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HomeMy WebLinkAbout1981-05-26; City Council; N/A; Local Costal Programyf 7 LOCAL COASTAL PROGRAM 1. Update on Carlsbad Local Coastal Program (LCP) (area in coastal zone excluding Agua Hedionda LCP and Mello Bill LCP) a) Regional Commission Action (April '81) b) San Dieguito LCP Comparison (agriculture and housing) c) State Commission staff recommendation d) Vice Mayor's comments at May 21st State Commission hearing and staff notes. e) Anticipated final action by Commission (final vote required on land use and implementation prior to July 1, 1981). f) Alternatives after final Commission action COUNCIL ACTION: 5-26-81 Council indicated their intent to express support of the Regional Conmission Plan and to notify the STate that the City will not implement the Plan proposed by the State Staff. Council also indicated approval for the Mayor to attend the hearing if it was determined to be desirable. VICE MAYOR'S COMMENTS TO STATE COASTAL COMMISSION 5/21/81 RE: CARLSBAD LOCAL COASTAL PROGRAM Chairman Grote and Members of the Commission: I am Mary Casler, Vice Mayor of Carlsbad and speak on behalf of the Mayor and the City Council. This LCP as presented to you is heavily padded. Of the 79 policies it contains, 34 are already in effect in the city. Several more refer to state lands and there are 2 very obvious errors. We have reviewed the staff recommendations for the Carlsbad LCP with deep disappointment, especially in the area of agriculture. Your staff has not moved from its stance taken in January. The staff has ignored the advisory approval of the Regional Commission, which heard the city's LCP and passed it unanimously. The staff has discarded the findings of the Regional Commission. The staff has repudiated the input of the city of Carlsbad. Your staff has ignored the soil classifications of the agricultural lands. They are recommending land stay in agriculture which is the poorest in the city. Land recommended for development is the best soil. I can only conclude that the staff has tilted the scales in favor of the large landowners of the "Mello 1" properties who can well afford to purchase development rights from our smaller farmers and leave them up the creek in years to come when their soil is no longer productive. We ask a return to the "mixed use" concept as approved by the Regional Commission. It will work and it will preserve agriculture. In housing, we ask you to accept the city of Carlsbad's Housing Element. We are making very satisfactory progress in its implementation. Last Tuesday we approved a development of 82 units to be sold between 60-80 thousand dollars (very low for San Diego County) and we included a provision that the owner must live in his unit for a year, in order to discourage speculation. We do have subsidized housing now and an additional project is before the Planning Commission to add another 40 units for seniors. We are providing "our fair share" but we are doing it near stores and bus lines - not in the hinterlands which the coastal zone encompasses. We consider this an unworkable plan. We request you ask your staff for an evaluation of the alternative as presented by the city and we ask you Commissioners to consider it carefully. We feel it is a plan which fulfills the objectives of the Coastal Act and will be one of which we can all be proud. MEMORANDUM DATE: May 26, 1981 TO: Frank Aleshire, City Manager FROM: James C. Hagaman, Planning Director SUBJECT: Summary of Major Policy Changes in Carlsbad LCP State Staff Report The following highlights the major policy revisions to the Regional Commission approved Carlsbad LCP, as proposed in the State Commission Staff Report. (p2-16) 1. Agriculture State recommends agricultural subsidy program administered by coastal conservancy, allowing land along 1-5 to convert by paying subsidy fee ($24,000/acre), and requiring areas between Palomar Airport Road and Batiquitos Lagoon to remain in permanent agriculture. Include review of program by state commission on annual basis. (p 23) 2. Cannon Road State staff has deleted all reference to Cannon Road from the Carlsbad LCP. (p 24) 3. Macario Park State staff makes no direct reference to Macario Park, designates park site as mixed agriculture/residential use; allows for park development at "future, undetermined site." (policy 64) (p 18) 4. Kelly Point Area recommends Rancho La Costa "sliding density scale" for Kelly point area, (policy 3.5) (p 16 & 5. Steep Slope prohibits development on 25% + p 20) slope; allow up to 1 du/ac credit, (policy 3-1, 4.7) (p 21) 6. G r a d i n g 0 r d i n a n c e recommends amending municipal grading ordinance (policy 4-12) (p 16) 7. Buena Vista Lagoon recommends down-zoning all vacant Buena Vista Lagoon lots (including Point San Malo) from 10-20 du/acre to 0-4 du/acre. (policy 3.2) (p 7) 8. Mello Bill recommends increasing density of Occidental parcels. (Mello Bill LCP) to 12 du/acre for participation in Agriculture Subsidy program. (p 24) 9. Encina Fishing Area/Beaches included in staff recommendations;should be deleted, these lands are in the Aqua Hedionda Specific Plan Area, (policy 6.3) (p 31) 10. Condo Conversions prohibit condo conversion where majority of displacees are "low/moderate income"; require 30% mandantory inclusion where conversion is approved, (policy 9-3) (p 32) 11. Affordable Housing mandatory inclusionary zoning of 25%. (policy 9.9) (p 14) 12. Agricultural Buffers requires minimum 100'-300' buffer between agriculture and new development, (policy 24) JCH:PT:rh -2- 1200 ELM AVEML'E CARLSBAD, CALIFORNIA 920C3 Office of ttic Mayor TELEPHONE: -P 438-5561 September 24, 1980 Commissioners • - CALIFORNIA COASTAL COMMISSION 631 Howard Street ' . San Francisco, CA 94105 • Dear Commissioners: BecaxiSG of the significant objections which the City continues to have regarding the Local Coastal Program for the "Mello Bill" properties, the City Council has determined that it does not intend to participate in the implementation of the plan. In the City's opinion, the LCP does not meet the mandates of . • 'Section 30170(f) or the policies of the Coastal Act and does -. •not reflect the'needs of the City or its residents. Many of our expressed concerns have fallen on deaf ears. The Commis- sion's response, that we may seek change through the amend- ment process, is both inadequate and unrealistic. Because the adoption of this program will undoubtedly set a precedent for the.'Local Coastal Program for the remainder of the City of Carlsbad, 'I would again like to renew our concerns. \ First, the City Council believes that the provisions .for mandatory inclusionary zoning for low and moderate income housing within :the coastal zone, without regard to the provisions of the City's Housing Element, is contrary to the express language of Section 30213 of the Resources Code which states: . "New housing in-the coastal zone.shall be developed in conformity with the standards, policies and goals of local housing elements adopted in accordance with requirements of Subdivision(c) of Section.65302 of the Government Code." • . * \ The City Council of the City of Carlsbad has accepted the responsibility to provide housing opportunities within the .entire City of Carlsbad for all economic sectors of the community. The Commission1s mandate for inclusionary zoning within the coastal zone disrupts overall City policies and Commissioners -2- September 24, 1980 ignores the demographic, economic and social realities of the .City of Carlsbad. Because the standards, goals, and policies .of local housing elements apply to the entire City, including the coastal zone, the Council believes it is'_more appropriate to deal with the housing crisis on a city-wide basis. Because most of the residential areas of the City of Carlsbad are with- in five miles of the coast, and readily accessible through convenient public and private transportation, the Commission's mandatory inclusionary zoning for low 'and moderate income housing cannot be justified under the goal of obtaining access to Carlsbad's coastal resources. . . The second major area of concern to the City of Carlsbad is the permanent agricultural zoning which the Commission has imposed. The City believes that permanent agricultural restrictions for the properties involved are not supported by the economic data. The City Council recognizes agriculture as an important industry and resource in the City of Carlsbad and has begun to adopt pro- grams which will protect the economic feasibility of agriculture in the City for as long as possible. However, the City Council . realistically recognizes that there comes a time when no economic return can be made through agriculture. Permanent agricultural'' protection prohibits the conversion of the land to a different ' • use-. If government demands that the property be maintained in a' use which is not economically productive, inverse condemnation may result. The City of Carlsbad does not wish to be placed in that position at this time. The City recognizes that protection of co.astal agricultural- lands, particularly given the mandates of 'Sections 30241 and 30242, is-an important policy of the Coastal -.Commission. However, the City believes that this protection can be better achieved through methods other than permanent agricultural use restrictions. The-evidence presented at the Commission's own public hearing supports the City's proposition. Finally, the City has significant concerns over the grading restrictions imposed by the Local Coastal Program for the Mello Bill properties. The development restrictions based on slope, particularly those applied to the Rancho La Costa properties, clearly indicate that the Commission is not concerned with the protection of the environment but is rather imposing severe developmental restrictions based on an arbitrary standard. The City desires to protect its significant coastal resources, including the lagoons, but believes that goal can be accomplished through the use of strict grading standards, mitigation techniques and other requirements rather than simply resorting to a ban on development. ' . •/"*>. Commissioners • -3- ' September 24, 1980 Many of the resources sought to be protected by the Coastal Act exist in the City of Carlsbad. These resources are among the •assets which make Carlsbad unique among California coastal cities. The City Council desires to protect these resources according to the policies of the Coastal Act, but in many respects has been given a "Hobson's" choice in the LCP for the Mello Bill properties. To accept the plan and ordinances as adopted by the Commission would be to subject our City to' liability, necessitate programs for which we lack legal authority and require that we act. contrary to what we believe is best for the City of Carlsbad. If we'fail to adopt them, it appears the requirements will be imposed upon us by-a continuation of the permit process. At this time we choose the latter course and advise the Commis.sian that the City does not •intend to implement the provisions of.the Local Coastal Program or the zoning ordinances as presently proposed for the Mello Bill properties. If the Commission persists in this exercise of State land"use control, you should do so with the knowledge that you will be responsible for the implementation and administration of the plan. . . . . ...-. •• ..«..-.. ..••-., • • ,.... . '-.. - , . .. ,.,, ,. ,;.-'. ...... Very "truly yours, / ROKALD C. PACKARD Mayor PCP/DSH/mla . . ' cc: Assemblyman Robert C. Frazee DEVELOPMENTAL SERVICES D Assistant City Manager (714) 438-5596 D Building Department (714) 438-5525 D Engineering Department (714)438-5541 Q Housing & Redevelopment Department (714)438-5611 D 1200 ELM AVENUE CARLSBAD. CALIFORNIA 92008 Citp of Carlstmb Department (714) 438-5591 March 20, 1981 Tom Crandall, Executive Director San Diego Coast Regional Commission 6154 Mission Gorge Road, Suite 220 San Diego CA 921 20 Dear Tom: Attached are the Carlsbad City Council's amendments to the PRC Toups Proposal for the Carlsbad Local coastal Plan. On March 10, 1981, the Carlsbad City Coun- cil took action indicating that the Toups Plan, incorporating the recommended changes transmitted herewith, would be acceptable to the city and will satisfy the city's requirements for a Local Coastal Plan. I have also outlined, for purposes of clarification, other written comments that have been forwarded to your staff from the city. These are as follows: 1 . Carlsbad Local Coastal Plan; Staff Summary provides a summary of city staff comments and recommendations on the Toups Report and Coastal Staff comments, focusing on major issues of substantial concern. 2. Carlsbad Local Coastal Plan; Staff Analysis provides a detailed analyses, by Carlsbad City staff of the Toups Report and Coastal staff comments. 3. Carlsbad Local Coastal Plan; Staff Summary: Council action provides a re- vised version of item (1), pursuant to City Council action on the matter. I hope the recommendations transmitted herewith will allow the city and Coastal Commission to resolve differences regarding Local Coastal Plan issues, and reach agreement on an LCP document acceptable to both the city and Commission. Thank you for your cooperation in this matter. If I can be of further assis- tance in this regard, please don't hesitate to. contact me. Very truly yours, TAMES C. HAGAMAN Planning Director" JCH:PT:ls I. Land Use Map Policy 1: Macario Canyon The city requests that the Macario Canyon Area be redesignated as "open space", specifically indicating a park use. Policy 2: Agricultural Buffers The determination of agricultural buffers should "be made on a project-by-project basis; they should not be included in the Land Use Map. Policy J>: Agricultural Lands Agricultural use should be protected with an "Agricultural Resource Overlay Zone" recognizing that agricultural production may not continue indefinitely. Policy 4: Savage Property Downzoning Savage Property is inequitable; environmental resources would best be protected through application of design criteria/mitigation measures and utilization of planned unit development standards as a means to protect the lagoon ecosystem and provide for public access/view points on the lagoon shore. Policy 5: Open Space An open space designation should be applied to Buena Vista Lagoon and is necessary to protect lagoon resources. Policy 6: Hello Bill Plan should delete mention of Mello Bill Properties. Carlsbad Local Coastal Plan Page 1 II. land Use Text 1. Coastal Element 1: Agriculture The city proposes deleting the policy recommendations contained in the Toups report regarding agriculture, and substituting the following policy recommendatons: General Findings: The city makes the following general findings regarding agricultural production/preservation in the Carlsbad • Coastal Zone. There are no substantial prime soils (Class I & II) in the Carls- had Coastal Zone. The city recognizes the importance of agricultural lands as a uni- que resource, and supports the continuance and enhancement of agricultural production. The city recognizes the variability and constraints on continued agricultural production, and supports a program directed towards encouraging continued agricultural production, recognizing the inherent relationship between preservation of agricultural lands and the economics of production. Policy 2.1: Agricultural Buffers The need for agricultural buffers should be made on an individual basis; should be the responsibility of encroaching development; and should be "adequate" to mitigate potential land use conflicts. Policy 2.2: Protection of Agricultural Resources The city shall develop an "Agricultural Resource Overlay Zone," respec- ting the current underlying general plan designations, to be applied to those lands generally indicated in the Toups Report as suitable agri- cultural lands. A. Class III Soils. land containing Class III soils, or better, shall be considered "most suitable" agricultural lands, and may be allowed to develop subject to a master development plan for the entire property. Such plan shall not be approved by the city un- less a finding is made that continued exclusive agricultural use is no longer feasible or that to allow development on a portion of the property will enhance the continued agricultural use on the undeveloped portion. The master development plan may allow up to one-half of the property to develop with residential uses, shall cluster development on the least agriculturally suitable portion of the property, shall include a management plan for continued agricultural production, and shall provide appropriate restric- tions to protect agricultural lands. Carlsbad Local Coastal Plan Page 2 o B. Class IV-VIII Soils. Shall "be considered "impacted" agriculture, shall be encouraged to continue in production as long as feasible, and shall be allowed to convert subject to conversion criteria (Policy 2.3). Policy 2.3; Conversion Criteria The city shall develop detailed conversion criteria to allow conversion of "impacted" agriculture (Class IV to VIII), considering the follow- ing: A. Relation to encroaching development and' surrounding densities. B. Impacts on adjacent agricultural production. C. Cccurance of diseased soils and/or poor drainage. D. Occurance of deteriorated structures. E. Documentation of declining profitability. Policy 2.4: Agricultural Incentives The city recognizes the need to protect and encourage agriculture on a city-wide basis, specifically noting the following: . The city has formed an Agricultural Advisory Committee to formu- late recommendations regarding the preservation/protection of agriculture on a city-wide basis. The city supports the enhancement of . agricultural production through incentive programs including: adopting a Right to Farm Ordinance; preferred water rates for agricultural lands; develop- ment of a reclaimed water program, giving preference to agricultu- ral lands; encouraging agricultural leasing on Master Plan areas slated for phased development; support tax incentives for agricul- turally designated properties. Policy 2.3: Utility Extensions The city shall act to protect the premature disruption of agricultural uses by not allowing growth inducing utility extensions into agricultu- ral lands until such lands are designated for urban conversion, and agricultural production has been proven unfeasible, subject to Policy 2.3- Carlsbad Local Coastal Plan Page c Coastal Element 2. Environmentally Sensitive Habitats, Water and Marine Resources Policy 3»1? • Preservation of Slopes and Vegetation Although the city has reservations regarding prohibiting all steep slope development, the city recognizes that not all steep slope areas are appropriate for development, and proposes the following: In areas of special resource/habitat value or highly erodable soils, development of steep slope areas may not "be appropriate. The city shall develop criteria relative to disturbance of steep slope areas, including the following: • (1) Use of Planned Community Zone and General Plan density ranges to encourage protection of steep slopes in natural state, and to minimize alteration of natural land forms. (2) Development of design criteria directed towards minimizing disturbance of steep slope areas, including cluster develop- ment, innovative construction techniques, combination drive- ways, limiting grading to area necessary for driveway utility and roadway access, encouraging development subordinate to natural land forms. (3) Development of a Hillside Ordinance directed towards regula- ting development on steep slope areas of significant environ- mental sensitivity. (4) The city supports density credit for steep slope preservation areas based on the density allowed for the entire property as a means of providing an economic incentive for steep slope preservation. Policy 3»7: Lagoon Management The city shall develop a Lagoon Management Program for inclusion in the Carlsbad LCP. At a minimum, such a program shall address the follow- ing: Structuring a joint-powers committee to develop a maintenance/ enhancement program. . Recommendations regarding specific trails, viewpoints and access improvements; discussion of potential funding sources. Structuring program to periodically review and monitor the lagoon ecosystem. Specific designation of local, regional and state responsibilities and duties regarding lagoon management. Carlsbad Local Coastal Plan,- * Page 4 Coastal Element 3« Geologic Hazards Policy 4.1: Coastal Bluff Erosion (p 69) The city proposes utilizing Coastal Commission bluff-top development guidelines, requiring certification of ."bluff stability and appropriate mitigation measures including subsurface drainage systems and drought resistant planting. Toups Policy 4«1> 4-2 and 4«4 should "be deleted. Policy 4-3: Beach Erosion Control Measures (p 69) The city shall incorporate into the LCP recommendations regarding the establishment of a regionally- "based "beach erosion control regulatory mechanism, proposed mitigation measures, and a discussion of possible funding sources to reestablish and protect the sandy beaches. Policy 4.10: Steep Slopes (p 71) The development of mitigation/design criteria proposed by city in Policy 3 • 1 '• Environmental Resources shall be substituted for Toups Policy 4.10. Policy 4«16: Amend Municipal Grading Ordinance (p 72) The city finds that the existing Municipal Grading Ordinance, incorpo- rating the policies of the Model Erosion Control Ordinance and the re- quirements of the Master Drainage Plan are generally adequate to con- trol soil erosion. In areas of identified highly erodable soils condi- tions, additional hydrology/soils studies shall be required, and appro- priate mitigation measures shall be applied. Coastal Element 4* Public Works Policy 5*6: Cannon Road (p 95) The city supports the Cannon Road alignment as proposed in the PRC Toups Plan, and feels that road construction may be necessary at an earlier date than indicated in the Toups Plan. Carlsbad Local Coastal Plan Page 5 Coastal Element 5« Recreation and Visitor serving Facilities The city fully supports the PRO Toups recommendations regarding recreation and visitor serving facilities, and finds no areas of substantial issue with the policy recommendations made in the Toups Report. Coastal Element 6. Shoreline Access Policy 7»6; Buena Vista Nature Trail (p 116) The city supports Toups Policy 7.6, "but recommends deleting the refer- ence to eminent domain. Policy 7«17i Access Improvements The City shall investigate the funding, maintenance, jurisdictional responsibilities and timing of construction for the access improvements recommended in the Toups Report. Coastal Element 7• Visual Resources The city fully supports the policy recommendations relative to visual re- sources contained in the Toups Report. Coastal Element 8. Housing The city recommends deleting the policy recommendations regarding Housing contained in the Toups Report, and substituting the following: Policy 8.1; Provision of Affordable Housing The city regards the Carlsbad Housing Element as the primary document guiding, the provision of affordable housing throughout the city, in- cluding the Coastal Zone, and incorporates the Housing Element into the Local Coastal Plan by reference. Major provisions of the Carlsbad Housing Element include: Carlsbad Local Coastal Plan Page 6 A. Maintain and rehabilitate existing stock of lower income housing. B. Develop . and implement a Mobilehome Park Zone to protect existing and proposed mobilehome park developments (accomplished 3/81). C. Establish a Housing Development Fund to assist in the provision of affordable housing. D. Identify suitable higher density sites in Master Plan Areas for ' low and moderate income housing. E. Seek Article 34 Referendum -authority for the construction of 150 units of elderly/handicapped low/moderate income housing (accom- ' plished 1/81). P. Establish Condominium Conversion Ordinance (accomplished 1/81). G. Revise municipal codes and procedures to expedite the processing of applications for affordable housing (underway). H. Participate in HUD Local Area Certification Program, to reduce processing time and costs for IHA funded housing developments (complete 2/81). I. Provide incentives to assist in the provision of low/moderate in- come housing, including the following for projects proposing 25$ inclusionary housing: 1. Density bonus of 25$ over otherwise allowable residential density, or two of the following; 2. Exemption from park dedication requirements, 3. Construction of public improvements adjacent to development, including, but not limited to streets, sewers and sidewalks. 4. Utilization of federal, or state grant monies or local reve- nues to provide land cost writedown. 5. Exemption from local ordinances which may cause an indirect increase in the cost of housing (reduction in off-street parking requirements, reduction in processing/permit fees, etc.). Carlsbad Local Coastal Plan Page 7 III. Implementation Recognizing the inherent relationship "between the formulation of a Land Use Map and text acceptable to the city, and the resulting implementing ordi- nances, the city will defer comprehensively addressing the implementation aspect of the Local Coastal Plan until substantial issues regarding the Land Use Map and text have been resolved. Carlsbad Local Coastal Plan • Page 8 . • • c STAU OF CAlirOM-JIA—CAUFOKNIA COA5-TAI I. AISS!OM EDMUND G. OUOWN JR.. .itivy/ v.v'«» la.?..>. i'S-l A\r.SIOM OO:!Cfc COAD. CUFE ??0 SAN DIEGO. CAUI-OIJUIA 92120—TF.!.. (7M) '/-30-6972 TO: .Commissioners and Interested Persons FROM: Chuck Damm, Chief Planner SUBJECT: City of Carlsbad Land Use Plan April 6, 1981 • .. FINDINGS FOR APPROVAL KEY FINDING - . The San Diego Coast Regional Commission finds that the City of Carlsbad Land Use Plan, as prepared by the consulting firm of PRC Toups Corporation and modified by the revised, policy language contained in these findings fox- approval, is consistent with all applicable provisions of the California Coastal Act of 1976.• • •BACKGROUND ' . • The land'use plan for the City of Carlsbad v?as prepared as required by Section 30171 of the Coastal Act. This section required the Coastal Commission to prepare and approve the Local Coastal Program (LCP) for the City of Carlsbad by July 1, 1981[vn.th the exception of the three Hello Bill (AB462) Properties and the Agua Hedionda Specific Plan area for which the Commission has already. approved the LCP/LUP]. To meet the time constraints, the Commission hired a consultant, PRC Toups Corporation, to prepare an initial draft of the C«rlsbsd LCP. This was accomplished, and a copy of the draft LCP v?as delivered to the City of Carlsbad on October 1, 1980, for their review and comments (for greater detail, reference the introduction portion of the preliminary staff recommendation for the City of Carlsbad LCP, dated March 2, 1981), The San Diego Co^^st Regional Commission held the initial public hearing on the Carlsbad Land Use Plan (LUP) on March 13, 1981, where the Commission heard public testimony but took no action on the LUP. At the second hearing on March 27, 1931, the Commission completed hearing public testimony and voted to approve the Carlsbad Land Use Plan, an prepared by I'RC Toups Corporation and as modified by the revised policy language and land use map changes adopted by the Commission, at the hearing. The following consists of the revised policy language and land use mr.p changes the San Diego Coast Regional Commission adopted in lieu of certain poli.cies and mapping designations in the Toups draft of the LUP, and the supporting COPY TO: Commissioners a. Tntcrestcd Persons April 6, 1981 findings for approval. All policies in the PRC Toups draft of the LUP not addressed below were adopted. The revised policies and findings for approval follow the same general format as found in the PRC Toups draft of the LUP. REVISED POLICY LANGUAGE AND LAND USE MAP CHANGES I. Land Use Map Changes ^* 'Macario Canyon - Macario Canyon Area shall be designated as open space/park use as the City is in the process of acquiring the site. If acquisition fails, the PRC Toups land use designation shall apply. B. Agricultural Buffers - The determination of agricultural buffers • shall be made on a pro ject.-by -project basis; they shall not be included in the land use map. C, Agricultural Lands - Agricultural lands will be protected by the "Agricultural Resource Overlay Zone", maintaining the current under- lying general plan designations. ®' Open Space - An open space designation shall be applied to Buena Vista Lagoon. **• Mello Bill (AB462) Properties - These properties are not part of the Carlsbad LCP or land use map. F. South Shore Properties of Buena Vista Lagoon - Those' properties adjacent, to Buena Vista Lagoon with a General Plan designation of medium high (10-20 du/ac) residential shall be modified to medium density (4-10 du/ac) residential. II. Agricu] ture ' ' The following revised policy language was adopted and shall be substi-_ tuted for the policy language on agriculture in the draft Land Use Plan in its entirety. policy 2-1; Agricultural Buffers ^ • The need for agricultural "buffers should 'be made on an individual • "basis; should be the responsibility of encroaching development; and should be "adequate" to mitigate potential land use "conflicts. Policy 2-2: Protection of Agricultural Resources ' • The city shall develop an "Agricultural Resource Overlay Zone," respec- ting the current underlying general plan designations, to be applied to those !lands generally indicated in the Toups Report as suitable agri- cultural lands. A. Clans J^n^rioi^s. I/anrl containing Clocs III soils, or better, .{JhlillTlje considered "most suitable" agricultural lands, and may be allowed to develop subject 'to a nvor.tcr development plan for the entire proper ty. r.Vich plan shall' not be approved by the city un- less a finding is made that continued exclusive agricultural u:':o MEMO TO; Commissioners and Interested Persons April 6, 1901 is no longer feasible or that to allow development on a portion of the property vail enhance the continued agriculttiral use on the undeveloped portion. The master development plan may allow up to one-half of the property to develop with residential uses, shall cluster development on the least agriculturally suitable portion of the property, shall . include a management plan for continued agricultural production, and shall provide appropriate rcstric- "tions to protect_agricultural Hinds. B. Class IV-VIII Hoils. Shall be considered "impacted" agriculture, "shall be encouraged to.continue in production as long as feasible, and shall be allowed to convert subject to conversion criteria . '(Policy 2.5). Policy J>-3 ^Conversion Criteria. . . • . The city shall develop detailed conversion criteria to allow conversion of "impacted" agriculture (Class IV to VIII), considering the follow- ing: • A. - Relation to encroaching development and surrounding densities. B. Impacts on adjacent agricultural production. C.' Occurance of diseased soils and/or poor drainage. D. Occurar.ce of deteriorated structures. E. Documentation of declining profitability. Policy £-4: Agricultural Incentives .. - The city recognises the need to protect and encourage agriculture on a city-wide basis, specifically noting the following: . The city lias formed an Agricultural Advisory Committee to formu- late recommendations regarding the preservation/protection of . agriculture on a city-Wide basis. • . . . ' • . The city supporta the enhancement of agricultural production through incentive programs including: adopting, a Right 'to Farm Ordinance; preferred water rates for agricultural lands; develop- ment of a reclaimed water program, giving preference to agricultu- ral lands; encouraging agricultural leasing on Master Plan areas slated for phased development; support'tax incentives for agricul- ' turally ciesi gnated properties. Policy ?~'3; Utility Extensions •The 'city shall act to protect the premature di.srujit.ion of agricultural uson by not allowing growth inducing utility extension:; into agricultu- ral lands until riuoh lands are designated for urban conversion, and ogricultural production has boon proven unfoasible, subject to Policy ox£«..>• . - -.3- • MEMO TO: Commissioners Interested Persons April T>, 19C1 III. Environmentally sensitive Habitat^;, Water and Marine Resources The Regional Commission adopted the following revised policy language in lieu of the corresponding policy language in the draft LUP. Policy 3-1; Preservation of Steep Slopes ' Certain areas of the Carlsbad coastal *one have very, high habitat value. These areas are generally confined to steep slopes which are not suitable for farming. These areas exhibit a large number and diversity of both, plant and animal species, several of which are threatened because of extensive conversion of coastal mixed chaparral .and coastal sage scrub habitats to urban or agricultural uses. Also, well-established and well-maintained vegetation is a major deterrent to soil, erosion and attendant difficulties. Unless specifically addressed in other policies of this Land Use Plan, the vegetation on steep slopes shall be maintained so that natural habitats are preserved and soil erosion is minimized. The City of Carlsbad shall prohibit the development of slopes greater than 25% except for minor encroachments for roadways or utilities.' Density may^ be clusjjgr^Jj^ t }ie si tes w i i: h_ density calcul a 1: j on s based. _cm the_._cntire property as a means of providing u: incentive for steep s3 ope preservation . The City shall also encourage the use of design mechanisms such as: •(1 ) Use of Planned Community Zone and General Plan density ranges to encourage protection of steep slopes in natural state, ana to minimize alteration of natural land forms. (2) Development of design criteria directed towards minimising' disturbance of steep slope areas, including cluster develop^ went, innovative construction techniques, combination drive- ways, limiting grading to area necessary for driveway utility and roadway ..access, encouraging development subordinate to . • natural land forms. (5) Development of a Hillside Ordinance directed towards regula- ting development on steep slope areas of significant environ- mental sensitivity. . ' * ' * Policy _ 3-2 ;. Kncna Vista Lagoon Developments located along the first row of 3ots bordering Buena Vista Lagoon wi th a multi-family (. 1.0-20 du/ac) designation, including the parcel at the mouth of Lagoon, shall be dcsiqnated 4-10 dwelling units per iicre not. medium h.iqh dcsnsity ar, is shown in tho Toimr; man. Such developments shall be required to .submit topographic, vegetation and soils reports as a part of the permit, application. The reports shall be prepared by qualified professional:; in the respective fit-Ids containing sufficient detail to enable the City to locate the boundary of wetland and upland - 4 .- MEMO TO: Commissioners Interested Persons April G, 1981 areas and areas of steep slopes. Topographic maps shall be submitted at a scale sufficient to determine the appropriate developable areas but no less than 1" = 100' having a contour interval of 5 feet with overlays delineating the proposed project's location. The permit application shall include the computation of the density of development. Criteria used to identify wetlands shall be based on the Coastal Act, Section 30121 and the adopted LCP Mapping Regulations. Developments shall be clustered to preserve'open space for habitat protection. Minimum setbacks of 100 feet from the wetlands, in order to provid a buffer between the development and the wetland/shall be required. he open space and buffer areas shall be permanently preserved for open space uses through a requirement of an open space easement. If the wetland is bordered by steep slopes in excess of 25% which acts as a natural buffer "by steep slopes in excess of 25% which acts as a natural buffer J o the wetland, the development need not be set back 100 feet. The density of development shall be based on the gross acreage of the sites exclusing wetlands and water areas. Storm drain alignments proposed in the Master Drainage Plan to be carried either through or emptying into Bucna Vista Lagoon shall be constructed only in compliance with the requirements of"Sections 30230, 30231,'30233 and 30235 of the Coastal Act by maintaining or enhancing the functional capacity of the Lagoon acceptable to the Department of Fish and Game. Further Icind divisions shall only be allowed on properties bordering the lagoon in compliance with master development plans which implement tho policies of this plan. Land divisions shall not be allowed 1:o create .new parcels except in compliance with this Plan. Policy 3-3: Bati gui tos Lngoon Erosion, drainage -and sedimentation of RatKju.ito:; Lagoon were? pvovir/u;-."!y addressed in the certified Local Coastal Program for Occidental, SUiiul.ii ••! Pacific and Kancho La Costa proportit-1:; also located in tho Bat iqui t o:; Lagoon watershed. Developments in this LCP located in the watershed of Batiquicos or Agua Heuiondo Lagoons will alr:o be required to meet those policies except that density -colculaticns shall be based on gross acreage of the sites excluding wetland:.,1 and water areas. Kuch of tho Batiquitos watershed in this LCP is designated for continued agricultural u:;e which doer, not require-coastal permits. When permits are required, however, conditions shall be imposed which' assure that development will bo. carried out in a manner that a-ssuros protection of the water: quality of the Lagoon. Removal of major vegetation for expansion of agricultural operations requires a coastal permit Mi'sd such uctivi tio:; sh-ill be conditioned with appropriate measure-.",, in- cluding, but. not limited to, numiu.-r, time, and location of vegetation removal and tyjx-u of contour plowing to minimise soil cronioh .and thus assure protection of liatiqui tor. J^agoon. - 5 - ' MEMO•TO: Commissioners .CInterested Persons .April G, 1001 Developments shall be clustered to preserve open space for habitat protection. At a minimum the following criteria shall be applied to properties fronting the lagoon; 1. A minimum setback of. 100 feet from the wetland. Extent of wetr- land shall be determined as described in Policy 3~2, 2. Where feasible, at least 2/3 of the- permitted development shall be. clustered on the half of the property furthest away from the lagoon/v.-etl and. 3. Existing mature trees shall be preserved to the maximum extent feasible. 4. Passive public recreation facilities which are compatible with the resource values of the lagoons shall be provided adjacent to the lagoons. .These facilities may include picnic tables, some public parking and shall include a minimum 10-foot v.'ide trail paral~ leling the l:\goon water's edge and providing unobstructed views toward the lagoon. 5; Further land divisions shall only be allowed on properties bordering the lagoon in compliance with master development plans which implement the policies of this plan. Land divisions shall not be allowed to create new parcels except in compliance v:iv-h this Plan. ' • • Policy 3-:7 ; Lagoon Managomont The City should develop a Lagoon Management Program in cooperation with the Department of Fish and Game and other appropriate agencies. At a minimum, sxioh a program should address the following: Structuring a joint-powers committee to develop i\ maintenance/ enhancemc-nt program. . Recommendati.cms regarding specific trails, viewpoints and access improvements; discussion ol: potential 'funding sources. , Structuring program to periodically review and monitor the lagoon ecosystem. Specific designation of local, regional and state rcsponsibilities and duties regarding lagoon, management. IV, Geologic Hasards , ' The Regional Commission adopted the following revised policy language in lieu of the corresponding policy language in the draft LDP. - 6 - MEMO' TO: Commissioner —<>d Interested Persons April 6, 1981 Policy 4-1; Shoreline Development .For oil new development?; and additions to existing development along the shoreline, a site specific geologic investigation similar to that required by the Commission's Geologic Stability Bluff top Guidelines (ref. attachment C) shall be required and r.iust demonstrate bluff stability for. 75 years or the expected .economic life-time of the structure, whichever is greater. Additionally, development shall incorporate, W!KM:O feasible, sub-drainage systems to remove groundv/airor from bluffs and shall use drought-resistant vegetation in landscaping plan.3 (as well as adhering to the standards of the erosJori control ordinance in the MDP) . 7\ waiver of liability shall be re- quired when assurance of stability cannot be given. Policies 4-1, 4-2 and 4-4: These policies were deleted by the Commission as they were no longer applicable with adoption of revised Policy 4-1 above. Policy 4-3: Beach Erosion Control Measures The city shall incorporate into the LCP recommendations regarding the establishment of a regionally- "based beach erosion control regulatory mechanismy proposed mitigation-measures, and a discussion of possible funding sources to reestablish and protect the sandy beaches. Policy 4-16: ' Amend^J-fanicipal Grading Ordinance The city finds that the existing Municipal Grading Ordinance, incorpo- rating the policies of the Model Erosion Control Ordinance and the re- quirements of the Waster Drainage Plan are generally adequate to con- trol soil erosion. In areas of identified highly erodable soils condi- tions, additional hydrology/soils studies shall be required, and appro- priate mitigation measures shall be applied. v- Public Works ' '• ' The Regional Commission adopted the following revised policy language in lieu of the corresponding policy language in the draft LUP. Policy '3-6: Cannon Road The city supports the Cannon Itoad alignment as proposed in the PRO Toupo Plan, and feels that road construction may be necessary at. an earlier date than indicated in the Toups Plan. . VI. Shoreline Access The Regional Commission adopted the following revised policy language in lieu of the corresponding policy language in the draft LUP. - 7 ~ ' .. TO: Commissioners '1 Interested Persons April 6, 1901 policy 7-6; Rucna Vista Lagoon Nature Trail A nature trail shall be provided along the southern ahoreline of the Buena Vista Lagoon. On undeveloped, non-public lands, Section 66478. 5 (c) of the Subdivision Map Act shall be enforced so that appropriate parcels may be dedicated to public use, Pol i cy 7 - 8 ; P ub 1 i c Trus t/Prescriptive Rights On the vacant parcel at the extreme -north end of Ocean Street, when development is proposed, due to a public trust and prescriptive .rights issue, an irrevocable offer to dedicate .the beach and lowland rreas shall be required pursuant 'to Sections 30211 and 30212 of the Coastal Act. Residential development shall be clustered on the highland area and the bluff face 'shall not be altered, Policy 7-17 ; Access Improvements The City in conjunction with the Coastal Commission and Coastal Con- servancy shall investigate the funding, maintenance, jurisdictional responsibilities and timing of construction for the access improve- •ments recommended in the Toups Report. VII . Hour.ipg The follovring revised policy language was adopted and shall be substituted for the policy language on housing in the draft land use pl£tn in its entirety . Policy 8— -1; Provision of Affordable Housing The City regards the Carlsbad Housing Element as the primary document- guiding the provision of affordable housing throughout the City, in- cluding the Coastal Zone, and incorporates the Housing Element into the Local Coastal Plan by reference. In addition it shall be City Council Policy to require on a one for one replacement within the coastal zone, new low and moderate income units where existing low and moderate income units are proposed for demolition unless such units proposed for demolition are not economically feasible to rehabilitate. Major provisions of the Carlsbad Housing Element include: A. Jfeintain and rehabilitate existing stock of lower income housing. B. Develop and implement a Mobile-homo Park Zone to protect existing • and proposed inob'ilchoine park developments (accomplished 5/81). C. JbtaMish a Housing Development Fun;:! to assist in the provision of affordable housing. J). Identify suitable higher donruf,y sites in Master Plan Areas for low and moderate .income housing. . ' - ft ~ ' .j MEMO TO: Commissioners Interested Persons April 6, 1981 E. Beck Article 34 Referendum authority for the construction of 1'JO units of elderly/handicapped low/moderate income housing (accom- plished 1/81). ' P. Establish Condominium Conversion Ordinance (accomplished 1/81). G. Revise municipal codes and procedures to expedite the processing of applications for affordable housing- (underway). II. Participate in HUD local Area Certification Program, to reduce processing time and costs for MA. funded- housing' developments (complete 2/81). I. Provide incentives to assist in the provision of low/moderate in- c.ome housing, including the following for projects proposing 25/£ inclusionary housing: 1. Density "bonus of 25^ over otherwise allcwable residential density, or two of the following; 2. Exemption from park" dedication requirements, 3. Construction of public improvements adjacent to development, including, but not limited to streets, sewers and sidewalks. 4- Utilization of federal or state grant monies or local reve- ' nues to provide land cost writedown. 5. Exemption from local ordinances which may cause an indirect increase in the cost of housing (reduction in off-street parking requirements, reduction in processing/permit fees, • etc.). ' . °- FINDINC4S FOR APPROVAL . •1. A 9 r i culture The Coast Regional Commission finds-that the issues involved in preserving agricultural lands and promoting agricultural production are the most complex issues in the Carlsbad LCP. At the public workshops held by the consultant during preparation of the initial draft of the LCP, the issue of preserving agricultural lands was discussed at length. The PRC Toups draft of the LCP and the technical support paper on agriculture prepared by Toups provide a substantial amount of information regarding the agricultural economy of San Diego. County. These documents indicate that agricultural operations in the Carlsbad area contribute significant-lv to the County, State and National agricultural economy and that the area is well suited for agricultural production. In addition, a number of other documents related to feasibility of agriculture in San Diego County, prior land use decisions and court cases support the feasibility of continued agriculture in the Carlsbad 'coastal zone and are referred to in this report. * In evaluating several alternatives to protect agricultural lands, the Coast .Regional Commission found that a combination mixed-use and impacted agriculture program would best protect and encoxirage continued agriculture in the Carlsbad area. There were serious reservations over the PRC Toups proposed agricultural subsidy progra-m as to its feasibility and administration. The Regional Commisson found that the mixed-use program was much simpler to administer and more likely to protect agricultural lands. The PRC Toups draft of the LCP notes that there is approximately 1,550 acres of land within the Carlsbad LCP study area which qualifies as prime agriculr- tural land uj, ilizing the Williamson Act definition (pg.' 18 "of draft LCP). Another 400-500 acres within the Carlsbad LCP has historically been farmed but does not qualify as prime agricultural land under the VJilliamson Act because the litnd has not been in'production in recent years. Within the PRC Toups draft of the Carlsbad LCP, or in the technical support paper for agriculture prepared by PRC Toups, the following information is provided. . • Agricultural crops in the Carlsbad coastal zone consist * • primarily of 'field flowers and a variety of vegetables, • '• particularly tomatoes. Relatively few greenhouse opcra- . t5.ons occur in the Cjxrlsbad coarital zone, the largest • is located off Poinsettia Lane within the south-western. portion of the study area. Production in the Carlsbad area is unique in that the crops which are grown can be grown in very few other places during the same time of year. This signifi.car.tly reduces domestic competition, • although -the area does compete with Mexican growers for markets for certain' vegetables. Pole tor.ioato production is the most significant vegetable crop in the Carlsbad area and in Sari Diego County, both in terms of revenue and planted acreage. The-tomato industry has a high ''multi plicr-effoct". That in, it generates a nubrjtcmticl amount of direct and indirect - -10 - economic activity. Revenues from polo tomato production tend to fluctuate widely from year to year, primarily because of competition fron other areas, adverse weather conditions, and disease problems. Disease resistant varieties, however, have increased yields substantially during recent years. ' • Other "crops noted in the PRC Toups LCI"1 draft as being either currently grown or capable of being grown in the area include: cherry tomatoes, strawberries, snap beans, cabbage, calif. lower, celery, cucumbers, chives lettuce and squash. Additionally, field flowers are a significant nursery crop grown in the Carlsbad coastal Kone. fts stated in the Toups LCP draft E.nd technical support document, climate is the major factor which has determined the success of the areas agricul- ture. The soils, while not defined as prime by the Soil Conservation Service of the U.S. Department of Agriculture, are nevertheless (for the most part) class III and IV soils which are well suited for growing truck crops, tomatoes, flowers and other crops. This is sxipported by the following data contained in Appendix 6 of the Toups technical support paper relating to tomato production. PRODUCTION ARKA otionwide California. Ban Diego C'o.xmcy Carl nbr.d Sj-horc of Influence PRODUCTION IN TONS 1,000,000 333,000 165,000 ' 78,000 % NATIONAL PRODUCTION 1.00% 33% 16% 8% % STATE PRODUCTION N/A 100% 40% - • 23% AVERAGE ' YIELD/ACRE 8 tons 11 tons 30 tons 30 tons HARVESTED ACREAGE 125 ,"000 29,400 5,500 * - 2,600' % NATIONAL ACREAGE 100% 23% 4% , 2% ?- c-.•> o ACRi - N/A 100 "1 C*J, *-> 8.8 The Coast Regional Commission recogniz.es the importance of certainty in real estate and the future of renewed agriculture in this area. In order to assure renewed and continued agricultural production, the Commission is suggesting a mixed-use/impactcd agricxilture approach that will assure renewed .and continued agricxiltural production. It would allow additional develop- ment incentive's in exchange for preservation of agricultural, opportunities through a mixed use concept and encourage interim agricultural use on impactc lands. In the Commission's opinion, the approach provides economical, foar.it: development opportunities consistent with preservation of agriculture. The Commission believer, that planning designations that enhance economic feasibi by allowing development of portions of the property or by provision of inoon to encourage agriculture on-impacted lands may be more protective of agricul because they provide a mechanism for permanently protecting the best «igri~ cultxirnl land and encouraging continued agriculture as long as • feasible on loss suitable agri oxiltural lands. With.the adopted policies*., the Koqional. Commission find:; the W1P policies regarding agriculture'. in eonformanco with applicable..' Coastal Act policies. - 11 - The revised policy language adopted by the Regional- Commission is a | „„ clarifying the PRC Toups policy recommendations and at ensuring thai |j, n velopment adjacent to the lagoons are sensitively designed in relal li ,' "" the resource values of the wetlands. In the draft LCP for Carlsbad, t'RC Toups found that there are thren M i ijnificant wetlands: Buona Vista Lagoon,. Agua Hedionda and Batiquitor; Lauoon ,,,,, within the Carlsbad LCP area or in clone proximity where direct an<| impacts iron upland development within the. LCP area can affect the l resource value of the lagoons. The PRC Toups draft of the Carlshvi;| |,r|, provj.des details on each of the lagoons . (pgs. 44-48) and indicates that eoc), lagoons is unique due to salinity .levels, water level, urban encro.i, and ownership patterns. Suffice it to say that each lagoon does li,,v "cant habitat resource value. This assessment is supported by the ' State Department of Fish -and Game which has designated the three 3,U|, K,lu; as important coastal wetlands and are, thus, given priority protcctiou ,,,llk,r Section 30233(c) of the Coastal Act. . • . ' Additionally, certain terrestrial areas of the Carlsbad coastal zon,, r. noted on page 51 of the draft LCP have very high habitat value. The Toiipn cirnft . states the following : These areas are generally confined to steep slopes, which are jVii suitable for farming. These areas exhibit a large nvurber and diversity of both plant and animal species, several of which a)(, threatened because of extensive conversion of coastal mixed c!''ii',u-ra_\ and coastal sans scrub habitats to urban or agricultural uses. AI... «. •"* . . * * -'- «, > -*J f .well-este-iblished and well-maintained vegetation is a inajox- dot ,.,, ,.(<n^. to seal erosion and attendant difficulties. Mainteiuince of viable populations of rare plants and animals i;i directly dependent upon maintenance of appropriate habitats. f:|,|1%.j._ • f leant upland habitats comprise the coastal mixed chaparral an,| ( no coasta], sage scrvtb occurring primarily in the Evans Point area ,nu| the Palomar Airport Hills area. These two areas have been des I , mated as Rcsourco Conso rva_tji._on Areas by tlie County. This dosignatioii j ,-. characterized by "significant vegetation, stands of trees, and v^iJc1- life popvilations wiij.ch are to be protected by the use of sensJ \ iv,, resource regulations and/or appropriate land. use controls". (p<j. ;JQ • •. -of PRC Toupp LCP draft) ' . Another resource issue addressed .in the draft LCP is soils managciiK'hV, , Qn pages 42 and 49 of the draft LCP, PRC Toups states the following: * * • Soils of 'the upland areas arc fundamentally important resource: t nn(i require study and management to prevent both loss through acce | , ,( a( ,,cj erosion and degradation of downstream, areas 'through sedimentat :. 1 (,,, t • Very .large areas of credible soil exist within the Carlsbad CO.L.JI aj_ zone* ... Vlic removal and disturbance of natural vegetation, especially n;i hillsides, should be minimi./.ed so that tho erosion ]>roces:;- is in^. accnleral'cd. Intensive erosion rc-movVs rich topoo.il. and inhibit, | tlu; re growth of vegetation. Kixulod liilhslde:; arc also acsthot | CM!) y dir:j)lciasing. Another major afreet, of: erosion is excessive sedimentation in reservoirs downstream and the transport of associated pollutants, such as phosphorus into the receiving waters. .Excessive sedimentation disrupts the natural •ecosystem in a number of ways including the destruction of naturixl habitJtts for certain r-peci.cs of animals. • The Cotist Regional Commission concurs with the above findings made in the draft LCP, and would add the following findings. As noted in the Mello Bi.31 Properties (AB4G2) LCI1, there arc two problems with sedimentation that are of special concern to the Commission because of their effects on the lagoons: increased sedimentation from the urban development process, and increase streambed erosion resulting from paving and storm drains in urbanized areas. Several publications note the dramatic increase in sediment production caused by urbanization, "Effects of Urbanization of • Sedimentation and Flood flows .i*n Col ma Basin, California" by J. M, Knott UoGS notes an increase in sedimentation to 130 times pre-developnicnt -rates. In- creases of 100-fold are also noted in Evaluation and Control of So:! 1 Erosion in T.i rb ?! n i ? :i n g Watersheds by Chang-Nine Chen while ever, more dramatic increases are related'in "Control cf Sediment:; Resulting from Highway Construction and Land Development" by the U.S. Environmental Protection Agency, 1971. The Commission has observed these effects throughoxit the San Diego County, and has. found Lhat stringent controls over the timing of grading and policies to assui'e revegetation are necessary to minimize these increases. The policies of the Mello Bill Properties (AB462) LCP provide controls and policies ana- logous to those required by-the Commission in its permit decisions. The second major problem with sedimentation, and the major long term concern, is increased flood flows due to urbanization. The Commission's own consultant, Karen Prcstegard, in "Stream and Laigoon Channel of the Los Penasquitos Water- shed, Ceilifornia, with an Evaluation of Possible Effects of Proposed Urbani- zation, "* reported that increased urban runoff can caruse stre.ambed erosion for periods of twenty to thirty years, and is the major cause of increased sediment deposition in San Diego County. The problems of streambed erosion have, been dramatic in San Diego, notably at Crest and Lux Canyons, and also • within the watershed of the lagoons in the Carlsbad LCP, and in the dramatic increases in deltas at eastern end of the lagoons. The Commission has found that phased construction of storm drains is not sufficient to mitigate the effects of urban i Kelt ion because u'nlinecl portions of .drainagoways contimie to erode at an even more rapid rate after construction upstream. The Commission has also been concerned that construction of artificial drainagoways avoids the benefits of filteration of urban runoff accomplished through naturcil drainageways. In conclusion the Coast Regional Commission finds that the basic concepts proposed by PRC T-oups in the draft LCP are responsive to the applicable Coastal Act policies; but, because of the sensitive envi ror'.mcntal nature of the wel.3and;-, that the Tou'ps proposals must be refined to adequately pro- tect the habitat value of the lagoons and steep slopes and to guard again-jt OMccssivo erosion and sedimentation. Those necessary refinements an.1 pro- vided in the above revised policy language and result in the LCP complying with previous Co mini r.uion LCP and permit precedential dcclr.icms. - 13 - 3. Geologic Haznrds The PRC Toups draft of the Carlsbad LCP found that geologic hazards in- the Carlsbad area can be grouped into four basic categories: coastal bluff erosion; landslide:.;, slope instability and soil erosion problem:;; flood hazard:;; and, seismic hazards. In general, the data and finding;.; prepared by Toup;; in the geologic hazards' component of the LCP (rot'. pgs. 5G-GR of the drafi LCP) ar.e considered by staff to be adequate. A quick synopsis of the PRC Toups findings reveals that: a.' Shoreli.no erosion is LI serious problem due to loss of beach sand which has been accelerated by urban development such as construction of darn's which have sharply reduced sand transport to the beaches, improper design of coastal' bluff iTop structures resulting in drainage problcir.s which erode the bluff , and excessive irrigation which has created groundv:atcr seepage concerns. b. Landslide areas have been mapped and are located mainly on the north facing slopes along creek channels; slope stability problems are generally considered to be caused by human activity such as grading and increased amounts of groundwater (irrigation or wet-year rainfalls) and can occur at any location . c. Flood hazards potential is minimal in the Carlsbad area at this time. ' . • d. There is a "relatively very high" earthquake hazard in the Carlsbad area. In conclusion the Coast Regional Commission finds that the coastal erosion policies as modified herein will provide the necessary protection for shoreline development consistent with protecting public rights of access; that the landslides, slope instability and accelerated soil erosion policies. adequately guard against potential adverse impacts from development on these types of lands; that the flood hazard policies arc sufficient to protect development and that the seismic safety policies are adequate. The policies . result in the LCP being in conformity with previous Commission LCP and pre- cedential permit decisions; and, with the applicable Coastal Act policies. 4* IPublic Works The Coast Regional Commission found the PRC Toups proposed policies and .findings in the draft LUP adequate to comply with Section 30253 of the Coastal Act. LUP policy 5-6 was modified to clarify the need for Cannon Road, pro- vided Cannon Road is within the Carlsbad LCP boundaries as per Section 30171 of the Coastal Act. 5. Recreation ami Vi si . 'f "S The Coast: Regional Commission finds that the ir.suos regarding . recreation and visi tor-:;orving facilities arc adequately defined in the draft Carlsbad LCP, The Commi sr; i on concluded that .the LCP policies regarding recreation ami visitor-serving facilities nrc in .compliance with Sections 30220-30223 of the Coastal Act. - ' . . 6. Shoreline Access The Coastal Act places high priority on protecting existing rights of public access to and along the shoreline and also supports enhancement of public access and recreational Opportunities. The draft Carlsbad LCP re- cognizes the priority given public access in the Coastal Act and appropriately identifies the planning issues. The revised policy language listed above accomplishes the following: establishes as a long-range goal establishment of a nature trail along the south shore of Buena Vista Lagoon (Policy 7-6); requires, prior to development, dedication of lands subject to the public . trust and/or with potential prescriptive rights (Policy 7-8); and, that the City, Coastal Commission and Coastal Conservancy investigate the funding, maintenance, jurisdictional responsibilities and timing of construction for the access improvements recommended in the Toups Report. With the above noted changes, the Regional Commission finds the Shoreline Access policies of the LCP in conformity with the public access policies of Chapter 3 of the Coastal Act. 7. Visua1 Re sources, Special Communities and Historic Preservation The Coast Regional Commission finds that the Visual Resources, Special Communities and Historic Preservation Policies of .the City of Carlsbad Land Use Plan, as prepared by PRC Toups Corporation, are in conformity with Section 30213 of the Coastal Act. 8. Housing . . . . Section 30213 of the Coastal Act requires that "...housing opportunities for persons of low and moderate income shall be protected, encouraged, and, where feasible, provided", and; The Coastal Act also states that "New Housing in the coastal zone, shall be developed in conformity with the standards, polici.es, and goals of local housing elements adopted in accordance with the requirements of subdivision (c) of Section 65302 of the Government Code. The City has recently adopted a comprehensive revision to its General Plan Housing Element in accordance with said Section 65302 of the Government- Code. The Coast Regional Commission finds that the City's Housing Element contains adequate policy language to fulfill the requirements of Section 30213 of the Coastal Act. - 15 - 5/2C/B1 IMPACT OF SENATE BILL 102 ON CITIES AND COUNTIES ESTIMATES DEVELOPED BY LEGISLATIVE ANALYST AND SENATE OFFICE OF RESEARCH BASED ON SALES AND PROPERTY TAX REVENUE DATA SUBMITTED BY LOCAL AGENCIES TO THE STATE CONTROLLER CITY/COUNTY SAN IIEGO CARLSBAD CHULA VISTA COROMDO DEL KAR EL CAJON ESCONDIDO IMPERIAL BEACHLA KESA LEHON GROVE NATIONAL CITY OCEANSI0E SAN DIEGO SAN HARCOS VISTA VLF REDUCTION 11,567,220 832,485 542,848 398,113 57,137 408,717 90,66463,764 154447 0 0507,316 7,774,180 275,337 135,511 SUBVENTION REDUCTION 1,333,446 229,167 456,64378,890 31,635 496,948 442,220103 035 311,529 114,509 314,979 395,266 4,991,419 111,266 189,061 TOTAL REDUCTION 12,980,6661,061,652 999,491 477003 89-772905,665 532,834166799 465,976 114,509 314,979 932582 12,765,599 336,603 315,572 TOTAL COUNTY 22,807,739 9,591,313 32,398,752 Distributed to Council at the meeting of May 26, 1981, by the City Manager. COUNCIL ACTION: 5-26-81 Council directed that the appropriate letters of opposition to SB 102 be sent to legislators. 5/20/81 IMPACT OF SENATE BILL 102 ON CITIES AND COUNTIES ESTIMATES DEVELOPED BY LEGISLATIVE ANALYST AND SENATE OFFICE OF RESEARCH BASED ON SALES AND PROPERTY TAX REVENUE DATA SUBMITTED BY LOCAL AGENCIES TO THE STATE CONTROLLER CITY/COUNTY VLF REDUCTION SUBVENTION REDUCTION TOTAL REDUCTION SAN JIEGQ CARLSBAD CHULA VISTACOROHADO DEL HAR EL CAJON ESCWDIDOIMPERIAL BEACHLA KSA LEHON GROVE NATIONAL CITYOCEANSIDE SAN DIEGO SAN HARCQS VISTA 11,567,220 832,485 542,848 398,113 57,137 408,717 90,66463,764 154,447 0 0507,316 7,774,180 275,337 135,511 1,333,446 229,167 456,643 78,890 31,635 496,948 442,220 103,035 311,529 114,509 314,979395,266 4,991,419 111,266 183,061 12,989,666-JJ6K652 999,491 477003 88-772935,665 532,884166,799 465,976 114,509 314,979 902582 12,765,599 386603 315,572 TOTAL COUNTY 22,807,739 9,591,313 32,393,752 o MEMORANDUM DATE: May 26, 1981 TO: Frank Aleshire, City Manager FROM: James C. Hagaman, Planning Director SUBJECT: Summary of Major Policy Changes in Carlsbad LCP State Staff Report The following highlights the major policy revisions to the Regional Commission approved Carlsbad LCP, as proposed in the State Commission Staff Report. (p2-16) 1. Agriculture State recommends agricultural subsidy program administered by coastal conservancy, allowing land along 1-5 to convert by paying subsidy fee ($24,000/acre), and requiring areas between Palomar Airport Road and Batiquitos Lagoon to remain in permanent agriculture. Include review of program by state commission on annual basis. (p 23) 2. Cannon Road State staff has deleted all reference to Cannon Road from the Carlsbad LCP. (p 24) 3. Macario Park State staff makes no direct reference to Macario Park, designates park site as mixed agriculture/residential use; allows for park development at "future, undetermined site." (policy 64) (p 18) 4. Kelly Point Area recommends Rancho La Costa "sliding density scale" for Kelly point area, (policy 3.5) (p 16 & 5. Steep Slope prohibits development on 25% + p 20) slope; allow up to 1 du/ac credit, (policy 3-1, 4.7) (p 21) 6. Gradi ng Ordinance recommends amending municipal grading ordinance (policy 4-12) (p 16) 7. Buena Vista Lagoon recommends down-zoning all vacant Buena Vista Lagoon lots (including Point San Malo) from 10-20 du/acre to 0-4 du/acre. (policy 3.2) (p 7) 8. Mel 1o Bill recommends increasing density of Occidental parcels. (Mello Bill LCP) to 12 du/acre for participation in Agriculture Subsidy program. (p 24) 9. Encina Fishing Area/Beaches included in staff recommendations;should be deleted, these lands are in the Aqua Hedionda Specific Plan Area, (policy 6.3) (p 31) 10. Condo Conversions prohibit condo conversion where majority of displacees are "low/moderate income"; require 30% mandantory inclusion where conversion is approved, (policy 9-3) (p 32) 11. Affordable Housing mandatory inclusionary zoning of 25%. (policy 9.9) (p 14) 12. Agricultural Buffers requires minimum 100'-300' buffer between agriculture and new development, (policy 24) JCH:PT:rh -2- o 1200 ELM AVENUE CARLSBAD, CALIFORNIA 92003 Office of the Mayor o TELEPHONE-. 438-5561 September 24, 1980 Commissioners ^ • . CALIFORNIA COASTAL COMMISSION 631 Howard Street ' ... San Francisco, CA 94105 • Dear Commissioners: Because of the significant objections which the City continues to have regarding the Local Coastal Program for the "Mello Bill" properties, the City Council has determined that it does not intend to participate in the implementation of the plan. In the City's opinion, the LCP does not meet the mandates of 'Section 30170(f) or the policies of the Coastal Act and does •. •not reflect the needs of the City or its residents. Many of our expressed concerns have fallen on deaf ears. The Commis- sion's response, that we may seek change through the amend- ment process, is both inadequate and unrealistic. Because the adoption of this program will undoubtedly set a precedent for the'Local Coastal Program for the remainder of the City of Carlsbad, 'I would again like to renew our concerns.\ First, the City Council believes that the provisions for mandatory inclusionary zoning for low and moderate income housing within. .the coastal-zone, without regard to the. provisions of the City's Housing Element, is contrary to the express language of Section 30213 of the Resources Code which states: . "New housing in-the coastal zone shall be developed in conformity with the stamdeirds, policies and goals of local housing elements adopted in accordance with requirements of Subdivision(c) the Government Code." of Section.65302 of The City Council of the City of Carlsbad has accepted the responsibility to provide housing opportunities within the entire City of Carlsbad for all economic sectors of the community. within the The Commission's mandate for coastal zone disrupts overall. inclusionary City policies zoning and Commissioners -2- September 24, 1980 ignores the demographic, economic and social realities of the .City of Carlsbad. Because the standards, goals, and policies Nof local housing elements apply to the entire City, including the coastal zone, the Council believes it is\more appropriate to deal with the housing crisis on a city-wide basis. Because most'of the residential areas of the City of Carlsbad are with- in five miles of the coast, and readily accessible through convenient public and private transportation, the Commission's mandatory inclusionary zoning for low 'and moderate income housing cannot be justified under the goal of obtaining access to Carlsbad's coastal resources. . The second major area of concern to the City of Carlsbad is the permanent agricultural zoning which the Commission has imposed. The City believes that permanent agricultural restrictions for the properties involved are hot supported by the economic data. The City Council recognizes agriculture as an important industry and resource in the City of Carlsbad and has begun to adopt pro- grams which will protect the economic feasibility of agriculture in the City for as long as possible. However, the City Council realistically recognizes that there comes a time when no economic return can be made through agriculture. Permanent agricultural protection prohibits the conversion of the land to a different " • use-. If government demands that the property be maintained in a' use which is not economically productive, inverse condemnation may result. The City of Carlsbad does not wish to be placed in that position at this time. The City recognizes tha't protection of coastal agricultural- lands, particularly given the mandates of 'Sections 30241 and 30242, is-an important policy of the Coastal -.Commission. However, the City believes that this protection can be better achieved through methods other than permanent agricultural use restrictions. The-evidence presented at the Commission's own public hearing supports the City's proposition. Finally, the City has significant concerns over the grading restrictions imposed by the Local Coastal Program for the Mello Bill properties. The development restrictions based on slope, particularly those applied to the Rancho La Costa properties, clearly indicate that the Commission is not concerned with the protection of the environment but is rather imposing severe developmental restrictions based on an arbitrary standard. The City desires to protect its significant coastal resources', including the lagoons, but believes that goal can be accomplished through the use of strict grading standards, mitigation techniques and other requirements rather than simply resorting to a ban on development. ' . Commissioners • -3- ' September 24, 1980 Many of the resources sought to be protected by the Coastal Act exist in the City of Carlsbad. These resources are among the -assets which make Carlsbad unique among California coastal cities. The City Council desires to protect these resources according to the policies of the Coastal .Act, but in many respects has been given a "Hobson's" choice in the LCP for the Mello Bill properties. To accept the plan and ordinances as adopted by the Commission would be to subject our City to' liability, necessitate programs for which we lack legal authority and require that we act contrary to what we believe is best for the City of Carlsbad. If we' fail to adopt them, it appears the requirements will be imposed upon us by a continuation of the permit process. At this time we choose the latter course and advise the Commission that the City does not •intend to implement the provisions of. the Local Coastal Program or the zoning ordinances as presently proposed for the Mello Bill properties. If the Commission persists in this exercise of State land 'use control, you should do so with the knowledge that you will- be responsible for the implementation and administration of the plan. . . ...• -.; -...,.,,. ..-...., . •-.,.... . '...,- .: . .. ,.,. ,. ..;.-'. , ... Very 'truly yours, RONALD C. PACKARD Mayor .RCP/DSH/mla . ' cc: Assemblyman Robert C. Frazee DEVELOPMENTAL SERVICES D Assistant City Manager (714) 438-5596 D Building Department (714) 438-5525 D Engineering Department (714) 438-5541 D Housing & Redevelopment Department (714)438-5611 1200 ELM AVENUE CARLSBAD, CALIFORNIA 92008 Cttp of Cartebab Department (714) 438-5591 March 20, 1981 Tom Crandall, Executive Director San Diego Coast Regional Commission 6154 Mission Gorge Road, Suite 220 San Diego CA 92120 .Dear Tom: Attached are the Carlsbad City Council's amendments to the PRC Toups Proposal for the Carlsbad Local coastal Plan. On March 10, 1981 , the Carlsbad City Coun- cil took action indicating that the Toups Plan, incorporating the recommended changes transmitted herewith, would be acceptable to the city and will satisfy the city's requirements for a Local Coastal Plan. I have also outlined, for purposes of clarification, other written comments that have been forwarded to your staff from the city. These are as follows: 1 . Carlsbad Local Coastal Plan; Staff Summary provides a summary of city staff comments and recommendations on the Toups Report and Coastal Staff comments, focusing on major issues of substantial concern. 2. Carlsbad Local Coastal Plan; Staff Analysis provides a detailed analyses, by Carlsbad City staff of the Toups Report and Coastal staff comments. 3. Carlsbad Local Coastal Plan; Staff Summary: Council action provides a re- vised version of item (.1), pursuant to City Council action on the matter. I hope the recommendations transmitted herewith will allow the city and Coastal Commission to resolve differences regarding Local Coastal Plan issues, and reach agreement on an LCP document acceptable to both the city and Commission. Thank you for your cooperation in this matter. If I can be of further assis- tance in this regard, please don't hesitate to. contact me. Very truly yours, FAMES C. HAGAMAN Planning Director JCH:PT:ls sj I. Land Use Map Policy 1; Macario Canyon The city requests that the Macario Canyon Area "be redesignated as "open space", specifically indicating a park use. Policy 2; Agricultural Buffers The determination of agricultural "buffers should be made on a project-by-project basis; they should not be included in the Land Use Map. Policy 3: Agricultural Lands Agricultural use should be protected with an "Agricultural Resource Overlay Zone" recognizing that agricultural production may not continue indefinitely. Policy 4: Savage Property Downzoning Savage Property is inequitable; environmental resources would best be protected through application of design criteria/mitigation measures and utilization of planned unit development standards as a means to protect the lagoon ecosystem and provide for public access/view points on the lagoon shore. Policy 5' Open Space An open space designation should be applied to Buena Vista Lagoon and is necessary to protect lagoon resources. Policy 6: Mello Bill Plan should delete mention of Mello Bill Properties. Carlsbad Local Coastal Plan . . Page 1 C II. Land Use Text 1. Coastal Element 1: Agriculture The city proposes deleting the policy recommendations contained in the Toups report regarding agriculture, and substituting the following policy recommendatons: General Findings: The city makes the following general findings regarding agricultural production/preservation in the Carlsbad Coastal Zone. There are no substantial prime soils (Class I & II) in the Carls- bad Coastal Zone. The city recognizes the importance of agricultural lands as a uni- que resource, and supports the continuance and enhancement of agricultural production. The city recognizes the variability and constraints on continued agricultural production, and supports a program directed towards encouraging continued agricultural production, recognizing the inherent relationship between preservation of agricultural lands and the economics of production. Policy 2.1: Agricultural Buffers The need for agricultural buffers should be made on an individual basis; should be the responsibility of encroaching development; and should be "adequate" to mitigate potential land use conflicts. Policy 2.2; Protection of Agricultural Resources The city shall develop an "Agricultural Resource Overlay Zone," respec- ting the current underlying general plan designations, to be applied to those lands generally indicated in the Toups Report as suitable agri- cultural lands. A. Class III Soils. land containing Class III soils, or better, shall be considered "most suitable" agricultural lands, and may be allowed to develop subject to a master development plan for the entire property. Such plan shall not be approved by the city un- less a finding is made that continued exclusive agricultural use is no longer feasible or that to allow development on a portion of the property will enhance the continued agricultural use on the undeveloped portion. The master development plan may allow up to one-half of the property to develop with residential uses, shall cluster development on the least agriculturally suitable portion of the property, shall include a management plan for continued agricultural production, and shall provide appropriate restric- tions to protect agricultural lands. Carlsbad local Coastal Plan Page 2 B. Class IV-VIII Soils. Shall be considered "impacted" agriculture, shall be encouraged to continue in production as long as feasible, and shall be allowed to convert subject to conversion criteria (Policy 2.3). Policy 2.3: Conversion Criteria The city shall develop detailed conversion criteria to allow conversion of "impacted" agriculture (Class IV to VIII), considering the follow- ing: A. Relation to encroaching development and surrounding densities. B. Impacts on adjacent agricultural production. C. Occurance of diseased soils and/or poor drainage. D. Occurance of deteriorated structures. E. Documentation of declining profitability. Policy 2.4: Agricultural Incentives The city recognizes the need to protect and encourage agriculture on a city-wide basis, specifically noting the following: . The city has formed an Agricultural Advisory Committee to formu- late recommendations regarding the preservation/protection of agriculture on a city-wide basis. The city supports the enhancement of agricultural production through incentive programs including: adopting a Right to Farm Ordinance; preferred water rates for agricultural lands; develop- ment of a reclaimed water program, giving preference to agricultu- ral lands; encouraging agricultural leasing on Master Plan areas slated for phased development; support tax incentives for agricul- turally designated properties. Policy 2.5; Utility Extensions The city shall act to protect the premature disruption of agricultural uses by not allowing growth inducing utility extensions into agricultu- ral lands until such lands are designated for urban conversion, and agricultural production has been proven unfeasible, subject to Policy 2.3- Carlsbad Local Coastal Plan Page 3 o o Coastal Element 2. Environmentally Sensitive Habitats, Water and Marine Resources / Policy 3-1: Preservation of Slopes and Vegetation Although the city has reservations regarding prohibiting all steep slope development, the city recognizes that not all steep slope areas are appropriate for development, and proposes the following: In areas of special resource/habitat value or highly erodable soils, development of steep slope areas may not be appropriate. The city shall develop criteria relative to disturbance of steep slope areas, including the following: (1 ) Use of Planned Community Zone and General Plan density ranges to encourage protection of steep slopes in natural state, and to minimize alteration of natural land forms. (2) Development of design criteria directed towards minimizing disturbance of steep slope areas, including cluster develop- ment, innovative construction techniques, combination drive- ways, limiting grading to area necessary for driveway utility and roadway access, encouraging development subordinate to natural land forms. Development of a Hillside Ordinance directed towards regula- ting development on steep slope areas of significant environ- mental sensitivity. (4) The city supports density credit for steep slope preservation areas based on the density allowed for the entire property as a means of providing an economic incentive for steep slope preservation. Policy 3«7: Lagoon Management The city shall develop a Lagoon Management Program for inclusion in the Carlsbad LCP. At a minimum, such a program shall address the follow- ing: Structuring a joint-powers committee . to develop a maintenance/ enhancement program. _ . Recommendations regarding specific trails, viewpoints and access improvements; discussion of potential funding sources. Structuring program to periodically review and monitor the lagoon ecosystem . Specific designation of local, regional and state responsibilities and duties regarding lagoon management. Carlsbad Local Coastal Plan • Page 4 Coastal Element 3« Geologic Hazards Policy 4.1: Coastal Bluff Erosion (p 69) The city proposes utilizing Coastal Commission bluff-top development guidelines, requiring certification of "bluff stability and appropriate mitigation measures including subsurface drainage systems and drought resistant planting. Toups Policy 4-1, 4.2 and 4-4 should be deleted. Policy 4«3- Beach Erosion Control Measures (p 69) The city shall incorporate into the LCP recommendations regarding the establishment of a regionally- based beach erosion control regulatory mechanism, proposed mitigation measures, and a discussion of possible funding sources to reestablish and protect the sandy beaches. Policy 4.10: Steep Slopes (p 71) The development of mitigation/design criteria proposed by city in Policy 3• 1' Environmental Resources shall be substituted for Toups Policy 4-10. Policy 4.16: Amend Municipal Grading Ordinance (p 72) The city finds that the existing Municipal Grading Ordinance, incorpo- rating the policies of the Model Erosion Control Ordinance and the re- quirements of the Master Drainage Plan are generally adequate to con- trol soil erosion. In areas of identified highly erodable soils condi- tions, additional hydrology/soils studies shall be required, and appro- priate mitigation measures shall be applied. Coastal Element 4. Public Works Policy 5-6; Cannon Road (p 95) The city supports the Cannon Road alignment as proposed in the PRC Toups Plan, and feels that road construction may be necessary at an earlier date than indicated in the Toups Plan. Carlsbad Local Coastal Plan Page 5 Coastal Element 5. Recreation and Visitor serving Facilities The city fully supports the PRC Toups recommendations regarding recreation and visitor serving facilities, and finds no areas of substantial issue with the policy recommendations made in the Toups Report. Coastal Element 6. Shoreline Access Policy 1.6: Buena Vista Nature Trail (p 116) The- city supports Toups Policy 7-6, hut recommends deleting the refer- ence to eminent domain. Policy 7• 17: Access Improvements The City shall investigate the funding, maintenance, jurisdictional responsibilities and timing of construction for the access improvements recommended in the Toups Report. Coastal Element 7» Visual Resources The city fully supports the policy recommendations relative to visual re- sources contained in the Toups Report. Coastal Element 8. Housing The city recommends deleting the policy recommendations regarding Housing contained in the Toups Report, and substituting the following: Policy 8.1: Provision of Affordable Housing The city regards the Carlsbad Housing Element as the primary document guiding the provision of affordable housing throughout the city, in- cluding the Coastal Zone, and incorporates the Housing Element into the Local Coastal Plan by reference. Major provisions of the Carlsbad Housing Element include: Carlsbad Local Coastal Plan ' Page 6 A. Maintain and rehabilitate existing stock of lower income housing. B. Develop and implement a Mobilehome Park Zone to protect existing and proposed mobilehome park developments (accomplished 5/81). C. Establish a Housing Development Fund to assist in the provision of affordable housing. D. Identify suitable higher density sites in Master Plan Areas for low and moderate income housing. E. Seek Article 34 Referendum-authority-for the construction of 150 units of elderly/handicapped low/moderate income housing (accom- plished 1/81). F. Establish Condominium Conversion Ordinance (accomplished 1/81). G. Revise municipal codes and procedures to expedite the processing of applications for affordable housing (underway). H. Participate . in HUD local Area Certification Program, to reduce processing time and costs for FHA funded housing developments (complete 2/81). I. Provide incentives to assist in the provision of low/moderate in- come housing, including the following for projects proposing 25$ inclusionary housing: 1. Density bonus of 25$ over otherwise allowable residential density, or two of the following; 2. Exemption from park dedication requirements, 3- Construction of public improvements adjacent to development, including, but not limited to streets, sewers and sidewalks. 4. Utilization of federal or state grant monies or local reve- nues to provide land cost writedown. 5» Exemption from local ordinances which may cause an indirect increase in the cost of housing (reduction in off-street parking requirements, reduction in processing/permit fees, etc.). Carlsbad Local Coastal Plan . . Page 7 t I III. Implementation Recognizing the inherent relationship between the formulation of a Land Use Map and text acceptable to the city, and the resulting implementing ordi- nances, the city will defer comprehensively addressing the implementation aspect of the Local Coastal Plan until substantial issues regarding the Land Use Map and text have been resolved. Carlsbad Local Coastal Plan Page 8