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Home My WebLink About2009-08-11; City Council; 19935 attachments; La Costa Town SquareC/600 it- Lisa Hildabrand Subject:FW: La Costa Town Square All Receive For the Information of the: CITY COUNCIL From: Debbie Fountain Sent: Wednesday, August 05, 2009 5:15 PM To: Lisa Hildabrand Cc: Gary Barberio; Don Neu; Sandra Holder Subject: La Costa Town Square Hi Lisa. I spoke with Gary regarding approvals for La Costa Town Square. Planning is working on a memo regarding processing options. As soon as this memo is ready, it will be forwarded to you for distribution to the Council. In general terms, it is possible to approve the commercial only on Tuesday. This would require revisions to the resolutions because they are set up to approve the entire project as submitted. It is also possible for the Council to approve the commercial, single family, and a lower density designation for the multi-family site. This, however, has implications for our Housing Element because the multi-family site is included as a site for higher density housing that satisfies the State requirements for affordable housing. It would not be possible to approve the commercial project and simply note residential for the other sites without a density designation. A density designation would need to be assigned. A redesign of the project to move the higher density residential to another location would require additional processing and possibly require an addendum to the EIR. This would need much more legal review before a recommendation could be made. As noted above, Planning is working on an informational memo and will forward as soon as it is ready. Thanks! AUG 7 2009 Cc- Lisa Hildabrand Subject:FW: La Costa Town Square From: Gary Barberio Sent: Thursday, August 06, 2009 12:56 PM To: Debbie Fountain Cc: Sandra Holder; Don Neu; Van Lynch Subject: La Costa Town Square All Receive For the Information of the: CITY COUNCIL Asst. ,CM__CA_^_CC ~>ate%/(gCity Manager 60- Debbie: RE:LA COSTA TOWN SQUARE Gary Barberio, Assistant Planning Director and Van Lynch, Senior Planner and La Costa Town Square Project Manager met with Council member Blackburn on August 4, 2009 to discuss the La Costa Town Square project. Council member Blackburn had met with adjacent residents(s) (Mr. Recce) on Trigo Lane regarding the project and in particular the triangular portion of land located between the old and new alignment of Rancho Santa Fe Road. This site is immediately adjacent to the rear yard of Mr. Recce's residence. The project proposes to re-designate this site from Local Commercial (LC), Office (0), and Low-Medium Density Residential (RLM) to Residential High Density (RH), which could accommodate approximately 120 attached-dwelling units (condos or apts, but not necessarily a 100% affordable project). Council member Blackburn was concerned about the location and impacts of the High Density Residential site adjacent to the existing single family homes in the Trigo Lane neighborhood. A question was raised as to if the RH designated portion of the project could be relocated to another portion of the project, adjacent to the Commercial Center, without delaying the approval of the Commercial Center project. The City Council could possibly take action to approve just the Commercial Center and not approve the residential portions of the project. However, staff would need to be directed to make modifications to most of the proposed Resolutions of Approval and return to the City Council with amended Resolutions at a subsequent City Council hearing. In order to approve any alternative residential project(s) and/or residential designation(s) for the remaining lands (outside of the Commercial Center), modifications to the General Plan and Zoning maps, the La Costa Master Plan, and the Local Facilities Management Plan documents and many of the plans, reports, and studies would need to be completed for the revised project. Additional environmental study/review processing would also be needed to address the residential land use changes and the changed project description and the revised residential project would need to be brought back through the public hearing process, at both the Planning Commission and City Council levels. In addition, any changes to the residential portions of the proposed project would need to be evaluated for potential impacts and conflicts with the proposed Housing Element, as the proposed RH site and the associated potential 120 attached-dwelling units are identified in the City's draft Housing Element. This may cause a delay in the processing of the residential portions of the project and in the processing of the Housing Element. Thank you-GTB CARLSBAD GaryT. Barberio Assistant Planning Director AUG 7 2009 CITY OF CARLSBADCITY CLERK'S OFFICE CCL SHEPPARD MULLIN SHEPPARD MULLIN RICH ATTORNEYS AT LAW 501 West Broadway | 19th F'oor | San Diego, CA 92101-3598 619-338-6500 office | 619-234-3815 fax \ www.sheppardmullin.com August 7, 2009 The Honorable Claude A. Lewis, Mayor Council Members City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, VA 92008 Writer's Direct Line: 619-338-6646 jponder@sheppardmullin.com A J J-'i v c: Ae 06V3-124908 Mayor City Council City Manager City Attorney City Clerk Re: La Costa Town Square Project: Response to North County Advocates Letter Dated July 14,2009 - City Council Hearing August 11,2009 - Agenda Item 7. Dear Mayor and Council Members: This firm represents La Costa Town Square, LLC ("LCTS") in land use matters related to the La Costa Town Square Project ("Project") in the City of Carlsbad ("City") scheduled for a public hearing before you on August 11, 2009. We are writing to respond to and add clarity to the issues raised in the North County Advocates' ("NCA") letter to the Planning Commissioners dated July 14, 2009. (Exhibit 1). As such, this letter is formatted to respond to each section in NCA's letter. In addition, because this letter provides a detailed comprehensive response, an executive summary is included and attached hereto as Exhibit 2 for your convenience. Introduction We agree with NCA that one of the purposes of CEQA is to inform the public and its responsible officials of the environmental consequences of a project before they are made. However, the required level of information detail is not what NCA purports. Before voting six (6) to zero (0) in support of the Project, several Planning Commissioners commented that the Project's Environmental Impact Report ("EIR") was one of the more thorough EIRs they had read and that City staff had exhaustively and methodically addressed all the issues raised by the public. We could not agree more. The CEQA statute and CEQA Guidelines clarify the legislative intent, purposes and policies of CEQA including: All persons and public agencies involved in the environmental review process be responsible for carrying out the process in the most efficient, expeditious manner in order to conserve the available financial, governmental, physical, and social resources with the objective that those resources may be better applied SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 2 toward the mitigation of actual significant effects on the environment." (PRC § 21003(f); emphasis added). The purpose of CEQA is not to generate paper, but to compel government at all levels to make decisions with environmental consequences in mind. (Bozung v. LAFCO (1975) 13 Cal.Sd 263; CEQA Guidelines § 15003(g)). CEQA does not require technical perfection in an EIR, but rather adequacy, completeness, and a good-faith effort at full disclosure. A court does not pass upon the correctness of an EIR's environmental conclusions, but only determines if the EIR is sufficient as an informational document. (Kings County Farm Bureau v. City ofHanford (1990) 221 Cal. App.3d 692; CEQA Guidelines § 15003(i); emphasis added). CEQA requires that decisions be informed and balanced. It must not be subverted into an instrument of the oppression and delay of social, economic, or recreational development or advancement. (Laurel Heights Improvement Assoc. v. Regents ofU.C. (1993) 6 Cal. 4th 1112; Citizens ofGoleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553; CEQA Guidelines § 15003(j); emphasis added). As such, LCTS implores the City to promote the efficiency of the process, to continue its good faith efforts to disclose information, but not to seek the technical perfection or oppress advancement of smart growth development in Carlsbad. We note that NCA's first comment on the project came the day before the Planning Commission hearing, not during CEQA's extensive notice and comment period on the draft EIR. Waiting until the 11th hour to express unsubstantiated, hyper-technical claims about the CEQA document's adequacy is the opposite of the expedited, good faith information disclosure process CEQA establishes for a project's entitlement and will only serve to divert resources away from actual mitigation of project impacts. A. The EIR Adequately Analyzes the Project's Impacts 1. Land Use Impacts - Open Space NCA alleges that the EIR's discussion of land use impacts is insufficient because the EIR fails to discuss the difference in open space from that required by the La Costa Master Plan. (Exhibit 1 at p. 1). As the City's EIR consultant (EDAW, Inc.) correctly points out in its letter dated July 15,2009 responding to NCA's allegations, the Project actually increases the amount of open space called for in the existing La Costa Master Plan from 4.4 acres to 5.6 acres and is specifically depicted in Figures 5.1-3a and 5.1-3b. (Exhibit 3 at p. 1). The EIR continues its SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 PageB discussion of the difference in open space on pages 5.1-17 and 5.1-18. In addition, the EIR discusses that the Project's new open space designations fulfill the objectives of the General Plan including objectives C-19 (using the General Plan Open Space Map as a conceptual guide and the proposed project realignment to better define areas for greenways and pedestrian trials by including a trail located within the 50-foot-wide open space corridor along the northern boundary of the multi-family residential parcel), C-20 (making adjustments to the open space areas with environmentally similar or larger open space areas by increasing the open space areas from 4.4 acres to 5.6 acres), and C-22 (using open space to buffer major land uses by incorporating 3.7 acres of open space to separate the residential parcel from the commercial parcel). (EIR at pp. 5.1-9,12 & 15). Furthermore, the EIR correctly concludes that there is no inconsistency with the General Plan or La Costa Master Plan because boundary adjustments to these plans will be made concurrent with any approval of the Project resulting in no physical land use impact that would cause an inconsistency. (EIR at pp. 5.1-18 & 22). Finally, given NCA's allegation that the EIR's discussion of open space land use impacts is insufficient (despite substantial evidence to the contrary), it is ironic that NCA's letter contains a single sentence with no detail as to why NCA believes the EIR's discussion is inadequate. 2. Noise Impacts NCA alleges that the EIR's discussion of noise impacts is insufficient because at 78 bBA the Project exceeds the General Plan's 60 dBA noise limit. (Exhibit 1 at p. 2). As ED AW correctly points out in its response letter, community noise increases of 3 dBA or less are not considered perceptible and therefore not significant. Although the project increases noise levels more than 3 dBA near the Project's commercial entrance on La Costa Avenue, the commercial use of the affected property is not a noise sensitive land use. (Exhibit 3 at p. 1; EIR at p. 5.4-13). Indeed, the Project complies with the General Plan's Noise Element Implementing Policy C.3 which "[r]equire[s] the use of project design techniques, such as...placing non-noise sensitive uses such as parking areas between the source and the receiver.. .to minimize noise impacts during any discretionary review of a residential or other noise sensitive project." (General Plan Noise Element at p. 6). Furthermore, General Plan Noise Element Implementing Policy C.5 clarifies that the requirement to mitigate to a 60 dBA exterior noise limit applies to residential units, not commercial properties. Finally, EIR Table 5.4-8 identifies the residential lots the Project's noise study disclosed would be subject to noise levels exceeding 60 dBA. However, these noise levels would be reduced to below a level of significance through the construction of noise barriers along Rancho Santa Fe Road required by Mitigation Measure N-6. (EIR at pp. 5.4-15 to 17). SHEPPARD MULLM RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 4 3. Hillside Development Regulations NCA alleges that the EIR's discussion of land use impacts is insufficient because the Project does not provide adequate support for the exclusions allowed by the City's Hillside Development Regulations and that there is no discussion of the written findings necessary to justify the exclusions. Specifically, NCA cites to the findings in CMC §§ 21.95.130(A)(1)&(2), 21.95.120(D)(4), and 21.95.090. (Exhibit 1 at p. 2). The opposite is true. The necessary Hillside Development Permit findings are provided in Planning Commission Resolution No. 6586 and as ED AW correctly points out in its response letter, a detailed supplemental discussion of the Project's compliance with the Hillside Development Regulations is provided for in the EIR, the Candidate CEQA Findings, and staff report. (Planning Commission Resolution No. 6586 at p. 2; Exhibit 3 at p. 1; EIR at p. 5.1-20 to 21; Candidate CEQA Findings at p. 16; and City Staff Report at pp. 19-20). First, CMC §§ 21.95.130(A)(1)&(2) provides an exclusion from the Hillside Review Regulations' design standards for: 1. Hillside areas where a circulation element roadway or a collector street must be located provided that the proposed alignment(s) are environmentally preferred and comply with all other city standards. 2. Grading volumes, slope heights and graded areas which are directly associated with circulation element roadways or collector streets, provided that the proposed alignnient(s) are environmentally preferred and comply with all other city standards. The Project's Hillside Development Permit ("HDP 01-05") Finding 5 states, "[t]hat the site requires extensive grading to accommodate a circulation-element roadway, in that Rancho Santa Fe Road has been realigned to cross the site and the project fronts onto La Costa Avenue. Both roadways have modified the slopes on the development site by grading to accommodate the circulation element roadways. Furthermore, HDP 01-05, Condition 3 requires the project to comply with all federal, state and local laws, which includes "all other city standards" called for by the exclusion and CEQA's requirement to mitigate for feasible environmental impacts which includes aligning roads where they are environmentally preferred. The City created and analyzed the environmentally preferred feasible road alignment through the CEQA review of the roadway in EIR No. 9101 in 1992 and its EIR Addendum in 2000. Second, we note that the findings support a "modification" to the Hillside Review Regulations' design standard under CMC §§ 21.95.140(A)(l)-(3), which can be establish through any one of the following findings: SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 PageS 1. The proposed modification will result in significantly more open space or undisturbed area than would a strict adherence to the requirements of Section 21.95.120. 2. The proposed modification will result in the development of manufactured slopes which are more aesthetically pleasing and natural appearing than would a strict adherence to the requirements of Section 21.95.120. 3. The proposed modifications will result in the preservation of natural habitat as required by the city's habitat management plan and the required amount of preservation could not be achieved by strict adherence to the requirements of Section 21.95.120 of this chapter. Modification findings (A)(l) and (A)(3) are made by HDP 01-05 Finding 6 which states, "[t]hat the proposed modification will result in significantly more open space or undisturbed area than would a strict adherence to the requirements of the ordinance, in that the site was previously identified as a site to be developed in the Habitat Conservation Plan. As such, mitigation land which is part of a larger preserve system with better habitat quality than the subject site was acquired and preserved to mitigate the biological impacts to the project site." Modification finding (A)(2) is made through the Candidate CEQA Findings on visual impacts. Third, NCA's contention that the project must make the findings identified in CMC § 21.95.120(D)(4) is misplaced because those findings only apply to projects that propose to cut and fill between 8,000 and 10,000 cubic yards per acre. The overall Project exceeds 10,000 cubic yards per acre, which is why the City instead made the aforementioned findings supporting an exclusion and modification to the Hillside Review Regulations' design standards. Even if NCA contended that cut and fill associated with the office portion of the Project would fall within the 8,000 to 10,000 cubic yards per acre range, these findings are not required because CMC § 21.95.140(D) specifically exempts all non-residential projects from the Hillside Review Regulations' design standards regarding limitations on quantity of fill and slope height. Fourth, NCA's allegation that there is no discussion of the findings required by CMC § 21.95.090 ignores the fact that HDP 01-05 Findings 1 - 4 specifically identify and make these findings. B. The EIR Adequately Analyzes the Project's Feasible Mitigation 1. Traffic Mitigation SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 6 NCA alleges that the EIR fails to provide adequate mitigation for several Project traffic impacts citing a California Supreme Court case, City of Marina v. Board of Trustees of the California State Univ. (2006) 39 Cal 4th 341, 360, limiting when an agency can dismiss mitigation measures that are within the control of another jurisdiction. However, the facts of that case are distinguishable from the matter before the City Council because in that case California State University ("CSU") refused to provide fair share funding toward public infrastructure projects contained in a capital improvement plan approved as part of a Base Reuse Plan mandated by the state legislature. CSU's EIR provided that payment of the fair share fee would have mitigated its off-site traffic and other impacts to below a level of significance, but CSU believed it did not have the authority to pay those fees under the Education Code. The Supreme Court interpreted the Education Code in a manner that allowed CSU to pay the fair share fee. The Project's off-site, extra-territorial traffic impacts cannot feasibly be mitigated because (1) there is no existing capital improvement plan for the traffic improvements that would be needed; (2) the City has no authority to amend Caltrans' or other cities' capital improvement plans; (3) the Project's contribution to traffic impacts are so small that it would be inequitable1 to impose a requirement on the applicant and beyond the capability of the applicant to effect improvements that would avoid significant cumulative project impacts. The courts have established criteria for making fair share contributions that can mitigate cumulative traffic impacts. Chief among them is the requirement that the lead agency demonstrate how the payment of fees "are part of a reasonable plan of actual mitigation that the relevant agency commits itself to implementing." (Anderson First Coalition v. City of Anderson (2005) 130 Cal App. 4th 1173, 1187; San Franciscans for Reasonable Growth v. City & County of San Francisco (1984) 151 Cal. App. 3rd 61, 79) Here, if LCTS were to pay a fair share fee, then the City could not demonstrate that such payment would mitigate any of the traffic impacts because there are no capital improvement plans in the other jurisdictions to construct those improvements with the fee. The traffic impact would remain significant and unmitigable. For any extra-territorial traffic improvements where the City believed it would be equitable and otherwise feasible to require LCTS to pay a fair share, at most, the City could condition the Project to pay a fair share upon the other jurisdictions removing the infeasible legal obstacles by including the traffic improvement in their capital improvement programs. However, 1 In addition to a finding that the changes in transportation infrastructure are within the responsibility of anther public agency and have been, or can and should be adopted by that other agency pursuant to PRC 21081(a)(2), the EIRs statement that it would be inequitable to impose these infrastructure requirements on LCTS qualifies as an "other consideration" that makes infeasible the mitigation measure identified in the EIR pursuant to PRC 21081(a)(3). In either case, a Statement of Overriding Considerations for the significant and unmitigable traffic impact would be required to approve the Project. Candidate Statement of Overriding Considerations have been provided for the City Council's review for this purpose. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page? since those legal obstacles are in place at this time, even if the City were to impose such conditions, the City could not conclude the traffic impacts would be reduced to below a level of significance. A Statement of Overriding Consideration would be required to approve the Project. As discussed in the introduction, one of CEQA's objectives is that "[a] 11 persons and public agencies involved in the environmental review process be responsible for carrying out the process in the most efficient, expeditious manner in order to conserve the available financial, governmental, physical, and social resources with the objective that those resources may be better applied toward the mitigation of actual significant effects on the environment." (PRC § 21003(f); emphasis added). Requiring payment of fair share contributions to extra- territorial infrastructure projects that have no plans for construction would only serve to divert financial resources away from the mitigation of the Project's actual significant effects on the environment that can and will be mitigated. ED AW also clarified in its response letter where and how the EIR and the Candidate Findings and Statement of Overriding Considerations extensively and adequately discussed the Project's traffic impacts in areas where the City has no authority to act. (Exhibit 3 at p. 2; EIR at Tables 5.2-19, 5.2-20, 5.2-26; Candidate Findings at pp. 28-32). The Courts have also made it clear that CEQA's requirement to mitigate impacts does not grant a lead agency new legal powers independent of the power granted to the agency by other laws. (CEQA Guidelines § 15040(b); Sierra Club v. California Coastal Commission (2005) 35 Cal. 4th 839). The City has no authority to regulate land use activities, including road construction projects, outside of its territory. Finally, NCA alleges that the Project fails to evaluate mitigation measures that are within the City's jurisdiction, citing synchronization of traffic lights to improve traffic flow. However, at the Planning Commission hearing, City staff set the record straight that feasible mitigation measures were being taken. In fact, there was an extensive discussion about how the Project will install synchronized traffic signals on Rancho Santa Fe Road from Camino De Los Coaches to Paseo Lupino to mitigate traffic impacts on that road segment as part of the City's larger plan to synchronize its traffic signal system. The City recognizes its obligation to impose feasible mitigation measures where it has the legal authority to do so and the City has done so. Table 5.2-26 summarizes the feasible project design features and mitigation measures the City is taking to address the Project's significant and potentially significant traffic impacts. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7,2009 PageS 2. Air Quality Mitigation NCA alleges that the EIR fails to provide adequate mitigation for the Project's air quality impacts. The Project does not create significant air quality impacts for most emissions, but the Project's carbon monoxide ("CO") and Particulate Matter ("PM-10") emissions exceed the threshold of significance. These emissions sources come primarily from the Project's mobile sources so in an effort to reduce vehicle trips, the Project incorporates enhanced bus stops along La Costa Avenue and Rancho Santa Fe Road, improves bike lanes, and provides bike storage on site. In addition, the Project is required to implement mitigation measure AQ-1, which includes the following to the extent feasible: (a) The applicant shall require the commercial development operator to operate, maintain, and promote a ride-share program for employees of the various businesses; (b) The applicant shall include one or more secure bicycle parking areas within the property and encourage bicycle riding for both employees and customers; (c) The warehouse and shopping center shall be designed to meet Title 24 plus 20 percent energy-efficiency standards and shall include photovoltaic cells on the rooftops to achieve an additional 25% reduction in electricity use on an average sunny day. (d) The applicant shall require that all materials handling equipment operated by the businesses within the facility be electric or use nondiesel engines. (EIR at pp. 5.3-34). Courts have repeatedly upheld such Alternative Mitigation approaches to reducing significant impacts when it is impractical to identify the specific mitigation measures at the time the EIR is prepared. (Sacramento Old CityAss'n v. City Council (1991) 229 Cal App. 3d 1011; Endangered Habitats League v. County of Orange (2005) 131 Cal. App. 4th 777, 794; Defend the Bay v. City of Irvine (2004) 119 Cal. App. 4th 1261, 1275; Riverwatch v. County of San Diego (1990) 76 Cal. App. 4th 1428, 1447; Laurel Heights Improvement Ass 'n v. Regents of University of California (1988) 47 Cal. 3d 376, 418; Dry Creek Citizens Coalition v. County ofTulare (1999) 70 Cal. App. 4th 20, 25; National Parks & Conservation Ass'n v. County of Riverside (1999) 71 Cal. App. 4th 1341,1366). Under this approach, the City may formulate the specific mitigation measures following further study if the mitigation measures describe the available options that will be considered, identify performance standards which are to be met, and make future approvals contingent on finding a way to meet mitigation measures that are suitable based on design and location. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 9 For example, in the Sacramento Old City case, the court upheld the Alternative Mitigation approach reasoning that "for the kinds of impacts for which mitigation is known to be feasible, but where practical considerations prohibit devising such measures early in the planning process, the agency can commit itself to eventually devising measures that will satisfy specific performance criteria articulated at the time of project approval." (Id. at 1029). Like in the Sacramento Old City case, devising final mitigation measures for CO and PM-10 emissions would be impractical at this time, given that there are no commercial and office building tenants who can (1) formulate the details of a ride-share program or (2) identify their materials handling equipment needs to determine if they can be equipped with electric or non-diesel engines. In the landmark Laurel Heights case, the Supreme Court held, "[t]he absence of regulation [of certain laboratory emissions] is, however, a factor that can reasonably be considered in the EIR process ... [T]he absence of regulation was relevant to the Regents' finding that they had taken all feasible steps to mitigate such effects in light of current scientific knowledge." (Laurel Heights, at 412). The Supreme Court further held that it was premature for the EIR to include study of the laboratory emissions because "[t]he changing nature of scientific research may make such estimates difficult and of little value." (Id. at 413). The Supreme Court concluded that "[a]n agency's commitment to monitor the effects of its activities may be considered as evidence of mitigation ... We think it unreasonable to demand a commitment to take specific action based on unknown and as yet unknowable test results." (Id. at 412). Similar to the Laurel Heights case, the absence of a green building code in the City to establish the regulatory standard for feasible energy-efficiency technologies, is relevant to the adequacy of proposed mitigation measures. It would be unreasonable to demand a commitment to a final list of energy-efficiency technologies, including solar panels, given the rapidly changing nature of such technologies and the ability to measure their effectiveness in reducing CO and PM-10 emissions. Instead, the condition establishes a performance standard of 20% more energy efficient than Title 24 building standards and a 25% reduction in electricity use on an average sunny day. Combined, these cases provide guidance on how to implement Alternative Mitigation. As discussed above, this Alternative Mitigation approach is appropriate because the lead agency has (1) explained why formulation of the specific mitigation measures following future study is appropriate under the circumstances; (2) committed itself to mitigation through conditions on the project; (3) provided a list of mitigation alternatives to be considered, analyzed and possibly incorporated into the mitigation plan; and (4) used independent performance standards to supplement regulatory agency approval of the mitigation plan. The Candidate Findings and ED AW response letter explain that despite these project design features and mitigation measures, the results cannot be reasonably quantified leaving the impact significant and unmitigated. (Exhibit 3 at p. 2, Candidate Findings at pp. 32-34 and 42- 43). The alternative method of assuring that the Project does not exceed the significance threshold is to reduce the Project's vehicle trips from 25,516 ADT to 6,000 ADT, which would SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 10 require reducing the shopping center from 284,400 to 40,450 square feet, which is not feasible because it would be inconsistent with the existing Carlsbad General Plan and Zone 11 LMFP. Without the development impact fees that have been calculated based on the level of residential and commercial development allowed by the adopted General Plan, planned public safety services, parks, libraries, public facilities and transportation improvements would not be fulfilled without income from other sources, for which excess City revenue is not available. The loss of property tax and sales tax revenue from reducing the size of the shopping center by 86% would reduce the City's ability to meet its annual budgetary obligations. The CBRE report on the Project demonstrated that the 10% reduction in the size of the originally proposed project would result in a $71,000 reduction in sales tax revenue ($753,000 instead of $824,000) a year starting in 2012 when sales are projected to stabilize. During the Planning Commission hearing, there was also testimony that failure to provide ample, attractive shopping center space would only cause residents to travel further to obtain commercial goods thus worsening the air quality. The LCTS is an ideal example of the type of well-balanced, mixed use, live, work and shop-type project adjacent to existing bus transit that the General Plan, SB 375, and other smart growth planning documents and legislation identify is needed to reduce environmental impacts caused by California's population growth. NCA's opposition to the Project is evidence that NIMBYism remains an obstacle to any growth - smart or sprawl-focused. In short, there is substantial evidence in the record that it is not feasible to avoid these air quality impacts through measurable mitigation or alternatives to the Project. In contrast, NCA has provided no substantial evidence identifying further feasible mitigation measures. 3. Noise Mitigation (interior noise) NCA alleges that the EIR's improperly analyzes mitigation of potential noise impacts to the second story residential units on Lots 34 through 48 because it fails to state what is required to be done if the study shows the noise levels exceed the applicable standards. (Exhibit 1 at p. 3). Analysis of interior noise impacts is proper because the lead agency has (1) explained why formulation of the specific mitigation measures following future study is appropriate under the circumstances; (2) committed itself to mitigation through conditions on the project; (3) provided a list of mitigation alternatives to be considered, analyzed and possibly incorporated into the mitigation plan; and (4) used independent performance standards to supplement regulatory agency approval of the mitigation plan. There is an enforceable commitment to the performance standard that must be achieved (45 dBA). (EIR at p. 5.4-16). The mitigation measures are fully enforceable through the Carlsbad Municipal Code ("CMC"), which states the following: SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 11 It is the intent of the city to ensure that all required mitigation measures to avoid potentially significant effects are effectively implemented and monitored throughout the project approval, permitting and construction process, as well as the lifespan of the project. In conjunction with the approval of each project, an individual program shall be developed and adopted to ensure that each feature related to the mitigation measures is specifically included as a reference in the conditions of approval, incorporated into the subsequent stages of development review and permitting process and monitored during construction and final inspection, as well as on an ongoing basis. The program may contain remedies to ensure compliance with the ongoing mitigation measures beyond final inspection. (CMC § 19.04.180; emphasis added). The Code further provides that mitigation measures are enforceable through the City's civil and criminal action, permit revocation, and withholding future building and occupancy permits. Specifically, it states the following: A. Except as otherwise provided by law, it is unlawful, and an offense punishable as designated in Title 1, Chapter 1.08 of this code, for any project applicant or permittee to fail to perform any required mitigation measure(s) specified in the mitigation monitoring and reporting program for the project. B. The city shall also have the right to revoke or modify all approvals granted in relation to the environmental review of the project, deny or further condition issuance of any future building permits and deny, revoke or further condition all certificates of occupancy issued under the authority of the related approval. C. Violations may be enforced by criminal or civil judicial action, or both, or in combination with any of the administrative remedies enumerated in this code to compel compliance with said conditions or seek damages for their violation. The planning director may record with the county recorder's office a notice against a property which is the subject of an enforcement action pending with the City of Carlsbad. (CMC § 19.04.210; emphasis added). It is not possible to identify the exact mitigation measures that will be used because the structures on these lots have not been designed yet. Among the mitigation measures that can be used to achieve the 45 dBA standard are double-pane windows, smaller window openings, fewer windows, windows that cannot be opened, and other techniques identified in the Project Noise Study and City Noise Guidelines. Finally, during the Planning Commission hearing on July 15, 2009, clarification was given that if it were not feasible to meet the interior noise standard on the SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 12 second floor, then a single-story structure would be constructed on those lots. 4. Blasting Mitigation NCA alleges that the EIR's blasting mitigation is insufficient because informing purchasers at the time of escrow will do nothing to mitigate impacts associated with blasting, such as pre- and post-blasting inspections, early warning and damage prevention procedures, and providing insurance against damage. (Exhibit 1 at p. 3). As ED AW correctly points out in its response letter, the EIR does much more to mitigate environmental impacts to existing residences than NCA suggests. (Exhibit 3 at p. 1). First, Mitigation Measure N-l requires use of a portable sound wall during rock drilling. (EIR at p. 5.4-16). Second, Mitigation Measure N-2 requires notification of all property owners within 250 feet of the blasting area about potential noise and vibration impacts, the estimated frequency of the blasting, and a contact number for all complaints. (EIR at p. 5.4-17). During the Planning Commission hearing on July 15,2009, City staff further clarified that City requires door hangers and letter notification to the property owners, and that the developer was required to make any party injured by the blasting whole. Furthermore, the City's blasting policy (Engineering Department Policy 15; Exhibit 5) also requires the blasting contractor to post a Certificate of Insurance with minimum coverage of $1,000,000 for property damage and $1,000,000 for bodily injury for each occurrence. In addition, it requires pre-blast inspection and report of all structures within 300 feet of the blast site and post-blast inspections of any property that complaints of damage. The Courts have made it clear that compliance with existing laws and regulations can serve as adequate mitigation of a project's environmental impacts. (Leonoffv. Monterey County Bd. of Supervisors (1990) 222 Cal. App. 3d 1337, 1355; Sundstrom v. County ofMendocino (1988) 202 Cal. App. 3d 296, 308.) 5. Flooding Mitigation NCA alleges that the EIR fails to discuss reasonable and feasible mitigation for the Project's potential flooding impacts because it does not analyze the level of flooding impact that would occur if structures were not placed within the potential flooding zone or require an early warning system should flooding appear likely or imminent. (Exhibit 1 at p. 3). As the EIR describes, the Project's proposed grading and street walls reduce the velocity and extent of flood waters in the event of a dam failure to a level of insignificance for human safety hazards. (EIR at p. 5.9-10,11,16, and 17). In addition, evacuation plans with two emergency escape routes are features of the Project providing further protection. (Id.) Therefore, there is no need for an extra early warning system to protect human safety. An early warning system would not prevent property damage, which is the potentially significant impact. However, notice of the property's location in the Stanley A. Mahr Dam Inundation Area through the CC&Rs as required by Mitigation Measure H-l mitigates potential flooding impacts to below a level of significance because the homeowner and the homeowner's insurance company are apprised of the potential SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 13 flooding risk and can price the cost of property insurance and purchase price they are willing to pay for the home accordingly. Furthermore, as there is substantial evidence that the potential flooding impact is mitigated to below a level of significance, CEQA does not require the City to completely avoid an environmental impact. The City can avoid an impact or mitigate an impact. (PRC §21002.1(b)). Finally, NCA's proposal to reduce the number of housing units by not building in the Dam Inundation Area is not permitted by CEQA where, as here, feasible mitigation measures exist that would not reduce the number of housing units. (CEQA Guidelines § 15092(c)). 6. Greenhouse Gas Mitigation NCA claims that the EIR fails to discuss possible solar panels and other ways in which to mitigate greenhouse gas emissions ("GHG"). There is substantial evidence to the contrary. First, as ED AW points out in its response letter, the EIR does discuss its project design features and mitigation measures to reduce GHG emissions. (Exhibit 3 at p. 3; EIR at pp. 6-27 to 6-30.) Included among them is the installation of solar panels on carports. (EIR at p. 6-28, B.2.) In addition, at the Planning Commission hearing, LCTS agreed to make the Project's commercial, multi-family residential, and office structures solar-ready. The single family residential structures are already required to be constructed as solar-ready by the City's building code. Furthermore, the City Attorney concluded that the City lacked the legal authority to impose solar panel installation as a Project condition because there is no City ordinance or building code requiring installation of solar panels and CEQA does not grant the City independent authority to impose mitigation measures. (PRC § 21004). Furthermore, CEQA defines "feasible" to mean "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors." (CEQA Guidelines § 15364; emphasis added). Therefore, CEQA imposes no requirement for an EIR to analyze mitigation measures that are not legally feasible2. (CEQA Guidelines § 15126.5(a)(5)). Second, the Project provides an extensive 21-page discussion of GHG in section 6.2 of the EIR, in which it inventories the Project's estimated GHG emissions, establishes a 30% below business-as-usual ("BAU") threshold as the level of Project GHG emissions necessary to avoid a cumulative impact to statewide GHG emissions necessary to achieve AB 32's goal of reducing 2 The City should note that the EIR is not required to analyze the Project's compliance with a draft plan or draft CEQA Guidelines. (CEQA Guidelines § 15007(c); Chaparral Greens v. City ofChula Vista (1996) 50 Cal.App.4th 1134). SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 14 statewide GHG emissions to 1990 levels by the year 2020, identifies project design features that will reduce GHG emissions, and a menu of mitigation measures to further reduce GHG emissions, attached hereto as Exhibit 4. Implementation of various state and federal laws and regulations will further reduce GHG emissions. However, because there is no local or state agency with an established significance threshold and the City lacks the technical capability to reduce GHG from vehicular emissions that represent 91% of the Project's GHG emissions, the EIR concludes that (1) pursuant to CEQA Guidelines § 15145 it is too speculative to analyze Project specific climate change impacts; and (2) pursuant to CEQA Guidelines § 15091(a)(3), there are specific technological considerations that make infeasible the mitigation measures identified in the EIR that would reduce the impact to below a level of significance. As discussed in the EIR, the California Air Resources Board ("CARB") and the Office of Planning and Research ("OPR") are in the process of developing draft CEQA Guidelines for the mitigation of GHG for the California Resources Agency's ultimate adoption by January 1, 2010. OPR recommends that lead agencies adopt their own approach to performing GHG analysis for projects that generate GHG emissions, including identifying and quantifying the GHG emission sources, assessing the significance of the impact on climate change, and identifying feasible alternatives and/or mitigation measures to reduce the impact to below a level of significance. (CARB 2008). OPR has recently issued preliminary draft CEQA guideline amendments pursuant to SB 97, which the Resources Agency has not approved. They are designed to be consistent with existing CEQA framework for environmental analysis, including but not limited to the determination of baseline conditions, determination of significance, and evaluation of mitigation measures. OPR did not identify a specific threshold for GHG emissions, nor has the OPR prescribed assessment methodologies or specific mitigation measures. The preliminary draft amendments encourage lead agencies to consider many factors in making their own determinations based on substantial evidence. At the same time, OPR acknowledges that the scientific knowledge and understanding of how best to perform this analysis is "rudimentary and still evolving" and that "more sophisticated emissions models for particular types of projects are continually being developed and that the state-of-the-art quantification models are rapidly changing." (CARB 2008). Finally, OPR advises that "[i]n the absence of regulatory standards for GHG emissions or other scientific data to clearly define what constitutes a 'significant impact', individual lead agencies may undertake a project-by-project analysis, consistent with available guidance and current CEQA practice." (CARB 2008; emphasis added). Current CEQA practice includes CEQA Guidelines § 15145, which states, "[i]f, after thorough investigation, a lead agency finds that a particular impact is too speculative for evaluation, the agency should note its conclusion and terminate discussion of the impact." Because OPR and CARB have stated that the scientific knowledge is "rudimentary and still evolving" and that the quantification models are rapidly changing it is reasonable for the City to conclude after 21 pages of thorough investigation in the EIR that GHG impacts are too speculative for evaluation. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 15 Third, it is important to understand that even though it is too speculative to measure the effectiveness of GHG mitigation measures at this time, the Project has no vested right to develop without complying with future state3 and federal regulations. Under SB 97, CARB is required to promulgate new early action regulations to reduce GHG by January 1,2010. CARB is also required to promulgate GHG reduction regulations necessary for the state to achieve AB 32's reduction targets by January 1, 2011 and those regulations must go into effect by January 1, 2012. To the extent these state regulations are in place before LCTS is constructed, they will apply to the Project. Fourth, even though it is too speculative to measure accurately the effectiveness of GHG mitigation measures at this time, the implementation of state and federal regulations that control the vehicle emissions that represent 91% of the Project's GHG emissions may very well reduce those emissions by 30% BAU. In the University of San Diego's Energy Policy Initiatives Center ("EPIC") report entitled "San Diego County Greenhouse Gas Inventory: an analysis of regional emission and strategies to achieve AB 32 targets" (EPIC 2008), the center has developed a preliminary assessment of emissions in San Diego County, including the effect of implementation of state and federal programs to reduce emissions from vehicles. The percent reductions in GHG emissions anticipated through implementation of Federal CAFE standards (15% less), Low Carbon Fuel Standard (11% less), and Pavley fuel efficiency standard (6% less and incremental to the Federal CAFE standard), as well as the effect of light/heavy vehicle efficiency/hybridization programs (4% less), can be estimated based on the EPIC study. (Exhibit 6_at Table 2). Emission from vehicles would therefore be reduced by as much as 36% from state and federal programs by the year 2020. It should also be noted that there are legislative and In addition to the future CARB regulations, the Project is not exempt from current or future state building code standards. Executive Order S-20-04, California's Green Building Executive Order, put in motion the State of California's Green Building Action Plan, which requires that the State agencies with responsibility for building standard amendments (California Energy Commission and Building Standards Commission) to develop building code amendments to ensure that "all proven, cost-effective, and achievable energy and resource efficiency, health and safety technologies and design practices are considered and employed in new non-residential buildings, with the goal to increase efficiency by 20% by 2015 compared to the Title 24 non- residential building standards adopted in 2003." (Green Building Action Plan § 2.3.1.1; emphasis added). Each updated version of the Title 24 standards creates greater and greater energy efficiency in non-residential buildings in a manner that is "achievable", rather than ad hoc requirements for commercial buildings to use solar panels. The state agencies follow a thoughtful, informed and public rulemaking process to arrive at its energy efficiency standards. The Building Standards Commission Code Advisory Committees will meet over the next few weeks to review hundreds of state agency amendments to the California Building, Residential and Green Building Codes. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 16 regulatory efforts underway to reduce GHG emissions from electricity. Implementation of the renewable portfolio standard, which requires utilities to purchase 20% of their electricity from renewable sources, would reduce GHG emissions by another 13% overall. (Exhibit 6 at Table 2). In short, NCA is asking the City to put the cart before the horse by mandating specific mitigation measures before the City can adopt its own green building ordinance or CARB has had an opportunity to promulgate regulations that will clarify what actions need to be taken for the City and development projects within the City to achieve the reductions called for in AB 32. LCTS is not interfering with CARB's efforts because it (1) is a transit-friendly, mixed use development in keeping with the California Climate Action Team's recommendation to promote strategies to encourage job/housing proximity, promote transit-oriented development, and encourage high-density residential/commercial development along transit corridors (EIR at p. 6- 25), (2) has incorporated legal and technological GHG reduction measures into its project design features and mitigation measures, and (3) has no vested right against new state or federal regulations that will allow California to meet the GHG reduction measures called for in AB 32. The City is entitled to rely on the expert opinions of its environmental planner, ED AW, who, after reviewing the current technological literature on the status of the scientific understanding of the link between land use decisions and climate change, has concluded it is uncertain and too speculative to determine the significance of the Project's contribution to the impact or to determine whether the mitigation measures can reduce that impact to below a level of significance. See CEQA Guidelines § 15145; Anderson First Coalition v. City of Anderson (2005) 130 Cal.App.4th 1173; Alliance of Small Emitters/Metals Indus, v. South Coast Air Quality Mgmt. Dist. (1997) 60 Cal.App^* 55, 66). EDAW's expert opinion on this issue is reinforced by OPR and CARB's acknowledgement that scientific knowledge is "rudimentary and still evolving" and that the quantification models are still rapidly changing. C. The EIR Adequately Analyzes the Project's Alternatives 1. The Project Objectives are Appropriate NCA alleges that the City has improperly narrowed the selection of Project alternatives because the City has defined the Project objectives too narrowly, citing Rural Landowners Assoc. v. Lodi City Council (1983) 143 Cal. App. 3d 1013,1024. The Project considers, but rejects four alternatives, including an alternative location for the Project, a Project with no commercial development, a Project that replaces single-family residential with high density residential, and a Project that replaces the multi-family residential with office space. NCA provides no explanation why these four alternatives would be environmentally superior to the Project or why the Project objectives are too narrow. In contrast, the City details its reasons for rejecting these alternatives on pages 7-4 to 7-6 of the EIR, which include the failure of those four SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 17 alternatives to either provide adequate vacant space for a commercial and mixed use shopping center, strengthen or diversify the City's tax base, provide an area available to the surrounding community that fulfills daily shopping needs and minimizing local trips, conform to the La Costa Master Plan designation of the site for commercial development, provide an attractive, well- balanced residential area with a range of housing types, styles and price levels, or conform to the Master Plan and General Plan's vision of low-medium residential development of the site. These are all legitimate planning goals for the City and proper objectives for the Project just as they are proper grounds for a statement of overriding considerations. See Towards Responsibility in Planning v. City Council (1988) 200 Cal App. 3d 61\\Dusek v. Redevelopment Agency (1985) 173 Cal App. 3d 1029; City ofPoway v. City of San Diego (1084) 155 Cal App. 3d 1037; Markley v. City Council (1982) 131 Cal App. 3d 656. Furthermore, NCA's quote from Rural Landowners Association that "[responsibility for a project cannot be avoided merely by limiting the title or description of the project" relates to the City of Lodi's failure to discuss the environmental impacts related to the annexation of a project into the City of Lodi. Simply put, the quote has nothing to do with what project objectives were selected and whether the City of Lodi evaluated an appropriate range of alternatives. 2. There is Substantial Evidence that the Environmentally Superior Alternatives are Not Feasible NCA alleges that the EIR does not provide substantial evidence that the environmentally superior alternatives are infeasible or impracticable and instead only provides cursory rejections of these alternatives without supporting analysis. The opposite is true. The level of analysis of alternatives is subject to a rule of reason. Recently, courts have explained what level of detail is sufficient. (Sierra Club v. City of Orange (2008) 163 Cal. App. 4th 523, 547; Del Mar Terrace Conservancy, Inc. v. City Council (1992) 10 Cal. App. 4th 712); Residents Ad Hoc Stadium Comm. v. Board of Trustees (1979) 89 Cal.App. 3d 274, 286.) In Sierra Club v. City of Orange, the Court affirmed that use of a matrix to summarize and compare the impacts of alternatives to a project's impacts followed by a two-paragraph explanation of the alternative and why each alternative was found to be infeasible was sufficient. It held that "[w]hile and EIR must 'include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project [citing CEQA Guidelines § 15126.6(d)], contrary to the suggestion in plaintiffs opening brief, '[t]he discussion of alternatives need not be exhaustive..." (Foundation for San Francisco's Architectural Heritage v. City and County of San Francisco (1980) 106 Cal. App. 3d 893,910). The SEIR/EIR's discussion of project alternatives may not be perfect, but it is sufficient." (Sierra Club v. City of Orange at p. 547). SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 18 The La Costa Town Center EIR far exceeds the Sierra Club case standard because it not only provides a similar matrix in Section 7, it provides a paragraph comparing the alternative to the Project for each impact category (Land use and Planning, Transportation, Air Quality, Noise, Paleontological, Biological, Water Quality, Geology, Hazards, Aesthetics, Public Services/Utilities, and Global Climate Change) along with a paragraph describing the degree to which the alternative meets the project objectives. (EIR at §§7.1, 7.2, 7.3). hi addition, the Candidate Findings provide an additional six pages of analysis of the specific economic, legal, social, technological and other considerations that make infeasible the mitigation measures or alternatives identified in the EIR that would reduce the impacts to less than significant. (Candidate Findings at pp. 32-38). D. There is No Need to Recirculate the EIR Recirculation is required whenever "new significant information" is added to the EIR. (CEQA Guidelines Section 15088.5). The City has not added any new information to the EIR. Courts have stated very emphatically that "we find nothing in CEQA commanding respondents to circulate for public review additional mitigation measures made in response to comments by those who oppose the project. To allow the public review period to proceed ad nauseam would only serve to arm persons dead set against a project with a paralyzing weapon - hired experts who can always 'discover* flaws in mitigation measures. As previously noted, the purpose of CEQA is to inform government decision makers and their constituency of the consequences of a given project, not to derail it in a sea of administrative hearings and paperwork." (Long Beach Sav. &LoanAss'n v. Long Beach Development (1986) 188 Cal. App.3d 249, 263; emphasis added). The California Supreme Court has cautioned, "[RJules regulating the protection of the environment must not be subverted into an instrument for the oppression and delay of social, economic, or recreational development and advancement (Citizens ofGoleta Valley v. Board of Supervisors (1990) 52 Cal.App.3d 553, 576; emphasis added). The City should not encourage project opponents efforts to delay a project through recirculation, especially when NCA did not take advantage of CEQA's notice and comment period on the Draft EIR and whose first comments against the project came the day before the hearing. This evidences that NCA is dead set against the project and is only interested in derailing the project in a sea of administrative hearings and paperwork. Conclusion City staff have done an excellent reviewing and analyzing the Project. Through CEQA's exhaustive technical studies and public outreach process, the City should be confident that it has made an adequate, good faith disclosure of the issues. As such, LCTS implores the City to SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 19 promote the efficiency of the process and not to seek the technical perfection or oppress advancement of smart growth development in Carlsbad as NCA seeks. By approving the Project, the City will allow LCTS to apply its limited resources toward actual mitigation of the Project impacts, rather than preparing additional paperwork that will not satisfy an organization that is dead set against the project. Very truly yours, hn E. Ponder for SHEPPARD, MULLIN, RICHTER & HAMPTON LLP W02-WEST:8JWF1\401659850.4 CC: Ron Kemp, Esq, City Attorney Van Lynch, City Planner Lorraine M. Wood, City Clerk Pat O'Day SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 20 Exhibit 1 North County Advocates' Objection Letter Dated July 14.2009 FROM :LAU OFFICESOF EVERETT DELPNO FftX NO. : 7605101565 Jul. 14 2003 02:14PM P2 LAW OFFICES OF EVERETT L. DELANO HI 220 Wt Grand Avenue . Escondido, California 92025 . -(760) 610-1562 . •' , . . , {760) 510-1565 (fax) .. .. ' July H 2009 . ; • . . VIA FACSIMILE &V.& MAIL ' '. . . . . ' . Lorraine M: Wood • . . . CityClerk ''.•'-.'• • City of Carlsbad . , . ' 120fr Carlsbad Village Drive ' . . Carlsbad, CA 92008 .. . . Re:. La Costa Town Square: EIR 01-02/0PA 01-02/MP 149rRVLFM? 87-1 ]fCVCT 01-09/CT 08-03/CT 08-07/CP,Qlr03/pUQ Qg^/ljDf 01-QS/SDP 01-03/SPP 01- 04/V 08-02/CUP 04-18/CUP Q8-01/GIJP 08>O^CUP 08-03/GUP 08-04/CUP 08- 05/CUP Q8-06/CUP Q8>07 Dear Ms. Wood: •-..'... This letter is submitted on behalf of Norffii County Advocates in connection vwth tbi proposed La Costa Town Cehter project ("Project"). Please ensure, that copies of this letter are prpvided to aH Planning Commission members prior to their consideration of the Project at this Wednesday's meeting. MtKODVCTION ..-. ' ' Y\ . ' : '•. •.'•.''.-• . The California finvlroraftental Quality Act ("CEQA"), Pub, Res. Code §§.21000 - 21177, must be interpreted "so.as to afford the fullest possible protection to the environinent within the reasonable scope of the statutory language." friends of Mammofyy. Board of Supervisors, S.Cal. App. 3d247,.259 (1972). If-an EfR.fails to provide agency decision-makers and the public with all relevant information regarding a project that is necessary for informed decision-making and informed public participation, the EIR is legally deficient and the agency's decision must be set aside. Kings County Farm Bureau v. City of Hartford,. Ill Cai. App. 3d .692, 712 (1990). An EIR is "aptly described as the 'heart of CEQA"'; its purpose is to inform the public and its responsible officials of the environmental consequences before they are made. Laurel Heights ImprovementAssoc; v. University ofCalifornia,.4'J CaUd 37^; 392 (1988). Here, the Project's Envn-onmental Itqpact Report ("EIR") ifc inadequate. INADEQUATE X»I$CU$S1ON^FPROJECTIMPACTS The.EIR's discussionof land use impacts is insufficient. The Effi fails to discuss ' the difference in open space from that required by the La Costa Master Plan. COPY FROM :LftW QFFICESOF EUERETT DELflNO FAX NO. =7605101565 Jul. 14 2009 02:14PM P3 Comments re La Costa Town Square - . . July 14,2009 . . . ' . Page2of4 "• •. ..-..••'.. The EIR. fails to provide an adequate discussion of noise impacts. For example, the KIR acknowledges noise levels up to 78 dB, yet the. Noise.Elemerit in the City's General Plan limits noise to 60 dB. RIR at 5.4-13. The EIR incorrectly applies the standards for hillside protection in. the City's Hillside development Regulations, Among other things, the exclusion's from the .: regulations are narrow and there is inadequate support iri the EIR fot such exclusions. Municipal Code §§ 21.95.130(A)(1) & (2)!. Additionally, written findings^ required to justify the volumes prpposcd, yet there is no discussion of these requirBments. Municipal Code.§ 21.9542Q(D)(4). Indeed, there is no discussion of other required findings, of the . hillside development regulations. See id. §21.95.090. • ,." .. INADEQUATE DISCUSSldN OF AflTlGATION "The core of an EIR is .the mitigation arid alternatives section.,.. 'The purpose of an |TBIR] is to identify the .significant effects-of A'project pn the eftykonm'ent, ta. . identify alternatives.!*) the-.project, and to indicate the manner iri .which those significant effects can be mitigated, or avoided."* Qltens ofGoleta Valley v, Bctqfd of Supervisors of Santa Barbara County (1990) 52 Cal.3d 553,564 - 65 (quoting Pub,. Res. Code § 2100Zl(a)). Ratherthan addressing the^Project's ittip^s,the City has thrown upits. hands claiming that mitigation cannot be accomplished without adequate examination, of possible ways to accomplish h. For example, the ETR fails to provide mitigation for several traffic impacts. The California .Supreme Court has ruled; that an agency .may'not avoid analyzing and mitigating the impacts.of its project merely on the basis that it did not havetfie authority to address such impacts: . . _ t s or sewers be improved, the Trustees may do the work themselves on campus, butthey have no , authority to build toads or sewers off campus on:lan«3 that belongs to. others. Veitihe Trustees arcnotthereby excused fromtfe dirty to mitigate . : or avoid [the project's] ofif-campus effects on traffic or wtetewater management, because CEQA requires a public agency to mitigate or avoid its projects^ significant effects ripf. just on me .agency's own property but . "6n the environment", with "environment*' defined for, these purposes as • • tfthe physical conditions which exist within'^he area.which wUl'be affected ' by a proposed .prelect." . . '' '•'•' ' '.' City of Marina v.Bpard of Trustees of the California State Univ. (2006) 200639 Cal.4*. 341,360 (emphases in original) (citations omitted). Here, there is no .evidence the City is somehow precluded fgsan requiring some mitigation, even if, as the City clatrris, no program is currently-available to. implement certa?.rji measures. Indeed, the City did not . even eval uate effprts it. could undertake within its jurisdiction) such as synchronising. traffic tights, Additionally, the proposed findings do not provide adequate reasons not to require mitigation for such impacts. Similarly, the EIR fails to provide further mitigation for air quality or for noise impacts. FROM :LftU OFFICESOF EUERETT DELftNO FAX NO. :7505101565 Jul. 14 2009 02:15FM P4. Comments re La Costa Town Square July 14, 2009 PageS of4 • • " y-' • • • - . '; ., Acliiitionally, ttxc EIR's discussion of blasting iniugatiojri. is insufficient . Informing purchasers at the time of escrow will do nothing to mitigation impacts associated with blasting. There is no discussion about possible 'mitigation, such as pre- blasting and post-blasting inspections .and reporting, early warning and damage prevention procedures, and/or insurance requirements associated with blasting. The EIR also illegally defers mitigation. Measure N-6 requires interior noise study but.does not say when, or what is to be done if noise exceeds applicable standards. • *• »-,The EIR foils to discuss reasonable: and feasible mitigation for potential flooding . impacts, such as requiring that structures are not placed within the potential flooding zone and requiring an early warning system should flooding appear likely or imminent The EIR fails to discuss possible solar panels and other ways in which. to mitigate greenhouse gas emissions. ''.'•' ' INADEQUATE ALTERNATIVES ANALYSIS CJBQA requires that an EIR "produce information sufficient ;to permit a . reasonable choice of alternatives' so jkr as environmental aspects are concerned" . San . Bernardino Valley Audub&n Society v,. County of San fiernardirfc? (1 984) 155 CaLApp.3d 738, 750 - 51. Mf rjhe discussion of qlternatiyes shall focus on alternatives to. the project or its location which are capable of avoiding or substantially, lessening any significant effects of the project, even if these alternatives would impede to some degree the . attainment of .the project objectives, or Would be more costly," CEQA Guidelines § 1 5 1 26.6(b), "Without meaningful analysis of alternatives in the SIR,, neither the courts. nor 'the public can fulfill their proper roles in the CEQA. process." .laurel tielghis Improvement ASSOC..V. Untversityof California Here, the Project and its objectives are defined too narrowly,. thereby resulting in . a nan'pwing of the cohsiderattori of alternatives to the Project .See Rural Landowners Assoc, v. City Council '(19*3) 143'CaLApp;3d 1013, 1024 C'Rcsponsibility for .a project cannot be -avoided merely by limiting the title or deSscnplioji of Ilie project"). For example, the EIR.rejects alternatives that are all listed as enwfonmentalty superior roei^ly because they supposedly do not meet certiath objectives. ' . . . CBQA contains a "substantive mandate*' thai agencies jefrain from approving a prefect with significant environmental effects if 'Ihere are.fea^ible alternaftves or mitigation measures" that can substantially lessen or .avoid those .effects. ; Mountain Lion Foundation v. Fish and Qame Camm. (1997) 160.01,4*105, 1.34; Fub,Res...Code § 21002. It "requires public agenciejsto deny ajpproval of a project with significant adverse effects when feasible alternatives or 'feasible uutigatibn measures can substantially lessen s^ich .effects." Sierra Club v. .Gilrcy (1 990) 222 Cal.App.3d -30, : 41 , "The City ]T^S not provided findings supported by substJintiai. evidence in the record that. environmentally superior .alternatives and mitigation are infeasible or hnpracticablc. .FROMJLRU OFFICESDF EUERETT DELflNO FflX NO. :7G05101SG5 • Jul. 14 2009 02:15PM P5 Comments re l^Cbsto Town Square ' . . July 14,2009 ' . . . '. Page 4 of4 .••".'.. Pacific Corp. v. City ofCamarilIof(19W) 149 Cal.App.3d 168,178. the EJRprovides only cursory rejections of environmentally superior alternatives without supporting analysis. ' • . . - . NEED.TO RECIRCULATE THE ETR The EIR is sufficiently lacking that.tihe only way to fix these issues is to revise it and rccirculatc an adequate report, . . . CONCLUSION , For the foregoing reasons* North County Advocates requests that the City reject' the Project and the EIR. Tf you have a question or need additional inforination., please . contact me. . ' • • Thank you for your consideration of these comments, . . Sincerely, Everett t)eLano SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 21 Exhibit 2 Executive Summary of Responses to North County Advocates' Objections 1. Land Use Impacts - No conflict with Open Space plans * The EIR specifically discusses the differences in open space between the La Costa Master Plan and illustrates them in Figures 5.1-3a and 5.1-3b. * The Project proposes to increase the total open space proposed in the La Costa Master Plan from 4.4 acres to 5.6 acres. Increasing the planned open space areas reduces environmental impacts and does not cause increases in impacts that are in conflict with the La Costa Master Plan. * The Project proposes to amend the applicable plans concurrent with the approvals so there is no technical or legal conflict. 2. Noise Impacts - EIR correctly applies the City's Noise Regulations. * NCA misapplies the General Plan's Noise Element Standard. The 60 dBA limit applies to residential areas, not commercial areas. * Mitigation Measure N-b reduce noise impacts to the Project's residential areas through the construction of noise barriers separating the proposed residential units from the traffic noise on Rancho Santa Fe Road. 3. Hillside Development Regulations - EIR correctly applies the Hillside Development Regulations * NCA's claim that the City does not have findings to support the Project's Hillside Development Permit is not correct. The findings are contained in the resolution to approve the Hillside Development Permit (HDP 01-05) and the CEQA Findings on the Project's visual impacts which detail the exact reasons why the Project satisfies the Hillside Development Regulations, its exclusions and modifications. * NCA also misapplies the Hillside Development Regulations by trying to apply them to the non-residential portions of the project, which the City Council specifically exempted all non- residential project from the regulations limitations on quantity of fill and slope height. * The City did not zone the Project site for large amounts of open space with views of the hillside. The City's large open space tracts are created through the City's Habitat Conservation Plan. This area is zoned for commercial use and incorporates contour grading and landscaping SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 22 techniques to mitigate the visual impacts of manufactures slopes necessary to accommodate the commercial center and its parking lot. 4. Traffic - EIR mitigates traffic impacts to the maximum extent feasible within the City's authority to act. * NCA improperly alleges that the Project fails to evaluate all feasible traffic mitigation because there are traffic impacts on roads outside of the City's jurisdiction. The reason why it is not feasible for the City to impose traffic mitigation requirements on the Project for these extra- territorial road improvements is because the City has no legal authority to require Encinitas, San Marcos or Caltrans to make improvements in their respective right-of-ways. Only those public agencies can control what projects are put in their Capital Improvement Plans. Requiring the Project to pay a fair share contribution to build road improvements that other jurisdictions have no intention of constructing only serves to divert resources away from mitigating Project impacts that can be mitigated. * NCA is incorrect that the EIR fails to analyze traffic signal synchronization as a mitigation option. The EIR actually requires the Project to synchronize traffic signals. 5. Air Quality - EIR's mitigation of Carbon Monoxide and Particulate Matter is appropriate. * The only feasible means to reduce the Project's Carbon Monoxide and Particulate Matter emissions is to reduce the size of the shopping center by 86%. This would significantly reduce the sales tax revenue that would be generated from the property. In addition to creating budget challenges for the City, such a reduction would make it difficult to finance the public infrastructure in the La Costa Master Plan because the City's public facilities plan assumed the property would contain a substantial amount of commercial square footage that would generate payment of development impact fees into the City's plan. Planned public safety services, parks, libraries, and transportation improvements would not be fulfilled without revenue from new sources, for which excess City revenue is not available. * The Project represents smart growth. It is a well-balanced mixed use project designed to allow residents to live, work, and shop in the same area without driving. Without such projects, existing residents will have to drive farther to find ample, attractive shopping, which would worsen air quality. 6. Interior Noise Levels — EIR's mitigation of Interior Noise levels to 45 dBA is appropriate. * The City sets an appropriate interior noise standard of 45 dBA. The reason why interior noise studies are required to be performed after the approval is that the design of the SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 23 building, number of window, etc. all affect the interior noise levels. The design of the buildings are not known at the entitlement approval stage. Therefore, like all jurisdictions, the City sets a noise level that the applicant must achieve once the building design is known. If the noise level cannot be achieved, then the applicant cannot construct a two-story structure at those locations or must change its design. 7. Blasting Impacts ~ EIR's mitigation of Blasting Impacts is appropriate. NCA misstates all the steps the Project must follow to mitigate impacts from Blasting. In truth, the Project must: * Use a portable sound wall to reduce noise in the direction of noise sensitive areas; * Provide door hangers and letter notification to area homeowners about the potential noise and vibration impacts including the estimated frequency of the blasts, a contact number for complaints, etc. * Perform pre-blast inspections of homes in the area followed by post-blast inspections when a complaint of damage is received. * Use a contractor who must post a Certificate of Insurance covering $1,000,000 for property damage and $1,000,000 for bodily injury for each occurrence. 8. Flooding Impacts - EIR's mitigation of Flooding impacts is appropriate. * The Project's flooding report demonstrates very minor flood levels in the event the Stanley A. Mahr Dam were to fail. The flood levels do not pose a risk to human health. Property damage is also minimal through construction of street walls and proposed grading. * Nevertheless, it is appropriate to require notification of these risks to potential homebuyers through the CC&Rs so that proper insurance can be obtained to mitigate property damage. * The flooding risks are not substantial enough to merit prohibiting home construction in this area as NCA suggests and CEQA does not allow the City to reduce the number of residential units as a mitigation measure when other mitigation options are available. 9. Greenhouse Gas Emissions - EIR's analysis of GHG impacts is appropriate. * Regulation of GHG is currently in its preliminary phases. Under state law, the California Air Resources Board ("CARB") is required to establish final regulations by January 1, 2011 that must go into effect by January 1, 2012. In the meantime, California's Office of SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7,2009 Page 24 Planning and Research ("OPR") advises that "[i]n the absence of regulatory standards for GHG emissions or other scientific data to clearly define what constitutes a 'significant impact', individual lead agencies may undertake aproject-by-project analysis, consistent with available guidance and current CEQA practice." (CARD 2008; emphasis added). Current CEQA practice includes CEQA Guidelines § 15145, which states, "[i]f, after thorough investigation, a lead agency finds that a particular impact is too speculative for evaluation, the agency should note its conclusion and terminate discussion of the impact." Because OPR and CARS have stated that the scientific knowledge is "rudimentary and still evolving" and that the quantification models are rapidly changing it is reasonable for the City to conclude after 21 pages of thorough investigation in the EIR that GHG impacts are too speculative for evaluation. * The City is legally entitled to rely on the expert opinions of its environmental consultant, ED AW, Inc., who after a review of the available scientific evidence has also concluded that it is too speculative at this time to know the GHG impacts of a project, the proper threshold of significance, or measure the effectiveness of proposed mitigation measures. * Specifically with regards to solar technology, the Project's mitigation includes installation of solar panels on carports and infrastructure to make the commercial, residential, and office structures solar-ready. Furthermore, the City Attorney concluded that the City lacked the legal authority to impose solar panel installation as a Project condition because there is no City ordinance or building code requiring installation of solar panels and CEQA does not grant the City independent authority to impose mitigation measures. (PRC § 21004). * Other important points for the City Council to consider include the following: * The Project is a well-balanced, mixed use development designed to reduce vehicle use because residents can live, work, recreate and shop in the same area without driving and vehicle sources are the largest contributor of GHG emissions in California. * The Project is consistent with "early action" guidance from the state regulatory authorities that cities should focus land use decisions on such mixed use developments. * As new state and federal regulations come into effect to control GHG emissions, the Project will need to comply because the City's approval gives the Project no vested right to develop in conflict with new state or federal regulations. 10. Project Alternatives * The EIR analyzes a proper range of alternatives for the Project and the City is entitled to reject proposed alternatives on the grounds that the fail to either: SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 25 * Provide adequate vacant space for a commercial and mixed use shopping center; * Strengthen or diversify the City's tax base; * Provide an area available to the surrounding community that fulfills daily shopping needs and minimizing local trips; * Conform to the La Costa Master Plan designation of the site for commercial development; * Provide an attractive, well- balanced residential area with a range of housing types, styles and price levels; or * Conform to the Master Plan and General Plan's vision of low- medium residential development of the site. * The EIR provides more analysis of the Project's alternatives than Courts have said is required by CEQA. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 26 Exhibit 3 EDAW. Inc. Letter Dated July 15.2009 Responding to NCA Objections EDAW AECOM EDAW Inc 1420 Keftner Boulevard, Sutte 500, San Diego, California 92101 T 619.233.1454 F 619.233.0952 www.edaw.com July 15, 2009 Mr. Van Lynch City of Carlsbad Planning Department 1635 Faraday Avenue Carlsbad, CA 92008 Dear Mr. Lynch, Subject: Letter from Law Offices of Everett L. DeLano III Re: La Costa Town Square EIR EDAW staff has reviewed the comments from Mr. DeLano, which concern perceived deficiencies in the La Costa Town Square EIR. A brief summary of each point raised by Mr. DeLano is provided below, followed by our response in relation to statements in the EIR or provisions of the California Environmental Quality Act (CEQA). "The EIR's discussion of land use impacts is insufficient The EIR fails fo discuss the difference in open space from that required by the La Costa Master Plan." Response: The open space design of the La Costa Master Plan and the project is described on page 5.1.9 of the EIR and illustrated in Figure 5.1-3a. The figure shows that the Master Plan includes a total of 4.4 acres of open space and the project proposes approximately 5.6 acres of open space. Therefore, the project is in compliance with the Master Plan. Page 2 "The EIR fails to provide an adequate discussion of noise impacts." Response: Page 5.4-13 of the EIR describes the results of off-site traffic noise modeling shown in Table 5.4-6 and states that an increase in noise level by 3 dBA or less would be less than significant if it occurs where the existing noise level exceeds the 60 dBA threshold. The only location where 3 dBA is exceeded is at a commercial driveway on La Costa Avenue east of Rancho Santa Fe Road ana, because commercial use Is not a noise sensitive land use, the impact at this location is less than significant "The EIR incorrectly applies the standards for hillside protection in the City's Hillside Development Regulations." Response: Consistency with the Hillside Development Regulations is evaluated on page 5.1-20 of the EIR and describes the locations where grading standards are exceeded. The Hillside Development Regulations allow the applicant to request modification of the grading standards and provide justification for consideration by the City Council. Unusual circumstances of the site are described on pages 5.1-20 and -2J of the EIR. on page 19 nf.fho gtgff "f™* and on page 16 of the "Candidate Findings and Statement fif t^a"'Minfi rnnoMnraH^mt • The EIR concludes that no significant tencT use or visual aesthetics/grading impact would result from the proposed project grading. Mr. Van Lynch City of Carlsbad July 15, 2009 Page 2 "[T]he EIR fails to provide adequate mitigation for several traffic impacts ... [t]he California Supreme Court has ruled that an agency may not avoid analyzing and mitigating the impacts of its project merely on the basis that it did not have the authority to address such impacts." Response: The EIR does not avoid the responsibility to analyze traffic impacts in areas where the City has no authority to mitigate the impact, specifically within the cities of San Marcos and Encinitas and within Cattrans' I-5 right-of-way. Table 5.2-20 of the EIR provides the results of traffic analysis conducted on arterials outside Carlsbad that the project's traffic would impact; and Table 5.2-19 analyzes project impacts on I-5 segments. The I-5 segments are currently operating at LOS F and most of the San Marcos and Encinitas segments impacted by the project are projected to operate at LOS E or F without the project in year 2030. In addition, Table 5.2-26 Identifies improvements needed to reduce or mitigate project impacts to facilities within these jurisdictions. Lacking the statutory authority to accomplish these improvements, CEQA Section 15091(a)(2) allows the City to find that mitigation is "within the responsibility and jurisdiction of another public agency." Facts supporting this finding are on pages 26-28of the "Candidate Findings and Statement of Overriding Considerations." "Similarly, the EIR fails to provide further mitigation for air quality or for noise impacts." Response: Air Quality - The project's significant impact of CO and PM10 emissions results from commercial traffic. Draft findings on page 38 of the "Candidate Findings and Statement of Overriding Considerations" state that avoiding significant CO and PM10 emissions impacts would require reducing vehicle use from 25,516 ADT to 6,000 ADT. This level of mitigation would not be feasible. Noise - The only noise impact not fully mitigated is from blasting; and mitigation measures to reduce drilling and blasting impacts are provided on pages 5.4-16 and -17 of the EIR. Draft Findings are provided on page 39 of the "Candidate Findings and Statement of Overriding Considerations" of why it would not be feasible to fully mitigate noise impacts from blasting. Page 3 "[T]he EIR's discussion of blasting mitigation is insufficient Informing purchasers at the time of escrow will do nothing to mitigate impacts associated with blasting." Response: The letter Incorrectly states that "informing purchasers at time of escrow* is proposed. Mitigation measures on page 5.4-1 6 and -1 7 of the EIR for impacts to existing residences are: N-1 Portable sound wall during drilling N-2 Notification prior to commencement of blasting "The EIR also illegally defers mitigation. Measure N-6 requires Interior noise study but does not say when or what is to be done if noise exceeds applicable standards." Response: Mitigation Measure N-6 (EIR page 5.4-17} requires that studies be conducted to demonstrate adequate noise attenuation if two-story dwellings are proposed to be built within the project on lots 34 through 48 adjacent to Rancho Santa Fe Road. The proposed project's conditions of approval require that this study be conducted prior to building permit issuance for homes on these tots. "The EIR fails to discuss reasonable and feasible mitigation for potential flooding impacts ..." Response: Mitigation Measure H-1 on EIR page 5.9-14 for potential flooding from dam failure is the same as was required for the adjacent development east of Camlno de los Coches. EDAW AECOM r Mr. Van Lynch City of Carlsbad July 15, 2009 Pages "The EIR fails to discuss possible solar panels and other ways in which to mitigate greenhouse gas emissions.' Response: Mitigation measures to reduce greenhouse gas emissions are provided on EIR pages 6-27 through 6-30 and include use of solar panels and other feasible methods that would be considered for inclusion in project plans during each phase of project development, "Inadequate Alternatives Analysis" Response: Mitigation of all project impacts would require adoption of the No Commercial Development alternative that was rejected as infeasible because "it does not meet several core objectives of the project..." (see EIR page 7-5). CEQA Guidelines Section 15126.6 states that "...the EIR need examine in detail only the [alternatives] that the lead agency determines could feasibly obtain most of the baste objectives of the project." Deletion of the commercial component would not meet the project's basic objectives. Of the alternatives analyzed in detail, the environmentally superior alternative is identified as Biological Open Space alternative, which is analyzed on pages 7-12 through 7-16 of the EIR and would replace the single-family neighborhood with biological open space. The analysis concludes that "development according to this alternative would not meet certain basic objectives of the proposed project The Alternative ... project would not increase the City's tax base for residential uses as much as the proposed project, and would offer a lesser range of housing types, styles and price levels." Yours sincerely, Jerry McLees, AICP Senior Environmental Planner EDAVV AECOM SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 27 Exhibit 4 GHG-Related Air Quality Mitigation Measures (EIR pp. 6-27 and 6-28) A. Energy Efficiency 1. Install efficient lighting and light control systems. Site and design buildings to take advantage of daylight. 2. Use trees, landscaping and sun screens on the west and south exterior walls to reduce energy use. 3. Install light colored "cool" roofs, cool pavements where appropriate, and strategically placed shade trees. 4. Provide information on energy management services for large energy users. 5. Install energy efficient heating and cooling systems, appliances and equipment, and control systems. 6. Limit the hours of operation of outdoor lighting, except where infeasible for security reasons. 7. Use solar heating, automatic covers, and efficient pumps and motors for pools and spas at the residential development. 8. Provide education on energy efficiency. B. Renewable Energy 1. Educate consumers about existing incentives for renewable energy. 2. Install solar panels on carports. C. Water Conservation and Efficiency 1. Create water efficient landscapes with native, drought-resistant species. 2. Install water-efficient irrigation systems and devices, such as soil moisture- based irrigation controls. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 28 3. Use reclaimed water for landscape irrigation. Install the infrastructure to deliver and use reclaimed water. 4. Design buildings to be water-efficient. Install water-efficient fixtures and appliances. 5. Restrict watering methods (e.g., prohibit systems that apply water to non- vegetated surfaces) and control runoff. 6. Restrict the use of water for cleaning outdoor surfaces and vehicles. 7. Implement low-impact development practices that maintain the existing hydrologic character of the site to manage storm water and protect the environment. 8. Devise a comprehensive water conservation strategy appropriate for the project and location. The strategy may include many of the specific items listed above, plus other innovative measures that are appropriate to the proposed project. 9. Provide education about water conservation and available programs and incentives. D. Solid Waste Measures 1. Reuse and recycle construction and demolition waste (including, but not limited to, soil, vegetation, concrete, lumber, metal and cardboard). 2. Provide interior and exterior storage areas for recyclables and green waste and adequate recycling containers located in public areas. 3. Provide education and publicity about reducing waste and available recycling services. E. Transportation and Motor Vehicles 1. Limit idling time for commercial vehicles, including delivery and construction vehicles through the following measures - signage and provision of power outlets for every two dock doors. Install signs prohibiting diesel truck from idling for more than SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 29 five minutes and requiring them to connect to the power outlet to run any auxiliary equipment. 2. Use electric or natural gas equipment at the loading docks. 3. Promote ride sharing programs with future tenants e.g., by designating a certain percentage of parking spaced for ride sharing vehicles, designating adequate passenger loading and unloading and waiting areas for ride sharing vehicles, and providing a web site or message board for coordinating rides. 4. Create car sharing programs. Accommodations for such program include providing parking spaces for the car share vehicles at convenient locations accessible by public transportation. 5. Provide the necessary facilities and infrastructure to encourage the use of low or zero- emission vehicles (e.g, electric vehicle charging facilities). 6. Incorporate bicycle lanes and routes into residential street systems. 7. Incorporate bicycle-friendly intersections into street design. 8. For commercial development, provide adequate bicycle parking to promote cyclist safety, security, and convenience. 9. Create bicycle lanes and walking paths directed to the location of schools, parks, and other destination points. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 30 Exhibit 5 City of Carlsbad Blasting Policy BLASTING PERMIT Applicable City Policy: Engineering Department Policy 15 PERMIT REQUIRED A blasting permit is required when any blasting operations will occur on a site. GENERAL GUIDELINES 1. No blasting operation shall be performed without a valid blasting permit. 2. Blasting permits will be issued only to qualified blasters. Qualified blasters must present the City with a valid Blasters License issued by the State of California Division of Occupational Safety and Health. See Exhibit 1. 3. Application for a blasting permit is required after issuance of the grading permit and before blasting operations occur. 4. The permit is a "NO-FEE" permit. 5. The Blasting Contractor must provide the City with a Certificate of Insurance, from an acceptable insurance company, naming the City of Carlsbad as additionally insured. The minimum amount of coverage is $1,000,000.00 for property damage and $1,000,000.00 for bodily injury for each occurrence. See Exhibit 2. 6. The blasting contractor is responsible for the notification of residences within 600 feet. 7. The blasting contractor is responsible for the notification of the City's Police and Fire Departments. 8. Preblast inspection and report of all structures within 300 feet of the blast site is required prior to the start of work. Copies of the Preblast Report may-be required by the City Engineer. 9. Post-blast inspections may be required if a written complaint of property damage is received. 10. Major blasting operations require seismograph monitoring. 11. Blasting is permitted only between the hours of 9:00 am and 4:00 pm, Monday through Friday, excluding City observed holidays. 12. A Right of Way Permit is required when blasting operations temporarily stop or reroute traffic. 13. For detailed information on the above items, please review the attached Engineering Department Policy 15. Development Processing Procedures/Counter Services Section 1: Blasting Permit Revised 5/2001 ( PROCESSING PROCEDURES: Permit Authorization and issuance 1. What to submit: A. Completed Blasting Permit Application. B. A copy of the Blaster's License (from the State of California Division of Occupational Safety and Health) for all blaster's which may be performing blasting operations on the site. C. A copy of the valid San Diego County Sheriffs Department Explosive Permit. D. Certificate of Insurance naming the City of Carlsbad as additionally insured. The minimum amount of coverage is $1,000,000.00 for property damage and $1,000,000.00 for bodily injury per each occurrence. All required insurance must be underwritten by an insurance company listed in the latest edition of Best's Rating Guide with a rating of "A-" or better and a financial size of $10 million (currently Class V) or better. ,---.. 8. The Engineering Technician will contact the applicant to let them know the permit (_ has been issued and a copy of the permit is available for them to pick up. 9. The permit and file are forwarded to the Inspection Division. 10. The Construction Inspector will set up a pre-construction meeting with the contractor within 2 working days after the approved and issued permit is received in the Inspection Division. Denial or Revocation of Blasting Permit 1. A blasting permit may be denied by the City Engineer if, in his opinion, the proposed blasting operation constitutes a hazard to the public. 2. The City Engineer may revoke a blasting permit issued to any blaster who, in the opinion of the City Engineer, has: A. conducted or been responsible for careless or reckless blasting operations, B. failed to observe any standard safety orders or other applicable rules and regulations, C. failed to adhere to any provision of the blasting policy or permit. ( ' *V . Development Processing Procedures/Counter Services Section 1: Blasting Permit Revised 5/2001 CITY OF CARLSBAD SUBMITTAL CHECKLIST BLASTING PERMIT CITY PROJECT NUMBER gL CITY PROJECT NAME GRADING PERMIT NUMBER PE CITY PLANCHECKER _ GRADING PLAN DWG NO. 1. Completed Blasting Permit Application Form. Note: A Valid Carlsbad Business License is required. 2. Copy of the Blaster's License (from the State of California Division of Occupational Safety and Health) for all Blaster's which may be performing blasting operations on the site. 3. A copy of the valid San Diego County Sheriff's Department Explosive Permit 4. Certificate of Insurance naming the City of Carlsbad as Additionally insured. The minimum amount of coverage is $1,000,000.00 for property damage and $1,000,000.00 for bodily injury per each occurrence. SUBMITTAL COMPLETE. CHECKED BY: DATE: COMMENTS- P:\DOCS\CHKLSmCHK-13 • REV 01/1004 o CITY OF CARLSBAD - ENGINEERING DEPARTMENT APPLICATION BLASTING PERMIT APPLICATION PROJECT NO.PROJECT NAME NAME OF APPLICANT: BUSINESS ADDRESS: BUSINESS PHONE NO.: EMERGENCY PHONE NO.: BLASTERS LICENSE NO.: INSURANCE RATING AND EXPIRATION DATE: VERIFIED BY:. VERIFIED BY: VERIFIED BY: DESCRIBE BLASTING OPERATION BELOW GIVING DISTANCE TO NEAREST STRUCTURE, APPROXIMATE YARDAGE TO BE BLASTED, ANTICIPATED NUMBER OF SHOTS, MAXIMUM NUMBER OF HOLES AND TOTAL MAXIMUM WEIGHT OF CHARGE PER SHOT, AND DATES OF BLASTING OPERATION. G I HAVE READ AND UNDERSTAND THE CITY OF CARLSBAD ENGINEERING DEPARTMENTS BLASTING POLICY AND AGREE TO ABIDE BY ITS PROVISIONS. SIGNATURE OF APPLICANT DATE P:\DOCS\MISFORMS\FRM00066 BEV 01/0493 SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 7, 2009 Page 31 Exhibit 6 San Diego Greenhouse Gas Inventory: an analysis of regional emissions and strategies to achieve AB 32 targets (EPIC September 2008) September 2008 I Executive Summary San Diego County Greenhouse Gas Inventory r An Analysis of Regional Emissions and Scott Jf. Director.: Policy Initiatives Center, University of San PiVgo Sctowl Associate Ptnfessor af Chemistry Ihm-t't'sity afSan&Kgff Senior Policy Analyst, Energy Policy to"fM4ivi>s Center. I !mvr rsitv «>| S«it IJrrgo Sean T, Tanaka £~«f rgy and Envii end CoftsttftiKg \ Lauren Tyncr -2008 Graduate L Remirck Sdtrdtrnrisi! uml i'tigim-cr, T«naft« Rts«mh / Srra Diego, C&enmtry «H<| Biochemistry Acknowledgements : 1 his project could riot haft* happened1 without the generous support, of .the Sdit Diego FottridiJiton, San Diego Association of (>overnnienis and NRG Energy, Inc. The authors would. like to thank the following. judividHals (iisicd »tphah«ttal!y by organization) for their help in pwvldingdato, reviewing drafts and pi^vitting insightful 'comments, and for their advtcc and ctmnsel during the project: Andy Alexis, Nkolc Etefegy, Kevin islirsgcr, Larry Hunsakcr, Karen Latter, Ben Mcwtova, Webster Tasat and Walter Wong of the CaHfornki Air Resources Board (C ARB); Andrea Cook of the California Center far Sustainable tenergf? CCCSC); Al Alvarsido, Gerry Bemfe and Tom Gorin of the California Energy Commission (CEC); Judith IrkM and Scott Murtishaw of the California Public lHiIitl.es Commission (CPUO; John fheroux of the City of San Diego; Wayne Spencer of the Comcrvation Bktlogy Institute; Niichelfe White, Dave Carey and Darren Correiaof the IPbrt of San Wegcn Albert Mar of the San Di«|p Air Polluiion Control District (AFCD): Ko&crf- Anderson, David Barker and Gregory K. Katwpis of Saw Diego Gas & Electric ISDC.»&E); Anne Frge tind Exequte! Ezciirra 'of the San Dirgo Natural- History MM.SCWOI; Ted Aniasisk Phil Bracawonte and Nelson Kelly of the San Diego Regional Airport Amhciriiy: Melissa Porter of the Couat| of:$a» Diego, Solid Waste ^txital Enforcement Agency; and Steve Mcssner arsct Joint W^^ierman ol Sdcttce tetemiitkmal Corporation (SAIC), We wxnili! ,ib«» like t0 rhanlk Merry Miti.sc'f »>f Sbprw«t»d A%mriales, our project editor, to ibis it f:or tin rfrcirotiif; >,vfn of tmi Diego Grcrnhouse Gxx. Inventory prc»|cci, go in <>vww, •1 1 Table of Contents Key Findings Report Overvicw Greenhouse Gas Emissions in San Diego County Emission* Projections Regional Greenhouse Gas Emissions by Gucgorv , Emissions Irorn Cars and Trucks Emissions from Electricity Use Emissions Irorn Natural Gas Etui-use. Sequestration and Wildfires Emissions Reduction Targets ............. 6 ............. 8 10 10 II Red net ion St rategies—Wedges - - I Conclusion.. |: Figures _________________________________ ________ San Diego County and California GHG Emissions ...... . .................. 3 2006 San Diego County GHG Emissions by IPCC Category .......... 4 2006 San Diego County GHG Emissions by Economic Sector ....... 4 Comparison of Total and Pel-capita Emissions San Diego County ......................................................................... 5 Total GHG Emissions lor San Diego County (J 990-2020) ............. 5 San Diego County GHG Emissions by Category (2006) ................. 6 Top 10 GHG Emitting Subcaiegories San Diego County (2006) .............................................................. 8 GHG Emissions from Passenger Vehicles and Light-duty Trucks. San Diego County ........................................... 8 On -Road Transportation GHG Emissions by Vehicle. Type San Diego County (2006^ .............................................................. 9 Electricity GHG Emissions by Subcategory San Diego County (2006) .............................................................. 0 Natural Gas End-use Emissions by Sector San Diego County (2006) ............................................................ 10 Total GHG Sources and Sinks in San Diego County ..................... 10 Theoretical GHG Reduction Targets lor San Diego County .......... I 1 Emissions Reduction Wedges by Sector. San Diego County ......... 12 Emissions Reduction Strategies lor San Diego Counsy to Meet Hypothetical AB 32 Targets by 2020 .............................. 14 Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figure 8 Figure 9 Figure 10 Figure 1 1 Figure 12 Figure 1.3 Figure 14 Figure 15 Listof Tables Table 1 Emissions Inventory Categories Table 2 Emissions Reduction Wedges to Achieve AB 12 Targets Table .3 San Diego County GHG Inventory and Emissions Projections I San Diego County emitted 34 million metric tons of carbon dioxide equivalent (MMT CO,E) in 2006 - an 18% increase over 1990 levels, commensurate with population growth during the same period. tn 2006, per-capita emissions for San Diego County were 12 metric tons CO,E, which is slightly lower than California as a whole (13) and significantly lower than the U S levels (24). In 2006, emissions from cars and light-duty trucks represented 46% of total greenhouse gas emissions in San Diego County. By 2020, under a business-as-usual scenario, regional greenhouse gas emissions are expected to be 43 MMT CO2E, an increase of 9 MMT CO_,E (26%) over 2006 levels and 14 MMT CO2E (48%) over 1990 levels. To meet AB 32 emissions reduction targets (1990 levels by 2020), San Diego County would have to reduce emissions by 14 MMT CO2E (33%) below projected business- as-usual levels in 2020. Nearly 60% of total regional emissions are associated with individuals (e.g., passenger vehicles, light-duty trucks, residential electricity and natural gas consumption). San Diego County likely can reduce its greenhouse gas emissions to 1990 levels by 2020 through a combination of reduction strategies from all sectors. This study estimates that through a combination of 21 strategies, the region could reduce its emissions by 15 MMT CO2E by 2020, more than the quantity required to reach 1990 levels. In the scenario above, reductions from the on-road transportation sector (7 MMT CO E) and the electricity sector (5 MMT CO,E) represent 81 % of total reductions. Two statewide policies would account for 41 % of these greenhouse gas emissions reductions. Implementing the Pavely (AB 1493) vehicle emissions standards by 2020 would reduce emissions by just over 3 MMT CO2E, 21 % of total reductions, and implementing a 33% renewable portfolio standard by 2020 would reduce emissions by 3 MMTC02E, 19% of total reductions. iptt^ ^gj^v__ jff This study developed a greenhouse gas inventory for San Diego County to better understand the emissions sources in the region and to serve as a resource for local and regional decision makers as they consider ways to reduce emissions at the local and regional levels. To that end, the project team calculated historical greenhouse gas emissions from 1990 to 2006 using the best available data, and then estimated future emissions to 2020 for San Diego County. Using emissions reduction targets codified in California's Global Warming Solutions Act of 2006 (AB 32) as a guide, the study also sought to establish emissions reductions targets for the region. Although AB 32 does not require individual sectors or jurisdictions (e.g., cities and counties) to reduce emissions """"Si! , by a specific amount, the study calculated the theoretical emissions reductions necessary in each emissions category (e.g., transportation, electricity, etc.) for San Diego County to reduce emissions to 1990 levels by 2020— the statewide statutory target under AB 32. Finally, the study sought to identify and quantify potential emissions reduction strategies to determine the feasibility of reducing emissions to 1990 levels by 2020. To the extent possible, the study followed the same calculation methodology used by the California Air Resources Board (CARB) to develop the statewide greenhouse gas inventory. In some instances, when doing so could yield a more accurate or precise result, the project modified the CARB method. This summary report is intended as an overview of the findings from the inventory, and no discussion of method is included. It provides information about the total greenhouse gas emissions for San Diego County and a summary of the highest emitting categories, including on-road transportation, electricity, and natural gas end-use consumption. It also gives an overview of the emissions reduction strategy analysis for each category of the inventory. Detailed analysis for each emissions category', including emissions levels, emissions reduction strategies (wedges), and detailed methodologies for calculating emissions are provided in eight supplemental reports available for download on the Energy Policy Initiatives Center Web site. ! In 2006 San Diego County emitted 34 million metric tons of carbon dioxide equivalent (MMT CO2E), an increase of 5 MMT CO^E (18%) over 1990 level emissions/ This increase is commensurate with growth in regional population, which increased at the same rate during this period. Statewide emissions grew at rate of about 12% during this same period. Though this is slightly lower, the general trends have been similar. Figure 1 shows San Diego County and California statewide greenhouse gas emissions from 1990 through 2006. Note that 2003 emissions are significantly higher due to the wildfires in San Diego County that year. Figure 1. San Dtego County and California GHG Emlssisons 600 1990 1992 1994 1996 19%2000 2001 W04 2006 Greenhouse gas emissions in San Diego County are primarily the result of energy use, 91% ol total emissions are associated with fuel use. Figure 2, compares emission's in the four principal categories established by the United Nations Intergovernmental Panel on Climate Change (IPCC). Dividing San Diego County- greenhouse gas emissions by economic sectors, as shown in Figure 3, reveals that the residential sector is responsible for more than half of all San Diego County emissions. When aggregated, the impact of individual actions on San Diego County's regional greenhouse gas levels is significant. The combination of passenger vehicles, light- duty trucks, residential electricity use, and natural gas consumption accounts for about 19 MMT CO2E, or 56% of total emissions. These are the sectors for which residential data are readily available, and it assumes that all light-duty trucks are used by individuals rather than by the commercial or industrial sectors.1 It is possible that a portion of passenger vehicles and light-duty trucks are used for commercial and industrial purposes, which would lower this estimate, but it is also true that the portion of civil aviation and waste attributable to individuals would increase slightly the estimated impact of individuals."* BEST Figure 2. 2006 San Diego County GH6 Emissions by IPCC Category Industrial n-f 5% Agric, -Fore&fcy, and Land Use -,, 1.6% Figure 3. 2006 San Diego County GHG Emissions by Economic Sector Agriculture 1% tndusifiai Per-capita emissions for the San Diego region was 12 metric ions of CO,E in 2006 and has been basically flat since 1990; however, total emissions increased by 18%, as shown in Figure 4. It should be noted that while per-capita metrics are useful for comparing different geographical entities, total emissions is the most important metric, since the object of AB 32 and other similar polices is to reduce the absolute amount of greenhouse gases in the atmosphere. Figure 4. Comparision of Total and Per-Capita Emissions San Diego County 1.4 i 1990 1991 1992 1993 J994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 San Diego County GHG Emissions (Indexed to 1990) San Oiego Courtly GHG Emissions Per Capita {Indexed to 1990) Emissions Projections Given a business-as-usual trajectory, defined as no change in current trends or policies, greenhouse gas emissions from San Diego County will be approximately 43 MMT CO^E in 2020, a 26% increase over 2006 levels and a 48% increase over 1990 levels. Figure 5 shows the projected emissions levels under the business-as-usual scenario. Figure 5, Total GHG Emissions for San Diego County {1990-2020} 1990 1992 1994 1446 1498 2000 2902 2094 2006 2008 2010 2012 2014 2016 2018 2020 3 HiitotKii Emisstwr, IP wls a Projected Ermsskms UveK Regional Greenhouse Gas Emissions by Category While many different sources emit greenhouse gases in San Diego County, a few sources account lor the vast majority of emissions in San Dtego County. The on-road transportation category—comprising cars and trucks—is by far the largest contributor of greenhouse gas emissions in the region, accounting for 46% of the total, almost twice as much as the next largest sector. Electricity generation and natural gas combustion were the second (25%) and third (9%) highest emitting sectors. These top three categories emit 80% of total greenhouse gases in San Diego County. Civil aviation, mainly interstate flights from Lindbergh Field, is the fourth highest emitting category (5%). Given San Diego's economic make up, emissions associated with non-fuel industrial processes and product use (mainly refrigerants) are relatively small and represent just under 5% of emissions, slightly higher than the emissions from the other fuels/other category (4%), which includes the use of fuels such as propane, which are not captured in other categories of the inventory. Finally, off-road transportation and equipment activities, which include construction and mining equipment, pleasure boats, and some agricultural equipment, account for about 4% of the emissions.7 Figure 6 shows the breakdown of emissions by source. A detailed table of inventory results can be found on page 16 of this report. (Table 3) Figure 6. San Diego County GHG Emissions by Category (2006} OFF-ROAD EQUIPMENT AND VEHICLES 4% A6RCUI.TUHE/ f ORBTOWLAND USE HMOUSTBAt PROCESSES AMD PRODUCTS 5% Table 1 shows the emissions categories and subcategories included in the inventory. Table 1. Emissions inventory Cagetories AGRICULTURE Enteric Fermentation Manure CIVIL AVIATION Interstate flights intrastate Flights ELECTRICITY Residential Commercial industrial Mining Agricultural Telephone, communications, utilities (TCU) Street Lighting DEVELOPMENT Loss of farmland Loss of native vegetation INDUSTRIAL PROCESSES AND PRODUCTS HFC refrigerants Sulfur netafluoride Other NATURAL GAS END USES Residential Commercial Industrial Mining Agricultural OFF-ROAD EQUIPMENT AND VEHICLES Construction and Mining Equipment Pleasure Craft industrial Equipment Agriculture Equipment Other ON-ROAO TRANSPORTATION Passenger Vehicles Light-Duty Trucks Heavy-Duty Trucks and Vehicles Motorcycle OTHER FUELS/OTHER Manufacturing Transport Residential Commercial Non-Specified Agriculture Cogeneratfon Thermal Emissions RAIL TRANSPORTATION SEQUESTRATION FROM LAND COVER Forest growth Woodland growth Chaparral scrub, and grasslands WASTE Landfills Wastewater Treatment WATER-BORNE NAVIGATION Ocean Going Vessels (OGV) Harbor Craft WILDFIRES Forest Woodlands Chaparral, scrub, and grasslands Figure 7 shows the top 10 emitting subcategones in San Diego County in 2006. Light-duty trucks and passenger vehicles are the highest emitting subcategories by a wide margin in all years. In 2003, the year of the devastating wildfires, emissions from all fires were the single largest source of greenhouse gases in the region that year, totaling 8 MMT CO,E (20% of total emissions). Figure 7. Top 10 GHG Emitting Subcategories San Diego County (2006) light Duty Trucks 0«Xtrtcity • Commercial Efectritity • Residential Natural O*s - Residential Heavy Duty Tcticks CMI Aviation - Interstate Indimiral. HFC Refrigerants Neural Gas - Commercial Ete«ridty-TCU Emissions from Cars and Trucks In 2006, light-duty trucks accounted for just over 50% of total on-road emissions, while passenger vehicles accounted for nearly 38%. Emissions from passenger vehicles were higher than those from light-duty trucks until 2003, when light-duty trucks became the highest emitting vehicle type in San Diego County (Figure 8). Figure 9 shows the on-road greenhouse gas emissions in 2006 by vehicle type. Figure 8. GHG Emissions from Passenger Vehicles and Light Duty Trucks, San Diego County 1990 1992 1994 !9% 1998 2000 2002 2004 2006 2008 2010 20)2 2014 2016 2018 2620 """—PassengerVWwcles Light Duty Trucks x Figure 9, On Road Transportation GHG Emissions by Vehicle Type, San Diego County 2006 Heavy-Duty Tnicteand Vehicles 0,4% By 2020, greenhouse gas emissions from on-road vehicles are expected to reach 19 MMTCO.E, a 21% increase over 2006 levels. Light-duly trucks are expected to continue to be the largest emitter among the vehicle classes representing nearly 50% of all emissions from the on-road transportation sector by 2020. Emissions from Electricity Use In 2006, electricity use accounted for 25% of total emissions in the region. About 44% of emissions from electricity came from consumption in the commercial sector. Residential sector consumption was close behind with 36%. Transportation, communication, and utilities (TCU) (9%) and the industrial sector (8%) are significantly lower than the leading subsectors. Figure 10 shows the relative breakdown of the electricity category. Figure 10. Electricity Emissions by Subcategory San Diego County, 2006 Agricuftural.ni -Sweet Lighting 1* KM. Emissions from electricity use increased by about 31% between 1990 and 2006, faster than population growth, and they are expected to increase by 28% over 2006 levels by 2020 under a business-as- usual scenario. : Figure 11. Natural Gas End Use Emissions By Sector, San Diego County 2006 Emissions from Natural Gas End-use Emissions from combustion of natural gas by end-users accounts lor just under 9% of total greenhouse gas emissions in San Diego County. Of this total, the residential sector accounts lor 60% of emissions, while the commercial sector emits about 33%. Figure 11 shows the contribution of each end-use sector to total natural gas emissions. Emissions associated with power generation from natural gas are accounted for in the electricity sector data. Sequestration and Wildfires In addition to the sources of emissions described above, this study estimated the ability of the vegetation in the county to absorb and sequester greenhouse gases. Carbon dioxide is taken up by growing plants and released again by decomposing plant matter displaced by development. During wildfires, the carbon dioxide stored in vegetation is released along with the other greenhouse gases nitrous oxide and methane. Figure 12 shows the total sources and sinks of greenhouse gas emissions for San Diego County from 1.990 to 2008. The very small green bars at the bottom indicate the level of carbon dioxide sequestered by vegetation. By contrast, the red bars at the top indicate the amount of greenhouse gas emitted by wildfires. The 2003 firestorm released nearly 8 MMT CO2E, more greenhouse gases than any other single emitting subcategory that year. These fires caused greenhouse gas emissions for that year to reach levels approximately equivalent to the projected emissions for 2017. Figure 12. Total GHG Sources and Sinks San Diego County o 10 1990 !992 1934 1996 1998 2000 2002 2004 2006 S3 Artttvopogerjfc Emissions, ' Sequestration from land Covet •m ' Kniissious Reduction Targets In 2006, California Governor Arnold Schwarzenegger signed ihe Global Warming Solutions Act (AB 32), establishing statutory limits on greenhouse gas emissions in California. AB 32 seeks to reduce statewide emissions to 1990 levels by the year 2020. While AB 32 does not specify reduction targets lor specific sectors or jurisdictions, this stud}1 calculated theoretical reductions targets for San Diego Count}'. To meet the targets established by AB 32, the San Diego region would have to reduce its projected business- as-usual 2020 emissions by 14 MMT CO,E or 33%. In 2005, Governor Schwarzenegger signed Executive Order S-3-05. which establishes long-term targets for greenhouse gas emissions reductions to levels 80% below 1990 levels by 2050. While this reduction target is not law, it is generally accepted as the long- term target of California regulations. Like AB 32, Executive Order $-3-05 is intended to be a statewide target, but if applied hypothetically to San Diego County, total emissions would have to be reduced to 6 MMT CO,E, 37 MMT CO,E (87%) below the 2020 business-as-usual projection and 28 MMT CO2E (83%) below 2006 levels. Figure 1 3 illustrates the magnitude of the theoretical emissions reductions necessary if San Diego County were required to meet both AB 32 and Executive Order S-3-05 targets. Figure 13. Theoretical GHG Reduction Targets for San Diego County so * • 11 rill I 1990 1W5 IIII.ilI Mlilsi.IIlil 3000 MOT 7010 3055 ,TOJO 70J5 !OW 2045 .>0501 r3-05 fefyoion T^fqt?w Reduction Strategies—Wedges To illustrate how San Diego County could achieve the AB 32 targets and reduce emissions by 14 MMT CO.F, the project team developed a range of strategies and calculated how much each could reduce emissions. The results were used to develop emissions reduction "wedges"' illustrated in Figure 14 and Table 2. This approach was adapted from the well-known study by Pacala and Sokolow demonstrating thai global emissions could be reduced to levels that would stabilize climate change using existing technologies." They look the total reductions needed to stabilize emissions and split that amount into equal parts, or wedges, each wedge representing an equal reduction. This study followed a similar approach to demonstrate how San Diego County could reduce its greenhouse gas emissions to meet AB 32 targets. Instead oi making equal wedges to achieve the reduction goals, the project team developed speohc wcdees COPY to show the effects of existing or expected policy changes. In most cases, wedges represent emissions reductions associated with existing law or regulation or are based on an authoritative source. In some cases, wedges were calculated on the basis of hypothetical but practical or realistic future policy changes. Figure 14 shows the relative greenhouse gas reduction possible from each major emissions category. The highest emitting categories also have the potential for the most emissions reduction. The on-road transportation and electricity categories account for 81% of total reductions: on-road transportation contributing 7 MMT COf (45%) and electricity contributing 5 MMT CO2E (36%) to the total. Some sectors have no emissions reduction wedge, due to their limited reduction potential. Figure 14. Emissions Reduction Wedges by Sector, San Diego County 4S 43 41 I " g ,5 * 33 Jl 11 *On-B<s>Kf Transportation ' Off-toad 8<|uip«ser •WWW Crural Gas End Us* Het Emissions lOOf »04 2010 JOU 2S12 H1U 2014 MIS WHS 2017 20!8 JOS9 2O1O The study identified 21 emissions reduction wedges and calculated how much each could reduce greenhouse gas emissions by 2020. Table 2 shows each wedge, its category, and the amount of emissions that it could reduce by 2020. The combined emissions reductions of these 2f wedges are 15 MMT CO2E, slightly more than the 14 MMT CO2E needed to reach AB 32 emissions targets prorated for San Diego County. The largest reductions derive from state standards for renewable energy, vehicle tailpipe emissions, and clean fuels. California's tailpipe carbon dioxide regulations (Pavley) if fully implemented would account for 21% of total emissions reductions by 2020.9 It should be noted that the Pavley regulations would reduce emissions by just over 3 MMT CO,E, significantly more than the new Federal corporate average fleet efficiency (CAFE) standards, adopted as part of the Federal energy legislation passed in 2007, which would reduce regional emissions by about 2 MMT CO^E. BEST COPT Table 2. Emissions Reduction Wedges to Achieve AS 32 CATEGORY ON ROAD TRANSPORTATION ~%- 200S CAFE Standard ft Low Carbon Fuel Standard Reduce Vehicle Miles Traveled by 10% -rf Pavley Standard (.Incremental to CAFES* Jfc Light/Heavy Vehicle Efficiency /Hybiidi/ation ELECTRICITY t^L Renewable Portfolio Standard 20*% Reduce Electricity Consumption 10% Renewable Portfolio Standard 33% ^incremental) Cleaner Electricity Purchases (<; 1 1 00 Ibs/'MWh) Replace Boardnvin Contract California Solar initiative 400 WW increase CHP by 200 MW INDUSTRIAL PROCESSES AND PRODUCTS Phase out of MFCs OFF-ROAD EQUIPMENT AND VEHICLES Reduce Fuel Consumption by 1 5% Low -Carbon Fuel Standard Reduce Pleasure Craft Fuel Use by 35% NATURAL GAS END-USE Reduce Natural Gas Consumption 8% CIVIL AVIATION Civil Aviation Lovv-C<irbon Fuel Standard WASTE Capture 80% of Landfill Gas AGRICULTURE/FORESTRY/LAND USE Urban Tree Planting /' Preservation Tree Preservation during Development REDUCTION AMOUNT (MMTCO,E) 6.8 2.3 1.6 1.4 0.9 0.6 5.4 2.0 1.1 1.0 0.6 0.3 0,2 0.2 1.3 1.3 0.7 0.4 0,2 0.1 0.3 0.3 0.3 0.3 0.3 0.3 0.05 0,02 0.03 PERCENTAGE OF TOTAL 46% !5% ?!% 9% 6% 4% 36% 13% 7% 7% 4% 2% !% 1% 9% 9% 4% 3% 1% !% 2% 2% 2% 2% 2% 2% 0.3% 0.1% 0.2% Total 15.0 100% 'The entire rodut't en jttnbuUbte :o Pavk-y •. J.2MMTCO £ ;CAF£ > P.ivlryS. Diego Ctntiify GHC* Irtvcnlory Cxecuth figure 15. Emissions Reduction Strategies for San Diego County to Meet Hypothetical AB 32 Targets by 2020 Pavtey Standard (includes CAFE) Renewable Portfolio Standard 33% (includes 20% WSJ On-Road Low-Carbon Fuel Standard Reduce vehicle MHes Traveled 10% Phase out of MFCs Reduce Etectrtcfty Consumption 10% Cleaner Electrkity Purchases (si 100 Ibs/MWh) Light/Heavy Duty Vehicle Efficiency Measures Off Road -15% Reduction in Foef Consumption Reduce Natural Gas Consumption 8% Civil Aviation low Carbon Fu«l Standard Capture 80% of landfill Gas Replace Ooardman Contract (Electricity) 400 MW of Distributed Photovoltaic* <jy Increase Cogeneration by 200 MW ASS! Off Road -Low Carbon Fuel Standard mi Off Road - 35% Reduction in Pleasure Craft Fuel Use si Tree Planting and Preservation d Phase Out SF6 ) 0,0 £t 4.- •- 0.5 1.0 !,S 2,0 MMTCO2E 2.S 3,0 J3 Figure 1 5 shows the magnitude of each individual emissions reduction wedge. Emissions reductions from the Renewable Portfolio Standard (RPS) wedges account for 20% of total reductions. California's RPS requires the state's three investor-owned utilities to provide at least 20% of energy supplies from renewable sources by 2010.'1' The emissions savings attributed to the 20% RPS wedge presented in Table 2 represents incremental renewable energy additions above levels already achieved by the local utility. In addition, the California Energy Commission's Integrated Energy Policy Report lor 2007 recommends increasing the RPS to 33%. !l While this increase to 33% is not law, it is very likely to be codified in the coming years. The wedge amount in Table 2 for the 33% RPS represents the incremental emissions reductions over the existing RPS requirements that would be achieved by increasing renewable energy supplies an additional 13%. A single amount for both the 20% and 33% RPS is presented in Figure 15. The California Air Resources Board (CARB) has approved the Low-Carbon Fuel Standard as an early action measure for meeting AB 32 emissions reduction targets. This standard, (01 thf Nc« 30 Ye.u-, wi(h II. a.% which was promulgated in Executive Order S-01-07, would reduce the carbon intensity of transportation fuels sold in California by 10% by 2020,n Applying this standard to fuels used by on-road vehicles would reduce greenhouse gas emissions by 11%. Reduction in vehicle miles traveled and increased vehicle efficiency measures make up the final transportation wedges. While many of the strategies identified here are based in state and federal law, there is a significant role for local governments in realizing emissions reductions. While local governments can help to facilitate statewide standards like the renewable portfolio standard, they can play a more direct role in locally and regionally based strategies. Strategies include reducing vehicle miles traveled, electricity and natural gas consumption, increasing use of distributed energy resources such as cogeneration and photovoitaics, and capturing more methane gas at our region's landfills. Conclusion . San Diego County emitted 34 million MMT C02E in 2006—an 18% increase over 1990 levels. This increase is commensurate with the increase in county population and statewide trends over the same period. On-road transportation, mainly cars and light-duty trucks, was responsible for 16 MMT CO2E in 2006, 46% of total greenhouse gas emissions in San Diego County for that year, and was by far the largest emitting category of the inventory. The electricity category emitted 7 MMT CO2E (25%) and natural gas end-use emitted 3 MMT CO^E (9%). These top three emitting categories are significantly associated with activities by individuals (e.g., driving and home electricity and natural gas use); thus nearly 60% of total regional emissions are associated with individual activities. By 2020, under a business-as-usual scenario, regional greenhouse gas emissions are expected to be 43 MMT CO2E, increase of 8.52 MMT CO2E (26%) over 2006 levels. Even though AB 32 does not specify reduction targets for counties, to achieve its emissions reduction targets (1990 levels by 2020), San Diego County would have to reduce emissions by 14 MMT CO2E (30%) below projected business-as-usual levels in 2020. San Diego County can reduce its greenhouse gas emissions to 1990 levels by 2020 through a combination of reductions strategies from all sectors, mainly driven by renewable energy mandates, fuel efficiency standards, and a low-carbon fuel standard. This study estimates that through a combination of 21 strategies, the region could reduce its emissions by 15 MMT CO2E by 2020, slightly more than required to reach 1990 levels. Clearly, meeting the greenhouse gas emissions targets of AB 32 targets will involve the entire state, and actions taken on a multi-county or regional basis may well influence the contributions made by or needed from San Diego County. A detailed analysis of the local and regional policy changes necessary to achieve the potential emissions reductions presented here was beyond the purview of this report, but will be addressed in the next phase of the project. 12.hup://R<>v ca.gov/incicx pbp?/cxccuuvf -<>rclei/51 72/ Table 3. S»n Diego County CMC Inventory and Emissions Projections (MMT CO,£) MO* iteiibftrt at i&«tfft'Bij#fi&m J010 Mil MIC CHMtOADtHAKSfOirtAnoK t» il I* «.$ •5.1 Sfewftnryef* EuciMcnv 17 40? J.S t.9 M 0.1 10 <u It *4 47 a» <W» MnNMLGMiNOUSCS 07 tt.1 0.1 07 JJI 1? s* O.I 0,1a? 0,1 07 not 3.4 4.J a,/ ft i *j» aes on-JKUOtQUWMIVTANOVtHKUS 1.0 t-J 47 a,; 00 9.1 54 a.i 6,* flwalKMW CmnnwKMI IndtMtml MkKini *<»itiv«i»«l (» a7 3.4 9,9« 001 17 ft.7 OJ »OJ o<a 1.8 Si 9.2 0.01 oca U 0.9on 0,33 0,0! 1.» IS <u OjOJ oca ?XI I.I OJ ftd)o.oi a.iu aj 003 OM t omjBKtMo ami wwtog $ tsttptw* at ai o.j 05 fl.i 0.1 0.1 9.1 0.1 01 0) 0.! 0.1 0.1 0,! OJ CIMtAVUDON MOWmMtMIOCffHSAMI IWOOUCTS 14 1* OJ ai at OJ «* «.! 9.1 0.4 uinncx* Mr»«t> *«T» un&m* VWUMWW* r*»*«»« )« U OJ OJ M I.I oj tis 16 OJ6 M OJ OJ! OJ M t.» aa M OJ 0.1 1A OJ 0.7 O4 «J 1.4 OJ ft* 05 OJ a.t«j 0.1 OA 0,2 M MMt WMWMOIIMi MMWWIWM 0.1 02 0.1a» u 0,1 as aos 0.1 10 60S O.J OJ l,i OJS ft* OJ OJ OJ am 03 0,1 o.w 04 OJ at OOJ 04 CL64 O4 IJ IJ til OJ OJK 9J 05 9.1 3<S4 o«s 0.2 04 •antvinimtgunsnxxt 004 0,1 0.2aoj OJ M 0.1 ai 0,1 049 0.1 ft?0,1 O.I OOJ e.t IVJ 0,1 07 0,1 01 ai 0,05 04 o./ 0,1 9.1 OJM 1! 0.1 O.1ai 034 0,03 94 OJ 002 002 am OJ 001 O.1 OJ OJ OX1J aj •4 0-1 Ltt»fi* «ife« t#rff«*K)f» s«im$rn<aK)M nmtuno tovm WtJJ w-n (OUT)«» Sti •0,23 *&!)ia.il Bi-i* Ousml Vn/fe «n( atKsbMK 43 '•• «e of ,\r m gj Hi 3 a|| |||| scW lev* < a< Is situ Hi .,,.»,,.,•;.( ctjflin HI tavoi i (g ^tud* i !- ;;-.n;-; ' -.:,...!;..••••. i , • • ;:;,••,« .V • i f,^-. i , : ,i" s : nitim. The U»beco fi '• •:-»' •. •'• :- • >•""••• •> ;:.;.- :-\:^ ." .. ' ftr-jr i«;!ua« cch.p. an !«• BESTCOPY AGENDA ITEM #. K Mayor City Attorney City Clerk OFFICES OF EVERETT L. DELANO III 220 W. Grand Avenue Escondido, California 92025 (760)510-1562 (760) 510-1565 (fax) August 7, 2009 VIA FACSIMILE & U.S. MAIL Lorraine M. Wood City Clerk City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 AUG 1 0 Re: La Costa Town Square: EIR 01-02/GPA 01-02/MP 149(RVLFMP 87-1KCVCT 01-09/CT 08-03/CT 08-07/CP 01-03/PUD 08-09/HDP 01-05/SDP 01-03/SDP 01- 04/V 08-02/CUP 04-18/CUP 08-01/CUP 08-02/CUP 08-03/CUP 08-04/CUP 08- 05/CUP 08-06/CUP 08-07 Dear Ms. Wood: This letter is submitted on behalf of North County Advocates in connection with the proposed La Costa Town Center project ("Project") and the Final Environmental Impact Report ("FEIR"). Please ensure that copies of this letter are provided to all City Council members prior to their consideration of the Project at their August 11th meeting. My July 14, 2009 letter echoed the sentiments of many other comments - that the FEIR is inadequate and the Project should be denied. I will not repeat those comments here, but would like to add a few additional considerations regarding the FEIR and Project. Staff has represented that the analysis of traffic impacts is sufficient and that it is acceptable to avoid mitigating traffic impacts. As my prior comments noted, this is incorrect. Indeed, the staff report to the City Council claims: "All required improvements needed to serve the project will be funded by the Developer." This is incorrect, as the FEIR itself acknowledges. Furthermore, the FEIR was changed substantially from the Draft EIR. See FEIR at 5.2-123 - 124. As such, it should have been recirculated for further public consideration and comments. Pub. Res. Code § 21092.1. Additionally, the FEIR fails to address the failure to mitigate impacts to other roadways, such as Olivenhain Road, San Elijo Road, and Rancho Santa Fe Road. Comments re La Costa Town Square August 7, 2009 Page 2 of3 Furthermore, the Project is likely to lead to water supply impacts. There is an inadequate showing of water supply for the Project. The California Supreme Court recently identified three "principles for analytical adequacy under CEQA": (1) "CEQA's informational purposes are not satisfied by an EIR that simply ignores or assumes a solution to a problem of supplying water to a proposed land sue project"; (2) "an adequate environmental impact analysis for a large project, to be built and occupied over a number of years, cannot be limited to the water supply for the first stage or the first few years"; and (3) "the future water supplies identified and analyzed must bear a likelihood of actually proving available .... An EIR for a land use project must address the impacts of likely future water sources, and the EIR's discussion must include a reasoned analysis of the circumstances affecting the likelihood of the water's availability." Vineyard Area Citizens for Responsible Growth, Inc. v. CityofRancho Cordova (2007) 40 Cal.4th 412, 430 - 32 (emphasis in original) (citations omitted). The FEIR fails to consider other mitigation or alternatives to address noise impacts. For example, the FEIR does not consider avoiding placing homes and/or avoiding blasting in those areas that would result in impacts. Similarly, the FEIR fails to consider alternatives to flooding impacts, such as not placing homes in a flood area. And the FEIR fails to consider other mitigation or alternatives that would avoid air quality impacts. "It is, of course, too late to argue for a grudging, miserly reading of CEQA." Bozung v. LAFCO (1975) 13 Cal.3d 263, 274. "CEQA does ... guarantee or at least attempt to assure that the environmental consequences of a government decision on . whether to approve a project will be considered before, not after, that decision is made." Stanislaus Natural Heritage Project v. County of Stanislaus (1996) 48 Cal.App.4th 182, 196 (emphasis added). The "grudging, miserly reading of CEQA" offered by the FEIR preparers is inconsistent with this mandate. Additionally, the City must demonstrate by substantial evidence that the findings are supportable. Pacific Corp. v. City ofCamarillo (1983) 149 Cal.App.3d 168, 178. The evidence supporting an agency's findings must have "solid value" in light of the entire record, including contrary evidence. Bank of America v. State Water Res. Control Ed. (1974) 42 Cal.App.3d 198, 213. The proposed findings for the Project, while numerous, are not supported by substantial evidence. In some instances, the evidence in the record actually conflicts with a proposed finding. Comments re La Costa Town Square August 7, 2009 Page 3 of3 Finally, the process followed has not been sufficient. The Planning Commission refused to allow persons to speak at its second meeting, although it did accept written comments. For the foregoing reasons, North County Advocates requests that the City reject the Project and the EIR. If you have a question or need additional information, please contact me. Thank you for your consideration of these comments. Sincerely, Everett DeLano cc: Van Lynch, Planning Dept. Kira Linberg From: Sent: To: Subject: lpershing@aol.com Tuesday, August 11, 2009 3:23 PM . Council Internet Email La Costa Shopping Center initiative Dear Council Members, I am a resident of Carlsbad and a university professor at Cal State San Marcos. I oppose plans to build a shopping center, condos, more houses, or multi-story office buildings in La Costa. I especially oppose any consideration of a Walmart. Walmart is an unscrupulous and exploitative corporation that relies on exporting production to workers in poor countries, where the wages are minimal and working conditions despicable. We do not want or need a Walmart in our area - the fewer Walmarts in the world, the better. The traffic on Rancho Santa Fe Road is already a big problem - adding a massive shopping center and offices and condos will make the problem much worse. We need more support for our libraries and school and community centers -- not for mega-corporations like Walmart. I strongly urge you to vote no on a development in the La Costa area. Quality of life issues are much more important to the residents of Carlsbad. Thank you, Dr. Linda Pershing 8048 Paseo Arrayan Carlsbad, CA 92009 AUG 1 1 2009 Name llonaJ. Moore Robert & Delores Kinsman Tom Christ Ernie Trujillo Pat Bleha Jennifer Bleha Barbara Tice Chris Magallon Wayne Dossick Kevin Thompson Sterling Krolicki Cleo Gihbsson Wendy Oxenhorn Brenda Corsi Ivan Jellinek Linda Pershing James & Doris Morgan Karen Burch Emilio & Mary Theresa Desoto Mr. & Mrs. Alter f Michael & Helen Kapnas Address 7669 Galleon Way 7249 Esfera Street 7251 Esfera Street 2644 La Costa Avenue 3209 Fosca Street 3560 Adams Street 7106 Lantana Terrace 7030 Avenida Encinas, Suite #100 (Realtor) 4136 Cadencia Street 3560 Adams Street 7936 Sitio Baniano 3315 Cabo Court 3117 Verde Avenue 7356 Altiva Place 3312 Cabo Court 8048 Paseo Arrayan 3331 Fosca Street 3302 Piragua Street 3506 Sitio Bario Avenida Diestro 3273 Avenida Anacapa Comments Against project No No Against proposal No No Against it - too large, disruptive - grading/air pollution - just a nice shopping center alone would be nice Against - no big box - traffic problems - too much right now - not necessarily opposed to another project (smaller). Opposed for all the environmental reasons - traffic, bright lights - We don't want another Orange County where commercial enterprise has its way over all else Opposed to project Against Opposed to project Opposed to project Opposed to project Opposed to project Opposed to project Opposed to project Opposed to project Opposed to project Opposed to project For the project - will be nice to have it nearby AGENDAITEM # \ c: Mayor City Councfl City Manager City Attorney City Clerk CITYC AGENDA ITEM #. Mayor 1 c: City Council City Manager City Attorney City ClerkFred C. Sandquist 6408 Crossbill Court Carlsbad, CA 92011-2783 (760) 918-2408 Sandqulst2@oarthlink.net August 11,2009 Carlsbad Mayor and City Council City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, California 92003 Subject: Opposition for La Costa Town Square, City Council Agenda Item AB# 19,935 Dear Mayor and City Council Members: Having moved to the City of Carlsbad in the summer of 2001, my wife and I have enjoyed living on the west coast, and more specifically, being a resident of Carlsbad. Contrary to many cities in north San Diego County, I was and continue to be impressed by the way the City manages growth and supports setting aside land for open space, parks, recreational trails, and that touch and feeling of being a village rather than a city. We don't see the urban sprawl and poor land use that is so common throughout many surrounding cities and communities. That being said, I feel that project proposals like La Costa Town Square will provide a critical success factor for the City Council and whether they have the courage to truly represent the interests of the city in terms of land use, urban sprawl, and the high priority they give to protecting the environment and having more open space. As a member of the Envision Carlsbad Citizen's Committee, I was impressed with the common theme in the city-wide survey and the various public workshops for more open space, trails, maintaining the character of our local communities, and parks rather than further development like the La Costa Town Square project. The Environmental Impact Report (EIR) process under the California Environmental Quality Act (CEQA) is intended to provide you and city staff with the information needed to make informed decisions. One of my key concerns with the CEQA process is how local municipalities address the key component of cumulative effects and the role it plays in causing problems with large projects. It is too easy to limit the cumulative effects of a project by reducing the see of the analysis area. In this project, located near the border with Encinitas and Encinitas's Olivenhain Community, the draft project EIR does not include this community in its analysis, which will potentially be seriously impacted with additional traffic. The Encinitas/Carlsbad boundary is approximately 0.5 miles to the south. The resulting study area, therefore, excludes the northern portion of Olivenhain, As with any complex project, while any single potential impact category might not be significant or can be mitigated to /ess than significant, when combined with other factors they can lead to a cumulative effect that becomes very significant On the economic front with many commercial properties being vacant, a housing market that has not recovered with a glut of units being available, foreclosures, inability of homeowners and businesses to obtain financing, and many existing businesses having to dose, I question why we feel there is a need to build more - sell or lease what we have before building more. M cib£ aj f ^ill ll£fil .88 J J> - -fc* S J8IIUJI n as O>__ * B3-1 H = T5£ g <£ "5 ® "P ,S * 2 E Js ® a> 2"O § 2 E 5 UJ^JiiEs m "te w S 15 |lpl| ago a«a •IflPlit nilJE js c >, a, ^ P<y C. -M Q ^ BE iailli-i 5 c21 o Kira Linberg From: Sent: To: Subject: pheidmann@qualcomm.com Tuesday, August 11, 2009 3:58 PM Council Internet Email CITY OF CARLSBAD I CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Please REJECT La Costa Town Square. More noise is not needed. More traffic is not needed. More water usage is not needed. More retail is not needed (many empty stores in the area now). peter heidmann 3 pheidmann(o)qualcomm. com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; Q312461; .NET CLR 1.0.3705; .NET CLR 1.1.4322; .NET CLR 2.0.50727; .NET CLR 3.0.04506.30; .NET CLR 3.0.04506.648; InfoPath.2; .NET CLR 3.0.4506.2152; .NET CLR 3.5.30729) 129.46.70.252 AUG 1 CARLSBADV^_> CHAMBER OF COMMERCE Mayor Bud Lewis City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, California 92008 August 11,2009 Mayor City Council City Manager City Attorney City Clerk Dear Mayor Lewis: I am writing in support of the La Costa Town Center project before you tonight for consideration. The Chamber of Commerce has supported this project for more than a decade. In the current economic conditions our nation and city are in, it is vitally important that a project that has met all its regulatory requirements be allowed to proceed. This project when up and running will create nearly $1 million annually to the City General Fund through the creation of new tax dollars. The project will provide exciting new opportunities for businesses, while not depriving existing businesses from obtaining sales and ensure the economic well-being of our community. With sales tax revenues down considerably citywide this project comes on line at a critical time. The Infrastructure and Energy aspects of the project are in our opinion financially feasible and won't have onerous impacts on the businesses or residents within the project area. In so much as the project is consistent with our goals of supporting Carlsbad's Growth Management Plan implementation, the Chamber enthusiastically supports this project and urge your approval of the development plans. Thank you for yotrs time and consideration of our request.1 -, Ted Owe President and CEO 5934 Pnesdy Drive * Carlsbad, California 92008 Phone: (760) 931-8400 s Fax: (760) 931-9153 9 E-mail: chamber@carlsbad.org * Web: www.carlsbad.org Kira Linberg From: Sent: To: Cc: Subject: cathy leclair [cathy@cathyleclair.com] Wednesday, July 15, 2009 10:56 AM Manager Internet Email 'Jay LeClair'; 'JEFF KANE1; 'Pat Kilkenny1 Shopping center project at corner of La Costa Ar,ENDAITEM# / c: Mayor City council City Manager CityAttorney City Clerk o pep on '' _,_„,„, - My husband & I have lived in the area since 1978 and have grave concerns regarding the proposed use of the land at the aforementioned corner. 1. Two gas stations is over kill 2. Traffic is already a "nightmare" in this area 3. Planned water usage is irresponsible in this climate Cathy LeClair Prudential California Realty 7030 Avenida fncinas Carlsbad, Ca. 92010 760-533-9492 fax, 760-436-6190 toll free, 866-leclair www.cathyleclair.com cathy@cathyleclair.com Relocation Certified, Chairman's Circle Member, Five Star Award Winner in Client Satisfaction Thank you for all your referrals AUG 1 1 2009 CITY OF CARLSBAD CITY CLERK'S OFFICE Kira Lin berg From: tlchero@hotmail.com Sent: Wednesday, July 15, 2009 4:18 PM To: Manager Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Manager. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: We do not need more traffic and congestion on La Costa Avenue, Rancho Santa Fe Road, Levante, Esfera, Cadencia and other surrounding streets that will take place once the La Costa Town Square is built. This project should not go forward. Thank you for your attention to this. Edward and Patricia Cerda Edward and Patricia Cerda 3314 Cabo Court Carlsbad, 92009 tlchero(3hotmail. com Mozilla/4.0 (compatible; MSIE 8.0; Windows NT 6.0; Trident/4.0; GTB6; SLCC1; .NET CLR 2.0.50727; Media Center PC 5.0; .NET CLR 3.5.30729; .NET CLR 3.0.30618; yie8) 75.33.14.130 Kira Lin berg From: charles.ca@gmail.com Sent: Wednesday, July 29, 2009 12:11 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department. City Council. #####*##****##*********#*#***********#**#**#** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Please vote NO to the current plan of La Costa Town Square project. The main thing I oppose is about building the high density residence buildings on the triangle shaped land to the west of Rancho Sante Fe. Why not put the high density buildings next to the commercial area of the project to the east of Rancho Santa Fe? This makes more sense. Please swap the high density buildings with the low density buildings on the plan. Thanks. Charles Charles Wang 7385 Calle Conifera Carlsbad, charles. ca(3gmail. com Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.9.0.12) Gecko/2009070611 Firefox/3.0.12 (.NET CLR 3.5.30729) 216.237.3.222 Kira Linberg From: juliehodges88@coldwellbanker.com Sent: Thursday, July 30, 2009 12:00 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department. City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: We are resident of La Costa Oak and the vacant lot west of Rancho Santa Fe is adjacent to our property. We request that no multi stories high density dwelling be built on this lot. The home value had already significantly definish due to the economy, it will be worsent if the above mention dwelling is built ontop of this lot. The potential of declining value will result in lower property taxes collected by the county for road and public service fundings. We urge the council man or woman take into serious consideration when make decision in approving this plan. As suggestion of 2 story patio home will be ideal for this vacant lot. Thank you for taking the time to read our comments. Barry and Dulie Hodges 7373 Calle Conifera Carlsbad, CA 92009 1uliehodges88(5)coldwellbanker.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; GTB6; .NET CLR 1.1.4322; InfoPath.l; .NET CLR 2.0.50727) 12.166.159.114 Kira Linberg From: huiwen_harrison@yahoo.com Sent: Thursday, July 30, 2009 12:51 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear city council, I would like to oppose to the building of La Costa Town Square near the intersection of La Costa Ave and Rancho Santa Fe road as well as building of high density low income housing on the triagular lot near the same intersection. When we bought the house almost 6 years ago, the proposed plan for the triangular lot was for low density medical offices. We made the purchase because we did not foresee increase in traffic as well as noise in the area. The change of plan from low density medical office to high density low income housing is perceived as an action of deception in my opinion. No home owner would want to pay close to or over $1 million dollar for houses to live next to low income housing development and the unexpected change of plan has raised a lot of speculation in the neighborhood, wondering if there is special interest involved in the decision-making process and if home owners like us were misrepresented when we bought the houses. Another concern is that Paseo Lupino is a very small and narrow street but will be the main entry for the town square as well as the high density low income housing on the triangular lot. Although Rancho Santa Fe roade may be wide enough to accommodate increasing traffice in and out of the town square and triangular lot, people have to get on Paseo Lupino first before they can get on Rancho Santa Fe road. The small and narrow street will be jammed with cars sitting there to get on Rancho Santa Fe road during rush hours and on weekends, not to mention the dramatic increase in noise and safety concerns resulting from the large number of cars on Paseo Lupino. Last but not the least, Carlsbad city government has opened the flood gate, allowing developers to come in and build like crazy in the past few years. The beautiful city with green hills, family friendly streets (no crowded streets like San Diego city) and wide open space for our children to run around is disappearing quickly each day. If the city is promoting ourselves as the best place for kids to grow up, building more houses, shopping centers in order to bringing more tax money for the city's use is really not the way to go. We love to see more parks, libraries, cultural activities and construction in the city that our future generations can truly benefit from. Please stop approving more housing projects unless the city council cares a lot more about tax collection than the true welfare of their voters. Thank you very much for your vote to say NO to the La Costa Town Square/ Low Income Housing proposal. Sincerely, Hui-Wen Harrison 13 #? Kira Lin berg From: pengwangusa@yahoo.com Sent: Thursday, July 30, 2009 3:27 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the Gity of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Dear Council Members: I am very concerned about the plan of having 3 levels 40 feet high density residence buildings for low income families. I believes such plan will seriously affect the single family home values nearby. The immediate impacts to the La Costa Oaks residents are: 1) Increased traffic at peak time, especially in the morning when all kids are going to school, the new high density plan will bring in too many kids; 2) Increased Noise; 3) Safety issue, more people will drive through the La Costa Oaks since it is not a gated community. My neighbour's car, was hit by a drunk driver at 12:30am of June 15, 2009 just along the curb of his home, the increased population will greatly increase the safety concern. 4) Unexpected parking cars. Many visitors oto the new residents may come over the weekends and holidays and park their cars in the La Costa Oaks community. Thank you very much for your consideration. Sincerely yours, Peng Wang, Ph.D. Peng Wang 3431 Corte Aciano Carlsbad, CA 92009 pengwangusaOvahoo.com Mozilla/4.0 (compatible; MSIE 8.0; Windows NT 5.1; Trident/4.0; Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) ; .NET CLR 2.0.50727) 70.164.99.98 Kira Lin berg From: dougcyphers@hotmail.com Sent: Thursday, July 30, 2009 10:37 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. sic********************************************* FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.#*##***###************************************ Below, please find the information that was submitted: I'm writing in concern of proposed development relative to the La Costa Town Square project regarding the smaller piece of land north of the project on the other side of Rancho Sante Fe Rd. I originally inquired through a Van Lynch who is one of your senior planners that emailed me about the property in question back in March stating that there were no plans at that time and the maximum allowable height was 35 ft. This left me the impression that the development footprint would be of limited size and overall land capacity. I'm now hearing that 3 story low income housing apt buildings are being planned for 40 ft high. If this happens, I will lose my only view and with low income housing I will likely lose my house value. I recently moved here from Minnesota and am concerned about this. I would like to understand if I have any options in guiding what is done on the property in question before there is anything determined permanently. Regards, Doug Cyphers Doug Cyphers 7381 Calle Conifera Carlsbad, California 92009 US dougcyphersQhotmail.com Mozilla/4.0 (compatible; MSIE 8.0J Windows NT 5.1; Trident/4.0; .NET CLR 2.0.50727; .NET CLR 1.1.4322; InfoPath.2; OfficeLiveConnector.1.3; OfficeLivePatch.1.3; .NET CLR 3.0.4506.2152; .NET CLR 3.5.30729; MS-RTC LM 8) 76.176.8.229 Kira Linberg From: bogardkc@sbcglobal.net Sent: Friday, July 31, 2009 9:51 AM To: . Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Hello, I am writing you today to voice my objection to the proposed high-density residential project planned for the westerly side of Rancho Santa Fe Road and Paseo Lupino. Not only would this project significantly impact the view from our home, this type of development is not in keeping with the low density single family units the are nearby. This land would be better sutied for this type of use of single story, single family homes or perhaps as a park with the 3 story high density housing located on the other side of Rancho Santa Fe adjacent to the future LaCosta Town Center. Please do not allow this project to proceed, if you lived in my house you would not want your former lovely view now filled with 40 foot high walls of buildings. Regards, Kimberly Troutman Kimberly K. Troutman 3329 Cabo Way CARLSBAD, CA 92009 USA boeardkcQsbcglobal.net Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; Agilent Technologies IE6 SP1; .NET CLR 1.1.4322; InfoPath.l; .NET CLR 2.0.50727) 192.25.240.225 Kira Lin berg From: troutmmr@yahoo.com Sent: Friday, July 31, 2009 11:48 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Hi, I am writing you today to voice my objection to the proposed high-density residential project planned for the westerly side of Rancho Santa Fe Road and Paseo Lupino. THREE STORIES IS NOT AN OPTION. Not only would this project significantly impact the view from our home, this type of development is not in keeping with the low density single family units that are nearby. This land would be better suited for this type of use of single story, single family homes or perhaps as a park with the 3 story high density housing located on the south side of Rancho Santa Fe adjacent to the future LaCosta Town Center. Please do not allow this project to proceed, if you lived our my house you would not want your lovely view being filled with 40 foot high walls of buildings. In addition look at all the current develops underway in the same area which I'm sure have not been considered in terms of increasing the population density and traffic in the area. With the current housing crisis all! we need are more vacant homes that are not affordable. Based on what I saw on the news the other night it would appear that vacant homes, which would be a considerable amount based on the project plan and other developments in the area, are prime targes for "RAVES" according to channel 10 news. PLEASE reconsider the proposed plan and what is right for our city. At least wait to see the other housing developments in the area finish to see if they sell or remain vacant. We moved to this area because of th open space and neighbor and this really is not what we expected living in Carlsbad. PLEASE RECONSIDER!!!!!!!!! Mike Troutman 3329 Cabo Way Carlsbad, CA 92009 USA troutmmr(o)vahoo.com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; .NET CLR 1.1.4322; .NET CLR 2.0.50727; .NET CLR 3.0.04506.30; .NET CLR 3.0.04506.648; InfoPath.2) 192.25.240.225 Kira Linberg From: djb83@netzero.net Sent: Saturday, August 01, 2009 5:53 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: RE: Proposed La Costa Town Square Project Dear Sirs/Madam: Unfortunately work obligations prevented me from attending the recent City Council and Planning Commission meetings at which this project was discussed. Nevertheless, I felt obliged to write and express the same concerns and objections that were no doubt voiced by many of my neighbors. First of all, when I chose to buy my house at 7450 Esfera St. approximately 5 years ago, I did so because I liked the established residential atmosphere. This seemed like a quiet, nice place to live and Carlsbad had a good reputation. I left the Clairemont section of San Diego to get away from noise, congestion, and traffic. I might further add that when I moved to California 9 years ago, I chose to live in San Diego county and NOT Orange county for similar reasons. In light of increasing development in the La Costa area, I am afraid that I may have made a poor choice, lacking the foresight to realize that this area would soon come to resemble exactly what I wished to avoid. In reviewing the proposed details of the La Costa Town square development it would not be overstating the case to say that I am shocked and overwhelmed at the size and scope of the project. Even with the alteration to the plan removing the movie theater, it is a massive project, not at all in keeping wit! h the general atmosphere of the surrounding area. Most of the large commercial developments in the vicinity are concentrated along the El Camino Real corridor or in other areas in which they seem more fitting and appropriate. To have a project of this size so close to already established residential neighborhoods seems out of place. I am deeply concerned about the effect such a project might have on my quality of life and the value of my property. Had I known such a project was in the offing, I might well have considered living elsewhere. To be more specific, undoubtedly the noise we can anticipate from the construction of the project would be more than just a minor annoyance. We have already been subjected to the deafening roar of large construction vehicles in the past as a result of the realignment of Rancho Santa Fe Rd. and filling-in and grading on the parcel of land along the NW corner of the intersection of Rancho Santa Fe Rd. and La Costa Ave. On many occasions the construction vehicles began work before 7 am much to my consternation. Once the project is complete we can only anticipate more noise from the increased traffic, both car and truck. This leads to my next point...security and crime. It doesn't take a genius to see that shopping centers attract criminals seeking victims whether they be the retail establishments or those who frequent them. In perusing the local paper I have noticed the relative infrequency of crime and vehicle thefts in the La Costa area in contrast to the relative frequency of ! criminal activities in downtown Carlsbad and the neighborhood near major shopping centers. Rancho Santa Fe Rd. has already become a major thoroughfare bringing people from Oceanside, Vista, San Marcos and elsewhere into our neighborhood. The increase in traffic in the last year has been significant, noticeable, and disturbing. The new developments already under construction will clearly add to this. This development would be the "straw that broke the camel's back". Rancho Santa Fe Rd. has become a freeway. The intersection with La Costa Ave. l is, at times, almost impassable as well as dangerous because of drivers who choose to ignore traffic signals. In addition to the concern over the increased volume of traffic and concomitant noise, I am also concerned that frustrated drivers would begin to use the side- streets (Camino Junipero, Cadencia, and Esfera) as a cut-through, contributing to an already disturbing trend of speeding drivers on residential streets. I was "amused" by! the traffic study conducted and posted for public view. While! the so- called experts spent considerable time examining the impact of this project on the Interstate 5 ramps, apparently the more obvious potential problems were ignored. If one were to simply stand at the intersection of La Costa and Rancho Santa Fe on any morning or late afternoon/early evening, one would see that the existing traffic ALREADY poses problems for those of us who live in the area. Traffic routinely backs up on La Costa westward so far that people cannot turn from Levante. Is this project going to improve that situation or exacerbate it? I think we know the answer to that question. Using pseudo-scientific studies and statistics to justify this project only serves to remind the public that money spent on such studies is wasted on self-serving companies that cater to developers. Finally, based on a prior meeting held at one of my neighbor's homes, I had understood that the triangular parcel of land on the west side of Rancho Santa Fe Rd. was intended to be made into an! office building of limited size. According to the revised NOP this parcel is slated to be used for multi-family dwellings. I do not believe such high density housing is appropriate or in keeping with the surrounding neighborhood. There are apartment complexes as one heads east on La Costa Ave. past the intersection of Rancho Santa Fe Rd. Perhaps somewhere on that section of La Costa Ave. might be a better place to locate this portion of the project. Besides, given the prevailing market conditions, is this really what Carlsbad needs? More housing? Further, given the current drought conditions, do we really want to have more lawns, landscaping, etc. to draw upon our diminishing resources? Rezoning the parcel of land on the west side of Rancho Santa Fe Rd. would completely contradict the existing atmosphere of the neighborhood, which is entirely composed of single-family homes. To place a multi-story, multi-family dwelling here would likely further lower the property values, ! which have already taken a hit. More significantly, such a dev! elopment would drastically alter the complexion of the surrounding area. We like living in a relatively quiet neighborhood in which people all know each other. If a multi-family dwelling needs to be built, why not place it closer to the shopping thus making it more convenient for the residents? Having expressed my concerns, let me say that if it turns out that the project is bound to proceed over and against any objection raised by people such as myself, I would at least hope that some consideration is given to limiting the size and scope of the project. There are already enough shopping centers nearby and God knows we don't need to squeeze in any more houses. It seems that this project is not motivated by any desire to improve the neighborhood, but more by that most basic and most base one...GREED. The organization behind this project is located in Austin, Texas. Let them build all the shopping centers they like...in Austin, Texas! I would appreciate a response and some assurance that my concerns as well as those of my neighbors will be addressed. Thank you. Don Burton 7450 Esfera Street Carlsbad, CA 92009 dj b83@netzero.net Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; GTB6; .NET CLR 1.0.3705; .NET CLR 1.1.4322; Media Center PC 4.0; .NET CLR 2.0.50727) 69.19.183.94 Kira Lin berg From: socal_tfc@yahoo.com Sent: Wednesday, August 05, 2009 3:29 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department , City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Dear City Council, I am writing to you in anticipation to the upcomming City Council Meeting, and specifically to the La Costa Towne Square portion of the Meeting. My schedule may not allow for me to attend so I would like to put down my thoughts prior to the meeting if I can not make it. My home fronts the proposed development, (in the North East portion of the Site). My bedroom on the second floor looks directly at the site. Needless to say I am less then thrilled. A few of my major concerns 1)1 fear the lighting will be a large problem, especially later at night, it will effect my ability to sleep. As I said my window looks directly at the site. I ask that the project be forced to shut off all of its lights at 10pm or there abouts (other then security lighting of course) and no deliveries be made at night. 2) Blasting. The EIR states the blasting is going to be very very close to my home. My home has a large slope that shares the property line with the project. I am very nervous there may be damage to the slope, and/or my home or my surface improvements. I ask that the Blasting is eliminated from the project even if the alternatives are very expensive. I could care less about "noticing" of the blasting which was discussed at length in the Planning Commision hearing, I am concerned about possible damage from blasting. This is a concern for several of us direct neighbors to the project. 3) Animal dispersion. Once the grading starts, I fear wild animals will just come onto my property, snakes, scorpions, what have you. How am I going to be protected against this? This may not effect many Carlsbad residents, but it most certainly is going to affect me. 4) The Walking Trail proposed along the eastern portion of the site will front my fence line. At the present time, there is already a trail there that people use (illegally I presume). The existing trail (likely the proposed as well) has a minimal setback from my fence line, people stand along it and stare into my yard, disturb my dog, and generally make it unpleasant for us, at one point I had to yell at underage kids drinking there. I ask that if this trail is going to be built, which I am against, that the developer creates a landscape/ buffer between our fenceline and the trail. Something where it visablly sheilds us from the trail. So to sum it up, my family and I do not want this project. Seeing how it is that few seem to care about that, I ask that at least some mitigation be done to assist us. Thank you for your time, Adam Podlich 3501 Sitio Espino Adam Podlich 3501 Sitio Espino Carlsbad, CA 92009 socal tfc(3yahoo.cotn Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; .NET CLR 1.1.4322; .NET CLR 2.0.50727) 66.123.229.166 Kira Linberg From: david_harrison@yahoo.com Sent: Wednesday, August 05, 2009 5:12 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Please disapprove the "La Costa Town Square" project as currently proposed or at least delay any vote to allow for additional public comment. At a minimum, please require a density swap so that the high-density housing currently slated for the triangular lot on the northwest of the site can be placed adjacent to the commercial center as has been noted as a more appropriate and logical placement. The triangular lot was not originally zoned for this use, but the Planning Commission has allowed for a change in zoning. Not only does this have a negative impact on current residents who purchased their homes before the zoning change, but there is also a more suitable location for the high-density housing which has already been noted. A density swap would allow detached single family homes to be placed in the triangular lot, and high-density housing to be placed in the appropriate location adjacent to the commercial development. Please also reference my "Letter I" commenting on the Environmental Impact Report: "We are extremely concerned by the findings contained in the La Costa Town Square Environmental Impact Report. As noted, both the "No Development" and "Biological Open Space" alternatives are environmentally superior (in almost all respects) to the proposed project. Specifically, this area already suffers from high noise decibel levels, has significant traffic issues, compromised air quality, and various safety hazards. This project in general would worsen these concerns as well as deprive current residents from the quiet enjoyment of their homes. The project also is slated to have building heights potential of up to 55 feet (or over including protrusions) which will interfere with the views afforded to current residents. [Although the report states that the project would not block any significant scenic views, we currently enjoy an ocean and lagoon view from our home which would indeed ! be blocked by the proposed high-density housing in the triangular lot in the northwest of the site.] Of greatest concern is the proposed multi-family development on the northernmost portion of the project. The resulting density, traffic, pollution, noise, crime [we have had several recent burglaries in the area and oppose new construction that would increase crime potential even further], reduction in general safety, and the loss of quiet enjoyment and views of the residents of the Hillock division of La Costa Oaks are of grave concern. Originally this parcel was to be developed into low-density professional office space not to exceed 2 stories in height. [Although the report states such development would contribute to greater traffic, this traffic impact would be concentrated during working hours which would be less burdensome to current residents' quiet enjoyment of their homes in the evening/non-working hours. Additionally, the proposed density swap enabling the building of detached single family homes in this space would be a superior and less environmentally impact! ful use of this space.] We would like to see further alternatives presented for the development of this space and/or further environmental impact mitigation proposals. At a minimum, the build-out, height and density of the development plan for the parcel should be greatly reduced. We do not believe this project should be approved in its current form. Sincerely, David Harrison David Harrison Carlsbad, CA 92009 USA david harrison(3yahoo.com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; .NET CLR 1.1.4322; .NET CLR 2.0.50727) 206.170.127.5 Susan E. Raley 7452 Trigo Lane Carlsbad, California 92009-7845 (760) 436-6243 home (858) 793-0300 work (619) 813-6736 cell susaneraley@yahoo.com August 6, 2009 VIA FAX AND U.S. MAIL Council Members Carlsbad City Council 1200 Carlsbad Village Drive Carlsbad, CA 92008 Re: La Costa Town Square Dear Ms. Kulchin, Mr. Hall, Mr. Packard and Mr. Blackburn: I am writing this letter to you as a very concerned property owner in La Costa, and the above-referenced proposed development. While I believe that the proposed commercial shopping center will be a catastrophe for our community, the main purpose of this letter is to express my outrage as to what is being proposed to be built on the 9.8 acre pad located on the west side of Rancho Santa Fe Road - right behind my property. Namely, a Residential High Density Multi-Family Project. In other words, there would be affordable "low income housing" in an otherwise nice, upper middle class neighborhood (one without multi-family housing, I might add) . I was present at the July 1st public hearing and I put my name in for a chance to speak, however, due to time restraints I was unable to stay past 9:00 p.m. I believe my neighbor, Alan Recce, spoke both for himself and on my behalf. The small pad of property directly behind my home is exactly that... small. The prospect of 128 units jammed inside that small space is unbelievable to me. From my upstairs bedroom window, I look out onto that 9.8 acre pad and my line of vision is at ground level. . .the new ground level that was created when the pad was raised. A couple of years ago there was a large pile of dirt on that pad, and I must tell you, that pile of dirt nearly blocked out the sun. Now a developer would like a 3-story low-income housing project built on that pad! I assure you, I would never see the sky again from my bedroom window. It is my understanding that there is the possibility of moving the Residential High Density Multi-Family development to the east side of Rancho Santa Fe Road adjacent to the future La Costa Town Square, and the 9.8 acre pad could be developed into single family Carlsbad City Council August 6, 2009 Page 2 homes. This seems the ideal solution for many reasons. The apartments would be located near the shopping center (convenient for those residents), and our neighborhood would stay consistently single family homes. And hopefully there wouldn't be catastrophic financial loss to the current area homeowners. My husband and I bought our home in 2005 with the knowledge that the lot behind our property was zoned as business/commercial, with the possibility that condominiums could be built there. I am a recent widow, having lost my husband in a motor vehicle accident this past year. I want you to know this because as a widowed homeowner, I struggle to keep my home in these difficult times. The very last thing I need is for my property value to decline anymore than it already has. The proposed Residential High Density Multi-Family development could be devastating to me. As a voting council, you all must be made aware of this. For me and for my neighbors sake. I invite you to come to my home, see for yourselves what we are up against in our community. I invite you to please imagine an apartment complex on that 9.8 acre pad as you look out my bedroom window. Please do not take lightly the task of voting on this issue. If you lived in my neighborhood, you would NOT approve this measure. Please feel free to contact me if you should have any questions. Sincerely, Susan E. Raley Kira Linberg From: arthur_waloch@yahoo.com Sent: Friday, August 07, 2009 8:45 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Dear City Council, I'm writing to ask you to re-consider plans to build an apartment compex on the 9.8 acre parcel near Rancho Santa Fe and La Costa Ave. My home on Fosca St is oriented toward the southwest and would be negatively impacted by such a structure. My current views of Del Mar, UTC and downtown would be replaced by a large building. I've lived in Carlsbad since 1993. I pay high property taxes and am active in my son's school activities, youth sports and Carlsbad adult sports (sponsoring teams, fundraisers, etc). Considering the drop in the real estate market. I ask you not to ruin the value of La Costa homes that have stood here since 1978. Respectfully, Arthur Waloch Arthur Waloch 3341 Fosca St Carlsbad, CA 92009 arthur waloch(8yahoo.com Mozilla/5.0 (Macintosh; U; Intel Mac OS X 10_5_8; en-us) AppleWebKit/530.19.2 (KHTML, like Gecko) Version/4.0.2 Safari/530.19 99.184.251.121 Kira Linberg From: Dfs0519@aol.com Sent: Friday, August 07, 2009 10:21 AM To: Council Internet Email Subject: Voting on land use for the shopping center and housing This Tueaday you will vote for the land development by Rancho Santa Fe and La Costa. Please put the final vote off. We don't need a store like Kohl's or Walmart anchoring a center by so many expensive homes. We also don't need more housing, esp with high capacity living. Our schools are over crowded, I know because I work at one for that area. Our roads are overcrowded. There is a noise facter with multilevel homes that would echo into many of our homes. There are also safety issues to consider. Please consider the preexisting home owners when it come to futher planning. The many issues stated would very much impact us, esp more housing. I have lived hear for 31 years, and I hope our elected officials would reconsider their thoughts on the matter. Sincerely, Dena Soukup Kira Linberg From: pcb@sbcglobal.net Sent: Friday, August 07, 2009 9:24 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Regarding the proposed La Costa Town Square project, there should be NO BIG BOX (you even said in 2005 they don't belong in residential communities, NO UP ZONING to high density, and NO REGIONAL shopping center -- too much light, noise, and traffic. We are in a drought Stage 2 and we do not need all these stores and offices when empty ones are all around. It is a poor plan. You can and must do better than that! You should use some of that open space money $35 million that we citizens voted on for the acquisition of open space seven years ago to buy more of those 83 acres. Survey after survey said citizens want more open space and trails. You have not spent a penny of it. Be the citizens' representatives for once and not the developers!!!! Patricia Bleha 3209 Fosca St. Carlsbad, CA 92009 pcbQsbcglobal.net Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; GTB6; .NET CLR 1.0.3705) 75.33.10.22 Kira Linberg From: troutmmr@yahoo.com Sent: Saturday, August 08, 2009 8:38 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ##*#*####****#**********#**#*****#***#*******# FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.##*##*#***#****#***********#*****##**********# Below, please find the information that was submitted: Hi, I'm writing to you once again because I did not receive any type of response from you concerning the La Costa Town Center. I will not be able to attend the Tuesday meeting because I will be traveling on business but I hope MY CITY Representitive will be there to voice a big NO for this developement. The "ADD_ON" condo complex is wrong and should not even be considered in this community. Especially with all the new housing being built right up the street. I'm bet if you lived near this proposed project you would be against it as well. Please support the community on this one! troutmmr(a)vahoo. com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; .NET CLR 1.1.4322; .NET CLR 2.0.50727; .NET CLR 3.0.04506.30; .NET CLR 3.0.04506.648; InfoPath.2) 99.150.241.217 Kira Linberg From: sstrum@roadrunner.com Sent: Monday, August 10, 2009 12:18 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. **********************************************FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: We have just been informed of the new development planned at the border of Olivenhain. The development of Carlsbad without proper planning for amenities and services and which has resulted in incredible traffic and inconveniences for neighboring communities has to stop. Carlsbad City Council is shirking its duty to his citizens by going for even more development. Given that we are forced to be a "car culture" there are enough stores and businesses and offices within easy cruising distance for Carlsbad residents to make this development both unnecessary and destructive. I will be out of the country for your meeting otherwise I would be there in person to object. Dr. Shirley C. Strum Shirley Strum 637 Windmill Ranch Rd , sstrum(S)roadrunner. com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; GTB6; .NET CLR 1.1.4322) 41.215.96.134 Kira Linberg From: jeffjeader@yahoo.com Sent: Monday, August 10, 2009 8:06 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: I am writing you re: the proposed developement at La Costa & Rancho Santa Fe. Are you determined to destroy every open space? I oppose the plans for a BIG BOX retail store in a residential neighborhood. I want the development designed to eliminate excess light that will ruin our "dark skies". I oppose increased traffic generated by the increased density and intensity of use. I oppose increasing the zoning for 128 additional condos, and oppose office buildings next to neighborhoods. Deff Leader 1043 Summer Holly Lane Encinitas, CA 92024 leff leaderQvahoo.com Mozilla/4.0 (compatible; MSIE 8.0; Windows NT 5.1; Trident/4.0; .NET CLR 1.0.3705; .NET CLR 1.1.4322; Media Center PC 3.1; yie8) 68.183.177.9 Kira Linberg From: RonBonQ@msn.com Sent: Monday, August 1 0, 2009 8: 1 3 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department , City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: CARLSBAD CITY COUNCIL, Living at 3305 La Costa Avenue since 1979 I've seen a lot of changes. This project will increase traffic tremendously ! Our past experience with the last major project that was done in that area caused nothing but inconvenience and dangerous situations to us all, tractor-trailers loaded with needed materials, and equipment, cement trucks, durt haulers, earth movers etc. etc. parading up and down the hill constantly, not to mention the use of their motor brakes coming down the hill. After the project was completed large trucks continue to use La Costa Avenue making their deliveries to the businesses that had been created. Hopefully, someone with the authority and consideration for others, will be able to reroute that traffic to Rancho Santa Fe Road on a permanent basis, it's safer and will be less hazardous to the residence's on La Costa Avenue . Thank You Ron Borodach RONALD BORODACH 3305 LA COSTA AVE., CA. 92009 USA RonBonQjSlmsn.com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; Trident/4.0; .NET CLR 2.0.50727; .NET CLR 1.1.4322; .NET CLR 3.0.04506.30; .NET CLR 3.0.04506.648; .NET CLR 3.0.4506.2152; .NET CLR 3.5.30729; MSN 9.0;MSN 9.1;MSN 9.6; MSNbMSNI; MSNmen-us; MSNcOTH) 99.30.177.42 Kira Linberg From: gljstj@aol.com Sent: Monday, August 10, 2009 8:25 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Please protect the dark slies of Olivenhain when you consider the HUGE project going on on La Costa and RSF RD. Our neighborhood as well as Rancho Santa Fe, has worked hard for this protection. Palomar College and their research will also be impaired, by any major lit areas around here. Thank you For your consideration. Geri Jones 3373 Calle Margarita Olivenhain, CA 92024 gl-ist1Qaol.com Mozilla/4.0 (compatible; MSIE 8.0; Windows NT 5.1; Trident/4.0; Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1) ; .NET CLR 1.0.3705; .NET CLR 1.1.4322; customieS) 75.49.37.6 Kira Linberg From: karen.mendez@wedbush.com Sent: Monday, August 10, 2009 9:56 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: I strongly oppose the plans for a BIG BOX retail store in a residential neighborhood. I do not feel the need for any further development of this area. In the last 15 years at least there has been way too much cement put in place that has taken away the cow pastures, fields of brush, horse trails, the rural environment of nature. DOwn the road in considerable years when things deteriorate and fall apart then I understand thingsd will need to be replaced to a small degree. Maybe they won't need to be replaced but just returned to a rural state! I want all development (if there is ANY) designed to eliminate excess light that will ruin our "dark skies". I strongly oppose increased traffic generated by the increased density and intensity of use. There is no benefit to those of us who have lived in Olivenhain,supported our local politicians/officials, and worked very hard to maintain the flavor and ambiance of our rural community. This project you are proposing will only cause our home prices to decline-which is very unfair to us-again we have been in the valley for more than 20 years. How can you overlook the fact that by approving this projecty you are okaying my quality of life to be negatively affected. As it stands now, my home is situated so that if anyone gets out of control and careens off the road-they can easily go right through the front yard of my neighbors home and end up in my front area where people are likely to be thus causing injuries or death! I cannot get into and out of my own driveway during several hours each day and it does not matter whether day or night-people are always speeding, big trash trucks and buses make tons of noise and pollution as they drive by. I oppose increasing the zoning for 128 additional condos, and w I oppose office buildings next to neighborhoods Have you look around and not noticed the fact that there is plenty of vacant office and retail space and surely you cannot think more is needed? Nothing is "needed". We will survive easily without and much better. There is no need for a Starbucks for example on every street corner. Why not keep demand high not supply? I ask that you deny the approval of this development and request you not approve any new development in the area. I also ask that you work hard to make sure all that is here is appropriate for our neighborhood and does not add to conjestion, traffic, increased population, noise, amout of cement, number of schools etc. Karen Mendez Carter 319 Rancho Santa Fe Rd Olivenhain, CA 92024 karen.mendez(3wedbush.com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; GTB6) 63.251.194.10 Marilyn Strong From: Dr Nora La Corte [drnora@webtv.net] Sent: Monday, August 10, 2009 10:03 AM To: Marilyn Strong Cc: drnora@webtv.net; billziefle@msn.com Subject: 25,000+ cars on La Costa Ave- just say NO Dear City Council, La Costa is already too impacted with traffic. More 4 minute lights could lead to more road rage accidents, pollution, and diminished quality of life. ' EMPTY STORES near La Costa Ave and El Camino Real should be filled (with another Henry's and Trader Doe's?) before more department/big box stores tarnish Carlsbad's image as a wonderful destination. Please, no more "Pedestrian"-Friendly Malls! They increase the frustration and pain of those challenged by disability- especially returning amputee vets and and our aging population. The Council has done a great job with beautiful Carlsbad (except for ugly Alga Rd). Dr Nora PS: The Council's foresight and financial prudence in these difficult economic times is most appreciated. A better solution can be found to increase city coffers. Kira Linberg From: josephcrilly@yahoo.com Sent: Monday, August 1 0, 2009 1 1 :45 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Dear Carlsbad City Council, As I am sure you are aware there is significant opposition to the proposed La Costa Town Center by Aspen Corp. As our ELECTED officials you are held responsible to uphold, protect and maintain the quality of life and condition of our city. This project does not solve or alleviate any deficiency that Carlsbad currently faces. Quite the opposite, it clearly creates the following problems: (to which the City has no proven answers: 1. Unresolveable traffic 2. Contribution to our city- wide and regional water shortage 3. Destruction of open space 4. Encroaching light, noise, commercial pollution I am also disgusted at the patronizing presentation that the developer gave, continuously referring to "sizzle" and I am greatly disappointed that the developers were treated as "old friends" by the Council more interested in the welfare of the developers rather than the TAXPAYERS OF CARLSBAD. Thank you and I look forward to the meeting tomorrow night. Joseph Crilly 3508 sitio baya Carlsbad, ca 92009 USA 1osephcrillv(3yahoo. com Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.0.3705; .NET CLR 1.1.4322; .NET CLR 2.0.50727; .NET CLR 3.0.04506.30; MS-RTC LM 8) 208.195.70.39 Kira Linberg From: mbrenker@hotmail.com Sent: Monday, August 10, 2009 12:44 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: Hello, I'm writing to express my concern over the big box regional shopping center being proposed at the juncture of La Costa Blvd and Rancho Santa Fe Rd. This location is only a few miles from my hourse, and I am very concerned about the construction of such a large shpooing center in the middle of what is currently a very nice residential area. I think this development will greatly increase traffic in the area and is not appropriate for the area. Thank you for taking my opinion into consideration. Margaret Brenker 3369 Rocking Horse Circle Encinitas, CA 92024 mbrenker(3hotmail . com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; .NET CLR 1.1.4322; .NET CLR 2.0.50727; InfoPath.l; .NET CLR 3.0.04506.30; MS-RTC LM 8) 165.109.1.240 Kira Linberg From: mk@MKPGroup.com Sent: Monday, August 10, 2009 12:58 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: We are extremely opposed to the development being proposed (heard it was approved)for the La Costa Town Square. It is not that we are against development - it's the nature and scope that is so offensive. I know you can do better with the planning and some people (council for tax revenues and developers) will make less money, but most should be pleased with the compromised outcome. For example lighting that won't ruin the Olivenhain dark skies, development that nestles in with the community and addresses the hideous congestion we have on RSF Road coming through (in and out)of Olivenhain. Thank you for your consideration as you design a solution that works for the community as well as the economy for Carlsbad and our neighbors. Kelli mk(3MKPGroup. com Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.9.0.13) Gecko/2009073022 Firefox/3.0.13 76.176.202.123 Kira Linberg From: eatruj@aol.com Sent: Monday, August 10, 2009 4:31 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Your Honor and Council Members: Subject: La Costa Town Square: My wife and I are opposed to the La Costa Town Square Project for the following reasons: 1. The project will add an additional 2000+ vehicles a day to La Costa Ave.(TRAFFIC SAFETY) WE HAVE A DIFFICULT TIME ALREADY LEAVING AND ENTERING OUR PROPERTIES. 2.Already the noise from current traffic exceeds the City's neighborhood noise guidlines(71Db)More autos/trucks will not make it better but WORSE. Vehicle noises prevents the La Costa Ave. residents from enjoying the use of their front yards. 3.Auto/Truck exhaust particulate matter will be inceased with the additional vehicles (2000+). This increase in particulate matter can effect the health of the Resident's on La Costa Ave. We were aware of the traffic issues at the time we purchase our home in 1988 and subsequent changes in traffic that occurred afterwards. But, we are now opposing any projects that will increase Auto and Truck traffic on La Costa Ave. without some type of mitigation so that living on La Costa Ave will be tolerable. Thank you, Ernie and Grace Trujillo Ernie Trujillo 2644 La Costa Ave. Carlsbad, Ca 92009 eatruKSaol.com Mozilla/4.0 (compatible; MSIE 8.0; Windows NT 5.1; Trident/4.0; GTB5; .NET CLR 1.1.4322; .NET CLR 2.0.50727) 75.32.241.146 1 Kira Linberg From: morebyles@aim.com Sent: Monday, August 10, 2009 5:17 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ####*#*#******#*#****#*****##*****#*********** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: I am concerned about the level of lighting proposed for the new commercial site at Rancho Santa Fe Road and La Costa Avenue. I am also concerned about the increased level of traffic that will undoubtedly move into the Rancho Santa Fe Road corridor in Olivenhain. Leslie Frumin 980 Via Di Felicita Encinitas, CA 92024 morebylesQaim.com Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.9.0.13) Gecko/2009073022 Firefox/3.0.13 71.154.212.134 Kira Linberg From: laniemeyer@roadrunner.com Sent: Monday, August 10, 2009 5:28 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: To the Mayor and City Council: My wife Linda and I reside at 3343 Fosca Street in Carlsbad and we both strongly urge the City Council not to rezone the 9.8 acre parcel at Rancho Santa Fe and La Costa Avenue for Residential High Density at the Meeting on Tuesday August 11, 2009. We strongly request a postponement of this plan element to a later date to allow more time for the homeowners in the immediately adjacent neighborhood to work with the City planning staff to identify acceptable alternatives for this parcel. We have lived at our home for over 20 years and believe that the proposed rezoning is not compatible with the immediately adjacent homes. Furthermore, a three story building at this location will negatively impact the view from our and our neighbor's homes. I do not believe the photos provided by the planning^department staff at the July 15 meeting adequately show the negative visual impact multi-family building will have on property owners in our neighborhood. /Attached a photo of the subject parcel taken from the back of our home. Our neighborhood has been in existence for over 30 years and I believe that the currently proposed reserving represents a significant negative impact to us and our neighbors. Respectfully Submitted, Roger and Linda Niemeyer 3343 Fosca Street Carlsbad, California (760) 944-9462 Email: laniemeyer(S)roadrunner . com Roger Niemeyer 3343 Fosca Street Carlsbad, CA 92009 USA laniemeverQroadrunner . com Mozilla/4.0 (compatible; MSIE 8.0; Windows NT 5.1; Trident/4.0; .NET CLR 1.1.4322; .NET CLR 2.0.50727; .NET CLR 3.0.04506.30; MDDR; .NET CLR 3.0.4506.2152; .NET CLR 3.5.30729) 66.166.41.146 Kira Linberg From: johnd@tfb.com Sent: Monday, August 10, 2009 10:45 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: I am writing to oppose the rezoning of the parcel west of Rancho Santa Fe Rd, north of LaCosta Ave. The added traffic burden that high density housing would create would be untenable for this area. My children went to LaCosta Heights Elementary on Levante and now attend LCC. The traffic patterns at the intersections of LaCosta Ave, Levante and Rancho Santa Fe are already troublesome. The safety of our kids will be affected. Please fix the intersections before you increase the traffic! Thank you, Dohn DeLand Dohn DeLand 3350 Del Rio Ct. Carlsbad, CA 92009 1ohnd(3tfb.com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 6.0; GTB6; SLCC1; .NET CLR 2.0.50727; Media Center PC 5.0; .NET CLR 3.5.30729; .NET CLR 3.0.30618) 72.14.141.183 Kira Lin berg From: surfsupmonday@yahoo.com Sent: Tuesday, August 11, 2009 9:01 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: I oppose the plans for a BIG BOX retail store in a residential neighborhood. I would like to have the council ask the developer to eliminate excess light that will ruin our "dark skies". I oppose increased traffic generated by the increased density and intensity of use. How does the council plan to deal with this? I oppose the increase the zoning for 128 additional condos, and office buildings next to neighborhoods. I ask you to deny the approval and request and make the development and its new shopping appropriate for our neighborhood. Thank you Carole surf supmondav(JDvahoo. com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; GTB6; .NET CLR 1.1.4322; .NET CLR 2.0.50727; .NET CLR 3.0.04506.648; .NET CLR 3.5.21022) 69.236.135.112 Kira Linberg From: paulseglund@yahoo.com Sent: Tuesday, August 11, 2009 9:53 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. **********************************************FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: Original Message From: Paul Seglund To: Carlsbad City Council RE La Costa Town Square proposal This is idiocy at its finest. With a new tax and environmental boondoggle staring us down, they want to further degrade the local environment by building this monstrosity. There are plenty of retail establishments & vacancies available to service this area. Enough of the subsidized housing too. That destroys home values and adds to the problems we have already. There are plenty of housing units available at market prices so don't burden taxpayers with new exhorbitant fees so someone can buy a home that if they cannot afford it should be renting anyway. Can't make it to the council meeting but feel free to use my comments against this project. We need to try to maintain the quality of life here otherwise there is no snese in staying. Paul Seglund Wealth Advisor CRPC Financial West Group (760)521-0314 cell (541)306-3071 office Paul Seglund paulseglund(Syahoo. com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; GTB6; .NET CLR 1.0.3705) 75.37.162.44 Kira Linberg From: Dean Work [deanwork@juno.com] Sent: Tuesday, August 11, 2009 11:11 AM To: Council Internet Email Subject: Tonight's Council Meeting - Proposed "La Costa Town Square" commercial development Council Members, We are residents of east Encinitas/Olivenhain and wish to express our opposition to the proposal. This is primarily a residential area and the effects of the Olivenhain longtime policy of "dark skies" will be adversely impacted. We do not need a big box store with its increased traffic in the area. Please act in a way to preserve the existing nature of the nearby neihborhoods. Thank you, Dean and Susan Work 3266 Brookside Lane Encinitas, CA 92024 Kira Linberg From: santaoli@cox.net Sent: Tuesday, August 1 1 , 2009 1 0:07 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department , City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Recently, I have been notified of plans to construct a large retail center near the Northern border of Olivenhain, part of Encinitas. We are committed to maintaining the semi-rural character of our community and we feel that while it is not in our city, the impact of parking lot lighting has a very significant impact that extends into our community. For that reason, we kindly request that the project, if approved, be required to maintain an absolute minimum level of parking lot lighting. We also request that you use lighting technology that is designed and tested so as to produce a minimum amount of stray light. George T. Santamaria, P.E. George Santamaria 722 Edelweiss Lane Olivenhain, CA 92024 santaoliOcox.net Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1j GTB6; .NET CLR 1.1.4322) 67.209.66.172 point at the top of the hill, allowing all the noise to roll down over our homes, shows that this is a specific point of impact on the larger community. The inclusion of a condition to replace and upgrade this structure would seem to be appropriate mitigation. As a homeowner who has lived in this area for the last 11 years I have consistently seen the traffic planning around this intersection fail to adequately meet the real world requirements. Specifically, when the current CVS location was developed (over 8 years ago) there was a last minute need to expand La Costa avenue east bound to accommodate the main exits from the development. This meant that the homeowners had to yield to the developer a strip of association property that moved La Costa Avenue approx 10 ft closer to their homes all along this stretch of La Costa. This need was not identified or included in any of the plans that had been approved by both the planning commission and the city council and almost resulted in an eminent domain taking by the city. We saw our buffer to traffic reduced and a wood fence that is wholly inadequate, not to mention a graffiti and vandalism magnet, installed. Our quality of live was definitely damaged by this original planning ove! rsight. Since then an additional development on the south west corner of La Costa has been completed in such a way that there is insufficient real estate available to cost effectively widen La Costa to accommodate the right turn traffic from La Costa north bound on Rancho Santa Fe. As a local homeowner my experience is that his is an intersection that continues to be poorly planned for and our remaining recourse is to ask that the minor protections offered by this fence be appropriately upgraded if in fact permission to move forward with the project is given. Second Item In regard to the second request, I am simply asking that as part of a high density development there be conditions for on site recreation such as a swimming pool and park like areas. Over the past 8 years, since the commercial development on the corner of Rancho Santa Fe and La Costa was completed, we have had numerous instances of vandalism, graffiti and other disturbances that are primarily youth related. There have been multiple occasions where the Carlsbad Police have had to be called to remove offending youth or others. Providing high density residential development in the area is appropriate for encouraging appropriate use of the commercial development, but it should also include recreational and other opportunities within that development that will reduce roll over impact on surrounding neighborhoods. I may be contacted at (760) 944 6305. Thank you for considering my requests. Frances Ryglewicz 7700 Corte Promenade Carlsbad, CA 92009 Frances Ryglewicz 7700 Corte Promenade Carlsbad, CA 92009 francesr@hzs.com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; .NET CLR 2.0.50727; InfoPath.l; .NET CLR 1.1.4322; .NET CLR 3.0.04506.30; MS- RTC LM 8) 71.140.123.99 Kira Linberg From: francesr@hzs.com Sent: Monday, August 10, 2009 3:49 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: The EIR states that there are negative impacts from this development in the areas of noise, pollution and traffic that can, not be fully mitigated. It also identifies that even so this is a relevant and appropriate development for the area and in line with the broader goals of city development. A statement that I can fully understand and appreciate. I also accept that developers have the right to develop their properties. However, the fact that these areas cannot be fully mitigated and that even so the development should be approved does not mean that some additional care to the surrounding neighborhoods should not be included in the final development project. In that regard I have two requests today . The first is a request to upgrade inadequate wood fencing adjacent to the site as part of the mitigation efforts . The second has to do with providing adequate recreation facilities in the proposed high density residential section. First Item In regard to the first item. There is a wood fence on La Costa Avenue, between Rancho Santa Fe and Calle Timeteo (approx a 100yrd length) that is directly opposite the key access point for the planned development. It seems appropriate that this should be upgraded and replaced by with a more robust sound controlling and secure structure. My reasons for this request are: 1. This stretch of La Costa is directly opposite one of only two exit methods from the upper level of the proposed development that will allow drivers to proceed either way on Rancho Santa Fe Road, (there are multi access in methods but limited out access) 2. This access driveway will have a four way traffic signal on La Costa Avenue, where there is currently no signal, causing traffic build up etc. 3. A review of the site plan will also show that there is a concentration of restaurant and other pads located in this area that will be one of the target activity areas for the development. 4. The additional development of office structures further east on La Costa will create high traffic impact in this region during key timeframes. All of these facts would indicate that this will be a high traffic area, with considerable noise and consistent activity. The location of this access point directly across from the On The Park housing development is going to heavily impact the environment of the homeowners in this geography. The forecasted traffic and noise levels and specifically the concentration of vehicles stopping and starting in this vicinity, along with the positioning of this access l Kira Linberg From: dfkmr@aol.com Sent: Monday, August 1 0, 2009 2:45 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. Below, please find the information that was submitted: La Costa Town Square-Support for the Project. I have lived for 22 years at this address which is 2 blocks from the proposed project. It has been zoned for this for 20 years and I totally support it. Please approve the project. Daniel Ryan 3521 Sitio Baya Carlsbad, CA 92009 df kmr(Saol . com Mozilla/4.0 (compatible; MSIE 7.0; AOL 9.0; Windows NT 5.1; (Rl 1.6); .NET CLR 1.0.3705; .NET CLR 1.1.4322; Media Center PC 4.0) 207.200.116.13 Kira Linberg From: kevin@healthcaregrp.com Sent: Monday, August 10, 20092:18 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: As a former resident of this La Costa neighborhood, I would implore you to APPROVE the La Costa Town Square development. This site has long been designated and planned as a retail/commercial site, and would bring much needed services and employment centers to the area. The improvements to RSF Road completed over the last few years will accomodate the increased traffic generated by the new development, and the new shopping will reduce many trips currently made from this development to the west into Encinitas or South Carlsbad. The owners have already reduced the size of the planned development, and should be allowed to build out the property for the use the City intended when it was zoned. Thank you. Kevin Moriarty 9619 Chesapeake Drive San Diego, CA 92123 kevinOhealthcaregrp . com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; .NET CLR 1.1.4322; .NET CLR 2.0.50727; .NET CLR 3.0.04506.30; .NET CLR 3.0.4506.2152; .NET CLR 3.5.30729) 216.70.251.3 Kira Linberg From: mjnortman@att.net Sent: Monday, August 10, 2009 11:03 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE.********************************************** Below, please find the information that was submitted: I love the idea of having a shopping center closer to our community of Olivenhain big box or not. How about a wall mart!! Traffic what's new., but please consider low light lightng for our dark skys that we have always had here! mlnortmanQatt.net Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; .NET CLR 1.1.4322; PeoplePal 6.2; PeoplePal 3.0; .NET CLR 2.0.50727; .NET CLR 3.0.4506.2152; .NET CLR 3.5.30729) 76.217.129.191 georgia@georgiamurphy.com Mozilla/4.0 (compatible; MSIE 8.0; Windows NT 6.0; Trident/4.0; SLCC1; .NET CLR 2.0.50727; Media Center PC 5.0; MDDC; .NET CLR 3.5.30729; .NET CLR 3.0.30729; InfoPath.l; OfficeLiveConnector.1.4; OfficeLivePatch.1.3) 76.176.204.147 We hope the City Council will recall their 2005 policy decision. During this March 2005 policy discussion. Mayor Bud Lewis stated he believes residents do not want the city to make it easier for BIG BOX retail outlets such as Wal-Mart, Home Depot and Fry's Electronics to locate in Carlsbad. According to other news articles, other council members said they would not approve a project "out of whack with residential areas." We agree and hope the council remembers their 2005 decision. Everyone agrees this project will negatively impact our quality of life and the results can not be mitigated. According to the City's Environmental Impact Report (EIR), it "finds that the project will result in significant and unmitigated project-specific and/or cumulative impacts to transportation/circulation, air quality (and) noise." If the impacts are unmitigatable, why would they grant a zoning increase from the existing "low to medium" to "residential high density?" Why approve a new BIG BOX store in the middle of a residential neighborhood? Why attract additional unnecessary regional traffic into our residential community by locating a BIG BOX store there? We understand the need for restaurants, grocery stores and local shopping, but disagree with the approval of a BIG BOX retailer, office buildings and increased residential zoning. Think of all the traffic and noise during construction which could take years since they want to "Orange County" it, blasting off the ridges and filling in the pristine and rare coastal sage valleys. Think of even more traffic when it is finished. The project will generate an increase of 25,516 average daily car trips. Many trips will be added to La Costa Avenue which, if widened anymore, would be at residents' doorsteps. Rancho Santa Fe Road is already a treacherous "highway" for pedestrians or cyclists to cross. Morning traffic jams for students traveling to and from the adjacent La Costa Canyon High School will be worse and frequent car accidents will become more so. The City's solution: More traffic lights! Additional traffic lights mean more waiting in long lines of congestion, smog, and noise. The developer's solution to noise is more noise. They propose putting in a large fountain in the outdoor eating area to mask the traffic noise! Should all the nearby residents do the same? Unfortunately, they're adding these fountains to mask the noise despite a Stage 2 Drought alert. Why should residents have to contend with this? We don't need more large stores. Look at all the already empty big boxes nearby: Home Depot Expo, Linens fn Things, Circuit City, to name a few. This is poor planning and it should go back to the drawing board. We must demand the City Council protect our neighborhood: NO BIG BOX, no regional shopping center, no upzoning. Attend the Carlsbad City Council meeting at 6 pm Tuesday Aug. 11 located at 1200 Carlsbad Village Dr. (Carlsbad Village Drive exit east at 1-5). Ask your neighbors to come, too, if they value a livable community. North County Advocates is a group of area citizens who organized to ensure good community planning in Carlsbad and Encinitas. We will be watching the decision of each Carlsbad City Council member and reminding voters of their decisions at election time. Pat Bleha, Carlsbad, North County Advocates Bruce Ehlers, Olivenhain, North County Advocates This Tuesday, August llth 6:00 pm at City Hall 1200 Carlsbad Village Dr. (just east of 1-5) Let them know ... you oppose the plans for a BIG BOX retail store in a residential neighborhood, oppose increasing the zoning, oppose office buildings next to neighborhoods, oppose increased traffic, noise and glaring light in the nighttime sky. Ask that they deny the approval and request they make the development and its new shopping appropriate for our neighborhood Learn more by ... Review project plans online at ... http://www.carlsbadca.gov/planning/4eir.html Guest Column form this week's Coast News ... Does La Costa need a BIG BOX regional shopping center? Does your vision of La Costa's residential character include multi-story office buildings, regional department stores or the possibility of a WalMart? It could if the Carlsbad Planning Commission has their misguided vision approved by the City Council at their August llth meeting. . The Carlsbad Planning Commission recently approved a massive development for La Costa including 284,000 square feet of shopping center, 55,000 square feet of multi-story office buildings, 64 single family houses and increased zoning density for an additional 128 condos on 83 acres. Included in this proposal is a BIG BOX store which, until recently, was slated to be a Kohl's department store. Kohl's withdrew from the project leaving a large, empty BIG BOX available to be filled by another regional retailer. This project is located along Rancho Santa Fe Road just east of La Costa Blvd. This regional shopping center promises to bring more traffic, noise, congestion and urban clutter to the middle of the La Costa, Southeast Carlsbad and nearby Olivenhain. Text of attached flyer ... Does La Costa need a BIG BOX regional shopping center? Does your vision of La Costa's residential character include multi-story office buildings, a regional department store or the possibility of a WalMart? Warning ... If unchanged, the current plans for the massive development along Rancho Santa Fe Road just east of La Costa Blvd will result in significant increases in traffic, noise, light and excessive blasting and grading. Background ... The Carlsbad Planning Commission recently approved a very large development for La Costa including 284,000 square feet of shopping center, 55,000 square feet of multi-story office buildings, 64 single family houses and increased zoning density for an additional 128 condos on 83 acres. Included in this proposal is a BIG BOX store which, until recently, was slated to be a Kohl's department store. Kohl's withdrew from the project leaving a large, empty BIG BOX available to be filled by another regional retailer. This regional shopping center promises to bring more traffic, noise, congestion and urban clutter to the middle of the La Costa, Southeast Carlsbad and nearby rural Olivenhain. What you can do ... Get involved now! Tell your neighbors Call your City Council at (760) 434-2830 Doin your neighbors, attend this week's City Council City Council Meeting 6:00 pm at City Hall 1200 Carlsbad Village Dr. (just east of 1-5) WHAT CAN YOU DO ... Come voice your opinion at the Carlsbad City Council meeting on Tuesday Aug llth at 6pm. Or just come to the meeting to show your support ... We'll have bright lime-green lapel labels to wear. Or let them know by sending them a web/email message at ... http://www.carlsbadca.gov/contact/?sendto=City%20Council Or call the Carlsbad City Council at (760) 434-2830 and tell them directly. WHAT SHOULD YOU TELL THEM ... Let them know you .. oppose the plans for a BIG BOX retail store in a residential neighborhood, want the development designed to eliminate excess light that will ruin our "dark skies", oppose increased traffic generated by the increased density and intensity of use, oppose increasing the zoning for 128 additional condos, and oppose office buildings next to neighborhoods Ask that they deny the approval and request they make the development and its new shopping appropriate for our neighborhood Bruce PS ... Remember it is at the Carlsbad City Hall, not Encinitas Kira Linberg From: georgia@georgiamurphy.com Sent: Monday, August 10, 20099:50 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Dust wanted to let you all know that not all of the Olivenhain residents oppose the new center. My husband and I support the growth, welcome the new jobs and opportunty to spend more of our hard earned dollars in the best managed city in North County! If your not growing you're shrinking...people are tired of driving to Oceanside, San Marcos and Vista for adequate shopping, and why does target get to monopolize the area? We welcome some competition. As for the dark skies...please it's 2009...maybe if it weren't so dark on Lone Jack Road people could keep their cars on the road! Sincerely, Georgia and Bob Murphy Olivenhain Residents MORE DEVELOPMENT IN LA COSTA ... means more traffic and light glare in Olivenhain. The new project, La Costa Town Square, is a massive development including retail, residential and commercial development placed high on a hill (and on top of a soon-to-be-filled valley) in La Costa. It is located less than a mile from Olivenhain's northern border and promises to generate an additional 25,000 Average Daily Car Trips (ADTs). The project includes a large regional department store and will draw regional traffic, much of which will be funneled through Olivenhain. The current plans call for a 98,000 square foot, 2-story department store plus grocery, two office buildings and 172 residential units. This new development in La Costa will undoubtedly fill the night skies of Olivenhain with glare. The development, located at Rancho Santa Fe Road and La Costa Blvd, is only about a mile form much of the northern portion of Olivenhain (Copper Crest, Lone Hack and Via de Felicita). If Carlsbad's City Council approves the project as is, there is currently little language in the approval to protect our dark skies. Please attend the Carlsbad (not Encinitas) City Council meeting on Tuesday night to ask that they severely restrict exterior lighting on this project to protect our dark skies. Carlsbad City Council Meeting This Tuesday, August llth Kira Linberg From: dwms@roadrunner.com Sent: Monday, August 10, 2009 8:35 AM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: Am very concerned about the lighting in the new La Costa center. I live at the end of Lone Dack Road and I already have a light glow from the intersection of Rancho and La Costa ave. I know there are ways to reduce the lighting and glare. It will save energy and create calmness with softer more focused lighting. Thank you for listening. diane Williams 3311 lone hill lane olivenhain, ca. 92024 usa dwmsQroadrunner.com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 5.1; (Rl 1.5); .NET CLR 1.1.4322; .NET CLR 2.0.50727) 76.176.196.216 Kira Linberg From: afiebing@roadrunner.com Sent: Sunday, August 09, 2009 12:38 PM To: Council Internet Email Subject: CITY OF CARLSBAD | CONTACT US A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Council. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: I have been follwing the progress of the La Costa Town Square development. We live very close to this area and are looking forward to having a high class center in our neighborhood. I am writing this letter to express my opinion against having a big box store in this development. There are plenty of walmart type options within 10 minutes of our neighborhood and would like this Town Square to match the surrounding neighborhoods. I know some people oppose everything ( after they have their house ) I just want this to be a center we can be proud of, not a discount shopping area. Please do a good job planning this out and make it nice like San Elijo or the area in Olivenhain. Art Fiebing 3012 Garboso St. Carlsbad, CA 92009 USA af iebing(5)roadrunner. com Mozilla/4.0 (compatible; MSIE 7.0; Windows NT 6.0; SLCC1; .NET CLR 2.0.50727; Media Center PC 5.0; .NET CLR 3.0.04506) 66.74.205.187 3011 Garboso Street Carlsbad CA 92009 August 5,2009 Honorable Charles A. "Bud" Lewis, Mayor; Ann J. Kulchin, Mayor Pro Tern; and Council Members Matt Hall, Mark Packard and Keith Blackburn RE: Proposed La Costa Town Square Agenda: August 11,2009 INTRODUCTION We live a few blocks from the proposed project and support the development of La Costa Town Square to provide shopping opportunities closer to our home. However, there are two substantial deficiencies in the Environmental Impact Report: electricity use and water supply. The EIR states a major 82-acre retail, commercial and residential development will have "no significant impact" on electricity demand or water supply. Therefore, no mitigation measures are proposed. In addition, the EIR, and accompanying Planning Commission recommendations, do not consider the potential future deterioration of the shopping center and the protection of the surrounding residential communities from that deterioration. Again, no mitigation measures are proposed. We respectfully request the Council to correct these three glaring deficiencies, and adopt appropriate mandatory mitigation measures, before the proposed center is approved. DISCUSSION I. ELECTRICITY DEMAND The Environmental Impact Report declares there is no significant impact from the project to public services and utilities or electricity demand, and, therefore, no mitigation measures are needed. If electricity supplies were truly abundant now and for the foreseeable future, there would be no need for new electricity generation plants, controversial transmission lines to connect to distant generation sites, or Smart Meters which are needed to "... save energy which saves natural resources and reduces the need to build new power plants or other equipment". (SDG&E.com/smartmeter/benefits). There would be no concern about aging power plants and re-siting requests, deteriorating and inadequate national grid systems, nuclear power waste depositories, "zombie" appliances, or increasing rates and tariffs for consumers facing summer black-outs. A credible and adequate analysis would place the project in the context of available electricity supply and demand over the next 20 years, and acknowledge the cumulative impact of a large commercial, retail and residential development. The EIR consultant responds Title 24 state requirements will apply to the project and be sufficient. Title 24 sets MINIMUM energy efficiency standards for new construction. "Building to code" is required. Carlsbad can do better. RECOMMENDATIONS 1. Require the latest technology for "green building" certification for the commercial and retail enterprises. The City should require adherence to the recommendations of the U.S. Green Building Council and its Leadership In Energy and Environmental Design ("LEED") standards for high-performance, sustainable buildings. 2. Require the installation of on-site solar electricity generating systems for the commercial and retail facilities. On-site solar generation technology is available and feasible. We have it on our home. It is time for new shopping centers to add to the supply of electricity instead of increasing the demand. "Solar ready" rooftops, as recommended by the Planning Commission, will not achieve the goal. H. WATER SUPPLY The Environmental Impact Report finds the project will have no significant impact on water supply and, therefore, no mitigation measures are required. If our water supply were stable and predictable for years to come, there would be no need for desalination plants, or for conservation measures and rate increases that are being imposed on households, or for yellow cards to distribute to your neighbors because"... our region is feeing a serious water shortage." (SDCWA yellow cards). And there would be no reason for farmers to cut down their mature orchards for lack of water. An adequate analysis would acknowledge the fact that the project is located in a semi-arid climate with limited annual rainfall that is presently in the throes of a prolonged drought. All of the water in our area is imported through long aqueducts from the Colorado River water basin or the State Water Project. The demands and legal restrictions on both sources are increasing, while the supply is diminishing. Drought, pollution, and urbanization exact an increasing toll on those supplies. The EIR consultant indicates if water cannot be supplied, the local water district can deny service. What happens then to all the new buildings, fountains and landscaping? RECOMMENDATION A credible and adequate analysis would admit a major shopping center will increase water demands in a time of scarcity. Mandatory mitigation measures should be proposed, including on-site water reclamation. The sight of shopping center fountains flowing in the daylight as homemakers restrict their water use does not increase public support for conservation measures or rate increases. III. FUTURE ECONOMIC IMPACT In approving a large retail and commercial project, how will the City protect the surrounding residential neighborhoods from future decay of the center - an event that can be precipitated abruptly by the closure of the proposed single anchor retail store or the large grocery? In Carlsbad, the proposed "La Costa Town Square" is unique because it is almost entirely surrounded by homes. Even one of the two major access roads, La Costa Avenue, is primarily a residential street between El Camino Real and Rancho Santa Fe Road. The established and new residential neighborhoods that are around and near the proposed shopping center are beautiful. The homeowners have significant property investments that have been maintained their value, in some areas, for more than 35 years. Many shopping centers change substantially in a much shorter time. A few years ago, new enclosed air-conditioned malls devastated downtown retail stores and restaurants. Now, such malls are obsolete - anchored by empty stores and shuttered shops. What begins as a sparkling commercial magnet deteriorates into rodent- infested vacant buildings surrounded by empty parking lots filled with weeds, litter, and criminal activity. We have personal experience with this tragedy from 35 years of residence in another California community. Shopping centers (both open and enclosed), once new and popular, withered and rotted from a combination of mismanagement and anchor- anchor-store closures. Nearby residential values were adversely impacted, and driving distances for customers increased as they went to the latest new mall farther away. The situation is acknowledged in the letter from the CBRE consultants as they describe... "... what constitutes the environmental impact known as urban decay. The leading court case on the subject, Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184,1204, described the phenomenon as'a chain reaction of store closures and long-term vacancies, ultimately destroying existing neighborhoods and leaving decaying shells in their wake."' (emphasis added) RECOMMENDATION The City of Carlsbad should direct their consultants to explore a financial vehicle for the developer to submit a bond or other "insurance" against future deterioration. Perhaps the zoning could revert to a non-commercial or public use if the property becomes a financial or physical drain on the City and its residential neighbors. The neighborhood should be protected from the downside of commercial development. CONCLUSION A progressive charter city like Carlsbad - a leader in areas such as municipal wastewater reclamation and community services - can work in cooperation with the developer to publish an adequate Environmental Impact Report and to make the proposed shopping center a standard-bearer for an environmentally appropriate, neighborhood-friendly facility that will maintain its value for decades. As its neighbors, we would welcome such a development. ne Kira Linberg From: Sent: To: Subject: lorindy@pacbell.net Wednesday, July 15, 2009 4:07 PM Manager Internet Email CITY OF CARLSBAD | CONTACT US AGENDA ITEMS f c: Mayor •', City Council City Manager City Attorney City Clerk AUG I 1 2009 CITY OF CARLSBADCITY CLERK'S OFFICE A visitor to the City of Carlsbad Web site has completed and posted the "Contact Us" form to department, City Manager. ********************************************** FOR SECURITY REASONS, DO NOT CHANGE THE SUBJECT LINE. ********************************************** Below, please find the information that was submitted: To Whom It May Concern, Regarding the proposed La Costa Town Square, July 2009 Views: For commercial portion, against residential portion. I realize that the City needs the revenue from taxes and developer fees that will be generated by this plan, but the financial benefit is offset by the negative impact the overbuilding of residential development will have on our community. Property values are falling due to the blight of foreclosed homes which sit on the market for up to 6 months before finally being sold at a price far below the original mortgage amount. If we continue to build new homes, the incentive for buyers to take the foreclosed and resale homes off the market will be nil, and will result in a further erosion of property values, and reduction in property tax revenues, not to mention further crowding of our already congested roads. The addition of 64 large homes (with an average of 8 cars per 4-bedroom residence), plus another 128 condominiums (with an average of 3 cars per unit) would add close to 1,000 daily commuters to our neighborhood streets. We don't need more cars on our streets, we don't need more residential crowding. We don't need a further erosion of property values. Why is it necessary to cover every inch of land with a house? Do we want to become the quagmire that is Los Angeles, or do we pattern our city after Santa Barbara, a picturesque community where housing density is kept at a minimum, where shops, grocery stores, and city amenities are all within walking distance with a shuttle to outlying areas, and where property values are high due to scarcity of inventory? It is not the responsibility of La Costa to accomodate everybody who wants to live in La Costa. Many people would dearly love to live in Rancho Santa Fe, but you don't see that community building high-density development to the detriment of the country atmosphere just to be fair to everyone who wants to live there. When you can afford the area you want to live in, you move there. This leads me to the commercial portion of La Costa Town Square. I am strongly IN FAVOR of this commercial development. We need less residential development and more commercial development to create jobs for our local teenagers and adults. I highly doubt that a grocery store or even a box store will draw traffic from San Marcos, Escondido, Oceanside or even Encinitas. Why should it? Those communities have their own box stores and grocery stores. The commercial portion of the plan could actually reduce traffic on our roads (as well as reducing our girth) by encouraging residents to walk to the grocery store rather than to drive down La Costa Avenue or Rancho Santa Fe Rd. to El Camino real to shop. One gas station is enough, but we could sure use another Post Office. i Perhaps the City could give tax rebate incentives for Carlsbad employers to hire Carlsbad residents, and add a "road use tax" to the employer who hires more than 5% of its employees from out of Carlsbad zip codes. Idealistic, perhaps, but it would be wonderful for residents. It would reduce traffic and create a walkable community. I love the idea of the Town Square. Aviara has it's own center within walking distance. Does Aviara have a glut of traffic? No. La Costa needs this center as much as it does NOT need any further residential development. Sincerely, Lorinda Pate Ld~Costa Resident in letter ! •»> 'lorindy(3pacbell. net Mozillia/4.0 (compatible;. MSIJE 8.0; Windows NT 5.1; Trident/4.0; YPC 3.2.0; .NET CLR 1.1.4322; .NET dLR 2.0.50727) ; "* * 99l30.178.92 , J 8HEPPARD MULLIN ATTORNEYS AT LAW 501 West Broadway | 19th Floor | San Diego, CA 92101-3598 619-338-6500 office | 619-234-3815 fax | www.sheppardmullin.com August 11, 2009 Writer's Direct Line: 619-338-6646 jponder@sheppardmullin.com Our File Number: 19HR-139638 Via Messenger The Honorable Claude A. Lewis, Mayor Council Members City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 Re: La Costa Town Square Project: Response to North County Advocates Letter Dated August 7,2009 - City Council Hearing August 11,2009 - Agenda Item 7. Dear Mayor and Council Members: This firm represents La Costa Town Square, LLC ("LCTS") in land use matters related to the La Costa Town Square Project ("Project") in the City of Carlsbad ("City") scheduled for a public hearing before you on August 11,2009. We are writing to respond to and add clarity to the issues raised in the North County Advocates' ("NCA") letter to the City dated August 7, 2009. (Exhibit 2). NCA's letter does not provide any information significantly different from its letter to the Planning Commissioners on July 14, 2009. On August 7,2009, we provided you with a detailed response to each of NCA's claims. Rather than repeat that exhaustive discussion, attached is an Executive Summary briefly responding to the points NCA raises in its most recent letter. (Exhibit 1). SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 11,2009 Page 2 City staff have done an excellent job reviewing and analyzing the Project. Through CEQA's exhaustive technical studies and public outreach process, the City should be confident that it has made an adequate, good faith disclosure of the issues. John E. Ponder for SHEPPARD, MULLIN, RICHTER & HAMPTON LLP W02-WEST:8JWF1\401713444.1 CC: Ron Ball, Esq., City Attorney, w/attachments Ron Kemp, Esq, Deputy City Attorney, w/attachments Van Lynch, City Planner, w/attachments Lorraine M. Wood, City Clerk, w/attachments Pat O'Day, w/attachments SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 11,2009 Page 3 Exhibit 1 Executive Summary Response to North County Advocates/Everett DeLano Letter Dated Au£ust 7.2009 No Recirculation Is Required Applicable Law on Recirculation * "Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications..." (CEQA Guidelines Section 15088.5(b)). * Recirculation is only required whenever "significant new information" is added to the EIR to a degree where it "deprives the public of meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project proponents have declined to implement. (CEQA Guidelines Section 15088.5; emphasis added). The Facts: * The changes to the draft EIR are only minor, administrative modifications correcting technical errors in the EIR text and adjusting mitigation measures to conform to the law without any new impact on the environment. * The traffic report in the appendices, which is considered part of the EIR, has always been correct so the modifications are just an administrative clarification of the main EIR text. * After clarifying that the City had no legal authority to amend another city's Capital Improvement Program to add a new traffic improvement project, the EIR removed a proposed condition for LCTS to pay a fair share toward such traffic improvement projects. This did not result in "new significant information" because both the DEIR and the FEIR came to the same conclusion — a significant unmitigated impact to traffic. A Statement of Overriding Consideration is needed with or without the fair share traffic mitigation measure. * The change did not deprive the public of a meaningful opportunity to comment on the changes: * All EIR changes were available in paper and on-line 14 days before the Planning Commission hearing on July 1,2009. * The public was given an opportunity to comment during the July 1,2009 hearing. * The public wrote additional comments between the July 1 and July 15, 2009 hearings. * The public will have another opportunity to comment during the City Council hearing on August 11,2009. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 11,2009 Page 4 Extra-Territorial Traffic Impacts Were Properly Addressed Applicable Law: * Mitigation measures do not have to be imposed if they are not "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors." That is CEQA's definition of "feasible." (CEQA Guidelines § 15364; emphasis added). * With respect to each significant environmental effect, a lead agency may find that changes which mitigate or avoid the significant environmental effect "are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency." (P.R.C. § 21081(a)(2)). * With respect to each significant environmental effect, a lead agency may also find that there are specific economic, legal, social, technological, or other considerations" that make mitigation measures or alternatives infeasible. (P.R.C. § 21081(a)(3)). The Facts: * There is no lawful mechanism for implementing fair share fees as mitigation measures because fair share fees only count as mitigation when it can be shown that payment of the fees is "part of a reasonable plan of actual mitigation that the relevant agency commits itself to implementing." (Anderson First Coalition v. City of Anderson). The City has no legal authority to amend another city's Capital Improvement Plan in order to create a legal mechanism. * Therefore, requiring a fair share payment is not a feasible mitigation measure the City can adopt, the responsibility is within the jurisdiction of another public agency, and it would be inequitable to impose the measure on LCTS. SHEPPARD MULLIN RICHTER & HAMITON LLP Mayor & Council Members August 11, 2009 PageS Water Supply Is Adequate * NCA quotes the Vineyard case to argue there is not a sufficient water supply for LCTS. * The Vineyard case is distinguishable because it involved a multi-phased 6,000-acre mixed use project with 22,500 homes. Having more than 500 homes, that project clearly qualified as a "water demand project" and triggered a CEQA requirement for the water agency to prepare an official Water Supply Assessment ("WSA") document. The "principles for analytical adequacy under CEQA" quoted by NCA's attorney applies to the sufficiency of that project's WSA. The LCTS project is not a "water demand project" because its water use is less than 250,000 gpd (i.e., the equivalent of a 500-unit residential project). (CEQA Guidelines section 15155(a)(l)). The EIR estimates the Project's water use to be only 186,000 gpd. Although a WSA was not required, the City chose to include an exhaustive discussion of LCTS water supply in EIR Section 5.11.1. * However, the Vineyard case affirmed that an EIR can rely upon the analysis in an Urban Water Management Plan to justify a project's water supply. * LCTS's long-term water supply over the next 20 years has been planned for because the project was included in Otay Municipal Water District's 2007 Urban Water Management Plan. * LCTS is a "water-wise" project. Page 6-28 of the EIR describes some of the measures the Project is required to take to promote water conservation and efficiency as follows: 1. Create water-efficient landscapes with native, drought-resistant species. 2. Install water-efficient irrigation systems and devices, such as soil moisture- based irrigation controls. 3. Use reclaimed water for landscape irrigation. Install the infrastructure to deliver and use reclaimed water. 4. Design buildings to be water-efficient. Install water-efficient fixtures and appliances. 5. Restrict watering methods (e.g., prohibit systems that apply water to non- vegetated surfaces) and control runoff. 6. Restrict the use of water for cleaning outdoor surfaces and vehicles. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 11,2009 Page 6 7. Implement low-impact development practices that maintain the existing hydrologic character of the site to manage storm water and protect the environment. 8. Devise a comprehensive water conservation strategy appropriate for the project and location. The strategy may include many of the specific items listed above, plus other innovative measures that are appropriate to the proposed project. 9. Provide education about water conservation and available programs and incentives. * Finally, with regards to reclaimed water, page 5.11-14 of the EIR states that installation of reclaimed water lines for landscape irrigation is a standard requirement for projects of this scale in order that the alternative irrigation system is available for connection when reclaimed water service is extended to the project area. LCTS looks forward to the day when reclaimed water service is available to the area so this required on-site infrastructure can be put to good use. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 11,2009 Page? The Project's Alternatives / Mitigation Measures Have Been Adequately Analyzed With little or no explanation, NCA repeatedly asserts that the EIR inadequately addresses additional alternatives / mitigation measures to reduce environmental impacts. Adoption of NCA's recommended measures either are not required, have already been done, or would violate CEQA. Applicable Law: * CEQA imposes no requirement for an EIR to analyze mitigation measures that are not legally feasible. (CEQA Guidelines § 15126.5(a)(5)). * Lead agencies are not permitted to reduce the number of housing units as a mitigation measure when other feasible mitigation measures are available. (CEQA Guidelines § 15092(c)). * "[A]n EIR need not analyze ever imaginable alternative or mitigation measure; its concern is with feasible means of reducing environmental effects. [Citation]. Under the CEQA statute and guidelines a mitigation measure is 'feasible' if it is 'capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.' [Citations] In keeping with the statue and guidelines, an adequate EIR must respond to specific suggestions for mitigating a significant environmental impact unless the suggested mitigation is facially infeasible. [Citations.] While the response need not be exhaustive, it should evince good faith and a reasoned analysis. [Citations.]" (Los Angeles Unified School Dist. v. City of Los Angeles (1997) 58 Cal.App.4™ 1019, 1029; emphasis added). * '"CEQA does not require analysis of every imaginable alternative or mitigation measure." [Citation.].. .A lead agency's 'duty to condition a project approval on incorporation of feasible mitigation measures only exists when such measures would [avoid or] 'substantially lessen' a significant environmental effect.' [Citation.] 'Thus the agency need not, under CEQA, adopt every nickel and dime mitigation scheme brought to its attention or proposed in the project EIR.'" (Gilroy Citizens for Responsible Planning v. City ofGilroy (2006) 140 Cal. App. 4th 911; emphasis added). The Facts: * Road Traffic Noise. NCA petitions the City to analyze a project alternative that avoids placing homes in areas that would be impacted by road traffic noise. The EIR imposes other feasible options, such as the use of sound walls and other noise barriers to reduce the road traffic noise. CEQA prohibits lead agencies from reducing the SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 11,2009 PageS number of housing units as a mitigation measure when other feasible mitigation measures are available. (CEQA Guidelines § 15092(c)). * Blasting. NCA petitions the City to analyze a project alternative that would avoid all blasting. Avoiding all blasting would reduce the footprint for the residential portion of the project. CEQA prohibits lead agencies from reducing the number of housing units as a mitigation measure when other feasible mitigation measures are available. (CEQA Guidelines § 15092(c)). The EIR and City Blasting Policy detail mitigation measures (portable sound wall, advance notification to area homeowners, posting insurance certificates, pre- and post-blast inspection of homes) that reduce the blasting impacts. Avoiding all blasting is already an element of the "No Project: No Development Alternative," that the EIR analyzes and rejects because it would not achieve important project objectives, such as strengthening the City's tax base, providing shopping and job opportunities, ensuring that the commercial services under the La Costa Master Plan are fulfilled, offering additional residential areas with a range of housing types and prices, on meeting the objectives of the General Plan's land use designations for this site. See Candidate Findings at pp. 34-36. * Flooding. NCA petitions the City to analyze a project alternative that would avoid placement of homes in areas subject to flooding. The EIR imposes other feasible options, such as construction of walls, levels of grading, and notification in the CCRs to reduce the significance of property damage to below a level of significance. There is already no significant threat to human health from flooding risks due to the emergency evacuation plan, evacuation routes, and national weather system emergency alert systems. CEQA prohibits lead agencies from reducing the number of housing units as a mitigation measure when other feasible mitigation measures are available. (CEQA Guidelines § 15092(c)). * Air Quality. NCA petitions the City to analyze alternatives to avoid air quality impacts and require solar panels as mitigation. The EIR already discusses how avoiding all air quality impacts from CO and PM-10 would affect the project. It would reduce the size of the shopping center by 86%. This is not a feasible alternative because it would significantly reduce the sales tax revenue that would be generated from the property. In addition to creating budget challenges for the City, such a reduction would make it difficult to finance the public infrastructure in the La Costa Master Plan because the City's public facilities plan assumed the property would contain a substantial amount of commercial square footage that would generate SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 11,2009 Page 9 payment of development impact fees into the City's plan. Planned public safety services, parks, libraries, and transportation improvements would not be fulfilled without revenue from new sources, for which excess City revenue is not available. See Candidate Findings at pp. 32-34 and 42-43. The EIR already analyzes NCA's request to incorporate feasible solar technology. All the commercial, office and residential buildings are required to be solar-ready and solar panels installed on the car ports. Air Quality Mitigation Measure 1 also requires the Project to meet energy efficiency standards that exceed Title 24 standards by 20% and achieve a 25% reduction in electricity use on an average sunny day, using a combination of technologies, which may include solar panels if they are the most feasible means of achieving these performance standards. The City Attorney has confirmed that it is not legally feasible for the City to mandate the use of solar panels because the City has no solar panel ordinance in effect. Therefore, CEQA requires no further analysis of solar panel-based mitigation. Finally, the Project represents smart growth. It is a well-balanced mixed use project designed to allow residents to live, work, and shop in the same area without driving. Without such projects, existing residents will have to drive farther to find ample, attractive shopping. Therefore, even though the Project increases air emissions generated at the site compared to current conditions, without the Project, overall air quality would continue to worsen from the extra driving. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 11,2009 Page 10 Due Process Has Been Provided * NCA alleges the public has not been afforded adequate opportunity to comment on the Project. * However, ample opportunity for notice and comment has been provided: * The Draft EIR was circulated for 45 days and the City respond to each comment it received, even comments that were sent after the deadline. * At a noticed Planning Commission hearing on July 1,2009, everyone was afforded an opportunity to comment on the project. * Instead of voting on the project on July 1,2009, the Planning Commissioners closed the public comment portion of the hearing, but gave the public an extra two weeks to provide written comments on the project. * These written comments were evaluated letter-by-letter for several hours during the July 15,2009 Planning Commission hearing, where the Commissioners deliberated among themselves and asked follow-up questions from City staff and others with information to assist them in providing a recommendation. * Since then, the public has been given almost three more weeks to comment and will have an opportunity to express their support or opposition at the City Council hearing on August 11,2009. SHEPPARD MULLIN RICHTER & HAMPTON LLP Mayor & Council Members August 11,2009 Page 11 Exhibit 2 North County Advocates* Objection Letter Dated August 7.2009 LAW OFFICES OF EVERETT L. DELANO III 220 W. Grand Avenue Escondido, California 92025 (760)510-1562 (760) 510-1565 (fax) August 7, 2009 VIA FACSIMILE & U.S. MAIL Lorraine M. Wood City Clerk City of Carlsbad 1200 Carlsbad Village Drive Carlsbad, CA 92008 Re: La Costa Town Square: EIR 01-02/GPA 01-02/MP 149(RVLFMP 87-1KCVCT 01-09/CT 08-03/CT 08-07/CP 01-03/PUD 08-09/HDP Q1-05/SDP 01-Q3/SDP 01- 04/V 08-02/CUP 04-18/CUP 08-01/CUP 08-02/CUP 08-03/CUP 08-04/CUP 08- 05/CUP 08-06/CUP 08-07 Dear Ms. Wood: This letter is submitted on behalf of North County Advocates in connection with the proposed La Costa Town Center project ("Project") and the Final Environmental Impact Report ("FEIR"). Please ensure that copies of this letter are provided to all City Council members prior to their consideration of the Project at their August 11th meeting. My July 14,2009 letter echoed the sentiments of many other comments - that the FEIR is inadequate and the Project should be denied I will not repeat those comments here, but would like to add a few additional considerations regarding the FEIR and Project. Staff has represented that the analysis of traffic impacts is sufficient and that it is acceptable to avoid mitigating traffic impacts. As my prior comments noted, this is incorrect Indeed, the staff report to the City Council claims: "All required improvements needed to serve the project will be funded by the Developer." This is incorrect, as the FEIR itself acknowledges. Furthermore, the FEIR was changed substantially from the Draft EIR. See FEIR at 5.2-123 - 124. As such, it should have been recirculated for further public consideration and comments. Pub. Res. Code § 21092.1. Additionally, the FEIR fails to address the failure to mitigate impacts to other roadways, such as Olivenhain Road, San Elijo Road, and Rancho Santa Fe Road. Comments re La Costa Town Square August 7, 2009 Page 2 of3 Furthermore, the Project is likely to lead to water supply impacts. There is an inadequate showing of water supply for the Project. The California Supreme Court recently identified three "principles for analytical adequacy under CEQA": (1) "CEQA's informational purposes are not satisfied by an EIR that simply ignores or assumes a solution to a problem of supplying water to a proposed land sue project"; (2) an adequate environmental impact analysis for a large project, to be built and occupied over a number of years, cannot be limited to the water supply for the first stage or the first few years"; and (3) "the future water supplies identified and analyzed must bear a likelihood of actually proving available.... An EIR for a land use project must address the impacts of likely future water sources, and the EIR's discussion must include a reasoned analysis of the circumstances affecting the likelihood of the water's availability." Vineyard Area Citizens for Responsible Growth, Inc. v. City ofRancho Cordova (2007) 40 Cal.4* 412,430 - 32 (emphasis in original) (citations omitted). The FEIR fails to consider other mitigation or alternatives to address noise impacts. For example, the FEIR does not consider avoiding placing homes and/or avoiding blasting in those areas that would result in impacts. Similarly, the FEIR fails to consider alternatives to flooding impacts, such as not placing homes in a flood area. And the FEIR fails to consider other mitigation or alternatives that would avoid air quality impacts. "It is, of course, too late to argue for a grudging, miserly reading of CEQA." . Bozung v. LAFCO (1975) 13 CaL3d 263,274. "CEQA does... guarantee or at least attempt to assure that the environmental consequences of a government decision on . whether to approve a project will be considered before, not after, that decision is made." Stanislaus Natural Heritage Project v. County of Stanislaus (1996) 48 CalApp^* 182, 196 (emphasis added). The "grudging, miserly reading of CEQA" offered by the FEIR preparers is inconsistent with this mandate. Additionally, the City must demonstrate by substantial evidence that the findings are supportable. Pacific Corp. v. City of Camarilla (1983) 149 CaLAppJd 168, 178. The evidence supporting an agency's findings must have "solid value" in light of the entire record, including contrary evidence. Bank of America v. State Water Res. Control Bd. (1974) 42 CaLAppJd 198, 213. The proposed findings for the Project, while numerous, are not supported by substantial evidence. In some instances, the evidence in the record actually conflicts with a proposed finding. Comments re La Costa Town Square August 7, 2009 Page 3 of 3 Finally, the process followed has not been sufficient. The Planning Commission refused to allow persons to speak at its second meeting, although it did accept written comments. For the foregoing reasons, North County Advocates requests that the City reject the Project and the EIR. If you have a question or need additional information, please contact me. Thank you for your consideration of these comments. Sincerely, Everett DeLano cc: Van Lynch, Planning Dept. Comments on Air Quality Draft Environmental Impact Report ROBERTSON RANCH MASTER PLAN CITY OF CARLSBAD, CALIFORNIA Prepared by Petra Pless, D.Env. Leson & Associates Kensington, CA November 30,2005 Table of Contents I. CONSTRUCTION EMISSIONS ARE UNDERESTIMATED AND REMAIN SIGNIFICANT AFTER IMPLEMENTATION OF THE DRAFT EIR'S PROPOSED MITIGATION MEASURES 2 I. A Construction. Fugitive Dust Emissions Are Underestimated 2 I.A.I The Draft EIR's Air Quality Analysis Does Not Consider The Total Quantity Of Material Moved During Grading 3 I. A.2 Construction Phase Of East Village And Grading Phase Of West Village Could Occur Simultaneously 4 I.A.3 The Draft EIR's Air Quality Analysis Does Not Include All Fugitive Dust-generating Activities 5 I. A.4 The Draft EIR's Air Quality Analysis Of Fugitive Dust Emissions Already Takes Into Account The Emission Reduction Efficiency Of Its Proposed Mitigation Measures 6 I. A.5 The Draft EIR Fails To Disclose Significant Impacts Due To Fugitive Dust Emissions From Construction On Air Quality 6 I. B Combustion Exhaust Emissions Are Underestimated 7 I.C ROG Emissions From Building Construction Not Analyzed 7 II. OPERATIONAL EMISSIONS ARE UNDERESTIMATED 7 II.A The Draft EIR Underestimates Operational Emissions By Excluding Area Emission Sources 8 II.B The Draft EIR Fails To Analyze The Urban Heat Island Effect 8 II.C The Draft EIR Fails To Analyze Secondary Emissions From Increased Electricity Generation 9 III. ADDITIONAL FEASIBLE MITIGATION EXISTS AND SHOULD BE REQUIRED TO MITIGATE THE PROJECT'S SIGNIFICANT IMPACTS ON AIR QUALITY 9 III.A Mitigation Measures Must Be Enforceable 10 III.B Additional Feasible Construction Mitigation 10 III.B.1 Fugitive Dust Mitigation Measures 10 III.B.2 Diesel Exhaust Mitigation Measures 14 III.B.2.a CARB-certified Construction Equipment 15 III.B.2.b Post-combustion Controls 15 III.B.3 Construction Area Sources Mitigation Measures 17 III.C Additional Feasible Operational Mitigation 18 III.C.I Operational Traffic Mitigation Measures 18 III.C.2 Operational Area Mitigation Measures 20 IV. CONCLUSION 22 List of Tables Table 1: Proposed Project Grading Quantities 3 COMMENTS The City of Carlsbad ("City") as the Lead Agency under the California Environmental Quality Act ("CEQA") has prepared a Program Draft Environmental Impact Report1 ("Draft EIR") for the Robertson Ranch Master Plan ("Master Plan" or "Project") located in San Diego County, California. The proposed Robertson Ranch project site consists of 398 acres of currently undeveloped and agricultural lands. Most of the site is surrounded by existing residential housing developments and a mobile home park. To the east, the site is presently bordered by open space and undeveloped agricultural land. (Draft EIR, p. 3-1.) The Master Plan defines two distinct project phases, the East Village and the West Village, which will be linked by a pedestrian circulation system and will include residential single-family homes, multi-family dwellings, an elementary school, a recreational vehicle storage area, a Village Center accommodating commercial uses and a community facility, and parks and open space. (Draft EIR, pp. 3-4 - 3-14.) The project is expected to be constructed over a period of 10 to 20 years. The City anticipates development of the East Village as Phase I. Development of Phase II, the West Village, is not anticipated to begin for 3 to 10 years after Master Plan adoption. (Draft EIR, p. 3-21.) CEQA Requirements CEQA has two basic purposes, neither of which the Draft EIR satisfies. First, CEQA is designed to inform decision makers and the public about the potential environmental consequences of a project before any decisions are made. (14 Cal. Code Regs. ("CEQA Guidelines") Section 15002(a)(l).) The EIR is the "heart" of this requirement. (No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.Sd 68, 84.) The EIR has been described as "an environmental 'alarm bell' whose purpose it is to alert the public and its responsible officials to environmental changes before they have reached ecological points of no return." (County oflnyo v. Yorty (1973) 32 Cal. App.Sd 795, 810 [108 Cal.Rptr. 377].) To achieve this goal, an EIR must contain facts and analysis, not merely bare conclusions. (See Citizens ofGoleta Valley v. Board of Supervisors (1990) 52 Cal.Sd 553, 568.) Second, CEQA directs public agencies to avoid or reduce environmental damage when possible by requiring alternatives or mitigation measures. (CEQA Guidelines Sections 15002(a)(2) and (3). (See also Citizens ofGoleta Valley v. Board of 1 City of Carlsbad, Program Environmental Impact Report for the Robertson Ranch Master Plan, EIR-03-03, State Clearinghouse #2004051039, September 2005. Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 Supervisors (1990) 52 Cal.3d 553, 564; Laurel Heights Improvement Ass'n v. Regents of the University of California (1988) 47 Cal.Sd 376,400.) The Draft EIR fails to satisfy these basic purposes of CEQA. The Draft EIR's analysis of environmental impacts falls short of providing the necessary facts and analysis to allow the City and the public to make an informed decision. These comments demonstrate that the Project will result in significant impacts on air quality that were not properly analyzed and which have not been adequately mitigated. Therefore, the Draft EIR should be revised and recirculated for public review. I. CONSTRUCTION EMISSIONS ARE UNDERESTIMATED AND REMAIN SIGNIFICANT AFTER IMPLEMENTATION OF THE DRAFT EIR'S PROPOSED MITIGATION MEASURES The Draft EIR estimates construction-related fugitive dust emissions from earthwork activities and diesel exhaust emissions for several phases of construction including rough grading, underground utility construction, and surface paving. (Draft EIR, pp. 5.3-14 through 5.3-19.) The comments below demonstrate that both construction and operational emissions presented in the Draft EIR are considerably underestimated, and consequently, not adequately mitigated. LA Construction Fugitive Dust Emissions Are Underestimated The Draft EIR presents fugitive dust PM102 emissions for the grading and site preparation phase of the West Village of 129 Ib/day of PM10, based on total earthmoving activities of 1,526,000 cubic yards of material. Based on the percentage material capable of generating some amount of PM10 and the total estimated number of working days to complete the grading phase, the average daily earthwork movement was calculated as 5,290 tons3. Resulting fugitive dust emissions for the grading phase of the West Village were estimated at slightly under 129 Ib/day of PM10. Fugitive dust emissions from the grading phase of the East Village were estimated at slightly over 98 Ib/day based on total earthmoving activities of 775,000 cubic yards of material and an average daily earthwork 2 Participate matter emissions from construction are either related to fugitive dust or combustion emissions, mostly diesel exhaust. Fugitive dust consists mostly of PM10, which is defined as airborne particulate matter with an aerodynamic diameter of 10 micrometers ("PM10") or less. Combustion emissions create mostly smaller particles, PM2.5, a subset of PM10, with an aerodynamic diameter of less than 2.5 micrometers or less. 3 West Village: (1,526,000 tons) x (1.3 tons/cubic yard) x (60% material capable of generating some amount of PM10) / (225 working days) = 5,290 tons/day. Page 2 Pleas Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 movement of 4,030 tons4. (Draft EIR, Appx. Q pp. 26/27.) For a number of reasons, as demonstrated in Comments I.A.I through I.A.4 below, these fugitive dust emission estimates are considerably underestimated. Consequently, contrary to the Draft EIR's conclusion, fugitive dust PM10 emissions remain significant after implementation of the proposed mitigation measures. (See Comment I. A.5.) I.A.I The Draft EIR's Air Quality Analysis Does Not Consider The Total Quantity Of Material Moved During Grading Inset Table 1 summarizes the amount of material moved during the respective grading phases, as provided in the Draft EIR's Section 5.11. Table 1: Proposed Project Grading Quantities (cubic yards)* Activity Cut Fill Total Earthmoving Total Acres Graded Balanced? East Village 775,000 775,000 1,550,000 96.90 Yes West Village 1,526,000 1,526,000 3,052,000 157.70 Yes Park/School 265,000 265,000 530,000 22.70 Yes Total Project 2,566,000 2,566,000 5,132,000 277.3 Yes * Based on Draft EIR, p. 5.11-17, Table 5.11-1 Presumably, the assumed 225 and 150 working days for earthwork activities at the West and East Villages, respectively, include both cut and fill activities. (Draft EIR, p. 5.3-17/18.) Therefore, the total cut + fill quantities would be 1,550,000 cubic yards of material for the East Village and 3,052,000 cubic yards of soil for the West Village, twice the amount accounted for in the Draft EIR's fugitive dust emission calculations. (See Comment LA.) In addition, it appears that the Draft EIR's fugitive dust emission calculations exclude the earthmoving activities for the 22.7 acres that will be developed as parks and schools. These areas are distributed over the planning areas for the East and West Villages and it is unlikely that they will be graded at a different time than these two development phases. Cut/fill activities of these 22.7 acres will further add to the fugitive dust emissions. Further, the Draft EIR's Geotechnical Report recommends that "[temporary grades should be constructed [for erosion control]..." and "construction of stabilization and/or buttress slopes may be necessary for some west facing cut slopes." (Draft EIR, Appx. G, p. 30.) These activities would require the movement of 4 East Village: (775,000 tons) x (1.3 tons/cubic yard) x (60% material capable of generating some amount of PM10) / (150 working days) = 4,030 tons/day. Page3 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 cut material more than once, thereby further increasing the total amount of material moved as well as associated fugitive dust emissions and combustion exhaust emissions (see Comment I.E.). Finally, the Draft EIR further claims that total cut/fill materials would be balanced on site. (Draft EIR, p. 5.11-17, Table 5.11-1.) According to the Geotechnical Report for the site, a considerable amount of unsuitable earth material must be removed across the site to make it suitable for development. The Geotechnical Report discusses the presence of "[earth] materials unsuitable for the support of structures, settlement-sensitive improvements, and/or compacted fill" and states that " [cjomplete removals of tributary alluvium (on the order of 5 to 25 feet) should be anticipated" and that "[r]emoval on sloping areas, including colluvium and near- surface weathered formational earth materials are anticipated to be on the order of 3 to 5 feet thick throughout the majority of the site." (Draft EIR, Appx. G, p. 1, emphasis retained.) Some of this material may be unsuitable for reuse on site, requiring export of this material. To achieve the final graded elevations for development, suitable fill material might have to be imported. Import and export of materials would further increase the fugitive dust and combustion exhaust emissions of the respective construction phases. As demonstrated above, the quantities of material moved estimated by the Draft EIR's air quality analysis account for less than 50% of the total material that has to be moved. Consequently, fugitive dust emissions are underestimated by more than a factor of two. I.A.2 Construction Phase Of East Village And Grading Phase Of West Village Could Occur Simultaneously The Draft EIR assumes that the grading of East and West Villages would not occur concurrently but that development of the West Village would occur 3 to 10 years after adoption of the Master Plan. (Draft EIR, p. 3-12.) Grading of the East Village is projected to take 150 working days, or 210 calendar days5. (Draft EIR, p. 5.3-18.) The Draft EIR contains no information on the anticipated duration of the buildout period of either Project phase. Since grading of the East Village alone takes almost two thirds of a calendar year, buildout of the East Village will likely take a several years, conceivably longer than three years following adoption of the Master Plan. If this were the case, grading of Phase II, the West Village, would commence before Phase I, the East Village, is entirely built out. Because the Draft EIR contains no requirement to the effect that construction of the West Village can only begin after complete buildout of the East Village, worst-case construction emissions must 1 (150 working days) x (7 calendar days/5 working days) = 210 calendar days. Page 4 Pless Comments on Draft ElR for Robertson Ranch Master Plan November 30, 2005 include emissions from the construction phase of the East Village and the grading phase of the West Village. Alternatively, such a requirement should be required in the Final EIR. Depending on the construction activities at the East Village, considerable additional criteria pollutant emissions could be generated. These include emissions from a variety of construction activities, including ROG6 emissions from asphalt coating, surface coatings, paints, etc. I.A.3 The Draft EIR's Air Quality Analysis Does Not Include All Fugitive Dust-generating Activities The fugitive dust emissions presented in the Draft EIR include only emissions from earthmoving activities, which based on a semi-empirical equation contained in the South Coast Air Quality Management District ("SCAQMD")'s CEQA Air Quality Handbook. (SCAQMD 04/93?, p. A9-101, Table A9-9-G.) This equation is used for emissions from "dirt piling or material handling" and applies to every instance this "dirt" is handled, e.g., for transferring graded materials into trucks, emptying truck contents onto a storage pile or other temporary structures such as temporary retaining walls (see Comment I.A.I), transferring materials from storage piles into trucks, etc. The Draft EIR only considered a one-time handling of less than half the material that has to be moved for both Project phases. Therefore, fugitive dust emissions from "dirt piling and material handling" are considerably underestimated. In addition, there are numerous other sources that generate fugitive dust emissions during the grading phase of a project. The SCAQMD CEQA Guidelines provide equations to estimate fugitive dust emissions for these sources, including entrained road dust emissions from passenger vehicles and trucks on paved and unpaved roads (Table A9-9-A through Table A9-9-D); wind erosion of storage piles (Table A9-9-E); and fugitive dust kicked up during dirt pushing or bulldozing operations (Table A9-9-F). (SCAQMD CEQA Guidelines, pp. A9-94 through A9-102.) 6 The term ROG, reactive organic gases, is used in these comments interchangeably with the term VOC, volatile organic compounds. 7 South Coast Air Quality Management District, CEQA Air Quality Handbook, April 1993. Page 5 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 I.A.4 The Draft EIR's Air Quality Analysis Of Fugitive Dust Emissions Already Takes Into Account The Emission Reduction Efficiency Of Its Proposed Mitigation Measures The Draft EIR requires 12 mitigation measures to reduce fugitive dust emissions and concludes that implementation of these mitigation measures would effectively reduce fugitive dust PM10 emissions to a less-than-significant level. (Draft EIR, pp. 5.3-23 through 5.3-25.) This conclusion is erroneous. As discussed above, the Draft EIR only estimates fugitive dust emissions resulting from "dirt piling and material handling" activities. (See Comment I.A.I.) Only two of the proposed mitigation measures, watering of active sites twice daily and the use of water trucks or sprinkler systems on all areas of vehicle movement, potentially reduce fugitive dust emissions from "dirt piling and material handling", the other 10 measures address different emission sources. Review of the Draft EIR's air quality analysis shows that the emission estimates for fugitive dust already account for the maximum emission reduction efficiency of this mitigation measure. The Draft EIR's air quality analysis states that "surface wetting will be utilized during all phases of earthwork operations..., thus the SMC [soil moisture content] would be 0.5" or 50%, which is the maximum soil moisture content recommended by the SCAQMD to calculate fugitive dust emissions from "dirt piling or material handling." (Draft EIR, Appx. C, p. A9-101, Table 9-9-G-l.) Therefore, the emissions of 129 Ib/day of PM10 presented in the Draft EIR already are mitigated emissions. By effectively double-counting the emission reduction efficiency of these two mitigation measures, the Draft EIR erroneously, and with no analysis whatsoever, concludes that mitigated fugitive dust PM10 emissions would be reduced to a less than significant level. Because these mitigated fugitive dust emissions of 129 Ib/day still exceed the quantitative significance threshold of 100 Ib/day (see Draft EIR, Table 5.3-3), emissions from "dirt piling and material handling" alone remain significant after implementation of the Draft EIR's proposed mitigation program. I.A.5 The Draft EIR Fails To Disclose Significant Impacts Due To Fugitive Dust Emissions From Construction On Air Quality As demonstrated in Comments I.A.I through I.A.4 above, the Draft EIR considerably underestimates fugitive dust emissions resulting from the Project because 1) its air quality analysis does not consider the total quantity of material moved during grading, 2) the construction phase of the East village and the Grading phase of the West Village could occur simultaneously, 3) its air quality analysis does not include all fugitive dust-generating activities, and 4) because its emission estimates of fugitive dust emissions rely on the emission reduction efficiency of the one mitigation measure that reduces fugitive dust emissions from "dirt piling or Page 6 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 material handling/' the only source of fugitive dust contained in the Draft EIR's air quality analysis. As a result/ the Draft EIR fails to disclose significant impacts on air quality from the Project. The Draft EIR should be revised to address these issues and be recirculated for public review. I.B Combustion Exhaust Emissions Are Underestimated As discussed in Comment I.A.I above, the grading phase of the Project will likely require more soil movement than accounted for in the Draft EIR. The additional combustion emissions from increased soil movement should be taken into account in a revised air quality analysis. I.C ROG Emissions From Building Construction Not Analyzed The Draft EIR analyzed combustion exhaust emissions from diesel-powered equipment resulting from rough grading operations ("dirt piling and material handling"), underground utility construction, and surface paving activities. While these construction activities likely result in the highest emissions of CO, NOx, and PM10 among all construction phases, maximum emissions of ROG can be expected during the building construction phase of the Project when large amounts of ROG are off-gassed during the evaporation of solvents contained in architectural coatings, such as paints, varnishes, primers, and other surface coatings. ROG emissions from the building phase can be estimated with the computer model URBEMIS 20028 model, developed jointly by the CARD and SCAQMD. URBEMIS 2002 is specifically designed to estimate criteria air pollutant emissions from land use development projects including demolition, construction, and operational area source and traffic emissions. Based on my experience with similar residential developments, ROG emissions from their building phases are almost always significant and, in this case, not adequately mitigated. The Draft EIR's mitigation plan contains no mitigation measures aimed at reducing ROG emissions from construction. The Draft EIR should be revised to analyze the worst-case scenarios of emissions for all criteria pollutants and should require additional mitigation to reduce the likely significant ROG emissions from construction. II. OPERATIONAL EMISSIONS ARE UNDERESTIMATED The Draft EIR's air quality analysis considerably underestimates emissions from Project operation because it fails to A) include area emission sources, B) discuss 8 The latest version of URBEMIS, v. 8.7.0, is available at http://www.urbemis.com/. Page 1 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 impacts on ozone generation from the urban heat island effect, and C) analyze secondary emissions from increased electricity demand. These emissions/effects would contribute to the already significant and unavoidable long-term impacts on air quality for CO, NOx, and ROG from Project operation. II.A The Draft EIR Underestimates Operational Emissions By Excluding Area Emission Sources As discussed in detail in the following comments, the Draft EIR only analyzes those operational emissions attributable to Project-related vehicle traffic. While the Draft EIR states correctly that vehicular emissions present the primary source of emissions associated with the proposed Robertson Ranch, area sources are non- negligible contributors to operational Project emissions. Notable area source emissions include NOx emissions from natural gas for boilers, furnaces, and gas- fired fireplaces9 (required by Mitigation Measure AQ-4, see Draft EIR, p. 5.3-25); ROG emissions from consumer products such as paints, solvents, other architectural coatings, hairsprays, deodorants, oven sprays, etc.; NOx and PM10 emissions from gasoline or diesel-powered landscaping equipment. Area source emissions can also be modeled with the URBEMIS 2002 model. Because of the lack of a buildout schedule in the EIR and some other pertinent Project information, such as projected number of students at the elementary school, square footage of the recreational center, etc., I was unable to run the model for a preliminary estimate. However, based on my experience with similar projects, I expect that Project operational ROG emissions will greatly increase if area sources are considered. The Draft EIR should be revised to include emissions from area sources and to disclose the full impacts of the Project on long-term air quality. II.B The Draft EIR Fails To Analyze The Urban Heat Island Effect The Project "would indirectly increase ozone by replacing open space with blacktop. This would increase local temperatures, contributing to the urban heat island effect and increasing the formation of ozone. The project would convert a substantial amount of land from green, open space or agricultural land to blacktop, e.g., parking lots, roads, and roofs. This can reasonably be expected to increase local ambient temperature and hence, local formation of ozone. 9 The Draft EIR's air quality analysis excludes emissions from the required natural gas-fired fireplaces because they are not subject to the EPA's New Source Performance Standards. While this is true, emissions from these fireplaces are still subject to CEQA review. Paae 8 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 Black surfaces absorb about 85% to 95% of the sunlight that falls on them, becoming one of the hottest surfaces in urban areas. The hot surfaces of pavement and similarly dark roofs quickly warm the air over urban areas, leading to the creation of summer urban "heat islands." On a clear summer afternoon, the air temperature in urban areas can be 2°F to 9T hotter than the surrounding rural area. The elevated temperature increases cooling energy demand, accelerates the rate of smog production, and increases evaporative losses of organic compounds from gasoline tanks of vehicles parked over the hot surfaces. Thus, the heat island affect would exacerbate existing exceedances of the ozone standards in the project vicinity. (See Draft EIR, p. 5.3-8.) This is a significant impact that was not discussed in the Draft EIR and is feasible to mitigate. II.C The Draft EIR Fails To Analyze Secondary Emissions From Increased Electricity Generation CEQA requires that an EIR identify direct and indirect significant effects of the project on the environment. (CEQA Guidelines Section 15126.2(a).) The Project will require a substantial amount of electricity. The generation of electricity generates emissions. The Draft EIR does not discuss these so-called secondary emissions. These secondary emissions from electricity generation will contribute to the Project's already significant operational impacts and must be mitigated. III. ADDITIONAL FEASIBLE MITIGATION EXISTS AND SHOULD BE REQUIRED TO MITIGATE THE PROJECT'S SIGNIFICANT IMPACTS ON AIR QUALITY As demonstrated in Comment LA, emissions from Project construction remain significant after implementation of the Draft EIR's proposed mitigation program. Therefore, additional mitigation is required to reduce these significant construction emissions. For Project operational emissions, the Draft EIR admits to "significant and unavoidable" impacts after implementation of its proposed mitigation program, yet fails to require more than a few vague mitigation measures. As discussed below, numerous other feasible mitigation measures, which are routinely required elsewhere as CEQA mitigation, exist for both the construction and operational phases of the Project and should be required to reduce the Project's significant impacts on air quality to the lowest level possible. Page 9 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 III.A Mitigation Measures Must Be Enforceable The Draft EIR's mitigation program is not enforceable due to its vague language. The City only "recommends" mitigation measures that should be implemented as "applicable" or that "promote" a certain mitigation measure. This makes the measures in effect unenforceable and any emission reduction efficiency these measures provide can not be relied upon. For example, the wording "feasible" or "applicable" renders a mitigation measure ambiguous and unenforceable if no standards are provided to determine what constitutes "feasibility" or "applicability." The Draft EIR must include specific criteria for rejection of any of these measures or require them unambiguously. III.B Additional Feasible Construction Mitigation The Draft EIR proposes only 12 mitigation measures that address fugitive dust emissions and 10 mitigation measures that address combustion exhaust NOx emissions for the construction phase of the Project. (Draft EIR, pp. 5.3-23 - 5.3-24.) As discussed below, there are numerous relevant and reasonable fugitive dust and diesel exhaust mitigation measures contained in the CEQA guidelines and rules of air districts and other agencies. While portions of some of these mitigation measures are included in the Draft EIR's proposed mitigation program, these measures discussed below are far more protective than those recommended for the Project. Most of the measures included in these agency guidelines are feasible and therefore should be considered for adoption here under CEQA Guidelines Sections 15126.4 and 15091. III.B.l Fugitive Dust Mitigation Measures Several agencies have conducted comprehensive studies of fugitive dust control measures to bring their region into compliance with national ambient air quality standards for PM10. For example, the SCAQMD has sponsored research, passed regulations (e.g., Rule 40310), and published guidelines that identify best management practices for controlling fugitive dusts at construction sites. The Rule 403 Implementation Handbook11 contains a comprehensive list of such measures. Clark County, Nevada, has also sponsored research, passed regulations (Rule 94), and published best management practices for controlling fugitive dust from 10 South Coast Air Quality Management District, Revised Final Staff Report for Proposed Amended Rule 403, Fugitive Dust and Proposed Rule 1186, PM10 Emissions from Paved and Unpaved Roads, and Livestock Operations, February 14,1997. 11 South Coast Air Quality Management District, Rule 403 Implementation Handbook, January 1999. Page 10 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 construction activities.12 Clark County's Construction Activities Dust Control Handbook contains a comprehensive list of best management practices.13 Similarly, Arizona has developed guidance to control fugitive PM10 emissions.14 Examples of feasible mitigation measures contained in these guidelines and regulations are as follows: — During clearing and grubbing, prewet surface soils where equipment will be operated; for areas without continuing construction, maintain live perennial vegetation and desert pavement; stabilize surface soil with dust palliative unless immediate construction is to continue; and use water or dust palliative to form crust on soil immediately following clearing/grubbing. (CCHD)15 — Grade each phase separately, timed to coincide with construction phase or grade entire project, but apply chemical stabilizers or ground cover to graded areas where construction phase begins more than 60 days after grading phase ends. (Rule 403 Handbook) — During initial grading, earth moving, or site preparation, projects 5 acres or greater may be required to construct a paved (or dust palliative treated) apron, at least 100 ft in length, onto the project site from the adjacent site if applicable. (BCAQMD) — During cut and fill activities, prewater with sprinklers or wobblers to allow time for penetration; prewater with water trucks or water pulls to allow time for penetration; dig a test hole to depth of cut to determine if soils are moist at depth and continue to prewater if not moist to depth of cut; use water truck/pull to water soils to depth of cut prior to subsequent cuts; and apply water or dust palliative to form crust on soil following fill and compaction. (CCHD) 12 P.M. Fransioli, PM10 Emissions Control Research Sponsored by Clark County, Nevada, Proceedings of the Air &Waste Management Association's 94th Annual Conference & Exhibition, Orlando, FL, June 24-28, 2001. 13 Clark County Department of Air Quality Management, Construction Activities Dust Control Handbook, March 18, 2003. 14 Arizona Department of Environmental Quality, Air Quality Exceptional and Natural Events Policy PM10 Best Available Control Measures, June 5, 2001. 15 The following acronyms are used in this listing of mitigation measures: ADEQ = Arizona Department of Environmental Quality; BAAQMD = Bay Area Air Quality Management District; BCAQMD = Butte County Air Quality Management District; CCHD = Clark County (Nevada) Health District; MBUAPCD = Monterey Bay Unified Air Pollution Control District; SBCAPCD = Santa Barbara County Air Pollution Control District; SJVUAPCD = San Joaquin Valley Unified Air Pollution Control District; SLOCAPCD = San Luis Obispo County Air Pollution Control District. Page 11 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 For backfilling during earthmoving operations, water backfill material or apply dust palliative to maintain material moisture or to form crust when not actively handling; cover or enclose backfill material when not actively handling; mix backfill soil with water prior to moving; dedicate water truck or large hose to backfilling equipment and apply water as needed; water to form crust on soil immediately following backfilling; and empty loader bucket slowly; minimize drop height from loader bucket. (CCHD) For large tracts of disturbed land, prevent access by fencing, ditches, vegetation, berms, or other barriers; install perimeter wind barriers 3 to 5 feet high with low porosity; plant perimeter vegetation early; and for long-term stabilization, stabilize disturbed soil with dust palliative or vegetation or pave or apply surface rock. (CCHD) Barriers with 50 percent or less porosity located adjacent to roadways to reduce windblown material leaving a site. (Rule 403 Handbook) In staging areas, limit size of area; apply water to surface soils where support equipment and vehicles are operated; limit vehicle speeds to 15 mph; and limit ingress and egress points. (CCHD) Following the addition of materials to, or the removal of materials from, the surface of outdoor storage piles, said piles shall be effectively stabilized of fugitive dust emissions utilizing sufficient water or chemical stabilizer/suppressant. (SJVUAPCD, ADEQ) For stockpiles, maintain at optimum moisture content; remove material from downwind side; avoid steep sides or faces; and stabilize material following stockpile-related activity. (CCHD) When materials are transported off-site, all material shall be covered, effectively wetted to limit visible dust emissions, or at least six inches of freeboard space from the top of the container shall be maintained. (BAAQMD, SJVUAPCD, Rule 403 Handbook, ADEQ, SLOCAPCD) Where feasible, use bedliners in bottom-dumping haul vehicles. (Rule 403 Handbook) Empty loader bucket slowly and minimize drop height from loader bucket. (CCHD) Clean wheels and undercarriage of haul trucks prior to leaving construction site. (CCHD) Install and maintain trackout control devices in effective condition at all access points where paved and unpaved access or travel routes intersect. (CCHD) Page 12 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 — All roadways, driveways, sidewalks, etc., to be paved should be completed as soon as possible. In addition, building pads should be laid as soon as possible after grading unless seeding or soil binders are used. (SLOCAPCD) — Pave all roads on construction sites. (MBUAPCD) — To prevent trackout, pave construction roadways as early as possible; install gravel pads; install wheel shakers or wheel washers, and limit site access. (CCHD, SLOCAPCD) — While clearing forms, use single stage pours where allowed; use water spray to clear forms; use sweeping and water spray to clear forms; use industrial shop vacuum to clear forms; and avoid use of high pressure air to blow soil and debris from the form. (CCHD) — Limit fugitive dust sources to 20 percent opacity. (ADEQ) — Require a dust control plan for earthmoving operations. (ADEQ) — Prior to land use clearance, the applicant shall include, as a note on a separate informational sheet to be recorded with map, these dust control requirements. All requirements shall be shown on grading and building plans. (SBCAPCD, SLOCAPCD) — Post a publicly visible sign with the telephone number and person to contact regarding dust complaints. This person shall respond and take corrective action within 24 hrs. (BCAQMD, CCHD) All of these measures are feasible and various combinations of them are routinely required elsewhere to reduce fugitive PM10 emissions. See, for example, the fugitive dust control program for the Big Dig (Kasprak and Stakutis 200016), for the El Toro Reuse Draft EIR17, and for the Padres Ballpark Final EIR18. Because fugitive dust PM10 emissions remain significant after the Draft EIR's proposed mitigation, all or a combination of these measures should be required so that the 16 A. Kasprak and P.A. Stakutis, A Comprehensive Air Quality Control Program for a Large Roadway Tunnel Project, Proceedings of the Air & Waste Management Association's 93rd Annual Conference 7 Exhibition, June 18-22, 2000. 17 County of Orange, Draft Environmental Impact Report No. 573 for the Civilian Reuse of MCAS El Toro and the Airport System Master Plan for John Wayne Airport and Proposed Orange County International Airport, Draft Supplemental Analysis, Volume 1, April 2001, pp. 2-121 to 2-123. 18 City of San Diego, Final Subsequent Environmental Impact Report to the Final Master Environmental Impact Report for the Centre City Redevelopment Project and Addressing the Centre City Community Plan and Related Documents for the Proposed Ballpark and Ancillary Development Projects, and Associated Plan Amendments, V. IV. Responses to Comments, September 13,1999, pp. IV-254 to IV-256. Page 13 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 significant mitigated fugitive dust PM10 emissions are reduced to a less-than- signifleant level. III.B.2 Diesel Exhaust Mitigation Measures As discussed/ construction-related emissions from diesel exhaust, asphalt paving, solvents, and architectural coatings are significant and, thus, must be mitigated. A multitude of controls for is available for emissions from construction equipment and should be required here. The following mitigation measures are routinely required as CEQA mitigation by air districts and other agencies in California for construction projects, (e.g., the mitigation programs routinely implemented by the SMAQMD and California Energy Commission ("CEC") decisions), including: — Implementation of activity management techniques including a) scheduling of construction truck trips during non-peak hours to reduce peak hour emissions; b) limitation of the length of construction work-day period; c) phasing of construction activities; d) limiting the hours of operation of heavy duty equipment and/or the amount of equipment in use; and e) lengthening of construction period during smog season (May through October), so as to minimize the number of vehicles and equipment operating at the same time; — Use of CARB-certified off-road engines that are 3 years or less old; — Use of alternatively fueled construction equipment, using, e.g., compressed natural gas, liquefied natural gas, propane, PuriNOx, or biodiesel; — Conversion to cleaner engines; — Installation of add-on control devices, e.g., particulate traps, catalytic oxidizers; — Installation of high pressure injectors on diesel construction equipment; — Substitution of gasoline-powered for diesel-powered construction equipment or electrification of construction equipment; — Utilization of new technologies to control ozone precursor emissions as they become available and feasible; — Buffer zone between facility and sensitive receptors; — Emission offsets if ROG or NOx emissions exceed 6.0 tons/quarter. Page 14 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 The following discusses the use and feasibility of construction equipment certified by CARB and post-combustion controls. III.B.2.a CARB-certified Construction Equipment Both the U.S. EPA and CARB have established emission limits on new off-road engines. CARB-certified off-road engines are engines that are 3 years old or less at the time of use and which comply with these new low emission limits. This equipment is widely available in the construction fleet and specified as a control measure/ e.g., in the Bay Area Air Quality Management District ("BAAQMD")'s Revised Ozone Attainment Plan. The SMAQMD and other agencies require the use of at least 20 percent CARB-certified off-road engines in the mix of construction equipment operating on-site, or alternatively, setting a NOx, ROG, and/or PM10 emission reduction goal for the construction fleet. A similar measure has been adopted by the Texas Natural Resource Conservation Commission ("TNRCC") for the Dallas/Fort Worth and Houston-Galveston areas. (Rennie et al. 2001.19) The Arizona Department of Environmental Quality (" ADEQ") has also recommended this measure to address the air quality problems in the Phoenix area. (ADEQ 11/9/00, pp. 19-24.) III.B.2.b Post-combustion Controls Post-combustion controls, such as oxidation catalysts and particulate filters, are devices that are installed downstream of the engine on the tailpipe to treat the exhaust. These devices are now widely used on construction equipment and are capable of removing over 90% of the PM10, CO, and ROG from engine exhaust, depending on the fuel and specific engine. The most common and widely used post- combustion control devices are particulate traps (i.e., soot filters), oxidation catalysts, and combinations thereof. The many variants of these devices have recently been identified, evaluated, and comprehensively reviewed by EPA20, CARB21, and 19 S.G. Rennie, L. Fiffick, D. Huckabay, and B. Ubanwa, Heavy Duty Diesel Engines Retrofit Programs as a Part of Houston SIP, Proceedings of the Air & Waste Management Association's 94th Annual Conference & Exhibition, June 24-28, 2001. 20 U.S. Environmental Protection Agency, Voluntary Diesel Retrofit Program, Verfied Products, http:/ /epa.gov/otaq/retrofit/retrofitverifiedlist.htm, accessed November 29, 2005. 21 California Air Resources Board, Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles, October 2000; California Air Resources Board, Risk Management Guidance for the Permitting of New Stationary Diesel-Fueled Engines, October 2000. Page 15 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 others22. The Draft EIR only requires the use of catalytic converters on gasoline and diesel-powered equipment "if feasible." (For a discussion of enforceability of mitigation measures see Comment III. A.) These post-combustion controls are commonly required as mitigation for construction emissions. For example, the Massachusetts Turnpike Authority ("MTA") implemented a voluntary program in the fall of 1998 which resulted in retrofitting 70 pieces of construction equipment with oxidation catalysts (Kasprak et al. 200123) at the "Big Dig/' the massive, 5-year, $10 billion-plus Central Artery/Tunnel Project in Boston's North End and one of the largest infrastructure construction projects in the country. These controls have also been widely required to mitigate construction emissions in California. The CEC, which follows a CEQA-equivalent process in licensing of new power plants larger than 50 megawatts ("MW"), has required these devices on many projects. The Sunrise Power Project was recently constructed using this equipment.24 No problems were encountered. Several other 500+MW power plants have been licensed and constructed successfully using these controls, including High Desert25, Elk Hills26, Pastoria27, Western Midway-Sunset28, Mountain View29, and Contra Costa30, among others. (All of the CEC siting decisions are posted at www.energy.ca.gov under the name of the individual facility.) 22 Manufacturers of Emission Controls Association, Demonstration of Advanced Emission Control Technologies Enabling Diesel-Powered Heavy-Duty Engines to Achieve Low Emission Levels, Final Report, June 1999. 23 Alex Kasprak, Guido Schattanek, and Ping K. Wan, Emission Reduction Retrofit Program for Construction Equipment of the Central Artery/Tunnel Project, Proceedings of the Air & Waste Management Association's 94lh Annual Conference & Exhibition, June 24-28, 2001. Also see: www.epa.gov/OMS/retrofit/documents/bigdig_case_01.htm, accessed June 18, 2004. 24 California Energy Commission, Commission Decision, Sunrise Power Project, December 2000, Condition AQ-C3, p. 120. 25 California Energy Commission, Commission Decision, High Desert Power Project, May 2000, Condition AQ-3(o), p. 107. 26 Ctilifornia Energy Commission, Commission Decision, Elk Hills Power Project, December 2000, Condition AQ-C2(3), p. 123. 27 California Energy Commission, Commission Decision, Pastoria Energy Facility, December 2000, Condition AQ-C3, p. 108. 28 California Energy Commission, Commission Decision, Western Midway Sunset Power Project, March 2001, Condition AQ-C2, p. 114. 29 California Energy Commission, Commission Decision, Mountain View Power Project, March 2001, Condition AQ-C2, p. 34. Page 16 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 Post-combustion controls have also been required as conventional CEQA mitigation in EIRs. The City of San Diego in the Padres Ballpark Final EIR31 required the control of 95% of engine exhaust emissions, using, among others, oxidation catalysts, particulate filters, and "Blue Sky" low-emission engines. Similarly, the Port of Oakland required the use of new engines or post-combustion controls on trucks serving its Vision 2000 expansion project. The Port's air quality mitigation program is now partially in place and has been very successful in reducing emissions.32 The El Toro Reuse Draft EIR33, page 2-124, AQ-llk and AQ-111, required the use of particulate traps with a minimum 80% PM10 efficiency and selective catalytic reduction ("SCR") or comparable technology with a minimum 70% NOx reduction on all off-road construction equipment. The Stanford University General Use Permit Application Draft EIR34, page 4.11-10, AQ-1, required a range of measures to minimize diesel engine exhaust, including catalytic converters and particulate traps. All of these post-combustion controls are feasible for construction of this Project, Therefore, the Draft EIR should be revised requiring the use of post- combustion controls on off-road equipment specifying target control levels. III.B.3 Construction Area Sources Mitigation Measures To reduce the likely significant emissions of ROG during the building construction phase of the Project, the Draft EIR should be revised to include a mitigation measure requiring the substitution of materials with high solvent content. The SCAQMD, for example, recommends the use water-based paints. 30 California Energy Commission, Commission Decision, Contra Costa Unit 8 Power Project, May 2001, Condition AQC-2, p. 12. 31 City of San Diego, Final Subsequent Environmental Impact Report, Ballpark and Ancillary Development Projects, and Associated Plan Amendments, September 13,1999 and Draft Subsequent EIR, May 12,1999,, page IV-262,18.A.89. 32 Port of Oakland, Summary Report #5, Vision 2000 Air Quality Mitigation Program, February 2002. 33 County of Orange, Draft Environmental Impact Report, No. 573 for the Civilian Reuse of MCAS El Toro and the Airport System Master Plan for John Wayne Airport and Proposed Orange County International Airport, April 2001. 34 Santa Clara County, Draft Environmental Impact Report, EIR Stanford University Draft Community Plan and General Use Permit Application, June 23, 2000. Page 17 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 III.C Additional Feasible Operational Mitigation The Draft EIR finds significant and unavoidable operational impacts on air quality for CO, NOx, and ROG. The Draft EIR proposes three mitigation measures to reduce emissions from gasoline-dispensing stations and to reduce traffic-related emissions from both commercial and residential units, and one mitigation measures to reduce stationary source emissions from the residential units, i.e. the installation of gas-fired fireplaces in all units that have fireplaces. (Draft EIR, pp. 5.3-24 - 5.3-25.) The Draft EIR concludes that after implementation of these mitigation measures, Project operational emissions of CO, NOx, and ROG would remain significant and unavoidable. (Draft EIR, p. 5.3-25.) Yet, the Draft EIR fails to require all feasible mitigation measures that could potentially reduce these significant and long-term impacts on air quality resulting from Project operation. Further, with the exception of the natural gas-fired fireplaces, the Draft EIR's mitigation measures are not directly enforceable due to their vague language. The City only "recommends" mitigation measures that should be implemented as "applicable" or that "promote" a certain mitigation measure. This makes the measures in effect unenforceable and any emission reduction efficiency these measures provide can not be relied upon. As discussed in the comments below, additional feasible mitigation exists that should be required to reduce the enormous unmitigated emissions from Project operations. III.C.l Operational Traffic Mitigation Measures The following traffic mitigation measures are routinely required elsewhere to mitigate significant impacts from a project and should be required, not just promoted or encouraged, to mitigate the Project's significant NOx, ROG, and PM10 impacts. — Establish a carpool/vanpool program; — Provide on-site shops and services for employees, such as cafeteria, bank/ATM, dry cleaners, convenience market, etc.; — Provide on-site child care or contribute to off-site child care within walking distance; — Provide preferential parking for carpool/vanpool vehicles; — Short-term bicycle parking for retail customers and other non-commute trips; Page 18 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 — Provide neighborhood-servicing shops and services within Viz mile of residential areas; — Design and locate buildings to facilitate transit access, e.g., locate building entrances near transit stops, eliminate building setbacks, etc.; — Construct transit facilities such as bus turnouts/bus bulbs, benches, shelters, etc.; — Provide shuttle service to food service establishments/commercial areas; — Provide shuttle service to transit stations/multimodal centers; — Implement parking fee for single-occupancy vehicle commuters; — Implement parking cash-out program for non-driving employees; — Provide direct, safe, attractive pedestrian access from project to transit stops and adjacent development. The Lent Ranch Final EIR35, for example, requires most of these measures. The NASA Ames Development Plan Draft Environmental Impact Statement ("EIS")36 would implement an aggressive transportation demand management program ("TDM") to reduce trip generation by at least 22 percent. The Stanford University Draft Community Plan and General Use Permit Draft EIR37 adopts all applicable Bay Area TDMs. The Bickford Ranch Specific Plan Final EIR38 requires that emissions be reduced by 40% by implementing many of these measures. The Old Greenwood Planned Development Draft EIR39 requires, among others, paying an air quality mitigation fee to offset PM10 emissions from vehicle exhaust and re- entrained road dust to zero. Therefore, the above-listed measures should be assumed feasible unless otherwise demonstrated, and used by this Project to reduce traffic emissions to a less than significant level. 35 City of Elk Grove, Lent Ranch Marketplace, Draft Environmental Impact Report, for example Table 4.3-21, page 3.0-96, and Table 12-2, October 2000. 36 NASA Ames Research Center, NASA Ames Development Plan, Draft Programmatic Environmental Impact Statement, pp. O-ll to O-16, November 2001. 37 Santa Clara County, Draft Environmental Impact Report, Stanford University Draft Community Plan and General Use Permit Application, Table 4.11-6, June 23, 2000. 38 County of Placer, Bickford Ranch Specific Plan Final Environmental Impact Report, Section 8.3.2 and 8.4, November 13, 2000. 39 City of Truckee, Draft Environmental Impact Report, Old Greenwood Planned Development, pp. 4.5-10 to 4.5-13, February 2002. Page 19 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 III.C.2 Operational Area Mitigation Measures Operational area emissions can also be mitigated by controlling other sources of emissions from the Project, including exhaust emissions from landscaping equipment/ emissions from natural gas combustion for heating/air-conditioning, increased ozone production from the heat island effect (see Comment II.B), and indirect emissions from electricity generation (see Comment II.C). In addition, the CEQA Guidelines and regulations of California air districts identify numerous other feasible measures for commercial/industrial operations. Some of these measures, which are routinely required as mitigation in other EIRs,40 include: — Increase walls and attic insulation beyond Title 24 requirements (SLOAPCD«, SCAQMD42); — Orient buildings to maximize standard heating and cooling (SLOAPCD) and include passive solar design, e.g., day-lighting (SCAQMD, SBAPCD43, BCAQMD44); — Plant shade trees in parking lots to reduce evaporative emissions from parked vehicles (SLOAPCD, SCAQMD, SBAPCD, BCAQMD); — Use energy-efficient and automated controls for air conditioning (SCAQMD, BCAQMD); — Use lighting controls and energy-efficient interior lighting (SLOAPCD, SCAQMD, SBAPCD, BCAQMD) and built-in energy-efficient appliances (SLOAPCD); — Use double-paned windows (SLOAPCD, SCAQMD); — Install solar cooling/heating (SBAPCD); — Install solar water heater for at least 25% of the building floor area (BCAQMD); 40 por example: City of Elk Grove, Lent Ranch Marketplace, Draft Environmental Impact Report, Table 4.3-5, p. 3.0-96, October 2000; County of Placer, Bickford Ranch Specific Plan Final Environmental Impact Report, pp. 8-20 to 8-22, November 13, 2000; Sacramento County, East Franklin Specific Plan, Final Environmental Impact Report, Table ES-1; and Appendix D, February 2000; City of Truckee, Draft Environmental Impact Report, Old Greenwood Planned Development, pp. 4.5-10 to 4.5-13, February 2002. 41 San Luis Obispo Air Pollution Control District, CEQA Air Quality Handbook, August 1997. 42 South Coast Air Quality Management District, CEQA Air Quality Handbook, April 1993. 43 Santa Barbara Air Pollution Control District, Scope and Content of Air Quality Sections in Environmental Documents, September 1997. 44 Butte County Air Quality Management District, Indirect Source Review Guidelines, March 1 Page 20 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 — Substitute materials, e.g., use water-based paint (SCAQMD); — Use solar or low-emission water heaters (SCAQMD); - Use centralized water-heating systems (SCAQMD, VCAPCD45); — Use energy star roofing products; — Use ozone-destruction catalyst on air condition systems; — Use energy-efficient low sodium parking lot and street lights (SLOAPCD, SCAQMD); — Use concrete or other non-pollutant materials for parking lots instead of asphalt (SBAPCD); — Reduce standard paving by 20%. — Landscape with drought-resistant species, and use groundcovers rather than pavement to reduce heat reflection; — Provide electric maintenance equipment; — Use electric lawn and garden equipment for landscaping (BAAQMD); — Use electrically or CNG-powered specialty equipment, e.g., utility carts (BAAQMD); — Use propane-powered specialty equipment, e.g., forklifts, utility carts, etc. (BAAQMD); — Pay an air quality mitigation fee; and — Secure emission offsets. Further, some air districts recommend that large projects that cannot be fully mitigated with on-site measures, should implement off-site mitigation measures, for example: — Retrofit existing homes and businesses in the project area with approved energy conservation devices (SLOAPCD); — Replace/repower school/transit bus with cleaner vehicles (SLOAPCD); — Construct satellite work stations (SLOAPCD); — Fund a program to buy and scrap older, high-emission vehicles (SLOAPCD); - Contribute to an off-site TDM fund (VCAPCD); 'l5 Ventura County Air Pollution Control District, Ventura County Air Quality Management Plan, Appendix G-94, Guidelines for the Preparation of Air Quality Impact Analyses, October 1989. Page 21 Pless Comments on Draft EIRfor Robertson Ranch Master Plan November 30, 2005 — Repair smog-check waived vehicles (SLOAPCD); — Introduce electric lawn and garden equipment exchange program (SLOAPCD); and — Retrofit/purchase clean heavy-duty trucks, construction equipment diesel locomotives, and marine vessels. (SLOAPCD) In sum, the few mitigation measures proposed by the Draft EIR to mitigate the Project's operational impacts are clearly inadequate to reduce its operational emissions to a less than significant level. There are many additional feasible measures that should be evaluated and required for this Project. The Draft EIR should be revised to include these additional measures and be recirculated for public review. IV. CONCLUSION As discussed above, the Draft EIR fails to disclose and adequately mitigate significant impacts on air quality from construction, and fails to fails to properly mitigate the Project's significant operational impacts. Consequently, the Draft EIR fails to comply with the requirements of CEQA. The Draft EIR should be revised to address the above discussed issues and be recirculated for public review. Page 22 TRIP (Traffic Relief Is Possible) 1021 Madison Avenue Escondido, CA 92027 760839-9128 March, 2009 Dear TRIP Member: There's a rather unsettling rumor going round that suggests SANDAG has already borrowed all it can against future TRANSNET taxes, and has already allocated those funds without coming anywhere close to funding all the projects on its list. So, where is the rest of the money coming from? In this economic climate the building industry will step up its pressure on local elected officials to reduce or do away with all development impact fees, including transportation impact fees. It will be as though they finally realized the truth of what we have been saying for years: the price that housing will sell for is not determined by the cost to build that housing, but rather by the market place. An increase in fees will decrease the price developers will pay for raw land, and a decrease in fees will only increase the developers profit. This is not the time to reduce fees! This is the time for SANDAG to initiate a NEXUS study to determine the real cost of new housing to communities. How much more traffic does each new home generate? What is the cost of the infrastructure needed to support that extra traffic? What will be the added cost of new classrooms, additional water supply (in a time of rapidly depleting water supplies), new sewage treatment facilities, additional fire and police protection? What will be the environmental damage of every acre of habitat lost to new housing? How much more air and water pollution will be generated? These real costs need to be determined and a reality based county-wide fee structure put in place. Developers are not purchasing or optioning land at this time, so now is the time to determine what those fees should be, so that developers can factor them into future land purchases. If developers had to pay their fair share of the cost of growth, the price of land might make farming more attractive to landowners. We hope you will continue to financially support TRIP'S efforts to convince the politicians to do what is right for existing taxpayers. Please sign the enclosed letter to elected representatives and return it in the enclosed envelope with or without a financial contribution. Your returned letter is valuable too. We have much work left to do on behalf of existing residents. Sincerely, Jerry C. Harmon March, 2009 To all Mayors, Council Members, Members of the Board of Supervisors and Members of SANDAG Board: In this difficult financial time, you will come under tremendous pressure from the Building Industry Association. It will be as though they suddenly realize that the price of housing is not determined by the cost of that housing. Their usual argument that higher fees will just be passed along to the home buyer doesn't hold up very well in this economy. This is not the time to reduce development impact fees! This is the time to do a county-wide NEXUS study of the actual cost of new housing to San Diego citizens. Determine the actual cost of the new infrastructure whether it be roads, public transportation, schools, police and fire protection, water supply, sewage treatment, etc., that each new home requires. Determine what the environmental loss will be for each acre of habitat bulldozed for new housing. Determine if and how such losses can be mediated. Then determine a reality-based fee system that reflects the actual costs of growth and includes provisions for inflation. Developers are not purchasing or optioning land for future development in this market. But this market will turn around, and when it does, developers will go back into business. If developers are given a fee-structure that reflects the true cost of growth, and are required to pay their fair share of the cost, they can factor that into the amount they are willing to pay for raw land. As a citizen of San Diego County, I am heartily tired of bearing the tax burden of building the infrastructure required by new growth. It adds insult to the injury of the decrease in the quality of life that unchecked development has caused. Please respond to me at the address below. Sincerely Address: V-A special report BIGGEST PAINS IN THE LANESs-ta)oi&o (jirtioto-rf^&uA)& &-i% San Diego County drivers spend a lot of time sitting in congested traffic, as these commuters were doing Friday morning on Interstate 5 at the southern tip of Encinitas. NanceeE. Lewis/ Union-Tribune County has no shortage of traffic bottlenecks By Steve Schmidt STAFF WRITER 15 near Lake Hodges, state Route 52 in the shadow of Mis- A San Diego Union-Tribune analysis of traffic data has located 28 dele coui Cali 2OC PRES By John Marc STAFF WRITER Aleita Hugi seems to stop r "I've heard J from Hillary," were very resj don't want to p just want to mal information." So why wouk Teachers Assoc ramento wa such personal ; tion from the fo president and fii dy? Because Huj in is one of th so-called super gates from Califi who have not dorsed either Hillary Rodham ton of New Yor Sen. Barack Or. of Illinois for Democratic p dential For Mary E Early, the calls s ed coming in f. January when first choice, I Mexico Gov. Richardson, was in the race. "I started getti in the Clinton a have a lot of resp son, but if he di consider supporti said the Sherman er who is now bac "I've been heai and their brother, who teaches com mento City Coll that'll make up m; Altogether, thei gates — nearly 40 delegates needed rinn Neighbors... Does La Costa need a BIG BOX regional shopping center? Does your vision of La Costa's residential character include multi-story office buildings, a regional department store or the possibility of a WalMart? Warning ... If unchanged, the current plans for the massive development along Rancho Santa Fe Readjust east of La Costa Blvd will result in significant increases in traffic, noise, light and excessive blasting and grading. Background ... The Carlsbad Planning Commission recently approved a very large development for La Costa including 284,000 square feet of shopping center, 55,000 square feet of multi-story office buildings, 64 single family houses and increased zoning density for an additional 128 condos on 83 acres. Included in this proposal is a BIG BOX store which, until recently, was slated to be a Kohl's department store. Kohl's withdrew from the project leaving a large, empty BIG BOX available to be filled by another regional retailer. This regional shopping center promises to bring more traffic, noise, congestion and urban clutter to the middle of the La Costa, Southeast Carlsbad and nearby rural Olivenhain. What you can do... • Get involved now! • Tell your neighbors • Call your City Council at (760) 434-2830 • Join your neighbors, attend this week's City Council ... City Council Meeting This Tuesday, August 11 6:00 pm at City Hall 1200 Carlsbad Village Dr. (just east of 1-5) th Proposed "La Costa Town Square" Let them know ... you oppose the plans for a BIG BOX retail store in a residential neighborhood, oppose increasing the zoning, oppose office buildings next to neighborhoods, oppose increased traffic, noise and glaring light in the nighttime sky. Ask that they deny the approval and request they make the development and its new shopping appropriate for our neighborhood Learn more by... • Review project plans online at ... http://www.carlsbadca.gov/planning/4eir.html • Want to help? Need more info? ... Call Pat Bleha (760) 845-8056 or Bruce Ehlers (760) 494-1103 Comments on La Costa Town Center Nancy Curry - 3325 Cabo Way (760-942-5004) We all know about the finite amount of oil and gas available for power generation. We all know about the degradation of the environment as a result of using oil and gas for power including: what it takes to get it out of the ground, refined, and distributed and the air pollution that results from the use of that power. Solar Power The technology exists right now for developers to build retail ready buildings with complete solar panel installations at affordable rates. The developer says buildings will be built "solar ready" but that is little more than a space on a wall where a converter would be located & not a significant effort at solar. I have consulted with the Chief Engineer of The Institute for Energy Conversion (University of Delaware). He has provided me with the following information: 1. The payback period is conservatively six (6) years given our location in Southern California. a. (This contrasts sharply with the developer's estimate of 12 years) 2. Quality Solar Panels for commercial use are manufactured here in the US 3. All kinds of firms are manufacturing panels in California including BP and Sun Power. 4. Last year's Photovoltaic Conference of IEEE was held the San Diego at Convention Center. a. Fifteen hundred (1500) engineers working in the solar field and manufacturers attended. 5. Lower cost panels usually produce less power and may not be cost efficient in the long run. Given the economy in the US and in California, this short a payback period, and the availability of solar panels manufactured in California, I believe it would be irresponsible for developers not to build all buildings with solar energy panels made in the US. This space is for the County Clerk's Filing Stamp PROOF OF PUBLICATION (2010 & 2011 C.C.P.) STATE OF CALIFORNIA 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- entitled matter. I am the principal clerk of the printer of North County Times Formerly known as the Blade-Citizen and The Times- Advocate and which newspapers have been adjudicated newspapers of general circulation by the Superior Court of the County of San Diego, State of California, for the City of Oceanside and the City of Escondido, Court Decree number 171349, for the County of San Diego, that the notice of which the annexed is a printed copy (set in type not smaller than nonpariel), has been published in each regular and entire issue of said newspaper and not in any supplement thereof on the following dates, to-wit: July 31st, 2009 I certify (or declare) under penalty of perjury that the foregoing is true and correct. Dated at OCEANSIDE, California On this 3 1st, day of July, 2009 I Noeiri Coffman NORTH COUNTY TIMES Legal Advertising Proof of Publication of NOTICE OF PUBLIC HEARING I NOTICE IS HEREBY GIVEN to you. becauseyour interest may be affected, that me City Coun-cil of the City of Carlsbad will hold a pubfic hearing at thee, Carls-Council Chambers, 1200 Carlsbad VillagUlllHl V^IICll IIWIO, IbWW WGUI0MCIW *1 California, at 6:00 p.m. on Tu<d.to consider certification of ant Report, including the approvals of Fact, a Statement of Overridiia Mitigation Monitoring and Repceneral Plan Amendment, Master' August 11,imental Im-__..idate Find-Considerations,g Program andIan Amendment,nt Plan .Amendment, three Residential Planvelopment Permit, aand eight Conditional Useof an 83.07 acre site with idominium Permit, a Non-Permit, a Hillside De- Local Facilities ManageCarlsbad Tract Maps, a iROU DOVtoiuuiiroiii r 01 inn, a i IMI^IUD u/w~" Development Plan, a VariancePermits for the developmenta 284,400 square foot corn-shopping center, 55,000 square foot officeproject, 64 single family lot subdivision, and a multi-Family residential site all located northerly and easterly ofthe La Costa Avenue and Rancho Santa Fe Road inter-section in the southeast quadrant of the City in LocalFacilities Management Zone 11 and more particularly I described as: A portion of Section 31., To...of Section 6. Township 13 !Bernardino Meridian, togethe ,5 of Rancho Las Encinitas according to Map.thereof No848, In the City of Carlsbad, County of San Diego, Stateof California Whereas, on July 15,2009 the (Commission voted 6-0-1 to ret_the Environmental Impact Report,d to recommendIan. Master Plan,an Amendments, illsideVari-HionaT Use Permits, and to 'approve"an for the La Costa Town Square. Those persons wishing to speak on this Icordially invited to attend the public heari-the agenda bill will be available on and E..... ..2009. If you have any questions, please call Vain the Planning DeparWent at (760) 602-4613. The time within which you may judicially challenge thisEnvironmental Impact Report, General Plan Amend-ment, Master Plan Amendment. Local Facilities Manage-ment Plan Amendment, Carlsbad Tract Maps, Condo-minium Permit, Non-Residential Planned DevelopmentPermit. Hillside Development Permit, Site DevelopmentPlan, variance and Conditional Use Permits, if approved,is established by state law and/or city ordinance, and isvery short. If you challenge the Environmental ImpactReport, General Plan Amendment, Master Plan Amend-ment, Local Facilities Management Plan Amendment,Carlsbad Tract Maps, Condominium Permit. Non-Residential Planned Development Permit. Hillside De-velopment Permit, Site Development Plan, Variance andConditional Use Permits in court, you may be limited toraising only those issues you or someone else raised atthe public hearing described in this notice or in written-~ indence delivered to the! Gity of Carlsbad. Attn:rk's Office, 1200 Carlsbad Village Drive, Carts-92008, at or prior to the public hearing. . . .iP 01-04/V 08-02/CUP 04-187 CUP 08-IP 08-03/CUP 08-04/CUP 08-05/CUP NOTICE OF PUBLIC HEARING NOTICE IS HEREBY GIVEN to you, because your interest may be affected, that the City Council of the City of Carlsbad will hold a public hearing at the Council Chambers, 1200 Carlsbad Village Drive, Carlsbad, California, at 6:00 p.m. on Tuesday, August 11, 2009, to consider certification of an Environmental Impact Report, including the approval of Candidate Findings of Fact, a Statement of Overriding Considerations, and a Mitigation Monitoring and Reporting Program and a General Plan Amendment, Master Plan Amendment, Local Facilities Management Plan Amendment, three Carlsbad Tract Maps, a Condominium Permit, a Non- Residential Planned Development Permit, a Hillside Development Permit, a Site Development Plan, a Variance and eight Conditional Use Permits for the development of an 83.07 acre site with a 284,400 square foot community shopping center, 55,000 square foot office project, 64 single family lot subdivision, and a multi-family residential site all located northerly and easterly of the La Costa Avenue and Rancho Santa Fe Road intersection in the southeast quadrant of the City in Local Facilities Management Zone 11 and more particularly described as: A portion of Section 31, Township 12 South and a portion of Section 6, Township 13 South, Range 4 West, San Bernardino Meridian, together with portions of Lots 4 and 5 of Rancho Las Encinitas according to Map thereof No 848, in the City of Carlsbad, County of San Diego, State of California Whereas, on July 15, 2009 the City of Carlsbad Planning Commission voted 6-0-1 to recommend certification of the Environmental Impact Report, and to recommend approval as amended of the General Plan, Master Plan, and Local Facilities Management Plan Amendments, three Carlsbad Tract Maps, a Condominium Permit, a Non-Residential Planned Development Permit, a Hillside Development Permit, a Site Development Plan, a Variance and eight Conditional Use Permits, and to approve a Site Development Plan for the La Costa Town Square. Those persons wishing to speak on this proposal are cordially invited to attend the public hearing. Copies of the agenda bill will be available on and after August 7, 2009. If you have any questions, please call Van Lynch in the Planning Department at (760) 602-4613. The time within which you may judicially challenge this Environmental Impact Report, General Plan Amendment, Master Plan Amendment, Local Facilities Management Plan Amendment, Carlsbad Tract Maps, Condominium Permit, Non-Residential Planned Development Permit, Hillside Development Permit, Site Development Plan, Variance and Conditional Use Permits, if approved, is established by state law and/or city ordinance, and is very short. If you challenge the Environmental Impact Report, General Plan Amendment, Master Plan Amendment, Local Facilities Management Plan Amendment, Carlsbad Tract Maps, Condominium Permit, Non- Residential Planned Development Permit, Hillside Development Permit, Site Development Plan, Variance and Conditional Use Permits in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice or in written correspondence delivered to the City of Carlsbad. Attn: City Clerk's Office, 1200 Carlsbad Village Drive, Carlsbad, CA 92008, at or prior to the public hearing. CASE FILE: EIR 01-02/GPA 01-02/MP 149(R)/LFMP 87-11(C)/CT 01-09/CT 08-03/CT 08- 07/CP 01-03/PUD 08-09/HDP 01-05/SDP 01-04/V 08-02/CUP 04-18/ CUP 08- 01/CUP 08-02/CUP 08-03/CUP 08-04/CUP 08-05/CUP 08-06/CUP 08-07 CASE NAME: LA COSTA TOWN SQUARE PUBLISH: July 31, 2009 CITY OF CARLSBAD CITY COUNCIL NOT TO SCALE SITEMAP La Costa Town Square EIR 01-02 / GPA 01-02 / MP 149(R) / LFMP 87-11(C) / CT 01-09 / CT 08-03 / CT 08-07 / CP 01-03 / PUD 08-09 / HDP 01-05 / SDP 01-04 / V 08-02 / CUP 04-18 / CUP 08-01 / CUP 08-02 / CUP 08-03 / CUP 08-04 / CUP 08-05 / CUP 08-06 / CUP 08-07 ap suss ®09LS lueqeB a) e sajpej BILL HAYS 3327 CABO WY CARLSBAD CA 92009 NANCY CURRY 3325 CABO WY CARLSBAD CA 92009 FRANCES RYGLEWICZ 7700 CORTE PROMENADE CARLSBAD CA 92009 SUSAN PODGORSKI 7321 MUSLO LN CARLSBAD CA 92009 JOY LANE 3011 GARBOSO ST CARLSBAD CA 92009 ANNIKA FABIAN 3329 CABO WY CARLSBAD CA 92009 BILL AND KAREN SIMS 7462 TRIGO LN CARLSBAD CA 92009 MEHDI ZOMORRODIAN 2464 LA COSTA AV CARLSBAD CA 92009 PETER AND EVELYN MONTALBAr 2404 LA COSTA AV CARLSBAD CA 92009 CONNIE DIAMOND 3554 CALLE PALMITO CARLSBAD CA 92009 DENNIS YEE 3454 CORTE FRESA CARLSBAD CA 92009 NEAL MEYERS 3539 CALLE GAVANZO CARLSBAD CA 92009 JEFF WILLIAMS LNR PROP CORP STE210 4275 EXECUTIVE SQUARE LA JOLLA CA 92037 EDWARD STRINGER 7245 ESFERA ST CARLSBAD CA 92009 BONNIE BLACKFIELD 7317 MUSLO LN CARLSBAD CA 92009 CLEO&LEIFGIHBSSON 3315 CABO CT CARLSBAD CA 92009 RON ISRAEL 3324PIRAGUAST CARLSBAD CA 92009 RICHARD & VALERIE CORLESS 7436 TRIGO LN CARLSBAD CA MARION ALLARD 3301 PIRAGUA ST CARLSBAD CA 92009 JANE BEVERIDGE 3318 DORADO PL CARLSBAD CA 92009 DON BURTON 7450 ESFERA ST CARLSBAD CA 92009 INAJA BAND OF MISSION INDIANS 309 S MAPLE ST ESCONDIDO CA 92025 SANDRA HABR 5067 1/2 WEST 20TH ST LOS ANGELES CA 90016 KIM TROUTMAN 3329 CABO WY CARLSBAD CA 92009 ERNIE TRUJILLO 2644 LA COSTA AV CARLSBAD CA 92009 LINNEA SHEAGREN 3219 ESFERA ST CARLSBAD CA 92009 NEVILLE LAATSCH 3219FOSCAST CARLSBAD CA 92009 ATSUKO SUZUKI 7450 ESFERA ST CARLSBAD CA 92009 TOM CHRIST 7251 ESFERA ST CARLSBAD CA 92009 SANDRA GRAVITT 7410 ESFERA ST CARLSBAD CA 92009 ®<ms |33<j Aseg a||jnaj BJ apsuas ®09lS®AM3AViUBqeBi 1 ? sajpej sauanbjl- ROGER & LINDA NIEMEYER 3343 FOSCA ST CARLSBAD CA 92009 KIM RAU 7466 ESFERA ST CARLSBAD CA 92009 ANDY DAVIS 3332 BAJO CT CARLSBAD CA 92009 SUE HARTLEY 3334 CABO WY CARLSBAD CA 92009 DONALD KNEPPER 7247 ESFERA ST CARLSBAD CA 92009 PATRICK RUSHING 3147 VISTA RICA CARLSBAD CA 92009 ON THE PARK HOA 7708 CORTE PROMENADE CARLSBAD CA 92009 PARK AT LA COSTA HILLS HOA 3523 CAMINITO SIERRA #K303 CARLSBAD CA 92009 CHARLES WANG 7385 CALLE CONIFERA CARLSBAD CA 92009 MARY HEANY 7934 CALLE POSADA CARLSBAD CA 92011 ADAM PODLICH 3501 SITIO ESPINO CARLSBAD CA 92009 MIKE MEWBORN 3510CAMINOCEREZA CARLSBAD CA 92009 Ti Aseg joj uoipruisui aa$ ®091S aiVldlfliai O^ISAV asfl s|aqe-| |aa<j g|qj}Bdujoo LULU 091.8/0919® AJ9AV iffiM miu gz jeuuoj sp ,,g/g g x „ (. az|S |aqe| SHELBY J & GERILYN HUNT 7914 VIA CALLENDO CARLSBAD, CA 92009-8634 ROGER K & NANCY RICE *B* 3523 SITIO BAYA CARLSBAD, CA 92009-8920 DANIEL F & KAREN RYAN 3521 SITIO BAYA CARLSBAD, CA 92009-8920 JUDITH C & GARY FOSTER 3519 SITIO BAYA CARLSBAD, CA 92009-8920 FRANK J & MASHELL INGRANDE 3517 SITIO BAYA CARLSBAD, CA 92009-8920 REGINA E DEFRANCISCO 7801 CENTELLA ST 8 CARLSBAD, CA 92009-8467 ELVIA ALVAREZ 7344 CIRCULO PAPAYO CARLSBAD, CA 92009-8693 ROD R & REVA MCKENZIE 7348 CIRCULO PAPAYO CARLSBAD, CA 92009-8693 PENA 7329 CALLE CONIFERA CARLSBAD, CA 92009-8695 NAZI 7325 CALLE CONIFERA CARLSBAD, CA 92009-8695 NICK STANKOVICH 3455 CORTE FRESA CARLSBAD, CA 92009-8964 MARC R & SHANA MAZZANO 3459 CORTE FRESA CARLSBAD, CA 92009-8964 DENNIS J & MARY TELFER 3463 CORTE FRESA CARLSBAD, CA 92009-8964 MEGA LAI 3467 CORTE FRESA CARLSBAD, CA 92009-8964 BRILLANTES 7345 CALLE CONIFERA CARLSBAD, CA 92009-8695 STEVEN & JULIE EPPERSON 7341 CALLE CONIFERA CARLSBAD, CA 92009-8695 CHELBERG 2009 7337 CALLE CONIFERA CARLSBAD, CA 92009-8695 TIMOTHY M & LAURIE MARTIN 7333 CALLE CONIFERA CARLSBAD, CA 92009-8695 DAO 7335 PASEO CAPUCHINA CARLSBAD, CA 92009-8692 DANIEL E & MARIA BURCIAGA 7339 PASEO CAPUCHINA CARLSBAD, CA 92009-8692 MATTHEW J & MELISSA LYTLE 7347 PASEO CAPUCHINA CARLSBAD, CA 92009-8692 MARK D & NANCY PAYNE 7351 PASEO CAPUCHINA CARLSBAD, CA 92009-8692 MOSHENROSE 7355 PASEO CAPUCHINA CARLSBAD, CA 92009-8692 YANG DU 7359 PASEO CAPUCHINA CARLSBAD, CA 92009-8692 DANIEL & KIMBERLY ESPINOZA 7363 PASEO CAPUCHINA CARLSBAD, CA 92009-8692 RAMAIAH & NANETTE INDUDHARA 3482 CORTE MANZANA CARLSBAD, CA 92009-8700 YEHUDA & LILIAN MOYAL 3478 CORTE MANZANA CARLSBAD, CA 92009-8700 PETER A & KELI DUMIAK 3470 CORTE MANZANA CARLSBAD, CA 92009-8700 MATTHEW COSTANZO 3453 CORTE SELVA CARLSBAD, CA 92009-8720 WAYNE D & MARJORIE JARVIS 3457 CORTE SELVA CARLSBAD, CA 92009-8720 STAPtES label size 1" x 2 5/8" compatible with Avery ®5160/8160 Etiquette de format 25 mm x. 67 mm compatible avec Aveiy95160/8160 091-8/09 (.SaAiSAVoa/ve aiqjjeduioa uiiu ig x uiiu 92 JBUIJOJ ap 0918/0919® A\i8AV tU!« aiqpduioo ,,8/g Z x „ L 9Z|S |aqe| SCHENKHUIZEN 3461 CORTE SELVA CARLSBAD, CA 92009-8720 RONALD P QUINI 3465 CORTE SELVA CARLSBAD, CA 92009-8720 JOHN M & DENA GOFER 3464 CORTE SELVA CARLSBAD, CA 92009-8720 JOHN P & GEORGE JOSEPH 3460 CORTE SELVA CARLSBAD, CA 92009-8720 ROBIN C & Tt 3456 CORTE-'SELVA CARLSBS35T CA 92009-8720 DATTILO 3452 CORTE SELVA CARLSBAD, CA 92009-8720 KATHY WESTFALL 7357 CALLE C ARL SB AD,^-eK" 9 2 0 0 9 - 8 6 9 5 BARRY H & JULIE 7373 CALLE CARLSBAD-—^ 92009-8695 MICHAEL & PAMELA SEAL 7361 CALLE CONIFERA CARLSBAD, CA 92009-8695 OLIVER G & KELLY DAY 7377 CALLE CONIFERA CARLSBAD, CA 92009-8695 RAUL I & AYUMI ALIDIO 7369 CALLE CONIFERA CARLSBAD, CA 92009-8695 DOUGLAS J & ANGELA CYPHERS 7381 CALLE CONIFERA CARLSBAD, CA 92009-8695 QIANG WANG 7385 CALLE CONIFERA CARLSBAD, CA 92009-8695 DAVID F & HUI-WEN HARRISON 7389 CALLE CONIFERA CARLSBAD, CA 92009-8695 GLORIA C BARHAM 3401 CORTE BREZO CARLSBAD, CA 92009-8696 GHOSH JOY & LANA 3405 CORTE BREZO CARLSBAD, CA 92009-8696 ROHIT & RITAVITASTA PATNAIK 3409 CORTE BREZO CARLSBAD, CA 92009-8696 DENNIS G RUSSONIELLO 3413 CORTE BREZO CARLSBAD, CA 92009-8696 DUANE KINNETT 3417 CORTE BREZO CARLSBAD, CA 92009-8696 ALIREZA KAHARLANI 3421 CORTE BREZO CARLSBAD, CA 92009-8696 DUANE W & BETTY BACHMAN 3425 CORTE BREZO CARLSBAD, CA 92009-8696 DAVID 0 & CONNIE CALDER 3418 CORTE BREZO CARLSBAD, CA 92009-8696 JERALD L & REBECCA COX 3414 CORTE BREZO CARLSBAD, CA 92009-8696 STEPHEN P & KELLY HUGHES 3410 CORTE BREZO CARLSBAD, CA 92009-8696 CAHEY 7382 CALLE CONIFERA CARLSBAD, CA 92009-8695 GEIGER 7378 CALLE CONIFERA CARLSBAD, CA 92009-8695 WINNIE WINDER 3403 CORTE ACIANO CARLSBAD, CA 92009-8697 ARIE & SHOSH LEVIN 3407 CORTE ACIANO CARLSBAD, CA 92009-8697 WILLIAM & MICHELLE WINDER 3411 CORTE ACIANO CARLSBAD, CA 92009-8697 COLLON LEE 3415 CORTE ACIANO CARLSBAD, CA 92009-8697 STAPtES label size 1" x 2 5/8" compatible with Avery ®5160/8160 Etiquette de format 25 mm x 67 mm compatible aver, Avery®5160/8160 0918/09 i.9s/J8AV09AB aiqiiediuoo IULU /g x uiui gg puuoj sp 0918/09 IS® Aja/iy M1!M aiqseduioo ug/g j x „(. ALLEN P & INA ROSEN *M* 3419 CORTE ACIANO CARLSBAD, CA 92009-8697 JAMES N & JOAN MESSRAH 3423 CORTE ACIANO CARLSBAD, CA 92009-8697 MCCABE 3427 CORTE ACIANO CARLSBAD, CA 92009-8697 PENG & WU WANG 3431 CORTE ACIANO CARLSBAD, CA 92009-8697 SCOTT S JOHNSON 3440 CORTE ACIANO CARLSBAD, CA 92009-8697 CARLOS ENCINAS 3436 CORTE ACIANO CARLSBAD, CA 92009-8697 MICHAEL S BATISTA 3432 CORTE ACIANO CARLSBAD, CA 92009-8697 MICHEL & JAMI BOWIDOWICZ 3428 CORTE ACIANO CARLSBAD, CA 92009-8697 DOUGLAS & AMY DOBECKI 3424 CORTE ACIANO CARLSBAD, CA 92009-8697 NORMAN H & ANNE ZASLOW 3420 CORTE ACIANO CARLSBAD, CA 92009-8697 QUANLAI SONG 3416 CORTE ACIANO CARLSBAD, CA 92009-8697 RONNY A & JULIE COX 3412 CORTE ACIANO CARLSBAD, CA 92009-8697 HELEN STEVENSON 3408 CORTE CARLSBAD—CA 92009-8697 THUY-TRANG DINH 3404 CORTE ACIANO CARLSBAD, CA 92009-8697 JAMES A LEBS 3494 CAMINO CEREZA CARLSBAD, CA 92009-8965 DAN & LAURA BAJEK 3490 CAMINO CEREZA L43 CARLSBAD, CA 92009-8965 WALTON 3482 CAMINO CEREZA CARLSBAD, CA 92009-8965 MICHAEL R & MEG WOODARD 3478 CAMINO CEREZA CARLSBAD, CA 92009-8965 GARY A & DEBRA RIEHLE 3474 CAMINO CEREZA CARLSBAD, CA 92009-8965 KYLE R YATES 3470 CAMINO CEREZA CARLSBAD, CA 92009-8965 JOHN D & LAUREN CHILDS 3505 AVENIDA MARAVILLA CARLSBAD, CA 92009-9554 JAMES D SOETEN 3509 AVENIDA MARAVILLA CARLSBAD, CA 92009-9554 DAVID NUNN 3513 AVENIDA MARAVILLA CARLSBAD, CA 92009-9554 STEVEN G & ELLEN SEYLER 3521 AVENIDA MARAVILLA CARLSBAD, CA 92009-9554 SCOTT R & KIMBERLY MARTIN 3516 AVENIDA MARAVILLA CARLSBAD, CA 92009-9554 MOK APOLLO & LISA 3512 AVENIDA MARAVILLA CARLSBAD, CA 92009-9554 MARUTHY P VEDAM 3508 AVENIDA MARAVILLA CARLSBAD, CA 92009-9554 FRANKLIN 3504 AVENXDA MARAVILLA CARLSBAD, CA 92009-9554 ROBIN ROBERTS 3507 CAMINO CEREZA CARLSBAD, CA 92009-8963 DENNIS J & DENISE FASANO 3511 CAMINO CEREZA CARLSBAD, CA 92009-8963 label size 1" x 2 5/8" compatible with Avery ®5160/8160 Etiquette de format 25 mm x 67 mm compatible avec Avery®5160/8160 091-8/09 (.So/J8A\/09AB aiqiiBdiuoo uiui 1.9 x uuw qz JEIUJOJ 3P awonoi^ ,,g/g Z x , DEBORAH S RAMESH 7421 SITIO LIMA CARLSBAD, CA 92009-8469 MICHAEL A ABAD 7417 SITIO LIMA CARLSBAD, CA 92009-8469 SHONN & SUZANNE HENDEE 7413 SITIO LIMA CARLSBAD, CA 92009-8469 NANCY S BURKE 7409 SITIO LIMA CARLSBAD, CA 92009-8469 LEMMONS & JONES 7405 SITIO LIMA CARLSBAD, CA 92009-8469 GREGORY & AMBER NEWTON 7401 SITIO LIMA CARLSBAD, CA 92009-8469 BETH A PAYNE 7397 SITIO LIMA CARLSBAD, CA 92009-8470 JOHN F & HELEN PALMA 7393 SITIO LIMA CARLSBAD, CA 92009-8470 FLOHR FAMILY 7392 SITIO LIMA CARLSBAD, CA 92009-8470 SHRI & AARTHI SHRIVAS 7396 SITIO LIMA CARLSBAD, CA 92009-8470 RICCO A WASHINGTON 7400 SITIO LIMA CARLSBAD, CA 92009-8469 STEVE & MARILYN ADAMS 7404 SITIO LIMA CARLSBAD, CA 92009-8469 MARCELA ALAUIE 7408 SITIO LIMA CARLSBAD, CA 92009-8469 MARGO L LEWIS 7401 CIRCULO^-BEOUOIA CARLSBABr""CA 92009-8467 JACQUELINE K MURPHY 7405 CIRCULO SEQUOIA CARLSBAD, CA 92009-8467 ALONSO & LAURA AMAYA 7409 CIRCULO SEQUOIA CARLSBAD, CA 92009-8467 MARK GOLDSWORTHY 7411 CIRCULO SEQUOIA CARLSBAD, CA 92009-8467 NELSON H & CYNTHIA VINCENT 7415 CIRCULO SEQUOIA CARLSBAD, CA 92009-8467 MICHAEL R & BEATRICE PIPER 7419 CIRCULO SEQUOIA CARLSBAD, CA 92009-8467 THAYER BARAKAT 7423 CIRCULO SEQUOIA CARLSBAD, CA 92009-8467 CHRISTIAN G & JOANNA MELLEIN 7427 CIRCULO SEQUOIA CARLSBAD, CA 92009-8467 DAVID J & ELIZABETH WALTERS 7431 CIRCULO SEQUOIA CARLSBAD, CA 92009-8467 KAREY L & VALERIE TSANG 3505 SITIO ESPINO CARLSBAD, CA 92009-8466 ADAM PODLICH 3501 SITIO ESPINO CARLSBAD, CA 92009-8466 JOSEPH M & CHRISTINE LARSCHEI 3502 SITIO ESPINO CARLSBAD, CA 92009-8466 CHRISTOPHER N CHURCHILL 3506 SITIO ESPINO CARLSBAD, CA 92009-8466 CUNNINGHAM 7357 SITIO LIMA CARLSBAD, CA 92009-8470 BRYON & BARBARA LUCAS 7353 SITIO LIMA CARLSBAD, CA 92009-8470 MICHEAL J & AMY YORDT 7360 SITIO LIMA CARLSBAD, CA 92009-8470 DANIEL R & LESLIE JACKSON 7364 SITIO LIMA CARLSBAD, CA 92009-8470 label size 1" x 2 5/8" compatible with Avery ®5160/8160 Etiquette de format 25 mm x 67 mm compatible avec Avery®5160/8160 aiquediuoo iuiu ^g x tuiu gg jeuuoj ap 091.8/091.9® AjSAtf IUIM aiqiiedwoo ,,8/g 2 x., |. 8ZjS iaqe| AARON & ROBIN CULL 7368 SITIO LIMA CARLSBAD, CA 92009-8470 JAMES A & ROCIO HILL 7372 SITIO LIMA CARLSBAD, CA 92009-8470 CHRISTOPHER BONNER 7376 SITIO LIMA CARLSBAD, CA 92009-8470 MORAN 7380 SITIO LIMA CARLSBAD, CA 92009-8470 VINCENT & ANGELIj 7384 SITIO 92009-8470 JEFF A & CARLA GRANT 7388 SITIO LIMA CARLSBAD, CA 92009-8470 ECKART H & INES VOSKAMP 7435 CIRCULO SEQUOIA CARLSBAD, CA 92009-8467 SANDO 7439 CIRCULO SEQUOIA CARLSBAD, CA 92009-8467 MARK R & SUSAN HERNDON 7443 CIRCULO SEQUOIA CARLSBAD, CA 92009-8467 JAMES & LIZA HANTSKE 7683 CIRCULO SEQUOIA CARLSBAD, CA 92009-8472 CHRIS & ROCHELLE HELLER 7687 CIRCULO SEQUOIA CARLSBAD, CA 92009-8472 JOHN & REBECCA RIEDY 7691 CIRCULO SEQUOIA CARLSBAD, CA 92009-8472 CHRISTIE MOON 7695 CIRCULO SEQUOIA CARLSBAD, CA 92009-8472 FREDERICK S & MICHELLE JONES 7699 CIRCULO SEQUOIA CARLSBAD, CA 92009-8472 MARX 8070 SITIO TOLEDO CARLSBAD, CA 92009-9552 JUSTUS & KRISTINE BREESE 7814 PASEO LA JOLLA CARLSBAD, CA 92009-9515 JOHN & SARA ALAIMO 7810 PASEO LA JOLLA CARLSBAD, CA 92009-9515 KEVIN L STAAB 7806 PASEO LA JOLLA CARLSBAD, CA 92009-9515 FRANK A & LAURA SACCO 7802 PASEO LA JOLLA CARLSBAD, CA 92009-9515 CHUNGKEN KAO 7798 PASEO LA JOLLA CARLSBAD, CA 92009-9506 C C C 7794 PASEO LA JOLLA CARLSBAD, CA 92009-9506 KRAIG B & J WINTERS 7786 PASEO LA JOLLA CARLSBAD, CA 92009-9506 GEORGE R & MARGARET BOHRER 7782 PASEO LA JOLLA CARLSBAD, CA 92009-9506 HAMA 7778 PASEO LA JOLLA CARLSBAD, CA 92009-9506 JEREMY C & JULIE LYONS 7774 PASEO LA JOLLA CARLSBAD, CA 92009-9506 ROBERT & MIEL BURNETT 7770 PASEO LA JOLLA CARLSBAD, CA 92009-9506 CHENG-HU 7781 PASEO LA JOLLA CARLSBAD, CA 92009-9505 JUSTIN & REBECA BISSING 7785 PASEO LA JOLLA CARLSBAD, CA 92009-9505 ANGELA BASHENOW 7793 PASEO LA JOLLA CARLSBAD, CA 92009-9505 DOUGLAS R & CHRISTINE ST *M* 7797 PASEO LA JOLLA CARLSBAD, CA 92009-9505 STAPtES label size 1" x 2 5/8" compatible with Avery ®5160/8160 Etiquette de format 25 mm x 67 mm compatible avec Avery®5160/8160 B aiquecfuioo uiiu ^g x tuiu gz IBUJJOJ ap attanong 0918/0919® AJBAV miM aiq&ediuoD l(8/9 z *,.(. 8Z|S |3QB| ESPINO 7801 PASEO LA JOLLA CARLSBAD, CA 92009-9514 JEREMY & NANCY LEE 3318 CORTE VERSO CARLSBAD, CA 92009-9323 STEVE D & MARY NYEHOLT 3322 CORTE VERSO CARLSBAD, CA 92009-9323 RANDAL C & MARY NAKAGAWA 7703 SITIO MUSICA CARLSBAD, CA 92009-9321 ALPHONSE CHAN 7704 SITIO MUSICA CARLSBAD, CA 92009-9321 RICHARD HENNESSY 7708 SITIO MUSICA CARLSBAD, CA 92009-9321 JOEL H NEW 4016 PENINSULA DR CARLSBAD, CA 92010-5564 ALEXANDER 831 CAMINITO VERDE CARLSBAD, CA 92011-3306 BRUNSON HOWARD 7061 SURFBIRD CIR CARLSBAD, CA 92011-4018 SHADES S TALEBI 7461 MERMAID, CARLSBA0T"CA 92011-4693 MARILYNN D STYERS 6485 WAYFINDERS CT CARLSBAD, CA 92011-4076 LA COSTA OAKS COMMUNITY ASSN 1959 PALOMAR OAKS WAY 320 CARLSBAD, CA 92011-1313 MARIO M & CLAVEL ZIALCITA PO BOX 130235 CARLSBAD, CA 92013-0235 RICHARD W & 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92009-7825 J HARRINGROBERT 7706 CARLS 202 CA 92009-2133 LITA CHERNOFF 3205 AZAHAR PL CARLSBAD, CA 92009-8303 AU3AV OLSON FAMILY 7045 LLAMA CARLSBAErr"'cA 92009-6520 HUGH P & KARA 3208 AZAHAR CARLSB.92009-8302 JOSEPH & FRANCES DEFILIPPIS 3203 AZAHAR PL CARLSBAD, CA 92009-8303 JOSEPH & REBECCA ARLAUSKAS 3206 AZAHAR PL CARLSBAD, CA 92009-8302 [ wi36p3 dn-dod asodxa i oi auj| 6uo|B puaa AH3AV-OD-008-1.e| ja|3Aa.i j ap wje ainipeq e| e zai|day ap sues ®AM3AV »ueqe6 ja|3d ? sajpej, sawanbag OPALSKI 3204 AZAHAR PL CARLSBAD, CA 92009-8302 JOHN C & LEEANN WERNER 3103 CADENCIA ST CARLSBAD, CA 92009-8311 JAMES T RIESTER 3207 AZAHAR PL CARLSBAD, CA 92009-8303 ANDREW & DANA LAYMAN 3028 AZAHAR CT CARLSBAD, CA 92009-8301 ROBB J & KRISTEN KIRSCHENMANI 3027 AZAHAR CT CARLSBAD, CA 92009-8301 EDWARD J & ROBIN GARVEY 3029 AZAHAR CT CARLSBAD, CA 92009-8301 ROBERT B MCCLENDON 3211 AZAHAR PL CARLSBAD, CA 92009-8304 RONALD & BARBARA BUB 3215 AZAHAR PL CARLSBAD, CA 92009-8304 BERTHOLD SCHULZ 3217 AZAHAR PL 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3302 AZAHAR PL CARLSBAD, CA 92009-8305 TED & CRISTINA MILLER 3218 AZAHAR PL CARLSBAD, CA 92009-8302 JERNIGAN 3216 AZAHAR PL CARLSBAD, CA 92009-8302 COLE STEPHAN M 3214 AZAHAR PL CARLSBAD, CA 92009-8302 ©AU3AV I ma6pa dn-dod asodxa i oj 3Uj| 6uo|B puag See Instruction Sheet j for Easy Peel Feature ^ ! A mm J[Feed Paper •"••• VINCENT & ANGELIKA LONG 17LARCHWOOD RANCHO SANTA FE, CA 92067-6311 IRVINE, CA 92602-0941 Easy Peel Labels Use Avery® TEMPLATE 5160® PAULA D HODGETTS PO BOX 676311 AVERY®5160® SAKAI 7325 CORTE TOMILLO CARLSBAD, CA 92009-8961 F CALLISON 1425 VIA VALENTE ESCONDIDO, CA 92029-7244 ROBERT J HARRINGTON PO BOX 3786 W LAFAYETTE, IN 47996-3786 SEAN MASTERSON 1832MILBANKRD. ENCINITAS, CA 92024-1028 BARRY H & JULIE HODGES 796 LYNWOOD DR. ENCINITAS, CA 92024-2389 ROBIN C & THANH BENAS 10900 WINDHAM WAY ALPHARETTA, GA 30022-4719 MAUREEN J BATIZ 1929SW541HST. CAPE CORAL, FL 33914-6888 JAMES R TONER 7777 ALVARADO RD., STE. 200 LA MESA, CA 91941-3667 LORI E. WAITE 10325 CHARWOOD CRT. RANCHO CUCAMONGA, CA 91737- 3077 FRANK N. & ERI BALES 4413 BANFF ST. ANNANDALE, VA 22003-4512 GARY & MICHELE MCCLELLAN 7588 DEHESA CRT. CARLSBAD, CA 92009-7703 JAMES CHANG 100 MC LELLAN DR., STE. 3093 S. SAN FRANCISCO, CA 94080-7540 CATHERINE SCHUSTER 1072 CREST DR. ENCINITAS, CA 92024-4042 KATERINA KARAMANOU 8775 COSTA VERDE BLVD., APT 917 SAN DIEGO, CA 92122-5345 MICHAEL & JAMIE SPIRITO 4912 AVILA AVE. CARLSBAD, CA 92008-3704 TARA A. LEAHY 17311BONNERDR. TUSTIN, CA 92780-1802 ROBIN M. GEHLSEN 1042B N. EL CAMINO REAL, #377 ENCINITAS, CA 92024-1320 THOMAS CHYNCES 191 E. EL CAMINO REAL, SPC. 201 MOUNTAIN VIEW, CA 94040-2716 OLSON FAMILY 3338 DEL RIO CRT. CARLSBAD, CA 92009-7815 KAREN ESCHRICH 1203 LAGUNA ST. OCEANSIDE, CA 92054-5438 EVAN ZUPANCIC 13754 MANGO DR., UNIT #226 DEL MAR, CA 92014-3438 JEFFREY S. SHEAN 13315 VIA MAGDALENA, UNIT #4 SAN DIEGO, CA 92129-4693 JOSE A. & DESIREA ACERO 8133 VIRGINIA AVE. SOUTH GATE, CA 90280-2407 STACY M. BLACKWOOD 246 SANTA LOUISA IRVINE, CA 92606-8882 DAVID NASH 137 AVOCADO ST. ENCINITAS, CA 92024-1007 LUIS URDAY 843 13™ ST., APT. #8 SAN DIEGO, CA 92101-6627 COREY L. & ANNALISA PULLIG 6060 FAIRMONT PKWY., APT. #9102 PASADENA, TX 77505-4074 Etiquettes faciles a peler Utilisez le qabarit AVERY® 5160®Sens de charqement Consultez la feuille H'inctrnrtinn www.avery.com Easy Peel Labels Use Avery® TEMPLATE 5160®j^Feed Paper See Instruction Sheet j for Easy Peel Feature ^ CARLSBAD UNIF SCHOOL DIST 6225 EL CAMINO REAL CARLSBAD CA 92011 SAN MARCOS SCHOOL DISTRICT STE 250 255 PICO AVE SAN MARCOS CA 92069 =NCIN!TAS SCHOOL DISTRIC1 ^1 RANCHO SANTA FE RD ENCINITAS CA 92024 SAN DIEGUITO SCHOOL DISTRICT 701 ENCINITAS BLVD ENCINITAS CA 92024 LEUCADIA WASTE WATER DIST TIM JOCHEN 1960 LA COSTA AVE CARLSBAD CA 92009 OLIVENHAIN WATER Dl STRIC 1966OLIVENHAINRD ENCINITAS CA 92024 CITY OF ENCINITAS 505 S VULCAN AV ENCINITAS CA 92024 CITY OF SAN MARCOS 1 CIVIC CENTER DR SAN MARCOS CA 92069-2949 CITY OF OCEANSIDE 300 NORTH COAST HWY OCEANSIDE CA 92054 CITY OF VISTA 600 EUCALYPTUS AVE VISTA CA 92084 CALIF DEPT OF FISH & GAME 4949 VIEWRIDGE AV SAN DIEGO CA 92123 VALLECITOS WATER DISTRICT 201 VALLECITOS DE ORO SAN MARCOS CA 92069 REGIONAL WATER QUALITY STE 100 9174 SKY PARK CT SAN DIEGO CA 92123-4340 I.P.U.A. SCHOOL OF PUBLIC ADMIN URBAN STUDIES SAN DIEGO STATE UNIVER! SAN DIEGO CA 92182-4505 SD COUNTY PLANNING STEB 5201 RUFFIN RD SAN DIEGO CA 92123 LAFCO 1600 PACIFIC HWY SAN DIEGO CA 92101 AIR POLLUTION CONTROL DISTRICT 10124 OLD GROVE RD SAN DIEGO CA 92131 SANDAG STE 800 401 B STREET SAN DIEGO CA 92101 U.S. FISH & WILDLIFE 601 CHIDDEN VALLEY RD CARLSBAD CA 92011 CA COASTAL COMMISSION STE 103 7575 METROPOLITAN DR SAN DIEGO CA 92108-4402 ATTN TEDANASIS SAN DIEGO COUNTY AIRPOI AUTHORITY PO BOX 82776 SAN DIEGO CA 92138-2776 CARLSBAD CHAMBER OF COMMERCE 5934 PRIESTLEY DR CARLSBAD CA 92008 CITY OF CARLSBAD PUBLIC WORKS/ENGINEERING DEPT- PROJECT ENGINEER CITY OF CARLSBAD PROJECT PLANNER SCOTT MOLLOY - BIASD STE 110 9201 SPECTRUM CENTER SAN DIEGO CA 92123-14( Etiquettes faciles a peler I M-ilic<v» la naKarit AVPRY® R1fiO*Sens de chargement Consultezlafeuille destruction wwv