HomeMy WebLinkAboutPRE 2018-0034; BEACH TERRACE INN; Admin Decision LetterFebruary 5, 2019
Renier Milan
2775 Ocean Street
Carlsbad, CA 92008
FILE
M. (A\ lq\ ~1 'B( I"\
SUBJECT: PRE 2018-0034 (DEV2018-0212)-BEACH TERRACE INN
APN: 203-235--02--00, 203-235-03-00, and 203-144--03--00
-___ ('cityof
Carlsbad
Thank you for submitting a preliminary review application for development of the Beach Terrace Inn hotel
properties, which consist of assessor's parcel numbers (APN) 203-235-02-00, 203-235-03-00, and 203-
144-03-00. The project site, approximately 1.26-acres, currently is developed with the Beach Terrace Inn
hotel on the west side of Ocean Street and associated parking on the east side of Ocean Street. Three
development scenarios are contemplated: 1) Scenario X: maintain R-3 Residential zoning, renovate
existing hotel buildings, and construct a new hotel-building with 45 hotel units on APN 203-144-03-00; 2)
Scenario Y: maintain R-3 Residential zoning, convert existing hotel units to residential units, and construct
residential units in two new buildings on APN 203-235-03-00 and APN 203-144-03-00; and 3) Scenario Z:
change zoning and land use from residential to commercial, renovate existing hotel buildings, and
construct additional hotel units in two new buildings on APN 203-235-03-00 and APN 203-144-03-00.
In response to your application, the Planning Division has prepared this comment letter. Please note that
the purpose of a preliminary review is to provide you with direction and comments on the overall concept
of your project. This preliminary review does not represent an in-depth analysis of your project. It is
intended to give you feedback on critical issues based upon the information provided in your submittal.
This review is based upon the plans. policies. and standards in effect as of the date of this review. Please
be aware that at the time of a formal application submittal. new plans, policies. and standards may be
in effect and additional issues of concern may be raised through a more specific and detailed review.
Planning:
General
1. General Plan and zoning designations for the property are as follows:
a. General Plan:
i. APN's 203-235-02-00 and 203-235-03-00: · R-23 Residential, 15-23 dwelling units per
acre (du/ac). Growth Management Control Point (GMCP) of 19 du/ac.
ii. APN 203-144-03-00: R-15 Residential, 8-15 du/ac. GMCP of 11.5 du/ac.
b. Zoning: R-3 Residential.
Community & Economic Development
Planning Division I 1635 Faraday Avenue Carlsbad, CA 92008-7314 I 760-602-4600 I 760-602-8560 f I www.carlsbadca.gov
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2. Local Coastal Program designations for the propl!lt? are ·as folfows:
a. The Coastal Land Use designation and Zone are the same as the General Plan and Zoning
above.
b. The site is located within the Beach Area Overlay Zone (BAOZ).
c, The site is located within the Coastal Shoreline Development Overlay Zone (CSDOZ).
d. The site is located within the Mello II Segment of the Local Coastal Program (LCP) within the
appealable jurisdiction of the California Coastal Commission (CCC). Early discussions with CCC
staff regarding the development scenarios is highly recommended.
3. The project may require the following permits depending on which development scenario is
pursued:
a. General Plan Amendment (GPA). Zone Change (ZCl. and Local Coastal Program Amendment
(LCPAl: The above permits are required to change the land use to V-C Visitor Commercial and
zoning to C-T Commercial Tourist.
b. Tentative Tract Map (CT}: A CT is required if development of residential condominiums is
proposed per Section 20.12.010 of the Carlsbad Municipal Code (CMC).
c. Major Planned Development Permit (PUDl: A PUD is required if development of residential ·
condominiums is proposed per the Planned Development ordinance (CMC Chapter 21.45).
d. Site Development Plan (SDPl: A SDP is required per CMC Section 21.06.015.
e. Coastal Development Permit (CDP): A CDP is required for development within the coastal
zone (appealable to the CCC).
f. Special Use Permit (SUP): Due to the recommendation of the City of Carlsbad Sea Level Rise
Vulnerability Assessment (SLRVA). APN's 203-235-02-00 and 203-235-03-00 will likely be
subject to the Floodplain Management Ordinance, CMC Chapter 21.110, which requires the
processing of a SUP.
g. Hillside Development Permit {HDPl: Pursuant to CMC Section 21.95.140, a HDP will be
required if any existing criteria slopes would be affected (projects that grade, erect, or
construct on top of, a slope which has a gradient of fifteen percent or more and an elevation
differential greater than fifteen feet).
4. The plans are very conceptual and need to be fully detailed prior to formal submittal. Please
review the Development Permits P-2 checklist. and ensure all items are included on the plans with
the formal application submittal. The Development Permits P-2 checklist is available for review
on the City of Carlsbad website at:
http://www.carlsbadca.gov/civicax/filebank/b1obdload.aspx?Blob1D=241l6
5. Nonconforming Nonresidential Use and Nonconforming Nonresidential Structure: The existing
hotel use does not conform to the R-3 zoning allowed land uses and is considered a
nonconforming nonresidential use per the nonconforming ordinance, CMC Section 21.48.070.
Additionally, the hotel structures do not conform to the R-3 zone development standards and the
structures are considered nonconforming nonresidential structures per CMC Section 21.48.060.
According to the nonconforming ordinance, CMC Chapter 21.48, nonconforming nonresidential
uses and structures may be repaired or altered if the project does not increase the degree of the
existing nonconformity. Adding hotel units to the existing hotel under the R-3 zoning is
considered an increase in the degree of existing nonconformity of the structure(s) and use and is
not permissible per CMC Sections 21.48.060.A.l.b and 21.48.070.A.l.a.
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6. Building Setbacks. Provided below are general comments regarding building setbacks.
a. Rear Setback {Seaward) APN's 203-235-02-00 and 203-235-03-00
i. City of Carlsbad Sea Level Rise Vulnerability Assessment {SLRVA). The rear (seaward)
building setback recommended in the SLRVA is anticipated to be adopted by
ordinance and applicable to the property in 2020. A draft ordinance reflecting the
building setback recommended in the SLRVA is anticipated for public review in Fall
2019. Eventually when adopted, the requirements will replace/revise existing CMC
sections referenced elsewhere in this letter. Early consultation with CCC staff is highly
recommended to evaluate whether the recommended SLRVA building setback
requirement will be applicable to development applications that are submitted to the
CCC prior to the city's adoption of the .SLRVA recommendations. The SLRVA
recommends existing building setback requirements be revised to account for
accelerated erosion caused by increasing sea levels and hours of wave attack, as well
as a factor of safety distance that is related to the erosion mechanism (e.g., dune
erosion versus cliff erosion). The SLRVA specifies that the setback should factor in the
life expectancy of the proposed development or redevelopment. The CCC
recommends a life expectancy of 75 to 100 years for a project in their Sea Level Rise
Policy Guidance documents. Therefore, a minimum rear building setback equivalent
to the anticipated sea level rise in 75 years (from construction) should be considered.
For reference, attached to this letter is an exhibit that depicts the Flood Hazard Area
forecast for year 2100 that was prepared with the SLRVA. With any formal submittal
of this proposal, a more detailed plotting of the sea level rise in 75 years from
construction will be necessary for determining the required rear setback for the
project.
The SLRVA is available for review on the City of Carlsbad Planning Division website at:
http://www.carlsbadca.gov/civicax/fi1ebank/blobdload.aspx?Blob1D=33958
The California Coastal Commission Sea Level Rise Policy Guidance documents are
available on the Coastal Commission website. The adopted 2015 Seal Level Rise Policy
Guidance is available at:
https://documents.coastal.ca.gov/assets/slr/guidance/2018/0 Full 2018AdoptedSL
RGuidanceUpdate.pdf
The draft 2018 Seal Level Rise Residential Adaptation Policy Guidance is available at:
https://www.coastal.ca.gov/climate/slr/vulnerability-adaptation/residential/
ii. Coastal Shoreline Development Overlay Zone {CSDOZ) Coastal Stringline. The
recommended rear setback of the SLRVA is more restrictive than the coastal stringline
detailed in the CSDOZ, CMC Chapter 21.204. The CSDOZ specifies that no enclosed
portions of a structure shall be permitted further seaward than those allowed by a
line drawn between the adjacent structures to the north and south; and no decks or
other appurtenances shall be permitted further seaward than those allowed by a line
drawn between the adjacent structures to the north and south. A greater ocean
setback may be required for geologic reasons as specified in the Local Coastal
Program, Policy 4-1, which addresses development along the shoreline. With any
formal submittal of this proposal, a more detailed plotting of the applicable structures
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and appurtenances on the adjacent properties to the north and south will be
necessary for determining accurate stringline measurements for the project.
b. C-T Zone Setbacks. A zone change to the C-T zone will subject the project to C-T zone
development standards, CMC Chapter 21.29. Please be advised that the C-T zone
development standards may change as part of the citywide zoning ordinance update. A draft
ordinance is anticipated for public review in Fall 2019. Once the changes to the zoning
ordinance are adopted by the City Council and the CCC, the project would be subject to the
. development standards of the revised C-T zone, which may differ from the current standards
of the C-T zone. The setbacks of the current C-T zone are outlined below.
i. .Front -None. Determined through the site development plan review.
ii. Side -10 feet abutting any residential zone.
iii. Rear -None. Determined through the site development plan review. However,
APN's 203-235-02-00 and 203-235-03-00 are subject to the rear yard setbacks as
outlined in comment 6.a. above.
c. R-3 Zone Setbacks. The setbacks of the R-3 zone are provided in CMC Chapter 21.16 and are
outlined below:
i. Front -20 feet.
ii. Side -10 feet interior side (10 percent of lot width) and 10 feet street side.
iii. Rear -10 feet. However, APN's 203-235-02-00 and 203-235-03-00 are subject to the
rear yard setbacks as outlined in comment 6.a. above.
7. Building Height. Provided below are general height comments for consideration in the
contemplated development scenarios.
a. Residential Land Use Development Scenarios X and Y. Per CMC Section 21.82.050, the
maximum building height in the BAOZ is 30 feet (minimum 3:12 roof pitch) and 24 feet (less
than 3:12 roof pitch) measured in accordance with CMC Section 21.04.065.
b. Commercial Land Use Development Scenario Z. Per CMC Section 21.29.040, building height
in the C-T zone shall not exceed a height of 35 feet or three levels, except for height
protrusions as allowed in CMC Section 21.46.020. A building height up to a maximum of 45
feet may be permitted through approval of a SDP permit approved by the City Council
provided that:
i. The building does not ~ontain more than three levels;
ii. All required setbacks shall be increased at a ratio of one horizontal foot for every one
foot of vertical construction beyond thirty-five feet. The additional setback area will
be maintained as landscaped open space;
iii. The building conforms to the requirements of the California Building Code; and
iv. The allowed height protrusions as described in Section 21.46.020 do not exceed
forty-five feet.
8. Parking. Provided below are general parking comments for consideration in the contemplated
development scenarios.
a. The parking standards in CMC Chapter 21.44 apply to a hotel project. Hotel projects require
1.2 parking spaces per hotel unit.
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b. The parking standards in CMC Chapter 21.45 shall apply to planned developments (i.e.
condominium projects) within the BAOZ. If apartments are proposed, the parking standards
of CMC Chapter 21.44 and visitor parking requirements of CMC Section 21.82.060 apply.
c. The minimum parking space width is 8.5 feet with a minimum area of 170 square feet. Parking
stalls which are located adjacent to a solid wall associated. with the parking structure should
be increased in width by two (2) feet to allow adequate space for car doors to open.
d. A minimum 20-foot drive aisle and 24-foot back-up radius is required for parking areas.
9. Floodplain Management. Due to the recommendation of the SLRVA, APN's 203-235-02-00 and
203-235-03-00 will likely be subject to a future floodplain management ordinance anticipated to
be adopted in 2020. A draft ordinance is anticipated for public review in Fall 2019. It is anticipated
that the future floodplain management ordinance will allow "non-substantial improvements"
without the need for projects to comply with the SLRVA setback as outlined above. A substantial
improvement is defined in CMC Section 21.110.050(35) and means " ... any reconstruction,
rehabilitation, addition, or other proposed new development of a structure, the cost of which
equals or exceeds fifty percent of the market value of the structure before the start of
construction of the improvement."
10. Residential Density. Please be advised that the maximum allowable density is based on the net
lot size, which excludes beaches, floodways, certain steep slope areas, significant environmental
features, etc. Based upon the results of the SLRVA and the anticipated amendments to the
floodplain management ordinance, the net developable area (and corresponding allowable
residential density) of APN's 203-235-02-00 and 203-235-03-00 will likely be reduced in the future.
Please see CMC Section 21.53.230 for additional details regarding how to calculate residential
density.
a. APN's 203-235-02-00and 203-235-03-00 have a General Plan Land Use designation of R-23
Residential (15-23 du/ac with a GMCP of 19 du/ac). To determine the potential unit yield for
the property at the GMCP, the net developable lot area (in acres) is to be multiplied by the
GMCP of 19.
b. APN 203-144-03-00 has a General Plan Land Use designation of R-15 Residential (8-15 du/ac
with a GMCP of 11.5 units/ac). At the GMCP, seven dwelling units may be allowed (7 .1
dwelling units rounded down to 7 dwelling units).
11. lnclusionary Housing. A residential project is subject to the City's lnclusionary Housing Ordinance,
CMC Chapter 21.85. Per City Ordinance, 15 percent of the total housing units constructed must
be affordable to low income households.
12. California Coastal Commission Lower Cost Visitor-Serving Recreational Uses. The City of
Carlsbad Local Coastal Program Mello II segment contains Policy 6-10, which addresses Lower
Cost Visitor-Serving Recreational Uses. The intent of the policy is to encourage a range of
affordability for overnight visitor-serving accommodations. The project should provide Lower
Cost Visitor-Serving accommodations accordingly. Early consultation with CCC staff is highly
recommended to ensure that the proposed project addresses this policy. The City of Carlsbad
Local Coastal Program is available for review on the City of Carlsbad Planning Division website at:
http://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BloblD=24088
13. Hillside Development. Unless exempt pursuant to CMC Section 21.95.040, no person shall grade,
erect, or construct into or on top of a slope which has a gradient of fifteen percent or more and
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an elevation differential greater than fifteen feet without first obtaining a hillside development
permit (HDP) pursuant to CMC Chapter 21.95. The project site includes a change in grade
elevation greater than 15 feet, slopes greater than 15 percent, and is not exempted under CMC
Section 21.95.040; therefore, a HDP is required. The project will need to demonstrate
conformance with the Hillside Development Regulations and Hillside Development & Design
Guidelines. As part of a formal submittal, please be sure that project exhibits address all
requirements listed under CMC Section 21.95.130-Hillside Mapping Procedures and CMC Section
21.95.140-Hillside Development and Design Standards.
14. Architecture. A residential condominium project must comply with the requirements listed in
CMC Chapter 21.45 (Tables "C" and "E") and City Council Policy #44 and City Council Policy #66.
Said City Council polices are available for review on the City of Carlsbad Planning Division website
at:
http://www.carlsbadca.gov/services/building/codes/planning.asp
15. Trash. Please contact Waste Management for approval of the trash location(s) and operations.
16. Landscape Plans. Conceptual landscape and water conservation plans shall be prepared in
accordance with the General Requirements listed in Section 3 of the City of Carlsbad Landscape
Manual (February 2016). Construction landscape and irrigation plans will also be required prior
to issuance of a building permit. The City of Carlsbad Landscape Manual is available on line at:
http:ljwww.carlsbadca.gov/civicax/fi1ebank/blobdload.aspx?Blob1D=24086.
17. Technical Studies/Exhibits. The following technical studies/exhibits would be needed with a
formal submittal:
a. Biological Study. A formal submittal of this project will need to include a biological study of
the site in compliance with the City of Carlsbad's Habitat Management Plan and Guidelines
for Biological Studies.
The City of Carlsbad Habitat Management Plan is available on the City website at:
http:ljwww.carlsbadca.gov/civicax/filebank/b1obdload.aspx?Blob1D-27193
The City of Carlsbad Guidelines for Biological Studies is available on the City website at:
http://www.carlsbadca.gov/civicax/filebank/b1obdload.aspx?Blob1D-24331
b. Geotechnical/Soils Report. In addition to the typical submittal requirements of a preliminary
geotechnical/soils report, please be sure to also address specific requirements listed under
the Coastal Resources Protection Overlay Zone (CMC Chapter 21.203). More specifically,
pursuant to CMC Section 21.203.040.C-Landslide and Slope Instability, developments within
five hundred feet of areas identified generally in the PRC Toups report, Figure 8, as containing
soils of the La Jolla group (susceptible to accelerated erosion) or landslide prone areas shall
be required to submit additional geologic reports containing the additional information
required in the Coastal Shoreline Development Overlay Zone. Additionally, pursuant to CMC
Section 21.203.040.D -Seismic Hazards, development in liquefaction-prone areas shall
include site-specific investigations addressing the liquefaction problem and suggesting
mitigation measures. New residential development in excess of four units, commercial,
industrial, and public facilities shall have site-specific geologic investigations completed in
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known potential liquefaction areas.
c. Cultural Resources/Paleontological Studies. The development of the proposed project will
require excavation in an area of the city known to have a high sensitivity as it relates to
architectural history and both archeological and paleontological resources. Please direct your
consultant to the city's Tribal, Cultural and Paleontological Resources Guidelines. Please note
that any archeological pedestrian survey of the site for the cultural resources study shall
include a Native American monitor during the survey. Review of the Guidelines may be
obtained at the Planning Division front counter or found online at:
http://www.carlsbadca.gov/services/depts/planning/codes.asp
18. Early Public Notification: Per City Council Policy #84, Development Project Public Involvement
Policy, all development applications that require approval by the Planning Commission or City
Council, shall provide early public notification and enhanced stakeholder outreach for this type of
project. The purpose of Policy #84 is to help ensure applicants proposing development projects
are aware of and have considered input from interested and affected stakeholders prior to project
consideration by city decision makers. The policy is intended to supplement and not replace or
conflict with legal noticing requirements or any other required public involvement for
development applications. Please see the policy for more information regarding the applicants'
early public notification responsibilities. Legal noticing requirements, which are in addition to the
applicants' early public notification requirements, can be found online by visiting the City of
Carlsbad's Planning Division website at:
http:l/edocs.carlsbadca.gov/HPRMWebDrawer/RecordHTML/490390
19. Provide documentation that all existing improvements beyond the stringline are legally
permitted.
20. Provided below is staffs response to applicant questions 1-8:
a. The expected permit processing path for each development scenario differs as summarized
below.
i. Scenario Xis not feasible because the development of hotel units on R-3 zone land is
not permissible. A rezone to C-T may be a better option for this hotel development
scenario. This would require a GPA and ZC approved by the City Council and a LCPA
approved by the CCC.
ii. Scenario Y is problematic as the proposed Building E does not meet the rear setbacks
as outlined in comment 6.a. above. The elimination of Building E would make this
development scenario feasible. This would not require a GPA, ZC, or LCPA and is
subject to Planning Commission approval, appealable to the City Council, and with
the CCC having the ability to appeal the city's decision.
iii. Scenario Z is problematic as the proposed Building E does not meet the rear setbacks
as outlined in comment 6.a. above. The elimination of Building E would make this
development scenario feasible. This would require a GPA and ZC approved by the
City Council and a LCPA approved by the CCC.
b. The expected reaction from the CCC to each development scenario is not known at this time.
City staff will meet with the CCC to discuss development of the property and receive their
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input. You are also encouraged to coordinate with CCC staff as you refine the development
proposal.
c. Construction of a hotel on APN 203-144-03-00 is not permissible under the R-3 zone. The
contemplated C-T zone would allow for development of hotel units on the property. A
residential project is allowed on APN 203-144-03-00 under the current R-3 zone.
d. The hotel use is considered a nonconforming nonresidential use as explained in comment 5
above.
e. The contemplated GPA, ZC, and LCPA would require applicant initiation via an application
submittal. The contemplated GPA, ZC, and LCPA would not be undertaken as part of the city's
update to the Zoning Ordinance and Local Coastal Program.
f. The expected implications of the SLRVA are outlined in comment 6.a. above.
g. The existing seawall is considered a nonconforming structure. Expansion or enlargement of
the seawall is not permissible per CMC Chapter 21.48.
h. A restaurant is a permitted use in the C-T zone. If the property is rezoned to C-T, a restaurant
use may be considered with development of the property.
All necessary application forms, submittal requirements, and fee information are available at the
Planning counter located in the Faraday Building at 1635 Faraday Avenue or online at
http:ljwww.carlsbadca.gov/services/depts/planning/default.asp. You may also access the
General Plan Land Use Element and the Zoning Ordinance online at the website address shown;
select Department Listing; select Planning Home Page. Please review all information carefully
before submitting.
Land Development Engineering:
Prior to formal application submittal the following items must be adequately resolved/addressed:
1. Complete the city's Storm Water Standards Questionnaire (Form E-34). This questionnaire will
guide you and the City in determining what type of reports and storm water mitigation must be
completed to satisfy state and City storm water quality requirements. The questionnaire can be
obtained on the city's web site. Preliminary analysis suggests that the project is a Priority
Development Project and subject to numerically sized storm water pollutant treatment BMPs. A
Storm Water Quality Management Plan (SWQMP) using the city's SWQMP template, E-35 Form
will be required. It should be verified whether this project is subject to Hydromodification
Requirements.
If the project qualifies as a 'Standard' Project, then provide a completed Standard Project
Requirement Checklist (E-36 Form).
2. A discretionary application for the proposed project will require a preliminary grading plan,
SWQMP, hydrology report, and geotechnical report.
3. A preliminary grading plan shall include the proposed and existing grades, earthwork quantities
of cut, fill, import, export, and remedial in cubic yards, course of drainage, and all existing and
proposed improvements (i.e., water & sewer connection, storm drain, sidewalk reconfiguration,
existing driveway approaches, etc ... ). A 5-ft wide sidewalk at the frontage of Parcel 3 is required
for the proposed improvements.
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4. A preliminary title report dated within 6 months of the application date is required with the
submittal of a discretionary application and final engineering application. Show and label on the
plans, all easements listed in said report.
5. If the project is proposing condominiums as discussed in proposed Scenario Y then a tentative
tract map will be required for the discretionary application and a final map for final engineering.
6. For Scenario X and Z, a certificate of compliance for lot legality will be required to be processed
with the city per the Subdivision Map Act 66412.6{b).
7. A Transportation Impact Analysis may be required to be submitted with the discretionary permit
and will be dependent on which Scenario is selected. It is highly suggested that a scope of work
for the traffic study be submitted to the city's Land Development Engineering division prior to
the submittal of the discretionary application. The city's Transportation Impact Analysis
guidelines are available on the city's website.
8. Show on the preliminary grading plan the method of drainage. Verify that the drainage away
from the building is a minimum of 2% for hardscape and a minimum of 5% for landscape within
10-ft of the building.
9. Provide the finish floor, pad, and finish grades elevations on the preliminary grading plan.
10. Provide the legal description of the property on the title sheet per the preliminary title report.
11. Provide on the title sheet, the project's traffic, water, and sewer demand.
12. Label on the preliminary grading plan, the APNs and/or short legal description of all adjacent
properties.
13. Label on the preliminary grading plan, the width of the street and distance from the property
line to the centerline of Ocean Street and Garfield Street.
14. Show and label on the preliminary grading plan, the proposed location of the transformer for
the new building proposed on Parcel 3. It cannot be located in the city's right-of-way and must
be located on site.
15. Show and label on the preliminary grading plan, the adjacent properties existing
grades/contours and buildings/structures within 25-ft of the project site.
16. Address the redline comments on the plans.
1. The submittal does not specify which buildings currently have fire sprinklers. All new
construction shall be equipped with fire sprinklers. Additionally, substantial changes to existing
buildings not equipped with fire sprinklers may require that fire sprinklers be installed.
2. Fire alarm systems shall be installed throughout the property.
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Building:
1. No comments.
If you would like to schedule a meeting to discuss this letter with the commenting departments, please
contact Cliff Jones at the number below. You may also contact each department individually as follows:
• Planning Division: Cliff Jones, Senior Planner, at 760-602-4613.
• Land Development Engineering: Kyrenne Chua, Project Engineer, at 760-602-2744.
• Fire Department: Randy Metz, Fire Marshall, at 760-602-4661.
Sincerely,
~/4
DON NEU, AICP
City Planner
DN:CJ:mf
Attachments:
c:
1. LDE Redlines
2. Flood Hazard Area forecast for year 2100
Kyrenne Chua, Project Engineer
Randy Metz, Fire Marshal
HPRM/File Copy
Data Entry
J:\RequestsMarch2015\ComEcon Dev\Planning\RITM0013320_ 18\Coastal.Hazards.mxd, 12/19/2018
Inundation Hazard Area (2.0m) FEMA Flood Zones and Floodways:
----2100 LJ Zone AE
Inundation Hazard Area (0.5m) LJ Zone VE
----2050
Flood Hazard Area (2.0m)
~2100
Flood Hazard Area (0.5m)
~205_0