wildlife. The loss of this capacity would
need to be offset by compensatory mitigation as near to the site as possible. I
recommend a 5:1 mitigation ratio to achieve a no net loss standard, as a 1:1 ratio would
simply ensure a 50% loss of habitat between the project site and mitigation site.
The loss of burrowing owl foraging opportunities would need to be mitigated, as well.
The applicant needs to consult with the CDFW to learn what mitigation ratio would be
acceptable for loss of burrowing owl habitat on the project site, and whether and where
habitat is available to be protected nearby.
Bird-Window Collision Mortality: If the project goes forward, it should at a
minimum adhere to available Bird-Safe Guidelines, such as those prepared by American
Bird Conservancy and New York and San Francisco. The American Bird Conservancy
(ABC) produced an excellent set of guidelines recommending actions to: (1) Minimize
use of glass; (2) Placing glass behind some type of screening (grilles, shutters, exterior
shades); (3) Using glass with inherent properties to reduce collisions, such as patterns,
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window films, decals or tape; and (4) Turning off lights during migration seasons
(Sheppard and Phillips 2015). The City of San Francisco (San Francisco Planning
Department 2011) also has a set of building design guidelines, based on the excellent
guidelines produced by the New York City Audubon Society (Orff et al. 2007). The ABC
document and both the New York and San Francisco documents provide excellent
alerting of potential bird-collision hazards as well as many visual examples. The San
Francisco Planning Department’s (2011) building design guidelines are more
comprehensive than those of New York City, but they could have gone further. For
example, the San Francisco guidelines probably should have also covered scientific
monitoring of impacts as well as compensatory mitigation for impacts that could not be
avoided, minimized or reduced.
New research results inform of the efficacy of marking windows. Whereas Klem (1990)
found no deterrent effect from decals on windows, Johnson and Hudson (1976) reported
a fatality reduction of about 69% after placing decals on windows. In an experiment of
opportunity, Ocampo-Peñuela et al. (2016) found only 2 of 86 fatalities at one of 6
buildings – the only building with windows treated with a bird deterrent film. At the
building with fritted glass, bird collisions were 82% lower than at other buildings with
untreated windows. Kahle et al. (2016) added external window shades to some
windowed façades to reduce fatalities 82% and 95%. Brown et al. (2020) reported an
84% lower collision probability among fritted glass windows and windows treated with
ORNILUX R UV. City of Portland Bureau of Environmental Services and Portland
Audubon (2020) reduced bird collision fatalities 94% by affixing marked Solyx window
film to existing glass panels of Portland’s Columbia Building. Many external and
internal glass markers have been tested experimentally, some showing no effect and
some showing strong deterrent effects (Klem 1989, 1990, 2009, 2011; Klem and Saenger
2013; Rössler et al. 2015). For example, Feather Friendly® circular adhesive markers
applied in a grid pattern across all windows reduced bird-window collision mortality by
95% in one study (Riggs et al. 2023) and by 95% in another (de Groot et al. 2021).
Another study tested the efficacy of two filmshades to be applied exteriorly to windows
prior to installations: BirdShades increased bird-window avoidance by 47% and
Haverkamp increased avoidance by 39% (Swaddle et al. 2023).
Road Mortality: Compensatory mitigation is needed for the increased wildlife
mortality that would be caused by collisions with automobiles due to project-generated
road traffic in the region. I suggest that this mitigation can be directed toward funding
research to identify fatality patterns and effective impact reduction measures such as
reduced speed limits and wildlife under-crossings or overcrossings of particularly
dangerous road segments. Compensatory mitigation can also be provided in the form of
donations to wildlife rehabilitation facilities (see below).
Fund Wildlife Rehabilitation Facilities: Compensatory mitigation is needed, and
it ought to also include funding contributions to wildlife rehabilitation facilities to cover
the costs of injured animals that will be delivered to these facilities for care. Many
animals would likely be injured during construction, by house cats, and by collisions
with windows and with automobiles traveling to and from the project site.
FRQW
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Landscaping: If the project goes forward, California native plant landscaping (i.e.,
grassland and locally appropriate scrub plants) should be considered to be used as
opposed to landscaping with lawn and exotic shrubs and trees. Native plants offer more
structure, cover, food resources, and nesting substrate for wildlife than landscaping with
lawn and ornamental trees. Native plant landscaping has been shown to increase the
abundance of arthropods which act as important sources of food for wildlife and are
crucial for pollination and plant reproduction (Narango et al. 2017, Adams et al. 2020,
Smallwood and Wood 2022.). Further, many endangered and threatened insects require
native host plants for reproduction and migration, e.g., monarch butterfly. Around the
world, landscaping with native plants over exotic plants increases the abundance and
diversity of birds, and it is particularly valuable to native birds (Lerman and Warren
2011, Burghardt et al. 2008, Berthon et al. 2021, Smallwood and Wood 2022).
Landscaping with native plants is a way to maintain or to bring back some of the natural
habitat and lessen the footprint of urbanization by acting as interconnected patches of
habitat for wildlife (Goddard et al. 2009, Tallamy 2020). Lastly, not only does native
plant landscaping benefit wildlife, it requires less water and maintenance than
traditional landscaping with lawn and hedges.
Thank you for your consideration,
______________________
Shawn Smallwood, Ph.D.
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Responses to Comments from Lozeau Drury LLP on behalf of the Supporters Alliance for
Environmental Responsibility (SAFER)
Response to Comment 2-1
The comment summarizes the CEQA “fair argument” standard and legal requirements for preparing an EIR versus an MND. The City acknowledges and has complied with these standards.
In this case, a Focused IS/MND was prepared because all potential impacts to biological
resources were found to be less than significant with mitigation. The City carefully evaluated the
whole record and determined that no substantial evidence supported a fair argument of
unmitigated significant impacts. On the contrary, the letter from Dr. Smallwood and the report
prepared by Ms. Smallwood rely on speculative analysis and unsupported extrapolation, which
substantially overstate the project’s potential impacts to biological resources. The following Responses to Comments 2-2 through 2-24 provide substantial evidence that the project’s
biological resources impacts have been fully analyzed and mitigated to less than significant
consistent with CEQA requirements.
Response to Comment 2-2
The project-specific Biological Resources Technical Letter Report provided a comprehensive
approach and included a literature/database review (California Natural Data Diversity Database
[CNDDB], US Fish and Wildlife Service [USFWS] Information for Planning and Consultation, California Native Plant Society, etc.), a site visit by qualified biologists in January 2026, and
consideration of previous biological surveys from 2001–2003. This effort identified all sensitive
biological resources with potential to occur on-site (including coastal California gnatcatcher,
Crotch’s bumble bee, and thread-leaved brodiaea) and determined that other special-status species were unlikely to occur due to the absence of suitable habitat (e.g., no wetlands, vernal
pools, or extensive native vegetation) or other environmental constraints. The commenter’s March
11, 2026 site survey by Ms. Smallwood recorded additional common wildlife species, primarily
birds such as hummingbirds, sparrows, and crows, which are typical of the region’s urban-edge
habitats and were not individually listed in the IS/MND but were generally acknowledged in the
description of the site’s wildlife community. These additional observations do not indicate that the
IS/MND overlooked any previously unknown significant resource; rather, they reflect common wildlife species acclimated to an urban environment. Crucially, all species of concern for CEQA
purposes (e.g., those that could trigger significant impacts) were duly considered in the IS/MND.
The City stands by the adequacy of the environmental setting description in the IS/MND, which
meets CEQA Guidelines Section 15063(d) requirements by focusing on the physical biological
conditions relevant to assessing significant impacts. The commenter’s broad claim that the site
supports numerous special-status species is not supported by substantial evidence of suitable
habitat or direct observations beyond those already addressed. In summary, the City finds that the IS/MND and supporting biological resources technical report properly identified the presence
and potential of special-status species on-site and that it provided an accurate baseline for impact
analysis. No species likely to be significantly impacted by the project were omitted.
Response to Comment 2-3
The City has considered whether the project’s biological resources impacts could be significant,
including those listed by the commenter. For each category—habitat loss and nesting productivity,
wildlife movement, predation by pets, bird-window collisions, vehicle-related mortality, and
June 3, 2026 Item #1 215 of 417
cumulative effects—the IS/MND provides analysis and, where necessary, identifies appropriate
mitigation measures. As detailed in Responses to Comments 2-4 through 2-8 below, the City’s
analysis concludes that these impacts would be reduced to less than significant with mitigation incorporated. MM BIO-1 (Pre-Construction Nesting Bird Surveys, Avoidance, and Notification)
establishes clear performance standards to avoid and minimize indirect impacts to gnatcatchers,
including protection of active nests and limitation of construction-related disturbance. The
mitigation measure requires installation of a no-disturbance buffer around any active gnatcatcher
nest identified by a qualified biologist and implementation of construction controls to ensure disturbance levels remain below thresholds that could adversely affect nesting behavior. It is
noted that clarification related to the coastal California gnatcatcher was made to MM BIO-1 (refer
to Response to Comment 2-23 for revisions). See also Response to Comment 2-17.
MM BIO-2 (Crotch’s Bumble Bee Avoidance and Clearance Survey) would ensure that Crotch’s
bumble bee focused surveys would occur on-site at the appropriate time of year (during the
flowering/active season) prior to any ground disturbance, when detection is most likely.
Subsequent to release of the IS/MND for public review, a site-specific three-survey protocol design was approved by CDFW. The three subsequent surveys were conducted in April and May
2026. Crotch’s bumble bee was not detected in any of the three surveys and the negative findings
were reported to CDFW. The commenter’s assertions that the project would result in loss of 61
bird nesting sites and 85 nesting attempts per year, as well as prevention of the production of 247
fledglings and 278 birds per year are not supported by substantial evidence and are therefore
speculative (CEQA Guidelines Sections 15064[d][3] and 15145). The project would convert
approximately 9.5 acres of previously graded, routinely mowed disturbed habitat. This would not substantially reduce local wildlife populations or bird reproductive capacity. The only on-site native
habitat (a 0.33-acre Diegan coastal sage scrub patch with potential gnatcatcher foraging value)
would be avoided and preserved as open space. The remaining habitat is of low quality and
supports common, regionally abundant species. Project compliance with Migratory Bird Treaty
Act and California Fish and Game Code requirements would be ensured through MM BIO-1 (pre-
construction nesting bird surveys and avoidance buffers). With implementation of MM BIO-1 and
existing regional conservation/Citywide coverage (via the City’s HMP3), project impacts from
habitat removal would be less than significant and an EIR is not warranted.
Response to Comment 2-4
The project site is an isolated, disturbed infill parcel surrounded by existing roadways and
development and is not identified as a designated wildlife corridor or linkage in regional plans (including the HMP, which clearly calls out wildlife corridors in the City). Existing barriers (e.g.,
Salk Avenue) currently limit wildlife movement through the area. The on-site Diegan coastal sage
scrub patch may provide minor bird stopover value; such habitat would be avoided and preserved
as open space with project implementation. The project would not add new major barriers across
natural open space. Further, there is ample alternative stopover habitat in the area for migratory
birds. Project conformance with applicable HMP Adjacency Standards (directed lighting,
construction noise controls, and pet management) would also ensure that the project would not substantially interfere with area wildlife movement. Impacts would be less than significant. Refer
3 City of Carlsbad. Habitat Management Plan for Natural Communities in the City of Carlsbad. Final approved December 1999; as amended and approved November 2004. https://www.carlsbadca.gov/home/showpublisheddocument/1600/638366818940500000.
June 3, 2026 Item #1 216 of 417
also to Responses to Comments 1-10 and 2-18 for additional discussion of habitat connectivity
and fragmentation.
Response to Comment 2-5
The project is subject to the City’s HMP Adjacency Guidelines which require pet/predator control
measures. In compliance with these standards, the project would include: (1) resident education
that provides all tenants with information on the ecological importance of keeping cats indoors or
supervised (e.g., through community guidelines prohibiting free-roaming cats and lease
provisions such as outdoor leash requirements), and (2) fully enclosed trash rooms and regularly
scheduled trash removal to avoid attracting rodents or other prey that could draw feral cats or
other predators. These measures are proven strategies that many jurisdictions use to minimize pet predation near sensitive areas. It is also worth noting that this infill project is surrounded by
existing residential developments in the vicinity where outdoor pets are likely already present.
Additionally, there is no evidence that the incremental increase of domestic cats, estimated by the
commenter as approximately 50 cats. This estimated increase in domestic cats at the project site
is not supported by evidence and is therefore speculative (CEQA Guidelines Sections 15064[d][3]
and 15145). Nevertheless, the City HMP Adjacency Standards explicitly require that projects
adjacent to preserves implement measures to control pets/predators. Predation by domestic cats on birds and other wildlife is a recognized issue primarily associated with single-family residential
development, where cats can freely exit homes and roam yards and adjacent open space. In
contrast, a multi-level apartment building is inherently not conducive to free-roaming cats, as pets
cannot independently open doors or access elevators to enter or exit units. As a result, cats
residing in multi-family developments are predominantly, if not entirely, indoor pets, substantially
reducing the likelihood of access to adjacent habitat.
Moreover, the HMP Adjacency Standards explicitly require that projects adjacent to preserves
implement measures to manage pets and potential predators of developments adjacent to
preserve area. Consistent with these requirements, the project would include provisions pursuant
to the City’s HMP, Objective Design Standards, and Landscape Manual to further minimize any
already low potential for pets entering the adjacent habitat. Specifically, the project would provide
educational materials (e.g., brochures or handbook provisions) to all new residents informing
them of the nearby sensitive habitat and requiring cats be kept indoors, with outdoor access permitted only if leashed and under direct supervision. Additionally, the project’s landscape plan
would avoid planting features that might inadvertently attract domestic animals to the habitat edge
(e.g., no litter boxes near open space, no features that encourage house pets to roam near the
preserve boundary). It is also noted that the habitat patch is relatively small and bordered on two
sides by existing development or roads. There is not currently nor would the project result in an
accessible path from the proposed apartment complex to the 0.33-acre Diegan coastal sage scrub
patch located in the northwest corner of the site. While the City can manage pet-related risks
through project design and adherence to City requirements, the project’s incremental contribution
to domestic cat presence near the preserve would be negligible. Therefore, future domestic cats
associated with the project would not cause a significant decline in local wildlife populations.
One coastal California gnatcatcher was observed in 2025 in the 0.33-acre Diegan coastal sage scrub patch on-site, which would be avoided by the project. The consulting biologist concluded
that the individual was transient, most likely residing in the more abundant and established habitat
opposite Salk Avenue and using the patch for foraging. Coastal California gnatcatchers primarily
occupy coastal sage scrub characterized by dense, low-growing shrub cover, where nests are
June 3, 2026 Item #1 217 of 417
typically placed several feet above ground within intact vegetation, limiting exposure to urban
predators. Predation pressure documented for the species is primarily associated with avian
predators and habitat fragmentation, and domestic cats are not identified by USFWS as a common or significant source of gnatcatcher mortality.4 In summary, with implementation of
required pet management practices and design features, indirect impacts from potential house
cat predation would be minimized and would remain less than significant. Refer also to
Responses to Comments 1-10 and 2-19.
Response to Comment 2-6
The City acknowledges increased attention to bird-window collisions and continues to address
potential risks through implementation of applicable state and local regulations. The IS/MND did
not specifically analyze bird-window collisions; however, CEQA does not require evaluation or
mitigation of speculative impacts absent substantial evidence that a project would have a
significant effect on biological resources. The project site is located in a developed, urbanized
setting and is not adjacent to large water bodies or expansive natural habitat typically associated
with elevated collision risk. Ms. Smallwood’s speculative collision fatality estimates based on window area and published collision rates, such projections rely on generalized data from varied
building types and locations rather than site-specific conditions for this mid-rise infill project. The
collision fatality estimates are not supported by substantial evidence and are therefore speculative
for evaluation (CEQA Guidelines Sections 15064[d][3] and 15145). The City enforces existing
state and local regulations that protect migratory and nesting birds during construction and applies
building and lighting standards that are intended, in part, to reduce potential hazards to wildlife
over time. Regarding the commenter’s suggested mitigation measures (i.e., bird-safe glass
treatments, window films, exterior markers), mitigation is not necessary as no potential significant
impacts have been identified. Moreover, such measures would only be appropriate where
substantial evidence demonstrates elevated collision risk. Absent such evidence specific to this
project site, imposition of these measures is not required under CEQA. The proposed apartment
complex would not contain any glass façades (other than windows) or glass walkways, which are
cited in Smallwood’s analysis. Rather, the project would include Spanish architecture with stucco
exterior. Based on the project’s setting and compliance with applicable regulations, the project would not have a significant impact on migratory or resident bird species related to building design
or operation, and no additional analysis or mitigation is required pursuant to CEQA. Refer also to
Response to Comment 2-20.
Response to Comment 2-7
The project would not create a significant new source of wildlife roadkill, and thus, potential traffic-
related wildlife mortality impacts are considered less than significant. The commenter’s assertion
that 1,800 to 4,600 additional animal fatalities per year would occur due to project traffic is
unsupported by site-specific evidence and is therefore speculative (CEQA Guidelines Sections
15064[d][3] and 15145). Such figures are derived from studies including rural highways (Vasco
Road in Contra Costa County) as well as the commenter’s urban/suburban study in Davis,
California; however, neither study reflects conditions comparable to the project’s infill location along already-developed arterial roads in Carlsbad. The proposed project would add traffic
primarily to busy urban streets (e.g., College Boulevard, El Camino Real) where wildlife presence
4 US Fish and Wildlife Service (USFWS). Coastal California Gnatcatcher Species Profile. https://www.fws.gov/story/coastal-california-gnatcatcher.
June 3, 2026 Item #1 218 of 417
is relatively low compared to the rural and semi-rural study areas cited by the commenter. Large
mammals and sensitive species are rarely found on these roadways and local data does not
indicate unusual roadkill hotspots that would be exacerbated by the project. The IS/MND did not identify such conditions as resulting in a significant impact because any incremental increase in
collisions with common wildlife (such as small rodents or rabbits) would be unlikely to cause a
substantial population decline or threaten any sensitive species. Implementation of standard
operational practices along with the project’s infill nature (which inherently directs traffic onto
developed roads) and minimal direct interaction with undeveloped habitat, would ensure that the
effect of project traffic on wildlife is less than significant. No mitigation is required under CEQA as
the impact does not meet significance criteria (CEQA Guidelines Section 15126.4[a][3]). Refer also to Response to Comment 2-21.
Response to Comment 2-8
The IS/MND’s analysis of cumulative biological impacts is consistent with the CEQA Guidelines
Section 15063(b) and fully considers the project’s contribution to regional habitat loss and species
decline in Carlsbad. The adopted HMP serves as a comprehensive mitigation program for
cumulative biological effects by establishing a regionwide preserve system and requiring project-
specific habitat mitigation fees or conservation measures for development in non-preserve areas. The project, located on a site designated for development under the HMP (and not within a
hardline preserve), would comply with all applicable HMP requirements. This includes preserving
the on-site Diegan coastal sage scrub habitat patch, thereby addressing the project’s part in the
regional conservation strategy. In any event, the IS/MND did not identify a cumulatively
considerable impact to specific species or resources. In the broader view, previous disturbance
and grading (in 2007) on the project site have reduced much of the site’s habitat value (and
associated species), and the current project would implement mitigation to address potentially significant impacts. Considering these factors, the City finds that the project’s incremental effects
on biological resources, when viewed in combination with past and future development in
Carlsbad, would not be cumulatively considerable. The conclusion of less than significant
cumulative impacts is supported by project consistency with the HMP and lack of evidence of a
cumulatively significant decline in biological resources attributable to the project. Refer also to
Response to Comment 2-22.
Response to Comment 2-9
As stated in the IS/MND, the project could result in potentially significant impacts to coastal
California gnatcatcher and Crotch’s bumble bee. MM BIO-1 and MM BIO-2 would reduce potential
impacts to these species to less than significant levels.
MM BIO-1 establishes clear performance standards to avoid and minimize indirect impacts to
coastal California gnatcatchers, including protection of active nests and limitation of
construction-related disturbance. The mitigation measure requires installation of a no-disturbance
buffer around any active coastal California gnatcatcher nest identified by a qualified biologist and
implementation of construction controls to ensure disturbance levels remain below thresholds that
could adversely affect nesting behavior. Consistent with USFWS guidance, these performance
standards are intended to meet or exceed commonly recommended buffers (e.g., approximately 500 feet) and construction noise limits during the breeding season, unless a qualified biologist
determines that site-specific conditions support an alternative protective distance or additional
measures. The City acknowledges that USFWS guidance commonly recommends a minimum
June 3, 2026 Item #1 219 of 417
500-foot buffer around active gnatcatcher nests and includes construction noise thresholds
intended to limit disturbance during the breeding season. USFWS guidance also allows these
buffers and noise controls to be refined based on site-specific conditions, nest location,
topography, intervening screening, and the nature of construction activities. In no circumstances
shall a buffer of less than 100 feet be used even with noise attenuation measures. Any reduction
in the 500-foot no-disturbance buffer must be supported by site-specific analysis by the qualified
biologist and approved by the City in consultation with USFWS. As a result, MM BIO-1 ensures
that protective measures consistent with USFWS recovery objectives will be implemented, and
the absence of a pre-approval protocol survey will not result in any unmitigated significant impact.
Because the coastal California gnatcatcher is a covered species by the City HMP, the HMP holistically addresses species concerns on a broader ecosystem scale. By establishing a citywide
preserve system with core areas interconnected with wildlife movement corridors, the City is
protecting the gnatcatcher at buildout and in perpetuity, while allowing development in appropriate places.
For Crotch’s bumble bee, MM BIO-2 ensures that focused surveys will occur at the appropriate
time (during the flowering/active season) before any ground disturbance, when the species is
most active and detection is most likely. Subsequent to release of the IS/MND for public review,
a site-specific three-survey protocol design was approved by CDFW. The three Crotch’s bumble
bee surveys were conducted in April and May 2026. Crotch’s bumble bee was not detected in any
of the three surveys and the negative findings were reported to CDFW.
Response to Comment 2-10
Refer to Responses to Comments 2-2 through 2-9. The comment summarizes SAFER’s position
that an EIR is required, but it does not introduce new factual issues beyond those addressed in
Comments 2-2 through 2-9. The City has provided detailed responses above, demonstrating that the IS/MND adequately evaluated and mitigated the project’s impacts on biological resources. As
such, the record does not contain substantial evidence of a potentially significant effect that
remains unmitigated and the IS/MND satisfies CEQA requirements for the project. Therefore,
preparation of an EIR is not required.
Response to Comment 2-11
The comment raises the issue of whether the IS/MND’s focus on special-status species
overlooked broader impacts to the general wildlife community. Pursuant to CEQA, analysis must be commensurate with the potential for significant impacts. In practice, as reflected in Appendix
G of the CEQA Guidelines, CEQA prioritizes special-status species and sensitive habitats as
proxies for broader ecological health. The IS/MND’s biological analysis evaluated the project site’s
overall habitat value and common wildlife use. It identified the site as mostly disturbed grassland
with a small area of Diegan coastal sage scrub, supporting a typical assemblage of urban-edge
wildlife (various birds, small mammals, reptiles). The project’s expected effects on this common
wildlife assemblage – primarily through habitat removal – were determined to be minor because the site is not unique or critical for those species, and similar habitat is widespread nearby. The
project does not propose any action that would eliminate an entire species or cause wildlife
populations to fall below self-perpetuating levels; thus, the broad CEQA mandate to protect all
wildlife is not violated. In summary, the City has considered the wildlife community and finds that
the project would not result in a significant adverse change to local fauna or ecological
communities. The analysis appropriately emphasizes special-status species and sensitive
June 3, 2026 Item #1 220 of 417
communities as required by CEQA, and no further generalized wildlife impact analysis is
necessary.
Response to Comment 2-12
The City acknowledges that Ms. Smallwood’s March 2026 site visit identified more total species
than the January 2026 survey reported; however, this does not indicate a deficiency in the IS/MND
analysis. Many factors influence wildlife detectability (season, time of day, survey duration, etc.),
and it is expected that an early spring survey would record more migratory and breeding bird
activity than a mid-winter survey. However, the additional species noted by Ms. Smallwood were
predominantly common birds and one or two raptor species, all of which are typical for the area
and none of which represent previously unknown sensitive species. Ms. Smallwood extrapolated from the March survey data to predict that extended surveys would detect 166 vertebrate wildlife
species (including 31 special-status species); however, such statistical modeling does not
constitute substantial evidence and is therefore speculative (CEQA Guidelines Sections
15064[d][3] and 15145). In fact, the modeling relies on extrapolation from brief survey periods and
assumes detection patterns from distant study sites (Altamont Pass) are transferable to this
urban-edge infill parcel. Such assumptions are unwarranted and not based on fact.
Regarding the commenter’s assertion that breeding-season detection surveys for burrowing owl were not conducted as recommended by CDFW (2012), the project site lacks suitable burrowing
owl habitat (e.g., open grassland with ground squirrel burrows or similar structures); therefore,
protocol-level burrowing owl surveys were not warranted.
Further, the IS/MND conclusions would not change even when considering those additional
observations, because the significance of a biological impact under CEQA depends on the nature
of the impact, not simply the presence of common species. All of the species observed by Ms.
Smallwood are generally well-adapted to urban environments or would continue to be supported in the region after project implementation (e.g., in yards, parks, and nearby open space).
Preservation of the on-site Diegan coastal sage scrub habitat and implementation of mitigation
(e.g., timing restrictions and buffers for nesting birds) as proposed with the project would further
ensure that loss of the site’s wildlife usage would not cause significant ecological harm. While the
site provides temporary habitat for a variety of wildlife, the overall environmental setting was
accurately captured in the IS/MND and demonstrates that the project is unlikely to significantly
impact local wildlife populations. Refer also to Responses to Comments 2-3 through 2-7.
Response to Comment 2-13
CEQA does not require analysis of impacts that are speculative or unlikely to occur (CEQA
Guidelines Sections 15064[d][3] and 15145). The preparers of the IS/MND followed standard
practice by using the CNDDB as a primary tool to identify special-status species previously
documented in the vicinity of the site. Contrary to the commenter’s assertion that the City’s
biologist “relied on only one database,” the biological resources analysis also consulted the
California Native Plant Society inventory, USFWS Information for Planning and Consultation
(IPaC), and other resources for federally protected species and critical habitat, ensuring a broad
initial list of species for consideration. It is true that CNDDB is a “positive occurrence” database;
however, it remains the most authoritative source for known locations of sensitive species in
California, and it was appropriately used to flag species for analysis. The IS/MND did not assume that absence of a CNDDB record equates to absence of a species; rather, absence of records
plus lack of suitable habitat on-site led to conclusions of “not expected.” This is a scientifically
June 3, 2026 Item #1 221 of 417
valid approach, as the potential for a species to occur is inherently tied to whether the environment
can support it. The commenter’s claim that 143 special-status species were “known to occur near”
the site is an over-inclusive list that effectively combines all species reported from a broad region (up to 30 miles away, per Dr. Smallwood’s Exhibit A) and is therefore speculative (CEQA
Guidelines Sections 15064[d][3] and 15145). The City’s biologists reasonably narrowed the list to
46 special-status species for detailed evaluation, focusing on those with ranges, habitat
requirements, and occurrence records suggesting a plausible presence on or immediately
adjacent to this infill site. For example, wetland- and aquatic-dependent species, as well as
species requiring large habitats, were screened out because the project site contains no wetlands,
streams, or extensive natural communities to support them. This is consistent with CEQA, which does not require analysis of every species, but rather allows for a more focused consideration of
those species having a reasonable potential to be impacted. This direction supports focusing
species-level analysis only on those with a reasonable potential for impact.
In summary, the desktop review conducted by the City’s biologists provided a foundation for the
field survey and impact analysis, emphasizing those species having the potential to be present
and did not “misuse” the CNDDB. Instead, it combined CNDDB data with habitat assessment and professional judgment to focus the analysis on relevant species. The result was that the IS/MND
closely examined all biological resources that may be significantly affected by the proposed
development and no substantial evidence has been presented that additional undetected special-
status species are present on the site. Therefore, the City finds the environmental setting
description and species occurrence analysis to be adequate.
Response to Comment 2-14
The comment questions whether the IS/MND mischaracterized the site’s wildlife community due to limited survey effort and an “inappropriately small pool” of species considered. While no survey
can document every species on a site, the purpose of the CEQA baseline is to capture the
presence of resources in sufficient detail to inform impact analysis. The IS/MND identified the key
habitats on-site, the common wildlife using those habitats, and the special-status species with
potential to occur. Additional context, such as regional species lists or statistical detection
probability analyses, can be useful for academic study; however, CEQA does not require
exhaustive surveys if the anticipated impacts can be understood and mitigated with available information. The “true wildlife community” of the site is not expected to include rare or unusual
species beyond those already accounted for. Even without documenting every single species, the
IS/MND’s conservative approach (e.g., assuming coastal California gnatcatcher present based
on one observation, assuming Crotch’s bumble bee could be present despite none observed)
ensured that if a potentially sensitive wildlife resource existed, it was considered. The conclusion
that impacts would be less than significant (with mitigation for sensitive species) remains valid.
Preparing an EIR or conducting additional surveys would not change the outcome; the exercise
would simply confirm that the site is used primarily by common species and potentially a limited
number of special-status species that the IS/MND has already addressed. Pursuant to CEQA, the
adequacy of the environmental setting is judged by whether it provides decision-makers with
sufficient information to assess potential impacts. Thus, the City finds no evidence of a deficiency in the baseline characterization provided in the IS/MND that would warrant a revised impact
prediction or additional mitigation beyond that already proposed.
June 3, 2026 Item #1 222 of 417
Response to Comment 2-15
The commenter’s Table 2 (Exhibit A) lists 143 special-status wildlife species and implies that the
IS/MND should have analyzed each one’s potential occurrence. The City maintains that such an expansive analysis is unnecessary and would not yield meaningful additional protection to
biological resources. The analysis in the IS/MND is focused on the subset of species with non-
negligible likelihood of occurrence, considering such factors as habitat presence/absence and
known species distributions. Many species in the commenter’s table require habitat types not
present on the project site (e.g., vernal pools for fairy shrimp, open water for waterfowl, large
undisturbed tracts for certain mammals) or are migratory birds unlikely to rely on this small,
disturbed parcel for any significant portion of their life cycle. Including numerous “in-region” species—some documented miles away—would not change the impact analysis, as the project
would not affect those species in the absence of suitable habitat or site usage. CEQA does not
require an agency to analyze every species; rather, it requires agencies to use their best
judgment, based on substantial evidence, to evaluate resources that could be substantially
impacted by a project. The project-specific Biological Resources Technical Report’s narrowed list
of 46 species was developed by considering special-status species that may conceivably use the
subject property. This methodology is consistent with the CEQA Guidelines and longstanding practice in biological impact assessments. Therefore, the City finds that the list provided by the
commenter does not represent the actual “wildlife community” of the project site, and no additional
significant impacts would be identified by analyzing all such species. The IS/MND’s conclusions
remain accurate based on the evidence gathered for the species that are considered relevant in
this context.
Response to Comment 2-16
The analysis provided in the IS/MND is not considered to be speculative; it is based on scientific data, including literature review and a habitat assessment/field survey conducted by qualified
biologists (refer to Response to Comment 2-13). CEQA requires a “good faith effort at full
disclosure” using the best available information, rather than absolute scientific certainty. In
preparing the IS/MND and Biological Resources Technical Report, the City’s biologists drew upon
professional experience, established scientific literature, and resource agency guidance to
evaluate the project’s likely effects. For example, the assessment of Crotch’s bumble bee followed
CDFW guidance for evaluating projects with potential bumble bee habitat. Impact conclusions in the IS/MND are supported by either empirical observations (e.g., the site survey and reference to
historical surveys) or by accepted ecological principles (e.g., understanding that small, isolated
habitat patches have limited carrying capacity for wildlife). The commenter advocates for
extensive comparative data and post-project monitoring to validate predictions, efforts that go far
beyond what CEQA requires for an individual project. Rather, a lead agency is required to consider
available data and make reasonable assumptions in determining whether a significant impact may
occur. In conforming with this approach, the IS/MND conservatively assumes the presence of sensitive species on-site and identifies appropriate mitigation based on available data, without
resorting to speculation. The IS/MND’s analyses and mitigation measures were formulated using
expertise and recognized standards and represents a scientifically sound basis pursuant to CEQA
requirements. For these reasons, the impact assessment provided in the IS/MND is considered
to be adequate and non-speculative.
June 3, 2026 Item #1 223 of 417
Response to Comment 2-17
As addressed in Response to Comment 2-3, the on-site habitat (aside from the preserved Diegan
coastal sage scrub patch) is of relatively low ecological value and its proposed removal would not cause a significant decline in regional bird populations. The comments provided assume that all
61 hypothetical nest sites and 278 birds produced annually on the property would be permanently
lost. However, such assumptions do not constitute substantial evidence and are therefore
speculative (CEQA Guidelines Sections 15064[d][3] and 15145). Further, this analysis does not
account for the fact that birds and other wildlife are mobile and would relocate to adjacent habitats
(including the preserved on-site patch and nearby open spaces) as the site is developed.
Moreover, the Diegan coastal sage scrub patch would remain intact, meaning nesting capacity for species such as wrentits and California towhees would persist on-site. The City’s
determinations are guided by Appendix G of the CEQA Guidelines, which does not treat the loss
of each individual bird or nest as a significant impact if it does not threaten a species’ population
viability or otherwise cause a substantial adverse change in the environment. Furthermore,
implementation of MM BIO-1 would require the project to avoid direct destruction of any active
nests (those with eggs or chicks) during construction, thereby complying with the Migratory Bird
Treaty Act and the California Fish and Game Code and preventing the direct take of birds. The IS/MND therefore appropriately determined that impacts from habitat loss (and associated
reduction in nesting/reproductive output) would be less than significant with mitigation measures
incorporated. A more expansive interpretation of significance (treating any reduction in wildlife
usage as “significant”) would be inconsistent with CEQA requirements to identify a substantial
adverse effect and would effectively make any development on disturbed land appear significant,
contrary to the intent of the CEQA Guidelines.
Response to Comment 2-18
As discussed in Response to Comment 2-4, the project would not significantly impact regional
wildlife movement. On-site vegetation and wildlife observations provided by the commenter do
not equate to a crucial movement corridor. Occasional foraging and movement on-site by wildlife
(e.g., birds collecting nest material or moving through the Diegan coastal sage scrub patch) would
not be blocked or substantially altered because the project design would leave the key habitat
area undeveloped and would implement measures to limit disturbance in that area. The site does
not have “stopover” value for migratory birds or other characteristics that would make it uniquely important. Migratory songbirds and other species can and do use a variety of green spaces
(including developed areas) during transit. The limited size of the parcel means its role as a
stopover is opportunistic, not critical. Additionally, the project would include a landscaping plan
with native trees and shrubs, which can provide some replacement for the low-quality foraging
habitat that would be removed with development of the site’s ruderal portions. The IS/MND’s
conclusions regarding wildlife movement were based on the absence of any large-scale corridor
and the urban context of the site, which the commenter does not refute. Further, CEQA does not require a project to maintain every minor usage of a site by wildlife. Rather, it asks whether a
project would substantially impede wildlife movement. Wildlife movement on the project site is
already constrained by existing development, and the project’s footprint does not extend into any
larger habitat block. The City finds that the project would not create a significant barrier or cause
wildlife movement to be substantially more constrained than under existing conditions.
Consequently, the impact remains less than significant, as originally addressed in the IS/MND.
June 3, 2026 Item #1 224 of 417
Response to Comment 2-19
The commenter’s assertion that the project would result in 6,344 wildlife kills per year by 52 free-
roaming cats is not supported by substantial evidence and is therefore speculative (CEQA Guidelines Sections 15064[d][3] and 15145). Predation by domestic cats on birds and other
wildlife is a recognized issue primarily associated with single-family residential development,
where cats can freely exit homes and roam yards and adjacent open space. In contrast, a multi-
level apartment building is inherently not conducive to free-roaming cats, as pets cannot
independently open doors or access elevators to enter or exit units. As a result, cats residing in
multi-family developments are predominantly, if not entirely, indoor pets, substantially reducing the likelihood of access to adjacent habitat.
Further, the assumed number of domestic cats associated with the project likely overestimates
for the project site and context, as they rely on national data that include areas with high feral cat
populations and sensitive ecosystems. Nonetheless, the City acknowledges that any avoidable
predation on wildlife is undesirable. Many of the potentially affected species (rodents, small birds)
are abundant in the region, and the project’s design and adherence to requirements set forth in
the City’s HMP, Objective Design Standards, and Landscape Manual would help ensure that increases in predation are minimized. The City therefore maintains that the project’s impact from
domestic animals would not result in a significant impact. This issue does not involve non-
compliance with any specific regulatory threshold as neither CEQA nor local ordinances consider
incremental pet predation a “significant impact” unless it affects a sensitive species or violates a
policy, which is not the case being considered in this scenario.
Response to Comment 2-20
The City has considered the issue of potential bird collisions with windows that would be installed on-site with the proposed residential development (see Response to Comment 2-6). Importantly,
it is not standard practice under CEQA to quantify expected bird fatalities for every project,
especially when a project is not located in a known migratory bird concentration area, nor is such
analysis required by law. The project’s location and scale do not suggest an unusually high
collision risk compared to typical urban development; rather, the project proposes a mid-rise
structure in a developed setting, similar to other buildings in Carlsbad that have not been
associated with noteworthy bird mortality events. Ms. Smallwood substantially overestimates the amount of exterior window area associated with the project, and her statement that bird-window
collision fatalities are higher than nationwide estimates is not supported by evidence and is
therefore speculative (CEQA Guidelines Sections 15064[d][3] and 15145). The IS/MND’s
conclusion that no significant operational impacts to avian species would occur remains valid.
Response to Comment 2-21
As addressed in Response to Comment 2-7, the project’s traffic-related wildlife impacts are
expected to be less than significant. The commenter cites studies of roadkill in various settings
(rural highways, semi-urban roads) and uses an inferred rate per vehicle-miles-traveled to predict
thousands of annual wildlife fatalities from project traffic. This information is not supported by
evidence and is therefore speculative (CEQA Guidelines Sections 15064[d][3] and 15145). The
project is estimated to generate approximately 2,382 average daily trips (ADTs) —contributing vehicle trips to major roadways that already experience tens of thousands of ADTs under existing
conditions. Any wildlife (mostly small mammals, reptiles, and birds typical of urban edges) on area
roadways are already subject to vehicle hazards. Dr. Smallwood overestimates vehicle miles
June 3, 2026 Item #1 225 of 417
traveled for the project by more than 72 percent compared to City’s analysis. The incremental
increase in traffic from the proposed project would be a fraction of total volumes and would not
create a new significant “death toll” for local wildlife. Additionally, evidence that such incremental road mortality would threaten any local wildlife populations or involve special-status species is not
presented. The City’s experience with similar infill projects in developed areas has not shown
traffic-wildlife collisions to rise to the level of CEQA significance. CEQA requires mitigation for
significant impacts; given the lack of substantial evidence linking project traffic to a significant
wildlife impact, additional specific mitigation is not merited (CEQA Guidelines Section
15126.4[a][3]). The project’s potential effect on wildlife from increased traffic is expected to be
negligible in the context of existing conditions.
Response to Comment 2-22
The IS/MND’s discussion of cumulative biological impacts (see also Response to Comment 2-8
above) is in line with the CEQA Guidelines Section 15063(b), which focus on whether a project’s
incremental contribution is cumulatively considerable. The City’s reasoning, in combination with
the findings of its biologists, is that the project’s contribution to area-wide habitat loss and wildlife
impacts are addressed through existing frameworks. Specifically, the HMP and related programs
have already accounted for the cumulative loss of habitats, including on the project site, and have set aside conservation areas to balance growth. The project would be consistent with the HMP
by avoiding direct impacts to sensitive on-site habitat (thus not diminishing the preserved open
space network) and implementing HMP standards to protect adjacent natural lands. In addition,
no aspect of the project would produce a unique or additive effect on biological resources in
combination with other projects. Project-related construction noise would be temporary and
localized; any incremental pet or lighting effects would be managed on-site; and the project would
not substantially affect regional wildlife corridors or water resources. The commenter references a generalized study pertaining to mitigation effectiveness. As such, this claim is not supported by
substantial evidence and is therefore speculative (CEQA Guidelines Sections 15064[d][3] and
15145). The City can only evaluate the specific context and mitigation for the proposed project.
Based on the evidence, the project would not result in a considerable contribution to cumulative
biological resource issues such as habitat fragmentation or species decline. Other future
development proposed in the project vicinity would also be required to comply with applicable
HMP and CEQA regulations to ensure that overall cumulative effects remain mitigated to the degree feasible. The IS/MND conclusion that the proposed project would not contribute to a
significant cumulative impact on biological resources remains valid.
Response to Comment 2-23
MM BIO-1 was originally formulated to be flexible, recognizing that appropriate buffer distances
can depend on factors such as avian behavior, location of the nest, existing ambient noise, and
the nature of construction activity.
To directly address the concern raised, the City has updated MM BIO-1 (Pre-Construction Nesting
Bird Surveys, Avoidance, and Notification) to require that, if a gnatcatcher nest is found during
pre-construction surveys, a minimum 500-foot wide no-disturbance buffer be established around
the nest and maintained until a qualified biologist confirms that the young have fledged, the nest
is no longer active, or that construction noise levels can be maintained below 60 dBA Leq at the nest site with a smaller buffer.
June 3, 2026 Item #1 226 of 417
A “qualified biologist” is defined as a professional biologist with demonstrated experience
conducting nesting bird surveys in southern California coastal habitats and familiarity with the
identification, behavior, and nesting ecology of avian species known to occur in the region, including federally listed species such as the coastal California gnatcatcher. By incorporating
these specifics—a numeric distance, noise criteria, and biologist qualifications—MM BIO-1 would
have clear performance standards. Specifically, MM BIO-1 from the public review IS/MND stated:
MM BIO-1 Pre-Construction Bird Surveys, Avoidance, and Notification. If construction
activities are initiated during the bird nesting season (February 1–August 31)
involving removal of vegetation or other nesting bird habitat, including abandoned
structures and other man-made features, a pre-construction nesting bird survey shall be conducted no more than 14 days prior to initiation of ground disturbance
and vegetation removal activities. The nesting bird pre-construction survey shall
be conducted on foot and shall include a 300-foot survey buffer around the
construction site. The survey shall be conducted by a biologist familiar with the
identification of avian species known to occur in southern California coastal
communities (i.e., qualified biologist). If active nests are found, an avoidance buffer
shall be determined by a qualified biologist in coordination with the City. The avoidance buffer width will depend upon the species, the proposed work activity,
and existing disturbances associated with land uses outside of the site, which shall
be demarcated by the biologist with bright orange construction fencing, flagging,
construction lathe, or other means to demarcate the boundary. All construction
personnel shall be notified as to the existence of the buffer zone and to avoid
entering the buffer zone during the nesting season. No ground-disturbing activities
shall occur within the buffer until the biologist has confirmed that breeding/nesting is completed, and the young have fledged the nest. Encroachment into the buffer
shall occur only at the discretion of the qualified biologist on the basis that the
encroachment will not be detrimental to an active nest. A report summarizing the
pre-construction survey(s) shall be prepared by a qualified biologist and shall be
submitted to the City prior to the commencement of construction activities.
Note: To mitigate the potential impact to California gnatcatcher or other nesting
birds, this mitigation measure shall be applied to land use and activities occurring
at the project site. No Pre-Construction Bird Surveys, Avoidance, and Notification
mitigation is required to implement the Study Area-Off-Site Sewer Line portion of
the project.
MM BIO-1 has been revised as follows (the bird survey window has been revised to a minimum
of three days prior to ground disturbance, and the second paragraph is newly added text):
MM BIO-1 Pre-Construction Nesting Bird Surveys, Avoidance, and Notification. If
construction activities are initiated during the bird nesting season (February 1–
August 31) involving removal of vegetation or other nesting bird habitat, including
abandoned structures and other man-made features, a pre-construction nesting
bird survey shall be conducted no more than three days prior to initiation of ground
disturbance and vegetation removal activities. The nesting bird pre-construction
survey shall be conducted on foot and shall include a 300-foot survey buffer around
the construction site. The survey shall be conducted by a biologist familiar with the
identification of avian species known to occur in southern California coastal
June 3, 2026 Item #1 227 of 417
communities (i.e., qualified biologist). If active nests are found, an avoidance buffer
shall be determined by a qualified biologist in coordination with the City. The
avoidance buffer width will depend upon the species, the proposed work activity, and existing disturbances associated with land uses outside of the site, which shall
be demarcated by the biologist with bright orange construction fencing, flagging,
construction lathe, or other means to demarcate the boundary. All construction
personnel shall be notified as to the existence of the buffer zone and to avoid
entering the buffer zone during the nesting season. No ground-disturbing activities
shall occur within the buffer until the biologist has confirmed that breeding/nesting
is completed, and the young have fledged the nest. Encroachment into the buffer shall occur only at the discretion of the qualified biologist on the basis that the
encroachment will not be detrimental to an active nest. A report summarizing the
pre-construction survey(s) shall be prepared by a qualified biologist and shall be
submitted to the City prior to the commencement of construction activities.
If an active coastal California gnatcatcher nest is found during pre-construction
surveys, a minimum 500-foot no-disturbance buffer shall be established around
the nest. The buffer shall be clearly marked (e.g., with fencing or flagging) and maintained until a qualified biologist confirms that the young have fledged, the nest
is no longer active, or that construction noise levels can be maintained below 60
dBA Leq at the nest site with a smaller buffer. In no circumstances shall a buffer of
less than 100 feet be used even with noise attenuation measures. Any reduction
in the 500-foot buffer must be supported by site-specific analysis by the qualified
biologist and approved by the City in consultation with the US Fish and Wildlife
Service.
Note: To mitigate the potential impact to California gnatcatcher or other nesting
birds, this mitigation measure shall be applied to land use and activities occurring
at the project site. No Pre-Construction Nesting Bird Surveys, Avoidance, and
Notification mitigation is required to implement the Study Area-Off-Site Sewer Line
portion of the project.
It is also noted that such clarification to MM BIO-1 does not represent “significant new information”
as defined in CEQA Guidelines Section 15088.5. The revised MM BIO-1 is more effective than that presented in the Draft IS/MND. Therefore, recirculation of the IS/MND prior to adoption is not
required (CEQA Guidelines Sections 15073.5[c][1] and 15074.1).
Regarding Crotch’s bumble bee, a site-specific three-survey protocol design was approved by
CDFW subsequent to release of the IS/MND for public review. The three subsequent surveys
were conducted in April and May 2026. Crotch’s bumble bee was not detected in any of the three
surveys and the negative findings were reported to CDFW.
Response to Comment 2-24
The City has reviewed the additional measures suggested by the commenter, including
compensatory habitat protection at a 5:1 ratio, bird-safe glass treatments, native plant
landscaping, and funding for wildlife rehabilitation facilities. The project’s biological resource
impacts have been reduced to a less than significant level through the mitigation measures identified in the IS/MND (including MM BIO-1 and MM BIO-2), project design (including
avoidance/preservation of the on-site Diegan coastal sage scrub), and applicable HMP
June 3, 2026 Item #1 228 of 417
requirements and Adjacency Standards. Regarding compensatory habitat protection, the project’s
compliance with HMP requirements addresses the project’s contribution to habitat loss within the
established regional framework. Bird-safe glass treatments are addressed in Response to Comment 2-6. Native plant landscaping is encouraged through the project’s landscaping plan,
which includes native trees and shrubs; however, mandatory native-only landscaping
requirements are not necessary to reduce impacts to less than significant levels. As the mitigation
identified for the project would adequately reduce project impacts to less than significant,
additional mitigation measures beyond those already required are not warranted under CEQA
(CEQA Guidelines Section 15126.4[a][3]).\
June 3, 2026 Item #1 229 of 417
Salk Avenue Apartments Project
Mitigation Monitoring and Reporting Program
SCH No. 2026030432
May 2026
Lead Agency: Prepared by:
City of Carlsbad
Community Development Department
1635 Faraday Avenue
Carlsbad, CA 92008
Michael Baker International
5050 Avenida Encinas, Suite 260
Carlsbad, CA 92008
JN 205484
Attachment B
June 3, 2026 Item #1 230 of 417
June 3, 2026 Item #1 231 of 417
Mitigation Monitoring and Reporting Program __________________________ Salk Avenue Apartments Project
Page 1
MITIGATION MONITORING AND REPORTING PROGRAM
INTRODUCTION
This Mitigation Monitoring and Reporting Program (MMRP) has been prepared in accordance
with the requirements of Public Resources Code (PRC) Section 21081.6. California
Environmental Quality Act (CEQA) Guidelines Section 15097 states:
In order to ensure that the mitigation measures and project revisions identified in the EIR
or negative declaration are implemented, the public agency shall adopt a program for
monitoring or reporting on the revisions which it has required in the project and the
measures it has imposed to mitigate or avoid significant environmental effects. A public
agency may delegate reporting or monitoring responsibilities to another public agency or
to a private entity which accepts the delegation; however, until mitigation measures have
been completed, the lead agency remains responsible for ensuring that implementation of
the mitigation measures occurs in accordance with the program.
ENFORCEMENT
In accordance with CEQA, the primary responsibility for making determinations with respect to
potential environmental effects rests with the lead agency rather than with the monitor or preparer.
As such, the City of Carlsbad (City) is identified as the enforcement agency for this MMRP.
MITIGATION MONITORING AND REPORTING PROGRAM
As the lead agency, the City will be primarily responsible for monitoring project compliance with
all required mitigation measures. The MMRP identifies the responsible parties for ensuring each
measure is completed; it is expected that one or more parties may coordinate efforts to ensure
compliance.
The MMRP is presented in tabular form on the following pages. The components of the MMRP
are described briefly below.
•Mitigation Measure Number: Provides the mitigation measure number as identified in
the Focused Initial Study/Mitigated Negative Declaration.
•Mitigation Measure: Identifies the details of each mitigation measure required.
•Timeframe of Mitigation: Identifies at which stage of the project the mitigation measure
must be completed.
•Responsible Party: Identifies the party or parties with responsibility for mitigation
monitoring, enforcement, and reporting.
June 3, 2026 Item #1 232 of 417
Mitigation Monitoring and Reporting Program _______________________________________________________________________________ Salk Avenue Apartments Project
Page 2
MITIGATION MONITORING AND REPORTING PROGRAM
Mitigation
Measure
No. Mitigation Measure
Timeframe
of Mitigation
Monitoring,
Enforcement,
and Reporting
Responsibility
Biological Resources
BIO-1 Pre-Construction Nesting Bird Surveys, Avoidance, and Notification. If construction activities are initiated
during the bird nesting season (February 1–August 31) involving removal of vegetation or other nesting bird
habitat, including abandoned structures and other man-made features, a pre-construction nesting bird survey
shall be conducted no more than three days prior to initiation of ground disturbance and vegetation removal
activities. The nesting bird pre-construction survey shall be conducted on foot and shall include a 300-foot
survey buffer around the construction site. The survey shall be conducted by a biologist familiar with the
identification of avian species known to occur in southern California coastal communities (i.e., qualified
biologist). If active nests are found, an avoidance buffer shall be determined by a qualified biologist in
coordination with the City. The avoidance buffer width will depend upon the species, the proposed work activity,
and existing disturbances associated with land uses outside of the site, which shall be demarcated by the
biologist with bright orange construction fencing, flagging, construction lathe, or other means to demarcate the
boundary. All construction personnel shall be notified as to the existence of the buffer zone and to avoid
entering the buffer zone during the nesting season. No ground-disturbing activities shall occur within the buffer
until the biologist has confirmed that breeding/nesting is completed, and the young have fledged the nest.
Encroachment into the buffer shall occur only at the discretion of the qualified biologist on the basis that the
encroachment will not be detrimental to an active nest. A report summarizing the pre-construction survey(s)
shall be prepared by a qualified biologist and shall be submitted to the City prior to the commencement of
construction activities.
If an active coastal California gnatcatcher nest is found during pre-construction surveys, a minimum 500-foot no-
disturbance buffer shall be established around the nest. The buffer shall be clearly marked (e.g., with fencing or
flagging) and maintained until a qualified biologist confirms that the young have fledged, the nest is no longer
active, or that construction noise levels can be maintained below 60 dBA Leq at the nest site with a smaller
buffer. In no circumstances shall a buffer of less than 100 feet be used even with noise attenuation measures.
Any reduction in the 500-foot buffer must be supported by site-specific analysis by the qualified biologist and
approved by the City in consultation with the US Fish and Wildlife Service.
Note: To mitigate the potential impact to California gnatcatcher or other nesting birds, this mitigation measure
shall be applied to land use and activities occurring at the project site. No Pre-Construction Nesting Bird
Surveys, Avoidance, and Notification mitigation is required to implement the Study Area-Off-Site Sewer Line
portion of the project.
Prior to
Ground
Disturbance /
During
Construction
as Applicable
City of Carlsbad
Public Works
Department /
Qualified
Biologist /
Construction
Contractor
June 3, 2026 Item #1 233 of 417
Mitigation Monitoring and Reporting Program _______________________________________________________________________________ Salk Avenue Apartments Project
Page 3
Mitigation
Measure
No. Mitigation Measure
Timeframe
of Mitigation
Monitoring,
Enforcement,
and Reporting
Responsibility
BIO-2 Crotch’s Bumble Bee Avoidance and Clearance Survey
•Focused Survey. Three on-site surveys for Crotch’s bumble bee (CBB) shall be conducted prior to initiation
of ground disturbing project activities to identify if the CBB is present within the project site. This survey
shall be conducted simultaneously with the blooming period of the species’ recognized food plants, when
the CBB is most active. Each survey shall be spaced at least 2 weeks but no more than 4 weeks apart,
corresponding with the Colony Active Season for Bombus species (April–August). The surveying biologist
shall be familiar with the primary identification characteristics of the CBB and be proficient in the
methodology produced by the Xerces Society. The qualified biologist shall utilize a telephoto lens or a
sufficiently long macro lens to obtain high-quality photos of bumble bees, sufficient for species identification,
without having to capture and potentially harm the bumble bees.
•Absence of Species. If no CBB are detected during the focused surveys, no further measures shall be
necessary.
•Presence of Species. If CBB are detected, then site-specific measures shall be implemented to avoid take
unless an Incidental Take Permit (ITP) for the species is obtained from California Department of Fish and
Wildlife (CDFW). Such avoidance measures shall include:
o If vegetation removal activities and initial ground-disturbing activities (i.e., clearing, grubbing, and initial
site grading) occur during the Queen and Gyne Flight Period and Colony Active Period for these species
(February–October), a qualified biologist shall conduct daily biological monitoring. During monitoring, the
qualified biologist shall inspect suitable habitat for CBB activity within the day’s work area. If the species
is not detected, then project activities can proceed without further biological monitoring that day.
o If the CBB is detected using nectar sources, then a no-disturbance buffer of at least 25 feet around the
individual(s) shall be established, and the individual(s) shall be monitored by a biological monitor until the
CBB are confirmed to have left the area on their own.
o If a CBB nest is detected where ground disturbance is proposed to occur, then a minimum 30-foot no-
disturbance buffer (with a buffer of up to 60 feet if disturbance is substantial) around the nest shall be
established. This buffer shall remain in place until the nest senesces, which would occur after no nest
activity observations for three sequential days. The qualified biologist shall discuss the buffer with the
contractor to ensure that work areas, including ingress and egress routes, avoid the CBB.
o If the project cannot avoid the established no-disturbance buffer(s) identified above, the project applicant
shall halt work within the buffer area and shall consult with CDFW on appropriate avoidance actions and
obtain an Incidental Take Permit if necessary.
Note: To mitigate the potential impact to Crotch’s Bumble Bee (CBB), this mitigation measure shall be applied to
land use and activities occurring at the project site. No CBB Avoidance and Clearance Survey mitigation is
required to implement the Study Area-Off-Site Sewer Line portion of the project.
Prior to
Ground
Disturbance /
During
Construction
as Applicable
City of Carlsbad
Public Works
Department /
Qualified
Biologist /
Construction
Contractor
June 3, 2026 Item #1 234 of 417
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF
CARLSBAD, CALIFORNIA, APPROVING A SITE DEVELOPMENT PLAN SDP
2025-0004 TO ALLOW FOR THE DEVELOPMENT OF A 397-UNIT, FIVE-
STORY, MULTIFAMILY RESIDENTIAL STRUCTURE WITH 548 VEHICULAR
PARKING SPACES BOTH AT GRADE AND WITHIN AN ATTACHED, FIVE-
STORY PARKING STRUCTURE ON A 9.78-ACRE PROPERTY GENERALLY
LOCATED ON SALK AVENUE BETWEEN COLLEGE BLVD AND EL CAMINO
REAL (ASSESSOR PARCEL NO. 212-021-04-00), WITHIN THE FENTON
CARLSBAD CENTER SPECIFIC PLAN, IN THE NORTHWEST QUADRANT
OF THE CITY, THE RD-M ZONE, AND LOCAL FACILITIES MANAGEMENT
ZONE 5
CASE NAME: SALK AVENUE APARTMENTS
CASE NO.: SDP 2025-0004 (DEV2025-0001)
WHEREAS, Hanover R.S. Limited Partnership, “Developer,” has filed a verified
application with the City of Carlsbad regarding property owned by Scripps Health, “Owner,”
described as
LOT 4 OF CARLSBAD TRACT NO. 00-20 FOX MILLER PROPERTY IN
THE CITY OF CITY OF CARLSBAD, COUNTY OF SAN DIEGO, STATE
OF CALIFORNIA, ACCORDING TO MAP THEREOF NO. 15253, FILED
IN THE OFFICE OF THE COUNTY RECORDER OF SAN DIEGO
COUNTY, JANUARY 30, 2006
(“the Property”); and
WHEREAS, an SB 131 Focused Initial Study and Mitigated Negative Declaration
(IS/MND) (State Clearinghouse No. 2026030432) was prepared in conjunction with said project,
and the Planning Commission has adopted it, along with the Mitigation Monitoring and Reporting
Program, per separate resolution; and
WHEREAS, said verified application constitutes a request for a Site Development
Plan as shown on Exhibit 12 to the June 3, 2026, Planning Commission staff report, SDP 2025-
0004 (DEV2025-0001), Salk Avenue Apartments (“Project”), on file in the Planning Division, as
provided by Section 21.53.120 of the Carlsbad Municipal Code; and
PLANNING COMMISSION RESOLUTION NO. 7579
Exhibit 2
June 3, 2026 Item #1 235 of 417
WHEREAS, the Planning Commission did, on June 3, 2025, hold a duly noticed
public hearing as prescribed by law to consider said request; and
WHEREAS, at said public hearing, upon hearing and considering all testimony and
arguments, if any, of all persons desiring to be heard, said Commission considered all factors
relating to the Site Development Plan land use application.
NOW, THEREFORE, BE IT HEREBY RESOLVED by the Planning Commission of the
City of Carlsbad as follows:
A) That the foregoing recitations are true and correct.
B) That based on the evidence presented at the public hearing, the Planning
Commission APPROVES SDP 2025-0004 – SALK AVENUE APARTMENTS
based on the following findings and subject to the following conditions:
Findings:
1. That the proposed development or use is consistent with the General Plan and any
applicable master plan or specific plan, complies with all applicable provisions of Chapter
21.06 of the Carlsbad Municipal Code, and all other applicable provisions of the Carlsbad
Municipal Code, in that the General Plan Land Use designation of the site allows for
multi-family residential use and the proposed development or use is consistent with
the General Plan and any applicable master plan or specific plan, complies with all
applicable provisions of Chapter 21.06 of the Carlsbad Municipal Code, and all other
applicable provisions of the municipal code, in that the various goals and objectives of
the General Plan will be implemented as the proposed Project is consistent with the
General Plan (Project Analysis provided in Exhibit 5 to the June 3, 2026 Planning
Commission staff report, which is incorporated herein as though fully set forth herein).
Although the Project's density of 40.6 dwelling units per acre is above the maximum R-
30 Residential density of 30 du/ac as the Project includes a request for a residential
density bonus, the 397-unit residential apartment project can be found consistent with
the General Plan Land Use designation.
2. That the requested development or use is properly related to the site, surroundings and
environmental settings, will not be detrimental to existing development or uses or to
development or uses specifically permitted in the area in which the proposed
development or use is to be located, and will not adversely impact the site, surroundings
or traffic circulation, in that in that multiple-family residential is a permitted use within
the Residential Density - Multiple (RD-M) Zone and is compatible with the other multi-
story development surrounding the Project site. The residential apartment project will
not adversely impact the site, surroundings, or traffic circulation in that the existing
June 3, 2026 Item #1 236 of 417
surrounding streets have adequate capacity to accommodate the 2,382 Average Daily
Trips (ADT) generated by the Project. With exception to the allowances for increased
building height, increased retaining wall height, and modified parking space
dimensions, through the density bonus process, the project complies with all minimum
development standards of the RD-M Zone, and the Project is adequately parked on-site,
in accordance with State Density Bonus Law. Moreover, the details of the request
include a reduction in development standards from the Citywide Objective Design
Standards (CMC Chapter 21.88). Relief or reduction from the design standards make it
feasible for the Developer to build to the density allowed by the zoning, as
reduced/amended by State Density Bonus Law, and does not constrain a local
government’s ability to achieve its RHNA housing targets.
For the waivers from development standards, adequate information has been provided
to show that the development standard for which the waiver or reduction is requested
will have the effect of physically precluding the construction of the Project.
3. That the site for the intended development or use is adequate in size and shape to
accommodate the use, in that the Project is entitled to the requested number of units
and the density bonus waivers are necessary for the Project to be developed at the
density permitted by State Density Bonus Law and CMC Chapter 21.86. With exception
to the allowance for increased building height, increased retaining wall height, and
modified parking space dimensions, requested through the density bonus process, the
residential apartment project complies with all remaining development standards of
the Residential Density - Multiple (RD M) Zone. The details of the request include a
reduction in development standards from the Citywide Objective Design Standards
(CMC Chapter 21.88). Relief or reduction from the design standards make it feasible for
the Developer to build to the density allowed by the zoning, as reduced/amended by
State Density Bonus Law, and does not constrain a local government’s ability to achieve
its RHNA housing targets.
4. That all yards, setbacks, walls, fences, landscaping, and other features necessary to adjust
the requested development or use to existing or permitted future development or use in
the neighborhood will be provided and maintained, in that with exception to the
allowance for increased building height, increased retaining wall height, and modified
parking space dimensions, the Project complies with all remaining development
standards (i.e. front, side and rear setbacks, lot coverage) of the RD-M Zone. Moreover,
the details of the request include a reduction in development standards from the
Citywide Objective Design Standards. Landscaping along the outer edges of the
property, including the areas along Salk Avenue, would be provided consistent with the
requirements of the city’s Landscape Manual. As such the Project is consistent,
compliant and in conformity with all applicable plans, programs, policies, ordinances,
standards, requirements, and other similar provisions.
5. That the street systems serving the proposed development or use is adequate to properly
handle all traffic generated by the proposed use, in that the Project will take access off
Salk Avenue with vehicles traveling to and from the project on Salk Avenue as well. Salk
June 3, 2026 Item #1 237 of 417
Avenue identified as an Industrial Street, designed to adequately handle the 2,382
Average Daily Trips generated by the 397-unit residential apartment project.
Furthermore, the Local Mobility Analysis for the project concluded that the access
driveway from Salk Avenue, an unsignalized intersection, would operate at a Level of
Service “B” during peak AM and PM hours and would not warrant installation of a signal
for the driveway.
Residential Density Bonus, CMC Chapter 21.86
6. The Project is consistent with the provisions of CMC Chapter 21.86 in that the proposed
residential apartment project meets all of the standards, including the requisite 15% of
"low income", deed-restricted inclusionary housing and the 20% "low income", deed-
restricted units per the Fenton Carlsbad Center Specific Plan. The Developer is
requesting 12 waivers as a part of this Project. The proposed waivers are for: (1) waiver
of location requirements for common recreational space; (2) proposed reduction in
screening requirements for parking spaces; (3) Proposed reduction in amount of
required common recreational space; (4) proposed reduction in landscape buffer
adjacent to ground level units; (5) proposed modification of wall plane variation; (6)
proposed modification of square footage of upper stories compared to ground floor; (7)
proposed modification of distance between roof line variations; (8) proposed increase
in the maximum building height (9) proposed modification in garage space dimension
within the parking structure; (10) proposed reduction in number of units required to
have private recreation space; (11) proposed modification in percentage of lower
income units which are three-bedroom units; and (12) proposing increase in the height
of retaining walls outside setback areas. These waivers (collectively resulting in
“reductions in development standards”) are legally mandated modifications that would
otherwise prevent the housing project from being built at the increased density. A by
right waiver is automatically granted when requested as long as the standard prevents
construction Adequate information has been provided to show that the development
standard for which the waiver or reduction is requested will have the effect of physically
precluding the construction of the Project.
To demonstrate compliance with the terms and limitations of CMC Chapter 21.86, the
Developer is required to enter into an Affordable Housing Agreement, which would be
recorded against the entire development and include specific Project information and
unit restrictions
7. The requested incentive(s} or concession(s}, and/or waiver(s) or reduction(s) of
development standards is not contrary to state or federal law in that increased number
of units and the requests are clearly laid out for density bonus projects in California
pursuant to CMC section 21.86.050 and Government Code section 65915.
No Net Loss
June 3, 2026 Item #1 238 of 417
8. Pursuant to Government Code section 65863 (No Net Loss Law), a local jurisdiction must
ensure that development opportunities remain available throughout the Housing
Element planning period to accommodate the jurisdiction’s Regional Housing Need
Allocation (RHNA). Based on the analysis provided in Exhibit 5 of the June 3, 2026,
Planning Commission staff report, the remaining sites in the Housing Element inventory
are adequate to meet the requirements of Section 65583.2 and to accommodate the
RHNA pursuant to Section 65584. The city’s Housing Element requires that the city
accommodate 3,873 low-/moderate-/above-moderate income units as its share of the
regional housing need, with 2,095 units allocated to the lower-income category, 749
units allocated to the moderate-income category, and 1,029 units allocated to the
above moderate-income category. As of this writing, if the Project is approved, the
analysis or the Housing Element’s sites inventory shows that the city would have a
capacity for 3,460 lower-income units, 1,726 moderate-income units, and 3,648 above
moderate-income units.
General
9. The Planning Commission finds that the Project, as conditioned herein, is in conformance
with the Elements of the city’s General Plan, based on the analysis set forth in Exhibit 5
of the June 3, 2026, Planning Commission staff report, which is incorporated herein by
this reference as though fully set forth herein.
June 3, 2026 Item #1 239 of 417
Conditions:
NOTE: Unless specifically stated in the condition, all of the following conditions, upon the
approval of this proposed development, must be met prior to approval of the building or
grading permit whichever occurs first. All references to the “Site Plan” reference the project
plans dated March 6, 2026, attached as Exhibit 12 of the Planning Commission Staff Report
dated June 3, 2026.
1. If any of the following conditions fail to occur, or if they are, by their terms, to be
implemented and maintained over time, if any of such conditions fail to be so
implemented and maintained according to their terms, the city shall have the right to
revoke or modify all approvals herein granted; deny or further condition issuance of all
future building permits; deny, revoke, or further condition all certificates of occupancy
issued under the authority of approvals herein granted; record a notice of violation on
the property title; institute and prosecute litigation to compel their compliance with said
conditions or seek damages for their violation. No vested rights are gained by Developer
or a successor in interest by the city’s approval of this Site Development Plan.
2. Staff is authorized and directed to make, or require the Developer to make, all
corrections and modifications to the Site Development Plan documents, as necessary to
make them internally consistent and in conformity with the final action on the project.
Development shall occur substantially as shown on the approved Exhibits. Any proposed
development, different from this approval, shall require an amendment to this approval.
3. Developer shall comply with all applicable provisions of federal, state, and local laws and
regulations in effect at the time of building permit issuance.
4. If any condition for construction of any public improvements or facilities, or the payment
of any fees in-lieu thereof, imposed by this approval or imposed by law on this Project
are challenged, this approval shall be suspended as provided in Government Code
Section 66020. If any such condition is determined to be invalid, this approval shall be
invalid unless the City Council determines that the project without the condition
complies with all requirements of law.
5. Developer/Operator shall and does hereby agree to indemnify, protect, defend, and hold
harmless the City of Carlsbad, its Council members, officers, employees, agents, and
representatives, from and against any and all liabilities, losses, damages, demands,
claims and costs, including court costs and attorney’s fees incurred by the city arising,
directly or indirectly, from (a) city’s approval and issuance of this Site Development Plan,
(b) city’s approval or issuance of any permit or action, whether discretionary or
nondiscretionary, in connection with the use contemplated herein, and (c)
Developer/Operator’s installation and operation of the facility permitted hereby,
including without limitation, any and all liabilities arising from the emission by the facility
June 3, 2026 Item #1 240 of 417
of electromagnetic fields or other energy waves or emissions. This obligation survives
until all legal proceedings have been concluded and continues even if the city’s approval
is not validated.
6. Prior to submittal of the building plans, improvement plans, grading plans, or final map,
whichever occurs first, developer shall submit to the City Planner, a 24" x 36" copy of
the (Tentative Map/Site Plan or other), conceptual grading plan and preliminary utility
plan reflecting the conditions approved by the final decision making body. The copy shall
be submitted to the City Planner, reviewed and, if found acceptable, signed by the city's
project planner and project engineer. If no changes were required, the approved exhibits
shall fulfill this condition.
7. Prior to the issuance of the building permit, the Developer shall provide proof to the
Building Division from the Carlsbad School District that this project has satisfied its
obligation to provide school facilities.
8. This project shall comply with all conditions and mitigation measures which are required
as part of the Zone 5 Local Facilities Management Plan and any amendments made to
that Plan prior to the issuance of building permits.
9. This approval shall become null and void if building permits are not issued for this project
within 24 months from the date of project approval.
10. Building permits will not be issued for this project unless the local agency providing
water and sewer services to the project provides written certification to the city that
adequate water service and sewer facilities, respectively, are available to the project at
the time of the application for the building permit, and that water and sewer capacity
and facilities will continue to be available until the time of occupancy.
11. Developer shall pay the Citywide Public Facilities Fee imposed by City Council Policy #17,
the License Tax on new construction imposed by Carlsbad Municipal Code Section
5.09.030, and CFD #1 special tax (if applicable), subject to any credits authorized by
Carlsbad Municipal Code Section 5.09.040. Developer shall also pay any applicable Local
Facilities Management Plan fee for Zone 5, pursuant to Chapter 21.90. All such
taxes/fees shall be paid at issuance of building permit. If the taxes/fees are not paid, this
approval will not be consistent with the General Plan and shall become void.
12. Prior to the issuance of the Grading Permit, Developer shall submit to the city a Notice
of Restriction executed by the owner of the real property to be developed. Said notice
is to be filed in the office of the County Recorder, subject to the satisfaction of the City
Planner, notifying all interested parties and successors in interest that the City of
Carlsbad has issued a Site Development Plan on the property. Said Notice of Restriction
June 3, 2026 Item #1 241 of 417
shall note the property description, location of the file containing complete project
details and all conditions of approval as well as any conditions or restrictions specified
for inclusion in the Notice of Restriction. The City Planner has the authority to execute
and record an amendment to the notice which modifies or terminates said notice upon a
showing of good cause by the Developer or successor in interest.
13. Prior to issuance of grading permits, developer shall make a separate formal landscape
construction drawing plan check submittal to the Planning Division and obtain City
Planner approval of a Final Landscape and Irrigation Plan showing conformance with the
approved Preliminary Landscape Plan and the city’s Landscape Manual. Developer shall
construct and install all landscaping and irrigation as shown on the approved Final Plans.
All landscaping shall be maintained in a healthy and thriving condition, free from weeds,
trash, and debris. All irrigation systems shall be maintained to provide the optimum
amount of water to the landscape for plant growth without causing soil erosion and
runoff.
14. The first submittal of Final Landscape and Irrigation Plans shall be pursuant to the
landscape plan check process on file in the Planning Division and accompanied by the
project’s building, improvement, and grading plans.
15. Project has been granted additional units, a concession, and waivers in accordance
with density bonus provisions found in Government Code §65915 and Carlsbad
Municipal Code Chapter 21.86. Per density bonus definitions, the project had a
calculation of 294 Base Units. Applicant requested an increase in density to allow 103
additional units, for a total project size of 397 units. Based on the requested density
bonus, applicant must provide 20% of the Base Units as low-income units, as defined
by California Health and Safety Code Section §50053 and §50093. The project must
provide 59 density bonus low-income affordable units based on calculations in
Government Code §65915.
16. Developer shall construct the project’s required affordable units concurrent with the
project’s market rate units in accordance with Section 21.85.100(C) of the Carlsbad
Municipal Code (CMC). Affordable units within the project must be distributed evenly
across various areas and floors, adhering to the guidelines of California Health and
Safety Code Section 17929, rather than being concentrated in specific locations.
Additionally, these affordable units should be equipped with equivalent amenities as
those found in market rate units, in accordance with CMC section 21.85.040(G).
17. Prior to the issuance of building permits, the Developer shall enter into an Affordable
Housing Agreement with the city. The agreement shall satisfy the following criteria:
a. To provide and deed restrict 59 dwelling units as affordable to low-income
households for 55 years, earning up to 80% of the area median income (AMI).
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The agreement shall be in accordance with the requirements and process set forth in
Chapters 21.85 and 21.86 of the Carlsbad Municipal Code. The draft Affordable Housing
Agreement shall be submitted to the City Planner no later than 60 days prior issuance of
the first building or grading permit and shall be recorded prior to issuance of the first
building or grading permit. The recorded Affordable Housing Agreement shall be binding
on all future owners and successors in interest.
18. Prior to issuance of grading and building permits, Developer shall list the following
condition on all grading and building permit construction plans. Construction activities
shall take place during the permitted time and day per Carlsbad Municipal Code Chapter
8.48. Developer shall ensure that construction activities for the proposed project are
limited to the hours from 7:00 a.m. to 6:00 p.m. Monday through Friday, and 8:00 a.m.
to 6:00 p.m. on Saturdays; no work shall be conducted on Sundays or on federal holidays.
19. All roof appurtenances, including air conditioners, shall be architecturally integrated and
concealed from view and the sound buffered from adjacent properties and streets, in
substance as provided in Building Department Policy No. 80-6, to the satisfaction of the
City Planner and Building Official.
20. Developer shall submit and obtain City Planner approval of an exterior lighting plan
including parking areas. All lighting shall be designed to reflect downward and avoid any
impacts on adjacent homes or property.
21. Developer shall report, in writing, to the City Planner within 30 days, any address change
from that which is shown on the permit application, any change in the
telecommunications provider, or any transfer in ownership of the site.
22. The Developer/Owner shall implement or cause the implementation of all applicable
mitigation measures associated with the General Plan EIR (City Planning Case No. EIR
13-02, Resolution No. 2015-242) and Supplemental EIR (City Planning Case No. 2022-
0007, Resolution No. 2024-0014), and their respective Mitigation Monitoring and
Reporting Programs, for the mitigation measures applicable to development of the
project site (Site 7). This includes the following conditions of approval:
a. Operational Emissions Reductions. The following measures shall be implemented
to reduce impacts to the maximum extent feasible:
x The engine size of construction equipment shall be the minimum size required
for its intended use.
x All off-road diesel-fueled equipment (e.g., rubber-tired dozers, graders,
scrapers, excavators, asphalt paving equipment, cranes, and tractors)
associated with Project construction shall be at least California Air Resources
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Board (CARB) Tier 4 Certified or better. All construction equipment shall be
maintained and properly tuned in accordance with manufacturer’s
specifications. All equipment shall be checked by a certified mechanic and
determined to be running in proper working condition prior to operation.
x Comply with SDAPCD’s Rule 67 (Architectural Coatings). Use architectural
coating materials, as defined in SDAPCD Rule 67.0.1, that are zero-emission or
have a low-VOC.
x content (below 10 grams per liter). Where such VOC coatings are not available
or feasible, the coating with the lowest VOC rating available shall be used.
These measures shall be noted on all construction plans, and the city shall
perform periodic site inspections during construction to verify compliance.
x All material transported off-site shall be either sufficiently watered or securely
covered to prevent excessive amounts of dust.
x All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas,
and unpaved access roads) shall be watered two times per day.
x All visible mud and dirt track-out onto adjacent public roads shall be removed
using wet power vacuum street sweepers at least once per day. The use of dry
power sweeping is prohibited.
x Idling times shall be minimized either by shutting equipment off when not in
use or reducing the maximum idling time to 5 minutes (as required by the
California airborne toxics control measure Title 13, Section 2485 of California
Code of Regulations [CCR]). Clear signage shall be provided for construction
workers at all access points.
x A publicly visible sign with the telephone number and person to contact
regarding dust complaints shall be posted on the project site prior to the
initiation of construction activities. This person shall respond and take
corrective action within 48 hours. The Air District’s phone number shall also be
visible to ensure compliance with applicable regulations.
x Adhesives, sealants, and caulks meet SCAQMD Rule 1168 for VOC limits and
prohibition on the use of certain toxic compounds.
x Prohibit the installation of woodstoves, hearths, and fireplaces in new
construction facilitated by the proposed Project.
b. Protected Tree and Tree Canopy Survey. Prior to the issuance of a grading permit,
a tree survey shall be conducted by a certified arborist prior to project construction
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to tag and assess all trees subject to the city’s Trees and Shrubs Ordinance
(Municipal Code Chapter 11.12) and/or CFMP. A city arborist will inspect the
property and recommend approving or denying the application in a written report
submitted to the city manager. The city shall post a letter of notification and a non-
removable marking upon the subject tree a minimum of 30 days prior to its
removal. The letter will be posted in a prominent location, visible from a public
street and will include the location of the tree, the reason for the trees removal,
the date of the scheduled removal, the species of tree to be replanted, the size of
the tree to be replanted, the date by which an appeal must be made to the parks
and recreation commission, and a description of the appeal process.
The following measures shall be implemented in addition to those required under
the city’s permits required for tree removal and maintenance ordinance
Guidelines (Municipal Code Title 11.12.090) to avoid and/or compensate for
potential indirect impacts to preserved sensitive natural communities and
protected trees within Carlsbad before, during, and following construction
activities
Pre-Construction
x Fencing. Protective fencing at least three feet high with signs and flagging shall
be erected around all preserved sensitive natural communities where adjacent
to proposed vegetation clearing and grubbing, grading, or other construction
activities. The protective fence shall be installed at a minimum of five feet
beyond the tree canopy dripline. The intent of protection fencing is to prevent
inadvertent limb/vegetation damage, root damage and/or compaction by
construction equipment. The protective fencing shall be depicted on all
construction plans and maps provided to contractors and labeled clearly to
prohibit entry, and the placement of the fence in the field shall be approved by
a qualified biologist prior to initiation of construction activities. The contractor
shall maintain the fence to keep it upright, taut and aligned at all times. Fencing
shall be removed only after all construction activities are completed.
x Pre-Construction Meeting. A pre-construction meeting shall be held between
all site contractors and a registered consulting arborist and/or a qualified
biologist. All site contractors and their employees shall provide written
acknowledgement of their receiving sensitive natural community protection
training. This training shall include, but shall not be limited to, the following
information: (1) the location and marking of protected sensitive natural
communities; (2) the necessity of preventing damage to these sensitive natural
communities; and (3) a discussion of work practices that shall accomplish such.
During Construction
x Fence Monitoring. The protective fence shall be monitored regularly (at least
weekly) during construction activities to ensure that the fencing remains intact
June 3, 2026 Item #1 245 of 417
and functional, and that no encroachment has occurred into the protected
natural community; any repairs to the fence or encroachment correction shall
be conducted immediately.
x Equipment Operation and Storage. Contractors shall avoid using heavy
equipment around the sensitive natural communities. Operating heavy
machinery around the root zones of trees would increase soil compaction,
which decreases soil aeration and, subsequently, reduces water penetration
into the soil. All heavy equipment and vehicles shall, at minimum, stay out of
the fenced protected zones, unless where specifically approved in writing and
under the supervision of a registered consulting arborist and/or a qualified
biologist.
x Materials Storage and Disposal. Contractors shall not store or discard any
construction materials within the fenced protected zones and shall remove all
foreign debris within these areas. The contractors shall leave the duff, mulch,
chips, and leaves around the retained trees for water retention and nutrient
supply. Contractors shall avoid draining or leakage of equipment fluids near
retained trees. Fluids such as gasoline, diesel, oils, hydraulics, brake and
transmission fluids, paint, paint thinners, and glycol (anti-freeze) shall be
disposed of properly. The contractors shall ensure that equipment be parked
at least 50 feet, and that equipment/vehicle refueling occur at least 100 feet,
from fenced protected zones to avoid the possibility of leakage of equipment
fluids into the soil.
x Grade Changes. Contractors shall ensure that grade changes, including adding
fill, shall not be permitted within the fenced protected zone without special
written authorization and under supervision by a registered consulting arborist
and/or a qualified biologist. Lowering the grade within the fenced protected
zones could necessitate cutting main support and feeder roots, thus
jeopardizing the health and structural integrity of the tree(s). Adding soil, even
temporarily, on top of the existing grade could compact the soil further, and
decrease both water and air availability to the tree roots. Contractors shall
ensure that grade changes made outside of the fenced protected zone shall not
create conditions that allow water to pond.
x Trenching. Except where specifically approved in writing beforehand, all
trenching shall be outside of the fenced protected zone. Roots primarily extend
in a horizontal direction forming a support base to the tree similar to the base
of a wineglass. Where trenching is necessary in areas that contain roots from
retained trees, contractors shall use trenching techniques that include the use
of either a root pruner (Dosko root pruner or equivalent) or an Air-Spade to
limit root impacts. An International Society of Arboriculture (ISA) certified
arborist or American Society of Consulting Arborists (ASCA) registered
consulting arborist shall ensure that all pruning cuts shall be clean and sharp,
June 3, 2026 Item #1 246 of 417
to minimize ripping, tearing, and fracturing of the root system. Root damage
caused by backhoes, earthmovers, dozers, or graders is severe and may
ultimately result in tree mortality. Use of both root pruning and Air-Spade
equipment shall be accompanied only by hand tools to remove soil from trench
locations. The trench shall be made no deeper than necessary.
x Erosion Control. Appropriate erosion control best management practices
(BMPs) shall be implemented to protect preserved sensitive natural
communities during and following project construction. Erosion control
materials shall be certified as weed free.
x Inspection. An ISA certified arborist or ASCA registered consulting arborist shall
inspect the preserved trees adjacent to grading and construction activity on a
monthly basis for the duration of the grading and construction activities. A
report summarizing site conditions, observations, tree health, and
recommendations for minimizing tree damage shall be submitted by the
registered consulting arborist following each inspection.
Post-construction
x Mulch. The contractors shall ensure that the natural duff layer under all trees
adjacent to construction activities shall be maintained. This would stabilize soil
temperatures in root zones, conserve soil moisture, and reduce erosion. The
contractors shall ensure that the mulch be kept clear of the trunk base to avoid
creating conditions favorable to the establishment and growth of decay causing
fungal pathogens. Should it be necessary to add organic mulch beneath
retained oak trees, packaged or commercial oak leaf mulch shall not be used as
it may contain root fungus. Also, the use of redwood chips shall be avoided as
certain inhibitive chemicals may be present in the wood. Other wood chips and
crushed walnut shells can be used, but the best mulch that provides a source
of nutrients for the tree is its own leaf litter. Any added organic mulch added
by the contractors shall be applied to a maximum depth of 4 inches where
possible.
x Watering Adjacent Plant Material. All installed landscaping plants near the
preserved sensitive natural communities shall require moderate to low levels
of water. The surrounding plants shall be watered infrequently with deep soaks
and allowed to dry out in between, rather than frequent light irrigation. The
soil shall not be allowed to become saturated or stay continually wet, nor
should drainage allow ponding of water. Irrigation spray shall not hit the trunk
of any tree. The contractors shall maintain a 30-inch dry-zone around all tree
trunks. An above ground micro-spray irrigation system shall be used in lieu of
typical underground pop-up sprays.
x Monitoring. An ISA certified arborist or ASCA registered consulting arborist
shall inspect the trees preserved on the site adjacent to construction activities
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for a period of two years following the completion of construction. Monitoring
visits shall be completed quarterly, totaling eight visits. Following each
monitoring visit, a report summarizing site conditions, observations, tree
health, and recommendations for promoting tree health shall be submitted to
the city. Additionally, any tree mortality shall be noted and any tree dying
during the two year monitoring period shall be replaced at a minimum 3:1 ratio
on-site in coordination with the city.
c. HMP Adjacency Standards. Project shall evaluate potential indirect impacts, such
as wildfire, erosion, invasive species, unauthorized access, or predators, to habitat
and species adjacent to the proposed development. Projects shall be consistent
with the HMP Adjacency Standards (Section F-3).
d. Before commencement of any ground-disturbing activities, the project developer
shall comply with the following requirements to ensure the appropriate response
to the presence of any tribal and cultural resources:
x Retain the services of a qualified archaeologist who shall be on-site for ground-
disturbing activities. In the event cultural material is encountered, the
archaeologist is empowered to temporarily divert or halt grading to allow for
coordination with the Luiseño Native American monitor and to determine the
significance of the discovery. The archaeologist shall follow all standard
procedures for cultural materials that are not Tribal Cultural Resources.
x Enter into a Pre-Excavation Agreement, otherwise known as a Tribal Cultural
Resources Treatment and Tribal Monitoring Agreement, with a TCA tribe. This
agreement will address provision of a Luiseño Native American monitor and
contain provisions to address the proper treatment of any tribal cultural
resources and/or Luiseño Native American human remains inadvertently
discovered during the course of the project. The Agreement will outline the
roles and powers of the Luiseño Native American monitors and the
archaeologist and may include the following provisions.
i. A Luiseño Native American monitor shall be present during all ground-
disturbing activities. Ground disturbing activities may include, but are
not limited to, archaeological studies, geotechnical investigations,
exploratory geotechnical investigations/borings for contractor bidding
purposes, clearing, grubbing, trenching, excavation, preparation for
utilities and other infrastructure, and grading activities.
ii. Any and all uncovered artifacts of Luiseño Native American cultural
importance shall be returned to the San Luis Rey Band of Mission
Indians or other Luiseño Tribe, and/or the Most Likely Descendant, if
applicable, and not be curated, unless ordered to do so by a federal
agency or a court of competent jurisdiction.
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iii. The Luiseño Native American monitor shall be present at the project’s
pre-construction meeting to consult with grading and excavation
contractors concerning excavation schedules and safety issues, as well
as to consult with the archaeologist PI (principal investigator)
concerning the proposed archaeologist techniques and/or strategies for
the project.
iv. Luiseño Native American monitors and archaeological monitors shall
have joint authority to temporarily divert and/or halt construction
activities. If tribal cultural resources are discovered during construction,
all earthmoving activity within and around the immediate discovery
area must be diverted until the Luiseño Native American monitor and
the archaeologist can assess the nature and significance of the find.
v. If a significant tribal cultural resource(s) and/or unique archaeological
resource(s) are discovered during ground-disturbing activities for this
project, the San Luis Rey Band of Mission Indians or other Luiseño tribe
shall be notified and consulted regarding the respectful and dignified
treatment of those resources. Pursuant to California Public Resources
Code Section 21083.2(b) avoidance is the preferred method of
preservation for archaeological and tribal cultural resources. If,
however, the Applicant is able to demonstrate that avoidance of a
significant and/or unique cultural resource is infeasible and a data
recovery plan is authorized by the City of Carlsbad as the lead agency,
the San Luis Rey Band of Mission Indians or other Luiseño tribe shall be
consulted regarding the drafting and finalization of any such recovery
plan.
vi. When tribal cultural resources are discovered during the project, if the
archaeologist collects such resources, a Luiseño Native American
monitor must be present during any testing or cataloging of those
resources. If the archaeologist does not collect the tribal cultural
resources that are unearthed during the ground disturbing activities,
the Luiseño Native American monitor may, at their discretion, collect
said resources and provide them to the San Luis Rey Band of Mission
Indians or other Luiseño tribe for dignified and respectful treatment in
accordance with their cultural and spiritual traditions.
vii. If suspected Native American human remains are encountered,
California Health and Safety Code Section 7050.5(b) states that no
further disturbance shall occur until the San Diego County Medical
Examiner has made the necessary findings as to origin. Further,
pursuant to California Public Resources Code Section 5097.98(b)
remains shall be left in place and free from disturbance until a final
decision as to the treatment and disposition has been made. Suspected
Native American remains shall be examined in the field and kept in a
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secure location at the site. A Luiseño Native American monitor shall be
present during the examination of the remains. If the San Diego County
Medical Examiner determines the remains to be Native American, NAHC
must be contacted by the Medical Examiner within 24 hours. The NAHC
must then immediately notify the “Most Likely Descendant” about the
discovery. The Most Likely Descendant shall then make
recommendations within 48 hours and engage in consultation
concerning treatment of remains as provided in Public Resources Code
5097.98.
viii. In the event that fill material is imported into the project area, the fill
shall be clean of tribal cultural resources and documented as such.
Commercial sources of fill material are already permitted as appropriate
and will be culturally sterile. If fill material is to be utilized and/or
exported from areas within the project site, then that fill material shall
be analyzed and confirmed by an archaeologist and Luiseño Native
American monitor that such fill material does not contain tribal cultural
resources.
ix. No testing, invasive or non-invasive, shall be permitted on any
recovered tribal cultural resources without the written permission of
the San Luis Rey Band of Mission Indians or other Luiseño tribe.
x. Prior to the completion of project construction, a monitoring report
and/or evaluation report, if appropriate, which describes the results,
analysis, and conclusions of the monitoring program shall be submitted
by the Project Archaeologist, along with the Luiseño Native American
monitor’s notes and comments, to the City of Carlsbad for approval, and
shall be submitted to the South Coastal Information Center. Said report
shall be subject to confidentiality as an exception to the Public Records
Act and will not be available for public distribution.
x Furthermore, the Agreement may include additional measures mutually agreed
upon by the project developer, city, and TCA Tribe such as evaluation of the
project site’s pre-construction conditions for the presence or potential
presence of TCRs as well as other measures tailored to and deemed necessary
for the specific project.
e. Construction Noise Reduction Measures. If Large, heavy duty equipment rated 300
horsepower or greater is used for the project, the following construction noise
reduction measures shall be implemented during Project construction:
f. Shielding and Silencing. Power construction equipment (including combustion
engines), fixed or mobile, shall be equipped with noise shielding and silencing
devices consistent with manufacturer’s standards or the Best Available Control
June 3, 2026 Item #1 250 of 417
Technology. Equipment shall be properly maintained, and the project applicant or
owner shall require construction contractors to keep documentation on-site during
earthwork or construction activities demonstrating that the equipment has been
maintained in accordance with manufacturer’s specifications.
g. Enclosures and Screening. Outdoor fixed mechanical equipment shall be enclosed
or screened from off-site noise-sensitive uses to the extent feasible. The
equipment enclosure or screen shall be impermeable (i.e., solid material with
minimum weight of 2 pounds per square feet) and break the line-of-sight from the
equipment and off-site noise-sensitive uses.
h. Construction Staging Areas. Construction staging areas shall be located as far from
noise-sensitive uses as reasonably feasible in consideration of site boundaries,
topography, intervening roads and uses, and operational constraints.
i. Smart Back-Up Alarms. Mobile construction equipment shall have smart back-up
alarms that automatically adjust the sound level of the alarm in response to
ambient noise levels. Alternatively, back-up alarms shall be disabled and replaced
with human spotters to ensure safety when mobile construction equipment is
moving in the reverse direction.
j. Equipment Idling. Construction vehicles and equipment shall not be left idling for
longer than five minutes when not in use.
k. Workers’ Radios. All noise from workers’ radios, including any on-site music, shall
be controlled to the point that they are not audible at off-site noise-sensitive uses.
l. Use of Driven Pile Systems. Driven (impact), sonic, or vibratory pile drivers shall
not be used, except in locations where the underlying geology renders alternative
methods infeasible, as determined by a soils or geotechnical engineer and
documented in a soils report
23. Transportation Demand Management Plan. Prior to the building permit issuance, the
Developer shall prepare and submit a Transportation Demand Management (TDM)
Plan for review and approval by the city, consistent with the city’s TDM Handbook, as
may be amended from time to time. The approved TDM Plan shall be fully
implemented for the life of the Project. The TDM Plan shall identify, describe, and
commit to specific, enforceable TDM measures to mitigate project-related
transportation and greenhouse gas emissions impacts to the maximum extent
feasible. The Plan shall include sufficient detail to demonstrate how each measure will
be implemented, monitored, and maintained over time, including, but not limited to,
program administration, performance targets (where applicable), reporting
procedures, and a clear identification of responsible parties. The TDM Plan shall also
include provisions for ongoing funding, staffing, and long-term operation of all
required TDM programs for the duration of the project. At a minimum, the TDM Plan
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shall include, but not be limited to, the following measures. The city may require
revisions to the TDM Plan to ensure consistency with the city’s TDM Handbook and to
ensure the effectiveness of the proposed measures in achieving emissions and
transportation impact reductions.
a. A ride-sharing program (e.g., carpooling and/or vanpooling incentives and
coordination).
b. Provision and maintenance of secure, covered, long-term bicycle storage facilities
(e.g., bike lockers, bike storage room).
c. Provision and maintenance of publicly accessible bicycle parking.
d. A comprehensive commute trip reduction and transportation marketing program.
e. An annual transit subsidy program that subsidizes 50% of the cost of a one monthly
transit pass per month for up to 59 units, with priority first given to the Project’s
deed-restricted affordable units.
If the full subsidy fund is not used in any given year, the unused portion of the
subsidy can roll over to fund the subsidy for the following year. However, up to
25% of the unused funds shall be used to increase the overall amount in the fund
to allow broader marketing and enrollment in the program. This increase in the
overall subsidy fund from unused funds need not exceed a 35.6% increase to the
base obligation amount for 59 units. That is, the Developer must fully fund the
program each year (with new or unused funds) and add 25% of any unused funds
to increase the fund up to, but not to exceed, 135.6% of the required minimum
amount. The specific value of budget can vary from year to year so long as the total
value of incentives offered is equal to or greater than the minimum requirement.
24. This approval is granted subject to the approval of the Focused Initial Study/Mitigated
Negative Declaration (Final IS/MNO, State Clearinghouse No. 2026030432) and is
subject to all project design features and mitigation measures contained therein.
Mitigation Measures include the following:
a. Pre-Construction Nesting Bird Surveys, Avoidance, and Notification. If construction
activities are initiated during the bird nesting season (February 1–August 31)
involving removal of vegetation or other nesting bird habitat, including abandoned
structures and other man-made features, a pre-construction nesting bird survey
shall be conducted no more than three days prior to initiation of ground
disturbance and vegetation removal activities. The nesting bird pre-construction
survey shall be conducted on foot and shall include a 300-foot survey buffer
around the construction site. The survey shall be conducted by a biologist familiar
with the identification of avian species known to occur in southern California
coastal communities (i.e., qualified biologist). If active nests are found, an
avoidance buffer shall be determined by a qualified biologist in coordination with
the City. The avoidance buffer width will depend upon the species, the proposed
work activity, and existing disturbances associated with land uses outside of the
site, which shall be demarcated by the biologist with bright orange construction
June 3, 2026 Item #1 252 of 417
fencing, flagging, construction lathe, or other means to demarcate the boundary.
All construction personnel shall be notified as to the existence of the buffer zone
and to avoid entering the buffer zone during the nesting season. No ground-
disturbing activities shall occur within the buffer until the biologist has confirmed
that breeding/nesting is completed, and the young have fledged the nest.
Encroachment into the buffer shall occur only at the discretion of the qualified
biologist on the basis that the encroachment will not be detrimental to an active
nest. A report summarizing the pre-construction survey(s) shall be prepared by a
qualified biologist and shall be submitted to the City prior to the commencement
of construction activities.
If an active coastal California gnatcatcher nest is found during pre-construction
surveys, a minimum 500 -foot no-disturbance buffer shall be established around
the nest. The buffer shall be clearly marked (e.g., with fencing or flagging) and
maintained until a qualified biologist confirms that the young have fledged, the
nest is no longer active, or that construction noise levels can be maintained
below 60 dBA Leq at the nest site with a smaller buffer. In no circumstances shall
a buffer of less than 100 feet be used even with noise attenuation measures. Any
reduction in the 500 -foot buffer must be supported by site-specific analysis by
the qualified biologist and approved by the City in consultation with USFWS.
b. Crotch’s Bumble Bee (CBB) Avoidance and Clearance Survey
x Focused Survey. Three on-site surveys for Crotch’s bumble bee (CBB) shall be
conducted prior to initiation of ground disturbing project activities to identify
if the CBB is present within the project site. This survey shall be conducted
simultaneously with the blooming period of the species’ recognized food
plants, when the CBB is most active. Each survey shall be spaced at least 2
weeks but no more than 4 weeks apart, corresponding with the Colony Active
Season for Bombus species (April–August). The surveying biologist shall be
familiar with the primary identification characteristics of the CBB and be
proficient in the methodology produced by the Xerces Society. The qualified
biologist shall utilize a telephoto lens or a sufficiently long macro lens to obtain
high-quality photos of bumble bees, sufficient for species identification,
without having to capture and potentially harm the bumble bees.
x Absence of Species. If no CBB are detected during the focused surveys, no
further measures shall be necessary.
x Presence of Species. If CBB are detected, then site-specific measures shall be
implemented to avoid take unless an Incidental Take Permit (ITP) for the
species is obtained from CDFW. Such avoidance measures shall include:
i. If vegetation removal activities and initial ground-disturbing activities
(i.e., clearing, grubbing, and initial site grading) occur during the Queen
and Gyne Flight Period and Colony Active Period for these species
June 3, 2026 Item #1 253 of 417
(February–October), a qualified biologist shall conduct daily biological
monitoring. During monitoring, the qualified biologist shall inspect
suitable habitat for CBB activity within the day’s work area. If the
species is not detected, then project activities can proceed without
further biological monitoring that day.
ii. If the CBB is detected using nectar sources, then a no disturbance buffer
of at least 25 feet around the individual(s) shall be established, and the
individual(s) shall be monitored by a biological monitor until the CBB
are confirmed to have left the area on their own.
iii. If a CBB nest is detected where ground disturbance is proposed to occur,
then a minimum 30-foot no-disturbance buffer (with a buffer of up to
60 feet if disturbance is substantial) around the nest shall be
established. This buffer shall remain in place until the nest senesces,
which would occur after no nest activity observations for three
sequential days. The qualified biologist shall discuss the buffer with the
contractor to ensure that work areas, including ingress and egress
routes, avoid the CBB.
iv. If the project cannot avoid the established no-disturbance buffer(s)
identified above, the project applicant shall halt work within the buffer
area and shall consult with CDFW on appropriate avoidance actions and
obtain an Incidental Take Permit if necessary.
25. Prior to the issuance of a Grading Permit, the Applicant/Owner shall enter into a pre-
excavation agreement, otherwise known as a Tribal Cultural Resources Treatment and
Tribal Monitoring Agreement with the Rincon Band of Luiseño Indians. A copy of the
agreement shall be included in the Grading Plan Submittals for the Grading Permit.
The purpose of this agreement shall be to formalize protocols and procedures between
the Applicant/Owner and the Rincon Band of Luiseño Indians for the protection and
treatment of, including but not limited to, Native American human remains, funerary
objects, cultural and religious landscapes, ceremonial items, traditional gathering
areas and Tribal Cultural Resources, located and/or discovered through a monitoring
program in conjunction with the construction of the proposed project, including
additional archaeological surveys and/or studies, excavations, geotechnical
investigations, grading, and all other ground disturbing activities. No photography,
invasive or non-invasive testing is permitted without prior approval by the Rincon
Band of Luiseño Indians
26. Prior to the issuance of a Grading Permit, the Applicant/Owner or Grading Contractor
shall provide a written and signed letter to the City of Carlsbad stating that a Qualified
Archaeologist and Native American Monitor affiliated with the Rincon Band of Luiseño
Indians have been retained at the Applicant/Owner or Grading Contractor’s expense
to implement the monitoring program, as described in the pre-excavation agreement.
27. The Qualified Archaeologist shall maintain ongoing collaborative consultation with the
Luiseño Native American Monitor during all ground disturbing activities. The
June 3, 2026 Item #1 254 of 417
requirement for the monitoring program shall be noted on all applicable construction
documents, including demolition plans, grading plans, etc. The Applicant/Owner or
Grading Contractor shall notify the City of Carlsbad Planning Division of the start and
end of all ground disturbing activities.
28. The Qualified Archaeologist and Luiseño Native American Monitor shall attend all
applicable pre-construction meetings with the General Contractor and/or associated
Subcontractors to present the archaeological monitoring program. The Qualified
Archaeologist and Luiseño Native American monitor shall be present on-site full-time
during grubbing, grading and/or other ground altering activities, including the
placement of imported fill materials or fill used from other areas of the project site, to
identify any evidence of potential archaeological or Tribal Cultural Resources. All fill
materials shall be absent of any and all Tribal Cultural Resources.
29. The Qualified Archaeologist or the Luiseño Native American Monitor may halt ground
disturbing activities if unknown Tribal Cultural Resources, archaeological artifact
deposits or cultural features are discovered. Ground disturbing activities shall be
directed away from these deposits to allow a determination of potential importance.
Isolates and other deposits will be minimally documented in the field, and before
grading proceeds these items shall be secured at a secured and locked location on
project site and as agreed upon by the Rincon Band of Luiseño Indians until they can
be repatriated for later reburial on site. If items cannot be securely stored on the
project site, they may be stored in off-site facilities located in San Diego County and
agreed upon by the Rincon Band of Luiseño Indians. If the Qualified Archaeologist and
Luiseño Native American monitor determine that the unearthed tribal cultural
resource, artifact deposits or cultural features are considered potentially significant
TCA Luiseño Tribes that have participated in the state-prescribed consultation process
for this project shall be notified and consulted regarding the respectful and dignified
treatment of those resources. The avoidance and protection of the significant tribal
cultural resource and/or unique archaeological resource is the preferable mitigation.
If, however, it is determined by the City that avoidance of the resource is infeasible,
the City of Carlsbad shall notify the Rincon Band of Luiseño Indians and other TCA
Luiseño Tribes that have participated in the state-prescribed consultation process for
this project and consult regarding appropriate next steps. If the decision is made that
data recovery is needed, the City shall consult with the Rincon Band of Luiseño Indians
on the drafting and finalization of any such recovery plan. The data recovery plan shall
also incorporate and reflect the tribal values of the TCA Luiseño Tribes that have
participated in the state-prescribed consultation process for this project. If the
Qualified Archaeologist collects such resources, the Luiseño Native American monitor
must be present during any cataloging of those resources. Moreover, if the Qualified
Archaeologist does not collect the Tribal Cultural Resources that are unearthed during
the ground disturbing activities, the Luiseño Native American monitor, may at their
discretion, collect said resources and provide them to the Rincon Band of Luiseño
Indians, as determined through the appropriate process, for respectful and dignified
treatment in accordance with the Tribe’s cultural and spiritual traditions. Ground
June 3, 2026 Item #1 255 of 417
disturbing activities shall not resume until the Qualified Archaeologist, in consultation
with the representative of the Rincon Band of Luiseño Indians, deems the cultural
resource or feature has been appropriately documented and/or protected.
30. The landowner shall relinquish ownership of all Tribal Cultural Resources unearthed
during the cultural resource mitigation monitoring conducted during all ground
disturbing activities, and from any previous archaeological studies or excavations on
the project site to the Rincon Band of Luiseño Indians, for respectful and dignified
treatment and disposition, including reburial at a protected location on-site, in
accordance with the Tribe’s cultural and spiritual traditions. All cultural materials that
are associated with burial and/or funerary goods will be repatriated to the Most Likely
Descendant as determined by the Native American Heritage Commission per California
Public Resources Code Section 5097.98. No Tribal Cultural Resources shall be subject
to curation.
31. Prior to the release of the grading bond, a monitoring report and/or evaluation report,
if appropriate, which describes the results, analysis and conclusions of the
archaeological monitoring program (e.g., data recovery plan) shall be submitted by the
Qualified Archaeologist, along with the Luiseño Native American monitor’s notes and
comments, to the City of Carlsbad for approval.
32. As specified by California Health and Safety Code Section 7050.5, if human remains are
found on the project site during construction or during archaeological work, the person
responsible for the excavation, or his or her authorized representative, shall
immediately notify the San Diego County Office of the Medical Examiner by telephone.
No further excavation or disturbance of the site or any nearby area reasonably
suspected to overlie adjacent remains shall occur until the Medical Examiner has made
the necessary findings as to origin and disposition pursuant to Public Resources Code
5097.98. If such a discovery occurs, a temporary construction exclusion zone shall be
established surrounding the area of the discovery so that the area would be protected,
and consultation and treatment could occur as prescribed by law. If suspected Native
American remains are discovered, the remains shall be kept in-situ, or in a secure
location in close proximity to where they were found, and the analysis of the remains
shall only occur on-site in the presence of a representative of the Rincon Band of
Luiseño Indians. By law, the Medical Examiner will determine within two working days
of being notified if the remains are subject to his or her authority. If the Medical
Examiner identifies the remains to be of Native American ancestry, he or she shall
contact the Native American Heritage Commission (NAHC) within 24 hours. The NAHC
shall make a determination as to the Most Likely Descendant.
33. The Developer shall prepare an improvement plan and shall identify on the plans all
improvements necessary to implement the project and its conditions. The
improvement plan will be reviewed for compliance with the Carlsbad Municipal Code
and any applicable engineering standards, including but not limited to the on- and off-
site improvements and storm water control plan, to ensure the design conforms to all
June 3, 2026 Item #1 256 of 417
requirements of the relevant regulations and codes. Approval of an improvement plan
must be obtained and secured prior to the issuance of a building permit to implement
the project. In approving the improvement plan, the City Engineer or designee may
impose such conditions as may be reasonably necessary to enable the City Engineer or
designee to make the required determinations and to prevent creation of a nuisance
or unreasonable hazard to persons or to public or private property.
34. All improvements within the public right-of-way, including curb, gutter, sidewalks,
driveways, paving and utilities, shall be constructed in accordance with approved
standards and/or plans and shall comply with the standard plans and specifications of
the City Engineer. Any damage to street improvements now existing or done during
construction on or adjacent to the subject property, shall be repaired to the
satisfaction of the City Engineer at the full expense of the Developer. This shall include
sidewalk repair, slurry seal, street reconstruction or others, as may be required by the
City Engineer or designee.
35. No portion of the project may be used for transient purposes. No housing unit shall be
made available for less than 30 calendar days, counting portions of calendar days as
full days. Every lease or other rental agreement for the occupancy of a housing unit or
portions of a unit shall include a clause providing that it is a material breach of the
agreement for the tenant to offer, rent, or maintain any short-term rental for less than
30 calendar days, counting portions of calendar days as full days. “Rent” means the
consideration charged, whether or not received, for the occupancy of space valued in
money, whether to be received in money, goods, labor or otherwise, including all
receipts, cash, credits and property and services of any kind of nature, without any
deduction there from whatsoever. Property owners or managers with knowledge of
violations shall take reasonable steps to investigate and enforce the regulations,
including a written notice to the resident of the landlord's knowledge of the violation,
a request to cease the violation, and the course of action to be taken if the violation is
not corrected.
36. Pruning, cutting and trimming of city street trees is not allowed, except as defined by
separate agreement or condition of approval. Removal of any city street tree shall
require permission from the Parks & Recreation Department and is first subject to the
department receiving a written request, an evaluation by the City Arborist, and
determination by staff based on the criteria included in §11.12.090 of the CMC. City
staff’s determination to permit or deny a request for removal of a city street tree is
appealable to the Parks & Recreation Commission; and its determination is appealable
to the City Council. Said permission for city street tree removal shall be obtained and
secured by the developer prior to the issuance of a building or grading permit needed
to implement the project. As defined by Section 11.12.100 of the CMC, all city street
trees permitted for removal shall be replaced at 2:1 ratio with trees of the same
species as those removed, except where the removed species does not conform to the
city’s street tree species list, or to the conditions existing at the site. Pursuant to the
Parks & Recreation Director’s or designee’s determination that the project’s frontage
June 3, 2026 Item #1 257 of 417
cannot feasibly accommodate a required city street tree, a street tree replacement in-
lieu fee of $500 per street tree shall be paid to the city to cover the cost to procure,
plant, and establish each street tree required. Said street tree replacement in-lieu fee
shall be paid to the Parks & Recreation Department prior to the issuance of building
permits. The Parks & Recreation Director or designee shall determine the locations of
the street trees planted using the street tree replacement in-lieu fees.
37. This housing development project is only subject to the local ordinances, policies,
standard, or any other measure (standards) adopted and in effect when the SB-330
preliminary application was submitted, which was May 14, 2025. When submitting
building plans to the Building Division, the Developer shall file a B-77 form (SB-330
Supplemental Application Form) to initiate plan check. Building permits will not be
issued until this B-77 form is completed with the B-1 Form Residential Building Permit
application. SB-330 “vesting” could be forfeited if construction of the housing
development project does not start within two and one-half (2½) years following the
date that the project receives final approval, as defined in Government Code
§65589.5(o)(2).
38. Any changes following discretionary approval must be entirely consistent with the
approved discretionary permits, including exhibits presented to decision makers, or
meet the objective standards and processes outlined in Chapter 21.89 of the CMC.
Additionally, any design changes that make modifications that increase the conflict
between an objective standard when the project approval was based on use of a
density bonus to deviate from the objective standards will be difficult to approve
under these findings. A decision, approval or denial, by the City Planner for Substantial
Conformance is noticed on the city’s website and appealable to the Planning
Commission.
39. The city prohibits the smoking of tobacco, or any other weed or plant or substance, in
multiunit residences or common areas. Every lease or other rental agreement for the
occupancy applicable to a multi-unit residential development adopted or amended
after January 1, 2025 shall include clauses or provisions that prohibit smoking,
pursuant to CMC §6.15.060.
40. Prior to issuance of building permit the Developer shall prepare and record a Notice that
this property is subject to overflight; sight and sound of aircraft operating from
McClellan-Palomar Airport, in a form meeting the approval of the City Planner and the
City Attorney.
Engineering Conditions
General
1. Prior to hauling dirt or construction materials to or from any proposed construction site
within this project, developer shall apply for and obtain approval from, the city engineer
June 3, 2026 Item #1 258 of 417
for the proposed haul route.
2. This project is approved upon the express condition that building permits will not be
issued for the development of the subject property, unless the district engineer has
determined that adequate water and sewer facilities are available at the time of permit
issuance and will continue to be available until time of occupancy.
3. Prior to issuance of a certificate of occupancy, Developer shall include rain gutters on
the building plans subject to the city engineer’s review and approval. Developer shall
install rain gutters in accordance with said plans.
4. Developer shall install sight distance corridors at all street intersections and driveways
in accordance with City Engineering Standards. The property owner shall maintain this
condition.
5. Property owner shall maintain all landscaping (street trees, tree grates, shrubs,
groundcover, etc.) and irrigation along the parkway frontage with SALK AVENUE as
shown on the Site Plan.
Fees/Agreements
6. Developer shall cause property owner to execute and submit to the city engineer for
recordation, the city’s standard form Geologic Failure Hold Harmless Agreement.
7. Developer shall cause property owner to execute and submit to the city engineer for
recordation the city’s standard form Drainage Hold Harmless Agreement.
8. Developer shall cause property owner to submit an executed copy to the city engineer
for recordation a city standard Permanent Stormwater Quality Best Management
Practice Maintenance Agreement.
9. Developer shall cause property owner to apply for, execute, and submit, to the city
engineer for recordation, an Encroachment Agreement covering private Storm drains,
Modular wetland system (MWS), and Curb Outlets located over existing public right-of-
way or easements as shown on the site plan. Developer shall pay processing fees per the
city’s latest fee schedule.
Grading
10. Based upon a review of the proposed grading and the grading quantities shown on the
site plan, a grading permit for this project is required. Developer shall prepare and submit
plans and technical studies/reports as required by city engineer, post security and pay all
applicable grading plan review and permit fees per the city’s latest fee schedule.
11. Concurrent with the grading plans Developer shall include non-standard retaining wall
June 3, 2026 Item #1 259 of 417
plans as part of the grading plans to the satisfaction of the city engineer. Structural
calculations for all non-standard walls shall be submitted for review and approval by the
Land Development division. Developer shall pay all deposits necessary to cover any 3rd
party review.
Storm Water Quality
12. Developer shall comply with the city's Stormwater Regulations, latest version, and shall
implement best management practices at all times. Best management practices include
but are not limited to pollution control practices or devices, erosion control to prevent
silt runoff during construction, general housekeeping practices, pollution prevention and
educational practices, maintenance procedures, and other management practices or
devices to prevent or reduce the discharge of pollutants to stormwater, receiving water
or stormwater conveyance system to the maximum extent practicable. Developer shall
notify prospective owners and tenants of the above requirements.
13. Developer shall submit for city approval a Tier 3 Storm Water Pollution Prevention Plan
(TIER 3 SWPPP). The TIER 3 SWPPP shall comply with current requirements and provisions
established by the San Diego Regional Water Quality Control Board and City of Carlsbad
Requirements. The TIER 3 SWPPP shall identify and incorporate measures to reduce
storm water pollutant runoff during construction of the project to the maximum extent
practicable. Developer shall pay all applicable SWPPP plan review and inspection fees per
the city’s latest fee schedule.
14. This project is subject to ‘Priority Development Project’ requirements AND TRASH
CAPTURE REQUIREMENTS. Developer shall prepare and process a Storm Water Quality
Management Plan (SWQMP), subject to city engineer approval, to comply with the
Carlsbad BMP Design Manual latest version. The final SWQMP required by this condition
shall be reviewed and approved by the city engineer with final grading plans. Developer
shall pay all applicable SWQMP plan review and inspection fees per the city’s latest fee
schedule.
15. Developer is responsible to ensure that all final design plans (grading plans, improvement
plans, landscape plans, building plans, etc) incorporate all source control, site design,
pollutant control BMP and applicable hydromodification measures.
Dedications/Improvements
16. Developer shall design the private drainage systems, as shown on the site plan to the
satisfaction of the city engineer. All private drainage systems 12” diameter storm drain
and larger shall be inspected by the city. Developer shall pay the standard improvement
plan check and inspection fees for private drainage systems.
June 3, 2026 Item #1 260 of 417
17. Prior to any work in city right-of-way or public easements, Developer shall apply for and
obtain a right-of-way permit to the satisfaction of the city engineer.
18. Developer shall prepare and process public improvement plans and, prior to city engineer
approval of said plans, shall execute a city standard Development Improvement
Agreement to install and shall post security in accordance with C.M.C. Section 20.16.070
for public improvements shown on the site plan. Said improvements shall be installed
to city standards to the satisfaction of the city engineer. These improvements include,
but are not limited to:
1. 2” Irrigation water service and meter
2. 2-2” Domestic water service laterals
3. 2-8” fire service laterals
4. Remove 12” water service, tee, gate valves and valves.
5. 8” sewer main in College Blvd. from El Camino Real to Sunny Creek Road
6. AC grind and overlay
7. Modular Wetlands
8. Removal of existing cross gutter, curb returns and ped ramps and replace with ADA
compliant alley type driveway
9. Curb, gutter and sidewalk
Additional public improvements required in other conditions of this resolution are hereby
included in the above list by reference. Developer shall pay the standard improvement
plan check and inspection fees in accordance with the fee schedule. Improvements listed
above shall be constructed within 36 months of approval of the subdivision or
development improvement agreement or such other time as provided in said agreement.
19. Developer shall design, and obtain approval from the city engineer, the structural section
for the access aisles with a traffic index of 5.0 in accordance with city standards due to
truck access through the parking area and/or aisles. Prior to completion of grading, the
final structural pavement design of the aisle ways shall be submitted together with
required R-value soil test information subject to the review and approval of the city
engineer.
20. Developer is responsible to ensure all utility transformers or raised water backflow
preventers that serve this development are located outside the right-of-way as shown
on the Site Plan and to the satisfaction of the city engineer. These facilities shall be
constructed within the property.
Utilities Conditions
21. Prior to issuance of a certificate of occupancy, Developer shall construct an 8-inch PVC
sewer main in College Blvd. from El Camino Real to Sunny Creek Road. If the city engineer
determines said improvements are infeasible, the developer shall upsize the existing 8”
sewer main in El Camino Real, from the existing manhole approximately 650 feet north
June 3, 2026 Item #1 261 of 417
of College Blvd. to Jackspar Lane. Said improvements shall be installed to current City of
Carlsbad Engineering Standards to the satisfaction of the City Engineer.
22. Developer shall maintain the existing 8” sewer lateral and manholes from the existing
manhole in Salk Avenue to and within the project as shown on the site plan. The
developer shall submit a plan amendment to the existing public improvement drawing to
change the designation of the existing 8” sewer lateral in Salk Avenue from public to
private. Developer shall pay plan check fees in accordance with the city’s current fee
schedule.
23. Developer shall pay for the bypass (detector) meter on the fire backflow device per City
of Carlsbad Engineering Standard Drawing W-9. CMWD will install the bypass meter.
24. Developer shall meet with the fire marshal to determine the fire protection
requirements (fire flows, fire hydrant locations, building sprinklers, etc.) required for the
project
25. Developer shall design and agree to construct public facilities within public right-of-way
or within minimum 20-foot wide easements granted to the Carlsbad Municipal Water
District or the City of Carlsbad. At the discretion of the District or City Engineer, wider
easements may be required for adequate maintenance, access and/or joint utility
purposes.
26. The developer shall agree to design landscape and irrigation plans utilizing recycled water
as a source and prepare and submit a colored recycled water use map to the Planning
Department for processing and approval by the District Engineer.
27. Prior to issuance of a certificate of occupancy, Developer shall install potable water
and/or recycled water services and meters at locations approved by the District
Engineer. The locations of said services shall be reflected on public improvement plans.
28. Prior to issuance of a certificate of occupancy, The developer shall agree to install sewer
laterals and clean-outs at locations approved by the City Engineer. The locations of
sewer laterals shall be reflected on public improvement plans.
29. Prior to issuance of a certificate of occupancy, The developer shall design and agree to
construct public water, sewer, and recycled water facilities substantially as shown on the
site plan to the satisfaction of the District Engineer and City Engineer.
30. The developer shall submit a detailed sewer study, prepared by a registered engineer,
that identifies the peak flows of the project, required pipe sizes, depth of flow in pipe,
velocity in the main lines, and the capacity of the existing infrastructure. Said study shall
be submitted concurrently with the improvement plans for the project and the study shall
be prepared to the satisfaction of the District Engineer.
June 3, 2026 Item #1 262 of 417
31. The developer shall submit a detailed potable water study, prepared by a registered
engineer that identifies the peak demands of the project (including fire flow demands).
The study shall identify velocity in the main lines, pressure zones, and the required pipe
sizes. Said study shall be submitted concurrently with the improvement plans for the
project and the study shall be prepared to the satisfaction of the District Engineer.
Fire Department Conditions
32. Building, fire protection, and landscape plans shall meet all requirements included in the
AM&M Approval Letter. The Alternative Material & Methods Approval is only valid for
the building/project design that is proposed and the codes, standards, ordinances, and
laws in effect at the time of this approval. Any changes to the project design, codes,
standards, ordinances, or laws before issuance of a building permit will void this approval
and will require a new Alternative Material & Methods request to be submitted for review
and approval.
33. The applicant has proposed a dedicated 20-foot-wide fire department access driveway
constructed with an impervious paver system to function as the second access point
from Salk Ave. Access gate(s) with “No Parking” signage and Knox locks will be provided
at the discretion of the fire code official.
34. Property is in a mapped Fire Suppression Zone and shall comply with the City Landscape
Manual. Landscape Plan with Fuel Modification is currently under review. All elements of
the final fire landscape/fuel modification plan shall be maintained in accordance with said
plans and are subject to the enforcement process outlined in CWUIC Section 109.
Continuous maintenance of vegetation is required.
Code Reminders
The project is subject to all applicable provisions of local ordinances, including but not
limited to the following:
1. Developer shall pay planned local area drainage fees in accordance with Section
15.08.020 of the City of Carlsbad Municipal Code to the satisfaction of the city engineer.
2. Developer shall pay traffic impact and sewer impact fees based on Section 18.42 and
Section 13.10 of the City of Carlsbad Municipal Code, respectively. The Average Daily Trips
(ADT) and floor area contained in the staff report and shown on the (SITE PLAN) are for
planning purposes only.
NOTICE TO APPLICANT
An appeal of this decision to the City Council must be filed with the City Clerk at 1200 Carlsbad
Village Drive, Carlsbad, California, 92008, within ten (10) calendar days of the date of the Planning
Commission’s decision. Pursuant to Carlsbad Municipal Code Chapter 21.54, section 21.54.150,
the appeal must be in writing and state the reason(s) for the appeal. The City Council must make
a determination on the appeal prior to any judicial review.
June 3, 2026 Item #1 263 of 417
NOTICE
Please take NOTICE that approval of your project includes the “imposition” of fees, dedications,
reservations, or other exactions hereafter collectively referred to for convenience as
“fees/exactions.”
You have 90 days from date of final approval to protest imposition of these fees/exactions. If
you protest them, you must follow the protest procedure set forth in Government Code Section
66020(a), and file the protest and any other required information with the City Manager for
processing in accordance with Carlsbad Municipal Code Section 3.32.030. Failure to timely follow
that procedure will bar any subsequent legal action to attack, review, set aside, void, or annul
their imposition.
You are hereby FURTHER NOTIFIED that your right to protest the specified fees/exactions DOES
NOT APPLY to water and sewer connection fees and capacity charges, nor planning, zoning,
grading, or other similar application processing or service fees in connection with this project;
NOR DOES IT APPLY to any fees/exactions of which you have previously been given a NOTICE
similar to this, or as to which the statute of limitations has previously otherwise expired.
PASSED, APPROVED, AND ADOPTED at a regular meeting of the Planning
Commission of the City of Carlsbad, California, held on June 3, 2026, by the following vote, to wit:
AYES: Hubinger, Lafferty, Fitzgerald, Foster, Meenes.
NAYES: None.
ABSENT: Burrows, Merz.
ABSTAIN: None.
_____________
ROY MEENES, Chair
Carlsbad Planning Commission
ATTEST:
________
ERIC LARDY, Assistant Director of
Community Development
June 3, 2026 Item #1 264 of 417
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Map generated on: 12/30/2025
Exhibit 3
June 3, 2026 Item #1 265 of 417
Docusign Envelope ID: 0BC14BDF-571 C-4429-B939-524A 16O7D23B
{'city ofCarlsbad AUTHORIZATION, CONSENT, AND
DISCLOSURE STATEMENT
P-1(A)
Development Services
Planning Division 1635 Faraday Avenue 442-339-2600 www.carlsbadca.gov
§) APPLICATION AND ACKNOWLEDGEMENT INFORMATION
This submittal form (Part A through Part F) must be completed as part of your application with the City
of Carlsbad. Your project cannot be reviewed until this information is completed.
PART A. Owner Authorization and Consent
NOTE: This Consent and Disclosure Form must list the name of the principal owners {10% or greater) and
attach a copy of the current corporate articles, partnership agreement, or trust document, as applicable.
Provide name(s) of the person(s) authorized to sign on behalf of the organization. (A separate page may
be attached if necessary.) IF NO INDIVIDUALS OWN MORE THAN 10% OF THE SHARES, PLEASE IND/CA TE
NOT-APPLICABLE {N/A) IN THE SPACE BELOW.
This is to certify under penalty of perjury that the undersigned is/are the record owner(s) of the
property known as:
Assessor's Map Book, Page and Parcel (APN/APNs): _A_P_N_2_1_2 _-_0_2_1 _0_-4_ -_o_o ________ _
_ L_o _t _4 _, _C _a _rls_b_a_d_T_r_ac_t_N_o_._o_o_-2_0_, _M_a_p _N_o _._1_5_2_3 ____________ ; and
street Address (if applicable): N o Address, Adjac ent t o 2177 Salk Avenu e, Carlsbad CA 92q08
that I/we (full legal name of all record owners) consent to the filing of the Land Use Review Application
on our property for processing by the City of Carlsbad Planning Division. I/We declare under penalty of
perjury that I/we have reviewed this Affidavit and the information is true and correct.
1.
2.
Name: Sc ripps Health S. t Brett Tande 1gna ure: ____________ _
Phone Number: _s_o_s4_4_s_o_o 3_2 _______ Ema i I: _t_an_d_e_._b_re_t_t_@_s c_r_i _P P_s_h_e _a l_t_h_. _o rg
Contact Address: 4555 Execut ive Drive, San Diego CA 921 21
Name: ___________ Signature: ____________ _
Phone Number: ___________ Email: __________ _
Contact Address: ______________________ _
NOTE: For additional names, please use a separate sheet of paper.
Page 1 of 6
P-1 (A) Form Rev 4/2024
Exhibit 4
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PROJECT ANALYSIS
The Salk Avenue Apartments Project consists of a Site Development Plan and Density Bonus request to
construct a 397-unit residential apartment project, on a vacant property generally located on the south
side of Salk Avenue, west of El Camino Real and east of College Blvd.
The Project is subject to the following regulations:
A.Land Use Density Allowances - General Plan R-30 Residential Land Use Designation, Density Bonus
Ordinance (CMC Chapter 21.86), and State Density Bonus Law (Government Code Sections 65915 -
65918)
B.General Plan Policy Compliance
C.Site Development Plan (CMC Chapter 21.06 and CMC Chapter 21.53)
D.Residential Density Multiple Zone Standards (R-DM Zone, CMC Chapter 21.24)
E.Objective Design Standards (CMC Chapter 21.88)
F.Inclusionary Housing Ordinance (CMC Chapter 21.85)
G.McClellan-Palomar Airport Land Use Compatibility Plan
H.Growth Management Ordinance (CMC Chapter 21.90) and Local Facilities Management Plan Zone 5.
I.No Net Loss (Government Code Section 65863)
The recommendation for approval of this Project was developed by analyzing the Project’s consistency
with the applicable regulations and policies. The Project’s compliance with each of the above regulations
is discussed in detail within the sections below.
A.Land Use Density Allowances - General Plan R-23 Residential Land Use Designation, Density
Bonus Ordinance (CMC Chapter 21.86), and State Density Bonus Law (Government Code Sections
65915 - 65918)
The site has a R-30 Residential (R-30) General Plan Land Use designation and is zoned Residential
Density-Multiple (RD-M). The General Plan Land Use designation for the property allows a residential
density between 26.5 to 30 dwelling units per acre (minimum to maximum base density). The R-30
General Plan Land Use designation generally provides for development of a full range of housing types
at higher densities. Housing types allowed in this Land Use designation category may include two-family
dwellings (two attached dwellings, including one unit above the other) and multi-family dwellings (three
or more attached dwellings), subject to specific review and community design requirements.
While property owner(s) have fundamental rights to decide when to sell their property and/or to make
changes in the way the land is utilized, the decision of how to develop the property is not absolute and
is heavily restricted by land use controls and regulations set by local and state agencies. In Carlsbad,
residential density is controlled by the General Plan and is normally required to be within the density
range (both maximum and minimum) specified in the applicable designations. Site constraints or
development standards established in zoning ordinances may also limit attainment of the maximum
density allowed. While cities and counties have historically been able to utilize their police powers to
control zoning, land use, and housing, the State Legislature recently shifted some of this control away
from cities and counties - to one where the state mandates housing production to address the on-going
housing affordability crisis. California’s “State Density Bonus Law” (Government Code Sections 65915 -
65918) is intended to encourage the development of affordable housing options throughout the state
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by, among other things, giving residential and mixed-use developments that meet certain affordable
housing requirements permission to exceed the otherwise maximum allowable number of residential
units (a “density bonus”). The legislative intent of State Density Bonus Law is to increase the production
of affordable housing. The density bonus that is authorized is set on a sliding scale based upon the
percentage of affordable units in a project, ranging from 5% to 50% additional units over the number
ordinarily permitted. Moreover, California has changed the State Density Bonus Law to give developers
the option to incorporate significant additional density into eligible bonus projects. AB 1287, statutes of
2023, created a new stackable density bonus (bonus on top of bonus). As with the base bonus, the
additional bonus is calculated based on a percentage of the project’s base density. Thus, this bonus is
additive of the initial 50% bonus, meaning a project could obtain a 100% density bonus (“double density
bonus”) if providing the required percentage of affordable units. More background information about
State Density Bonus Law and the city’s implementing ordinance (CMC Chapter 21.86), is provided in the
city’s Informational Bulletin (IB-112), provided in the link below.
https://www.carlsbadca.gov/home/showpublisheddocument/8169/638967418316170000
Table “A” below identifies the permissible density range for properties within R-30 Zone, as well as the
allowable density range based on the size of the Project site and the proposed density and residential
units under State Density Bonus Law.
TABLE A – DENSITY COMPUTATIONS
Gross
Acres1 Min/Max Dwelling Units per Project Density;
Proposed Dwelling Units per Density Bonus
9.78 acres Density per General Plan 26.5-30 du/ac
Min: 259.17, rounded to 259 dwelling
units2
Max: 293.4, rounded to 293 dwelling
units3
35% density bonus over base density (103 units)
Allowed maximum density: 396.9, rounded to
397 dwelling units4
40.6 du/ac
1 State Density Bonus Law (Government Code Section 65915(f) refers to “gross” density, not “net” density. Therefore, density calculations must
be based on gross acres, rather than net acres.
2 For residential minimum density calculations (CMC Section 21.53.230), residential unit yields are rounded-down if fractional units below 0.5.
3 For residential maximum density calculations (CMC Section 21.53.230), residential unit yields are rounded-down if fractional units.
4 For projects subject to State Density Bonus Law, all density calculations shall be rounded up per CMC Section 21.86.050 and State Density Bonus
Law (Government Code Section 65915(f)(5).
The proposed Project entails a request to construct 397 dwelling units. As summarized in the table
above, the maximum base number of dwelling units allowed for a 9.78-acre parcel at 30 du/ac is 293.4
dwelling units (which is rounded up to 294 units in accordance with State Density Bonus Law,
Government Code Section 65915(f)(5)). In order to construct 397 dwelling units, the Applicant is
requesting approval of a density bonus pursuant to CMC Chapter 21.86, the Density Bonus Ordinance,
and State Density Bonus Law. CMC Chapter 21.86 was established as a means to implement California
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Government Code Section 65915 – 65918 (State Density Bonus Law) and the goals, objectives and
policies of the Housing Element of the General Plan which includes the provision to provide housing
affordable to lower- and moderate-income households. In this instant, to support the implementation of
the Project, the Applicant is requesting a 35% density bonus pursuant to State Density Bonus Law. (The
resulting computation of permitted density is rounded up from 396.9 dwelling units to 397 dwelling
units pursuant to Government Code Section 65915(f)(5)). In exchange for the 35% density bonus, the
Applicant is required to designate 20% of the 294 base maximum density units, or 59 dwelling units, as
affordable density bonus units. The affordable density bonus units are required to be affordable to “low-
income households” for a period of 55 years.
State Density Bonus Law stipulates that a request for a density bonus does not constitute a valid basis
on which to find a proposed housing development project is not compliant with a local general plan. In
addition, State Density Bonus Law explicitly requires a city or county to consider “the density allowed
under the land use element of the general plan” in determining maximum allowable residential density.
Therefore, the proposed density of the Project is deemed compliant with the R-30 Residential Land Use
designation of the General Plan.
Incentives, Concessions or Waivers
Along with density bonuses, State Density Bonus Law also requires cities and counties to grant
concessions, incentives, and waivers to development applications meeting a minimum percentage of
affordable units. State Density Bonus Law provides for a progressive approach to incentives or
concessions, allowing up to four incentives or concessions in some cases. It also includes additional
regulatory relief in the form of waivers from development standards, which do not count as incentives
or concessions, and are unlimited and limits on parking requirements. For projects located near transit
stops, additional concessions are afforded.
A project can request incentives and concessions as defined in State Density Bonus Law. The number of
concessions and incentives are limited to the following based on the percentage of on-site affordable
units provided is listed below in Table “B.”
TABLE B – ALLOWANCES FOR INCENTIVES AND CONCESSIONS
Minimum Percentage of Affordable Units
• 5% Very Low,
• 10% Low, or
• 17% Low, or
• 24% Low, or
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An incentive or concession may include any of the following:
• A reduction in site development standards or a modification of zoning code or architectural design
requirements (excluding State Building Standards), that results in identifiable, financially sufficient
and actual cost reductions. A reduction/modification to standards or requirements may include, but
is not limited to, a reduction in minimum lot size, setback requirements, and/or in the ratio of
vehicular parking spaces that would otherwise be required.
• Approval of mixed-use zoning in conjunction with the housing development if: (a) commercial, office,
industrial or other land uses will reduce the cost of the housing development; and (b) the commercial,
office, industrial, or other land uses are compatible with the housing development and the existing or
planned future development in the area where the proposed project will be located.
• Other regulatory incentives or concessions that result in identifiable, financially sufficient and actual
cost reductions.
• The city council may, but is not required to, provide direct financial incentives, including the provision
of publicly owned land, or the waiver of fees or dedication requirements.
In addition to incentives or concessions, waiver or reduction of development standards that would
“have the effect of physically precluding the construction of a density bonus housing development at
the density or with the incentives or concessions permitted by” can also be considered. There is no limit
on the number of waivers or reductions of development standards that may be granted, and the grant
of a waiver or reduction shall neither increase nor decrease the number of incentives or concessions to
which the project is entitled. Waivers or reductions of development standards shall be granted by the
city or county unless certain findings can be made. In order to deny the requested waivers or reductions,
the city would have to make any of the following findings in writing based upon substantial evidence:
• The standard(s) requested to be waived or reduced will not have the effect of physically precluding
the construction of a housing development at the densities or with the incentives or concessions
permitted by this chapter.
• The requested waiver or reduction of development standards would have a specific adverse impact
(a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written
public health or safety standards, policies, or conditions as they existed on the date the application
was deemed complete) upon public health and safety or the physical environment, or on any real
property that is listed in the California Register of Historical Resources, and for which there is no
feasible method to satisfactorily mitigate or avoid the specific adverse impact.
• The waiver or reduction of development standards would be contrary to state or federal law.
The Applicant is not requesting incentive/concession but is requesting waivers as annotated below. Staff
has found no substantial evidence that any of the above findings apply in this case.
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Waivers:
• Waiver of Objective Design Standard 2.A.2 requiring an on-site common recreational space
located outdoors and adjacent or visible from the primary street (applicable to project with 50
units or more).
• Waiver of Objective Design Standard 2.B requiring parking within 15 feet of a residential unit to
be located within a structure or be screened.
• Waiver of Objective Design Standard 2.D requiring 100 sf/unit of common recreational space.
• Waiver of Objective Design Standard 2.F.1 requiring a landscape buffer of minimum five feet be
located adjacent to all ground-level residential space.
• Waiver of Objective Design Standard 3.A.2 requiring a two-foot variation in depth of wall plane
for every 40 feet of building façade that is visible from a primary street.
• Waiver of Objective Design Standard 3.A.2.a limiting upper floors to a maximum of 90% of the
ground floor total area.
• Waiver of Objective Design Standard 3.A.4 limiting the horizontal distance of a roofline to more
than 40 feet without a prominent change.
• Waiver of CMC 21.21.030 limiting the height of a structure in the RD-M zone to 35 feet.
• Waiver of CMC 21.44.060 (Table D) requiring parking spaces within a garage be 8.5’ x 20’.
• Waiver of Objective Design Standard 2.E requiring each unit be provided private recreation space
(balcony or patio).
• Waiver of CMC 21.85.030.C requiring at least 10% of provided lower income units have three
bedrooms or more.
• Waiver of CMC 21.46.130 limiting walls and fencing outside of setback areas to six feet in height.
The Applicant’s proposed justification for the requested waivers that pertain to CMC-related
development standards and Citywide ODS is provided in Exhibit 7 to the June 3, 2026, Planning
Commission staff report. For the waivers, adequate information has been provided to show that the
development standard for which the waiver or reduction is requested will have the effect of physically
precluding the construction of the Project.
It is important to note that State Density Bonus Law includes specific provisions (Government Code
Section 65915(p)) regarding minimum parking ratios for density bonus projects. This is in addition to the
incentives, concessions, or waivers listed above. This is explained in more detail in Section “D” of this
attachment.
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B. General Plan Policy Compliance
In addition to the above, the project also complies with the other goals and policies of the General Plan
as outlined in Table “C” below:
TABLE C – GENERAL PLAN COMPLIANCE
ELEMENT COMPLY
Land Use &
Community
Design
compatible land uses throughout
the city, to enable people to live
close to job locations, adequate
and convenient commercial
services, and public support
systems such as transit, parks,
schools, and utilities.
multi-family residential apartments
in the form of 338 market rate units
and 59 affordable units located near
jobs, beaches, lagoons, and
convenient neighborhood-serving
commercial services. The immediate
area surrounding the Project is
home to large number and diverse
employers including Tylor Made
Golf and Thermo Fisher Scientific,
and the Rancho Carlsbad Golf
Course.
Potential land use conflicts or
incompatibilities are typically the
result of environmental effects,
such as noise or increased traffic on
area roadways. However, the
proposed Project is being developed
as multiple-family residential
apartments, a land use that is
consistent with the land uses
envisioned pursuant to the city’s
General Plan. The Project’s
compliance with zoning standards
and objective design standards, as
amended by State Density Bonus
Law, ensure that the Project would
be compatible with adjacent off-site
land uses and those uses proposed
Community
Design
development that makes efficient
use of limited land supply, while
ensuring compatibility and
site surrounded by existing
developments and open space. The
site is not identified in the city’s
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ELEMENT COMPLY
Ensure that infill properties
develop with uses and
development intensities
supporting a cohesive
development pattern.
in the city’s HMP. The Project
provides all required parking on-site
in accordance with State Density
Bonus Law.
Surrounding land use designations
include PI, and OS. Although the
proposed Project would be larger
and taller than adjacent one, two
and three-story commercial
structures, compatibility with the
adjacent neighborhood and overall
mass and scale of the Project have
been addressed through the use of
Community
Design
neighborhoods with a variety of
housing types and density ranges
to meet the diverse demographic,
economic and social needs of
residents, while ensuring a
cohesive urban form with careful
regard for compatibility.
project with 397 apartments units
(338 market rate and 59 affordable)
in a variety of bedroom counts,
provides for much needed higher
density housing located near
employment centers.
The proposed Project is being
developed as multiple-family
residential apartments, a land use
that is consistent with the land uses
envisioned pursuant to the city’s
to construct or pay their fair share
toward improvements for all travel
modes consistent with the Mobility
Element, the Growth Management
Plan, and specific impacts
associated with their development.
install a bench, trash can, and an
ADA pad at the transit stops on
College Boulevard which improves
the transit stops to LOS A for the
northbound bus stop and LOS C for
the Project. The LMA concluded
that the Salk Avenue, El Camino
Real, and College Blvd intersections
would operate at acceptable levels,
and no intersection improvement
are warranted due to increased
vehicle trips. The project is required
to install a bench, trash can, and an
ADA pad at the transit stops on
College Boulevard which improves
the transit stops to from LOS F to
LOS A for the northbound bus stop
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ELEMENT COMPLY
southbound bus stop. Payment of
development impact fees would
fund necessary public infrastructure
and services (like roads, parks,
schools, sewers) caused by the
growth, ensuring new development
pays its fair share for increased
Conservation
& Recreation
environmentally sensitive lands,
wildlife habitats, and rare,
threatened, or endangered plant
and animal communities.
any riparian or jurisdictional water
resource features or trees that are
protected by the Trees Ordinance
and Community Forest
Management Plan. Although, the
site does contain habitat for
protected species and HMP
standard areas are located to the
north, a Biological Resources Report
has been provided in connection to
the Focused IS/MND for the project
and mitigation measures to protect
biological resources have been
prepared and are included as
and welfare by eliminating existing
noise problems where feasible,
maintaining an acceptable indoor
and outdoor acoustic environment,
and preventing significant
degradation of the acoustic
environment.
Goal 5-G.2 – Ensure that new
development is compatible with
the noise environment, by
continuing to use potential noise
exposure as a criterion in land use
planning.
residential apartments located in
one building. A Noise Study was
prepared by SLR International
Corporation, (May 7,2025). The
city's residential exterior noise level
standard is 60 dBA Community
Noise Equivalent Level (CNEL) and
the interior noise level standard is
45 dBA CNEL when openings to the
exterior of the residence are closed.
As part of the Noise Study, sound
level measurements taken on the
site show an existing ambient noise
level no higher than 54.1 dBA CNEL.
The existing measured ambient
noise level is below the city's 60
dBA CNEL standard for exterior
noise in residential areas. The
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ELEMENT COMPLY
decks for the proposed residential
units. Decks facing outward from
the project site onto Salk Ave would
not expose residents to exterior
noise levels greater than the
normally acceptable range for
multi-family residential uses, based
on the existing ambient noise
measurements collected at the
Project site. The interior noise
standards are also expected to be
met with standard window
construction. Therefore, the
ambient noise environment is in the
"normally acceptable" range for the
proposed residential use. That is,
the project would not result in the
generation of a substantial
temporary or permanent increase in
ambient noise levels in the vicinity
of the Project in excess of standards
established in the General Plan or
Noise Ordinance, or applicable
standards of other agencies.
In general, compliance with the City
of Carlsbad Noise Ordinance (CMC
Chapter 8.48) would limits the days
and hours of construction in areas
with the potential to cause
disturbance. Moreover, conditions
of approval related to noise
exposure would reduce
construction noise within 500 feet
of life, and damage to property
resulting from fire, flood,
hazardous material release, or
seismic disasters.
in any Very High Fire Severity Zone,
Flood Zones, or Earthquake Fault
Zones. The proposed structural
improvements would be required to
meet all seismic design standards at
time of building permit in
accordance with the California
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ELEMENT COMPLY
has reviewed and approved the
proposed conceptual building
design with fire sprinklers included
throughout the building per the
National Fire Protection Association
hazards related to aircraft
operations in areas around the
McClellan-Palomar Airport.
compliance with the ALUCP airspace
protection surfaces because the
maximum height of the proposed
structure including the architectural
features are below the height that
requires notification of construction
to the FAA, would not exceed
obstruction standards and would
not result in hazard to air
services that are responsive to
citizens’ needs to ensure a safe and
secure environment for people and
property in the community.
provided for the entire structure,
including the parking structure; and
the dwelling units proposed by this
Project are all within a 5-minute
emergency response time (Fire
Station no. 5 and Fire Station no. 3).
Fire Station no. 5 is located 1 mile
driving distance to the east. Fire
Station no. 3 is 2 miles driving
distance to the northeast.
The capital facilities required to
provide fire services are funded
through the city’s development
impact fee program. The fees levied
against the Project address the
Project’s proportional impact on
capital facilities, such as structures
and equipment, associated with fire
protection. Public funds such as
property taxes, sales taxes, and fees
generated by the Project would be
used to cover the incremental costs
associated with providing fire and
emergency medical services. Future
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ELEMENT COMPLY
to meet established public facility
standards, including those related
to fire response services, with
respect to the additional needs
created by such development.
These fees would be exclusively for
future facility improvements
necessary to ensure that the
development contributes its fair
share of the cost of fire facilities and
equipment determined to be
necessary to adequately
accommodate new development in
requirements of Titles 18, 20, and
21 pertaining to drainage and flood
control when reviewing
applications for building permits
and subdivisions.
develop and implement a program
of “best management practices” for
the elimination and reduction of
pollutants which enter and/or are
transported within storm drainage
facilities.
Uniform Building and Fire codes,
adopted by the city, to provide fire
protection standards for all
existing and proposed structures.
with all Building and Fire codes to
ensure that fire protection
standards are met by the proposed
structures.
development complies with all
applicable regulations regarding
the provision of public utilities and
facilities.
or pay applicable fees for necessary
improvements, public utilities, and
facilities in accordance with Growth
Management requirements; Fire
Station nos. 5 and 3 are within
emergency response timeframes;
and the Project would not affect the
city’s ability to implement its
Action Plan (CAP) as the city’s
strategy to reduce greenhouse gas
emissions.
consistent with measures identified
in the Climate Action Plan (CAP)
through the provision of renewable
energy generation (photovoltaic
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ELEMENT COMPLY
(Green Building Code), and by
accommodating Zero-Emission
vehicles and other greenhouse gas
reduction measures and features.
At building permit plan check, the
Project would also be reviewed for
compliance with the CAP
affordable housing opportunities in
all quadrants of the city to meet
the needs of current lower and
moderate-income households and
those with special needs, and a fair
share proportion of future lower
and moderate-income households.
15% of the total residential units as
affordable for lower income
households. The Project is
conditioned to enter into an
Affordable Housing Agreement with
the city to provide and deed restrict
59 dwelling units as affordable to
low-income households for 55
developed with diversity of types,
prices, tenures, densities, and
locations, and in sufficient quantity
to meet the demand of anticipated
city and regional growth.
increase the diversity of housing in
Carlsbad by adding 338 market rate
dwelling units and 59 deed
restricted dwelling units (397 multi-
family apartment units) to the city’s
housing inventory. The Project is
conditioned to enter into an
Affordable Housing Agreement with
the city to provide and deed restrict
49 dwelling units (15%) as
affordable to low-income
Inclusionary Housing Ordinance,
require affordability for lower
income households of a minimum
15% of all residential ownership
and qualifying rental projects. For
projects that are required to
include 10 or more units affordable
to lower income households, at
least 10% of the lower income
units should have three or more
bedrooms (lower income senior
into an Affordable Housing
Agreement with the city to provide
and deed restrict 59 dwelling units
(15%) as affordable to low-income
households for 55 years.
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ELEMENT COMPLY
Housing Policy 10-P.19 – Address the unmet
housing needs of the community
through new development and
housing that is set aside for lower
and moderate-income households
consistent with priorities set by the
Housing and Neighborhood
Services Division, in collaboration
with the Planning Division, as set
forth in the city’s Consolidated
Plan.
jobs/housing ratio where there are
more jobs than housing. The Project
utilizes a vacant piece of land and
constructs 397 residential
apartment units (338 market rate
dwelling units and 59 affordable
dwelling units). The project expands
the city’s affordable housing stock
to assist in meeting its Regional
Housing Needs Assessment and
provides an adequate number of
housing units to meet the needs of
C. Site Development Plan (CMC Chapter 21.06 and Chapter 21.53)
Pursuant to Section 21.53.120 of the CMC, a SDP is required to be processed for this 397-unit apartment
Project pursuant to CMC Chapter 21.06, the Qualified Development Overlay Zone. The Qualified
Development Overlay Zone does not contain any specific development standards but does allow the
Planning Commission to increase any standards or impose special conditions that may be deemed
necessary. However, the ability of the city to implement this provision is preempted to an extent. When
a housing development project meets all objective planning, zoning, and design standards in place when
its application was complete, state law generally requires cities and counties to approve it, limiting their
ability to deny or add conditions, except for specific, objective health/safety impacts, under laws like the
Housing Accountability Act. This prevents cities and counties from using subjective criteria or new rules
to block compliant housing development proposals. As demonstrated in Table “D” below, all of the
required SDP findings can be made.
TABLE D – SDP COMPLIANCE
That the proposed development or use
is consistent with the General Plan and
any applicable master plan or specific
plan, complies with all applicable
provisions of Chapter 21.06 of the
CMC, and all other applicable
provisions of the code.
elements and objectives of the General Plan as
discussed in Section “B” of this attachment.
The various goals and objectives of the
General Plan would be implemented as the
proposed Project is consistent with the General
Plan Land Use designation, which allows for a
mixture of residential uses and housing types,
including multiple-family residential. As
discussed in Section “B” above, although the
project’s density of 40.6 dwelling units per acre
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SDP FINDING COMPLIANCE ANALYSIS COMPLY
Residential Land Use designation of 30 du/ac,
the 397-unit residential apartment project can
be found compliant. See Section “A” of this
attachment. The granting of any density bonus
or incentives, concessions, or waivers shall not
be considered an increase in density or other
change which requires any corresponding zone
change, General Plan amendment, or other
is properly related to the site,
surroundings and environmental
settings, will not be detrimental to
existing development or uses or to
development or uses specifically
permitted in the area in which the
proposed development or use is to be
located, and will not adversely impact
the site, surroundings or traffic
circulation.
would not be detrimental to existing uses or to
uses specifically permitted in the area in which
the use is located in that multiple-family
residential is a permitted use within the RD-M
Zone and is compatible with the other multi-
story development surrounding the Project
site. The Project would not adversely impact
the site, surroundings, or traffic circulation in
that the existing surrounding streets have
adequate capacity to accommodate the 2,382
Average Daily Trips (ADT) generated by the
Project. With exception to the requested
incentives, concession, and waivers, the Project
complies with all minimum development
standards of the CMC and ODS, including but
development or use is adequate in
size and shape to accommodate the
use.
to accommodate the proposed 397-unit
residential apartment building. The Project is
entitled to the requested number of units and
the density bonus incentives/concessions and
waivers are necessary for the Project to be
developed at the density and with the
incentives/concessions permitted by State
Density Bonus Law and CMC Chapter 21.86.
With exception to the allowance for increased
building height, increased retaining wall height,
and modified parking space dimensions
requested through the density bonus process,
the residential apartment project complies
with all remaining development standards of
the Residential Density - Multiple (RD-M) Zone.
The details of the request include a reduction
in development standards from the Citywide
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SDP FINDING COMPLIANCE ANALYSIS COMPLY
Chapter 21.88 of the CMC. Relief from the
design standards make it feasible for the
Developer to build to the density allowed by
the zoning, as reduced/amended by State
Density Bonus Law, and does not constrain a
local agency’s ability to achieve its RHNA
landscaping, and other features
necessary to adjust the requested
development or use to existing or
permitted future development or use
in the neighborhood will be provided
and maintained.
building height, increased retaining wall height,
and modified parking space dimensions as
discussed in Section “A” above, the Project
complies with all remaining development
standards (i.e. front, side and rear setbacks, lot
coverage) of the RD-M Zone. Landscaping
along the outer edges of the property,
including the areas along Salk Avenue, would
be provided consistent with the requirements
proposed development or use is
adequate to properly handle all traffic
generated by the proposed use.
with vehicles traveling to and from the project
on Salk Avenue as well. Salk Avenue is identified
as an industrial street, designed to adequately
handle the 2,382 Average Daily Trips generated
by the 397-unit residential apartment project. In
addition, the Applicant would be required to pay
traffic impact fees in accordance with CMC
Chapter 18.42 prior to issuance of building
permits that would go towards future road
D. Residential Density Multiple Zone (R-DM Zone, Chapter 21.24)
The intent and purpose of the RD-M Zone is to implement the R-8 (Residential 4-8 du/ac), R-15
(Residential 8-15 du/ac), R-23 (Residential 15-23 du/ac), R-30 (Residential 26.5-30 du/ac), R-35
(Residential 32.5-35 du/ac) and R-40 (Residential 37.5-40 du/ac) Land Use designations of the General
Plan. It provides regulations and standards for the development of residential dwellings. In accordance
with CMC Section 21.53.120, an SDP is required to be processed pursuant to the provisions of CMC
Chapter 21.06, Qualified (Q) Development Overlay Zone, where the Project is greater than four dwelling
units and includes affordable housing on-site. An SDP analysis is provided in Section “C.”
Compliance with the RD-M Zoning Standards are noted in Table “E” below and compliance with CMC.
June 3, 2026 Item #1 296 of 417
TABLE E - RD-M ZONE COMPLIANCE
Setbacks Front: 10 feet, 20 for carport or garage
openings that face onto the front yard
Interior Side: 5 feet
Rear: 10 feet
40 feet to parking.
Interior Sides: 68 feet
Height CMC Section 21.46.020
The Project consists of one
building with a maximum
height of 74’ 5” when
accounting for tower elements,
2
1 The Project is requesting a density bonus waiver for building height.
2 Roof structures specifically for the housing of elevators, stairways, tanks, ventilating fans or similar equipment required to operate and maintain the building, fire or parapet walls, skylights, architectural features or towers, flagpoles, chimneys, smokestacks, wireless masts
and similar structures may be erected above the height limits prescribed in this title but no roof structure or any other space above the
height limit prescribed for the zone in which the building is located shall be allowed for the purpose of providing additional floor space, or be taller than the minimum height requirement to accommodate or enclose the intended use (CMC Section 21.46.020).
The Project complies with all applicable development standards for residential uses in the RD-M Zone
including lot coverage, height, setbacks, etc. subject to density bonus provisions for reductions of
standards (i.e. building height). The Project is proposing to utilize the Density Bonus Parking Standards
as requested per Government Code section 65915(p)(1). Compliance with Government Code section
65915(p)(1) is outlined in Table “F” below, as implemented by CMC Chapter 21.86. As explained
previously in this attachment, local agencies are required to grant qualifying projects the parking ratio
reduction listed in State Density Bonus Law as a matter of right.
June 3, 2026 Item #1 297 of 417
TABLE F – PARKING
No. of Bedrooms No. of Units 1
Studio 4
1-Bdrm 253
2-Bdrm 112
3-Bdrm 28
Total
Total Parking Provided 542 Spaces
1 Residential parking ratios are specified under CMC Section 21.44.020. The number of off-street parking spaces required for the uses or structures designated in this section are set forth in Table A.
2 Pursuant to CMC Chapter 21.44, visitor parking is required at 0.25 spaces per each unit with projects with 11 or more residential units. Based
on the scope of the Project (amount of residential units proposed) and the parking ratios required, the Project would be required to provide an
additional 99.25 additional spaces to accommodate guest parking – or 765 total parking spaces.
E. Objective Design Standards (CMC Chapter 21.88)
The city has created objective design standards for multi-family and mixed-use projects in Carlsbad as
one way the city can retain some control over new development, shape the design of certain projects,
and identify the design priorities for neighborhoods.
The Project’s compliance with the Citywide ODS is provided for in the Applicant’s ODS Compliance
Checklist – Exhibit 6 to the Jan. 21, 2026 Planning Commission staff report.
According to CMC Section 21.88.030(B), a project sponsor may request up to four ODS waivers to the
applicable objective design standards provided in the ODS without the requirement for an additional
application. To be supported, a project must demonstrate that it meets the intent of the design
standard under consideration, or a similar design standard is implemented in substitution. The waiver
process set forth in Chapter 21.88 is a separate process from the concessions/incentives and waiver
process pursuant to State Density Bonus Law and/or other applicable state laws. However, if the density
bonus concession/incentive or waiver is for an ODS, it would be counted as one of the four allowed
waivers under the Citywide ODS.
The Applicant is requesting incentive/concession and waivers as authorized by State Density Bonus Law
(refer to Section “A” of this attachment). The Project is entitled to one incentive/concession
(Government Code section 65915(d)(2)(A)) and a potentially unlimited number of development
standard waivers (Government Code section 65915(e)). A project that meets the eligibility requirements
of the State Density Bonus Law is entitled to a density bonus, incentives/concessions, development
standard waivers, and limited parking ratios (Government Code section 65915(b)). The city must grant
(i.e., “shall approve”) the specific incentives/concessions requested by the applicant unless the City
makes written findings, based on substantial evidence, that the incentive/concession would (1) not
result in a cost reduction, (2) have a specific adverse impact on health or safety (as defined), or (3) be
contrary to state or federal law (Government Code section 65915(d)). The city is also strictly limited in
June 3, 2026 Item #1 298 of 417
denying requested development standard waivers, preventing it from applying any development
standard that would physically preclude a project as proposed unless doing so would have a specific
adverse impact on health or safety (as defined) which could not be mitigated (Government Code section
65915(e)).
The Applicant’s proposed justification for the requested incentives, concessions, and waivers that
pertain to ODS-related provisions are listed in Exhibit 7. For incentives and concessions, adequate
information has been provided that shows the request results in identifiable and actual cost reductions.
For the waivers, adequate information has been provided to show that the development standard for
which the waiver or reduction is requested will have the effect of physically precluding the construction
of the Project.
The Planning Commission is not required to make any findings related to CMC Section 21.88.030(B).
Under State Density Bonus Law, a project is entitled to an unlimited number of waivers from
development standards. Specifically, the city is not permitted to apply any development standard that
physically precludes the construction of the Project at its permitted density and with the granted
concessions/incentives. (Government Code section 65915(e).)
F. Inclusionary Housing Ordinance (CMC Chapter 21.85 & Fenton Carlsbad Center Specific Plan)
Carlsbad Municipal Code Chapter 21.85 requires a minimum of 15% of the project’s total number of
residential units as inclusionary units. Additionally, the Fenton Carlsbad Center Specific Plan requires a
minimum of 20% of the projects total number of residential units as affordable to lower income
households. To satisfy this requirement, the applicant proposes designating 20% of the project’s base
density units, or three (59) units, as inclusionary units.
Inclusionary requirements can sometimes negatively affect the economic feasibility of residential
development projects. The state inclusionary zoning statute addresses these limitations, providing that a
local agency must provide alternative means of compliance (e.g., in lieu fees) and that rental
inclusionary requirements in excess of 15% may be subject to state level review (by HCD) to consider
economic feasibility (Government Code sections 65850(g) and 65850.1). A few court cases address
situations in which local ordinances or interpretations have affected the mechanics of inclusionary
zoning, especially for projects that are also subject to or otherwise invoke State Density Bonus Law.
Accordingly, the benefits and protections of the State Density Bonus Law apply to all projects that meet
the statutory minimum percentage of affordable units. Deed restricted affordable units can serve both
as an “inclusionary unit” meeting a local inclusionary zoning requirement and as a “target unit”
qualifying a project for a density bonus. Because of this conflict, the law therefore requires the city to
credit a project for both the density bonus qualifying units and inclusionary units. Moreover, while the
city’s inclusionary regulations are separate from State Density Bonus Law, pursuant to CA Attorney
General Opinion No. 24- 501 (dated April 2025), local inclusionary housing requirements can only be
applied to base density units, not the density bonus units.
In this instant, the Project is subject to three requirements, CMC Chapter 21.85 (Inclusionary Housing
Ordinance), the Fenton Carlsbad Center Specific Plan, and density bonus (Density Bonus Ordinance, CMC
Chapter 21.86, and State Density Bonus Law, Government Code Sections 65915 - 65918). The Applicant
is proposing to satisfy the affordable housing requirements of State Density Bonus Law and the city’s
Inclusionary Housing Ordinance and specific plan requirements by providing 20% or a total of 59 units as
June 3, 2026 Item #1 299 of 417
affordable to low-income households. The deed-restricted affordable units would be located on the
same site as the market-rate units and the Applicant is not requesting financial assistance from the city.
As required by CMC Chapters 21.85 and 21.86, the Project has been conditioned to require the approval
of an Affordable Housing Agreement and Density Bonus Housing agreement, respectively, prior to
issuance of a building permit. The three units would be affordable to households earning more than 50%
but not exceeding 80% of the San Diego Area Median Income (AMI) as determined annually by the U.S.
Department of Housing and Urban Development.
G. McClellan-Palomar Airport Land Use Compatibility Plan
The proposed project falls within the boundaries of the McClellan-Palomar Airport Land Use Compatibility
Plan (ALUCP). The ALUCP was amended on December 1, 2011, and all projects within its boundary are
required to be reviewed for consistency with its goals and policies. The ALUCP identifies four types of
airport impacts that must be considered for each development: Noise, Safety, Airspace Protection, and
Overflight.
Noise
The proposed project is located outside of the mapped Community Noise Equivalent Level (CNEL) noise
contours within the ALUCP.
Safety
The proposed project is located within Safety Zones 6 (Traffic Pattern Zone). Per ALUCP Policy 3.4.4.(e)
and Table III-2, new residential development in Safety Zone 6 is determined to be a compatible land use.
Additionally, the Fenton Carlsbad Center Specific Plan was reviewed by the Airport Authority and found
the specific plan consistent with the ALUCP, with specific limitations on assembly areas. The project is
consistent with all requirements and limitations for assembly areas.
Airspace Protection
The proposed project is in compliance with the ALUCP airspace protection surfaces because the maximum
height of the proposed multi-family building including architectural towers are below the height that
requires notification of construction to the FAA. Additionally, the project applicant submitted a FAA Form
7460-1 Notice of Proposed Construction of Alteration with the FAA.
Overflight
The project site is located within the Airport Influence Area (AIA) per Exhibit IIII-5. According to ALUCP
Policy 3.6.3, recordation of an overflight notification is mandated for new residential land use
development. The project is conditioned to record an overflight notification document on the property.
H. Growth Management Ordinance (CMC Chapter 21.90) and Local Facilities Management Plan Zone 6.
The proposed Project is located within Local Facilities Management Zone 6 in the Southeast Quadrant of
the city. The impacts on public facilities created by the Project, and its compliance with the adopted
performance standards, are summarized in Table “G” below.
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TABLE G – GROWTH MANAGEMENT COMPLIANCE
Standard Impacts/Demand Compliance
Schools
I. No Net Loss (Government Code Section 65863)
To expand the supply of housing, including affordable housing, and to ensure jurisdictions do not take
actions to reduce the potential capacity for new development, the State Legislature adopted the No Net
Loss Law in 2002. The No Net Loss Law ensures that a jurisdiction maintains a sufficient supply of
adequate sites in the Housing Element sites inventory throughout the Housing Element planning period.
This law was amended by Senate Bill 166 (2017), which requires sufficient adequate sites to be available
at all times to meet a jurisdiction’s remaining unmet housing needs for each income category.
The Project site or a portion thereof was identified in the Housing Element to accommodate a portion of
the regional housing need. The estimated capacity on the Project site was 259 housing units allocated to
the lower-income category. To comply with the No Net Loss Law, as development occurs, the city must
assess its ability to accommodate new housing on the remaining sites in their Housing Element site
inventory.
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TABLE H – NO NET LOSS TABLE
Lower
income
Moderate
income
Above
Moderate Total
RHNA units allocated (2021-2029) 2,095 749 1,029 3,873
Adopted RHNA capacity (2021-2029) 3,424 901 1,643 5,968
Losses to Buffer (unit production below
projection in HE sites inventory) -19 -10 -209 -238
projection in HE sites inventory*) +255 +835 +1,876 +2,966
+236 +825 +1,667 2,728
No Net Loss Buffer (as of April 2026, before
project approval) 1,565 977 2,281 4,823
Inventory assumptions about the Project site 259 0 0 259
Remaining Buffer after project approval 1,365 977 2,619 4,961
Updated RHNA Capacity 3,460 1,726 3,648 8,834
*sites not listed in the HE inventory have an assumed capacity of zero units. All development activity on
sites not identified in the HE inventory adds units to the buffer.
Table H shows that the Housing Element’s sites inventory accommodated a site capacity of 259 lower
income units at the Project site. The scope of the land use development application proposes 59 lower
income units and 338 above-moderate income units (397 total units). After the Project’s approval, the
city would have a remaining RHNA capacity of 3,460 lower-income units, 1,726 moderate-income units,
and 3,648 above moderate-income units.
The proposed development's residential density is consistent with the Housing Element, and the
remaining sites identified in the Housing Element are adequate to meet the requirements of Government
Code Section 65583.2 and to accommodate the city's share of the regional housing need pursuant to
Section 65584.
June 3, 2026 Item #1 302 of 417
City of Carlsbad Citywide Objective Design Standards
REF. SUBJECT DEVELOPMENT STANDARD WAIVER COMPLIANCE COMMENT NO. REQUEST?
SECTION 2: SITE DESIGN STANDARDS
2.A.1 -lf there is an existing contiguous building wall that maintains the
Site Layout same building plane setback for at least 75% of the buildings on a single NO N/A street block, then buildings shall be located to maintain the contiguous2.A and street wall and consistent front setback.Building 2.A.2 -.?SO-unit projects shall include at least 1 on-site commonPlacement recreational space located outdoors and adjacent or visible from the YES See attached Concession/ Waiver/ Incentive Detail Document
primary street;.
a.Side street or alley access shall
serve as the primary vehicular NO N/A access to parking and carport areas,
if available.
b.A maximum of one vehicle access
point from the street is permitted NO One vehicle access point will be provided. 2.B.1 -Access and Driveways per 100 linear feet of street
frontage.
Vehicular c.Entry driveways connecting public
2.B Parking and streets to the interior of the site Enhanced driveway paving will extend not less than 12'-0" into Access shall use enhanced paving treatment NO the property as depicted on sheet Ll.00. a minimum of 12 feet deep and
spanning the width of the driveway.
2.B.2 -To determine parking requirements, Section 21.44.020, Off-Street Compliant per Density Bonus IB112 -Refer to sheet G107 for Parking Spaces Required, of the Carlsbad Municipal Code shall be NO
implemented except as defined by Section 65585 of the Government Code.parking breakdowns.
2.B.3 -Projects with privately owned or maintained streets shall implement Entry treatment, textured pavement, speed tables, and
4 traffic calming measures and techniques from the City's Residential NO residential stop signs will be incorporated into the final private
Traffic Management Program throughout the project.access road design.
Exhibit 6
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Concession / Incentive / Waiver #1
Concession / Incentive Waiver
Concession / Incentive / Waiver #2
Concession / Incentive Waiver
Reason for
Deviation
Common outdoor recreational space is proposed on a portion of the site that
might normally be visible from the primary street; however, due to the site’s
inherent topography this amenity will not be visible. Required grade
adjustments to achieve visibility would conflict with other building requirements
and previous entitlements.
Select Type:
Code / Policy
Number
2.B Vehicular Parking & Access
Required
Standard
2.B.5 - Where parking areas are located within 15 feet of a residential unit, they
shall be located within a garage, carport, or parking structure, or screened by a
solid wall, fence, or landscaping a minimum of 6 feet in height
Select Type:
Code / Policy
Number
2.A Site Layout and Building Placement
Required
Standard
2.A.2 - ≥50-unit projects shall include at least 1 on-site common recreational
space located outdoors and adjacent or visible from the primary street .
Proposed
Deviation
N/A
Proposed
Deviation
All parking spaces are at least 12' from any unit windows, which are at least 30"
high on the ground floor. Landscaping will offer some buffer for light intrusion.
Reason for
Deviation
The distance between back of curb and face of building is less than 15’-0” in
some parking areas due to site access constraints and the need for a continuous
perimeter fire road around the site. Surface parking spaces more than 15’ away
from the building and / or blocked by a wall or landscaping would cause fire
access issues as well as hinder the ability to provide affordable units to the
project.
Exhibit 7
June 3, 2026 Item #1 316 of 417
Concession / Incentive / Waiver #3
Concession / Incentive Waiver
Concession / Incentive / Waiver #4
Select Type: Concession / Incentive Waiver
Required
Standard
Projects of 20 units or more shall provide on-site common recreational spaces at
100 sf/unit (indoor and outdoor). Since the project proposes 397 total
residential units, the required common recreational space equals 39,700 sf.
Proposed
Deviation
The applicant seeks a deviation from the required common recreational space
and proposes to reduce it from 39,700 sf to approximately ± 26,000 sf.
Reason for
Deviation
Given the site’s relatively tight constraints, it is not feasible to provide the
required amount of common recreation space without increasing the number of
stories and/or adding cost prohibitive roof decks. By reducing the common open
space requirement, the proposed project construction costs would remain
feasible, thus enabling the provision of the proposed number of affordable units
on-site.
Select Type:
Code / Policy
Number
2.D Common Recreation Space
Reason for
Deviation
The units in question are only able to provide a 4' buffer instead of the required
5' due to the need for a loop road around the property and amenity space. It is
not feasible to provide a 5' buffer while maintaining the same unit count & mix,
which allows the applicant to build the proposed number of affordable units.
Code / Policy
Number
2.F Landscaping
Required
Standard
2.F.1 - A landscape buffer of minimum 5 feet shall be located adjacent to all
ground-level residential spaces to provide additional privacy and security for
residents. The buffer shall be planted with shrubs which grow to or are
maintained at a maximum height of 4 feet.
Proposed
Deviation
Applicant has been able to revise the design of the project so all units except for
5 meet this requirement. The units in question are identified on A102 and
provide a 4' buffer instead of 5', and the buffer areas will have the required
planting to achieve the privacy contemplated in this requirement.
June 3, 2026 Item #1 317 of 417
Concession / Incentive / Waiver #5
Select Type: Concession / Incentive Waiver
Concession / Incentive / Waiver #6
Select Type: Concession / Incentive Waiver
Code / Policy
Number
3.A Building Form, Articulation & Massing
Required
Standard
3.A.2 - Building façades visible from the primary street shall not extend
horizontally more than 40 feet in length without a 2-foot variation in depth in
the wall plane .
Required
Standard
3.A.2.a - The floor area for upper floors of project with 5 or more units shall be a
maximum of 90% of the ground floor area. The upper floor area shall not
protrude over the first floor along the street frontage more than 5 feet.
Proposed
Deviation
The applicant seeks to deviate by removing the upper-story setback requirement
in the wall plane variation, otherwise top-floor units would be eliminated.
Reason for
Deviation
As this requirement would cause units to be removed it is not feasible for the
project to comply with and provide the required number of affordable units.
Proposed
Deviation
Building facade breaks are typically every 45’. Because they follow the unit logic,
and the typical 1bed unit is about 22 to 23 feet wide. They facade breaks at the
unit balcony which is recessed 2’ from the facade and extends 4’ beyond for a
total of 6’.
Reason for
Deviation
This requirement would cause they typical units to be too small for the project
to be feasible and comply with required number of affordable units.
Code / Policy
Number
3.A Building Form, Articulation & Massing
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Concession / Incentive / Waiver #7
Select Type: Concession / Incentive Waiver
Reason for
Deviation
As this requirement would cause units to be removed it is not feasible for the
project to comply with and provide the required number of affordable units.
Code / Policy
Number
3.A Building Form, Articulation & Massing
Required
Standard
3.A.4 - Roof lines shall not extend horizontally more than 40 feet in length
without at least one prominent change.
• Provide variation in roof form, such as hipped, gable, shed, flat, and mansard.
• Provide variation in architectural elements, such as parapets, varying cornices,
chimneys, and reveals.
• Provide variation of roof height of at least 18 inches (as measured from the
highest point of each roof line).
Proposed
Deviation
Building facade breaks are typically every 45 feet based on the typical unit
module.
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Concession / Incentive / Waiver #8
Select Type: Concession / Incentive Waiver
Concession / Incentive / Waiver #9
Select Type: Concession / Incentive Waiver
Required
Standard
Building Height is limited to Thirty Five Feet in R-30 Zone
Proposed
Deviation
Proposed building height is 59'.
Reason for
Deviation
The project is proposing a height increase in accordance with SDBL and would
not otherwise be able to provide the affordable units included in the project.
Code / Policy
Number
Building Height (CMC 21.21.030)
Reason for
Deviation
Due to site constraints, it is not feasible to extend the garage footprint and be
able to provide the same number of affordable units in the project.
Code / Policy
Number
CMC Section 21.44.060, table D
Required
Standard
Per CMC Section 21.44.060, table D: Each parking space shall maintain a
standard stall size of 8.5 feet by 20 feet, exclusive of
supporting columns or posts.
Proposed
Deviation
Standard parking size in the garage is 9'X19'. There are aslo 52 compact stalls
provided. Size of each compact stall is 8.5'X16'
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Concession / Incentive / Waiver #10
Select Type: Concession / Incentive Waiver
Concession / Incentive / Waiver #11
Select Type: Concession / Incentive Waiver
Code / Policy
Number
Private Recreational Space (see CODS: 2.E.)
Required
Standard
Section 2, E. Private Recreational Space, private recreational space shall be
required for each residential unit (balcony or patio).
Required
Standard
Per 21.85.030.C., At least ten percent of the lower-income units shall have three or
more bedrooms.
Per 21.85.040. H., bedroom count and unit sizes of affordable units to be
commensurate with market-rate units.
Proposed
Deviation
As we are unable to satisfy both of these requirements at the same time we
have adjusted the proposed BMR unit mix to be commensurate with the overall
unit mix and request a waiver for 21.85.030.C (in order to comply with
21.85.040.H).
Reason for
Deviation
As the current project includes a total of 28 3-bedroom units (7% of the total
units), it is impossible to provide 10% of the total affordable units be 3-bedroom
units and comply with a commensurate % of affordable units on the remaining
unit types.
Proposed
Deviation
The applicant seeks a deviation from 100% of all residential units having private
recreational space and proposes reducing the requirement to 44% of all
residential units.
Reason for
Deviation
If 100% of the units had balconies they would have to be recessed into the
building which would ultimately lower the unit count and not allow the building
to include the affordable housing currently proposed.
Code / Policy
Number
21.85.030.C.
(21.85.040.H. listed for justification of waiver request)
June 3, 2026 Item #1 321 of 417
Concession / Incentive / Waiver #12
Select Type: Concession / Incentive Waiver
Reason for
Deviation
If the project is unable to have this retaining wall with a portion above 6' then
the loop road and associated parking would have to move further into the site
which would encroach on the building footprint which would ultimately lower
the unit count and not allow the building to include the affordable housing
currently proposed.
Code / Policy
Number
CMC 21.46.0130
Required
Standard
Retaining Wall height over 6' must be approved by planning
Proposed
Deviation
The project design includes 1 concrete retaining wall that is higher than 6', and is
located at the NW corner of the project. Per the included retaining wall details
exhibit, this retaining wall will be covered in Fig Ivy (Ficus pumilia) and the
others fronting Salk (6' or less exposed) will also be screened with planting.
June 3, 2026 Item #1 322 of 417
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 8
June 3, 2026 Item #1 323 of 417
has the appropriate permits and approvals and
access to needed public facilities.
•The project is a senior citizen housing
development; in which case, no affordable units
are required.
•The project is a mobile home park that is age-
restricted to senior citizens; in which case, no
affordable units are required.
AFFORDABILITY DURATION
State density bonus law establishes how long an
affordable unit must stay affordable.
•Affordable rental units must be restricted at the
targeted income level group for at least 55 years.
•Affordable for-sale units must be restricted at the
targeted income level group for at least 30 years,
which starts after the initial sale of the affordable
unit. Affordable units may be sold at a market
price to other than targeted households provided
that the sale results in an equity sharing
agreement with the city.
DENSITY BONUS CALCULATIONS
Despite the city’s rounding requirements under CMC
§21.53.230 (Table A), for projects utilizing density
bonus, Government Code §65915(q) requires that
each component of any density calculation resulting in
fractional units shall be separately rounded up to the
next whole number. In other words, all density related
calculations must be rounded up.
Base Density Calculation
Step one in calculating density bonus is to calculate
the project’s base density, which represents the
number of dwelling units allowed under the city’s
General Plan, per acre of property. Calculating base
density under density bonus is no different from how
the city calculates density for standard residential
development projects, with the following exceptions:
•While the city uses developable (or net) acreage
in determining density, density bonus law
requires cities to use gross acreage. This
allowance was clarified in an HCD technical
assistance letter dated July 26, 2023.
•While the city utilizes a “mid-range” density
calculation for determining the allowable number
of units on a property, state law requires that
density bonus be calculated based upon the
maximum density allowed under the city’sGeneral Plan and zoning ordinance for the
subject property.
•Pursuant to SB-330 (Housing Crisis Act of 2019),
the city is prohibited from enforcing housing
caps. As such, the housing caps in the city’s
Growth Management Plan (GMP) cannot be
applied to new housing development projects.
Refer to IB-132 for more information on SB-330
and Reso No. 2021-074 for the city’s suspension
of the GMP cap limits and performance standard
moratorium provisions.
Density Bonus Calculation
Step two in calculating density bonus is to calculate
the project’s density increase, which represents the
number of units allowed in addition to the base
density units. These additional dwelling units are set
per a sliding scale, based upon two primary factors:
•The percentage of units in the project that will be
set aside (reserved) as affordable; and,
•The household income category of those
affordable units (i.e., very low, low, or moderate
income).
For convenience, a Density Bonus Table is included on
page six of the city’s Density Bonus Report (Form
P-1(H)). As you will see from the table, the number of
affordable units (far left column) and the level of
affordability (top row) greatly influence the number of
density bonus units that can be granted.
For example, a project that reserves 10% of its units as affordable for very low-income families is eligible for a
32.5% density bonus, as opposed to a density bonus of
only 20% if those same affordable units were reserved
for low-income families. Refer to info-bulletin IB-137
(Carlsbad’s Housing Plan) for more information on
household income and affordability.
June 3, 2026 Item #1 324 of 417
INCLUSIONARY HOUSING CALCULATIONS
To help provide local affordable housing, the city in
1993 adopted an inclusionary housing ordinance
(§21.85), which established the legal basis for
requiring affordable (inclusionary) housing units in
new residential development in the city.
For more information, refer to info-bulletin IB-157
(Inclusionary Housing Program). While the city’s
inclusionary regulations are separate from density
bonus law, there are a few important provisions in the
city’s inclusionary ordinance that directly affect
density bonus projects, as reflected below.
•The city’s inclusionary requirements apply to all
proposed development projects that include
residential units. This means that projects
subject to the state density bonus law/city’s
density bonus ordinance (§21.86), must also
comply with the city’s inclusionary housingordinance (§21.85).
•Projects proposing seven or more housing units
are required to restrict at least 15% of the total
proposed units for low-income households. The
total proposed units include base density and
density bonus units.
•When calculating inclusionary requirements,
fractional units resulting in less than 0.5 are
rounded down to the next whole number.
•The required affordable inclusionary units satisfy
the required affordable density bonus units.
The city’s application of its inclusionary code is
consistent with AB 2345 and the Department of
Housing & Community Development’s (HCD)
technical assistance letter dated September 2, 2022 to the City of West Hollywood.
THEORETICAL EXAMPLE
Sometimes showing the math helps folks better
understand how density bonus works. The following is
a theoretical example on how these different density
calculations are applied.
SECONDARY DENSITY BONUS
AB 1287 (Alvarez, 2023) amended state density bonus
law by requiring jurisdictions to award an additional
(or second) density bonus for projects that have
allocated a certain amount of affordable housing for
very-low income, low-income, or moderate-income
units, as summarized in the section below.
Minimum Eligibility
The proposed density bonus project must comply with
one of the following affordability requirements to be
eligible for an additional density bonus.
•A minimum of 15% of the base units are reserved
for very low-income households; or
•A minimum of 24% of the base units are reserved
for low-income households; or
•A minimum of 44% of the base units are reserved
for moderate-income households.
A property 1.003 net acres in size has a zoning
designation of R-15 (11.5 to 15 dwelling units per
acre). Under density bonus, this results in a maximum
base density of 15.05 units for this site (1.003 acres
multiplied by 15 units per acre), which rounds up to 16
units.
The applicant proposes that 3 of the 16 units will be
reserved for low-income households. This results in
18.7% of the units that will be reserved as affordable
housing (3 affordable units divided by 16 base density
units), which rounds up to 19%.
Based on the sliding scale found in the Density Bonus
Table in the Density Bonus Report (Form P-1(H)), with
19% of the affordable units reserved for low-income
families, the project’s base density can increase by
33.5% or 5.36 units (16 base density units multiplied by
33.5%), which rounds up to 6 density bonus units for a
total of 22 units for this project.
To satisfy the city’s inclusionary ordinance, a total of
3.3 affordable low-income units are required for this
project (15% inclusionary requirement multiplied by 22
total units), which rounds down to 3 units.
In this example, the 3 affordable low-income units
satisfy the requirements under state density bonus law
as well as the city’s inclusionary housing ordinance.
June 3, 2026 Item #1 325 of 417
Density Increase
Under state law, the city must grant the developer an
additional density bonus if additional units are set
aside for either very low or moderate-income
households. Like traditional density bonus calculations,
the secondary density bonus is also on a sliding scale,
based on the project’s base density.
For reference, the secondary density bonus allowances
have been included in the Density Bonus Table found
on page six of the city’s Density Bonus Report (Form P-
1(H)). To help illustrate how this secondary density
bonus is applied, let us relook at the previous
theoretical example.
It is important to highlight that AB 1287 caps the
affordable set aside at 50%. For projects that allocate
the maximum of moderate-income units (44%), they
would only be eligible to set aside another 6% of very-
low income or moderate-income units to receive an
additional bonus of 23.75% or 22.5%, respectively.
REMOVAL OF EXISTING RENTAL UNITS
Under density bonus law, projects that include the
demolition or removal of affordable rental units are
ineligible for density bonus unless the units are
replaced concurrent with the development of the
project. This provision applies to the following types of
rental units:
• Units subject to recorded restrictions
• Units subject to rent control
• Units occupied by very low- or low-income
households
If household rental income cannot be determined, the
city may assume households are occupied by low-
income households in the same proportion as low-
income renters in the city, consistent with AB 2556.
Additionally, under state law the affordable units
required under density bonus may also be used to
satisfy any replacement unit requirements. This
allowance was clarified in an HCD technical assistance
letter dated December 14, 2023.
DEVELOPMENT STANDARD DEVIATIONS
Traditional development projects must be designed to
comply with city established development standards
and design regulations such as building height
limitations, setback requirements, minimum parking
ratios, and on-site open space directives.
However, under state density bonus law, applicants
can deviate from these development standards when
found that the standards prevent the applicant from
achieving the density allowed under the state law.
There are two types of tools available to applicants:
• Incentives & Concessions
• Waivers
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.
June 3, 2026 Item #1 326 of 417
Incentives & Concessions
Incentives and concessions, as defined under state
density bonus law, allow a developer to deviate from
those requirements when modifying such regulations
would provide “identifiable and actual cost
reductions” to provide for affordable housing costs
and rents. This requirement was clarified in the court
decision of Schreiber v. City of Los Angeles (later
codified as part of the passage of AB 1287) and the
sections below reflect the holdings in that case.
Application
A few key considerations regarding the application of
incentives or concessions:
• Under the government code, the terms
“incentives” and “concessions” are used
interchangeably. As such, the city considers them
one in the same (“incentives/concessions”).
• A density bonus project is entitled to
incentives/concessions even without a request
for a density bonus --- if a developer provides the
affordable housing specified under density bonus
law, they are eligible for incentives/concessions.
• The city applies incentives/concessions to the
development standards or design regulations
requiring deviation, not to the individual
situation.
For example, say a project proposes three
separate buildings with each building requiring
an increase in the city’s maximum building
height standard. In this example, the city would
require one incentive/concession for this
deviation, even though the deviation applies to
three separate buildings.
If that same project requires a deviation from
the building height and rear yard setback
standards, the city will require two
incentives/concessions since these are
considered two different development
standards.
• Pursuant to the Schreiber case, which was later
codified as part of the passage of AB 1287, a
developer is not required to provide financial
evidence (i.e., pro forma) documenting that a
requested incentive/concession will result in
actual cost reductions. However, applicants need
to reasonably document “why” the requested
incentive/concession will reduce affordable
housing development costs. As such, the city
requires applicants to provide reasonable
documentation to show that a requested
incentive/concession will result in identifiable
cost reductions to provide for affordable housing
costs or rents.
Number Authorized
The number of incentives/concessions that can be
requested by a developer varies by the amount and
type of affordable units being proposed, as reflected
below.
INCOME % OF AFFORDABLE UNITS1
Very Low 5% 10% 15% 16% ≥80%
Low 10% 17% 24% --- ≥80%
Moderate 10% 20% 30% 45% 20%
Student2 20% --- --- --- ---
Incentives 1 2 3 4 53
1 The % of a project’s affordable units must be at least equal to the listed %.
2 Lower-income student in a dedicated student housing development.
3 To qualify for 5 incentives, a project must reserve at least 80% of the units for lower income households (very low, low, or combination thereof). The
remaining 20% may be reserved for moderate income households. The
applicant shall also receive a height increase of up to three additional stories, or 33 feet.
As noted in footnote #1, when determining the
appropriate number of incentives/concessions, a
project’s percentage of affordable units must be “at
least” equal to the percentages shown in the table
above (§65915(d)(2)). In other words, the percentages
in the table are minimums.
So, in the case of the theoretical example project that
reserved 19% of the units for low-income, the
applicant is eligible to receive two
incentives/concessions. If affordable units are
provided to satisfy the city’s inclusionary housing
obligation above required density bonus affordable
units, the total number of affordable units count
June 3, 2026 Item #1 327 of 417
when determining the number of
incentives/concessions allowed.
Grounds for Denial
Under the Schreiber case, the city must grant a
requested incentive/concession unless it finds, under
a preponderance of evidence, the following:
• The incentive/concession does not result in
identifiable and actual cost reductions to provide
for affordable housing costs or rents.
• Granting the incentive/concession would have a
specific adverse impact on public health or safety
or on property listed on the California historical
register, which cannot be mitigated, or would be
contrary to state or federal law.
Waivers
Density bonus law offers another form of assistance to
developers, separate from concessions/waivers, in the
form of “waivers.” A waiver is a modification or
reduction to established development standards or
design regulations when those requirements
potentially cause the construction of the development
project physically infeasible, if not approved.
Application
A few key considerations regarding waivers.
• Waivers do not count as an incentive/concession
and can be used in concert (combined) with
incentives/concessions.
• The developer must provide sufficient
documentation justifying why the city’s
established development standard(s) or design
regulation(s) physically preclude construction of
the project and why the waiver(s) is necessary.
Sufficient documentation may include a written
explanation of the physical constraints
accompanied with an exhibit showing the site
and developable envelope.
Number Authorized
Unlike concessions/incentives, applicants are
entitled to waive any established development
standards or design regulations that would physically
preclude the development from achieving the
allowances authorized under density bonus law. In
other words, there is no limit in the number of
waivers an applicant can request.
Grounds for Denial
The city is not required to grant or otherwise
authorize a waiver if it finds that the requested
deviation or modification causes a specific adverse
impact on public health or safety and cannot be
mitigated, would have an adverse impact on property
listed on the California historical register, or would
otherwise violate state or federal law.
Like incentives/concessions, the city must include a
showing of substantial evidence when making a
finding of denial on a waiver request.
PARKING ALLOWANCES
Despite the city’s parking requirements under CMC
§21.44, the city may not require more than the
following parking ratios for a density bonus project
(including parking for persons with disabilities):
Unit Type Required Parking
June 3, 2026 Item #1 328 of 417
State law further limits parking requirements for
specified projects as reflected below.
• 0.5 spaces per unit for projects with at least 11%
very low income, 20% lower income, or 40%
moderate income, when located within ½ mile of
accessible major transit stop, which in the city is
the Carlsbad Village Coaster Station or Poinsettia
Coaster Station.
• No parking spaces are required for projects
meeting the following:
o 100% affordable to lower income residents,
within ½ mile of a major transit stop, which
in the city is the Carlsbad Village Coaster
Station or Poinsettia Coaster Station.
o 100% senior or special needs rental project
affordable to lower income, either with
paratransit service or within ½ mile of an
accessible bus route that operates at least
eight times per day.
o Rental supportive housing development
that is 100% affordable to lower income households.
Parking requirements may be satisfied by providing
individual parking stalls or in tandem, so long as the
stalls are provided onsite.
Requesting these parking standards does not count as
an incentive/concession or waiver; however, an
applicant may request further parking standard
reductions using the incentive/concession or waiver
allowances.
DENSITY BONUS APPLICATIONS
The city’s Density Bonus Ordinance can be found in
CMC §21.86 and applicants should follow the permit
submittal requirements and processes set forth in the
Land Use Review Application (Form P-1).
Pursuant to changes in state density bonus law that
went into effective in 2019, the city developed a
supplemental form outlining the information that
must be submitted for a complete density bonus
application; referred to as the Density Bonus Report
Form P-1(H). This includes project location, property
description, project description, density calculations,
and information on any requested
incentives/concessions or waivers.
Once a development application is determined to be
complete, the city, under state law, will notify the
applicant of the level of density bonus and parking
ratio the development is eligible to receive.
PROJECTS IN THE COASTAL ZONE
When a density bonus project is proposed in the
coastal zone, legislation that went into effect in 2019
attempted to strike a balance between the state goals
of promoting housing and protecting the coast.
Density bonuses, incentives/concessions, waivers, and
parking reductions are to be permitted so that they
are consistent with both density bonus law and the
California Coastal Act. Granting of a density bonus or
an incentive does not require a general plan, zoning, or
local coastal plan amendment.
YOUR OPTIONS FOR SERVICE
To schedule an appointment to submit an application
or to learn more about density bonus, please contact
the Planning Division at 442-339-2600 or via email at
Planning@carlsbadca.gov.
NOTE
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
June 3, 2026 Item #1 329 of 417
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.
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.
Exhibit 9
June 3, 2026 Item #1 330 of 417
Income Category % of AMI Household Income1,2
Extremely Low <30% <$28,500
Very Low 30 - 50% $28,500 - $47,600
Low 51 - 80% $47,600 - $76,000
Moderate 81 - 120% $77,000 - $114,100
Above Moderate >120%>114,100
1 AMI as of April 2021 was $95,100 for family of four; 2 Figures rounded.
For housing costs to be considered affordable, a family’s
monthly rent/mortgage payment should not exceed 30%
of the gross annual household income of any given
income category. So, a low-income family of four with a
gross annual income of $55,000 should pay no more
than $1,375 per month for housing.
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
•All residential development projects proposing seven
or more housing units are required to provide at
least 15% of the total units (including density bonus
units) to be restricted 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.
•To the extent possible, projects using for-sale units to
satisfy inclusionary requirements shall be designed to
be compatible with conventional mortgage financing
programs.
June 3, 2026 Item #1 331 of 417
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 are
restricted for low-income households; or,
•A least 15% of the total residential 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 are
restricted for very low-income households.
June 3, 2026 Item #1 332 of 417
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.
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.
June 3, 2026 Item #1 333 of 417
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).
June 3, 2026 Item #1 334 of 417
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
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.
June 3, 2026 Item #1 335 of 417
•THE HANOVER COMPANY
November 24, 2025
Kyle Van Leeuwen City of Carlsbad Planning Division 1635 Faraday Avenue Carlsbad, CA 92008
SUBJECT: Project Outreach Report for the Hanover Company Salk Ave Apartments proposed development (SDP 2025-0041 DEV 2025-0001) (Parcel adjacent to 2177 Salk Ave with APN# 212-021-04-00)
Dear Kyle,
Hanover Company and it's consulting team Intesa Communications Group conducted Stakeholder Outreach for the Salk Ave Apartments project in conformance with Carlsbad Council Policy No. 84. This project was initially submitted as a ministerial project as part of the City's Housing Element (Site #7) in December of 2024. We subsequently resubmitted the project as a discretionary project in October of 2025 which triggered conformance with the City's Policy 84.A detailed explanation of what is included in the report is outlined below.
We'd like to note that prior to moving to the discretionary process, we did meet multiple times with the board members of the Salk Owners Association HOA. Those owners are Scripps Health and Brookwood Financial Partners. Both entities are aware of the details of our proposal and supportive of the project.
Lastly, no one from the public attended our outreach meeting. We remain open to any feedback or questions from the public going forward.
•Project's Public Notice (Attachment A):
o Mailing radius information showing that we have met the City's requirements.o Letter informing neighbors of the proposed project.o Flyer inviting neighbors to public meeting
•Project Sign image (Attachment B)
•Enhanced Public Engagement Affidavit (Attachment C)
•Early Public Notification Affidavit (Attachment D)
•Community Outreach meeting information, including (Attachment E):o Sign In SheetsoComment CardsoImages from meeting
•Project website address and images of site including contact form for stakeholders to providefeedback and ask questions (Attachment F)o Questions and answers from website
11611 San Vicente Blvd, Suite 740 I Brentwood -Los Angeles, CA 90049 I Tel: (310) 200-7351 www.hanoverco.com
Exhibit 10
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LIST OF ACRONYMS AND ABBREVIATIONS Exhibit 11
This is a list of acronyms and abbreviations (in alphabetical order) that are commonly used in staff
reports.
Acronym Description Acronym Description
APA American Planning Association LCPA Local Coastal Program Amendment
APN Assessor Parcel Number LOS Level of Service
AQMD Air Quality Management District MND Mitigated Negative Declaration
BMP Best Management Practice NCTD North County Transit District
CALTRANS California Department of Transportation ND Negative Declaration cc City Council PC Planning Commission
CCR Conditions, Covenants and Restrictions PDP Planned Development Permit
CEQA California Environmental Quality Act PEIR Program Environmental Impact Report
CFD Community Facilities District PUD Planned Unit Development
CIP Capital Improvement Program ROW Right of Way
COA Conditions of Approval RWQCB Regional Water Quality Control Board
CofO Certificate of Occupancy SANDAG San Diego Association of Governments
CT Tentative Parcel Map SDP Site Development Permit
CUP Conditional Use Permit SP Specific Plan
DIF Development Impact Fee SWPPP Storm Water Pollution Prevention Program
DISTRICT City Council Member District Number TM Tentative Map
EIR Environmental Impact Report zc Zone Change
EIS Environmental Impact Statement (federal)
EPA Environmental Protection Agency
FEMA Federal Emergency Management Agency
GP General Plan
GPA General Plan Amendment
GIS Geographic Information Systems
HCA Housing Crisis Act 2019
IS Initial Study
June 3, 2026 Item #1 373 of 417
Reduced Exhibits found on Meeting Webpage &
(On file in the Planning Division.)
363 to 438 Item #1June 3, 2026June 3, 2026 Item #1 374 of 417
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June 3, 2026 Item #1 375 of 417
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June 3, 2026 Item #1 416 of 417
AC1
June 3, 2026 Item #1 417 of 417
Shannon Harker, Senior Planner
Community Development
Department
March 1, 2023
Salk Avenue Apartments Project
Kyle Van Leeuwen, Senior Planner
Community Development
June 3, 2026
SDP 2025-0004
1
9.78 acres
Vacant Site
Access from Salk Ave
Housing Site 7 (2024)
R-30 Gen. Plan Land Use
RD-M Zoning
Fenton Carlsbad Center SP
LOCATION MAP
2
PROJECT DESCRIPTION
397 Units (Density Bonus)
5 Stories
59’ Building Height
- Projections 74.5’
542 Parking Spaces
5-Story Parking Structure
3
Density Bonus Calculation
PROJECT DESCRIPTION
44
•Base Density:
30 DU/AC X 9.78 AC = 294 units (293.4)
•59 Units Low-Income Dedication (20% Base)
= 35% Bonus Density
•294 Units X 35% = 103 Units (102.9)
•294 units + 103 units = 397 units (40.5 DU/AC)
(Project is required to include 20% base units low-income)
STATE DENSITY
BONUS LAW
Density Bonus Waivers
PROJECT DESCRIPTION
55
•Height Limit (35”)
- 59’ feet proposed
•Parking space dimensions (8.5’ x 20’)
- Dimensions consistent with building code
•10% of affordable units as 3-bedroom units
- Less than 10% but consistent with proportionality
•Fencing/wall height limits (6’)
-One retaining wall location taller than 6’.
•8 Objective Design Standards
STATE DENSITY
BONUS LAW
PROJECT SPECIFICS
Studio, 1-BR, 2-BR, & 3-BR Units
3 Central Courtyards (Pool, BBQs, Fire Pits)
Amenity Rooms (Club, Media, Co-Work, Fitness,
Etc.)
Defined Ground Floor (15’ plate height)
Tower Elements on Main Façade
Stucco, Stone Tile Base, Metal Guardrails, Concrete
Roof Tiles, Dark Bronze Storefronts
6
PROJECT DESCRIPTION
7
AB 130 – Infill Housing Statutory Exemption
- Compliant Except for Single Area (Bio)
SB 131 – “Near Miss”
- Initiate CEQA Initial Study for Just the
disqualifying condition.
Potential Impacts found to be less than
significant w/ mitigation measures.
CEQA PROCESSING
8
Biological Resources
Patch of Coastal Sage Scrub (NW corner)
Habitat for special status species
-Thread-Leaved Brodiaea, California Gnat Catcher,
Crotch’s Bumble Bee
Sage Scrub Patch buffered from
development footprint
Mitigation Measures for Bird & Bumble
Bee survey and avoidance
CEQA PROCESSING
9
Potential Impact Bio. Resources
10
City received 2 comment letters (Jim Miller, SAFER)
Applicability of AB130/SB131
HMP designation
Scope of species surveys
Buffer distances
Impact to habitat and connectivity
IS/MND Public Review
11
Response to Comments
Clarified applicability of AB130/SB131
Letters did not represent significant new information,
rely on speculative analysis
Staff evaluated the record and determined that no
evidence supporting a fair argument of unmitigated
significant impacts
IS/MND Public Review
12
Received Correspondence Prior to Hearing
(SAFER)
Supplemental comments do not raise any new
potentially significant impacts, do not identify an
increase to the severity of any impacts disclosed in the
IS/MND.
EIR is not required - All potentially significant
environmental impacts have been mitigated to less
than significant levels
CEQA PROCESSING
13
•Project is consistent with Gen. Plan, Specific Plan,
Municipal Code, ALUCP, Local Facilities MGMT
•Density Bonus per State Law/Fulfills City Inclusionary
Requirements
•Project Design complies with Objective Design Standards (with waivers)
•Potential environmental impacts mitigated to less than significant
CONCULSIONS
14
RECOMMENDED ACTION
1)ADOPT the Resolution ADOPTING an SB 131 Focused Initial
Study and Mitigated Negative Declaration and Mitigation
Monitoring and Reporting Program, and;
2)ADOPT the Resolution APPROVING a Site Development Plan
based upon the findings and subject to the conditions
contained therein.
Salk Avenue Apartment Project
15
6/3/2026
Salk Avenue Apartments
Planning Commission Presentation
1Salk Avenue Apartments
Site Location
2Salk Avenue Apartments
Site Plan
3Salk Avenue Apartments
Rendering – Main Entrance
4Salk Avenue Apartments
Rendering – Pool Courtyard
5Salk Avenue Apartments
Rendering – Courtyard Entrance
6Salk Avenue Apartments
Indoor Amenities
Lounge #1 Focus Rooms Mail Room Leasing Lobby Golf Simulator
Club Room Package Room Lounge #2 Co-Working Restrooms Fitness
7Salk Avenue Apartments
Outdoor Amenities
Resort Style Pool | Water Feature | Fire Pits | BBQ-Grills | Dining Tables | Outdoor Living Spaces
Outdoor Televisions, Gaming and Co-Working | Three Courtyards | Two Activity Lawns | Dog Run
8Salk Avenue Apartments
Thank You