HomeMy WebLinkAbout2009-12-16; Planning Commission; Resolution 66571 PLANNING COMMISSION RESOLUTION NO. 6657
2 A RESOLUTION OF THE PLANNING COMMISSION OF THE
3 CITY OF CARLSBAD, CALIFORNIA, RECOMMENDING
ADOPTION OF A MITIGATED NEGATIVE DECLARATION
4 AND MITIGATION MONITORING AND REPORTING
PROGRAM AND ADDENDUM TO ALLOW FOR THE
SUBDIVISION OF A 10.07 ACRE SITE INTO FOUR LOTS
6 WITH 49 AIRSPACE CONDOMINIUM OFFICE UNITS AND
THE DEVELOPMENT OF A 66,000 SQUARE FOOT THREE-
7 STORY OFFICE BUILDING AND PERMANENT RV
STORAGE AREA ON PROPERTY GENERALLY LOCATED
8 SOUTH OF CANNON ROAD, EAST OF EL CAMINO REAL,
o AT THE SOUTHEAST CORNER OF THE INTERSECTION OF
WIND TRAIL WAY AND CANNON ROAD, WITHIN THE
10 ROBERTSON RANCH MASTER PLAN, PLANNING AREA 22
AND THE "OPTION PARCEL," IN LOCAL FACILITIES
11 MANAGEMENT ZONE 14.
CASE NAME: ROBERTSON RANCH PA 22
12 CASE NO.: GPA 09-01 /ZC 09-01 IMP 02-03(B)/CT 09-01 /
13 SDP 09-01/PUD 09-01
14 WHEREAS, Brookfield Tamarack, LLC, "Developer," has filed a verified
application with the City of Carlsbad regarding property owned by Calavera Hills II, LLC,
16 "Owner," described as
17
Lot 3 of Carlsbad Tract No. 02-16, Robertson Ranch East
' 8 Village, in the City of Carlsbad, County of San Diego, State of
California, according to Map thereof No. 15608, filed in the
Office of the County Recorder of San Diego County,
20 September 18, 2007; and Parcel 2 of Parcel Map No. 19804, in
the City of Carlsbad, County of San Diego, State of California,
21 filed in the Office of the County Recorder of San Diego
County, August 3, 2005 as Instrument No. 2005-0659805 of
22 Official Records
23 ("the Property"); and
24
WHEREAS, a Mitigated Negative Declaration and Mitigation Monitoring and
25
Reporting Program and Addendum were prepared in conjunction with said project; and26
27 WHEREAS, the Planning Commission did on December 16, 2009, hold a duly
28 noticed public hearing as prescribed by law to consider said request; and
WHEREAS, at said public hearing, upon hearing and considering all testimony
2 and arguments, examining the initial study, analyzing the information submitted by staff, and
3
considering any written comments received, the Planning Commission considered all factors
4
- relating to the Mitigated Negative Declaration and Mitigation Monitoring and Reporting
g Program and Addendum.
7 NOW, THEREFORE, BE IT HEREBY RESOLVED by the Planning
o Commission as follows:
9 A) That the foregoing recitations are true and correct.
10
B) That based on the evidence presented at the public hearing, the Planning
11 Commission hereby RECOMMENDS ADOPTION of the Mitigated Negative
Declaration and Mitigation Monitoring and Reporting Program, Exhibit
"MND," according to Exhibits "Notice of Intent (NOI)," and "Environmental
13 Impact Assessment Form - Initial Study (EIA)," and Addendum, Exhibit
"ADDM" attached hereto and made a part hereof, based on the following
14 findings:
15 Findings:
1. The Planning Commission of the City of Carlsbad does hereby find:
17
a. it has reviewed, analyzed, and considered the Mitigated Negative Declaration
IB and Mitigation Monitoring and Reporting Program and Addendum for
ROBERTSON RANCH PA 22 - GPA 09-01/ZC 09-01/MP 02-03(B)/CT 09-
19 01/SDP 09-01/PUD 09-01, the environmental impacts therein identified for this
20 project and any comments thereon prior to RECOMMENDING APPROVAL of
the project; and
21
b. the Mitigated Negative Declaration and Mitigation Monitoring and Reporting
22 Program and Addendum have been prepared in accordance with requirements
of the California Environmental Quality Act, the State Guidelines and the
Environmental Protection Procedures of the City of Carlsbad; and
24
c. it reflects the independent judgment of the Planning Commission of the City of
25 Carlsbad; and
" d. based on the EIA and comments thereon, there is no substantial evidence the
27 project will have a significant effect on the environment.
28 2. The Planning Commission has reviewed each of the exactions imposed on the Developer
contained in this resolution, and hereby finds, in this case, that the exactions are imposed
PC RESO NO. 6657 -2-
to mitigate impacts caused by or reasonably related to the project, and the extent and the
2 degree of the exaction is in rough proportionality to the impact caused by the project.
3 PASSED, APPROVED, AND ADOPTED at a regular meeting of the Planning
Commission of the City of Carlsbad, California, held on December 16, 2009, by the following
5 vote, to wit:
6
AYES: Commissioners Baker, Dominguez, Douglas, L'Heureux, Nygaard,
7 Schumacher, and Chairperson Montgomery
8 NOES:
9 ABSENT:
10
ABSTAIN:
11
12
13
14 MARTELL B. MONTGOMERY, Cjmperson
CARLSBAD PLANNING COMMlfSION
15
21
16 ATTEST:
1?"
18
19 DONNEU
20 Planning Director
21
22
23
24
25
26
27
28
PC RESO NO. 6657 -3-
City of Carlsbad
Planning Department
NOTICE OF INTENT TO ADOPT A
MITIGATED NEGATIVE DECLARATION
CASE NAME: Robertson Ranch Planning Area 22
CASE NO: GPA 09-01/ZC 09-01/MP 02-03CBVCT 09-01/PUD 09-01/SDP 09-01
PROJECT LOCATION: South of Cannon Road. East of El Camino Real., at the southeast corner of the
intersection of Wind Trail Way and Cannon Road, within the Robertson Ranch Master Plan, Planning
Area 22 and the "Option Parcel" CAPNs 168-360-03 & 168-050-55).
PROJECT DESCRIPTION: A development proposal to subdivide a 10.07 acre site into four (4) lots
with 49 airspace condominium office units, and to allow for the grading and construction of a 66,000
square foot 3-story office building and permanent RV storage facility. The proposed project requires
approval of a General Plan Amendment, Zone Change, Master Plan Amendment, Tentative Tract Map,
Site Development Plan, and Non-Residential Planned Development Permit.
PROPOSED DETERMINATION: The City of Carlsbad has conducted an environmental review of
the above described project pursuant to the Guidelines for Implementation of the California
Environmental Quality Act (CEQA) and the Environmental Protection Ordinance of the City of Carlsbad.
As a result of said review, the initial study (EIA Part 2) identified potentially significant effects on the
environment, but (1) revisions in the project plans or proposals made by, or agreed to by, the applicant
before the proposed negative declaration and initial study are 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 (2) there is no substantial evidence in light of the whole record before the City that the project
"as revised" may have a significant effect on the environment. Therefore, a Mitigated Negative
Declaration will be recommended for adoption by the City of Carlsbad City Council.
A copy of the initial study (EIA Part 2) documenting reasons to support the proposed Mitigated Negative
Declaration is on file in the Planning Department, 1635 Faraday Avenue, Carlsbad, California 92008.
Comments from the public are invited. Pursuant to Section 15204 of the CEQA Guidelines, in reviewing
Mitigated Negative Declarations, persons and public agencies should focus on the proposed finding that
the project will not have a significant effect on the environment. If persons and public agencies believe
that the project may have a significant effect, they should: (1) identify the specific effect; (2) explain
why they believe the effect would occur; and (3) explain why they believe the effect would be
significant. Please submit comments in writing to the Planning Department within 20 days of the date of
this notice.
The proposed project and Mitigated Negative Declaration are subject to review and approval/adoption by
the City of Carlsbad Planning Commission and City Council. Additional public notices will be issued
when those public hearings are scheduled. If you have any questions, please call Jason Goff in the
Planning Department at (760) 602-4643.
PUBLIC REVIEW PERIOD
PUBLISH DATE
OCTOBER 21, 2009 - NOVEMBER 10. 2009
OCTOBER 21.2009
1635 Faraday Avenue • Carlsbad, CA 92008-7314 • (760) 602-4600 • FAX (760) 602-8559 • www.ci.carlsbad.ca.us
ENVIRONMENTAL IMPACT ASSESSMENT FORM - INITIAL STUDY
(TO BE COMPLETED BY THE PLANNING DEPARTMENT)
CASE NO: GPA 09-01/ZC 09-01/MP 02-03(B)/CT 09-01 /PUD 09-01 /SDP 09-01
DATE: October 16.2009
BACKGROUND
1. CASE NAME: Robertson Ranch Planning Area 22
2. LEAD AGENCY NAME AND ADDRESS: City of Carlsbad
3. CONTACT PERSON AND PHONE NUMBER: Jason Goff. Associate Planner (760-602-4643)
4. PROJECT LOCATION: South of Cannon Road. East of El Camino Real, at the southeast corner
of the intersection of Wind Trail Way and Cannon Road, within the Robertson Ranch Master
Plan. Planning Area 22 and the "Option Parcel" (APNs 168-360-03 & 168-050-55).
5. PROJECT SPONSOR'S NAME AND ADDRESS: Calavera Hills II. LLC. 12865 Pointe Del
Mar. Suite 200. Del Mar, CA 92014 (Phone: 858-481-8500)
6. GENERAL PLAN DESIGNATION: Unplanned Area (UA) & Residential Low Medium Density
(RLM. 0-4 du/ac)
7. ZONING: Planned Community (P-C) & Residential Mobile Home Park (RMHP)
8. OTHER PUBLIC AGENCIES WHOSE APPROVAL IS REQUIRED (i.e., permits, financing
approval or participation agreements): N/A
9. PROJECT DESCRIPTION/ ENVIRONMENTAL SETTING AND SURROUNDING LAND
USES:
The proposed Robertson Ranch Planning Area 22 project site is located within the Robertson
Ranch Master Plan community, and is composed of Planning Area 22 (4.37 acres) and the 2.21
acre westerly portion of the adjacent 5.7 acre property, identified in the master plan as the
"Option Parcel". The applicant is proposing to develop a 66,000 square foot 3-story office
building and permanent RV storage facility on the project site.
The project involves a General Plan Amendment, Zone Change, Master Plan Amendment,
Tentative Tract Map, Site Development Plan, and Non-Residential Planned Development Permit.
A General Plan Amendment (GPA 09-01) is proposed to change the existing General Plan Land
Use designations on the project site from Unplanned Area (UA) and Residential Low-Medium
Density (RLM, 0-4 du/ac) to Office (O) and Open Space (OS).
A Zone Change (ZC 09-01) is proposed to change the existing zoning designation on the 2.21
acre westerly portion of the 5.7 acre "Option Parcel" from Residential Mobile Home Park
(RMHP) to Planned Community (P-C).
GPA 09-01/ZC 09-01/MP 02-03(B),of 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
A Master Plan Amendment (MP 02-03(B)) is proposed to:
a) Expand the existing Planning Area 22 boundary in the easterly direction to incorporate
the 2.21 acre westerly portion of the 5.7 acre "Option Parcel" into the Robertson Ranch
Master Plan community,
b) Change the underlying zoning of Planning Area 22 from Limited Control (L-C) to Office
(O) and Open Space (OS),
c) Create a new Robertson Ranch Planning Area 23 (G) to include a 1.15 acre Open Space
lot over the wetland buffer for Calavera Creek, and
d) Establish a permanent RV storage facility on Planning Area 22 to accommodate both the
East and West Villages.
A Tentative Tract Map (CT 09-01) is required in order to subdivide a total of 10.07 acres,
consisting of two parcels (Planning Area 22 (4.37 acres) and the "Option Parcel" (5.70 acres)),
into four (4) lots and 49 air space condominium office units. Proposed Lot 1 is 4.63 acres in size
and will accommodate the proposed office building. Proposed Lot 2 is 0.80 acres in size and will
accommodate the proposed permanent RV storage facility. Proposed Lot 3 will become a 3.49
acre remainder of the "Option Parcel", which is not being developed as part of this project.
Proposed Lot 4 is a 1.15 acre open space lot, which will include a minimum 100 foot wide
wetland buffer extending from the northerly edge of the low flow of the Calavera Creek channel
(located on the adjacent Rancho Carlsbad property to the south) to the toe of the PA 22 office
development pad slope.
A Site Development Plan (SDP 09-01) is required for the approval of a conceptual site design for
the proposed development. A 66,000 sq. ft. 3-story office building is proposed on Lot 1, which is
oriented along Cannon Road with its primary entrance centered off of the south elevation. A
parking lot, accommodating 265 spaces, is proposed around the south, west, and east sides of the
office building. The office building structural height is 45 feet to the top of the roof parapet, and
55 feet to the top of the tallest architectural feature. An RV storage facility is proposed on Lot 2,
which is located in the northeast corner of the property adjacent to the proposed office building
and Cannon Road. The entire site will take access from an existing signalized intersection
located at Wind Trail Way and Cannon Road.
A Non-Residential Planned Development Permit is required to allow for the proposed 49 air
space condominium office units.
The site is part of a previously approved Master Planned residential community, and has been
previously mass-graded through a grading permit issued for the Master Tentative Map for the
Robertson Ranch East Village. There are no sensitive biological resources presently existing on
the site. Six habitat types are present on the proposed project site; revegetated Diegan Coastal
Sage Scrub, Developed Land, Disturbed Land, Eucalyptus Woodland, Exotic, and Non-Native
Grasslands.
Surrounding land uses include single-family residential (PA 21: approved, but undeveloped
courtyard homes) and an existing 3-story multifamily residential apartment complex (PA 15)
across Cannon Road to the north; the Rancho Carlsbad mobile home residential community to the
south; the undeveloped Residential Mobile Home Park (RMHP) zoned "Option Parcel" to the
east; and a community park site (PA 12) and a water quality open space lot (PA 20) to the west.
Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(B>^T 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
In order to construct the proposed project, the site will require an additional 6,200 cubic yards of
excavation, 4,500 cubic yards of fill embankment, and a resulting 1,700 cubic yards of export of
soil to accommodate the proposed office development and associated parking lot, RV storage
facility, and landscaping amenities.
The project site was the subject of a previous CEQA review in the Robertson Ranch Final
Program Environmental Impact Report (EIR), which was certified by the Carlsbad City Council
on November 14, 2006 (EIR 03-03, State Clearing House #2004051039). Through the
certification of the EIR, the City Council adopted CEQA Findings of Fact, a Statement of
Overriding Considerations, and a Mitigation Monitoring and Reporting Program. The EIR is
intended to be used in the review of subsequent projects within Robertson Ranch Master Plan.
The project incorporates the required Robertson Ranch Master Plan EER mitigation measures, and
through the analysis of the required additional plans, reports, and studies pertaining to biological
resources, geotechnical, hydrology, storm water management, and noise, a determination has
been made that with the implementation of additional mitigation measures, no additional
significant impacts beyond those identified and mitigated for by the EIR will result from this
project. The Robertson Ranch Master Plan EIR and additional technical studies are cited as
source documents for this environmental evaluation.
Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(B>^f 09-0I/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:
The summary of environmental factors checked below would be potentially affected by this project,
involving at least one impact that is a "Potentially Significant Impact," or "Potentially Significant Impact
Unless Mitigation Incorporated" as indicated by the checklist on the following pages.
I | Aesthetics
O Agricultural Resources
D Air Quality
O Biological Resources
[>3 Cultural Resources
D Geology/Soils
I | Hazards/Hazardous Materials
l~~l Hydrology/Water Quality
I I Land Use and Planning
f~l Mineral Resources
£<] Mandatory Findings of
Significance
Noise
Population and Housing
Public Services
Recreation
Transportation/Circulation
Utilities & Service Systems
Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(BKf 09-01 /PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
DETERMINATION.
(To be completed by the Lead Agency)
[H 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 the mitigation measures described on an
attached sheet have been added to the project. A MITIGATED NEGATIVE DECLARATION
will be prepared.
I I I find that the proposed project MAY have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.
O I find that the proposed project MAY have "potentially significant impact(s)" on the environment,
but at least one potentially significant impact 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. A Negative Declaration is
required, but it must analyze only the effects that remain to be addressed.
O 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 all potentially significant effects (a) have
been analyzed adequately in an earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE
DECLARATION pursuant to applicable standards and (b) have been avoided or mitigated
pursuant to that earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE
DECLARATION, including revisions or mitigation measures that are imposed upon the proposed
project. Therefore, nothing further is required.
/o - is-
Date
Planning Director's Signature Date
Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(B>^ f 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
ENVIRONMENTAL IMPACTS
STATE CEQA GUIDELINES, Chapter 3, Article 5, Section 15063 requires that the City conduct an
Environmental Impact Assessment (EIA) to determine if a project may have a significant effect on the
environment. The Environmental Impact Assessment appears in the following pages in the form of a
checklist. This checklist identifies any physical, biological and human factors that might be impacted by
the proposed project and provides the City with information to use as the basis for deciding whether to
prepare an Environmental Impact Report (EIR), Negative Declaration, or to rely on a previously approved
EIR or Negative Declaration.
• A brief explanation is required for all answers except "No Impact" answers that are adequately
supported by an information source cited in the parentheses following each question. A "No
Impact" answer is adequately supported if the referenced information sources show that the
impact simply does not apply to projects like the one involved. A "No Impact" answer should be
explained when there is no source document to refer to, or it is based on project-specific factors
as well as general standards.
• "Less Than Significant Impact" applies where there is supporting evidence that the potential
impact is not significantly adverse, and the impact does not exceed adopted general standards and
policies.
• "Potentially Significant Unless Mitigation Incorporated" applies where the incorporation of
mitigation measures has reduced an effect from "Potentially Significant Impact" to a "Less Than
Significant Impact." The developer must agree to the mitigation, and the City must describe the
mitigation measures, and briefly explain how they reduce the effect to a less than significant
level.
• "Potentially Significant Impact" is appropriate if there is substantial evidence that an effect is
significantly adverse.
• Based on an "EIA-Initial Study", if a proposed project could have a potentially significant
adverse effect on the environment, but all potentially significant adverse effects (a) have been
analyzed adequately in an earlier EIR or Mitigated Negative Declaration pursuant to applicable
standards and (b) have been avoided or mitigated pursuant to that earlier EIR or Mitigated
Negative Declaration, including revisions or mitigation measures that are imposed upon the
proposed project, and none of the circumstances requiring a supplement to or supplemental EIR
are present and all the mitigation measures required by the prior environmental document have
been incorporated into this project, then no additional environmental document is required.
• When "Potentially Significant Impact" is checked the project is not necessarily required to
prepare an EIR if the significant adverse effect has been analyzed adequately in an earlier EIR
pursuant to applicable standards and the effect will be mitigated, or a "Statement of Overriding
Considerations" has been made pursuant to that earlier EIR.
• A Negative Declaration may be prepared if the City perceives no substantial evidence that the
project or any of its aspects may cause a significant adverse effect on the environment.
• If there are one or more potentially significant adverse effects, the City may avoid preparing an
EIR if there are mitigation measures to clearly reduce adverse impacts to less than significant, and
those mitigation measures are agreed to by the developer prior to public review. In this case, the
Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(B)/^f 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
appropriate "Potentially Significant Impact Unless Mitigation Incorporated" may be checked and
a Mitigated Negative Declaration may be prepared.
An EIR must be prepared if "Potentially Significant Impact" is checked, and including but not limited to
the following circumstances: (1) the potentially significant adverse effect has not been discussed or
mitigated in an earlier EIR pursuant to applicable standards, and the developer does not agree to
mitigation measures that reduce the adverse impact to less than significant; (2) a "Statement of Overriding
Considerations" for the significant adverse impact has not been made pursuant to an earlier EIR; (3)
proposed mitigation measures do not reduce the adverse impact to less than significant; or (4) through the
EIA-Initial Study analysis it is not possible to determine the level of significance for a potentially adverse
effect, or determine the effectiveness of a mitigation measure in reducing a potentially significant effect to
below a level of significance.
A discussion of potential impacts and the proposed mitigation measures appears after each related set of
questions. Particular attention should be given to discussing mitigation for impacts, which would
otherwise be determined significant.
Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(B>^F 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
AESTHETICS - Would the project:
a) Have a substantial adverse effect on a scenic
vista?
b) Substantially damage scenic resources,
including but not limited to, trees, rock
outcroppings, and historic buildings within a
State scenic highway?
c) Substantially degrade the existing visual
character or quality of the site and its
surroundings?
d) Create a new source of substantial light and
glare, which would adversely affect day or
nighttime views in the area?
Potentially
Significant
Impact
D
D
Potentially
Significant
Unless
Mitigation
Incorporated
D
Less Than
Significant
Impact
D
No
Impact
D
a a
a-b) No Impact. The Robertson Ranch Master Plan and EIR included a visual quality and landform
analysis for the Master Plan area. The proposed site is located on mostly level ground previously used for
agriculture and will not require significant alteration of landform. The majority of the development area
of the subject site has been previously graded with a deposit of fill soil placed over much of the site via
the grading permit issued with the Master Tentative Map for the Robertson Ranch East Village (CT 02-
02). This fill was assessed in the EIR and found to not result in a significant impact. PA 22 is not within
the view shed of a scenic vista, and is not visible from a State scenic highway. No impact is assessed.
c-d) Less than Significant Impact. The proposed project complies with the Robertson Ranch Master
Plan development standards for architectural design and landscaping. Compliance with these standards
and guidelines mitigates any potential visual quality impacts of individual development projects that are
approved and implemented consistent with the Master Plan. Compliance with the development standards
of the Master Plan specifically mitigates visual impacts including those associates with line of sight views
from the Rancho Carlsbad Mobile Home Park, the closest existing development. The project complies
with these standards. The project also complies with the development standards of the City's Office (O)
Zone, which is being proposed. The office building will not exceed 45-feet in height, with architectural
projections not exceeding 55-feet. The project design incorporates increased setbacks at a ratio of one (1)
foot per additional foot of building height in order to compensate for the proposed building height. The
RV storage lot will be surrounded by an 8-foot visual barrier consisting of a 2 ft. tall earthen berm and 6
ft. tall solid masonry wall set on top. The Conceptual Landscape Plan incorporates a plant palette and
layout designed to reduce the mass of the proposed office building and to screen the permanent RV
storage facility from the existing Rancho Carlsbad Mobile Home Park by utilizing a combination 6 ft. tall
solid masonry wall at the top of the surrounding pad along with a dense planting of both evergreen and
deciduous trees. A view analysis has been conducted from existing residences along the periphery of the
Rancho Carlsbad Mobile Home Park. This analysis concludes that the distance and dense landscaping
will serve to eliminate the potential for significant visual impacts from this area. Further, the project will
incorporate light shielding to minimize the potential for any light spillover into adjacent neighboring
properties.
Rev. 10/02/09
f r
GPA 09-01/ZC 09-01/MP 02-03(B)/cT 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
PA 22 was analyzed to be developed with a residential (20 courtyard units) development in the Robertson
Ranch EIR. PA 22 development was addressed specifically for any potentially significant aesthetic
impacts. The EIR concluded that Robertson Ranch (including PA 22) was not considered a scenic
resource nor will future development on the project site block any existing scenic vistas from the view of
surrounding land uses. Moreover, the project was determined to ensure aesthetic quality of future
development through compliance with the Master Plan Design Guidelines. Also, it was noted that the
project will avoid substantial changes to significant natural features. Notwithstanding that the present PA
22 development proposal proposes a modification of the EIR-assumed land use, and the proposed office
building will be approximately 10-feet higher than the residential units could have been, the proposed
project is otherwise consistent with the Robertson Ranch Master Plan Design Guidelines. The proposed
dense landscaping buffer will mitigate visual impacts associated with the increased height of the proposed
office building and the RV Storage facility. Furthermore, the project strictly complies with the O-Zone
development standards for parking, landscaping, setbacks, and other requirements. In light of these
factors, a less than significant impact to aesthetic values is assessed for the proposed project.
II. AGRICULTURAL RESOURCES - (In
determining whether impacts to agricultural
resources are significant environmental effects, lead
agencies may refer to the California Agricultural
Land Evaluation and Site Assessment Model-1997
prepared by the California Department of
Conservation as an optional model to use in
assessing impacts on agriculture and farmland.)
Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland),
as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of
the California Resources Agency, to non-
agricultural use?
b) Conflict with existing zoning for agricultural
use, or a Williamson Act contract?
c) Involve other changes in the existing
environment, which, due to their location or
nature, could result in conversion of Farmland to
non-agricultural use?
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant No
Impact Impact
D D
D D
n
a-c) No Impact. The Robertson Ranch Master Plan EIR identifies all Important Farmlands within the
Robertson Ranch Master Plan Area. All of the Prime Farmland and Farmland of Statewide Importance is
located north of Cannon Road and is outside of the proposed development envelope of the project and
will not be impacted by the project. In addition, the EIR concludes that implementation of the Robertson
Ranch Master Plan does not constitute a significant impact to agricultural resources and thus no
mitigation was required for implementation of the Master Plan. Therefore, it is concluded that no impact
is assessed to Agricultural Resources.
Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(B)/cT 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
Potentially
Significant
Potentially Unless Less Than
Significant Mitigation Significant No
Impact Incorporated Impact Impact
III. AIR QUALITY - (Where available, the
significance criteria established by the applicable air
quality management or air pollution control district
may be relied upon to make the following
determinations.) Would the project:
a) Conflict with or obstruct implementation of the [~~1 CD CD Kl
applicable air quality plan?
b) Violate any air quality standard or contribute |~] CD El CD
substantially to an existing or projected air
quality violation?
c) Result in a cumulatively considerable net I I I I £3 CD
increase of any criteria pollutant for which the
project region is in non-attainment under an
applicable federal or state ambient air quality
standard (including releasing emissions which
exceed quantitative thresholds for ozone
precursors)?
d) Expose sensitive receptors to substantial I I I I | | [X]
pollutant concentrations?
e) Create objectionable odors affecting a I I I I | I IXI
substantial number of people?
a) No Impact. The project site is located in the San Diego Air Basin which is a state non-attainment area
for ozone (Oi) and for particulate matter less than or equal to 10 microns in diameter (PMio). The
periodic violations of national Ambient Air Quality Standards (AAQS) in the San Diego Air Basin
(SDAB), particularly for ozone in inland foothill areas, requires that a plan be developed outlining the
pollution controls that will be undertaken to improve air quality. In San Diego County, this attainment
planning process is embodied in the Regional Air Quality Strategies (RAQS) developed jointly by the Air
Pollution Control District (APCD) and the San Diego Association of Governments (SANDAG).
A Plan to meet the federal standard for ozone was developed in 1994 during the process of updating the
1991 state-mandated plan. This local plan was combined with plans from all other California non-
attainment areas having serious ozone problems and used to create the California State Implementation
Plan (SIP). The SIP was adopted by the Air Resources Board (ARB) after public hearings on November
9th through 10th in 1994, and was forwarded to the Environmental Protection Agency (EPA) for approval.
After considerable analysis and debate, particularly regarding airsheds with the worst smog problems,
EPA approved the SIP in mid-1996.
The proposed project relates to the SIP and/or RAQS through the land use and growth assumptions that
are incorporated into the air quality planning document. These growth assumptions are based on each
city's and the County's general plan. If a proposed project is consistent with its applicable General Plan,
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ROBERTSON RANCH PLANNING AREA 22
then the project presumably has been anticipated with the regional air quality planning process. Such
consistency would ensure that the project would not have an adverse regional air quality impact.
Section 15125(d) of the State of California Environmental Quality Act (CEQA) Guidelines contains
specific reference to the need to evaluate any inconsistencies between the proposed project and the
applicable air quality management plan. Transportation Control Measures (TCMs) are part of the RAQS.
The RAQS and TCM plan set forth the steps needed to accomplish attainment of state and federal
ambient air quality standards. The California Air Resources Board provides criteria for determining
whether a project conforms to the RAQS which include the following:
• Is a regional air quality plan being implemented in the project area?
• Is the project consistent with the growth assumptions in the regional air quality plan?
The project area is located in the San Diego Air Basin, and as such, is located in an area where a RAQS is
being implemented. The project, as discussed below, is consistent with the growth assumptions in the
regional air quality plan and will in no way conflict with or obstruct implementation of the regional plan.
The Robertson Ranch Master Plan EIR addressed a project that included 1,383 dwelling units at final
build out. The worst-case traffic impact assumptions were based on this residential figure. Subsequent to
the EIR analysis, the Robertson Ranch Master Plan was approved with a maximum of 1,154 dwelling
units, or 229 residential units (200 multi-family and 29 single-family) less than what the EIR had assumed
would be constructed within the Robertson Ranch property. Therefore, at build out, the Robertson Ranch
project would generate 1,890 total ADT less (1,600 multi-family ADT, plus 290 single-family ADT) than
the project intensity addressed in the EIR. This reduced traffic generation will result in a corresponding
reduction in air quality impacts.
However, the Traffic Analysis that was prepared for the proposed PA 22 project concludes that this
project is expected to generate a net 308 ADT greater than the amount of ADT originally assumed for the
PA 22 property and its direct neighboring planning areas within the East Village. For air quality impact
purposes, this 308 ADT net local traffic generation increase when subtracted from the 1,890 ADT
decrease for the overall Robertson Ranch project will result in a net decrease in build out traffic generated
by the Robertson Ranch project of 1,582 ADT. Furthermore, the proposed PA 22 project no longer
proposes residential dwelling units, and thus does not propose fireplaces, barbecues, or similar emission
creating sources. Therefore, both the mobile source and fixed source emissions from the PA 22 project
will not exceed the amount projected in the Robertson Ranch Master Plan EIR. No impact is assessed.
b) Less Than Significant Impact. The closest air quality monitoring station to the project site is at
Camp Pendleton. Data available for this monitoring site from 2000 through December 2004 indicate that
the most recent air quality violations recorded were for the state one hour standard for ozone (a total of 10
days during the 5-year period). No other violations of any air quality standards have been recorded
during the 5-year time period. The project would involve minimal short-term emissions associated with
grading and construction. Such emissions would be minimized through standard construction measures
such as the use of properly tuned equipment and watering the site for dust control. Long-term emissions
associated with travel to and from the project will be minimal. Although air pollutant emissions would be
associated with the project, they would neither result in the violation of any air quality standard
(comprising only an incremental contribution to overall air basin quality readings), nor contribute
substantially to an existing or projected air quality violation. Any impact is assessed as less than
significant.
c) Less Than Significant Impact. The air basin is currently in a state non-attainment zone for ozone and
suspended fine particulates. The proposed project would represent a contribution to a cumulatively
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ROBERTSON RANCH PLANNING AREA 22
considerable potential net increase in emissions throughout the air basin. As described above, however,
emissions associated with the proposed project would be minimal. Given the limited emissions
potentially associated with the proposed project, air quality would be essentially the same whether or not
the proposed project is implemented. According to the CEQA Guidelines Section 15064(h)(3), the
proposed project's incremental contribution to the cumulative effect is not cumulatively considerable.
Any impact is assessed as less than significant.
d) No impact. As noted above, the proposed would not result in substantial pollutant emissions or
concentrations. In addition, there are no sensitive receptors (e.g., schools or hospitals) located in the
vicinity of the project. The nearest school (Kelly Elementary School) is located approximately one mile
west of the site. No impact is assessed.
e) No Impact. The construction of the proposed project could generate fumes from the operation of
construction equipment, which may be considered objectionable by some people. Such exposure would
be short-term or transient. In addition, the number of people exposed to such transient impacts is not
considered substantial. No impact is assessed.
IV. 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 California Department of
Fish and Game or U.S. Fish and Wildlife
Service?
b) Have a substantial adverse effect on any
riparian, aquatic or wetland habitat or other
sensitive natural community identified in local
or regional plans, policies, or regulations or by
California Department of Fish and Game or U.S.
Fish and Wildlife Service?
c) Have a substantial adverse effect on federally
protected wetlands as defined by Section 404 of
the Clean Water Act (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?
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
D D
Less Than
Significant No
Impact Impact
D
D D D
D D D
D D
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ROBERTSON RANCH PLANNING AREA 22
Potentially
Significant
Impact
D
Potentially
Significant
Unless
Mitigation
Incorporated
D
Less Than
Significant No
Impact
D
Impact
D
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?
a) Less Than Significant Impact. According to the Robertson Ranch Master Plan HMP Hardline Map,
the project site, consisting of both PA 22 and the "Option Parcel", is identified as Development Area with
no adjacent hardline boundaries. A Preliminary Biological Assessment was prepared by Planning
Systems, dated August 10, 2009, to provide a site specific evaluation of the biological resources on the
project site. The results of that assessment are described below:
VEGETATION ANALYSIS
Plant Community Type
Revegetated Coastal Sage Scrub
Developed Lands
Disturbed Lands
Eucalyptus Woodland
Exotic Lands
Non-Native Grassland
Total
Acres Present
0.34
0.43
3.78
0.24
0.28
1.51
6.58
Acres Impacted
0.06
0.04
3.50*
0.23
0.00
0.71
4.54
*Mitigation fee for 3.40 acres of land for PA 22 grading associated with CT 02-16 has already been paid.
A balance amount of .10 acres will be required for the area of expansion into the "Option Parcel".
The only potential sensitive habitat present on the site is 0.34 acres of revegetated Coastal Sage Scrub,
which was planted on the south slope of the Cannon Road right of way. According to the Preliminary
Biological Assessment, this is an immature, not yet established community existing in a disturbed state
due to the installation of eucalyptus as a community component. Given these conditions, this area does
not represent a viable sensitive plant community. Furthermore, review of the project specific Preliminary
Biological Assessment and Robertson Ranch Master Plan EIR indicates an absence of riparian, aquatic or
wetland habitat, or any other sensitive natural communities on the proposed project site. Pursuant to the
HMP, the developer will be conditioned as part of the project to pay in-lieu fees for impacts to 0.06-acres
of Unoccupied Coastal Sage Scrub (Group-D Habitat), 0.36-acres of Annual Non-Native Grassland
(Group-E Habitat), and .33-acres of Disturbed Lands (Group-F Habitat). No mitigation is required for
impacts to the landscaped (i.e., exotic) and developed/paved areas. Therefore, a less than significant
impact is assessed to biological habitat modification or impacts to sensitive biological communities.
Calavera Creek is located off site and adjacent to the project's southerly boundary within the Rancho
Carlsbad Mobile Home Park. According to the Preliminary Biological Assessment, the open water found
in the creek bottom of this off-site creek channel does not support any wetland species typically
associated with a freshwater stream. Winter rains scour the channel bottom periodically keeping it free of
vegetation, while the creek banks and adjacent flat bench are planted with ornamentals and maintained
regularly by the Rancho Carlsbad HOA. Therefore, the northern edge of the channel bottom (the edge of
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ROBERTSON RANCH PLANNING AREA 22
Open Water) represents the wetland feature most proximate to the proposed project boundaries. Pursuant
to the HMP conservation standards, a 100-foot buffer is required from all wetlands, which this project
incorporates by design. . Best Management Practices (BMPs) as required by the Storm Water
Management Plan contains adequate measures that will preclude significant sediment runoff from the site.
The project will implement erosion control measures to avoid pollution and sedimentation of important
water resources and the loss of vegetative resources from sloped areas by incorporation of such features
as silt fences, brow ditches where needed and desiltation basins. Furthermore, it should be noted that
there is an existing 6 foot tall masonry wall belonging to the Rancho Carlsbad Mobile Home Park and
located on the north side of the creek channel further separating this project from the creek channel. As a
result of these factors, a less than significant impact is assessed.
b-f) No Impact. The Robertson Ranch Master Plan EIR and the project specific Preliminary Biological
Assessment both indicate an absence of federally protected wetlands on the project site as'defined by
Section 404 of the Clean Water Act. Therefore, the project will not have a substantial adverse effect on
federally protected wetlands through direct removal, filling, hydrological interruption, or other means
The project has been designed to comply with the requirements of the Carlsbad HMP. This document
shows that the proposed project does not directly impact any identified animal migration corridors
through the city. The project is located adjacent to the Calavera Creek, which according to the
Preliminary Biological Assessment may serve as a wildlife movement corridor. As discussed above, the
project is providing a 100-foot buffer from the creek channel. Standard HMP requirements as they
pertain to fencing, lighting, and the use of noninvasive plant species have been incorporated into the
project design to minimize any potential edge effects.
The project has been designed to comply with the City of Carlsbad HMP and does not conflict with any
policies or ordinances protecting biological resources within the city. As a result, the project is
determined to comply with the regulations and requirements of the HMP and does not conflict with any
other policies or ordinances protecting biological resources at a local, state or federal level. Therefore, no
impact is assessed.
Potentially
Significant
Potentially Unless Less Than
Significant Mitigation Significant No
Impact Incorporated Impact Impact
V. CULTURAL RESOURCES - Would the project:
a) Cause a substantial adverse change in the I I I I I I [X]
significance of a historical resource as defined
in §15064.5?
b) Cause a substantial adverse change in the O [X] CH d
significance of an archeological resource
pursuant to §15064.5?
c) Directly or indirectly destroy a unique pale I I [x] I I I I
ontological resource or site or unique geologic
feature?
d) Disturb any human remains, including those | | I I | | 1X1
interred outside of formal cemeteries?
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a) No Impact. A Cultural Resources Survey and Evaluation for the entire Robertson Ranch Master Plan
Area (including the "Option Parcel") was prepared by Brain Smith and Associates (BFSA), dated June
2002. Cultural resource sites were identified throughout the Master Plan area and no historical sites were
located within the footprint of the proposed project site. However, a Historic Structure P-37-024329, the
original Robertson Ranch House, was located nearby to the east and just outside of the footprint of the
subject project. This structure was described as a rectangular wood-frame and sided, Victorian style
structure that had several modern era additions. The BFSA Cultural Resources Survey and Evaluation
determined that the structure was in poor condition and not deemed a significant historical structure and
no mitigation was suggested. The structure has since been removed.
b-c) Potentially Significant Unless Mitigation Incorporated. The BFSA Cultural Resources Survey
and Evaluation identified a small archaeological site on (at the location of the proposed RV storage lot)
the proposed project site. Cultural Site SDI-16,138 was identified as a small scatter of marine shell and
associated lithic artifacts located on a gradual slope west of the of the original Robertson Ranch house.
Testing of the site demonstrated that SDI-16,138 consisted of a moderate scatter of marine shell with a
small amount of bone and lithic artifacts. Testing concluded that the presence of both marine shell and
bone indicated food processing was the primary activity at the site, while the surface artifacts suggested
limited lithic tool production or maintenance also occurred. The site was deemed to be significant and
required mitigation through excavation and analyses.
In accordance with the Robertson Ranch Master Plan EIR mitigation measures, a data recovery program
was completed for archaeological site SDI-16,138. This data recovery program is documented in the
Results of a Cultural Resources Mitigation and Monitoring Program for Robertson Ranch, dated
November 26, 2008, by Brian F. Smith and Associates. According to this report, no lithics were present
in the collection, nor was pottery or any other temporally distinct artifact encountered from SDI-16,138
during the data recovery program and thus mass grading of the site was allowed to occur in compliance
with the Robertson Ranch Master Plan EIR mitigation measures.
In order to further develop the project site in the easterly direction for the construction of the proposed
office building and RV storage facility, some additional excavation and grading is necessary to develop
the pad in this area. Therefore, in accordance with the California Environmental Quality Act (CEQA)
Section 15064.5(f), which requires provisions for the identification and evaluation of accidentally
discovered archeological resources; mitigation measures have been added to the project requiring
archaeological monitoring by both a qualified archaeologist and tribal monitor(s) of the San Luis Rey
Band of Mission Indians during all earth-disturbing activities. In the event that any cultural resources,
concentration of artifacts, or culturally modified soil deposits are discovered within the project boundaries
during construction activities, all work is to be halted near the discovery and a qualified archeologist shall
record and evaluate the discovery under CEQA. Through the implementation of these mitigation
measures, along with the requirements of tribal monitoring and a formal pre-excavation agreement with
the San Luis Rey Band of Mission Indians, impacts to any unforeseen or accidentally discovered cultural
resources are reduced to a level of less than significant.'&••
In addition, the Robertson Ranch Master Plan EIR identified the possibility of paleontological resources
being present within the soils that were identified within the Robertson Ranch Master Plan area. Grading
of the project site will require minor cuts and fills. Therefore, a mitigation program which involves the
review of the grading plans and full time attendance of a paleontologist during' grading operations (i.e.,
cuts), with the authority to direct grading in order to salvage and curate resources, will mitigate impacts to
a less than significant level.
d) No Impact. There are no known human remains anticipated to be encountered during excavation
and/or construction of the PA 22 project. No impact assessed.
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ROBERTSON RANCH PLANNING AREA 22
VI. GEOLOGY AND SOILS - Would the project:
a) Expose people or structures to potential
substantial adverse effects, including the risk
of loss, injury or death involving:
i. Rupture of a known earthquake fault, as
delineated on the most recent Alquist-
Priolo Earthquake Fault Zoning Map
issued by the State Geologist for the area
or based on other substantial evidence of a
known fault? Refer to Division of Mines
and Geology Special Publication 42.
ii. Strong seismic ground shaking?
iii. Seismic-related ground failure, including
liquefaction?
iv. Landslides?
b) Result in substantial soil erosion or the loss of
topsoil?
c) Be located on a geologic unit or soil that is
unstable, or that would become unstable as a
result of the project, and potentially result in
on- or off-site landslide, lateral spreading,
subsidence, liquefaction, or collapse?
d) Be located on expansive soils, as defined in
Section 1802.3.2 of the California Building
Code (2007), creating substantial risks to life
or property?
e) Have soils incapable of adequately supporting
the use of septic tanks or alternative
wastewater disposal systems where sewers are
not available for the disposal of wastewater?
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant No
Impact Impact
D D
D
n
n
n n n
n
n
n
n
a.i.-a.iii.) Less Than Significant Impact. The project site is situated in the western portion of the
Peninsular Ranges geomorphic province of southern California. The most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the State Geologist for the north San Diego County area,
indicates that the project is considered to be in a seismically active area, as is most of southern California.
This map however, indicates that the subject site is not underlain by known active faults, nor is there
evidence of ground displacement in the area during the last 11,000 years.
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ROBERTSON RANCH PLANNING AREA 22
The closest fault, the Rose Canyon fault, is located approximately 4.5 miles westerly of the site. The
Elsinore fault zone is located approximately 24 miles east of the site. The potential for rupture resulting
from earthquake is considered to be low. The subject site is not within a fault-rupture hazard zone as
indexed in the Division of Mines and Geology Special Publication 42.
The geotechnical evaluation that was prepared for the Robertson Ranch Master Plan EIR by GeoSoils,
Inc., dated September 2004, concluded that the subject site appears generally suitable for grading and
development from a geotechnical perspective. A further analysis by GeoSoils, Inc., Report of Rough
Grading. Planning Area 22 of Robertson Ranch. East Village, dated March 6, 2009, was also prepared
subsequent to the import of fill soil onto the PA 22 site per a rough grading plan approval for the East
Village Master Final Map. This latest analysis concludes that the fill soil operations have been completed
in general accordance with the City grading ordinance and per recommendations by the geologist. Poor
quality soil, such as concentrated organic matter and debris, was removed prior to placing fill, loose
surficial materials were removed, saturated alluvial soils were left in place and compacted, the site was
brought to rough elevation grade and compacted to a minimum 90% relative compaction, all monitored
by the geologist. Oversized materials were disposed of off-site. Field density tests were taken at periodic
intervals and random locations to check the compactive effort of the fill soil. Laboratory testing and
analysis was conducted in order to determine risks associated with corrosion, acidity, alkalinity and other
potential issues.
Based on anticipated foundation loads and preliminary design information, the geotechnical report
concludes that the proposed office building and RV storage lot can be supported on the existing
compacted fill soils. By following the recommendations contained within the referenced report, the site is
suitable for the proposed project and exposure of people or structures to geotechnical related hazards is
considered to be less than significant.
a.iv.-b) No Impact. The geotechnical evaluation for the Robertson Ranch Master Plan EIR concluded
that no landslides exist on the subject PA 22 site.
c) Less. Than Significant Impact. Liquefaction describes a phenomenon in which cyclic stresses,
produced by earthquake induced ground motion, creates excess pore pressures in relatively cohensionless
soils. These soils may thereby acquire a high degree of mobility, which can lead to lateral movement
sliding, consolidation and settlement of loose sediments, sand boils, and other damaging deformations.
This phenomenon occurs only below the water table, but after liquefaction has developed it can propagate
upward into overlying, non-saturated soil, as excess pore water dissipates. According to the geotechnical
report that was prepared for the Robertson Ranch Master Plan EIR, liquefaction potential was identified
within the alluvial soils of Robertson Ranch project area. Alluvial soils appear to occur within two
distinct depositional environments onsite. One is characterized as tributary alluvium (QalA), deposited
within smaller canyons and gullies dissecting slope areas; and valley alluvium (QalB), deposited within
the larger, broad flood plains located along the eastern and southern sides of the Robertson Ranch project
area. The Robertson Ranch Master Plan EIR included a mitigation measure requiring a minimum 10 to
15 foot layer of non-liquefiable soil material (i.e., compacted fill plus alluvium above the groundwater
table) be provided beneath any structure to reduce any potential liquefaction potential. The Report of
Rough Grading. Planning Area 22 of Robertson Ranch. East Village, dated March 6, 2009, GeoSoils,
Inc., indicated that loose surficial materials (i.e., existing topsoils, colluviums, near surface alluvium, and
unsuitable formational soils), were removed to expose suitable bearing soils, as defined in the approved
report for the site. Therefore, impacts as a result of liquefaction are considered to be low. Based on
anticipated foundation loads and preliminary design information, the geotechnical report concludes that
the proposed office building and RV storage lot can be supported on the existing compacted fill soils. By
following the recommendations contained within the referenced report, the site is suitable for the
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ROBERTSON RANCH PLANNING AREA 22
proposed project and exposure of people or structures to geotechnical related hazards is considered to be
less than significant.
d-e) No Impact. The expansion potential of the soils underlying the subject site is considered to be low.
No septic tanks are proposed. The subject project will utilize the public sanitary sewer system. No
impact is assessed.
VII. HAZARDS AND HAZARDOUS MATERIALS -
Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use,
or disposal of hazardous materials?
b) Create a significant hazard to the public or
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?
c) Emit hazardous emissions or handle hazardous
or acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or
proposed school?
d) Be located on a site which is included on a list
of hazardous materials sites compiled pursuant
to Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the
public or environment?
e) For a project within an airport land use plan, or
where such a plan has not been adopted, within
two miles of a public airport or public use
airport, would the project result in a safety
hazard for people residing or working in the
project area?
f) For a project within the vicinity of a private
airstrip, would the project result in a safety
hazard for people residing or working in the
project area?
g) Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
D
D
D
n
Less Than
Significant No
Impact Impact
n
n n
n n
n n n
n n
n n
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Potentially
Significant
Impact
D
Potentially
Significant
Unless
Mitigation
Incorporated
D
Less Than
Significant No
Impact Impact
h) Expose people or structures to a significant risk
of loss, injury or death involving wildland fires,
including where wildlands are adjacent to
urbanized areas or where residences are
intermixed with wildlands?
a-b) Less Than Significant Impact. The proposed project involves grading operations and construction
activity for the future development of an office building, RV storage lot, and associated improvements.
During the construction phases of the proposed project, construction equipment and materials typically
associated with land development (i.e. petroleum products, paint, oils and solvents) will be transported
and used onsite. Upon completion of construction of the project, some use of hazardous cleaning
products on the site may occur. Other than during this construction phase, the project will not routinely
utilize hazardous substances or materials. All transport, handling, use, and disposal of any cleaning
substances will comply with all Federal, State, and local laws regulating the management and use of such
materials. No extraordinary risk of accidental explosion or the release of hazardous substances is
anticipated with construction, development, and implementation or operation of the proposed project. It is
concluded that the routine amount of hazardous materials utilized during the construction period is not
significant, and therefore the impact to the public or the environment through the routine transport, use, or
disposal of hazardous materials is considered to be less than significant.
c-h) No Impact. The project site is not listed on any county, State or Federal databases as a hazardous
waste use or disposal site. The site is in excess of one mile from the nearest (Kelly Elementary) school,
and is not located within the Airport Influence Area of the McClellan Palomar Airport Land Use
Compatibility Plan, or adjacent to or within the vicinity of any private airstrips. Neither construction, nor
the operation of the proposed project, will significantly affect, block, or interfere with traffic on public
streets, including any streets that would be used for an emergency response plan or emergency evacuation
plan. No emergency response or evacuation plan directs evacuees through the project site, and no
improvements are proposed by the project in any area which would physically interfere with an adopted
emergency response plan or emergency evacuation plan. Furthermore, the project site is not adjacent to
a wildland interface where residences are intermixed with tracts of natural vegetation. No impact is
assessed.
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VIII. HYDROLOGY AND WATER QUALITY-
Would the project:
a) Violate any water quality standards or waste
discharge requirements?
b) Substantially deplete groundwater supplies or
interfere substantially with ground water
recharge such that there would be a net deficit
in aquifer volume or a lowering of the local
ground water table level (i.e., the production
rate of pre-existing nearby wells would drop
to a level which would not support existing
land uses or planned uses for which permits
have been granted)?
c) Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or
river, in a manner, which would result in
substantial erosion or siltation on- or off-site?
d) Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or
river, or substantially increase the flow rate or
amount (volume) of surface runoff in a
manner, which would result in flooding on- or
off-site?
e) Create or contribute runoff water, which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff?
f) Otherwise substantially degrade water
quality?
g) Place housing within a 100-year flood hazard
area as mapped on a Federal Flood Hazard
Boundary or Flood Insurance Rate Map or
other flood delineation map?
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
D
D
n
D
Less Than
Significant No
Impact Impact
n
D n
n
n n n
n n n
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h) Place within 100-year flood hazard area
structures, which would impede or redirect
flood flows?
i) Expose people or structures to a significant
risk of loss, injury or death involving
flooding, including flooding as a result of the
failure of a levee or dam?
j) Inundation by seiche, tsunami, or mudflow?
k) Increase erosion (sediment) into receiving
surface waters.
1) Increase pollutant discharges (e.g., heavy
metals, pathogens, petroleum derivatives,
synthetic organics, nutrients, oxygen-
demanding substances and trash) into
receiving surface waters or other alteration of
receiving surface water quality (e.g.
temperature, dissolved oxygen or turbidity?
m) Change receiving water quality (marine, fresh
or wetland waters) during or following
construction?
n) Increase any pollutant to an already impaired
water body as listed on the Clean Water Act
Section 303(d) list?
o) Increase impervious surfaces and associated
runoff?
p) Impact aquatic, wetland, or riparian habitat?
q) Result in the exceedance of applicable surface
or groundwater receiving water quality
objectives or degradation of beneficial uses?
Potentially
Significant
Impact
D
D
D
D
D
D
Potentially
Significant
Unless
Mitigation
Incorporated
n
Less Than
Significant No
Impact Impact
n n
n
n
n
n
n
n
n
n
n
a) Less Than Significant Impact. Impacts to Hydrology and Water Quality as a result of the Robertson
Ranch Master Plan project (including the PA 22 project site) were analyzed in the Robertson Ranch
Master Plan EIR. Mitigation measures to reduce impacts to less than significant were identified in a
Preliminary Storm Water Management Plan for the Robertson Ranch East Village and the Preliminary
Drainage Study (prepared by O'Day Consultants, dated September 2005), which included implementation
of the Storm Drainage and a Desiltation/Depollutant Plan as proposed in the Master Plan. A subsequent
Preliminary Drainage Study for Robertson Ranch PA 22 (O'Day Consultants, April 14, 2009) and a
Preliminary Storm Water Management Plan for Robertson Ranch PA 22, (O'Day Consultants, April 14,
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ROBERTSON RANCH PLANNING AREA 22
2009) have been prepared to address the modified hydrological circumstances based on the post-deposit
of fill soil for a development pad on the proposed project site.
The subject property is required by law to comply with Federal, State and local water quality regulations
including the Clean Water Act, California Administrative Code Title 23, and specific basin plan
objectives identified in the "Water Quality Control Plan for the San Diego Basin". The project is required
to adhere to all applicable Regional Water Quality Control Board (RWQCB) regulations for control of
sedimentation and erosion, and to comply with the National Pollution Elimination Discharge System
(NPDES) requirements and Best Management Practices (BMPs) for water quality. The proposed project
will include all water quality infrastructure as required by the City. As a result, the project will not
violate any water quality standards or waste discharge requirements; and there will be no impact to water
quality, site erosion, pollution discharge, or drainage from the site as it may affect adjacent properties and
existing storm water infrastructure.
The project site presently consists of a rough-graded pad with a temporary sediment basin. This pad area
is approximately 3.64 acres in size and runoff flows from east to west into the temporary sediment basin
via overland flow. An existing 24-inch storm drain pipe conveys runoff into an existing depollutant swale
downstream within Robertson Ranch PA 20.
The proposed hydrology conditions for the proposed project have been designed to preserve the existing
drainage patterns to the maximum extent practicable. The drainage study concludes that post-
development runoff generated on the project site will be collected and conveyed by a proposed private
storm drain system to the existing depollutant basin in PA 20. The increase in pad area will result in an
increase Q,0o from 14.1 cfs (existing) to 21.1 cfs (developed). It is concluded that the existing
downstream 24-inch storm drain and depollutant basin can adequately convey the developed Q^O. As a
result, it is determined that the proposed project will not violate water quality standards and a less than
significant impact is assessed.
b) No Impact. The project does not propose to directly draw any groundwater; instead it will be served
via existing public water distribution lines within the public right-of-way adjacent to the site. Existing
water lines will adequately serve the project's water demands. No impact is assessed.
c-f) Less Than Significant Impact. The alteration of drainage patterns in the area of the project site will
not be substantial, and will be consistent with that analyzed in the Robertson Ranch Master Plan EER.
Likewise, the grading of the property will not result in substantial erosion on or off-site. The proposed
project will not create or contribute runoff which would exceed the capacity of existing or planned
stormwater drainage systems or otherwise degrade water quality beyond the assumptions in the Robertson
Ranch Master Plan EIR. The post-development runoff generated from the proposed project will be
collected and conveyed by a proposed private storm drain system to the existing depollutant basin in PA
20. The increase in pad area will result in an increase Qioo from 14.1 .cfs to 21.1 cfs and thus it is
concluded that the existing downstream 24-inch storm drain and depollutant basin can adequately convey
the developed Qioo- Therefore, it is concluded that the project will not substantially alter the existing
drainage pattern of the site or area in a manner that would result in substantial erosion or siltation on-site
or off-site.
g-j) No Impact. The proposed project will not place housing within a 100-year flood hazard area as
mapped on a Federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood delineation
map, or expose people or structures to significant risk of flood based on FIRM Map No. 06073 C 0768F
as revised to reflect FEMA Letter of Map Revision 09-09-0276P effective September 8, 2009. However,
the Robertson Ranch Master Plan EIR noted a history of flooding in the Rancho Carlsbad Mobile Home
Park and required construction of detention basins and modification to the Calavera Creek stream bed to
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ROBERTSON RANCH PLANNING AREA 22
reduce flooding in the Rancho Carlsbad Mobile Home Park. The project will not place any structures
within the 100-year flood hazard area, which would impede or redirect flood flows, and it will not expose
people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a
result of the failure of a levee or dam, or as a result of inundation by seiche, tsunami, or mudflow.
k) Less Than Significant Impact. Federal, State and local agencies have established goals and
objectives for storm water quality in the region. The proposed project is considered a priority project as
defined in Order No. 2007-01 by the San Diego Region of the California Water Quality Control Board.
As a result, the project is subject to state requirements for water quality standards. In addition, prior to
the start of construction activities, the project will be required to comply with all Federal, State and local
permits, including the Storm Water Management Plan (SWMP) required under the County of San Diego
Watershed Protection Ordinance.
The project applicant has'prepared a SWMP for the proposed project. The purpose of this SWMP is to
address the water quality impacts from the proposed improvements. The SWMP includes guidelines in
developing and implementing post-construction Best Management Practices (BMPs). The project is
required to adhere to all applicable Regional Water Quality Control Board (RWQCB) regulations for
control of sedimentation and erosion, and to comply with the National Pollution Elimination Discharge
System (NPDES) requirements and Best Management Practices (BMPs) for water quality.
The anticipated pollutants of concern for the proposed project include heavy metal, organic compounds
(petroleum hydrocarbons), trash and debris, oil and grease, sediment, and nutrients and pesticides from
landscaping. Site design BMPs, source control BMPs, and treatment control BMPs are recommended,
and have been included in the project in order to minimize the potential for significant downstream water
quality impacts from these pollutants.
Structural treatment control BMPs have been included in the project design, including construction of a
vegetated swale, bioretention, storm drain inlet filter inserts, and pervious pavement materials. As a result
of the inclusion of these BMPs into the project design, impacts to water quality resulting from erosion and
other pollutants are considered less than significant.
1-n) No Impact. The proposed project will not increase pollutant discharges, change receiving water
quality during or following construction, and will not increase any pollutant to an already impaired water
body.
o) Less Than Significant Impact. The proposed project will increase the area of impervious surfaces;
however it will not be significantly increased beyond that analyzed in the certified Robertson Ranch
Master Plan EIR. The impervious footprint of the proposed project has been minimized through
increasing the building density, utilizing pervious construction materials on walkways, driveways, and
low traffic areas. A significant area of natural open space has been retained in proposed Lot 4 (PA 23G).
p-q) No Impact. The proposed project will not impact any aquatic, wetland or riparian habitat and will
not exceed applicable surface or groundwater receiving water quality objectives or degradation of
beneficial uses.
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ROBERTSON RANCH PLANNING AREA 22
VIII. LANDUSE AND PLANNING - Would the
project:
a) Physically divide an established community?
b) Conflict with any applicable land use plan,
policy, or regulation of an agency with
jurisdiction over the project (including but not
limited to the general plan, specific plan, local
coastal program, or zoning ordinance) adopted
for the purpose of avoiding or mitigating an
environmental effect?
c) Conflict with any applicable habitat
conservation plan or natural community
conservation plan?
Potentially
Significant
Impact
D
Potentially
Significant
Unless
Mitigation
Incorporated
D
D
Less Than
Significant No
Impact Impact
D
a) No Impact. Development of the subject project will not physically divide an established community.
No impact is assessed.
b) Less Than Significant Impact. The proposed project involves a General Plan Amendment which
would modify the allowable land uses on the subject site from Unplanned Area (UA) and Residential
Low-Medium Density (RLM, 0-4 du/ac) to Office (O) and Open Space (OS). The Office use would
allow for development of a commercial office, related parking lot, and accessory uses, as well as an RV
storage lot for the benefit of the residents of the Robertson Ranch East and West Villages. The Office (O)
Zone enacts the Office land use category. The project is consistent with the requirements and standards
of the O Zone. These uses are consistent with the urban uses envisioned in the Robertson Ranch Master
Plan. The RV Storage facility is a requirement of that plan and has been designed in accordance with the
development standards outlined within. The proposed uses are identified in the City's General Plan as
desired urban uses.
The Robertson Ranch Master Plan EIR included an analysis of then-proposed residential development
compatibility with the adjacent Rancho Carlsbad Mobile Home Park project. The proposed PA 22 office
building and RV storage lot maintains the setbacks, grades and general quality and standards that were
identified in the EIR to mitigate potential land use compatibility impacts to the Rancho Carlsbad Mobile
Home Park project. Furthermore, as discussed throughout this Environmental Assessment, the proposed
office building and RV storage lot has been designed or conditioned to include measures (i.e.,
landscaping, noise control, etc.) to mitigate any potential land use compatibility impacts of development.
Therefore, the proposed project does not result in a significant impact to Planning and Land Use policy
compliance.
c) No Impact. The proposed project does not conflict with any habitat conservation plans or natural
community conservation plan policies. No impact is assessed.
24 Rev. 10/02/09
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ROBERTSON RANCH PLANNING AREA 22
X. MINERAL RESOURCES - Would the project:
a) Result in the loss of availability of a known
mineral resource that would be of future value
to the region and the residents of the State?
b) Result in the loss of availability of a locally
important mineral resource recovery site
delineated on a local general plan, specific
plan, or other land use plan?
Potentially
Significant
Impact
D
D
Potentially
Significant
Unless
Mitigation
Incorporated
n
Less Than
Significant No
Impact Impact
n
n
a-b) No Impact. There is no indication that the subject property contains any known mineral resources
that would be of future value to the region or the residents of the state. The subject site is not delineated
on a local or regional plan as containing significant mineral resources. No impact is assessed.
XI. NOISE - Would the project result in:
a) Exposure of persons to or generation of noise
levels in excess of standards established in the
local general plan or noise ordinance or
applicable standards of other agencies?
b) Exposure of persons to or generation of
excessive groundbourne vibration or
groundbourne noise levels?
c) A substantial permanent increase in ambient
noise levels in the project vicinity above
levels existing without the project?
d) A substantial temporary or periodic increase
in ambient noise levels in the project vicinity
above levels existing without the project?
e) For a project located within an airport land use
plan or, where such a plan has not been
adopted, within 2 miles of a public airport or
public use airport, would the project expose
people residing or working in the project area
to excessive noise levels?
Potentially
Significant
Impact
n
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant No
Impact Impact
n n
n
n
n
n
n
D n
n
25 Rev. 10/02/09
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ROBERTSON RANCH PLANNING AREA 22
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
f) For a project within the vicinity of a private
airstrip, would the project expose people
residing or working in the project area to
excessive noise levels?
a, c, & d) Potentially Significant Unless Mitigation Incorporated. An acoustical analysis was
prepared for the proposed project by Urban Crossroads (Robertson Ranch PA 22 - Office Building
Analysis, October 5, 2009, JN: 06679-06) in order to determine compatibility with the City of Carlsbad's
Noise Guidelines Manual. The report identifies vehicle noise from Cannon Road as the primary noise
source within the vicinity of the project site. It is estimated that each of the three floors of the proposed
office building would experience worse-case unmitigated exterior noise levels as high as 68.3 dBA
CNEL. The design of the proposed office building will be required to provide a minimum noise
reduction of 13.3 dBA CNEL in order to comply with the City's interior Leg(h) standard of 55 dBA
CNEL. In order to meet the City of Carlsbad interior noise standard of 55 dBA CNEL and to reduce exterior
traffic noise impacts to level that is considered to be less than significant, the proposed office building will
need to provide the following:
• standard dual-glazed windows with a minimum Sound Transmission Class (STC) rating 26 for all
first, second and third floor windows;
• all window and door assemblies used throughout the project shall be free of cut outs and openings
and shall be well fitted and well weather-stripped;
• provide a windows closed condition requiring a means of mechanical ventilation for all units to meet
the City and/or Uniform Building Code (UBC) requirements stating that in lieu of exterior openings
for natural ventilation, a mechanical ventilating system shall be provided (i.e., air conditioning).
Such a system shall be capable of providing two air changes per hour with minimum outside fresh air
requirements; and
• Provide exterior walls with a minimum Sound Transmission Class (STC) rating of 46. Typical walls
with this rating will have 2x4 studs or greater, 16" o.c. with R-13 insulation, a minimum 7/8"
exterior surface of cement plaster and a minimum interior surface of 1/2" gypsum board. Masonry
block or concrete tip-up assemblies will perform better than the above described wood assembly and
would be an acceptable alternative.
No additional interior noise mitigation is required to meet the City of Carlsbad 55 dBA CNEL interior noise
standards.
In addition to the above, the proposed office building is proposing a ground mounted mechanical
equipment enclosure on the south side of the building. The nearest noise sensitive areas to the project are
the existing single-family residential land uses (Rancho Carlsbad Mobile Home Park) to the south of the
project site. According to the report, noise levels were assessed at the residences during nighttime hours
(considered the worst-case scenario) in order to determine any potential operational noise impacts from
the mechanical equipment.
Calculations were completed to assess the nighttime noise level impacts from the proposed project to the
residents located in the single-family residences to the south. As the ground mounted mechanical
equipment enclosure is designed, with the louvers facing the eastern and/or western property lines and the
26 Rev. 10/02/09
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ROBERTSON RANCH PLANNING AREA 22
wall heights extending at least one (1) foot in height above the proposed mechanical equipment that is
enclosed within, it is concluded that nighttime noise level projection is expected to be 42.7 dBA Leq at the
nearest residential noise sensitive use located approximately 215 feet to the south.
It should be noted that the City of Carlsbad Noise Guidelines manual does not include a quantitative
threshold for operational noise levels from fixed "point" noise sources. Instead, the City determines if the
proposed use is compatible with the existing surrounding land uses based upon the results of an acoustical
assessment. According to the acoustical analysis that was prepared for the project, the 42.7 dBA Leq
noise level is below both the City's exterior 60 dBA CNEL and interior 45 dBA CNEL requirements for
residential land uses. Because CNEL is used only for determining mobile noise sources over a 24 hour
period, the acoustical report identified that the one hour Leq is a more appropriate and restrictive
standard.
By comparison, the anticipated property line noise level is also below the most restrictive residential property
line threshold established by the County of San Diego of 45 dBA Leq during the nighttime hours. Therefore,
as designed no impacts are anticipated from the proposed mechanical equipment. Furthermore, it should be
noted that this analysis did not take into account the additional noise level reductions from the existing 6 ft.
tall masonry wall located at the boundary of the Rancho Carlsbad Mobile Home Park, or the proposed 6 ft.
tall masonry wall that is proposed at the top of slope between theses residences and the proposed noise
sources. These two (2) walls will further reduce the noise levels below 40 dBA Leq, which is similar to the
existing nighttime ambient conditions. Therefore, through the implementation of these mitigation
measures, impacts from noise are reduced to a less than significant level.
b) No Impact. The uses associated with the proposed project are general office and RV storage. These
uses will not expose people to excessive groundbourne vibration or excessive groundbourne noise levels.
No impact is assessed.
e) No impact. The subject site is located within 2 miles of McClellan-Palomar Airport. However, the
project site is located outside of the Airport Influence Area, Flight Activity Zone, and the Runway
Protection Zone, which are established by the Airport Land Use Compatibility Plan for McClellan-
Palomar Airport. As such, the project will not expose people working in the project area to excessive
noise levels. No impact is assessed.
f) No Impact. The subject site is not located adjacent to or within the vicinity of a private airstrip for
which the project would expose people residing or working in the project area to excessive noise levels.
No impact is assessed.
XII. POPULATION AND HOUSING - Would the
project:
a) Induce substantial growth in an area either
directly (for example, by proposing new
homes and businesses) or indirectly (for
example, through extension of roads or other
infrastructure)?
Potentially
Significant
Impact
D
Potentially
Significant
Unless
Mitigation
Incorporated
D
Less Than
Significant No
Impact Impact
27 Rev. 10/02/09
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ROBERTSON RANCH PLANNING AREA 22
b) Displace substantial numbers of existing
housing, necessitating the construction of
replacement housing elsewhere?
c) Displace substantial numbers of people,
necessitating the construction of replacement
housing elsewhere?
Potentially
Significant
Impact
G
Potentially
Significant
Unless
Mitigation
Incorporated
D
Less Than
Significant
Impact
D
No
Impact
m
D D D
a-c) No Impact. Development of the proposed project will not induce substantial growth in the area,
either directly or indirectly. No major infrastructure facilities are proposed for extension to serve this
project. The proposed office and RV storage use will not substantially induce growth. The subject site is
currently undeveloped and therefore no existing housing or people will be displaced. A portion of the
subject site has previously [per the approved Robertson Ranch Master Plan] been identified as a potential
site for temporary or permanent RV Storage for the East and West Village of Robertson Ranch. With the
addition of the western edge of the "Option Parcel", sufficient area is present to support both uses. The
office development does not result in a take of sensitive natural resources and is consistent with the other
approved uses within the Robertson Ranch Master Plan. No impact is assessed.
Potentially
Significant
Impact
XIII. PUBLIC SERVICES
a) Would the project result in substantial adverse
physical impacts associated with the provision
of new or physically altered government
facilities, a need for new or physically altered
government facilities, the construction of
which could cause significant environmental
impacts, in order to maintain acceptable
service ratios, response times, or other
performance objectives for any of the public
services:
i) Fire protection?
ii) Police protection?
iii) Schools?
iv) Parks?
v) Other public facilities?
Potentially
Significant
Unless
Mitigation
Incorporated
D
D
D
D
D
D
Less Than
Significant No
Impact Impact
D
D
D
D
D
28 Rev. 10/02/09
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ROBERTSON RANCH PLANNING AREA 22
a.i.-a.v.) No Impact. The Robertson Ranch Master Plan EIR concluded that the overall impacts to public
facilities and service systems were not significant provided that all the appropriate agency conditions for
development are met including payment of public facilities fees. The addition of the office development
does not represent a significant increase in development area and therefore no additional mitigation
measures are required. No impact is assessed.
XIII. RECREATION
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial
physical deterioration of the facility would
occur or be accelerated?
b) Does the project include recreational facilities
or require the construction or expansion of
recreational facilities, which might have an
adverse physical effect on the environment?
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant No
Impact Impact
D
D
a-b) No impact. Development of the proposed office and RV Storage facility will not result in the
deterioration of existing neighborhood or regional parks or cause such parks to be expanded. The
Robertson Ranch Master Plan does include a city park site. The Robertson Ranch Master Plan EIR
analyzed recreation demand for 20 residential units on PA 22. Per the Carlsbad Parks and Recreation
Element of the General Plan, residential units generate demand for recreational facilities. Office uses are
determined to generate a much smaller recreation facility obligation. Thus, the proposed office
development will not contribute a significant increase in park users beyond that which was originally
anticipated. No impact is assessed.
XV. TRANSPORTATION/TRAFFIC - Would the
project:
a) Cause an increase in traffic, which is substantial
in relation to the existing traffic load and
capacity of the street system (i.e., result in a
substantial increase in either the number of
vehicle trips, the volume to capacity ratio on
roads, or congestion at intersections)?
b) Exceed, either individually or cumulatively, a
level of service standard established by the
county congestion management agency for
designated roads or highways?
Potentially
Significant
Potentially Unless
Significant Mitigation
Impact Incorporated
D
Less Than
Significant No
Impact Impact
D D D
29 Rev. 10/02/09
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ROBERTSON RANCH PLANNING AREA 22
c) Result in a change in air traffic patterns,
including either an increase in traffic levels or a
change in location that results in substantial
safety risks?
d) Substantially increase hazards due to a design
feature (e.g., sharp curves or dangerous
intersections) or incompatible uses.(e.g., farm
equipment)?
e) Result in inadequate emergency access?
f) Result in insufficient parking capacity?
g) Conflict with adopted policies, plans, or
programs supporting alternative transportation
(e.g., bus turn-outs, bicycle racks)?
Potentially
Significant
Impact
D
Potentially
Significant
Unless
Mitigation
Incorporated
D
Less Than
Significant
Impact
No
Impact
D D D
D D D
a-b) Less Than Significant Impact. A traffic impact analysis, Robertson Ranch PA 22 Traffic Study, by
Urban Systems dated December 15, 2009 and later updated on September 2, 2009, has been prepared for
the subject project. This analysis, as illustrated in the following tables, concludes that the proposed
project (66,000 square foot office building and RV storage lot) will generate 1,320 Average Daily Trips
(ADT) and 216 peak hour trips. This traffic will utilize Cannon Road, College Boulevard, Tamarack
Avenue and El Camino Real. The Robertson Ranch Master Plan EIR analysis anticipated 160 ADT from
20 residential courtyard units that were originally proposed on PA 22. Also, two other planning areas
within Robertson Ranch have since been restricted to a lower number of units than was originally
assumed and addressed in the EIR analysis. These planning areas are PA 13 and PA 14. The EIR
assumed multi-family residential development on both of these planning areas, and the adopted Master
Plan ultimately restricted them to single-family development. A comparison of these assessments are
described below:
Traffic Generation - Certified EIR Analysis
PA
13
14
22
Use
Multi-Family
Multi-Family
Courtyard Homes
TOTAL
ADT
828
414
160
1,402
AM Peak Hour
66
33
13
112
PM Peak Hour
75
37
16
128
Traffic Generation - Proposed PA 22 Project with Recent Land Use Changes
PA
13
14
22
Use
Single-Family
Single-Family
Office
TOTAL
ADT
230
160
1,320
1,710
AM Peak Hour
18
13
185
216
PM Peak Hour
23
16
172
211
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ROBERTSON RANCH PLANNING AREA 22
Net New ADT Generated
Proposed PA 22 project .
Certified EIR
TOTAL (net difference)
ADT
1,710
1,402
•308
AM Peak Hour
216
112
104
PM Peak Hour
211
128
83
Existing traffic (plus the proposed project) on impacted intersections and street segments are shown on
the following tables.
Existing plus Proposed Project - Intersections
Intersection
El Camino Real/Tamarack
Ave.
El Camino Real/Cannon
Road
Cannon Road/PA 22
Driveway
Existing
AM
ICU
0.67
0.59
NA
LOS
B
A
NA
PM
ICU
0.55
0.72
NA
LOS
A
C
NA
Existing plus Project
AM
ICU^
0.68
0.60
0.37
LOS
B
A
A
PM
ICU
0.56
0.74
0.49
LOS
B
C
A
Existing plus Proposed Project - Street Segments
Street Segment
El Camino Real (Tamarack-
Cannon)
El Camino Real (Cannon So. of)
Cannon Road (ECR South of)
Cannon Road (ECR West of)
Existing plus Project
AM
VOL
858
1,060
337
. 527
V/C
0.48
0.59
0.19
0.29
LOS
A
A
A
A
PM
VOL
874
1,124
381
613
V/C
0.49
0.62
0.21
0.34
LOS
A
B
A
A
Year 2030 conditions for the intersections and street segments including the proposed project are as
follows:
Year 2030 with Proposed Project - Intersections
Intersection
El Camino Real/Tamarack
Ave.
El Camino Real/Cannon
Road
Cannon Road/PA 22
Driveway
Cannon Road/College Blvd.
Existing
AM
ICU
49.7
49.8
12.3
34.1
LOS
D
D
B
C
PM
ICU
50.7
48.0
10.1
38.3
LOS
D
D
B
D
Existing plus Project
AM
ICU
53.3
47.6
11.5
34.5
LOS
D
D
B
C
PM
ICU
51.4
48.0
10.5
39.0
LOS
D
D
B
D
31 Rev. 10/02/09
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ROBERTSON RANCH PLANNING AREA 22
Year 2030 with Proposed Project - Street Segments
Street Segment
El Camino Real (Tamarack-
Cannon)
El Camino Real (Cannon So. of)
Cannon Road (ECR South of)
Cannon Road (ECR West of)
Existing plus Project
AM
VOL
902
857
685
823
V/C
0.50
0.48
0.38
0.48
LOS
A
A
A
A
PM
VOL
805
812
665
779
V/C
0.45
0.45
0.37
0.43
LOS
A
A
A
A
Thus, it is concluded that while the increase in traffic from the proposed PA 22 project may be slightly
noticeable, the street system has been designed and sized to accommodate traffic from the project and
cumulative development in the City of Carlsbad. Therefore, the proposed project would not cause an
increase in traffic that is substantial in relation to the existing traffic load and capacity of the street
system. The impacts from the proposed project are considered to be less than significant.
b) Less Than Significant Impact. SANDAG acting as the County Congestion Management Agency has
designated three roads (Rancho Santa Fe Rd., El Camino Real and Palomar Airport Rd.) and one highway
segment in Carlsbad as part of the regional circulation system. The existing LOS on these designated
roads and highway in Carlsbad is:
Rancho Santa Fe Road
El Camino Real
Palomar Airport Road
SR78
LOS
"A-D"
"A-D"
"A-D"
The Congestion Management Program's (CMP) acceptable Level of Service (LOS) standard is "E", or
LOS "F" if that was the LOS in the 1990 base year (e.g., SR 78 in Carlsbad was LOS "F" in 1990).
Accordingly, all designated roads and highway 78 is currently operating at or better than the acceptable
standard LOS.
Achievement of the CMP acceptable Level of Service (LOS) "E" standard assumes implementation of the
adopted CMP strategies. Based on the design capacity(ies) of the designated roads and highway and
implementation of the CMP strategies, they will function at acceptable level(s) of service in the short-
term and at buildout.
c) No Impact. The proposed project does not include any aviation components. The project is consistent
with the Airport Land Use Compatibility Plan for McClellan-Palomar Airport. Therefore, it will not
result in a change of air traffic patterns or result in substantial safety risks. No impact is assessed.
d) No Impact. All project circulation improvements will be designed and constructed
and thus will not result in design hazards. No impact is assessed.
e) No Impact. The proposed project has been designed to satisfy the emergency requirements of the Fire
and Police Departments. No impact is assessed.
f) No Impact. The proposed project is not requesting a parking variance. Additionally, the project would
comply with the City's parking requirements to ensure an adequate parking supply. No impact is
assessed.
per City standards;
32 Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(B>cT 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
g) No Impact. The project site is located adjacent to circulation element roadways which accommodate
public transportation. No conflict with adopted policies or standards will result from implementation of
the project. No impact is assessed.
XVI. UTILITIES AND SERVICES SYSTEMS -
Would the project:
a) Exceed wastewater treatment requirements of
the applicable Regional Water Quality Control
Board?
b) Require or result in the construction of new
water or wastewater treatment facilities or
expansion of existing facilities, the
construction of which would cause significant
environmental effects?
c) Require or result in the construction of new
storm water drainage facilities or expansion of
existing facilities, the construction of which
could cause significant environmental effects?
d) Have sufficient water supplies available to
serve the project from existing entitlements
and resources, or are new or expanded
entitlements needed?
e) Result in a determination by the wastewater
treatment provider, which serves or may serve
the project that it has adequate capacity to
serve the project's projected demand in
addition to the provider's existing
commitments?
f) Be served by a landfill with sufficient
permitted capacity to accommodate the
project's solid waste disposal needs?
g) Comply with federal, state, and local statutes
and regulations related to solid waste?
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
D D
Less Than
Significant No
Impact Impact
D
D d D
D
D
D
D
D
D
D
a-g) No Impact. The Robertson Ranch Master Plan EIR concluded that overall impacts to public
facilities and service systems were not significant provided that the appropriate agency conditions for
development are met, including payment of public facilities fees. No impact is assessed.
33 Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(B>^T 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
XVII. MANDATORY FINDINGS OF
SIGNIFICANCE
a) Does the project have the potential to degrade
the quality of the environment, substantially
reduce the habitat of a fish or wildlife species,
cause a fish or wildlife population to drop
below self-sustaining levels, threaten to
eliminate a plant or animal community, reduce
the number or restrict the range of a rare or
endangered plant or animal or eliminate
important examples of the major periods of
California history or prehistory?
b) Does the project have impacts that are
individually limited, but cumulatively
considerable? ("Cumulatively considerable"
means that the incremental effects of a project
are considerable when viewed in connection
with the effects of past projects, the effects of
other current projects, and the effects of
probable future projects?)
c) Does the project have environmental effects,
which will cause the substantial adverse
effects on human beings, either directly or
indirectly?
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
D
Less Than
Significant No
Impact Impact
D
n
D D D
a) Potentially Significant Impact Unless Mitigation Incorporated. The subject site does not support
any protected or sensitive biological resources or habitat types. Calavera Creek, which is located off site
and to the south, is the nearest sensitive biological resource. The proposed project is not directly
impacting Calavera Creek. Potential indirect impacts are mitigated through the incorporation of a 100-
foot wide buffer made part of proposed site plan, and the requirements of a Storm Water Management
Plan precludes any offsite migration of sediment. However, the project's required mitigation as outlined
in the Cultural Resources section will preclude any elimination of important examples of major periods of
California history or prehistory, thus reducing impacts to less than significant. Therefore, the project will
not reduce the habitat of a fish or wildlife species; will not threaten to eliminate or reduce the number of
endangered plant and animal species; and will not result in the elimination of any important examples of
California history or prehistory.
b) Less Than Significant Impact. San Diego Association of Governments (SANDAG) projects regional
growth for the greater San Diego area and local General Plan land use policies are incorporated into
SANDAG projections. Based upon these projections, region-wide standards, etc., are established to
reduce the cumulative impacts of development in the region. All of the City's development standards and
regulations are consistent with the region wide standards. The City's standards and regulations, including
grading standards, water quality and drainage standards, ensure that development within the City will not
result in a significant cumulatively significant impact.
Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(6,,,, F 09-0I/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
There are two regional issues that developments within the City of Carlsbad have the potential to have a
cumulatively significant impact on. These issues are air quality and regional circulation. As described in
the Robertson Ranch Master Plan EIR, the project will result in an increase in cumulative emissions in the
air basin. However, the increase attributable to Robertson Ranch or this one specific project will not
significantly impact basin wide air quality, which will remain effectively unchanged whether or not the
development is implemented.
The County Congestion Management Agency (CMA) has designated three roads (Rancho Santa Fe Road,
El Camino Real and Palomar Airport Road) and two highway segments in Carlsbad as part of the regional
circulation system. The CMA has determined based on the City's growth projections in the General Plan,
that these designated roadways will function at acceptable levels of service in the short-term and at build-
out. The project is consistent with the City's growth projections, and therefore the cumulative impact
from the project on the regional circulation system is considered less than significant.
c) No Impact. The office building component of trie-project and the future development of the site for
RV storage will comply with City standards, and by design the project will not result in any direct or
indirect significant adverse effects on human beings.
35 Rev. 10/02/09
GPA 09-0i/ZC 09-01/MP 02-03(3,, v,r 09-01 /PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
XVIII. EARLIER ANALYSES
Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA
process, one or more effects have been adequately analyzed in an earlier EIR or negative
declaration. Section 15063(c)(3)(D). In this case a discussion should identify the following on
attached sheets:
a) Earlier analyses used. Identify earlier analyses and state where they are available for
review.
b) Impacts adequately addressed. Identify which effects from the above checklist were
within the scope of and adequately analyzed in an earlier document pursuant to
applicable legal standards, and state whether such effects were addressed by mitigation
measures based on the earlier analysis.
c) Mitigation measures. For effects that are "Less Than Significant with Mitigation
Incorporated," describe the mitigation measures, which were incorporated or refined from
the earlier document and the extent to which they address site-specific conditions for the
project.
36 Rev. 10/02/09
GPA 09-Ol/ZC 09-01/MP 02-03(B,,~r 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
EARLIER ANALYSIS USED AND SUPPORTING INFORMATION SOURCES
The following documents were used in the analysis of this project and are on file in the City of Carlsbad
Planning Department located at 1635 Faraday Avenue, Carlsbad, California, 92008.
1. Final Master Environmental Impact Report for the City of Carlsbad General Plan Update (MEIR
93-01). City of Carlsbad Planning Department. March 1994.
2. Carlsbad General Plan. City of Carlsbad Planning Department, dated March 1994.
3. City of Carlsbad Municipal Code, Title 21 Zoning, City of Carlsbad Planning Department, as
updated.
4. Habitat Management Plan for Natural Communities in the City of Carlsbad. City of Carlsbad
Planning Department, final approval dated November 2004.
5. Robertson Ranch Master Plan Final Environmental Impact Report (EIR 03-03). BRG Consulting,
Inc., San Diego, CA, April 2006 (State Clearing House No. 2004051039).
6. Robertson Ranch Master Plan, BRG Consulting, Inc., San Diego, CA, November 2006.
7. Cultural Resources Survey and Evaluation for the Proposed Robertson Ranch Project. Brian F.
Smith and Associates, San Diego, CA, June 2002.
8. Results of a Data Cultural Resources Mitigation and Monitoring Program for Robertson Ranch.
Brian F. Smith and Associates, November 26, 2008.
9. Preliminary Biological Assessment Robertson Ranch PA 22. Planning Systems, Carlsbad, CA,
August 10,2009.
10. Report of Rough Grading Planning Area 22 of Robertson Ranch. East Village (W.O. 5353-B1-
SC], GeoSoils, Inc., March 6, 2009
11. Updated Geotechnical Evaluation of the Robertson Ranch Property, GeoSoils, Inc. Carlsbad, CA
September 2004.
12. Robertson Ranch PA 22 - Office Building Noise Analysis (JN:Q6679-06). Urban Crossroads,
October 5, 2009.
13. Airport Land Use Compatibility Plan for McClellan Palomar Airport, Carlsbad. California. San
Diego County Regional Airport Authority, as amended October 4, 2004.
14. Preliminary Storm Water Management Plan for Robertson Ranch PA 22 (JN: 011014-5). O'Day
Consultants, Carlsbad, CA, April 14, 2009.
15. Preliminary Drainage Study for the Robertson Ranch PA 22 (JN: 011014-5). O'Day Consultants,
Carlsbad, CA, April 14, 2009.
16. Robertson Ranch PA 22 Traffic Study. Urban Systems, dated December 15, 2008 and updated
September 2, 2009.
37 Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(B>^r 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
LIST OF MITIGATING MEASURES (IF APPLICABLE)
1. Archeological mitigation measures shall be implemented as follows:
a. Prior to the issuance of a grading permit or a building permit, whichever occurs first, the
developer shall enter into a pre-excavation agreement with a representative of the San Luis Rey
Band of Mission Indians. The purpose of this agreement will be to establish the requirement of
tribal monitoring and to formalize procedures for the treatment of Native American human
remains and burial, ceremonial, or cultural items that may be uncovered during any ground
disturbance activities.
b. Prior to issuance of a grading permit or building permits, whichever occurs first, the project
developer shall retain the services of a qualified archeologist to monitor all grading and
excavation activities, including utility trenching, etc. The applicant shall provide verification that
a qualified archeologist has been retained, and verification shall be documented by a letter from
the applicant and the archeologist to the Planning Director.
c. A qualified archeologist shall be present at the pre-construction meeting to consult with the
grading and excavation contractors.
d. In the event that any cultural resources, concentration of artifacts, or culturally modified soil
deposits are discovered within the project area at any time during construction, the archeological
monitor shall be empowered to suspend work in the immediate area of the discovery until such
time as a data recovery plan can be developed and implemented.
e. The discovery of any resource shall be reported to the City of Carlsbad Planning Director prior to
any evaluation testing.
f. If any deposits are evaluated as significant under CEQA, mitigation may be required as
recommended by the qualified archeologist.
2. Paleontological mitigation measures shall be implemented as follows:
a. Prior to issuance of a grading permit the project developer shall retain a qualified paleontologist
to carry out the mitigation program outlined here. (A qualified paleontologist is defined as an
individual with a MS or Ph.D. in paleontology or geology that is familiar with paleontological
procedures and techniques.) The applicant shall provide verification that a qualified
paleontologist has been retained, and verification shall be documented by a letter from the
applicant and the paleontologist to the Planning Director.
b. A qualified paleontologist shall be present at a pre-construction meeting to consult with the
grading and excavation contractors.
c. A paleontological monitor shall be onsite at all times during grading and excavation activities,
including utility trenching, etc. (A paleontological monitor is defined as an individual who has
experience in the collection and salvage of fossil materials. The paleontological monitor shall
. work under the direction of a qualified paleontologist.)
d. When fossils are discovered, the paleontologist (or paleontological monitor) shall recover them.
In most cases this fossil salvage can be completed in a short period of time. However, some
fossil specimens (such as a complete large mammal skeleton) may require an extended salvage
38 Rev. 10/02/09
GPA 09-01/ZC 09-01/MP 02-03(B')/wT 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANNING AREA 22
period. In these instances the paleontologist (or paleontological monitor) shall be allowed to
temporarily direct, divert, or halt grading to allow recovery of fossil remains in a timely manner.
Due to the small nature of some fossils it may be necessary to collect matrix samples for
processing through fine mesh screens.
e. Any fossils collected shall be prepared to the point of identification and properly curated before
they are donated to their final repository.
f. Prepared fossils, along with copies of all pertinent field notes, photos, and maps, shall be
deposited (as a donation) in a non-profit institution with a research interest in the materials, such
as the San Diego Natural History Museum.
g. A final summary report shall be completed that outlines the results of the mitigation program.
This report shall include discussions of the methods used, stratigraphic section(s) exposed, fossils
collected, and significance of recovered fossils.
3. To reduce exterior traffic noise impacts and to meet the City of Carlsbad interior noise standard of
55 dBA CNEL for the office building, the final building plans shall reflect the following
construction requirements prior to issuance of the building permit:
a. Provide standard dual-glazed windows with a minimum Sound Transmission Class (STC)
rating 26 for all first, second and third floor windows.
b. All windows and door assemblies used throughout the office building shall be free of cut-outs
and openings and shall be well-fitted and well weather-stripped.
c. Provide a windows closed condition requiring a means of mechanical ventilation which shall
meet the City and/or Uniform Building Code (UBC) requirements stating that in lieu of
exterior openings for natural ventilation, a mechanical ventilating system shall be provided
(i.e., air conditioning). Such a system shall be capable of providing two air changes per hour
with minimum outside fresh air requirements.
d. Provide exterior walls with a minimum Sound Transmission Class (STC) rating of 46.
Typical walls with this rating will have 2x4 studs or greater, 16" o.c. with R-13 insulation, a
minim W exterior surface of cement plaster and a minimum interior surface of '/21' gypsum
board. Masonry block or concrete tip-up assemblies will perform better than the above
described wood assembly and would be an acceptable alternative.
4. Any louvers required for venting the ground mounted mechanical equipment enclosure shall not
be located on any portion of the south elevation facing the Rancho Carlsbad residences. The final
building plans shall reflect this requirement prior to the issuance of a building permit for this
facility.
5. The wall height of the ground mounted mechanical equipment enclosure shall at a minimum
extend at least one (1) foot above the surface height of the mechanical equipment housed within.
The final building plans shall reflect this requirement prior to the issuance of a building permit for
this facility.
39 Rev. 10/02/09
GPA 09-Ol/ZC 09-Oi/MP 02-03(B)/CT 09-01/PUD 09-01/SDP 09-01
ROBERTSON RANCH PLANMNG AREA 22
A PPL 1C ANT CONCURRENCE WITH MITIGATION MEASURES
THIS IS TO CERTIFY THAT I HAVE REVIEWED THE ABOVE MITIGATING MEASURES AND
CONCUR WITH THE ADDITION OF THESE MEASURES TO THE PROJECT.
Date Signature
40 Rev. 10/02/09
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City of Carlsbad
Planning Department
November 25, 2009
Diane Nygaard
Preserve Calavera
5020 Nighthawk Way
Oceanside, CA 92056
SUBJECT: RESPONSE TO PRESERVE CALAVERA COMMENTS
ROBERTSON RANCH PA 22 - MITIGATED NEGATIVE DECLARATION
Dear Ms. Nygaard,
Thank you for your comments dated November 9, 2009 pertaining to the Mitigated Negative Declaration
(MND) that was prepared for the proposed Robertson Ranch PA 22 project. The project area is generally
located in Planning Area 22 of the Robertson Ranch Master Plan and the adjacent property referred to in
the Master Plan as the "Option Parcel" at the southeast corner of the intersection of Wind Trail Way and
Cannon Road in the City of Carlsbad, California (APN168-0-50-55 & 168-360-03). '
We have subdivided your letter into the four issue areas (i.e., Land Use, Biological Resources, Hydrology
& Water, and Traffic), which are identified below in italic text followed by staffs response.
Land Use
- The proposed land use is not longer required.
The RV parking lot is identified as a requirement for the residential development approved in the east and
west villages of Robertson Ranch. Shortly after approval of the project Master Plan the City changed
their ordinance and eliminated the requirements for R ¥ parking with residential development. This
change was made in recognition that such a mandate no longer serves a public purpose - and in fact is
damaging to the watershed by creating excessive areas for vehicle parking, is a poor use of valuable
coastal land, and there is a reduced demand for such parking.
Please clarify - is the city still forcing this land use on the developer based on the now obsolete
ordinance - or is this developer just so backward that they think it makes sense to park RV's next to a
creek in an area with a history offloading?
RESPONSE: The size of the proposed Planning Area 22 Recreational Vehicle (RV) storage lot is the
minimum size necessary to accommodate the projected build out of both the East and West Villages of
the Robertson Ranch Master Plan as calculated per the newly-adopted RV storage requirements of the
Carlsbad Municipal Code (C.M.C.) Chapter 21.45 - Planned Developments. These new requirements for
residential developments did not eliminate the requirement for RV storage as mentioned in your letter, but
rather eliminated the requirement for rental apartment projects, standard single-family lots, and projects
located within the RMH and RH General Plan land use designations. Medium-density projects with 100
or more units, or in a master or specific plan with 100 or more planned development units are still subject
1635 Faraday Avenue • Carlsbad, CA 92008-7314 • (760) 602-4600 • FAX (760) 602-8559 • www.ci.carlsbad.ca.us
RESPONSE REGARDING ROBERTSON RANCH PA 22 MND
November 25, 2009
Page 2
to the requirement to provide RV storage. Robertson Ranch is a Master Plan with an excess of 100 units,
in which nine of the planning areas (i.e., PA 1,3, 6, 10, 13, 14, 16, 17, and 18) are approved for
residential uses at medium densities. Therefore, the Robertson Ranch Master Plan continues to be subject
to a RV storage requirement. Of the total project dwelling units within Robertson Ranch, a maximum of
320 are located within the East Village (PA 14, 16, 17, and 18), and 232 are located within the West
Village (1, 3, 6, 10, and 13), resulting in a maximum requirement of 11,040 square feet of RV storage,
excluding drive aisles. The proposed RV storage lot is providing 11,667 square feet, which will be
available to both the East and West Villages and will accommodate the Master Plan's requirement to
provide RV storage.
Biological Resources
- Insufficient discussion and adequacy of creek buffer.
The Bio Resources report and checklist discussion states that the project has provided the required 100'
creek buffer. However the drawings indicate that part of this buffer is within the development footprint
fence and on slopes that are proposed for "naturalizing" plantings and not_ actual wetlands buffer plants.
Furthermore the description of the buffer states it is from the "creek channel." Buffers are properly
measured from the top of creek bank. It is not clear from this description if that is what was used to
measure the buffer.
Please clarify that the 100' buffer is measured from top of bank.
Buffers behind fences and vegetated with plants not appropriate for the area reduces the functional value
of the buffer. At least the full buffer minimum width of 100' should be provided without obstructions and
with plants that support the intended wetlands and wildlife movement corridor functions.
Please provide further discussion of the adequacy of the buffer for all of the intended purposes and assure
that the buffer does not include floodw alls, fences or other barriers and that all proposed plant material
within the buffer is appropriate for this location.
RESPONSE: The majority of the project site presently exists in a partially developed state, having
already been rough graded pursuant to the mass grading plans approved for the Robertson Ranch East
Village Master Tentative Map (CT 02-16) and analyzed by the Robertson Ranch Master Plan
Environmental Impact Report (EIR 03-03). Other portions of the project site exist as previously farmed
land; eucalyptus woodland; underground pipelines belonging to C.M.W.D. with easements measuring
between 20 and 30 feet in width; a paved access road with access easement measuring 60 feet in width;
and an existing six-foot tall masonry security wall running adjacent to the entire southern property line
and belonging to Rancho Carlsbad Estates. The initial grading of the site provided a 100-foot buffer from
Calavera Creek, except in areas where a buffer of a lesser width was previously approved by the Wildlife
Agencies near the main project entrance at Wind Trail Way and Cannon Road. The approved grading
plans for the Robertson Ranch East Village Master Tentative Map (CT 02-16) measured the 100-foot
wide buffer from the northern edge of the creek channel to the closest point of development (i.e., toe of
slope). At the transition of where the newly proposed pad area will extend east beyond the existing pad,
this same measurement for the 100-foot buffer is being followed for approximately 25 lineal feet before
the creek channel and the toe of the newly proposed slope veer away from each other providing for a
buffer that is > 100 feet.
RESPONSE REGARDING ROBERTSON RANCH PA 22 MND
November 25, 2009
Page 3
The Preliminary Biological Assessment that was prepared for the project and referenced in the MND
concluded that this portion of Calavera Creek primarily constitutes a drainage channel within an urban
environment. According to the Preliminary Biological Assessment, the open water found in the creek
bottom of this off-site creek channel does not support any wetland species typically associated with a
freshwater stream. Winter rains scour the channel bottom periodically keeping it free of vegetation. In
addition, the banks of the channel are surrounded entirely by existing urban land uses, some of which
provide no substantive buffer at all along the south side of the channel, inasmuch as existing residences
and their rear yards and porches are situated within five feet of the top of channel slope. Furthermore,
exotic species planted and maintained as ornamental landscaping covers the sides of the channel which •
are routinely maintained and managed by the Rancho Carlsbad Estates Home Owners Association. Also,
as indicated in the MND and mentioned above, an existing 6-foot tall masonry block security wall for
Rancho Carlsbad Estates exists along the entire length of the property [and much farther in both
directions] through the middle of the buffer which separates the project from the creek channel. In
addition to this wall, the area of buffer is entirely encumbered by easements for existing pipelines for
C.M.W.D. and a paved access road. These existing circumstances render the subject creek area as a less-
than-ideal circumstance for habitat linkage or wildlife movement. Furthermore, the Carlsbad Habitat
Management Plan (HMP) does not identify any wildlife corridors through the project area or within the
adjacent properties. As a result of these factors, as well as the minimal or lack thereof of any buffers on
the south side, the Preliminary Biological Assessment concluded that the channel represents a marginally
viable east to west movement corridor for mammals and reptiles. Nonetheless, as indicated above, the
existing and proposed grading provides the necessary 100-foot wetland buffer (with exception to the
reduced buffer that was previously allowed by the Wildlife Agencies), which does help to further support
any possibility of an east-west corridor. The MND and Preliminary Biological'Assessment were
reviewed by the United States Fish & Wildlife Service (USFWS) and the California Department of Fish
& Game (CDF&G). A response of "no comment" was received from the USFWS on November 19,
2009, and no comments were received from the CDF&G.
- Inadequate mitigation for CSS impacts
On page 34 it is stated that there is some disturbed Coastal Sage Scrub (CSS) planted on Cannon Road
right-of-way but since it is disturbed it is no longer considered sensitive and no mitigation is required.
We find it hard to believe that in this area of relatively new road construction that CSS would have been
planted if it was not required - and if it was required then: 1. It should have been properly restored and
not be classified as "disturbed" and 2. Impacts to required mitigation does not result in reduced
mitigation requirements - it increases the mitigation requirement to 5:1.
Please provide further documentation for the creation, and condition of this CSS and include full
mitigation for impacts to sensitive CSS habitat.
RESPONSE: The MND indicates that the Cannon Road slopes contain 0.34 acres of revegetated CSS,
which according to the Preliminary Biological Assessment is identified as an immature, not yet
established community existing in a disturbed state due to the installation of eucalyptus as a community
component. This hybrid community was indeed sprayed/planted on the slope as a drought tolerant
erosion control mix, and was not required as an element of any mitigation program.
This hybrid CSS community exists on a 2:1 slope below an existing 6-foot tall masonry noise wall that is
supporting the existing Cannon Road Reach 3. Cannon Road Reach 3 was graded and landscaped as
required for Calavera Hills Phase II, which was required to have a secondary access. Calavera Hills
Phase II was the subject of the Calavera Hills Master Plan Phase II, Bridge and Thoroughfare District No.
RESPONSE REGARDING ROBERTSON RANCH PA 22 MND
November 25, 2009
Page 4
4 and Detention Basin EIR (EIR 98-02). The CSS restoration mitigation requirement for the entire
project was 2.4 acres of CSS restoration. The amount of CSS restoration is small because the project also
purchased the Calavera Nature Preserve, and also dedicated a significant amount of existing CSS on-site
in Calavera Hills. Review of the Calavera Hills Phase II CSS Restoration Program shows that the
location of the required 2.4 acres of CSS restoration occurred on the Calavera Hills Phase II graded fill
slopes and was not required on any portion of the Cannon Road slopes. Restoration occurred in three
locations within Calavera Hills, and is not along the slopes adjacent to Cannon Road nor is it adjacent to
subject project under consideration. The hybrid CSS/eucalyptus habitat was hydroseeded on the PA 22
slope when Cannon Road and the existing noise wall were constructed for the benefit of Rancho Carlsbad
Estates in 2003-04. The CSS seeds were included in the hydroseed mix as a drought-tolerant erosion
control mix, and were not a mitigation requirement. Impacts to this vegetation are determined not to be a
significant biological impact, and payment of a mitigation in-lieu fee for unoccupied CSS is typically
required as a condition of approval. The following condition is included as part the Planning Commission
Resolution associated with the recommended approval of the Tentative Tract Map (CT 09-01):
This project has been found to result in impacts to wildlife habitat or other lands, such as
agricultural land, non-native grassland, and disturbed lands, which provide some benefits to
wildlife, as documented in the City's Habitat Management Plan and the environmental analysis
for this project. Developer is aware that the City has adopted an In-lieu Mitigation Fee consistent
with Section E.6 of the Habitat Management Plan and City Council Resolution No. 2000-223 to
fund mitigation for impacts to certain categories of vegetation and aninial species. The Developer
is further aware that the City has determined that all projects will be required to pay the fee in
order to be found consistent with the Habitat Management Plan and the Open Space and
Conservation Element of the General Plan. Developer or Developer's successor(s) in interest
shall pay the fee prior to recordation of a final map, or issuance of a grading permit or building
permit, whichever occurs first. The applicant shall pay habitat in-lieu mitigation fees,
consistent with the City's Habitat Management Plan (HMP) and the Preliminary Biological
Assessment (Planning Systems, August 10,2009), for impacts to 0.06-acres of Unoccupied
Coastal Sage Scrub (Group-D Habitat), 0.36-acres of Annual Non-Native Grassland
(Group-E Habitat), and .33-acres of Disturbed Lands (Group-F Habitat). If the In-lieu
Mitigation Fee for this project is not paid, this project will not be consistent with the Habitat
Management Plan and the General Plan and any and all approvals for this project shall become
null and void.
Please note that in addition to the condition listed above, an addendum to the MND will be included,
adding the requirement to pay habitat in-lieu fees. The Mitigation Monitoring & Reporting Program will
be revised to include the following measure:
Prior to recordation of a final map, or issuance of a grading permit or building permit,
whichever occurs first, the applicant shall pay habitat in-lieu mitigation fees, consistent with
the City's Habitat Management Plan (HMP) and the Preliminary Biological Assessment
(Planning Systems, August 10,2009), for impacts to 0.06-acres of Unoccupied Coastal Sage
Scrub (Group-D Habitat), 0.36-acres of Annual Non-Native Grassland (Group-E Habitat),
and .33-acres of Disturbed Lands (Group-F Habitat).
RESPONSE REGARDING ROBERTSON RANCH PA 22 MND
November 25, 2009
Page 5
- There is no specified mitigation measure for habitat impacts in the MMRP although they are called out
in the Bio report and checklist.
Page 34 lists habitat impacts and indicates that in-lieufees will be paid for .06 acres CSS, .36 acres NNG
and .33 acres disturbed lands. However mitigation for these impacts to habitat is not included as a
mitigation measured in the MMRP. Please include all habitat impact mitigation in the MMRP, consistent
with the HMP.
RESPONSE: Please see above.
- There is no mitigation for indirect impacts along the creek/wildlife movement corridor
The HMP specifically identifies a number of indirect impacts from adjacent development- include lights,
noise and trash control among others. There also are no hours specified for access to the RV's stored on
the project site. In the absence of any restrictions this could occur 24 hours per day seven days a week.
Infrequently used RV's often have maintenance issues requiring repeat engine starting and revving and
testing of mechanical systems. Such activity at night could cause disturbance of the adjacent creek
corridor and nearby residents. In this area next to the creek, which is called out as a local wildlife
movement corridor in the MND, there should be specific inclusion of these mitigation measures. Please
add the requirements to meet all of the relevant edge effect conditions of the HMP, including hours and
noise restrictions and included this as a mitigation for indirect impacts in the MMRP.
RESPONSE: Regarding wildlife movement corridors, the' Preliminary Biological Assessment
identified Calavera Creek" as ". . .a stream drainage within an urban environment." To further clarify, it
indicated that the ". .. creek is not identified as a habitat corridor in the HMP but represents a marginally
viable east to west movement corridor for mammals and reptiles." As discussed above, the creek channel
exists wholly within Rancho Carlsbad Estates, and is separated entirely from the proposed project by a
100-foot buffer, plus an existing 6-foot tall masonry block security wall running along the entire length of
the property through the middle of the buffer, further separating the project from the creek channel.
Despite the highly impaired (i.e., C.M.W.D. pipelines and paved roadway both with significant
easements, along with the existing 6 foot tall masonry wall) nature of the proposed buffer area and the
"marginally viable east to west corridor" as described by the Preliminary Biological Assessment, the
project nonetheless, as indicated in the MND, provides for or incorporates into the project design the
standard HMP requirements as they pertain to fencing, lighting, and the use of noninvasive plant species
to minimize any potential edge effects. The proposed landscape plan does not utilize any invasive plant
species; fencing is proposed at the top of slope to restrict trespass, noise, trash, and debris; and a lighting
plan is required as a condition of approval specifically requiring that all lighting be designed to reflect
downward and avoid any impacts on adjacent homes or properties.
Regarding the proposed RV storage area use and its proximity to Calavera Creek. It is anticipated that the
RV storage area will be used far less frequently than a typical residential unit might (i.e., the existing
Rancho Carlsbad Estates directly adjacent to the creek, and/or the residential land use that was originally
considered as part of the Robertson Ranch Master Plan EIR for this site). Residential uses are allowed to
be active any hours of the day or night and could generally include barking dogs and cats, and even
children who might view the creek as an ideal area for exploration. All of these would appear to pose
more of an impact on the creek.
Please note that the proposed RV storage area is setback approximately 270 feet from the creek channel.
The RV storage area is surrounded entirely by an 8-foot tall barrier consisting of a 2-foot tall earthern
RESPONSE REGARDING ROBERTSON RANCH PA 22 MND
November 25, 2009
Page 6
berm with a 6-foot tall solid masonry wall. Beyond this is another 6-foot tall solid masonry wall, which is
proposed at the top of slope between the parking lot for the office building and the creek channel, all of
which will be significantly buffered by a dense canopy of trees proposed on the slope just outside this
wall. Beyond this and approximately 90 feet away is an existing 6-foot tall solid masonry security wall,
which further separates the proposed project from the creek channel and Rancho Carlsbad Estates. It
should be noted that the following condition will be included as part the Planning Commission Resolution
associated with the recommended approval of the Site Development Plan (SDP 09-01) to restrict the
following activities:
The RV storage area is subject to the following requirements:
a. Only recreational vehicles as defined in CMC Section 21.04.298 may be stored within
the recreational vehicle storage area; all stored vehicles must be in an operable
condition and, if required, currently licensed.
b. Permitted recreational vehicle storage shall not be utilized as a sales yard or storage for
a sales yard. An occasional sale by an individual may be permitted.
c. The maintenance, restoration, and/or repair of any vehicle shall not be permitted within
the storage area.
d. The utilization of a stored vehicle as a living unit shall not be permitted.
Notwithstanding the above, we believe that adequate provisions have been incorporated in to the project
design to minimize any potential edge effects in accordance with the HMP. Please note that the MND
and Preliminary Biological Assessment were reviewed by the United States Fish & Wildlife Service
(USFWS) and the California Department of Fish & Game (CDF&G). A response of "no comment" was
received from the USFWS on November 19, 2009, and no comments were received from the CDF&G.
- Landscape plan
While the landscape plan requires further review and properly restricts the use of invasive plants, it still
includes excessive water use and much less native planting than is warranted for this area next to a creek.
The "refined" and "lush" landscaping areas constitute almost 63% of the total landscape areas - all with
10-30 inches of water a year required—for an RV parking lot. This area is behind a screening wall so it
is not visible by the nearby residences or the public roadway. If any site justifies reduced landscaping
and reduced water use this would certainly be it.
Please re-look at the landscaping plan to reduce the amount of water use -^particularly increasing the
amount of native plants.
RESPONSE: The proposed conceptual landscape plans meet City of Carlsbad Landscape Manual
requirements and proposes the use of reclaimed water for all landscaped areas. The plans provide (on-
site) for an approximate 50-foot wide native planting area (Zone 4) along the creek and an additional
approximate 20-foot wide transitional planting area (Zone 3) between the native area and parking lot
wall. The transitional area includes large native screen shrubs as well as native trees, which along with
the wall should provide appropriate screening and separation between the creek area and the project. It
cannot be argued that further reduction in water use by specifying more drought tolerant plantings around
the parking areas and building would not be a benefit; however the applicant is allowed to make
RESPONSE REGARDING ROBERTSON RANCH PA 22 MND
November 25, 2009
Page?
appropriate design decisions that provide a balanced project design as long as the City's landscape
requirements are met. While the applicant is already utilizing reclaimed water for purposes of water
conservation, we would still encourage the applicant's landscape architect to review the plans as part of
the final landscape and irrigation plan submittal to determine if further revisions could be made to
conserve water. This could be achieved by reducing the area of Zone 1 and 2 plantings and increasing the
area of Zone 3 planting.
Hydrology and Water quality
- FEMA flood mapping
The MND text and figures are not consistent regarding the area of this project -within the 100 year
floodplain. This is of particular concern considering the long history offloading in this area and the past
failures of storm water management plans/structures to adequately address flooding (as evidenced by the
emergency dredging project from 2005 still not fully mitigated). Furthermore the city has yet to initiate
the regular maintenance of the storm water system in this area and there is a current buildup of silt
deposit that will further exacerbate flooding conditions.
Please confirm that 100% of this proposed project is outside of the 100 year floodplain and that adequate
consideration has been given to past flooding history and current conditions.
RESPONSE: As stated in the MND, the Robertson Ranch Master Plan EIR noted a history of flooding
in Rancho Carlsbad Estates and required construction of detention basins and modifications to the
Calavera Creek stream bed to reduce flooding within this community.
As a result of upstream improvements to the basin BJ outlet (limit plates installed), the construction of the
84-inch reinforced concrete pipe per the Robertson Ranch East Village Master Tentative Map (CT 02-16),
and the Lake Calavera valve improvements, these resulted in flood plain modifications to the FEMA
FIRM Maps. A Letter of Map Revision (LOMR) was filed resulting in updates to FEMA Map no. 06073
C 0768F (see FEMA Letter of Map Revision 09-09-0276P, effective September 8, 2009). Based on the
LOMR, the developable portion of this property is located outside the 100-year regulatory floodplain,
with exception to two subsurface private sewer laterals. The southerly toe of the 2:1 slope for the existing
pad, constructed as a part of the mass grading for Robertson Ranch, is coincident with the north limit of
the flood plain.
- Excess impervious cover
Other than landscaping, only two small areas of the proposed parking are proposed for permeable cover.
We recognize that there are issues with leaking RV's stored for long periods of time but there are
alternative pavements designs that allow for water percolation but still trap and treat pollutants.
Permeable and semi permeable pavement can be used for fire trucks that weigh a lot more than most
RV's.
Please re-look at project site plan for more LID design including potential use of permeable and semi-
permeable surfaces.
RESPONSE: The Report of Rough Grading, Planning Area 22 of Robertson Ranch, East Village
Carlsbad, San Diego County, California dated March 6, 2009 prepared by Geosoils, Inc. and referenced in
the MND recommends that due to relatively low R-values of the soil samples obtained from the finished
RESPONSE REGARDING ROBERTSON RANCH PA 22 MND
November 25, 2009
PageS
subgrade, water should not be allowed to penetrate street subgrades. The tentative map, in addition to the
pervious pavement areas shown, includes an underground perforated storm drain system, which achieves
the same purpose and intent as permeable and semi-permeable surfaces. The use and extent of permeable
and semi-permeable surfaces as well as other lid features will be reviewed as part of the final design
process. The City's Engineering Department has reviewed the project, along with the preliminary Storm
Water Management Plan (SWMP). The preliminary SWMP does demonstrate compliance with the City
of Carlsbad Standard Urban Storm water Mitigation Plan (SUSMP), Order R9-2007-0001 issued by the
San Diego Region of the California Regional Water Quality Control Board and City of Carlsbad
Municipal Code.
Traffic
- Incorrect comparison of traffic changes.
The traffic study concludes no adverse traffic impacts from this project by ingeniously including two other
project changes that reduced traffic to offset this change that increases it. This project site had 160 ADT
in the approved EIR and now. identifies 1,320 ADT from the office building alone. The traffic analysis
should both re-evaluate all changes to traffic from the original approved Master Plan to what is now
proposed for the entire Master Plan area and look at the specific changes for just this specific project
area. The traffic study has correctly done neither of these. It has cherry picked some changes but not
properly related this to either the total area or this specific site.
RESPONSE: The traffic study .only-assumed land use changes that have been approved and [in the PA
22 case] proposed. Thus," it correctly evaluated changes in traffic from approved or known revisions only
within the Robertson Ranch Master Plan. Thus this traffic report utilizes the most up-to-date, correct land
use assumptions. The fact that two of the nearby planning areas have been approved at reduced
development intensity since the original Master Plan allows those reduced ADT to contribute an off-set to
the proposed PA 22 increase. The cumulative Year 2030 traffic comparison uses the traffic generation
from the entire master plan and quantified the changes in traffic using these known revised planning area
projects.
- Failure to include any traffic for RV parking portion of the project.
Although the majority of the project site is being used for RV parking, there is not one daily ADT
identified as being associated with the RV parking. The traffic analysis for this project only shows the
office building trips at 1320 per day. Does the SANDAG trip generation model include standards for RV
Parking lots? If not, some other method needs to be used to account for the trips associated with this
land use.
RESPONSE: SANDAG does not catalog a trip generation rate specifically for RV storage facilities.
The certified Robertson Ranch EIR traffic study applied a trip rate which is used for household storage
facilities, which typically would generate more vehicle trips, to the 2.3 acres of RV storage listed in the
Master Plan. Applying that rate to the 0.8 acre RV storage facility planned for PA 22 would yield the
following vehicle trips as showing in the table below:
Size
0.8 Acres
Trip Rate
30/Acre
AM Peak Hour
IN
0.03*
1
OUT
0.03*
1
PM Peak Hour
IN
0.045*
1
OUT
0.045*
1
*Peak Hour % x (In & Out) Ratio
RESPONSE REGARDING ROBERTSON RANCH PA 22 MND
November 25, 2009
Page 9
As indicated, conservatively, the PA 22 RV storage lot would generate no more than a 24 average vehicle
volume with one inbound and one outbound vehicle trip occurring during both the AM and PM peak
hours. The effects of these few vehicle trips would be less than significant. It should be noted that the
proposed RV storage area is a private storage facility, used solely for the benefit of the Robertson Ranch
community residents, and at no time is intended to be used as a public facility.
- Cumulative traffic impacts.
A new high school was recently approved at College/Cannon very near this project site. Please clarify
how the increased trips associated with this new high school have been assessed as part of cumulative
impacts to these roadway segments and intersections and confirm that with these trips, and with added
trips for the RV parking that there are no additional cumulative .traffic failures caused by the proposed
project.
RESPONSE: Cumulative impacts were determined by using the results of the Year 2030
SANDAG/Carlsbad Combined North County Transportation forecast, as included in the Robertson Ranch
EER traffic study. The forecast of future traffic included the assumed build out of the city of Carlsbad and
included the future high school northeast of the Cannon Road/College Boulevard intersection. The PA 22
traffic study revised the cumulative volumes, which included high school traffic. Therefore the effects of
high school traffic have indeed been evaluated.
We thank you for providing comments on the Robertson Ranch PA 22 project and hope that we have
addressed your concern. If you have any further questions, please do not hesitate to contact me at (760)
602-4643, or via email atjason.goff@carlsbadca.gov.
Sincerely,
JASON GOFF
Associate Planner
C: Paul Klukas, Planning Systems, 1530 Faraday Ave., Suite 100, Carlsbad, CA 92008
Adam Pevney, Brookfield Homes, 12865 Pointe del Mar, Suite 200, Del Mar, CA 92014-3859
Don Neu, Planning Director
Chris DeCerbo, Principal Planner
Glen Van Peski, Senior Civil Engineer
Steve Bobbett, Associate Engineer
Doug Bilse, Traffic Engineer
File copy
EXHIBIT "ADDM"
ADDENDUM TO THE
MITIGATED NEGATIVE DECLARATION FOR
ROBERTSON RANCH PA 22
GPA 09-01/ZC 09-01/MP 02-03 (BVCT 09-01/SDP 09-01/PUD 09-01
The purpose of this Addendum to the Mitigated Negative Declaration is to describe revisions to the
Mitigation Monitoring and Reporting Program associated with the Robertson Ranch PA 22 project, and to
state the determination that this revision does not create any new significant environmental effects, that none
of the conditions contained in Section 15162 of the California Environmental Quality. Act (CEQA) have
occurred, and that a subsequent Mitigated Negative Declaration is not required.
The revision contained in this addendum adds Mitigation Measure No. 6 to the Mitigation Monitoring and
Reporting Program. The following mitigation measure shall apply: Prior to recordation of a final map, or
issuance of a grading permit or building permit, whichever occurs first, the applicant shall pay habitat in-
lieu mitigation fees, consistent with the City's Habitat Management Plan (HMP) and the Preliminary
Biological Assessment (Planning Systems, August 10, 2009), for impacts to 0.06-acres of Unoccupied
Coastal Sage Scrub (Group-D Habitat), 0.36-acres of Annual Non-Native Grassland (Group-E Habitat), and
.33-acres of Disturbed Lands (Group-F Habitat). This revision is not considered substantial or significant as
it relates to the environmental effects associated with the project, or the conditions contained in Section
15162 of CEQA, and a subsequent Mitigated Negative Declaration is not required.
Date: Don Neu
Planning Director