Loading...
HomeMy WebLinkAbout1991-10-22; City Council; 11409; GENERAL PLAN AMENDMENT - HOUSING ELEMENT - GPA 90-8CIT~ CARLSBAD,-,AGEN~&LL h : C>.& ;. 27 AB#- Dl TITLE: GENERAL PLAN AMENDMENT - MTG. 10/22/91 HOUSING ELEMENT - GPA 90-8 CI JDEPT. PIN) I a I I I 1 RECOMMENDED ACTION: If Council concurs your action is to ADOPT Resolution No.?/ -3 s/ , APPRO\ Revised Housing Element of the General Plan (GPA 90-8) and Negative Deck ITEM EXPLANATION e > ;a :x a. w a The Housing Element is one of the seven required elements of the General Plan. schedule adopted by the State of California all jurisdictions in San Diego County are to revise their Housing Elements this year. Included within this revised Housing Eler Attachment) is: (A) a discussion of the specific housing needs of the City, (B) an idet of governmental and non-governmental constraints to housing development, and opp to mitigate those constraints, and C) an integrated set of six (6) long-term goals, thim near-term objectives, sixteen (16) housing policies and fifty (50) housing action 1 through which the City will implement its Housing Element over the next five years (thrc 1, 1996). One of the primary conclusions of the needs analysis of this Housing Element is that, \I City there exists a large need for, but a lack of, housing affordable to households in 1 and moderate income groups. This Housing Element includes an ambitious array 01 action programs, the implementation of which will enable the provision of housing opp~ to all economic groups within the City. The revised Draft Housing Element has undergone extensive public review includir public workshops, and three public hearings before the Planning Commission (June ~ August 7, 1991 and September 4, 1991). Consistent with Article 10.6 of State Law (Housing Elements), the State Department of and Community Development (HCD) has formally reviewed the Draft Housing Elen made written findings regarding the Element's adequacy. Copies of letters from HCD 8 letters of comment, with point-by-point staff responses are included in Exhibit "A, attached to the staff report to the Planning Commission. In response to issues raised by HCD and others, a list of proposed changes to ' Housing Element are included in Exhibit "BI of the staff report to the Planning Cor together with a discussion of each change. On September 4, 1991 , the Planning Commission unanimously approved the revis Housing Element (GPA 90-8). z 0 0 F a 6 z 3 0 The Commission did approve several minor modifications to the Housing Element w listed below: 0 0 * PAGE 2 OF AGENDA BILL NO. /!I YO4 1) In order to ensure that affordable housing opportunities are spread throughout and not concentrated in any single City quadrant, the Planning Con recommends that Goal 3, on Page 11 9 of the Housing Element be revised as Sufficient new, affordable housing opportunities in all quadrants of the City the needs of groups, with special requirements, and, in particular the needs o lower and moderate income households and a fair share proportion of future lo moderate income households. 2) The Planning Commission recommends that Policy 3.7.b. and Program 3.7.b., ( 124 of the Housing Element, be amended to delete reference to "single room oc( hotels". In its place, the term "managed living units" should be substitute Housing Element and a proposed Managed Living Unit Ordinance which sta bringing forward to the Planning Commission and City Council in the near futl Consistent with Article 10.6 of State Law, after the City Council adopts the Housing I it shall be required to be resubmitted to HCD. Within 120 days from the date of submit shall respond to the City with formal written findings stating whether the Housing Elern substantial compliance with State Law. If HCD finds that the Housing Element is in SUI compliance with the requirements of Article 10.6 of State Law, there is a rebuttable pres of the validity of the Housing Element if action is taken to challenge the validity of the in court. ENVIRONMENTAL REVIEW The Planning Director issued a Negative Declaration for the proposed amendmen Housing Element, finding that it would not have significant adverse impacts on the envir The Negative Declaration was recommended for approval by the Planning Commis September 4,1991. During the public comment period, one objection to the proposed I Declaration was received. After thoroughly reviewing and analyzing the objection, z believes a Negative Declaration is appropriate and adequate for the revised Housing E The letter of comment and staffs responses are contained in Exhibit "C" of the staff rl the Planning Commission. FISCAL IMPACT No direct fiscal impacts are anticipated from GPA 90-8. All future studies or progr< recommended in this Element, will be introduced to Council on a project-by-project ba: fiscal impacts of each study or program will be evaluated on an individual basis. EXHIBITS 1. Resolution No. q/ -351 2. Planning Commission Resolution Nos. 3254 and 3255 4. Planning Commission Staff Report w/ attached Exhibits "A-"E, dated September L 5. Excerpts of Planning Commission Minutes, dated June 26, August 7, and September policy and program language change is necessary to ensure consistency betv 3. Draft Housing Element (distributed previously) !I v ,4!P c 1 RESOLUTION NO. 91-351 2 3 4 5 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD, CALIFORNIA APPROVING A NEGATIVE DECLARATION AND GENERAL PLAN AMENDMENT (GPA CASE NO: GPA 90-8 90-8) TO REVISE THE HOUSING ELEMENT WHEREAS, the Planning Commission did on September hold a duly noticed public hearing as prescribed by law to c an amendment to the Housing Element of the General Plan GI and 6 7 a WHEREAS, the Planning Commission has determined t] project Will not have a significant impact on the environn 9 10 11 12 G 0 0 m u c z w 0 > 0 z z om 32 cum aQ8 OWN uom oa~ OoLL ’0 ‘Qi >ma urn0 ZJ u=o SUE gig ps p2 aZ5 uv ~ 13 14 15 16 17 18 19 20 21 22 23 24 25 26 a Negative Declaration was issued and approved on September in compliance with the requirements of the City of ( Environmental Protection Ordinance of 1980 and the Cal Environmental Quality Act; and WHEREAS, the City Council of the City of Carlsb; October 22, 1991 held a duly advertised public he’ consider said amendments and at that time receiv recommendations, objections, protests, comments of all interested in or opposed to GPA 90-8; and WHEREAS, the City Council, after considering all1 changes to the Housing Element of the General Plan direc City Attorney to return with appropriate documents to a1 City Council to approve the Negative Declaration and the Housing Element of the General Plan. NOW, THEREFORE, BE IT RESOLVED by the City Counci City of Carlsbad, California, as follows: 1. That the above recitations are true and cor: 27 /I 2. That the negative declaration on the above re 28 project is approved and that the findings and conditions !I 1 2 3 4 5 6 7 a 9 10 11 Do, &zm ooaa SUE v)> gang ou%% sgi: m,:g SO$$ '$82 U ' Qi +>.ma wcnv coca $21 :-a NU Isv 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 m IW Planning Commission contained in Resolution No. 3254 a hereto as Exhibit A and made a part hereof are the findi conditions of the City Council. 3. That the revised Housing Element of the Gener (GPA 90-8) is approved and that the findings of the E Commission as set forth in Planning Commission Resolution b attached hereto as Exhibit B and made a part hereof I findings and conditions of the City Council. PASSED, APPROVED AND ADOPTED at a Regular Meetinc City Council of the City of Carlsbad on the 27& day of 1991, by the following vote, to wit: AYES: Council Members Lewis, Kulchin, Larson, Stanton I NOES: None ABSENT : None ATTEST : ALE*m4TENm*G-clTk R (SEAL) 2 11 I le 1 2 31 4 5 PLANNING COMMISSION RESOLUTION NO. 3254 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CARLSBAD, CALIFORNIA RECOMMENDING APPROVAL OF A NEGATIW DECLARATION FOR A GENERAL PLAN AMENDMENT TO THE HOUSING ELEMENT OF THE CITY OF CARLSBAD GENERAL PLAN. CASE NAME: HOUSING ELEMENT CASE NO: GPA 90-8 6 7 8 WHEREAS, the Planning Commission did on the 26th day of JI day of August and the 4th day of September 1991, hold a duly noticed publi prescribed by law to consider said request, and 9 10 11 15 14 Commission considered all factors relating to the Negative Declaration. l3 submitted by staff, and considering any written comments received, tl 12 testimony and arguments, examining the initial study, analyzing the 16 WHEREAS, at said public hearing, upon hearing and con NOW, THEREFORE, BE IT HEREBY RESOLVED by the Planning as follows: A) That the foregoing recitations are true and correct. 11 18 B) That based on the evidence presented at the public hearing, tl Commission hereby recommends APPROVAL of the Negative Declaratic 19 I to Exhibit "ND", dated April 25, 1991, and "PII", dated April 20, 19' 20 I1 hereto and made a part hereof, based on the following findings: 21 11 Findinns: 22 1. The initial study shows that there is no substantial evidence that t amendment may have a significant impact on the environment. 2. The proposed amendment is not associated with any development therefore will not have a significant adverse impact on the envimm 23 24 25 26 ..... 27 ll .... I 28 Wl i/ 0 9 1 PASSED, APPROVED, AND ADOPTED at a regular meeting of tl Commission of the City of Carlsbad, California, held on the 4th day of Septer by the following vote, to wit: 2 3 4 5 AYES: Chairperson Holmes, Commissioners Erwin, H Savary, Schlehuber, and Schramm 611 NOES: None 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 ABSENT: None ABSTAIN: None r ATTEST: n CARLSBAD PLANNING COh ujfl- , MICHAEL J. H~ZMILL~R PLANNING DIRECTOR PC RES0 NO. 3254 -2 - 8 0 NEGAT[VE DECLARATION PROJECT ADDRESS/U)CATTON: CITYWIDE, City of Carlsbad, San Diego Count PROJECX DESCRIPTION: General Plan Amendment 90-3 Housing Element Revisic City of Carlsbad General Plan The City of Carlsbad has conducted an environmental review of the above describec pursuant io the Guidelines for Implementation of the California Environmental Qui and the Environmental Protection Ordinance of the City of Carlsbad. As a result review, a Negative Declaration (declaration that the project will not have a dg impact on the environment) is hereby issued for the subject project. Justification action is on file in the Planning Department. A copy of the Negative Declaration with supportive documents is on file in the P Department, 2075 Las Palmas Drive, Carlsbad, California 92009. Comments fi public are invited. Please submit comments in writing to the Planning Departmen 30 days of date of issuance. If you have any questions, please call Torn Ponsforc Planning Department at 438-1161, extension 4449. DATED: APRIL 25, 1991 MICHAEL J. MLZ~LER CASE NO: GPA 90-3 Planning Director APPLICANT; CIIY OF CARLSBAD PUBLISH DATE: APRIL 25,1991 TP:lh 2075 Las Palmas Drive Carlsbad. California 92009-4859 (619) 438. NOTICE 9F COMPLETIOE' Mail to: State Clearinghouse, 14 e .I Street, Rm. 121, Sacramento, CA 95814 *,, r sn MOTE Be Project Title: CITY OF CARLSBAD HWSING ELEMENT REVISIW Lead Agency: CITY OF CARLSBAO COntaCt Person: Toll POUSFORD Street Address: 2075 LAS PALMAS DRIVE Phone: 619-638-1161 x 4449 City: CARLSBAD Zip: 92009 County: SAN DIEGO PROJECT LOCATIOY: County: SAW DIEM City/Wearest Cunninity: CITY OF CARLSBAD Cross Streets: CITYUIDE Total Acres: Assessor's Parcel No. Section: Tup. Range: "--"----"""".""-----......"""""""""""""""""."""""""""""""""""""~ Uithin 2 Miles: State Hwy t: Waterways: Airports: Rei Lways: Schools: DoQ)(EYT TI# """""""""""""""""""""""""""""""""""""""""""""""""""""", EM: - NW - Supplement/Subscqwnt YPA: - YO1 OTHER: - Joi - - Draft EIS Othl - Early Cons - EIR (Prior SCH No.) - EA Fin; Other X Neg Dec - - Draft EIR - FONSI """""""""""""""""""""""""""""""""""""""""""""""""""""" - - LOUL ACTIOI TYPE - General Plan Uwtr - Specific Plan - Rezone AI - X General Plan Amnctncnt - Master Plan - Prezone R - General Plan Element - Planned Unit Developnmt - Use Permit C - C-ity Plan - Site Plan - Land Division (Subdivision, - 0 - - - Parcel Map, Tract Map, etc.) """""""""""""""""""""""""""""""""""""""""""""""""""""" DMLOP(EYT TIPE - Residential: Units Acres Uattr Facilities: Type - - Off ice: Sq. Ft. Acres Enployees - Transportation: Type - - Comnercial: Sq. Ft. Acres Employees Mining: nineral - - Industrial: Sq, ft, Acres Enployeer - Powr : Typh - - - Educational - Waste Treatment: Type - - Recreational - Hatardaus Uaste: Type - X Other: ELEMENT REVISIW """"""""""______________1__11_""""""""""".""""""""""""""""""""""- PROJECT ISSUES 01- IN WlllOlT - Aesthetic/Visual - Flood PLain/Flooding - X Schools/Univrrsities L X Agricultural Land - Forest Land/Fire Hazard - Septic Systam L - Air Quality - Gcologic/Seisntic - Sewer C-i ty 6 - Archacological/Historical - Minerals - Soil Erosion/Carp.ction/Grading - L I X Coastal Zone - Noise - Solid Mate b - Drainege/Absorption - Pgulation/Hwsing Balance - Toxic/Hazardous G X- Econanic/Jobs Public Services/Fscilities - Traffic/Circulation F i scat - - Rrreation/Parks - Vegetation x- L C x Ot - - - - - - """"""""""""""""""""""""""""""""""""""""""""""""-"--------- Present Ld U.aRaniw-1 Plr, UU N/A """"""""""""""""""""""""""""""""""."""""""""-"""""-------"- Project Wriptim GENERAL PLAN AMENDMENT TO REVISE THE HOUSING ELEMENT OF THE GENERAL PLAN FOR THE CITY OF CARLSBAD, a. NOTE: Clearinghouse will assign identification nrnbars for all neu projects. If a SCH nnkr atre- exist from a Notice of Prepmation or previous draft docrncnt) please fill it in. 8. 9 ENVlRONMENTAL IMPACT ASSESSMENT FORM - PART II (TO BE COMPLETED BY THE PLANNING DEPARTMENT) CASE NO. GPA 90-3 BACKGROUND DATE: APWL 20, 195 1. CASE NAME: HOUSING ELEMENT REVISION 2. APPLICANT: CITY OF CARLSBAD 3. ADDRESS AND PHONE NUMBER OF APPLICANT: 2075 LAS PALMAS DRIVE CARLSBAD. CA 92009 (619) 438-1161 X 4430 4. DATE EIA FORM PART I SUBMITTED: MARCH 30. 1991 5. PROJECT DESCRIPTION: HOUSING ELEMENT REVISION TO THE CITY'S GE ENVIRONMENTAL IMPACTS STATE CEQA GUIDELINES, Chapter 3, Article 5, section 15063 requires that the Ci Environmental Impact Assessment to determine if a project may have a significant effect on th 8 identifies any physical, biological and human factors that might be impacted by the propo provides the City with information to use as the basis for deciding whether to prepare an Impact Report or Negative Declaration. * A Negative Declaration may be prepared if the City perceives no substantial evidence th any of its aspects may cause a significant effect on the environment. On the checklist, "NO to indicate this determination. The Environmental Impact Assessment appears in the following pages in the form of a checklisl * An EIR must be prepared if the City determines that there is substantial evidence that a project may cause a Significant effect on the environment. The project may qualify Declaration however, if adverse impacts are mitigated so that environmental effects insinnificant. These findings are shown in the checktist under the headings 'YES-sig" respectively. A discussion of potential impacts and the proposed mitigation measures appears at the end 01 DISCUSSION OF ENWRONMENTAL EVALUATION. Particular attention should be give mitigation for impacts which would otherwise be detennined significant. 8 q PHYSICAL ENVIRONMENT WILL THE PROPOSAL DIRECTLY OR INDIRECTLY: 1. Result in unstable earth conditions or increase the exposure of people or property to geologic hazards? 2. Appreciably change the topography or any unique physical features? 3. Result in or be affected by erosion of soils either on or off the site? 4. Result in changes in the deposition of beach sands, or modification of the channel of a river or stream or the bed of the ocean or any bay, inlet or lake? 5. Result in substantial adverse effects on ambient air quality? 6. Result in substantial changes in air movement, odor, moisture, or temperature? 7. Substantially change the course or flow of water (marine, fresh or flood waters)? 8. Affect the quantity or quality of surface water, ground water or public water supply? 9. Substantially increase usage or cause depletion of any natural resources? YES YES big> (insig) - - - - - - - - - - - - - - - - - - IO. Use substantial amounts of fuel or eneigy? 11. Alter a significant archeological, paleontological or historical site, structure or object? - - - - -2- a 0 BIOLOGICAL ENVIRONMENT WILL THE PROPOSAL DIRECTLY OR INDIRECTLY: YES YES (sig) (insig) 12. Affect the diversity of species, habitat or numbers of any species of plants (including trees, shrubs, grass, microflora and aquatic plants)? - - 13. Introduce new species of plants into an area, or a barrier to the normal replenishment of existing species? 14. Reduce the amount of acreage of any agricultural crop or affect prime, unique or other farmland of state or local importance? 15. Affect the diversity of species, habitat or numbers of any species of animals (birds, land animals, all water dwelling organisms and insects? 16. Introduce new species of animals into an area, or result in a barrier to the migration or movement of animals? HUMAN ENVIRONMENT WILL THE PROPOSAL DIRECTLY OR INDIRECTLY: 17. Alter the present or planned land use of an area? 18. Substantially affect public utilities, schools, police, fire, emergency or other public services? - - - - YES (si& - - - - - - YES (insis) - - -3- 0. HUMAN ENVIRONMENT WILL THE PROPOSAL DIRECTLY OR INDIRECTLY: 19. Result in the need for new or modified sewer systems, solid waste or hazardous waste control systems? 20. Increase existing noise levels? 21. Produce new light or glare? 22. Involve a sigmficant risk of an explosion or the release of hazardous substances (including, but not limited to, oil, pesticides, chemicals or radiation)? 23. Substantially alter the density of the human population of an area? 24. Affect existing housing, or create a demand for additional housing? 25. Generate substantial additional traffic? 26. Affect existing parking facilities, or create a large demand for new parking? 27. Impact existing transportation systems or alter present patterns of circulation or movement of people and/or goods? 28. Alter waterborne, rail or air traffic? 29. Increase traffic hazards to motor vehicles, bicyclists or pedestrians? 30. Interfere with emergency response plans or emergency evacuation plans? 31. Obstruct any scenic vista or create an aesthetically offensive public view? 32. Affect the quality or quantity of existing recreational opportunities? 4- 0 as E& - - - - - - - - - - - - - - - - - - - - - - - - - - - - e 0 MANDATORY FINDINGS OF SIGNIFICANCE WILL THE PROPOSAL DIRECTLY OR INDIRECTLY: YES YES (si@ (iwig) 33. Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wild- 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 en- dangered plant or animal, or eliminate important examples of the major periods of California history or prehistory. life species, cause a fish or wildLife 34. Does the project have the potential to achieve short-term, to the dis- advantage of long-term, environmental goals? (A short-term impact on the environment is one which occurs in a relatively brief, definitive period of endufe well into the future.) time while longterm impacts will 35. Does the project have the possible environmental effects which are in- dividually limited but cumulatively considerable? ("Cumulatively con- siderable" means that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other ament projects, and the effects of probable future projects.) - - - - - - 36. Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? - - -5- e e ' DISCUSSION OF ENVIRONMENTAL EVALUATION PHYSICAL ENVIRONMENT 14. The proposed amendment is not associated with any specific development an( result in any unstable earth conditions or increase the exposure of people or PI geological hazards, change topography, affect or contribute to, the erosion of c proposed amendment will not result in any changes or modification of rivers ocean beds, inlets or lakes. 54. The proposed amendment will not have any adverse impacts on ambient air will result in any change in air movement, odor, moisture, or temperature. 7-10. The proposed amendment is not associated with any specific developmer therefore the proposed amendment will not substantially alter the course c marine fresh or flood waters or effect ground water or public water supply. The amendment will not cause a depletion of any natural resource or will use s amounts of fuel or energy. 11. The proposed amendment will not alter a specific paleontological or histc structure or abject. BIOLOGICAL ENvmONMENT 12-14. The proposed project is not associated with any specific development pro. proposed amendment will not affect the diversity of species, habitat or numbers of plants including trees, shrubs, grass, microflora and aquatic plants, will not new species of plants into the area, or act as a banier to the normal repleni existing species and will not reduce the amount of acreage of any agricultu affect prime, unique or other fannland of state or local importance. 15-16. The proposed amendment will is not associated with any specific development 1 will not affect the diversity of species, habitat or number of any species (1 animals, all water dwelling organisms and insects) or introduce new species into an area, or result in a banier to the migration or movement of animals. HuMANENvlRoNMENT 17. The Housing Element is interrelated to the Land Use Etement of the City's Ge: The Housing Element will not directly alter the present or planned land use o area. The Housing Element is compliant with the present Land Use Element j overall density and land-use. Product type (types of housing and shelter) are within the Element and may be addressed at the time of development. -6- a 0 18-22. The Housing Element is not associated with any specific development. It 1 substantially affect utilities, schools, police, fire, emergency or other public servic proposed amendment will not alter or result in the need for sewer, solid waste, h2 waste or other systems. The proposed amendment will not increase noise levels, glare or deal with hazardous substances. 23-24. The proposed amendment, The Housing Element, a required part of the City's Plan identifies the need for shelter and addresses the demand for housing in all e income ranges, of the current and future population of the City. It will not sub! alter the density of the City. 25-32. The proposed amendment will not substantially affect parking, generate substanti or alter existing transportation systems. 'The proposed project is not affiliated specific development project and will not interfere with safety issues such as el evacuation response pIans or increase traffic hazard to motor&, pedestr bicyclists. The Housing Element is a mandatory element of the City of Carlsbad's General Plan. : Element is undergoing revision as require under Government Code 10.6 Section 9659 intent of the General Plan Amendment is to provide housing policies within the residen areas of the City of Carlsbad of the City of Carlsbad General Plan. This amendment is I with any specific development project and will not directly or indirectly cause any adve biological or human environmental impacts. Its intent is to provide a housing strategy 1 the City's General Plan into compliance with State General Plan mandates and is consist San Diego Association of Governments (SANDAG) Regional Housing Needs Statement. -7- 0 0 ANALYSIS OF VLABLE ALTERNATTVES TO THE PROPOSED PROJECT SUCH AS: a) Phased development of the project, b) alternate site designs, c) alternate scale of development, e) development at some future time rather than now, f) alternate sites for the proposed, and g) no project alternative. d] alternate uses for the site, The proposed amendment to the Citfs General Plan, a revision of the Housing El€ is not affiliated with any specific project. Therefore alternatives such as site d phased development, scale of development and alternative uses for a site a1 applicable. The Housing Element identifies the need for housing for all segments current and future population of the City over a five year time frame (1991-19' identifies need, and establishes goals, policies and objectives to meet those needs a mandated element and under California State Planning Law. The no project alter is not applicable. The revisibn to the Housing Element of the Carlsbad General Plan is not associate! any specific development project or physical change. Therefore there are no alten for phased development, alternative site designs or scale of development. The HI Element is not site specific and therefore there are no alternative site uses. The HI Element is State of California mandated requirement for all .General Plans. TP: lh -8- e 0 DETERMINATION (To Be Completed By The Planning Department) On the basis of this initial evaluation: X I find the proposed project COULD NOT have a sigmficant effect on the environment, a1 DECLARATION will be prepared. - t find that the proposed project COULD NOT have a significant effect on the environmc environmental effects of the proposed project have already been considered in cc previously certified environmental documents and no additional environmental red Therefore, a Notice of Determination has been prepared. - I hd that although the proposed project could have a significant effect on the environ not be a significant effect in this case because the mitigation measures described on i sheet have been added to the project. A Conditional Negative Declaration will be proposed. - 1 find the proposed project MAY have a significant effect on the environment, and an EN IMPACT REPORT is required. r A .+, 2QLyq / / L. ?' lgnature / W " L-& - Planning Directo? LIST MITIGATING MEASURES (IF APPLICABLE) ATTACH MITIGATION MONITORING PROGRAM (IF APPLICABLE2 -9- e 0 APPLICANT CONCURRENCE WITH MITIGATING MEASURES THIS IS TO CERTIFY THAT I HAVE REVIEWED THE ABOVE MITIGATING MEASURE AND CONCUR WITH THE ADDITION OF THESE MEASURES TO THE PROJEn. Date Signature -10- I1 * * 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 I 20 I 21 22 23 24 25 26 27 28 PLANNING COMMISSION RESOLUTION NO. 3255 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CARLSBAD, CALIFORNIA, RECOMMENDING APPROVAL OF AN AMENDMENT TO THE HOUSING ELEMENT OF THE GENERAL PLAN. CASE NAME: HOUSING ELEMENT CASE NO: GPA 90-8 WHEREAS, the availability of housing is of statewide, region importance, and the early attainment of decent housing and a suitable living c for every California family is a priority of the highest order; and WHEREAS, the attainment of housing goals requires the participation of governments and the private sector in an effort to exp; opportunities and accommodate the housing needs of Californians of all econ and WHEREAS, a housing element is one of the seven elements California Government Code Section 65302 to be included in all local ge: which element shall consist of an identification and analysis of existing a housing needs and a statement of goals, policies and quantified objectives, an programs for the preservation, improvement, and development of housing; i WHEREAS, Government Code Section 65588 requires each locd to review and revise its housing element not less than every five years, jurisdiction in San Diego County scheduled to complete its review and revi! 1, 1991; and WHEREAS, Government Code Article 10.6, establishes specific t Housing Elements; and ..... €lMIBlT 1 2 e e WHEREAS, the City of Carlsbad has, with diligence and 3 /I conducted a comprehensive analysis of housing needs and from this analysis 4 Comprehensive draft for a revised housing element; and 5 WHEREAS pursuant to State Law, the California Department of € 6 Community Development (HCD), has conducted a review of the draft elemen 7 // that certain revisions are necessary to bring it to a state where HCD can fi1 8 9 element is in substantial compliance dth State housing element law; and 10 /I WHEREAS, in response to HCD’s comments and other written I.1 /I City staff has prepared replacement language to the draft element, which 12 13 14 15 16 17 18 19 contained in Exhibit B, dated September 4,1991, on file in the Planning Dep; incorporated herein by reference; and WHEREAS, the Planning Commission did, on the 26th day of JI day of August, and the 4th day of September 1991, hold duly noticed public prescribed by law to consider said amendment; and WHEREAS, at said public hearings, upon hearing and con, testimony and arguments, if any, of all persons desiring to be heard, said ( 20 11 considered all factors relating to the General Plan Amendment. 21 /I NOW, THEREFORE, BE IT HEREBY RESOLVED by the Planning ( 22 23 24 25 26 27 PC RES0 NO. 3255 -2 - of the City of Carlsbad, as follows: A) That the above recitations are true and correct. 28 i 1 2 3 4 5 0 9 B) That the Planning Commission recommends finding the revk Element, incorporating the language contained in Exhibil compliance with all regulations and requirements of Govern Article 10.6, and is not in direct conflict with all other Elem General Plan c> That based on the evidence presented at the public hearing, the ( recommends APPROVAL of GPA 90-8. I I 6 7 PASSED, APPROVED, AND ADOPTED at a regular meeting of tl 8 by the following vote, to wit: 9 Commission of the City of Carlsbad, California, held on the 4th day of Septer 10 11 12 13 14 15 16 17 18 19 I AYES: Chairperson Holmes, Commissioners Erwin, I- Savary, Schlehuber, and Schramm NOES: None ABSENT: None ABSTAIN: None ROBERT HOLMES, Chairperson CARLSBAD PLANNING COMMISSI 20 11 ATTEST: 21 li * 22 23 24 Planning Director 25 26 PC RES0 NO. 3255 -3- 27 11 28 0 * 6g STAFF REPORT DATE: SEPTEMBER 4, 1991 TO: PLANNING COMMISSION FROM: PLANNING DEPARTMENT SUBJECT: GPA 90-08 - DRAFT HOUSING ELEMENT - Request approval of the revi to the Housing Element of the City of Carlsbad's General Plan. I. RECOMMENDATION That the Planning Commission ADOPT Planning Commission Resolution No. 3 recommending APPROVAL of the Negative Declaration issued by the Planning Direc and ADOPT Planning Commission Resolution No. 3255 recommending APPROVAL GPA 90-08 based on the findings contained therein. 11. PROJECX DESCRIPTION AND BACKGROUND On August 7, 1991 the Planning Commission conducted its second public hearing on draft Housing Element. For that hearing, staff had prepared written responses (incluc recommended revisions to the draft Housing Element) to letters of comment on the c Housing Element. Staff, requested that this public hearing on the draft Housing Elen be continued until the City had received from the State Department of Housing Community Development (HCD) a follow-up letter of comment on staffs proposed d Housing Element revisions, and written responses to HCD's original letter of corn After taking public testimony on staff's written responses to public comment, the Plant Commission voted to continue GPA 90-08 to September 4, 1991. e 111. ANALYSIS On August 26, 1991 the City received the State Department of Housing and Commu Development's follow-up letter of comment on the revised draft Housing Element. 1 letter, with staff responses, is labeled Attachment "1" and is included in Exhibit ' attached to this report. GPA 90-08 DRAFT HO d jING ELEMENT I) SEPTEMBER 4, 1991 PAGE 2 In response to HCD's comments No. 2 and No. 3 of Attachment "l", staff is proposin incorporate; (1) a new Housing Program 3.7.i. into the draft Housing Element, together with a discussion about why staff is recommending these changes are includf recommendations 'W' and "X' in attached Exhibit "B". With the completion of the responses to the public letters of comment (Exhibit "Att) the proposed draft Housing Element revisions (Exhibit "B"), staff believes that the Hoc Element is in substantial compliance with Article 10.6 of State Law (Housing Eleme In accordance, staff recommends approval of GPA 90-8. additional language to Program 3.6.C (In-Lieu Fee). Thege Housing Program revisi Iv. ENVIRONMENTAL REVIEW The Planning Director has determined that the proposed amendment to the Hot Element will not have a significant effect on the environment and, therefore, has issu Negative Declaration on April 25, 1991. The environmental analysis determined tha proposed amendment is not specifically associated with any development project therefore no project-created environmental impacts are anticipated. There was one 11 of comment received during the public review period for this Negative Declaration. letter of comment and staffs response is included as Exhibit It". ATTACHMENTS 1. 2. 3. 4. 5. 6. 7. 8. Planning Commission Resolution No. 3254 Planning Commission Resolution No. 3255 Draft Housing Element (distributed previously) Exhibit "A", dated September 4, 1991 - Letters of comment on the Draft HOI Element, together with staff responses. Exhibit "B" - Changes proposed to the Draft Housing Element in respom Department of Housing and Community Development comments and other wr comments. Exhibit "C" - Response to comments on Notice for a Negative Declaration. Exhibit 'ID" - Draft Housing Element Staff Report, without attachments, c June 26, 1991. Exhibit "E" - Draft Housing Element Staff Report, without attachments, c August 7, 1991. CDD:lh August 27, 1991 e I) Errata to Ekhibit MAW Letters of Comment and Responses Report to the Planning Commission. GPA 90-8, Draft Housing Element Hearing of August 7, 1991 The attached text was inadvertently omitted from Exhibit "AIt. Please insert these responses to comments 9 and 10, received f the California Department of Housing and Community Development The insert should be between pp. 6 and 7 of Exhibit ltA1*. The Planning Department regrets the inconvenience. Response to Comment 9 Consistent with State Law, the San Diego Association of Governments (SANDAG) devel the Regional Housing Needs Statement, which was subsequently approved by the Calif; Department of Housing and Community Development. The minimum number of total hol units to be constructed in Carlsbad during the period of 1991-1996 is estimated at 6,273. minimum number of additional lower income households to be provided housing assistan 1,125 (as identified by SANDAG's fair share goals). The City's revised Housing Ele (Objective 3.5) has committed to providing 1,400 lower income households (275 units in e: of the identified fair share requirement). While the City believes that the provision for I lower income households is the most that can feasibly be provided over the next 5 year p given the market constraints already mentioned, it needs to be emphasized that if the marke able to produce the balance of Carlsbad's identified regional need, there is nothing that the is doing in terms of zoning or land use controls which would preclude the balance from 1 provided. As was explained in Response No. 8, there is suitable land and remaining dwc units to provide the regional need. - 10 You are correct in noting that residential uses would not be compatible uses within the Pal Airport Influence Area. However, there remains several industrially designated propertie located within the Airport Influence Area upon which residential uses may be feasible. 0 e SEPTEMBER 4,1991 EXHIBIT "A" Letters of comment on the draft Housing Element, together with stafi responses 0 e uj-&X$S $&e xe.g . 9629 gpf$;ffq':g.g ii ?q"pqs$I ly&\!p;2 *" OB" sg a,.-g8$ c EX gj ?$&-(is papSpbg_,e !!J 8,5 1 Z5$PU$ cm gn.L osm,,o. 5% f m 2 *.'" E$l. 2.3 g:,sgp, a f 0 m m.93 99'$2 m 2 @5f x.': .z agg 5 3 '$=:Egs.tj@ '$+xi Ea.'"g Q'5.g E" L g - bs=$?g ai: ; g?g s'ii@Lgs.- ,g g,g%68F{& .2:= 081&$69 2 332& 'CLL 3 5Tu .o_ Lom o.-t2S 8 hEQ2 a* a E.€ ao. a Q 6% g >.s c a= -.= h" 025 SPs-p .- J agEv1Ezah2a o a-- m ED& a 5 m 5e8sicEazL= .- o ? g$ !5fj):,zaa 8: g.2; ax c 255 8x32 5 52s v1c.E ~n 825 -="E; $32 5.5 2 8.~9 2 - E2iJ~;s a $= gigzgggssn 5; ss PX~S I ";~.g X~?.S% vj~.g3 m-05 0-9 &%g $3: 8 2': *= $5 iq$y5 2k.G +b m 5:jpp 5 &E 5: z:LpGk$$z; 2; .i~2~~~gua.5 a E73 cqi a6 p5 as'g m$5u rnca ,.ou g2.y;#2 Y@ sknz.g= Z? 0$gs gcE -x 2 g&,, c . OIn,~lO~ e= %gxo a%UEmz ' =?EX * E gilg; $2 2; .E Euc 3 ?ggh 2 E!!~mcm'c do .ruE.gZm%.$.$ 0$~ b E,E 6@ 3 . 2s gg 2 E?.g87 2 & g 5 h ac--&.;$mac a.c zmmm*- &'I a SrEr 22.- > m-g m 2 @US% c oz ~.;&J~.f'~~.ga,~z:g $5 : ~~0.~ 88 a; .u,58c s o 2.g~ t!j mu m 5 a- 2zpg @.Om m- a (:€ a;csgg gzz Ef !.E 53 !! 3.EE 25s caa.-$d6 g? 5 2.E9 E-8 22 gc 30 m 36 p>gpm qEe .- OaS~zmg~mm g-332 8-su2 =a= JAjcz a,= - 2 =a -S2gfspj as a g8%i;g$E.&E2b,g :as 2 uc v1 EC z Ia2 z- m.,aJgG'2gg hLQgz$z ' uu2-m 5 - o,€Z27J.==p .- 0.G a 0 u) $STu (, 2 gam as %',E 8g5 z.gr22 -8fi 62 g.E!l gg E 0.- 5E2gE2 - uz'!!.G~c~~~~ m; ~ay~~~~~,g~~ ,162 .gg~Ez2~~o=2E c v1 C aU21 E &KI 820 Qfz E'S ;p~~~&~, ~, -m a,$@+= m_BJs$ '$,_6fa amQ833 8.g 05 J-% m Cg'c C-2 sg.gH:eo azs 320 o ~SE.P rJ)cj .G L 2 - - '-ac >3.%2 ca 5'm%'$sUd8?% ~~~~~c8~,,5Ea -0 p6 822% ur.0 a g mr 'pzz E.2 m- C=.E=- ~azcmc~u~$ si .SQ~~OP~ .cazu$ zaa% IarnE3~E~ar 8~~~%'?~~~~ 8s Ee9,- a 8 pa 0 8.Y ,-8$i!?: aWE o~Oag%~$u~ 8 a==- nc, n,cazEOlj'~&O 2: Q.~~=ca~ 2.saagS c c E 52 2.L.Z B,svS$;B cj i 4 4 LI 3 F 01 ... r I - 5% .g - .- - ,- -, c- x C i ri G w 03 ow UOY rm m ?uOw"J m PI 2 ;:u :< 0 x:; .-rcVIOmmE 4 N GG Si ilY C.44 -4 EEGm3 0 rj0'4L: cPI3mil C> OQIONO a 0 P) cli il E.3.C = dTJCalGCI3 -40 Y u > a.4 m Y -la, QUI YYF 3ZU3ilxJnlCh 3UG mi U"U rJ :A ail h.4 B.4 CY J6OIP)SO 0 3 a 0 mi- JU rJ 0 ilu 0- >.-IC PI E a u > u.~ .c roalmm uomu oil4 TlUUVI6 PUP) 0m)rlPw 0 OUUH P ?IYO VIp1'0Llx u c= m AOU r: VI 0 .oPI3Lu.4 ? C 0 C'CIP 0-4 oam~u am> c cus~mmo uo(rl3r: Gfl.4 u-34 >iLlrlVIU~ 0.4 c 0.4u 0 .C>m zeac 0) u pi-4" m uuc CI 4J.d alalU J h iYiVIECU 3xc13il m40s a Li m ow pi E.4 Lio G7.c am 3u -ECu3P) k * D.a PG J 0.C P)Cr p 0 2.4 FVI ul u u s.4 "il -YPCul- Y c'm OU u 0 0 v) S il 0 GEUA VI 0 0 ci J il.4 '34 * C U ¶ 0 C J 0'0 -4.c xil 0 JUOVI~ 30Oc)O mr..+al c; 4bA-I al C 0 3- FhL mil 4 II m m z 2c- c~cz2~c~uY0 5 !2y:~.~~.~~ g7 IL (3 ALP J 3 3 oi 0 v).-'nO UYUlU>TJJEOu e r;i =r m c 0.3 ilw o u 3.- e ~5s- ~m C> PI0 rig um " si4 ¶ mo VIU? mu5; m 00 n ax mu BG il s.4 c "J OYO) mum€ 0 34 mu urn ¶dm 0 0 IB- Yxsh OU $4 al .3 .4 m m-3 aha P) 4 0 IBY VI E x0 mal su m mu u aavs ihmm --apio m43s m3 >u 0 +-.I .AH il U s am .-la ow s 4 m s U.M h4U E am CY VI 01 PIU4J-O U 4 a E xm UP E 0) 03 E Y mu 0 0 m -3 lIBWuaO mio z =&z3, 2% 8 .3 4 k ssal x rl PI al C .4 cn -. < sil 6 :< v yo 4 $ $22; 0 e c, JJ c 4J a 55 ma a aula 4 0.4 e> mho om Oc, kc, 0 ua m 0 ma3W . c4J a, 4 c, 02 CiN c-l xLlm a u mdm ECE 4 ..+ muE: I4 us UG.4~ u-4 B c, cc a0 03 04J -lac 0 wu a, 0.4 u.4 a, 0 a WEhh .A m 4 a, c I: m hW m4 39.4 ox a, m m 4 c -a ul a,@ u I-4EE cue a, a, a,dU!-!E E .4 a, 0 .4 a, acc,CIa, 0-i a, 3 u oa, e uc, Em E.d 2 h s z5a;zLl ria, ?2 .4 .r( u m swm z hu m m :: F&Z x cm .@ ea a ma, z.2 a,: mw $ em xu c .4 ul Inmo a, hm ra ul h.4 0 E mauum u 2.4 mc .A 0 xm mu CWCE 4Hmm -4 . .A 4 ul-l !-! 3 m.4 E .!J -4 n m m5 dm -I* a, u cu ex m hQ.4 4J U Ed C 4 a, 0 ut:4u s tT.0 m .A n, B "i QJ u~3m c, ui $42 mgoa. .4 0 rl me m .r- m U4JN c,Qa,I ul o-ln ma, c cr- s:B1: :5 $4 FZ a UP) .A 3 0 .d m 0.4 s c rl ul In- a, a,* s a 0 3 OCI corm %&$ omom UCO m ulw c xu c 0"iW a, u4J 0 !-! Zolcg 8 .; g.; 2 L %.A ocm~g 7u?sm Ea, h m> a5 rnrcl4 4 me c U .4 -lo Pc a 20 0 a,4J c ULl 01 Oc, uv 4J-l mm 22 mas: Llu s aW . CImo mal4 2.g 4 a, oa ha, hCul mu 4 -4 -4 e& marl 0FJm 3c ChO c, 0.4 -4 W u 3m2 23$4 a, h.4 umc em mmtn 0- ubJa uuc m4 m Hac cmm h0 om u$4 ma, aa x -l m a, c -4 VI & x -4 Lz 0 5 4 0 'ua "i F cc u 4 -3 YO ;XU. mra uwc *E OQ v @ c -4 n Hn I m 4J a, E 5 c, .. UU 40 GI W Ll a,o mr 5 Y ::; 2: s a.!c 3 mmmoc e04 OrnCPrE auo R .rlammm mm @a,c,c~l mmc, u) n .do > m4.4 -4 4Jmmo-lc u Ll c m u)"l w m.4 bo m0L.r.m ~lchm mcl4acdmb J VI& v)WO)G~v) o;ogp.+~aGam u uum 4Jmuu QUQO Ll -4.4 aI-rl4il m c mo u 0.44 m .rl ~l Q c'u 0 UP $44 u 0 u-4.4 -In0 7 7 a 04J?ta.-4 ~lmmaahmc,u-lm 7 m4'u"iu 'xu h cl m.4 xW2': 24amma4 c a 4-4.4 h0 2 . mc*ccmoc,_m c -la !-!Ll4ms do a 40 0 e 0 ah-4 m hm'u'u $4.4 P) o c.4 ~l-l m.rl.4 onn c ~l $4 .rl ad m m-4 e -QU o 0 u Q-l-l%4 Ll 0 Ll cc uu-lmc>-r(f: ac - rdvl0Od VIOC "0 mwmc !-L%25 tJ KI In % -G ais : -"S ;z c ma m m.44.d~ 0.4 Ll E Llu Ei 7E E hLl ~VQLU~~III adu I3-l 0.4 E %x dE 5 Cad mw!.lP)I=.rlUaplLl 4 QIIQT3adum> c'uc'u 0 7 E& c Ll c'uc,'u-lmcu~u~ nhubwuxxmax a, a, m P)-l-la, a 0.4 Q C TI 4J a aa m 0 4J 4 17 a5 0 uc x EH ad 52 F G 5 $2 5: .A .A ut- P 4 .4 Ll VIA dm UP) 7 OM c, 28 ':E? 74J , Ll m.4 7Q oc cm 4 $4 4 a EO c Ll IIQ 0 - 01: "I a, -4 'ua ur3 do) 4. ab uc am a-l , :a :.; .c 4J In5mJJa,m koeacal Id m05c a me4 0 7 -no -e c .-t&m o ~l.4-4 an 4~ m c, u-~l rn 0.4 u) m o)~~uu)nm EU am f"' Ec&cwZaJcaJe ;z v; 9 5 a XVIMaJM TYdaJ (I) > mS 8 ..& sme2z =-;;i.c:-e e 5 55 ..a.c:s gam -0 moVI"2 z- 7 5 -2 a aJ EV .d 2 X $2 k? .I km$;5 kg t.5 P) $ g bd $3; ':g<; 2&3 .g!2%ad2'e $-{ S"~2-U 5 s-z-sz-d4 5- 9" 3 VI o QZA 2 .5j = & g .g Q OEZZ ~C~$-"m z 2; g -0 gm m .2n-S ," 9 a, 22 -5 52; 2 g.2 '"-0.5 Mo?; .... ES,mm g.8 5 Z3P~ ;$? g -4 ur: ZV 2 c VI c c ma %g $2 !j aJzm o) m a. 22 c 2.5 E 2-2 Za"3.2 g.s 1 s; YI*z g .; 5 3 .+2 2: 25 3y 82 2 &$2 MA 25.2 2mc0-muc3 -0-, Wd ~ 5.g $2 2" aJ 0 c c E25 - GS m.> 3 ,uz 2 maa e aJ VI GSZVIaJ m5-2 k a.5 22 ul$hh5%ww "su E 2rnC.Z ;*% $.um:2 5 aJ 3 Y L.lS 8" 0.- Z"5Z2 -03 92 2&j .- aJ aJ e$; z 5s $ g g.5&+ QJm*E>g cQzo sk- VImS 0s gu >$V,ZS Fx " O'C E % VI MVI m c g.2- 2 jc.5-$-;: 2 2.,.,i &$, : ?g$!.$z 2% -d "0 ur u5 2-4 24 S&.;= O w 2 3.2;z m 5 a -5 .g 8 .u .E 2 VI- .5 56.2% . 5s.5 Ea 3 5 E .s .z VI"0 m 2 E %$aJ q .$ r gg9;:;2025: mVI sVI=m3 E o'2c:c3iti~ u .- ,d 82 mB'E 0 E 5 a$ Etaa a.3 9) c agr,c aJ aJ2m ai E.: m e 8.2 mau e c2 VI Om.---_C 3 m' VI' aJu~;.g~~eg r= .Q>boGa-do mcE cc @2 $y% 3 c 5; g55aJ $gpY -.- % 2 az m *m 2 E.z .e g E s &.C *.2 Em ,p 822 u3 $';a 2 :=E to2 .~ 6 - 2 .: m 73,= VI MOT o.o.-$j 2.pe-E E:u s ZZSZ m Mm.- Bg$s&gLle W't: EX> 2-5 E I e ab0L.G & 2.' c =pLd.g;: us: M&Z$ >arma Xm s22 1 8 9 2g.g g-8; ~2EL35+e VI'Z E a, aJVIg+J.s'-% a,.;; 0 aaJ aJ a.-c y%b 3-d 32 m a e- 2 $f,; OEM Y aJ.5 ggz gz 5 5 Y om . SB. &' ME ,@ s:zs2.'4 5 2%s 9 55- !cju Mtu a a& m% c-8: 2 3-Z y.g . 2 F. 5 0 ij*zcc 3 ,$W$ bo m m Mm Q c v) v O r$a 0 7 7'" +-* aJL3Y "22 0s: caJ1 c , 5T 0 2 l&4 E.$$ gG$ $22 22 go - 3.- > $2 g 2: c hVIs c.jz v .-.m 0 oa%.?jz w Wg.g3 !& $2 n .% +o-%yck cJz.,.s.., Q QJ 5 g .- -s E tu E? a ~ am + 3 z-;.g&+ a u aJ w 1 5- :: tu 0.- a-2 aJ 71 W'EEU 2%3zgpgG~ lu: o,.-.c as,:; xs2-g ija 2 0 WAG E6Ms M m F a-, d-C =;.$ r .9 q2;p.z 3 *a % -5 8 7z.e a.5 kL2.5 2 =: a 835s k&?& m 7 e....o $&a rv u 7 v"2goVI .?E ;p~~:za-"- Am22 Y @$ p !2$ 'G5 $,,,n tu "m e c .9 MZ o E *z tu g $% $! 35% 0" Y E E. aJg aJG2 EZb'Z? &J 2 .? -22 & g zg $4 .... .? 2 2 =; 2 E 8 *a e E M% 0 2 5: E%sbgs7j-ccE 8% c . 'G"St: c 0 z m 0 tu mx& aJ b.0 o aJ aJ w ggZE2g5gzd4 5Sj&+uG :I 8 gz 9.-e aJ 32 22 g:;Qa....soE celEY= 29 +.1"z&ygze a aJz1 25% 25 m u,.gfj 22; -e< v- 5 Lo.: aJEe E Zs> ~3 ~.~~.~ ,- &+Q E a2 eu. w q s3a .- c 13 YI gk&Ea c 2 VIVI mw 8 ak c a% " aaJ c-d QJ.2 bo3 aJ a, M<G ~2 22s B 5%- 01 aE VI L. '9 E' t- E :< 0, .VI 22% 0 YaJa tu .-c 32: u 0.- ;;;z 0 9) 7 @aJ$'im T2%!$$zz%gz -ug$zz*.gc m>momlo zaJ 5- E5-S a%w8gzo2 m2: 2; -Pv;MO 'i. g%z ZOZ EGg Y Y s3N > 0 * 0 aJ.9 c, 0.2 e tu2 '"a &e% 2 E u.= 2 9 tu m aJ 2.j 8 ~E"3-z $z Urn MZGS36 282 %aT* am aJ m ti 2a.m V.SaaJ *;l&---5 $2: z a- m'2M .%kt& hl, +~~maJm~~m~~ oou+mz3'ij m wamn25 ka-ca w ~mc3a~occ.- wEE. w H n E 2 a 4.l EI B 4 w D ..4 m 0 X a n .-I U 0 U 0 A u 4 0 a c mu a, !4G i am cr 4J-l s! 43 4J -le lnP)O~ 2 huaumU ow mmom m 3hh S OQa N-4 F F m.4 .rt .mha,mc cwcmmsm nrfucuv hoc ale 01, me -ala3 -hu 0 va -2 m.2 c-l PI 4.4 s a,u3 KUP)PY) F .4LIE0.4 s a4 EUd ..4 0 0 x>r k1,alCkca c 00 m4-l a.-i-ra,mo~ 03c:mc8 2.2 ZU 0 m€E Kp10htlO .rl u m a v.4 w -m ogm sm>huo 3 a.4 a, o m o E 31: mu a, v-l m.4 m+~ U~G m.4 o xo 3 0 ouu c E 111 -8Wd h Plooo ha, ec coo0 c .-i ln Ouaua!-la, ca 0- 0 VI Fa, 0 m aw 0 -4 cEuvl$mz a 2".5">r T-lU mx r u - FE~ eu m occhrnm~ w.4 h 0 fl a, a, 3 > a0 wu ma, PFFX coo31-13.4 ESU m amu c .rl -A m a g a k 4 5, k a k a coo mww mu cu $4 a, cu ln mrfa ow 0 E ;~J~:RO.,"$ a al m -m s.4 > u m.sm!-la, ma K a, z v.4 -4 m .d-4 4J m c ~~mmurn mu a.4 u -4 .s - a m 0 > K-l 3U ha00 Chd ah v am m m K a usmm molu -marl coInI.r-l0c W1,KtlO@ 0 4 KC04 M !-l 0 4 0 v u.4 Iu > a, ."I ae a, a4un u E > c ou 91.4 m 0 am cc3-4 u m4-l ow k.4 we 00 S 'c)vo3w 4UB a a,r(w mrf a0 &#I Ka 70-3 ah.. 0 x c- lO*ao) u >a m.4 3.4 mu o ou m m3amcuos ""$,2"a2 c.4 a, m4 o a ZumF mEZ.. mmL':$zaFj .4'-GP)2:a!-l %~rnwcuvao o--lmog hum hhrnO+J ua a m EQlU USW 0 0 LI m K v) almsuohm. cu 4 w a,@ u cum k u.4.4 a a, rd au ..-I74 0 u Fk DE P) >w m mo m o m.- a k-a a4 av 0 a, am a, h a, hen UOLEdU5 w a* M Y c k 0.0 hl a mu mm 3 .2 4J zz: 2 .-i rum 003 cc a,m sma, OOh -la 3 00 sum ac a a5 mal m Ea c-lo 4 a, a mo 3PIh 02. a cu um am v a c c1, 0Q.C E 1-0 m+w ah Ham IC ~m E5.5 . rfaa E aS a, mE3~ k .4 w .4 D-4 0 u x.4 h ocu hC31 6 c9 mu > 09) .4 xc a, 4J UP 0 Ti> 0 ._ rnskc) P 9) a3 0 Of2 m a,? 27sa::: S @K>m -4 a, mu > m c > 0.4-4 dah na C 13 al hm 4Jrl3.c CP) uma o>m urf u mu a.4 1 a4 N 0 cr cxcu E: m 74 v moma,on g",;;$ 4u F a, *uoo m m ou h G.4 a, a €4cLIulr(a,. I Od1,z I rl4u 0 0 m EO+ a, m.! 1 UEVlaIO mowrl3 10 krl-4 a, k w u *Urn 0 alaumk h 0 WuUd E M w ac.4 a, 0 mumc a 7 m anc-l r-nrm u3m 0 Ea 2, "8 cc 8 R t a, a 0 asao B4J UE ZIBGEO rf 4rlE34 muso em- a4m>LI!Z3 * c am -4 s .~a~m a 40 ma 0 !-lU 0 a, xa k F4.4 rra-IL%ao k .rlrf c P) m n- a cgm hma, u u ms.4 a .do~m* xc a,$$ P mn cs uGaam m.4a ucwc c c4J u 4 UuI CK:>I+C d@ * E3U-l rl JJa,c.rlm m *ma, a aa, c ado) a, -4LBO)uanem v a E m 6.4 u-4 43 (Uu.4 k e c 4-4 u >I@ Ea, coa3m 1 v) ad0 v)C: I "4 c > b.rt C a K N 0 m c.44 m 7 H~O E 0- 1a1a,a7 a HRCU Cca4 50 Plomua ula,.rl cw $44"(c.-4 a P) a DX>+, s-u km&lGodEI a n a.d o P) .rl .ul u 4 u a a 2.;: 1:zaE%$$ oca iaau 0 rc) m kEW .4 h m o mu c: DZI ual !a> 04 70 UW4J cm P) ma EaC 00 -1mm ammE a,w 0 LB 5OUb 30 G .4 a ammk u ma LBrl 7 a hala omcul w $4 0 au a d eo I COk Hrl U a H H *@'+I ma1 dh0 mw ul m cmaa mcul UP) u 7uou ul Uua 7m ul ulrl k k a.4 ma mu 037c !$? aum . > am 1 a2: LDO? 0Wda MTirl a KulO e3 uoulc 0c.4 u (D 0 a \01 Z"'5.g 5 .- %"cg2 2 a 0 .Lo 5 5.2 Y ui $.E" aJ 3 =i 0 0 aJZ Q) - x2; $2 - La.?% & 8aJom .55z3Z -8 -uw 5 ms ?I aJ .ua% -& U aJ E 3 -11 0 C mQc "-G .- U Y :E2575 2 - x SZSg - ,E s .$ me.: vj zi b:; g:& 2g 5 v-u L-cEn~k gm M;2 $ ,xu bo %% .G 3 *: 4 .g 7.' S-?SuS 25 0 WXTi~ 0 E& :3&jp zv .o 1. $!s c-ua :$ g+ $gg,2+- mo c.2 2; aJ 2C k;gg{g 2.g v~~~~o %a 2 "Lo u 2 F 23 z.2 &.'c E& 0 --- 8 m" 73: z g y 2%: .e."- 8.9.r:S.S* u $ y &C"U La m"'w w ZZb 3 oa $$ .; 3 gg g 5 $2 2 m Fgz*z -2 O aJd g-eaJ.00 CaJ v u .- P> .z 'G; + 'C aJ % c c 2 0 g-&s sm w.m 3.- o M m $ + aJx . .. g.2 2j < s..as 2 -m% V; &ha, m2 - kg .3 C aJw zzg 2 2 E$25% d ozsg u 3 --a C-mZ* 3.5.g .5 p .; ; E? E - 8ac FLq *s:a; 5M3aJ0.5 smzem +- an aJ$ bG 8 3 e, 2s 23 ;a ;-a EqpE pmm-.5 gp 22 - g,s gs 5 waJe2p .;5$222 aJ3sa-8 k62pZ '2 g 2.5 a 0 aJ.9 F g huo 5 @o": 7 (J c 2; u -2 sjgg2 "-a aJ uo m qz -zg&a~o-~ m GZjO e>,.c$ x 62 gkcm > .2 0 + -8.5 aJ ow aJ mu aJo(ff &22mo+ c glq d 3 &sa E97 2 o&-11 P c x 3g g -4" g $ B gz zv+c EoZ" n 6-3 *- gg2 ?gJ <.g$zL< a+d 0" z, k..8zz!co ";;;a aJ are a E E 86 ""h32 2 .- -%:G E sq+oi xm&mg goom CO gv c .- -In c m - % : 2 $3 us ; :zzb2 &E G a .-I >caJ a02 2-u ~a: E G.5.g ~ $ 224:: m 0. m .. c .- wm>oc a.9 EVb 0 hy. y 0 B2-2 J:g%:s 2.E 32 .8g ,xg$gg.s zs 2 .$5 2 B *22&3.S W 9) w5 2-63 +30UY JuU-lam 0 e N % &- 6 3 $2 ;= e - dd ; c .t: 'X e, ; .z s c: 3 .c x :s x 2 I g 8Q gg 2 V 5gg Da, G '7 .M pi ,-a G.2 0 QJCE 5.4 E 4 0.z 0, $EZ 4- aJ 52 m M Z-Q 2- 5 ar.0 a ac wu E 6.; 2 22 $:g ON ZEB $qth a2 $3 g g;s 01 6.2 .U 2 'd u 2 5 mmb \D E.2 ZQ c.l .- LC z c-c bV am rn wm m 4J c vi v4 u c U ! m at h 0 at a m e 01 z tY F4 r( n 0 m m WI $$Z % $2; Z3-Q % 62~2.~~g-~ a& 520..52= mw 2Q-Q 0 0 m: 2pq s :: s g2$.555 Es4<y;,8% gsp 2hh O 2 - gu a, NmzU5mZm;b.m-a,M w z2q 5 ; 0 g,FF w E.54= dpJ$p$ *Q G-Q mh&?2% gz m $2 g; k.5- h -"<;.'E T.="i & 0: 5 E22 g42.z c '2 c:a 0 N oa $52 a,v2 E-8 5 $2 0 rU 5% 2 a ~-~~~O1~~.~~~~~~~~Ga,aa,~ a 2 ac.l&L;;:r: gJ3 g 2 wu ZT 345:: 2 g :%z E: m5-2.E: :: ,e 5: Ej 52 5 2 7 p+ Y c: m A-&hs E $6 E+% a & 2 zgs 0" - .- E x w Ea w & ~.~ao ~ZO t: w %;a s.ag.5 g, 5 8 gz & ma, E bOz Q.~~U?~Q~ 0 0.3 m 2- hZ E gG$ c as ECJ c 92 0.G2 z &- E m ass a sa, wvgz g g 22 8s VI uJ c 5s s: u ME!o G 3- a % S.G E: m3 ms.c3.r. u &J;233 gq e % g6-Z g< E.: 2 2 g w 2-Q a c., --5 w.5 9 u ~zp$~~~ s m 2 a,'?.'!$ E E," B 2 c LZ i4 L%3 2: UZ .z.5mm.5 U x" 5=~2 2zj 2zX Q1 E .-us sW-2 8.z 3 wa c E m m 0) mvu-la OJ c T2 -= 2- k m 5 BUZ -gq ;..g g 1-5 2 2% a, m c m 6 v) g i3 zs.5 Wna u 0 c 85 3-2 2 2 t; 5, 0 h u c %sg p-S& c 2-i M2-Qc-l- I:aOMh on. w &ma C" v) EQ-Marn-c:s E2°j.$.&g b' p)*G 7 a, wNz'.G; 2 "AS 53 w m lA m d+,.p 0 si ,+ gz+""s@j:; $243 2 g 01 d." 9 3 03, 5 .: $8 "2 v) -IZ .z .G o ZMMa Cg &e '$!ma 0 Olsa a $5 pg=z; 8 0, aJ -0E:fiZ- 3 k sa.&$ !xw 0 3 g g g*ga w !d !dd w u aoy ci.*z= ! al 0 % 8 M" 2 E 34 '2 =: 2m.Z ??$.s -?2 kmma VI -45 E2X.Z OQ &Q L1 $zj"ogz. gg @x c s G >x$ x RJ.9rnI L1 0 UU 0 - E ~-2.2 n t; 3 a a w aJ.- cm amb g aJ c c a, we o.v- m'Z 3 m $& as m v1 m m h 25 3 aw v) $v 0 - h.- 0 wg -0c a 3 M.Z z.3 ~5 gE & M"35.2 2 m a5 2A g3 h m" c g-5 OJ 2 GJ N.2 4- ' ai &a,- CU N.O w 3 a Ma v)aNa ' '2% m-2 2.m-c 2.5 $*&wCU a 3 mU m3z'~un u gm hw 3 3.5 m N 3 G N * 4Ca, hW 0.4s LIE c>u 00 aewc c mffl >me amfflffl cau h u -4 w .4 .4 .4ffl-le >a, h m zu 05 oa wa mrlu m ad 0 rl.4-i Ch 3 c e-4 04 o a,mmom xc rl mm mb.4 nmcw- o mom mu0 7 VI crlu 7 > m v) mn.44 c c mu 0.4 m 3 rl m PI c a~uue mucam eo U.c x.4 PI 4 U rl c 07moal ClrlQNrlP) 0 'i D am a urn .rl om mma, *u ufflmcffl 4+a4 ala mrl u 3 ffl u.4a ac-a c rl >EdCC ffl 0 $2: L!!Z !-4a>c ea; cua, nT: ..A mc~lwrn~-u >.A or(. m m .rl -0 am-cl E c Ll 4 .O JJWd>-l 0 cc cmmww.. mwrlm -OK@ E m I: VI -4.4 C 2 8Z.2 :?arl.$ IrlK4J.4nP)70 rlwwm rnm'url o surl 2, m mrl l-IaaLlfflw-7w CwOPImmafflo ea, ffl mE m 0 UOCh rl m arl o.duxm a, a,a,mmw w me mrla w cua ouurl c c > I m Ll2 0 x hrlrla PI u.4 I u m.4 VI m 3 umoa cmrl '0.4 E.4 0 0 ad F W-4 W m u1 > 0 0 LIa DaJ w 3.4 0)-4 h cu uu PI 7 c Ll.4 3 cea,-lrl-4 c >um cmc 7cm m rl a, I m m 7 91.4 ma oa me 0.4 m x0 Llm"im0 2. uamu~4Ccu ~lmnxcu ED(U-P)E F .rl -4 eu>l7mCD da a, acm uw a, XPI~ c E u PIU m man cc o a1.4 ffl.oH.4 Ll m.4 cw a, oa 0 E PI 7u c CP) uawmm m~>Erlumz m a10 -a,m~ urn .rlooxa, mo me cc-i Oh PIE7 rlua .a a, cu~cu ~uomummmmmcm .ca (u 3 .u.r(.rl~m m am4 o 7 o h c Q u Q crl c x.4~ xrl0.4 w momhcnm mrl w rluw mcwa '4 Em .Ea -u .~'u 0)-4 o m.4 m a, c m ~l m ara m ho>m D ~l~merlmrlmrlo.4c.c rlrlamcmuu..+c m m>a, m acucx c-rlurlu~) arlrlmcr om apr~~-~cmuc -wuosmmm v-4 7 4yI Ldc.4rl w.4 E* rl c.-(1: o c war mu cowh>h O~~BOPI mrlccmmm m a.4~ m sw ~lna wm.rln ou h a u-+auoom.~aca~urn~~~ h uurl u cc~wmmm0~l0macm~o3ur-~ ca>c m.4P c.uu UmEaUCmOOLlrlal COG .dWV EE mm~a, wa .rlrla'~lwmm~ max u hew ~wmaw~lucaw rloua-rl .mummc-r(c mummoL: wrl.r(rlrlm 3 nmuom soarlo w>cou"~m~lrnc~lm~orn ma>% PI u) 3.4u u 00 h c.4 >u u.4 0) cm~~~meo~crn~a~~ncuccmc waa bow 2 E-@ u u.4 ~l mu m-rlua 3 NUS --lOH(U>IG UGrl UfflOPI u c E mo Ll a- VI DO u5Eu"wUa a;"&& 000 020c a kU 3 a EU-4 w.c v1 v1 m -j Fh %2 E OU a 0) hurl ad 0'0.0 111 m.4 PI CU X II u 8 :I g,gp 5 a.zw 2 223* SSk2 & 22: 2 3 a, ,s 'C &Z 0 G 01 $; $ E6.2 v1 Uho M 32 M C .- m N 0 v .Y Gm &ZE 5 m:x - h 0 m .2 .9 0 .- a, .3 I ;% 34 v) & gzz .? g -3.5 5 2 .c p2.22 5s m c4 & 2 3 !+ 2-z g: 5 rQ G& p_cmB" 5 ." .Y 4 g 3 '5 E.2 $%f=M-, :g E25 g .;g g 2% 6 .E p ZhTJZ 9-2 2 g hwo BN o> u 0.5 L12 s 5-z z-2 $ z- .,v)aJ3m d 8 .I 3 .5 ax VI -4 .4 OW Llwu m au PI c.4 c a a .rl ffl a, 4 Ll 'u 111 0.4aL: 0Llu rlm m a3 vi 7.4 a m c 4- GD uwcoww OLlQUEh 01.4 K m ea m en hu orl o E@ mdc a % "; 24J.2 om um amm wrl mdcumrlrl eo 7 0 & 30 ww D.4 c "lwfflu c ca= PILl .u e-DW 0 0) au 1w.4* mmumum DO c as10 a.5: ip;q 3-m m h o umwoouo meso; e*)~m mrl ecmmc w 5 2, IflH OR rlcm WLtLlat .mw a a>> m4Jm G 0 PI 0 W-4-l EU fflu E vlrl u w mnao)u A II I rl LJ , ,A Q) $$,&p??. v) aJs-cs Gc c*u .2 cz - 3 B y' 32 u 3Qa 0 - ' 3 355 22. .d 2T "aS2 x5 -m c"7 5 ' $mi32ca z.z.2 ra& 0,1: 22 2% 5 MU MC..= u O 3.5 g%- 3G.C "".E.;; 5 r, v)2! 2 9.5 s 3g?$3:$? 2zgs.gpj Em wd m.5 z $cis $23 2- Vra 6%; a,: M s.5%-zzz -0 c3 6 e .,a c3 >.- u 2 m.; mu 2G-::%$s w S.$$ mo z.2 $2 g& Ma ,a ti 'cI r:c;8zz.2" &C a,c; g -8 22: w M-Q 5g Y 5; w 8 h 77 0.9 G t *VI ;j s e$ u .- 8"" sZa3 z .- -2 Id m CL MU CJD.zn .- w .m c al oa w.5 c w ; 3 2 ti,='@ -unD Urn .5 c E U ?oxu I- tj 8 E2 5 :'% 'R h : .5 w m .- Fs&".Mg E $ m 1111 7 D: a4 ( ern< 404 1, 00 arl * .4 > . Llm mw a m- dco z ww4e w c1wp.p. uu om- hw rlrlrl~ an, .... wrl c .rl 7m m 0' ma us m g., ~l am c '; 1 :5 G - E& :2 23$% :e' v >4x:3 u"l wooa u atu PIG rlcr c crl Em mm I_, e e a4 -X t VI,O,zYP),CMM 4-u Ezzz*-8 Ejj P) cP.; E.2 o 2 2.5.3 Y cam E g 0s EjG2 mO - 0 Ce';.$.s g YE* g Pgz ;; 5.3 "cwTll"~w v)R 1 " 8 e.2g & Z$k 01 E k -3 u.- " @J1".C P) "5 & :&: n.0.; gzz 2 ,u g; E $65 Io5pi ro9 bv)> uG%$ 2 g.&3.Ga-s m.2 "8'g.5a z<<: c 3%.zD " QI & 0 c: 2.- $2 *<z:p z.c aJ .* rnZ"E!$ marr: as Lo a: " 3 2 &.=,-22 a-" ~gE,~aJm~oaJms3a" ,2 co~L?-o~,,o &% zz g6; E v) > Z@maa-S 0 .2 s 5 + m.w xu aJ.z c * $3 gJE5 2 23.e 8 z s $ gp . 5$ FS gz-g.5.:2gz2 &- v) a-z w.2 " 2.2.g; $.%E M 2 z 22.2.; E 3 p Y aJ c wmz 0 o% i.5 E $2- -.z%.Egp~u;-c"mP) -lz 8 G~ z.5 "3 5z 85--a 01 ' w; E.gN MYa O w-o 6" r ~E ,&c: 02 M 2.:" 25 v)'G d 0 a m 0 ' Y'GZ m 3 gLl$xw$g z g 5~ozEsz~8x2~g38 w*m 4- 0 am-5 g Q, 0) 0) $5.; 5-22 E '24 2 I"? L- €3 d c!u 0 I ";;sWg,22g"dN 3 $.= O a, E'L..SS 5 ,E%$ g gE2gg~2qz2L?€o$ 2 5 L; Q.z> ~2 g E$Z; C $ X E M'$Z.LZG 2 % w w a E wZ MOJI 0 on 22 P.3 &PZ.$L *a" a aJ e 366% 0 m 0'- c $= P) 0 "* h+ Qw "ENS, c t: m, 2 P) c 8. aJ wZd.0 aa>z:o G 2 '0 MU%? "-= ' 23 ase, 0- 3- m .2Zusy) ,U L. U ua I a", k .y a" m c "$" U-a,C+,FS 3';;iSSk-a swm ca x ;%E 3.g 4 '5 $ 2 " x.2 7 .z 4 $2 2 g.5 5 Ez2 E53 w2c z= c I"" 0) Y .- n"0, 2.z : a E$ :zaJ 3;; $52 z!$c jgg -z z -a Y $5 2w 2 2.2 m85 .E c 3 0 %: c% - .- c- g I E2 83 -0s k.2 (E! 13 a* 0 0mEP) 4 *o. Gn ' k-" Y m, 825% %'2 2 3 ; -4z a 2 v aJcz LaJA a =& -0aJaJ xw1. .- 0 2 $2 3v10 x Q =2 3 EA z&$ .Y a 0) c Q); .u, E x 3:; 5.2 g 2z ; & ..s .> e aJ a22 .- E .5 z =a k 0 z O2! 2 &z= a25 $a 9) Fgs ;j gzdJ - 2& 9 ax ; - E8-T z.34 I -I bEE.2 1.3 xm u 2 .$.Z m 7- aJ awl4 4 -g -5 2 gzy, 743 5 " G 3 2- '2 g g aJcw e, .- N +?$ ; u2 ,c- g "w e;": -gZ% 2.3 g "- ;; G us 3 5 -c .'= aJ .s % geg m 22 F w.5 4 $&g 2.9 2 -E $2.52 M.2 z E CZO 2 2 E.$ aJ a2 g 0 g; g Z2.M sa 22; m - M-0 -u- rn? g $2 MaJ vI - .I 2 g,ia a l4C'aJ : %+ sb E-= Vro- e-- u+ uQ.- cc *5 QJ .Y '2 S-d..'" -%.+-$2&m -m 2z2G: -5 v1 g.$@.?- zqzz,aJ P 2 14Ee $.E d!G &Z? &AlaJ$ $2: 3%* E: 2 $ad g T;kO 2 gq$;.2 .d c Em "U" 2,~ mL m = x.sq L. $ 2.5 " mal sa EaJ.2paJ Y 8 aE ;"E -.s 5 g G.G m2 u; g-2 s aJ%2 Y p 8 O1 ""d p 6 9 2 52ZZ y .& 2m, aJL , vl-$w vI- vl-O% 3 %O sc 3- c , 5 5 5 22% i a.,z 0.52s --,a c 0 0)- c: AQ.2 2 Z.? 0 aJ aJ 3-2 s .4 -.aJaJmgc Uk aJaJ1. &<'2+ggd 2 5 g-5 g,.: s$&-.&gqj FZ.2 x:; L e gc.t mSaJ2-d 2 L, 5 't ,z .e b.1. t,J E 5,; $1: b - Z354$.&@ 2$2E!%ZU 2% m --- 0 a .d - .? m- 22 53- e? 2 g 2.Ch , ma, g g gu -ggpFvI E&aZW'2. 0" aJ v1 ?am .cz g;q+dy .- 4 .z -g ,Q + yc .Y -5 sW $6 2 3 m E ab . !22 sz Q5 pQl$.@;;.p g aJ a l. aJ vI ;sg 2 g -s-z : % 2 E: g g aJ aJ 5-g 5 2.- " 25.5 $? 5.5 $3i& 0 %:E2 pz 7,E E%m%Z.@% 8 0- Q-w 3580. Q,R mrr~ u 01 oa .gs SF2 ~E.."'7~ (IJ a- 0 ..: wmz -.= > ,e 0 .- 0.2 aJu v, aJ x ,a aJ -"(Inop! Y w3 A5w m3+J .. Q 'GU FJ s Be:? pz tz &-;.z.g:z &$d,-clEi g2n ea^ .4 ffl 3 fflcl ffl he drnffl m~e cah mha ffl4 a h N am -4 .a ffl rl DE VI 4 01 a u .r-lffl 0 3 &4fflma hammmc 4 4 % 2.2 2U -0 0" alG %.a* 5 $ * '$5:; P hU hG>K 3 cc ma c P) 0.4 w.2,~ , n a, mn5 c uadu 0 kmwd cd hrlm -4JdP) moa dN am P 3Wa,G4h P)uum almu 3 4 -?I m z a 0 a, c-40) >.-rc.-l >.c 3 3 x OE30 %aD215 ..!$$ ,202222 E ololu "kcla u a0 x 0 x 2 Z3PZZ5 ma -4Q.d h U h uffl 3rnm3c L4 fflx oxooo5 a, a, m 2 5.; BQ N 5 a3 affl hh uuac CL crlm ffl Ecl 4Jaraurlrl .4 mrl PI a m VI a m-d CGP E 5 ffl.z g.;g 0 ffl ad a a.4 a a5 s3 m onem cmmcoa, 3cI :: % ddud ha oa> aZ"CE';l uamol Ba5wuh /d me 0, u 3m x;4-;1 i TihOh Ua,.CP a0 n3ca a ca h % 3amc mJJ 0d)Bd) a,Q)rlD -+ ma c ham h n.4 m um3E mm ad .c 0 0-4 0 cu3 lo44 Ll d m.4 t7 hmm 1. e.: 5 a m xu m (us a, ffl.25 famo Z??w ",$E hm hu UOIffl ha 3 c 0 oc, a aoha >vu E cum0 .~mrnu nmcm meu-ia B u.4 u 6 Y 2 P, S$ 5; 5 .E bb3 2% 52 9 .; 0.2 eo 5% W 22 B 2 34- e% UE s2 0 .; 55 .z * aJw 5% b Zi3 g% $5 d, .d cz * aa Qm aJh W" 31 12 .z LI a5 Uffl cwu .ch cl c PP) mo-lalhmca lo 3 5 a4 ha arn4ua 3 u m c5 ffl c F;? ::.? ~$22 az m 5 c.4 0 Ut.$; 4 c1 EWE= a> om Uhc, *a, In4 C, C-NU E: 0 nffla-xcab4 * ucEePim5uw 3 m a-m E-CU oLio-ca oc h rlmmomu~) Dda- d4J E aumWc>mYk mpnaa,cnm c cam m a E 3.4 @a, EhwmaZZg Ln z E 0 e,f z.4 Pt -0 L.4 % - ?:u"iV5m-o 2d$:a0,zB4 UOKUVIZfhz$ c ma v 0-4 lo30 d cxc m > - x.& .r( m -uhmdfflOaa umE3UO LO hUaamdN a .4 -4 0 4 !4 - 0 ua kwU3Yo E -F"i E a u am P) v 0.4~1 r: uaau>cv1 udcEa a,oc a.4 c u m 0.4 mmomak-40 NUUC~Z~~~~+J rl a, e 3 a 4.4 0 xco.4rl I Pua mu"cd0cmE 12:2M2k 21 eaga* 0 .vl ,a aJ m .z .z EZgggac aJ2E 0 m 0 8 L 2 aazc c 2 aJs 2 bl aJ" 0 b.'q aJ- aJ g2 3&Qo"S 4 2 $.&g o$-s I$ -32 i2z 'y;" m e$ ObW3 *a)X 2 5.5 $3 ;a3 .z aJ Q) aJ 2.c 14c%~vIu,ao - e O% e: 3 &; 2; c s:g.~g%~8 v? 2 &:E, un.5 a's2."" mu-5 $5 r c 0 2 E9 e&% *s w k.22 2 3 aJ e., m4j Ffj $,zqi c -t2 zg22.=& "ee&aJ'" 4% Zaqqg$kC 2?%;;;9Um.s u+tgp"m' +a Y ".5 E u O8E !*g oi! 63- - v, ago O& a hZ2 %$L!$!3"0 - t&&z m .& u aaJ CaJ a3 -98 e.?% g $22N- m;;i E -$j e4.??a' mgg Gx.2 5 L Ea 2% g g2.$2$ LJ mzokoma% t-a ED. v 3s G VI .c k" Dc ma83bo 2 d .- aJ aJ +- bm~m 01: aJ 2 g -2 SI cz EqZ: -cE 8aJ 2 .sw* 3 2 $ @%, Q5 @J "= 0 2. &u.zz 0022 aaJ d a 6222 E, 2 m; .% 22:s 94.0 VI aJ +z 2 03 a bo 5 aJL 0. Gz "9 G.Z. b 3 z.5 23% vI g c $ma' mm 2 aJ.0 - c F;" .5m =-'z @ Ip; aJ .E 5.- OWAL. 6 &G% X 52 2SZ; "u .c $2 8. 2251.0,J p ma M 3 &E.% ~ -5 2.9 2 c 5 g 0 v1 coeg!,. a 2.2 ug235g $g U 32 gz w ," W.? &A Ep&S g+ j 22 aJ- .G mu 0 X g5-Z 4 2 m 0) mu, zc E$ 2.- a*,$ 63" g.2: c pEa.--a 223 c g-.-zJ= mu um&u 3.2 ,.% -lJ 0-c = z 7 a 5 km 2x0 F3uuw dn oc G%%Z Ill c -: ".:,x? >t .F 4 0)aa c .Cnoa, uu5c 4Ldg ZmxU 5$y!2a2y LI au m mu.4.c 6 E U-4-d E 4J h h C $4 rl K.4 L,a,cI.4- UOY m.c c m c~ e-+ E Fu"lhmOa*m o a, mu c-t.4 E. VLhmm uam 30 c a m.454 rl moaawma mocv3ou E. UO 0 45 s c.4 Emdu.4 7 E: .U - 5,"2ZU,""O 2: $2 2.2; 2 g2 mze3:+j.f$gs o~muP)mvoxk g$t:Ez$P)';;fg ;a a p *.$ g 4J.G b .s:$aa%2L8:: 55 tu,yg 0 2 v1.y F4 "a$ $5: 2.2 g .,$.,.,; :;$; ~u.rlmo~)ahc Y m url 0 .4P,Oh m 1.00 3 m a554 ow.4 e 0 k P) c.4 0 u.4 a u oau aa auu ha mmwn>P) h 000 . a,@ uom 0 ccffl ha aw 7 PIN NN~V~UQ~~U~ nha rl~m 2 00c.Caacmu c u;42'cd agn.dd5.4 E .A dkp b al+$ 5 >.A $ Pt cc g a ~r~.dc;mp~a Z25*43 2 E m e crl m m ola acT ~n mu a c aa c.4 lo o h .- g2-2.5 m tu .N 0 0 m In 014 .rl rl ~>avm u u ln0.4cnam un 44.7 5u a dcrlhwco.4 4 .",.=",;"::*gOggr:.! maa2%mzD%:a$l gg"2g~u:'~~~'d& a2.5tg .gg"$ .p %A5 h e-in- 1 m a map m2: arlrlum rlP 111 .%TU, $I'22m5? ..?$X: mu3 c u 0 wP)0m~~~aae4 c.4 m"+u.-tu or0 c ah& OY dr: I au arl m.4 t 'e,hw~c,rlrn mu u ~s-4 uc - ~arnarlu 4 hl8.A ma L.l u P) a+ gY+uu Mcna a.52 . 'uno FP) 4 &"am 1 m m.4 0 I El .8url.-lccccI I aaaavwrlummmm~)~ edge 04 7 Erld-4dG: e P) mrlrln.4 aam 3u rl rl2 ;; 2.f v) h a5 1 a0 0 74 9 0) E U ou3n v1 €4 c m a.c N G c a PI cur m om u m.-t~ m I kYN u w aaa d! PO ~E-OZ~OZE~~ E 7-1 m EO +.?I* m.4 Cl+r0.4 RW CmP) m.4u B II ,1 7 r 9 L."JL, 0 0 v.5 2 $371 go:$ "a"m F2 : .d m P 03 322 42 2 ha, a 22 2 aJ.2 g.2 2 m $% .I ?%? ._ oEg gam as z 2 754 am aJ !g % 25-z 0 wag c az2.Z .g52aJ mm ga 5 2.2 2 %&am E 2 .%-$ -- $2 E: E 6% s 0 ;.z aJ'eaJ,P -z 0 1 v) .%T;$2 dl 3Sda .- -71 VI 52 aJb VI 9 0.z I mu- >.- c .G EIOm g 5 marc: m z 3 am \o dl g 0 -0 m QI 6 z 2 E: 2 VI E: Y 0 r -2 2 3 u a I 3 mm*aJ aJ .* c OZB " T2G d aJ Bm 3 3;:yIVI 71 3ZSS .aJ * .- 5 2 + 2 aJu 3 6"'- P) 3 e.s3 2b pg 2 EaJ2 gGs G+eaJ > 05 $2 ;; <$E e2 ';1 Id .5 E " wrm -z 02 m113 2 C mu- 13 Ga3u 085 c 2s -0 %z2- egi'; $232 m 4 g..; $ ggz- 2 QZzg .Y mo 2 c=a e Q5.2 2 2-2 8 $3 0 22-5 B Q t: .Y .- 3E:aJdZ "-.E ' 3 u V12h> b ssm &.= M, .- 3Q 5 U QW c .2 a % G2 'C g BR -g : z s.2 g5 u g 52 qEg 0) g2.Z %ua @? g ?-VI 82; v E: .Y mm 2 Pi 2- $jGg bGz 2" l%ti L- % 2 .$ 'C 2; g-aJ - cz E 22 a2 0 3 5 8 6c.i g 12 2 5 %mu m kp S&& cb urn- "bM - 00 ** m GI '= me mm 5.2 M 2-* a 'E SI Y 0 - d .- 3bb g L2 2s UP $5 gs 2% 55 22 zec! 6% WE .e b% "yd sg, 23 WaJ w- 9 >aJ o> 9aJ mv 5s $2 52 aJ a $ VIb 25 -5 8 %" .9 : me a0 x 12 uu 23 ma cu .rl m em ..-! 6.4 mo E ...-! mu fi he mo ea PI Eo u oo hala rlc OSE wa,m ma a-4 GF 4 4 e mea am+, a woc 0 .c .r( rlc, a m oa ao 3 7a n4 u 0) crl m h.4 .+ma u umc ? gn E":. am gg m an m a mma PI0 E u muLC u 9) tn.4 r 0 us 9 N a* e az.4 mcoa e" 1 7- rl -4 3arl 5 Sam.. 3"$m"4 ac2mcx rl ..-!a nha r E mc, 0-4 m F.4 FFm &I-.+ $4 .4 a, 4cPI3m UlomoaCl N 000 JJ m.4 m 0 OECh mu4 v) * 3 mna o- w+ 7 C aa m- 4 or: a, a- > a-4 m u c, orlorn cr c-4 m 03 mo 0) Fm 0 Xu, 40 -'u a, c hm 40 una 0 hd c m >u a h am mz hUc,XX .: 43zw3 oohc,mu a4 E; Q a: $a,J?i?u" TI.; v1 g 02 1 PI E: Ea" maa i E25ZE5 omu urn i rla 0.4 0 m P4 E PI-4 a, 0 a, mrlrlr( E a so>u r:aammc enau5.4 .4 ?I . x4 V -9 aa h a C u Qcho -n ..-! ocmmmrl F ao a a oauo 4- e m a aaCrl3mM m ffl0c-I annoa E44 I E 0) 4 GWMX 2 PI:: . mrmm1o\JJcmamarl 0@3..-!h e .4 4 E a,m~whrlm..-! EEOO~ >ho~ a, C, OOOE-4 EdU ClU-l'O'U PI h sou 0) PI 0 €4.4 m m or h a -.-!r:oo>-caomuu>h ah3m mu gcu mmmmumnmor: mofflmoam aLIuL&w> w1un >04Jr(PIu'uc E mrl E m4.4 o -u $4 mc, u mrlh om rl €3 Q PI m -rl a.4 c.4 mu rl 4 PI4 we. 3mrlwm3JJ3 oma --IS4 0) 0 a 5 * 04.4 0 C W C Ka uc, huhu-d~13amcmmm mu c VI moca > om au-~mmc ah a~.1~4~rl-.-!ahcm~ 0) -.A m .d..-! 01 0) v1 h I 0) U.4 a-4 K e .-1ma.4cmmmm c mou~uumh m>aJJ-ihuhafflour m cue7 am~..-!mummom EFT. om uu u 3 m m7 ah e PI 3 m-4.4uo E 3 m3.4 ow u 70.4 a€ zuc,uo m url-dm xo GdJJ E I C3aah ~ o.:zasPE-4n or(-.-! me 3 an ma 0 0"S~ hz pzg ts : .$aw~~a~3aP100m0woa OhC0\@3gCOES EQa*cla .+ham ghm .+ma .4m m XC 3mcrloc cmou wmrlo>nr F uu uc, 0 cmhc5rl macrl.4 -4 -4am~ mo m a, Ecuh 17 *aGl3Q-EEuBOB u u0)a O)c,3h>O- m'umhartx$o mc4~ma~~mmamrlmu p) -1ha3corl ouarlcumm~~s ~~aaaorlumnmv,~,-~3~moasc Cmm.4CtnwrlclQo~oma~~..rlrlLI h XE l34J VIC -COW W'UV 5 aq -2 2 a !..'$+42 0 22 $2d$ 7c 1u,>.-la3 erle:+c2: E v1T: B B Q '--O'rlQ E.4 PI mt-4 a.44 4.4 0 WC.4 -?zaX..-!Qm.4.4 PI C .Cn 0 P).C 0 aQ PIQZ 0'0.4 0 CC.4 C 0 I II I I.!L,l 9) PI a-ln PF 052 3mc c adho u.4 m o m.4 u u ac mu Dm 3 e.5: F rl E.4 0.4 haCWQ mma 4 ma LC aa c.4 mh a FSrlO ln7.4.: mu.007 Cm7"lmrl PIVIK~~~ .-~aohmorlw UCQ 0 m ZS55.5. z21ncu e au.5.::.5 m.4 a cmu..-!o -3u m~mrl -a PIC ammo aEc.4mm a,hPIlnBaclPI 2mEmPI nmmulncoc m ana c rlrl E c 9.4 EU mtn m .+PI SNO) EUCU)C.z aLCPIU0 E mu h0 uu'u4a u.23aam owmm om0 -4 omma 'u capm.;; -4 4JhQ.dO F m w n %$c)umuLC, PI E 4-4 m -CamQB go? 22; a o E PI m n4J XU m c uo.4 am 7 0 h5 PIaOE 22: * m CI -0 UhCOECU 0 E .A u -4 ..-! m a.4 rl m c.d nrh Emu OmOStncC7Q -mu..-! F .- aPIhuPIFLC m ocd a hahu h ca aen QOOW 'u-luc hJJ 0. E7 a..-!craP umu 4 UF I Fa,.4.?& "4 momuoa -rl ag$tu c.4 0U,*gsa*; Q OQPl CJ%EPIQDmQfi ua aQaSo0 PI 32 ,$2't?@l 07ucSPI ulnas a-la crlauou QmmdUr;',$$m ~$33 m url.4 c QE u uc m VI E 0 E u 0 PI-.-! m LC S o ou un.4 ~ao PIC e 0 3 v1- mu2 2!G g ;gm s-dz w -G 2 : 0 5 %.e F z .E TEE pa. 22 w M 8 $ 2 .d 73 iaJ % w urn 0 G g.2 2 z.j g .- aJ u w.2 vl"O - .- 0 Q aJ - MZ 26 .g z .e 2 zzge g Ui5 2 6-2, wSU2 e$ 2% m 2s2; 32 ;; z-z? E 0 .s 2 2 - .z -; 3 2 - zz ; $22 002s g .B 5 .z mEOgJ 25 2.2 c u 04 EE-Fj- aJz aJ.13 2 .2 .% zu $22: ga2;moY r. 3 2 3:+25ez 32E-0 .%? ga 0 aJ-2 32 $%no h:sY50g 22pii2Ec5 .$: 2 g cJL& om3 n s-2 $5 2 ,s 2 $ $2 $3 ..;x.$ 73 E.:; 22 Ohw*eg 0 0 .e-. In w g3.g ME gE 05 2 e b.4 5 2 .Q j @E&Or: g 2 c& $! YI xm aJ aJc OaJ .i?!s ,m kv1 -0" dEEEo Sv1ncj,E0C $3 m&l @as 5 2 E - %hZ-DEM .z w e C 0.: WVgjZrnu2 e a2K.I t: aJ zZ,uaJE"a -3225 aJ 7 g3.2 z.2 g 2 :sgggg 2 5 gBS2 pzg.; $67 $2225 s-2 3 .- sq 2s 0- 2 G)moaJ~aJQJ Ego-, In.9.55 mz L.2 z3.5 m Lee, u 0 vumo Ll 0 we. n- -la uffl a1a, x c x mom m uo mncrl~ 4.4 cm m nu mcm um uucom u mTtu-4 c u m 3WUm -4EUS 5 .PI2:Ll5m; a'2 E!u$ o g52 c.4~ m me ~ld E m m ~rl m 0.4 a, mrlo&.du-doa m m oa mu ma m 4wuc3 L!c> u c m.44 m m 'u umau am .dam cccl a cmo~ mcrlrl a m c, cu.4 m-4 m uma~!or(m .-I h mrl m munu a, a, 0) $4 c fflXucrloaem m ~l.4 m m ua e+, (I1.4 0 GUU PIQCGC, c: ulu.LJ Ll a u al oa4 EO" acme Em 5.2"o.Y a, Ll s.2 ow u L! rlmm+Ju.;;o~ m.4-a 0 E m-4 o ec c m nm>u mEu m LIJJ.4 m m L! c,mwme am& PI-4 0 C m O.nO Q.+VL!-l -+an umc mmmmu CEaI07v)> L! 4 oac. 0 0 0 a, 3 Cnc.+EC aanw R u v1 -n !Z 0 3 xa rl xm VI a mn m m 0-4 "I eo a m o umn -4 .4 n m ucmaou am eo mku urn %earl m3 c cm~3 ~m m mao o-drl burl 0 3U.5 5 OCObCEffl wm>c,o a I: EOUd auu m B I fflCaOE. u E;'u"z:: co muc 3d.4 m 0 o 5mn oa m U E-IDrl C C U m Ll 4 0.4 m u .mxm 3ma 07 ccma 2$2$2Q2 2m.4 earl nm mmmm u u m mu-4 e 04rl 0 carl3ccm mmmooam m L!c ec rlLlL!umwm w 0 m u L!-I.c 5 rn':c.4 m.4 u L! mU5mam%' u n m o ~u.4 c E w 0 -4 4 m -4 U s sL.7 aJ- :-z= % O0 e .!jj2C go 08 .e .e m - a 7 E42 3 22 t 56 a-;;; e". "2 22.es M haJ yk.5 260 .a ++ E v3 c 0l.Y aJ g: 8 35n c ,a21nz!! 2.2 5 3" .; ua cd $s.i:g -z- 2.@h 3.2 KJ 3 ?$ ?-E2 c VI-= Ea 2 .- .2 p e u .% .z 2 z .$ 4 $.- aJ h ..s 22 Q 24 s=-0 u393cm 0 '& 2 Y g.s2 2 w $ga.a, w vl- E w.2 7 -3 0- m 3 oE3gco c3zooE 55-2 2% fJz Ins2 ' 5 .2 .s 24 z.a.2 aJ3 aLulr0 m oc .z g g ; :g c U5 VI a MMGz 2 k u Ma- I 4 'c. p;gg 9%" 0 u - c mal EE 4 m url 2.5 h 5 mo OL fflu - .rl c 1 ou * u a- UEU mu- .4 (1 g2: -4 0 ul uuu) urnc e- 0 PI x.4 Euu a-4 0 rlvm am m B 0- -4 m m OE -4 m e wu h ULlO mu Ll am 5 me !-I mu oa c a rlrl mu m m ?la, E 3mma C4.c x urlu m .45 111 m P-" Eo$.. ucmm 0 NI u m .4 rlffl .m 5 OF. CEmS m Llu m 0) L! u.4 m 5Ll ffl wo L!dW a, ad%! E 4 0) 0 u L!m Of .c a . m-4 Od mxcn mu0 0 C-4 5 E mL! vm mc.+Jm m 0.4 mu n G G2@ c vr8; ua:2 .A 4 Q) Q) U ! ;.i $ em EO C, mn P) c rl ma m PI4 3a mn u m -4 rl .4 noca E E.4 L! m~mm m E c2 9 $ -0 -0 M e .- 2 2 VI -u - .I4 2 -0 A m E - m - aJ ar; % ea -2 Z m '3 2E am !gJ3 5-s 22 25 'B 5, s$ 3: 2g V .- -kb d, wa ba GI 0 u m 2 zc, ma c xc3m u.4 d ).r ucc1 ocuL! eac m c 0-4 .4 m PIE m 1RU 70 0.4 0) b rl L!n L! cl ma ma 3 ' emc mcoe . $4 u.4 0 4J .rl L! mmu ocum 4 kW c c, -4 4 u c 5.4 P) m m.4 u rl .c $2.5 8-8 It-. om a0 a Edal c, c, c, Ed c a-4 I4 "QC 0 rlm 4 4 e Ea. C b .43c a E a.4 a L! 0 m e4 * E3$ a' E .5 $ E.; ouumm n k X aJ MM $,B.YZ B'E.!jj, 5 2 2 t: .e aJ w 55 &%? % .z; %% c 2 .$! m G=i -- >z3 2 & 2 6 ' 2.5 2 .* shszg 5 b.2 5; g r$$"g 2w e5 s Pi &.zg:z: 52G)2"2 E'G; E v1 2.: - o"42 s22 aJ c) u.l! -2 2 g.2 m5g 22EG %O c 0.9 0 " G)c 2 aJ E * aJ.zz 5s z E ;; .s-G w m o.g aJ o= '*I mea2 ux ,Gag 02 8 $3 o F E .9 .9 a c w 22 v En&h 0 or7 m w no -2 .~:5 a G) (J a .!i >e=wmL. @g4 ggg aJz$z.,: gr2 g E4 9 Erl2 E23 BO a5.s aJ TI c 4 e h*S 0 MZ 62e e4 NI 8.sei jc ..* ag: bw-z : a E2 / 25 3 < 3'0 - -.;;;.m c x: $:i! ma L.' z WJaJ 5 5 2: 6: 5 g $; 8 .e s LOU (rJ z A- d 0- m VI e( G gz ( 2 !+ G: Y 2% gj;. E 9 m, E+ 2, e2 g, 45 > -g< vi 82 Z' 23 E .p 5 .P ; go3 c e g' MaJ 01 n 0.2 VI 0 .- aJ'c. VI 0 aJ' + c e. -e$! 'E :;; 26 P au dEc mmm a, L!L!x 3 mem ~1 cou L! mLl a3 m5m mn a un m m PIWrl 0 533 ..:u wuca c !.I m m 30 0moLlum 0.4 m m E cau G+J .A +I m .rl 4 aKgU-5 8 L!m ea mo. 3 ma cuw m : 0 u 2 3 om .dcm Vu.! Gw2 m3uEofi rima 111 udmo PI FC 0) mu aGQI 0 ' .$$ g 5 bi g an.2 5 mw 5 :2L!kt$w 0 !z rl 0 0'd.d L! m a--c m ma mdwmrl a Eiw (ouu PI > c. 0.4 mor: GNO Ll oL!PI-lL! mm.4 P) SF4 a 0 mum a4 11l3msmz10 L! m u cr(u l4 d .mo -+POI VI hal d LlLl on m ma m m z.4 nu c uummwum 22 2w E5 O c:, ffl c 0 a -i.4,5. 3cm u1 Ud mL!uae rl m.4 m PI m m %m e a.5 t a.z xz m. K.4 PI> X&@' u (un3o)mlr rnwrl"trl0 cla aua 0.4 0 7 .r(z~c,rlommc 0 m PI m 3 -mu rl ac.w d.4 ea WmUWE Up1 a K e PI WS.4 0.4 o .4u~! ma> monoourla uL!u aucl>m mmc ocma muucm ma QI I G4+4J E PI cn m 0 EL: c Q) bk &" g 9a g"a.4 s" ..i $,""2CEFi& orlrlu PI $LE m Lld am 0 0.4 3 m am~acd ou 4 .rl PI k c 4 IDL! om>o c .ocu mwm7 nwm a rl m uno ~ac,rlia~rlmz E E z3 E922 mmzme 90; 004JmoL!.cwu ).r l4.d 0 ).r 0 uw.4 a a3 aaw m mu 4 N 8 5 cu cu c3 cu LC cu 0 0 IlJ= 2: rQJVIe:a 9) w; 0 a; 8 QU, 4 w-w aJ w w 42gs2 25: 32.p- 5 5CD555 - 7 z.2 EC'I:vlg a 0- vi 2 g.2 d. $23 2 2 .$ :$ .=% ;; gs 3 a 2a.z l-, Us E 0 m- $ u w-E$;.s 5 u 2w 93 w aL CB 2 2 3 ,& mom 2'&e w.- % gs <s -E; 2 .$ $ c 9 M.- !jVI.g; 2 2pg.Q 2% E6 "a u a>= w E L.= L. ' M-s a m2.E:U D.-bz* oar: 'c .5 5 Uch ;z %:2$'$ .z; :$ MU h a i& m ylq s-80 ; P).- ui3 m E: g; 'I. 3 0 .-5 G.d b< s- 5: mn".m3m i5 z sz $: tg 'derc:ai 2s rn.? $2 m E - -2.3 3 Y 0 b5D.z: $$ w~ m9 dm * ma-6 5 ;%& Z-Ek -2 -~ 8 E &'a E 5 5 as5 $$$$$ amuaJ w52w 20 & .2zg3Em n= $ & 2 2.5 -E: wsu 20.5% czwc hem u ?gU' -6 0, EE$.gg$ sf 2.G; x02 -5gu-G c, LZ 2x2 5 $,x a '5 a, *3 YV- 0 w> x 0 .5 .z m s;vz m zs %aJ(q EG2%+ e, G.Z g 4 32 ", %& c gGfjq a 0" m VI &Z* % cU 0.5 M 'S -vu 0 E+ E.g $5 Urn zg;6 u"sa5 $gg U SUEZ -=: 3 .- - am.5 3 9 1 3 s 52 0"r.J 52 &> mwcc -1: ?r= &aEE 22 g 0.25 8 % gz G$ ;ST G2gTz -;3 -- !- %!Pi E.! e,~ s gm a m" F: Gnu3 ha. X'C sg zez G&$ q,p 2.z o bbn uo\ aJ.2e.g .g* a5 OJ wd2 wk e,.&@ g; ~Zw *-,-E urn4 01 gP{ .g g 2 ? - p a-0 EE 22 G1:z~M mm a, mziij%, 3.2 g.z M g.sp a VI 2% mas $E{%g ;=$g T6 & h aYVID- 'p3w.t: 2.2mE gE ~CJ 3m2.3 s: am 22.2 z3cw :g.Sg 25 5 @gBw-42 ~~ ocz 2u 2 8 b0.G mu- Gg a K .EEa yj o.2u 2 2.05 wi!*& .4 czz% -0 $2 81: "E 2 awaJ aJ y) 02:'S.s .5 & 2% *-%Z +mzu E3 e 3.G- e, 5 E:52 y- 8 c: MZ as 22 baa, "e e g$35 %$?$ dwh :.e .ea 0;; g3b.S m yI vmz .r:>h'F$g ?ag Q25 :; gz 350 mgt4 "G2 K! QJ2 kg.; 0) 33 a ~~s2-z I: -4 nz 011: huQ:* ~E-\oEz c zj -5 E % gct 3 8- M.- zmsg gx 9) E- z ce: E& a egg ma y32- wm .5 $ is sE oz:p+-C, *- uP)u aJ 'Glq G@ wm I; &$ Vi .Y Q u-$& 2: +g :zz .s.L.2s; e&3a 8m,C m.z& g& ti!! $2 dm G3-=- LJg g. 752s __ z+l,g rn .+ c%Mu' rM wn ~u~EE.v.~ +s a.22 9 0 .g.g 3 2 .sa? g32 B;.,$g- w9 "0 $5 &ga.s -c,".G+g 4.5 +ti m*m3 - ecVIc 'E 5 1 .d 'rj ;? - abU-5 22 mdrn r= Pwq)g.o .i? 2 ;z B-.qP Kg I gE3aE,e VIP) zgac 02 .z 22 a e, 22w- m wuc mu aJ E2 c: w 5- urn010 b2 IC 5 i u. am UQ& ms,zg rn1:e'Z .5 p) dU c @J 22.5c F.5 V3.G; w 2 k aZ2 w 'G; 0 M g a!i Y U VIP) mq ssq rw,vlms.M eM2M Z'CS w g 5.s; 8 Y gI au 'Q Zrn- "Em zs3%%3 Ez"c Omo 3 522ge 22 I d n E s aJ 0 G .- Y B m, 'E- a 5 Y C .- W P -c m cv m m VI h 6 k - =I CI al u. 5s .9 2 2, y? 2.3 Kg ;E & '2 a- P) + $B Gz - 'T E E e a 5 Q) 22 2 G C w .- .Ej I 91 a L 2 E e EJ a m I 0 Y %& 2z g .E A& m h, Ec: yjz A a a- ; .B .e s ux QJ"a An t-m 4 22 2s - 22 4 s *z SGi kZ3 2:s e2 3 aI2~ Ll .Y m h2 r. s 0 N 2 ua =y 0 VIEW g-0- OaJW NP w G L .- aJ a= - YIL. '5 q .d &P L M 2zg asz j?: m g.g 0 25 r= ae u v.6 cv .s H .y .z m .z ; d 2- UQJO 5 2" aJxa 05 s 5 .c: 9 3s g E'S5 & .- w amvl Y 5 $2 Y +aJ c - 2 .2 .- aJ w a5 6 5 z$ 3: 9 mu &u ?Qzgg gg2-w- g 3 .E k.": .g z GE3.2Z w.-= E 3 2 E I mgwmwg .- ; 5 c+.z wz= L. ,ZT z & E2 I oc - 2- gss aJ G ; $4 3 g.m k? a c.5 22.2 0 2 29 ?Z e ; w w.2 x +zszfag 5.Q; 5 F 5 &.Z 2 - gJ: $22.- a- La aw 0 L 5.t; 2% L Z x g gy BE M5za ?:bo c.5 ;5 0 E""? g C hb'" a c: v) C&zgzz g z On.., t: g,:;.o 8E&2mg$ w ME ban I= 2.E m E 0 0 Ag$ $4 >ZLL"b 0 0 r aJzs v) nGc gcj c Y Ez.5.G m 82.5 1 c: a0 0 0 cow .- .r( - c:;b€7J kzsg LL a- u m4 aa7 a, 4 OUO a, mmmm 4ac 3 E 0 0 m m.4 xaa,u-rl wrl m 0 aubl uu >cr: c a, s s.4.4 Fa, mu u)n lo-rl4a-l ra E urla a,u x4n c m-lu . he Q-d.4 a a, a, -4 .rl o n .r( r. a m cx . 2 -ook~m.tg horn crtoa u mcnom E5hdUdWkdOI? -++ a> VIP >w a, m 3-8 m 0 a*.c mmc cac ua, .u Fa FXU me a, u ~>cmawudF a, a4 a .cl.rlwmaE 6 c a,.r(u"~-l m a c m m a, c.4 3 cu ra4a .4 Q m rl -4 .4.+ u 4 -4-l m u F k k 7-4 3 vwamcrko~oco .?R u) x.d-+2w" 3 30 hxx-4uxoukamPx,j Fa, g2: .QO $72 a, g wu.c.r(n N o a, a,u ou c a.4 u v a ac.4 0.4 a u u)7kkUC VE -4c~~uommckPcc-l cuk FlV-4-4 \Dsum r: 7-l rnk m\Dm > -le "lksum maoa a34 3 d o-lc 0 c 7 cnkuuch a mmw -0 u ma,a,a, 0.4 m-l mu cuuu m-4 m 4 k m a74 PO 9) m LIP) >uuE-lm"lcPaEuk km1Xcmmmmocas a5 mm.4aa 3u €.dm-4 I mxa-lx7mon -43m gnmm.dx a,u)cunm almumucm h~.l mu /I /I u 03 40 0,r: 4 u so ma w oc au . x4 3 ma %E$ oc ZCE mwa, u.4 dl .- 2 QCE 0 o'd, mu) 4 a n cram 0 u-l uc7 4 0 -Id $.3 CCE 4EF . #I 0 -rkk Fa EO ka De omu ha3 4 E2-0 omm mkm , awm a, SI s.gg-z 2 Y 2 mom0 a GP E3 E z5.q aJ 9 M 2sgggw-gs 2 5; & ;.g TI $iQ a, k U a wir- a% 2 E 2 25 -0%" :.gq% 000 VI '3 8 'C,U L.2.Z OdaJWYrnO ,.I & c EL? $5 g gz $v L B w 0 mat:gLn $5 2 M.$.Y;Z$ v) e= q.24 3 -- 5 s 2 - Y C c.zg E" w t: 5 ;j -222- 6 2-25 0 aG c - v)y ,".5-0 m who c:iigz g ?.Z 5 '= 2 5 s 3.s 5 .% z LC2 ' $2 w.E - ma E-2~3 s -2- g X nG 3 c: 3 2 .% 5 c .s .y szs g &; 22 a mi$ v Es5 aJm E 'W %m,Oc mE:&bJZ .a .SaJ,go, 6 0 aJ a5 !2u w.z 9 a aJd;.d aJ % $25 $8 5.23 8 0 -0 &e- ag $ 2% gG g .5? 8 %a O "s $3 & " u LE c E> E 0 w - 0 "JZS G w .- 2.2.5" E 'G; w xa YU .2 0 w " c: V I m a' 0 a- a m x a, 0. ua,cs a a, 4r:umca, umaa,s u wur: C -4 u u s k m s4 I;- r: u.4 m Fm m a, a, mcna-lhu I c -47amn e*Em u m a, a .a xm m u L4 g uu ema, krl L4 Pod "45 5.4 0 C-45 om~m-lmlo cararacaclati; m b x0 >-+e E 0 ; ;; $8 5.: G '0 E&- mc3ug LIES! 3000 -4Q -id 0)U-I WO m s 01 5.4 u m "EEFFCII mm .urn cxu *o-mrm u m UmlOQnm rl-a .4 7 m a monou L4wmumaa .k F m kEO-F 0 Fm h a 04n 0 ~4camavh~h 04-4 mocal a m c &E4 a . 47oa I a4 m 0.4 ma a P-m ccu cuc c .4w a, 0 k e a,"l %-I 30 m c.4 au ooo-l a a c marl E aam m ma E4 m ha m.4 am a, a0 E 0 c 3w a a oc mw m 0-4 o 34rnk "IC).+ rlmmmal >cm u>5oa,3mm> uar: ac-l a45 ca,oka,oham o uu mm-+a o uorn-cl a,cmu n 0 d '2 - - 2 5 4 2 aJ J 4 .- 0 I Y 5;; " 58 bo2 2: W- .9 3 X, VI 62 nu 62 ax IL.m or mm Ea 2 .c 5 3 ?$ p4 g$ Om -% 2E .- qJ "& $1 32 GO .4 vc c m mum.4m au u-ls a mua.4 g-imzl u3m> ouxa am 2 cmwu u g a auc mu mnam i;oc"s.2w .5g ala! .amouw f!rl'?U o.5 giu mucm m cia c-4u 0 m Fal hG vam7uuwrtm~ m m oa 0) m.4 m.4 uc c makc .4au 09 n c PI 7 u '4 c fi ed ale h E $4 U-I h aluwa amam 2; mw 2 $="I 5 x a m E E-2 c ma 04 01 0 ma 0 v ca kdu 9) x.+ a, a.4u m m xarc m mm>cFhal7c> u Fh E 05 c 0 a omca rtom e 4 u mo-l In nm mu9) a .mu3 @kea me mu .4 c.4 Y a, m eo ala >una@ 4mmu - 0.4 3 m mu 1 m @.no -m >IC, un F.4 I.I LI rtuEOUl QlhC a alcm om oaam a u-lUda.4lU F a, murl-l a k k 8.d c a .d 24 0 a E* c omcmeEwmda4 acuwm.4mwmma m E ag2t4.5~ v1 ca >mcm..c n~mohuo-~ ~iw xm m cn 20.':.':ag::$g.5 kmmooawaa~um 3* .4 5 .ij P E -? U .* E; %$ c, .o w uz :D YY -2 O v; = 2.Y 5 E2 n.s2 328 g 52 :$$ I- Mm c GaJ3 .* a n :om rn 'E -z xIL. 8C- w8 SZE ,?,a .g +7 a25 3caJ *s *g 2 .- 5s 'f .- + 0 VI =: 05 u aJ .z aJmz c-Vd so 3 a $8 2E rlz.2 u -;hac a, 00 a > .4 ha, cu 0 dP oh m.dm mm mmuooo Gi r az -4.4 c mu 0 C,malcoLI 0 mu4 c mocm m a4 1 m - a x22.43 krl v.4 m-lmwuw kP0 em am u-c. 4 0 c-u m -a E-wm m ua-3 .d 4 mu 0 0 omco 3 c m a-03 g m.5:x??g a.4uam Gm z gg-2 E22 .dum>comm 4 h am rlhm -mu chum0 a ma 4QEi a4 -us 0 u m mu uu u E wcm ~)ccmcnmm E al m Ei-c 43c>m @Gem .dm .P)LIamm OGOEIP)~~ Bas a>u m €4 d m-44Q Q m LlOrlE: -3 BE%: gs 9 ; :z:; 'S $5 I w.: +2; aJ aJ -7 -3 E 2Z.E 5v)O' !$ma' E:2 t .- h; j za 0s; 2EC7 .Y M4 c 'i 3.a ~ i C g El szq 32z: $'O VI > aJ" gmc; h'&S aJ GS 5% 5- aJ cc .- aJ .- as j 0 .Y .- , -z3 9 2-07 'r: MU: "32. a-0 e 1 2waJ Ea: 2% 0). 'CCB .9.2 .t I A E3; US 8C om I t2;- .,$3: u.m -. c- no, I -4 W 0 5 $5 PI .rl In 4 .r ut 0s >ou *rl k P am. ala! m a" .a ... o+ VCI oc 0-4 c 5$ f E3 t $ ay "dl u;f hot 0 h.. PIC, cc ww I 01 ou I x-. m.4 < mrt4 VI-d I -3 j C m1 OCI -4 0 I ua u m1 @all Cnhl !I c; CLSJ $2 (u (u N 0 .i r- co 0) a 0 Tu- QJZ ? >n 22 e 2 p -2 -2 95 23- -2 2g $3 S2-g 3: s s % .p u.p'd 5 :+z "2 2 2 gumg wgow $E'; 3 2 $cy xw- E 0 20 5 3EgE " 23 $ E '&E; :2 2 a- 2 5 $25 VIa 8 g 22 " !i3 g '"a ga w 3 Y cl.g X' m ' cv eco %2U zmc 2 E s X- aJ w - Ea In 0 QJ 0 0" "CW uo .- 0" 5 0 wu - Cmc m rlrl a d0 JJ PI u.4~ VI m .+ cdu aI+C na In.4C.4 3 0 3 a, rn VI a00 -E md am umumwum .4 !A E rl .4 a, $2.4 L1 Ul @-4rl C S 0 > 0, c c m u 01: mm.4 !A a-rlaa m.4 5 c om I muu .4sa u U) PI lA.4 m.4 -m.4 0 H mu owaau a c ~m .rloamom * 0 Ll G U E 4 3C-W m.C a0 0) U ma-4 a0 K E Q > 4 0 CdOmUlCHOE03 $$L?GUQ *: E go 8 PP"k 6; .2 Zl P).,-IE~ m coum hESC03rl >F umrlmmm m moconrl~uh os1 u rluuatr tn-4 3 Cl v) h.4 v1 d 0-4 noh~omduum 41dm7w>omuC mrl cu muamu 4.4 .u"Iaa 0.4 u v1.4 m m o m-4 a* c P I -4 fic::Om7+J u3v)Ll P)Q)ErlE CUP Z$a f $ I ai 8.; ;.; :: 225.2 Zlm aJ P2 E 0 mc"7Es$~~ E'uu cmsou!A 4 P-u+J m 0 am E z$Z 22 Pf22 E f m.iu &"a$$f8 !G2! K?!2.! kt?! "am mmua ua a.cs.4 ma o ua ma mrl E m mmaa 4J a m E rl s a u v1 cc u -4 .4 m c EL00 P) -2uE cc UU.d a, 0 0 sa 3 m c mOGUON2 u rl-lriu VIDaE$$ mssm 9) 0.4 !A a, 10 -44J 7W PI OR 3uoonu tr.4 C a ma hxmm Ll 10 m muc h ~1.4 VI u mh aJhOE.+ 1 "I E P ..-! C, 4 aaoarncff 0.nc c u.4 a, VA'? ",2* )-r u'nr ilz 'ii VI cuuumom mmm ~u Ern hac, ma h ua m VI PP coos m $ .2 -3.5.; om ammo 0 ma mC 7 h ucz oa C a .4.4 a u a1 4s 9) s 13owdrn w OE P ourla .ma maw mho c aaam rnEOhUOO In m 04w a InrlLl >wu \~mmaomo mmmnms g3332k;"a 4.4 c m mP @no urn >uucm 0 7 PI C.4 0.4 Ln mndcl u 9 nu, P)OCOGCP)~ 5e2zz E ?LE:: g2%zs 2 Zsn w-55 2::s: 0 g 09 VI .a.g:.$ z .i?z .; ." 0 UTI z cli 0.2 rS g g .mw- hGZN C2rZE " m 0.2 $ E xu- .- VI 2 g.ss '5 - .P 5 2 2 g .? .5 gguoc 0 E .z .- w&ZU z 2 -5 Y 3 -2 .e2 .E 8 2 s.22 3 g$% -% &L 2 z.9 Ob 6 M'Cr,'G; 032 k; g w ME a O E ma- g21gu 2322 2 LI c-z 3.; WE m LI k2.S w =,z33 2.SZA E k3 ~~"4 244 5 g w aJv m m 3 :u m ow .... u ON E a Y -0.mEVI -.E 2 i 00 m.!z F $ .4 rl rl 0 w m C u VI m ij h % rl rl m .4 w 4 U a m In In W C .4 u 0 VJ m P) S 0 -4 42 7 1, k g Ll 0 W -0 > e a a. mm m 4Jd sm .d s- ad 3% mLl em wc: o m. h mu 1w -2: zm - m mega 2:z.z 32 Y $ 22.. E aJ k4 >E m.2 m "3 u c bow I, m CB g P;c;o 2 y.22 53 s .3 'et3 223 5 qzg 2.; &A gg; $ I Y ;.t: t; &aJ 3 *z m NG i2OU aJs zz sgv3 g s g.- bo w D 0 w5.z .Q: .E M s1 r= 02 c 2 c.z-w 2.2 3 g os?$ %gzz WEga g.g e% am .a ibZ c m w- xs acma 'OWW -52 >.Y c m cu =J=< c 52 10 I, ac 0 m am Ed 0 ..-I ULlE KU 2 ! a'" h u0.C Lla mmc a a 4 0 4 C E>U 0 .rl ah3 ea m!A mo m JJ' In 50s rlu g ha 0 mi wum u v) .;; 4 m 0 EhU Wac 0rlu hCC * m m.4 u 7 0.4 w ZP 3 0 'mm -2 Y 9'" - P qj E2 SE 23 SaJ E5 s" .9 $ '5 tB m3 mzl Zt? mn wo LN -0, .2 0 $2+ s .Y CJ 3 $2 x'd 2 UC' 5.u-E 2 c... =y: g ". g ,a2 x 2 ZZ LI ?,..I " =ox .- .- a waw - pd mow I0'I I' boo cu .e .p! E 8 z.2 2 d 25 vi .g 2 22 8 cold 0 u- 4 a m?i .. Nk -A d h3 22 5 im: mu- 7 rl c.4 05 c mm h P ma am P44J m0Ll .4 P m u70 uou OC ma0 *E 4 oa sum $4 I 4 0 mrl uo ohm- 3: 2 7 .5 4 ~lm~ 1 o am -2:a2 2 End - 0 mm . urn u ri Bu a om m eo Ll *?"o!! m QC, E uc 0 muhu ha m E:* Ll a.4 h 0 OP 0 a 34 2. Grn d Ll VI4 m 0-i I PA 0 3 U.4 E 0.4 E m 40 a LlamtP oahc w )-I C.d 4 u m .4 m .r( 0 c hs v) wa 3u 04 ohm UP 0 u E.? c:z $&eS ' VI:: -8YEd"a aa m ZP N Ll 1ooa - a u m Pa um rl m uti :: ,uu,A 25 $2 v) ucti2% E '4 u 4 0) OmE Llarlum w 0 a0 h ugh a 9) c-4 0.4 VI g 0:::: x-4 VI a mmx 4 ma h .r( .4 a m u mm~lco hm m a+ Lla 2 .r( m srou uu em U Ed N VI al a04 m 95uJ5 u -$%a Pa al U& J #.5$ mhBoo +, 5-l Baa us PO Urn& E a 0 au a rn .%I a uu uv) mom E: GX E-4 $iZi$ I;?k9.!!*i a gxgm Pal asc e h m L~J I E "I P la 1 1 .- CI - 0 : 3 s +2 - 9 a u 3 LI * 0 c, k w =M E d 0 3 8 a aJ 2 *d 3 a co s w 48 Q rl t.. % y:;" L : I-l E m u m u C .u 6 9 2 s Fc' 5 - - ... m m % 2 Y - z 1 D E, 5 d r a.22 Y %Sm v) "a ;;up Fi h 3 .c p-2 OUaJ &,aV b3-o a .9 x 0 :EX z2 2 aJ aJZ zj "" mcm QD'G; 7 2 CQ *as mea % v) .9 $4 E 2Z.S g! g a, fJ-JZL mfJ F 4-2 z 34 us 2 2 i .g 2% 8 2s g aJ*k 3 $- *x3 .' I u 'E .z .z 3 2z.a 22 8- VI c,m 2 432 O 4 +Gf-5 k 0- msr= B=, g .? - a- 0 2 z.23 $.$2- 0 t 26 g.L 5 aJ aJ.2 h o.i? 2 = u v) 9 $2 i2z mS aJ2 e, ~23 - 0 P. % 9 aJ c, a';;; gga.5 :%Ea 0 25 0 g ;i 2 p; 4 z.2 E v) w-2 - m m.Ya p) m ".5'5.$Z x:! u aJ ; $ G 5; 3 amz.2.p ;-;$ 52 -- aJ x; 0 5 k% $2- E aJ g.2 aJ C.fj2 gz.z 5 g €6 m m I h v 9 g-; $51 .- L. 0.2 - c d-3 w.2-67 v, .- %*S5~~-L5$$~ 3 +-as &.s $ &sa; gaJ 22 ..$ .Z~~*G.~ tG~:2v)gzx~*k* RE 6!Ab$YI-h o Ex .'G;gz2$cEmIz v hj: u';z'z m c * m x 2 c gz aJ G v .- QI h e- ; ,z m a* a w :+ s.2 Ed q t$ $4 E:$ $ a g GZ<.G3 > 0 .- c ac 3.. WV m ? 0 .5z=z .t: obc- aJ m 3w ga<;;;.$TI I mzcg mS1.1 2 -,*~uwn- g&.zz 8 zg aaLg ;.g en aJ vi c 0 g %vr * 2.G m; u 5 m*cu5~;pph~ 8.2 E!S "OL ".C g ; 8 FgJS 5: 23" 2s m:p ' "5 mg3 3 &,%-.z 2 2.2 $2 5 aJ X'S * c.2 I . r: v) m&6 v) x gJ.W&-Y "nE*Z QJ MaJ k g *a E&; z wGuE W.k ' s2s.5 FJ u c 7 e k.- w E 7; 1.I- MWU v; v; "r; w w b9 -a - fJ-Jaan..- 2!'ga II) YI 2 ms% Q= %e 9) m- sz SCaJ' hg EzZcmz zz a~z Ra v) QJ W.- a 0 0 > G"k3 aJ6 G"woU3~m,~~.c~~ z 3.z F: YQE y 2; 2-0 -Qz c AaJ u *a 0" hj E 3 23 zz2.5 > E5 9 E $ ;-? v5~~=~ng~ 2.Gg aJG RaOA-,zdS 8.C .- > m 7 C:.z e.=" ma "<.C U" 3c.Y v) 2 2% g 0 8, 8 m@ ~W~'~~~ ReZS Y c .d -- 0% slz * 2 m 3 FE@ 56 g mz v) $ ;?.sm NlZ 'a30 RCaZ.s%?82a 8 &ss$ mi .I I gg EE =a w2 e, .5 MM .d yY 2: s: 2u cG 2- hj 05 =: 4g2 2 ,?z 8 5s p 2 .: m .z z 23; c R$ 2 *E 2.2 I $2+ E;2 4 8 8< $$ a -2% ;53 3 3s rm -a m .- < v DZ m -0 ;+$ u.22 US O 5.2 .- u n 23 w us=_ 2-sz +p. v) ? .- E- $8 .Y a -"4;$ g ;:&z FC"2rn 2 2U Z%l3%3 s ;.E+$l; Y) .- a .- - .- U d i i U U B B E W 0 z C - x 2 5 5 .- E" a - w M .- a 2 P 9 m - d ? f 2 5 B - .; 2 .s 2 5" 9g % .E ; -2 s+ .g 2 5 E ET -0 0-z G G z.22 P*n'yE a:z2 rJ ,>-3 c L5Z 2 0 boo 3 ,g Q -g 0 S2-O $ >=2 a5z z::p &s-s Fc2Q SZC" 3 $ gz -5:s 3 g.52 ;$E% SU22 5 %c;2 ,532 2 5 ,z E, 5 .s imum c L. .- -5 0 a .= .B y *- u 1.- a* alirOU .- *aJU30 ->o $5 $5 i=s .- In- -u do qfl r 0; =*dccomJ=0 .i??, ,$$ $.g 2 M.C .: - .- ah m ,= &;; g E" 6 0 6 5 sz-a 2 2," 2: -2 I. 5- M usEIzME$ 3$ZE ?=Eq ac.-.c ; o,.g aJ=U 5% 2 Gg ;::E4 - - in c' &: 3 2- :z.+s: ;;=? a2 ti O 2 gz.2 3~a-.g= €9 E 8 g:= QC 5% XZ.BZ8 q2 "P,.f8& {$;s 2' 2 $5 rJ i a41 E! m c * 41 2 ; ,E+ 2".s v) -2 E.? g* 41 c .- Y g;22$".2p g+gg UI z We,2E3 - 2 I. d8.gs p 2 f,"a=epncn: ggazg ; $.?A -5.2 32 ,$3 gg2 ;; 5 x gU g,g y -UIGz eJ &!sz,psgg2 'O no.2gm .2.48oJR -$ u& !%s c :: $&j 2; @.f zz ,+Bo coq z'3 c aL5 ."& e 5 ma 2.c- m c- 0 c ad 3% 3 6 ,o 5 E - .: zEau3"" uc - cX2.g .c.- ~ *,s rJ,c J .c- 50-a E2 - c c u "-0.2 u,$ 2 gz M =so c E: an 55 .? h-.5 0.- I_ ,.= > J= .ss.*s a E U Mm m ,x52 1 m g~.~b~~'E.~ c m E ETg %$el; Bmca.2-o. ;.E;$ :I %:8 2 a ,e Em z FS - 8 z=e.zz2 ?.Jc,Z'E m5%&cr .- i E~~-OE.ZQ 2 lzu.-= ~ g E25 - CS w gzg$ .::.'.-.I - b2 '\y 4 .- g I cu , m I[% - up0 s:.E.S: - a,- 1"- %= -s - i $5 g i 0 z 2 ~ 3 I%% :: E $4 2;; 2F i: md e- E 94 .+z id 2% 2% 3" g: L.u s3g $2; 225 -IC= E$g $525 *: 3 4- $; n f 2 t$ 25 !;: ;pj $2 ;-; ",Fg :a d$S 2 2 e $ 2% ;3: 5 & g$z gz gga gg5. 2lla *:z 5; $::$ 2 3 : ; -< 8 zl zz 2$ 2; 4; ;$ g; 222 91; 828 E;d !&: 2 fz 2 - -.. U 24 a5 6- *V 5 .@ ?s - A&. e! 3 2: .$1 2 8z J=CE i g5 UCZ 0 ri nl ,z I .- I CI - 0 0 z 2 2 .=t - J a 3 h -1 &kj "t;N u c:cwo, 245 a TIC aJ-g5 uZZE E"d E oEg u qgm gw "5 urn E aJ wuc ,T,"? Y QJ 9.1.E 5 RP)- .- .? Y Q ?.;< 2 :;; .z p E2 2.5 g 5 s ,z 2 .:sA; c 2ul aJ 2-W- 3 .- 3 u+ wu3aJ aJ Ua" aJaJc, LUWaJ 2 M E-z - u M', 'B LI Ch momm QSZ oa g5 mag LI "2 m.s 3 >La g.23 4 ,gp,aJ "E gz aw u" 5 8 c2 + g 2 .5 5Q2 +mea 05 om . .45 v1 NI I- :2 8 ulp: 6 2.a 2 -2 .z ME 3 .lj - 2 e -2 'C E c 3 .: 5 8 .A ; z !$ iz 2.2 -cg. 2aJc -h- w as WaJO c >h 3h gs$ s 3-u -aJ c:- '* Y Y 0 m!- c.z 0 IC bo ;2& 5s .z 2: E gs; us aJ 2u.w rnmm wzz 55 m &E9 = aJ5 4"g aJum Omrn .4 $=+ ?j4E t: .s .$! p222 m E3 i gEs3 "52 D aJ '3 U !? E,-$ %: $29 zs& 85: k,B $=I+ $92 zws 2:: 2-W ut3 9 ZU' ?E5 mt. zzm wmnv, UOI W v) .z P 0 n - 8 !! m- (D I! Z P 5 2 .3 P 2 0 t- ml 5 us Ob EL2 &aJ& 5 3 .c ot5 332 2-uz aJm2 E b-0 5.3 g .QE%J mgB .5 s 2l u aa 975. ""06 x- o\ "54,- Z,p% E22 aJ x& 3 3s%h w g 2s E 3.2i 6 c.-a L 5.5% UaJS" Oi3 .ul .4 b M2.G u .? 2 ." aJ7mm wc so7aJ FI: crc aJs u ma gb R aJ1 oc vl-u . - 'U Cd us, cE 3 Y .u ac- Y 200) c aJw-4 ,LC z aJ aJu "a7 -w 0 *M k -w m 5 3 i 3 H 0 a a2 5 % a s m m A! F" B - L m 25 2'tgEP %aaU.rn g23z *.ou 2; E"3" m 0 s.2 gk$Ts m Ll g 3; F - .-E: 2 z.;!: g2z5 - - p. cg200, 3w-z S$ - ~,,sa tc2E %EO .c 0-mc =:E" 6 " 8.g g,:.+(j !i&g= 5 82 .=si3 2 . ,ys @ .- P q* 5 a 4s ;&+. z 2 g.S.2 ,Xmmu dS%$ E B 8 $5: "c.m:2* 4 m_o<2 8j $2 *zz 2pp%b g cop 0x5, px 2 _* mWb 52 g 2.p.. 2% $ 0 22 .UrW,s,: gz"."." -$C Tz ; .E:: SO%TJO .s&i:z U 9 E$S@g.i Z?k%= s I b,?2 g :E2 " .Opz$ 9~z-M m 3 g,z .- 3 . %52gza, e'W-a 2E ; " 4 L!z+ 5,"s "W.5 a,: 243 3 C C U .- " .sS c ¶.DU> VI d E ;j .- W U .- E: - 7 a ,Lug &gx:: 2s =- .. m -= .-a E ?DE g -5 2 3gE G-jjt.2, .- P Lo 6 m c m 1 VI " u33 cc - 2 2 ,==" ZZC: 6o.g am'.- n .- ! -"E p: 2- al -.. E ; ~ 2q n& $u.~{U~ " *a? 3-q OSLE d $! I S% j g 33 3p3X sg5.s 2 us" 9 uc -&;g g&z $ a .2 : :: g g3: ,o .- .- Lm FPag gg u Bzd; 2% x in &! 3:-31 n 2 ," 3& s,.zm- uisg 5 5 U.PO ;cDl?r P j c & ggB9 us23 pU2S c 8 v 9 1 d gg 5 z$ na z zz < zj $ 5; i ; z2 ?.j 2 x 7. 5-:, * li4 2z za;.e:z nz2 -I 6 g-2~ c 4 2; g-$ 3; 2$ 3.5 5: gfi z-2: g; 86 Hz$ 2;: z:= p;z 5 p +& -)i ~~ -7 .n> ^_/ e.,. z?; :p'? gj: ;=x IXd3 ;Ej s:c8. -a .- g 22.2 55; b= cc 0) c $ - - 9 x {B 22 g. ax> Woe Waa c 8.56 "0 y g 8 :$; t 1 s2 Si~E n's c' 2 ,saBU 2 *$E LE I E8s.c.z 5zzga ,$id FS B f& ,- 5 Esrillad 1 klss2.e BSb& iii ...u r) 'e 5 ~ r cu rc) m 2:" -., u CAN sp z 3 w $2: Ezm 8'- zij : ccl AiU ~~ 6 8 g 5 $2 si? 2iz +LE 7 j j ; (E k - z g <$ iJ 2 E *< 5.5: PpIn,; ti.:$ 1 * * 2 LI .- - .d 2 n Y m 3 v) VI Y .- 0 Y .- u $ 2 m - 2 5 a L. G v) Y .- .- G a C - I I m .- $ Y m 3 m - 5 x d U $G 2: .e VIA &3 G3 4 g 5 t: 2 wo n- . :; _. 4; ep $' w ,4 8 s 0; PI g NI 2 22 6% w 0 I VI% g-zEZ G $ 3-c 2 3; g % t;;g..;a 2 2 ._ gko~~~flg m 52%; 52E0%Q k.-c - ti .:O? c g gQJ - ZiE2kyz 0 2 22s",+g 2 3 V122Q 9 0 EzSL2gz bG Qi.z 8 &E a c ;24 2 m e g5 3b.Y 2 born$ Qi c aJ VI c.- oazn-w .zz m kQi2 ' aJ e2 0.2z z e zs zz.9 e;.g% m $2 % m v) M &-e Qi 'G; 'R 0 -- VI 2 ?.a v a c3 cG=;.sv;gE' - 3 .z c M@ Qi G.5 3 c - u ya t: E32 2 3.5 5 z.2 23 ~YQi-coz3= @p;ijhj.GGmm $4 LTJ !l&% g g?p~sv~ 'C & 2.5 0 aJ aJ g<E;g$hL 3 -dE 3 0 Fz M.3 .;;.% 2 0 2f-.$zz 5 Caa.,3uoH 2 '2 s i .- 1- k m wa w a E2 m42 v) EU W)k c" 2 k- -.-kg> .- =soow -VI m w u ,=-ma 0 .- c 2s- MC 0 0 WYO-~03LI v) 'L. .d 3 .z L1 vI u w d 3u.z-d ml &E42 =&E $ -5.& '5 Mu .z m gE w gu 2-2 .5o.g owwo 2 v1 gi u3 4- g$ v ",;z -2 (riS25 .G "$=; nE: M.- m 3 @+,- .g 3 8% ei 2 M1"" 7 w m L.- %.5qE gps % yq't; VI.-SSZ 0 Iz g $4 Gb -5 5:s 2 w $5; 0Jv)G.t: - 3 'f z.2 ; g.g E-2 u L.OmW GI c s3-2gz Zh w om4 gMq2 %b -a 2 a, G M Q .9 u 0 E 'Z z%.c= 8 vI %:?.E mQ5 v) a E 3 ;;i 2-g 'O"$ 5 cw SQiX 2 5; .s .s ,E; z .: 'w5GO O::Pr:9 LEGSS s Qi EZJ= .Z.R&& .E= -aX+i? o3 2 :& T zzzq *us ms cwg &Em+" sx3 g m p.2 ;x gd &:so3 E $3 m !! mL;';:!2a, 2,,- VI uv 22G=% vI "%w GW35 E 2 g2-g g d 2 g-s E g.3 . a, p ~;zzz 23k.22 wmrv, 2s 2.2-2 3-5 5 53 Ip"- oag acoaJ5 Uh'cU VIV a 2 no w G 5. 0' .- sa aJk uwma CI mu., wnmo E w s 0 C 0 Y .C( Y B .- - a a CJ (ri .?.. .- I Y 9 0 a VI .- I VI 3 u .- - 2 i a G 2 .- 2 3 z cri $4 2; P 4 bl y v wa zw 5 w Cd v)I h 0 2 2 - E 55 I .g 8" .- .$ ij M& I'8 24 c4u v 26 :us Tag3 u-.u GU .d 0 "P 3 2. - oc =*e, g9 2 .$ 9 9 -2 e,* g 0 "5 {g P :: gE i 5.z e, e,x P,c_ $3. :2 B ..A 5yS $9 gs e .- n 4 23 E5 g,+s 2.5 $5 .- 2 '-3 g.42 -E 2: 3j 3bb 3 !h 5g h82 zfi f& ,$$ 2" $2; "a $ $!= ssp Y $2 "OU 'E z 2-s ma" .ss 3s: Q-% b 3ze. -95 23 -= rQ0 '2 2's g a .kl2: 82 $5 3% SQQ5 ,x?:$ -gzs 31 2jWO gg 52 .ski g, Z-."a esi: EgY ;ao", .EOC - 55 =QQ z:: $&$Jg 03 25g e9 ggg E22 03% mgj 25% os y d sa.." w caw 3 zzz ?.s$ < ..=,oz 2$ !! 383 ca4s E$ 95,x $!as $2 4 'C c, ,A 'p .Y __ g " 2 sg 'p .y-=* :S.Z g .~ 0 EOQ z-82 &Gi zcu 5% x. 2g.a g23 $ =%e 2,- 022 uzpw &.$ d 'I -5s 2"" e :s Q2E! .G- GQQ 2 2 :.2 029 c ,e= c -05" YQQ c3 W-0 g$ &f.2 222 8 2gg c& 3 .::a wn~ok~ -00 :.;e- y0-S $;z 0% Qss ri'z Cas wqg a3.r: 5 c gas .- $55 .g"g.Co% .?G 62;'3P .8$Sg BEE 0 ZQa 8EO, ."--p"82 %.e*< - a g@ g4; .g'BP gz; :: u 5.2 3L.S nPa3 x oq ogr= 0 gt;.pO 0:; aSQe DQDE - .r .. E."-2g cdz ..2q o:gj5 gzj g zm 23; 2 =$as 2~2 dass 232b 22% 2 2.3 $ B gs; i e,z 5z.g SZW g 2: -0 u % .$! U 04 +- 0 CM - - EE EQa .a .Y Q" U gK2 8 Ye WQQ d --e 8c-g as >8a 2% Q 'D .- c. 0 M 8-g .E a 3 0 E .2 .g 6: -0 c- .!= .- 00 3 2-c r( c.2 44.3% A- 0 0" oirze wovo m030 2 azo ri vi i vi F hl M * m e e 6 L! T Y 0 m rJ i % 2 0) u -1 v) $i $20 .= 3 5 su 3 3 a.2 - m k$ 6-2 E g In= 2: 3 E&€ fisg -a 302 E$, E. r -a0 a'C3 80 d? 8 $2 9 gz Eo E -g w a= g% 3 kL d* os2 55 a 'p btj 5 '2 .a z3 % @ 4 $8 t q 92Aa w 5 $ 2 .- 9) i 2 - h 8 8 0 e 2 sg a a2 .- g: 22 €E sz c 55 $4 3: a ow v) -- o 5i -8 $2 gz g f - >; z Q E 3 u I - e 8 L. u 5 .- o c 4 3 :: (0 0 533 www - 23 3 8 :5 gc? z -a" 0 4i; p?; a? $ 4.z 01 -a E: 522 .s 5 T. 9 g$ g8E w! v) c80 2 B 3& - Y !J3 ',a %QJ2 F!i 3 3 b4 om= :5$ -a -3; i&$ "qg +I=> 8 3 2$& Z'R E O G'OE wg3 E L%Z 8Cau 5 a &% 31 g532 mw ,mw wmw e rl m 0, .-I (0 N a 2: i' K; <.. : %91911'..:. .. ~ ': 0 N .. m Woa glnu .:E 2x8 $a B -0 s? . I a &*a a G 8 E W z w d W u 5 B rn4 E $2 a d gi2 H rno Ha O!Z 04 I W V zb. I co HO g Z 2% av w 5E 2 0 k 2 v) ffl 0 -4 v) v) .4 5 U fr 0 m n ao wm ux Po tnc JJ e0 w> EC 0.c L4 .4 4 3 W-C m ~m d frc a, '4 mo 22 Om 2;: 2. u .?, 5% a: ea o ut- 224 Lu ; .r( -4 2 $?w 2;; 2 2% 0 h2 d2l3 3~ m "x2 gg: Xd* -4 m 6 a0 rl -Q ON 4Jfflv)U cr:o4 mu ~4 0 fflP $$?L %mUZ v1 G2: 1o 2 2ES2 2 g-2 II) -A o w.4o L4 4JhwQJ Wh r mu mwL0 Er: ms wornc w*o DWdP tnofflo d .,0g 4 'u KE~ 203 W Ern & n% m $Q ;: ",; aJ O$U$ *Q E& o @ .; *.2 mn g.2 2 $ . k& ow20 -C eo r:Cc*>, mo :mew m .4 .rl E 3 womac JJ .4 a %4'uTlu 5rlP a 3 EV tn.4 e.+ am oa hm waJ ou -4 0 "5 :2 5s ag u $ -iu .: a 3: ' 2z m .-I > 00 ufr ffld 'uo w 4 ~4m w c .' ~4m u RR xm o 3' mm c@ go gzi u 3.4 322 un t CW* w 0s JJffl ao c a fflo ffld 3 wP 3w m ocm mctn 1 5 2 D kl I3 3 a a .r( [i; # d GF $ v1 c 4 a 0 Crn 5 aJ. 0- ??E x 2 zz x y. r'u" -0 ?2 aJ .m x; SE 5% :s 22 g 5' x, QU 3k gz a 82 ,z B 2 .; ;:g $ x! : 5, 8 2. aJc QJQ LQ L CI cM m -w aJ -. QG 2% - x .z z3 I-j .e 3s - .- .- .4c 00 cu a2 a - ;i u m% VCL 22 w5 88 E: 5% E+ Q 21 22 &z Eg e2 25 $W m MEi VI .9 % m M.5 mM .- .Y .e ,-3 5s 203 VIS -1 b.20 Nl E? 2p *VI J=c 2 3 " -c 'C cu I mQ aJW .r! 2 US - .- . 3u " m Q- bz Q, 7! uz 'Y & -- m 8 zi; N- N 228 3 2-4 s%u 2 00 4 ch L x m- ._ , I az 4; 25 26 OB 2 'P LL b 3% 3 r F- -3 'J q c d '3 i p? 2 - i 2 g a 8 s d b m & 5 b 5 s 4l E e - VI P Po a a 8 8 c? * I :; 2s 2 c5: 0 1 k lo o* 33 5U I e* B V 9 - m 2 $.s 8% 4 =_m-w.gu 6 9 ?SUE 0 zs:z"q ;gp;;z a* ziz g. .- z 0 3 23 uz.z x$@ 0 .- .S$H $98 $ ef P *qa 8 - Z.$af"aZ 9 3 5 e .:.g 6 g= "4 u e z 8: ugg e -2 M0 0 ~anya~d 0 '- .- a 2 p.gz a- o QA- g a2.E3$sg g2 a.2 y .? 3 =bqzg 0 Q .o -0.m 2 3 z ej 8 82 s .g Es:,;;w 2 6 2 &= dQ 2 g:"z.2 i E.2 2 '-a 8z $ g22 5m.d 50 24;:;9: - g0-a 'c) p>-.E!u 0- h: m2 .- ZZ.2 32-0 3 lo0me-g . 3x2 0 I a.9 333 2j.g Z'S 0 &E m a 9 La8 Om3u 3 E 0 E I u U P - I w w E U I 8 I 3 1 3 I U u 5 - c! U M 0 5 2 L. .- M 4 U m 3 0 6 51 5 n 6 2 53 si ;,x 2 * :: @ -a eg PI- .9 0 42 ji 89 -0 .P 8% .- 0 U 2 6 8 e 0 U Y, 4 - a .- - Q + n b .- $5 -9, 98 a' 0 .9 '3 m $! g; 23 ai 24 '0- $5 gs 0.f! ou '3 0 * s .: .e 3 -01 - ml 'C @z mG E 0 % w @$g:- 2 55.G 5 6.5 E 2 w ; ze$&j 2 F-..ZO JW LO 2 I.- .g '5 u"2 *j I - xazz 2 a Eg4ZEZ -9 8 2SS g$ cc 2 2 $ g:: ' E &S E" c m E .-MmEZ . 3 2a.5 M a,w - a2 L 0 2 g2d &"a- c; 235 5 W 0 2.z g m mu7 In 0 = Y.m xu ta amk.a22 x> zp ua z &I= ad a 2-cG 2 m m 0 2.5 .zm ~-0 E 2 - ! V?%x - a.2 5z gJ.2 L.W w 0 e 0 -&iE ME ;.E k2 7 z.g 2 Jaw0 coo LSCU G.C.5 cmp g-i! r w 3- u.5 0 Ez-&i ZZ"$ VI WFJ v .; 8 'E Lr. .- CE&Z2C u 2 e z .m"5 VI VI .; t;gz g% 2.2 2 .g - v,cng h" $2 222 W g:8t;z yeu "2 + 0 - w;; UL 0 o** 2 Y w 32.2 2 -ww,Lc m u "5 g 7-E.Z w > e $4.22 $g L!% 2 -3.i5 2 e2 2 a, gam m9C:Y 3 zxcj 6 5 o~:o"E g.."m W CJ Eii$" 3 5 e0.c €m x gL2 $ w ws w EV.+ o5 LVIS a aJ &52 o*gc~m Fi E w Jm & .kzez 7 " sTYJ?J,m . TJ- mm aJ c\ W-Q c m+ D a moz, EZyhz .- X.P. M 0 y *Cmai I CGi79 z 7 5 ;r: MCx v)I r( i W VI 0 E 2 Y 0 h G2 g t 2 d a 0 - rCV ij 8 6 - 3 ow- - 8% 8 .?$ $23 %by h 8 .- * 0 - ..a 8 m 2 si a - ic - - -0 2 B 2 04L -u 6W .s 3 $4 94 4 .5 5: 22 :* .: p ji 2. at: 4 .s s: ma .C + =,:a w 3% gs.2 y a3 3 -a~~ ysu9 -- $g+ g 0'; * - 8E3u 5.5 2 - 8 ;h,z ag #* BS4-z ; ;= .$ =zg 2 2 g'w 'k 6 B u .s f $$ u=%I= :: g 84 p p 5 4 .f 3 2 ,z .z g3"Sg 0 p .- si22 a- m 6-O 0'0 0 %a= $ 6.: a a8 6 0- 3 4; w -.sf= 6 *" z 0 85 9: < u o a.- + 93 w E .s .Y .E E! 6 g 6: 5.: .- - YI :z e9 6 2s: 3 -24 gz $4 smaw u aw5 z Ea- rn au il 3 a.2 2 :QrB - wg kn w% n a.5 %.§ g: ag 0) 8 : ",w .Y '2 ,g j 5" 3.3 s 3 8 w-8: 24 l.6 "Oi33 Or ZGE?L$ sa457 pq$ 00 aU 6 =axz Q 9q -De 3 Q . .Y up 8 * p9 + ,s = x: 80, 4z h, '- 04 .Y a= 0 .- mu u .j 2 9 a* s@g a8 - 6 .5 6: .s Q 'ci m as gg2. .2 5 : ad vi d w-2 - "5% i? 36 s 2 2 853 -6Z a .4 nQ gs 22& 0s: +Ez 8;;; 8 MU 8;s *e= wu6 zi$ + - 9 8 5 i Q .- -0 9 6 z 2 s - 0 * u - 8 w 09 .- 6ui 2: 98 zz -0 3ij 8: g .$ .s 9 $3 $2 89 E- .- *E ZB =a H P 0 5 e L. 1 * d 3 5 I e 3 5 2 5 8 u 3 I 2 I u u 6 4 =."sf E !2..' a &I %z gz Si -3zw24 E~WSO Ljs;t3a a, 2 ou E w 6.sz 0 p 8 8 e.%= 3 w %f t QmC "02 w E= Q) 36: =6$~;$6 -2 0 0 w'w3 6s 90 aa I ,x;g;j f Fj! : : 5 s 2t.U E 5 m.82 f 0 0 n.%e Q, :3l3 V1 * 3 z $ .§ f2 -3.2: u m !2 ."I g .$ .2 q .[ ! g.; s4zv)3n -2 u8 B a 2 m 2 A? .s 022p '$"J-,;a as w c .d u 2.2 U"af2,. $8 $E2 k, - a0 $1 86 8.5 -v) + (3 t c3 m 0 0 M c3 e m 2 B B U g is e .!p HZ, 9) hzcr: MS 2 552 Qfi ow 0 z3 u.z S"6 E 2# 5 625 @ OGj zm @::6p; fl - .?si 8 2: 2 d Sa E Y g z-ij 2% 8 .s 'g 3 $2 iZ $ g32 :..E- g $.; El egg$& n -Q 3% X'S v) * 8 2z3 B .f! w 53s -0 5 $7 p 2; e .% * - mzsijj.2 q. zi u * 0 "'Z e = gg 8 5 z a,;'; iib.2 j.2 b: *ga 8.2 !06 z 5 .?2 .E 2.s ";%f :E pz 6'5.93 E95 :,e E% = 2': ,an a:.- x $ * u:ss .:e 5 o .u n "i; a-,hS;z 3% 3 %T 3pzi 2Z.G o% = g8 -5 623 2 E" ut $o,o, gS"gp3 -0 $9):- 22; - $2 .s-.I.da E; n$2z.2 $,si$ 3% * gsgg u.E! g .B ; a0 $E& 2 5 2 :; 23 TizghJo 'gzzg 88; sggQ+s,, 56g 2 i g.332$ 33 g;;gx: '''i.2 2~1 g .ca.5az ,g2~ -2- 55 -30-2 z$us oz.2 Z2 k? s.xq g $5 3 6 M8 oozz$ vr+z ='a *sz "'sab-,g Ed ew dI,a.uv ?ips 322 .ah: y.s urp ;q 1: $q$: L;zsf an$ gyzgf qz ==u3 .p e La .gs+ s SB3t;lO %** y'cz* s= 3sgz+ uea6 2:: pd$gQ $&bas 8 83 gg UJj 884; ZiEj 4 2.21 zm 9 !id e b: I. g ma-*z;2, - ,a p&..lo.a Oa Qz%AQ zzs .- .- * 4 gw2p.2 .- 0 6 9)- s$ Ef.Q us a2 w' ua 6 O* u g pe .E $p QrSQ.2 6 02- u~ gla,= hz i$* zag3s j.g z>.r? b 0 0.2 I. tu ii .a on2 59)s;; couv) 42% ug *x,fizs3 zu"M6.ar 3gL 580 ",4 ;$aaf 9 z .: C&'Z 4 a J" 0 a zr= 0" J'O'E3ZS:, 0% u8$2 a 2z.5.s 2s.g 96 ae 0 *? I Em38 ia :8~.5Sg a 'S 6 gyas 8.2.5 3 'T: : p 3 g .g TI :ob=,, %&" ,au"sg.; 3; *nbOE;@2 c1 e 0 (0 h cv 00 5 Of c'u$fJJ~$ yn-u ~K~no 2ZZ a:! 8s d 3- E :a W.03 'G .s 5 .s ee:z et 9 egg; 5 2 CI 0 5% &a 2 .P 0 55 5.2 2xz, =aepu us0 2.g 9 8 5J.Z .us: I ip"." n z";: E %& 2 &.u s - 2 - z3 2.2 2 0 2 q $ 53 E 0 :aq:ts&q pmap2: SiUZ 2 9 .- g $'i p "=pzspa .- yF5_+;9B "Ug 5: A ?j .o %.9.9u 3 OD g 13 3 ,e'a : 9",d,$ 6'; u 2 $ g; $..,Sd-=kJ g 3 9 .g .g! .- - gz 5. 8 g%.jzz &,a y.qtj; ug%*c $<.9* 00 s=u f3 9 L. 5 $2 g qzejcstd 5 9 wzz=u .,:g 00 3 €p$!iu20u 0 z a's % z .z E 0 n cI L. 6 E .:I 3 3 .==a Bs=+pI .- z- .- -, o 5 2 a et~ - O g.g E.g$! 8~0 'c.9 zzzl fQ 8 7z 8..,XSZ =2 ;z i.a.5: 3 1" i%<.iis I a .oo 2@=.Juausg$ .-a ,g+pe,.r::s * Fi - *u uqig 3 &'a 4.y.z 6 I a b, $2 i; 9; 2"dq BY2 * =% 9 8 Hg3g.: 3 '= = P 5 24 3 & .s .9 74 : 832 a2 a=g $ :: 32; 2 3 :y & Aa =,g.S sG=.?:- I I 4bii3qgpz pEgg uq,r i?.$aa- 3-a "42 Ebsl ~4 I Pa '2 .- a ,jt.gaz41 $3 s b' e a-d gr.:%n tB"d ad2pcg i g,~uz~ mEE-op~~4 3% 23 2% e e-<% 32 uuu3toupf4 u a 2,gz $ sf 2 = gs3 25- "is3 =!!a* z pnZ5W E 9Y Lr. om- .9 3 ~~60~~~6d $%t6.2. ?'g.gJ+ 8wwoaZdsz8 GQ *s=SiLgY 2'~~58tu~ an 5 GZ;! ZSiL#$ OQ IF ,egg0 %$.E$ fn &ig 5 1 p .s.=i 8 o L a 6 ;:q3 UP) .E 2222 ~m~s,=gzs gg::? ga.9.a O~QJ~ZQ~.?:~ 22.-3 "9 -34 ud ma 3.: 2 zz uld (oi$=PY 3 =gss=S, g68gS mz=3a g3 u h'? zzgz:u 9 ai 2 :4 E* 5.$b me i = .-bud a.2 -00 &!'$ E-o~u E& gl ~$~~z.9ma~J Y ~§US ,ua -w=Q n 3 .;$kg o 3 uzg=a;+J f $ 8 %"UEa - zz.2 $''Eq3 rJaaa 0 .z%sgo u-CI .gii~f 0 .$idgBo *;*y2 u 6.5 p I. = = %ba,x - u) .. ZXZ e Q 8 3 8 s - I ea- .5. 00 .*- L& .9 N kXZ Ig - %3 P 23 ii : 'j s .c,j.co, .$ 'j; % $2 d 0 0 au yu 1O" 0 EIa.3 u 0 0 ..r33 "Z G 6 UlO~ZS.~3 "; jzz.ue u-ue -8s $ a e% f 'j; ra,aq~gZz4~ .y .- n 10 E3 a -89 erg =a.sgt:.o $s5bqg$.13 $31 -*-970ugrn,:o ~zi%greun 3 z b 8"- ba '9 ;g3jqa:5 9- Si2 22 '0 2 f ;g$$.t.[l 4a sa- a- ' g3 .y E.2- 5s- t %B 'Z VI 0.3 E.., u*a & 0 %.,x3 * 0 0 Cn $~~~~;s.~ zv $a 0' a-x, * .e 0-E ~~S~~~~$ 9 5 g=: OzeU e= t-,=P f d 8. pa &fl 'iiz.*ut$;j-,,s."a. a 2-8' 12: 'SpSZQ $-s=s$,".- 33: g *u*aegez4s: - 9; 9.g.0:042-, 29 d:: .:ggq&$qpz.z g33 ez: ;a8sdgs9g - aq ?83322-51+g 82 :~;&4sp# aE 8 ".i 3 s'aqg ""qv - "31 %zo%jgm qd3u-, u.0,~ a 2- - rog8.2q-,ggZfg! Eag B 2:3 [$ ;3 2 g !a,5 &a gg -E '5 g ssz oza 1 $j'i;$$ .a '5 z.3 g 9 z E.'", - a B rU e -:$3 d 3 s 6 il 2 ai 2s -d &2i Et 224 r;,s z s 9 0 0 4 &.S :; g g Cgd4sVc > aJ bDa U aJQ ;@ ;es 2 23 .;!:; 2; E - LGn”3 $4 bo:? p E c m ’Z E aJ. * 9 g mzla 5 ws: C“ aJ gz2 g 2 u^ g ma’m,c 5 L 2 z $.$& 5: gg5x E 9 2 .g .g3 ; 2 maJ3 aJm L.2 22?e3 M$ .zw aE w 2 aJ ;s -3s: aJ * Ki% a.e,=5 02-fJaJmaJ $cz -5s ?.c ‘3 5 > m-m 5 .- kaJC sal2 mxg Y, c 2 En m.;m-- Y $!zdbO+o$ Y mF;3 z 2 .2 .s ”.g “ .x 3223:55; 3 xa.2 =+ Kim2 x:; 2, ;Z.$ g; 5; 333 8 $2 2 y-34gug 07 2 %:as g.E% ks m 0 uaJE 2 aJ o-u=c* um -uc a.z 0 a&$ maw 222 6 25 33 3 -9 8 $ %.G 2 Yvl wm aJmm E-: s g 5.z $2 $ .s 2 E q? EWE 4uc 9%2 m5u 2.35 5 Mu- 2.2 0 ZZaJ 2GE 2a- 9 49 0 v); “-z 2:- 2 us 55 nc%& g; 5.2 c .s 0 ‘5 7z-g KgUJ: 223s ucm W * za a0 -UGW # ,Em ’c LC sa2 “ ’x$ $ I “ m C NI r,=a 2: i 8 w .c 2 E2 222 9:g z d 8 g .; I 2.5 i 02 E. “3 m aJm7 -u -0 M3 5 e 6 % .z &-E 5 EW. E E g-. 2 E= %-54 gz2. no 3aJ” J3 c. 6$2 222 us 3 m: gaJw 0 a.- kT; - s 3. “0 E ,Xr u .fi UJ b aJ51 y2 G 2 $. ce 060 ‘Z aJ -i2 Y 2.z 2. go2 a u a1 *i,<d’3.“ ,,”: U 6 8 _)lj .(rv t 2: <n ;= $1.. , 0 &i.; :, ,~ : > u,’ .:*’ 5 9 SQ g; 38 + 0, $0 as Je 0 z 0 rl m d \D N a, 7 5 C M 5; 2j za VU SF gg .4 @+J 3 ‘i .A m2 .z m Eg oa E:: 5-. Ma, c* m ” a ul a, 3c co urn .i -i Fu ~ C .i uuom m C E.C Cud 0 TiOU+OR v3Y!?c, 13 orr.; 2 mum007 mu -a, Q...d, L.4 3 LJ m >-I VmuobQ m Mm v) 0 Q13 Q0.d . aJL.4aJ.c ”JG-0 a, Q0JbQal:I 4uri a, c >.C UM w uc4 -00. 4 m XQWC PUUa,CU m c c 3 m.4 dmJWL43 bU 0 -4 a, om a, c rP.-IU > C M aka &a a, 0 C V1.A a14>0a, 4aP)P)mw m 00 lil MY .. c VIC xm m a, u -4 0 mwz.4 m CMO 0.C !- N CUIJ Y< 0.Cm *mm Z Mm m.C acoc c .4OVUM .i 0 alQ.4 . Mus E c mu L.4 UE.43 0 zcov S” m Mr. ow 0 w .AZ Q n .ri mw E lad In mY >.CQ J - w bo u ”-$ m E u1 ffl u CV.4 m LaJWL.4S CEGIdEOu m uw ww x omdwc x-> L.4 a, m 0 U C .4 L.4 lul 0 .A” 0- cu 0.4 C c I .4 u w: L.4mo u ka, oarn m mI: UlIJ >TI I: aU!2S.I!!2LJ CmJu uwuu OJ4c AkV 4 N .dImmO.C .AU E aI U Qh U us !- 0 0.4 . .A mal-4.4 0 .Cu V.4 > 3 .r( GI 3 J w ow a, a,n+u c.4 0-Ind.C 0 Ob %h3 mu Y X3 JQZ m$ V *A 4 UU * MC a,uc4a,>xcm .?C 0 kQ1U.d.C JEmu3.CCwm Ia)3mcUvJa,m dOY-mEE3 waJ4cn B s ” a,oouu umm ruucc .4 . 1, m a, LSJ~UI uebE uuu3 ^kCWa, 4 .d Q u 0 u m4 3ws.4 cw >a, 0 3 > a)wu.lw bCEL.4W b.C Ea0 a, a, 0 J44u m zlu >-4!-a,a,cuo BU0.C acuc 3 mwu Mma, .A .C 3 m u.r(” Mo c 04 C4EU -!- C a, JQ mz 0 E cm.4aI 3 0 0.4 m 0 wr a,w alr mvum c MC .Am C W C QU W E.4 Q al.C-4 sx 0 I k vu b 01, m c c.4 C rOV EO05 ... n a, a, .A.~u u.-r Y) c 0 w OCU u uus E.4” VI0 aJCVaJk dm4 C 0.A N CU LniS u m .id -i CY m m UDUWC baJ 3 -hU CE ou D o z 3.4 C aJw m 3 u m >. 0 ruL.4a, c) vz.4rlJr xu C a,-40 dZ u ZY u IC( 0)u rmc) 3 oulwa,L.4!4ulL.4 xma, a, 0.4 X m c) EOCuJu M u 3 m.c k 0 0) mu aJ.4 ?+ULS-c > UVI 1J~ui>3a~~i$n,.iuu c LO... c.4 .u c dQC 03u m a .= c+ mu r.4 3v m 3 O.- -’- u .4 0 a, CaJ~w~Vumm~4 uw * a,~a,mcou m nr m OQ‘OQ..-I v” o 3 c cn a, AJ N C0.l CU(3~LICLC WOmdO J .A CrMC OJWQqE uomw-~al;:PmU1:~ u macmm .13v ...Cm”mm... m.CuuoM,r:e.JrJC . .iv...cu EUbLJ”4CUb 4XUY ma, v bJOmm.4 a,Sm+O!-a,>wu.+ w v)~..+a,mm X!- 3u rn oms mwuau mcormmmd .A U r[l b E b’U I‘M0 .i b X0 Q 4 CL CO dE.4 aonoa, mQu 3 oa,VIov !Jmo c3.4 n a,+ vu m a, m m w m 111 a, m d a,udu v~~a,wCa,c-nc~~cuoo.A.Au CV)a,a,CU a,smlJEmmUE Q mmCC4S.d m.4 woar 3 ox3c us umE wa,c 0 09 a,- vd m3 u > a, x n OOI>O xu JYEC-DS I aLJ WJ WOrJ mn 0 0)V ad N m $v)YWCL.i CG) 0 QOr[iOOX N 4 c c u (0.4 N o a,nw e b.4 m .a U .4 .4 U C cu .-< U 4 v1 E VI C-d 3 U~T~T~~KILJ .-.la,a,cv nb .4vIuP)uO a,.~mmCEOCa,3w vc a, cumvgru amrao m3E!-C3.~ c w w c I”Xa,W CbQmUmmoI u - o om aa, e& >,uw cu o J m J In !-.A wwD..isu+a, . v) owoaJaJa, >u uuVI 3mIn.4 V MVS C id VU U VI 0 c t. 0-4 m.4 ma, !- a, c a.4 a, c Q Cra, In b”4M QJA Q-IL~CRICUCO * acc --na~ uwu !-XJ.~V VJ4z VI JCOU 4 hCcQCv)W a, a, me. MU a.4 u ~IJ vw w 3 a.4.~ M .C€JQCL u m OCO -I>@ u om.4+ua,mu u Ud a, b -~mw-.~ -u =no..+ VI uu EOCku v~umAomuwmCC Y mn.4 !-.A L. L.~A 9.4.~ J b- a, a, -A>Q onanaam .~cmuua,v c w Ria 4 m.4 0 m.4 Eu c Ma XE 0 Ti >,W 3 34 3 0 Q > 0 C U a C.44 C ~n~Yo~nua~nmuvoo-I.cluom 14 c c r: o c v !- hun.4 ‘UCt’? m~mC’U~dE?uar.d~i~ CD z E 3 a- VIC mr> 3 v- 0 u Q 03 2: 2 uCc”; ... C 11 $ J 5: mm d$ E .A 2uaJz 3vm LaJ In30 q.la, 4 0 v4aJ m3 -=a uu w 3 Y n m3 3 a, >.VI m uu 0 r*a,c 2 ua,>a,p almE4u vu - 0.4-0 azc n ~4 x0 OS0 E3WCO m u u-f.4 QEC wm > a CID m au -cs c4 u c- IJ o uJ a,ama, 4 .A a, U a,.-’n N >.C E”” .4a,wwc~1 uQ d.IJ1 uam Jc C m JIJ :: z WCOO:~~ 7010U~ 4 c 2O-I 0 C.Am5 xus a,YZ $V:JJ -;? ... c X3” k om 2: gz :2 O M * w .., .4 Urn c86 >g 2 *i .-4 M c a, Cd 2.2 :5:2 - a, m!-aJz k .: t \: 5 2. C ... u u am-c cu 0 >r E +., 2 a, CI 9 I= Q, S a 0 0 0 Q) c3 @r Jc 0 z 0) U 2 a, k- iWaJE.C i rmraI$4 uo .d e mu f ow c-i -l mu m E P. mu aJ 0) (0 aJ.4 ."aJU 0.1 3 Co~LUO~~ 2,X:E2P.~:P,,Zw~ ommob mk anmcle ~am~uuo m .A+.> c $4 QJ '3-4XCSwOlMO 0 ern 4W'U U U4M mu ru vc c ..4.d m c ulS QI 3.d UU 0 XES 7.4 . mum. v UuEaoCc a, mu 4 $4 .dom-cco uwn c .A a, a, w u u L m.4 00 w)GL.r(m>b MOI4U $4 m E E 3 a, 0 4 a, MOE:..rl QV-IalO .!Z bCQJU mmrw $4 aJvum WE0 L >UcllUUS:.rl-l.4 tQ w? us0 3 43 rmcum OuCb.dc-.4Oa,uumuuu $4 $4 0.dU U UU J 6.4 m QO @JWS LOWbUumC EaCS mUxmOmOCw0 .A.d 4 u 0 u w Ea, x 0 ub M ulubul -ad4 C EW 0.4 v) > 0 Q0I.d am 0 b g 5a,~$~2~~;$~~OuV 3 v) ::3"=: :gm2a,i.222 g 8 uMmOCCu4cm ui-lc rc o +., "!EOUUiLJS$44 QmU> am rn 0 ;':2$22 :u2:2 g NE $ "Ib .dm.4uE EBB bcomu~ma~iuod u wE.dmc CwEuu-caJE 3aJ oa,a,-Ia,>m wuuw ObmQEddEw .. 04 S a, o a,n.rl QU m a,& cs a, -.!Z:r(QCLU 4$4 -Om Cm u 0U.d or >r w alu m EX mu> EbOa, mu alal.4 me $4 c w3 QJu b L Od ou 44Pm mu U+ma, >? OCLJrnL r.d LIY >mw > ooG-oux xc .- 00 u.4 a, m 3 @J ma.4 a, mu 0 L 1JEO maCCEmmuUQ urn w Mu0 m.dQVi2 J a on.4 in.4 moccxegm C+ OW 3 04 MEA Q) 0)u m ~1.442 .4 Q3.4~ > E a, uA+ 0 ou$4..4c a, E u1.d mu .-!u(Yuw tJl4aIOb 3 ~mc~wo~muu~a~wo u m $4 w.dSr 0 w a, Y mrrs CI QU EULJZZU L,$4 bu!" u1 a,v b4 4 3 0 w LA 0 Yrn 03 .cog 0 I 2.; 5 .Y 3: 5 'j: m$ G .* U-U OaJ 3 '5 m .% au a0 Ec -w& $8 M$ .e I 2 3 .5 Goa 2% g2 ;2 8 .E F r;:r " !z 't a 56 QS e% cS ES WaJ .g ;;i z.9 $2 - uti 2 -w 1: .E aJ .* Wlt- LJ w 5; 0 .d ZG k?u -uW c .e W: p m5 .e 2 z .G 8 '5 2- &E &2 mm -aJ -- v1 mu P i2 aJ: 5z El, gJ .z g2 3% h 3 .* E3 $5 a2 U " M eo aJ& 20 we -5 .* le 0 c 2 .i 28 0 U .Jl m cu Y OinOlnl al cud nl u c CA nu co a,.-" mMXN rU VU J m.dU &. 4cm3uc u >a, .dmcw OEwmU.-Om Sa 3 Cdm m 4 00s a, 4 IJ 3 CcwJmQRm 04-imu L.4 .A 3.4 0-0 uv cumw a ce.4 a, b c a, .rl wuoc Q~U a.dn .d c a, E oou.4 uu > UIJ ac4 u a, .d m > 4 ..4 b EE $4k- a, 3 3 mauw S nom aJuwm 4 m.4 UP) w >nm m 04 m 40 m $4 m Ed NO) 0 Qm .-us a0 c UL u .daJWLIEOO uoum 4 u IJUlCWmWulC a w IJ ...A mwc6t33aJQ3 LMUQJ EJ IJ m c .^ 0 u mmoumc@G u3 uMLm m zcw"4 m >-l a,$4mxcO ai >a,.dUC 4 CaJCUClJ .4 m . vu > .4 .4 QJ c m b4.4 3 a, n44w aJ,Ew ou u-4 3 Q UUEE 4 034 OD Ln rn>&E>WO +m uu3 m 0 . c a, a,un c w 3 mr,l Ld '"02 a::u VI u a3um 3 OCQlninrP UI>.CQmC.d C Q m- u 0.- a, Salk a,%4U 2 >x wrru4 .d 1J EoV U m U ou LU U*d x 0'U m m c .A m HmO4Vo>a I rnd GtJ L 3 .* .r( bl1J 073 u 0 xu > SuCUb r:4 m 0 43 a, m u-do c a. 3 LIE04 MO a,u (il ucc4 0 m.4 Qu ho SmEC a,u w..4 a, a, .dC4a,LlU >o> Er: $4 OE.4 k.c > 0 EX mmCmEm ..4 .4 0 .A e4 uv4 xv!--u u os LO :: g.2 2 a, g .dm czm u3u25x UV M V u ..A 4 ur: i 0 S .A 0 a4 3u mu u c ..+ d n .., uuL.0 u CCmcm'll m L ar2 c m.- 0 3 4 iu 3W Q.4 0 a~ Iw U $4 u G1J u u-c 0 m ma4 cm aJ0.403 I: 4 Z QZ QO J IJ n c .2 u on #vA uo OD z N 4 J., m 4.) .?. m i w u 3 U-l u -4 -4 M.4 L aluum33 m 4c 0 33oocw OE~~OL XaJaIUa, w m fC 01: bEAJv1Ln u .d .r( lOELivnr LU wc aa, c 32,E QJi IJCU> .d4 m m1J W Cu uu OCUCVCCE 13 CL .r( aJ.4 Ql MC E QJ UUJUJ +a0 CS.4 $4 a, m.4 u .A COW E 0 -4-C J Q m3.dmEurruO $4 uou$4om-4 SUO CSCIMU 3 - CW cJ"4mb.d m4 -0 a, b 3 ..dumuw b -0oom w c m a, c-l a, oom L M u Qw ~0u~rW.dr 4 b .d c.40 c a, C E u MC .d m uw E U UmmC CJ rJ0 E X m.dU 3 0 C V VI UaJEmCESUw 01 4 34E UJJU abwo ow .4vm UL w nu o~u 0 OEU v-l . > a, $4 0 CUQURJUlbOm VI 04 0 WU 0 Qb C o ..rlnrlc~cl no nuurnwco o E 0 c $4-0 > mu4 mum a, $4 a, 0 b w-4111 m .do CE QOU aa 3u-c a,W cu w4mwmba,Ca,OC Sa, mmwuoEuaJ u u SuJ.da, u 4-1 cr ou m U4.d 0 v M?J b mi VI b b.4 OdUW c E c > 3.4 c m3 EC awn m al .d .d v b .d 40 ua,.~onb m ounoc~ma,wu m Q cmnow OJSmWL U J Cd QINdU WUOJZ su L4.d 3.-( x L Ob e .d 4 0.4 u x #A e w 2.4 0) j." L. SWOJJ JEOUC Ybb mcum wo 0. 01.4 al $4UU m.d cu VI uu bn c.4~ a, . w unrao 3 VI owc unaalomm J1 awl n-uc.4 >>uEmumoM UE C QJQlQ> Cm E Z.4 a, m ES m VI 3 0 u m c4 b aJ m c.4 mc 0 e- 0 0 > S .cI 2 a, .cI 9 C a, E - 8 3 0 0, a, D 9i L rc " 0, 3$ g8 ar a-c 0 z m h Y 0. ,+a Oh a,u >a UE am uc m .4 500 22 a, 4 !4m CS m 03 UD m wv w!- 40 uw mu m 5: !?$ cc w3 Mm CJ 4.4 22 > .4 hC 0.0 uw om X1 uh uw .c wu . Sa u3c om XCd DA a .4 .4 47 w U u .4 00 C cr 0 3 F." d 40U Uu m J WUX w Q J.4 LJ m oduwuE U u mr w uw a, m *.A u uD .4WX w-l u .A u 3 b.4 u w 3.4 w wcm3 zum m um!-c:4'0 uu 00 .c 3.4 c m w a, u.4 SU?V bJ LJC mum m -oca 03 . c a,.A alU7wmE-r rl h u a+ .dU3 uo NU~EU~ 2 225 i.; . *mG mhaD Jw w w XU (0 >. !- x doc ad al a, m-c c Urn u.4 rn 0.4 k.4 v U E > V.4P Cd cm.c cad GwmmDm a, c u 04UD E:huwhm OU zu2 Z2Z.S ww .4umcr ouwo w 4u-c GI ul a, E m VY- u J.4 E rn >.c M.4 a)Eum : c?d5 0.2 b Jauw Ern I u Jd CmJrnCO w > aiyv EM +.c E E m um A.2 y ?.: .'G k ;.:> s ?.--" I A - 2s 4 X e\2 : ,k 2 ; .\, M m - i a, c.J .A * , -P I e 5 n e v1 2 - # .* - e x m Y 6 5 2 5 E 3 .e I m 3 a a - v) aJ d ? 2 -5 aJ .IC 0 2 5; '2 bo ab0 'C 2 42 i$ %% 2s EJk -% 4 + 2 2 'S aJm /$$ 32 zi 5 5 - L - - I h I CE - - -11 w: sa 02 48 u.3 zz - HS c42 g: k? B v) P 4 m m 4 \D N x 1 r, 4 u C a, a, w 4 F C m '3 UO 05: ,u cu 1w cub om c n .A (0 c 0- u1 aJ 0 -4 4 x mx EZC 0 -E CJ Y 4 u -r( s:: mE+; .rl 4 €4 ca, cc 4 a U .. a, .. 0 11 E -n Oh3 BLV) v WE PI0 CF 4 mu am 4 3 a mo va a, QJ (0 zm a, w- cW .rl E (00 3x 0 Za rlmu ma .i .+ E mwm @EU u a, -4 0)ZW RO m a, a m C u .rl c3 2z2 u 6- c m1uw aruro ua, .+ha, u.4 a)* 0- 8 c c hu: -rl- 0 m u mud) 0 A .. 4 u v 1u c w.4 ,ua,3> m EV k "2 cc m OW -m urn me u C" m004 a-4 E PI wu os 3 .4 = a,Ij ward GhWd U8U 0 mu c ua, a, a,o vw E xv U -4 4 dp 0 4cou am - hrn c -a wtV-4 00 v 3EbG a03 uwwu vm~ w :I u .rl aai cmc .rl cm 0-v 11 )-I me .rl 0 hG WE 0 0- w ea, VI .rl mu 0 (0 .4 ouo u m >o 0 WO us. m auo WW OOh W .Ye:> uoo 4 4 .+U E mo a,.+ L! e 1w ua 0-3 OaW 0 v. pI3m WGa- 5u WO a UP VWmW cs ml: m3 30 k ar- 4 %- - e ; 8 aJcaJaJ ~ w $5.5 E C 2 0.G M R .E E 5 a2.p c .E g x Vi 3: 5 6: 0 m< Cj gs mLZ0t;;; ;B5E-Zk - I ,%EoWoc - Y va iz C.z EGZ k& ;,Go ax,. Z" - s:,sj $ wo 2 222 5&433h r3 g*L$% $ .- %"krg: 2E g&:s c FLOW aJ nm v cz w.2 22 m.z 2 E ;;; 2 -5 ,x G.5 E ; L O&U - .- gz=Z E 2 w.a< 3 9 '- MA2 2,; 2 5 2 . ,5 =r 5 zj3w moi%"- gsm 2g: M e~gszn cl".z.z - 01 03 ,m 2 v;" ET g g Mn-ii w3 vI O v Ww.Z aJ.z - - .- L 3.-~ E.= awso L0 o.~ w 3 nSI.5 aJm~LomE L 2 OL en E am wo w ob u I = .- g5 LZ 2 o&s EB 4- E 3 '5 E .% 2 .% Z2mEaJOaJ AI k - m.-QSm z.5 ZEZ y 2 *3 2 v7j E4 2 ;2: ,d .Y x -u 8 Wm c.5 5 . 2"" 0 zg &i 3 5C8 " .g .5 ' %;a3 nyh Wgc 4 Ezz 2 3 W.? aJ2s 12 emu >r -E: 2 5 g2 ; EA2 - gsE $ eog " b z2j w 2bz g egg CJ -c CCLO n .I .- 5 E2 0 2s rows Dn " mnm c= .- W c v; ccm u m .+ .- - 0 22-3 3aJ 2 E .'C m aJ02 c A:'C2 CS b aQ 9 MWg 2 aJ ,ai ucc .; 2 G 7 2 2.- L 0 u I h E g 'Z :: ,E L 2 m.E; v OI .gGs EZ3 2"- 2 0 5 =-i &+$x 2.2 g<s c 5% 2 t.22 aJ m.2 a c.2 c ,=q c !$Jz&%8 I "'; 0.- 2 G, L 2 aJ m" g o cs"- .-cw 2.5s 2 5 g STJ b-g .- c) Mo $5 k m u.C o 2 3 aJ 2mg3EoA Ls L.5 2 2 ; g3 2 0.2.: 2 3 u gLE G.62 .- 5.2 cA " .* *$ i%z euigyl ; g 6 .e .g > '2 ti E-0 2-x E g;;scb. in=.z?J si z .- " eg C%VS m*!S b z5 42 -5 v) 201 ,vu3 2 aJ ZL 2.z d Of4 E O=" a Q 3.5 v; 3.2 mw .- cs U9Q . 9 w ct ac wz RmS&z Q2% iEs m E Qb'3 8 M8 o~-.D Cc - %E$?:$? s 2s $E%.? : -\ m-, r, '. ' 0" C. c+ " - bo a_ .- C0 UO E- + 0" 14 1 r( G rn r1 M 3 .-) 6 ? T: 01 c m - C M i3 E M .- a z .= ; M f S 0 in - .- g sz E% :< Q34u cS-2 z zsq &+ 2 .- 2 M= E? 2% 5 u 2oL;EG tj .- -c: w c x- m- 3 xe e r ._ %=? S32 - .- 2 M rM E2; 2; [ -mc, MC v, w p" .- '2 z ;z e czc gg: ZGE. GZ$ $5Q "7 CY =2z 55 - ZuM 0 05 SMz zePJ mc M 000 -=< =z ,x -E 0 ".E .$ g 5 g= 0 E22 6 orlm g g.52 '2 2 c: ; ggsg ;; n'3 e .- in "7 .z v) &<a E 2s u Y 26 -2i s ;..z 2 2 ?..'"? $~~~g~2 0 0.5 .G = 5 g s ,z.p 5.g 5 2g e, e,:Es $2 $2 zGs 3 $2 2;%:5zn&l "'5 f 3 z '5 e*"" - L 0 0 2.2 2. g< p" E 2 c a* m L .- pz.f3 > 2z ;2=5 z'g gz 2 M ; ?g2zgz= nhp;gs m 0 .- '.q :!.E '3 "g;g;"'H 32 :: $ "3 a 22 e Q) 3 g'. 5 ~ "7- al >;x ,=me a ~QL 2: M 2 z p.92 nz u M o CD 5 E %om2 ms2 0 .- C M ' ow 0 g.22 ma k=Mg'309 ulr ZyES "'UMCQJE zeSEMC~. t: 0.z o E %5 5 - m E eze'! 8 z.=e= & 2 0 E M w3.s 0 93 "c 2.9'' - rJ s2zzz p ,C'S 2 2 8 9 rJ OC;c'3% %i=B x 0 aaD 3 M.2 C L =LC .2, --Z m E2 - 2 3.g5?g :$ X 0 E Y 5 a 0. E .- c .2 ww ;z - :i $2 53 .c i; .Y 2 mE im a, Lm $; TlY 22 &- 2 p- 32 zg .- 3 m- m C< 3C 2s 5: .% m Am 2s aJ= =2 blu 53 .- ZJ: 2s 2; aS t;E: c4 R aJaJ - $3 5Q <5 WaJ .d rJggg'3.z2'= +g';gg=%, 2e,,1-c E 2 z 5 .g.g.gs g 5 M &Z 2 %%.E -5 0 P) uE$ E 3 633,;; g 35 qu Zss g 25% g% 5 ESU 3-2 0.3 ?$zgg%;: $E z c5%22 cb.0-"7 O&gsGMM k.zU ;j 3 M 2 8 -e) mom'3c $Eg>MzEz E$ :,;? EGT 2 .s - e Q.2 " E: 2 g 93 8.2 - 5 gij 2 8" ZUZM a6nJ 9 2 ZZ'' 2 2-3 g a$zB.e"n%:.uZ 'Z 0 %.eo & cz$ g ::g5s2.5 %.Q 3 3% EJ $2.5% E um~~fA3 E 5.55 2-E .vu v) ti=* 2% 6 5 g P) -5 E'q E .- ;c.= Em g 2 5 e, n e, - .3 nc G~ "2 3 5 8"s = d L .; .O~a~z~ 8% Q 03 L c J E. E c.E=S zZ2 C M " = 9 0.z 2 naJ a~a~og2M n 9 vd y.2 -5 25 < 6 d 0" E 2 2 E.s m ,= .: 5 nE tj &%'Z2Z 7- e 0 ril - .C 8 zs% &3C E yg.5 c G.E 22 m u wvv E a==. g25 cqgg.; QJ 3 g.ZU , 5 d z .E$ 5 gc- r: Cr: c m.2 s; 02-?&; 0 &.% E.: L 23 - ~ E g-;;; '2 2 .; m a ZI n.S 3 VI m- w w nu" 5:; 5 ;;; .Z$EbCwEG 23 zs 2 E2 c : ;%.$E*; &$E *z I E p& E 6 M w >-c .c rLI2 '6 M I; z.zo 2 2.g a u3I: E di- E k -E =Sa u4 3 0s u'c3 VI 2 2.z E 0 2.2 2 aJ bog ,"a l- zsz w wc, w - a 22QZ=z. E.5 i, w2u; , ap;i - 3 EL.?' w,g m m 2'; O Y% -w aJ -5:q L VI 8 zw $2 g.;% 2s..Le 0 e, eku OCEwk ges=i?eiz'J c w "'t aJ n%zL5 Yu~ MSZUEr:wE~ 2 .9 M * Te .=" -.. w + m 3 AXc E E" -4 0 C 02 E ~'3 -.- m EZ.5 y $9 %%~%EC~EZ mu aE z 25% wo "5 kg m mczE .I? 0s 7 a * aJ wEg$z; " EPBS.2,bg *?e E 2.Pg c Mm 0 w 8 ;j .z:2 .z .= 23 & c 2 p p:k% t *c: Jm c u* 3 2z c : '2mm: .gj 2Z?k?-. Um-wQJ~w; aJ&G32+: E, *I =VI- W, W" y ~ rj i -c3ZEZ-c! F 0r:'SVI u c .ZzkEC; m 3. r,XVIW,Cl 3 2 b.SG.2 * 0 w 5%: GLi g e+z zz 22 25 VI 3.' 5 5 E ;-2 y: 3.E -"QZla, - .; f .% .z g : a ,501: .y -J z 5 2 E .a.= 2 < L wz E." m w .- -+e 3 3~, E;. ZT G" 5 aWZ.2 C' EZ 2 %g Ed n w3 E- wr: 2 w > 7 E.- L kG2 -2 cv gwwi. E.6; gz k -2 z ".G: .= X$ 0 ; m'; 2 3 $ '60: 2 ,! m$+Z- .;x224 0 i $*Z h &; ?.E -z 3 3 L hJz G 8 I - a u. ,2 .- - w c =W= 2- a> o 3 3 5- a3 I 5 3 .- c- VI 'j 5 Z 2, v 'Z Gz 25.2 gu e 3 w TIUCS c ,2 +zzsz5 5z.z u 9) X""%,OZ ma- .- c u) e e, c 0 w.3 tS z E5 E %.gE$ 8 E 133 -wgzgz &%- US 0 Y) = .- &$t ',cg-sq x .E 5 .e, 0 " -5 e 2 c%*.o.gg-g 5%; 7 m -3 co e, ~-i~wcw a: 4g't E ,OUP.~~$ og~j >:: $<p 2 c TJ n.2'2 52 e - E '3." ~:.~~Ej,PB .s<z :,=z &yg 3 L e$+.: 3 a- a.2 5.2 & 3%: :g: C 00 2s:E$$&$z *oVIcJ Ygzz -c opg c Oa~s 00 .no $2: c E:? & g * $$." o%ze 9%" 0 2 nE'=" ;g .Ez @@ ; 2'5 2 cad 5 *- &::; TI > = YL sm Y e. u) 2.0 c.5 u u E." 5 8 a 0 8" 8 "a.ze v Y,e 5.E 0 o gz.;gd.. g; :E ~~=s.%~ * E.'"^9 ,gs g &2r$k'= &3 eczoo 8, g.s.2 g 0 * u) a,..$ z =% $h-.ea s'ta 8, no k 3 O 3 w.2 0 5 g 2s :& .&E2 $-a 5% 322 E E8 gXJzz x z c3.E 5% 8" a, "XJ c aAjzgs ;i 5: .I g 2" EJgz $s%+ ?e -0 5 * 2.2 a 2 g kg q -=.2 2 g.gs'Bg 3.g y 3 $3 5 3.z 'c) m.02 5 > 2da$ 3: Gas -2 e cod .so E g5 m. 8 u 0.@3 @ $E ;;eoa ms 5 F"g$z r Y gB 8, %.+ Y 9 g s 0 xc 9 2 2 g" ;k 4r.g k.z 3% - 'J CLOD "+Si& r 5% 62 gs&j s -OD . gzss= %$ e 2.g3 5" $ gg e= $ 9 =,E 'J 3 0s sou * 0 .z .G g.5 En 2 g.; ,583 VI* .Y? u 2 0-2 S .- "O"3 g;.gaDo.,u 3;s E $ p) $2 P) 2253c" -2.e.; - o ng z 8 Lzs.g $3 9 ,Iz.g+ g "8 % -g m c *'Z ;a c 222 5.E .= f2E !5 a $8 ga OB 22 agr "W.C YO a s.rg o",.gg3 5 g a pt 0- ,?= ; ,g .- YJ ._-.-nu~bE 0 E a" 2 v)-yI c '= g jsg 2.2 eu 2% ;aogrze;- ;.zL gangzge 'j; ~.ao ,a p$won $>a auE: 3~3 - 2v E "XJXJ LI 3P; a;a ;c"o~"z8;E~ &Bg .E=. 2 s-,s 0 s'J;z'J c 5.3 > O$@ (0 * e Mr U .."-a e, 5 0 w- *sa85 - EE8"2E, 3eM=$ avig 2 pDfUs.c$ guQz"s3 zJF c ue,sozg3 ssc on,sgk 22.z 5 ~8,~t;~~ S !5ac.= u) E - o d 2 L.2 L .2 e "&5? 2 0- 23 u.5 g a", 2 o Pr $ 22 - b : 22 2 L s$.z c: e%2$.$.;$ gz.2 6c 2co.3GD S E= + 3Z%% $ s24p$j g!g;q"Ba' ."US CD-C ;02z a& 2c Z&'n% r c M - p) L oc.gz= .'" x 3 PZ.5 ac - -~~~~2~ -C.?ZE - 9 ~a e, L a -CS.-.~,- .- 2-0 23 .- SMmQ ~,i~~~~ zzz .-a gm$2a$ 0 M ,,,s'5 ",$ Le,En=;-oz UF z-u-2 00 5>must =a:! CV iij .E .. u) E 2 .Z 'i: * 3.52f 2: ,"x= 2:: e 55 5.5 2 w .- ", - 0 >* 25 0) I.. m .- 6 e-, 5:~.m .- .o 9 J ? ;w=q c Y .sg ggz.,,, =n=, $ c) CL~ g .2z e E 0, >D 9 e. .E '2 .- ,,gLCceo a e .2 Q 2 0" k.5 4 as-- 2.9 3 E .= s Y - CMOC~~ e 9) 52 g € x 2 gS&& g 5.5 iJ @g E%.$ mco5Eeza ve8 g 2 e ~3% ng ~~'5a.z fUDuvl73 .r O nsl I 4 F 1 I(v e e w-wVIM 5 5 g .F.g $5 .sa aY a2 $w 022 u m g.2 m 3z 4s g 0 .Y a 3 .s xij - M3 I m g cz d 2 E2.5 - 9 9 M.Z 0 am, 32uu 4-0 a-6 .I -pa : -g@ z 2- ma 2.2 2 .c Eml; .c. 2 -5 " e, 3'w<~~ "Me 2 .4 .- bo M g g-; 5 2 VI c .? .E zz-2 Eg z.=: 32 m w aa w4 i2.p h - c.z e 52 oUs% O .t: 't 3 ,o, 5.5 5 c 2 z MW,.y - SeZ.;? mgom gVI-aJu, 4 32 a-0, VI.4 :3w4= , 2% 0 0 cy. c;Q- QJ 2 0 0- 2 &$s M a?,?$ Zzg@. 8 g-i c" q a, " ml P u z a'? E 0 E e" %g~-g-z~g 2.E rd E? E.$ 9 0 7 e$.= s .S M - -- .- .EZZ.$$? E ,e- 25, g 92 g "u 0 g 8.2 e '2 2 u .E 3 2ss-2ca 33 ggs 2 : -%a.2zu h!3 sw 3bzE;gLJ 2a.$$z.z 9 2.2 k .e " c a "sgp- -3, QQ $.%g &$ ag-" g.SE.5 - 5%2" 2 3! ".E$% $ a $3 5 .$'4 0 $?p+gs E ;."p?-ija; -u 0 g z.ssg2 E% 3 W.53,-O 8- cmY=-E2: g .a os i2.8- $ 6 g$fBa".- mauog : qsZ a.46 ".%ZS 8 ~~$~2g~ gS E 8 s.23 v) .S.%?,g,, y ebagO2 %-;a,: bo z --a o z 2-a~ 2 "MC v1-4~~~~ .- GQ"$ 0Q)u u WE E .L- s,g+ zss '522% oc,o 5322 23, mgw 2 a$ OX %* OGZ2 c.;; .'el ,mzg 525 5sdX 2 2a e0 $us gags Os'& ?&2$ 238 'W ??i4 .: 5;s 0 f ZTj . sm%u mau.9 czs g 82 csza 4.88 ,zh;2 9%%;8 *=o& 0 .- (u E 00 p) ai *z ,e"< gps $Eoe ,454 giqg 4 a2 3.2 .g:g . 2 -42% SS8 =MB $2 2 3 ggga $-"e% Oh= O 3&c 8c.z :pus c,ZQ 8 9Sf.S 4 2,'Bc a .s$40 g*--g s c, s 5 8 Wi g 525 cug.g 2 2.5 s I 5 znu LI mca.ra *n,O af>o a 2 T, z e G-4 a a- a " m*=o so I. a ,O u.vr.2 Zgo c I. u - us3 8 f &$ - a -J$i %zu $:x; $9 @z u Eg$$.?g gE:zC 2 ,? z i 9sosz. s42;;8 z 3 LmI 0 e g2 2; 2 X282 2Qz.m zzMm .; E .a ;ij s a 2.2 2 23 k52 && y m 2 0i.d g ,xa; 2 aJ UL v) QI E QJ 5-2 bog> 2: 5 g E.$ .g y 5%: w)L.M e Ek a? Cf e 52V Er-aJ -2 Em5 z2 -i .I5 9 g.g a . a2 I :5?2%2 c L! .c :a T!2mQIz. ag z.2G $.E d 2 $$.; 5 :> m g2g-U ;%5qz zfl I a .f Oca 9 c 1 EQI 0 3% 3 gz22 E c 2-3; .s Y;-%.eg tu M gs v1 alwaJcE2 QJ m- Val03 n'=:eLL.sr z oE 2: g 22z 'Z 57 !a 2.z 2 3 e's salze E v1I: a s -2.5 5: E A? $2-g gz $3 5% '9 Ef-Z 2d2 2 4dkT1ZLI 2 E.? Mfj z 0gi2 m 1 hal m.2 &2 2 -c,u ass e a 2.2 bqs$ "G 'Z e .- 5 c > '8 d 2nEu UA.24=& u-z ws d 2szaJ:2 0 ,xal 2 v)I f-.osrr,a -1 =eS.GGE "Eat; L "U 0-f 5Gd2 0) b0G-d I: lhUUG c) m a.z Z 0%: 3izocg 0-c c u L. - -- %.LC) + -3 nb 22 caE "a I. m-Q 0 3d 3 3 a,.-, calwnm xd k Am w L- w z '6 .; ,a8 e 5s .w Mal-? " LI 4 m I c ..I A!.. D YY w E .d w 31: 0 am m cm mu-. w .A !.. E .rl uu WLdws 3- -4s 4 0 .a, 0 UYI: u f wum u w YOU Iwm awm bF- DZ m E cws 090 do m 0 u IJWW UbErnaI4X 0 4 bm . OU-4 .4 m I xu IIb IoJOW)Y4UU 3VICaLI.4m I ooovc cv.40 WC Mmmc- UVWWE J JZOJIbMO>. W" I 4ms.4 bWCIOL4+W u.4 4 .4 N -4 a C 0.U ronr~b s O~UCJ(DIL WIJWIOUU 3 b u 0.4.4 rA obmm UUYUVI 0 0uwJZ uW I .4 b ..4 to W 5: 0 WD v) a.do,cud a LU >>aL E I: .d.4XVmuD301 amuoum- om3u Yvmm.cam 0 bas x vcm a,~n 33~~ CCUW.~ obwmmz4 oc 0 4 w%2a 2ggt9222. ?2UZ!i2JJ 882 c E: cL o $a:.: 225 02 2.2 40 4 bMmVWXmUI U3 U1J C 3br.X XJI4 dEU I WUIVIJE. -c M ,4130 I ax wv u J o 0-04 A 14n o arm a,..+ cz c m.4 o E VI 4-1~014 u JU~IXU LZ~ -COW MMO4 QJCC OLd v1 UWUCO4 Y JZ3a CWML UNO) W WI3IJOcl C.4AU b0.4UUV wm cscox3ub .4W4 m b v)c W W.4 b oLlo.4 c .rlbwm m-c 31 mu mn04o.rlau VIVI X m .uEE X09 " Cu OUbKi-dm JZ I JWEO 00 OlC -4b 3 Cn VI4MIJb43 W 4C QUVIIUUW u WO bUa>C CmaICWWo 0 a.4 6) 4 0 c c ou: 3 04 W E mx m3E UIV.4m um0 IbWUOOU cm w cw ~uua~bn 3mmo4c o OXIJ > ob 3.x 14.q~ m w 3 n.4 mu 4 c 0 mvlE 0. MO CL C3 0.z 0 4.4 .4 .4 W >WaE -OW W $+h 0.4 crl ow E~IW-I x . a)nncc o JJ W 3- m ma4 m cmmmo4 4CI4 0 mua~u E b c m~s:r m c.-ran.+ b.44 O)C>O WO mu bW 0 JE-4OV-I bmao JZa.4cc wmu ooO~rlWmm auor U uom~~nb wwbv3 u WZWO OCJU mu3G 0 OP bmbmSwwCv, mOOCmEW dI0M YI.43bhVIO v) b E 34.rl 0 -c Mduur~u a b.4W W W 0 N m m a.4 a, L co o o u.rl c m m ~i u P) war^ os xw JZ m 0 w b-c'+I: m I: m ma4 W E.4 t- QUV WVIVF-4 +JZm VI 0 bd0 ucma 2 .~mc~om; u uu maw cm u 4 m u-1 m uu 3 UZ mb $03 :u : e ZW Ul :i? E.52eO m b 3uv-4E4mEo !-,~Ubu;g; +d M*ui In (b e .I &E " .v z2 5- 'C 8 ijg .g 5 d 5e "D a2 2: "U Z$ g2 i!: g .y .2 && "S Eo 02 5 'CE %oE scs 2.2 ' E'G aJ OE .5 -u $! z g4 a9 aJ 0 aJ6 54% Ewe 222 3* E AI 223 E: 2 :F? - 'Z > ,zzs a "3 e.- - $i.z 32 E;c. 3 E L2.% j's UJ -a 0 0 5%: ; gJ E.: 2 .s 2 5 $&6GZ e g.2 E! $;; $22 3.3 5: 25go.5Sm mz.2 c: m mz Lw p szs 2 2S 3 UJGkZG& LE -D $Tie S aJ w E92 aJ 22.2.g $85 2D.W Q-k u x ._ maE: $2 UT! ZaJ.2 aJ . 5% k "= 5 Lz aJs &E 5 23 g ;;j "3.5 01 s 0; .e c:.$h- aJ2.2 aJ :; 00, 3 5 &% E.2 gz a&: 2 b.6 9.g 2 "OE2wh/ZE& =I t;.sBri! -22 $ $j <c' z 3 .: s 2 -- " 6 - m 2 5-5 a>- &z "-; E8 o.aBB.55 o k'EE:aJ .s a. 3 ua52 u kn 1.3 u h'G3gc:E:C m30 OaJ Tl e.7 4 5 aJ & UJ-z 3" S~U~UJS 2 52 g"*+ w m k.? k o ;-e - ma ah - az .o 5 v xao $ w -e '5 Z"&rn aJ g u E.5 8 u && a5 .- $0 d 55 2" .2 LE Pa .x w n .- $a aJ% 2a 5= -q I &g x $2 2& m '3 5D .Y 2 GUJ 'Z 3 02 8-, aaJ uw 'e, US x v) il m-e 02 ra =c GM u3 m '3 .I gg 6s haJ ZE ag m " Y- al .2 c b2! m < CL < - 2 + m s m- N 0 3 c, e 0 .- .- vr II) E V E .Ej Ly) z 5 a) \oo 26 G$ ,n 2s c4. m" $m c1 = 3s E, vr "9 d&mz) * .P 2.a w 3 z 5 =2 .s x z:.z.t;u; .- n 6 rucLu 25 L - =>o 2 g .!&: 2 Gh?.GS$ ZrU$4" G -;a F! nmwU3-6 E - .. 2 M 0%,3" @C: Err; .e E u;g 3 52,: 5.SG $2 3 c.*;v t.sB5.2 p* :$ 2 "5s 2z.g 9 2 Q) Q) 0.0 :: a * E ='5 ' -a xgp2 ."B es 03 ;ri, +;<g vr Ug 5 a;; $gT;zz 0 Em us g, &2 0.- 2 5,e 5 rn ebcz 2: $2.9, 3 22.2 gs e "w.j 2,: .$ 2.g: 8 1 2.2 ;&s? 0 EX24 c 3 % " 3.2 3 s~n 2 e"- 0 e c .2 .- .- ... - c.G sa- EEa \o ne $z% E$ e QD mN "E.< G Q .I 0" 0 x0 hG 4 :$;.i i 0 e a.U E gc Y 'i: -z 3, -v '& 2; s& .- &2 83 Q) .z 52 9 'Ell "l 2s .y EI .'" .s! X0 nJc sal me P CU g ,z z .i g; 5s 2% a)$ ZE $5 .- QD %!8 $3 33 e; #no .I 5; 23 e 3% 25 : ut> 2* Q c.fl -5 &,:M $2 g;,z;.z zz c ;:-~pg -emusz I ".%: pgs g.- %37 e 0 *z c&.!&". ${ .c '3 'I: 3 PTC- ::; pb'" E"- 2 6 0 2 *dgg, m * e 9 X g.2.S E Q) Q) u.; B E 2 g a28 2 QZ .t: L.. 3.2 Q c 5 '2 E ~PJ a gzi @ggz.2.z 5; zg B n k.5 g ,; .; : -5avrL.-. b 2vc -.s~ 8- =a s2 E.z .- 9.3 8 m ~.&p€g~,o-"~"o .$s Qg gg ?4&" $0 u ME - OL.. Y 0 h?$.B.$ i:!;! 7Jx$Ouu :y.p 2 g,$qwz =EE-<gzo Q) u as$% vr 2 ip.g 22.2 e gz vrc e aez %.%ma ; 5 23 -OF:$ g 5 Zsa %os~3&%.~#n..Q)Q weD- e - 0 e e,k3,2w L.. !i&S,;pg g Ed.S aw u ... 5.- zs z 2 g.g< "S.2 g e .goy2 $ g &?"o& $2 Y gw2! ow -e e ot;Q;2g .a .- +j $.s$%~a u a p. a,- .- --ea SQ)&~$EO~~QU 2.2 y "'C o u "'5 2 i.2 z H _.e '6' VUOU ,5.wZ E I?.s 3 !%a i$.zi3 0 G.G 3 3 ab2 e ;;.g ij $3 !& LIy.z.gq 8 $23.3 o o Q E.2 g.2 $8 $&H &EQ) zi g.5gji.Q i szz y E ? i .; Z 2,.g 94 %. g z! o u E .9 unauo 0 ,:OS -7"- e 0 GL hue m .u 2 0 .z +w 'B T gq EU SZG L, v+ 5.Q bu M pl E55 2"Y.g CP" 5-z 0 aJ aJ & F.2 z ZSkSE u " 4 ,z 3 - &&z E! c2-u 3 VI m- .* a.. L $z.zg !$ -mum:: t;SS$E s-c m m r 5 o-u M.2 a 2 2 . .- e. "am.- 5-z $2 2 a 2" r-2 E<: 85- aJm m30& ?j E zv 2 x.c g.m M z m aJ ,.m.9 .- i: 3.5 23 5 4 p e. c2 w.2 aJ E g E E "%%.8 2 ".? , .G .- %OEaJ2 ghQ-Ze. 5 rz mz & s!mEeo a c.2u -2 g : y'c E: g e2 g; TlUaJaJ 0 E 03 E h" r: v) TI y *s 0 d"0r: c 4" v mu plv Cil $2i2% g e. 2 Q Id e. s.5 vi g3g 0.:: 5 er-a m 0 r 0 3 u C izk.; -u L. m5 ggstj" .$ E.E g 3 z 2% <'2ia'*S EO.9 e.15 2 Z@ rr= .;2 aJ- -s 2 .:: + >2!2 E 2 5ZGo3-mao .;$3gZr?-u% aaJS a .A " aaJm32 r.5 3 10 t;'S 0 m 3 0 '"G; < 3 2 &:VI IJ 3 8 : 2.2 $ gZ.5 GgGE a g'$ g.g.2 dJ . 5 'G; , Gz s 2.5" gjm3L2,z P a.5 a~a2.~&l .z-;q E; p 5 "2?G.c=ao".:: %an+ 3 3 aJ 3 0 a" ohh g$+i'$s "2 5 &zS" 2 e.z .5r?:zMuQcm g '3 .- rl z .; 3 5 .g 33 -< f $%.? 4s 6 2% q E 2 z4-c &g 3 B o@ w-bz 2 m 5 ","P,E'G- u o3&baJ&0?i !22+.55$ aJ gz 2mm O@ygeE 3; 5- 8.2 .Mg:$gg% .Y - aaJc?s:gg y Sm535Pwvm aGS6 GL rO %-= 6aJ ow s 3.- AM*m C .- 2 $ .i GC f .: c65 - x, 35 :.El z ZkZ 0 z 3l m a C $2 tg; - If m22 5 x .- Jz , .- .= b n.Q TJ L4xu c c -c2 : .%E-;$; E , 2 $;;z+.gZ 2 2.2 ma & z $E ZiU: =.=+a '0 a0 0 c 0 mo 9 :d .- c 0 g.* 2 -5 Murob2:s$ 3 2 .g E 2.2 7 2.22 ,g as uug5 -22 c --. +jO8 = 'j; Fs ;;$ $:'; - 0 x,cL 53: .GUaS$r a"3LcEE.ro 1ocog pg.zG0%2 22:$2 .cs Q cm g$& .m * a-2 0 3 5 > 0 m mu , m.2 p:.z u mJ= y m-s u 3-g = *a z s Sv.- ."-s 2&,9 0 L. 6" c gps aI L $2 2 =G.Zs& 2 0 u 5j.g- Y QD E 0 a:i g?i-..s I ObVI a, 325.2 n 0-- e'; VI- 0. - u ;3 ED L. 2 mMhQ 9 223 2-2 4 0 - u"2..i!e 0 s rcr 'd8Mo-Zou f& rssZe5 e ss u ro- 323- 2 qsg=93 oom, 4l 'i; 3 g bOQ,Z =-3 Gfi a 0 m- u *b m 3 .- .z d .g 'S ~ZZcm~$- $$;$Lg VI ,22a)Z&U3" &za a.C M3 CYC * W 5 g-,a.?Jg ,a.C.aEgE;-Pg, m "2 0 2 z 'dz m2z%*L <.53z22:, > c e- 8." e 0 2 * .a 22 So,? M t;.ggq 2 0.2--'= % %r-g.=: &B 5% @g.gy z g3 ms- 23 $.-a ,$ i :; ,+sa "2 2 zgq zEs Q M.Ch,tgg&a 2, Q 8 .E.- 5.8 E",= 0 u c c 5% 6 c .- : :z m 0 c 2 5x x3.z tm? g Ff. 0 E wo- W"B.2 , v) *' d'ak;o73,,, 0 c: .- z au 2 z 2 2 Q$ vi PC,.- 9) 2.E 0, 4g+u * Q C 2 I. EdG Q.2 $? 2 C%+$3~ Y ;I 5 gz 0 2 Id & -2 ys4 2- 7'3-0 % 'd m 3 2.24 $g; Pr=W $3 2- VI" 222 n29qwcm"- -... c m c 2.2% 2 3 225 0. -322- ges -3 m 04- Q c s-22 Q n 95 g 252 g.32 z apJJ i2.a 2 63 3 0 ua,.0't.2 9 3 2 E q$ $2 % e.$gp $; g ,E u 5 & .- D $E.z o 3 '5 3 a ~- - g~.$,'Tp.~ 1 aUs m a g F1mum 1 .- u.2 a.2 s5 z c- o "be: &a23 -m &a 3.z , "ru= - aE 9s 28.zEz on 22 9 $Q~--~$~a E 20, 0 $zsZ M2.e - a 0 s - O"39 m rn~4 a5 E ro m E o 4 6% I " .& 5 .c 2 - 3.22, g zgzz mu.??, VI c v) ,a25 B 593g g.2 ,& 5 2 zw u'GW 2 -3.z a . %zE 0'~ &.E: 3 e" w 2 -5 u -w+2 a 5 .F Q*%2vu ;"3baa @ i;:g ;;is z..= G 0 $2; 2 ;g ..5 5 g ~$:Oz.CS *gL iP= "2 'B c 8 02 ga3o 352 9 c - a2 3 '13 > uy. .u uta g3 z v,,Cu.gB Xu-09 c1 $2 2q3 B c& 2 3 3.2 .$? y I gsgsg c .:.Os," s 3E.S $6 a 5, 94 ezs 0 LI 0 Q z.z8% E sG:.G* :: 25.a 2, k34 .- ,OS.&, kc*, , 5" CL -Q 1 '5 u E .s z.2 ES QO u nu .D E 3 8 cz 0 au c.E: 3nz oucm %$:E 2: - ;.g gg:; .dL 3 E5 L 4m-=:: 2 g$ g Joco lLI..=E& &Y 7 Yji !Z a 5 22 :* 23% 5 0 3%3 -58% g c VI &I= 6.- u 2 p25: 333 g gagr -g2. 5.g .a 2 ;25g I X35 a Gs m u b)L j3@ "W c I -r -101 e 0 C s GC E@ u ’a $1 x- 33,- ; :I 2 $l ZGZ a 2g 23 Ti 0) ?u z5.a 2 DSZ E 0-0 ”2 ULu 1D 1c OLOU 2 2? g o“5, UBg: mor0 c.z E 2 L. s 25 p 9 .F.C 52:: mL.3 ‘5 32 - . 08 g .g? x p 29.5 or me ac Lu2 ;:g[ :so0 L. 0 OU k 2 52Q lee22 2 0 m C $52 .$ ’S64G 2.2 $% $& Z:S,<$ .“ E 0.5 i .GJ 0) =:A? 2 . .H Y M- 2 3s rm acb 2 z qzgs G& 2 “aoWa iz Q> Cl I. “I E: LZ e 00- .“I=.= OL. L. s A$ ‘2 .: t; 5 .-. p 8 I %Is .z 8 -0JEJq k33”’l” 0 0 9 4a-A pzyg mc,o .% a- -a -2 E3 L. $s%% .e‘z:-d3 >$ sy E 3z a-dgzb 0 wzcsg ,.-a: l2z&jc,zm 2‘2.“ 0 .o.o Q U M’c Z MMW 3.2 Mm.!vuv.-, 3 Sc ‘81 O 0 EiZ$9&$Q .. :: 4 Ei 2 8 e 0 9 %A>Z gp .e L“+.;= o’= -3 522 3 $$ &.$ oa2’.9gcs2 gr! g ”& w20m&m;?m 2 P 3 A,= - &..- a 5 B;-pPJ u a,: 2 a 3 Ei s ‘B g,*m>m+w 2 b.7 39 =: 2 ;;a a2u-d5 .f? sc:3’;8$s acO~.mu L. 3 &= E “2 3 2 -& 2.52z - m L%Z.SZ VI I.. Z$gs Q2-2 2 g 2 :2 m* 2 2 c yzgZ0 QE e- m m Y xx$ 3= g * gq k.2 d “wat? um3 iL QJ-Ep!, p1 E$.%..I E w.2 g a -.Sz%.g; alrz m ”I am 2~2 82 a “;p$ m5O &.- - VI w ab u 3-d Exc92 . 0 5 9 56 u-2 : &u2 ;sg g.c Ej3 z5 ,I ago 25 0 LJG wL? - 0 2 cE$ 5 a2 Fm93 &Q.smL.a B ooG-o,EVI ,Jo$&z; c>Q-wum AI 0 4.5 5 .5 E .y .5 mal gga 8 2 -g= .zEV13 ‘3 .a g & u 5 .- .d .[: < % u ME E2 .!zgs+ geV14 - m 5 $ g.2 2 .$ 3 z 825 F2 zg ’Z g.2 5 I rX8m “Zal m” .a * .e .; ;ij al& ‘ -35 0 3 m c s‘o Z‘“ 3 I.. :2& ‘Po csbo:! G‘mE 3 % s- 22.2 g J G’G; E w a g% 5 22 c g .g ‘8 -2 age2 ’Em0 2.5sq ;s*z E22Z g $$$ Q.3 &. 9) e 3 E M$ k baJ w ‘1 ltcr g2 Lz s $4 . b ;$ g.2 - k2 5 mqm ,:u s & 2= g & a ‘u yi E.- EO 2 u ;; -&. .- y: xc aJ ?= t; xc sal, bag cs 5 32 a& Jr: u= m aJ al- 9” a o=m VIom ~u E %$ L;;; ‘7 cov gz: 5 &; : .g ;i o L 5 sf; o STi - 0 E. -s a1 - u ci SO€ 2.5 & 4 al 5 M 0 a .- d ?! V 0 I x 3 “E .M k =: mc 4d ‘C se B .E ij t .- - oa -E cc mi .g .? 2: 32 p 8 .E .d 5: u! E .E &s M: 5 E 6 .- .x w& E: QJT Y I- k I I. v a;, 543g; 2:s- q$& 0 &is 279 %x L x 0 d - el d d m ‘0 (1 0 5 5 C 0- -40 QO *cy im is 3 0nE’ % nxcs.4 a 0-1 au do a 0 e 2 5Z!$O u a ad a C‘O aa’ o anwn urn II) Crakoh Sr4dO-4 4s am a UUUrlY a CCd 0 Q U i 0 U C I P 4 W 4 0 0 z U U & 0 a 6 5 3 rn d a t V d) s 6 U U 0 Clu WU 0 P .4& 04 tU om +)a &O ao sc U-4 bO 3 -44 C-+ ca 21 am -4 s: >a *U 6S & ai g!? <a Ed 6Y ua 0 W -46 0 UP alr”G’ 22 !?a% 20ad 0 h ecoa cuaau -4 Ed a 0 6 &U u. ; $22 2 21 5kta.I: zz 0 6-43 h& om u a Ir-x ¶ & 0a-I aao c 0-44 a4 kc c amr 0 0 &U4S a 6-4UU & E 3.4 a3 01: 0 a EO 0‘8 aa3au 1 2 z{ 8.3; -41:amuo 0auaac o sa8 had rlw ana a 0.8 .am oaho e vd-4 0 a no4cm ou>aar a UBCU 1 Sro‘c)4w 4V &QWV 43aace ode44 -+mmoc u* Eo4 & OU&O C!!?!,?! 0 U E 0 .U ha 0 U, a e cu e-4~ m Ira6 OOUO ooacnccaa $mfi t 29 a: ehu ga+ur( an ao an I~IOOUI~U~~:~ ohaaaaa maoa~~o~ U u E bC CUU ow a4 & SJd2?4JIUS E0000-4>E 44 3&DU-44 a X0 zzr:E%.,s: aabIr no?; +&Z$$Zg -4~ a aa 0000 -a:asQda.rr 323:2<:b#.!l 82?’C0,.5SU OXU4& UUP oaa 2!a6S4aGn‘s B 81tES.!l 5OU. 8SdS u u>..oom ua-4xaua OecO-4&c3C a2:k$2asz aao O-IO-I~. tcc“aoaEg%: a aahd Qb onoWiu5 cucdao k8 PP 4.43 a aao~&o daa*koewrifi ~LUO-ICL~~ 4-1 E 0 ow o &U *sa ShO r.vrE~:3~00 r“ooln- 3 SO UP a 3 m* 0. s: a:;; 0% U-4-l. QEA &E 00-4 -4am-4 -4ruauoax u 4.0 0 au 0-4 c ma a LI rnZze4 m &U 84 Ir-i C 96- QSai 40 :.20a -2: 8SCs9J::: 0 dame ueam .u ass$ u 5 c 0 hZ-4 ¶.4UOd&IrW -taa~ac c-1-4~ a e a r( adocp n a a-4++d c cl~am a 4 CZ-4 > sa4 ao II) ad OY as OUC .-( a & caw a a ne04 d-4 4 ou-4-4 0 > 0 40ua .a g,aooc OS 43 ZU 1213 24 a 322% e 00 S dWS8-t PSSC04a8 CYO.4 OC ZLB ua ac.s *is; E s I @3’: S2SBt3XB a4o 0 886% 8 .a u ’* !as 1 E :4 CU 0 !a4 u ~. . -LO%. :k7U MU ooaoo P4UU or( am OW ma0 c k bo ae duoaea a “160 ,G’5mP UdU-4 1.C -40 ~eaoca aGao ,461~ t !E 0 PG u b~ a *-(“I s 0 01 OUU laceel4 18-4 UQ a03 :>S m &U 1:u 0.4 ti: z3: 4JU4 ac I: z 8‘0 ljaz 22 4 eoum ws a-4 ou earl -clan cc ca JJ~ E Y a ua a 0 a g 04 &-iU -4 0 8 aocc $Sag;: I: 143 g ;{if ;s c4 *uou -v- cy e a u F 0 2 2% m4 PP m m 51P mcm E. ir +a B m 0 -4 m m >4J m %Dm m BrlO h u c as s m &-4 e - YPC 4 30m uo s-4 i8Q Q 0 al u culucu m 0 0 0% 80 4a -4 rea mcuuir ammo BuBcm 4 cs mc m 0 Bu -4 S-4d-W 5184 m m h.n a0 u vm eh co 5 (De B 0 vc, (D 0 cL( dC 4 10 a)* 0 D PU c,.c,c4 @Q81Qal amu04> hU4C ir d) -4 ti Ll4c H Lluyl am cmooho N& ctmhmm mu on o a a a+ a a 4 su4: m ec, a k @P)U OLI hirf",< om B 0-4 al B u Pa 5u mc co & 00 u em UU 44 mu m mm -4s urn 5, ZC 40 aa mm Fm ea &: ma 0- 4c uo m-4 . mum qi ij ;;; 4> mc 5-4 0 emu cs Ob 14 1 514 51 ou 0 a WP4J Ham 1 %e G3qrl 4 mir F i2 b & u s Oir 4 uo CO QU a& 04 mu > Pm ecc hC-4 cm 44 C&ir am -4n n4 c u a& P ;s *2 g OP)@ V4Ul rt 51-4 c coir ax 7 0-4 &B mm ha+ us c -hOC SSZ8 4 e-umg,: @ .9 $6 $ E $ ;i 2 $E 9.22 3 .zm 3 z 5 1 8 0" u - vr.? 0) 3-u.Z maJhaJaJ3 .45 G3-i t; VIcnrn*L.baJ 2 23 52 0.3 23L.L z2 k I)%z$TJe 0 =% 3 he7 .- ?$ bb, ;jc aJ 6 UG 2 0, .s :E L.s % a0 g$ 3 'i p ac U'i s m2 v) $82 3 :$$ ,xt;a 232 Z'G; 3 & 2.5% ,2 m :% u2.2 5:: ?A& 2 5g.x .$53?g i 5 .+ 2 9 E.., .2g3e0ZG vr 3b2,:ap- % E2 e{% 2 ggz 8x22 g $25 gz" .- ea.5 gz-2 2 .9 _. .E -Ei - 5; 6 zj 22 6'i;tr.X r: a0 p$p m% 8 9 a.9 .g: aJ A m.5 22 5 2." 0 aJ u 2 + s 0 aa m.- I 3 a" EMGO -25 .- .Y e S E m6 K 0 I vr-.G; m-c g2 z cz rjl M a aJ -0 .- d 2 VI U I .g a L. 2 VI e -3 (d % Y II) - G 5 A e, Q 2 u, 0 e .- I m m - 2 L. aJ VI 2 $ .$ 52 .- 0 3-r: .* 53 "5 2s k% crjl L. 2 .g vr W a -E G u, h I) aJ Ed 2 a g% 2s 25 FZ 2; 2: 3 a'.m aJ8 5g. 22 3E Ek .., 3 a3 "8 -cE! 2g Q .s aJl-4 -E .4 E u,aJ aJ- VI0 E% .c Y aJ .- +a +I e 2z2zsp 1 E c E F.5 E E 2.s L. c l-40032~ 246 gz L.-u :: z3gwaJ2 .4! m 2 .c: -c - 5 zn st-? g.$2 0 . e, I e.2-c z !- eu, 2 5aJ a yaJ22 E2 .ij z 0 .G; M 3 1 ow.2 2 Ezz.;.E % 00 Ez.5 25 U35T" spcgc3 7 VI.E! -5s 2 s 4.F.. .5 s 3$a, .e Fk.2-W gz ; 2 .c: -g g% g 2:g Pa e aJ ,s 2-2 '6 VI - QJ W"\D E g.; .m -u m.g.ss u w& E c 8 . z k9 2 b2 2 -- e&:Z pg051==0 OJ aE2, ori: -5% 2UO 2.3 aJ E! vrueri: 2i-O zez:, .aJm m aJ w.i;$- e $%$< eg.2 e- t; 0 c.z ??a 0 rn*2% - - 0) 0 0)-. -U~~CD .- 0 aJ-1 a 3 -=Ern 3aF ml-42 am & I: VI mc, az .e U"al-4 Es ma vjl 65s.- aJaJZ2 Ivr $5 2 gz .M.9 n - I SZ.5 2% h& 2 85% 2 e 52< Z-U - % 0 2 3 29.2 cs g.2: 2S-c c,: G"*ZL -; $3 %2 'ij 7 3 0.2 .S$E M 2 5 me.2 QJ E .g w 2, O I 0'2 aJ% 2 I vr:.ge; '$$32" L 2 o.%d u3B zL-h tagzga 'C y 2 .; aJ ?:$$$ ceg2: 8 E=;= J S;3:% -g .$ 2 3 3 "9 3; Zo$s!$ Y $3 haw 3 aJ2c"e .d 0.2 3-c Z K 22 % 33 *-c We ec t; ar - m 0 ;;jr c $95 y p u VI vr.2 d OI OI rl w N 0) 7 b W ad WB tl g.22 f i . 4g Ea 5 m 0 zg:2 B B 6 %a m 40 5 rri E.:* B i3 W 2 ;; wa g4 IJI E mIJIlcIJl 2 E 8 sl2 8 3za IJlE vu a2 m3 x.;; 2 gyq 5 0 B W 3 "32 E2 E .E m a w; SEE Y O 92 O:: E3a 90 r: 8 E ax 8 WwBm 2 l2 i.2 $E WhB5 2 gm B; 32 ZOk rags el!$ mrl m h* 2!4 Eq'z E W $g 3; ow4 5 m mo d 4B 0 XHH om ha a mlme g E 2. E5 E wwz a: E %Blc aE a n 2:: ZEi8 R olacn cm m H~SB UC, Bk Hrl Ka $E ZH H &Iv 3 2$w5 1 a ii p. IT& zs :go E": Bg ;a*; k whu B w8ng C >C, Bmqm A 2 z q. 3s E% :El 6x23 $j 3 Bn g; E; gag EE 2zi3$ -4 82 !?E E2h 2s; 02E2 @$E 0 WW$ B g E! -A m SH - !k mo Yt! m BE,,.4 2 :I Zd om EMH Zil3 l3qc 2 p ';$ 82' E 2 oww2 -== UreE xE Emaxc B E:: 8" ;z 82 gag:: zn3 2 Ez;s z0 c2 XB ii ;JtP 85 :: 8 w$aBT: uzpPx 2 Jp gg CIS 4i sy2 E86 q26: mF sg oa & gh?$ E 28 2: IW I B lX3h k2E 2 52 40 om 8% A N - LA A E5Z- 24 x EO ow n w h04 C,o E h lc4 4JV c3 dw7u 5.. moclc a4 O2 a3cu a nga W HO!X x Br: E a BE m h. m hH OK&, 5 53 $3 ma nz ago; r5.d W3z mz 5 -2s "1 p3 *m B m; nu w *$$; 1 3 0 Br mz ~wmo zoom Brl U&B$ gq gig$$ 4 hm vo cx u X oa7am KC, mz rn om V~OOE n gn Z~PLIQI n ZG 25 22 2 wama5 4 A gz a0 dlc .. w 7 .. g alv OEEi:; 6l m * m .-I B v- e 0 \dl a: B B 2 2 u €I i B w B q !r3 h 42 P% BE .p i; B Oa P 4 tz 8 c1 B -4 E P)&W E E c tnm ew Ftn .4 e4J!J-4.4 mmh am3 $eao*2=l $5eaaoP) PZU. oP)-:&+ me S$gc)-w7 0 E20 P)OI4uuw e tno LIS me0 xdu am *e uurl m7 arz c$a m > 4Jo eo Eog &"';;I u ea Gg22 3$ z20 rn 03; 4 H(dE u arc.z 7 mo*r(z 3 U';'-4 ea #':Q e h: .:z &': rl :.,a 01 m-4 ac .Q*d ar Eararm .Eg a$p8g,g 44 e u o'4 m>eod c 1.I oc mu 3 * azt2 02 w m,* 0 cA :$gek=s.. m44.5 0-40: f?::tn3 .52 P)uoLloom!2 c ob ga$j m !&rlo,w nara ma 0.C 3 0-4 34 em-uc an m-4 OB m I maX az-4 cmeo1.Izmo B e c 3 a-m u aJGMM E a .: .$ gs.3 z pE2 'C Fg: - 2 .& 2 e, Q? 8 "2.: e, B 2.5 6 $$ ++ E 9 ae -2 0 9 4:C-u aJ 5 52 'Z A z .y $%=- .- 3 0. z ;."E - 2.a % .- 3 c Ma 2 2 .$3 I& 0 2 -c&b" aJ g.2; k 5 G.2 5 E:.. E L?.u E! p& gs"a ezsa mZaJo E c: 2.: 2.- In k E.5-0 $ M.2 2 %Yb gzcz .as .2 5 8.%.Zri! $ g'z $5 E 5% 5 Ei3 ouc bo1 e, OI e 4J 4 a 7 U .4 F d 4J h C 0 c i. g! & wa tn ee LIE aa " 4Jo o mu m 1.Id nd m 4 0-4 mu 1.ILlar h u4rl.4 c 4coP)cm me m+ ma rl 0:: gg tnn5zEgn uwmn3m )IAA)IA 4J *wme m mmdc m- mmc, , OOrIO czgFn UCD tnh f la.% :2 g; 2 e e4c e s$!:&. ,,ap: -+u ms: tn-:X2g. .: m4J m4J 51 ~tnmwgc; 252yUlh e $ g-4 3.5 2 tn'Z t: g m %g g 22% Emcop" $5 P)";1$ ms 8.4 0 > y1e c cxg 0 s.7:;w gi,ij Q; $pd g: z3mmm.4 oOJa$ m 9.': a" o By: Qmof*a: bn "om ;c:9c-:g mo 0 00 c.: 1.Is gQ P) CN ea.4 EoOa wet3m7ar cP)>wom P)we oc B LO-4 am 2 H rn b B E 2 1 €I 8 B ii G E E rn 4V P) OlT! P) E a KC, E BE 0 m u40 u m4mnaa m om 4~ m m I mu.4 u.4 e %E$? ocua m-z 5 5 u.4 2.5pg;m: ZepPYg e$ *gZ e: $$%4 Zalk oc 3.2 a& c4J cw+i Ea -2 m4J -ces$n -2 4 22 >I ;s sk5p, x"' 4J Eu 0 gc tn, m~mg~so w $"a 1.I 8" Q$$U 3;; - 0*hc8 ar go oz3 a, Io E u4Jc3g g: ~ow$m,Pmg :a"m=P)gg mf eE2:p -2 01 arw gL75 $z;$:octn 2:eEm.: 19 1.1$g5emxo ocm'mcrlQC amEzu$c* 5.24 m uo x m tn2Z +u ma 0) 3-4 u P) h trim h e4ua c i: E a 1 c ma4 P) 0 Z!25zm;$= h o4J sue a0 moemoo1.Iw Ea acam e 3 e4 uomm a4 m m aw a 0 PO m om 0 01.I 5%: a. far*F$ eoF+> m 82.m 0 g",S & z$!!:g a, e4 tng m 8 m du ad 0 cehcu VlSd 2.fgw Gg do 5g;:cP) 22" 4': m <.fUP,O P) U" >e: :$2$ f&@m $ mz 0-4 ccz sr :g3-4c m;1$ :i! 2s b% E 7 ocz 2 am 4 "23; 4 0 70 m am047 cc u e$ $2 dB3 mcouar a -4 >7EU.c .440 ao 5 U 0 C.4 H -4 -4 c 3 c c c oe -.~mmo 5 ,f.:.Z &.: v) m 4J+z .4 m1.Ic%u: 0 0 E9 4: tns .5 $3 5.2 p) p:s m 0 cpJ o:mg8Z 2s.. "4 ,o P)Xh B;a 2852 &I B e""": c. m a 8,4J p f zu 9 ar-4 'u>ome7 0 P); >W 2 t &$ c:pLmh oc c 8-2 .;urn agg 1.IQQ3m aob$g. .; 0 9w;; >& *a5 ametnmh .44~ m X, m tnm a ma$ 7 m .4 m > 4 ;$ m2e u p) 0-n r(ma 4 ar aEmO1.1c +m%ca,e a 34 m4 2 04 ena g2:$22 m am e e-4 04 1.I c ocoao -..In m>wrl 44.4 P) 0 6 (OQ 9 e E i3 g 8 8 P v 5 E B B 8 4J 4 8 m c 4J m m j & 4 -4 rc 3 E B €4 i 3 cn 0 X €4 2 8 E E 9 P c -4 .I Nm 4 ln em mu E: 0th I s4J4J>m ummm 08 4 cc4J~m $!!+E! !!2 0gY;OUJ $ gf.4 ln p$ a4J 0: gg $5 8 a: ::E gS-&g"sq hm,mghmg xi2 a3 e%$ m 8 ,Z$@ $.d a& orf & ?+$as"" a, LC ma k? 1s m mZ-+Zu p&%mg.u 0 mh4 ci a'? 0-4 0) Q &&WC* sdma 04Ja 4Jmmps; a* clad eHA.4 m s+ JJ&zaulg$.4 *am3 w+Ja ammn 3 3 $; $2 -$ 'Z " mu :+n 8 ZB &" ,emcoo -3 is ;s i$J N doam jggsg32< DI f44Jsn 9 m m mmcmhw e .-I gumcnvx I Idl3teOl mmoam4J hdz a m U4J GB & mmm 4~h a542 0 E nu a m c n'uu ma cnmc P)FrnOll+ 32 u -4 I >"5X',$ $2 %Om m:4 h Ql d azva 2 %cZF$$ 8:Og,t arc OdU 9":&e aR<coa .m*€4'u;. m mz $ZEj&nu+ u 0*.4m8 c P-4 E2I7:% g;o&43c 0 "Ji.2 %€4 gs 0 +, : *g "3q 2- 13: d! -4 m4J c4J UOoW E+ FI.4 4J 'tl ud au ??d? 35: gJ $jz s $E?Z$l55 c am'u N 2!PEd5P2 o +)dum "IC, uswu 4J'uhE oommc&o&o m-l Ll &I m m F? LI4Jao anu -40 amno P El c II] &4J 7-4 p) c rf GIrc m 22 2 :: 2rf%n-2 8 ,ig4jzm5 .~p4=~"f: :vYIm33g3g $525 m m$Z 8 E&da.:gom m p a;;; a.2- : 2 i "$gp2;m& ga, hO4J .?iP q as .$Z p"m'1'0" 3 9";p q; 5 hd E Qd4' m .,, .! $2:: s . mcf4mg om oeYI*€4'P)a E$ gg *Flzh@N $$$.;;2 a€4 %."a6 O$N g 4J-42 e 0 0 w m m ngu WP)H(c moonr(uemw ua marl m m mu0 Hm4Jm3m4Jwoe c cc c-44~ x a 8 m~O$Bfur~Qp,~ 18: g a 522fiU ok%d~mp3 r-l 0 I In E 0 P 2 m x 'u YI s I x .-I nu- E c m a o QI *nUUdUk 7mB u II] 'u m m-4 hYI 2 PO ac-4rf m r( 7 m 0 0.c mf 3*rn$.4 4 he >% m 0.4 E+, 5; m$ mc'u c .,+ma UH.52 p+oz h 4.52 $2 $ :,a 44J .e% O w.;:4J &I 0 "Z'u ob rf p) 0 "05: :sea $2 mmJ5%:8; $no €4$m v0:zo m ES; 4J mw4J$,aez Sua E & os+, HS @3Gu 5 mh-c gooma 8 mB xizg $"4" 8g.5Z%a.,8= XPcc rn.~Q;,*;; m aE 0-4 SZ-,hc a8 m 0 !%?!,?Lm*$, cas a.: "4up 2%8p235.5 4J hdrc P pip f2Uizi; $252 8 !5< gt 2;: !qg !ip3 CqmgEaa.a shqjaDmm& P @4J OrlE 423 a-4 h H.4V m 0 m B a0 .4 4J m a 0 V 8 .rl N OE & -4 la 07 m4 mu P)tF a .5 2.2 "0 hII] nu a -4 E3 ;.;;t ..-I 'u-4 4J O-5 sa $5 L3 .5 $1 $2 am dm &u -4 0 4Jo i: 3 -. a- 2-l 4: e,: :m zc old & am &E: ma WV m+, d Em p 2,u &E 0. w 'B -4 0 0 $2 zr 5s mo E= mr I al 2% &a -m h- G-2 g-2 2% wu 9% 'Z $8 >u 32 za -c ZP 3 .u, * v), gj +j 3 $3 02 58 $ .f x b2 an zc ez 2.; $ 2 3b - .ez f! 9 u.-a 4 m r( m ID cu a 7 b e 4 a 4 m a W u a C c 4-J .rl o\ w VI 00 lnw .rl d LI is u 2 {z s ;a E'; f m D3 .&I: z2 E; @ m m.rl me eo .,-I c .rl ..-I .-I r mm hc rn ~4 nu 3% U& Oh tpp 'CIO 2.; 4U.l 00 &I s: r,Fu.3z E2 aqr0rl 4JhOt-9 aH hW n wbu -- ornutom a aruwu a Dm c .* 4 e u)o 2: aW :3; ooa a %$ $X 2 SP C 4JB Io :: mu lno lJY .a Zz.5 .: gz ofg 52 2." m 5-c 5 'CId "a h, u hw4J sy g 8% .5 2hf 5 ;2 I40 04J4J sh ; lum 2 aU2 h 55s 1 r4a 2 E$$ XWh 0 EO0 SEfZSg"2 3 y g,, 4J $3 kg2 E 4 $p" e hlnS$Z -4 4J .c H* PI 0; $2 3a,.OP"" VI mJ-+4J.:,g: ccp, -4Wh 2 is: ::a$ 0 :zg.22$0 e; $2 a4.4 :: .-I h.Q q p) 5:zgQs g ln"Sm:mop h.4 c ln p, ul*; a 3 0 4 g.4 m .rl :z;. mQ L hmh$o.$a, k G-d$:g a $!!2tl.,$!$ u 3 XW'k4.4 .LgG3p >: 4 &I -4 w EGZZ G4.25 vz.",4p,p~~ 8 kP:"%" a ,+ UrnBS a; -g!!ko38~oEma e rn4 4J a u OW* 0s: I ps1;9s a gg:: w :g 4J $ mur ow+, c,;=.2 s .doh emu a awn hd ma m WP E; w>wauluch aadu w4Ju S 22 z $2 gaz g5.i ln.4: ;d h2 m F SaP? s -$$ 5$23 $a22 a3 .rld 0 0 a 3 4 .rl UNO0 a.c WJ=C a, $2 ;$., W .4 - a EU.lZ a " U.l mmm h %-I E &I a3* 2hED 4Jhmz hC m$ t.2 E-+ mag 22 za 4Jzmc &I -2: 2 $q @ 00dW . 5%;: .5 $-w ln 4Jzgt ,& 8 %.a22 mh w .* 4J 4 rlc 4J I = a" h4 cuc 0 >" 3 h ..is 0" h 111 0 0 0-4 e5 Sa,$$ ;:0 3 a 'CIE35.4alnEz 2O4JEu5chg 4~ o m mi _E".': maam - q4Jz u) E E.4 ",aaaC @:4J as 35 ha ".;f c rn $%a $5 353".3,p sn2222 +g5.:z$jJp$ 29)f4J:k2m3i > 5n : m m E.2 pQ E$& a4 h52 2Zg;E2ul:-9 $$ .4gwsw raOe.E;vga A %:gg z p* ;.; zU.l m ,.j,r~~~~.d Q:&8 w WZ.5bln4J t& g"$4'"; 94 a 3m G$S $2 IJi w b : Ic!g$jcrnoa gia.,.E18H %:a I m m4-3 >cI 9) 5 OEO rl n #.A m .:ha cul C QQd rl4J3r gmCneamao+ *as oag5o 0 Db4 %.lJ 0 mu um; c h u a4 2" E *m4J5m Oh4J 0 hlrn. m acw c hm > am H mo m-r( ad 0 @E : kZZ$.IE 2 x3 - -zcno - 0 ua,- e 5s 52 0 0 Ea SQJSE aJZ2 g "a 1 9uaJaJ 2 yi 6.25 - v) a- - ,;; .- $2 E 2E .; M E3 yi .- -u3 0 0 "d"; c.2- - '53 cu 2 g.sz ai a&-= QJ a, z 2.2 5.e E4 c %go26 bn5grna 'G 3 .z' gg2 M QJEE 8 2n.u o 23 Z.Z.2 "rn maJ gzm% $ OOEQJM n.* 0-c g 2 me I ay 3 25 VI u c "d .- 1 a, Mc -5VEcm 6 E (L- .z .z QJ-U 0 c I3 a, QJa -5 :z$s '3% (JQ PI uomo OW2 %$ gzz ZCW" b.3 $i 8 8 4 G&E53 much 21 gs;;;$ -%c 0 dZLT.2 c aJ'Gr= c .;e 5 s L. mu " v) 3 g.5 .- &$Z &E F v .G; 2 i3 .z 'G; 4 3 2 >; z@Q m.5 3 -E g; ,s 'S M 2 .* .3%U52 E. 5 253 s 0 u 0- c am .5, g ; .z 0, 9 .m i '3 .5 0 m a; "5UE5W 9 3 m m 2.; "ME!QJ2E c'ax m 3 'i; QJ 5.3 2 -$gE E Sa ge.5 9 6-2 v) a,p-,m mli. g2.g g &8-,g.2. mocmv)& m.G 0) m.zg c "5 5.4 2 0, E.2.2 tl E, 21.5 yJ3g pqa,,+&l L"u '0- I rg.2;'"og uz 3 Cm .c,1=-c I aJ)xrn* - .- QJ c a- 2 a ;;.G;z%.s :"- E .," smm,Eg Y VI -n 3 3 z.3 = a, c:" kcggeu '- u M a,m14yisc b20baJv) -c>k C 0 -4 m m .4 E U 8 CF e 4 Llc -4 c mm PA uaa -8R VIP v)+ mc Zu?% oou - 4w mFl X UIWW ClLlOruN LlQ CUR hQ Q LZZUrnh nzucm o 0.4 7 m aao>a,x4 m Q mu LI 04 p U) CI-4 mx m v) 14 c m rnE3H: u mP 0 ;Zwz m2P cuu. 3 .:.zw5 : G; - eQmm uP Q.4 c h2.2 mFlm O.4m k22 zt$s !d :E-x *sa -8.5 a 0 : 02 .;;; - c,*&-:;g m$:z[:;'z gpPc) P\n 4 Ll E a0 a: w c m 24 m.2 g ?3>n~maP cTPm+N m QhPPmw$c eo $a, hupQw ..;a 0 ZiG .4 p) c)w3 :zg u1 c.4v.l m c u3mez &mgtem p mc,%* " m.2 hz$: $a$ 3 &-+* $ gJ m v1 da2 :3 a22 E a ".253>E m E U? kg$; .;4u i; c m 0 0% om m alddp) mom casu P) mWS2Q.d >a$ h%'c)$z; 3 3 3wn u.4 a mP.4 m m 0 v) m -+KEQZL~ m -maQum urn+* m ceua aa mm 00 uam3 mw m m ca 3 me mm 5cm2 Qv)%4JQ 0 e 2 d m.4 m $O$>OP) WC 2 "gt; 005 gij g;2 i a4 tJ3 04 3u h4h .;..%.&.E? .53umI",Ccl u ."i.Tp. 5 2mg Z'$ g $bg3Gc)h 13 %: gJ s4 E :$a0 wzk 8, g ?gv a: %a .mom Ll c -4.4czm h -$g" .!4 0 h 0s "2 O U! s:':azn;5 c$wmUCm3 a mz q2.Z 0-4 am h "2 a2 x Q b m sm Q PI .z.: 22 E P EP.4 O""2 m -.+ 2 rc @-dm c.4 oao= w!=mu rc m 0s e h.4 a, m4cc) am> aax PI 20 PPh-4dP 0 &E m 3c)umu .4t 1 0 0 awn uou> m IwuLlc)wom ea1 P umc oma Llmm BPI 0-q ual P wu "lm .-IC cm S'"'2 PLl a5; +- 0. u) e ga.3 g; .:am 3um 4: .4$% .z".= sag aylc a; "f 2 *z "0) EwgE 2;s c;n !d@hF 252 mc ;&s )I.! C ha E2 $dz'$ UliZ a0 30 * 07% E:; sa: %P z:w :ma 3vz 28"8 ,a0 gcrn OWCQ UP m ;g; Ll&.* *@$: 2"U 2-u cwmd em c s: 2;y 3Z5A 02 gas$ : Zh2 zmu IQz.: :$w mi25 J4QC !z$ p$ $221 E"; 2C"k g",>. Icw 3Z+J$ omcu m u macg ;$p! z2 e4 E mm 3 -m agal u BO w Cu m 1 CrG 4J mal E~ a 3.4 01 8 v.4 UO . .4 -4Llam -4wd) am 5;ZY mho pi li: EQN arc oa am h0 ;mu3 om0 a3 *+I PI aQhQ q ; is25 E!! *,: c) mm PI mw 5 hag: 2g p m &Cj -*- m w.:. 2: 5 $U"' "Z oc n" $2~ da V) c, c .* gg 2 c) Son;: gae $ 9) $400 3 hzum q 2 -@!=a .4 F: nl .zaua fAb 2 mcLI3 2 aumz :z w .:gzm =kt (P z .'I$"& *ul O ZZa'E, E 2 :E281 Yul os U Q Z!$m.- P@ (r f c)o.$ja 0 Ll 2 km.4 E 8tl 5 I Zuz! u .d Q .4 w w :::O 0 a.4w- 4 Q -U 4 b dCM 3m z5 * uQ@CI LID LC 91: r( %%I; m 0 $" I .5% n ,,,.- LIO i GBs X$ $.2f 1; l;.A z2 T P ms aac NOa w 4JU"II omes 7 cu .' 0 0 wq w 0 .* C u ED $ VI .s 'Z 2 E 3m SZ22E p) &'a 3 8 z.2 ;$jz 2-0" 51 &;2 %Z zn m?l? $2 c au .- 0 '3 -2 .5! I am us u VI a.% c .* cz mn~ sou .% ;; n9.' z um m% g g2Z E '0" E.2 $,a E urn!+ ?Irk" - 'LC WLk VI gZg$: 3 %LC2 $ 0 e.": $6 .,r:mzm gbOEE2 QG0EO 0,Za. E+J am 2 Ea ,p I -: : 0s 9 c 0 I "$y3 x zu 2s = .z .g; 3 .g 5 5 ; '2 0.cz g.2 m'CJ* &5 g2w E3 w- m m .e .U E 2 & UOQ u& R2 I E= m 0 am3 E x \dl a .Y .4 & 1 mc Ys B .% Lw 0- .? 5 . 5s C.2' mu x 3. aJW .E u ; E%\ E E' E2 $2, 8 2g '5 .5 2: E2 2: E- ce -2 a g8 -?E ?In *2 vu 30 Er: + .- VI az aa -w ma yo) aJ- m we -0 mu u-c m $2 VI3 c -4 m m ..-I E V fib 8 E 'G mc .d c am Cd V&a -an m V).Cla- PIurlo\ rlw m.+ Et blm = mwa oou . an ha, PI o a.4 z m 4J bl 0Nm &PI A2 Eo c b GXVbe, im 3; !4! PIPI blu m: me % '$ *ul 20 k': e *z Om %: 5: 0.2 "8 ;& 2; 2.5 E 4J .$ rl am PIP) UI: EO 2" *I4 k w3 gz a, bl -d E .rl 5 03 4J 5 P m c, h 0 a PI e c, a" m c, .d e '. 40 alm au om wPI w -4 48 wrl 0 -4 mz 5: ual SN a5 1: 3; IC g Ern& Clc, 0 3 .rl 25% b .: g 2.; *2: #;" og01 w Oh0 .+ 09 0 fz w h.4 ap 3 EhU .d 0 ; flus E: . 2 $: cr -4 0 3PI% lnn h .d d L: Pia, .d -d *dB d3 .4 w 5.:: :a; 4' d .Q : ;u.; 3(;.i PI md tnE m cc, m m d -4 E SU m.4 u F 2 .d E 0 PI 4J & % 5 I e 0 h rl 0 a .i p1 m PI w PI 4 !i? ! 8 ti: * PI G c, a" b .4 m 0 G a, z-4 n a 0 w w m 01 5 w 0 :: PI .; 4Jl %.-I E:, G PI0 u ubl 'a 9 q lw li 5 2z 0 012z PIc01PI c, Wcl (Y Uacu 4J ogzo :..-Io, 0; .$ e2 auaz PI ,$E":: ?.-I.;: g $g a4J z m; 1 c Q$+ 4?201=; mSL2Z @Cp wbldmz 82832 5; 4Jb g.;: : $;;kg 8 E ka,* a%:"% t!ic CI g m; -EC# -In I? 04 a,@ m :do IPI 0 Qlac >I ea' 1 @=D g lnw; 048 ps .3 I mu; m.4 PI rl . kGC0 acr 4 c I $ 'd f Q) w 0 4J s B f k u 0 2 bl -i m .rl 4 B B c u a, LC m Y PI t a a rln k- 86 a, a ..rl m3 PI G cl w 0 c, ' 1 a, .G 4J a" i? :; 3 .L: PI d n a 0 w 3% w 0 c, 0 0 a c 4J k g. 3% g PI m hdp PI4 &P-lo&m ~~GNPIO !OaE! U"S",O 4J -Z$a au;z+jc a 0) m 3.4a PI c m mp* d PI QI.4 3 c 3E 4~ .52u 0 uFemcm v) oclno .4up eo WG pzz .f: gu . a.E 4 .mom 0 .: b$ .: d bl maul:a wc"Qq0 4JZPIkk 9) nEV fy!&wPI dp 34 Of 2gmzgc "2235" Q 44: lpct E;'w C 3w pP14Jdd CGWO 4.i g a+ 'y mc,c,.;l K PIG m G4J c PI+J @ ac, pw 5agg.5; g =.: 0 I ~.+23Clo 1 PIPI- ."#e tnc, ode 0 4 Gd-rm mh#mSa aw w u 3-4 . PIOO~OE! *& lna, 1' .- s E* a-2 4J2 %5 $2 gz 9 rln PI rl wO 8% wdP 0 .d i* u$ .5 2 &% 2 '! .t a L, 091b a 3-g % m2 20 v1c g ma 1% ha.' bl U+ .4 rl .E 0 \D 3ru 0 e 'c 0 *- v)s 5" K2 mu v) .- r4 3s 02 5: gE LG maJ -M 0' 2 .e a8 .Y B 52 05 k .- 4G g?i a2 z.2 @2 m oi .s 25 2 e.5 a Lz z 2s -2 B g.5 7% % g& 2 35 c.2 g aJ 82 'cm s:L. - .GG -2 01 G uzm .+ UGo &:E7 F- ;- n d %$!,?E %-..sg 3 w &-z 5G 7 73 0 0 5S-x. h2m 26 g; :2 $j $B"d d-25 %%SF +Q$ 2: gc L;z2 2 &,? 2 md; E. .2 3 a-n m 0 k=- 2 Y $322 7m E 7p5 u *Go 60 352 aJ $2 e q &" .5 O"132Z 2gzmg SbJDz!; 2*z 7 E k M w<r +C n 7 .z zm!2 E .* a WL TlQ 0's bn .Y -"-ale 0 0 2- 4- ay x C.U-3 QJ I 'c m r .- 20.2 aJ E .r( 10 .4 E a u rm E -4 LIE .r( c r.-l Uaa tnr *?i .-lw mrl me mm -an zOz: oou ~ ti5z:: X mwlo 0hONd. ha, a,n ha, Q) aXUbB4 -4 P $ti 23 .4 ULl %I I Y 0 4 4 04J ..+ c cm 4 58 0 rl& a** a> mc urn 2: QI rlul Efic eLC Vro ak s .$ II w1.' %*n mo 0 4 4 cow n 4J .5 OD :; 2: .4 r 7 r3 .I 0 .e 0: am cu +JO 0tn 00 >u 0 ')a, .5 c mu Llk m.-l - 0 t: 4 ?Tq al2 si 5!?: ar; 03g * .X: 001.' E c .r( U @.c* 3Y Fl kg !if uk4 k4% -mmo >**e 4 a, > 0 u mu v -.r( 'u OLIO ea a, h a- E2 m-1 ma 0- 0- u h.* E'u 1 .-I m am .-lo : r2.X mu h$ .rl @0 0 w.5 0 h 0 mc ua,0= Ea 2 52 m o'$E 0 a,:: 222; a -4 % 3 e gm g !gic 44 a;g8 * 2.; VI g; E.2 a, g: $-;::urn Fl aZ.Z.5 .-l; -2 9g.m 30m$$ Ilu e* 0-w 5 1 .-l 011) a, 0a, ea0 a, u-na E.4 0 0 os k4 $4 v) 3 aa 5.2 z22 gl :@! $0 1.' & a& 5-2 2.; e*- ea $!- $3 2s m5.Z g$ m*B 30c 2.; : $ . 4k e.-!* a,$$ s: "h0. 30 $&; $3 hh.2 85 ;a,$% $2 5P'S *q ma?, *z a M .c+ E kg 2,.% 4.2 ';opz ZQ no; 2.2 2$-+& p $25 2 og(v-4 ..+ 1s: 8" ,ma$ rlP .& 4c +ij i3€@ gmu QI * h3h * c.-l 2 4 .X h.C.4 Q)#C(U .dm ec XP i, @LC .rl os0 Fa 00s VI a,w m L4 a,ffl000 07 hw mmeo huoa- GOm 4 OEa,@d $0;:: g*b: - fiacccN 0 00- 2 a,02; 3ai3E *.; 15 m ua,mo~ Uld u hg "X""l;& 91 E'" a 5Q) ea e4 p:&$ aU 2285g 2: e$: w+JPJ eo' ozpJu2 rl LCutJg a$oou;: &.g@a, 4p 0 a0 .p"a,uz g.4 UI $ .= ';1 %z::r 2.: *s; ' 04 h0P 2.; 0 m a, 4Jpdi *UgE3 'lma E LIS ! $. 0P)O .-l &e $4 h ha,@ a a,0*oa, 4-4 e as u al1 50 m s.4 e .:4 P 3*2 kg 2.: r; gi% m& 5 m2m $2: = $4 u!lu *rl 4 01 I# .e 4 &om -4 0 a as .fi 4 %Sg sa LC .w Q [: 1 :: 48 opz 1.' ti ?S,S LC4 g9; !!i$F 44 $rat gp; & 3 .r( 1 a$$ : V.!l "!dSO 4 4 .2 .i urlc *UP 0Q) h> mm ac "2 zz $1.' sg a2 zm 82 "$ 3QI7 $22 Zm4 3 .-I * m4 5 w a rl 'u- La 0:: E% m0.2 de -%a, 1 "% E!!! am, 88i srn8 3nm* 52: :823 ~2: -,t $25 k-$fr;d ea m a,u $0 a, 102 Ic( .4 . ig&l ::o .... F eu 5u i!): 00 0 0 3.;2.$# WQ 1 zg.pz2 fz G.2 $; 055LJZ$ z&w:oa .- aJ5 2+ g L:am $me,o32 a aJ n.z.2 0c 022 he - 33 cu g-5 amo~ae 0% c5 M 8 :g.p; - Y b E.: c a 2 unwh3L g2 UJ4 2; .Ea z ws% ap.52 VI2 l4aJu 0 $J 25.g aJ w 9 85222 +24sc.. E &V) x0 3 2 z .z z.: g u c 33 a1 2.2 acc40: w-3 - VI.." o2 2 0 3 bo32 0 7- VI .Y 22 4 g-7 5 g< $2 E5 Elx v) w a;; If a22 0 u '2.u 'WrnaJ mYp-;2$ u a .gs 2 :: d t-.,ooo5 2zzk3m Ea." 4 X0 - a 0mEO aJm'EAJ Y :g 2 2 Q-2 - GaaJ Y s E ,-go A' 3 O'C " u aJ c 42 ;3 3 Q z 4 'w + 5 U C3 sj z E? 3 J- w -1 m 6 d 0, %e 3s <% G LaJ 2; <4 '2 u3 HaJ nB 4 a+ gz - 6% :$ 8E am 2% s.;t k-0 $5 0 -1 % 01.z -(I w VI I W 4 '$QI ;; & aJ%Q 4 c Y .= E.:P E: % Q E, a 2 2 E u 2.~2.~ g ~JEC~ E w m.." n.&EZ 2 s rnZ=& VI i u iJ =aJ= l4 E= a aJ aJ.~ * a 222 g5 a $8 z-pgaJc-.5ygLJ c y 0 hz; w 4- bOv&'Z LJ GZ cn 2 E.i.~c 9.5 Y VI VI- *s 0 e.2 aJ w 522 2z~2~& 32 E E IL. 1 g 0 0 rn" m Us go? 0 0 Oe3&523.$;2g -55.2 :;% ;%-Z $ $j .- 2 3.s a6 ;;5$2 gz g2.g a,p)~; 2 Y v v aa.;T go~wmaJGaJ:g;$S 5.22 z g :sa s 2s 0 g & 0 ;%pZ 2 g gg g 223 EA ~5w;$&mzaJ'hw $ .M z 2 $2 g Y 4 --(I 2-c VITgaW M2 2 E5 wB-c: XW h h e, e M" VI 'a 2 2 3 2 z :y5-; zmMm3: su3 m>eo 3 & m g 22 aJ5 > :: 25 2.- z 22 E2 p p i;.gz $25 2 G.5, 5.g.g p q % 3 aJ g 4 :w.:.g aJ 3 &a pea &-w 2 &.'. 3 Y -0 r 0-2 3 'Z g .." 2 2 0 2Q m 3.z-z-2 2 s $ mQ'c F F=aJ% m az aJ m.s o, s Me" -12 aJZz E Q Ob cT 52 e.25 c m G& e 2.52.2 2 ks i '2: w z E ,a' .aJoaJQ. aJXaJ OCJm aQ mQ g.z 5 h .Z Q b 2.z.~ vls-za v;.sn S.26 up,Wrn~WOaJMQ gp&gg.g5 24 2; g;: 2 as3 OYS&* 2 man h +;%.5* Et- 0 m a= 2 %2 0 VI 2% $ XG d.-m E h VI & aJ QI$ 8 GZ.%s m 51 VI aJ .- .z I 2 8 9 a a U VI m .- z .- 2 2 3 5 4 aJ Q 0 e C * 6 - - m x - .- ? VI VI ii M m W 2 2 2 - d h 2 $4 0 Y a .- u t- Q f2 d d s 2 h 0 cl E , E m VI I m c) .e VI o\ u .e g r .e Y aJ a 2-g 6 z$2 g .;tg=2.2 m VI w 0.5 2 z-bz EwE ou225 aJ E 4uar/jsu 2s" :g $.& 5 t .e_ %.t:&?:s 1 3 ;"g ; 2 .y T; .z 5 E-&! $3 .d 5 a, w $*g$ 2.5s %E% 22 @a * 5 M=.Z g 2 g.5 z 0 CI .5! 2 2 23 3.n; f 2zpz.g 30 930"3 aoc., v; l4 0- aJ r] VF VI a2-Q 0 QJ LIT322 ~LG ma VI o .VI X -C V 'A Q c .." s.s;g 2" $ E$ g ,,&a 5;&ZL. ;s:4522 aJ 9: +. 5.2 B;;;,=am- 4prV 3.4 3Les A233 2 VI P 9 .g aJ .YI g .- u P) 2 g.x-5.2 QI >z u 2 $' 5 2 .s .s a l4 .2 x ,urn mn V) w mu m 'B 6 0 VI aaJmaJ'm 3 .4 c $4# d .? - 2: 'p% mY $8 0 w w* 25 $4 .A u1 OC 22 m $% ug .PI E 1; .4 .; 2 B 0.: DO E m .?I E w u .. V KF mK E 4 a:% 4 E LK Q; d4 mm nu -an V"4 @g QUdO 2% ;;;in ;5; mc mrl E La 4umrl mo oov 8:- La P E+ K F 0 PI.4 7 m an~aa 2m PI 4 arulYc4 li9d +a 2 i5 E &g m c' $4 $a I4 3 .4 3 .rl ; zd Bk g 3L, 'E <: 4 'A ..52 & 1 8 05 %,SC pI u '0.d gy3 m cs gg mzi ;tc 0q 2V,O LCPIgokA 022 E: 4 Ci.2 2 $2 :E ! keg3 -I4 u % E. X $4 dPI Bt: mal 22 q !$ I$ 4k a), GO 0- zi bkA J" m2 S% z? q .rl 0 Fl P F>.@ m A+, 30 JPIm rl XO# OK$4 2 2n.2 L mE.I: u 0 2 ;o-4 WK E ma z %PI4 -4 a :: 4 F$; 2 22 a ;c u1 IllU&d P cog,: oc;. *LOU 5.5 uoa.4 E g -4 m F5 2% >#xP !3 .4 m .4 c, $4 c2 8." mu W 0 g& PIm L LP va.47 PI a-ln(* 2(QlKe xPI L2gPI 4 a? -2% .;;;z I-: :z$; WL Ed a IQE 1 mcco aa u 4J grl*w m: PO"a Ea HogPI o: (WUP Hal oa?l oa oa i.! p; #U u)# 10 7am 4 Hc,o LdO m'de a2 LC ';1 $ .rl co a- 4 q c 4al 55 -sz PI .u ox +PI In %d .x 4 Q 0 DIU CW lm c BX qs 8g 0 PI+ r( EQ mo +I LO PI o4J m m.4 a aw+JC) * CK ul mm"xaorl g >. :?.:am m rl PI L E $4 0 L.42 c, 09 O p1 "q.! 5 >zzQ;$ge; .t: ."S$fm .LC m"a"$o*.-ig WI K K $.:spc *J a m,Q ".?E', $5 .z .$ a$ .4 m c, m .rl 'kt&$ 4%2.:Ga 0 Sg&::$ aooa.*o,e,$ PILX 4cc d apnLc,m z:= +~c2:p10PI * K2 :$aw5mQ#"e ahgo L,ta#9) ps"#""'a: 652 O,E$ -+a *U %"+PIp2e ov)g @ mc15 E 2 blc: b $: PI a- m m.4 2 r :- oa & "8=<2 ,+ a4.c ;.$E; a.da m t% Ea .: amoaar;z4 K a a# :4-zu m a - C5;#30!3g.!i2 PIaommD agsar ~.l@ U !3$ $40>>u munbzm #om ,Loa U# 0 9) p1 a* K 0) 0 lnW L, ac.4 PI x 1- $4 bl* = L 6 &#on a- aau m ># a >-I EO s +a PI P.4 .rl @ K PI IUK eo m +a a +m P $45 5 :$ c, OW e~ VI-4 C P K v) "I c,d om 6 0: d om 2 m 0 az (* ea at : 5" p1 'c1 a: 2 z .rl JJm * ad: : o#a 2 .4x 2 E;.;: .z 3; bl PIG 0 ;(* 4 5: + $$ 9 .:>* E :&Is 2 $OD .4 e-5 2 025 ; 2:z 9) $ z Q) 4 :.z g.t:g # +PI k <EjE .? $2.5 2 za4J 2 m$.2 g Q;; : EC$ 4 K** ; 2; 2: ; v,c *. ;a2 -4 'QU :a 4%: I bl v) a.g 3% 4J E" a 0 4 a c, 3 a PIC, P P# 2 1 -PL !$ :i 4a pi 1 a 82 us 0 -3 u I c-4 0 o> a€ #a 40 a3 * 0 K v) -4 j u Cb mc .4 e fd uaa -an a dw mrl oou - xmWU E 2 mm pi 4JhON\O hP) OP xP) P) P Eo K b 0 01.4 3 m UXUQ,a 4 P) 0 ma I: +J QU u .4 Hlu 5 zag. .;so m *:>?A gz$$ p: :.i-j 01 m g:.: z4J Efi x:“: $f25 Li g,$ U i.5 E f a, b$ 2 $ H.4 0 2 .5G E 2Q Ez “m: 4Jo v) go;., ~S$o 52: 2 LI c 4 ,: $3 x3 m$P)m v)o *ma mfhm P)4Jgv) h 0 -4 3 0 @“I 91 ‘0 am K b P 0 v)-+d 4J4J 0 Li P)Ud 3 34J-4 01 Cf K 9) 7.m u1 >4Jv)m CCkV) * m.4 m 222 tl gpJg?j u 0.4 0 a -4 a Quh * c 7.4J xmgs,m d mK 2 F F a.2 z.;:g.m ..d.?+Z .+:u : 0 baz 0.4 2 p) 4J .,&a gni a P) b: F OB 0 m4J v) (u 0 m.4 gs ;a ’a m5% us 4 P) h $2 0 E$? $ eEi,: GhP) 4Gad W 4J-U+rov) e 04 34J .4 I: mz v) 0 v) P) P)’4 g4a d h5<tE OZ a8 E .E2ha ::czs5 4J ow +p) .kg 3 P)Kb “4 4 9) -4 v) > > p1-4 a g k w x 0 r( H PI K -4 K 2; :s 52 hu 4Jv) mA! E3 a8 $2 94J 5.5 $: !5 v- 3 4 ab w .d @E: X $$ m do a4J 4 x -4 iQ 4 rn’ VI H 5 s W 3 P, d i 2 I i. I- 5 I w A w 0 v) z c+ A a E32 a4g rqg ZG 0 I- z t E!* G L e e zzi;$j % g3 B .g z- I 3e091w GUST2 2 v1 aJ 0.s.g EbZ E aJE ;;Gezs ; 2 us-, 0 - 2G.3 a5% C" ?g $.as p) ?.t:$Z ' 3 aJ L-22 ;Tap, cn.2- .OaJomaJm cEET;S .T 3C"FZ rij ,YE $$ 2-5gzaJ5 m c: 5 g.2 E$c 9 5 5 k$p. 2 33 aJ)9.6_.= a 3.2-5 0'" $ E-c 5 2 aJ z y $m m&aJ 5 2 &me 4 b @&$82 0 22 E x 5.2 ;g&-$zaq qs3 .a w)as 8 5 y g z "-$g g22.g %.,.a aC: m.n cn o w.0, a5 aJ C .n.G.n cnh m 2 Mna Ec a-45 c -5 aJ --3aJo D aJ ad OcnaJ*" m 0 m-zs .- B ii .s 9) .??I aJ -7 c ' \' x .,k 3; . 4 , s .\ '.u <. > , '; L\ .\ a y '? r \\ ;, x ( . r .: . ' ,' ( \. 3 , .> (,> .*: .- i- 9 + .. i! , % , :% .(. . '! i d '\\I .J I u 5 .: ; ,,y v. ; \ w, 2 '0 k G' *c P <d -4- CJI - aJwQJ .I! I $4 .g 2 zz z $ :: 0 05 m'B v an -9 Y 5 2z 3 5.; aJ VI E 3- u g 3 z.2 m z & G.55 "CP"$ XaJ E :a us 2 222% %-c r,m 5 0 $2- E : 9253 >>.e 2 $a 2 c.2 my i og :i aJ %25+ 5 E.2 ;;j E 2 &2Mm 2.2 gd E2 0.2 m Mm .e cgzw2 2 2 e$. d ms 2; g2 : E: cm =n us "Cw-h n RaES 3 bo- UZ m @g$ n ag 3 E E.g 2 mm -2 v x- .- ._ u2 &E VI aJ- aa.2 cn% m g.z e: .g .2 - sg&& wzs: g 2 S5G 4s B-;L-126 aJu c c aJ 0 VI _- 'I: E 'B u 3 23 2 2% $$ f g,? c aJ u g$ ra as 3 -2 5 p .% .$ 2.m- z x 5 u w c xy aJ.z r 6 ,suomE - w-ce xz 2';z % Z"2- .E! 0 k 3 -- 0 'r: c u r u m u.2 $.,y,mg g c s+= & wg-2zm8 s2-z &-S.E ?U.!74?3 .Z.Z-'" 3 : g~~go~ ,z vi E !i,p2 .E! .! 8 m s ; ,s : g 8.5- 22 239 c aJ u22cuw 0 wz 8= c c3%a3aJ E2 m'3wP -$os? 25% 3 w k 55 g.p2 ," ozvu; s 5 .g 5 .e; m an "v aJ 0 a0 $2 5 85" 0 .- I: a- s " x 0 0 -- '-b E 23 L v) oa W a?- u w E 0.- ._ b - Q m 6% -Z ml c c wmw - $o6Ea!f& ;.;2$2E gs 2 2.;:z X3 ; 5 us x8 5 gs d E6 EZgz-. b Q;% mo= 5 a .; 2 2 w v-.= -e: 5 32 ;Ed 6 G .C'2 c go z 2 u .y 2 y lil r' ,% ,? mm& qp2g2= pw-Y;,2?2:= m c bm EL. K"8 3 gz2-e aJ h.2 2 =LIj ij5.2 5e.z: - - aJTJ u 0 wg 3.zs 2 a=.':O 2 $$Z x5 26 m.z am om 23s b -a 2% 0 & aJ-c 2 py,;=; 2 EGG E m.= wz W~32aJ 8.m g gn 3V 0-Q -z.g 2 $;<" swc Mu: E 2-3 E'S 9 ;; aJ ag.5 E = &; 8 gz g; 5 6 ,572 " - a 04 YQ mv S v) w aJ m.~rOaJYrI:X - 2 P g,m-c- Md c WaJLC4KJ a m 4.a 0- s M2.L.a.k m r Y u8 t'X-crwmC2 &, E-0.N wc Gbo.c&?j c MW"' o p2.Z g& E 0 u sm-aJc- Z€ 22 Eg ;& d 52 W cr 02 .2 ;a t;2 y,P 2 cs m g .$ ,m maJ sg 5= ;3 .2 3 5 u .z x zmo vi <E 'z EE Em3 032 2; 2 .g .2$ .e ; 6 .s 3 5 226 Y as 09 aJ ?.P% lijer kaJ2 8.S a 2 $3 ma m r2 - a2 .A x_m a aJmu v 3s 22 6 2 zj ZZaJ 32 5 .- e? 'R 6 .s 7wl mor: 4 2 Y 2Wb -a M3 % .F: 2 cqr s Ea w aJ-2 '1 .s g 3 x0 7 n .z .Y 5 a -a 0; dn .9 - .9 mmp F? "a 48 em c22 -a? a22 c;s ; ssq 64: g -5 3 0 g5z aJ6 .- u " d- 6 M" Y I c '2 = Us& 5 pj g8G VI C;kV e .- .- m c2b 2.2 a%< Y 0 'E ma, % g.25 g 2 SEE 292Zt %$% 5 2 38 5 m3 mrmm zfzc;;jq 0 g6-Z .z =; 2 .z 0 aJ+ w u C$DB3 .yzo w ..I., 5 n?% $Z 8 $ r( -- .y Y c Ea-" m E2 25c v; >"a OOE - a Z-g E 2; o$? 8 Zb "5 8 .E m 8 bo= aQ .E 2 E -2 ," =a 2% g gs €2 % 5 $.5 r- E;&%? 2 ZZ"dO2 01 r.- 2 EaJl2 $228 4 .; 4 x0 0 Mm u 6 d mmwm+ ss 2s 2 w:Gaz x5 3; 03,.5 z 6" U M U m v1Q .A 2 5 U 0 cb QI aJ * s t 5 .- w m m a * u z < m d cn E Y I C $ Y 6 si '5 Y Y cn m 3 t tQg g g $2 aC dm a2 ii c .* mw Gc? Gmz2 ses; 02 5 m %X Eo aJvcraJ ZS 02 m0aJ s .E aJ n ?.s ._ 2.z aJ u QJ z.2 a .- w 5 .z v c x aJ Fa % ass g .w Mw 8 3 scccr 2.z 0 pi & ,M5g5 Y dKgOE 2 .; c I m 2s !2$ pg z :% 2.2 g 2+ 0 a aJd p1 b 82 F;Lpg 4- as gs &.G 2 $22 f u .2 5 5 .; ZQMS 0'; c g $3 2 xf a- %s $ wr c+ aJ -oEa~' dz2- - n ZZ W QJ 0 p M aJ= v1 a33.5; 0 m.Om Ecbd< g scsG K wo c.0) < f I u < I I < > I I C c c i ( I i 1 , Q ,I( 6 2z rlm -4 n4 SI=$ w m .v -c xu mu" ha, GI '9) >r scs CmmdudUY m4m OTJU~N~UWU~I~U~~O~UC c ma_( .muuumuYo url 0 $zdNrPmuO1 YC'XYO :ZrlnUOu mu o-lm-loam uu m u$4.wL=L.; cu -7 Y .4:"zucrl oca .Zucc, 4uR) 0 .,~-l""d5G2m:. u Ym OauU :m uumuw 2: m sa E,;.: O "x ,>CY&,ka.2 um mc$~J~'clv~ cEu.:@z;: 5p: cdmQn 4 ;$"mdS= 3 :: Dm: mD@2Yz2:&~%Z:::: .;GUT2 m ua 40 u9u"u$gY: uu :u,=;;-'x; -',n:;%"z e2 2 Xma m ,,uw.:,":; 1 u;2 rl mE mcu* 2go,$:,$3 um* ,,,u,m4%: .2: 5 5 .YE GI al3omu:;m d3V1,.nGI wm d42u UWW'U GImuY cuw m u:;;;y;2 2uwmurlm u' :>.:"2 mg: Zi40 rlum:rPz;nJ u ".+;:u~zQ:~ *a4P)"mo 2;;!~$J:um YO=P)cSa *d0umZ uG vuu: " 4aluo>m cmod z ~ar~c~~" ma-u '110 mc rl~mumA;guu m a* 40. Ammhmm sxx OYC mou:+ O a 4 'rl um '4 %:a" WZ;,,~: EZZ ~~uw~;wc%oo~un o;a ad c".~mV1"X.P,$ mv)vu4v uu uyEE -4 0 Udr ma0 UuGI.os"P)m w Ulmm-al-c .mm.rluYm'4cm u.rl.rlouu uGICuua.rl-ln.~cu AUrlW' m0>3u.-I rlmmuos a m m url "4 4 au m 4 0.4 9 u-l r: mmu.nasoourl3mYaJYuc GIuurPmmwm 0v)CUI nTGY Y WCD 4 ~YUCO~uWQ>u-A.AY @ a, aarl 'J u) u u ao o a Lln u m a rP5 YP c u m 'mu -mu . csuc4mm 4 umma.4 0l.Y YEY YmrnN0d4 = aum a,' oyOms c BadC).cE ua cuz 'u doc .u Toy) urn =oud.Am p :: 2 4:=2,: m'U P uE - .c w Ecmmo 0 *%.Y3 p" x$:;; :;.luau ',x:ouu u 2: rn 080 u",m-g5'; mcu Am-m 5 mv uwy c := 5 5; .WZ uuYm :a4 *2;-loc d :m o'm3 0) 0:- 0 vrlo 3;; u - 03 ZiO'II :: m GI %OU v cu -l c; 5 .$E aJ:u2 m c U ,n ,a a, .cn Qu Y m m uow yc 31c -I cnA,zuuC' > .d n 4 b.0 2r2N g:: U*.rlSJJ 0.d.d XS:E5ffloCC .rl uq)O E.rl y x IJ mm 4 u u.4 > u-l mAa"uo4v EJ m u 3 0.W.d cc arrl Y QI c Cmumo'Cc-Icmm" m - m u m m PTTJ rP4d c YC@Y s4~AnJ-u~G du4mummauoou ,'mcuwo'um4 mcum TTJ 2uu c 0 u Y Y o~-lu vww U7-l .. AG N wm: :;5002: -0 >rwo4ug,g~~ uY;$ m u u d, 5m 0 0%; rPm2 c/mcIm~~mJ3 mn 0~ 0 ~'sa OE *s:":;&capo cmu :u:pc;l: nJcvuuE uuGmuu*m 2o4m dq5x;: cc3:u:;$:.c, u 0 -0 :: ::: u:- ux GIuy; 2mmz *2;:guuyuz $60 cu~"umm~$" * s u F: c uc%.: ; 4 CTJ m :mu a",%:;y; :\ g$mq 524 u !!~u+:cT3:V1uLJ~ .s Ll W G12:yy:pz2GI u a- um~mom44~GucC mo m rl.dCP $2.;; w@u=';@;*wJ Om~~~~z~aI~~ ae ggvuu >- uuo uP)c.da3s=lll ,owg: "no >. EuOOu a >.u&#m mm.4 u,grnwmmE u'D P) md . fJl uzz: u3 ul-lc~ mmoa m rlm;mdc ymumm z'i .qz$az3uux Q &I u c m.- 0 my( e 0 Q.d ud-lcsrl .unWmooc smmo uad EEZZYW UlWm omnwouua~m ~IZY.~ 4pEmwu-lwu.duccu C~nJCUvaJrlrCGOOs= P)u 33uucm0Ics.d *%GI0 vu -In -xu; c -Iu UP4 3 mmad PC. COCajaJGI uz =dm> a nmP) mal uQ dB" ;xm 0, ad u cw::. mm;:;z aJuuwaJ N umIJlnE ""&oz.lm ; z mo "'2 2 ;u- u) = a;, VI cxTv: -l QA3g< >.u *:= aJ c u $' Zw': O $:uuo,o w "y" ZTO.4 o:!~up4" *y-E:yd QI 0 a.4 *m &?JdU $'4$z! b%:.mo, $5 $.s: :z pum$ rn $'.:WE 3 ;. 8 Q'd-l am m 4mucc m" a aJ3.u mc u -dm P) cm mo .c) :ma€ cw 0--2 vu % u"" :u2B:m 2:x:;P): won+ P) Q .rl GI m u u ma rr.4 m 0 mu luuurlau cu m * v) e 0 c.c 3 gr""9 1 FZ d2 M ..or;+ 2 .; 0 .r: g2 Eo~Ew, ZEEOE!: k c 2.0s: -Qk h aJ-c :::k; L.s2:2.0 5 cLC.5- z -aJo 32 .- qggcw ,-.-& 0 * r GS kEC uEsaaa al .- ._ = a .. 'Z E: 0 LI a,\ E 622% o ~.z~.a Z e 99E%z* - w0P)m - $!aJc+s u "453 'I" 42 E< &go3mr Ti, 25 SJg & =a aJ cc4'j~;s 2gEgg.g 5; g;.eg g;z.;$ B - &.%E5 5 $!aJ20@ 3::3,d N-U 25 $! bo zg.2 z2.g &%E; -$gao& azo 2 2 m a,oEo:r d m.9 p) J a dm o\ GS;s 0) 0 o\ ern m MZ "9 m Mm > v1I zsmsze Y i '5 g$,zwM wd E ESea Wti :Em 5 0 a b0.i c "9.5 2 Rl -s 6 ; ; .% $92 2z 2 $ gz.2 oa, ;:; g 2 .$5 .r; m .5 g al ws d al5; .&'$ aaJ a o .5 3 .k 2 E 2;SaJ m c.2 3 22 a gJ-z .s aJ rl a,sl 0 35 3 $2." (J MZ -0 z : g's g m-iii gz-5 e m v) .s E .9 .: E.za"LC. m $ Jt;.Gt; .% 2 2 0s .- 22 22 b 3<.c 22z 5 2.B ZQ s.=5 s-u 5 Ow7 5 Qcfc e L. .G 0 mar: Mc c VI"" m a 'ZZ 0 aJ a% 2 .- we U xg 5.5 rs v a jG3,~o ens $. 2 y h+ 4 aE mZO~aq, " S'C al E: w $5 o-cl a wo2Eom g% % Fg.2 t:2 k.22 g 8: MOL g M c v .* v aJ E w 2 c $ i% w e r: 0. I $. g E e 2 m 5 t: < e; Eo al .5 $2' % 5% - EM 2: zz 2$ 5z 50 5'Z $5 Um 0-0, .s d -1 5 m .- 2J 8 w 7 LC. I c c E b m a a? aJ. aJ- m-Q G4 e Z- er- c x$ -z ah E2 += wx 5 .m E8 E@ 8s 2s -E :3 gz E.2 gn Y w2 $ -3 is 20 av P) -55-3 gwvdd $2 593 aJocQ sg3z.2 %oi: Gag v) - E5 ;; w& zS.%Sg "2hS 2C-rl 'f: E j; a$ t: a3 c2 u,os Ob g 224 g: 2 %$ 5 M5EZ z .: .% c- cU 5 2 5.Ei: 25 ye3 $2 8 b p aJn r-c SCS? 2 -sg22w aJ aJW$ 52$dC .ZZ 8 m jgs21: nx 8 g4-c 3 ;; m2-3 a w ;.$ t: .EPm h 0 6 21 .$ gj g.2 $j4 oar$? w x- c -0 m- X aJ=m c $;Mu -- E2 2 :; .5 gJ gj s+;s E m 2ez2 g c n a4 b .-I $2 t;: g 2c OUCL '9 bz r" 2 2 2 gz E 0-U w 2 m aJ Vl, & E y;.2 c. 0 al.z 8 m M 2 2 ZcX.$ p) s3.2 s-, $;& v) 0 %3Tzk.; :022wQJ .% c aus 5 -52 P Mb- * m w.9 g% e, .5 .z - v~.c$jma g 0 a, aJ 29 aJ mc-g ;z m b5i 3.5 & h 0 2343 g22 rn ME 2 5:-2.2 2 '%a 2 3.2 z $.SZ $ :s g%--Gg a =rnj v) 2.5 - #22z 2 0- zugz .e w 2 g2 w c .r: u " p! $ pg E.2 bl -cl g sgz e ma.59 .- 0 aJ .-cu SJ r: 05 -.&s yrn2ea OW E -a+ 5 cy i pa c.2 ~1 C EJXao muaJw 7 v) .z aJ N 50 OJ pz q't! p" b7s =2 GI a% '$ Zn malo .- -0 - ?j 5.: 055 8 25- m XZ - h.5 v 2 a8 2-c 0 4 %.E 0s %?So3 29 5: csE %%E.: e; 29 LaJ2i? 0 Mi, T< 0 .- Mr 0 LE: % -mx ;s . .t: w m 0.0 22E$ CJ 0. "i. * a c- E > $223 2 ?l g.3 2 .%ss oz'uz 5 g E% -Ut; 0- 2.s3- 13 E.wB uc-a 2 a20 c-E 1 a$.$? wal g5 vu .# do 2 .s .j %a2 ,a 5 .Y 05 2 u,c $2 $ $% -m JrS LaJ 'G: aJ K! T .; E gzz .t: .E, 2 Em0 a, a, LC.wv) 0 .- .o, 5 'u ccE i 6.2 EE!E FaJX 4" E 2% g m5 'GB 5 2 &? m2a 5aJ5 %5 g, $i F z t4 2ber c5 J gm __ .- mu I e we3 3.w 0 "4- 90 0,- d.2 E wz g: .# :: 2 .; - 2: $! .E 5: C? ms Sa 92 .- L 4-0: WT $2 o= ca ZL .E f -c: uli mb vrc b9: 2; :; e; 5 .i Bc '3 : Et Ea :fi 55 zs Ki w- g; .- vu Wb M xu m .f & uc Wi .;I U ald Em dm ;Iq nd a"<d cw mal 83 uc -8 22; AJ. Vum 4 urlm ku c GZG um mE sal u>m uc 2%; -0 :2 .IC; RIYC 22; CYS m 1Jav rlYY 30 mu Q5 ." ;: -z 43q 3cc VI- oow s 4s u3 uu W 0"; uu 'Czz 5 3 .rl ;;: P mm mu0 AJ0w maw uam u C .rl m U IJ m C 0 U d a JJ C P) C Id P) 3 W ~vrlsc~uqou- .ucss-~o~~n~ms~o~~~)a)mc>~)5s~ ~1wmum~33h~~mm~)mv)a)u~u~umu.wu~n .u -mamw~ u n2 e~ua~~-.rldmrluu u URI->IJ- ms~s-~-!dcoma ;;a EOU rn~c( v) Y S>O ~&YQuOCUOv)AW a)-$ ouVQuOw.YO3 U rlUdOXpu)ua SO Y E a OUhC4 m3k++wa;wvo w 4004 NdS ;s ;.+g~uyJ~wcsc~ m~~~~u0uT~~7~~~03uwwm rlwKIUgE CC"~~U~~UQC~"P)~,~~~P)~P):€ S UA u mum mx;p.:~"mo: .m~~m~,o:+oP) -4 Q' EE-OuUs P)m;uJJzuGcm2z ::gE" -4.2 0 3m: ::*mg;s",u,:>, 0yu:u3 z%o,n Qm3um3~uAu~ c v ,,n9a0,dg"a3;1 v)z 2 zu a 24 0 'nrn - xu vJ.-32-5m "v):"E 5; ;;,, 2wuz 3 "JJm,"g;Z"$ u;-&l o u" * m p; m;;aou x pc;ig.o,$ !&2,J+5EU" -"J,n c"~$~~~~~4m 0; U5rn5V 5UUYE;~~"dOC.4a .E.cLI *Su UTI~~'NfJ 2;;t;;&5a) $52; .Imm3 iou 504.-2L m~w>Wm~QuwU ";za"";m,=:L":&"c I 00 mu c E m-O= b) m.-,2xA.rl ; zs 5x2 Ea.= 2 v) y,rl mU"$"z+f *;:~Q;$~zW$$: Eo:= a$qO~gomOQ" c . ..,cc-o~ua~E~c~;:u;2u YP)2+TCU gad" Omd-rlaJ2 2Ym wsu. .IE -O)"O~Eu u0u401y -44QQP)cn w uaP%.;:oy.X-rl 4 CT: m4c P)dag4z.4uP);4Q0Q: $J;o;s;z L.4 ~.g.;o244~rlu~y" ,grnmh:$ @: ~o;ldumX~N~m~.=~~V)b)~3u~ aP):;.z'; E~u5u2.:.:-~ ,a,c: aa, y)tlv)v)oc 3TJgrnoP)= u3%'p ,mClw ~~,3u~'*.~uwmo" X@ P)m'U,-rl 2:- 2 w:o au P)um Ip.!ju: .;::ma ;mu-!€ xuYucm~oua~P)o~ A0 my P)m~~~EEv.rld.2~-0=~~~d~~~~~wP)v~d I10 d4W g:.z5;; ua-5 5.5 ;: 5: 2222 E2 ;$:$z;$z ;:;;.; g,;.$;$ m 04: 3 > my:a)vJ-~NAu::u uu 0 '3 .~~:.-sN..b:.~~:~:s3~ ;?+%:$ m,oc >5.Ucu .c 5 v)o~~;7F~0~~4u~~ ,,urnA m~csG~QP)~z~fz~.;m 3~nE~~.rl;mzz;m~~P)~- cu um34vm~~or.-! mum0mxm2c::d 4u:a c u.rls .sZ(n~zrnu~$ vJ rl =I Ed am"' Zu 2Q a uv u UQ vu ,,n c zmmz FEd om gzz y -8; 0 u U ~Av).c~~~Ztn~Z~m 0 .a:::E;:: 003 "I oauu vwa?Q E 01 J~E,~~~~~~,-+~~ "4 a m'Ic'ou .rl ~n.:~~g~'$Z3~4:gm~ u.aJ3rl7Juo AJ; ~X,.I;':S>.O,, -4 2 a ::uz,,y:a,:s u;_ay,:.I;'o uP))u4P -iou fJ: a mu aym:.4m'3 C"RJ 0 a?;$ mu';;:^-;^^ rEOCU n mo w QhU -+mcuur( OOOP)~) w m 3chmw dmu4uP) ..Cu-taV)u ~rluoal4YP)vvvuYv P)33um3ucP)P) malm3u3Vmm~Ec4 01 %a e>. C[LAJQCQ "-vddP 40.4 4 P) ,am m> rl Q ;423g2 $?p 2 IJ : E2 corn 2&: rlw 0 mrlum aJdCC"W 4vE '4 4P)'P)m urlP);"c u"::5; Z";;, c ghu c >.d ;.; a:: 0: 01 c 5rn "0 Ubop mo; 24 0) .z" m 2 a 5" x"; uz: g ac mu 2 u:= u .2; u .o, c .rl;m;: d ,."Z 010 2: "AJ 001 T: c.4 2a1 a UP) @W aJuc-u urn- o a m mu E ..I 3 u ;2 g9 .2 4 & pu.22: OOP)C5E UCC4J"L 2 N E mQ (D h 0 co1 C 0 .d L : w 2 a c M .- 2 s v) -2- .4 ., V aJ VI s $ 0 a A aJ V I .- VI 4 - m M 3 6 aJ Y 4 -a vr aJ e a m .d TJg 8. M$ %E ua a -5 M .e Y m C 8 vl I V .? I! R m 0 - - Y a E G u 1 - - -2 z e vr 5 a M C .d zi 8 '2 E' a2 -72 :% *E aJ -4 a 9 22 $2 .e -: 'pr. WaJ w- 0 -I 21 v /Il n.4 034 alla uecScsc~ ma,ma,.oaJ -91 5LI"4u5uou >u 4 .4u91YBcm uoma,04ma a>-l :2 aw u mg JJ O -$; $ 2::ZEyJ: 5GR+*Llw QY 2h:2z ~a391umLI :m2;:2Q91 a,* Q am2 ;2 2 mz 2-h: p.Cwcuu4 &A 4vu 3::(uo9 a, OS u2tn i:; gou E:p)"EG ou~l%.zc:~ 52 -u 0: m. g;;+J:$z da,5 "&;: : ,,nuaY0 3 '"alU$z$ ;Ya=ala 2 'r: :E 91 E . * c.: ; 91: "dP910z um YCCrnrn~ :g 04: 0 mr c,.-i:m n zg OS: v ;;.4$"a;J OW um E ,., azz $2 a.4 us 40 LlLI d u4r5 w u Y w"uv a91 c wc9191400cm mO)>YdEa3E 0 4 h3 w w 3 uw mC.4091wNY91 a, ma, 3 Y w .S Y .4mr4u Y 040.4Smm43 40 uumm 3t'VmoaI32 -4 ZQaJa:; 391u 4xcy'y hd ' c LI 0'; 10 .: 4 ; 5 r3 .: p .; .z *2cc.':usuc 2: 823;"' uwm Y 4uz :yo 4 muc mq.4mp *mu4 O ama,E.wY :,a su as c 91 cy O~OYG 91 (3>.z4u EOlZ :EuUm$a.o p:a,:$u"; 23;"$:$ 9) 0 .cZ;4 ~ &Yu2Q "5.1 ; 3$ $7 2% z u um 2auz. $2 *m::ao uw c m a, t.d m; wz 0 0.4 : 5;EzU.4 $5.2 .-4 2-m; Y m u 30 ?$SY4 AS cm 6- c plwc . O)rGaJa,~ EQIZZ-Z~~E am o> c cuwm y 4Jsm $"";yzF ,4 w z -4 c YW 4.4 m€ cc3 4u 3~udrn n 4~ OCUULI mcI2)E .4t4a03smra,c Y 0 ad c 5 Y.4.c u LmomOuU3u~ c1o=la~-.oao uu3OP)Yw 4mouclaJm ru u a4s 04 qQ'0 0 m >. vmu a, dUYC vz:;.. ;:wa,z:z Q, uamo4 :'$EmL1$ z; 91 x-& 3 c';f 522 3 a kgm< 40 e.: %E; 2; :x291a04 xu&u.4Y; mwurlu5m mouu4~~ a, u.4 cp 2 :: 03ww 0 u 'n cuax ;1 VZCx0. 4 (0 s4m u s -4 c 91 .4 -4 c EpL~o: mum.2E * ;r"TfJ.::;; u"' u p 0 rn+,.2vJ m umuw yoLlil3.y 22,c-. z$' 22 ,*'Z vu': gsc ; a 0 $2; * ; g: um JJ:; uu432 4w E9C Uh x3 w m-4 -4 YC'J'aJ. 4 3 c E m m uc c -ou*wo Y >U"U.4 J"L"43303 4 m B c c cws 2.:3sge ct $3.0'" aJ-c "'Si5p.s ccE8 2 Sa,., 3 M0.8ij : .k$ 5 :s k7 yLs:E e::>? Pa3 m g MS 2.: 2 : ... a ca ,,,a,F 0 E %s:A z .o p .Y E a 0 M -5ug %biz 0, om n3-C 2 p 2m ZaJ G2i €2 5 WE aJ @$.g g 3- o* V m LuJc c o=.s 2 c.3 Ef.@ E go 0 622 2-s Cd.G 01 & 01 >I.. 6 g g:; 22 $2 -$ ?.$j aJ;.p< 5 E 2-2 $*" 6 Ti v .z a-0 aJD m v; 2; rmamko 0 u.2 c 2 g z'>m cEmv)nS2 a=lc3$c v) 3.2 3 y 8 I mu, CO.0 O x E 0-- -Z e .e mas 0G-o &E.G-" w m.-* c c c m aJ aJ.g .c c1wooo 2 Y m u a > 4 U 4 4 Q Ilr > > 4 IJ U a, 0 \ ffl 0 c3 n 4 rn 91 91 -mo mV uww 91 -m mxc mmrn e u c a, 0 0 0-c c- c u.4 YUU.4 .4uw uou.491 55mmucm 4ams, dd u 3 c 9) dV x2G:Yn 3 m &laQcOa3P~ .: .o -4 m.4 a, 0 mmwug mm:2::::2$::2q; gm CEch913;;Cuo ; d ;zmov,~-s2~"~242 m &ao.-l 4$Oma,Xr:c:.:,p&pgo ~ aJm:;g:2::,$:$ -VpV.4,4 x $ c %I 3 $ m.4 * 4 4m g $m ;V'Z,zz 2; Gal.: 2m Ecmp491~mc5 mmuYc~$2 2:;;:m a .4,.*au,0~g 4Esacrl EaQa;,p;: m~;,:*~;,~m:YYc.4 ua gcw 3; *v '4 .::ET, 91.z2 c2 u91m*:mgE;s:z3: m wccYmcc om-4;o'ua ::0$.pEm 0.c 91.4.: Taz ;l.d"w 52 .4.2$,oo a3 ;.:.4 m a,wCEU u4r;::91.4u~x s;; 2 g x:: ; mS u $5:::; Ou;4uuuma,91c~opE 91mm$J.pycqug91 0: A zw.; mf fzu; 915 c aza 'U'0go ro0z3 I..o'o,:€ * r: a, a, m m 2zg m 4 m 07 1 guw -44.4 In an"' 0 Ll c Ll ul; ud u.4 gQ .*E"r(C .4 p, cv 0 PI ca mcc 25'7Jugm:91 0 39m4.473 4Q ~~OUOALOQS 0 u a, = m 9:: 91 ;5,z; m 91 3 0.4 mu Y 91 x0 zwuumw .I.:U a,a .4 $54 wm y . -" 00 ode4 m v) T3 ucI)OQwm U.4 WQ Llwuv a m a4 oI4 -4'"4omoa m om "EEUYd CULJWoI OYC4 aw.cuwn~m5macmawEU ~KJoqo~c91~uWalmuo~d~ 91. .4 0 C .d u h ,* U d) r u I) h Tl m 0 a 0 & 0 m m Y U a U.l 0 u x .d Y 0 -ll : 91 S Y U u z nl m co .Q) a % 9 I 5 : s s 2 E .$ a 2 Y 0 W 5 2 !5 - .- 2 I 0 a 0) 2 w,: $5 .2 g g: 33 p a< sc Is? 9 '$ Y- 0 .5 aJ @ 2s F;: e '%E 0T.Z aJ% b223g3 @; ga kW L, a" .E 2 2 .E .s 8aJp a;2 aJd .Euo .r aJ% MO ' 2 gg E.$** 5~&Cmp& a.~.~~a, QJi02g 5.5 $3.2 2; 0-2 !!$ 2 ;*; 2s3ss g: 0d-Z % 5-u a.30 a 0 2.2 E >oG3SXp$ ?I v) ms gaJ 3 c-l gg.5 22 3- 2 EZ"2 2s %i a, t; 9.- 6 aJz52?32 $ 2$%$ fj2 v)a2 5.2 3: m c & Ez@.a .p 0 %bas .a EG ZZSSS 2 E -23 8 z 32 ysp E aJ m so "a 5% mwEg E 67 $*& g; T"w sui!za& ZI +-2aJc aJ0 aJm>m3c; aJ l-lm 0 x u o E.C P) a~ $2 - aJb (d .E: 2 u- Mmco35a mz~m~nz maGaJw m.2 aJ "E m a~n c~ z-% 633 0) e 2 &$ v) u .9 2 -e 3mv)cc n &2.; g 5 :=- za2caJ Ern c FS; E? 2 2- 0 &I '6 ZZTp 03 E -2 2 0 m '2 a$.-1 8 23 Mm EaJ .ST aJ; 52g z aJ22 m aJ E cw-? -a m c us 2.2 0 0 w 9 E.2 22 85 2 5.% aJ5-w Y 0 2 :z c-2 ap g,.zaz b - ow 5 5-2 $z$m; 2 Ag+- do>,$ s2aye ;;i ' .5 p .$ 586,;;i 3 9 234 a- 0 01 2 2 2 1 .9 .c 2% tA .- 2 pg5 -l aJ >;a- aJa 2 a, @if g 3 Y $32 3 .gEgY: 2.5 &g,lc 2 $522 2 2.5 u > E am42 -dv'Oi '17 OQ M$$ aJaemaJ $?&; 0 kc2 t? a~ aJ aa E ~pl2,E +cv)oo ,E: $2 riy U-C 2 aJ5 m.2 mG'I 5 ."I '5 3 5 ;G &zs zc.? E -2 d 2.w 3 g,g 5FSEC 52 Mq gs cq., -2 2s d o -.z c 4*aJZa :=A 3.2 225 $3 aJg aJ u aJ * g =i g 0 -:;;io m m 2 .z :G t; $\.- 5 8amma L, 2.22 E I R-CQ 0 o u .,,a y v 0 Gum -2 3 bm "G; aJ E.0 < 3ss ;j Y Ob ,om- 57$p 'I .3/ V .c ill X g:l br)& o3a u .XWO-IhW 0Em Cffl~orJmam aa- hu 0 s w ao E 2- 3" u:;"~wGu 0 uuzp,: u2wuU;ua cu2g5usI) w 4muw : .2??& I) w v.2. c :33z.,:ma mc v) $2 :2:m;yJ 7J c czis :zwZh uw ;:gmm.440 dm =,,2:%%!0 Qm::u ;U ul P)W hQIS_(.Cmau 5 w:2 ::,as3 m=mg ::Ea .;cl: 23w uil .=.A (0 2 3muamg cg s ,yJmm:; 3 e., . owua 3pZg53; W4 xE"m ,dm nJ ou.* a w. uuaw ., wu u m-i a, az g::;:s; rn W.d u~n2* C: Ul 0 aw- 2 5.5g: z2g.5 2 4 m- aa>- uu .w cou~woowo,rcuc -cwmuwwu .w 4W"uwvu awca-- 34 umsY>cuuoo J ,zowguam 3unuuu LI EW x~w4ac"uaoa~n oa~omuo4wu 4us 4 uo3$uw>-m a4.o h:;u.4 u4 cuu rn a 0 m.4a a Or, -+*a2 uw e2w25: ZZd 28.: yLIm * u u a h.4 m .4 3a: 4zQaW 4 wzu3 z3wa~a2W~EdaIu .xu 100 :;u.:JJw,v 020 4 0 * 2 wQ n $ sw z:s os5 pu""@ :#:uEu uq2::k"2: cw YoEu~'YaL44C s::;;YC;E v wo%;o;.4, C"N2 g:4;uzwg2$& aJ e uu4W"a~;;; u 2!%!72$;<zs md30V >: B,duwaEc u 0 c-2 2 9) m;; 4Yuszvrl 2 r: 2 5.. 0 5 g a- d .Z'G :m2QWpC;duumC up:u3ag:a:u; rn PI .; m:: ;I :zw ;: ,: z "..:z .w' a T3 M.7 4 kQZpE m '4 :&$?&r:Qm: c 2 u.4 @awm*&!p* s E uom E€4 40 Y.UY wb uu aJE .rl .g u c vcda;u W QC;" Qa CWW' CO ac.4 UWWEU cmwmO3a aococo~o3soua.4 VZUVuYOEEuUadG -iwmEou::u":g,": muw3Ew g".."$.:z @a- > aJz 5 d mw m -2.52 aJ m aJ g,: l-z=; E 6 gs2 ;sa ' aJ aJ:g% '5 pz 2 3 MbViEG z w-5 c aJ.G;z 33 Ym u 2 zz.2 3 2 gam e 3 aJ3 k-2 BY 2.G2 2 $x %"~~~C~,~~ u aJ u aa." $ h2.Z aJY IC m u 3 aJ.2 aJ $< 62 .: 2 f 2 .: '5 2 3 $ .g '2s E 32.2 p Gj aJgszb\o$3 ? Y av)~"La u 2 E $;g ;; O ea 3 2% &a aJ y 52.za.c I-, m 52.gxaJ c cLL2m a 22 @ 2.2 " c ap aJ x tQ.2 h "C 2s 4g .g 2 g &"-$g g kaJ ms0 $z"~8"?2:22:: aJ aJ hC*5 QJ 5 aJ.0 ?gzG:rS:q$,$ g.2 p c5 O v, M'i: &E c-5 w y 3 ; .B 2 .g &.G si: $5 53w-g cE3qZ g 0 M zg 5.c aJ 2-s -z:i: c a u,& m a uap 2 3aB gG 0 $E a 6 gA; Ei 73 m-5 6 -0 d m 8 c3z I a5+ ocg 2 og.g VI aJ 0 Mu aJ'.Zv,Eo$5 h aJ e x aaJ ZZG aJx .e c bum >QZmM - V) 0 ws E&.= 55 m la.- c m-d oaJmaJ 5a c:\mmmca7 D 2% E.e E & W =tu% b.aJoa m5 3cvOmc~s m ma2 m av'$2,$? %z y 6.2 2 2 Y m 3 25.22 a m 3.G ; '4 Eo">:c:x m-C%.%!.%!z 2 E*---- aJ w=aJ & &. 2 can 2 VI m w aJ.s a h2 g3 3 23 Ekg.2 "oz, '24 ci& ?:b=aJa 5:; $22v 9 ?%A?% -aJ 0 a% L1 E 0.- u e 132.- aJ g 522g 3 .- u in I Y I ;$2A&oE mmc2 m aJ.- - VI t: a"L" - aJ d .- -. 3 $3 g*gj; 0 2 3 L) a =&.2 -w - a, m Mt; S&M>aJCaJ n 'k C rm z %Ek -32 9 3 i.2 g:: 2 m2 9 :g,F 8 .$.S "2 3@ 3'5.55 $2 5 z owa -os$;$ I aJ8ggda k?m:6 z d F mag ui 2.5 g g k.$$ am OF$ Fg E& a0 v)2 ama EI - ah cw aJXk 2 z.5 GaJ Y -I 2 5 aaz 28 xu0 -m -3uc uorJEamOc4 m Y r-4a zgw5 .m'hC'W ;;;lcm uL7g Y4a25;:.:o cu-f:*:*';I:: a uu 2"u u 2 $4 ,$"" c;* c- €W2 f E u x .:Go a c 0 Zb" o,-,"c; 22 "u"y.=w.+;::: u, 0 0,522 c FY IuoByL2_\~2; ccu d>U u. ua 0.4 3 0-a "U aJC ac u wo4,3 .-i 03 A wCONw-Ca ouuy4 9lnw v w,+ OLI 5gzm .-iEd m : &a0 Qg5 ;;";I z F2 0 0l w =u rmu CCE UU"@nJ mu",": , 9) 4 a $'4 0.4, a Em: : u w . ,"Z a u $2 Dm .-z: a c my- a O%$L co&;w3mmwrl 2za 2 .m:2c; tu uu".rJ rnm-;4w ucaJumnw:5 c~~n3~,~m~~ ou Laso a maxJ cg: a .4 4 .d c u au D4u 0 C.4 N m4u CO E Y afnw ala .o c- wYcwaoo1uuo uows'xu .cou 0.C CPpU W QM 4u.4 a *h 24 ou -u E2 2U :; as 58 mY 30 Qw UU hh *a m .d cv $2 22 u: YU 0- '0" UP) z: 2a Y 5g '2 I 4 hW 4 40 a 'U va WO v. Wl- a. mn 4u 4 4 m w -w.4 u w u.4mornwc vnu cmo 3O"h$5s2 Wc) VUlX ..::: 3 I: -0 2 ;$a Eu.4s woe ,"Jay iu 0.54 a-ig uz$noumrl -9 .az ;ss;agsx mal~W-loww 3 a 5GUd 0 ,;% 0'0 a2 :n%w:2: V:ch:Q $z:~g; .5s =dl CQ :p;g$."; 2Ez . .x?g "9.24";" $5. 4J$*Vrn .c P)~U~~).Z ""2;; x En c,u;X :E 0 u ~4m~n o ,".a 3 mrlo e OY a Wh m0. w 44 Q 0.4 m3> n 33 ",.5.4:." m EU C E4uc u*u ,: Y u c '4 u cuouw c -3w uu .wcua x.4 m d c mrtu 3.4 wx cu4ouuu 0wcc.Caca UW'45v)OL'Q UI CIO 02 2';" =a U $:a *U L: E.ZW -c 2: ern m. 0 a4 e uw wm OW un,+ ou m s 0) OPU YO UWO u ~gm g: zv: 0, ocw mv 0 .;o &a2 a, mcw u.: man] P) 52% 2% ouw .: z h.4 n] u@ ;i' p cam & W4Y m 2 ;.:: m.44 '"4> €2: 2.:; W m 3Q c 4 4 WY U ovlm h. .rl m 3aa 2~2 cca hUU uu ww Ycl..- 5c m c E-"' 5;CC 0 a m 2.22 2 5: :.:& 57: 2% 4 4 Y.dS 9c 3 cu w3)c 0Wd EC 01.40 UE c F r 9 9 0 e 2.giqj.z c WSTu a x=-U c: s" d.5 L. 4% 26% * $s.gzi$;A Y 0 e. M-U 2 V MY " ta= $Q.% c,Z m ..-. z.2; 3.2 aJw z.g.22 u CU p O'Ws.0 "C 3bZww apq .;gaJz .uJ g$2zo'3 32 3 g c:r: 2 2 27.53 .G-+ ~s.5 una E'" to-5 2 aJ g 8 a4 g.2 k "5 a&.-p- u Q) 2-5 : " mccLG*o.z %BE 4.5% aJ2!T-d uz.z >% 5 $ :.z-c 9 od 3z ,,>m -e5 s".G 8 2 O fw 0 yz,~~& ;j 3.232 e m'u %.G y k! m M !$J 1-z; Gm -0 && :cq-5:3 3 8 1- M d:ag su 8 ;ij 0 8 52 p 3 u al E;& E< OOv"5~~92z"g+P'z 1; u" aJ- - wik 0 ws % 22.2 bo- O.G$Z ez 5 EW pc 2.2: 5 ~$~~~S?~-Q~ E use o 0 cat; E ;s 25.5 Ej..JY ?&s "-2 u u X'S E qe3$s3pQoz,pyJ: &E "3.+E i3.g %: Ep;.Ez bok&% 0, 7 bow 2 E $5 hG 2 E F!u:.z ES-0 u my r: 5 0: $'--& gz 3; 8 s xr\Ec v; km.5 $22 u Ckii.5 0;j 8 E.2 5 2.g QJ w 0,= 3 23 : 0 9 2% 3 ;- E2 * w > 5 g a" 3% >A2pq 51 04 U%€m wor= w g.2 8 E \o 0 m-< gf $A ;z z g 5 1 E 2 2.; u >"" E 0 m u m.- -5s.g E? z2 3 'j wseq g $.: M Y 5.@s g I Ef z.;.; x.22 EpJg E h" 352 2 g 5"d.G 52: gg 2:s mo zgpe p% 5 gz a Mz w m'" w m w2sc &w z 8 93 2.2 - Y -2 cU Ebgs3wzz w O c,cn CS GZ~$; 0.55 2 ,z 3 5:" 5b5 '3 3 Y os$ 2z 2 a'=% wG g g; 0, zv -&: 2 5 o) k.% 3 Eb M.5 U0 ,ai'S E G-0 E=.a ?:e "..= Y% 5 q w w3 .3 w-- 3 25 am "7 5 U-eTg 9.;>II) g m 3 5: 3v E+ aJh.52 I: z 0323-Ztlc~~,!~E3Eg, aJ 0) is gs .Y 9 51 Y gi a x0 :E2 s" g.2 $corn, a, 2so.c ";".g.@Tj-.5^a ;: a-2 0 u 0 $?& 2 !j z5g zs 2 0 a.- .E! u-U R3 r% 2 $a $ g2.3' +" s" 2,- ggY Llk hW 2 ;,5'$2 m"7cvofl *rnkrnPI aapl pg.0. 2 ;i;? $2 ;z*g E 3 - 3z 2,- fl~d a$ E E$Z g E 3 m d ,P g&u@ 2 .gaJ TJ 9.2 w kAE E m y 3 m zpz v) 3 gs E -mz< LZW.5 0 mr= VI 2q aJ'c: a- g 5% $3$p am v) c % -2 -- 2 E:..-. F&g 8 g m-ca 0 2 2: z ? k?% 2 %:23 t! 2 0 aJ&S M -0" ou 5 0 25= c 2s 0 2 m N S g bi; "">E m.- uir "2..e.2:7 E a aJ I. 0 - a0 -n cu 32.: ws $2 3 m a:*?'? sz.5 3 8 E~$~cn"u ".E z 9.5 2 U a o) "3 0 w..-::" 0 &Car ;;i .c * .c.r 50 n , u u - I: g 25 u.g -q !;$ m.22 0, 2 mz.g.~&?~ 3.22 2 iga yziz2 ?z a, ,,,; uz? % f s m E 5 u 'I: g, .e "Y) a 9 9.;; 'c, aJ 0°C VILU" .zmc .g .;,S E 5 sv.$% 3om e- e:: 2 E 0.- "Em m 0 0s Y UT3 2; :s 3 zz)212s E Uk 5; 5 g.5 maJw wE8 v, 5$G gczm Y cc "¶¶ ow 0 " u 9 s3 xm.0 bok-g.s.ss w L &beboo c 2 .c t:,aPoE m 0.53 , 3000 5 M2 omEm r$.g c$;g.%a-. m =I zn m m a, E m., 62 w:% aa 5" ED 3 -.Y do rw m.2 05 En U VI m E 3E v E-= u cc-e;.F: > '3 mZ.2 2 ,Xw m E E g.5~~2 ->a - w op mrrw 2.z-E.gC w EZz2 v) 3 ME u U e.& Y aJ "3 4 0, ww2E 55.25 .9 &E C bw-2 E: I 2 x 22 g3 g." c 1W-,C.$ 3 E ws z O wz*z2% eac -Wag c.2 -aZE aua3T -go..-.~ntz;~ '2% :%E$! EZ.0 cs:7 8 aa Le - 3 , " b" 0 Wl hkm Q A?@ 25 k 3 tax 2 0 c.z " z.c, u __ RcAz- ;u EO .+:-z-Z-> c M 3- !J .s 2.:: g ; ZEZ.2 aJaJ E.sv Mg :: yg g 2 z k ab g+J aJ".S E .D.Y a~ * w L.L.I.D 8 &- tl M~ u $ m z%.g 2 g-U% E U2 b EZ 3 2.5 w 8 2 82% 2.2 s" g 8 01 saaa='W aJ $E 3-32 $2 u E.? L. '21 P Pnd ~~"~~gg,.t;~t; m au 3 ~~~u.-~~~.26m~g.~~3~2 22%;;; ZI e.242 2853 .;l V 8.4 do\ Em ;$ 04 &Qn4 oYm s:5:p::~24,P"c22:22 u ..I W~DO.~~UU UD GI WC u X.- c -0 u dm UU~U~PNC~EU~ n, 0~~3dEU0" ~u~~<~2 0 UEWA 7n; md m UCd mdcmz 0 +SUAz.;.:$ u3cv)m25 2 0mu.C OaJXuc~:;~:, qz c gu 3; :; "".:som~$ :::zzzY $5 >34 u wTJu 3c 9' .d CVOaQ: " 47'; >do E$ 0) .d 9F2;p'=z'~2;= c:":pp:e,o;&"~ Wd 0 4 *:; y *:Qua, NO /pA ccu $>W aJ 04:s cv) -'7JE<<2m;.myI zw s u8au$cc:".~m u-g3mtnaJp;y:P d> m Q d :E CUX0*3OU RIu;u; z"i::a>..s uuo; 2:: 0 op 0 r) PZQUPW c=. m. -u-i ~Yu.dQunuXu till Go s a 6 ; 22;05;:;:$.$ mzm "~;a"uou aJ)y3dp2Wr11u dm3UO:': kJzG:UV:g2m YCJ .== 2 %g;$P4 y $;E.:; p.20 y c X22 z; 4 xu X? 3H m q -2bGU dEumOLI 3 uaJaJuy; 'us4.d 5 2':- 5W LI m y aJaJQacuQ::~%P yn 9) 'P u 4 >u yd~:~m~~UmYcmoud x 0 vcmc CYC :s;s$==s%s2gza52:2 8 *c (9 UX m ..4 5- opluYumYu u.c>cY cx u~Bco3do ,- NOZaJOu .m $5- -c uu u .aJc Y 0 0 uu~uuu Ud ud 4J EUu4 C4 CTaJWYuQm a WUVP.4auT osaJ)-~uw3w aJ0. -couu uc~mmscY rJUCESUY0 -mu EX @c;g.2rsm ZOOOP u3 &z add-0 4EEy;:o ~aJgcuuu~ ;ucooc suc>aJu 0rnmaJU.' u .aQ:"j~ 0 u-c .rl pS i U E'- e 3 T*$!?a,!!Sd. ;:;C-<;m S0.0CWUTX 0ou 3- :,""Fs;&"u m2agrnuEDj: W~>,YC aJ '3 ;$;a g v::,ns20 : .o;-u Q; :3,u;uzo;Qu y;.:::gtn2 unu UYUS~ WmYU .4;:a - m .d 5 -* >. r( > 3.; Cn ,;;aJc'3U2aJ: yoyP 4 uu E XY '4u5rn:5311 2 c nu oc ",2=rnQ;=E rn3m*ug UUO O)--( IIm Po~u~~U rn Y Q'" 3 ' u Ycc~Yuc CY x cumouc 443PV 3 Y8--uOaJYmm u>oc XU0 suucr(c0caJ EaaumU>UU QO a3 X C :: H3 X' ;me gou 9" E2; ;aC YE aaJ -w u c-. mo >Iu Earn 0.T cu P ugm -4 3 uo (Ill>. PE uu 0.. -3 nn U 0 3 CUD uw u . rn Q 0) w.C om. $2 q $2; z: a XUW 2 CW 0 a2 rlW =.CU 2 X0 OCX xm P W'CI c uoa V 2 I s' GI Y a z 2 LC E 0 w r( V 0 ro 4u Xn YU 014 Ud .d w cw mil LI t "--o k sz E? & i; il 2 I9 x o\ QVU" U C W 0 U C ; W ; m a n C 0 n c x- 04 uc m m a .' c : x31 2 * WC D 4 :I 0 ub . u o< v) X mc d u v- u LI.4 < m 8V w: v v O( a -0 c 1u c .dm XC cu. SQzmr .A .-I u 0 vw.4p . -1 ..d 0 - 3 YE ....I4 aJc c ou vu* @mu ;I CUUUE .d cn4 P) ec UaId cm>.cYd aJ r( m .4 4 .r( o munu: u 0 >. .mm ! mwccw; WEL~~GU 'Iv2L:9' w.4 m Crn.31, nn4.xSzs: U V f e 0 !2 d w z X v b 4 0 u a W U u s :I 1 i? 0 a z > 0 z i! E > I I 1 I I I 0 0 N I I I $ I I I I \ v C 4 ! X U 0 C 0 m .4 > I I I- IC la 14 la I IV 1- IW 1 .- IV 1W om la In\ mc la 1-4 ILL 1 tu IY IU 1m IS IZ 1- I I I I \ x U m C 0 4F ulc 3 -4 4m uz YZ co \ I I- IV 1aJ IN I .A la 1- 1m I3 Im I IT IW 1- I'CI 04 I4 010 N3 ID i? IC la 14 la I 10 1- tu4 I4 'U IW la lm I- \ x 2 0 .4 w mc dm 3 .4 uz co nx \ I I I I I- IE au la om 40 IU la I IU IO IU la I \m IC I4 Im 10 I3 IX a0 03 dZ I- I 1 I I I I I \ > U m4 cu 40 mc r)U or) X" \ 1 I 1 I I I I , I I I I I , I I l 0 .-I I I I I I I I I 1 I I I I I I \ a 03 C 0 JJ V v) 4 I I I I I 0 0 m 4 I I I I \ m .w C 0 W ma Szl u0 TC s!x u> OW I I I I I 0 0 N I I I I I \ - C m 4 a 0 rl Ly .- V W a \ v) U a u x m k2! C- 0 -4 m mc 34 4m ur) -x co \ n mu rnT '1 Y '96 d ew w P P4 4 mm c) F1 F1m m .. .. hl w 4 il u E ii u a >>> I I ! I t 1 I I , I I I I I I I 1 101 1-1 1 , I I I I I 1 I I I I I I I I I I I I I I I 01m ?>Y I I I I I I I I I I , I I , I I I I I 101 141 , 1 , t , I I I I I I I I I I I I I I \4 \ \ Im I CJJ C a j,. 5; JJ! OC N 2 um 4u u.r( 5". 4 0) u.4 ..le 4.4 44 -3 4 Ty m .4 .4 am 3a So) Q.-I 4~ nu KD crc .cc 2; 98 22 IL)PoI 4d4 z el * s 6 8 !2 I 111 Ill Ill 111 Ill Ill Ill 111 !I! Ill Ill 111 111 Ill 111 111 111 Ill Ill 111 Ill 111 Ill oao Ill Ill I11 111 Ill Ill Ill Ill Ill Ill 111 111 Ill 111 Ill 111 Ill Ill 111 111 Ill Ill Ill Ill Ill Ill Ill \\\ Ill xx UU LLO, aa !!I I 22: $22 32s 00 '0 .4 4 044 coo rlmm 444 e.. 0 0 I. sEPTElmm4, EXHIBIT "B" Changes proposed to the draft Housing Element in response to 1 Department of Housing and Community Development comments i other written comments " -. e 0 EXHIBIT "B" .. RECOMMENDED CHANGES TO THE DM HOUSING ELEMENT: Since the Draft Housing Element was circulated for public review, a number of lettr comment have been received by the City. During this time, staff has also comp comments and this additional work, the following changes to the Draft Housing Ele are recommended. A. RECOMMENDATION It is recommended that Table 16 (p. 36) be changed by adding data on total housinl that the following text and Table 16A be added immediately following Table 16. additional research and work on the draft Housing Element. Based upon the WI TABLE 16 1980 HOUSEHOLDS PAYING MORE THAN 25% OF INCOME FOR HOUSING COSTS i I1 I I 1 I 1 Owners 529 . 1980 Renters Total Housing 24.7% 720,346 33,138 144,614 Regional Total 16.3% I4352 Carlshad % Overpay, ~ ~~ SANDAG Regional Housing Needs Statement (p.88). Historically, the costs of shelter to a household have been considered to be "affordable" iftl not exceed 25 to 30 percent of household income. Specific definitions have vaned somewhat various federal and state housing assistance programs. Recently, the state of Californi attempted to bring its various definitions into conformance with standards used by H.UJ). 16A reflects the definition used by California as of January I, 1991, for housing receiving form of state or local assistance. The cost of rents is taken to mean a combination of rent and an allowance for utilities; thc of ownership is taken to mean a combination of principle, interest, insurance, utilities a allowance for upkeep. The fovmulas shown h2 Table 16A apply to all households ;n the ;, range, irrespective of the exact income for a given household (Although a local agency n ordinance match costs to the exact income when those incomes exceed 60 percent and 70 p for renters and owners, respectively). The area median income is adjusted for family siz also Table 15). 2 0 0 TABLE 16A .. ANNUAL AFFORDABLE HOUSING COSTS AND RENTS Income Level 30% of 50% of the a 30% of 50% of the Very low income Ownership Units Rental Units < 50% of median income median income area median income Low income median income (1 area median income 51 - 80% of median income 30% of 70% of the a 30% of 60% of the (1) (1) With optional higher housing cost linked to actual income at the top end (above 11 60%) of the illcome cafegory I' ~ ~~ Per Sections 50052.5 and 50053 of.the California Health and Safety Code ANALYSIS .. The change to Table 16 was requested by the Legal Aid Society of San Diego. Tabk and the accompanying text will help clarify what constitutes "affordable" housing when a project receives public participation, pursuant to state law. B. ' RECOMMENDATION It is recommended that Table 41 (RESIDENTIAL ZONING DISTRICTS) on Page 71 ( draft Element be replaced by the following Table 41 (RESIDENTIAL, : REQUIREMENTS). Please see Attachment I, revised Table 41. ANALYSIS In response to the State Department of Housing and Community Development's (H Comment 13 (see Exhibit "A"), and consistent with State Law (Section 65583(a)(4) Housing Element is required to describe and analyze the City's land use controls, incl development standards and zoning requirements relative to their actual constraint upc maintenance, improvement or development of housing for all income groups. The ri Table 41 includes relevant zoning information (development standards for each resid zone within the City) in fulfillment of this requirement. 3 0 0 C. RECOMMENDATION It is recommended that the existing draft Housing Element discussion of the City‘s Grc Management Program - Governmental Constraint (Pages 74-76) be deleted, and rep1 by the following discussion. It is also recommended that Table 44 (Existing Reside Development As A Percentage Of Buildout) on Page 76, be deleted. CONSTRAINT: GROWTH MANAGEMENT Exfraordinary growth In housing in the early 198O?s, fueled by a growing economy, attractiv6 prices and proximity to a coastal location, led in 1986 to a growth management plan approv the voters of Carlsbad. The program accomplishes two primary objectives: (I) it ensures that needed public facilitie; . infrastructures are provided concurrent with development, and (2) it sets limits on the maxi number of dwelling units that can be constructed Citywide and within each of the City’s . quadrants at buildout ofthe City. The Growth Management Program divides the City into 25 Local Facilities Management i i (see Map A). Each zone is required to prepare a Local Facilities Management Plan (LE ‘ The LFMP’S project the amount of development expected to occur in each facilities zone bas the full buildout of the General Plan or apprr~ved Master Plan area within each facilities Using this projection of development, the plan estimates the public facilities required to sem development. The plans require new development ;n the fac;llt;es zone to fund or construct facilities that serve only new development or those not otherwise funded through the City’s 1 fees and exactions. The second key feature ofthe Growth Management Program is a limit on the ultimate nu of dwelling units in each of the four quadrants of the City. These limits are stated in ter; numbers (gunits that can be constructed or approved within each quadrant afer Noveml 1986. The number of units available within each quadrant is then allocated to the indiv Local Facilities Management Zones within the quadrant. In each quadrant there will significant number of unallocated (excess) units. The sources of these unallocated units is ft explained in the Growth Management Addendum There are currently at least 1,000 una116 units in the four quadrants. These unallocated or ”excess” units constitute what the City to as an Excess Unit Bank. Staff projects that the Excess Unit Bank will reach, and may pa exceed, 2,500 dwelling units. Withdrawal of units from the Bank must be in accordance wit, Council Policy No. 43, which is included in the Growth Management Addendum to this Ho being the priority. There will be additional unifs added to the Bank due to the fact that individual development projects will build at less than the allowable density permitted und, Growth Management Program. Element. The poficy prioritizes the withdruwaf of units from the Bank, with a$ordaZde ho 4 0 0 Although construction of new housing units temporarily declined afer adoption implementation of the Growth Management Ordinance, this reduction was due primarily t( need to complete LFMP's for each of the zones and the requirement forfitlanciizg-mechanisl ensure completion of the necessary facilities. During this time, applications for tentative map! other cievefopment approvals have been accepted, processed and approvals given colztingent completion of financing plans. Seven zones have acceptable, adopted facilities plans that construction at this time (1-6, 19). Zones 1-6 are primarily the developed in-fill areas of the Eleven other adopted zone plans (7-9, 11, 12, 14, 15, 18, 20, 22 and 24) do not allow develol; until a financing plan has been approved. These financing plans for zones 7, 11, 12 and 2 expected to be approved by the end of 1991. The financing plans for the remaining zones 14, 15, 18, 22 and 24 are expected to be approved by the end of 1992. The City's Mello Community Facilities District was approved on June 13, 1991. This District provides guara financing$)r the largest and most expensive public facilities. The zone financing plans can be submitted and approved, and development can resume. MITIGATWG OPPORTUNITIES Full scale residential development within the City is expected to resume beginning in the sc half of 1991, because 21 ofthe 25 Local Facilities Management Plans have been approvec zone financing plans jw 18 of these zones will be approved by 1992. Therefore, the temp slowdown of residential development resulting from the facility planning and fina requirements of the Growth Management Program will no longer finction as a sign4 constraint to the devekoptnent of housing within the City. It is estimated that there presently exists with the City a bank of 1,000 excess dwelling unit: it is projected that this will reach approximately 2,500 units. This projected bank of 2,500 e dwelling units can be used to increase site densities to a level necessary for the developmc housing projects which address special housing needs (i.e. affordable, seniors, handicapped). bank of excess units will also enable the implementation of City-proposed density bonus Program 3.7.a.) and density transfer programs as well as future General Plan Amendment: Profrant 3.7.h.) to increase site densities throughout the City. ANALYSIS In response to the State Department of Housing and Community Development's Corn 14 (see Exhibit "A"), the discussion of the City's Growth Management Ordinance has rewritten to describe more clearly the impact that it has had on housing produ( Citywide. In summary, although the Growth Management Program has temporarily slc down the production of housing pending the completion of Local Facility Manage Plans and financing plans, it should not significantly impact the future productic dwelling units in that 18 of the 25 Facility Zones will be open for development by 1 5 0 0 This section of the text has also been modified to incorporate a discussion of the C Excess Dwelling Unit Bank. This Bank of Excess Units can be used to increase .densities, as necessary, to enable the development of affordable housing. For the ab mentioned reasons, the Growth Management Program will not function as a constrail the development of market rate or affordable housing. (See also, Recommendation D. RECOMMENDATION It is recommended that the existing Draft Housing Element discussion of General Densities - Mitigating Opportunities (Page 79) be deleted, and replaced by the follol discussion. MITIGATING OPPORTUNITIES: There are 5 residential densities associated with the Land Use Element of the City’s General. including a Residential High (RH) General Plan Land Use designation that permits up , dulac. With. the implementation of a 25% Density Bonus, as mandated through Government Section 65915, and the City’s proposed Density Bonus Program 3.7.a, a total project density dulac could be achieved on any RH designated site proposed for the development of affo. housing. As discussed under the Growth Management portion of this Chapter (pages 74 dwelling units shall be permitted to be withdrawn f.om the Citj-k Excess Unit Bank in on achieve the site densities necessary for the development of affordable housing. Although there exists a limited supply (60 acres) of undeveloped RH designated land withi City, the City does have in excess of 6,000 acres of undeveloped PC (Planned Community, LC (Limited Control) zoned property upon which higher residential densities, necessary ji development of aflordable housing could he accommodated. All PC toned properties requin a Master Plan f.r rlevelopnterrt be approved. The LC zone is an interim (holding) zone I planning for future land uses has not been completed. Property zoned LC can be re: consistent with a proposed master or spec,@ plan. Although plans approved for any PC I zoned property shall he required to comply with the underlying General Plan densities, th considerable jlexibility regarding the ability to transfer densities to any neighborhood with, plan. A proposal to increase a specific site density for the development of affordable hc would be evaluated relative to the proposal’s: compatibility with adjacent land uses and pro; to employment opportunities, urban services, or major roads. In order to enable the develoi of affordable housing, the City i~ committed to accommodating where necessary general anrendments to increase residential densities on any PC, LC or other residentially toned pro1 (see Policy 3.7.h)) and in consideration with the above-mentioned locational criteria. In addition, there is a Residential Density of up to 40 units per acre associated with the Pl> Industrial (P-M) Zoning and up to a 72 unit per acre density for Senior Citizen Projects the Residential Professional (R-P) and Multi-family (R-3) Zoning classification. The Comn Business District (CBD) Classijkation of the General Pian also allows residential with residential density. (However, densities in this CBD area are suhject to growth managc 6 0 architectural,. scale and bulk limitations.) These higher density allowances could be encoun to provide additional lmv income housulg opportunities. .. State Law (65915) currently mandates that all local jurisdictions adopt an ordinance that per a density bonus as an incentive to the development of low income housing. The density bonus provide the densities needed to assist in making the development of lower-income hou economically viable. Carlsbad is in the process of adopting an ordinance within the guide of the current State LQW. Although the City's Growth Management ordinance imposes a hit to the-number of reside units built within a quadrant or within the City, an increase in the densities of some reside acreage to facilitate the devdopmerzt of addihnaf hwer imme housing units ca; accommodated to meet the City's future housing needs. The strategy for accomplishing tl discussed in the Growth Management Addendum within the Growth Management portil Section Three (pages 74- 76). ANALYSIS In response to the State Department of Housing and Community Development's Corm 8 and 15 (see Exhibit "A':), this discussion of the City's General Plan Densities has rewritten to explain that although under the existing General Plan, the maxi: residential density that can be achieved is 19 du/ac, the City has identified means (P 3.7.h. - General Plan Amendments, Program 3.7.a. - Density Bonus and Program Excess Dwelling Unit Bank) for increasing residential densities up to 29 du/ac in ord enable the development of affordable housing. Specifically, through a density bonus percent, a density of 29 du/ac could be achieved on an RH (15-23 du/ac) designated densities as necessary, for the development of affordable housing, on any PC (Pla Community) or LC (Limited Control) zoned property or any other residentially desig property within the City, provided that locational criteria are satisfied. As discussed I RECOMMENDATION "0", a new Housing Policy 3.7.h (GENERAL PLAN AMENDME is proposed to implement this City commitment. E. RECOMMENDATION It is recommended that the following discussion of Section 1 of Article x;rQ(rv c California Constitution as a Governmental Constraint be added to..Page 89, immed following the discussion of the California Environmental Quality Act and Mitii Opportunities. CONSTRAINT: ARTICLE x;rGyV OF THE CALIFORNIA CONSTITUTION The City is also willing ro accommodare General Plan Amendmenrs ro increase residt Section I ofArticle XXXNofthe Cafifnrnia Constitution provides that no "hw rent housing] shall he developed, constructed, or acquired by any "stute public body" until voter approv 7 a e ’ been obtained. The electir~n requirement of Article XXXIV could limit the participation of a p~ body in the development of low- and moderate-income housing because ofthe delays, uncertai, .and potential additional expenses associated. with l(1ca1 elections. ,. MITIGATING OPPORTUNITIES: In general, Article XXXIV requires that two criteria be met: (a) a “state public body” “develop, construct, or acquire”, (b) a “low rent housing project.“ Article XXYIV woud inapplicable if one of these criteria was absent. It would be possible to confine the role of a p body in a housing development so that one of .the two criteria is not met and an Article X election would not be required. In order to clarijj Article XAXW, in 1976 the Legiisature enacted the Public Housing Elk Implementation Law (Health and Safety Code, Section 37000 et sea.). According to that, a rent housing project” does not include the following types of development: a. Housing with 49% or less lower income occupancy, that is privately owned a not exempt from property taxation (unless fully reimbursed to all taxing enti any public ownership and utilizes land banking, property acquisition resale down, guarantees and insurance of private loans and other assistancc constituting direct long-term financing fiom a public body; b. Housiltgr that is privalely owned, is not exempt from property taxation by rea C. Housing that is developed for owner occupancy rather than rental occupant d Housing consisting of newly constructed, privately owned, one to four j e. Housing that consists cf existing units leased by a state public body from a p dwellings not located on aiijoining sites; owner; and project. f. Rehabilitation, reconstruction or replacement of an existing low rent ha Public body involvement limited to these types of housing developments would still help pJ low- and moderate-income housing and would not be subject to the Article XXYN el requirement. Not all activities carried out by public bodies can be defined as “development, constructi acquisition” of a low rent housing project. The meaning of “develop, construct or acquire” not be applicable if the agency’s involvement in pwviding low- and moderate-income how limited to offering the fi~llowing incentives and concessions: a. Reducing or waiving of planning fees, building plan check and permit fees, 01 b. modihing or reducing development standards; d. pass through of land. dedication or infrastructure improvements; C. granting density bonuses or; 8 0 0 The California Supreme Court in Califimia Housina Finance Apeno v. Elliot (I 7 Ca1.3a [I 9761) concluded that whenever a public body very extensively participates, or assists in no1 making a low rent housing project possible but also jidy regulating the project so that the 1 is that the government is essentially the landlord, the matter will be subject to the Article X election requirement. Thus, a public body that grants a loan for a low rent housing projec, the loan is conditioned on typical government agency requirements such as review and app of plans, project financing, operation and maintenance standards and occupancy would gem constitute development and construction of the housing project and fulfills the criteri applicability of Article AXXIV. Any mortgage revenue borzd issued or direct filzawial assistance given by a public body to in the development of a low rent housing project would necessitate an Article XXYN elect these other criteria are also met. On November 4, 1980, the$>llowing measure (Proposition X) was placed on the Carlsbad for voter approval. "Do the qualified electors ofthe City of Carl.vbad, pursuant to Article XYXIV of the Constitutim of the State of Calijmia, approve the development, construction, and acquisition of low rent housing projects by the City of Carlsbad, or other City- designated public agency, not to exceed 250 total units on scattered sites throughout the City to provide living accommodations for low-income senior citizens?" Carisbad voters approved this Article AXXWreferendum to allow no more than 250 units of, low-income housing. However, this authority has not yet been exercised. ANALYSIS This discussion of Article XXXIV as a Governmental Constraint to the developmc affordable housing has been added to the Housing Element consistent with AB Article )cyxTv requires that voter approval be obtained before any "state public develops, constructs or acquires a "low rent housing project". Due to the potential uncertainty, and additional expense of a local election, public agencies cou discouraged from participating in the development of low and moderate income hc projects which would be subject to this Article XXXIV election requirement. The Mitigating Opportunities section of this discussion indicates that exemption frc Article XXXlV election requirement is possible, provided that one of two findings ( made: (1) the proposed project does not qualify as a "low rent housing project" or ( activity conducted by the public agency does not qualify as "development, constructj acquisition". 9 0 m F. RECOMMENDATION It is recommended that the fourth paragraph on Page 106 (Vacant Land Inven following Table 52) of the draft Housing Element Le deleted, and replaced by the follo. discussion. The above-noted undeveloped residential acreage total (6,621.06 acres), is not completely acc because all recent development approvals on previously vacant lands located within Local Fac, Management Zones 1-6 and 19 have not been entirely accounted for. Despite this, the rema buifdout capacity of 26,084 dwelling units, as shown on Table 52, is very close to the estil remaining Citywide buildout capacity of 26,576 dwelling units identified in Table 44 (pagc It is anticipated that additional acres of higher density land use designations (RH and RMH result from the use of the surplus units located in the Citywide Excess Bank to increas densities that will enable the production of aflordable housing, ANALYSIS This text revision is necessary to: (1) delete the inaccurate build-out capacity of 2f units and replace it with a revised tulld-out capacity (26,576 units) which is cons: with Table 44 on Page 75 of the Housing Element; (2) indicate that the undeve residential acreage total (6,621.06 acres) in Table 52 is not entirely accurate in that r development activity upon residential property in Facilities Zones 1-6 and 19 has not deducted from this undeveloped residential acreage total; and (3) that additional ac higher density land (RH and RMH) will likely be created as surplus units located v the City's Excess Unit Bank are used to enable the development of affordable ho projects. G. RECOMMENDATION It is recommended that the following be added after the 3rd sentence, 1st paragraph: 107 (Vacant Land Inventory). Hmwer, as dimmed ,uirhin the Gelzeral Plan Densitigs portion of Section III of this doc (page 79), there does exist in excess of 6,000 acres of undeveloped PC (Planned Communi[ LC (Limited Control) zoned property within the City. In order to enable the develop affordable housing, the City is willing to accommodate General Plan Amendment as neces: increase residential densities up to 29 d.u.fac. on any PC or LC zoned property or anj residentially designated property (see Policy 3.7.h). 10 0 W ANALYSIS This text revision simply cross-references the recommended text change (Page 79) tc Draft Housing Element’s General Plan Densities section (see RECOMMENDATIO above). H. RECOMMENDATION It is recommended that the last two sentences of the first paragraph , page 102 be de and the following text change be made to the Coastal Zone Constraint portion of Sem Three, page 102 (Coastal Zone). It is also recommended that the following new Obje 2.6, Policy 2.6 and Program 2.6 be added to page 118 of the draft Housing Elemen Until this revision of the Housing Element, the City of Carlsbad had mistakenly believed it3 be exempt from portions of Government Cocle Section 65588 and 65590 (collection of Ct Zone housing data), pursuant to Public Resource Code, Division 20 Section 30519.1. Tht now understands that it must fully implement these Governmental Code Sections. Specificall City must collect and report Coastal Zone housing data including, but not limited to, the follo 1) Thti number ofnew housing units approved for construction within the coustac ajier January 1, 1982. 2) The number of housing unitsjw persons and families of low or moderate in( as defined in Section 50093 of the Health and Safety Code, required to be prc; in new hortsing.developments within the coastal zone or within three miles I 3) The number of existing residential dwelling units occupied by persons and fa, or low or tnoderate income that have been authorized to be demolished or con: since January 1, 1982 in the coastal zone pursuant to Section 65590 t Government Code. 4) The number of residential dwelling units occupied by persons and families t or moderate income, as defined in Section 50093 of the Health and Safety that have been required for replacement or authorized to be convert demolished as identified in paragraph 3). The location of the replacement either on-site, elsewhere within the locality’s jurisdiction within the coastal or within three miles ofthe coastal zone within the locality’s jurisdiction, st, designated in the review. coastal me. After researching the matter, the City believes that it is not now possible to recapture the d6 particular, regarding affordability) from previous years. It is possible to conclude that due recent adoption and implementation of the Growth Management Ordinance, only a few hc units have been constructed wlthin the coastal zone in the recent years. In addition, we I that very few (if any) affordable housing units within the coastal zone have been demolk converted since 1985. Realizing our responsibility, the City will henceforth monitor and r 11 0 W data on housing units constructed, converted, ad dendished within rhe coastal zone, as in& in Housing Element Policy 2.6. OBJECTNE 2.6 (COASTAL DEVELOPMENT MONITORING) Identi& monitor, and report the number of aflordable housing units constructed, convert6 demolished in the coastal zone. POLICY 2.6 Pursuant to Government Code Section 65588 and 65590 from January 1, 1992, thc shall monitor, record, and report data on housing units constructed, converted, demolished in the Coastal Zone together with information regarding whether these are affordable to lower-income households. PROGRAM 2.6 As a function of the building process, the City will monitor and record Coastal housing data irtcluding, but not limited to, the following: I) The number ofnew housing units approvedfor construction within the coasfa ajler January 1, 1982. 2) The number of housing units jhr persons and families of low or moderate in as de$neri in Section 50093 of the Health and Safety Code, required to be prl in new housing developments within the coastal zone or within three miles coastal zone. 3) The nrrntber of existing residential dwelling units occupied by persons and fa or low or moderate income that have been authorized to be demolished or con since January 1, 1982 in the coastal zone pursuant to Section 65590 l Government Code. 4) The number of residential dwelling units occupied by persons and families or moderate income, as defined in Section 50093 of the Health and Safety that have been required for replacement or authorized to be converl demolished as identified in paragraph 3). The location of the replacement either on-site, elsewhere within the locality’s jurisdiction within the coastal or within three miles of the coastal zone within the locality’s jurisdiction, si designated r‘n the review. These data will be reported in the City’s annual housing report. FUNDING: General funds - (Administrative only) LEAD AGENCY: Building Department TARGET YEAR: 1/92 - Begin capturing data 1992- 1996 - Ongoing. 12 e a ANALYSIS In response to Comment 30 from the State Department of Housing and Comml Development (see Exhibit "A") and as indicated in the text change, the City has detern that we mistakenly assumed that the City of Carlsbad was exempt from Government C 65588 and 65590 and will now fully comply with these Government Code Sections. incorporation of Objective 2.6, Policy 2.6 and Program 2.6 is necessary to indicat commitment of the City to comply with Government Codes 65588 and 65590. How we are unable to capture the required data from previous years. I. RECOMMENDATION It is recommended that for Program 3.1 (FARM WORKER) Page 119 of the draft Ho Element, the TARGET YEARS 1991-1996 be deleted and replaced as follows: : TARGET YEARS By first Quarter of 1992.- Meet with local farmers and advocates to , the needs assessment of permanent and migrant farm workers, aggressively pursue grant and siting possibilities. Continue efforts thi 1996. ANALYSIS In response to Comment 19 from the State Department of Housing and Corn Development (see Exhibit "A"), the City has committed to initiate discussions with the farming community to discuss the housing needs and potential solutions for homeless workers and migrant day laborers. The specific implementation action and time 1 recommended in response to H.C.D.'s general request to "include more specific implementation action time lines to demonstrate the City's commitment to implement the Housing Eler Programs". J. RECOMMENDATION It is recommended that the following implementation information be added to Prc 3.6.c (IN-LIEU-FEE), Page 123 of the draft Housing Element. FUNDING: General Fund (Administration Only) LEAD AGENCY: Plarzning Department TARGET YEAR: Begin strdy in 1991 - Adopt ordinance by July 1992. 13 0 0 ANALYSIS In response to Comment 26 from H.C.D. (see Exhibit "A'), this specific In-Lie1 imp2ementation action program and time line has been added to the text, This inform was inadvertently omitted from the draft Housing Element. K. RECOMMENDATION It is recommended that the following implementation information be added to Pro 3.7.a (DENSITY BONUS), Page 124 of the draft Housing Element. TARGET YEAR Draft Ordinance 1991 Ordinance adopted by the first quarter of 1992. ANALYSIS In response to Comment 24 from H.C.D. (see Exhibit "A"), the TARGET YEAR for ad< of a Density Bonus Ordinance has been established for the first quarter of 1992, This date is consistent with the City's commitment to draft the Density Bonus Ordinar December of 1991. L. RECOMMENDATION It is recommended that Program 3.7.b (Alternative Housing - page 124) be modi: include a reference to managed living units and second dwelling units as follows: PROGRAM 3.7.3 (ALTERNATNE HOUSING) Corzsider devekopment stanciardy for alternative housing types, such as single room occ hotels, managed living units, homeless shelters, and farm worker housing alternatives whicl assist in meeting the City's share of housing for low and very low income households. AL alternative housing projects through a Conditional Use Permit or Special Use Permit. 7 will also examine the existing Second Dwelling Unit Section of its Municipal Code ( 21.42.01O(ll) (A)) to explore means of better encouraging and facilitating the develop affordable second units. ANALYSIS In response to Comments 27 and 28 from H.C.D. (see Exhibit "A'), the Alternative I- Program has been rewritten to: (1) reference "managed living units" as an altc housing type; and (2) commit the City to reviewing its' existing Second Dwelli: Ordinance so that revisions could be incorporated which would.encourage its' use 14 0 a development of affordable second dwelling units or "granny" flats. A "managed living is a unique type of affordable dwelling unit which is a cross between a SRO hotel r and a studio apartment. In that staff will be bringing a Living Unit Ordinance ,to Plar ' Commission in the near future, it is recommended that this unique product ty~ specifically referenced under Program 3.7.b. of the Housing Element. M. RECOMMENDATION It is recommended that the TARGET statement for Program 3.7.c (CITY INITTI DEVELOPMENT), Page 125 of the draft Housing Element be revised as follows: TARGET: Approximately 200 new units. Of these new units, 100 units )c aflordable to very low income households. ANALYSIS This revision is a text edit ta clarify the proposed TARGET. No substantive changf proposed. - ._ N. RECOMMENDATION It is recommended that Policy 3.7.e on Page 125 of the draft Housing Element be rc as follows: Public Facilities Fees (PFF) may be waived for lower income housing projects pursuant i Council Policy 17.5.e., which states in part: ... ANALYSES This revision is a text edit to clarify proposed Policy 3.7.e. No substantive chang proposed. 0, RECOMMENDATION It is recommended that a new Policy 3.7.h (GENERAL PLAN AMENDMENTS) as fc be added to Page 126 of the draft Housing Element: POLICY3.7.h. In order to enable the development of afordable housing, the City will accoml General Plan Amendments to increase residential densities on all PC and LC properties and all other residentially designated properties. Any proposed Generc 15 e W Amendment request to increase site densities fix purposes of providing afordable hou will be evaluated relative to the proposalk compatibility with adjacent land uses proximity to employment opportunities, urban services or major roads. These Gene Plan Land Use designation changes will enable up to 23 dwelling units per acre, an conjunction with a twenty-five percent density bonus, up to 29 dwelling units per a1 ANALYSIS Consistent with the recommended text revisions to Pages 79 and 107 RECOMMENDATIONS 'ID" and "G") regarding the City's willingness to accommc General Plan Amendments on any PC, LC or other residentially designated properl enable the development of affordable housing, this new Policy 3.7.h is being recome for incorporation into the draft Housing Element. . P. RECOMMENDATION It is recommended that Policy 3.8 (portion of City Council Policy-No. 43), on Page 1 i the draft Housing Element be revised as follows (i.e. strikeout/underline format): POLICY 3.8 Pursuant to Council Policy No. 43 {which is herebv modified as indicated): Residential development that does not yield the maximum allowable number of units the growth management control point are considered to have "excess units". These I units are allocated to be developed under the jMowing priority. 1. Housing development for low and verv low medw~? households as d&n 2. Senior Citizen housing as defined by Carlsbad Municipal Code Section 21 .I' 3. In-Jill Single Family Subdivisions, zoned R-1, that meet all development star; and where lot sizes are equal to or greater than adjacent subdivided R-1 prop compensation, jhr some signijkant prrblic facility not required as part development process. 5. Projects proposing a zone change fronl non-residential to residential based following findings: a. The property was zoned for other than residential use on July 1, 15 b. The property i.v compatible for residential use without significant miti) Cafijbrnia Government Code Section 65915. 4. Projects within the existing general plan density range that provide, withour C. The density ofthe project does not exceed the Growth Management C Point of any adjacent developed residential property. 16 0 m ANALYSIS This minor lexr revision is necessary to comply with the revision of California Govern1 Code Section 65915 (statutes of 1989), which references very low and low inc households only. Moderate income households are no longer referenced in this State ( Section. On adoption, this change would automatically amend Council Policy No. 4 Q. RECOMMENDATION It is recommended that a new APPENDIX I (GROWTH MANAGEMENT), as follot? added to the draft Housing Element. See Atlnclzmeizt 2 (Appendix I) ANALYSI s In response to the State Department of Housing and Community Development's Com 14 (see Exhibit "A"), this new Growth Management Appendix has 'been added to the background and purpose of the Growth Management Program; (2) to explain the sp provisions (Le. Quadrant Dwelling Unit Caps, Growth Control Points, Local Fa Management Plans, Excess Dwelling Unit Bank, and Financing Plans) of the Program to discuss the Program's temporary effect on the production of housing pendin; completion of Local Facilities Management Plans and Financing Plans; and (1 demonstrate how the Program will not function as a constraint to the future develop of affordable housing. Housing Element, The primary purposes of rhe Appendix is: (1) to explair R RECOMMENDATION It is recommended to add Table 40(A), a cross tabulation of identified constraint program recommendations that offer mitigating opportunities, to follow page 70. See Attachment 3, Table 40(A) ANALYSIS The table will facilitate an understanding of how the City intends to respond to idel constraints. 17 m W S. RECOMMENDATION It is recommended that the demographic description of the homeless population whl mentally ill on page 54 be revised as follows: The mentally ill accountj~r 25-30% ofthe homele.s.s, due to the reduced funding for mental 4 services, generally, and, particularly, due to the lack ($provision for housing when the popul of the state mental hospitals was reduced from Over 30,000 to 5,000 during the 70's. ANALYSIS This change is in response to the comment made by the North Coastal San Diego Cc Alliance for the Mentally Ill. T'. RECOMMENDATION It is recommended to delete the last sentence of the second paragraph on p. 64 of the (STUDENTS), and add the following paragraph and Table 35A. Full-Time Equivalent (F.T.E.) enrollment during spring semester 1991 at California University San Marcos was only 404 F.T.E. University planning oflcials state that by aca year 1995-1996 the University will he authorized to enroll up to 2,750 F.T.E. Also in 1992 the University is scheduled to complete construction on 600 student housing units. See Tabl TABLE 35A 1 PROJECTED STUDENT ENROLLMENT AND STUDENT HOUSING AT CALIF. STATE UNIVERSITY, SAN MARCOS Academic Year Enrollment unknown 200 apts. 0 0 0 Housing Units Equivalent 25,000 2,750 I, 700 730 404 Full- Time 2020+ 1995-96 1992-93 1991-92 1990-91 400 res. hall Source: S. Chafin, Asst. V.P. Physical Planning, CSUSM, 7/91 18 e * 4 QJd 'cQ- 52 0- $2 s2 E$ SE 2: -u m P 01 .2 ws yJ 3s - z3 e': uw @Ju a.5 YG 00 GU ww win aJ 1- -2- -5g 35 2 Y" ou E vo 2: %g 3 g2 .r! s $+ zg 22 2lIli .- VI .B 3 m bod +LC0 NI 5 :* x 5. mO 5% w 5. $2 x .; z;, 'E 0 *a 42 26 ab mz 80 3-2 w-a 'c CL OM x .e ?$ -am w -_ wa -a- mc - - .- wia SI= s 'C .41 0 "u 4% !I : 2' 2s :5 .- . -* ME3 .Y .E mM z$ Tt 02 Q, - s",s 4; + 5 sG '@ :! 0: iL. u 3j "4 J 'I) & -- tJ -2 ,-? ,.> Lr: k! '3 i Y 2 0 ? a m i; 2 ea4 oI 4 54u r( ZiQ 3 aa esg ; oI L4 x m- ._ . - E P a 5 I5 L m L i3 2. c, al 0 E - - -? P M - n 2 8 c1 g s zi 11 P k S8 u, 54 - nl. gG 3 E V 3 7U3" Em- 0 u&% uQ u Jtw5<Jo0 2 zj LLl .s a CI i$a+"= s,q Zyi;8fiua - Q)v!azg2 W~&3zwe2 .- a-vwz a, 2$53=-.2 o= g 'S pggmqg .s 2 2 $5 8 0,3= 8 2 .$ 2 ; 12 %, 8 a: 28 L. BZz2,g.g 6 p Rt;u f 8 ?$ ,; g = & 29 o*oge,t;~ 32 0 u 2 p e * go ga..+g gv.l'U;z &S 4.2 ;;i s EI 33pJ$g, 0 0.2g.g e $ "+ 8 ass$ 35 .$ 3; 2 1 24 F&Qt,$ A5 g.2.g -3 mai- a" * w.3 Up) 0 2 S2m 'gsn~~;u 02 z abvi a UZ Q) ~umYOc0 em 33 2 zz a .- g 6 .s ,g .%u 8.- a tag aa,meL.a8 f? 8 ii 5 I 1 z - P (1 * w M - a 0 r E j V I z I (1 d E B 9 8 3 3 9 L .I 3 a Q) g E s 2 gf 2; .B d +r' eg 32. zz L2 'f .9 e, +r= Brn a2 -3 &-" $2 .- 2. U z 8 6 9 e, U 3 9 - .- * m * 3 g $5 :4 .- 2 .5 2g gB 2; :.tj a- 0: .F. :E zg y 'a .9 t 2: L. .- mu rna *m a- P- .Is 7 01 C@ E aJ .o 5s 0 z 2.52 m; "m E w . 6.9 E 8 5 2 a Fz.2 0 37w .d .z ,z % z 2 a, ,-9 0 Y 8$Q$j2E c 8 ZG.22 8 2 Urn.$ w Q$:z5 2 ~Q-~ $ s h$.mpx8g amZaS2 3s 0 w - 2 m EVZZQ m 0 2.5 ZTJ E-D E 'i szbs;& -2 a 5 5.3 g .c .$ ; sz 5g 2 2;: "3w v) 5 2 2 e2.p Y &+ g $ g.gg ge52.$$ diqa llJ+ z% E::z 73a.c w - zz a42 E-as-5 z xs '/+ m v) hv) w aw E.y1 2:s u 0 7mm0 m-i v1 2312.; v.: 0 v) L.; E ml ~88"az-g bl .- ?i E.% 24& $ 2% 2.2 2.2- m - CQS L. c) $0 22a 9 s8t;2 rnL.2w 6-2 b u + O,Qa $ 2 'i I$ h"2.2 7% 55 ~ osO,,a m c, '5 g aBz 2 2 5 242- m a-9 .w $.rn m2-U 2 -3;g c 2% "X mmng5 zzu 0 w m-5:- C wsocg 5:.2.2- w 5+gM -2 5 k 0 .9 z.g.c M 0 x ""5 EU.E gx 8 wz-l w 06 &S* " *A v12- -g ejsz -wT5 2 cZ c.( w m **am 2 z2.- 10 =ww rn ma c -56 m m aJ a+ m > Q 2my1-3 E29 5zMC Lnl e d z. g 2 4 Y 0 L. E aJ L, QJ y1 - g a .$ kC, E oa, OPI a.4 m =mw r: a t Ul4 PIheCQW QC, h= 0.4 c 0 Ul PI t7kU $2 PI= -4Ul mq I c WdlVICYbl 4J403QP)QPIam X N-4.4 k c 0) bl t7 -.IC, ac, t7 4 k a, CC, k aa 0 0 0) 3"tW 0 0 0 P) k VIflGfl4iqU.nPi P) eo kU4 k f& a, cmPIa .W u.4 m C, PI ma c h . s m-4 aE a4 C ww lu tom 3 a.4 (d 0 CLs kUokek.4 C, Ulm wm CUlPIPIU -C, 0 9) 8.4 C, 4a * PIPIQ OQPI m saw N c $4 m.4 as UlkPIQ.4 aCP, 1 GQln CC, U>mO Ob Ul E F*-IC, PIC 0 %* z.2 8 ...52**a mnmmm~srn~ca, = oc,sdn 5 n m-4-1 m o > Q t7.4 k 0.4 ln k C a-4 E oc gal PIQSrdaC, PIlnmlnElPIQk F: 27: b15 El22 P.55 e42 IQ 0 3 Ul h.4 YC,X U4QlDP) OhU -445 dB C.44 4 PI b a a@ 0 V.2 a5.5 WHC+)rn a aaa 0aPIm am Ee dd 0 uu4aUla c, 4.4 0 C 4CI E a *4 C QC, 0 *E m 1 Ll-4 m 3 eo UPIb mcx - IQ o an m"tw E ~ka *1 aa a ~>ra ac, Q 5!$mg9$%E:s 0 0 G4 G.4 u910 tf5 ah0 *hoshaa hSU)OPI 0usarJ .rl a= a a 7.4 v) a rl &Lab: U.4aTsmtoW N . ECPIEC~~QC~~ - ra 2 $ 8 * P fk oiZ2 is2 F .;rt; &a a m 0 .* a - 8 e, m .E. 2 - a e, 4 - 5 a, 2 *e 04 eo .s 3 35 5s 22 zg g3 !$z 3 .c 2 ji -0 .- 8u 8 20 'CI 'e, ma 4 Saga 0 3: 83.50, 8 0.35 = m': 2 5- g -ma5 0 'S L- -06% $284 s.ag * 4;2i 2 Q 2 Fg. 2 9Pk 4zg 5 -g 8" 0 'k c 0 2Jas i :.;+ .f! a.2 6 e,sG u 6.5 a O: 84 8=, gsl g= e, .9 $ = u *.- 9 fi $ .E 3 2 .z 'j; g2:z 0 e, .- E <,a& e," 6 -U .Y m E= Urn 0 .- *e,.vw 8" m + Sf: e, u .Y .9 da 2.3 .$QZ .'" 2 u g "84% 30 7 d 5!= &z; &?E 3 $;$P 3 Eg$ g Y$ z2.h i i-gz $3 $2 z;e,g e, m=+ 1 ,%-g 2.c ,"I .: E .a 6 i; p g2 &g 435: w. L-pi "aig5 ;= 2a- ?aaa ..8 w2 azzz =% d m 6.3 ZbS-&% a e.0 o s 4 .3 .f! 311, g .a 0-8 9'1 2";; . 2 .s B 9s 2 .s a 'G 3 22 9 - &$% ; i .g 026 M .s -0 mu .;; g.3 a .E 8 ij g2 c P vi 2 e,; m c" " e, 3 .9 8 no g; e, .* z5g +Sa u$" a0 g3: Z64 43j 4 - e, P B a B 9 - m E 2 - B d - 3 * e, w .a Vi ta $2 z8 =e, 08 Sf2 ob .s .f! 43 32 89 2- cl g '5 .- m2 Ue, 2: -n -0 Ti H 5 P L. * 3 Y E V 3 5 I e i 5 M 2 b & tn * I -g g u s e, L- M.50, e, s on o sl$.9*sl m CI e, ag g.; *%X 02z lay e,* e, 35 & !j%Z$':+ e, us 0 s,e, 0.8 3q .N z El - =$3*,36 e,uu "g 3 -g g .p .Y ;>3 a.: 16 e, 2s t ; $< 893 2-3 '2 'S 3 g =m% 2 p, 3 Lr, ..us g .a 2 Z 34% 2.g e, 84 m 8 e, g $+$$-X 0 0 o 0 =.BE j p.52 c 05 8 .a5 E2 2-7 maa E@a 8 gs !a .§ -=o*am s aBu$ 39 $6 82 2 2 .g gi.; $ E L- 'Z.;a.f!d? i &*me,PI *naiL2g uaae,;;;g] E6 8Zsl &< -1, 4 m * m v) P) m 5rO -1u a, a, k 0 P) "4 $E2 4 .?tJ*.;i gcr $3 a, gu;ullJ3+J$ zc.4u~~ 5 a,% commm Bu. u B u) g.; ; w Ea a.>e -E 0 -4 mw E a, E a cluaromoara m0uLl CmBm E-4 E a, aac ou 0.5 au m 0 4 m u h.4 :2aaumfaE Of da,Lla,uma 0 u E ou m a, 0 sr3 C5aOek u 0 U C 3 O73.4.U 0 ou EV u acmua,m m same a,a *a a, E IC,-4 c . ma PO 0 mammm *ma uomormxe a, a, m 0--4a v a, acrccc cra iha .&* G5.5 cu me k m o-z u:4k%kx3w a, au a, E u 0 0.4 uaoc oa,co mOImuuI k P) 4JmaoP)a ua c)U U+d 5 kQ C wo L: 00) 3 IJCr(4Jq134J - c m k uPIu a,a,uE;lmm>I 0 B amcc- OEE suo= 0.4 &l E v.4 srm m 30-44 a, c, a,-4 L, m > O-n@.4 kc, omw kkla,a, kcaomc E u1 B 04 -71 Baa, 5umm ~cou4~~-4n oo;*a ad :; @%PI f %"% c 0)s la -a 0 0-a BQ+P)(UmUU- a!! a e -I a DO EO m-4 "I m 0 cu 0 u 5 4-4 v E -4JrnuC.i E an 0-4 ld 32.5- m ham -4uw m E a00 u -4 -a&= 0 w--4a, rcu BE OkF 0 amE k a--4 .d crlmc cu ma> u.4 on a, e, -e:a, CP)DoQk mau k m c,O ova, vu > ma, I wa Ek3Od 4 4 0 Narc 22 EPIkE Fk 0 a, PI u -4 a,u mu 0 LC E a,--4* a.4 0 EBc, s 4JW 7uu --4 o mw ~n "22x2 P trh Q) k.5 EO5 82340 0 b4u aXaC, d COB *@@a, 4Jw aa Camam pfL$ 0 PIC, 1 E uc cw uPI m PI vas, cw Ec 0 e4 0--4*a :u+, a, -.-I E C, ul P) 4 ,ijZ $ g.2 g3 u %2 *do ma a,u %E E *mu rcc Ud 0 mPI aem u ma-4 k I *u e a, k cue kt0 a,m3010 uoo it 2rcuu a a,mEE a, mrc--4 a, a, k* uu Be e can *a,*a,OO E B ourcrc a,a,EOa,a, 5.2 m a5 5 : g4Xaa a,** Fd e P)kU .Ed . -4 -4 *a, *mu e .= mr wum @a, 0 a,* 0 ,moa, Em E E a-4 a, -4u c m F oe x p: *oma,c +as 7w Ll 5mar ac 94rO m 0 F.4 u a, mac: Gi.4 PIa,ma, m4 E-4 m mumc -a, c Ok E4 a, asu> aJu am@* E E-4 k arc h0 c -c, .d am ca,1mPIm a,!3mmrca, uuu > m*uma,c a m a--4 a--4 0 a 0 k.1 nr4awPlyr ' 4J $E kg O? ,"cPIa a.: PI -4 4 CJ E-: E 0 f$i?:a, a t-2 : 2 2 @'JL dl& :g*: E mmuu f Ea:" : :!2cg uzsoa "Sf z :*lis c Hwha 2 43z3 a >T3hZ >3 Ll uu ow k maam a mm*u LIE m @E E 1.4 a, a d 4 U.zw p) m me-4 5 u a a, a,u as E %Band 50 e, Ea,@ (d a,4urc UI"EUIE PI pIP)P)PI ha .+a a@. k 4 a* kC, maac c a,"PIPIBP) e4 rc rcYk 0 5"{E# 3 2 z.2 %$ a, m0>4> k PICCEa, m kUa,05 m cm 0 5E-4 0 a, 4ma *. 2 ; "a'"55;; 2 a !s3 !-$2.! 2 G$"- auburn 0 LC a,U& k -i>hu)wwP)a,mrl uau a,- u) Ll m ao u m.4 a,w m am E P) Q) ukw mHQ ku FauC k E a, mu 4 PIc-4 PI omcmmca,um> c EO -4 u uu-d unp-4u.r( wwa-5 0 m 3 01 a u.4 0 f yz -g 5 aEi%u,a,a, moz ao:hh$f.;:SC5 -44rcuc 0 a, c k wmml13~uo"1a, k E L+uw.-4a Llw auma,ua,>mao 0 0-4 $4 a, w us m 0 am mu m m -no am& fu m& m.5 g4 0 g dG!lwS$a Eu*$ m.4 vu -4 c a, m I a, m 0 a,u m e ad mho kc a,FU mrc .Im .FEE 4 mrcuu*a m 0 Ed c 10 a, me u u md aFrn-4 a, o u mrc3 iu 223 hX am arc 0 0 E EO H-40 -ne&& a HUYWQIYQI I dC ac k u) E c m E 4 FO 0) m4 FE Q 0 B.4& Q) E 0-4 2$d19rk$a,$& aemxao I ra $3 E! w bl Em.-4a,3~ iZ455525k22 a, 400 nktio E u aumuu owcu mIEu Liw a,wuaea (d c dEC kQ) FCammuLlB e m oan c o m s E4 m I 4 e-n a, 0 >--4 o.-40 ou u) c7 c7 * rc) 3 i 8 1 .,2g a ew, fl 2s $a x EG5 25; os$ U'82 L2-S 299 $$: $E a g F .$; 3 -33 0 0;c 5 3:'g; &s$ $2 3.; gz .s E, b zz.2 & j:"Zm on$ .?Ens p B .I 229; or30 2 58j 2 0 % .g 2250 2=.§ 3 pzc Vp aE 3 L% q: UI 0 .= 9" C* Y ruo- + ufi 0-0 *m 2i -p fg 5 .g "2 .- q gg .9 ; gE -3% ear vluEL .2 P $ on UI gs H 3 z .I Z?JZ 30% n -2 .- 0 C-g -2' 2s 0 4) ** -0 "i - CY 99 7)' a .- - "b g2; gzg + mnbm-* 0 $8 9.- ZY0-06$ 2 0 P Epg.z z.v 2 2.z 82 g 2.9 e 8 a$$ g." %> m'5.94 .- n aa.5 d) "%n.n ~ 2.5 9 9 M P "1 g"Mg.2 - 2me 0 0.3% 0 9 'G - .- El ".UT 23 fi a'= .$ * abz n 4 Q2-s OfiQ * 2 g = nl! $uC a3'"P. g gu = fig gZna933 352 . d 5 g E;$ iy; ruvlm-un pa t .g a .ii; a - B g.KS.5 n.U WB 949,; E -.sa YX% g z2 2 2 -f 2 - * 5 ggs 0 8 c; 9 !a.g$$$ T3 ;af z $ E 8 E 0" M 3 .s 2 .- Eptfm I; ao 3gS 0 .- 36 2.92 54 + $"E 2 fl .z zgn .- -0 .= .g !ids am 5; 159 aea 0 .& 995 $* " * E% = ie a3 2 3 .$ B?;. .g 8 3 $3 g ;-q -pea us 0 3 .Y Q && 9 ZL e A5 %-E 2 02: * 53 c. moo mr- 6 .- m O', 8 2 2 .E g i $d g &cd $3 + - g 3 3 n c - B 3% oi - Bs $2 ZE II 33 VI -10) 28 5; iy q ME *a 9; $8 i2i 3s ab zz q D - aias g .:gg 5 i: 72 2 ~EQE g2-ga .z ; B Z .2 * 8 3.5 0% a" .t a" 5 g .[ .I$5:.2 : f!i$i 8 0 SO 0 g223.5 .3 - .EJ & 8 - $fa-02 i g am9 090 ..zag g $3$gm 23 e$ $ -3 0 2 .;;gs,S Q$g8 4.81 p ~ -.& zsa E = a0q6 an mo :a B .g 3 2 8.2 1434 3s pu 2; 06 0 a24 224 ,-2U"s%.i a- .- .- * aV' 0 u.2 b 2 *a - an-.%.o .- mL068 0 0 m Ll 0) u 0 c ua, m a .4 c aE! Q)c, Q) -4 c -4 Y we E.4 m 0 m Ec 0 -4 u u1 .4u mu E UE !Y f E ;.?: mu m E-4 12 Em rl 0 me@ Y c, Q) E.4 1 s: o>osm OC cu3m m -4 -4a 0 0.4 u ma u Q).d rl E* rn Llu c.4 919) 24J 4 m4J uE! E1 CrlC CEaIUE1. 9) hud Q) 4JICIEP)U) Vlt 4J09)uQ)v bdc, 0 mu> 9) mu vrm 4 I Fcu P)c: km 0 mu4 Q) kZCOrn Q) ullu Q)-4 E 1 9)cuu 9) kta 1C 0 kc, mw e 4JQ 4 1mE. km -4kO &- uxas me Q) 0) > mmu -n a u u S"9wu c4Y .Q) la P)o - -mc Q)(:EO-d IC Ek 0 N 0) 0.4w u-4 EI k u-rl -4 Q) rl rll a>rl Q)-4u>om .4 1-4 aE - 4m3 4) Elamam Fa4 . e u 0 E 3.4 u.3 4J u rl $Q)cwk kC p.: z .I: 3 8:: no a 5 9)YS EIU a3 5 5 P -9.4 8u -a oxo 1 19) k ma.3 uz r; 007 .I: e$r15 5 :.I o EC EOC .4 i mu E! EO co b cv 00 z 8 B * 3 8g c.32 Lr. .: s St4 kzer: hg 2 pgpz;%2 0 3 $2 q3ms"st,g % @% ga a 3 J g.3~ '3 o %..y - - ,a z g * ~1.- ZE-&&% as e m g 2%.5 g=z.'B .- 22.5 gp a2 n~E~~$~~ o 2% 2 $r 5 gz ti 2.2 = - E t; .o ..,.Eg;; cog pa- 3.z 9 = 5 4 m E .B 2 ,?% mg 4 ' a 2z$l E= 3ggsgL% QJ 2pQ0.5 $2 2 2 2-2 0% 8 0s. -* g,s 5 -X 8.0 xo a+-.,* 8 z.5, €452 m a'= C-gs :za % $2 9.2, az pQ g 0;iq- EE .I y&iZz 2 82 .Ga *C.~O c) 3 '(n 8 o8 o .- oz$Rg +fig e '9s g'E!,g6, M ns zEBJi{;jg 0 a.z c. 5- 0- a 22 a% QJZ Q) a 2,g.g 8 g 7 = gii~u~un~d 90) + .- 28s: .o .% g .z - 0 * a.& a5 83 : q 0 eJa$ w 2 gm.2 0 os%='5 3 ,.P 5 'pa 2, g a qg; pQ g o,3e 0 s, 8 d 2$:-%3 gs gg as, Me2 zwsq 51 j- "z:.; 5 .F -2 ,x 0 E::=z +z 0 0 6;; Et2 QJ QJ22 >';;e30 s 2 gJe i; tg.g.'B 8 0, 3% a3 e 9 D B.+ Eo"& 8Ses8 .o 38 - 8s m.z c 0.0 El L .- w 5E0cc c -a '1 3 m n- E + EEE- z! 3-2 si;;tEm 33: 8 3 20 p .- 2.2 Mi; 2 .9 .z .., m -0 g -E+ 5 3i.z u gwti *w 9 u u .p .! 222:: 0 'S zz g a QJS 3 1: 2.2 3 2 :a.s j .f .9 2 : 2 5 .: $ 9 tqe; ui; u 0 ."," g LA$ 8 : w 22 k 2E::E qg 9" .% '? 0 Q) LI Lgzg 25ad; g L§$3 om mijs .s 91 5 6 0" - z! o.Qg., + .,t;yeao I-b i3 m a m 5s $ sg 3.8 g $ g; p&g S3=22:.;$:5 " 8 4 6 gu e3.2 "5 g8 E g.g%.83? 3QJQJg =$a 5 ~;Lse.SBgX ,sz$o*a $wE:."g*%$s - O g ,$ 8 .El 5 3.p E$=, 6 5, 6-b 2 'E .! 0 4'0 > mc.Ga"'" '1 * 6 P a g.* 'c) ou=i 5 0: a $2 s"aa$gxg .s 2-0- 3.3 8 i32 52'2 8-d a.2 a o m E...S 3*Tl.%= Q $p321:jz .s P p, Fa s, 2 % 42 d., E Q m QJ, E- &g+E88%gg QJ*v~zS=au= zss z 9 Hz{.; E=.:$ n"2s$z9 - a E o ti::3.~- g.s * g '3 Ma E !j.v"gE.8zq EBI" mu2~:Q)-~ 1" pjjf 2 ?j p %$.urn QJ 0 Ea-3 0.5 ww~ .on~~#z~ d $N 5Z.i Mti d $9.2~ m WJ = 03 ,go29~= a-o o a78 S o E + e 0 3 B 8 * 9 B ,a9 ZG %g m" kZZ .2 M L .g $ BB 4: 6 -am *mz jnz ea =m* ET8 -4 9 E e-& 8 :z 42 1 =-3 "Y 5 !z% 5%. @g* Jg7 zq g ET L. 0- a* ;;j i3 =5 h a2 $ arY * "a 3- ass m5 G X@* 3ag >OX * c: "09 4: 5 22 g e= e a3-s OP 9 08 E - 2 0" s it 2'3.22 .$ p % 9 2x2 9) g O 8 g.2 z 6 coszs.zgg; glp.pp"z- ~z.Y.=~~Z+$g+ OL. 2: gz z 5 oz+ 2 0 2 z:.j g.3 8 * sa 8. $5 g+ z.2 %a $sr*g.gSOnz9 gg24 2 O.% ?=$I pp p;:.= cF.& 3 ps2*e*zzpJz i $2 gg'g;g $ 2 ' 3z9qJzsp,3 243 !$ p&-.g OPW 3 8 :lazg$; is.2 * .- gggaggg$2_"2 *w2 2gxa-p$g$Qe "'2 Q .Y oyma2 g p 2%'0,4 n3 i-W.3 o 83 .g .&fp;;;+=" Giz 88.S3 =seaz+ B t SI ti 6- v-3 0 asp3 8 p-, 3.3 3 H S - !&0?29 * a3 b.ss a ,. E Q a,s * 0Cu.zv * E .- oa.Q 0895 OE 95&0;6 :Ea2 63 k3 m 8 u a rc1 3 B > m.e.5 - 2z; -fO UkOy 3 za 6 20 88.2$* fig3 8 %%Z3S B.5 9 5 - -;R~$U 58 $ d *: g s =- a= O a L.o 5 3.z .g 3 aofja 25 2 iij s P a p ojb E4 e2.f E,. -5 ; ; e 0 EXHBIT'W STAFF REPORT 6 f: \ DATE: JUNE 26, 1991 TO: PLANNING COMMISSION FROM: PLANNING DEPARTMENT SUBJECT: GPA 90-8 - DRAFT HOUSING ELEMENT - Discussion of Draft Ho Element and attached Letters of Comment. I. RECOMMENDATION That the Planning Commission take public testimony on the Draft Housing Elemen Letters of Comment, discuss identified housing issues and continue this item fo Resolution of Outstanding Issues and Adoption of GPA 90-8. 11. PROJECT DESCRIPTION AND BACKGROUND State Law and Recent Ledslation The Housing Element is one of the seven required elements of a General Plan. I Government Code, Article 10.6, the required contents of the Housing Element are sp and contain over 25 areas of identification and analysis including: population and ho projections; employment growth; and analysis of the elderly, large families, the hom and other population groups with special needs. The element must also contaj identification of governmental and non-governmental constraints to housing opportunities to mitigate those constraints. It must also analyze future housing de: by economic ranges. The element is also required to undergo a comprehensive re1 of revisions and adoption of the revised draft element by July 1, 1991. Recent legislative changes have added several important new regulations governing ho elements. once every five years, San Diego jurisdictions are on a schedule requiring the compl 1) There is now a requirement for the City to report annual progress ( housing programs to the City Council and to the State of California. 0 GPA 90-8 - DRAFT HOUSING ELEMENT JUNE 26, 1991 PAGE 2 2) The State Department of Community Development (HCD) must now con a review of the City's draft and the final adopted Housing Elemenl compliance with State Law. HCD must make written findings in which 1 determines if the element substantially complies with the requiremen Government Code, Article 10.6, Housing Element law. Prior to adoptic the draft element, the City Council is required to consider the findings r by HCD. The City Council may adopt an element that HCD has found to be in compliance with State Laws only upon the City Council's ado1 of written findings which explain the reasons it believes the draft eler substantially complies with the requirement of State Law. If the HCD has found the draft element to be in substantial compliance the requirements of Article 10.6 of the Government Code, there rebuttable presumption of the validity of a housing element if action is ti to challenge the validity of the element in court. Exhibit "A" contains comments made by the State Department of Housing and Comm~ Development and other letters of comment on the .City of Carlsbad's draft Housing Elen City staff will present and discuss the major issues identified within these letter comment. Public testimony on the Draft Housing Element and letters of comment will be taken. Following a discussion of issues by the Planning Commission, this item wi continued to a future public hearing date for the purpose of: (1) discussing s recommended responses (including potential revisions to the Draft Housing Element 1 to issues contained within the letters of comment, (2) resolving identified issues, anc adoption of the Draft Housing Element (GPA 90-8). ID. SUMMARY OF THE DRAFI' ELEMENT Review of Previous Housinn Element In Section One a review was conducted of the previous (1985-1991) Housing Elen The review focused on the progress of the City in carrying out the action programs 0: current element. The review is summarized in Section One (page 23) of the draft Hoc Element. Needs Assessment/Demomd&s Section Two of the draft Housing Element contains an assessment of current and ft housing needs for the City of Carlsbad. Identified is the large need for, and lac1 housing affordable to households in the lower and moderate income groups. The hoc affordability crises is a region-wide issue. The draft Housing Element shows that the Diego region is one of the least affordable housing markets in the nation. Contin economic growth within San Diego and within the North County area will increase 0 GPA 90-8 - DRAFT HOUSING ELEMENT e JUNE 26, 1991 PAGE 3 demand for housing which fits the wages earned by employees in new job and employn growth. The assessment also identifies groups with special housing needs. These groups inc: farmworkers, the elderly, the homeless, military families, the handicapped, students large family households. Often these groups are a sub-group of the lower-inc household group. They may compete with each other for adequate housing or sheltt The San Diego Association of Governments (SANDAG) is required, under State Law conduct an assessment of housing needs for the entire region. The "regional share" is portion of the total regional need which each City should supply. Carlsbad's "regi share" has been identified through SANDAG's Renional Housing Needs Statement (1: 1996). The objective is derived from a methodology developed by SANDAG that takes account many demographic and economic factors that include; job growth, past hou demand and vacancy rates, developable residential acreage and, particularly in are2 high housing growth, how well the locality has previously provided for housing in lower-income ranges. SANDAG suggests Carlsbad's five-year goal should be to build 6: new dwelling units. The City's minimum share of housing to be provided for lower-inc households is called the "fairshare" housing objective. This figure is meant to be minimum good faith effort the City should achieve in providing new housing opportun for lower income households. SANDAG has set Carlsbad a "fairshare" objective of 1: lower-income households over the next five years. Housing Constraints and OD~ortunities Section Three analyzes constraints and opportunities to housing production. Constr: are classified into two major areas: 1) governmental, in which a locality's decisi policies and actions affect the production of housing, and 2) non-governmental, in w market, environmental or economic actions beyond the control of a locality affect production of housing. A comprehensive list of constraints are identified in the draft Housing Element. T constraints may be current or potential and some may have a significant effect on hot development. Some constraints may be minor but, combined with other minor constra may affect overall or specific housing development. It is important to note that s critical potential constraints remain outside the City's control. Strategies to overcome these constraints are also discussed in this section, as are a r; of opportunities for responding to identified housing needs. Many of these mitig: strategies and opportunities are carried over to Section Four for implementation. 0 e GPA 90-8 - DRAFT HOUSING ELEMENT JUNE 26, 1991 PAGE 4 Goals, Obiectives, Policies and Prom The action plan of the draft Housing Element is contained in Section Four. In the prevj sections, past housing production and performance was analyzed, housing needs we identified for current and future populations, and constraints and opportunities for hou! production were recognized. In the final section, six long-term goals and 34 short-t objectives were developed to meet the housing needs. To achieve the goals and objecti 14 policies were proposed. These policies become the City's official position on issues serve to implement objectives. Last, at its heart, the element proposes 48 action progr through which the City will implement its housing program over the next five years. 111. ANMYSIS Planning Issues 1. Is the proposed General Plan Amendment 90-8, the draft Housing Element compliance with Article 10.6 of the State of California Government Code, Housing Element Law? 2. Is the proposed General Plan Amendment 90-8, the draft Housing Elem consistent with the other elements of the General Plan? 3. Are there sufficient programs proposed by the draft Housing Element to overcl housing constraints and provide for the City's "regional share" of the local hou needs, particularly households in the lower-income economic range and identi as the City's "fairshare" housing goal? DISCUSSION The proposed General Plan Amendment, a revision to the Housing Element, has I reviewed by the State of California Department of Housing and Community Developn (HCD). Specific comments on the Draft Housing Element from HCD are include1 Exhibit "A". When all of the major issues identified are adequately resolved or addre HCD will be able to find the Housing Element to be consistent with State Law an compliance with the requirements for Housing Elements contained in Article 10.6 of State of California Government Code. In response to HCD's comments, staff will draft responses, including language changes which will be proposed to be made to the draft Housing Element. These responses and text changes will be included in the Draft Housing Element and/or staff report which will be scheduled before the Planning Commission at, a future date with a staff recommendation for approval. GPA 90-8 - DRAFT HO AB NG ELEMENT e JUNE 26, 1991 PAGE 5 Adoption of these changes will bring the Element into conformance with State Law. The draft Housing Element has been reviewed by staff in context with the other elem of the City's current General Plan. Staff believes the Housing Element is gene] consistent with the other ten elements in the General Plan and in particular, it is consis with the City's Growth Management Plan. Currently, the General Plan is undergoi~ comprehensive revision and update. Consistency will be maintained with the o elements during this update through necessary revisions and amendments to elemen the General Plan. The draft Housing Element proposes an ambitious set of programs for the develop me^ housing and shelter for the current and future population of the City in all econc ranges. The City's housing program is designed to meet the "regional share" of housir all economic income ranges. In particular, over 20 programs are proposed to meet City's "fairshare" goal for assisting households in the lower-income range. Many of t programs are scheduled to be phased in over the time of the Housing Element's five cycle. Some of these programs will require the City to allocate significant resources. T programs are necessary to achieve the stated goals and objectives of the Housing Elen A brief summary of the key action programs is itemized below. The responsibilitie! implementation and administration of the programs fall mainly on the Planning Departr and the Housing and Redevelopment Department. Major programs tasked to the Planning Department include: Indusionarv Housinn Program This program will require master planned communities in the City to provide a mini1 percentage of all units to be made affordable to lower income households. A large nur of the City's "fair-share" lower income objectives will be met through this program. details of the program are being worked out and this program will be implemente conjunction with other "tools" identified below. Alternative Housing Alternative types of housing can aid significantly in meeting the need for lower inc housing. One alternative is the "living unit", a cross between a studio apartment a hotel room. An ordinance to customize this type of shelter for Carlsbad is in prepara Density Bonus/Senior Ordinance A density bonus ordinance is required to be adopted by every locality pursuant to : Law. The California Government Code requires a locality to grant a minimum of a GPA 90-8 - DRAFT HOU d 'ING ELEMENT e JUNE 26, 1991 PAGE 6 bonus over the otherwise maximum allowable density and one additional concessior incentive such as a modification of development standards, fee waivers, or in-& infrastructure improvements. Projects given approval for density bonuses are requirec make a certain percentage of units to be affordable to lower-income households or ol "qualified tenants" such as the elderly. The City's existing senior ordinance will be rev to conform to this State Law requirement. There are potential fiscal impacts to the if fee waivers are given, or infrastructure improvements are supplied by the City, Lower-Income Incentive PackaRe - Several incentive programs to assist in the development of housing for lower-incl households will be set up. These incentive packages will be utilized both in conjunc with the density bonus ordinance and independently. The fiscal impacts of these incent will depend on the amount of subsidy that is needed and the amount of units nee( assistance. In-Lieu Fees To assist in the creation of lower-income units, an in-lieu fee is proposed to be asse! against some private sector market-rate residential units. The fee will then be used by City to subsidize lower-income units. A non-residential in-lieu fee is also proposed nexus can be found between the creation of new employment generated from 1 commercial and industrial development and the demand for lower-income housing. nexus must be established by a rigorous study. Excess Unit Bank Residential projects which have been developed with fewer units than originally all0 under the City's Growth Management Plan are considered "excess" units. These units : be stored in an "excess unit bank" until they are withdrawn to be built in another pro: The excess units can be used to create additional density where such density is usefi achieving a housing goal, such as low income housing. A program is needed to accc for and expend these units. Rental Smw Promam - To determine current market rents, occupancy rates, and other housing data, a prog is proposed to survey periodically all rental units within the City. AdaDtive Re-Use and Small Lot Subdivisions Ordinances are proposed to bring about the adaptive reuse of older, non-reside] structures and small lot subdivisions to promote smaller, less costly houses. GPA 90-8 - DRAFT HO dkJG ELEMENT 0 JUNE 26, 1991 PAGE 7 8 mud Housinn ROrt The Planning Department (as required under new State Law) will produce an annual re to the City Council and the State of California on the progress the City has made i~ housing programs. The Housing and Redevelopment Department will also undertake major new progr; These include: Grantsflundinn Sources There are various sources of grant funding for lower-income and other hou developments. Financing obtained through State and Federal sources demand exter administration time to obtain notices of funding availability and to put together elig projects. The department will establish an aggressive program to find and acquire t: funds, Housin~ Trust Fund The draft Housing Element proposes that the City establish a Housing Trust Fund to repository for all funds the City may collect and earmark for housing programs. Land Bank Prom A program will be implemented to accept land donations and handle the acquisition disposition of real property which will be used for lower and moderate income hous Rehabilitation Promam The Housing and Redevelopment Agency will greatly expand its existing efforts dire at rehabilitating deteriorating housing stock. Under the program, the City may acc ownership of deteriorating rental units for rehabilitation purposes. Communiv Reinvestment Act The draft Housing Element proposes a program to evaluate the lending activities of 1 commercial lending institutions. Under the California Reinvestment Act, these institul have a legal obligation to provide credit/lending activities for all economic segments o population. An evaluation will be made of lending institution’s activities on construc loans, mortgage, and take out financing. The goal of this program is to create additi lending opportunities for lower-income housing. 0 GPA 90-8 - DRAFT HOUSING ELEMENT JUNE 26, 1991 PAGE 8 0 Low-Income Housin~ Contract Prom Lower-income housing developments built under an inclusionary program or developed subsidized using State, Federal or local resources will be required to enter into hou! contracts with the City to ensure that the units remain affordable to the inten households. The Housing and Redevelopment Department will monitor and admini these housing contracts. Annual Priorities The Housing and Redevelopment agency will annually prioritize the community's lo\ income housing needs in order to better allocate the expenditure of City funds. The housing program proposed in the Draft Housing Element is ambitious and long-tc The full implementation of the program will require a significant commitment of 1 resources over a number of years. It has been designed to provide real solutions to problems. ATTACHMENTS 1. Exhibit "A", California State Department of Housing and Community Developn written comments, and other written comments. 2, Draft Housing Element (distributed previously) May 7, 1991 CDD:rvo:vd e 0 EX-"' STAFF REPORT DATE: AUGUST 7, 1991 TO: PLANNING COMMISSION FROM: PLANNING DEPARTMENT SUBJECT: GPA 90-8 - DRAFT HOUSING ELEMENT - Request approval of the rev to the Housing Element of the City of Carlsbad's General Plan. I. RECOMMENDATION That the Planning Commission ADOPT Planning Commission Resolution No. : recommending APPROVAL of the Negative Declaration issued by the Planning Director ADOPT Planning Commission Resolution No. 3255 recommending APPROVAL of GPA based on the findings contained therein. 11. BACKGROUND On June 26,1991, the Planning Commission began a public hearing on the Draft HOI Element for purposes of taking public testimony on the Draft Element and lette comment, and discussing some of the major housing issues which were identified. majority of the public comments focused on: (1) the immediate need for, and conter Housing implementation ordinances and programs, and (2) requests for continuous p involvement in preparation of these implementation programs. After taking oral and written public testimony and briefly discussing some of the r issues, the Planning Commission voted unanimously to continue GPA 90-8 to Aup 1991, for purposes of allowing staff time to prepare written responses (inch recommended revisions to the Draft Housing Element) to letters of comment on the Housing Element. 111. ANALYSIS Fourteen letters of comment on the Draft Housing Element and one petition were rec as of June 26, 1991, the date the hearing began. One of these letters contained corn on the draft Negative Declaration. On July 10, 1991, a letter was received from the Aid Society of San Diego, Inc. These letters represent the comments of the follc parties: GPA 90-8 - DRAFT HO a! ING ELEMENT I) AUGUST 7, 1991 PAGE 2 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. California Department of Housing and Community Development Carlsbad Unified School District (first letter) Carlsbad Unified School District (second letter) Carlsbad Chamber of Commerce Project Future (first letter) Project Future (second letter) Northwest Quadrant Citizens Group and Barrio Group League of Women Voters - North Coast San Diego County North Coastal San Diego County Alliance for the Mentally Ill Hofinan Planning Associates Aviara Land Associates Limited Partnership Henthorn & Associates VTN Southwest, Inc. Fieldstone Company (Villages of La Costa) Petition (residents of Rancho Carlsbad Mobile Home Park). Legal Aid Society of San Diego, Inc. Of particular importance is the letter from the California Department of Housing Community Development. Pursuant to new state law effective January 1991, the State Department of Corn Development (H.C.D.) must now conduct a review of the City's draft and the final ad( which it determines if the element substantially complies with the requiremen Government Code, Article 10.6, Housing Element law. Prior to adoption of the element, the City Council is required to consider the comments made by H.C.D. Thf Council may adopt an element that H.C.D. has found not to be in compliance with Laws only upon the City Council's adoption of written findings which explain the re, it believes the draft element substantially complies with the requirement of State Li If H.C.D. has found the draft element to be in substantial compliance with the require1 of Article 10.6 of the Government Code, there is a rebuttable presumption of the va of a housing element if action is taken to challenge the validity of the element in cc H.C.D.'s eight page letter contains over 20 specific comments. In response to this 1 City staff met with H.C.D. staff in Sacramento to discuss the matters raised by H.C.C to determine what actions the City needs to take, including changes to the draft elel Housing Element for compliance with State Law. H.C.D. must make written come1 Copies of all of the letters, together with point-by-point staff responses, are contair Exhibit "A", attached to this report. GPA 90-8 - DRAFT HO ak - G ELEMENT e AUGUST 7, 1991 PAGE 3 PROPOSED CHANGES TO THE ELEMENT In response to issues raised by H.C.D. and others, staff has prepared a list of prop( changes to the Draft Housing Element. The changes range from the inclusion of additil data to the housing needs sections, to revised language designed to clarify points w were not clear, to proposals for modified and additional housing policies and prop; The adoption of these changes is believed by staff to be important to bringing the ( element into substantial compliance with the requirements of state housing law. Exhibit "B", attached, contains each proposed change to the Housing Element, tog€ with a discussion about why staff is recommending the change. N. ENVIRONMENTAL, REVIEW The Planning Director has determined that the proposed amendment to the Hoc Element will not have a significant effect on the environment and, therefore, has issu Negative Declaration on April 25, 1991. The environmental analysis determined tha proposed amendment is not specifically associated with any development project therefore no project-created environmental impacts are anticipated. There was one 11 of comment received during the public review period for this Negative Declaration. letter of comment and staffs response is included as Exhibit "C". ATTACHMENTS 1. Planning Commission Resolution No. 3254 2. Planning Commission Resolution No. 3255 3. Draft Housing Element (distributed previously) 4. Exhibit "A" - Letters of comment on the Draft Housing Element, together with responses. 5. Exhibit "B" - Changes proposed to the Draft Housing Element in respons Department of Housing and Community Development comments and other wr comments. 6. Exhibit "C" - Response to comment on Notice for a Negative Declaration. DT:vd July 10, 1991 0 e MINUTES Meeting of: PLANNING COMMISSION Time of Meeting: 6:OO p.m. \ Date of Meeting: June 26, 1991 Place of Meeting: Senior Center COMMISSIONERS 1 I CALL TO ORDER: Chairman Holmes called the Meeting to order at 6:OS p.m. PLEDGE OF ALLEGIANCE was led by Commissioner Hall. ROLL CALL: Present - Chairman Holmes, Commissioners Erwin, Hall, Savary, Schhhuber, and Schramm Absent - Commissioner Noble Staff Members Present: Michael Holzmiller, Planning Director Gary Wayne, Assistant Planning Director Dennis Turner, Principal Planner Chris DeCerbo, Senior Planner Bobbie Hoder, Senior Management Analyst Ron Ball, Assistant City Attorney Martin Orenyak, Community Development Director 1 COMMENTS FROM THE AUDIENCE ON ITEMS NOT LISTED IN THE AGENDA: There were no comments from the audience. Chairman Holmes introduced Dolores Kronenberg and Millie Lerner representing the League of Women Voters. I PUBLIC HEARING: 1) GPA 90-8 DRAFT HOUSING EU"T - Discussion of Draft Housing Element and attached Letters of Comment. For the record, Chairman Holmes announced that letters from The Fieldstone Company, Aviara, and Jack Henthorn & Associates, dated June 26, 1991, had been received but were not included in the staff report. The letters are on file with the minutes in the Planning Department. Dennis Turner, Principal Planner, reviewed the background of the Draft Housing Element and stated that during the drafting process, staff has expended numerous hours attempting to educate the public on the proposed Element. A public briefing was made to the Planning Commission at a previous meeting on May 1, 1991. This meeting is intended to receive public input prior to adoption of the final Element. At the close of this meeting, staff is recommending that the public hearing be continued to August 7, 1991, at which time a recommendation can be made to the City Council. Mr. Turner stated that the needs assessment has shown that 40% of the households in Carlsbad are considered low income, many of which are homeowners. Therefore, it is incumbent upon the City to allocate 40% of future residential development as affordable housing. However, since a free market has not been meeting this objective, the Housing cost housing. Element is designed to assist in meeting the need for low Mr. Turner stated that the Draft Housing Element contains a needs assessment, 34 short term goals, 14 policies, and a five year plan of action which includes 48 specific action programs. MINUTES 0 \ June 26, 1991 PLANNING COMMISSION Page 2 COMMISSIONERS Mr. Turner stated that letters have been received from the Carlsbad Unified School District, the Carlsbad Chamber of Commerce, Project Future, the Northwest Quadrant Citizens Group, the Barrio Group, and the North Coast League of Women Voters, copies of which are included with the staff report, Chairman Holmes opened the public testimony and issued the invitation to speak. Margie Monroy, 3610 Carlsbad Boulevard, Carlsbad, representing the League of Women Voters, addressed the Commission and stated that the Housing Element is one of the most important documents the City will produce in the immediate future. Because of this importance, the League believes there should have been more opportunities for public input up to this point in time. There are many questions which still need to be answered. She stressed that the public must support the document in order for it to work. She would like to know what happened to the City's Housing and Redevelopment Committee. They were not consulted during the formulation of the Draft Element and they have not been given a copy of the document. There are still many questions which need to be answered, She noted that, to date, no low income units have been built in master planned communities and that a recent opportunity for affordable housing was lost in a 111 unit residential subdivision because the developer was told of the requirement on the afternoon prior to his project coming before the Planning Commission. The League urges the City to abide by the mandate and to make the financial commitment to assure that affordable housing obligations in Carlsbad will be met in a fair and equitable manner. The League believes a committee including citizens and builders needs to be established to provide input on implementation. 1 Ofelia Escobedo, 1611 James Drive, Carlsbad, representing the Northwest Quadrant Citizens Group and the Barrio Group, addressed the Commission and stated that she feels a committee needs to be appointed to develop details on how the Housing Element will be implemented. She noted that most of the existing affordable housing is located in Zone 1, specifically in the Barrio, and both groups she is representing are concerned whether or not low income housing will be allowed in the other zones in the City. They are also concerned that there is no time limit set for implementation. She feels that citizens and developers alike need to know all of the rules. John Todd, 3365 Donna Drive, Carlsbad, addressed the Commission and stated that he owns property on Garfield Avenue. He is concerned about the height restrictions development. Gary Wayne, Assistant Planning Director, replied that the July 3rd Planning Commission Meeting will be considering building height and that the Housing Element has no relation to building height. Paul Klukas, representing Hillman Properties, 2011 Palomar Airport Road, Carlsbad, addressed the Commission and stated that Aviara is well aware of the State mandate to provide affordable housing. They are currently in mid construction and their plans have been well scrutinized. They have been burdened by extraordinary costs associated with Alga Road, the Aviara Oaks School, the community park, etc. They are in agreement that Aviara I1 and I11 should accept the obligation to provide affordable housing. However, Hillman Properties objects to the "in lieu fees" being proposed in the Draft according to square footage which are being placed on future 0 0 MINUTES \ June 26, 1991 PLANNING COMMISSION Page 3 COMMISSIONERS Element. Had they known about this earlier, the Aviara development would have been planned differently. Mr. Kukus feels that some consideration should be given to Hillman to allow Aviara to continue. He referred to their letter to staff dated June 26, 1991. Doug Avis, representing the Fieldstone Company, 6670 El Camino Real, Carlsbad, addressed the Commission and stated that the Housing Element is the most important issue facing the City of Carlsbad. He feels there is a policy void in getting those projects built which have already been approved. He feels that costs need to be allocated on a unit by unit basis. He referred to his letter to staff dated June 26, 1991 which outlines eleven items of concern. He feels that cost is the most important concern because the market rate units pay the public facility fees. However, he cited a strong need for creativity in meeting the affordable housing objective. He would like to see the City allow single room occupancy (SRO's) and granny flats, as well as other methods in meeting the requirement. He corxluded his comments by stating that Fieldstone is committed to providing affordable housing as mandated. Ronald Schwab, 5200 El Camino Real, Carlsbad, representing the Rancho Carlsbad Mobile Home Park, addressed the Commission and stated that he did not see any mobile home parks addressed in the Element. He feels that mobile home parks are designed for senior citizens who need affordable housing and noted that Rancho Carlsbad is planning a 150 unit expansion. He presented a petition of 400-500 signatures in favor of exempting senior citizen mobil home parks from the Housing Element because they already meet affordable housing needs. He noted that mobile home parks provide housing in the $90,000 to $130,000 range, which is considered affordable, and he therefore feels they should be exempt from the 15% inclusionary requirement. Rusty Rhodes, representingVTN Southwest, an engineering firm located in Sorrento Valley, addressed the Commission and commended staff for being open and accessible to questions regarding the Element. He urged the City to incorporate flexibility into the program. He noted the State Density Bonus Law which he feels is a very workable program. He would like to see it incorporated into the Element because it possibility of reducing design standards in certain projects in order to facilitate more efficient use of space and thus provide more affordable housing. He urged the City to develop flexible options for the 15% inclusionary requirement and suggested that developers be given some type of credit for achieving more difficult affordable housing. For instance, he noted that there may be a need for housing for very large families which could be addressed. He also suggested that nonprofit entities might become involved in providing some creative financing such as a silent second trust deed or other financing mechanism. would be a big help to developers. He suggested the Renata Mulry, 7010 Nutmeg Way, Carlsbad, addressed the Commission and stated that she doesn't understand what affordable housing means. She has heard that only 17% of the population can afford to purchase a home in California which means that 83% just have to work it out. She doesn't understand the 15% rule. She would also like to know who makes up the cost difference between a $250,000 home and a $125,000 home. 0 0 MINUTES \ June 26, 1991 PLANNING CONNISSION Page 4 COMMISSIONERS I After the public comments, Chairman Holmes opened the forum to the Commission to ask questions. Commissioner Erwin asked Doug Avis if 85% of the homes would be paying for 100% of the homes. Mr. Avis replied that generally this is what happens. In actuality, the design standards, setbacks, etc. already reduce the number of units which can be built under growth management and he feels a developer should be given a reduction in fees in order to provide more affordable housing. Commissioner Schlehuber inquired how we would be able to meet the goals if we cut the fees, since the City's costs would not change, i.e., same number of inspections, etc. Mr. Avis replied that the developers would be more willing to comply extent. on a voluntary basis if the costs were reduced to some Commissioner Schlehuber noted that the voluntary program has not worked so far and he does not feel the deve- 2ers could police themselves. Mr. Avis replied that the rules have changed and developers are required to perform; there is no choice. Commissioner Hall inquired how Fieldstone would propose using single room occupancy (SRO). Mr. Avis replied that an SRO would fit well in an urban area which has pockets of commercial uses because it allows single persons working in the area to live nearby and avoid a commute. There being no other persons desiring to address the Commission on this topic, Chairman Holmes declared the public testimony closed and opened the item for discussion among the Commission members. Commissioner Schlehuber believes that a mandatory program is important and that Carlsbad needs to follow the HCD guidelines q Commissioner Schramm agrees, Commissioner Savary thinks we may need more input before we make a binding decision. She appreciates what has been said. Commissioner Erwin would like to hear discussed the possibility of commercial structures being converted to residential use, sometimes referred to as "adaptive reuse." Commissioner Hall feels it is hard to visualize how an SRO would work in Carlsbad. He feels that the northwest quadrant has more than its fair share of low cost housing and the Draft Element does not clearly state how the other three quadrants will take care of their fair share. Commissioner Hall feels this is the most important Element that we will have to work on during this year. He wants to make sure that we don't have problems 5-10 years from now. Chairman Holmes would like to have manufactured housing addressed in the Element. He stated that manufactured housing is much different than it was years ago. He thinks we should make it readily available to developers because it is a way to reduce costs. Commissioner Schlehuber feels that the formula about what constitutes low cost housing should be clearly set out in the Element. Commissioner Hall would like to see the final draft available to the public more than one week before the August 7th 0 0 MINUTES \ June 26, 1991 PLANNING COMMISSION Page 5 COMMISSIONERS meeting. Gary Wayne, Assistant Planning Director, feels this could become a logistical problem. Commissioner Hall would rather have the meeting delayed longer in order for the material to be available for a longer period in advance of the meeting. He could support a continuance for a date later than August 7th. Michael Holzmiller, Planning Director, stated that the meeting should not be delayed because he doesn't know what the ramifications could be. The City is mandated to have an Element in place by July 1 and he feels that since that date won't be met, he would at least prefer to keep on the tighter schedule. Dennis Turner, Principal Planner, then made a presentation on income ranges and how they relate to affordable housing. The income figures used were provided by HUD. After additional discussion on continuing the meeting past August 7, 1991, and the possible legal ramifications, the Commission agreed that the meeting should be held on schedule. Michael Holzmiller, Planning Director, stated that staff would attempt to have the staff report available earlier than one week before the meeting. Those persons who addressed the forum tonight would be notified as soon as the staff report becomes available. Commissioner Erwin requested that copies of the proposed Element also be made available in the Library. Dennis Turner, Principal Planner, advised the Commission that the final document would not be a strike-out version. Motion was duly made, seconded, and carried to continue GPA 90-8 to a public hearing on August 7, 1991. Commissioner Hall voted no because he felt that there would not be sufficient time for citizens to review the document before it is adopted. ADJOURNMENT: By proper motion, at 7:55 p.m. the meeting of June 26, 1991 was continued to a Planning Commission party on June 28, 1991 at the Altamira Clubhouse. Erwin Hall Holmes Savary Schlehube Schramm Erwin Hall Holmes Savary Schlehube Schramm Respectfully submitted, Planning Director BETTY BUCKNW Minutes Clerk MINUTES ARE ALSO TAPED AND KEPT ON FILE UNTIL THE MINUTES ARE APPROVED. 0 MINUTES e \ August 7, 1991 PLANNING COMMISSION Page 6 COMMISSIONER RECESS The Planning Commission recessed at 6:45 p.m. and reconvened at 6:54 p.m. 1) GPA 90-8 - DRAFT HOUSING ELEMENT - Request for approval of the revision to the Housing Element of the City of Carlsbad's General Plan. Dennis Turner, Principal Planner, stated that this item is a continuation of a hearing which began on June 26, 1991. At that meeting, the Planning Commission heard the staff report and took public testimony. During the hearing, staff made a recommendation that the matter be continued to allow staff time to respond to the testimony received. The public hearing was continued and is brought back with several exhibits which represent staff responses to the public testimony and revisions to the.Draft Housing Element. Unfortunately, staff has not yet received a reply from the California Department of Housing and Community Development (H.C.D.). It is mandatory that the State make a formal finding as to whether the Element is in substantial conformance with State housing law. Since the finding has not been received, staff is recommending that no action be taken on the Housing Element until after a response is received. H.C.D. has indicated that a determination should be received by August 13, 1991. Therefore, Mr. Turner requested that the matter be continued to September 4, 1991 to allow time for staff to respond to H.C.D.'s finding and, if necessary, propose additional changes to the Draft Housing Element. Vice-chairman Erwin inquired about Table 41 (Attachment #l to Exhibit "B"). He is concerned about tying some of this information into.the General Plan when much of it is in the process of being changed. Mr. Turner replied that the table was included to respond to the requirement to describe all of the various constraints and regulations which could potentially constrain housing. It is staff's responsibility to demonstrate that the regulations do not constrain the development of housing. Table 41 was revised and included on the advice of the housing consultant. Staff will consider the comment of whether it should be included in the General Plan Amendment. Motion was duly made, seconded, and carried to continue GPA 90-8 to September 4, 1991, with the public testimony period being left open until that date. Erwin Hall Noble Savary Schlehubl Schramm Vice-chairman Erwin opened the public testimony and issued the invitation to speak. He requested that only new issues be addressed. Doug Avis, 6670 El Camino Real, Carlsbad, representing The Fieldstone Company, addressed the Commission and stated that he has two new concerns which should be considered. Fieldstone is concerned about excess units which are being stored by the City to achieve low and very low income housing. He feels that in a Master Plan Community, it is extremely difficult to achieve the very low affordable housing. He-urged the City to encourage flexibility in how excess units are used. He felt it might be necessary to consider single room occupancy (SRO's) and possibly granny e e MINUTES \ September 4, 1991 PLANNING COMMISSION Paqe 5 COMMISSIONEF Motion was duly made, seconded, and carried to adopt Planning Commission Resolution No. 3273 denying without prejudice, LC 91-2 based on the findings contained therein. Ron Ball, Assistant City Attorney, advised the applicant that the Planning Commission's decision is final and the item will not go forward to City Council. RECESS The Planning Commission recessed at 6:20 p.m. and reconvened at 6:30 p.m. CONTINUED PUBLIC HEARING ITEMS: 3) GPA 90-8 - DRAFT HOUSING ELEMENT - Request approval Of the revision to the Housing Element of the City of Carlsbad's General Plan. Dennis Turner, Principal Planner, reviewed the background of the request and stated that on August 7, 1991, the Planning Commission conducted its second public hearing on the draft Housing Element. Staff had prepared written responses to public letters of comment. The public hearing was then continued to September 4, 1991 while staff awaited a response on the Draft Element from the California Department of Housing and Community Development (HCD). Staff then made several changes to the Element in response to the HCD and other written comments which are included with the staff report as amended Exhibit "B" dated September 4, 1991. He stated that the remainder of the staff presentation would be made by Kathy Graham, Director of Housing and Redevelopment, and Chris DeCerbo, Senior Planner. Kathy Graham, Director of Housing and Redevelopment, gave a slide presentation on the housing in general and defined the criteria for affordable housing as mandated by the State of California. The presentation included salary and housing cost data for Carlsbad as compiled by the San Diego Association of Governments (SANDAG) . Also shown in the slides were different types of housing throughout California which qualifies as affordable housing. Chris DeCerbo, Senior Planner, addressed the Commission and stated that the Housing Element must be adopted by the Planning Commission and the City Council, after which it will be sent to HCD for final approval. HCD must respond within 120 day6 stating that the Element is in substantial compliance. Once the Element has been adopted, the City will have in its grasp goals, policies, and objectives to implement a Citywide housing program. This Housing Element is the City's commitment to address the needs of all segments of the existing and future residents of Carlsbad. Subsequent to the adoption of the Housing Element, staff will begin developing specific details, standards, procedures, and ordinances for the individual action items of the Citywide housing program. There are approximately 50 action items to Erwin Hall Bolmes Noble Savary Schlehuber Schramm 1 I @ e MINUTES \ September 4, 1991 PLANNING COMMISSION page 6 COMMISSIONER be addressed, including density bonus and in-lieu fees, which will be subject to full public hearings. Staff recommends adoption of the Draft Housing Element including the amended Exhibit "B" to the staff report. Commissioner Erwin inquired how the affordable housing criteria would apply to a young, single person who, perhaps, is employed in a deli or similar activity. Kathy Graham replied that the housing/salary criteria are all geared to a family of four. Even a family of one should not have to spend more than 30% of their income for housing. If two persons are sharing a dwelling, they would be considered a household of two and the criteria would be adjusted accordingly, commissioner Erwin inquired if a single person making a minimum wage chooses to live alone, would the City be required to subsidize their low income housing. Ms. Graham replied that, at the current time, there is no program other than Section 8 which deals with rental assistance. The City cannot discriminate against a single person who chooses to live alone if they want to apply for Section 0 assistance. Commissioner Erwin noted that the pie charts did not show taxes and he inquired if the income figures stated in the staff presentation are net or gross incomes. Ms. Graham replied that the amounts represent gross income; taxes were not considered. Commissioner Schlehuber inquired if he was correct in assuming that the Housing Element applies to all residents regardless of their marital status, household size, age, income, etc. Ms. Graham replied to the affirmative and stated that there is no discrimination based upon any of the items mentioned. Commissianer Ball commented that he really appreciated the slide presentation and inquired about the mixed use developments. He would like to know the size of one of the small use units. Ms. Graham replied that in the Renaissance project in Venice, California, the smallest apartment is approximately 300 s.f. They are all handicapped equipped and certain areas are.restricted to seniors only. The largest unit in that particular development is a condominium of approximately 1,700 s.f. Commissioner Hall inquired if there is a required ratio of small units to large units. Ms. Graham was not aware of a specific ratio; however, she stated that the general target is 20% affordable. Commissioner Hall inquired about the age of the different developments shown in the slides. Ms. Graham replied that the youngest one is Columbia Place which was just completed within the past year. The Hillcrest project has probably been there a little more than a year. The Venice Renaissance project is approximately three years old. Some of the Carlsbad projects were assisted by the Mortgage Revenue Bond financing and were completed in 1983-85. The mixed developments combined with commercial development tend to be the newer projects. 0 MINUTES e y September 4, 1991 PLANNING COMMISSION Page 7 COMMISSIONERS I I Commissioner Hall inquired how many of the projects contained more than 100 units. Ms. Graham replied that all of them had in excess of 100 units. Commissioner Hall noticed that most of the projects had a common height and he asked Ms. Graham to speak to the height issue. She replied that there are many ways to create a spacious illusion. The Venice Renaissance project Contains one story of retail on the ground floor with two stories of apartments above. The condos had an additional story. The Hillcrest project had three stories but the terrain is varied so, in many cases, you walk up some stairs to reach the first story. Then there is underground parking. Columbia Place in downtown San Diego has four stories. In developments such as this, the land is so expensive that it is not feasible to have street level parking so most of it is underground. Commissioner Hall commented that all of the projects shown has good architectural design and were attractive without the boxy look. Commissioner Hall inquired how the density bonus is calculated in these types of projects. Dennis Turner, Principal Planner, replied that in order to build affordable housing in Carlsbad, there will have to be some tradeoffs which will probably include such things as density, unit size, height, etc. Another method might be cash subsidies or land write downs. The tough questions will be to find a balance between those various tools. These things will be decided during the planning process. Commissioner Hall is also concerned about the sharing of affordable housing throughout the four quadrants. Mr. Turner replied that all of the special needs projects must be distributed throughout the City and no one quadrant should receive more than its share. He realizes that this is not explicit enough in the Draft Element and he suggested a minor change on page 119 under Goal #3. He suggested that the words "in all quadrants of" be added to Goal #3 just prior to the words "the City." Commissioner Erwin would like to see the wording on page 124 under Alternative Housing, paragraph 3.7.a., revised to replace the words "single room occupancy hotels" with "managed living units" which would include single occupancy hotels. Mr. Turner replied that this change would be acceptable but it should be changed in both the policy and the program. Commissioner Schlehuber inquired about the projected future needs for affordable housing in Carlsbad. It appeared from the slide presentation that the need for low and very low income housing is: more than 20%. Dennis Turner replied that the figures shown on the slide were prepared by SANDAG as part of its Regional Housing Needs Statement. SANDAG believes that the need is approximately 40% of 6,203 units or 2,481. However, staff feels that this goal is extremely ambitious and, as a result, has advised HCD that a goal of 1,125 to 1.400 affordable housing units is a realistic goal for Carlsbad. Commissioner Schlehuber inquired of the goal of 1,125 units has been broken down into low and very low income. Mr. 0 8 MINUTES \ September 4, 1991 PLANNING COMMISSION page 8 COMMISSIONEF I Turner replied that it has not. As he recalls, the breakout is approximately 18% for low and 22% for very low. commissioner schlehuber inquired what the very low rent would be in Carlsbad, including utilities. Kathy Graham replied that $350 for a family of 4 is considered very low. It would be a lesser amount for a smaller household. Commissioner Schlehuber noted that this rent would equate to $4,200 annual rent and that the City fees are in the neighborhood of $6,600 per unit. He inquired if staff will be addressing this issue. Dennis Turner replied that staff is meeting with members of the development community (profit and non profit) to develop the specific economics of construction, i.e. land costs, construction, fees, financing, etc. At that point, the various alternatives can be explored. Commissioner Noble inquired if steps will be taken to ensure that the low income housing will remain as low income ad infinitum. Kathy Graham replied that the existing low income housing in Carlsbad which was made available through Mortgage Revenue Bonds carries a stipulation that it must remain low income housing for a period of 25 yrs. There is a report which must be filed annually that contains the rental amounts, incomes of residents, etc. Dennis Turner added that staff has been telling the development community to expect a 30 year period of affordability. Chairman Holmes opened the public testimony and issued the invitation to speak. Doug Avis, 6670 El Camino Real, Carlsbad, representing The Fieldstone Company, addressed the Commission and stated that there are still a few unresolved concerns which need to be taken care of prior to adoption of the Housing Element. He does not feel that specifics can be addressed until the final approval from HCD has been received. He noted that the philosophical issues set forth in his letter to the Planning Director have been covered in the Element and he believes the document contains the flexibility to implement affordable housing. He is especially concerned about the difficulty of achieving the very low category of affordable housing in a Master Plan Community when the fees for a home in Area 12 would be approximately $39,168. This figure does not take into consideration land costs, construction, or soft costs. The second unresolved issue is the percentage of affordable housing required in Master Plan communities. He would like consideration given to basing the percentage on the entire Master Plan and not on each development within the Master Plan. For instance, to get 150 affordable apartments in a development, it is necessary to build 450 units. He requested the Commission to delay approval of the Housing Element until HCD has given their response to some of his concerns. Ron Ball, Assistant City Attorney, commented that the law does not allow the City to wait for another response from HCD. They have already made their comments. The Element must be adopted by the City Council before it is sent to HCD for final approval. They have 120 days to approve the Element. e MINUTES e \ September 4, 1991 PLANNING COMMISSION Page 9 COMMISSIONER Mike Howes, Hofman Planning Associates, 2386 Faraday Avenue, Suite 120, Carlsbad, addressed the Commission and stated that the Housing Element contains some very good programs, if properly implemented. Approval of the Element is just the first step. The implementing ordinances are the most important and will be the vehicle to make the Housing Element work. He noted that the slide presentation showed many types of structures in other cities which could not be built in Carlsbad today, primarily due to the Height Ordinance. Ted Marioncelli, Land Use Planning Consultant, 701 First Street, Oceanside, addressed the Commission and stated that he represents the Construction Industry Federation, Associated General Contractors, Building Industry Association, and Engineering and General Contractors Association. He feels the major problem impeding development of affordable housing in Carlsbad is the Growth Management Plan because there is an upper limit of 19 du/ac stated in that plan, Further, the Element does not indicate that affordable housing is a priority. It remains to be seen whether mitigating measures in the Element can mitigate development constraints. He feels the only tool available to provide affordable housing is inclusionary zoning. Mr. Marioncelli requested that the Commission broaden the scope of alternatives contained within the Housing Element prior to submission to the City Council for final adoption. There being no other persons desiring to address the Commission on this topic, Chairman Holmes declared the public testimony closed and opened the item for discussion among the Commission members. Chairman Holmes noted receipt of a letter dated September 4, 1991 from Renata Mulry, 7040 Avenida Encinas, Carlsbad. The letter addresses affordable housing and will be on file with the minutes in the Planning Department. Commissioner Erwin can support the staff recommendation with the understanding that we are looking at a skeleton. There is a lot of latitude here which will have to be built piece by piece. There is a lot of work yet to do to complete the project . Commissioner Schlehuber agrees with Commissioner Erwin. Commissioner Hall feels the general building climate is not good and he has heard that this may last for 2-5 years. He inquired how that will impact the City. Dennis Turner replied that if no housing is produced, then no low income housing would be required. When new housing is built, then low income units are required. Commissioner Hall agrees with Commissioners Erwin and Schlehuber. Motion was duly made, seconded, and carried to adopt Planning Commission Resolution No. 3254 recommending approval of the Negative Declaration issued by the Planning Director, and adopt Planning Commission Resolution No. 3255 recommending approval of GPA 90-08, based on the findings contained therein, with inclusion of the changes to Appendix B which Erwin Hall Holmes Noble savary SchlehubE were added. Schramm e MINUTES e September 4, 1991 PLANNING COMMISSION page 10 COMMISSION ADDED ITEMS AND REPORTS: Commissioner Schramm requested other Planning bmissioners to join her in a Minute Motion to request the City Council to look at the feasibility of establishing a City Housing Commission. Commissioners Erwin and Schlehuber both felt the request was premature and they would prefer to wait until the Housing Element is ready for implementation. The motion died for lack of a second. ADJOURNMENT : By proper motion, the meeting of September 4, 1991 was Hall adjourned at 7~51 p-m- Erwin Holmes Noble Savary Schlehu. Schramm Respectfully submitted, MICHAEL HOLZMILLER Planning Director BETTY BUCKNER Minutes Clerk MINUTES ARE ALSO TAPED AND KEPT ON FILE UNTIL THE MINUTES €!RE APPROVED. e (I, ANALYSIS These changes are in response to comments received from the Legal Aid Society of Diego, Inc. in which the society requested clarification of the growth in student enrolln at C.S.U.S.M. and the associated impact on hasing. U. RECOMMENDATION It is recommended that the first paragraph on p. 60 of the draft element (POTEN1 SHELTER SITES) be deleted and replaced with the following: Cm-lshnd l~as pledged to work with any agency desiring to create and operate shelters for Itorneless. While izomeless shelters are nor permitred by right in arty zone, tile City ha. specific critericl for their locution and, under a Condiiional Use Permit, would consider prop( almost trtlywiwe. Sites mar to support sewices) hiring izalls, and public tramportation especially nttrctctive. The City lzns attempred 10 ussis! homeless advocacy grolLps to invev public nnd private property 011 wlrich shelters c~n be operated. In 1990 tile City pledged to a irz the plarrrzitzg arzd permitting of an emergency shelter proposed by Caring Residenl Crrrlsbcrd (a llousing Ndvocate group), in conjunction with Catholic Charities (a non-p orgmizcrtion with progrllrn arzd admitristrative abilities). ANALYSIS The original language of the draft element has been misinterpreted by some to suggest Carlsbad has adopted locational criteria for emergency and transitional shelters which so rigorous that no site can qualify. The replacement language clearly states that Carls has no special locational criteria, and that it would consider shelter proposals anywh via Conditional Use Permit. V. RECOMMENDATION It is recommended that the first paragraph on page 54 (Estimated Homeless Populat be deleted and replaced with the following: The homeless are defined as individuals who lack N fked and adequate nighttime reside, Hotneless persons can he considered residetrt (those wllo remain year-round), or transient. tmrzsierrt homeless popdution can be broken dowrz into several sub-categories. Tlzose who temporarily seeking imlsitrg because of diflcult economic situalions, migrant workerpopulat) wllo choose to camp in undeveloped areas so as to sme money to serld home, or residents 1 ore iempororily Iznmeless hecorm of o disnstrous sifuntiorl, i.e. enrtllqunke, fire or Jood. 19 e e An accepted rule of thumb used by some experts, is that the number of resident homele: urban areas k equal to 114 to 112 of one percent of the general population (in which case City’s urban homeless might range from 150 to 300 persons). In an effort to obtain a more accurate figure with regard to the number of Carlsbad’s u1 homeless, social service agencies and charity organizations operating in neighboring cities contacted to determine the number of homeless persons residing in Carlsbad to whom provide assistance. The following is a list of agencies and organizations which were contal 1) 4 3) 4) 5) 6) 7) 8) 9) 10) 11) Brother Benno Foundation, Oceanside Catholic Chanties, Oceanside Community Resource Center, Encinitas Ecumenical Service Center, Oceanside Epkcopal Community Services, Encinitas Faith and Love Ministries, Vita Gateway Family Shelter, Oceanside Lifeline Community Services, Vita North County Chaplaincy, Encinitas Regional Task Force on the Homeless, San Diego Salvation Army Cops (Family Services), Oceanside All the agencies contacted agreed that the homeless population k a very dificult populatil count. Lifeline Community Services was the only agency which was able to provide a cou Carlsbad homeless persons they have assisted (see Table 30A). These numbers were obtl; from case management files (numbers are unduplicated ) and infomation and referral. 2 numbers may include homeless migrant workers, in addition to the urban homeless. TABLE 30A SERVICE AGENCY PROVIDING ASSISTANCE TO HOMELESS PERSONS RESIDING IN CARLSBAD Social Service Agency No. of Asskted Persons 410 407 Lifeline Community Services I, 990 1,989 None of the other agencies were able to provide any jigures in regards to Carlsbad’s horn population. Some agencies do not obtain extensive information, such as place of resid from their clients. while some do solicit residency information from their clients, they do regularly assemble statistical compilations and the agencies were unwilling to go thr individual case files to do a special compilation in response to the City’s request. 20 0 0 There are also inherent problems with asking the homeless population their place of resid, Many claim that they have no place of residency. They merely refer to the street as residence. Thk street may be in Carlsbad one week and Encinitas the next week It can be assumed that many homeless will give their place of residency as the city in which the s agency tS located because they fear they cannot utilke the agency's services unless they cla, be a local resident. ANMYSIS The discussion of the estimated homeless population was rewritten in respom comments from the Legal Aid Society of San Diego, Inc., in regards to the draft elen discussion of the estimation of the urban homeless population in Carlsbad. In sum^ it is very difficult to count the urban homeless. Although efforts were made to co local social service agencies and charity organizations who provide assistance tc homeless, the City was unable to obtain a definitive numerical estimation of its 1: homeless population. W. RECOMMENDATION It is recommended that a new Program 3.7.i. as follows, be added to page 126 of the Housing Element: PROGRAM 3.7.i. In order to enable the development of a$ordable housing, the City shall adopt a mechani allow discwtwnary considiration of density increases above the maximum now permitted t General Plan. nis mechanism will include either; a Conditional Use Permit (CUP), Development Plan (SDP) or Affordable Housing overlay Zone. FUNDING: General Fund (adminiwation only). LEAD AGENCYI. Planning Department TARGET YEAR: I992 ANAJAYSIS In response to the State Department of Housing and Community Developments Corn #2 (see Exhibit "A", Attachment "1") this new program 3.7.i. has been added to the Housing Element. This new program will create a land use permit process or overlay whereby residential density increases above the existing General Plan maximums n permitted in order to enable the development of affordable housing. By allowing thc to consider density increases above the maximums permitted by the existing General this new proposed program will help to facilitate the implementation of the State man( Density Bonus Law, and the City's Enclusionary Housing Ordinance (Program 3.7.: 21 e e 3.6.a, of the Draft Housing Element), It is anticipated that the majority of any afford housing developed within the City will OCCUT through the implementation of these Housing Programs. X. RECOMMENDATION It is recommended that the following statement be added as the last sentence to Pros 3.6.C. (In-Lieu Fee - page 123). A detailed plan for the priority use of these in-lieu fees shall be included in the In-Lieu Fee Shuiy. ANALYSIS In response to the State Department of Housing and Community Developn City's plans for the use of the in-lieu fees is being recommended for incorporation intc Draft Housing Element. Comment #3 (See Exhibit "A", Attachment "l"), this additional statement regardhi gpas 22 0 0 ATTACHMENTS FOLLOW r z W I W U - 5 W U W z 0 N J a F z W 0 W E z r d W id 3 r I- b I F t 0 * - v) I- 56 xsj, 9 $$it: $Gig g g g d- 2 d G XP- 9 * 2s 5 '5 -s 7 $5 "3 E, =c $E.: .: it: it: e =&e 83s 88 88 88 5g 2-l 9 $ 8 8 ii z s z s z s s z d, z m, s it: it: $4 $4 $4 $4 $4 it: e I i m g; XP- x0 Fm m m m cum cuv) XP- cum m Nul *Q, c c 'c :g gg OC gs OX 'is or Ec 50 35 4! &! rE 33 Zk = q 8 si5 za 2 % % g 2 =I- g 3a e it: 4= 8 8 8e 8s 8s v- 8 8 0 c c c c c 0 c c 0 =K it: 4= 4= 4= s2 3 r; 9- b- L 3- b- s 3- b- L l" 30 33 .. 0 c gsLi= o>=v)-m o.gUj,.gE gmfagz gEo,g.zg a%Esg cg.- amp$$: cs aza*Zg -3fa 'DOPG, fa gE.E uiuiui p m.9 0 ui 0 -3l-a tig,v)c 0 a.2 0 E 0 5-a sg m&g-& 0 22 w aF= O .= c.r-0 3 om Er .- ouq E .$*~~.$r~ *-a52g oc s c Q.E 9 ,me-,m E;ij p) (5, u) 033 zazsm9 fu v)ui5g m~ w5q.s * P 3Sn eui/j ~$8a= 9gg sz 5? rn3.E5 ma' 3 mzp,g =036 >2v) - 0 -E E - - .. - €g+ L6a Lg VI- 2 r W rchg?j %U 0 .Ez- goo2 asz .- WEmam N m$ E &,-E :J'" $g N 0, g $.zg or- N FE-5 - N gECj f g aSa3m a moa cu 23 a~u3v)- afa3Smfa 5 k ? SZKJ "mcu -E r >: > .- W z - .- - -fa fa FKJ l" " - E. .- as .- E=$.- gs 4 38% mo fa ag$r 0 .g % eq? - &.E5 g= k zsg m55? EO 53: ON -ma - ZZ~~Z ccao z$ $6 am Eo -.Erns (3 3 v)c ar Eo r z w I W U 2 a. W a W - i5 N -I a F n E a z W W v) W v) !k - Q Q U rz u Q= .o uj 8 6- "9 "EQO Q gFE ana 0 p aj g%z QL UQ UO>b$ os g .E E." S gbu = 032 0 . .h Q) - m ui .s 8 s 0 0, 2 9 C Q m U a, 0) v) = v)e 8za 8' -5Q -353 5 0 OCUO~ QG$n a8 a~~$ a'tjn nu2 =Gs E a, Qg hQ d.g ~CJS~E QU a k ~~~~ e$ gsia sc8 g5-G &Q ak. QOaov) I- 6: $X= zit: git: e c ZG~ 9 d a \ m, 02 P, gp 5 3 "ai 2 4= =e OL %@ 2 it: "eez OS it: yzc x3 %C 5 In d In d S P*In E 8 ee LL ?%;e 0, os BE 2 s z z 2. z . a . a V)L w- CD mE 8 it: $2 I- it: w =)c e z 5ca &Q ms 3 cc g ES e it: c it: zg 8 s z In ae rc $ IC 18s 53 8 5" %I- aE c =s c e e ZI- Zr 8 In rc =3 8 c 0 c c 0 ;r 0 c c 0 d 8s 3 8 =4 c e it: "g+Ug " =re ~4 5: In 5: 5: Sg"'5 gs 0'5.E NSYSEr)' 0 uj a Rsg$g: NO@*E>QZZ 0.5 5 a z - gz 0 3 2=f E%- 8 Edgz$$ g$v)gz"bo mQ,EEoQ$YZ '@ co,Z.Em m- ma3 QQ?5?Lj.G a* iiigo&5 ciiiQZE ~oEo gg# gag; s0~~~$ WnC ~Zg0.g~~ v) q p) .E _. e . $.pa% -0 ujnw gg.L?st;J QQug&$@ g 2E,uao uCmc..- -82 3=.=3 u- m Sa u > Q KDc= ua $Ti, +,, vi€= 0.2" pLDn Bzairjo gq@gtEz om 42 "$ L so E 2 $2 2 v) amla E""pa Q c Og 3 Q In- &-$& rc-0 7 E E "v) rc- rc- Inm c cc =a 0 a .e VI - .. - to CE =a x c CL ogao 3 m+$Ea.g: ESZE~~~ $B@ZE~)~- E?~S;~F gpa.~~v) c " c. NS8OeSE anm3nm anmzaus NSgt;J32 acznmma uti~2mn aZJSg6aB - Q Qd 90! - 1.4 -a F 3 3r -2 aL- c P kaka Z!Z~Z ZdSG ai7j 80 CCUO Lg82 XDnEq 0 .@ uY 58 SC3, aQ m Q8S L ago E .p L- ES2 fCJ Q) .@S .- m s& .s 0 Q .s r "r €? -Ed G W Z - -m. 5 g; ON &2z 5?22$ OQQ U n t~ ac VI c z W z W K I z R 2 W a W z J z W v) W U Q v) W - L v) 5 >.Or* ujL EL* a ncca E2 A s f ptma O~ZEU~ 8 0,o @ 0.- 3gpg QZ a 0 8.' E:% zp mu) L3 La $9 Q L!g Qm.kO!+= @E 3 ghaa -v)Lav) SPZ~ =2 N -corn z~N LL egg egg S3E 9 aa m2a CQ)~@P, -baa hCO YQL ^CO -azc> agsag Hoc9 auc abai u)L. Po fe ias s- 29 .!43 E $$!= . a s- 8s t o -I= 9% s Z s- 3 t; *:, $ v) sG s- ze s ZEg w g =e a LL sgg s- 29 s Z 6 9 m- z z ze Q) 2.3 s z U z I Ig 80 $5 s- # z9 s z EE 58 z+ '9 s E4 =a za zt- :e SI3 -a 2G 30 Z 5- z9 s z p1 a- < z uj -06 li .e . . cme - = 8.G g g NOaaapgSa,,, NO mcgg$g%i g:f+ %OVs* ~~~mQv)Cag~ g c 05 a mE== ms =%cam ErOcEo a-a+s$jfJja "0 ZEgQy-2 W %E$ rar c 3gs L 2.5 .o 0 $gm" BL -3z* kjlJz$a3 as5ijo-o 3 >EE LD$gz#gum8i oos~ua5g(o,a c-g O,? 0) a0 35 v) 3 CGE gc~v~ pOEztjEaB 20u$u=Q 'Pm-cnuj v) :=a v) 3 .- m-pJEEg:r-o a% 1-0 v) a f.Eogm man m a aa~u~ ouu Q baEh=ti$eE- a t~ cc Q.. 06 v, 0 3 W R g&i g&i -0J z $!I ? u .g & Etjn E - a038 35ao aaoo - EEg g)# g 4sae c?S OC tcgzg aa+O 0 0 ATTACHMENT 2 GROWTH MANAGEMENT APPENDIX I 0 0 A Discussion of the Growth Management Program For Inclusion In The Housing Element The purpose of this discussion is to describe the City’s Growth Management Program to demonstrate how the program will not function as a constraint to developmer affordable housing. 1. Background The City of Carlsbad enacted its Growth Management Program in 1986, basing program on provision of adequate public facilities. It was first enacted by ordinance in 1986. Subsequently, a citizens group qualified a ballot initiative which proposed an am cap on residential development (Proposition G). The City viewed an annual residential as not only inconsistent with its facilities based growth management ordinance but inconsistent with the provision of affordable housing and good land use planning. The then placed its own measure or rhe ballot for voter approval (Proposition E). The C measure proposed an ultimate dwelling unit cap on each quadrant of the City coupled I provision of adequate public facilities concurrent with need. Furthermore, the C measure stated that it was incompatible with the citizens initiative, and if both meas were approved by a majority of the voters, the one receiving the greatest number of v would be the only one enacted. Both measures did receive approval by a majority of voters, and the City’s measure received more votes than the citizens initiative. T Proposition E was the only one enacted by vote of the people, The ordinance was 1 amended to be fully consistent with all provisions of the voter approved measure. The following will analyze the specific provisions of the Growth Management Program provide detailed explanation of how affordable housing will be developed consistent 7, these provisions. 11. Ultimate Dwelling Unit Caps A. Flexibility Built Into the Program to Allow For Density Increases W1 Appropriate. In the early stages of development of the Growth Management Program it was intended to institute statutory dwelling unit caps. Rather, the intent was to proc realistic estimates of the ultimate amount of development for purposes of projecting public facilities that would be needed at buildout. The estimates were arrived at applying the mid-point of the General Plan’s residential density ranges to the remair vacant, developable, residentially zoned land. Subsequently, as part of Proposition E it decided to utilize statutory caps as a way of assuring that facilities capacity would no exceeded at buildout. A2 - 2 0 a Knowing that there would be a need to provide for density bonuses within any ( established by Proposition E, the City added additional units to the original reside] buildout estimates. These units were added as a safety margin to address a worst 1 scenario in which no projects were approved below the Control Points. If this worst scenario were to occur through buildout of the City, there would still be units availablt density bonuses without exceeding the caps. It was anticipated that, in actual prac some projects in each quadrant would develop at a lower density than the Control Po. This would make additional units available for density increases elsewhere within quadrant. In other words, room was built into the Proposition E caps to accomo affordable housing projects at higher densities. Flexibility was also built into the Control Points to allow for the granting of hi: densities. Proposition E provided that the Control Points can be exceeded if the City f that adequate facilities will be provided and the quadrant caps will not be exceedec number of projects have been approved already based upon this finding. A sample li these projects follows as Exhibit "A". Clearly then, the City has the capability, built the Growth Management Program from the beginning, to grant higher densities wit1 exceeding the quadrant caps. Exhibit "A" SAMPLE OF SELECTED cm RESIDENTIAL PROJECTS APPROVED BELOW THE GROWTH CONTROL POINT - B. Dwelling Unit Bank for Affordable Housing The City's ability'to grant higher densities has been refined and made more formalizt we have proceeded with implementation of the Growth Management Program. quadrant caps were originally calculated based on gross information available at the 1 Subsequently, Local Facilities Management Plans have been produced for eighteen o A2 - 3 0 e twenty-Gve zones of the City. These Zone Plans have projected residential bdldout much more accurate level. For example, each zone plan contains a 200' scale map oj physical and environmental constraints that exist within the zone. This mapping ha, provided the City with a vastly improved picture of the amount of developable acrc within each zone and quadrant. As a result of the production of these Zone Plans, the City has verified that the proje amount of residential development within each quadrant based on the control points be less than the Proposition E caps. In fact, it is now projected that the amour residential development based on the Zone Plans may eventually be more than 2,500 1 under the Proposition E Caps for the City as a whole. This is an extremely important point to understand about Carlsbad's Growth Managel Program. It means that if each of the 25 Zones were to develop according to its Zone at the maximum density that the Control Points will allow, there will still be units avai under the cap for granting density increases. As noted above, this was designed intc program, and it has been further refined by the zone plans that have been completed far. The units available for density increases due to the above are known as "excess units. ensure that these units are retained for the primary purpose of encouraging afforc housing by means of density bonuses, the City has established a Bank of excess unit: a City Council Policy (No. 43) for allocation of these units. The Policy was adoptc February 1990, and is attached as Exhibit "B". C. Additions to Bank Due to Individual Project Density Reductions There is yet another source of excess dwelling units to be added to the Bank. anticipated, some projects in each quadrant are being designed and constructed at less the Control Points. This occurs for a variety of reasons. In many cases it is a mark1 free up more units because the projected residential buildout for the Zone is predic upon everyone building at the Control Point. Exhibit "A" provides several recent exar of density reductions which will make more excess units available for other properti the quadrant. These excess units are added to the Bank and are available for de increases within that quadrant to encourage affordable housing. As indicated above, units are retained by the City and allocated in accordance with adopted City Council F No. 43. In summary, the City has a Bank of Excess Dwelling Units that are available for de increases without exceeding the quadrant caps. It is estimated that the bank approximate over 2,500 units. Excess units are made available from three sources: 1. Additional units built into the quadrant cap numbers in the begil decision by rhe developer to provide larger lots. Regardless of rhe reason, these prc of the program. A2 - 4 0 m 2. Zone Plan residential buildout numbers for a given quadrant that cumulatively less than the quadrant cap. 3. Reductions in some individual project densities. In conclusion, the dwelling unit caps that are a part of the City’s Growth Manager Program will not be constraints to development of affordable housing because a suffic number of Excess Units will be available to grant density bonuses wherever appropr 111. Requirement for Adequacy of Public Facilities In addition to setting an ultimate dwelling unit cap, the City’s Growth Manager: Program requires that adequate public facilities be planned, funded, and constru concurrent with the need generated by new development. To implement this requirerr the City has been divided into 25 Local Facility Management Zones. Each Zone is requ to prepare a Local Facilities Management Plan as a prerequisite to development. Zones 1 through 6 are the in-fill areas of the City, and those Zone Plans were prepare City staff. Most facility needs for these zones are addressed by the City’s Ca: Improvement Program through typical fees. In the rest of the zones, the property ow are responsible for preparing the Zone Plans. As part of these plans, the property ow must indicate how the public facilities needed by the zone will be paid for. The privately prepared plan was Zone 19. This plan contained acceptable financing provisit Thus, zones 1 through 6 and 19 are able to develop normally at this time. Zones 7, 8, 9, 11, 12, 14, 15, 18, 20, 22, and 24 prepared Zone Plans that did not con acceptable facility financing provisions. Their primary deficiency was in addressing cer citywide facilities. However, the plans were otherwise satisfactory and useful for planr purposes. It was decided to conditionally approve these plans, subject to later prepara of an acceptable Financing Plan. With conditional approval of their plans, the prop owners have generally been able to obtain Master Plans, Tentative Subdivision Maps, other similar discretionary approvals for their land. In the absence of an apprc Financing Plan, they cannot obtain a Final Map, grading permit, or building permit. In order to facilitate financing for the Citywide facilities, the City has pursued a large-s Me110 Roos Community Facilities District (CFD). The CFD required some rime to asserr but it is now fully approved and operational. With this key financing program in plac is now possible for the zones listed above to complete their required Financing Plans. Financing Plan for Zone 7 is the furthest along and is expected to go to the City Cou for approval in July 1991. Financing Plans have also been submitted to staff for re\ for zones 11, 12, and 20. Approval of these plans is expected to follow closely after Z( A2 - 5 0 0 7. Financing Plans for zones 9, 14, 15, 18, 22, and 24 will be submitted by the pro: owners when they are ready to proceed with their development. Zone Plans for zone: 16, and 21 are in preparation at this time. Zone Plans for zones 10, 17, 23, and 25 be submitted when the property owners are ready to pursue discretionary approvals The facility requirement of the Growth Management Program has probably had the e of a temporary moratorium within certain zones, bur ir did not srop housing produc During the five year period from 1986 through 1990, a total of 4,991 new dwelling 3 were constructed. This development took place in zones 1 through 6 and 19, as wc other zones where "pipeline" projects were to go to completion. Development will resume in Zones 7, 11, 12, 20, and other zones. The City is in an excellent positic encourage and facilitate the development of a significant affordable housing compone the large, undeveloped areas of these zones. Therefore, in looking to the future requirement for provision of adequate public facilities concurrent with need will not in or act as a constraint to the development of affordable housing in Carlsbad. A2 - 6 CAHw I "W' AI IAL IZ Cliy OF CARLSBAD No. 43 COUNCIL POUCY STATEMENT General Subject: PRoPosrnoN E *MESS' DWEWNG tF! lSSII@d 2/6/9 UNIT ALLOCATION ve w 2/6 n De Specific Subject: FORMAL PROCEDURE ESTABLISHING GUIDEUNES FOR ALLOCATION OF PROPOSMON E 'MESS - DWELUNG UNITS. 1 ~~~ Copies to: City Council, City Manager, City Attorney, Department and Division Heads, Employee Bulletin Boards, Press, File PURPOSE To establish guidelines for allocation of "excess" dwelling units when, following the adr residential Local Facilities Management Plans within a quadrant, the Proposition E qua( greater than the number of dwelling units approved or issued after November 4, 19 allowable units per the Growth Management Control Points. . STATEMENT OF POLICY Although it should not be mandatory that excess dwelling units be allocated if they becor and it would be desirable to not attain the ultimate residential dwelling unit caps establi: adoption of Proposition E, the following criteria is established to determine eligibility for CI of "excess" dwelling unit allocation, subject to the required findings in Proposition E. Projects eligible for consideration in order of priority include: 1. Housing development for low or moderate-income households as defined b Government Code Section 6591 5. 2. Senior citizen housing as defined by Carlsbad Municipal Code Section 21.1 8.045 3. lnfill Single Family Subdivisions, Zoned R-1, that meet all development standards a1 sizes are equal to or greater than adjacent subdivided R-1 properties. 4. Projects within the existing general plan density range that provide, without other co for some significant public facility not required as part of the development proces! 5. Projects proposing a zone change from non-residential to residential based upon 1 a) The property was zoned for other than residential use on July 1, 19€ findings: b) The property is compatible for residential use without significant mitis c) The density of the project does not exceed the Growth Management ( of any adjacent residential property. ATTACHMPCT3 @ TABLE 40A CONSTRAINTS AND MITIGATING OPPORTUNITIES r3b (A Cross Tabuhtion of Needs and Sohtwns) _.- Corutmints PoliciesIPmgram Offering Mitigating C?opodunities Land Use Contrds Program 2.4 (Adoptive Reuse) Program 2.5 (Mired Use) Program 3.4.a (SenwriEhiedy) Progmm 3.11 (Smaller More Affdle Housing) Progmm 3.7.b (Alternative Housing) Gmwth Management Program 2.3 (Developable Acreage) General Plan Densities Program 3.8 (Growth Management) Program 3.7.a (Density Bonus) Pmgmm 3.751 (Geneml Plan Changes) Program 3.8 (Growth Management) Redevehyrnent Plan Program 1.6 (Rehab Subsidies) Program 1.8 (Rehab Incentives) Program 1.7 (Acquisition & Rehab) Program 1.9 (Rehab - Homeowners) Open Space Requirements Program 2.2 (Development Stadunk) Development Standards Program 2.2 (Devekyment Stanakra3) Program 3.7b (Alternative Housing) Buihiing, Electrhl and Plwnbing Codes Program 3.7.e (Fee Waiver) Fees and Exactions Program 3.7.g (In-Kind Impmements) Offsite Improvements Program 1.5 (Rehabilitation) Code Enfmement Program Program 3.7b (Alternative Housing) II Processing and Permit Processing Program 3.7.f (Priority Processing) I Cak$wniu Environmental Qua& Act Program 4.1 (lfousing Impad Fee) Article XXYN - Calif& Conditution Program 3.4.b (SenioriEkierfy) .%flq Program 3.9 (Housing Needs Priorities) Financing Program 3.10~ (Motigage Revenue Bond) Program 3.10.b (Lending Program) Program 3.13 (Community Reinvestment) Program 3.14 (Housing Trust Fund) Price of Land Program 5.2 (Water Conservatwn) Drought and Water Supply NONE Environmental Program 2.2 (Devebment Standards) COSZ of Condructwn Program 3.12 (Land Banking) Topogmphr Progmm 3.7.g (In-Kind Contributions) Sensitive Habitcrts NONE CaaS&l zone Program 1.6 (Rehab Subsidies) Program 1.7 (Acquisition & Rehob) Program 1.8 (Rehab Incentives) Program 1.9 (Rehab - Homeowners) Program 1 .I 1 (Cmstal Zone) Program 3.6.a (Inclusionary) Program 3.6.b (Incluswnary) Program 3.7.a (Density Bonus) Agricultural LandiWiUiamson Act Program 2.5 (Mired Use) Airpod Land use Plan None P.ogmm 3.3.a (Transiiionai Shebr) Program 3.7.b (Alternative Housing) e m EXHIBIT "C" Staff response to letter objecting to the draft Negative Declaratic (Note: A portion of this letter deals with the content of the d Housing Element and responses to these comments are containec Ex h i b it "A1') ? C e 0 ,Ll Y-i 4 City Council Carlsbad 1 "' RECE/U~~ I had previously submitted most a€ these com~nents to the Planning Commission on September 4, 1991. Generally, government's success in providing housing has been a dismal one, at least judging from public housing projec Furthermore, mention "low income housing" ta any property own' however modest the investment, and every red flag goes up. If: income housing'' is viewed as detrimental to property values (which., after all, is of some significance to this City also) causes an increase ia traffic, congestion, crime, bad schools etc. Only senior housing escapes the property owners' wrath.. least partially. Certainly this Housinq Element, by stressin1 that every quadrant must absorb its "fair share" of low incomi housing seems to reinforce these perceFtions, by giving the impression (maybe unintentionally) that it's a burder: to be shared, along with its pain and disagreeable features. need for a Housing Element. This legislation, from 1980 is completely outdated and unworkable for the State of Californiz now. Our representatives need to work on this. Ir, the last decade, we have seen two explosions in the state, particularly in Southern California -- population and housing prices. Californiz immigration continues at an unprecedented rate -- legal, illegal, transient, temporary, wi a strain or: every resource. Most of us notice it most througf. heavy development, traffic congestion, air pollution, lack of recreational space, lack of classrooms, and even an adequate water supply. Choice residential areas, particularly near the ocean be( more expensive and gradually out of reach financially for almc everyone. Younger families go into new tracts (e.g. Temecula) where they trade a longer commute for more open space, lower prices, and aR agreeable life style. aerospace, finance, heavy manufacturing, are shrinking or disappearing to other locations. These are the jobs which provided the good wages which built up Southern California OVE the last forty years. Fewer opportunities in high paying jobs that's what is sustaining the "Affordability Gap". Of course market will adjust. It has already. Housing srices are flat have even declined. Rousing is being auctioned. Prcperty pri I've read Government Code Article 10.6 which dictates tht What I think is ominous is that the well paying jobs,, in e e 2 are reduced to sell. Actually, there is a tremendous amount affordable housing all over North County: houses, apartments, condos, townhomes. Gf course much of this hou.sing is further inland, and therefore not in perhaps what a lot of people perceive as prime areas. But actually very few people can li exactly where they wish. Ultinately, the market determines t selection, I find it difficult to agree with the report that links traffic congestion with the fact that people don't live near their jobs in Carlsbad. If that were true, then our roads wo' only be crowded at rush hour. But that's simply not the case Interstate 5 is always busy, as is the Village, and the Palom Airport road interchange. Congestion comes from massive development and inadequate rcads and no continuous, convenien rapid transit. Carlsbad is obviously not just housing worker: for local employers. It is also a bedroom community for work1 in La Jol.la, Mira Mesa, San Marcos, even Orange County. Some people even commute (at least part of the time) into Eos Ange It is unfortunate that the Housing Element could not use 1990 Cemus figures. A lot of the statistical data is from tl 1980 Census and projections are based on that. California of 1980 is simply not the California of today. groups -- students, seniors, handicapped, military, homeless, migrants/agricultural. Probably, the only group whose needs 1 be accurately assessed are those of seniors. In assessing housing needs, the report considers various Let's take the case of students, junior college and up. Traditionally students commute from home or share living space near campus. Carlsbad has no college, except a small Chapman facility in an office park, UCSD, University of San Diego, San Diego State are almost twenty miles away. Califorr State University San Marcos is at least eight miles away. Wh: are we considering housing needs of students who don't attend college in our city? On the one hand, we say workers should : near their jobs -- why would we build housing for a universit] mi i es away? Is it Carlsbad's responsibility to build housing for Cam! Pentagon simply has not adjusted its budget to reflect the fa( that the majority of our volmteer military force is married, usually with dependents! Here, our political representatives need to exert some pressure! Military housing stipends need 1 be realistic and to keep pace with inflation. Peradleton, or Miramar Naval Air Station? I don't think SO. ! I) e ! 3 Obviously, the place to build this type of family housina at Camp Pendleton, Fortunately, the areas near tha base are of the most affordable. rao city in America has solved the homeless problem. It generally agreed that many are ill, drug and alcohol addicted full-blown psychotic, Police in many areas do "mercy booking to get them off the street. Others are women and children, o families, often dislocated, out-of-area, who need temporary assistance, the way the Red Cross assists disaster victims, v: motel vouchers, etc. A local jurisdiction cannot tackle this problem except in the most elementary wayI which is how churcl and charitable organizations approach it. 15 many homeless (particularly single adults) belong in a hospital, how can yo. build hcusing for them? Seniors is one group for whom affordable housing p!.a.nninc can bs accurate, often successfui and easier to gain local approval. A great deal of innovation can be used here. Abov all, this type of housing has to be accessible to two things: transportation and services. Therefore, what sense would it : to locate it in a remote area in c)ur south-east quadrant, for instance? The lack of housing for migrant agricultural labor is of course a disgrace" even although the problem will disappear \ Carlsbad builds out. However, the recent inability of Encinil to convert just one defunct motel for migrant housing is I believe 5 pretty accurate indication of the difficulty of building housing for this group. Trailers should be brought ( the agricultural sites. already being provided by relatives in this city. What about adult child living with parents, the senior living with a chi: the handicapped adult being cared for by a relative? The rep( really doesn't consider these people. Technically, all of thc should be provided with housina. Would the city then pay a stipend to their families? I doubt that. Often. these people can't even be claimed as dependents for income tax purposes. Let's now consider Carlsbad's housing stock and the repor recommendation on how the affordable housing should be built. First of all, 1 saw nothing in the Housing Element legislatior that mandated that 3 city has to spend any of its own revenue5 Furthermore, a lot of federal and state funds have "dried up". A great deal of housing for "low income" residents is However, in the area of rehabilitation, there still may f: money available. I am uuite shocked at the large number of dilapidated or decaying residential structures in this city. Unless this is reversed, their decline will result in areas of 0 . 4 high crirne, with lenders refusing to make any type of loar, in area. Deteriorating areas always create even more need for housing. People won't consider them as housing options, unle: they are absolutely desperate. More and more Enits are reall: sort of ''off limits". This decreases the housing stock and increases the price of the other units, I don't think there i: one thing a city can do that is m~re beneficial and pays g-rea' dividends than to reverse urban blight -- whatever it takes more inspectors, code enforcement, impounding of abandoned or illegally parked vehicles, prevention of illegal business activities., garage conversions, etc. In the long run it's mu1 cheaper to take remedial action than to let a project or bloc: completely decay. Whenever a building project is sv-bsidized by waiving fee: someone else has to pick up the difference. Since all fees are passed on to the buyer eventually, thl result is that the other projects become even more expensive, creating- even a greater need for affordable housing. It's a vicious circle. Also, how can you consider lowering building standards, particularly in earthquake country? In fact, the higher the building density, the stricter the codes should be That's why there are required exit and emergency signs in hot^ and not in houses6 1 am emphatically opp~sec! to a Real Estate transfer tax ' pay for anything. I consider it highly discriminatory. Why? Because only one type of property is singled out. What about other property which appreciates, such as stocks, bonds, jewe: antiques, club memberships? What about people who arec't selling? I think it is outrageous that a 70 year old widow g( into a nursina home is taxed to pay for someone else's' housi~ Call it z hvnothetical I- case! but that's the scenario th3.t is created. We are unhappily ir, a five-year drought. Statewide, residential water use is 15% of the total. However, the residential customer has bzan hit with severe restrictions. : there is a real emergency, I don't understand how one buildin! permit is handed out. However, the report proposes that some1 if we retrofit our houses (to the tune of hundreds or even thousands of dollars) somehow the water we save can provide wi to hundreds of new homes, without any change in consumption! "Retrofit" has become a nice little buzz-word. I'm not sure : current residential customer should lose his landscaping investment to supply water for new hook-ups. This point has E made repeatedly, particularly in the last year. e 0 5 Nothing in the Housing Element discusses how candidates 1 the low-income housing should be selected; by lottery, waitin? list? Should a applicant have to be a resident or employed iI Carlsbad for say, five years, or can anyone qualify, even a recent arrival from out of state? I haven't zddressed every point in this Sousing Element : my comments are lengthy enough. Thank you for reading them. In. COBC~US~O~, I do find it irc;nn.ic that at a time when mi of the world is struggling to achieve a market economy, with ( blessin? and encouragement, this Housing Element report goes completely against the concept. ResFectfully submitted, Henata B. Mulry Carlsbad resident October 21, 1991 ' t 0 W October 22 I 1991 Mayor Bud Lewis 1200 Carlsbad Village Drive Carlsbad, CA 92008 Re: Draft Housing Element of General Plan Dear Mayor Lewis: On behalf of the property owners who are the applicants 1 the recently filed Rancho Carrillo Master Plan Amendment, we 1 like to take this opportunity to express our general suppori our specific reservations concerning the Draft Housing Eleme: the General Plan which is before the City Council tonight. We encourage the City in its efforts to provide adec housing to all segments of the community. High housing cos1 Carlsbad have resulted from a reduced supply of developable and expensive City fees and construction costs to meet the qui of life standards the residents of Carlsbad have demanded. , are all aware, those high housing costs have made reside: purchase or leasing by low and moderate income households nl unattainable in housing projects completed within the last sev eight years. While we look forward to working with the City in achiev form of inclusionary zoning may well render projects economi infeasible and in so doing, exclude residential projects fro: City. Our comments to the Draft Housing Element are as foll 1. The 15% affordable housins soal is not attainable a unenforceable without specific implementins ordinances. You m aware that a representative of our group has been particip with City staff and other members of the building industry 1 advisory committee for affordable housing. The challenge of committee and for the City tonight and in the near future ensure that the 15% inclusionary zoning standard set forth i Draft Housing Element can be achieved without causii disproportionate share of the affordable housing burden to be by new residential development. Part of that burden mu: shouldered by the City as contemplated by Objective 3.7 01 Draft Housing Element. broader base of affordable housing, we are concerned that a : 1 1 * w Mayor and City Council October 22, 1991 Page 2 2. The Draft Housins Element mandate directins that 8! 1400 new affordable units be Provided within master DL communities will cause nesative economic impacts on developmen is an inefficient allocation mechanism. It has been recog] that affordable housing sites should be near employment and r( support centers and public transportation facilities. characteristics will not always be available in or even nc given master planned community. Therefore, in addition to subsidies the Housing Element should allow developers to pay a "in-lieuI1 fee or directly to provide alternative sites affordable housing outside a given master planned area or quad: Such contributions are contemplated for specific plan areas qualified subdivisions under Policy 3.6(b) and should be add1 Policy 3.6 (a) . 3. Enforceable implementins ordinances of the Hol Element should be enacted followins a survey of existins afforc housins and an analvsis of proiected deficiencies the: Imposition of conditions which aim to overcome deficiencies 1 would occur as a result of new development, as oppose cumulative deficiencies which would exist without new develop] can only be crafted after such a survey and analysis have completed. Ordinances implementing the City's Housing Element be grounded in a finding that new development 1381 se h reasonable relationship to a shortage of affordable housing. a nexus has not yet been demonstrated. We wish to reiterate our support for the City in meetinc affordable housing objectives and we look forward to continui: work with the City toward that end. We wish to thank the COI for considering our comments to the Draft Housing Element. Yours very truly, CONTINENTAL HOMES BY Christopher J - Chamber! CJC:rf hsqelmt.rf cc: Ann Kulchin Eric Larsen Julie Nygaard Margaret Stanton Ray Patchett Marty Orenyak Michael Holzmiller Vince Biondo Residential Parcels/Zone 18 e w PROJECT FUTURE P.O. BOX 4650 CARIBBAD, CALIFOMIA~ 92018 October 22, 1991 TOt CITY COUNCIL CITY OF CARLSBAD RE$ GPA 90-8 - HOUSING ELEMENT Dear city councilmembers, We have made numerous comments regarding the Negati. Declaration. We believe that this document needs an EIR. Planni staff and the Planning Commission have decided it does nat. Specifically, answer #8 (to the comments by HCD) point o just one of many of the potential. adverse impacts associat with the adoption of the proposed dement. Staff states the "under the existing General Plan the maxim residential density that can be achieved is 15-23 d,u./; (with a Growth Mahagement Control Point of 19 d.u./ac). I permitting the upper limit of 23 d.u./ac. and providing i least a 25% density boh116, 29 d.u./ac. could be attained," The response goes on to state that "there exists in excess ( 6,000 acres of undeveloped Planned Community and Limit1 &mkr.c>l zbhed property with the City." These PC and LC zonc are defined as "holding zones until more precise land UI planning is done". Therefore under the City's present land use plan and proposr housing element, there is a potential for 174,000 dwellir rr-ulecc r-ucure, p. 2 a m units in the undeveloped areas of the City of Carlsbad. The potential adverse impact of the proposed and promised { HCD) density increases is not discussed anywhere in the eith the proposed negative declaration or the proposed eleme itself. Nor is the potential impact on public facilities a schools, etc. addressed. Tn fact such an increase is n' mentioned or evaluated. Master Plans are designed to fBow from the Land Use Elemen The Land Use Element should set a cap on the total number of acr which can be desiqnated for 29 d.u./ac. within the City Carlsbad. Then this cap for each of the Quadrants should delineated within the Proposed Housing Element. This type of planning is required to meet the density a] intensity requirement of the Government Code, OPE Guidelines, a1 the KCD. This has not been done. The City of Carlsbad acts 86 , it may determine ultimate densities and intenxities at will, SOJ time in the future. This is not the purpose of the General PLi Process. This is the type of potential adverse impact which the city Negative Declaration does not mention, discuss or evaluate. Whij the housing element is in fact a policy document, its adoption set in motion the road map for the future of the city of L'arlsbad. Environmental Impact Reports are done not only on "developmer projects" but also on policy documents which have the potential t set in motion future actions which create adverse impacts. Ti EnVirOnmental Impact Report can be included within a General PI.; Element, and in this case should evaluate how the proposed nt policies and goals meet the requirements of the City's Land Us Element and Growth Management Policy. This single point requires more in depth evaluation. We d R 0 e hat believe that. a sentence hy sentence evalutll..ior) of tlle elem is required to point: out ti~nt the Neyative becbarati.on cannot supported. Wle prup,,osed element.., while attempting tu meel; E;tr.at;e hous, goals is in cwflict. wit11 other Blemeut;s, both adopted l pxuposed, of the city ' B yr!nernl plan. while i;he city is planned quadrants, the tutal nunbx or I~ousiny units 111 each quadrant, ulthate &msit:.y, Lyp, a11d- design give rise tu a variety envirunmental and sucin.1 impacts, sane pusitrive and son\e adver whioh the City llas 1)(.11; even attempted to evaluate, Instead this proposed element gives a 1au11dx-y list pvseibilityies ~311~1 states that a11 lnay be t;r:iecf if t-ha priv develup~tler1i; ir~dustxy wa1jt.s t~, Whj.Qll uol: L,it:)tf rlq a goLutioI2 pXWVIdillCJ ade(4llat.e lOW aY~d NlOderatC3 1kOUEiirlCJ wili<:il i.s i.11 keep with the chauautser of the city, and its other goals. A ckkizert * B iiousincj RI.~!ment C:o~rrrni~tteo should he c;rc?nt:ed given tho j& of Po~~ml1Ia.~.:i.rl~ the Blement, a tlectlr11.que which rec!ommenderl by the Off ice of PIa,nniny and ~esanrc11, and successfully impl~mentetl in mst Cities in califosnia. Carlabat one of tlie few wlrioh cut, tl~ residerllx out of tlje pla~sniny prod^ despite it+ 's so-called ttext.elwive publia review p.rvces~1~. 9incerely, PROJECT FUTURE Ahne Mauch &. /k afxcA---"-.- -.._ 6 a LEGAL AID SOCIETY 6F SAN DIEGO, INC Office of Ithe Public AtItolrmey s?nb so ~~~~~~t sto Oceanside, CA 92054 (bn91724-2740 (6119) 722-1935 1 f. YW !%:, :.. - m October 22, 1991 Bud Lewis, Mayor City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 Re: Draft-City of Carlsbad Housing Element 1991-1996 Dear Mr. Lewis: < The Legal Aid Society of San Diego, Inc. represents very-low income residents of the City of Carlsbad. As throughout San Diego County, the need for affordable housing constitutes a crisis in the City of Carlsbad, While lower income house- holds (those making 80% of median or below) represent over 25% of the City's population (Carlsbad's, Draft Housing Element 1991-1996, page 43) only 2.4% of the 26,931 housing units in Carlsbad are affordable to the lower income. (SANDAG Housing Needs Performance Report, Table 1, page 1, November 23, 1990). Before commenting on Carlsbad's proposed programs, it is necessary to question some of the assump- tions made in assessing the City's needs. The Society hopes that these comments, and any resulting revisions to the Housing Element, will provide the frame work for an aggres- sive housing program to meet the needs of Carlsbad's very- low income residents. Needs Assessment As part of the City's needs assessment, it is required to focus on the special needs within its population, Although the homeless farmworker population is reasonably estimated at approximately 1,000 on a year-round basis and 3,000 at peaks of the season, the urban homeless population is gros- sly underestimated at approximately 8 individuals (Draft Element, page 54). Because the City of Carlsbad provides no services to resident homeless, it is understandably diffi- cult for the City to estimate this population. However, the neighboring City of Oceanside provides emergency shelter and services to Carlsbad residents. In fact, the City is regu- larly provided with data from the various social service agencies in Oceanside when they apply to Carlsbad for CDBG %w.wnPartby Unl" af~oies3cunty . Bud Lewis, Mayo October 22, 199 Page 2 0 funds to cover the cost of serving Carlsbad residents. The City should contact the Ecumenical Society, Brother Bennos, and other agencies in Oceanside as well as the San Dieguito Resource Center in Encinitas for more accurate figures with regard to the number of Carlsbad's urban homeless. The first step to house the homeless is the identification of potential shelter sites. While Carlsbad notes that it has established criteria for selecting these sites (Draft Element, page 60) it fails to acknowledge that the criteria established precludes any site from being so designated. On April 2, 1991, the City Council heard Agenda Bill Item No. 11,102, an update on finding a Carlsbad location for an emergency shelter. In Eecember of 1990, the Council direc- ted the staff to investigate shelter sites. The City sent over 100 letters to owners of vacant land in Carlsbad and inventoried properties owned by the City, Carlsbad Municipal Water District, School District and County of San Diego. No city owned property or private land was deemed to meet the criteria established by the City, which suggests that the City should re-evaluate its standards. While it would certainly be desirable to locate shelters along transporta- tion routes, requiring them to be adjacent to hiring halls and police stations imposes negative stereo-types and precludes any shelter from being located in the City of Carlsbad. The City also underestimates the need for student housing. While the new Cal State University, San Marcos Campus, has approximately 1,000 students at this tine, it is projected that that amount will grow to 3,500 by the fall of 1992 and, ultimately, to 25,000 full-time students. With no housing provided on campus until, at the earliest, 1995, the impact felt in San Marcos and in the surrounding communities, including Carlsbad, will be substantial, Another part of the needs assessment is analyzing the dis- parity between residents' income and the cost of housing. Table 16, on page 36, purports to show the number of renters and owners in Carlsbad overpaying for housing. It is unclear from what year this data is taken. Nor can these figures be reconciled with those cited in the first para- graph of this letter. The Needs Assessment for Carlsbad's 1985 Housing Element cites the 1980 United States Census in acknowledging that 83.2% of very-low and low income Carlsbad households paid in excess of 25% of their income for hous- ing. By including the year from which this data is taken, the number of total households for that year, and thus the percentage of total households overpaying in the renter and owner categories, than this information can be verified and will be more useful, . Bud Lewis, Mayo October 22, 199 Page 3 0 While Carlsbad has no federally subsidized units, and there- fore does not need to address the needs created by their risk of conversion to market rate, in reporting to SANDAG, Carlsbad claims it has created nearly 300 affordable units locally. (SANDAG Regional Housing Needs Statement, Table 7, page 10, November 23, 1990). These units were allegedly created by virtue of a senior ordinance, a mortgage revenue bond, and density bonuses. The City needs to identify to whom these units are affordable (very-low or low income), at what rates, and for how long. With this data the City can then address what actions will be taken to preserve their continued affordability, when, and through what funding mechanisms. Governmental Constraint While expedited processing and permit procedures is a cred- ible first step to removing governmental barriers to the construction of affordable housing, it is not a meaningful one if there is no land upon which that housing may be built. The State Department of Housing and Community Deve- lopment estimates that densities of 8 to 18 dwelling units per acre are necessary to construct affordable housing for moderate income households, 18 to 25 dwelling units per acre for low income and 25 to 40 dwelling units per acre for the very-low income. Carlsbad identifies land in its three highest density categories as being sufficient to produce enough multi-family housing to meet its five-year Fair Share goal. At 6, 11.5 and 19 dwelling units per acre, respecti- vely, these zones are of inadequate densities to meet Carls- bad's actual housing needs, or their Fair Share goals. Of concern is not only the low densities allowed but the fact that the tenure of the housing to be built in these zones, dwelling units per acre the resulting housing product will be either attached homes or townhomes for ownership, far out of the economic reach of the very-low, low, or moderate income. Even Carlsbad's highest density, at 19 dwelling units per acre does not provide adequate land upon which to develop its Fair Share goal over the next five years. Only 59.91 acres located in but 2 of the 25 local facilities management zones, are zoned RH (19 dwelling units per acre). While it is true that if each of these acres is developed at its maximum yield, Carlsbad's Fair Share goal will be achieved, it is inconceivable that this could occur. Not all of the raw land may be developable. Further, room is needed for streets, sidewalks and other developments includ- ing shops, park areas, day care, schools, etc. Nor is their any indication that all of these remaining high-density acres will be developed within the next five years or that is not restricted. It is far more likely that at 6 and 11.5 . Bud Lewis, Mayor October 22, 1991 Page 4 e all of the units developed in these two zones will be affordable to the very-low and low income. Carlsbad simply has inadequate land zoned of a sufficiently high-density to either meet its actual needs or its minimum fair share obligations. Nor is it clear that the redevelopment area includes land zoned of a sufficiently high-density to facilitate Redeve- lopment Law's inclusionary housing requirements. The City anticipates that approximately 350 new housing units will be built in the redevelopment area, over the life of the plan. (Draft Element, page 80). Should this housing be developed by the City or Agency, not less than 30% must be affordable to lower and moderate income households with at least 50% affordable to the very-low income. If developed by a priv- ate entity, then 15% must be affordable with 40% set aside for the very-low income. Further, Redevelopment Law has targeting requirements to assure that all housing developed over the life of the plan meets the needs of the very-low, low, and moderate income in proporation to their representa- tion in the population. It is unclear from the City's brief discussion, whether adequate land has been set aside to develop the mandated affordable housing. Without an effective preservation program, the City will lose ground in its effort to provide more affordable housing opportunities. New construction alone is not the whole solution. Historically, the City has been content to allow owners with substandard housing to demolish their units rather than rehabilitate and preserve them. The Society endorses Carlsbad's more progressive approach, as reflected on page 82, which calls for combining Code Enforcement activities with rehabilitation programs, thus preserving the units for lower income families. With regard to expedited permit and processing procedures, it is unclear whether the City intends to offer these cost savings only to housing developments which are entirely low income or to those which are mixed, including market rate units. To further the City's policy of disbursing afford- able units throughout its jurisdiction, it may want tc consider offering this incentive to mixed projects as well as those which are entirely affordable. Goals/Ojectives/Policies/Programs Despite the overwhelming need of families, including large families, for affordable rental housing and Carlsbad's large homeless population of farmworkers and day laborers, Carls- bad's sole commitment with regard to developing housing for . Bud Lewis, Mayo October 22, 199 Page 5 0 any of its special needs populations is a commitment to build 200 units for seniors, This is especially dishearten- ing in light of the fact that Carlsbad has exclusively assisted senior housing developments in the past. While the need for affordable senior housing is real and certainly worthy of attention, the preservation, rehabilitation and development of affordable senior housing must be put in perspective with the needs of other special populations in Carlsbad, In addition, as evidenced on the attachment, implementation of Carlsbad's programs would result primarily in the development of housing for low and moderate income households, and only to a very minor degree to very-low income households, those most in crisis from the lack of affordable housing. ./ By far the majority of programs proposed by the City involve either monitoring the loss of affordable housing or research regarding solutions to the affordable housing crisis. Much of this work has already been done, and Carlsbad need not expend its precious resources to reinvent the wheel. For example, Goldfarb and Lipman has a report entitled "The Affordability Gap Analysis". Local resources such as LISC and Enterprise may be tapped as well, What is really needed is for Carlsbad to develop the in-house expertise on how to leverage local dollars with state and federal programs so that the City may in turn educate the development community about these resources. Carlsbad cites the Redevelopment Set Aside for Low and Moderate Income Housing, as one of the funds that will pay for these studies. This is an inappropriate use of this Fund. Community Redevelopment Law requires that the Low and Moderate Income Housing Fund be used, to the maximum extent possible, to defray the cost of production, improvement and preservation of very-low, low, and moderate income housing. The amount of money spent for planning and general adminis- trative activities must not be disporportionate to the amount actually spent for the housing. In addition, plan- ning and general administrative costs payable from the Fund must be directly related to the programs and activities authorized by Community Redevelopment Law and must be direc- tly attributable to a specific project, Planning and admi- nistrative costs associated with the preparation and revi- sion of the Housing Element, inclusionary housing program, density bonus program or other activities of general appli- cability are not appropriately attributable to the Low and Moderate Income aousing Fund. At a minimum, expenditure of the Fund on the following programs, as proposed, would be inappropriate: 1.10, 2,2, 2.4, 3.3, 3,7e, 3.9, 3.13, and 6.3, Rather, the actual development of very-low income housing (as proposed in program 3.5) and acquiring land for future affordable housing development (as proposed ir 1. . .- . Bud Lewis, Mayo October 22, 1991 0 Page 6 program 3.12) are appropriate uses of the Fund. Specifically with regard to the density bonus program (No. 3.7, Draft Element page 1241, the Society encourages the City to do more than the minimum required under state law. A density above the minimum 25% may be awarded to projects including more than the minimum percentage of affordable units. In addition, the duration of affordability, 30 years, should be extended. The City should provide a menu of options, to be selected by the developer, as additional incentives. Reductions in the square footage, lot size, set back and parking requirements should be included. While one incentive may make a particular project work, other or addi- tional incentives may be required for yet another affordable housing development. In developing the inclusionary housing program for master plan communities, residential specific plans and qualified subdivisions, the Society endorses Carlsbad's efforts. Of the 15% to be affordable to lower income households, we urge Carlsbad to require that: (1) At least 40% of those units be affordable to the very-low income,. and (2) All regulated units be affordable, in perpetuity. If we have learned nothing from the experiment of the late ~O'S, with federal programs such as Section 236 and 221(d) (31, we have learned rents which may be charged fnr a period of only 20 years merely defers the crisis to another generation. Throughout San Diego County, approximately 10,000 federally subsidized units are eligible to convert to market rate between 1988 and the year 2008. Affordability is achieved through a variety of financing mechanism and the leveraging of local monies with state and federal resources. Thus, affordabi- lity is "built-in" from the beginning, It, is therefore, purely arbitrary to restrict the units for merely 20 or 30 years. There is absolutely no reason that those units cannot remain affordable into the future, And certainly they should, as the need for affordable housing will conti- nue to grow. The City's resources for affordable housing development are precious and few. If the City is going to depend on the private sector to develop low and moderate income housing, along with other incentives such as expedited processing, then the City's resources should be directed entirely to the very-low income, We encourage the Council to recommend that revisions be made to the Housing Element to focus your resources on this most needy group. that restricting the income level of the occupants and the through its inclusionary housing and density bonus programs, -. Bud Lewis, Mayo October 22, 199 Page 7 e If you have any questions regarding my comments, or I can be of any help in this effort, I would be happy to speak with you and your staff further about my suggestions. I remain Sincerely, LEGAL AID SOCIETY OF SAN DIEGO, INC. &% CATHERINE A. RODMAN Attorney at Law CAR/b cc: City Council Ray Patchett, City Manager Vincent F. Biondo, Jr., City Attorney Mike McLaughlin, SANDAG William Andrews, State of California, Department of Housing and Community Development 9 9 ATTACHMENT No. /Name Very Low Low - Mc PROGRAMS NEW CONSTRUCTION 3.4.a/b Senior Housing / """" 200"""" / 3.6.a Inclusionary /--""-""""- 853------------------ / Housing (Master Plans/Specif ic Plans) 3.6.b Inclusionary /----"""""-- 233""""""""" / Housing (Specific Plans/Qualified Subdivisions) / 3.7.c Housing /"""- 190 """_ / "" "" 130 """" Authority (New Housing Prod Program) 3.7.d Section 8 /"""""""" 103""""""""" / 3.10.a Mortgage /""" Revenue Bonds 3.1O.c Inclusionary /""" Housing (Master/Specific Plan) REHABILITATION 1.6 Rehabilitation /-----------------5O------------------ / Subsidies/Rentals 1.7 Acquisition /"""-10""""/""""-40"""" / Rehabilitate 1.9 Rehabilitation / -------__----____ 25"""""""-"- / Owner Units PRESERVATION 1.1 Condo Conv. /""""""""""""""~""""""". 1.2 Mobilehome Park/----------------------------O--------------. 1.3 Mobilehome Park/----------------------------O--------------. TOTALS : /- """ 110"""" """_ / / 15p+""-- _____, ..' c m * (Form A) TO: CITY CLERK ' S OFFICE FROM: PLANNING DEPARTMENT RE: PUBLIC HEARING REQUEST Attached are the materials necessary for you to notice - GPA 90-8 - GENERAL PLAN AMENDMENT - HOUSING ELEMENT for a public hearing before the City Council. I Please notice the item for the council meeting of I& . Thank you. MARTY ORENYAK 9/20/91 Assistant City Manager Date e e NOTICE OF PUBLIC HEARING NOTICE IS HEREBY GIVEN that the City Council of the City of Carlsbad will hold a public he. at 1200 Carlsbad Village Drive (formerly Elm Street), Carlsbad, California, at 6:OO PM., on , 1991, to consider a request for approval of the revision to the Hol Element of the City of Carlsbad's General Plan. This revised Housing Element includes a review of the City's existing Housing Elemen assessment of current and future Citywide housing needs, an analysis of constraints opportunities to new housing production or rehabilitation, and a comprehensive action plan to the City's identified housing needs. Included within the action plan are 6 long-term goals, 35 s term objectives, 16 policies and 50 action programs through which the City will impleme, housing program over the next five years. Those persons wishing to speak on this proposal are cordially invited to attend the public hea If you have any questions, please call Chris DeCerbo in the Planning Department at 438-1 161 4445. If you challenge the Revision of the Housing Element in court, you may be limited to raising those issues you or someone else raised at the public hearing described in this notice or w correspondence delivered to the City of Carlsbad at or prior to the public hearing. CASE FILE: GPA 90-8 APPLICANT: CITY OF CARLSBAD PUBLISH: CITY OF CARLSBAD CITY COUNCIL ill @* pcD &!>/ (-(J+pliPd I e 0 NOTICE OF PUBLIC HEARING REVISION TO THE HOUSING ELEMENT OF THE GENERAL PLAN GPA 90-8 NOTICE IS HEREBY GIVEN that the City Council of the City of Carlsbad will a public hearing at the City Council Chambers, 1200 Carlsbad Village D (formerly Elm Avenue), California, at 6:OO p.m, on Tuesday, October 22, 199 consider a request for a revision to the Housing Element of the Cit Carl sbad’s General P1 an. The revised Housing Element includes a review of the City’s existing Ho Element, an assessment of current and future Citywide housing needs, an ana of constraints and opportunities to new housing production or rehabilitation a comprehensive action plan to meet the City’s identified housing n Included within the action plan are 6 long-term goals, 35 short term object 16 policies and 50 action programs through which the City will implemen housing program over the next five years. If YOU have any questions regarding this matter, please call Chris DeCerbo i P1 anning Department, at 438-1161, ext . 4445. If you challenge the Revision of the Housing Element of the General P1 i court, you may be limited to raising only those issues raised by you or so1 else at the public hearing described in this notice, or in written corresponl delivered to the City of Carlsbad City Clerk’s Office at or prior to the pi hearing . APPLICANT: City of Carlsbad PUBLISH: October 11, 1991 CARLSBAD CITY COUNC b2CT 16 '91 BB; '35 SCII-ITHIZW *_. .. -+ e I I, m NOTICE IS HEREBY Q1VEN that the City Councll al the Clty Of Carisbad will hold a publlc hearing at the Clty Council Chambers, 1200 Carfsbad Vlllage Drive (formerly Elm Avenue), Carlsbad, Callfornla, at 8:OO P,M., on Tuesday, October 22, I991 , to mnslder a request for a revision to the Houslng Element of the City of Carisbad's Oensral Plan, The revised Housing Element include6 a review of the City's existlng HOU6lnt~ Element, an assessment of current and future Citywide housing needs, an analysis of c~nstralnts and opportunitiea 16 new housing production or rehabilitalion, and a comprehensive action plan to meet the City's identifled houslng needs, Included within the adlon plan are 8 long-term goals, 35 short tern objectives, 16 potlcies and 50 action programs through whlch the City wifl Implement its houslng pragrarn over the nexl five years. If you have any questtons regardlrtg this matter, please call Chris DeCerbo In the Planning Dapartmenz, at 438-1 761, ext. 4445, H you challenge thw Revlelm of the Housing Element af the General Plan in coun, you may be limited to ralsing only those issues raised by you or someone else at the public hearing described in thls notice, or in written correspondence dellvered tu the City sf Carlsbad City ClWk's Offlce at or prlor to the public hearing. APPLICANT: City of Carlsbad I PUBLISH: October 11, 1991 CARLSBAR CITY COUNCfL FRIDAY City-of-Cbad-10-11 3x5 ciinainzfiGy 10-1 1 ' ' ()ib: Ki!i@p* c"l .. Carlsbad Journal Decreed A Legal Newspaper by the Superior Court of Son Diego County Mail all correspondence regarding public notice advertising to W.C.C.N. Inc. P.O. Box 230878, Encinitas, CA 92023-0878 (619) 753-6543 Proof of Publication STATE OF CALIFORNIA, ss. COUNTY OF SAN DIEGO, I am a citizen of the United States and a resident of the county aforesaid; I am over the age of eighteen years, and not a party to or interested in the above enti I am principal clerk of the printer of the Carlsbad Journal, a newspaper of general published weekly in the City of Carlsbad, County of San Diego, State of California, and which is published for the dissemination of locaI news and intelIigence of a genera1 character, newspaper at all times herein mentioned had and still has a bona fide subscription lis subscribers, and which newspaper has been established, printed and published at regular intc said City of Carlsbad, County of San Diego, State of California, for a period exceeding one preceding the date of public; notice hereinafter referred to; i notice of which the annexed i copy, has been published in e and entire issue of said newspa in any supplement thereof on ing dates, to-wit: October 10 I certify under penalty of perj foregoing is true and correct, Carlsbad, County of San Diego, : fornia on the 10th day of October, 199 w / Clerk I c - NOTICE -OF PUBLIC HEARING REVISION TO THE HOUSING ELEMENT OF THE GENERAL PLAN. . GPA 90-8 NOTICE IS HEREBY GIVEN that the City Council of the City of Carlsbad will hold a public hearing at the City Council Chambers, 1200 Carlsbad Village Drive (formerly Elm Avenue), California, at 6:OO p.m. on Tuesday, October 22,1991, to, consider a request for a revision to the Housing Element of the City of Carlsbad's General Plan. The revised Housing Element includes a review of the City's existing Housing Element, an assessment of current and future Citywide housing needs, an analy- sis of constraints and opportunities to new housing production or rehabilita- tion, and a comprehensive action plan to meet the City's identified .housing needs. Included within the action plan are 6 long-term goals, 35 short term. objectives, 16 policies and 50 action programs through which the City will imple- ment its housing program over the next five years. If you have any questions regarding this matter, please call Chris DeCerbo in the Planning Department, at 438-1161, ext. 4445. If you challenge the Revision of the Housing Element of the General Plan in court, YOU may be limited to raising only those issues raised by you or someone else at the public hearing described in this notice, or in written correspondence delivered to the City of Carlsbad City Clerk's Office at or prior to the public hearing. Applicant: City of Carlsbad CARLSBAD CITY COUNCIL CJ 6363: October 10,1991 . . .. . . . . " . " _. .-..-. - - rx f: .. 3 I Hiryna Pdmoiir .- I - >-->..-* -?-"" ....: ~. . , .. .. .- . . !n house Satur- re Marshal Paul -- luipment wil1.b- t tire pfeventbn .-.- Dawson . - .. said. '~ -1 .~" ~ .____ . tri a I : *g .~ he associamn's t he played for the 982 to 1984 before Los Angeles Rams a Eagles. The asso' careertotals as 82 .,7M yards and 13 ,1 .I :- 1 - '& sa-. , 'FF~' ~.. "" ~ ?s+"~, :. .."." /.".$L i " -+ -.* -~.:2.;';~-=L -~ gz-,L.$i;, :.*&l*.r+ .i -~.~=-:-~~~~.~~~~~.~~~~.~~~~-~~~~.~ , --Fire,~d~stroys~-.Escond"ido .house .- ~ ~ ~ ~~ .. - .. .. . ., . . , ." ; . -+ " . -. ! .. . .. .. . .,: - . ~. - . .. I: - I, : ~ -. .1 , :.;: . L1 :-.. c .__.. r;.q,.. F..e.r- ."* ." -~ . .- . ~, ._ . .. . ...: ? *-;"-,e. :,-?3 ! . i *" .- . ~. . .~ ~, :~ i I ,~ . . -; si- _-.. ~. ".. .. . . r"' ? ~ ; . _. . - .- -~ "._ . ~ . .~ - -- . . _I -* . : +-...... . - . . -~ i- ,.--- . -; ..,,,.:. r., __ . . 4: . .. .. ..: .. ., I - . i >, -. _. : *- ~ ... - . . . ~ "=~. . -. i _. - . ~. .. . . -- : .. - . .. -. ., . .~ ~ ! -:-. - .~ .- ~. . - . - ><~.*?" . .-I .:.*- ..I ._ r . , - - . . ._ . . ..i .. . .- . ~. i_- .I ril rB" I I I I I I I I I I I I I I I I I I I I - CITY CLERK'S OFFICE COPY ~ ~ ."" ~. . ~ I I I I I I I I I 1 I I I I I I I I I CITY COUNCIL CLAUDE A. LEWIS, MAYOR ANN J. KULCHIN, MAYOR PRO TEM ERIC LARSON JULIANNE NYGAARD MARGARET STANTON PLANNING COMMISSION ROBERT HOLMES, CHAIRMAN TOM G. ERWIN, VICE-CHAIRMAN MATTHEW HALL MARY MARCUS JEANNE B. McFADDEN CLARENCE SCHLEHUBER SHARON SCHRAMM STAFF RAY PATCHETT, City Manager MARTY ORENYAK, Community Development Director MICHAEL HOLZMILLER, Planning Director DENNIS TURNER, Principle Planner TOM PONSFORD, Associate Planner, Project Manager RENEE GRABLE, Planning Intern I I I I I I I I I I I I 1 I I I I I I THE CITY OF CARLSBAD The City of Carlsbad, California, incorporated in 1952, is approximately 40 square miles of bea coastal San Diego County. Known as the "Village by the Sea," Carlsbad has the charm of a q seaside community together with the contemporary feel and look of a progressive bus environment. Named for a famous spa in Karlsbad, Bohemia (because of the similarity of the mineral water), Cal is bordered on the west by uncrowded Pacific beaches and on the east by rolling hills and char covered mesas. Carlsbad has evolved in the past decade as a focal point in North San Diego County for busines cultural activity. The city welcomes progressive and creative businesses to explore some of San County's most prime industrial land and commercial opportunities. Its progressive city government legislates a unique balance of public services and planning stra. to meet the current and future needs of the citizenry. Though committed to economic growth, tt is critically sensitive to Carlsbad's unique ecological position as a coastal city of beaches, 1 lagoons, and unspoiled canyons. Carlsbad is strategically located between two of California's largest metropolitan areas - Los AI 90 miles to the north and San Diego 35 miles to the south. A major freeway, Interstate 5, tra\ the city from the north to south, providing easy access and transportation to all points of Sot California. Carlsbad boasts one of the most attractive climates in Southern California. Virtually smog-fre air is regularly cleansed by the cool ocean breezes of the Pacific. Its vivid blue skies, low hun and light rainfall make the Carlsbad area delightful for living, working and playing. Temperatures from an average of 58 degrees in January to an average of 73 degrees in July. Annual r averages about 7 inches, most of it falling between October and February. Source: Culsbd Chmbar of Commsrce. Cammvlity Overv~ew i EXECUTIVE SUMMARY The Housing Element is one of the most important of the mandatory elements required to be included in a jurisdiction’s General Plan. Within the last ten years substantial changes have been made to the statutes that concern the information required and the processes that produce the Housing Element. The Housing Element is divided into four major sections. Section One deals with a review of the City’s previous Housing Element, what programs were successful, and what programs were not. The purpose of this section is to critically look at past housing programs for better success in the next five year housing period. Section Two is the Elements housing inventory, needs analysis and demographic projections. It also looks at housing for special groups such as the elderly, handicapped and the homeless. Section Three identifies the constraints and opportunities for housing production within the City. It looks at all constraints that are applicable to Carlsbad. Some of these constraints are major and some have little impact individually, but cumulatively may be substantial. After each constraint a mitigating opportunity may be identified in order to overcome constraints. An inventory of the total acreage in Carlsbad is identified along with the approximate amount of residential acreage still to be developed. Section Four identifies the City’s Goals, Objectives and Policies that deal with housing development. The housing needs are identified and programs to meet these needs are offered. The Housing Element as presented represents a commitment by the City to provide for existing and future housing needs for all economic ranges. It also must be identified that Carlsbad may have significant constraints to development of some types of housing and that a commitment must be maintained to development of opportunities for housing that has been previously overlooked. ii I I 1 I I I I I I I 1 I I I I I I I I TABLE OF CONTENTS BACKGROUNDANDINTENT........................................ STATELAW ................................................... RELATIONSHIP TO OTHER ELEMENTS ................................. SECTION ONE - REVIEW OF PREVIOUS ELEMENT HOUSING NEEDS PERFORMANCE .................................... REVIEW OF HOUSING ELEMENT 1985 - 1990 ........................... SUMMARY .................................................... SECTION TWO - HOUSING INVENTORY AND NEEDS ASSESSMENT HOUSING NEEDS ANALYSIS ....................................... POPULATIONGRO~H ...................................... POPULATION PROJECTIONS .................................. POPULATION BY AGE GROUP ................................. POPULATIONBYRACE ...................................... HOUSING PROJECTIONS ..................................... HOUSINGTRENDS ......................................... APPROVEDANDPROJECTED UNITS ............................ HOUSINGCOSTS .......................................... RENTS ............................................ SALESANDRENTCOSTS .............................. HOUSEHOLD CHARACTERISTICS .................................... HOUSEHOLDSIZE IIII.,o.,,l.III,II,~III.,II~II~IIIIII~II VACANCYRATES ......................................... HOUSING UNITS BY TYPE .................................... HOUSINGTENURE ......................................... OVERCROWDEDUNITS ...................................... HOUSEHOLD INCOME ...................................... PRESERVATION OF AT-RISK UNITS .................................. EMPLOYMENT ................................................ EMPLOYMENTTRENDS ..................................... JOBSHOUSINGBALANCE................................... SPECIAL HOUSING NEEDS .................................. ESTIMATED HOMELESS POPULATION ..................... SHELTER CAPACITIES, SERVICES & SCREENING AGENCIES ..... POTENTIAL SHELTER SITES ............................ ESTIMATED FARMWORKER POPULATION .................. SINGLEPARENTS ................................... LARGE FAMILY HOUSEHOLDS I I a I I 1 , I 8 e I e e e a b 1 1 n I I I I * 1 I SENIOR/ELDERLY POPULATION .......................... HANDICAPPED ..................................... MILITARY FAMILIES .................................. STUDENTS ........................................ HOUSING NEED BY INCOME CATEGORY ........................ LOW AND VERY-LOW INCOME HOUSEHOLDS ............... MODERATE INCOME HOUSEHOLDS ...................... UPPER INCOME HOUSEHOLDS .......................... EMPLOYMENT BY OCCUPATIONAL SECTOR ...................... HOUSING NEEDS iii SECTION THREE . OPPORTUNITIES. CONSTRAINTS. LAND INVENTORY. ENERGY CONSERVATION OPPORTUNITIES AND CONSTRAINTS TO HOUSING DEVELOPMENT .................. 70 GOVERNMENTAL CONSTRAINTS ..................................... 71 LANDUSECONTROLS ....................................... 71 ZONING ............................................ 71 MITIGATING OPPORTUNITIES ............................. 73 GROWTH MANAGEMENT ..................................... 74 MITIGATING OPPORTUNITIES ............................. 75 GENERAL PLAN DENSITIES .................................... 78 MITIGATING OPPORTUNITIES ............................. 79 REDEVELOPMENTPLAN ...................................... 80 OPEN SPACE REQUIREMENTS .................................. 81 MITIGATING OPPORTUNITIES ............................. 81 DE'IELOPMENT STANDARDS .................................. 81 MITIGATING OPPORTUNITIES ............................. 81 BUILDING, ELECTRICAL AND PLUMBING CODES ..................... 82 MITIGATING OPPORTUNITIES ............................. 82 CODE ENFORCEMENT PROGRAMS ............................... 82 MITIGATING OPPORTUNITIES ............................. 82 OFFSITE IMPROVEMENTS ..................................... 83 CIRCULATION IMPROVEMENTS ................................. 83 MITIGATING OPPORTUNITIES ............................. 83 FEES AND EXACTIONS ....................................... 83 MITIGATING OPPORTUNITIES ............................. 83 WAIVING OF PFF FEES .................................. 83 HOUSING-IN-LIEU FEES ................................. 85 JOBS HOUSING IMPACT FEES ............................ 85 REAL PROPERTY TRANSFER ASSESSMENT TAX ............... 85 PROCESSING AND PERMIT PROCEDURES .......................... 86 MITIGATING OPPORTUNITIES ............................. 87 CALIFORNIA ENVIRONMENTAL QUALITY ACT ...................... 87 MITIGATING OPPORTUNITIES ............................. 87 MITIGATING OPPORTUNITIES ............................. 88 NON-GOVERNMENTAL CONSTRAINTS ................................. 89 AVAILABILITY AND USE OF PUBLIC FINANCING ................ 89 CURRENTRATES ...................................... 90 MITIGATING OPPORTUNITIES ............................. 92 MORTGAGE REVENUE BONDS ............................ 92 PUBLIC FINANCING .................................... 92 LOW INCOME PERMANENT FINANCING ...................... 93 COMMUNITY REINVESTMENT ACT ......................... 93 MITIGATING OPPORTUNITIES ............................. 80 STAFFING ................................................ 88 FINANCING ............................................... 89 REDEVELOPMENT SET-ASIDE FUNDS ....................... 93 COMMUNITY DEVELOPMENT BLOCK GRANT FUNDS ............ 93 PRICEOFLAND ............................................ 94 MITIGATING OPPORTUNITIES ............................. 94 IMMINENT DOMAIN/FRIENDLY CONDEMNATION ............... 94 LANDBANKING ....................................... 95 GOVERNMENT/PUBLIC LAND ............................. 95 CONSTRAINED ACREAGE ................................ 95 iv I 1 I I I I I I I I I I I I I I 1 I I COSTOFCONSTRUCTION .................................... LABOR ............................................. AVERAGE CONSTRUCTION COSTS .............................. MITIGATING OPPORTUNITIES ............................. FACTORY BUILT HOUSING/MANUFACTURED HOUSING .......... DEVELOPMENTSTANDARDS ............................. CONSTRUCTION MANAGEMENT ........................... ENVIRONMENTAL CONSTRAINTS ............................... ENDANGEREDSPECIES ....................................... MITIGATING OPPORTUNITIES ............................. DROUGHT AND WATER SUPPLY ................................ CONSTRUCTION ...................................... LONG TERM AVAILABILITY .............................. MITIGATING OPPORTUNITIES ............................ , TOPOGRAPHY ............................................ MITIGATING OPPORTUNITIES ............................ SENSITIVEHABITATS ....................................... MITIGATING OPPORTUNITIES ............................ COASTALZONE ........................................... MITIGATING OPPORTUNITIES ............................ AGRICULTURE LAND/WILLIAMSON ACT .......................... MITIGATING OPPORTUNITIES ............................ AIRPORT LAND USE PLAN ................................... MITIGATING OPPORTUNITIES ............................ VACANTLANDINVENTORY ........................................ ENERGY CONSERVATION IN HOUSING DEVELOPMENT ..................... SECTION FOUR - GOALS, OBJECTIVES, POLICIES, PROGRAMS .................... GOAL 1 (PRESERVATION) ......................................... GOAL 2 (QUANTITY AND DIVERSITY OF HOUSING STOCK) ................. GOAL 3 (GROUPS WITH SPECIAL NEEDS, INCLUDING LOW AND MODERATE INCOME HOUSEHOLDS) ..................................... GOAL 4 (HOUSING, JOBS, WORK FORCE BALANCE) ...................... GOAL 5 (RESOURCE CONSERVATION) ................................ GOAL 6 (OPEN AND FAIR HOUSING OPPORTUNITIES) ..................... PRIORITIES, CITIZEN PARTICIPATION, UPDATE AND REVIEW ................ INTRODUCTION ........................................... CITIZEN PARTICIPATION ..................................... MANDATED REVIEW AND UPDATE ............................. APPENDICES V LIST OF TABLES PAGE # POPULATION 1980 - 2000 TABLE1 ........................................................ 1 HOUSING NEEDS PERFORMANCE TABLE2 ........................................................ 6 POPULATION TRENDS TABLE3 ....................................................... 26 PERSONS PER HOUSEHOLD TABLE4 ....................................................... 27 POPULATION BY AGE GROUP TABLE5 ....................................................... 28 MEDIAN AGE TABLE6 ...................................................... 28 POPULATION BY RACE TABLE7 ...................................................... 30 PROJECTS IN SUBMITTAL TABLE8 ....................................................... 31 PROJECTED HOUSING UNITS TABLE9 ....................................................... 31 AGE OF HOUSING STOCK TABLE10 ...................................................... 32 CONDITION OF RESIDENTIAL STRUCTURES BY TENURE TABLE11 ...................................................... 32 CONSTRUCTION OF HOUSING UNITS TABLE12 ...................................................... 33 APPROVED UNITS AS OF 12/90 ' TABLE13 .................................................... .. 34 AVERAGE RENTS TABLE14 ...................................................... 34 LOWER INCOME RENTS TABLE15 ...................................................... 35 HOUSEHOLDS PAYING MORE THAN 25% TABLE16 ..................................................... 36 REGIONAL ACERAGE RENTS TABLE17 ....................................................... 36 vi 1 I I I I I I I 1 1 1 I II I I 1 I 1 1 PERSONS PER HOUSEHOLD BY TYPE OF UNIT TABLE 18 ........................... .................. ........ VACANCY RATES TABLE19 ............................. ........................ NEW HOUSING BY TYPE TABLE20 ..................................................... HOUSING TENURE TABLE21 ..................................................... OVERCROWDED UNITS TABLE22 ..................................................... CARLSBAD HOUSEHOLD INCOME DISTRIBUTION TABLE23. I ..I ,. I I..I I a I I., I I. I I 1,,,,~,,,,,,,,,,,,,,,,,,,,,,,1 CARLSBAD MEDIAN HOUSEHOLD INCOME TABLE24 ..................................................... CARLSBAD MAJOR EMPLOYERS TABLE25 ..................................................... EMPLOYMENT TRENDS TABLE26 ..................................................... EMPLOYMENT BY OCCUPATION TABLE27 ..................................................... EMPLOYMENT BY INDUSTRY TABLE28 ...................................................... WEEKLY EARNINGS OF OFFICE, PROFESSIONAL AND TECHNICAL WORKERS TABLE29 ..................................................... HOURLY EARNINGS TABLE30 ..................................................... HOMELESS PROGRAMS AND SERVICES OFFERED BY CITY CHURCHES TABLE31 ..................................................... HOMELESS PROGRAMS AND SERVICES TABLE32 ..................................................... SINGLE PARENT WITH CHILDREN TABLE33 ..................................................... LARGER HOUSEHOLDS TABLE34 ..................................................... MILITARY HOUSING NEEDS TABLE35 ..................................................... vii FUTURE HOUSING NEED BY INCOME CATEGORY 1991 -1 996 TABLE36 ........... .....so..., ....., I.II...~II.,I,4 ,,,, a~IIII, 65 AVERAGE PRICE OF HOMES SOLD DURING 1989 TABLE37 ...................................................... 66 MEDIAN AND AVERAGE HOUSING PRICE TABLE38 ...................................................... 68 COST OF RESALE HOMES TABLE39 ...................................................... 69 CARLSBAD HOME AND CONDO PRICES TABLE40 ...................................................... 69 RESIDENTIAL ZONING DISTRICTS TABLE41 ...................................................... 71 OVERLAY ZONES TABLE42 ...................................................... 72 (NOT USED) TABLE43 ......................................................... DWELLING UNITS BY QUADRANT TABLE44 .................. ;.. ................................. 76 GENERAL PLAN RESIDENTIAL LAND USE DENSITIES TABLE45 ..................................................... 78 FEES FOR PROTOTYPE HOME TABLE45 ...................................................... 85 PROCESSING TIME TABLE47 ...................................................... 87 CHANGES IN INTEREST RATES TABLE48 ...................................................... 91 MORTGAGE INTEREST RATES TABLE49 ...................................................... 91 MONEY RATES TABLE50 ...................................................... 92 CARLSBAD SENSITIVE SPECIES LIST TABLE51 ...................................................... 99 ACERAGENNIT YIELD TABLE52 ..................................................... 106 RESIDENTIAL LAND INVENTORY TABLE53 ....................................,................ 108 viii I I I I I 8 I I I I 1 I I I I I I 1 I EXCERPTS FROM THE CALIFORNIA GOVERNMENT CODE Article 10.6 Housing Elements Policy 65580. The legislature finds and declares as follows: fa) The availability of housing is of vital statewide importance, and the early attainme, decent housing and a suitable living environment for every California family is a priority o highest order. fbl The early attainment of this goal requires the cooperative participation of governmen' the private sector in an effort tc expand housing opportunities and accommodate the hoc needs of Californians of all economic levels. (cl The provision of housing affordable to low-and moderate-income households require cooperation of all levels of government. Id) Local and state government have a responsibility to use the powers vested in thr facilitate the improvement and development of housing to make adequate provision fc housing needs of all economic segments of the community. le) The legislature recognizes that in carrying out this responsibility, each local goverr also has the responsibility to consider economic, environmental, and fiscal factor: community goals set forth in the general plan and to cooperate with other local govern, and the state in addressing regional housing needs. (Added by Stats, 1980, Ch. 1 143.) Uncodified policy Sec. 1. The Legislature finds and declares that the need for lower income housing is incrl throughout the state. The Legislature further declares that local governments and the F sector must work together to produce the necessary affordable housing; and in so doin local governments must offer the private sector incentives for the development of affo housing to ensure adequate housing for all Californians. (Added by Stats. 1985, Ch. Amended by Stats. 1986, 1 190. Urgency; effective September 26, 1986; Amended by 1989, Ch. 8421. ix Uncodified policy Sec. 1. The Legislature finds and declares that because of economic, physical, and mental conditions that are beyond their control, thousands of individuals and families in California are homeless. Churches, local governments, and nonprofit organizations providing assistance to the homeless have been overwhelmed by a new class of homeless: families with children, individuals with employable skills, and formerly middle-class families and individuals with long work histories. The programs provided by the state, local, and federal governments, and by private institutions, have been unable to meet existing needs and further action is necessary. The of homeless and the causes of homelessness, and for systematic exploration of more comprehensive solutions 10 the problem. Both local and state government have a role to play in identifying, understanding, and devising solutions to the problem of homelessness. (Amended b y Stats. 1984, Ch. 169 I. Urgency; effective October I, 1984; Amended by Stats. 1986, Ch. 1383; Amended by Stats. 1989, Ch. 145 1) Legislature further finds and declares that there is a need for more information on the numbers Policy 65913. fa) The Legislature finds and declares that there exists a severe shortage of affordable housing, especially for persons and families of low and moderate income, and that there is an immediate need to encourage the development of new housing, not only through the provision of financial assistance, but also through changes in law designed to do all of the following: 111 Expedite the local and state residential development process. 121 Assure that local governments zone sufficient land at densities high enough for (31 Assure that local governments make a diligent effort through the administration concessions and incentives to significantly reduce housing development costs and thereby facilitate the development costs and thereby facilitate the development of affordable housing, including housing for elderly persons and families, as defined by Section 50067 of the Health and Safety Code. (Added by Stats, 1980, Ch. 1 152; Amended by Stats. 1985, Ch. 1 1 1 7.1 production of affordable housing. of land use and development controls and the provision of regulatory X 1 I I 1 I I I i 1 I I 1 1 I I I I I I FISCAL STATEMENT This Housing Element proposes a number of follow-through objectives and actions designed to res to the housing needs identified herein. The ability of the City to successfully meet these objec and carry out the programs will depend, in part, on the availability of City resources. It mu recognized that there are always competing priorities for the allocation of these limited resourcl xi I I 1 I I I I 1 I 1 I 1 1 I i I 1 I I BACKGROUND AND INTENT The Housing Element of the General Plan is intended to provide citizens and public officials of Car with an understanding of the housing needs of the community and to develop an integrated $ goals, policies and programs which can assist the community in meeting those needs. The Ele also includes implementation procedures and priorities. This document is the result of tecl revisions to the Housing Element that the City adopted in 1985. The most significant changf updates to the needs assessment and additions necessary to comply with the State requirer governing Housing Elements. The GoalslPoliciesiPrograms section was revised where changes needs assessment suggests a revision in goals, or where evaluation of the City’s progress from indicated a need for such revisions. The two crucial themes that were identified in the 1985 Housing Element continue to be emph, by the revised Housing Element. The first theme is the City’s desire to ensure orderly gr Carlsbad‘s population has exhibited a rapid rate of growth, more than doubling from 1980 to Although the rate of growth is expected to continue, it is expected to stabilize as implementat the City‘s Growth Management Plan is achieved and Local Facilities Plans are adopted and fin: for the required improvements are secured. The following table illustrates past trends from 198 the projections of growth in Carlsbad to 2000. TABLE 1 CITY OF CARLSBAD 1980 - 2000 I I - Year PoDulation Households 1980 35,490 13,352 1985 44,964 17,383 1990 63,452 25,850 1995 77,310 31,800 2000 86,130 35,576 I Source: U.S. Census, 1980 Series 7 Regional Growth Forecasts, SANDAG Califomia Department of Finance, 1990 The second major theme is the desire to preserve the character of the City’s existing residential community scale and desirable environment. This theme is expressed through an emph: rehabilitation and preservation activities in older neighborhoods and an emphasis on neighb identity, orderly development and compatibility with surroundings to be stressed in new develo Both themes are addressed in the goals and policies of this element. A new third theme is achieving a balanced community with the creation of adequate housins income ranges and creating a comprehensive planning strategy to achieve an overall jobs and 1 balance. This theme is expressed by the proposed creation of approximately 1,400 new I housing for lower income categories and a total of 6,273 units for all incomes within the nc years. This theme is addressed further in the goals and policies section of this element. 1 The Housing Element is intended to serve as a guide for both elected officials and staff in evaluating proposals, determining priorities, and making housing decisions of all kinds. The oaals of the element provide a basis for reviewing day-to-day issues and serve as a basis for evaluating alternatives. The element, when viewed as a comprehensive housing strategy, also provides the City with a framework to respond to regional, state and federal housing initiatives and to evaluate state and federal programs for local use. The element is a comprehensive housing strategy that informs all residents of Carlsbad's goals, policies and priorities which attempt to meet "the housing needs of all economic segments of the community." The Housing Element includes six general goals. Thirty-five objectives relating to the general goals are identified; each relates to a specific set of housing issues and problems. The first ten objectives relate to preservation of the existing community. The next twelve objectives relate to response to new development and special needs, while the next thirteen objectives involve low and moderate income needs. Objectives for promoting a jobs housing balance, conservation, organization, equal opportunity and updating the Housing Element are also stated. Action programs designed to carry out the policy are identified following each objective. The City is expected to use its best efforts to implement these programs consistent with sound legislative judgment. In implementing these programs, due consideration is to be given to the balance of new and existing housing, available resources, environmental protection and general community welfare. Section Four of this Element highlights those policies and programs which, because of both state guidelines and local need, are to be given priority. Section Four also assigns responsibility for implementation and administration of the program. Ultimate responsibility lies, of course, with the Carisbad City Council, which is to assign staff and resources to carry out responsibilities under its guidance or under that of appointed review bodies. 2 I I I 8 I I I I I 1 I 1 I I 1 I I I I STATE LAW A Housing Element is required by State Law (Government Code Section 65580). The Housing El€ became one of the required elements of a General Plan in 1969. State Law passed in 1980 (AB 2853-Roos Bill) describes the requirements for housing element' need to include an assessment of Regional Housing Needs, the role of the California Departmt the adoption of the Housing Element. The law requires this Element be updated every five yea According to AB 2853, the Housing Element is expected to contain three parts: (1) a statement community's goals, quantified objectives, and policies relative to the maintenance, improvemenl development of housing; (2) a program which sets forth a five-year schedule of actions to imple Housing and Community Development (HCD) in the review of elements, and procedures and timi the policies and achieve the goals and objectives of the Housing Element: and (3) an assessm( housing needs and an inventory of resources and constraints relevant to the meeting of those n Additional changes to the Housing Element (Article 10.6 of the Government Code) requires that perform an analysis of persons and families in need of emergency shelter and the identificati adequate sites to facilitate the development of emergency shelters and transitional hc (65583(c)(l)). The City must also identify publicly assisted housing developments that are eligi convert to market rate developments during the next ten years. Carlsbad currently has no units SI to this analysis and program. The needs assessment must include the City's share of the regional housing needs of persons income levels. The San Diego Association of Governments (SANDAG) has developed the Re1 Housing Needs Statement which responds to the state requirements and has been approved by The City of Carlsbad accepted for planning purposes the Regional Housing Needs Statement on 26, 1990. The minimum number of total housing units to be constructed in the period 1991 -1 996 is estir to be 6,273 (see Regional Housing Needs Statement, on file in the Planning Department). (as identified by SANDAG's fair share goals). The minimum number of units to be rehabilitated public assistance would be over 50. The private sector also conducts rehabilitation, but the prop of private activities that would constitute rehabilitation or conservation cannot be detern However, if one were to assume at least as many units are to be rehabilitated by private fundi public funding, the maximum number would be 200 units. The conservation figures are more di to determine since these efforts are indirect types of activities. How many units are conserv code enforcement? The City's objective is to conserve most of its housing stock. Only li demolition and the described rehabilitation programs would influence this total. The pro! described under conservation are designed to prevent all housing from falling from stand: substandard condition. Of course, the major efforts will be expended in the old neighborhoods City where housing is more susceptible to deterioration. In addition to the code enforcement and other general regulatory activities of the City whic designed to conserve the City's housing stock, several specific programs have been identified \ would conserve affordable housing. The minimum number of units conserved by these mea would be 100 units (in the Village Area Redevelopment Project through public improvements) units through condominium conversion development standards, and approximately 1024 units th efforts to protect existing mobile home occupants. minimum number of additional lower-income households to be provided housing assistance is ' 3 RELATIONSHIP TO OTHER ELEMENTS California law requires that General Plans contain an integrated and internally consistent set of policies. The Housing Element is most affected by development policies contained in the Land Use Element which establishes the location, type, intensity and distribution of land uses throughout the City. The Housing Element has been drafted to be consistent with the Land Use Element, the Noise Element and the Pubiic Safety Element which, for reasons of safety, geology, open space and noise, declares that certain areas are to be preserved or developed with non-residential uses. Specific types of housing are indicated in the Land Use Element as an effort was made to make these recommendations consistent with the Land Use Element. If it becomes clear that the goals of the Housing Element are not being met within the locations and densities established for residential development by the Land Use Element, the Element(s1 will be amended to ensure consistency. The Housing Element also is related to the Circulation €/emant in that major areas for housing must be provided with adequate access and transportation systems. Finally, because of its policies regarding preservation and rehabilitation, the Housing Element is related to the Historic Preservation Element. The Housing Element uses the residential goals and objectives of the City's adopted Land Use Element as a policy framework for developing more specific goals and policies in the Housing Element. Although the Land Use Element enumerates numerous goals and objectives for residential development, they encompass five main themes. 1. Preservation - The City should preserve the neighborhood atmosphere, retain the identity of the existing neighborhoods, maximize open space, and ensure slope preservation. 2. Choice - The City should ensure a variety of housing types, single-family detached or attached, multi-family (apartments, townhouses, etc.), with different styles and price levels in a variety of locations. 3. Medium and High Density Compatibility with Surroundings and Services -The City should provide close-in living and convenient shopping in the commercial core but limit large-scale development of apartments to areas that are most appropriate. 4. Housing Needs - The City should utilize programs to revitalize deteriorating areas or those with high potential for deterioration and seek to provide low and moderate income housing. The City will also address the special housing needs of the homeless, the farmworker, the handicapped and the elderly. 5. Growth ~8n89twmnt hgrarn - The Housing Element was reviewed with regard to the Growth Management Program in 1986. The analysis found that the Growth Management Program would not significantly impact the Regional Housing Needs or the Housing Element as the City's housing needs and fair share goals will continue to be met. It is the purpose and intent of this program to provide quality housing opportunities for all economic segments of the community and to balance the housing needs of the region against the public service needs of Carlsbad's residents and available fiscal and environmental resources. 4 I I I I I I I I I I I I I I I I I I I I 1 I I I I 1 I I I 1 I I I I I I 1 I HOUSING NEEDS PERFORMANCE The City of Carlsbad Housing Element adopted objectives to measure housing goals for all incc groups. The objective goal for total housing production for the City of Carlsbad, as set by the Regional How Needs Statement for the period of 1985-1 991, was 1 1,589 total housing units. The total numbe units actually constructed during this period was approximately 6,599 units. Addition; approximately 4,900 units have received discretionary approvals but have not yet been built. figures represent 11,499 new units constructed or approved during this period and account for I of the total unit housing goal. The Regional Housing Needs Statement also established objectives for providing housing opportun to low and very-low income households. This "Fairshare Objective" for Carlsbad was for households either through new units constructed or assistance in the five year period from 1985-1 ! The City achieved 321 households, or 57 percent of its fairshare goal. Out of the 17 jurisdictions (c and county) in San Diego County evaluated for success in meeting "fairshare" housing goals, the of Carlsbad ranked 12th overall. TABLE 2 I HOUSING NEEDS PERFORMANCE i ~~ ~~~ ~~~ ~ ~ ~~~ ~~~ ~ ~~ ~~~ ~ ~~ - Goal Amroved Constructed - Total All Housing Units 1 1,599 4,900 6,599 1 1,499 Section 8 Goal GuaranteedlAssisted(11 PotentiallBuilt~2) Total Lower Income Units 567 105 216 321 cc: bhbd P-6 Dcp..N., "3 (1 )Guaranteed/Assisted - Existing Assisted Units under Section 8 programs these include senior: family. They are "Guaranteed" to rent at no more than 30% of the renters income th vouchers/certificates. (2)Potential/Built - Units new or rehabilitated that are rent restricted, they may or may not be affol to tenants depending on the tenants income. 6 REVIEW OF HOUSING ELEMENT 1985 - 1990 The City of Carlsbad's last adopted Housing Element set goals and objectives for housing development for the previous five year housing period from 1985 to 1990. The five goals set forth in the 1985 Housing Element were followed by nine policies and 38 action items. A review of these policies and a progress report on the action items is contained below: GOALS The Housing Element has five major goals. These goals are intended to provide general direction in meeting Carlsbad's two major housing concerns: preserving existing community values and responding to projected growth. 1. The City should preserve Carlsbad's unique and desirable character as a coastal community and maintain high design and environmental quality standards in all new development or redevelopment. 2. The City should assure that future development provides an adequate diversity of housing, with types, prices, tenures and locations consistent with the age and economic characteristics of present and future residents. 3. The City should provide affordable housing opportunities in a variety of types and locations to meet the needs of current low and moderate income households and a fair share proportion of future low and moderate income households. 4. The City should assure that the amount and type of housing development or redevelopment is compatible with, and convenient to, the locations of major facilities and services and, in particular, major transportation and transit routes as well as major employment centers. 5. The City should assure that all housino, whether market or assisted, is sold or rented in conformance with open housing policies free of discriminatory practices. 7 I I I I I I I 1 ,n, I I I I I I I I 1 I I POLICY I The City should preserve its existing character and protect residential communities, which cou susceptible to blight or deterioration, from the encroachment of conditions or uses which would a negative impact or degrade the environmental quality of those communities. Actions - 1-1 - The City should monitor signs of early decline within certain communities by conducting frem spot inspections of housing conditions and attempting to make rehabilitation funds availat necessary. Responsible Agency: Building, Housing and Redevelopment. Quantified Objective: There were no quantified objectives. Three units received rehab loans ( this period. Cumulative Results: This program provided three residential rehab loans primarily to ( occupants within the five year housing period. Actions - 1-2 - The City should monitor signs of early decline within certain communities by conductin( inspections of conditions of public and community facilities and services, Conditions shot evaluated for possible inclusion in capital improvement programs. Responsible Agency: Engineering, Housing & Redevelopment. Quantified Objective: There were no quantified objectives. Cumulative Results: The City maintains an ongoing program to monitor facilities conditions 1 communities. There are further standards and service levels outlined Local Facilities Management Plan for each of the 25 zones within the C Actions - 1-3 - The City should encourage greater involvement from community and neighborhood organiz in the preservation of existing neighborhoods. The City will undertake an increased pror campaign and also conduct this effort in Spanish. Responsible Agency: Housing and Redevelopment. Quantified Objective: Although there were no specific goals on meeting, at least one meeting with each community group on an annual basis. Cumulative Results: The Housing and Redevelopment agency has met with interested groups the City on a variety of improvement issues. 8 Actions - 1-4 - The City should distribute public notices of major developments and plans to community and neighborhood based groups. The City should continue to distribute the City Newsletter which provides such information for all residents of Carlsbad. Responsible Agency: Planning, Housing and Redevelopment. Quantified Objective: All major developments were noticed to the cammunib. Cumulative Results: The City has a comprehensive noticing procedure, as required by law. In addition standard newsletters on various subjects were distributed to the community on substantive issues. Actions - 1-5 - The City should, where feasible, preserve historic houses from demolition or conversion to inappropriate uses. Historic properties are eligible for federal and state funds to carry out rehabilitation. These funds are difficult to obtain, so economic feasibility of maintenance or conversion of historic sites is of prime importance. The City has established an Historic Review Committee which will update the existing historic housing inventory and draft an ordinance for the development of historic sites. Responsible Agency: Building, Planning. Quantified Objective: No quantitative objective was set for this program. Cumulative Results: The Historical Review Committee has been replaced by the Historical Preserva- tion Commission. An historical inventory of sianificant structures has been completed and adopted by the City. An ordinance implementing this policy is in effect. 9 I I I I I I I I I 1 I 1 I I I I I I I POLICY II The City should utilize code enforcement and rehabilitation activities to preserve and rehabilitat housing stock within the Village Area Redevelopment Project. Actions - 11-1 - The City should continue rehabilitation of residences with funding from the block grant pro! Almost $80,000 has been allocated to rehabilitation and $45,000 is on deposit. The City will cor to provide funds for the rehabilitation of housing. Responsible Agency: Housing and Redevelopment. Quantified Objective: The Housing and Redevelopment Agency has issued three residential loans totaling $42,970. Cumulative Results: Three rehab loans were issued within the redevelopment area. Actions - 11-2 - The City should pursue federal aid and state rehabilitation program funds which allow flea in rehabilitation assistance for investors and moderate and middle-income owners. Applicatio federal loans for the area designated will be made by the Carlsbad Housing and Redevelol Commission, depending on available funds. Rent maximums allowed on investor-owned rehabi units should be those established by the U.S. Department of Housing and Urban Development Section 8 Moderate Rehabilitation Program. Responsible Agency: Housing and Redevelopment. Quantified Objective: N/A. Cumulative Results: The City has received CDBG funds for rehab purposes. No other pro Actions were initiated during this period. - 11-3 - The City should seek to maintain and improve public facilities and services within the Villag Redevelopment Project. Funds from additional Community Development Block Grant monic increments, bond issues or general city funds will be used to finance these improvements. Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: N/A. Cumulative Results: Redevelopment tax increment funding has been used in several improk programs to maintain and improve public facilities. 10 POLICY 111 The City should develop a greater diversity of housing types and programs to meet a significant share of Carlsbad's lower income housing needs; maintain and rehabilitate where necessary the existing stock of lower income housing. Carlsbad's six-year goal as presented in the 1985-1 991 Housing Needs Statement is to provide housing assistance to 567 lower income households from 1985 to 1990 (or 680 over the six-year period; 1 13 households per year). Actions - 111-1 - The City should pursue those federal and state housing programs which are compatible with the objectives of the City and can provide the greatest number of housing units which would meet the City's current and projected needs. Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: N/A, Cumulative Results: The City has implemented one federally funded housing program during this housing period. (Section 8). Actions - 111-2 - The City should continue the existing Section 8 Housing Assistance Program (265 units) seeking revised rents from the Department of Housing and Urban Development consistent with coastal area market prices. Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: 265 units. Cumulative Results: The City has retained 100% of all units in existing (19851 Section 8 program. 11 I I I I \11-3 - The C'm should also apply to the U.S. Department of Housing and Urban Development fc , additional 175 units of Section 8 assisted housing phased aver the six year time frame of the Hal Element (1985-1991 1. The allocation of these units between elderly and non-elderly householl expected to be determined by funding priorities of the Department of Housing and Urban Developr and the City of Carlsbad Housing and Redevelopment Commission. Responsible Agency: Housing and Redevelopment Agency. I I I I I I 1 I I I I I I I I Quantified Objective: 175 units. Cumulative Results: 105 Section 8 units were added to the existing program, 60% of the objective was met. - 1114 - The City should continue to implement program(s1 to develop up to 250 new units of s citizen housing on scattered sites in Carlsbad as approved by the Article 34 referendum in Novel 1980. These sites would be located in any of the City's four geographic quadrants as long as are consistent with site selection criteria outlined under Policy VI (Adequate Sites) and concentrations in any one of the quadrants. The City approved three projects with a total of 160 for seniors by 1985. These units have controls on rent and age to ensure their affordable as ho for senior citizens. Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: Total 60 unit objective set for five year period cumulative results. Ninet new units were created under senior/density bonus provisions. These w the northwest quadrant. Cumulative Results: The City's five year goal has been exceeded by 50%, Actions - 111-5 - The City should establish a Housing Development fund to assist in land purchase or write- costs for development of lower income housing. Tax increment funds, portions of annual CDBG 1 or state or federal contributions to nonprofit housing sponsors should be sought. Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: 100. Cumulative Results: The City has not developed a Housing Development Fund-Twenty perc Redevelopment tax increment funds are set aside for moderate-low il housing projects. No units were developed under this program. 12 Action% 111-6 -The City should ensure that the design, location, and quality of projects be reasonably consistent and compatible with other types of ownership housing. Condominiums and condominium conversions constitute a significant portion of the city's stock of affordable housing. In order for the standards for new condominium construction to be valid, the same standards should also be applied to condominium conversions. In order to ensure that all condominiums offered for sale meet the City's goals, the City should consider the need to reduce and mitigate the impact of conversions on tenants who are forced to relocate. The policy of the City should be to reduce and mitigate these adverse impacts by providing adequate notification procedures and relocation assistance (including payments for relocation and moving costs). The City should provide additional counseling, referral, and other services to aid displaced tenants to find replacement housing. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: Currently the planning staff issues compatibility issues through design reviews. The City currently has not developed its own assistance programs for condominium conversion. 13 1 1 I I 1 I I I I I 1 I I I I I I I I POLICY IV The City should develop public incentives to encourage the private market to provide broader hou opportunities for low and moderate income households. Actions - IV-1 - The City should establish a density bonus program which would implement Section 6591 seq. of the Government Code. The bonuses and incentives provided pursuant to Section 6591 seq. are alternatives, not additions, to the bonuses provided in other housing programs. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: The City provided density bonus provisions to two projects during this period. A new density bonus ordinance pursuant to recent changes in Se 6591 5 is being developed. Actions - IV-2 - The City should continue to implement ordinances encouraging the mixed use of comr commercial and residential uses, particularly in the Village Redevelopment Project and in the comn centers of newly developed master plan areas. Compatible commercial uses should if administrative and professional offices, retail uses with pedestrian orientation and some public (See Village Area Redevelopment Plan.) Combination Districts (combining two or more generi land use designations over the same piece of property) are being used in Carlsbad to provide uses. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: The City has encouraged the mixed use development by requiring ' residential projects to include commercial square footage in the Redevelopment Area. The P-M Zoning (manufacturing) includes provisi onsite housing that is related to industrial development. Actions IV-3 - The City should continue to encourage use of ordinances that extend the provisions of the Citizens Housing Development Ordinance to zones other than the R-P zone. The City has used t process in conjunction with the RDM, RW and R-3 Zones. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: The Senior Ordinance has been extended to cover the RDM, PC, F Zones, and is allowed by CUP in the VR (Village Redevelopment) Zon 14 Actions - IV-4 - The City should continue to encourage the continued use of the affordable senior housing ordinance on a case-by-case basis. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: The Planning Department has encouraged the use of affordable housing for seniors. The City Council has established a policy to waive development fee as an encouragement for low-income senior housing. Actions - IV-5 - The City should continue to encourage the preparation of specific or master plans for residential development on specified sites within the City to avoid the need for further environmental review of individual projects within such specific plan areas. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: The Planning Department allows the use of "Tiering" environmental review especially environmental impact reports, to avoid redundant environmental processing. Actions - IV-6 - Where federal and state subsidies mandate such programs, or where the City Council deems it necessary to ensure that units which are developed pursuant to Actions IV-1, IV-3, and IV-4 remain available to persons of low and moderate income, the City should adopt programs for rent regulations and resale control. Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: N/A. Cumulative Results: The City has adopted an Ordinance Chapter 21.70 that requires development for low income projects enter into an agreement with the City to retain the goals of this policy. Actions IV-7 - The City should require that a portion of master or specified plan areas be utilized for housing which helps meet Carlsbad's identified share of the regional need. Much of the undeveloped land in Carlsbad is located in areas where ordinances require master or specific plans for development. Responsible Agency: Planning. Quantified Objective: 100 - 120 units. 15 I I 1 1 I I I I 1 1 1 I I I I I I I 1 Cumulative Results: No program to implement this action developed. As a result most master p gave only vague or no housing opportunities for lower or moderate incc housing. No low income units were built as a result of this action. Actions IV-8 - The City should continue participation in Local Area Certification process. HUD has certified the City's development codes met VA/FHA standards. This certification reduces processing timc applications for VA and FHA assistance. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: The City currently participates in this program. Actions - IV-9 - The City should continue to encourage "fast-tracking'' of housing projects which adc Carlsbad's share of the regional need for low and moderate income housing. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: Fast tracking of affordable (low and moderate) projects is offered a incentive for low-income unit production. The City has not implemenl formal procedure for doing so. This procedure has not been requested b development community as very few projects that could be considered I the policy have qualified. Actions - IV-10 - The City should continue to work with private developers to provide affordable housing thl the use of mortgage revenue bonds whenever feasible (dependent upon continued legislative sup\ Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: 300 - 400 units. Cumulative Results: A total of 106 units assisted with mortgage revenue bonds were deve during this housing period. Approximately 35% of the cumulative objective (300) was met unde program. 16 POLICY v The City should assure the availability of adequate and suitable sites for development of a variety of housing types and especially to assure affordable. Actions - V-1 - The City should continue to encourage zoning of suitable sites in all new developments for medium and high density. The determination of density and location within appropriate areas should be negotiated by staff and developers subject to Council approval. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: In 1986, the City of Carlsbad adopted a Growth Management Plan that limited construction until local public facilities are estimated, planned for and financed. Public facilities and services were correlated with population and residential density and increases in densitv can be approved provided that sufficient public facilities for that (increase in) density are sufficient. Due to the process of developing facilities plans and assuring the finance of the required infrastruc- ture, no increases in density were approved by the City Council. Changes of density may now be approved as most Local facilities plans have been approved, financing for infrastructure is being secured, and the City can estimate if adequate facilities exist or are planned for to handle an increase in density. Actions - V-2 - The City should continue to encourage the development of suitable sites within the City for manufactured housing, including mobile home parks, mobile home and modular unit subdivisions, and consider zoning code amendments to permit these housing types. These actions should ensure that suitable sites for a variety of housing types would continue to be made available by implementing the newly adopted amendments to the subdivision and zoning ordinances that provide for the establishment of exclusive mobile home zones and by establishing criteria for the location of factory built housing on a variety of sites throughout the City. The City should provide standards for development and design as well as special considerations for low and moderate income and senior citizen residences or projects. The City should reduce the impact of the conversion of mobile home parks to other uses by providing procedures for notification to occupants and adequate assistance for relocation of persons and units. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: The City has encouraged the retention and development of mobile home sites by adopting a mobile home park zoning. Additionally, the City has encouraged the retention of mobile home parks by direct subsidy for purchase to convert to ownership opportunities. Nine units of low income mobile homes were created under this program. 17 1 I I I I I I I I I I I 1 I I I 1 1 I Actions - V-3 - The City should review low and moderate income housing proposals based on HUD sit neighborhood standards (588.21 061, which included the following criteria: 1. The site must promote greater choice of housing opportunities and avoid undue concenl of assisted persons in areas containing a high proportion of low-income persons. 2. The site must comply with any applicable conditions in the Urban County Housing Assi! Plan approved by HUD, as long as that document is required. 3. The housing must be accessible to social, recreational, educational, commercial and I facilities and services, and to other municipai facilities and services that are at least equi to those typically found in neighborhoods consisting largely of unassisted, standard hc of similar market rents. 4. Travel time and cost via public transportation or private automobile, from the neighborhc places of employment providing a range of jobs for lower-income workers, should n excessive. While elderly housing should not be totally isolated from employment opportu this requirement should not be rigidly applied to such projects. Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: N/A. Cumulative Results: No HUD funded projects were developed within the City. Any non-HUD f low income projects that the City did review generally did not meet th design criteria outlined under these guidelines. Most proposed projects w be developed in or near the downtown area or within the redevelopment This would have caused an undue concentration of lower-income units j one section of the City. 18 POLICY VI The City should plan for the location of major new residential development along transportation and transit lines to assure access to commercial and industrial employment centers; and plan for residential development to accommodate anticipated growth, as approved by City Council from available forecasts. Actions - VI-1 - The City should undertake a community education program within each of the four quadrants to acquaint residents with recent growth forecasts, availability of services and facilities, and possible impacts of growth. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: The Planning Department routinely attends the City’s Quadrant meeting to address specific planning issues. Actions - VI-2 - The City should seek cooperation of major employers in estimating five-year job growth, profile of employees and estimate of housing needs. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: Through the City’s advance planning and growth management sections of the maintains an ongoing effort to look at future projections. The City maintains reports with SANDAG on official projections and Housing-Needs Assessment. Plannino Department, and the research office of the City Manager, the City Actions - VI-3 - The City should continue to prepare the Public Facilities Monitoring Reports which contain an estimate of the major services and facilities capacities (housing units) on an annual basis and compare these estimates to population forecasts. Responsible Agency: Planning. Quantified Objective: N/A. Cumulative Results: The City Council currently approves Local Facilities Management Plans which contain levels of service and estimates of service and facility capacities. Monthly reports prepared by the Growth Management Department monitor these estimates. 19 I 1 I I 1 1 1 I I 1 I 1 1 1 1 I I I I POLICY VI1 The City should actively pursue organizational changes and the development of new organizatiol facilitate meeting the City's housing needs. Actions w - The City should work with local nonprofit and limited profit groups to develop applicatior housing development, loan and counseling funds available to such groups through state and fe programs. Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: N/A. Cumulative Results: The City currently maintains contact with a several non-profit grl Proposals for CDBG grant funds to assist low-income residents are award1 a yearly basis. Actions Vll-2 - The City should consider expanding the role of the Housing and Redevelopment Comm to include municipal finance and land banking functions. Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: N/A Cumulative Results: The Commission currently assesses program and site selection criteria fc income housing. No programs for land banking or financing were impleme 20 POLICY Vlll All housing in the City should be sold or rented in accordance with the federal and state governments' equal opportunity regulations. Actions VIII-1 - The City should continue to support affirmative fair market programs by builders developing housing in Carlsbad, Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: N/A. Cumulative Results: The City currently maintains as policy this action item. Actions Vlll-2 - The City should encourage developerslowners of mobile home parks to operate in conformance with "open" park laws. The City should also report any closed park practices to the San Diego District Attorney's Off ice. .. Responsible Agency: Housing and Redevelopment Agency. Quantified Objective: N/A. Cumulative Results: The City maintains this program on a complaint only basisl Complaints are forwarded to the proper authorities for action. The exact number of complaints was not recorded. 21 I 1 I I 1 I I I II I I 1 I I i I I I I POLICY IX The City should periodically review all housing program implementation efforts and update v necessary. Actions !&l - The City should prepare periodic reports on implementation of the Housing Element goals policies for Planning Commission and City Council review. Ix-2 - The City should conduct updates and evaluations of projections, needs and goals in the Hol Element when the Regional Growth Forecasts are adopted by the City. Responsible Agency: Planning, Housing and Redevelopment Agency. Quantified Objective: N/A. Cumulative Results: Although no periodic reports are issued on implementation of housing goal programs, programs or issues that deal with the Housing Element are brc before the Planning Commission and City Council for review as the occ warrants, Regional growth forecasts are evaluated when they are available. Actions - IX-3 - The City should conduct updates and evaluations of housing needs when more CI information that would affect the housing needs assessment becomes available. Responsible Agency: Planning Department. Quantified Objective: N/A. Cumulative Results: Currently needs are reassessed when regional housing information fro1 Regional Council of Governments (SANDAG) is made available and decennial census data is made available. - 1x4 - The City should conduct a major evaluation and update of the Housing Element in 199' revise where necessary. Responsible Agency: Planning, Housing and Redevelopment Agency. Quantified Objective: NIA. Cumulative Results: The City has expanded its Planning Department to include an ad\ planning section. A task of this section is review and revision of the H Element for 1 991. 22 SUMMARY Although overall housing production grew strongly over the 6 year planning period of the Housing Element, overall goals in producing the projected units for all income categories fell short, Approvals for over 1 1,000 units were given during this period, but slightly over 6,500 units were constructed. This lower construction number was due in part to: the adoption of a Growth Management Plan that restricted development until facilities and infrastructure were built or financed, a general economic downturn in the latter part of the decade which in turn softened the real estate market, and a finance crisis within the savings and loan industry which usually finances residential real estate. The goals for lower-income units fell short due to a variety of reasons. Some of these reasons were beyond the ability of the City to affect. These reasons included: 1. Changes in the Federal and State Tax codes that made multi-family tax-benefits and financing more difficult to obtain. 2. Market forces which channeled more multi-family, high density development to ownership tenure (condominiums) rather than rental products that may have been affordable to lower- income residents. 3. Higher land prices that are prevalent in most coastal locations. 4. Lack of required infrastructure improvements in undeveloped areas of the City. The internal factors that affected the City’s Housing performance, especially in the creation or encouraging more affordable units included: 1. Allocation of financial and staffing resources. The City did not implement several programs such as Land Banking or a Housing Trust Fund that would have been an incentive to lower- income housing construction. Redevelopment tax-increment funds set aside for lower-income housing were not allocated due to the lack of supportable developments. The City has only recently implemented an inclusionary policy that was stated in the previous Housing Element. 2. Additional requirements for infrastructure improvements and services as required under the Growth Management Plan. The requirement of Local Facilities Management Plans for the developed and undeveloped areas of the City did not stop housing production, but did have a slowing effect. Although the previous Housing Element called for many programs to assist in the development of lower-income units, few were adopted. Successful programs were the increase in Section 8 programs and development of more senior housing. The success and failure of the past housing policy are reflected in this revised Housing Ekment. It calls out many of the Element’s previous programs and supplements them with additional programs. The ultimate success of any program, minor or major, funded from within or from other sources, ultimately depends upon the political will and economic considerations necessary to carry the proposed programs out. 23 I I I I I I I 1 I I I I I I 1 I I I I I I I I I I I I I I I I I I I I I I I HOUSING NEEDS ANALYSIS This housing needs analysis is a review of selected information on population and housing trends VI the region and Carlsbad. It contains information on employment and employment trends, hol costs, the estimated number of households that need assistance and other relevant statistical These data are important in understanding the evaluation of supply and demand indicators an1 current market analysis of housing within Carlsbad. The analysis in this section has been done the best available data from the Census Bureau, City , SANDAG and other sources. Much of the derived from 1980 Census figures has been extrapolated to 1990. The 1990 Census figures wer yet available at the time of this analysis. Certain groups of people have special needs for housing. These groups, the elderly, handicapped, families, students and the military have a significant impact on the demand for housing, espe those in the low-income category. These special needs groups may overlap. A migrant farmw identification and analysis of those special needs groups. may be homeless or a senior citizen may be handicapped. The following section contair 25 POPULATION GROWTH Within the last 20 years, the City of Carlsbad has experienced rapid growth. In 1960, a few years after incorporation, the population base was under 10,000 people; by 1970, that had been increased to almost 15,000. In the 1970's development just outside Carlsbad, most notably the La Costa area, had begun, and with the annexation of these areas the City's population had doubled. By 1980 the population stood at over 35,000. The 1980's brought on a development boom to the North County with additional employment centers, more housing and the need for public services for the increase in population. Within five years, the population had grown by another 10,000 people and in 1986 ballot measures were approved limiting growth by requiring that certain standards in public services and infrastructure be met prior to development. This action had a stabilizing effect and population growth leveled off to its figure of 63,451 by 1990. Table 3 shows the past increase in population and the projected population to the year 201 0 based on regional and City forecasts. TABLE 3 POPULATION TRENDS - Year 1960 1970 1980 198 1 1982 1983 1984 1985 19 86 1987 1988 1989 1990 1995 2000 2010 Population 9,253 14,944 35,490 35,725 37,583 38,827 39,963 43,685 47,810 53,900 58,850 6 1,948 63,45 1 80,000 95,000 110,820 Source: Carlsbad Economic Enhancement Council. Source Point Population and Housing Repoa, July 1990 @age 4 of SANDAG INFO). State Deoartment of Finance. 1990. 26 I I I I I I I I I I I I I I I I I I I POPULATION PROJECTIONS Population projections for the region show that there will be continued population growth over the decade. Factors that may change this pattern are varied, but the key factors are: - Housing growth - a prolonged economic slump or moratorium may retard growth. - Persons per households - regional requirements for more low and moderate income ho may require changes of housing product types. As different housing types have diff person per household yields, this may result in some small variations to population projec. TABLE 4 /I CITY OF CARLSBAD AND REGIONAL PERSONS PER HOUSEHOLD I! I ~ERF:EEOLD 11'11 Aiz 1 person 159,098 21.1 2,863 2 persona fir ::I 231,213 40.0 5,439 3 persona 13.8 92,374 13.7 1,864 4 persons 16.8 112,288 16.4 2,224 5 persons 1. 4.7 3 1,798 3.2 437 6 or more persona 1. 6.5 43,323 5.6 759 TOTAL r 100.0 670,094 100.00 13,586 Source: 1980 Census Summary Report; SANDAG, Page 41. The City's growth management program contains a buildout capacity set at 54,599 dwelling unit a projected population of 134,914. The final population figure is based on an assumption of persons per household based on the Jan 1, 1986 State DepaRment of Finance Estimates. 27 POPULATION BY AGE GROUP The distribution of population by age groups is an important factor to consider in the development of housing strategies. Age group characteristics for the City of Carlsbad show the largest population group to consist of persons between the ages of 35 to 59 years (or about 30% of the population) as shown in Table 5. TABLE 5 CITY OF CARLSBAD POPULATION BY AGE GROUP & 0-4 5-13 14-17 18-24 25-34 35-59 60-64 65-74 75 + TOTAL Carlsbad 4,379 5,252 1,859 4,772 13,121 17,801 3,442 5,981 2,237 58,844 Source: Source Point 1988 Age and Sex Estimates SANDAG page 44 - 96 7.4 8.9 3.2 8.1 22.3 30.3 5.8 10.2 3.8 100% This table indicates that approximately 20% of the population is 60 years or older, and almost 50% of the resident population is under the age of 34 years. The median age in Carlsbad is 32.2 years as shown in Table 6. TABLE 6 - Area Median Age Carlsbad 32.2 San Diego County 28.8 Source: US. Bureau of the Census, 1980. * The City shows a slightly older median age than the County as a whole, and a substantial part of the population is under 35 years of age. 28 I I I I 1 I Age distribution is an important factor in determining market housing demand. Traditionally, the yc adult population (20 - 34 years old) tends to favor, or can afford, apartments, low- to moderate condominiums, and smaller single-family units. The group of persons aged 35 to 65 years old proc age group tends to have higher incomes and larger household sizes. Carlsbad, with its higher median age and higher median income, shows a continuing demanc housing in the upper income range. However, it is important to consider the argument that the of housing built also influences the age and income characteristics of the population. Housing targets the older "move up" buyer may attract an older, more affluent population range from surrounding communities who often will commute back to their jobs located close to their fo residence. As 90% of Carlsbad's housing stock has been built within the last 20 years and all 40% within the last 10 years, the people who have purchased these homes have tended to be c and may have established jobs elsewhere within the region or County. This situation may cre; jobslhousing imbalance. the major market for moderate to high end apartments, condominiums or single-family homes. I 8 I I I I I 1 I 1 I I I 29 POPULATION BY RACE From 1980 to 1988, Carlsbad has experienced some changes in ethnicity. Although the population of the city is predominantly white, Table 7 indicates that the two largest increases were for Asian and Hispanic population groups. TABLE 7 POPULATION BY RACE 1980 - 1988 I -I - 1980 Percent - 1988 Percent Change Percent Hisvanic 4,790 13% 9,137 16 9% 4,347 91% White 29,450 83 % 45,954 78 % 16,504 56 % - Black 213 1% 3 70 1% 157 74 96 AsianIOther 1,037 3% 3,384 6% 2,347 226 96 TOTAL 35,490 100% 58,845 100% 23,355 66% Source: SANDAG Sourcepoint, Jan 1, 1988, Estimates by Ethnic Group This population estimate does not figure in the transient work force that may include a larger number of Hispanic workers. 30 I I 1 I i I I I I I I I I I I I I I I HOUSING PROJECTIONS Carlsbad is projected to have a high expected housing growth rate (over 500 units per year) in the five years. This is due to general housing demands, the backlog of approved projects and a I amount of pending projects. Pending projects are those that have not yet received discretionary approvals and/or are in submittal process. Table 8 indicates the number of pending projects within the City. TABLE 8 I PROJECTS IN SUBMITTAL 1 I 1 Proiect Pending Units Pending 53 4,352 I Source: City of Carlsbad Growth Management Division Monitoring Report December, 1990. I I Total housing unit projections differ from one source to another. Regional growth forecasts I approximately 35,576 units by the year 2000. The City ‘s Growth Management Program anticil no more than 38,861 dwelling units through 2000. As market demand is a key factor in ho growth, a recessionary cycle or prolonged housing slump would act to suppress these projec, Table 9 indicates housing growth projections from both SANDAG and the City of Carlsbad’s Growth Management Division. TABLE 9 PROJECTED HOUSING UNITS 1 YEAR 1990 2000 2010 CITY‘” SANDAG~) 27,244 38,861 35,576 48,993 42,613 Source: (1) City Growth Management Division. Local Facilities Phasing Wan, 12/90 (2) SANDAG. Regional Growth Forecast, July 1988. The City’s figure, which is larger, is a maximum figure determined on facilities phasing and s improvement throughout the City. The levels of service and public facilities in place at that time accommodate the maximum number of housing units projected through the Facilities Managl Plan. The regional forecasts are consistent with the City’s own as the City would be a accommodate the City’s share of regional growth and housing units under the Growth Manag1 Plan. At this rate of growth, Carlsbad will achieve its estimated build out capacity of 54,599 housint in the first or second decade of the next century. 31 HOUSING TRENDS Carlsbad has experienced a tremendous growth in housing units within the last 20 years. This is consistent with regional growth trends in the San Diego area. Carlsbad, with its coastal location and large undeveloped acreage, has experienced a slightly higher growth rate. Almost 40 percent of the City's housing stock is under ten years old and 90 percent of it's housing stock was built within the last 20 years. Table 10 shows the number of units and approximate range in age of Carlsbad's housing stock. AGE AND CONDITION OF HOUSING STOCK Nearly 80 percent of Carlsbad's housing was constructed in the last 20 years as table 10 indicates. As such, Carisbad has only a small stock of older homes. These are primarily located in the older northwest quadrant of the City. Table 11 indicates that although the substandard housing stock within the city is small (under 5%) the majority of substandard housing is owner occupied. These older units are also a major source of affordable housing stock for lower and moderate income residents as rents and sales prices are usually lower. It is important for Carlsbad to preserve these units through careful monitoring, code enforcement and application of rehabilitation funds, otherwise this affordable stock is in jeopardy of being lost. TABLE 10 I AGE OF HOUSING STOCK I I I ~ ~~ ~~~ ~ Years Built Before 1940 1940 - 1949 1950 - 1959 1960 - 1969 1970 - 1979 1980 - 1989 As Number More than 50 years old 419 40 - 50 years old 536 30 - 40 years old 1,432 20 - 30 yearn old 2,860 10 - 20 year~ old 9,863 Less than ten years old 11,296 Soumcr: SANDAO 1SWl- SWDlnyr RqodSD C-y Bvikhg Rcpat h 1.1990 1 TABLE 11 k CONDITION OF RESIDENTIAL STRUCTURES BY TENURE STANDARD UNITS Vacant Units Occupied Units Vacant Units Occupied Units SUBSTANDARD UNITS Owner 66 873 763 10,038 Renter 10 258 473 13.307 Source: City of Carlsbad Housing and Redevelopment Dept. Housing Assistance Plan 32 1 I I I t I I I I I I I 1 1 I 1 I 1 1 APPROVED AND PROJECTED UNITS Over the last ten years, Carlsbad completed construction of over 11,288 housing units as indica in Table 12. The estimates of units built may be different depending on the source and methodolc used to count the unit, i.e., permit issued, certificate of occupancy etc.. TABLE 12 I I - CONSTRUCTION OF HOUSING UNITS Total Housing Total Housing - Year Units Comdeted Units Authorized 1980 191 422 1981 477 482 1982 365 41 1 1983 49 1 1,560 1984 1,793 1,907 1985 1,985 2,811 1986 2,624 2,565 1987 1,885 659 1988 1,046 425 1989 43 1 353 TOTAL 11,288 11,595 Source: San Diego County Building Report Compiled by the Greeter San Diego Chamber of Commerce SANDAG INFO Page 6. Table 12 shows a lag time between authorization and completion of units of up to two years. addition, after implementation of the Growth Management Plan in 1986 by citizen initiative, buildin permits and authorizations were halted until key conditions of the Growth Management Plan were me These conditions included the completion of a Local Facilities Management Plan for each of the City’ 25 Local Facility Management zones to ensure that the needed facilities would be provided in a time1 manner. 33 These conditions resulted in a decrease in building permit issuance following 1986, although discretionary actions approving housing development were continued, This has resulted in a large backlog of approved developments awaiting building permit issuance as indicated in Table 13. TABLE 13 ~~ APPROVED UNITS ~~ ~ Approved Approved Building Permits Remaining Approved Proiects Units Issued as of 12/11/90 Units 94 5,797 362 5,436 HOUSING COSTS RENTS A significant portion of the households in Carlsbad are housed in rental units. Rental units may be the typical stacked flat apartment style dwelling unit or may be a town home or single-family dwelling unit. Traditionally, rental housing is the most affordable type of housing unit. Typical tenants include singles, young families, retirees and lower income wage earners. The length of stay for rental units is shorter than for owner-occupied units. Households that rent usually live closer to job sites than households that own their homes. In general, with the increase in the cost of homes in recent years, more and more moderate and upper income households are renting. This trend has put pressure on existing rental stock, encouraged the construction of new multi-family residential structures and has kept vacancy rates low. Rental costs, however, have increased due to this increased pressure and a downturn in multi-family construction. TABLE 94 AVERAGE RENTS TY!x Rent 1 Bdnn Apartment 53 1 2 Bdnn Apartment 669 2 Bdnn Duplex 800 3 Bdrm Apartment 875 3 Bdrm Condo/Townhouse 1,023 4 Bdnn Condo/Townhouse 1,200 Source: Rent Survey conducted by Cartsbad Planning Depawnt. December 1990 - I 1 34 I I I I 1 1 I I I I I I I I I 1 I I 1 Table 14 shows the average rates for rental units in Carlsbad. A typical one bedroom unit rent around $530400 per month (excluding utilities). This is within the ranoe of affordability for a I, income household of two persons. As indicated in Table 15, an average rent in Carlsbad for a bedroom apartment unit is still within range for a family of four making 80% of the County mec TABLE 15 I LOWER INCOME RENTS State HCD Standards (includes utilities) 1 Unit Type 1 BDRM 2 BDRh4 ~~ ~ ~~~ ~~ 3 BDRM VERY LOW Family Size 1 person 2 verson 3 verson 4 verson 5 Derson 6 person Max. Annual Income $ 13,600 to $ 15,550 $ 17,500 to $ 19,450 $ 21,000 to $ 22,550 Max. Monthly Income $ 1,133 to $ 1,296 $ 1,458 to $ 1,621 $ 1,750 to $ 1,879 RENT (hcl. uti11 (30%) $ 340 to $ 389 $ 438 to $ 486 $ 525 to $ 564 LOW Family Size 1 uerson 2 verson 3 verson 4 verson 5 verson 6 verson Max. Annual Income $ 21,200 to $ 24,250 $ 27,250 to $ 30,300 $ 32,200 to $ 34,100 Max. Monthly hcome $ 1,767 to $ 2,021 $ 2,271 to $ 2,525 $ 2,683 to $ 2,842 RENT (kc. uti11 (30%) $ 530 to $ 606 $ 681 to $ 758 $ 805 to $ 853 , i BASED ON SAN DIEGO COUNTY MEDIAN INCOME OF $37,900 (Family of Four) 1 ~ ~ ~ ~~ ~~ ~~ Although most housing stock in Carlsbad is less than 20 years old, most of the rental units are Ioc in the older northwest quadrant of the City and are older than 15 years. New rental units built n the last ten years have higher rents than the older units, reflecting increases in land and construl costs. Rental multi-family development in the City has decreased in the last ten years. New units that been developed typically rent around 25% - 30% higher than units developed over 10 years ago to development standards, higher land costs, higher construction costs and greater financing c( The large amount of Carlsbad's rental stock is 10 years and older and have correspondingly I( rental rates, but are higher than the County average and inland cities as shown in table 17. Reduc of multi-family residential is also indicative of market considerations. Over a ten year period there been an increase in multi-family construction as indicated in Table 21, but a decrease in rental te as indicated in Table XX. 35 SALES AND RENT COSTS The costs of home ownership have risen dramatically within the last two decades. Only 20% of the households in California now have the qualifying income to purchase a typical single-family home. Carlsbad, with its unique coastal location, high development standards and emphasis on creating a community with a unique quality of life, has been attractive to upscale, move-up housing. This market has been most successful for the development community in terms of marketing and sales. Lower densities, increased infrastructure and facilities demand has led many builders to concentrate in this housing market. This has led to a decline in the small, single-family detached entry-level home in Carlsbad. This housing type would be affordable to the moderate income household but has been replaced in favor of the larger, more profitable "move-up housing" product type. This issue is discussed further in the Housing Needs analysis section for moderate income home buyers. The high rents and sales Costs have forced many residents to pay over 25% of their monthly income as indicated in table. TABLE 16 Ll HOUSEHOLDS PAYING MORE THAN 25% OF INCOME FOR HOUSING COSTS RENTERS 0 WN ERS Carlsbad Regional Total 144,614 33,138 SANDAG Regional Housing Needs Statement (p. 881 36 I I I I I 1 I I I I I I I I 1 I I I 1 TABLE 17 Average Rents Regional Housing Needs Statement San Diego Region 1989 1 Community Averaee North County La Joila $717 University City S72 1 CardiffiEncinitas $707 Dei Mar mbad $736 $687 La costa $651 Oceanside $748 Vista $597 Bonsall $578 Escondido $587 Fallbrook $566 San Marcos $521 Camel Mountain Ranch $587 Mira Mesa $699 Poway $605 Rancho &mardo $5 10 Rancho Penasquitos $728 Scripps Ranch $670 $682 Pacific Beach $800 Downtown San Diego $698 Clairemont $613 Linda Vista $600 Mission Valley Tierrasanta $63 1 Golden HillKensington/ $77 1 Hillcrest/Old TownMission Hills $550 East San Diego City $559 Alpine $559 Casa de Om $530 El Cajon $540 Lakeside $517 La Mesa $557 Lemon Grove $560 Rancho San Diego 5590 San CarlodGrantvillelDel Cem $642 Spring Valley $565 hmOM $582 Sou& County Point LomafCOroMdo $580 Normal Heights htee $65 1 Cbuh Via 5538 Bonita $642 Impcrirl Beach National City PlldSouth San Diego Plradire HiildSoutheast San Diego San Ysidru Solana Eeach TOTAL SAN DIEGO COUNTY saua: MphaProfii-Ssn~UaiaD $543 $577 547 1 $608 $548 3583 $604 (Sunyof~,~1apsrtmcnbin766somp~~ol25rmit.amacm48oomm~.) - - - 37 HOUSEHOLD CHARACTERISTICS HOUSEHOLD SIZE The persons-per-household figure, or the average number of people who reside in any one unit, varies according to the type of dwelling unit. Single-family dwelling units are typically larger, have more bedrooms, and as such, house a larger number of people than a smaller rental apartment unit. Mobile homes, which are smaller in size and are attractive to senior households with no dependents due to generally low costs, have the lowest person per household average. The person-per-household rate for Carlsbad has remained consistent over the last ten years due to the predominant housing product type that has been allowed to develop. The preponderance of new single-family homes built in Carlsbad has allowed the person per household rate to remain steady. Varying the product type of new construction to less single-family homes and more multi-family may change the average person per household figure. Household size may be affected by other socio-economic trends. Children and dependents in many households tend to stay with parents for longer periods until such time as they can economically afford their own housing. Areas with high rents, such as Carlsbad, tend to keep dependents at home for longer periods of time. Table 18 shows the person per household for each type of dwelling unit in 1989 - 1990. The largest person per household, 2.84, is in single-family type units, the smallest, 1.625, are mobile homes. Creating a greater percentage and mix of multi-family units which have a lower person per household factor than single-family units would tend to generate a slightly lesser population buildout. 38 1 I 1 I 1 I I I I I I 8 I I I I 1 I I TABLE 18 I[ 1 I1 CITY OF CARLSBAD PERSONS PER HOUSEHOLD BY TYPE OF UNIT li Single Family Attached Detached Single Family POP PlHH HHS POP P/HH HHS w ::E 12,955 2.142 2,190 4,691 2.835 13,171 2.149 2,236 4,805 2.840 Multi-Family Ll Multi-Family 2 - 4 ddstructum 5 Plus Wstruchrre POP P/HH HHS POP P/HH HHS 4,877 1.957 6,921 13,544 1.988 2,555 5,079 1.948 6,816 13,277 1.981 2,462 - Mobile Of units Homes MTYPes .. POP PlHH HHS POP PlHH HHS 89 source: DqmmallofFbnoa 2.415 25,850 62,415 1.635 967 1,581 90 2.409 25,358 61,091 1.625 935 1,519 Demognphic Ruarcb Unit Carlsbad's person per household average is slightly lower than the County average of 2.6 persol household. 39 VACANCY RATES Vacancy rates are an indication of housing supply and demand. A key factor in determining over or under supply of the type of unit, An overall vacancy rate of 5% - 7% is considered to be optimum. Vacancy rates that are greater than 7% mav indicate an oversupply of housing. This may be a temporary situation because of seasonal fluctuations or new construction that may not have been occupied yet. A prolonged high vacancy rate tends to discourage new construction, especially multi- family residential. A vacancy rate below 5% indicates a high demand relative to supply. A prolonged low vacancy rate tends to elevate rentals in the multi-family rental stock. Lower income households are particularly hard hit when rents rise due to low vacancies. The vacancy rates for Carlsbad over the last ten years are as indicated in Table 19. These data show that the vacancy rate has dropped significantly over the last ten years. The decrease in vacancy rate is due to several factors that include; high demand for and saturation of new housing units, increase in local employment and job growth, decrease in number of new units especially multi-family built within the last five years, and growth management which restricts development until facilities and infrastructure are built or financed. TABLE 19 I 1 40 I I I I I I I I I I I I I I I I I I I HOUSING UNITS BY TYPE A diversified housing stock to provide housing for all economic ranges is a stated goal in the cu Carlsbad Housing Element. Carlsbad currently has 58% of its housing stock composed of single f; type homes, and 38% composed of multi-family dwelling units. Mobile homes compose approxim 4% of the housing stock. However, recent trends in construction have tilted predominantly tow single-family construction. Table 20 indicates that over the last ten years approximately 54% c 11,661 units constructed were single-family homes. In this same period, 44% or 5,150 new I family units were constructed. TABLE 20 I Fi 1980 (1) crrangc (-1 H Pct Inc- 19801990 Pa. ai Td. Having aa of 1990 M al NewCd i9S1990 6 I HOUSING UNITS BY TYPE (TRENDS) 'I% 47% 50% WI 32% 44% 1% (1) U.S. Ceosus, 1980 (2) Ca. Dept. of Fwe, 1990 Table 16 indicates that rental multi-family construction, as a percent of new construction, has off over the last ten years. The reasons are varied. On a regional and national basis changes tax code in 1986 and more importantly new banking regulations have kept the supply of mon this type of product below previous levels. In Carlsbad, the amount of acreage that had been avi for multi-family construction was reduced. Carlsbad, as part of its growth management pro lowered the density ranges of its land use classes. Perhaps as a result, the private sector has ret1 from rental multi-family construction within master planned communities so as to focus on profitable ownership projects featuring condominiums, townhouses and single-family homes. 41 HOUSJNG TENURE According to the most recent figures, Carlsbad housing stock is approximately 67 percent owner- occupied and approximately 32 percent renter occupied (Table 21). This varies from the San Diego regional average of 55 percent owner and 44 percent renter occupied units. As indicated in the needs section, opportunities in Carlsbad for ownership have lessened over the years for the moderate and lower income buyer. This trend has led to a greater demand on existing rental stock. Demand on rental stock forces rental prices higher and creates less housing opportunities for every income category. TABLE 21 HOUSING TENURE YEAR OWNER (%I RENTER 1%) ! 1970, 2903 (47.5%) 2152 (42.5%) 1980, 8680 (63.9%) 491 5(36.1 %) 1 ggo3 15981 (67.2%) 7825 (32.8%) i SOURCE: Ill 1970 Cemu I21 1980 Cemu (31 Estlmate. Key= “on hoc. OVERCROWDED UNITS Overcrowded units are an important factor in determining an underhoused population. The chart below indicates overcrowding based on 1.01 person-per-room. Using this factor, Carlsbad has an estimated 41 6 households that are overcrowded, according to the 1980 Census. As vacancy rates fall and supply of affordable housing diminishes, overcrowding increases. As overcrowding leads to accelerated deterioration of housing stock, code enforcement activities which can abate overcrowded conditions and further preserve existing older housing stock is an important tool. It is important for Carlsbad to implement an effective program to identify and abate overcrowded conditions and preserve existing housing stock. TABLE 22 - OVERCROWDED UNITS E33 Carlsbad Regional 37,054 Total SOURCES 1980 Csmu Sunmvy Rspom. SANDAG RHNS (w. 871 42 I I HOUSEHOLD INCOME II Household income is an important indicator of the demand a city may experience for certain hol types. 1 I I It also reflects an economic profile of the type of population that the City of Carlsbad has am As housing prices have escalated, the typical family that can afford to buy a home in Carlsbad ha, to become more affluent. Table 23 indicates for 1988 the number of Carlsbad households in standard income classifical The largest single population group is for the $50,000 and up income group which included f households in 1988. The median income for Carlsbad was approximately $41,015 in 1987 d (Table 19). This is significantly above the County median income of $37,900 dollars. Only 31 about 10,000 households fall below the County median income and over 25% of Carlsbad house are in the low income range. I TABLE 23 I I I I I I I I I CARLSBAD HOUSEHOLD INCOME DISTRIBUTION Income Number Percentage I Under 10,OOO 1,358 6% $lO,oOO - $14,999 1,293 5% $15,000 - $24,999 3,484 14 96 $25,000 - $34,999 3,864 16 % $35,000 - $49,999 5,095 21 96 $50,000 - and UP 8,990 37 96 24,084 100% Source: SANDAG - 1988 Estimate of Household Income by City TABLE 24 CARLSBAD MEDIAN HOUSEHOLD INCOME - Year Income 1980 ('79$) $22,354 1988 ('799 $23,905 1988 ('87$) $41,015 Source: SANDAG - 1988 Estimates of Household Income by City 1 " I I I 43 PRESERVATION OF AT-RISK UNITS Currently, Government Code 10.6 (Section 65583.a.81 requires an analysis of public assisted multi- family rental housing units subject to loss to non-low income housing during the next ten years. As Carlsbad has generated no assisted rental housing in the past, it has no at-risk units due to return to market rate rents with the next ten years. Assisted Units At risk 1) Housing that received government assistance under HUD Sec 221 (dH3) 0 0 HUD Sec 236 interest reduction payment program 0 0 HUD Sec 202 direct loans for ELD & HCP 0 0 HUD Sec 101 rent supplements 0 0 HUD Sec 8 (new construction) 0 0 Rehab 0 0 LMSA 0 0 2) Other federally or state subsidized rental units with rent-use restriction subject to termination within ten years. FMHA Sec 51 5 HUD COBG Redevelopment programs ln-Lieu programs 0 0 0 0 0 0 0 0 31 Local developments that have rent restrictions due to expire within ten years. lnclusionary programs Density bonus programs 0 0 0 0 As no public housing units as defined by this section have been built in Carlsbad, it is not possible at this time to determine a replacement cost for these units. A strategy for the replacement and retention of public housing units will be developed as the need arises. 44 I I I I I I I I I I I I I I I I I I I EMPLOYMENT EMPLOYMENT TRENDS Employment continues to increase in the City as raw acreage designated for commercial, office industrial uses is developed. The major employment centers continue to be in the regional shopping center (Plaza Camino Rea the office/industrial "Platinum Corridor" that surrounds the Palomar-McClellan Airport. Carlsbad has significant amounts of undeveloped acreage designated for commercial and indl development. Currently the City, with its major employment centers and access to major transpor corridors such as interstate 5 and State Highway 78, has been one of the fastest growing emplo) centers in the San Diego Region. 45 Table 25 indicates major employers in the City of Carlsbad and the approximate number of employees. TABLE 25 I TITLE: CARLSBAD MAJOR EMPLOYERS 100 900 700 500 275 250 200 175 150 EMPLOYEES 15m+ thlll thN thru thN thru thN thIU thm rhIU 149 1499 899 699 499 274 249 199 174 Manufacturing Companies Hughes Aircraft Company Burrough Corporation Taylor Made Golf Eaton-Leonard Corporation Beckman Instruments Dyna Industries, Inc. Southwest General Industries Watkins Manufacturing Corp. rn Sargent Industries rn Sierracin-Magnedyne, Inc. Non-Manufactured Companies La Costa Resort HotellSpa Plaza Camino Real Car Country Auto Dealers City of Carlsbad Carlsbad Unified School Dist. San Diego Gas & Electric Farmers lnsurance Group Pea Soup Anderson Army-Navy Academy Frazee Flowera 1 I 1 ____ ~~ Source: Sauh Caut Nmpppcr N@.nuk Mutcc chvvtcrhtia 1988 46 I I I I I I I I II I I I I I I I I 1 I Employment growth in Carlsbad has shown a far greater rate of increase than the San Diego reg average. The regional average continues to show an increase (Table 26) of 4.8 % in new job cre; over the last decade. Carlsbad shows an average increase of 10.9% over the last decade, or dc the average Countv rate. TABLE 26 EMPLOYMENT TRENDS FOR 1980, 1988 ANNUAL AVERAGE GROWTH YEAR CARLSBAD REGIONAL RATE OF NEW JOBS 1980 16,189 30,252 10.9% 1988 30,252 1,163,156 4.8% 47 Table 27 shows Carlsbad employment growth by occupation from 1986 and projected until the year 2010. This table shows a 105% increase in employment which will not be matched by housing growth. TABLE 27 I r~ CITY OF CARLSBAD EMPLOYMENT BY OCCUPATION 1986 - 2010 INDUSTRY Change Change Numeric Percent 2010 2000 1995 1986 - Basic 65.5 3,840 9,704 8,371 7,712 5,864 Manufacturing 0.7 6 865 863 862 859 Agriculture & Mining 68.4 6,155 15,152 12,675 11,551 8,997 Wholesale 575 749 80 1 337.4 1,589 2,060 1,302 1 ,OOo 47 1 Transportation 62.1 357 932 HotelsMotels 29.6 363 1,591 1,338 1,228 1,228 StatelFederal Government 0 0 0 0 0 0 Local Serving 35.5 837 3,192 2,797 2,599 2,355 Other Local Serving 86 .O 1,017 2,200 2,007 1,762 1,183 Local Government 143.9 1,949 3,303 2,349 1,932 1,354 F.I.R.E. 106.9 2,575 4,983 3,750 3,131 2,408 Business Service 291.8 5,653 7,590 5,177 4,181 1,937 Retail Service 126.0 6,332 11,358 8,476 7,305 5,026 Retail Trade 128.7 18,363 32,626 24,556 20,910 14,263 Uniformed Military 105.4 24,s 18 47,778 37,U 1 32,46 1 23,260 Total Civilian Emlovment 0 0 0 0 0 0 he: Regid Grot& Farscplt 1#61010 (SANDAUI 48 I 1 1 I I I I I I I I I 1 I I I I 1 I EMPLOYMENT BY OCCUPATIONAL SECTOR Carlsbad's employment by sector shows the greatest employment in manufacturing, retail tradc in the services sector. The approximate number and percentage for each occupational sec Carlsbad is indicated in Table 28 TABLE 28 CITY OF CARLSEAD EMPLOYMENT BY INDUSTRY 1988 NUMBE EMPLOY INDUSTRY - % (1988) Agriculture, Forestry, Fishing, and Mining 2.5 161 Construction 5.4 1,621 Manufacturing Transportation, Communication, and Utilities Wholesale Trade Retail Trade Finance, Insurance, and Real Estate Services I Government Military I I TOTAL 20.7 3.5 3.1. 23 .O 9.1 26.1 6 ,O 100.0 6,212 1,047 1,117 6,972 2,743 7,886 1,827 30,252 Sarne: SANDAG INFO Regid Employmmt lnvmtoy 1989 (page 52) Wage earnings in these employment sectors are important to note. Generation of wages approximately $1 4.00 dollars an hour would place a single wage earner in a family of four in th income category. Tables 29 and 30 show wages for office, professional, technical workers and earnings of maintenance, custodial and other industrial wage earners. 49 TABLE 29 WEEKLY EARNINGS OF OFFICE, PROFESSIONAL AND TECHNICAL WORKERS SAN DIEGO COUNTY DECEMBER 1989 Occuvation Secretaries Word Processors Key Entry Operators Accounting Clerks Payroll Clerks File Clerks Messengers Order Clerks Receptionists Switchboard Operators Switchboard Operators/Receptionists Computer Systems Analysts Median $450 387 3 15 337 342 240 278 300 280 280 280 76 1 Computer Programmers 64 1 Computer Operators Drafters Electronic Techcians Source: U.S. Department of Labor, Bureau of Labor Statistics San Diego Economic Bulletin, Vol. 38, No. 6, June 1990 43 1 500 541 Middle Ranee $398 - $51 1 346 - 441 280 - 350 294 - 380 289 - 413 229 - 247 252 - 278 246 - 340 277 - 311 255 - 337 260 - 304 667 - 854 542 - 785 372 - 471 430 - 562 420 - 674 50 1 I I 1 I I I I I I I I I I 1 I I I 1 TABLE 30 I HOURLY EARNINGS OF MAINTENANCE, TOOLROOM POWERPLANT, MATERIAL MOVEMENT AND CUSTODIAL WORKERS SAN DIEGO COUNTY DECEMBER 1989 I Occupation Maintenance Electricians Median Middle Range $14.27 $13.74 - $19.07 Maintenance Machinists Maintenance Mechanics Motor Vehicle Mechanics General Maintenance Workers Tool and Die Makers Truck Drivers Light Truck He& Truck Tractor - Trailer Shippers Receivers Shippers and Receivers Warehousemen Forklift Operators Guards Guards I1 Janitors, Porters, Cleaners 16.54 13.79 16.45 10.25 15.87 13.10 5.25 9.25 15.18 6.00 7.75 14.47 - 16.54 13.07 - 15.87 13.00 - 17.00 8.20 - 11.50 15.12 - 16.50 8.85 - 15.80 4.75 - 6.00 9.25 - 13.00 13.00 - 15.20 5.80 - 7.30 6.05 - 7.75 8.04 7.60 - 9.00 8.49 7.00 - 10.57 13.07 12.51 - 13.91 5.00 4.75 - 5.50 14.28 7.10 - 14.35 4.92 4.50 - 6.00 Source: U.S. Department of Labor, Bureau of Labor Statistics S.n Diego Economic Bulletin, Vol. 38, No. 6, June 1990 In the creation of jobs in these categories, there is also created a housing demand in these categories as discussed in the job/housing balance section. 51 JOBS HOUSING BALANCE A jobs-housing balance is a concept to create housing opportunities closer to employment centers and to create housing in the corresponding economic ranges that correlate to their respective employment sector. This concept creates less travel and transportation demand and thereby reduces pollution as well as promotes energy conservation. Creation of employment centers and jobs that occupy lower wage scales create demand for housing in the those lower income ranges. As employment opportunities increase in a certain occupational sector and housing demand does not increase proportionally, a jobs housing imbalance is created. A jobs housing imbalance creates unwanted traffic situations during rush hours as commuters leave job-rich areas to return to areas that have adequate and cheaper housing. Although Carlsbad has created a significant number of housing opportunities within the last 10 years, it has not created enough housing to match job creation in the retail, industrial and service sectors. These employment sectors traditionally offer a lower wage level and, as a result, those employed in Carlsbad's industrial parks, resort areas, and commercial centers must seek housing in the surrounding communities where housing costs are lower. Impacts to the city's streets, arterials and freeways are increased as workers commute to and from their work sites. This is particularly evident on Palomar Airport road, El Camino Real and the 1-5/78 Interchange during the morning and evening rush hours. The predominate construction of "move-up" and luxury single family homes in Carlsbad within the last ten years and the promotion of the coastal location of Carlsbad as a highly desirable place to live has attracted affluent families from around the county to relocate here. Many of these households move here to be closer to jobs that are created in the City of Carlsbad and the North County area. There are households that may retain their former jobs and commute causing a secondary migration of commuters, those who live here but are employed elsewhere in the county. Creation of housing opportunities for all economic ranges particularly those in the lower-income categories and situated close to employment centers will reduce traffic related impacts and congestion on arterials throughout the community. Analysis of employment growth in Carlsbad shows that more growth can be expected in the industrial and retail sectors over the next 5 years (Table 27). As this job growth will correspond with the average wages for this employment sector (Table 29 & 30),it can reasonably follow that additional housing demand for this income group will increase. This would be in addition to the demand already created by existing employment. Vacant land and land available for potential redevelopment should be carefully monitored to assure that an adequate supply of acreage is available for new development to satisfy the housing demand for all economic ranges. Jobs-housing balance strategies needed to assure that future employment growth matches housing demand should focus on providing increased employment opportunities in the technical, professional, medical and other employment sectors that have higher wage earnings. An additional strategy would be the requirement for major employment centers that create housing demand for lower-income wage earners to contribute to the creation of housing. Currently the State of California is developing guidelines to assist cities in achieving a jobs housing balance locally and on a regional scale. It is anticipated that these guidelines will in time become mandatory and when available will be incorporated into housing elements and will become a policy for short term goal and a long range planning objective. all cities. Carlsbad has instituted a goal to achieve a jobs housing balance as a 52 I I t I 1 I I 1 I 1 I 1 I I 1 I I 1 I SPECIAL HOUSING NEEDS Population Groups that have been identified as having the need for special and different typ shelter are referred to as Special Needs Groups. These groups, because of economic, social, m or physical condition have difficulty finding appropriate housing. These groups have been identified as the homeless, large families, the elderly, students, farm wc and military families. Many of these groups are in the lower-income economic range. Where possible these groups have been quantified. In some cases where differing methodologies been used to estimate these population groups, figures may vary. Attached in the Appendices is the Housing Assistance Plan as required under Federal Law fc allocation of HUD Community Development Block Grants. The Housing Assistance Plan contains s information provided by SANDAG for the purposes of preparing the Housing Element. The Plar provided for informational and background use and is generally consistent, although some figure! vary, with the Housing Element. 53 SPECIAL HOUSING NEEDS HOMELESS ESTIMATED HOMELESS POPULATION Efforts to count the homeless population is always difficult. The homeless are defined as individuals that lack a fixed and adequate nighttime residence. Homeless persons can be considered resident; those who remain year-round, or transient. Current estimates for Carlsbad are approximately 6-10 people that are considered resident homeless. The transient homeless population can be broken down into several categories. Those who are temporarily seeking housing because of difficult economic situations, migrant worker populations who choose to camp in undeveloped areas so as to save money to send home, or residents who are temporarily homeless because of a disastrous situation, i.e., earthquake, fire or flood. Migrant worker populations in Carlsbad who are considered homeless have been estimated from local and state sources to be as many as 500-1,000 on a year-round basis, but can be three times as large during certain seasons of the year. As identified above, the nature of the homeless population precludes the existence of an exact census. Recent demographic estimates have been made, however, by the San Diego Association of Governments (SANDAG). In the February, 1990, Regional Housing Needs Statement (RHNS), SANDAG provided the following demographic information on the homeless in the San Diego Region: a There are approximately 5,000 homeless people in the San Diego Region, with 3,000 located in downtown San Diego; a The mentally ill account for 25 - 30% of the homeless, due to the reduced funding for mental health services; Approximately 1/3 have severe alcohol and drug abuse problems; Approximately 20% work full time or part time at minimum wage jobs; I About 1/2 are single males, and of these, at least 40% are veterans: H A significant number of homeless women and children are thought to be escaping from abuse; a Families are considered to be the largest growing segment of the homeless population. According to nationwide statistics, 40% of the homeless are families; Homeless individuals may fall into more than one category fe.g., a homeless individual may be a veteran and a substance abuser) thus, making it difficult to accurately quantify and categorize the homeless. 54 1. I I I I I I I I 1 I I I I I I I I I There are many different reasons people become homeless. In the 1990 RHNS, SANDAG report! homelessness can be attributed to such things as unemployment, low income, mental ill disabilities, substance abuse, domestic violence, and combinations of these problems. As a rl many social service agencies that provide help for problems associated with homelessness work with shelters to address the needs of the homeless, even though these agencies do not neces specifically target the homeless population. These agencies and shelters that operate within a net to help the homeless are located throughout the North County and receive contributions from I County cities.There are social service aaencieslpraarams available to the homeless in Carlsbac North County in the City of Carlsbad, and the City is a significant funding source for many st providers. Services and Programs The following services and programs are available to the homeless: H Project 01 - Serves youths in crisis and their families, and operates a temporary s to house runaways. Counseling is provided for residents and their families, and outpatient basis for non-residents. Foster home placement is arranged for those y not returning to their families. H North Coastal ROP Center - Registration for ROP classes and job counseling. H Community Churches - As a group, services provided by our local churches in1 canned and dry food, lodging at local motels, gas vouchers, clothing, shelter ( inclement weather, and referrals to social service agencies. Carlsbad Department of Housing and Redevelopment - Provides applications for SI 8 assistance. In addition to these services and programs, various City churches provide some sort of servici ranges from referrals and food to vouchers for temporary lodging. These services are itemized ir- 31. 55 TABLE 31 I HOMELESS PROGRAMS AND SERVICES OFFERED BY CITY CHURCHES I NAME OF CHURCH TYPE OF SERVICE PROVIDED AVERAGE NUMBER SEEN PER MONTH Good Shepherd Assembly of God Food, clothing, lodging 10 - Transient motorists Carlsbad Union Church Gas voucher for 5 gallons of gas, food 1 family in 1989 or meal, bus fare to Ecumenical Center, 2-3 Transient motorists per month some lodging St. Patricks Church Gas, food, lodging - also once a year 20 - 30 Transients outreach to the Hispanic Community through the Harding Center St. Michaels Episcopal Church Gas voucher, food, refer to Bro. Beno 8 - 10 Transients and Ecumenical Center Pilgrim Congregational Church Refer to Ecumenical Center, Bro. Be- 3 - 4 Families no’s or Transient Lodging Program. Provide room on occasion Maranatha Fellowship Refer to Good Samaritan provide lodg- 5 - families and singles ing to some at motels and thru church Beautiful Savior Evangelical Luther- Food - cash 3-5 an Church Christ Presbyterian Church of Motel - one nighter 0 Residents Rancho La Costa 1 - 2 Transients per year First Baptist Church of Carlsbad Food and bus passes 4 As the homeless is a regional issue and not confined to any one city, many cities offer services for the various segments and population of homeless. These resources are listed in table 32. 56 I I I I I I I I I TABLE 32 REGIONAL HOMELESS PROGRAMS AND SERVICES Organization Name Homeless Location of Population Served Tyue of Service Provided Organization YMCA of San Diego County, Human Temporary shelter to house runaways, counseling Carlsbad Youths and their Development DepartmentlOZ North foster home placement. families Coast Women’s Resource CentedEmergen- Emergency shelter lodging, food, individual and Oceanside Women and Chil- cy Shelter group counseling, parenting advocacy, and locat- dren ing housing and employment. Transient Lodging Program, Inc. Provides overnight lodging in local motel for Oceanaide Women and Chil- transients with I.D. dren Emergency and crisis shelter. Red Cross WIC Supplemental food program to women who are Oceanside Women and Chil- pregnant, or have recently delivered, and to chil- dren dren under 5. Shelter assistance also. Catholic Community Services- Emergency assistance, food, clothing, shelter Oceanside Multi-Denomi- /Ecumenical Service Center vouchers, bus tokens, prescriptions. national individuals FEMA rent assistance, motel shelter, winter and families assistance program by SDG&E homeless preven- tion program. Catholic Community Services/Gd Nighttime emergency shelter from 1-30 days, Oceanside Men Samaritan Shelter meals and clothing. Men must be employed Ecumenical Service Center/ Emergen- Three day supply of food, transportation and Oceanside Families or Individ- cy Assistance clothing uals 1 I I CasaDeAmparo Children in crisis and their families Oceanside 0-18 year old chil- 19 0 dren dren dY. I Oceanside Community Action Emergency service food, clothing, etc., counsel- Oceanside All CorpMulti-Services ing, housing referrals and placement volu men I Peter and Paul’s Shelter for mentally ill Oceanside Men I I I I I 57 I I REGIONAL HOMELESS PROGRAMS AND SERVICES ~~ Oreanization Name Homeless Location of Population Served Number of Twe of Service Provided Oreanizdtion Social Concerns/ Emergency food, clothing, and furniture, trans- Oceanside All Mission San Luis Rey Parish portation, shelter referrals, crisis intervention, support educational programs for single mothers, intervention counseling advocacy The Salvation Army, Corps and Food, clothing, shelter referrals, emergency shd- Oceanside Males and Families Community Centzr/Social Services ter vouchers for a motel, local transportation, and limited direct financial assistance, problem solv- Escondido I ing . BenosiMartha and Mary Shelter for women and children up to 7 days. Oceanside Women and children Brother Benos Soup kitchen provides evening meal every day, Oceaneide All clothing, hygiene supplies, bus passes, and helps clients obtain identification. NIA N/A 6 NIA Gateway Family Community Shelter Trailers for about 30 homeless families until they Oceanside All can save enough for a apartment deposit. County Mental Health Counseling, treatment and referrals. Oceanside Mentally ill NIA Community Resource Center- Emergency food, clothing, shelter referral, em- Encinitas All /Emergency Assistance Program ployment counseling, financial counseling, advo- cacy, provides rooms in local motel for up to 60 days. Family Health Center Health care is offered to homeless and low-in- Encinitas All come people. Doctor from Mexico takes a van to pick-up points all around N. County. NIA Lifeline Community ServicedArmory Armory is open to homeless during inclement Vista All weather Faith and Love Soup Kitchen Food, clothing, household items, hygiene packets, Vista All job counseling, and referral to and assistance drug and alcohol abuse programs N1 A Escondido Youth EncountdHidden Temporary bed and board. Maximum stay 30 Escondido Women Valley House Emergency Shelter days and Children North County Interfaith Council/ Emergency food distribution, information and Eacondido All 10 beds for adul Crisis Center referral, advocacy, and vouchers for shelter, 10 beds for fam hnspoct.tioa, prescription, and recycled clothing I County Interfaith CouncillBethlehem: Individuals are acrved a hot breakfast and provid- Esfondido All House of Bread ed with r sack lunch N/A St. Clare’s Home, Inc./St. Clam’s Short-term helter, shelter for pregnant women or Eacondido Single pregnant 4 horn< dren rl cwwling and medical carc, emergency food Home for Single Mothers with chil- for women who have jug given bifi. Profession- women and clothing, nutrition classes, and patenting and childbirth chsoes 58 I I I I I 1 I I I I I I I I I I I I I SHELTER CAPACITIES, SERVICES & SCREENING AGENCIES The charts on the following pages contain information gathered in May, 1990, on shelters and serr available to the homeless. The information was obtained from the United Way's listing of non-$ social services that include Carlsbad in their target service area, and interviews with pro! administrators. The list is by no means exhaustive, however, because (1 1 people become homc for a variety of reasons and therefore have a variety of needs, some of which can be met by agen such as the EDD, that cater to, but are not specifically targeting the homeless population; ( practice, agencies are governed less by geographic area than by capacity; (3) some programs ir Diego are available for referral but the distance from North County creates logistical problems; (4) : half-way houses with a small number of beds shun publicity and take referrals from select screc agencies only; and (51 some professionals, volunteers, and organizations donate time, skills, and g to assist the homeless through a network established by screening agencies. SHELTERS Oceanside Taraet Grow Re-referredNacancv Rate Martha & Maw Women & Children 1 0-20% Gateway Family Community Families (min 1 child) NIA" Good Samaritan Employable Men 1 Casa De Arnparo Abused Children . 33 Women's Resource Center Battered Women & Children 14 Peter and Paul's Mentally ill men 10-20% Carlsbad Project Oz Youths 12-1 8 13 Escondido Taraet Grow Re-referrednlacancv Rate Escondido Youth Encounter Battered Women & Children 50 St. Clare's Home Pregnant Women & Children 20 North County Crisis Center Men 18 In addition, the Armory in Vista and select churches in North County, including Carlsbad, are OF the homeless during inclement weather. + This is the average number of individuals each month who must be referred to another ag because the shelter is operating at capacity level, and/or the individualk) is not preparc a structured environment. The vacancy rates are due to referrals to other agencies bec the individuals are unable to operate within a structured environment. Opened May, 1990, and has not yet been filled to capacity. ++ 59 POTENTIAL SHELTER SITES Carlsbad, in canjunctian with the concerned residents of Carlsbad, a housing aduocacy group and Catholic charities, and a non-profit organization with programs and administrative abilities, have established Criteria for designating potential sites for a future homeless and transitional shelters. Shelters can be a conditional use located on an industrial or commercial parcels. Site locations are to be near (within 1000') of a bus line and should be adjacent to hiring halls and to Police stations. ESTIMATED FARMWORKER POPULATION Carlsbad has a farmworker population that is currently underhoused. It is important to note that figures for this group are highly variable due to the nature of work. Carlsbad's farmworker population is estimated at 967 people. This figure is from the best official sources (SANDAG), although several other unofficial sources project that the population of resident and migrant farmworkers at certain times of the year can be as much as three times this figure. The farmworker is often a migrant laborer, and in some cases this worker has not established a permanent legal residence. Thus, the farmworker population is difficult to quantify due to factors such as language barriers, the fear of authority, and transient living quarters. This one group constitutes the largest unmet housing need in the North County region. Recent trends that have aggravated this special housing need are an increase in year-round, as opposed to seasonal, agricultural production and families increasingly joining workers. Migrant day laborers, traditionally Hispanic immigrants, are workers who seek day labor jobs outside of agricultural employment. The availability of day labor jobs plus vacant land for transient campsites tends to draw documented and undocumented foreign laborers to the North County area. These two groups, farm laborers and day laborers, have the greatest unmet need within the City of Carlsbad. Special housing accommodation such as dormitory style housing may prove helpful to meet some of this need if adequate financing and a suitable developable site is found. There is a host of sociological and economic issues surrounding this group of people that dictate the need for sensitive, but creative solutions to their housing needs. It is difficult to quantify the housing needs for this group. The housing demand for this group is not met by the region nor by local jurisdictions. It can be estimated that a good faith effort to provide around 200 beds of housing over the next 5 year housing period may partially satisfy the current need. Agricultural employment within the City is predicted to decline as more agricultural lands are turned to different uses. The City's long-term policy on development of agricultural lands is based on the fact that the use is not a long-term one and with a few exceptions will be phased out within the next 20 years as the City builds out. This makes the development of permanent long-term housing for migrants not consistent with the future uses of agricultural lands. 60 I I I I I I I I I I I I I 1 I I I 1 I SINGLE PARENTS An important group that requires special consideration are single-parent households with &per children. This group has a great need for day care, health care and related facilities. This group comprises a significant portion of low income households that may pay a proportionately greatel of income on housing. Carlsbad assists this population group through the Federal HUD Sect program for large families. Further information is included in the City's Housing Assistance located in the Appendix. While current information for this population group will be available when the 1990 Census figurc released, the older 1980 Census information shows that 1.5% of the population are male-he households with children, 4.7% of the population are female-headed households with children, of the female households are below the poverty levels. Table 33 show estimates for these popu groups. TABLE 33 SINGLE PARENT WITH CHILDREN Total Households(*) % Total Households(') Househldr w/ Childr Male 25,850 1.5 3 87 Female 25,850 4.7 1,214 Female Below Poverty 25,850 0.2 52 Source: W.S. Bureau of Census, 1980 %an Diego Association of Governments, 1990 61 LARGE FAMILY HOUSEHOLDS Households with five or more persons are defined as being large households. These households need larger housing units and pay a larger part of monthly income for housing. Large households also shape demand for schools, parks and other facilities. Table 34 shows estimated households by family size. TABLE 34 Larger Households Total Household 5 + pph 96 1990 25,850 2,275 8.8 Source: SANDAG - Regional Housing Needs Statement 1990 Large households usually require units with two or more bedrooms. Three bedroom rental units are not common in most apartment rental units for any income range. SENlORlELDERLY POPULATION Carlsbad's elderly population constitutes about 1 1.5% of the general population or around 7,297 individuals. Elderly is defined as being 65 years or older. Regional population trends indicate that this population is expected to grow significantly within the City of Carlsbad in the next ten years. The income characteristics of seniors are, on the average, in the lower economic ranges. This is due to many seniors being on fixed incomes from Social Security Benefits and/or pensions. The Bureau of the Census estimates that 44% of seniors in the San Diego Region are in the lower income (up to 80% of county median) category. The senior age group is expected to increase 20% in the San Diego region by the year 2000, which will create additional housing demand for lower cost housing. Many seniors suffer from physical debilitations. Therefore, seniors often need housing outfitted with special amenities suited to diminished physical abilities, medical alert needs, and safety. HANDICAPPED Data on the handicapped population and the extent of this group's housing need is difficult to obtain. Based on Department of Health and Human Services, it is estimated that 10% of the population of the United States is handicapped in some way. A sizable but undetermined portion of this population overlaps the elderly category. Applying this percentage to the City's population would result in an estimated population of 6,345 handicapped persons. A significant number of the handicapped may require special amenities such as wheelchair ramps, bathroom fixtures and special oversize door widths. Others may need no special amenities. The biggest need often is for low to moderate rents as many handicapped persons have incomes derived primarily from public assistance or lower-paying jobs. 62 I I I I I I I I I I I 1 I 1 I I I 1 I MILITARY FAMILIES Military populations from the Camp Pendleton Marine Base influence demand for housing. In adc to existing military households trying to find housing, households with discharged or retired mi personnel often remain in the area trying to find housing. The City of Carlsbad is located withir miles of the Camp Pendleton Marine Base and is considered by the Marine Base one of the surroul communities that would provide private affordable housing opportunities for all ranks. As indicated in Table 35, Camp Pendleton has approximately 18,706 families eligible for housin( these eligible families, 16,615 of them reside in the surrounding San Diego area. The Camp Pendleton Master Plan currently estimates that of the 16,515 families, 12,573 are SUI housed. Of these, 4,393 reside on base and 8,180 reside in private off-base housing. An estin 4,042 family households are unsuitably housed. Approximately 2,000 families are on waiting lis base-housing with an average waiting time of 6-1 2 months. Camp Pendleton has a five year 1 1995 goal of new housing construction of 1,512 units. This goal will be short of the needed un house adequately existing and projected military needs. Of the existing 4,042 families that ar suitably housed, 336 are officers and 3,706 are enlisted personnel. The pay scales for most m enlisted personnel are in the lower income range. Therefore, the creation of additional lower-in affordable housing in Carlsbad would assist in meeting this need. TABLE 35 MLITARY HOUSING NEEDS MILITARY FAMILIES UNSUITABLY HOUSED SUITABLY HOUSED M. FAMILIES ELIGIBLE 24% 4,4042 0 76% 8.180 4.393 89% 16.61s 18,706 m. PRIVATE BASE m. PRIVATE BASE FIT RESIDING IN AREA Source: USMC Camp Pendleton Master Plan, Aug 1990 63 STUDENTS Student populations are another special need category affecting local housing demand. Full-time students, especially those who attend graduate or undergraduate colleges or universities, are usually classified into low-income groups. This demand sometimes becomes critical in areas immediate to universities. Areas that have a high cost of housing, increased conversion of rental stock to condominiums and student restrictions make it difficult for students to find affordable housing. Preference for location also plays a factor, with beach areas a preference to inland areas. The new campus of California State University in the neighboring city of San Marcos, will create an additional demand for rental housing particularly in the neighboring communities of Vista, Oceanside, Encinitas and Carlsbad. This demand will not be critical until the university builds out over the next decade, and housing plans in and around the university will absorb much of the need. The highest demand will be for older housing stock, which traditionally carry the lowest rents. As such, students may be competing with other low-income groups for this housing. Currently it is estimated that Carlsbad has around 4,404 students of college age. These students may attend any one of the community or other colleges in the region. The percentage and number of college age students will grow within the next 10 - 20 years. The San Marcos campus began construction in 1990 and will not expect a significant number of students within the Housing Element’s five year time frame. 64 I I I I I I I I I I I I I I I I I 1 I HOUSING NEED BY INCOME CATEGORY LOW AND VERY-LOW INCOME HOUSEHOLDS The regional housing needs statement shows a greatly increased need for housing opportunities i low and very low income ranges. Low income is defined as 50-80% of the County median inc Very-low income is defined as those households making 50% or less of the County mediar regional need on Table 35 shows Carlsbad's share of low income housing should be almost 40 its new development within the next five years. TABLE 36 REGIONAL NEEDS STATEMENT FUTURE HOUSING NEED BY INCOME CATEGORY 1991 -1 996 m Amount Very Low -- 5096 < of County Median 1,443 Low -- 5096 - 80% < of County Median 1,066 Moderate -- 80 - 120% of County Median Upper -- 120% + of County Median TOTAL 1,317 2,447 6,273 Percent of Lower 40.04 Percent of Moderate and Above 60.05 Source: Regional Housing Needs Statement, SANDAG (page 135) This allocation is derived from a methodology using available developable acreage, jobs and er ment growth, and past housing performance by income category. The methodology for the allo also includes a vacancy factor and replacement need. Due to the future growth of industrial retail, office and service jobs in Carlsbad, the dema housing in these traditional lower-wage earner occupations will increase. Achievement of the goal to provide housing for the total need of 2,509 units indicated in the r( housing needs statement Table 30 is impractical. A more modest goal, called a "Fairshare" g( been developed. This goal is far more achievable and shows that approximately 1,125 new h opportunities for low income households will need to be created. This is 18% of the total n approximately 6,273 units needed for Carlsbad in the next five years. 65 MODERATE INCOME HOUSEHOLDS Moderate income households are those that have an income of 80% to 120% of the County median (adjusted for household size) according to the California Housing and Community Development Federal Department of Housing and Urban Development. Affordable housing for these households is also a great concern as local incomes needed to qualify for a loan on a typical median priced home is far below what is required in San Diego County, as indicated in Tables 37 and 38. Department (HCD), Moderate income is defined as between 80% to 95% of the county Median by The TABLE 37 AVERAGE PRICE OF HOMES SOLD DURING 1989 AND QUALIFYING HOUSEHOLD INCOME NECESSARY FOR A CONVENTIONAL MORTGAGE Average Price of Qualifying Average Cushion or - Rank - Area Homes Sold Income Household Income Deficit+ l1 San Francisco Bay area 2 Los Angeles area 217,400 204,500 75,300 71 ,OOO 59,600 53,900 -15,700 -17,100 l3 New York City area 199,100 77,100 59,500 -17,6oC 4 Washington, D.C. 5 saaD;ego 6 Boston area 193,600 67,900 189,600 176,400 M,W 60,900 68,700 48,OOo 59,000 800 -16,90E -1,900 7 Baltimore 155,100 54,200 52,600 -1,600 8 Atlanta 149,700 52,100 49,800 -2,300 9 Denver - Boulder 149,500 51,800 47,100 -4,700 10 Seattle - Tacoma 146,700 52,000 47,200 -4,800 11 Minneapolis - St. Paul 145,700 5 1,300 51,600 300 12 Dallas - Fort Worth 142,800 52,800 49,500 -3,300 13 Philadelphia area 141,800 50,800 5 1,900 1,100 14 Chicago - Gary 135,300 49,800 52,100 2,300 15 phoenix 130,500 43,500 46,100 2,600 16 United States 142,400 49,900 45,600 4,300 * Difference between the market’s average household income and the average income needed to qualify for a conventional mortgage on the average home sold du& 1OSP. Saua: U.S. Having w. la “rpga U.S.A. SanDiegoEarrOmic~ Vd. 38, No. 3, MvFh 1990 I Table 37 shows that a typical family of four making above the County median with a 20% down payment would not have enough income to qualify for a mortgage at the current interest rates. 66 I I 1 I I I I 1 I I 1 I 1 I I 1 I 1 I Many moderate income households, having no equity in a current home or no large down pay (over 20%1, have been forced out of the ownership housing market. Carlsbad's moderate in1 families that can afford to purchase a home here are usually "move-up" buyers with substantial e from a previous home. Many households on fixed income, such as the elderly are also precluded purchasing a home. Although the affordable issue is a regional problem, it should be addressed i city level. Although more opportunities should be provided for first time home buyers or senior I buyers, it is expected that the trend of moderate income "move-up" home buyers will contin Carlsbad. UPPER INCOME HOUSEHOLDS This is the income group with the largest stated need in terms of total units. It reflects the natl Carlsbad as a growing upscale community. The Regional Housing Needs Statement shows a min need for around 2,500 units within the next five years. Due to Carlsbad's scenic coastal locatio the market for move-up housing, it is expected that this minimum goal for housing units to mee economic range will be achieved. Spiraling housing prices and uncertain economic times in San County may preclude some upper income households from seeking larger or more expensive hc and may soften the overall market. Though "move-up" buyers are the most popularly targeted buyer in the Carlsbad real estate market, development to meet this income group is only a smal of the total housing need for the community. 67 TABLE 38 I MEDIAN AND AVERAGE HOUSING PRICE SAN DIEGO REGION 1 % Change % Change % Change Prlcs Rtce for lnflatlon Oieao CW Year - Median Rtce Avera(le Aversg. Adjuated In SM - - April 1990 1200.000 $232.800 2.8 N/A NIA 1989 183,500 218.200 26.9 19.9 5.8 1988 144,500 172,000 10.9 5.6 5.0 1987 133,300 155,100 6.1 2.5 3.5 1986 123,500 146,200 8.3 5.3 2.8 1985 1 18,500 135.000 2.9 -2.3 5.4 1984 111,500 131,200 5.5 -0.4 5.9 1983 103,400 124,400 -0.1 -2.9 2.9 1982 106,000 124.500 -2.0 -8.2 6.8 1981 104,500 127,000 8.7 -4.2 13.4 1980 90,000 1 16,800 12.5 -2.3 15.2 1979 83,400 103.800 23.1 5.7 16.5 1978 72.300 84,300 29.3 17.6 9.9 1977 54,000 65,200 24.7 16.9 6.6 1976 42,300 52,300 14.7 8.0 6.2 1975 37,000 45,600 13.2 3.6 9.2 1974 34.000 40.300 16.5 4.8 11.1 1973 28,800 34,600 10.5 3.8 6.5 1972 26.300 31,300 8.7 4.7 3.8 1971 24.600 28.800 7.5 3.4 3.9 1970 23,300 26,800 7.2 1.8 5.3 1969 22,300 25,000 10.6 5.2 5.2 1968 19,400 22,600 7.6 3.4 4.1 1967 18,000 21,000 4.5 1.5 3.0 1966 17,000 20.1 00 0.5 -1.5 2.0 1965 16,800 20.000 .05 # # - EaaomicRaeprthWuePu.Grratcr~DiegoCbpmkrofCommera %a Diep Efooomis BulkQI. Vd. 38. No. 6. hmc 1990 - - - - d 68 I I I 1 I I I I I I II I I I I II I 1 I TABLE 39 I COST OF RESALE HOMES I North County Coastal Carlsbad Del Mar Encinitas Oceanside Solana Beach Median $290,000 $475,000 $279,500 $151,000 $388,000 Source: San Diego Union, February 25, 1990 January Home Resales in San Diego County SANDAG (page 64) RESALE COSTS WITHIN THE SAN DlEGO REGION RANGE FROM $90,000 TO $590,000 TABLE 40 , CARLSBAD HOME AND CONDO PRICES FEBRUARY 1991 I Existing Homes $242,000 Existing Condo's 143,000 New HomeKondo 220,000 Zip % Changc Condo Price % Change Home Price Code 90-91 Median 90-9 1 Median I 92008 -3 1 40 -1 4 240 92009 0 155 -3 242 1 Source: Dataquick Information Systems 69 OPPORTUNITIES AND CONSTRAINTS TO HOUSING DEVELOPMENT The constraints and opportunities section of the Housing Element identifies the various constraints, both governmental and non-governmental, to housing development. Although constraints may apply to all housing production, they significantly impact housing that is affordable to the lower-income households. Many constraints are significant impediments to development, but must be weighed in the context of achieving balanced economic growth and preserving environmental resources as well as the particular quality and way of life. Housing programs should be designed to achieve a local jurisdictions share of housing for all economic ranges. Programs to remove or alter constraints are judged on the fiscal resources a jurisdiction may have. Constraints and the mitigating opportunities that may remove or lessen these constraints are discussed. In identifying mitigating opportunities it is important to note that the identification is not necessarily a commitment to implement these opportunities. As with all implementing programs identified in Section 4, the ability to carry out the programs will be affected by the availability of fiscal resources, (Federal,State, Local funds, grants, private financing, etc.) Competing interests for the available resources may impact whether and when programs proceed. Where possible, alternative strategies may be presented to mitigate constraints identified. Constraints identified within the Housing Element may or may not be a significant housing impediment within a certain time frame but are identified to help define housing issues. In some cases it may beyond the immediate capability to remove some constraints. The City has no control over private lending rates and Federal or,State actions. In the Goals section of the Housing Element, programs are identified which may offer these mitigating opportunities. The programs may be incentives such as density bonuses or requirements such as an inclusionary program. Programs of incentives may or may not be implemented depending on fiscal resources, market conditions or substantial adverse environmental impacts. 70 I I I I 1 1 I I 1 I 1 I I I 1 I I 1 1 GOVERNMENTAL CONSTRAINTS CONSTRAINT: LAND USE CONTROLS Land use controls regulate development through policies, ordinances and other regulatory proced Land use controls are necessary to ensure development compatible with the community ar preserve the health, safety and welfare of its citizens. Regulatory procedures sometimes act to constrain housing development through develol: processing and fees. These additional costs are passed on to the home buyer or renter which incrl housing prices and lessens affordable. Carlsbad has adopted a comprehensive General Plan that guides development in the City. Pric have been set to achieve quality development, protect sensitive areas. There are several levels of land use controls that the City of Carlsbad has adopted. These are: ZONING Currently the City has adopted a land use zoning ordinance that contains 12 separate residential 2 categories. These Zoning Districts (table 41) establish the type of housing units that cl constructed. Of the 12 Zoning Districts that allow residential land use, four of them are primarily family in nature while four are primarily multi-family. The remaining districts allow both. Alter1 or special housing uses may be allowed in certain residential or commercial zones on a "cond use" basis. T4BLE 41 T - ~~~~~~~~~~~~ RESIDENTIAL ZONING DISTRICTS Zoning Minimum Lot Size Rural Residential 1 acre Residential Agriculture 7,500 sq. ft. Single-Family Residential (R-I) 7,500 sq. ft. Two Family Residential (R-2) 7,500 sq. ft. Multiple-family residential (R-3) 7,500 Sq- ft. Residential Multiple Density (RD-M) 7,500 sq. ft. Single Family Waterway (R-W) 5,000 sq. ft. Residential - Tourist (R-T) 7,500 sq. ft. Residential Mobile Home Park (RMHP) 5-15a~re~ Planned Community (PC) Varies Village Redevelopment (VR) Varies Planned Industrial Residential (P-M) Varies 71 In addition to zoning that allows residential development, the City has adopted overlay zones to protect or enhance a special attribute or quality of the underlying land area (Table 42). These are: TABLE 42 OVERLAY ZONES OVERLAY PURPOSE Scenic Preservation Overlay (SP) Protect Scenic areas Flood Plain Overlay (FP) Regulate development within floodplain Beach Area Overlay (BAO) Regulate development in the beach areas Qualified Overlay (Q) Requires site development plan and Planning Commission approval Hospital overlay (HO) Zone established for hospital development Residential development in Carlsbad usually requires approval of site development plans. These plans are approved administerial for single-family projects outside overlay zones. Projects larger than single- family developments usually require discretionary actions before a Planning Commission and City Council. The requirement for discretionary approvals for most residential projects within the city adds additional time to the construction of housing units. This time factor results in hioher loan carwino costs which adds additional costs to housing. 72 I I I II I 1 I I 1 I I I I I I I 1 1 1 MITIGATING OPPORTUNITIES- Although Carlsbad currently has a wide range of land use controls, there are opportunities to mil some regulatory constraints. These controls do allow a varied range of housing types, from multif apartments to single family residential. Within these regulations there are opportunities to encol and initiate housing types for all income ranges. The Carlsbad Municipal Code allows multifamily development under several zoning designations. ' are also additional opportunities provided in the Municipal Zoning Code for multifamily develoc within the industrial area (P-MI with a density not to exceed 40 units per acre. The L Redevelopment Area and areas within the City's Coastal Plan encourage mixed uses which can r' the cost of residential construction. These savings can be passed on to the renter or purchaser. opportunities although currently available are under-utilized. A program to examine and encourai use of multi family residential in PM areas and the encouragement of mixed use projects shol initiated. In addition standards for alternative types of housing which do not fit within an residential zoning district should be developed. Alternative housing types may include Single occupancy hotels or managed living units, dormitory style farmworker housing or transitional hc for the homeless. These housing types may be allowed in certain zoning districts with condition permits with certain development standards 73 GROWTH MANAGEMENT Extraordinary orowth in housing in the early 1980'3, fueled by a growing economy, attractive land prices and proximity to a coastal location, led in 1986 to a growth management plan approved by the voters of Carlsbad. The City of Carlsbad's Growth Management Program contains several features that constrain housing development. The program ensures that needed public facilities and infrastructure is completed concurrent with development, it also limits the ultimate population and housing growth of the City at buildout. The program does not limit the number of units that can be built within a year, but limits the total maximum number of units to be built in each of the 4 quadrants within the City and therefore the City as a whole. A key component of the Growth Management Ordinance is the Citywide Facilities and Improvements Plan. This plan requires that each section of the City, (divided into 25 total zones in 4 quadrants) complete a Local Facilities Management Plan that estimates the amount of services and facilities and the capacities of each. These are set according to adopted performance standards that need to be met or assured before development can occur. Assurances are made through a financing program with each Local Facilities Management Plan. Although construction of new housing units declined after adoption and implementation of the Growth Management Ordinance, this reduction was due primarily to the need to create and complete facilities plan for each of the zones and requirements of financing-mechanisms to ensure completion of the necessary facilities. During this time applications for tentative maps and other developments were accepted, processed and approvals given contingent upon completion of zone and financing plans. Only seven zones have acceptable adopted facilities plans that allow construction at this time. (1 -6,191 Zones 1-6 are primarily the developed in-fill areas of the City Before any development project can be built, it must go through the following process: 1. A Local Facilities Management Plan must be approved for the zone in which the project is located. 2. The development project must comply with all of the conditions stated in the Local Facilities Management Plan. 3. A complete project application must be submitted to the Planning Department. 4. The project must be reviewed by the appropriate departments which typically include Planning, Engineering, Building, Fire, Growth Management, and Redevelopment (for Redevelopment Area Projects only). 5. The project must be reviewed by the Planning Commission, and in many cases, the City Council. 6. Following approval, the necessary building permits can be issued and construction can begin. As the Growth Management Plan calls for an ultimate buildout of each portion of the City, further analysis of buildout capacity is identified in the vacant lands inventory section of this document. The chart on page 76 shows buildout analysis for each quadrant of the city under growth management. 74 I I I I I I I I I I I 1 I I I I 1 1 1 MITIGATING OPPORTUNITIES Under the City's Growth Management Ordinance, the ultimate number of residential units for each i of the City is fixed in relationship to existing and future facilities and improvements. Development does not reach this total creates a surplus number of units under the Growth Management Ordinal Utilization of these excess or unused units are prioritized for lower income units. Within a large residential project, a master planned or specific planned community, an opportu exists to increase density in one area while subtracting it from another. This concept of der transfer would not result in a net increase in units from a project but would allow an opportunit create housing opportunities such as stacked flat apartments in one area of a master plar community and detached large lot single-family residential in another. Programs that require all m: and specific planned communities to provide housing for all income ranges would assure that mz planned communities which will account for 50 percent of all future residential development withir City, provide a reasonable mix of housing affordable to households of ail economic ranges. The Growth Management Ordinance requires that a Local Facilities Management Plan and a finan plan be developed and implemented to proceed with construction. Delays in developing or appro these plan can delay or halt development of new housing. Key to the Growth Management Ordin, is financing of the required infrastructure. A pay-as-you go approach has been slow as it require! developer to front the necessary money, to be recouped as the housing is sold, which sometim, difficult given the cost of some projects. Alternative financing mechanisms such as Mello-l assessment districts set up to take advantage of City Bond financing will remove a significant finar constraint under the Growth Management Program. MAP A indicates the current status of the City's Zone Plans, and Table 44 indicates the curren of December 1990) status of the residential units remaining by quadrant until buildout TABLE 43 NOT USED 75 TABLE 44 EXlSTlNG RESIDENTIAL DEVELOPMENT AS A PERCENTAGE OF BUILDOUT Ancther Nay !o wew existing tevelopflent IS :o analyze ?e Tmcer zf ?x,s:;r; Gweiling units in each quadrant as a ?ercentage of :he quadrant caps as sta:ec :: :re Z,:wca Facllities and lmprovements Plan. as shown below: NW QUADRANT ZCNE EXlSTTNG OWELLNG iJNlTS As of 12131.90 1 10,180 3 235 a 1 24 - 115 TOTAL 10.531 CFlP QUAORANT LIMIT = 15,370 PERCENT OF BUILDOUT = 69% NEQUADRANT ZCNE EXIST:NG CWELL.NG Lh.ll-5 AS of 1231.90 2 2.487 7 1,101 14 2 15 520 25 1 TOTAL 4.1 11 - CFlP QUADRANT LIMIT = 9.C42 PERCENT OF BUILDOUT = 45% I ~~ ~ ~ SW QUADRANT ZONE MISTING DWELLING UNITS As of 12/31 /90 4 3,065 9 459 19 44 20 28 22 268 ww) 410 TOTAL 4,2?4 SEWADRANT a F<ISTING DWELLING UNITS AS Of 12131190 WE) 7,324 11 954 12 589 18 1 TOTAL 8.868 - CFlP QUAORANT L" = 12.859 CFlP QUADRANT LIMIT = 17,328 PERCENT OF BUILDOUT 3: 33% I PERCENT OF BUILDOUT = 51% 76 I I I I I I I I I I I I I I 1 I I I I M I STATUS OF ZONE PLANS CITY OF OCEANSIDE CITY OF VISTA BEING REVISED I c] ADOPTED PLANS B REVIEW UNDER TECHNICAL H INITIAL PLANNING Comprehentlv@ Monitoring Report January 1991 i 6 k p a. .C , - - I I I I I I I I I I I I I I I I I I E I I I I I I I I I I I I I I I I I I I GENERAL PLAN DENSITIES The Land Use Element of the General Plan establishes the maximum amount of housing per acre of that can be developed. This is called the "density" of permitted development. General plan den! are expressed as dwelling units per acre (ddac.1 Currently the City of Carlsbad has 5 residential density ranges.(Table 45) TABLE 45 I GENERAL PIAN RESIDENTIAL LAND USE DENSITIES n A" "B" Density Range (du/ac) Growth Control Point Low Density 0 - 1.5 1 .o Low-Medium Density 0 - 4.0 3.2 Medium Density 4 - 8.0 6.0 Medium-High Density 8 - 15.0 11.5 High Density 15 - 23.0 19.0 The ranges in Column A are the density range for each land use classification. Column 6 denotc "growth control point" for each density range. Densities are calculated and allowed from the range in each land use category. The density ranges established for the residential categories a meant as minimums and maximums. The lower figure for each of these categories represe guaranteed density and the higher figure represents a potential maximum that could be located ir area if certain criteria as outlined in the Land Use Element are met. The growth control point wa$ to determine facilities need, and as development may not exceed standards set for fac development cannot occur over the growth control point unless findings can be made that the sufficient facilities available for the allowance of increased housing units over the growth control Another constraint to general plan densities is the net developable acreage or yield. Acreage wit 40% slope is considered undevelopable and is not allowed for density calculation. Acreagc topography with slopes 25% to 40% is given half the allowable density of acreage with less thal slopes. Constrained lands such as sensitive wetlands, riparian habitat and utility rights-of-wa also excluded from developable acreage. Additional environmental constraints that may I developable acreage, are dealt with separately in this section. The lack of developable acreage in the upper density ranges may constrain development of ( types of housing. Stacked-flat apartments which house lower income households may require de greater that 12 units per acre or higher depending on land costs to be developed economica indicated in the Land inventory section of this Element, there is a decreasing supply of acreage Medium High(ll.5 du/ac) or High (1 9 du/ac)density ranges remaining in the city. 78 MITIGA TING OPPORTUNITIES: There are 5 residential densities associated with the Land Use Element of the City's General Plan. In addition, there is a Residential Density of up to 40 units per acre associated with the Planned Industrial (P-MI Zoning and up to a 72 unit per acre density For Senior Citizen Projects within the Residential Professional (R-PI and Multifamily (R-3) Zoning classification. The Commercial Business District (CBD) Classification of the General Plan also allows residential with no set residential density. Densities in this CBD area are subject to growth management, architectural, scale and bulk limitations. These higher density allowances could be promoted to provide additional low income housing opportunities. Opportunities exist to reinterpret density calculations that deal with Open Space, Hillside Development, and constrained land. Allowance for density credit in these areas for purposes such as low income housing would increase the overall yield of housing units on developable land. State Law (6591 51 currently mandates that all local jurisdiction adopt an ordinance that permits a density bonus as an encouragement to low income housing. Carlsbad is in the process of adopting an ordinance within the guidelines of the current State Law. The density bonus will allow densities appropriate to develop lower-income housing. Although the City's Growth Management ordinance imposes a limit to the number of residential units built within a quadrant or within the City, there may be a need to increase some residential acreage with higher densities to develop additional lower income housing units to meet the City's future housing needs. There are three strategies to pursue this opportunity; 1. Increase density through General Plan amendments or density bonus using unused or excess units from development built or approved under the growth management control point. 2. Increase density to one area or project and correspondingly lower the density in one area or project an equal amount to result in no net gain of units. 3. Ask for a vote of the citizens to approve a higher number of units at buildout or within a quadrant. The first two strategies are the most desirable in terms of keeping with the intent of the Growth Management Ordinance. The third strategy may not be required at this time. 79 I I I I I I I I I I I I 1 1 I I 1 I I CONSTRAINT: REDEVELOPMENT PLAN In 1981 the City of Carlsbad approved the formation of a redevelopment area in what was oncc City's commercial core. Carlsbad like many other municipalities found that, with the developme1 regional shopping malls, former downtown areas were losing economic vitality. The City of Carlsbad adopted a redevelopment plan to halt this decline. As its theme, thG downtown Carlsbad area was designed around a low intensity "village area". Close to the ocear other recreational amenities, the downtown Village Redevelopment Area focused upon the touris recreational trade. Permitted uses include residential, including multi-family. The theme, scope scale of residential development within the redevelopment area encourages low intensity residc development. As the intent of redevelopment is to reduce blight, increase economic vitality and ref deteriorating structures, circumstances exist that might remove deteriorating residential structure the housing stock. Wherever possible priority is given to rehabilitation of existing structures, espe those of historic nature. MITIGA TlNG OPPORTUNITIES The Carlsbad Village area Redevelopment plan anticipates that between the adoption 01 Redevelopment Plan and its expiration in 2006, approximately 300-400 new housing units will be within the redevelopment area. This is over the existing 1600 units. These units are to be devel for all economic ranges. The Village redevelopment area contains land uses of all densities. It cor significant acreage of high density residential that is suited for units in the moderate to lower-inc The Village Area Redevelopment Plan contains policies and programs designed to assist il relocation of residents who may be displaced due to redevelopment projects. The redevelopmenl also emphasizes the rehabilitation of existing residences to conform to the nature of the \i atmosphere of the redevelopment area. Although opportunities exist to increase the number of for lower-income households because of the potential high density multi-family areas withi redevelopment area and in surrounding neighborhoods, it must be emphasized that impaction ( area with too much new multi-family development must be avoided. A predominant number of within the redevelopment and adjacent areas are affordable to lower-income households, and for historically have developed them. The remaining undeveloped acreage within the City was desig at a lower single family intensity. The strategy to spread multi-family densities throughout thc would avoid impaction to the redevelopment areas. years the housing strategies focused on providing high density multi-family units in areas 80 CONSTRAINT: OPEN SPACE REQUIREMENTS Preservation of open space is one of the goals of the City. It also acts as a constraint to the development of housing as ordinance requires a minimum open space standard per unit plus a 15 percent set aside for each subdivision or community. These policies and requirements may reduce the yield of housing units. MITIGA TING OPPOR JUNITIES: Currently the City is preparing an Open Space Management Plan that will organize the various open space policies into a cohesive policy document. This Management Plan will provide guidance for housing development that will occur in the city sensitive areas. Incentives for developments that include low income housing may include exemption or reduction of requirements for parkland dedication of open space dedications. Identification of sensitive habitats for endangered species that may preclude future development can designated for open space may allow that density to be utilized elsewhere on a development site. This may allow "clustering" of residential development that would accomplish: 1) Increases in open space, and 2) higher density within a residential development to encourage affordability. MAP B shows the City of Carlsbad's current Opens Space and trails Network, be allocated toward a project's requirement for Open Space. The allowance of the densitv on acreage CONSTRAINT: DEVELOPMENT STANDARDS Development standards are standards set by the City of Carlsbad to ensure that development of residential or commercial that occurs, is compatible with the surrounding community, ensuring the health, safety and welfare of it's citizens and providing quality development. The City of Carlsbad has two levels of development standards. Standards that are codified in the ordinances adopted by the City, and standards that can be considered administrative policy, through interpretation of the code or through interpretation of policies and guidelines of the City's General Plan. MITIGA TING OPPORTUNITIES Opportunities exist to waive administrative policies that may add additional time or costs to low income housing, The exemption of some administrative policies for low income housing could be considered an incentive for such housing. Another alternative would be to develop policies or codes that would apply only to low income housing. The purpose of these alternative codes would to be reduce cost associated with some standards in order for these costs to be passed on to the eventual low-income household. 81 I I I I I I I I 1 I I 1 I I 1 I I I I I CONSTRAINTS: BUILDING, ELECTRICAL AND PLUMBING CODES The City currently has adopted the 1988 version of the Uniform Building Code, the 1980 versio the Uniform Plumbing Code and the 1987 version of the Uniform Electrical Code.The City ha: substantive amendments to the Code that would adversely affect standard types of hous Furthermore reduction of State required codes to reduce costs are not in the best interests of pt health and safety. Interpretations of some codes may be biased against certain alternative housing types such as SI (Single Residential Occupancy) of farmworker housing., MITIGA TING OPPORTUNITIES Certain types of alternative housing structures may be given flexibility in code interpretation VI otherwise that certain type of housing may not fit into any one residential category. Examples of these alternative housing structures may be what are commonly called SRO hotels, v1 although serve a residential function, are commercial in nature and may be required to be built L restrictive commercial codes to be cost effective. Another alternative may be dormitory style housing for homeless and transient or migrant farmwor These types of housing structures not normally found in Carlsbad and may require broad interpreta of existing codes and regulations to be built. CODE ENFORCEMENT PROGRAMS Currently the City of Carlsbad has a code enforcement effort designed to protect the health safety welfare of it's citizenry. The City's Building Department in conjunction with the City Attorney's ( undertakes abatement proceedings for deteriorating and substandard housing or bootleg (ill housing units. The City of Carlsbad's code enforcement division of the Building Department currently detect! abated violations to the State and County Housing and Health Codes as they relate to substal housing. Over the last 5 years there has been an average net loss of around 3 to 4 illegal or substa housing units per year through enforcement activities. There are also abatement programs for I campsites or makeshift housing in undeveloped agricultural areas of the City, MITIGA TING OPPORTUNITIES The code enforcement activities should include a monitoring and rehabilitation program to detec monitor housing units in deteriorating conditions. These units, which predominantly house income residents, may be demolished to abate an unsafe condition thereby reducing the stock of income units. Monitoring in conjunction with a rehabilitation program would preserve these low in units. Code enforcement programs that result in abatement of substandard housing should coordination with the Housing and Redevelopment Agency that can target those units for rehabili programs that will preserve the older housing stock, It is important to coordinate unsafe resic abatement programs with relocation assistance for the tenants. Some tenants especially, handica elderly, and very-low income may have problems finding suitable residences if displaced fron current residence. Prompt relocation assistance may be crucial as the ability to rehabilitate substa units on a timely basis may focus on relocating existing residents. 82 CONSTRAINTS: OFFSITE IMPROVEMENTS Currently the City has design standards for all offsite improvement. These standards are outlined in administrative engineering policies associated with offsite improvements for residential projects. CIRCULATION IMPROVEMENTS During the course of development, circulation improvements are addressed at that time to achieve satisfactory circulation improvement goals. The City through its Local Facilities Management Plan has further identified standards for circulation. Currently some circulation improvements are funded through a "Bridae and Thorouahfares Fee" the City imposes on the areas of benefit. This fee varies according to the size of development and circulation impacts. (See fee schedule in appendices). The cost to the developer for the improvements required are usually passed on to the cost of the home or residence, increasing its cost. MIJIGA TING OPPORTUNIJIES: Circulation as well as other infrastructure improvements paid for by development through requirements of fees are usually passed on to the purchaser or renter. Usually the improvements required as part purchase price of a house. The City is currently adopting a Mello-Roos District for bond financing for infrastructure and facility improvements. The infrastructure costs may be passed on to the buyer of a home under Mello-Roos as a one time single fee assessed against the home, or under an easement district, annual installments may be used to cover the assessment. The result is the "up front" costs of infrastructure improvements may or may not be reflected in the cost and price of a home, depending on the method used to pay back the assessment district. The City may contribute to on/offsite infrastructure improvements through in-kind contributions for residential developments that would be made affordable to lower-income households. the City "Engineering Design Standards" publication, In addition there are also approximately four of a project or subdivision are passed on as an "up front" cost of the dwellino unit as Dart of the 83 I I I I 1 I I I 1 I I I 1 1 I I I II I CONSTRAINT: FEES AND EXACTIONS Currently the City assesses fees for most administrative processing of application for developr Fees and exactions receive the most amount of attention from the development community an most often singled out as contributing to the growing costs of housing. These fees are identified i appendices. Other types of fees may be exacted to mitigate effects of development that would have an ad effect on the community or district. A typical exaction would be for school fees. These exactior identified in the appendices. MITIGATING OPPORTUNITIES WAIVING OF PFF FEES Council Policy allows the waiver of Public Facility fees for low income housing. Implementation c policy should also assess the fiscal impacts that the fee would normally generate on the budget respective departments. Typically all fees including impact and processing fees average between 20,000 per unit depending on type (multi vs. Single family) and location. Reducing fees is a signi incentive for some residential developments. Table 46 shows the total fees in Carlsbad of a typ bedroom home. a4 Table 46 TOTAL FEE COSTS TO BUILD A PROTOTYPE HOME 1 Escondido 2 San Marcos 3 Poway 4 San Diego City 5 Carlsbad 6 Solana Beach 7 Encinitas $ 2 1,507 19,13 1 16,740 15,755 15,742 14,590 14,527 8 Chula Vista 14,193 9 Santee 12,397 10 Oceanside 11 Vista 12 San Diego County 12,012 10,791 9,279 13 Imperial Beach 8,567 14 Lemon Grove 8,459 15 Del Mar 8,222 16 La Mesa 7,733 17 El Cajon 7,645 18 National City 6,443 19 Coronado 5,908 CIF PROTOTYPE HOME Three bedroom, two bath single family detached home. 1800sf (square feet) living area. 400sf garage and 240sf patio. Apx. $139,000 valuation (calculated by each jurisdiction). Type V wood frame construction. lOOA single phase electrical. 100,OOO Btu FAU gas service, and a common set of fixtures. Sourcs: Annual Fee Survey, BIA, Builder Mapazinc, January, 1991. 85 1 I 1 I I I I 1 I I I 1 I 1 1 1 I I 1 HOUSING-IN-LIEU FEES A Housing-in-lieu fee targeted at market rate units or units built above a certain price range cou assessed to generate funds to subsidize the construction of lower income units. The fee would si a requirement that some projects may have to provide low income housing opportunities. JOBS HOUSING IMPACT FEES In-lieu fees or exactions leveled against developments that normally create jobs and a demand for I exacted at the time of construction on a per square foot basis and are used to subsidizc construction of low income units. The fees would be contingent upon establishing a nexus bet, job creation and demand for the type of housing it would create. REAL PROPERTY TRANSFER ASSESSMENT TAX Property that is sold and realizes a gain in assessed value is assessed a transfer tax. This tar portion thereof may be utilized as a source of revenue for housing programs. This would gener source of funds from other than the new development and would spread the responsibility and of providing housing for all income ranges to existing development. The revenue generated each by this transfer tax is approximately $350,000.00 and is not encumbered for any special projec goes to the General Fund. income housing, primarily industrial or commercial/retail development, may be assessed. Fee 86 CONSTRAINT: PROCESSING AND PERMIT PROCEDURES As indicated in Table 47 the type of permit for residential development defines its length of processing time. Projects that require multiple discretionary entitlement are usually processed concurrently. The exceptions are for multi-phase residential master planned communities in which case these projects are usually processed in phases. TABLE 47 AVERAGE ADMINISTRATIVE PROCESSING TIME FOR DISCRETIONARY APPLICATIONS AVERAGE LENGTH OF ADMIMSTRATIVE CATEGORY APPLICATION TYPE PROCESSING TIME: FROM SUBMITTAL TO 1ST DISCRETIONARY ACTION Master Master Plans 12 - 24 months Development Master Plan Amendments Specific Plans Specific Plan Amendments EIR's Major Minor RMHP Tentative Tracts Site Development Plans Redevelopment Permits Conditional Use Permits Tentative Tract Amendment/ Revisions Zone Code Amendments Planned Developments Zone Changes General Plan Amendments Minor Subdivisions Conditional Use Permits Redevelopment Permits Site Development Plans Special Use Permits Precise Development Plans Planned Industrial Permits Coastal Development Permits Miscellaneous Hillside Development Permits Administrative Variances Local Coad Plan Amendments Day Carer Satellite Antennas Planning Commission Determinations CM Conditional Use Permits Variances Street Name Changes Condominium Permits 6 - 12 months 3 - 6 months 1 - 3 months -, - 87 I 1 1 I 1 1 I I I 1 I I I I I I I I I MITIGA TlNG OPPORTUNITIES: Permit and processing procedures can be utilized to create incentives for low income hou! opportunities. Cost associated with carrying loan amounts during the processing time are usually a 1 While these costs can be absorbed by the developer, they are usually passed on to consumers via sales prices or rental rate. Expedited, fast track or priority processing can be utilized as an incentive for more low incc affordable housing. A target of 25-30% reduction in processing time can be utilized to reduce carr costs by the developer that would be passed on to reduce cost associated with the project. CONSTRAINT: CALIFORNIA ENVIRONMENTAL QUALITY ACT Under the California Environmental Quality Act,(CEQA) developments or actions defined as projc unless otherwise exempted under specific CEQA guidelines, are required to undergo an assessmer to the impact the project will have to the environment. This assessment determines if a substa or more detailed effort will be needed to assess the full impact or a determination that it will not I a significant impact. Developing rural areas, and environmentally sensitive areas that include lag1 and wetlands are particularly sensitive to the impacts of urbanization. Assessment and mitigatic these impacts are sometimes lengthy and meticulous adding extra cost to the developn Identification of impacts that cannot be mitigated may preclude development altogether. Carlsbad has a substantial amount of environmental constraints due to its sensitive habitats, co location and conservative approach to preserving its unique natural surroundings. These constr may preclude, reduce, or in most cases, slow down construction of new housing in Carlsbad. MITIGATING OPPORTUNITIES: The California Environmental Quality Act provides opportunities for "tiering" environmental revi Projects that require a comprehensive review and assessment with an ensuing Environmental In Report often may contain specific mitigation measures to offset impacts. When a project req multiple phases for completion. assessment and mitigation details can be included in the environm impact report. Subsequent phases of the development may preclude further general or der environmental review. This may lead to faster processing of projects after a master environm review and assessment and mitigation of impacts is completed and can be utilized for subsec EIR's. Additionally, as environmental impact reports may require mitigation measures for adverse imp new strategies to mitigate these adverse effects can be introduced. A jobs housing balancc strategy to reduce energy consumption and auto emissions by locating housing and jobs i together. Carlsbad with its predominantly single family housing construction over the last 2 de' and the creation of lower paid retail and manufacturing jobs, has created an imbalance of a resic population and a secondary employment population that tax the existing roadway capacity t maximum at the traditional rush hours. By creating a better mix of housing styles and types to ( a greater range of and number of housing units for the current and future employment popul would also place employment and housing closer together. A mitigating effect is created to con fuel, reduce emissions, and reduce traffic impaction. of the cost of development. Substantial delays in processing can exceed development estima 88 CONSTRAINT: STAFFING Constraints to housing opportunities may also include insufficient staffing. Federal, State and Local regulatory procedures often call for substantial review of development prior to construction. Staffing to fulfill current requirements and for additional regulatory procedures must be identified as a constraint for housing if sufficient staffing to meet processing goals and time lines are not allocated. Community Development activities such as Planning, Building and Engineering functions are impacted by the pace of the City's Housing and Redevelopment Agency, creation of additional low-income housing opportunities and the administration of them, may require additional staffing. Review of the City's previous element has shown that a variety of programs were never effectively implemented due to the increased staff time required For additional housing programs. Future programs that add additional administrative tasks to staff will also fail to be implemented if sufficient staffing time is not available to administer additional housing programs. MITIGA TING OPPORTUNITIES: Insufficient staffing and under-budgeting of positions in City Departments may also act as constraints to housing. Implementing programs to increase affordable, or the production of low income units, are dependent on adequate staffing. Frequently these programs are prioritized below other administrative and regulatory tasks and as such are not implemented on a timely basis. Housing programs that require more administrative and managerial time may result in a need for more staff for it to be effective. The Citv may need to allocate additional financial resources to assure sufficient staffing for housing programs. and magnitude of development. In addition, as the administration of housing programs are a function 89 I 1 I I I I I I I 1 I I I 1 1 I I 1 I NON-GOVERNMENTAL CONSTRAINTS Constraints that are usually beyond the local jurisdiction to control are labeled as non-governml constraints. Several of these constraints are defined at the State and Federal level but mu: addressed by the local jurisdiction sometimes under guidelines that are detrimental to the constru' of housing. CONSTRAINTS: FINANCING Financing is a key component of housing development. Financing can be broken down into twc categories; takeout (construction), and permanent (mortgage). Construction financing is usually s term in nature and is used for acquisition and development of property. Mortgage or perm: financing is the long-term financing of the project, This debt usually buys out the constru financing and is serviced by income received from rents or sales. If financing, either takeout or permanent, is not available for any of the reasons listed below, construction will not occur. Recent developments in the banking and financing industry have had substantial impact 01 development of both multi and single family housing. Several recent events have had major effec the supply of money that has traditionally been used to finance affordable housing. The 1986 Federal Tax Reform Act substantially changed the rules for real-estate investment particular regards to multifamily construction. Recent legislation has reduced tax benefits nor associated with investment in multi-family development. This has had the effect of reducin amount of money available for multi-family construction. 1989 Federal Savings and Loan Act restructured and added new regulations to the Saving! Loanflhrift Banking Institutions. These changes limited (1) the amount of money that could b to one borrower and (2) mandated extra capitalization reserves for all Savings and Loans as a ra money lent. (This has had an impact on the ability to acquire money for acquisition and develoc and for permanent financing.) Impacted the hardest were multi-family builders and small develor (< 100 units) companies who usually only used one or two lending sources for their developmc AVAILABILITY AND USE OF PUBLIC FINANCING. Funds that are available through Federal, State, and Local sources are referred to as public in n These funds are usually made available at below market (private) interest rates for purpos providing low-income housing opportunities. These funds are not widely available and are res1 in their use. With the decrease in private market financing for multi-family development, the dc for this financing has grown. Competition for these funds is high and availability is not a consistent. The additional constraint to using government financing is that of restrictions of use and i administrative burden that sometimes accompanies these funds. Many cities have chosen compete for these funds as they do not have the administrative capability to manage them. 90 CURRENT RATES Table 49 below contains July 1990 rates for construction and mortgage loans for several major banks. The effects of mortgage rates on housing affordability is indicated in Table 48 . Table 50 shows the prevailing rates of some government sources of funds. TABLE 48 THE EFFECTS OF CHANGES IN INTEREST RATES ON THE COST OF A HOME LOAN. (~l[rI1[1l11110%)1111%11112% I $60.000 $440 $483 $527 $571 $61 7 $80.000 $587 $644 $702 $762 $803 $1 00,000 $734 $804 $878 $952 $1 028 $120,000 $880 $961 $1053 $1 143 $1 234 9 150,000 $1 100 $1 207 $1 31 6 $1 428 $1 543 $200,000 $1467 S 1 609 $1 755 $1 905 $2057 - I - - TABLE 49 , MORTGAGE INTEREST RATES Fixed Rate First Lender Int Rate & - PtS Wells Fargo 10.25 10.53 2.0 Security Pacific 10.125 10.40 2.0 Fixed Rate Seconds Far West 10.75 11.16 2.0 Heartland 11.125 11.54 2.0 Adjustable Rate First Int Rate Lender - APR - Pts - Index Marein Union Bank 8.625 10.97 12.5 1 YTB 2.60 Wells Fargo 8.75 11.3 1.75 6 MTB 2.75 Source: San Diego Union - July. 1990 SANDAG @age 105) - Year 30 30 1s 15 Rate Neg '4dJ m 6 Mo No 6 Mo No Max - Loan $187.450 $187,450 $93,725 $93,800 Max - Rate 13.75 14.0 L I 91 I 1 I I I I I I I I I I 1 I I I I I 4 Table 50 contains the cost of funds by several governmental sources. TABLE 50 MONEY RATES AS OF 12-20-90 Prime Rate 10 5% Federal Funds Rate high 7 51165% (-), low 7 3/16%(-) LABOR 8 118% (c) one month 7 13116% (-) three months 7 518 (-) one year Treasury Bills 6.86% (-) 13 weeks, 6.74% (-) 26 weeks Freddie Mac 30-year fixedl3O-day delivery 9.63 % (-) Fannie Mae 30-year fixedI30-day deliver 9.53 % (-) 1 lth District COF For December '90 8.05 % (+) The above key rates are a general guide only, they should not be used for actual transactions and no warranty to their accuracy is rendered. Source: Lin Walton, First California Moflgage 92 MITIGA TING OPPORTUNITIES Financing constraints may be overcome by several financial tools available to create more affordable housing. MORTGAGE REVENUE BONDS These are bonds sold by the City to create a pool of money for subsidized mortgages. The bonds are serviced through a return rate on the mortgage or resold on the bond market. The up-front cost of issuing bonds are prohibitively expensive for a small issuing. To reduce the "up-front" cost of the issuance of a Mortgage Revenue Bond that will cover only a small amount of mortgages that a city may wish to offer, many cities have formed pools in a cooperative effort to spread the up-front cost among several cities or housing authorities, Mortgage revenue bonds can be issued for multi-family or single family developments, but multi-family bonds have become less in demand and more difficult to issue due to recent changes in the tax code. PUBLIC FINANCING The State Housing and Community Development Agency, and HUD offer construction, rehabilitation, and permanent financing as low as 3% to qualified applicants such as housing authorities or private not-for-profit developers. These funds are competed for based on participation of other funding sources and local need. A brief list of these programs is listed below: Federally funded rehab and construction programs; Section 202 Direct loans for elderly and handicapped housing. Section 502 Rural home ownership assistance. Section 51 5 Rural rental housing assistance. Section 17 Rental housing rehabilitation. Section 31 7 Rehabilitation loans. Housing and Community Development Act Block Grants. Family Housing Demonstration Program (HCD) Home Mortgage Purchase Program (CHFA) Predevelopment Loan Program (HCD) Rental Housing Construction Program (HCD) Rental Housing Mortgage Loan Program (CHFA) Self Help Housing (CHFA & HCDI AB 665 (1 982) Bonds - Renter occupied construction Funds authorized by the Mark-Furon Residential Rehabilitation Act and SB 99 - New construction California Energy Conservation Rehabilitation Program Deferred Payment Rehabilitation Loan Fund (HCD) Home Ownership Mortgage Bond Program (CHFA) Home Ownership Assistance Program (HCD) Matching Down Payment Program (CHFA) Natural Disaster Assistance Program (HCD) Non Profit Housing Program (CHFA) Farmworker Housing Grant Program (HCD) Mobilehome Park Assistance Program (HCD) State Legalization impact Assistance Grant Program (HCD) Federal Emergency Shelter Grants Program (HCD) Senior Citizen Shared Housing Program (HCD] State funded rehabilitation and construction programs; Statellocal Multifamily Program (HCD) This list of financial and assistance programs is not all-inclusive, and many programs may not have funding availability at this time. It is important that the City familiarize itself with the application process and availability of these funds. 93 I I B 1 I I 1 I I 1 I 1 I I 1 I I 1 I LOW INCOME PERMANENT FINANCING A consortium of banks and savings and loans has formed an organization (SAMCO) designed to ( private below market permanent financing for low-income projects. This organization, based in Diego, is a prime source for below market financing needed for low income projects. COMMUNITY REINVESTMENT ACT This Act requires lending institutions to report on their lending activities and how they meet the n of the community. Lending institutions may face official sanctions for not meeting performance g A City may have a program to evaluate an institution's lending practices for its community. It impose its own sanctions. These sanction may include withdrawal of funds by the City, or cooper businesses, from lending institutions who have not made adequate mortgage or construction final loans in their community. REDEVELOPMENT SET-ASIDE FUNDS Currently State Law required that 20% of tax increment returns be set aside for low-to-mod income housing. This is a good source of gap funding or equity positions the City may wi participate in with qualified law income residential projects. COMMUNITY DEVELOPMENT BLOCK GRANT FUNDS The City of Carlsbad uses the Federally entitled grant funds to support a wide range of service: programs that benefit the community's lower and moderate income households. CDBG funds m used for housing purposes in the acquisition of land using these funds and in the fundi1 rehabilitation and preservation programs. The CDBG funds may also be used to fund a wide ran planning studies and programs which will benefit low and moderate income households. 94 CONSTRAINT: PRICE OF LAND The price of land varies depending on location, improvements and use. The cost of land in Carlsbad is a prime constraint in providing affordable housing opportunity, Carlsbad contains a significant amount of land with coastal views; a premium that is added to the cost of land. In addition location factors such as proximity to freeway access, public facilities, and intangible factors such as image and quality of life contribute significantly to demand and price. The cost of improving the land, grading and added infrastructure also contributes to the final costs. Carlsbad has a considerable amount of land located in hilly topography. The added costs of grading required as well as the additional engineering and improvement costs are greater as opposed to flat level land. Costs associated with land have traditionally contributed to around 40 percent to the cost of a home. In Southern California the price of land and its preparation sometimes may be as high as sixty percent. The price of land is also determined on the number of units that the land may yield after constraints such as topography, environmental constraints and density are factored in. The actual yield may be far below the allowable density. Land prices in Carlsbad vary substantially. Undeveloped vacant land with varied topography and no improvements is approximately $1 00-250,000 an acre, with coastal view land slightly higher. lnfill residential land, with all improvements may run as high as $1 million an acre depending on location and density.The added value and price of land in Carlsbad has severely limited market-rate financed construction for low-income households. MITIGATING OPPORTUNITIES: Land prices are generally determined in the market place. As such, the availability of non constrained developable acreage suitable for residential development is higher in areas closer to significant employment centers and areas with significant desirable attributes, i.e., coastal vs. inland. Carlsbad has substantial acreage that falls within these attributes. Land pricing is also a factor of yield or return. Land costs are also determined on "how much" or yield of development that can occur upon a specific property. This yield is a product of the General Plan Density which often determined housing product type, infrastructure or the amount of acreage needed for public improvements, net developable acreage and general market conditions. Final land prices are determined by how much (if any) entitlement are secured for the land. This is important if the land is sold and currently undeveloped but has secured entitlement to build. Price can be affected by knowing there are considerations such as low income housing that need to be included in the project. This may affect the project pro-forma and the selling price of the property may be adjusted to compensate for this. Other techniques may be used to supply land at reduced prices. These include: IMMINENT DOMAINIFRIENDLY CONDEMNATION To assure an adequate supply of housing in all income ranges a city may choose to acquire suitable property to assure this need is to be met. Property acquired through friendly eminent domain proceedings is subject to fair market value but substantial tax benefits may accrue to the owner of the parcel. Property that is acquired by this method through "friendly" negotiations usually arrive at an equitable disposition and the property may be acquired at a below market price. 95 I 1 I I I I 1 1 I 1 I I 1 I I I I 1 I LAND BANKING Land that be acquired or purchased that may not be currently used for housing but may be { entitlement at a future date, could be acquired by the City. This land could be resold with entitle1 to a non-profit developer at a reduced price to provide housing affordable to lower income househ Land may be accepted as an in-lieu contribution for an inclusionary housing requirement. purchased or contributed for the purpose of residential construction must be suitable fol appropriate density. GOVERNMENTlPUBLlC LAND Surplus property that is owned by the City or another public entity can be acquired to provide pots housing opportunities for lower income households. Surplus property is then passed on to a deve at a negotiated reduced price in exchange for a requirement for more housing affordable to t income groups. CONSTRAINED ACREAGE Developable acreage that is regulatory constrained ie., constrained due to government control, be utilized to increase yield of developable acreage. Currently Carlsbad does not give density cre acreage that is constrained due to several factors. Density credits may be given to this lanc transferred to an adjacent property for the purpose of low income housing. CONSTRAINT: COST OF CONSTRUCTION Construction costs may contribute significantly to the affordability and cost of housing. Factor' contribute to construction costs are referred to as "hard costs" and typically refer to labo materials. Soft costs are typically a developer's overhead, and carrying costs on acquisiti construction loans. Carrying costs are associated with finance and lending constraints as VI processing times as referred to earlier in this section. LABOR Labor costs are significantly higher in the southern California region than averages nationwic similar employment. The prevailing wage for construction is $12.00 - $22.00 per hour a\ depending on skill, experience, and labor union affiliation. AVERAGE CONSTRUCTION COSTS COST PER SQUARE FOOT The cost per square foot for construction is a general average for the San Diego Region. This ma fram builder to builder based upon a number of factors. The average residential construction CC square foot is indicated: Multi-Family $38.00 - $45.00 per square foot Single-Family (detached1 $50.00 - $56.00 per square foot Single-Family (attached) $48.00 per square foot 96 MITIGATING OPPORTUNITIES Costs of construction in this section refers to labor and materials. The typical labor rate for construction workers depends upon the level of skill associated with the job, whether it is union or not and the availability of construction workers. Opportunities exist for reduction of costs associated with construction. These include, but are not limited to: FACTORY BUILT HOUSING/MANUFACTURED HOUSING Using new technology, manufactured homes may represent new shelter opportunities in the low and moderate income range. Some of the housing construction is conducted offsite and transported to the construction site. A fast growing alternative to onsite development, construction of flooring and framing is done in computer controlled factories and then transported onsite for assembly. Estimates on cost reductions using these methodologies may be as high as 30%. The City could encourage developers to take advantage of these type of programs. The product is identical in appearance to custom onsite stick built single family or multifamily product. Residentiai-manufactured home development(R-MHD) are residential developments that have characteristics common to both multi-family and single-family neighborhoods. R-MHD are income producing properties as are multi-family complexes, but individual detached manufactured homes in the development are owner occupied. Home owners enter into a long-term lease with the partnership or corporation(which may be owned by the tenants) which manages and maintains community infrastructure. R-MHD are typically pegged to area apartment rates. The lifestyle and density patterns are decidedly single-family in nature. R-MHD compete in the shelter market between multi-family and condominium. DEVELOPMENT STANDARDS Development standards, either modified or as part of administrative policies, sometimes add extra cost because of additional materials required and extra labor. A significant reduction of costs from a modification or waiver of the standards can be attained and passed on to the savings of the unit for low-income housing. CONSTRUCTION MANAGEMENT Development of affordable and low cost housing is sometimes accomplished through special construction management techniques. Companies that specialize in low cost housing utilize these special management techniques to cut costs. In any low income development, this should be a requirement. 97 1 I I I I I I I I 1 II 1 I I 1 I I I 1 ENVIRONMENTAL CONSTRAINTS The City of Carlsbad faces several major environmental constraints. These constraints are out11 briefly in this section. These constraints may be significant in that mitigation measures may include restriction development that would reduce the net developable acreage in Carlsbad. CONSTRAINT: ENDANGERED SPECIES Currently there are several species of flora and fauna that have been assessed as being endang for survival. Under the Federal Endangered Species Act which was designed to prescribe species may be threatened with extinction, the federal government may supersede local authority to pres habitat of the endangered species including moratoriums or restrictions on local development ur a management or mitigation measure is identified or implemented. Currently there are several species of floral and fauna that are listed on the state and fec endangered species list. These are indicated in table 51. 98 TABLE 51 THREATENED and ENDANGERED SPECIES COMMON TO THE CITY OF CARLSBAD I Sensitive Carlsbad Ran Species: StateIFed. Status (1) Acanthomintha iliciofolia (San Diego Thorn Mint) CE C1 (2) Brodiaea tilifolia Fread-leaved Brodiaea) CE C1 (3) Dudleya viscida (Sticky Dudleya) c1 Note: The following plants have a high potential for Occurrence in any Carlsbad Coastal Mixed Chaparral. (4) Comarostaphylis diversifolia v. divenifolia (5) Corethrogyne tilaginifolia v. linifolia c2 (6) Baccharis vanessae (Encinitas baccharis) CE C1 Note: Species I, 2, 5, and 6 will probably be listed within a year. Sensitive Carlsbad Reptile Species: (1) Cnemidophorus Hyperythrus (Orange Throated Whiptail) (2) Phrynosoma comnatum (Coast Homed Lizard) (3) Thamnophis hamondii (Twestriped Garter Snake) c2 Sensitive Carlsbad Bird Species: (1) Polioptila melanura California (Calif. Gnatcatcher) c2 (2) Vireo belii pusillus (Least Bell's Vireo) CE FE (3) Sterna antillarum browni (Calif. Least Tern) CE FE Note: Species number one will probably be listed (Federally Endangered) within two years. Status Definitions: (1) CE - California Endangered (2) FE - Federal Endangered (3) C1 - Candidate for Federal Endangered Species slatus. Enough information is on tile to support the listing of these species. (4) C2 - Can date for Federal Endangered Species status. More information on this species is needed to support a listing. sourcC: Sen Diego Biodivenity project. kitive Species Within Culhd City Limib. August. 1990. The most significant species list in Carlsbad is the California black-tailed gnatcatcher. This bird has been requested to be officially listed as an endangered species. A significant amount of its habitat (coastal sage scrub) is prominent in undeveloped areas of Carlsbad and the coastal region. If the gnatcatcher is listed as an endangered species and there is no mitigation plan, major undeveloped areas of the City would be closed to further development. MITIGATING OPPORTUNITIES: Potential exclusion of development for the project protection of endangered species may be avoided should a management plan to mitigate the effects of development be adopted by the City and approved by the appropriate state, federal and local agencies. Currently Carlsbad is preparing a management plan for the California Gnatcatcher, a species that may or may not be placed on the endangered species list. This plan would provide an in-depth study as to the habitat, number and location of the species, mitigation efforts and a monitoring plan. If implemented, development could possibly proceed providing that mitigation efforts were acceptable and provided for that development. This plan could be a bench-mark to provide acceptable management and monitoring plans for other endangered species of flora and fauna. 99 I I I 1 I I I I I 1 I I I I I I I I I CONSTRAINT: DROUGHT AND WATER SUPPLY Climatological factors such as drought conditions may constrain housing, both in construction anc term availability CONSTRUCTION Water reserves in a region drop and conservation becomes necessary as mandated in various alerts, construction grading becomes a low priority and is sometimes halted. This may push construction scheduled and add additional costs to housing. LONG TERM AVAILABILITY. Long term availability of water is allocated in a state and regional level and is sometimes beyor purview of local municipal governments. Cities jurisdiction may provide restriction in developm the long term if in coordination with local water authorities. MfTfGATfNG OPPORTUNfTfES: Water conservation efforts in developments that would significantly reduce water consumption may be included as an incentive for low cost housing for future housing developments. The use of water saving appliances and increased xerophytic landscaping that are consister compatible with the City's Landscape Standards should be encouraged with ties to incentives fc income housing production. Xerophytic landscaping may be substituted for normal "lush" landsc standard for low-income projects. Water conservation would also be encouraged by requiring the use of reclaimed water for gl purposes during construction periods. Additional incentives for development may be given if water conservation fixtures and applianc utilized in new construction. Retro-fitting of existing housing units with water conserving appliances or fixtures shot encouraged. During times of water alerts and shortages, retro-fitting and the savings produce allow residential development without a net increase in water consumption. 100 CONSTRAINT: TOPOGRAPHY Topography is sometimes a key constraint to housing development, as it removes significant acreage in the city from development and contributes to the land prices. Carlsbad, through an adopted Hillside Development Ordinance, does not allow significant amounts of grading without required regulatory permits. Land that has slopes of over 40% is precluded from calculating density on the site. Slopes under 40% and greater than 25% are allowed one half of the sites density. Carlsbad has over 5,000 acres that are constrained topographically. Hilly land that is allowed for development has significantly more costs associated with its improvements than flat level land. These cost are usually passed on to the home buyer or renter. MITIGATING OPPORTUNITIES: The City in order to achieve development compatible with the community and preserve unique scenic qualities of hillside topography has developed a hillside ordinance. Provisions of this ordinance calls for no residential development on hillsides with slopes greater than 40%. On slopes with density greater than 25% but less than 40%, densitv is reduced bv one half. A possible incentive for low income housing would be a density credit in hillside acreage of slopes greater than 25% or less than 40%. This would increase the yield of low income units over what normally could be provided, especially with developments in hillside areas. The city may make in-kind contributions to odoffsite improvements to lower the cost and pass it on. These contributions should be offered as an incentive especially to lower income housing. CONSTRAINT: SENSITIVE HABITATS Carlsbad has three coastal lagoons. These lagoons contain a significant amount of migratory birds and other unique flora and fauna. Preservation of these habitats is a key goal in land decisions by the City. Sensitive wetland and riparian habitat may also significantly impact development. MITIGATING OPPORTUNITIES The City currently has several sensitive habitats. These include three lagoons, Buena Vista, Agua Hedionda, and Batiquitos. In addition, the City has several watercourses and accompanying riparian to be developed within the next decade. Currently identified sensitive habitats are listed as constrained lands and not developable. This does not affect the net developable acreage as indicated in the Vacant Land Inventory which removes this acreage as constrained lands. Preserving this habitat is essential to other land use and quality goals the City has set. Opportunities to preserve these natural settings as identified through environmental assessments and other means, may be enhanced by providing density credits on developable residential acreage on these sites if the increase in density would achieve a housing element goal for low income housing needs. habitat. These lands are part of acreage that are adjacent to or within lands that have the potential 101 1 I I I I I I I I I I I I I I E I I I CONSTRAINT: COASTAL ZONE Currently a significant portion of undeveloped acreage is situated in the State designated coastal : areas. Development activities of significant impact must be approved by the California Co; Commission in addition to local approval processes. Often, to protect coastal resources signifi changes or reduction in residential unit yields or densities are required for project approval. T requirements may significantly affect production of lower income units in coastal zone areas. Carl: has additional regulatory policies to preserve agriculture and scenic resources contained in its 1 Coastal Plans approved by the State. The City of Carlsbad has received a special exemption fron requirements of Section 65590 of Government Code 10.7 for requirements of low and modc Section 30519.1, the text of which is found in the appendices. MITIGATING OPPORTUNITIES: Although the City’s current coastal zone plan does not mandate low income housing as a provisic development as some plans do, opportunities using density bonus ordinances would be utilizc coastal zone development. Currently most of the City‘s existing low income housing stock is w the City’s coastal zone. Preservation and rehabilitation programs may be mandated and impleme through this program. The city will also implement an inclusionary housing program for all mast specific planned communities, several of these communities are located in the coastal zone, then be significant contributions to the low income housing stock in the coastal areas through this pro€ Map C depicts the City‘s coastal zones. CONSTRAINT: AGRICULTURE LAND/WILLIAMSON ACT The City of Carlsbad has a large amount of agricultural land (400 acres) currently that is unde Williamson Act, which is designed to preserve longer term agricultural land for that use. The ( policy is that agriculture will not be a long-term land use for the city and will eventually be phased These areas have not been designated for future use as residential as it is primarily in areas not pla for residential development such as steep hillsides and airport impact zones. MITIGATING OPPORTUNITIES: The ultimate use for all agricultural land including lands under the Williamson Act will most likely be determined on the physical constraints and the market conditions at that time. I of the land under long-term agricultural preservation is not suitable for future residential develop as there may be significant land use, i.e., airport, environmental, coastal constraints. These const: may include topography and the City’s Growth management caps which limits the amount of residential units at build out. income housing in coastal zones. This exemption is found in The Public Resource Code, Divisior 102 1 8 I I 1 I I 1 I I I I I I I I I 1 I MP cARLsa, LOCAL COASTAL PROGRAM (LC SEGMEN' BOUNDARY Mi I ~ i LCP SEGMENT ~MELLO I ~MELLO 11 AGUA HEDIONDA EAST BATIQUITOS LAGOON/HUNT a WEST BATIQUITOS LAGOON/SAMMIS a REDEVELOPMENT AREA City of tarlsbad L 1 I I I I I I I I I I I I 1 I I I I 1 CONSTRAINT: AIRPORT LAND USE PLAN Carlsbad is home to the McClellan-Palomar Airport, a public general aviation facility. In 1970, the ! of California enacted a law requiring the formation of an Airport Land Use Commission in each cc containing a public airport. Among the duties of this Commission is the formulation Comprehensive Land Use Plan (CLUP). In San Diego County the San Diego County of Go ments(SANDAG) has been designated as the Airport Land Use Commission. In 1974 the original Use Plan for the McClellan-Palomar Airport was adopted and in 1986 a revised plan was adopted plan was adopted to assist in ensuring compatible land use development in the area surroundin McClellan-Palomar Airport. The plan contains the Airport's Influence Area, projected noise cont clear zone, flight activity zone, land use compatibility matrix and recommendations. The signii restrictions to housing and residential development are within the flight activity zone and within cc projected noise contour levels. The flight activity zone contains areas restricted from certain use: to crash hazards. The projected noise contour levels are used to quantify noise impacts ar determine compatibility with land uses. Noise levels are quantified based on a descriptor of daily level, the community noise equivalent level (CNEL). The boundaries of these levels are definc "contours" and are depicted on the Airport Noise Contour Map, MAP D. The contour does not define a land area in which residential uses are unsuitable. Rather, the co identifies an area in which mitigation measures may have to be utilized to reduce the impact of ail noise on dwelling units other than single family detached. State Noise Standards have adopted the 65 CNEL contour level as the value defined as a boul within which the noise environment is not suitable for residential use. MITIGATING OPPORTUNITIES The General Plan Land Use Map of the Land Use Element of the General Plan for the City of Car shows the area around the McClellan-Palomar Airport as being industrial in nature, with agricultural uses. There are no residentially zoned lands and the Land Use Map indicates f Industrial and Open Space Use. Although the area is primarily industrial there does exist opportunities for residential habitation PM zoning district of the City's Zoning Ordinance allows multifamily residential development of 40 units per acre providing it serves with or is built in conjunction with adjoining indt mitigation measures. The area around the airport also allows commercial land uses that may include, hotels, motels or transient commercial housing structures such as Single Room Occupancy Hotels. Transient Shelters are also allowed in Industrial areas with a conditional use permit. development, Any multifamily development within the 65 CNEL is subject to a noise stud! 104 I 1 1 I I I I I I I 1 I I I I 1 I I I r ~ ~~ ~~ ME I ~ I I I I I I I I I I I I I I I I I I I VACANT LAND INVENTORY The City of Carlsbad has a substantial amount of vacant and developable residential land. This val land is itemized by General Plan land use category in Table 53. Carlsbad has approximately 6621 acres of residentially designated land currently undevelope underdeveloped remaining in the city. Of this total remaining unconstrained residential acre approximately 94 percent has a density of 6 units an acre and under. Of the remaining 6 percent, acres have medium high density of under 12 units per acre and 60 acres, or one percent, o remaining developable acreage has a density of 19 units per acre. The total number of units that this acreage may yield according to its density limitations impose the general plan and growth control point is indicated below. TABLE 52 AcreagelUnit Yield ACRES General Plan Density(Growth Control Point) ESTlMATED YIELD 1391.14 Residential Low (1 .O) 1391 3431.35 Residential Low Medium (3.2) 10980 1347.69 Residential Medium (6.0) 8086 390.42 Residential Medium High (1 1.5) 4489 59.91 Residential High (19.01 1138 6621.06 26084 OF UNITS. This total remaining acreage yield shows that the remaining buildout capacity of over 26084 which is approximate to the remaining build out cap of approximately 2681 5 units. The city of Carlsbad also has additional acreage that is under-developed that is situated in built. in-fill areas of the city. This area is predominantly in Northwest Quadrant of the city. These contains 3 levels of potential developable residential land. The first level is vacant in-fill land which is land parceled in small lots within the older and built-ul of the city. This land is residentially zoned and designated for residential development in the (l Plan Land Use map. The second level would be under-utilized land which contains parcels of land developed but not * highest density. The third level would be land that would be transitional in nature, commercial or industrial la1 could be utilized for mixed use or residential development. It is estimated that around 10 percent of the total developed acreage may fit into these cat6 This would add approximately 700 acres to the existing vacant land. A unit yield would be difl estimate given the more stringent development controls given to in-fill residential projects 2 various densities that this acreage would be comprised. 106 The remaining vacant land and its present densities indicate that the yield of units in the 3 highest density categories; RH, RMH and RM is sufficient to produce enough multifamily housing to meet the specific 5 year goals. Lower density; RL and RLM are primarily single family densities and can be used to meet moderate and upper income category housing goals. The inventory does point out a diminishing amount of RH (residential high) density remaining in the vacant and undeveloped areas of the city. There is additional under-utilized higher density residential within the redevelopment and in-fill areas of the city. This acreage may accommodate additional units at this density range. Under Growth Management guidelines the city may allocate "unused" units, from projects that have been built under the Growth Management caps to special housing needs such as the need for lower- income units. General Plan amendments to increase densities for projects that meet this need, or, density bonus provisions to increase the yield of units above the growth control point can be achieved using the available "bank" of unused units. An additional strategy would be to decrease the density in some acreage designated in the medium residential density range and increase density in the medium high or high range. This would increase the amount of acreage in the higher end of the density range needed for multi-family housing and for special housing needs such as low-incomes housing. This strategy to increase density would not add units and would keep within the Growth Management caps but would reassign densities, if needed, to accommodate alternative housing types that need higher densities such as apartments or town homes. One adverse effect to this strategy would be to reduce the available acreage for mid-density housing such as small lot subdivisions that typically are needed for moderate-income housing. The following maps show the remaining units to be built in each quadrant of the city. Map C shows the status of the Local Facilities Management zones. The status for each zone is important as it determines how much acreage is available for development with appropriate facilities. Within the 5 year time frame for this housing element (1 991 -1 996) 22 of the 25 zones will be available for development. The remaining three zones may be available, but at this time no zone plan for facilities have been adopted. 107 I 108 ENERGY CONSERVATION IN HOUSING DEVELOPMENT. The City of Carlsbad through the introduction of a new housing goal in creating a better jobs housing balance for the city, has instituted a strategy to encourage increased energy conservation through reducing distance between housing and employment. A secondary benefit is the reduction of vehicular emissions and improved air quality. By reducing potential future commute time and distance for residents, conservation of energy particularly oil and gas, can be promoted. Reduction in distance and travel time may also reduce auto emissions as less work commuting will occur. Encouragement of future housing in proximity to existing and future transit and rail centers will be encouraged to reduce driving. The City will continue the enforcement in Engineering and Building plan-check of the State Title 24 guidelines which include energy efficiency standards for new development. Additional use of energy saving appliances especially those built-in to new housing will be encouraged. The City will require all lower-income projects that utilize City assistance or subsidy to be provided with energy efficient appliances. Through cooperative efforts with local utilities, the City will encourage retro-fitting existing housing stock with appliances and fixture that will increase energy efficiency. The City of Carlsbad currently has regulations in its subdivisions that require where possible that future subdivisions take advantage of solar orientation to reduce heating and cooling costs. 109 I I I I I I I E 1 I 1 I I I I I I I SECTION FOUR HOUSING ELEMEN ~ ~~ 1 i m - GOALS I OBJECTIVES \ PROGRAMS 1 I I GOALS, OBJECTIVES, POLICIES, AND PROGRAMS FISCAL CAVEAT I I 1 1 I I 1 I I I 1 I I I I I The following section of the Housing Element sets out the City's long-term housing goals and iden a menu of shorter-term objectives, policy positions, and action programs which can be utilizl achieve these long-term goals. Taken together these four components (goals, objectives, policies, and programs) comprise a ambitious, broad-based program for the provision of shelter throughout the City. Via this elemer City demonstrates its understanding of the magnitude of the housing problem, as well i solutions to the problem. Having demonstrated this understanding and having affirmed its commitment towards meetin City's housing needs, it is nevertheless incumbent on the City to acknowledge that the ho program is but one of a large number of programs competing for the finite fiscal resources of the Because not all of the following proposals are precisely defined (requiring further study), some dc upon the development of new funding sources which currently do not exist (trust fund, in-lieu etc.), and many will be implemented over a number of years (years for which budget projectior not available as this element is being drafted), it is not possible to subject this program to budgetary scrutiny. In addition, there may be legal requirements affecting future encumbranc funds, as well as demands in other areas requiring the City to make difficult decisions on bud( priorities. Simply stated, while the City, in adopting this element, embraces the housing prc contained in the following section, it may or may not be possible to do everything proposed with program, within the time-frame envisioned by the program. Nothing in this observation should be construed to mean that the City has any diminished commi, or diminished obligation to responding to Carlsbad's housing needs. understanding of the need for a substantial commitment of City resources to providing the nece 110 I GOALS, OBJECTIVES, POLICIES, PROGRAMS The Goals, Objectives, Policies and Programs Section of this Element contains the actions the City of Carlsbad will take to promote housing and shelter opportunities for all segments of the community. This section contains overall Goal statements, Objectives to meet those Goals, Policies on positions the City may take to meet those Goals, and Programs which are action statements. There are six Goals stated in this Element. The Goals are articulated as a general "end condition state- ment", which state a desired achievement. The Goals do not contain an action verb as they reflect a final statement of what the City will hope to achieve. How the goal will be achieved is established via the subordinate objectives, policies and - importantly - action programs. Under each Goal there are several Objectives. Objectives are more specific achievements the city will strive for to obtain the more broad based Goal. Each Objective should address a particular outstanding housing need that is identified in the previous sections of the Element. Many objectives establish numerical targets to be achieved in action programs. Each Objective will contain one or more Programs that will describe an action necessary to achieve an Objective. The Programs are briefly described and are to be implemented over the five year period of the Element. Many of the programs are studies that will take a comprehensive look at a certain aspects of housing and may follow through with a more specific program should the study indicate a plan of action should be required. Due to complexities of certain subjects it is important to take a close look at the impacts and implications that these programs may bring about. Under many Objectives, but not all, there are Policies. Policies are statements on position the City takes to implement an objective. Policies contained in the Housing Element are important statements as they reflect the City's official position on a matter. Future development must be consistent with these policies. Following each program are line items: FUNDING: indicates the source of funds to be used for each program, Where a funding source indicates General Fund it is to mean that the program uses existing staff or resources and is funded by the General Fund. Some Funding source indicate the use of State, or Federal funds. Where these funds might become unavailable, implementation of these programs may not be possible. LEAD AGENCY: indicates the agency, department or authority responsible for the program. When more than one agency is listed it is a joint or cooperative effort. The Housing Authority means the City Council authority over any housing program, the administration and actual staffing to be carried out by the Housing and Redevelopment Department. TARGET YEAR: indicates the time span for most of the programs, usually from 1991 until 1996. Where only one date is indicated it means the fiscal year the program is scheduled to be implemented or the study will take place. 111 I I I I I II I I I I I I I I I I I I I GOAL 1 (PRESERVATION) Carlsbad's existing housing stock preserved and rehabilitated with special attention to hot affordable to lower-income households OBJECTIVE 1.1 (CONDOMINIUM CONVERSION) Create a program to monitor conversions to condominium of those rental apartments v house primarily low and moderate income households and limit those conversions that re the supply of affordable housing for those income ranges. POLICY 1.1 Conversions to condominiums of existing rental units which contain households c and moderate income may not be approved unless findings can be made that; the units will remain affordable, and the City has met its need for affor housing stock for lower and moderate income groups. PROGRAM 1.1 Develop a program to restrict condominium conversion when such conversions \ reduce the number of low or moderate income housing units available through01 city. This program may require apartment owner who are undertaking the conw to pay a fee to the City. These funds would be used to mitigate the impacts I loss of these rental units from the City's housing stock to low and moderate in households. FUNDING: Condominium Conversion Fee LEAD AGENCY Planning Dept. TARGET YEARS 1992 OBJECTIVE 1.2 (MOBILE HOME PARKS) Reduce or eliminate net loss of existing mobile home rental opponunities available to low1 moderate income households. PROGRAM 1.2 The City will continue to implement the City's existing Residential Mobile Homl zoning ordinance (Municipal Code 21.1 7) which sets conditions on changes of conversions of Mobile Home Parks. FUNDING! CDBG & Redevelopment Set-aside Funds LEAD AGENCY: Planning Dept. Housing and Redevelopment Dept. TARGET YEARS: 1992 113 0 BJ ECTIVE 1.3 Retain and preserve the affordability of mobile home parks. PROGRAM 1.3 The City will assist lower income tenants to research the financial feasibility of purchasing their mobile home park so as to retain rents and leases affordable to its tenants. FUNDING: CDBG funds, State Grants and Loans, Private loans. LEAD AGENCY Housing and Redevelopment Dept. TARGET YEAR 1992 OBJECTIVE 1.4 (RENTAL STOCK MONITORING) Maintain a data base of information on vacancy rates, rental rates and physical condition of the city's existing rental housing stock, and utilize this database to evaluate programs affecting rental stock. PROGRAM 1.4 The City shall develop and implement a program in which it will periodically collect information on the factors affecting supply and demand of existing rental stock within the city. This information will be used in analysis of rental housing to be contained in the annual Housing Element Report. FUNDING: Existina Citv staff (General) LEAD AGENCY: Planning Department, Housing and Redevelopment Dept. TARGET YEAR: 1991 OBJECTIVE 1.5 (REHABILITATION) Identify and rehabilitate substandard and deteriorating housing. PROGRAM 1.5 The Building Department will develop and implement a program to monitor and report to the Housing and Redevelopment Dept., information on housing stock that is substandard and or deteriorating. Identified structures will be reported to the Housing and Redevelopment Dept. for assistance under the City's rehabilitation and assistance programs. FUNDING: CDBG funds, State and Federal Rehab, Loans, Private reha- bilitation loans. LEAD AGENCY: Building Dept., Housing and Redevelopment Agency. TARGET YEAR 1991-1996 114 I I E I I I I I I I I I I I I I 1 I i OBJECTIVE 1.6 (REHABILITATION SUBSIDIES-RENTAL STOCK) Provide loan subsidies, loan rebates and other assistance to owners of lower income unl need of repair and rehabilitation. Target: approximately 10 units per year PROGRAM 1.6 The City through the Housing and Redevelopment Department and in conjunction the Building Department will provide loans, rebates and other support to preserv existing stock of low and moderate income rental housing. Priority will be givl housing identified by the Building Department as being substandard or deteriorati which houses families of lower income and in some cases moderate income. program depends partially on outside funding from State, and Federal sources. FUNDING: State grants and loans. Private lending institutions, Re( LEAD AGENCY: Housing and Redevelopment Dept., Building Dept. TARGET VEARS: 1991 -1 995 opment set-aside funds, CDBG funds. OBJECTIVE 1.7 (ACQUISITION AND REHABILITATION) Acquire deteriorating and substandard rental housing from private owners, utilizing Vi local, state, and federal funding sources. Target; Approximately 50 units through 19% POLICY 1.7 Of the rental units acquired b y the city for rehabilitation purposes by the City's tic Authority, approximately 20% will be set aside for households in the very low-ir range. PROGRAM 1.7 The City through the Housing and Redevelopment Dept. will implement a progr acquire, using local Redevelopment set-aside funds, CDBG, State, Federal and E sector loans, rental housing that is substandard, deteriorating or in danger of low income households. FUNDING: Redevelopment set-aside, CDBG funds, State and Feder, LEAD AGENCY: Housing and Redevelopment Dept. TARGET YEARS: 1991-1996 demolished, Twenty percent of the units, once rehabilitated, will be set aside fa programs, private sector loan programs. 115 OBJECTIVE 1.8 (REHABILITATION INCENTIVES) Provide incentives for the rehabilitation and preservation of deteriorating rental units wht house lower income residents. PROGRAM 1.8 The City will provide financial and processing incentives for the owners of lower income rental stock in need of rehabilitation and preservation. These incentives will include, but not limited to; the waiving or reduction of planning and building fees, priority processing and financial incentives such as low-interest rehabilitation and propeny acquisition loans. FUNDING: Redevelopment set-aside. CDBG Funds. LEAD AGENCY: Housing and Redevelopment Dept. TARGET YEARS: 1991-1996 OBJECTIVE 1.9 (REHABILITATION-HOMEOWNERS) Provide rehabilitation assistance, loan subsidies and loan rebates for lower-income households, persons of special needs, and senior homeowners to preserve and rehabilitate deteriorating homes. Target; Approximately 5 units per year, POLICY 1.9 The Housing Authority provision of rehabilitation assistance and assistance to homeowners wilt be targeted to low-income, special needs and senior households in that priority. PROGRAM 1.9 The City will implement a homeowner rehabilitation program targeted to lower-income, special needs (handicapped, low income large-family, etc.,) and senior households that will consist of financial and processing incentives such as low interest and deferred repayment loans, loan rebates, and priority processing. FUNDING: Redevelopment set-aside, CDBG, State, Federal and private LEAD AGENCY: Housing and Redevelopment Dept. TARGET YEARS 1991-1996 sector loans and grants. 116 I I I I I I I I I I I I 1 1 I I I 1 I OBJECTIVE 1.10 (NEIGHBORHOOD IMPROVEMENT1 Assist in the creation of a Neighborhood Improvement Program to provide local resident and participation into neighborhood preservation and improvement proQrams. PROGRAM 1.10 Assist residents, especially in older neighborhood, in the creation of a Neighbo Improvement Program under which the city staff would : 1) promote an organi directed at fostering neighborhood pride and improvement, 2) provide informati city and other funding resources. Activities might include housing rehabilitatio repair, infrastructure maintenance and repair, weed abatement, abatement of violations, neighborhood pride and awareness activities, charitable activitie: information outreach, among others, FUNDING: CDBG funds, Redevelopment Set aside funds. LEAD AGENCY Housing and Redevelopment Dept. TARGET YEARS 1992-1 996 117 GOAL 2 (QUANTITY AND DIVERSITY OF HOUSING STOCK) New housing developed with a diversity of types, prices, tenures, densities and locations and in sufficient quantity to meet the demand of anticipated City and regional growth. OBJECTIVE 2.1 (REGIONAL HOUSING NEED) Allow development of sufficient new housing to meet Carlsbad's share of the total regional housing need, as identified in SANDAG's Regional Housing Needs Statement, 1991-1996. Target; Approximately 6273 units. PROGRAM 2.1 With the exception of some lower-income and special needs housing which may be assisted by the City, new housing development will be achieved through private sector efforts. New development will be achieved through the auspices of State Planning Law and the City's General Plan and Municipal Code. There is no special program for this overall goal. It is recognized that achievement of this goal will be heavily influenced by private sector marketing strategies; local, state and national economic trends; availability of regional infrastructure and services, and other factors beyond the control of Carlsbad. OBJECTIVE 2.2 (DEVELOPMENT STANDARDS) Ensure that development and housing construction achieved through the use of modified codes and standards, that will reduce the cost of housing, will retain quality design and architecture. PROGRAM 2.2 The Planning Department, in its review of development for all income categories, may recommend waiving or modifying certain development standards or recommending that certain Municipal Code changes be implemented to encourage the development of low and moderate income housing. These recommendations will be reviewed with a goal to reduce costs associated with overly strict or outdated standards. These cost savings need to be guaranteed to be passed on to the future cost of the unit. AlthouQh standards may be modified they will also retain aesthetic and design criteria acceptable to the City. FUNDING: CDBG Funds, Redevelopment Set-aside funds, General funds LEAD AGENCY Planning Dept. Engineering Dept. Building Dept. TARGET YEARS 199 1-1 996 for administrative purposes only. 117a I I I I I I I I I I I I I. I 1 I I I I OBJECTIVE 2.3 (DEVELOPABLE ACREAGE MONITORING) Ensure sufficient developable acreage in all residential densities to provide varied housing 1 for households in all economic ranges. PROGRAM 2.3 The City will monitor the absorption of residential acreage in all densities a1 needed, recommend and encourage the creation of additional residential acrea densities sufficient to meet the City’s housing need for current and future resid Any such actions shall be undertaken only where consistent with the Gr Management Plan. FUNDING: Existing City Staff (General) LEAD AGENCY: Planning Dept. TARGET YEAR 1991-1996 OBJECTIVE 2.4 (ADAPTIVE REUSE) Provide alternative housing environments by encouraging adaptive reuse of older comm or industrial buildings. PROGRAM 2.4 The City should encourage adaptive reuse of aging industrial, commercial and residential buildings by developing an ordinance that would create affordable spaces for combined living/working spaces. The principle targeted area for this t) housing would be in the downtown redevelopment area. FUNDING: Redevelopment Set aside, CDBG funds. LEAD AGENCY Planning Dept., Housing and Redevelopment Dept. TARGET YEARS 1992 OBJECTIVE 2.5 (MIXED USE) Encourage increased integration of housing with non-residential development. PROGRAM 2.5 Review existing zoning and land use policies to remove impediments to mix€ development. Major commercial centers should incorporate, where appropriate, commerciaI/residentiaI uses. Major industrial/office centers, where not precluc environmental and safety considerations, should incorporate I industrial/office/residential uses. FUNDING: Existing City staff (General) LEAD AGENCY Planning Dept. TARGET YEARS 1993 118 GOAL 3 (GROUPS WITH SPECIAL NEEDS, INCLUDING LOW AND MODERATE INCOME HOUSE- HOLDS) Sufficient new, affordable housing opportunities in the City to meet the needs of groups with special requirements, and, in particular the needs of current lower and moderate income households and a fair share proportion of future lower and moderate income households. OBJECTIVE 3.1 (FARM WORKER) Provide adequate shelter for both the permanent and migrant farm worker. PROGRAM 3.1 The City shall work with and assist local community groups, social welfare agencies, farmland owners, and other interested parties to provide shelter for the identified permanent and migrant farm workers during the five-year housing element period. These efforts will be in coordination with other regional and local programs. FUNDING: State and Federal grants and loans. CDBG funds LEAD AGENCY Community Development Department. TARGET YEARS 1991-1996 OBJECTIVE 3.2 (LARGE FAMILY) Assure the development of an adequate number of housing units suitably sized to meet the needs of lower-income larger households POLICY 3.2 In those developments which are required to include 10 or more units affordable to lower-income households, at least 10 percent of the lower income units should have 3 or more bedrooms. This policy does not pertain to lower-income senior housing projects. PROGRAM 3.2 Those housing projects entering into an agreement with the City to provide lower income housing shall be required to implement Policy 3.2 FUNDING: General Fund (administration only) LEAD AGENCY Planning Dept. TARGET YEARS 199 1 -1 936 119 I I I I 1 I I I I I I 1 1 I I I I I 1 OBJECTIVE 3.3 (HOMELESS) Provide transitional shelters and assistance for the homeless. PROGRAM 3.3.a Carlsbad will continue to facilitate the acquisition, for lease or sale, of suitable sit local non-profits and charitable organizations in securing state funding fo acquisition, construction and management of these shelters. FUNDING: Redevelopment Set aside funds, CDBG funds LEAD AGENCY Community Development Agency TARGET YEARS 1991 -1 996 PROGRAM 3.3.b Continue to provide Federal Community Development Block Grant (CDBGI fun community, social welfare, not-for-profit and religious groups which provide sel within the North County area. FUNDING: CDBG funds LEAD AGENCY Housing And Redevelopment Dept. TARGET YEARS 1991 -1 996 transitional shelters for the homeless population, The City will also continue to PROGRAM 3.3.c Encourage and assist a subrecipient (non-profit organization) of CDBG funds to de a program which will offer a City Referral Service to refer, on a 24-hour basis, trar homeless individuals and families to local agencies providing services to the homc FUNDING: CDBG Funds LEAD AGENCY Housing and Redevelopment Dept. TARGET YEARS 1991-1996 1 20 OBJECTIVE 3.4 (SENIOR/ELDERLY) Provide additional senior housing. TARGET: Approximately 200 units PROGRAM 3.4.a Amend the City's current Senior Citizen's housing regulations to conform to the provisions of Government Code section 65913.4 and 6591 5 (density bonus]. Establish standards for location, parking, safety, recreation facilities, medical care, and other approved under Conditional Use Permit. Establish appropriate monitoring and reporting procedures to assure compliance with approved project conditions. FUNDING Existing Staff (General fund) LEAD AGENCY Planning Department. TARGET YEARS 1991 PROGRAM 3.4.b Under the Constitution of the State of California, Article 34, housing projects that have more than 50 percent of the total units set aside for low-income households, and are developed by, or utilize funding from, Federal, State or local sources are subject to a vote by the citizens. In 1980, Carlsbad voters approved an Article 34 referendum to allow 200 units of Senior low-income housing. This authority has not been exercised. The City will study the feasibility of creating a low-income senior housing project at an appropriate site(s1 within the Carlsbad. FUNDING Redevelopment set-aside funds, Private financing, state public LEAD AGENCY Housing and Redevelopment Dept., Planning Dept. TARGET YEARS 1991 -1 996 aspects of senior orientated housing, Consider requiring all senior citizen projects to be financing. OBJECTIVE 3.5 (LOWER INCOME) Provide a range of new housing opportunities for lower-income households, in all areas of the city. Target: Approximately 1400 (1,125 minimum) additional assisted households. Through the implementation of various programs, the City will ensure the creation of the minimum fair share goal of 11 25 lower income housing opportunities. These programs and their associated numerical goals are indicated below. FUNDING: General fund and various other funding sources. LEAD AGENCY: Planning Department, Housing and Redevelopment Dept. TARGET YEARS 1991-1996 121 1 I I I 1 I 1 I I I I I 1 1 I I I I I OBJECTIVE 3.6 (INCLUSIONARYI Ensure that all master planned and specific planned communities and all qualified subdivis provide a range of housing for all economic income ranges. POLICY 3.6.a A minimum of fifteen percent of all units approved for any master plan communi residential specific plan shall be affordable to lower income-households. PROGRAM 3.6.a Develop a program to implement Policy 3.6.a within all master planned commur under which a minimum of 15 percent of ail approved units for that community be set aside for lower income households. This program shall require an agree1 between the developer and the City that stipulates these units will remain afforc for a specific length of time, and that the units may be offered for rent, or wit1 approval of the city, for sale. The program will also identify incentives the city policies such as where the units will be developed and their timing. The prograr be monitored by the Housing Authority. TARGET: Approximately 850 units FUNDING: Private funding, with some public funding available LEAD AGENCY Planning Dept., Housing and Redevelopment Dept. TARGET YEARS: 1991 -1 996 POLICY 3.6.b A minimum of fifteen percent of all approved units in any residential specific p qualified subdivision (to be defined) shall be set aside and be made affordable to income households. Where it can be demonstrated to the City’s satisfaction th; economically infeasible to build the required units, an in-lieu contribution consist funds, land, or other contributions may be made to the City. The City shall ass4 fiduciary responsibility for these contributions and assure their ultimate and exc use, in providing shelter for lower income households. The in-lieu contribution st in developing and constructing market-rate vs. lo wer-income affordable housing PROGRAM 3.6.b Develop a program to implement Policy 3.6.b within all residential specific pi; qualified subdivisions. This program will require an agreement between the det and the City that stipulates these units will remain affordable for a specific len time, and that the units may be offered for rent, or with the approval of the CI sale. The program will also identify incentives the city may offer. An in-lieu fee determined, may act to meet the requirement to construct the low-income hous developments less than 5 units. TARGET: Approximately 200 units FUNDING: Private developer funding LEAD AGENCY Planning Dept. TARGET YEAR 1991-1996 offer. The program will outline oolicies for integration of the units into the commur participation with non-profit developers. in an amount to be determined from a study which shall evaluate the cost differ 122 PROGRAM 3.6.~ (IN-LIEU FEE) The City will conduct a study pursuant to Policy 3.6.b to evaluate, as an alternative contribution for the inclusionary requirement. The fee may be assessed against the market rate units for the development and will be based on the difference in cost to produce a market rate rental unit versus a lower-income affordable unit. to inclusionan/ requirements as stipulated in Policv 3.6.b of the feasibility for an in-lieu 123 1 I I I I I I I I I 1 I I I I I I I I OBJECTIVE 3.7 (LOWER INCOME DEVELOPMENT AND INCENTIVES) Provide incentives, housing type alternatives, and city initiated developments and progran the assistance of lower-income household. PROGRAM 3.7.a (DENSITY BONUS) Develop an ordinance that implements Government Code section 6591 3.4 and 6E (Density Bonus) These sections require the City to grant a minimum of a 25 pe bonus over the otherwise allowed density, AND one or more additional ecor incentives or concessions that may include but are not limited to: fee wal reduction or waiver of development standards, in-kind infrastructure improvemen, additional density bonus above the minimum 25 percent, mixed use developme other financial contributions in return for the developer guaranteeing that the PI will reserve a minimum of 50 percent of the units for Senior or other special households, or 20 percent of the units for low income households or 10 percent I units for very-low income households. These units must remain affordable for a E of 30 years. Under the City‘s program each project should enter into an agrec with the City and this agreement will be monitored by the Housing and Redevelop Dept. for compliance. FUNDING: General Fund (administration only). Redevelopment Set LEAD AGENCY Planning Dept. Housing and Redevelopment Dept. TARGET YEAR 1991 POLICY 3.7.b Approvals and development of alternative housing types such as single occupancy hotels, transitional shelters, and migrant farm worker housini contingent upon meeting the City’s required lower income and special housing I Alternative housing types and their approvals may be denied should the findi made that the project is not needed to meet the special or low-income housing of the community. PROGRAM 3.7.b (ALTERNATIVE HOUSING) Consider development standards for alternative housing types, such as single occupancy hotels, homeless shelters and farm worker housing; an alternative would assist in meeting the City’s share of housing for low and very low ir households. Authorize alternative housing projects through Conditional Use Per Special Use Permit. FUNDING Private Funding, State and Local funding. LEAD AGENCY Planning Dept., Housing and Redevelopment Dept. TARGET YEAR 1991 POLICY 3.7.c Of the total units developed under the Housing Authority New Construction Pro{ 100 units will be affordable to households of very-low income. funds. 1 24 PROGRAM 3.7.c (CITY INITIATED DEVELOPMENT) The City of Carlsbad, through the offices of the Housing Authority and through the Housing and Redevelopment Department, will institute a New Housing Production Program that will create new units of housing affordable to households of low and very low income. The Housing and Redevelopment Dept. will work with private for-profit and especially not-for-profit developers. The program will use local funds from CDBG, redevelopment set-aside funds and other city originated funds and leverage them against State, Federal and private low interest funds to create these housing opportunities. TARGET: Approximately 200 new units of these new units 100 will be affordable to very-low income households. FUNDING: Local, CDBG, Redevelopment set-aside funds, State and Federal loan and grant funds. Private funding from various sources. LEAD AGENCY: Housing and Redevelopment Dept.. TARGET YEARS 1991 -1 996 PROGRAM 3.7.d (SECTION 8) Continue the City’s Section 8 program to provide additional assisted housing opportunities in the Housing Element Period 1991 -1 996. TARGET: Approximately 100 additional households. FUNDING: Federal Section 8 funding. LEAD AGENCY Housing and Redevelopment Dept. TARGET YEARS 1991 -1 996 POLICY 3.7.e The provision for the city to waive Public Facilities Fees (PFF) may be waived for lower- income housing projects pursuant to City Council Policy 17.5.e.. which states in part: The City Council may grant an exception for a low cost housing project where the City Council finds such a project consistent with the Housing Element of the General Plan and that such an exception is necessary. In approving an exception for low cost housing the City Council may attach conditions, including limitation on rent or income levels of tenants. If the City Council finds a project is not being operated as a low cost housing project in accordance with all applicable conditions, the fee, which would otherwise be imposed by this chapter, shall immediately become due and payable. PROGRAM 3.7.0 (FEE WAIVER) Implement City Council Policy number 17 under which public facility fee would be waived for lower income housing projects. Developments for which Public Facility Fees are waived may be subject to an analysis of the fiscal impacts of the project to the City. FUNDING: Redevelopment Set-aside funds. LEAD AGENCY Planning Dept, Housing and Redevelopment Dept. Finance TARGET YEAR 1991 -1 996 Dept 125 I 1 I I I I I I I I I I I I 1 I 1 1 I PROGRAM 3.7.f (PRIORITY PROCESSING) Implement priority processing for lower-income development projects. The prii processing would include an accelerated plan-check process. The priority proces would be limited to projects which would not need extensive engineerin[ environmental review. FUNDING General Fund(administrati0n only) CDBG funds LEAD AGENCY Community Development Dept. TARGET YEAR 1991 PROGRAM 3.7.g (IN-KIND IMPROVEMENTS) The City will implement a program to contribute to selected lower-income hot development, in-kind infrastructure improvements that may include but not limite street improvements, sewer improvements, other infrastructure improvement needed. FUNDING: CDBG funds, Redevelopment tax increment and set-; LEAD AGENCY Community Development Department TARGET YEAR 1992 funds, General fund. 1 26 OBJECTIVE 3.8 (GROWTH MANAGEMENTI Ensure that incentive programs, such as density bonus programs and new development programs are compatible and consistent with the City's Growth Management Ordinance. POLICY 3.8. Pursuant to Council Policy number 43; Residential development that does not yield the maximum allowable number of units under the growth management control point are considered to have "excess units". These excess units are allocated to be developed under the following priority. 1. Housing development for low and moderate households as defined by Cat. Government Code Section 659 15. 2. Senior Citizen housing as defined by Carlsbad Municipal Code Section 2 1.18.045 3. ln-fill Single Family Subdivisions, zoned R- I, that meet a// development standards and where lot sizes are equal to or greater than adjacent subdivided R-1 properties. 4. Projects within the existing general plan density range that provide, without other compensation, for some significant public facility not required as part of the development process. 5. Projects proposing a zone change Prom non-residential to residential based on the following findings; a.l The property was zoned for other than residential use on July I, 1986. 6.) The property is compatible for residential use without significant mitigation. c.) The density of the project does not exceed the Growth Management Control Point of any adjacent developed residential property. PROGRAM 3.8 Formalize the concept of an Excess Dwelling Unit Bank. The "bank" should be an accounting system to keep track of "excess units" anticipated under the city's Growth Management Plan, but not utilized by developers in approved projects. Surplus units would be available for inclusion in other projects using such tools as density transfers, density bonuses and changes to the General Plan land use designations. FUNDING: Existing Staff (General) LEAD AGENCY Planning Dept., Growth Management Division. TARGET YEARS 1991 1 27 I I 1 1 I I 1 I I I I I I I I I 1 I I OBJECTIVE 3.9 (SPECIAL HOUSING NEEDS PRIORITIES) Ensure that new development constructed by the private sector, and public funds allocatec lower-income and special needs groups, will meet the City's lower-income housing need POLICY 3.9 New development and housing that is set aside for low and very low inc households will address the unmet housing needs of the community by prioritie. by the Housing Authority through the Planning Department and the Housing Redevelopment Agency, PROGRAM 3.9 The City will annually set priorities for its future lower-income and special hol needs. The priorities will be set by the Housing and Redevelopment Dept. assistance from the Planning Department and approved by the City Council. Pr given to the housing needs for lower-income subgroups (i.e., handicapped, ser large-family, very-low income) will be utilized for preference in the guidance of housing constructed by the private sector and for the use of fund used or allocat6 the City for construction or assistance to low income projects. Setting prioritl necessary to focus the limited amounts of available financial resources on hol projects that will address the City's most important housing needs. Priorities will t annually as needs fluctuate according to how well they are accommodated over FUNDING Redevelopment set-aside funds. LEAD AGENCY Housing and Redevelopment Dept, TARGET YEAR 1991 -1 996 128 OBJECTIVE 3.10 (MODERATE INCOME) Provide a range of new housing opportunities affordable to moderate-income households in all areas of the City. TARGET: Approximately 1300 units PROGRAMS 3.1 0.a (MORTGAGE REVENUE BOND) The City will encourage the development, subject to market conditions and feasibility, of a minimum of 200 new units affordable to first-time home buyers of moderate income through a City-funded mortgage revenue bond program. The program will be limited to first-time home buyers who rent or work in Carlsbad. FUNDING: Mortgage Revenue Bonds LEAD AGENCY Housing and Redevelopment Dept. Finance Dept. TARGET YEAR 1992-1 996 PROGRAM 3.10.b (LENDING PROGRAMS) The City's Housing Authority and Housing and Redevelopment Dept. will work with local lenders and the local development community to secure funding and develop additional lending programs through local private and State and Federal housing programs for moderate income, and especially first-time home buyers. FUNDING Private Lenders, State and Federal agencies. LEAD AGENCY: Housing and Redevelopment Dept. TARGET YEAR 1991 -1 999 POLICY 3.10.c A minimum of 5 percent of all units approved for any master and specific planned community will be affordable to moderate income first-time home buyers. PROGRAM 3.10.c (MODERATE INCLUSIONARY) To assure the provision of a full range of housing opportunities for all income groups in master and specific planned communities, the City will develop an inclusionary program to implement Policy 3.1 0.c TARGET: Approximately 200 units. FUNDING: Private Lenders, Mortgage Revenue Bonds, State and Federal LEAD AGENCY Planning Dept.,Housing and Redevelopment Dept. TARGET YEARS 1991-1996 Funds. 129 1 ! 1 I I 1 I I i I I 1 I 1 I I 1 1 1 OBJECTIVE 3.1 1 (SMALLER, MORE AFFORDABLE HOUSING) Reduce the size of housing, thereby reducing costs and increasing affordability. POLICY 3.1 1 Residential subdivisions may be approved with lots smaller than required ir underlying zone, but only when the size of the structures is reduced so as to yielc costly houses. The City will consider alternative measures, including, but not lir to, height limits, lot coverage limits, and maximum floor area ratios as the mel control the size of structures on these smaller lots. PROGRAM 3.1 1 The Planning Department shall study the relationship between the size of house sizes, density, and construction and development costs. Some single family deta and attached houses should be built on smaller lots and have smaller floor areas the private sector currently provides, so as to reduce development and constru income households. The study will present findings together with recommendatior minimum sizes for permitted substandard lots, the appropriate floor area: associated houses, and the applicability of providing density bonuses so as to ac reduced development costs. Small lot subdivisions will continue to be approved through Planned Developments (Municipal Code Section 21.45) FUNDING: General Fund(administrati0n only) LEAD AGENCY Planning Dept. TARGET YEAR 1991 -1 996 costs. Smaller homes at lower costs would create housing more affordable to mod OBJECTIVE 3.1 2 (LAND BANKING) Provide adequate land for low income and moderate housing development throughout thc PROGRAM 3.12 The City will implement a land banking program under which it would acquire suitable for development of housing affordable to lower and moderate in households. The proposed Land Bank will accept contributions of land in-lieu of ho production required under an inclusionary requirement, surplus land from City, Cc State or Federal governments: and, land otherwise acquired by the City for its hc programs. This land would be used to reduce the land costs of producing lowe moderate income housing developed undertaken by the City or other parties. FUNDING: CDBG, Redevelopment Set aside funds, General Funds (i LEAD AGENCY Planning Dept. Housing and Redevelopment Dept. TARGET YEAR 1992 only) 130 OBJECTIVE 3.13 (COMMUNITY REINVESTMENT ACT) Monitor the lending practices local lending institutions’ for compliance under the Community Reinvestment Act to evaluate lending activities and goals towards meeting the communities credit needs. POLICY 3.13 The City will annually evaluate its banking practices with local and regional lending institutions based on CRA lending reports. The City will reevaluate its relationship with lending institutions that are substantially deficient in their CRA ratings. PROGRAM 3,13 The Housing and Redevelopment Dept., in conjunction with the Finance Department and the City Treasurer will monitor and evaluate local lending institutions compliance with the C.R.A. Lending institutions which are deficient in meeting C.R.A. lending responsibilities in areas such as multi-family construction and lending for affordable housing will be identified. The City will explore means to encourage greater lending activities in Carlsbad. FUNDING: CDBG fund, Redevelopment Set-aside funds LEAD AGENCY Housing and Redevelopment Dept., Finance Dept., City TARGET YEARS 1991 -1 996 Treasurer OBJECTIVE 3.14 (HOUSING TRUST FUND) The City will create a Housing Trust fund to facilitate the construction and rehabilitation of affordable housing. PROGRAM 3.14 The City will create a Housing Trust Fund for the fiduciary administration of monies dedicated to the development, preservation and rehabilitation of housing in Carlsbad. The Trust Fund will be the repository of all collected in-lieu fees, CDBG and tax- increment funds targeted for proposed housing as well as other, local, state and federal and other collected funds, FUNDING: In-lieu fees, tax increment funds, real property transfer tax, and LEAD AGENCY Housing and Redevelopment Dept., Finance Dept. TARGET YEARS 1992 CDBG funds, local, state and federal funds. 131 1 I I 1 I I I I I I R 1 I I I I I I 1 OBJECTIVE: 3.1 5 (HOUSING ELEMENTlANNUAL REPORT) Ensure that the Housing Element retains its viability and usefulness through a amendments, review and monitoring. PROGRAM 3.15 To retain the Housing Element as a viable policy document, the Planning Depl undertake an annual review of the Housing Element and schedule an amendm required. Staff will also develop a monitoring program and report to the City Cc annually on the progress and effectiveness of the housing programs. This monil program will be in conjunction with new State of California requirements reg: annual reports. FUNDING: General Fund LEAD AGENCY: Planning Dept. TARGET YEARS 1991 -1 996 132 GOAL 4 (HOUSING, JOBS, WORK FORCE BALANCE1 Maintenance of a high quality of life and a strong local economy through a balance of residential and non-residential development, in particular, a balance of the skills desired and wages offered by local employers; the skills and education possessed. and wages earned by the local work force; and the cost of local housing. OBJECTIVE 4.1 (HOUSING IMPACT FEE) Achieve a balance between 1) the numbers of local jobs created relative to the availability of housing, and 2) the cost of housing relative the wages that are offered. PROGRAM 4.1 The City will study the impact of commercial and industrial development on housing demand, and the ability of local employees to afford local housing. Where adverse impacts are identified, mitigation measures will be considered to reduce the impact. These measures will include, but are not limited to, the requirement for commercial and industrial developers and employers to contribute an in-lieu fee towards the production of affordable housing and employer assistance to finance affordable housing for their employees. FUNDING: CDBG funds., General Fund [administration only) LEAD AGENCY Planning Dept. TARGET YEARS 1992 1 33 I I I I I I I 1 I 1 I I 1 1 1 I I I I GOAL 5 (RESOURCE CONSERVATION) New and redeveloped housing which conserves natural resources, in particular energy and wate OBJECTIVE 5.1 (ENERGY CONSERVATION) Promote energy conservation in new housing development. PROGRAM 5.1 The City will continue to implement energy conservation measures in new ho development through State Building code, Title 24 regulations, and solar orientat major subdivisions through Title 20., Chapter 17 of the Municipal Code. FUNDING: Private funding LEAD AGENCY: Community Development Dept. TARGET YEARS 1991-1996 OBJECTIVE 5.2 (WATER CONSERVATION) Promote resource conservation including water conservation in new housing developmc PROGRAM 5.2 New housing construction developed under a water emergency may be requil develop strict conservation guidelines, including but not limited to, man( installation of low flush and low flow bathroom and kitchen fixtures, xerol landscaping or suspension of landscaping requirements until the water emergel lifted, and requiring the use of reclaimed water in all construction grading project: such actions shall be in accord with policies adopted by the City in respor declared emergencies. FUNDING Private funding LEAD AGENCY Community Development Dept. TARGET YEARS 1991 134 GOAL 6 (OPEN AND FAIR HOUSING OPPORTUNITIES) All Carlsbad housing opportunities (ownership and rental, fair-market and assisted) offered in conformance with open housing policies and free of discriminatory practices. OBJECTIVE 6.1 (FAIR HOUSING) Disseminate and provide information on fair housing laws and practices to the community. PROGRAM 6.1 The Housing Authority and Housing and Redevelopment Dept will make information on “fair housing law and practices” available to all tenants, property owners and other persons involved in the sale and rental of housing throughout Carlsbad on an ongoing basis. FUNDING: CDBG funds, Section 8 administration funds. LEAD AGENCY: Housing and Redevelopment Dept. TARGET YEARS 1991-1996 PROGRAM 6.2 The Housing Authority will continue its program of referrals to the appropriate agencies on complaints on fair housing issues. These complaints will be monitored as to the status of the complaint and will direct any action, if required, to the appropriate Local State or Federal agencies for further actions. FUNDING: Section 8 administration Funds, CDBG funds. LEAD AGENCY: Housing Authority TARGET YEARS: 1991-1996 PROGRAM 6.3 (MILITARY, STUDENT REFERRALS) The City will assure that information on the availability of assisted, or below-market housing is provided to all lower-income and special needs groups. The Housing and Redevelopment Agency will provide information to local military and student housing offices of the availability of low-income housing in Carlsbad. FUNDING: CDBG Funds, Redevelopment Set aside funds. LEAD AGENCY Housing and Redevelopment Agency TARGET YEARS 1991 -1 996 135 I I I 1 1 1 I I II I I I I I I I I I 1 PRIORITIES, CITIZEN PARTICIPATION, UPDATE AND REVIEW INTRODUCTION The preceding policies and action programs are designed to meet a broad range of housing goals needs identified in the Housing Element. The design of the program is a comprehensive attem meet both long-range community and State guidelines. However, in order to implement the pros resources available and, in some cases, identify the need for additional time, staff or funds. CITIZEN PARTICIPATION The original Housing Element was developed with the guidance and cooperation of a Citizens' Rc Committee appointed by the City Council. This Review Committee met in 12 sessions betweer and October 1979. A final review meeting was held in January 1980, followed by Pla Commission and City Council hearings and workshops in the Spring and Summer of 1980. The revision of the Housing Element is a technical update of that document. The 1990 Census, Serie$ Regional Growth Forecasts, and 1991 -1 996 Housing Needs Statement were used in the revisic The City has provided several opportunities for all economic segments of the population to partic in the revision of the Housing Element. The Housing Element went through an elaborate c participation process when it was first drafted in 1980. A series of public workshops for each quadrant of the community were held in October and Novf of 1990 to discuss housing concerns and issues. Two workshops were held with affordable hc advocates and the building and development community to receive input and discuss the 1 housing element. A questionnaire was passed out to the participants at these meetings to CE citizen input on local housing issues. A copy of this questionnaire is contained in the appendicc Prior to adoption of the Housing Element, public hearings will be held before the Planning Comm and City Council. MANDATED REVIEW AND UPDATE Environmental Assessment and Review A Negative Declaration on the Housing Element has been prepared and filed with all appra agencies in accordance with Title 19 of the Carlsbad Municipal Code and the California Environn Quality Act. lnteraovernmental Coordination Regional data on population and housing forecasts and fair share allocation from the San priorities are set which concentrate resources on the most immediate needs, make best use c Association of Governments (SANDAG) were used, Local Review and UDdate After adoption by Planning Commission and City Council, the Element will be updated as nece The state requires that the next revision be accomplished by July 1, 1996. 136 San Dieao Counw A copy shall be filed with San Diego County pursuant to development of future Community Development Block Grant Program applications. City Staff Carlsbad's Community Development Block Grant submissions shall be reviewed to assure conformance with Housing Element Goals and Programs, DeDartment of Commerce, Bureau of Census The decennial national census was taken April 1, 1990. This information and more current information were used as part of this revision. Review of Housing Element projections and goals should take place if data that would require amendmentslrevisions become available. Proaram Evaluation Local evaluation of program effectiveness and implementation of policies and programs, with recommendations for change, should be conducted annually over the next five years with public hearings before the Housing and Redevelopment Commission. Maior Revision A major evaluation and revision of the Housing Element should take place in 1995. 137 I 8 1 I I I I 1 I I I I I I I I I I I I I I I I I I I I II I I I I I I I I I APPENDIX A I , I HOUSING QUESTIONNAIRE I , I I I I i I 1 I ! i 1 i I 1 DEVELOPMENT QUESTIONNAIRE The purpose of this questionnaire is to identify issues of a concern to the developmenc community for purposes of needs assessment, constraints and opportunity assessmenr and public input for the City's revised Housing Element. Participation in this questionnaire is requested to more formally identify issues, and to provide background data for the formation of future housing policies. 1. NAME: COMPANY: ADDRESS: CONTACT PERSON: PHONE: TYPE OF COMPANY (eg. developer, consultant, architect) 2. REGtON OF ACTMlY (eg. City, Regional Nationwide) 3. LIST IN ORDER OF IMPORTANCE YOUR TOP CONCERNS: A. IMPACT FEES/DEVELOPMENT EXACTIONS B. INFRASTRUCTURE FINANCING C. WETLANDS D. WORKERS COMPENSATION E. DEVELOPMENT COSTS F. ' GROWTH/NO GROWTH ATTITUDES G. AFFORDABLE HOUSING (LOW-MOD) 2075 Las Palmas Drive 0- Carlsbad. California 92009-4859 (619) 438-1 161 ~~~-~ ~~~~~ ~~ ~ ~~ ~~~ I 8 I I I I I I I I I I I I I I I] I I H. PROPERTY TAKEC I. COASTAL DEVELOPMENT RESTRICTIONS J. FINANCING COSTS/LOAN SOURCES K. ECONOMtC FORECASTS 4. NUMBER OF HOUSING STARTS OR PROJECTS YOUR COMPANY AVERAGES 1 YEAR IN CARLSBAD. 5. TYPE OF PRODUCT MULTI FAMILY SINGLE FAMILY COMMERCIAL OTHER 6. AVERAGE SQUARE FEET PER UNIT 7. AVERAGE LOT SIZE 8. WHAT DO YOU BELIEVE IS THE GREATEST CONSTRAINT IN THE DEVELOPM OF AFFORDABLE HOUSING TODAY IN CARLSBAD (CHOOSE ONE) LAND COSTS GOVERNMENT EXACTIONS/REGULATIONS CARRY COSTS/FINANCE CONSTRUCllON COSTS AVAILABILITY OF FINANCING 9. WHAT IS THE AVERAGE TIME SPAN ENCOUNTERD WHEN APPLYING ENTITLEMENTS FOR MASTEWSPECIFIC PLANS MOS. SUBDMSION APPROVALS MOS. LOWSTATE COASTAL PERMITS MOS. OTHERS (IDENTIFY) MOS. ENVIRONMENTAL MOS. 10. WHAT WOULD BE ACREDIBLE REDUCTION IN PROCESSING TIME THAT WOULD SIGNIFICANTLY REDUCE YOUR CARRY COSTS THAT COULD BE PASSED ON TO MAKE THE DEVELOPMENT COST AND RENTAL OR SALES PRICES LOWER. MOS. OR 010 11. WHAT IS YOUR AVERAGE RAW LAND COST PER SQUARE FEET OR PER ACRE 12. WHAT IS YOUR IMPROVED (ON/OFF SITE) LAND COSTS PER SQUARE FOOT OR PER ACRE OR AVERAGE PER LOT 13. WHAT ARE YOUR AVERAGE CONSTRUCTION COSTS PER FOOT MULTI FAMILY SINGLE FAMILY DETACH/ATTACHED OTHER 14. WHAT, IN YOUR OPINION WOULD BE THE MOST WLE PROGRAMS THE CITY REMAINING WITHIN THE CONTEXT OF THE CURRENT GROWTH CONTROL/FACILITIESMANAGEMENTPROGRAMS (INORDEROFIMPORTANCE). REDUCTION/WAIVING OF FEES REDUCTION OF EXACTIONS REDUCTION OF PROCESSING TIME (FASTI'RACKING) LAND PURCHASE WRITE DOWNS BELOW MARKET FINANCING INCREASE PROJECT DENSITY COULD IMPLEMENT TO PRODUCE LOW TO MODERATE INCOME HOUSING, BUT REDUCED DEVELOPMENT STANDARDS -3- I I I I I I B 1 I I I I I I I I I I I 15. SHOULD YOU BE REQUIRED TO PRODUCE LOW INCOME HOUSING, ARE YC WILLING TO (YES, NO) JOINT VENTURE WITH CITY WITH NOT-FOR-PROFIT DEVELOPER WITH OTHER FOR PROFIT DEVELOPER PAY IN LIEU INSTEAD OF CONSTRUCTION 16. WHAT IN YOUR OPINION WOULD BE A FEASIBLE IN LIEU FEE PER UNIT. 17. DO YOU USE LOCAL BANKS OR OTHER FUNDING INSTITUTES FOR YC CONSTRUCTION FINANCING? IF YES, WHO 18. DO YOU HAVE TROUBLE FINDING CONSTRUCTION OR LONG TERM FINANCI FOR MULTI-FAMILY CONSTRUCTION. FINALLY, SHOULD YOU BE REQUIRED TO CONSTRUCT A 60 UNIT APARTMI INCOME UNITS ARE A MIX OF 50% 1 BDRM, 50% 2 BDRM) AND GNEN YC CURRENT LAND COSTS, FINANCING, FEES, EXACTIONS, CONSTRUCTION COSTS W€ AMOUNT OF SUBSIDY PER UNIT WOULD BE REQUIRED FOR THE UNIT TO PENCIL ( FOR LOAN PURPOSES OR WHAT PERCENT OF PROJECT COSTS WOULD HAVE TC SUBSIDIZED BY DEVELOPER EQUITY OR ANOTHER SOURCE? PROJECT WITH 50% SET ASIDE FOR LOW INCOME (80% OF CO. MEDIAN L THANK YOU FOR YOUR TIME AND PATIENCE. 'I -4- COMMUNITY HOUSING QUESTIONNAIRE [Y YOUR OPINION, WHAT IS THE IMPORTANCE OF THE FOLLOWING HOUStNG [SSLES FACING CARLSBAD IN THE NEXT DECADE. LOW MEDKM EIGK Special housing needs (Senior, adult disabled) Availability of low to moderate income housing "- Housing affordability "- housing rehabilitation Overcrowding - maintenance "- Neighborhood improvement "- Homelessness Are there other outstanding housing issues you think the City of Carlsbad should address. "- "- "- ~-~ ~ Do you cunady participate or are you on a waiting list for a housing program in the City ofCarlsbad(eg.Section8) ~~~ ~~ ~~-~ ~~ ~~ ~ 2075 Las Palmas Drive Carlsbad, California 92009-4859 o (619) 438-1 1 61 I I I I I I 1 1 I I I I I I 1 B I 1 I what we of housing do you chink there is a shortage of in the Ciry of Carlsbad. No Fume Cum Shortage Shortage Shcn2 Single family affordabie (moderate income) hlulti-fdy affordable (condominium/townhomes) Apartments Sr. Citizen Complexes/viUaages - - - - 3 or 4 bedroom apartments ” - Shon-term/vacation/transiKiond housing Mobile home parks ” ” - [f you wish to be put on a mag list for future notices On housing issues, Please coml below Name Organization Address City,State,Zip I I I I I I I 1 I I I I I 1 I I a 1 1 , 1 I 1 I ! APPENDIX B ! ! ~ 1 I , 1 I I DEVELOPMENT FEES 1 i I I I j ! I I i 1 I 1 DEVELOPhIENT PROCESSING FEES APPL1CATION;~EQUIREMENT - FEE XDJUSnIENT PLAT ________________________________________- S 3?O,w .&DMISIS"RATIVE VXRIAVCE Single Family ________________________________________-- s 240.(N Other ________________________________________------------ s 410.00 - APPEALS Engineering Planning Tu City Council Single Familv ________________________________________-- s 110.00 Other ________________________________________------------ s 470.00 To Planning Commission Single Family------------------------------------------ s 110.00 Other ________________________________________------------ S 470.00 - BRIDGE AND THOROUGHFARE FEE (See Page 21) BUILDING PERMIT FEE (See Page 19) BUILDING PLAN CHECK FEE (65% of Building Permit Fee - See Page 19) BUSINESS LICENSE TAX (See Page 19) 3.5% of Building Value CERTIFICATE OF COMPLIANCE----------------------- s 240.00/Lot COASTAL DEVELOPMENT PERMIT Single Family ________________________________________-- s 110.00 Other ________________________________________------------ s 360.0 CONDITIONAL USE PERMIT Regular ____________________-----_--------------------- ---------- s2,100.00 Amendment---_----_--_----_-------_------------------ S l,oO0.00 Extension ________________________________________------ s 375.00 Non-Profit ________________________________________---- ---------- S 110.00 Amendment ................................... -"""-$ 75.00 memion ..................................... ---__--- $ 50.00 CONDOMINIUM PERMIT (See Planned Development) CONSTRUCTION CHANGE Minor ........................................ ----------- S 50.00 Major ____________________~__-_--_-_--_-------- ----__---- s 160.00 DAYCARE PERMIT (Large Family 7-12 children)---S 110.00 Extension ____________________~~~~--__-_----_--------- ----------- S 50.00 I I 1 1, I I 1 I 1 1 I I I I I I I I I APPLICATION~REQC'IREMENT - FEE DEDIC;\TION OF EASEMENT---------------------------S I&).@) DES[GS REVIEW - PREL[MMINARY REVIEW Minor ________________________________________------------ ,Ciajor ________________________________________-""------- s 50.00 s 250.00 DISCUSSION ITEM TO PLXUNIWG COMMISSION {See information to Planning Commission) DRAINAGE FEES (See Pages 14 s( 15) DUPLICATE TRACING FEE (Final Tract Map)-----S 30.00/sheet DUPLICATE TRACING FEE (Final Parcel Map)----S 50.00isheet ENCROACHMENT PERMIT (Before Installation)---S 50.00 ENCROACHMENT PERMIT (After Installation)-----% 100.W ENGINEERING VARIANCE Minor ________________________________________------------ 2 92.00 Major _________________.______________________------------ S 157.00 ENVIRONMENTAL IMPACT ASSESSMENT---------% 210.00 ENVIRONMENTAL IMPACT REPORT 0-20 Acres ________________________________________------ $2,1i)O.i)O Over 20 Acres ......................................... $5,250.00 ENVIRONMENTAL IMPACT REPORT ADDENDUM------------------------------------------------- $ 250.00 ENVIRONMENTAL IMPACT REPORT SUPPLEMENT-----------------------------------_----------- $1,050.00 + Actual Cost ENVIRONMENTAL MONITORING FEE------------- $ 110.00 FACILITIES MANAGEMENT FEE (See Page 17) FTNAL PARCEL MAP (Minor Subdivision)------------- $1,580.00 FINAL TRACT MAP (Major Subdivision)--------------- $2,630.00 + FIRE HYDRANT FEES (See Utilities Department)--S2,500.00 deposit $ S.OO/Acre FUTURE IMPROVEMENT AGREEMENT------------ s 80.00 GENERAL PLAN AMENDMENT 0.5 Acres _______-_________________ -- ____-__ -------------- $1,050.00 @er 5 Acres ________________________________________--- $2,100.00 APPLICATI0N;'REQCIREMENT - FEE GRADING CXSH DEPOSIT-------------------------------- 10% (Max.) of Grading GRADISG PERMIT FEE (See Pages 18 and 19) GRADIYG PLhU CHECK FEE (See Pages 18 and 19) HILLSIDE DEkTLOPMENT PERMIT Single Family ________________________________________--- s 110.00 Other ________________________________________------------- S 370.00 s 75.00 Amendment Single Family ________________________________________--- Other----------------------------------------------------- s 300.00 IMPROVEMENT AGREEMENT EXTENSION-------S 160.00 IMPROVEMENT INSPECTION FEE (See Page 13)--3% - 5% of IMPROVEMENT PLAN CHECK (See Page 13)-"""1.5% - 6% of INFORMATION TO PLANNING COMMISSION (Discussion Item) Engr. Est. Engr. Est. Single Family ________________________________________--- 5 110.00 Other __________________________________I_____------------- $ 390.00 INSPECTION - ADDITIONAL PLANNING------------ $ 50.00 (First inspection included in plancheck fee) INSPECTION OVERTIME (on request)------------------ S 75.00hour LANDSCAPE INSPECTION (same as Improvement Inspection) (See Page 13) LANDSCAPE PLANCHECK (same as Improvement plancheck) (See Page 13) LOCAL COASTAL PLAN AMENDMENT Minor ________________________________________--------- --- $1,580.00 Major ________________________________________------------ $5,780.00 MASER PLAN ________________________________________--------- $9,980.00 + $ 15.00/acre MASTER PLAN AMENDMENT Minor ________________________________________-- ---------- S 1,580.00 Major .................................................... $3,m.OO+ S10.m/acre MODEL HOME DEMOLITION DEPOSIT MONUMENTATION CASH DEPOSIT PARK-IN-LIEU FEES (Applies only to Subdivision) (See Page 16) PEER REVIEW I 1 I I I I I 1 I 1 I I I I I I I 1 I APPLICATION,/REQUIREMENT - FEE PLANNED DEVELOPMENT FOR NON-RESIDENTIAL Minor (4 01 la) __._________._.--....... -..-.- .-.__.__ s 420.00 5 5,250.00 s 10,088.00 Major (5 to jo) ........................................ Major (51 or more) ................................... PLAXNED DEVELOPMENT OR CONDOMIXILM Minor (4 or less)-------------------------------------- s 420.00 Major (5 to 50) ........................................ Major (51 or more) ................................... s10.500.00 s 3.680.00 PLANKED DEV'ELOPMENT AME;VDMENT/REVISION FOR NON-RESIDENTIAL Minor (4 or less) ...................................... Major (5 to jo) ........................................ S 2.599.00 Major (51 or more) ................................... S 530.00 S 5.250.00 PLANNED DEVELOPMENTiCONDOMINIGM REVISION Minor (4 or less) ____________________------------------ Major (5 to 50) ........................................ $ 1,&u).00 Major (51 or more) ____________________--------------- S 5,250.00 s 210.00 PLANNED DEVELOPMENT FINAL MAP Minor (4 or less) ____________________------------------ s 20.00 Major (5 to 50) ........................................ s 60.00 Major (51 or more) ................................... s 60.00 APPL1CATrON:~EQvIRE~E~ - FEE PLANNED I.?JDUSmIAL PERMIT----- ---_______________ S 530.00 Amendment----------------------------------------------------- s 375.00 PLXVNING COMMISSION DETERMINATION Single Family ________________________________________-- Other _____________-__________________________---~-~------ s 210.0 s 790.00 POSTAGE PRECISE DEVELOPMENT PLAN------------------------ S 1.580.00 Amendment __________._____________________________---~----~--~- s1.ooo.00 PRELIMINARY PLAN REVIEW .......................... S 110.MlRevit.w PUBLIC FACILITIES FEE (See Page 19)---------------- 3.5% of Building Value PUBLIC FACILITIES FEE AGREEMENT--------------- s . 40.00 QUITCLAM OF EASEMENT------------------------------ s 260.00 RECORDING FEES REDEVELOPMENT PERMIT Minor ______-_________________________________------~--~-- Major ______-_________________________________------------ s 110.00 51,310.00 s 75.00 S 750.00 Amendment Minor ________________________________________------------ Major _-______________________________________------------ RESEARCH TIME Engineering (By written request to City Engineer)--$ 1Or i ‘HOUR Planning (By written request to Planning Director)--S LC1 HOUR Building (By written request to Building Officer)-----$ 1C4 . *):HOUR REVERSION TO ACREAGE------------------------------- $ 250.00 RIGHT-OF-WAY PERMIT (single family pool, spa, etc.)----------------------- $ 30.00 s 80.00 SATELLITE ANTENNA PERMIT FEE----------------- $ 30.00 All others ________________________________________------- SCHOOL FEE (See Pages 21 and 22) Residential -I_____________-____------------------------- $1.58 per Sq. Ft. &mmercia~nd~trial_--_-_-___--_- -- ____-________-- -$ .26 per Sq. Ft. SEWER BENEFIT AREA FEES (See Page 26) SEWER LATERAL CHARGES - Carlsbad Sewer District (See Page 14) I I 1 I 1 1 I 1 1 I 4 I I 1 I I I 1 I APPLICATIONREQUIREMENT - FEE SEWER PERMIT - Carlsbad Sewer District------------- 51.250.00 Per E.D.C. Effective 2-22-91 ...................................... S1.610.00 Per E.D.U. Commercial & Industrial Development Effective 3-25-91 - Residential Development SIGN PERMIT--------------------------------------------------S 30.00 SIGN PROGmM ________________________________________------ s 160.00 SITE DEVELOPMENT PLAN Minor ________________________________________------------ S2.630.00 Major ________________________________________------------ S5,250.00 SITE DEVELOPMENT PLAN REVISION Minor ________________________________________------------ S 420.00 Major---------------------------------------------------- S 1.050.00 SPECIAL USE PER,MIT-------------------------------------- s 260.00 Amendment----------------------------------------------------- s 200.00 SPECIAL USE PERMIT FLOOD PLAIN---------------- S 1,050.00 Amendment ________________________________________------------- S 750.00 SPECIFIC PLAN Less than 5 acra ................................... --- S 1.580.00 5 (0 25 acres ________________________________________---- S 5,250.00 More than 2 acrm ___________________________________ s 12.600.00 SPECIFIC PLAN AMENDMENT Minor ________________________________________------------ !$ 1,580.00 Major ________________________________________----------- - s 5,780.00 STREET LIGHT ENERGIZING FEE (See Page 13) STREET NAME CHANGE---------------------------------- !$ 110.00 STREET SIGN DEPOSIT------------------------------------$ 19.00 TO $129.00 STREET VACATION (By Citizen Request)------------- $ 530.00 STRUCTURE RELOCAnON------------------------------S 160.00 TEMPORARY DEPOSIT ACCOUNT TENTATIVE PARCEL MAP (Minor Subdivision)-----$ 1,580.00 TENTATIVE PARCEL MAP 1-YEAR EXTENSIONS 424.00 APPLICATION/REQUIREMENT FEE TENTATIVE TRACT MAP (Major Subdivision) 1 - 25 Units or Lou .................................. S1,050.00 26 - 100 Units or Lo& ............................... 52,630.00 101 or more L'nits or b& .......................... s4,200.00 ENTATIVY TRACT MAP 1-YEAR EXTENSION--l:? of Original Fee TENTATIVE lRACT W LITIGATION STAY-----l.'J of Original Ft'e TENTATIVE MAP REVISION 1 - 25 units or Lo& .................................. S 1,050.00 26 - 100 L'nits or Lots ............................... S1.310.00 101 or more Units or b& .......................... s2,100.00 TRAFFIC IMPACT FEE (See Page 23) VARIANCE Single Family ________________________________________--- s 260.00 Other ________________________________________------------- 5 530.00 WATER SERVICE CONNECTION FEE (See Page 25) (Carisbad Municipal Water District)---------------------- %1,713.00E.D.U. ZONE CHANGE 5 acra 01 &s ........................................ - s 260.00 5.1 to 25 acre5 ......................................... s 790.00 25.1 acre5 or more ____________________________________ %1,970.00 ZONE CODE ~ENDMENT---_--------------------------s~,~~~.~~ I I I I I I I I I I 1 I 1 1 I I 1 1 1 IMPROVEMENT & LANDSCAPE PLAN CHECK PLAV CHECK FEES ARE BASED ON THE CURRENT CITY OF SAN DIEGO UNIT PRICES. THIS [y( THE COST OF CURBS, GUTTERS, SIDEWALKS, ASPHALT OR CONCRETE PAVING, STORM DRAIN ESTIXIATED COST OF IMPROVEMENTS FEE s -0- to s 20,000 S 20.OOO to S 50,000 S 50,OOO to S 100,000 S 100.000 to S 250,000 S 250,000 to S 500,000 s 500,000 to s 1,ooo,000 Over S1.0oO.OOO 6.0% (S 200 minimum) 5.0% (S 1,200 minimum) 4.0% (S 2,500 minimum) 2.75% (S 8,750 minimum) 2.25% (S 13,750 minimum) 3.5% (5 4,000 minimum) 1.50% (S 22,500 minimum) IMPROVEMENT & LANDSCAPE INSPECTION FEE ESTIMATED COST OF IMPROVEMENTS FEE 5 -0- to s 250,000 S 250,001 to S 750,000 S 750,001 to $ 2,000,000 5 2,000,001 to $ 5,000,000 S 5,OOO,001 and over 5.0% (3 250 minimum 4.0% (S 33.750 minimum 3.0% (S 175,000 minimum 4.5% (S 12,500 minimum 3.5% ($ 80,000 minimum STREET LIGHT ENERGIZING FEE WATTS 70 100 150 200 LUMENS 3,600 9500 16,000 22,000 FEE S 85.00 $ 115.00 s 160.00 $ 175.00 ABOVE FEES ARE THE COST FOR ENERGIZING EACH STREET LIGHT FOR EIGHTEEN MONTI- DRAINAGE FEES PER GROSS ACRE (SEE NEXT PAGE FOR MASTER DRAINAGE PLAN AREA NUMBERS) AREA - FEE #1 s -0- #:! s -0- #3 s3,808 #4 51,686 #5 S2,658 #6 s 200 #7 52,273 #8 $ -0- #9 $2,878 # 10 $1,1% #11 S 1,630 # 12 $4,445 # 13 $2,858 SEWER LATERAL CHARGES 1" Line - 30 feet long, 10 feet deep-----$720.00 6" Line - 30 feet long, 10 feet deep-----%850.00 Over 10 feet deep - ADD $7.50 per foot Over 30 feet long - ADD $1250 per foot ACCOUNT NUMBER """ - - - - - - - 350-810-18-70-8740 350-810-18-71-8740 350-810-18-72-8710 350-810-18-73-8740 350-810- 18-74-8740 """_ 350-810-18-75-8750 350-810-18-76-8740 350-810-18-77-8740 350-810-18-78-8740 350-810-18-79-8740 1 I I I I 1 I 1 I I I I 1 1 I 1 I I I GRADING PIAN CHECK FEES AVOUNT FEE 1(x) Cubic Yards or [ss ____-______---__________________________---------------------------- 's 100.00 1(]1 [O l,m Cubic Yards ________________________________________-------------------------- S 500.00 for the first 100 cubic yard s80.00 for each additional 100 cubic fraction thereof. $1,300.00 for the first loo0 cubic y $80.00 for each additional loo0 cu or fraction thereof. 1.001 to 10,m Cubic Yards ________________________________________---------------------- 10,001 to 100,)OO Cubic Yards ________________________________________------------------- %2,100.00 for the first 10,OOO cubic ) $80.00 for each additional 10,ooO CL or fraction thereof. 1m,m1 to 200,000 Cubic Yards ________________________________________----------------- $2,900.00 for the first 100,oo0 cu plus $80.00 for each additional 10. yards or fraction thereof. 200,001 Cubic Yards Or more ________________________________________-------------------- $3,700.00 for the first 200,000 cu plus S80.00 for each additional 100, yards or fraction thereof. GRADING PERMIT FEES AMOUNT FEE 1f)O Cubic Yards or la ________________________________________------------------_-_------- $25.00 101 to 1,m Cubic Yards ________________________________________----------------_------- $ 75.00 for the first 100 cubic J $10.00 for each additional 100 cub] fraction thereof. 1,001 to lo,)@) Cubic Yards ____________________---_----------_---_---------------------- $ 175.00 for the first 1,OOO cubic $52.50 for each additional 1,OOO c or fraction thereof. 10,001 to 100,m Cubic Yards ________________________________________----------_------- $ 700.00 for &he first 10,OOO cubic W.00 for each additional 10,OOO c or fraction thereof. 1rn,rn1 to 200,000 Cubic Yards _-_____-___________ - ______- -- "_.. ~~~~~_..~~~_~~~~~~~~~~-- %1,300.00 for the first 100,OOO E plus 3180.00 for each additional 11 yards or fraction thereof. 2)0$01 Cubic Yards or More ________________________________________--_------------_--- S3,100.00 for the first 100,OOO c plus $300.00 for each addition cubic yards or fraction thereof. RESIDENTIAL VALUATION CHART ESTIMATED FEES SINGLE FAMILY DWELLINGS .XXD DC:PLEXES--------------------------- (number of square feet) X S72.00 = MARTMENT HOUSES AND ATTACHED MCLTI-FAMILY UNITS------------------ (number of square feet) x $62.00 = G MAG E- ....................................... (number of square feet) x $18.00 = CARPORT--------------------------------------- (number of square feet) X $13.00 = COVERED PORCH-------------------------- (number of square feet) X S 6.50 = COVERED PATIO---------------------------- (number of square feet) X S 6.50 = BALCONIESISTAIRSDECKS------------- (number of square feet) X S10.50 = RETAINING WALLS------------------------ (number of square feet) X $12.75 = POOLS ...................... (number of square feet) X S26.75 = SPAS (Gunite) .................................. VALUATION S4,700.00--------------------- - - SPAS (PlasticFactory Made)---------------- VALUATION $2,050.00--------------------- - - AIR CONDITIONING----------------------- (number of square feet) x s 2.40 = MOBILE OR MODULAR HOME ON SINGLE-FAMILY LOT (number of square feet) X $18.00 = TOTAL VALUATION PLAN CHECK FEE Building plan check fee is 65% of Building Permit Fee (Phone Development Processing Division at 438-1161 for permit fee) Public Facilities Fee Tax is 35% of building valuation: Total Valuation x .035 = Public Facilities Fee For Commercial and industrial uses please contact the City of Carlsbad Building Department at 438-1161. I I I I I I I I II I I 1 I I I I I I I Sewer Benefit Area Fees 514-810-75-09-8897 ~~~ ~~ I I I I I I II I I I I I 1 I u I I I I i ! APPENDIX C ! 1 ZONING MAP ~ 1 I i I I ! I I I I 1 I I I I 1 I 1 I I I 1 I I I I I I I - *.. I,_" - - - I """ - - -I "a" - - I "- A - _I. "I - - I, "-.- + - .~ ...".~-<- - 3 d I L,/ "I - - s " - F., -I - - /.I "I c_. """ - - - 3 - . " - , LS I "I - z """ 0 ""P =-FA 5 "." e"," E" =-- I """,."".".I."- 1 I I I I I I I I I I I 1. I I I I I I 1 I I 1 I [ APPENDIX D I ~ I I I ~ I i I ~ 1 1 i I I 1 I I i I I I GENERAL PLAN MAP " ". . "om . I . " :, r. "rm i- , -.mum I , -," - I. "mu " , 0 IY" 0-7 - M "1" B "" B" El-- ="" €3- r;l"-. /tl c.s,.L I-U. ..a. I I I I I I I I I 1 I 1 I I I 1 1 I I 1 ~ ! 1 APPENDIX E I ~ ~ 1 ~ i i I ! PUBLIC NOTICE I I I i i 1 I 1 I I I 1 I I I I I I I 1 I I 1 I I I 1 I 1 I 1 I NOTICE OF COMMUNH" MEETIT i HOUSING ELEMENT mws1or 1 I *i?lc Ci1.v 01' Ccii'l~b;~~l is ~cilc~[ll~li~l~ c1 scrics 01 cc!llllIl\l1~lt;~* 1llcc.iiIlqs tu I.C(.C%I\ Cun~rn~nts trin~ Cx-lsbaci CitizcIls O\.CI- l-fousirlg I-CI~C~YI ~ssut's. rille Cith. is currcntl~~ w\:isiIlc tllc Iiousi~lc Lhwnt ou tllc Cmnl 1'1~1. :\ L) i 1 ;,.,llictl [vi11 be available tor re\'ie\v L~L tllc begillrlirlg ut' t11cl ~C:LI*. legislation. CLtrlsl,ac~'s I-IoLlsiIlc Ilt.t;dt; ;Is cietcrlllirlccl ~jy [11c ~t2xt.c. :lrltl to rc.c%c>i\.(x ' The purpose of the Irleetings is to irlforrrl tllc' c'o~llrl1clIlit>- ol rcxc,cIlt I ILI\I~~I\~ (.or1irllerlts Il-0111 tile corrtlllurlit>~ 011 i IoLlsiIlq issllcs ul'cor~~~~~r~. I-ol~r (4) nlectings are scllctlLll(:(l arltl I~~cl11bcr-s oi' tilt: i)Ll\)lic ;II-(' ILTI(Y)II~~ tc ' ;Ill\- 01- :Ill 01' \tlCIll. i -rl. Lt5t 3. , meetings are schcdulccl lor: SOUTHEAST 9UADRANT: NORTHEAST QU.4DRNY1 Stagecoach Park. Monday. Oct. 29 ;it ipm Caiavera f Iills 1)ark. Montf;l~.. Xov. SOUTHWEST 9UADRANT: NORTHWEST GJUADRNV' SaI'cty Ccr1rc.r. l\~'cclIlcstia\.-. Oct. 24 :It 7p111 Cou1lcil Ct~all~l)(~rs. Mo~~(lah.. NoL.. Siloul~l ~OIJ wish additional informrttion plcase call Tom E'onslortl irl thr: Plannix , Cepartrnent at 438- 1 161. extension 4449. I.'".:. . " 11 L( \g; 11 ' :j2.- . 2.1 0ctoi)c.r 19. 19X) I I 1 I I I I I 1 I I I I I I I c I i I I i ~ I 1 1 APPENDIX F HOUSING ASSISTANCE PLAh I I ~ I ~ I I I ~ i I I I I I I I " Lb U.S. Deputmm of wng and urban Dev- Los ,bg&es Area Ofb, Reglon IX 1615 West mpc Boulevard Los Angeles. Califomla 90015--3801 December 12, 1988 '^ L? , /" ). ?- . q '/, "e. -1, '. I.. , . " ', . 1 Mr. Raymond R. Patchett City Manager City of Carlsbad ATTENTION: Patty Cratty 1200 Elm Avenue Carlsbad, CA 92008 QEC ', ; ,I ;;.,a Dear Mr. Patchett: SUBJECT: Community Development Block Grant (CDBG) Program Three Year Housing Assistance Plan (HAP) Approval Grant Number: B-89/91-MC-06-0563 City of Carlsbad In accordance with the CDBG regulations at 24 CFR 570.306, the HUD Los Angeles Office has reviewed your locality's Three Year Housing Assistance Plan for the period of October 1, 1988 through September 30, 1991. Based on our review, we find your HAP to be acceptable and it is therefore approved. We have enclosed copies of the HUD approved forms (HUD-7091.1, 7091.2, and narratives) which constitute the official HA? documents, unless amended in accordance with 24 CFR 570.306( f) and (9). Accomplishments toward your HAP goals will be reviewed annually. Sincerely , c wu Benjamin . Bobo, Ph.D. Manager B Los Angeles Office, 9.4s Enclosure I I I I I I I 1 1 I I 8 I I I I I I I i NT PROGRAM TABLE I - HOUSING STOCK CONDITIONS I 1 TENURE ~ TYPE VACANT , VACANT ! 3CCUPIEO OCCUPIEO STANDARD UNITS i SUBSTANOARO UNITS 1 SUBSTANOARO UNITS SUITAL I I OCCUPtEO UNITS UNITS UNITS ' UNITS UNIT9 j tot.^ i L- Income I l A - I 0 C 0 E F 6 I Owner 66 I 733 A43 10',%-3 6 1 763 j 873 7 1 Renter 10 j 216 ~13 1 13,307 I 473 a 258 TABLE II - RENTAL SUBSIDY NEEDS OF LOWER INCOME HOUSEHOLDS ! ELDERLY LA%€ FAMILY SMALL FAMILY w I I J 8 Very Low lncomr 587 1 1,993 216 9 129 10 other Lowor Income i 283 1.168 Pwant 21.0 % I 71.3 % 7.7 % 1 11 13 I Total. 972 3,585 1387 - 11 TO k Displd 1 -0- 42 424 ETR ! 102 c " " 1 I 14 1 Perant 20 %I 72 96 I a % PART II * THREE YEAR GOAL TABLE I - UNlrSTO BE ASSISTED L GAIII~TATION NEW 1 CONVERSldN 10 -- - M N L CONSTRUCTION I STANDARD UNITS 15 I Owner I 75 ! -0- I 45 15 1 -0- 75 16 1 Renter i 30 15 j -0- (UNITS EXPECTED TO ASSIST LOWER INCOME HOUSEHOLDS) , 17 1 OWMI I 18 j Renter j 75 I -0- i TABLE II - LOWER INCOME HOUSEHOLDS TO R€CEIVE RENTAL SUBSIDIES 1 1 ELOERLY LARGE FAMILY SMALL FAMILY - c 1 Q I R 19 ~ Households to be Auistad 20 , Percent 31) % I 77 961 8 % , 9 370 ! 36 TABLE Ill - GOALS FOR HUD RESOURCES: SUBJECT TO LOCAL REVIEW AND COMMEN' - ELOERLY LARGE FAMILY SMALL FAMILY T u I V 21 1 Households to be Assisted 89 370 j ?h HOUSING TYPE PREFERENCE fMaxirnum Numbor of Units that will be AceegwudJ- REHAB -1 r 445 2 r1 EXISTING - -. ..- 231 c meek this box it the aoplicmt wirhr to review state Housing AgsncyproPoSds wiMin its jufitdicrion. PART 111 - GENERAL LOCATIONS - ' 24 ' Att8ch ma@ idmtifying rhr gwmr8l locatims of propojd arrirtsd houring. I- +-? 17 / 3 L". c a- hl 4 " - LP a34 i- am F x x.d " - U m 43 00 0 N A a4 .nd u WrlL) Urn tq 444 a 4u v ocrl c.n oa aa *+a 6AZad~~ cc w L32 :2SZQ Golmoa a u rlu WQlUU$ e urn >rc uracc a44W QlQ ac sa w+Q Yrn UQ V1WW a aa. rn 4 au Q maOQlOu o o v ma avwawa V Wvr Baa +cy al4 *s a a= QY~~UC ~WUrlWCo 0 dhau rn Y c a4 dm802 D-J U aarn rnC La c I 81 NARRATIVE SECTION ON HOUSING ASSISTANCE NEEDS: I- I 8 I SUBSTANDARD: Any unit which does not meet or exceed the Section 8 Existing Housing Quality Standards or local building codes, whichever are etricter, are considered to be substandard. SUITABLE FOR REHABILITATION: Any substandard unit which can be rehabilitated to a standard condition at a cost which does not exceed the cost of building a new replacement structure. I EXPECTED TO RESIDE (ETR): 1 I I ETR: 568 SOURCE AND METHOD: ETR provided by SanDag 9: Is not and doe8 not expect to be a problem. Ordinance6 governing conversions setting standard6 and procedure6 including living space and off street parking have been approved and adopted by the City. However, to date, no application6 for convererion have been received and/or proceseed, nor ha8 any interest in such conversion been expressed by the owners of such units. 1 I I rnow ANDE INCOME H0-S TO *IZ -: There are no public actions currently acheduled nor none planned that will have the effect of displacing any households in the City of Carlsbad. LOW AND MODERATE INCOME MINORITY HOUSEHOLDS: SUBSTANDARD UNITS:* 1 TOTAL MumInxs BLBCg INDIAN= QTHERSHISP OWNERS 131 4 0 10 29 8 B RENTERS 443 14 0 35 96 2 I I I 1 REQUIRING RENTAL SUBSIDIES: SHALL LARGE ELDERLX FAHILIES FAKILIES TOTAL TOTAL MINORITY HOUSEHOLDS - 3 75 1,072 133 1,580 -0- -0- -0- -0- TO BE DISPLACED: - BLACK HOUSEHOLDS: 11 30 4 45 TO BE DISPLACED: -0- -0- -0- -0- - INDI."N HOUSEHOLDS: 6 18 2 26 TO BE DISPLACED: -0- -0- -0- -0- ASIAN HOUSEHOLDS: 73 211 26 310 TO BE DISPLACED: -0- -0- -0- -0- OTHERS : 53 151 19 223 TO BE DISPLACED: -0- -0- -0- -0- HISPANIC HOUSEHOLDS: 232 662 82 976 TO BE DISPLACED: -0- -0- -0- -0- * -- See page 7 - SanDag Methodology ** - See page 8 - SanDag Methodology LOW AND MODERATE INCOME HANDICAPPED HOUSHldLDS: ELDERLY 1 PERSON SHALL LARGE - NON-ELDERLY FAMILIES FAHILIES IDW AND MODERAW INCOXE HOUSEHOLDS WHICH CONTAIN AT LEAST ONE HANDICAPPED PERSON: 906 359 3,016 741 SPECIAL NEEDS: Handicapped households need housing units with access ramps, wider doorways, assist bars in the bathrooms, lower cabinets, and elevators (in two or more story buildings) SING= INDMDUALIS WITH DEPENDENT CHILDREN: Female headed households in 1980, No .pous% Present, vith children leu than 18 years of age: 1,149 Households No .pourre Present, with children less than 18 years of Age: 369 Households Male haadad households in 1980, SPECIAL HOUSING NEEDS: Single individual's with dependent children need housing which is both affordable and located close to day care centers and schools. A higher than normal percentage of these households are low and moderate 2 I I I I I M I I I I 1 I I 8 I I 1 1 i inColUU. Alf30, a higher than normal Percentage of these houeeholde are payins more than 30 percent of their incomes for rent. OTHER SPBCIAL HOUSING NE8bS 68 LOW AND MODBRATI INCOMI HOUSEHOLDS: - - Owners are faced with the problems of rieing space rents and conversion of their mobilehome parka into new commercial and residential developments. Programs continue to be needed that help preserve mobilehomes as a source of affordable housing and assist residents convert to resident ownership. "No other epecial housing need8 of low and moderate income houeeholds exist in our city". METHODOLOGY: A copy of the methodology used to derive the figures on the HAP is on file in the Community Development files. However, there is attached a copy of SanDag's Methodology for the above computations which is the baeis of data included in the HAP. STANDARD UNITS WHICH WILL BE DEMOLISHED THROUGH FEDERAL, STATE OR LOCAL ACTIONS: OWNER UNITS: None RENTER UNITS: None SPECIFIC ACTIONS THE COMMUNITY WILL TAKE TO MINIMIZE DISPLACEMENT OF LOW INCOME HOUSEHOLDS: The City's condominium conversion ordinance setting standarde and procedures has not resulted in the loss of any rental unit available to low income households. No conversions have occurred, nor are any planned. The city is prepared to evaluate and consider actions necessary to maintain its low income rental housing stock at such time as conversions tendl to reduce low income rental units. The city will not widen streets and/or remove house8 in low available. The city will not undertake any CDBG activities which will result in the displacement of low income households. income area# unlese affordable replacement houeing i8 3 SPECIFIC ACTIONS THE COMHUNITY TAKE TO MINIMIZE DISPLAC~M~NT OF MODERATB INCOME HOUSEHOLDS: The city'u condominium conversione ordinance setting etandards and prOCedur88 has not reeulted in the lose of any rental units available to moderate income households. No conversions have occurred nor are any planned. The City is prepared to evaluate and consider action6 necessary to conversion trend to reduce moderate income housing stock. The city will not widen street6 and remove houses in moderate income areas unless affordable replacement housing is available. The city will not undertake any CDBG activities which will result in the displacement of moderate income households. SPECIFIC ACTIONS THE COMMUNITY WILL TAKE TO PRESERVE OR maintain it0 moderate income houeing etock at such time at3 EXPAND THE AVAILABILITY OF HOUSING FOR LOW-INCOME PERSONS: Bedevel-t Set Anide Funding - Redevelopment Agencies are required to "set-aside" 20% of their tax increment for lower income housing purposee. The city has and will continue to use the "set-aside" funds in a manner consistent with State law and in such a way as to assist the city's housing for low income residents o the city. Continue to implement the Coaetal replacement housing and inclusionary housing requirements of the Government Code Section 65590. Where appropriate the city will offer density bonusee or other financial incentives pursuant to Government Code Section 65915. The City will not uae CDBG funds to demolish houeing occupied by low income households unless replacement housing is provided. The City will continue to use CDBG funds (including program income) to rehabilitate housing for low income households. The City will act ae an information source and liaison for private developera interested in using Low Income Housing Tax Credits to develop affordable housing projects. The City will pursue the development of affordable housing , for low income households through available funding resources. 4 1 I' I 1 I I I I I I I 1 1 I I I 1 I I SPECIFIC ACTIONS THE COMMUNITY WILL TAKE TO PRESERVE OR EXPAND THE AVAILABILITY OF HOUSING FOR MODERATE INCOME PRRSONS : Continue to implement the Coastal replacement housing inclueionary housing requirements of Government Code Section 65590. Where appropriate the city will offer density bonusee or other incentives pursuant to Government Code Section 65915. The city will not use CDBG funds to dernolieh housing occupied by moderate income households unleee replacement housing is provided 1 The city will continue to use CDBG fund8 (including program income) to rehabilitate housing for moderate income households. The city will act a5 an information source and liaison for private developers interested in using Low Income Housing Tax Credits to develop affordable housing projects. The city will pursue the development of affordable housing for moderate income households through available funding resources. velow Set Wde Fm- Redevelopment Agenciee are required to "set-aside' 20% of their tax increment for lower income housing purposes. The city hae and will continue to use the "set-aeide" funda in a manner consistent with State Law and in as such way as to assist the moderate income resident8 of the city. SPECIBIC ACTIONS THE COHIMUNITY WILL UNDERTARE TO IMPLEMENT ITS THREE GOALS: The city will provide fast track proceesing for housing proposals which will provide affordable housing for low and moderate income households. The city shall cont.inue to administer its Section 8 and voucher aaei~ted houefng program. The city shall apply for the Section 8 Exieting Certificates and Vouchers which will become available during the three year period. Zoning changes to help implement the production of housing for low and moderate income households will be considered on a case by case basie. The city will continue to administer a variety of housing 5 rehabilitation programs for low and moderate income households. EXPBCTBO OR PLANNED REMEDIES: PROBLEM: Lack of vacant land suitable for new construction. REMEDY: The city where appropriate write down land with CDBG funds and/or available resources to make the purchase and clearing of sites economically feasible. Such other incentives, as may be appropriate and within the City’s authority to offer will be tended to developers if the propoeed development includes a percentage of percentage of low/moderate units. REHABILITATION - MAJORITY BENEFIT TO LOW AND MODERATE INCOME HOUSEHOLDS ASSURANCE: 1, OWNER OCCUPIED UNITS: The city will require owners applying for rehabilitation or home improvement loans/grants to complete a loan/grant application which will require the owner to indicate his/her gross income. The owner will also be required.to submit a signed copy of hie/her lateet federal tax return and his/her lateet pay receipt. The incomes will be checked against the latest HUD Section 8 income limits. The city‘s rehabilitation program is not limited to only low/moderate income houeeholde. However, the awarded applications will be monitored to assure that at least a majority of the loans/grant are made to low/moderate income households. 2. RENTAL UNITS: Currently the city’s rehabilitation and home improvement program for rental units is designed to only benefit low and moderate income renters. To assure compliance, the city will require all landlord6 seeking rehabilitation and/or home improvement loans/grants to submit a signed certification that he/ehe has surveyed the incomes of the tenants and that all of the tenants have incomes equal to or lese than the Section 8 Lower Income Limits for the applicable household eize. The city will periodically conduct ita own surveys to assure that the landlord certifications are accurate. HUD’S Rental Rehabilitation Grant Program will be reviewed in the first year of this HAP and within the capacity of the City to administer Section 8 Mod Rehab, Section 312 Rehab, and HUD Rental Rehab Grant Program all three resources shall be utilized. 6 1 I I I I 1 1 I I 1 I I I I I I I I I PART 111, GENERAL LOCATIONS * PRIORITY CPNSUS TRACTS FOR NEW CONSTRUCTfOH! 179 180 PRIORITY CENSUS TRACTS FOR SUBSTANTIAL REHABILITATION. 179 180 CENSUS TRACTS ACCEPTABLE FOR NEW CONSTRUCTION: 171.01 179 178.01 180 178.03 198 178.04 200.03 CENSUS TRACTS ACCEPTABLE OR SUBSTANTIAL REHABILITATION. 171.01 179 178.01 180 178.03 198 178.04 200.03 # THE CENSUS TRACTS LISTED COMPRISE ALL CENSUS TRACTS IN THE CITY OF CARLSBAD. A map of all censue tracte in the City including the number of occupante nd median income for each tract is attached. 7 PART IV. ANNUAL GOAL NARRATIVE: SPECIFIC ACTIONS THE COMMUNITY WILL TAKE TO MININIZE DISPLACEMENT OR LOW INCOME HOUSEHOLDS: The city’s condominium conversion ordinance setting standards and procedures has not resulted in the loss of any unit available to low income households. No convereione have occurred, nor are any planned. The city is prepared to evaluate and consider actions necessary to maintain it8 low income rental housing stock beginning with year one of this rental units. The city will not widen any streets and/or removes houses in low income areas unless affordable replacement housing is available. The city will not undertake any CDBG activities which will result in the displacement of low income houeeholds. Pursuant to Government Code Section 65590, the city will not approve the demolition or conversion of residential unite located in the Coastal Zone occupied by low income households, unless appropriate replacement housing will be provided. SPECIFIC ACTIONS THE COMMUNITY WILL TAKB TO MINIMIZE DISPLACEMENT OF MODERATE INCOME HOUSEHOLDS: The City’s condominium conversion ordinance setting standards and procedures has not resulted in the loss of any units available to low income households. No conversions have occurred, nor are any planned. The city is prepared to evaluate and consider actions necessary to maintain its low income rental housing stock beginning with year one of this HAP if, in fact, conversions would tend to reduce moderate income rental unite. The City will not widen any etreeta during the first incremental year. The City will not undertake any CDBG activities which will result in the displacement of moderate income households. Pursuant to Government Code Section 65590, the City will not approve the demolition or conversion of residential units located in the Coastal Zone occupied by moderate income hausehdda, unleglgl apprapriate replacement housing will be provided. HAP if, in fact, conversion8 would tend to reduce low income 8 I I I I 1 I I 1 I I I I 1 1 I 1 I I I SPECIFIC ACTIONS THE COMMUNITY WILL TARE TO PRESERVE OR EXPAND THE AVAILABILITY OB HOUSING FOR LOW INCOME PERSONS: The City will not u80 CDBG fund6 to demolish occupied low income hoU6ehold8 unlese replacement housing is provided. Continue to implement the Coastal replacement housing inclusionam housing requirements of Government Code Section 65590. Where appropriate the City uill offer density bonuses or other financial incentives pursuant to Government Code Section 65915. The City will continue to use CDBG funds (including program income) to rehabilitate housing for low income households. nt Asalstance Praum - The City has aesisted and will seek to continue that assistance to permit low income mobilehome residents to convert to resident ownership. JZYW ae HnU TFIX Credits - Since the passage of the 1986 Tax Act, .the State has established a program enabling developers of rental housing receive federal and state tax credits if a portion of the units in their projects are reserved for low and very low income households. As developers gain an understanding on how to beat utilize this new program, it is expected that tax credits will become a viable program. The City will try to tandem the program with other programs and funding sources to provide low income rental housing units. on 8 (-1 / Houelnn Vow - The Section 8 Certificate and Voucher Rental Assistance Payment Programs The City will apply for unit allocations as they are available from HWD. - Ho- - Additional housing for farm workers is needed. The City will investigate, review, and make every attempt to uae any State or Federal fund8 targeted for farm worker houaing. ad8t very low income households with their rental payments t Set - Me FU - Redevelopment Agencies ar required to “S8t-a6ide” 20% of their tax increment for lower income housing purposes. The City has and will continue to use the “set-aside” funds in a manner consistent with State’ Law and in such way as to aseist the low income resident of the City. 9 SPECIFIC ACTIONS THS COMUNITY WILL TAKE TO PRESERVE OR EXPAND THE AVAILABILITY OF HOUSING FOR MODERATE INCOME PERSONS : Continue to implement the Coastal replacement houeing ineluaienary hauefng requiremente of Government Code Section 65590. Where appropriate the City will offer density bonuses or other financial incentives pureuant to Government Code Section 65915. The City will not use CDBG fund8 to demolieh occupied by moderate income households unless replacement housing is provided. The City will continue to use CDBG funds (including program income) to rehabilitate housing for moderate income householde. Jaw Income How- - Since the passage of the 1986 Tax Act, the State has established a program enabling deve.loper8 of rental houeing receive federal and etate tax credits if a portion of the units in their projects are reserved for low and very low income households. As developer6 gain an understanding on how to beet utilize thie new program, it is expected that tax credits will become a viable program. The City will try to tandem the program with either program6 and funding sources to provide low income rental housing units. Farm Worker Ho- - Additional houeing for farm workers is needed. The City will pursue any State or Federal funds targeted for farm worker housing. Ocr-~ P- - The City has aeeieted and will seek to continue that aeeiertance to permit moderate income mobilehome resident6 to convert to resident ownership. Bedevcla-nt Set - Bafde Fw~d&uz - Redevelopment Agencies are required to "set-aside" 20% of their tax increment for lower income housing purposes. The City ha8 and will continue to use the "6st-a8ide" funds in a manner coneistent with State Law and in such way as to assist the moderate income resident of the City. 10 I 1, I I I I 1 I 1 I I I 1 * - - - - 1 - - ~~ SectlQD 8 (m) 1 - V0uc.a - The Section 8 Certificate and Voucher Rental Assistance Payment Programs assist vary low income houeeholde with their rental payments. The City will apply for unit allocations a8 they are available from HOD. SPECIFIC ACTIONS THE COMMUNITY WILL UNDERTAKE TO IMPLEMENT ITS ANNUAL GOALS: The city will provide fast tract proces13ing for housing proposals which will provide affordable housing for low and moderate income houaeholds. Zoning change6 to help implement the production of housing for low and moderate income households will be considered on a case by case basis. The City will continue to administer a variety of hosing rehabilitation programs for low and moderate income households. The City shall continue to administer its Section 8 and Voucher Aseisted Housing Program. The City shall apply for the Section 8’Existing Certificates, the Section 8 Moderate Rehab unite, and the Section 8 Vouchers which will become available during the three year period. REHABILITATION - MAJORITY BENEBIT TO LOW AND MODERATB INCOME HOUSEHOLDS ASSURANCE: 1. OWNER OCCUPIED UNITS I The city will require owners applying for rehabilitation or home improvement loans/grante to complete a loan/grant application which will require the owner to indicate hia/her grose income. The owner will a160 be required to submit a signed copy of his/her latest federal tax return and hie/her latest pay receipt. The incomes will be checked againet the lateat HUD Section E income limite. The city’s rehabilitation is not limited to only low/aoderate income households. However, the awarded applications will be monitored to assure that bl leaet a majority of the loans/grant are made to low/moderate income householde. 2. RENTAL UNITS: Currently the city’s rehabilitation and home improvemen, program for rental units is designed to only benefit 101 and moderate income renters. To a~eure compliance, the city will require all landlords seeking rehabilitation and/or home improvement loane/grants to submit a signed certification that he/she has surveyed the incomes of the tenante and that all of the tenants have incomes 11 equal to or lees than the Section 8 Lower Income Limits for the applicable household size. The city will periodically conduct ita own eurveye to assure that the landlord certifications are accurate. HUD'S Rental Rehabilitation Grant Program will be reviewed in the first year of this HAP and within the capacity of the City to administer Section 8 Mod Rehab, Section 312 Rehab, and HUD Rental Rehab Grant Program all three resources shall be utilized. EXPECTED OR PLANNED IMPEDIMENTS AND PLANNED REMEDIES: PROBLEM: Lack of vacant land suitable for new conetruction. and/or available resources to make the purchase and clearing of sites economically feasible. Such other incentives, as may be appropriate and within the City's authority to offer, will be tended to developers if the propoeed development includes percentage of low/moderate unite. REMEDY: The city will write down land with CDBG fund6 12 I I I I I I I I I f I I I 4 1 I I I I CARLSBADt REVISED HAP (October 1, 1988 throwh September 30, 1991) Methodology for Revisions A. PART 1, TABLE I, HOUSING STVCIS CONDITION STANDARD AND SUBSTANDARD 1) Units = 25,786 (total) (DOF 1988) + (Building Permits) 2) Vacant = 1,312 (DOF 1988) + (Building Permits x Vacancy Rat( 3) Occupied = 24,474 (DOF 1988) (1-2) OwnedRentcr Ratio Census 1988 1980 Renter / Total - = Percent % SF = 1,638 1 a,am = 18.6% 2-4 = 754 / 982 = 76.8% 5+ = 2,464 / 2,961 = 83.2% MH = 65 / 820 - 7,9 % - Bldg. Permits DOF Jan. I-Oct. 1 1988 + - 1988 SF = 14,672 + 272 S+ = 7,124 + 40 MHH = 925 + 25 2-4 = 2,658 + 70 Total Occupied Renter 1988 = Total Occupied Owner 1988 = Ren' 1! " 1980 = Estimate X .186 = 2 X .na = 2 X A32 = 5 X .079 = - 1I 10,909 13,565 (24,474-10 4) Vacancy Rate = 5.09% (1988 DOF) Vacant for Sale 1980 - 329 Vnant tar Rent 1980 = - + 565 - 894 Total Vacant 1980 *The proportions of the housing stock that are substandard are not inconsistl local housing authorities' information regarding housing units that do not me building/housing codes. These local codes meet or exceed the Housing Quality 5 (HQS). Thus, the substandard unit totals would exceed the total for units not HQS requirements. In addition, this definition of substandard was used 1 regionwide consistency and compatibility of the Housing Assistance Plan condition assessment with the "fair share" planning program as well as loCa elements. 1 % Vacant We = 329 / 894 = 38.8% % VICUlt Rant = 565 / 894 = 63.2% 1,312 x .368 = 483 Total Owner Vacant 1988 Eat. 1,312 x A32 = 829 Total Renter Vacant 1988 Est. 5) 9,713 Owner Occupied Standard (1985 HAP) + 186 Owner Occupied Substandard (1985 HAP) 9,899 Total Owner Occupied (198s) Standard Owner 9,713 / 9,899 = Percent 1985 = 98.1% Total Owner Occupied (1988) = 13,565 (Step 3) 6A = 13,307 .981 X 13,565 f 13,307 Owner OCCUpiCd st.ndud (1988 HAP) 6) 5,173 Renter Occupied Standard (1985 HAP) - + 450 Renter Occupied Substandard (1985 HAP) 5,623 . 5,173/ 5,623 = Standard Renter Percent 1985 = 92.0% Total Renter Occupied (1988 mP) = 10,909 (Step 3) 7A = 10,036 ,920 x 10,909 = 10,036 Renter Occupied standard (1988 m) 7) 13,565 Step 3 - Total Owner Occupied (1988) -13,307 Step 5 - Owner Occupied Standard (1988) 6C = 258 258 Owner Occupied Substandard (1988 HAP) 8) 10,909 Step 3 - Total Renter Occupied (1988) 7C = 873 -10,036 Step 6 - Renter Occupied Standard (1988) 873 Renter Occupied subtandard (1988 HAP) 9) 672 Owner Vacant Standard (1985) - + 14 Owner Vacant Substandard (1985) 686 Total Owner Vacant 1985 6721689 = 98.0% = Standard Owner Vacant Percent Total Owner Vacant 1988 = 483 60 = 473 483 x .980 = 473 Standard Owner Vacant (1988 UP) 2 I I ., I 6D=10 10) 483 Step 4 -473 - Step 9 10 Wmtmdad her Vacant (1988 HAP) I I 11) 466 Renter Vacant Standard (1985 HAP) + 41 Renter Vacant Substandard (1985 HAP) 507 Total Renter Vacant (1985) - 466 / 507 = Standard Renter Vacant Percent = 92.0% I Total Renter Vacant 1988 = 829 7B = 763 829 x .921 = 763 Standard Renter Vacant (1988 HAP) I I I I I I I l I I I I I 70 = 6% 12) 13) 829 Step 4 - -763 Step 11 66 wmdard Renter Vacant (1988 W) 156 (::$ 1985 / 186 (l&$ ,839 SUBSPANDARD UNITS SUITABLE FOR REHABILPTATION Substandard units are "suitable for rehabilitation" if they are: 1. Structurally sound (based upon proportion of deteriorating to dilapidated and i original construction); and 2. Economically feasible for rehabilitation (based upon housing rehabilitatior experiences which are not inconsistent with the total identified. In addition, the definition of suitable for rehabilitation was used to insure r consistency and compatibility of the Housing Assistance Plan housing condition a with the "fair share" planning program as well as laad homing element$ .839 X 258 (6C 1988 HAP) = 216 Total Owner Occupied Substandard { 6E = 216 14) 378 ($'$, 450 ti;) = .a40 .840 x 873 (7C 1988 HAP) = 733 Total Renter Occupied SubatanQrd (1988 7E = 733 15) 23 (I&) 1 156 (1%) = ,147 HAP HAP 3 J47 ;r 116 (IE 1988 HAP) = 32 Owner busr [ncoma cwuptcd Subrt.ndud (1988 HAP) 6F = 32 16) 121 (l$) ,378 (l$:) = ,320 .320 X 733 (?E 1988 HAP) = 235 Renter Lower Income Occupied Substandard (1988 UP) 7F = 235 17) 12 tfP) 1985 / 14 (1%) HAP = ,857 .857 X 10 (6D 1988 HAP) = 9 Omcr Vacant Substandard (1988 FlAP) 6G = 9 18) 34 ' ( 1985 7G) 141 (l%) = ,829 HAP HAP 329 x 66 (7D 1988 HAP) = 55 Rente Vacant Zfub6tU"d (1988 HAP) 7G = 55 B. PART 1, TABLE II, RENTAL SUBSIDY NEEDS 1,304 (8K 1985 HAP) +737 (10K 1985 HAP) 2,041 Total RSNLIH 2,041 / 5,623 (?A + 7C 1985 HAP) = ,363 2) .363 x 32.6 (1986 SP): SRA 41 (Percent Lower Income Households) 27.1 (1980 SP) -313 X 1-26 = -438 (1988 % Rentm RSNLIH) 3) .436 (Step 2) x 10,036 (7A 1988 HAP) = 4,376 1988 Renters - RSNLIH 4) 737 (10K I985 HAP) + 1,304 (8K 1985 HAP) = 2,041 1985 Renten - RSNLIH 1,304 / 2,041 = .639 5) .639 x 4,378 (Step 3) = 2,796 Total Very Lou Income (1988 HAP) 8K = 2,796 'RSNLIH = Rental Sub;idy Need of Lower Income Households. ' 2SP = SourccPoint, 1986 Household Income Report. 4 1 I ... I I I I I I I I I I I I I I I I I 8) 4,376 (Step 3) -2,796 (Step 5) 1,580 TOW Other Lower Lncoma (1988 HAP) IOK = 1,380 7) 65-75+ 1980 = 17.6% (CPC) 19.3% (9H 1985 HAP) X 18.8% zi.o% 1987 = 18.8% (CPC) " 17.6% - Percent Elderly Very Lou Income (1984 9H : 21.0% 8) 100.0% - 21.0% = 79.0% Split 79.0 in same portion SF/LF 1984 72.9% / 00.7% = 90.3% 91 = 71.3% 79.0% X 90.3% = 71.3% SF Pcmnt Small Family Very Lou Income (1984 9J = 7.7% 79.0% - 71.3% = 7.7% LF Percent Large Family Very tow Income (1988 Step 5 Step 7 8H = 587 9) 8K X 9H 2,796 X .210 = 587 Elderly Very Low Income (1988 HAP Step 5 Step 8 10) aK X 91 81 = 1,993 2,796 X .713 = 1,993 Small Family Vuy Low Income (198 11) Step 5 - (Step 9 + Step IO) 85 : 216 88 - (8H + 81) = 85 2,796 - (587 + 1,393) = 216 Large Family Very ~aw trcamc (141 10H 1OK 12) '1.07 (Step 7) x 16.7 (123 / 737 1985 HAP) 1.07 x .167 = .I79 13) 100.0% - 17.9% = 82.1% (1984) 75.0% / 83.3% = .900 82.1% x 90.0% = 73.9% (SF) 8.2% (LF) IOH = 283 141 1.580 X .m = 283 Elderiy Other tower Income (1988 HAP) 101 = 1,168 1,sao X .739 = 1,168 SmaU Family Other Lower Income (1988 H 1OJ = 129 1,580 x .OS2 = 129 Laqe Family Other Lower Income (1988 E 15) ETR unchanged 16) Displaccts to be added by city 5 .. REVISED NARRATIYB UNSOUND EiOIJmG BY UCB A-1) Total lower income minority in unsound housing = .138 (1985 HAP (Step A-2) 13.5% x 10.8% (1987 total minority CPC)* 8.8% (1980 total minority) = 16.6% (1988 HAP) A-2) Update Minority Distribution 1980 1987 - - Black Indian Asian Others 4.8 4.9 4.0 5.9 - 8.8 - 10.8 Hispanic 10.4 12.4 A-3) Use CPC to adjust substandard by race .166 x 258 (8C 1988 HAP) = 43 Minorities in Owner Substandard (1988 .166 x 873 (7C 1988 HAP) = 145 Minorities in Renter Substandard (1988 A-4) Adjust distribution by race using CPC for Indian, Asian, & Others - Use 1988 HAP (A-1) percent (16.5%) as control total. - Assume Indian and Othcn relatively unchanged - Assume percent change in othen (CPC) due to Asian increase 1985 HAP 5 1988 CPC - = 1988 HAP Percents Black 1.6 x 4.9(Step A-2) - 1.6 - 4.8 (1980) Indian 0.0 x No Change - 0.0 - Asian 2.7 x 5.9 (Step A-2) - 4.0 - 4.0 (1980) Other 9.8 X. Balance - 11.0 Total 13.5% 16.6% - - I *CPC = California Population Characteristics (Center for Continuing Study of the ~~ California Economy, 1988) 6 I I .* I: I I 1 I I I I I I I I I I I I I A-5) Dbtrfbuta minority among owner/rcnter unsound howing control tot& 1988 Step A4 Owner - - Renter Black (1.6 / 16.6 = 9.6%) 4 (9.6% x 43) 14 (9.6% x 145) Indian (0.0 / 16.6 = 0.0%) 0 (0.0% x 43) 0 (0.0% x 145) Asian (4.0 / 16.6 = 24.1%) 10 (24.1% x 43) 35 (24.1% x 145 Others (11.0 / 16.6 = 66.3%) __ 29 (66.3% x 43) 3 (66.3% x 141 Total 43 (Step A-3) 145 (Step A-3) A-6) Hispanic 1980 Distribution (1980 Census) 1988 Distribution (CPC) 10.4 12.4 12.4 / 10.4 =1.19 (Control Total) A-7) From 1985 HAP (Step C) 28.7% Hispanic occupied unsound ho' adjusting tor Hispanic growth 28.1 f 1.19 (Step A-6) = 34.1% (1988 HAP) A-8) 258 (6C 1988 HAP) x .341 = 88 Hispanic owners unsound housing (1988 873 (7C 1988 HAP) x .341 = 298 Hispanic rcntcn unsound housing (198 tOWER INCOME OVERPAYERS BY RACE A-1) Proportion minorities overpayers = .112 (1985 HAP, Step E) A-2) Increase in minorities as a whole 16.6 (1988 HAP) / 13.5 (1985 HAP S A-3) .112 (A-1) x 1.23 (A-2) = 13.8% minorities overpayers 1988 A-4) Adjust distribution by minority categories 1980 Census 1988 CPC 1980 Census 1988 H % Of All Minorities x - 96 of Househoids 5 % of a1 M' Black 7.3% X 4.9 - 7.5 - - 4.8 Indian 4.3% X No change - 4.: -Asian 34.8% X 5.9 - 51.: - - - 4.0 Others 53.696 X Balance - - - 36.' 100.0% 100. 7 A-5) 8K = 2,796 (1988 HAP) log = +1,580 (1988 HAP) 4,376 Total RSNLIH (1988 HAP) A-6) 4,376 x .138 (Step A-3) = 604 Lower income minority households with rental subsidy need 1988 A-7) Distribute by minority categories using control total and total percent from (Step A-4) and apply 1985 HAP Step F-1 to control totals; Le., for blacks .075 x 604 (Step A-6, above) = 45 which is distributed by type. Elderly Small Family Large Family Total - % (Step A-4) Black 11 (24.1) 30 (67.8) 4 (8.1) 45 (7.5%) Indian 6 (23.7) I8 (67.9) 2 (8.4) 26 (4.3%) Asian 73 (23.7) 211 (67.9) 20 (8.4) 310 (51.3%) Others 53 (23.7) 151 (67.9) 19 (8.4) - 223 (36.9%) 604 (Step A-6) A-8) For Hispanic ,187 Hispanic RSNLIH x 12.1 = 1.19 (1984 HAP, Step F-2) 10.4 .187 x 1.19 = .223 (1988 Proportion) - 1988 Total 99 1984 Total tx A-9) ,223 x 4,378 (Step A-5) = 976 Hispanic RSNLIH (1988 HAP) A-10) Hispanic RSNLIH by household type: using 1980 proportions and 1988 Total (Step A-9) Small Large Elderly Family Family - To tal 23.8% 67.8% . 8.4% 976 232 662 82 DISPLACEES (from jurisdictions) HANDICAPPED The data avrflrble from the census for handicapped-related items include responses to are presented by applying 1988/1980 total incrcuc (1.97) to proportions of 1980 total to each factor from 1985 HAP. two disabultp questfern. For the City of Carhbad the following data, revised to 1988, 1980 Total Population 29,964 1988 Figure Total Pooulation (DOF) 58,888 8 I I. n I I I I I I I I I I I. I I 1 I I I A. - B. A. 8. Work Disability With work dbabtlity 1. In trbor force 2. Not in labor force a. Prevented from working b. Not prevented from working No work disability To tal Transportation Disability Age 16-64 With a public transportation disability No public transportation disability With a public transportation disability No public transportation disability Age 65+ 9,086 1,395 2,691 2,043 648 54,943 59,029 699 58,330 1,375 8,449 Although HUD defines handicapped as "capable of independent or group home 1 which does not coincide with the definition of the census, transportation and wor abilities certainly constitute the main ingredients to determine independent living. Although no crosstabulatiow of income, household size, or race with dfsabilftg are able, one could assume that a substantial portion of the handicapped would fall witt Section 8 income limits, especially those households not in the labor force. Furthc could assume a substantid portion of the lower income handicapped would fall in "In need" category. Their housing needs are further compounded by design and lo requirements which uc limited in supply and more expensive, The special ne handicapped households, for example, may require ramps, holding bars, special bat design, lower cabinets, and elevators (in two or more story buildings). 'In Carlsbad the elderly comprise 66.3% to the total disabled from public transpor The balance of 33.7% were small family and 1-e family. Based on conversation and limited information from the Community Service CeF the Disabled (CSCD), and the San Ditgo Regional Center of the State Departn Reghabilitation, the balance appears to be small family concentrated. Thw, an e! was made. It was assumed that positive responses to the two disability questions would be erably overlapped. To avoid double-counting, the 699 persons of age 16-64 transportation disability were omitted from the total. Disabled Work disability 4,086 Transportation disability, age 65+ + 1,375 5,461 Family size dbtribution could be estimated based upon the following assumptic Census defines disability as the presence of a physical, mental, or other heaith C 9 which has Wad 8ix of mom months and which limits or prevents a particular type of activity. Th8 t.cm "health condition" refen to any physical or mental problem which has lasted for six month8 or more. A serious problem with seeing, hearing, or speech would bc considered a health condition, whereas Pfefg'nMCy or 8 temporary health problem such gj a broken bane that is expected to heal normally would not be considere4 a health condition. Categories of work disability status are tu follows: With a work disability. Persons who have a health condition which limits the kind or amount of work or prevents working at a job or business. A person is limited in the kind of work he or she can do if a person has a health condition which restricts his or her choice of jobs. A penon is limited in amount of work if he or she is not able to work at a full time job (35 or more how per week) job or bufncss. Within this category, tabulations are fFcqUently provided on the number of petsons with a work disability who are not in the labor force. Prevented from workinq. Penons not in the labor force who have a health con- dition which prevents working at any job or business. Public transportation disability category is as follows: With a public transportation dfsability. Penom who have a health condition which makes it difficult or impossible to use buses, trains, subways, or other forms of public transportation. Limitations: The disability item was included in the 1980 Census becaw of the need lor local area data on the relative prevalence of work and public transportation disabled penons. The decision to include the item was made even though there wad test evidence that there was likely to be a problem with data reliability. Sgecificaily, an analysis of the 1978 National Content Test, which collected disability information in both an original interview and a subsequent re-interview, showed that the Indexes of inconsistency for responses to the work and public disability questions were in the moderate to high range. Historicai Comparabilityr The 1980 disability item WM concerned only with work dis- ability and did not attempt to identify penow with a public transporatation disability. The 1980 item did not contain clause restricting disability to those resulting from a health condition which hu lasted six or more months; however, it did contain a separater question about the duration of the disability. Family She distribution was estimated as follows: 0 l'ho8e ci8s8ified as having a work disability were assumed to be ages 16-64. The 6S+ age group would be predominantly retired, and would therefore not be classified as work disabled. o According to recent HUD estimates, 11.1% of one penon non-elderl$ house- holds are handicapped. Other small and large families have 11.7% disabled, with 19.7% of these being large family. Digtributing ttm census total by family size according to this preportion and updating fOl 1988 household estimate of: 10 I I. s I I I I I I I 1 I I I I I I I 1 I Elderly = 500 (178s HAPI 13,510 1980 Census Households) x 24,474 (1988 DOF total households' 906 handicapped 1988 One Pcmn = 13,510 lg8 x 24,474 = 359 Handicapped 1988 Small Family = 13,510 1'665 x 24,474 = 3,016 Handicapped 1988 Large Family = - 13,510 409 x 24,474 = 741 Handicapped 1988 Elderly One Person Non-Elderly Small Family Large Fa. 906 359 3,016 741 Grouping the oneypenon households into the elderly category group yieic following 1988 estimate. J Elderly Small Family Larg'e Family 1,265 3,016 741 SINGLE INDIYIDUALS WiTEI DEPENDENT CHILDREN The Census data, revised to 1988, are as follows by applying 1988 prooportforw o households (24,474) vs. 1984 households (16,752 1985 HAP Table 27-1) to 1985 HAP for each category. HOUSEHOLD TYPE AND RACE Total White Black Indian Asian Other Hi .y .-, - 7 - " A- Male Householder, 369 334 1s 0 0 20 No Spouse, with Children E. Female Householder, 1,149 983 25 31 7 104 No Spoum, with Children C. Total A+ B 1,518 1,317 40 31 7 124 The first table provides a profile of the single parent household with children by comparison te all households by race. The following tables provides the percental single parent households with children by race and the percentage of all howei race. 11 PERCENTAGE HOUSEHOLD TYPE OF ALL RACES - White Black Indh Asfan Other Hisoanic 96 of all households 93.3 0.8 0.3 2.1 3.5 8.3 % of sfngle parent with 86.7 2.6 2.0 0.5 8.2 15.8 children me proportions of minority and Hispanic households with single-parent households with children is substantially higher with the proportionS of minority households of all house- holds. The other comparison that would provide some detail regarding race and singIe parent households with children is the percentage of such households as a percent of the households for each race. PERCENTAGE OF HOUSEHOLDS WITH SINGLE PARENTS White Black Indian Asian Other H!spanic - - % of all households of 5.8 20.6 46.7 1.4 14.8 110s each race Again, the proportions for minorities arc substantially higher than non-minority (white). The second table also provides several profiles which should be identiffed. Although no direct income information about single-parent households with children is available, the poverty status of female-headed families is illustrative of the needs of this special group. Fernale-headed families with children form 8.8% of all families. Further, such families form 43.9% of all below-poverty families, but only 12.3% of ail above-poverty families. Thus, one can assume that the proportion of single-parent households with children forms a significant portion of lower-income households "in need." Although no direct measure- ment of this need hsJ ken provided, the above information provides an indication of the magnitude of such needs. Single parent households require special consideratfon and assistance because of their greater need for day cnrc, health cnre, and other facilities. SPECIAL m The following information will present & additional categories of need under this sectfon of the narratives military and student. MU- The military population's influence OR the demand for housing takes two forms (a) the existing service households trying to find housing; and (b) the former (either retirement or non-retirement separations) service households trying to find housing. According to the latest statistics from the Navy Houing Referral Office, 43,899 military families are eligible for housing. Of course, the major con cent ratio^ of military population center around Camp Pendleton (immediately north of Oceanside), Mframar Naval Air Station (north area of the City of SM Diego), and other Navy stations 12 I I ,. I I I I 1 I 1 I I I 1 I I 1 I I I in the Central md South Bay areas of the Cities of San Diego, Coronado, National ( Chul. Wt8, ud Imperial Beach The Department of Defense Housing Survey is compiled in order to determine mil family housing needs, especially in the context of new construction goals. The folio information is a summary of the findings for fIscal year 1990. MILITARY HOUSING SURVEY SAN DIEGO REGION 1. 2. 3. 4. 5. ' 8. 7. 8. 9. Gross military strength Gross Eligibie Housing requirements Voluntarily separated Effective requirements (2-3) Program Iimit (90% of 4) Military Family Housing Non-military Family housing Projected net deficit (4-[6+7]) Projected Programable Deficit (S-[6+71) 108,651 42,352 3,619 38,733 34,860 6,878 25,314 6,541 2,668 The existing military family housing is scattered around the region but several munities have substantial portions of their total housing stock comprised of mi family housing. Student. Student housing is ais0 a cause for concern. Although each studen produce only an individual temporary housing need, the impact upon housing deman of coupse, post-study residence, is critical, especially in the immediate university The University of California at San Diego, for example, provides about 3,600 accc dations on earnpus; more than 6,000 students require off-campus housing in are JoUa and North Shore) that are even more costly than most housing in other parts Diego. UCSD expects, an increased enrollement of 3,000 students over the nexl yea, but does not know whether additional on-camptw units will !?e made availabl Diego State Unvienity, the largest university in the region, has an enrollment of students, but provides housing for only 2,000 students on-campus. The University Diego has about 1,300 ontcrrnpw housing units for its student pogulatfon of jus1 4,000. The smaller universities and colleges in the area also generate similar 1 problems. The same market forces that impact the lower income housing population will in student housing. The high cost of housing, condominium conversions, and student tiom make it difffcdt for students to hd dfsrdable heusing. This infhlence is e: beyond graduation and hu a detrimental impact upon the region's economy. The graduates provide a specislized pi of skilled labor that is vitai to the region; hc the lack of affordable housing often leads to their departure from the rcgion. 13 - *. 3 .* OCEANS~Q~ I I PACIFIC OCSAN * . '. "0. '. - 1987 POPVIATION ey CENSUS TRACTS (#I AND ~~ tg86 QStlMATES OF WOUSEWOCO MEDIAN INCOME ($1' - *HwMd konm im1ud.S all 1%- =reas within each houutwld 50% of tho hourahold8 e8rnrbOVe tho,mrdirn income md * 50% e8rn below tho mrdirn income. 8' - '0 . ,- .I .. *. -sour'r: Syl pS-0 Association of Covrrnrnents - e '., * -a i ,; " ; 9 i:-- I I I I 1 1 I I 1 I I I 1 1 I I I 1 1 ! i I , ~ j , \ I I APPENDIX G ~ I j i I I i DEFINITION OF TERMS I i I ! I ~ I I I ! I I I I i DEFINITION OF TERMS ADEQUATE HOUSING Housing which is structurally sound, weather tight, with adequate cooking and plumbing facilities, heat, light and ventilation; and provides enough rooms for its occupants within the economic means of the household. AFFORDABLE HOUSING The federal standard for affordable housing is that no more than 30 percent of the household income is paid for shelter. CODE ENFORCEMENT City actions implemented to carry out the provisions of the Uniform Housing Code, Uniform Building Code, Zoning Code and other regulations to maintain City standards for proper use and development. COMPREHENSIVE HOMELESS ASSISTANCE PROGRAM State required planning document which assesses and monitors housing and other social services for the homeless. CONDOMINIUM CONVERSIONS A change from the rental or leasing of a residential dwelling to the ownership of the residential unit, e.g. condominium, cooperative or similar form of ownership. DEPARTMENT OF FINANCE State department responsible for population estimates provided to cities each year. Estimates are used for state tax and fee disbursements to the regional and municipal levels. DEPARTMENT OF HOUSING AND COMMUNIM DEVELOPMENT (HCD) State department responsible for preparation of the Statewide Housing Element and Housing Element Guidelines, review of local housing elements, and technical assistance for local jurisdictions. DETERIORATED HOUSING A residmtid unit having one or more major defects contributing to the poor condition of a structure as reflected by lack of adequate repair and maintenance. (See Housing Conditions). DllAPlDATED HOUSING Units which are unsafe for occupancy due to structural or health hazards and cannot be rehabilitated at a reasonable cost, thus needing to be replaced. FAMILY Two or more related people living together in a household (e.g. married couple or adopted person living in a household). I I I I I I I I I I I I 1 I I I 1 1 I FEMALE HEAD OF HOUSEHOLD Household headed by a female with children. GENERAL PLAN Document which addresses land use issues through data analysis, policy and implemen programs which are all consistent with long-range plans the jurisdiction. GROUP QUARTERS A place where ten or more unrelated individuals share common dining room(s) and co entrances: ten or more unrelated individuals not living in a household. HOMELESS Families or persons with no fixed or adequate and clean residence. HOUSING ASSISTANCE PLAN (HAP) A planning document required by the Federal Depanment of Housing and Urban Develo to assess community housing needs and to link local housing activities c'losely in community development and comprehensive planning process. Required of cities utilizini grant funds for housing projects. This document will be replaced by the Compreh Housing Affordability Strategy (CHAS) requirement in 1991. HOUSEHOLDS IN NEED Those lower income households paying over 30 percent of their income for housing. HOUSING ELEMENT Document which consists of identification and analysis of existing and projected housing and a statement of goals and objectives and scheduled programs for preservation, improk and development of housing. HOUSING STOCK CONDITIONS The structural condition of housing within a jurisdiction; condition can be categorized a) sound (good) condition b) suitable for rehabilitation (substandard, deteriorated condition) C) not suitable for rehabilitation--those units which are not structurally sound and the cost of rehabilitation will exceed 90 percent of the projected market valu rehabilitation (dilapidated, deteriorated condition). HOUSING UNIT The place of permanent usual abode of a person or persons in a single family dwellir single unit in a two family dwelling or, a single unit in a multi-family dwelling. a) single family unit - unattached housing unit with open space on ail sides. family units which are attached are categoriz condominiums. b) multi-family unit - housing unit attached to another along sides, floors ceiling. HOUSEHOLD All persons occupying a residential unit. INCOME RANGES Those categories established for the purpose of defining households of low, moderate and upper income. a) Above Moderate Income - above 120 percent of the County median income b) Moderate Income - between 81 percent to 120 percent of the County median income C) Lower Income - less than or equal to 80 percent of the County median income dl Very Low Income - less than or equal to 50 percent of the County median income LARGE FAMILY A family of five or more. 1 1 I I I I I I I I I I I I I I I I I MANUFACTURED HOUSING Housing that is predominately constructed off-site and assembled at the housing site. OVERCROWDING Households which have 1.01 + person per room. REHABILITATION Actions to restore a structure to sound conditions. (See Housing Stock Conditions). REGIONAL HOUSING NEEDS STATEMENT (RHNS) Regional Housing Needs Statement developed by San Diego Association of Governmc (SANDAG) which provides information on current and projected housing needs (1 991 -1 9 for each community in the region. Information includes, but is not limited to, needs by incc category, tenure projections and farmworker needs. SECTION 8 An existing housing program for low and moderate income families and elderly. The pror operates by providing "housing assistance payments" to owners, developers and public hoL agencies to make up the difference between the "Fair Market Rent" of a unit, and the ten: contribution toward the rent (not more than 30 percent of the tenant's income). This exi$ program gives a subsidy to the owner of an existing housing unit wherever an eligible fi rents that unit, SAN DlEGO ASSOCIATION OF GOVERNMENTS (SANDAG) The Council of Governments established by local governments in San Diego County to facil regional planning for the area. SPECIAL NEEDS Assessment of the special needs of such groups as large families, farmworkers, elc handicapped and families with female heads of households. SUBSTANDARD HOUSING Refers to all deteriorated and dilapidated housing. I i I I 1 I I I I I I I I I I I I 1 I j I APPENDIX H COASTAL ZONE EXEMPTION ! , 1 I i j I ~ I I i ! i I I I 1 I I Excerpt from California Public Resources Code 1JtPLE\lEST.\TIOS Ch. b § 303 19.3 S 303 19.1. Cit!. ot Carlsbad: housing for persons and families of {ow or moderate income: issuance of coastal de\.eloprnent permits .v Y':,> -i.-::on -5,ali appi~ IInii 10 those par,ce!s a~d are25 $.\::?i?. ;hc c' :I. ,i Cdr;b:d :or ,,L~IL~, J [oc~i <oa>:ai program has heen ?repa.rctj a.ir,d :c:-:.::i: ?\ !KC Lol:~l~,:~jion ?ti:juant to saCdi\ljlon it) ,)t Sec!:on jO1-O or Se:::,~!~. ;0171. ,I 15) \?\, ?roLisions or Jn!. >uch !occti coas~al program l.\lrh re>prc: :,,I :'orsc or ciiec: ~t~er Januq 1. 1332. After !ha[ date. housing requlrcmni.n:s ig~r :how ?arcs13 2nd areas ,hail be determined pursuant to Section 65530 or [he Go\c.rnnent Code. is! Lntl! such time as. (1) [he City of Carlsbad adopts or enacts the irnpiementlng actions contained In any such loca! coastal program. or (!: 1 other statutor?. prot lslons pro( tde Jiternately for the adoption. certif:catlor2. 2nd implementation of a locai coastal program for those parcels and areas. coastal det.elopment permits for those parcels and areas shall be Issued b!, the ;ommlssion as prot.ided In thls subdivlslon. Notlc-ithstandlng an! other provision of this dit.ls1on. tlle commlssion shall Issue a coastal det.elopment permlt if it finds that a proposed development is in conformity [Lith the sertlfied local coastal program. exciuskve of any provisions tc-ith respect to housing tor persons and families of low or moderate income \vhlch hat.e been rendered in0peratil.e pursuant to subdivision (b). i.4ddtd by Stats.1982. c. 43. p. 120. 5 14.5, cff. Feb. 17. 1981.) ?.OU,IP,~ !or pr;o~!s snd Fm~lvr ot [o~i. or modt3rw Income hi1 !.~1.2 ;.(I Library References Health ;rnd Enslronrnent -15.34). 31. CJ.5 Health and Enrtronmenc $4 ?!I to 36. 52, 91 tt srq.. L30. 132. - REFERRED TO CITY MANAGER FOR RESPONSE William C. Mann 1701 Ocean Street Carlsbad, California92008 November 27, 1991 TO WHOM IT MAY CONCERN: WE THE UNDERSIGNED ARE OPPOSED TO THE BUILDING OF THE SRO’S PROPOSED ON CARLSBAD BLVD. HIGH DENSITY IS NOT APPROPRIATE IN THE BEACH AREA. THE BEACH AREA IS THE MOST EXPENSIVE REAL ESTATE IN CARLSBAD. MILLIONS OF OUR TAX DOLLARS HAVE ALREADY BEEN SPENT IN THE REDEVELOPMENT OF THE VILLAGE, MAKING THE AREA ONE OF THE MOST ATTRACTIVE IN NORTH COUNTY. THE ATMOSPHERE SHO.ULD NOT BE DESTROYED BY THE ADDITION OF SRO’S. THE CHARACTER OF OUR VILLAGE SHOULD BE MAINTAINED FOR THE ENJOYMENT OF FUTURE GENERATIONS. WE UNDERSTAND THE NEED FOR AFFORDABLE HOUSING, BUT FEEL THAT THE NORTHWEST QUADRANT HAS MORE THAN ITS SHARE, IT IS FULLY SATURATED NOW. WE FEEL THAT THE REST OF THE QUADRANTS SHOULD ABSORB THEIR SHARE. THE AFFORDABLE HOUSING REQUIRED BY THE STATE IS NOT EXCLUSIVELY FOR SINGLE PERSONS, BUT INCLUDES FAMILIES AND SINGLE PARENTS. SURVEY - NORTHWEST QUADRANT AREA 1. HOW LONG HAVE YOU LIVED IN CARLSBAD? 10 YEARS 2. HOW LONG HAVE YOU BEEN A PROPERTY OWNER IN THE AREA? 13 YEARS 3. HOW XNZ HAVE YOU BEEIU’ IN ZUSINESS IN THE AREA? 10 YEARS 4. ARE YOU IN FAVOR OF MULTIPLE HIGH DENSITY UNITS IN THE VILLAGE AREA? NO - 5. WOULD YOU LIKE TO SEE A FIRST CLASS HOTEL IN THE VILLAGE AREA? YES NAME : ADDRESS: 2701 QCeU J.Y. TELEPHONE: 720 - /do *SRO--SINGLE RESIDENT OCCUPANCY TO WHOM IT MAY CONCERN: REFERRED TO CITY MANAGER GCTOBEF! 1991 /F;F?;y;, Date: WE THE UNDERSIGNED ARE OPPOSED To THE BTJTLDING OF THE SRO’S PROWSED .ON CARLSBAD BLVD. HIGH DENSITY IS NOT APPROPRIATE IN THE BEACH AREA. BEACH AREA IS THE MOST EXPENSIVE REAL ESTATE IN 0. TAX DOLLARS HAVE ALREADY BEEN SPENT IN THE REDEVELOPMENT OF THE VILLAGE, MAKING THE AREA ONE OF THE MOST ATTRACTIVE IN NORTH COUNTY. SHOULD NOT BE DESTROYED BY THE ADDITION OF SRO’S. VILLAGE SHOULD BE MAINTAINED FOR THE ENJOYMENT OF FUTURE GENERATIONS. T”Ds OF OUR THE ATMOSPHERE THE CHARACTER OF OUR WE UNDERSTAND THE NEED FOR AFFORDABLE HOUSIFG, QUADRANT HAS bDRE THAN ITS SHARE, IT IS FULLY SATURATED NOW. WE FEEL THAT IWT FEEL THAT THE NORTHWEST THE REST OF THE QUADRANTS SHOULD ABSORB THEIR SHARE. REQUIRED BY THE STATE IS NOT EXCLUSIVELY FOR SINGLE PERSONS, BUT INCLUDES FAMILIES AND SINCZE PARENTS. THE AFFORDABLE HOUSING 1. HOW LONG HAVE YOU LIVED IN CARISBAD? 2. HOW LONG HAVE YOU BEEN A PROPERTY OWNER IN THE AREA? 3. HOW LONG HAVE YOU BEEN IN BUSINESS IN THE AREA? 4. ARE YOU IN FAVOR OF MULTIPLE HIGH DENSITY UNITS IN THE VILLAGE AREA? 5. WOULD YOU LIKE TO SEE A FIRST CLASS HOTEL IN THE VILLAGE AREA? *S RO--SINGLE RES1 DENT OCCUPANCY h. .. To IT IAY CONCERl WE THE UNDERSIGNED ARE OPPOSED TO THE BUILDING OF THE SRO'S PROPOSED .ON CARLSBAD BLVD. HIGH DENSITY IS NOT APPROPRIATE IN THE BEACH AREA. THE BEACH AREA IS THE MOST EXPENSIVE REAL ESTATE IN CARLSBAD. TAX DOLLARS HAVE ALREAIY BEEN SPENT IN THE REDEVELOPMENT OF THE VILLAGE, MAKING THE AREA ONE OF THE MOST ATTRACTIVE IN NORTH couEPry. SHOULD NOT BE DESTROYED BY THE ADDITION OF SRO'S. VILLAGE SHOULD BE MAINTAINED FOR THE ENJOYMENT OF FUTURE GENERATIONS. THOUSANDS OF OUR THE ATMOSPHERE THE CHARACTER OF OUR 1 WE UNDERSTAND THE NEED FOR AFFORDABLE HOUSING, BUT FEEL THAT THE NORTHWEST QUADRANT HAS MORE THAN ITS SHARE, IT IS FULLY SATURATED NOW. WE FEEL THAT THE REST OF THE QUADRANTS SHOULD ABSORB THEIR SHARE. REQUIRED BY THE STATE IS NOT EXCLUSIVELY FOR SINGLZ PERSONS, BUT INCLUDES FAMILIES AND SINGLE PARENTS. THE AFFORDABLE HOUSING SURVEY - NORTHWESTQUADRANTAREA I I 1. HOW LONG HAVE YOU LIVED IN CARLSBAD? 2. 3. 4. I HOW LONG HAVE YOU BEEN A PROPERTY OWNER IN THE AREA? Jcr HOW LONG HAk YOU BEEN IN BUSINESS IN THE AREA? 5iLGzGL I - 1 k YOU IN FAVOR OF WTIF'LE HIGH DENSITY UNITS IN Tl& VILLAGE AREA? 5. WOULD YOU LIKE TO SEE A FIRST CLASS "EL IN THE VILLAGE AREA? U NAME: ADDRESS : Ah. TELEPHONE : 719- 34q.r 6 "SRO--SINGLE RESIDENT OCCUPANCY