Loading...
HomeMy WebLinkAbout2009-10-19; Parks & Recreation Commission; 1009-4; Use options radio or remote controlled devicesPARKS & RECREATION COMMISSION - AGENDA BILL AB#1009-4 MTG. DATE:10/19/09 STAFF: | CALARCO OPTIONS FOR THE USE OF RADIO OR REMOTE CONTROLLED AIRCRAFT, CARS, OR SIMILAR DEVICES IN PARKS AND BEACHES INFO ACTION RECOMMENDED ACTION: Review the four options for the use of radio or remote controlled aircraft, cars, or similar devices in parks and the beach area west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive, and make a recommendation to the Carlsbad City Council for their consideration. ITEM EXPLANATION: In response to resident, park user, and staff concerns regarding excessive ambient noise, personal and property safety issues associated with the use of radio controlled aircraft in parks, subsection (31) was added to section 11.32.030 of the Carlsbad Municipal Code. The subsection specifically prohibits the "use [of] radio or remote controlled model aircraft, cars or similar devices [in parks], excepting the beach area west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive." Safety concerns were primarily related to the use of radio controlled aircraft in the close vicinity of active and passive park users. Park visitors expressed a feeling of being threatened by low flying planes while using the athletic fields or walking in the vicinity of where the planes were being flown. City staff has received and responded to noise complaints from residents in the vicinity of Poinsettia Park regarding the use of radio controlled airplanes and helicopters. This particular amendment to section 11.32.030 of the Carlsbad Municipal Code was first presented to Council at their meeting of January 27, 2009, and the amendment was later adopted at their meeting of February 10, 2009. No public comment regarding the revision was received at either meeting. Subsequently, staff received several e-mails from local radio controlled aircraft enthusiasts, expressing concern over the limitations of this amendment. On June 16, 2009, professional pilot, local aerial photography business owner, and radio controlled aircraft enthusiast, Gus Calderon, addressed the City Council during public comment. Mr. Calderon said that he was surprised and upset by the change. He stated that he had been safely flying in parks for many years, and didn't understand why the code was amended in the first place. Mr. Calderon requested that the City Council reconsider their decision to prohibit the use of radio controlled aircraft in parks. In August 2009, California State Parks staff issued a related position paper regarding the use of the beach area west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive (commonly referred to as "Dave's Beach") (Exhibit 1). An aerial photograph of the subject area is provided for your reference (Exhibit 2). The report authors expressed concern regarding the increased use and potentially detrimental environmental impact of radio controlled aircraft on adjacent State Parks property resulting from the amendment to the Municipal Code. During ideal weather conditions, State Park Rangers have apparently observed as many as 12-14 pilots flying at one time. The report authors surmised that Page 2 The increased use may be attributed in part to the fact that the use of radio controlled aircraft in parks was recently prohibited. In an effort to address and alleviate site use and safety concerns, city staff met with Mr. Calderon, a small group of radio controlled aircraft enthusiasts, and a representative from California State Parks. Creation of an exception for an alternative use park site(s) was discussed as a means to ease some of the influx of radio controlled aircraft activity on the subject beach area, and to reach a compromise of limited activity on a designated park site(s). City staff, with assistance from Mr. Calderon (president of the Carlsbad Electric Flyers), other radio controlled aircraft enthusiasts, and State Parks staff thoroughly researched the issue. Staff consulted the Academy of Model Aeronautics (AMA) for industry best practices regarding radio controlled aircraft safety rules and regulations, insurance requirements, and equipment definitions and use specifications. Based on all of the available information, staff is presenting four possible alternatives for the Parks and Recreation Commission to consider, and then make a recommendation to the City Council. Option #1: Repeal the recent amendment to section 11.32.030 (31) of the Carlsbad Municipal Code that prohibits the "use [of] radio or remote controlled model aircraft, cars or similar devices [in parks], excepting the beach area west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive," thereby deregulating the use of radio or remote controlled aircraft, cars, or similar devices in parks and beaches. Option #2: Make no changes. Section 11.32.030 (31) shall remain as amended. The use of radio or remote controlled model aircraft, cars, or similar devices would still be permitted only at the beach area west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive. Option #3: Amend section 11.32.030 (31) of the Carlsbad Municipal Code to allow the strictly regulated use of radio or remote controlled aircraft at Zone 5 athletic field, and at the beach area west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive (Exhibit 3). Formally adopt a set of safety rules and regulations for both locations, and require AMA membership and insurance that includes express limitations (Exhibit 4). Amend section 11.32.030 (31) to prohibit the use of radio or remote controlled cars, or similar devices at all parks and beaches. Option #4: Amend section 11.32.030 (31) of the Carlsbad Municipal Code as follows, "No person shall operate any remote control vehicle on any artificial turf field within any park. Recreational use of electric remote control model airplanes will be permitted on park baseball fields only if a scheduled league game or practice is not occurring; provided, however, they meet the Academy of Model Aeronautics (AMA) definition of a "Park Flyer Model." No person shall operate any remote control model airplanes within the park unless they are a member of the AMA Park Flyers Program and they obey the AMA National Safety Code" (Exhibit 5). Page 3 FISCAL IMPACT: If Option #1, Option #2, or Option #4 were selected, there would be no direct fiscal impact. If Option #3 were selected, there would be an estimated $400 fiscal impact related to the cost of fabricating and installing rules and regulations signs at Zone 5 athletic field and the beach area west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive. This cost would be absorbed within the parks maintenance operating budget. EXHIBITS: 1. Position paper on the use of remote controlled gliders and planes within California State Parks. 2. Aerial view of the beach area west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive (commonly referred to as "Dave's Beach"). 3. Aerial view of proposed Zone 5 athletic field use area. 4. Proposed rules for the use of Park Flyers and Sailplanes (Gliders) at Zone 5 athletic field and the beach area west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive (commonly referred to as "Dave's Beach"). 5. September 2009 proposal to city staff from Carlsbad Electric Flyers AMA chartered club members. State of California EXHIBIT 1 Department of Parks Recreation San Diego Coast District - North Sector ISSUE PAPER REMOTE CONTROLLED GLIDERS AND PLANES WITHIN STATE PARKS ISSUE: Remote control (R/C) glider and airplane enthusiasts have become an increasingly visible recreational user group within the San Diego Coast District-North Sector with a primary location unofficially named and known as "Dave's Beach," which is located above South Carlsbad State Beach just north of Solamar Drive. Effectively July 01, 2009 the City of Carlsbad made an addendum to Carlsbad Municipal Code Section 11.32.030 (31) which "prohibits the use of radio or remote controlled aircraft, cars, or similar devices, excepting the beach area west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive." This enforced municipal code section has added displaced R/C pilots to the already congested and crowded mixed use area of South Carlsbad State Beach. Complaints regarding the recreational activity of R/C piloting prior to the City's enforcement of CMC 11.32.030(31), included damage to property caused by gliders or planes striking vehicles, minor injuries to other user groups in the area when gliders or planes of inexperienced pilots strike pedestrians, and increased erosion and degradation to the fragile coastal bluffs within the area when gliders and planes are retrieved by R/C pilots. Other concerns, although neither scientific data nor accident reports were found are the possible negative effects of R/C gliders on local native wildlife including the California Least Tern and other migrating coastal seabirds and the threat of disrupting vehicle traffic on the adjacent southbound lanes of Carlsbad Blvd. This change in the City's Municipal Code will increase the recreational use of R/C aircraft on State Park property and air space, necessitating a review of our current policies within the area including, but not limited to: • Does the area allow for this specific type of recreation? • Is public safety jeopardized by allowing this recreational activity to continue? • Is their a limit to the number of participants utilizing the property and airspace managed and under the jurisdiction of Ca State Parks? • Does the area allow for "mixed" use recreational activities? • If the activity is allowed to continue, what rules or regulations need to be mandated to maintain safety for the direct user and other park visitors, as well as, protect the resources within the affected area? Further research has found the area has historical and cultural significance concerning R/C piloting dating back to the early 1970's. The activity has coexisted with the other multitude of recreational activities for nearly 50 years, however, the populations have increased within all local known recreational activities in the area including running, bicycling, beach combing, walking, surfing, body boarding, swimming, snorkeling, as well as R/C piloting. The continued increasing visitation to the area by all user groups may cause a significant hazard to any recreational user; however, the current enforcement of CMC 11.32.030(31) appears to have maximized the dangers and issues concerning R/C piloting in this area, by concentrating R/C pilots into a very small area of City and State Park owned lands. OBSERVATION OF THE AREA KNOWN AS "DAVE'S BEACH"; The R/C piloting area north of Solamar Drive, known by R/C enthusiast as "Dave's Beach" is bordered by a 4- foot fence on the east side of the piloting area, and steep eroding descending coastal bluffs, the beach below, and the Pacific Ocean to the west. A portion of the area is paved on the southern end, with graded decomposed granite and sand composition on the northern end of the piloting area. Free on-street public parking is available n directly behind the piloting area and to the south. The busy southbound lanes of Carlsbad Blvd sit approximately 15 feet to the east of the fence line of the piloting area, as does a North County Transit bus stop. Numerous voluntary and unstable pedestrian trails descend down the steep coastal bluff areas directly below the flight area. These trails are used by walkers, joggers, surfers, swimmers, beach combers, and guests of the adjacent hotel located directly across from the area and on the east side of Carlsbad Blvd. These systems of trails are also used by R/C pilots to retrieved down gliders and planes when necessary. Use patterns of the area suggest multiple recreational activities and user groups utilize the bluff top area known as Dave's Beach. Cyclists, walkers, joggers, surfers, R/C pilots, and others all utilize the area. No signage or markers provide information or regulations concerning any of the recreational activities commingling within the confined space. The fencing provides no significant demarcation line for any activity and the only permanent item to possibly define the area for R/C piloting is a metal pole with an attached wind sock. The beach area below the R.C flight area does have a consistent use pattern by sunbathers, walkers, and surfers. Various maps show conflicting State Park and City owned property boundaries within the area. It is unknown if lawful approval was given for the installation of the fencing, windsock, and memorial plaque. It does appear the pavement and bluff top area used was a potion of the old Highway 101 route. According to those associated with the "Academy of Model Aeronautics" (AMA) Park Pilot Program the area should host no more than 4 to 5 pilots at one time; however, various random visual inspections of the area during satisfactory flight conditions has seen as many as 12 to 14 pilots flying at one time.. BACKGROUND INFORMATION REGARDING R/C GLIDERS What is an R/C Glider Remote controlled gliders are small radio-controlled aircraft that operate on radio frequencies in the same fashion as remote control vehicles. The gliders are controlled remotely via radio signals from a hand-held controller which essentially moves the wing -flaps of the glider, allowing the operator to manipulate the aircraft. RC gliders do not have motors and utilize the natural lift created from on shore winds hitting the coastal bluffs thus creating a mass of rising air. Gliders fly effortlessly in this lift in the same way Pelicans and other seabirds glide close to the bluffs or over waves, riding the natural lift energy the earth formations assist in creating. What is an R/C Airplane Remote controlled airplanes and helicopters are both propelled by on-board motors which are controlled by radio frequency remotely. These types of aircraft are not dependent on rising air mass for flight. Existing Regulations /Organizations The Academy of Model Aeronautics, or AMA, is on of the world's largest Aero-modeling organizations and has established some governing documents and suggested safety guidelines for all R/C glider pilots to follow (attachment A). These guidelines should be reviewed by the State Park Policy Group as they address many of the issues concerned with the current activities at South Carlsbad State Beach. During the research of this issue authors met with the Torrey Pines Gulls, an R/C glider pilot's association which flies out of the Torrey Pines Glider Port. The group has produced a strong framework of rules and regulations (Attachment B) which governs R/C piloting of all aircraft at the Torrey Pines Glider Port. The City of Carlsbad has also recently made an addendum to Carlsbad Municipal Code Section 11.32.030 (Subsection 31) which prohibits the use of R/C gliders within all city parks and beach areas, and State of California Code of Regulations, Title XIV, Section 4309- unsafe recreational activities may be used to prohibit the use of R/C gliders and planes if data suggests it is harmful to others, the resources, or wildlife. AUTHORITY TO ACT California State Parks owns and manages property within the area where R/C pilots are currently flying. Although property boundaries are not precise, no entity can deny that gliders and planes which land or crash upon coastal bluff areas are being used within State Park boundaries. The California Code of Regulations also provides State Park to lawfully protect airspace above any State Park owned and managed lands up to an elevation of 500'. Gliders flown from the bluffs north of Solarmar Drive consistently are flown within airspace managed and policed by State Park Peace Officers. As a sworn law enforcement department of the State of California, State Parks has the jurisdictional authority and obligation to enforce all CCR, as well as, CMC codes within the area described. State Park law enforcement entities also have the responsibility to protect all user groups and curtail or deny any dangerous or unhealthy recreation that causes unsafe conditions for the resources, cultural or historical artifacts, or visitors and pedestrians within any lands owned or managed by State Parks. DISCUSSION: The initial discussion concerning the flight of R/C gliders and airplanes from "Dave's Beach" and within the air space of California State Parks was to decide if the recreational activity was conducive with the current recreational opportunities utilizing the area and the ever increasing pedestrian traffic in the area. This discussion point has diminished with two new facts which have been discovered during the investigation of this issue. First, it is apparent R/C pilots of both gliders and planes have been utilizing the area in question for the past 50 years. The recreational activity and the location have historical and cultural significance of the craft of R/C piloting. As the area is part of a California State Park it is important to acknowledge the importance of this location and the activity to the evolution of the sport of R/C piloting. Second, the City of Carlsbad has created and is currently enforcing the Carlsbad Municipal Code (CMC) 11.32.030(31), which prohibits the piloting of R/C gliders and planes in any city owned park or beach area, with written and verbal instructions from City officials to pilots to utilize "Dave's Beach" as the single and only area for the specific recreational activity of R/C flying. It is apparent the area, prior to the addendum to the CMC, was impacted by the onslaught of today's less expensive R/C aircraft and the increase of participants of pilots within the sport. The new and enforced municipal code will further impact the area and create an area unsafe for not only the recreational activity of R/C piloting, but also impact and create unsafe conditions for other user groups in the area. ALTERNATIVES CONSIDERED: • Prohibit the activity of R/C piloting within the area known as "Dave's Beach" utilizing CCR, Title XIV, Section 4329. This seems the least suitable alternative researched with enforcement of such a ban being near impossible with the current workload of law enforcement officers, coupled with the known historical and cultural relevance of the activity and the area located within the boundaries of California State Parks which is directed to protect such values. • Meet with various user groups including, but not limited to R/C pilot groups, surfers, walkers, runners, and cyclist to develop a comprehensive general plan for the area to provide safety to all users and develop specific rules and regulations for all activities currently utilizing the area. This may include providing signage defining rules and regulations pertaining to R/C piloting, fencing or boundaries for the flight, take-off and landings of R/C gliders and planes, creating an observable route for runners, walkers and joggers, and develop a long term plan to provide safe and lawful access from the bluff area to the beach below. • Create a partnership with the City of Carlsbad and the AMA to identify and develop other locations for the recreational activity of R/C piloting, due in part, because the current municipal code causes undo stress and danger to those pilots and other user groups currently utilizing the area known as "Dave's Beach." RECOMMENDATION: The recommendation of the North Sector Management Team is to find a solution to the issue by seeking resolution within "Alternatives 2 and 3." While the cultural and historical significance of the recreational activity of R/C piloting is important to the area, it is apparent that the current recreational trends direct staff to seek alternatives or develop future policies through input through the public and the City of Carlsbad for all involved. ACTION REQUIRED: The issue paper requests review of this document by the City of Carlsbad and Park Policy Group to find clarity and resolution to the issues described. Submitted by: Gary Rasse State Park Peace Officer/Ranger San Diego Coast District - North Sector Brian Ketterer Sector Superintendent San Diego Coast District - North Sector EXHIBIT 2 EXHIBITS EXHIBIT 4 PROPOSED RULES FOR THE USE OF PARK FLYERS AND SAILPLANES (GLIDERS) AT ZONE 5 ATHLETIC FIELD AND THE AREA COMMONLY KNOWN AS "DAVE'S BEACH" • Zone 5 Athletic Field Park Flyers and Sailplanes (Gliders) may be used at Zone 5 Park during the following days/hours: o Monday-Friday from 8:00 a.m.-11:30 a.m., and 1:00 p.m. to 3:00 p.m. o At other times when the athletic field is not in use for organized or individual sporting activities (football, soccer, baseball, softball, etc.) o Athletic sports activities take field use priority at all times • "Dave's Beach" Park Flyers and Sailplanes (Gliders) may be used at the area commonly known as "Dave's Beach" (beach bluff plateau west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive) during the following days/hours: o Monday-Sunday from sunrise to sunset • Park Flyer Models Defined o Weigh two (2) pounds or less o Are incapable of reaching speeds greater than 60 miles per hour o Are electric or rubber powered, or of similar quiet means of propulsion o Are remotely controlled or flown with a control line o Remain within the pilot's line of sight at all times • Sailplane (Glider) Models Defined o Class A hand-launch Sailplane (Glider) with a projected span limited to one and one-half (1 Vz) meters or less o Class B Sailplane (Glider) with a projected span limited to two (2) meters, but greater than one and one-half (1 Yz) meters • Park Flyer and Sailplane Safety Code and Operating Guidelines o Inspect your Park Flyer or Sailplane (Glider) before every flight to make certain it is airworthy o Be aware of any other radio frequency user who may present an interference problem o Always be courteous and respectful of other users of your selected flight area o Make sure the area is clear of obstacles and large enough to safely accommodate your flying activity o Make certain the area is clear of friends and spectators prior to launching your Park Flyer or Sailplane (Glider) o Be aware of other activities in the vicinity of your flight path that could cause potential conflict o Carefully plan your flight path prior to launch o Abide by any and all established Academy of Model Aeronautics (AMA) National Model Aircraft Safety Code items where applicable and appropriate ALL PARK FLYER OR SAILPLANE (GLIDER) OPERATORS MUST BE A CURRENT MEMBER OF THE ACADEMY OF MODEL AERONAUTICS (AMA). For membership information call: (800) 435-9262, or visit: http://www.modelaircraft.org/membership/membership.aspx. o A valid Academy of Model Aeronautics (AMA) membership card must be clearly displayed on your person while operating a Park Flyer or Sailplane at the prescribed locations. o As a benefit of AMA membership, all pilots must maintain valid general liability insurance coverage (with express limitations) for the operation of a Park Flyer or Sailplane. EXHIBIT 5 Carlsbad Electric Flyers 878 Hollyhock Court Carlsbad, CA 92011 Mick Calarco & Kyle Lancaster Carlsbad Parks and Recreation Department 799 Pine Avenue, Suite 200 CC: Carlsbad City Council & City Attorney Dear Mick and Kyle, Effectively July 01, 2009, the City of Carlsbad made an addendum to Carlsbad Municipal Code Section 11.32.030 (31) which "prohibits the me of radio or remote controlled aircraft, cars, or similar devices, excepting the beach area west of Carlsbad Boulevard, between Palomar Airport Road and Solamar Drive." On July 20th, our recreational group of r/c enthusiasts was invited to a meeting at "Dave's Beach" with Brian Ketterer (Sector Superintendent of the CA State Parks, San Diego Coast District). We were informed that CA State Parks was unaware that the Carlsbad City Council had authorized a recreational activity on land upon which they do not have the authority to act. The CMC was passed without the consent or authorization of the CA State Parks. Mr. Ketterer informed us that since the CA State Parks had not formally taken a position on flying r/c airplanes at "Dave's Beach," his office was going to write an "Issue Paper" to address the situation. Review of the Issue Paper discloses two important points which are relevant to why the CMC must be mandated to change: "It is apparent the area, prior to the addendum to the CMC, was impacted by the onslaught of today's less expensive R/C aircraft and the increase of participants of pilots within the sport. The new and enforced municipal code will further impact the area and create an area unsafe for not only the recreational activity of R/C piloting, but also impact and create unsafe conditions for other user groups in the area. AUTHORITY TO ACT California State Parks owns and manages property within the area where R/C pilots are currently flying. Although property boundaries are not precise, no entity can deny that gliders and planes which land or crash upon coastal bluff areas are being used within State Park boundaries. The California Code of Regulations also provides State Park to lawfully protect airspace above any State Park owned and managed lands up to an elevation of 500'. Gliders flown from the bluffs north of Solamar Drive consistently are flown within airspace managed and policed by State Park Peace Officers. As a sworn law enforcement department of the State of California, State Parks has the jurisdictional authority and obligation to enforce all CCR, as well as CMC codes within the area described. State Park law enforcement entities also have the responsibility to protect all user groups and curtail or deny any dangerous or unhealthy recreation that causes unsafe conditions for the resources, cultural or historical artifacts, or visitors and pedestrians within any lands owned or managed by State Parks." On August 10th, 2009 our recreational group, which is now organized as an Academy of Model Aeronautics (AMA) chartered club named the "Carlsbad Electric Flyers", met with Mick Calarco and Kyle Lancaster from the Carlsbad Parks and Recreation Department. During that meeting we were told that it was not their intent to completely ban our recreational group from the City of Carlsbad, but simply move the activity to the bluff area along the coast known as "Dave's Beach". Unfortunately, this line of reasoning proved invalid for the following two reasons: First, the City of Carlsbad has no jurisdiction over "Dave's Beach" as stated above in Brian Ketterer's Issue Paper. Additionally, the CA State Parks has the authority to "Prohibit the activity of R/C piloting within the area known as 'Dave's Beach' utilizing CCR, Title XIV, Section 4329." While this solution is not the preferred course of action by CA State Parks, it is certainly their option; especially if the CMC is not amended by the Carlsbad City Council. Second, Mr. Calarco admitted honestly that the Carlsbad Parks and Recreation Department had a lack of understanding about our recreation group (r/c flying) and all the new technology surrounding its expansive growth and educational value. Additionally, the Parks and Recreation Department did not realize that narrow strip of land known as "Dave's Beach" is an unsuitable location for the flying of electric powered r/c airplanes, especially by novice and even intermediate pilots. The uneven surface of the ground, numerous pedestrians, strong wind currents, and proximity of Pacific Coast Highway are all factors for deterring novice and intermediate pilots from flying at Dave's Beach. Numerous conversations with park employees resulted in the determination that the most practical locations for flying r/c airplanes in the city parks is within the baseball fields. The ball fields are frequently unoccupied by other park users and the high fences are an added safety margin. Both our club members and park employees are in agreement that due to the higher usage of the artificial turf soccer fields they should be prohibited from use by r/c enthusiasts. Our goal is to try and eliminate any complaints made to park employees and co-exist peacefully with other park users. We sincerely appreciate the effort being made by the Carlsbad Parks and Recreation Department to learn more about aeromodeling and its educational value to members of our community. Because of Mr. Calarco's research, the City of Carlsbad is now aware that the Academy of Model Aeronautics (AMA), offers $2,500,000 primary site owner's insurance for each flying site location. The AMA also offers $2,500,000 comprehensive general liability protection with its standard membership and $500,000 for members of the Park Pilot Program. The AMA (a non-profit organization), which represents the interests of more than 150,000 members nationwide and over 2,400 chartered clubs (many of which are located on city parks) works to indemnify and protect both the flying- site owner and its members. Additionally, Mr. Calarco has learned that the AMA has established a new category of remote control model aircraft which are electric powered, very quiet, weigh less than 2 pounds, and fly at airspeeds less than 60 mph. These "Park Flyer Models" have become widely available due to their low acquisition cost and are now being flown at parks, playgrounds, and backyards across the nation. The emergence and widespread availability of park flyer models is expanding the role of aeromodeling as an educational, safe, and enjoyable form of recreation across the nation. A testament of the educational role of aeromodeling is exemplified by the membership of the Carlsbad Electric Flyers whose roster includes an electrical engineer, corporate pilot, airline pilot, mechanical engineer, environemtal scientist, real estate investor, military personnel, etc. Many of our club members began aeromodeling as a youth and continued their passion throughout their professional careers. Others are now retired citizens wishing to enjoy their hard-earned free-time enjoying our hobby in our city parks. One common thread among all of us is the fact that we are all tax-paying citizens of the city of Carlsbad. As upstanding members of the community, we believe that use of our city parks for a safe and educational recreational activity is a fundamental civil liberty granted to us by the the County of San Diego, State of California, and the federal government of the United States of America. Review of the Carlsbad Parks and Recreation Department's mission statement by the Carlsbad Electric Flyers clearly demonstrates that the recreational activity of aeromodeling is both a consistent and mandatory component of its original stated intentions: "The Carlsbad Parks and Recreation Department is committed to building strong community through a broad range of high quality recreation and park services including lifelong learning, safe places to gather, and access to trails, parks, and open space for all who live, work and recreate in Carlsbad. " It is important to note that there have been no known injuries in any Carlsbad city parks due to the operation of r/c vehicles. Innumerable injuries from more "traditional" forms of recreation have, however, been reported and are well documented. ,27 Furthermore, according to the Facility Use Regulations of the Parks and Recreation Department (dated and revised 5/19/09), use of the athletic fields within the city of Carlsbad is based upon the following CLASSIFICATION OF APPLICANTS: "Each application will be reviewed by Parks and Recreation Staff and classified into a group depending on the type of organization and the intended use. The Parks and Recreation Department activities have first priority for the use of the facilities. The categories are listed in order or priority with category A first, category B second, etc. The City attempts to accommodate all groups; however, there is a limited number of facilities. Unfortunately, the demand exceeds the supply. For that reason, a priority classification system for use was established. A Carlsbad Parks and Recreation activities; Co-sponsored activities; other City departments Examples: Friends of the Library, Carlsbad Book Fair, Recreation and Lap Swim, Swim Lessons, MastersSwim Program B Carlsbad resident not-for-profit, civic, social organizations (non-paid management - no voting board member can be paid); any organization sponsoring a public forum or candidates night; public education Examples: Carlsbad Rotary, La Costa Youth Organization, Carlsbad Softball Association, Carlsbad Youth Baseball, Boy Scouts, Carlsbad Homeowner's Associations, Carlsbad Unified School District" As supporting and attached documents will demonstrate, Carlsbad Electric Flyers, which is a "Class B Group" has the potential to become a strong educational force in the community, schools, and parks for subject matter relating to aviation, engineering, electronics, aerodynamics, science and mathematics. For the reasons stated above, the Carlsbad Electric Flyers hereby requests a revision of the CMC 11.32.030 (31) to be rewritten in the following manner: "No person shall operate any r/c vehicle on any artificial turf field within any park. Recreational use of electric r/c model airplanes will be permitted on park baseball fields only if a scheduled league game or practice is not occurring; provided, however, they meet the Academy of Model Aeronautics (AMA) definition of a "Park Flyer Model." No person shall operate any r/c model airplanes within the park unless they are a member of the AMA Park Flyers Program and obey the AMA National Safety Code. Carlsbad Electric Flyers; AMA Chartered Club President: Gus Calderon Vice President: Charles DuShey Secretary: David Sindelar Treasurer: David Saenz Safety Coordinator: Irvin Stafford Public Relations: Maha Calderon