HomeMy WebLinkAboutPRE 2021-0001; RINCON HOMES; Admin Decision LetterFebruary 22, 2021
Patrick Kornman
444 S. Cedros Avenue,# 190
Solana Beach, CA 92075
SUBJECT: PRE 2021-0001 (DEV2021-0012)-RINCON HOMES
APN: 204-240-13-00/204-240-14-00
{'city of
Carlsbad
8FILE COPY
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Thank you for submitting a preliminary review to consolidate two parcels to create one approximately
0.57-acre lot to develop a three-story, multi-family residential project consisting of four buildings, totaling
sixteen for-sale condominium units, and a request for a density bonus located at 3570, 3588, and 3590
Garfield Street.
In response to your application, the Planning Division has prepared this comment letter. Please note that
the purpose of a preliminary review is to provide you with direction and comments on the overall concept
of your project. This preliminary review does not represent an in-depth analysis of your project. It is
intended to give you feedback on critical issues based upon the information provided in your submittal.
This review is based upon the plans. policies. and standards in effect as of the date of this review. Please
be aware that at the time of a formal application submittal, new plans. policies. and standards may be.
in effect and additional issues of concern may be raised through a more specific and detailed review.
Planning:
General
1. General Plan and zoning designations for the property are as follows:
a. General Plan: R-23 Residential, 15-23 units/ac. Growth Management Control Point (GMCP) of
19 units/ac.
b. Zoning: R-3, Multiple-Family Residential
c. The property is in the non-appealable area of the Coastal Zone. The Coastal land use
designation and zone are the same as the General Plan and Zoning above.
2. The project is subject to all applicable codes and policies. The project requires the following permits
and the Planning Commission will be the decision-making authority:
a. Tentative Tract Map (CT) -for the subdivision of sixteen air-space condominiums;
Community Development
Planning Division I 1635 Faraday Avenue Carlsbad, CA 92008-7314 I 760-602-4600 I 760-602-8560 f I www.carlsbadca.gov
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b. Planned Development (PUD) -for the development of a three-story, attached multi-family
condominiums; and
C.
l ,. \~: ~i·
Coastal Development Permit (CDP)-for the airspace condominium map and development of
t~E! three-story, attached multi-family airspace condominiums within the Coastal Zone. ,, ' ' ' :~ , ...
3. The Housing Crisis Act of 2019 (SB 330} established a preliminary streamline application process for
housing projects. It is not mandatory unless applicants seek the vesting and processing benefits
offered under SB 330. Participation in the SB 330 streamline process would occur first, followed by
the formal development application process required under Government Code (Gov. Code)§§ 65940,
65941, 65941.5, and Carlsbad Municipal Code (CMC) § 21.42.050. Acceptance by the city of a
complete SB 330 Streamline Application (Form P-32) and fee will vest the project for 180 days in
accordance with the ordinances, policies and standards in effect at the time the SB 330 Application is
accepted. The city is finalizing the application form and process for SB 330 Streamline Applications.
Please contact planning@carlsbadca.gov for more information.
4. Climate Action Plan (CAP). New requirements related to the city's goals to reduce greenhouse gas
(GHG) emissions will likely impact development requirements of this project. A formal application
submittal will need to include a completed CAP Checklist (Form P-30) to determine what requirements
will apply to the project. New GHG reduction requirements are related to energy efficiency,
photovoltaic, electric vehicle charging, water heating and traffic demand management requirements,
as set forth in the California Green Building Standards Code and in CMC Chapters 18.21, 18.30 and
18.51 which is available on the city's website at the following address:
http:l/www.qcode.us/codes/carlsbad/view.php?topic-18&frames-on
To the extent that new GHG reduction requirements are in effect at the time of application for grading
or building permits, the project will be required to comply with the effective requirements even if
different than what is proposed in the project's planning approvals. GHG reduction requirements may
impact, but are not limited to, site design and local building code requirements. If incorporating new
GHG reduction requirements results in substantial modifications to the project after planning
approvals are obtained, then prior to issuance of grading or building permits, the applicant may be
required to submit and receive approval of a Consistency Determination or an Amendment
application for the project through the Planning Division.
5. lnclusionary Housing.
a. The project proposal includes an incentive to purchase a housing credit to satisfy the
inclusionary housing requirement, which would be considered off-site or a combined
project. If inclusionary units are provided in an off-site combined project, the required
number of inclusionary units shall be fifteen percent of the total residential units to be
provided both on-site and/or off-site. In accordance with CMC Section 21.85.050,
Example 2, if the proposed 15 market-rate units are approved, then that total is divided
by .85 which provides the total residential unit count (15 + .85 = 17.6). The 15 percent
requirement is applied to the total unit count of 17.6 which equals the inclusionary unit
requirement of 2.6, or three units as fractional units are rounded up (17.6 x .15 = 2.6).
Therefore, as proposed, one very low-income unit would be provided onsite and two
housing credits would be purchased based on the project proposal. Please see comment
no. 7d for more details regarding the proposed incentive of purchasing housing credits.
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b. The project is subject to the affordable housing standards found in CMC Section
21.85.040. The standards include building inclusionary units onsite whenever reasonably
possible, construction of inclusionary units must be done concurrently with market-rate
units, and inclusionary ownership units with a density bonus shall remain affordable to
eligible income buyers pursuant to resale restrictions with a term of 55 years. Please refer
to the most updated code section found in Ordinance No. CS-368, which contains the ·
entire list of required standards. Ordinance No. CS-368 can be found here:
http://www.qcode.us/codes/carlsbad/revisions/CS-368.pdf
c. For a comprehensive list of provisions regarding inclusionary housing, please refer to CMC
chapter 21.85 for more information.
6. Density Bonus.
a. Please refer to the updated density bonus code amendment for a comprehensive list of
requirements, which can be found here:
http://www.qcode.us/codes/carlsbad/?view-desktop&topic-21
b. Application Requirements: Any application requesting a density bonus and any incentives,
waivers, or parking reductions shall submit a Density Bonus Report with the filing of the
formal planning application for the housing development in accordance with Section
21.86.040, found in the link provided in comment 6a. The Density Bonus Report shall
include the following information:
i. Summary table showing the maximum number of dwelling units permitted by the
zoning and General Plan excluding any density bonus units, proposed affordable
units by income level, proposed bonus percentage, number of density bonus
units proposed, total number of dwelling units proposed on the site, and resulting
density in units per acre.
ii. A tentative map and preliminary site plan, drawn to scale, showing the number
and location of all proposed units, designating the location of proposed
affordable units and density bonus units.
iii. The zoning and General Plan designation and assessor's parcel number(s) of the
housing development site.
iv. A description of all dwelling units existing on the site in the five-year period
preceding the date of submittal of the application and identification of any units
rented in the five-year period. If dwelling units on the site are currently rented,
income and household size of all residents of currently occupied units, if known.
If any dwelling units on the site were rented in the five-year period but are not
currently rented, the income and household size of residents occupying dwelling
units when the site contained the maximum number of dwelling units, if known.
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v. Description of any recorded covenant, ordinance, or law applicable to the site
that restricted rents to levels affordable to very low-income or lower income
households in the five-year preceding the date of submittal of the application.
vi. Please refer to the Density Bonus Supplemental Checklist, form P-l(H), to assist
in the preparation of the required materials and information for the Density
Bonus Report. This form can be found on the city website at:
https://www.carlsbadca.gov/civicax/fi1ebank/blobdload.aspx?Blob1D-46075
c. Calculation of Density Bonus Units: The calculation for density bonus is taken from the
maximum allowable gross residential density. For this project, the maximum allowed
density per the General Plan and zoning is 23 units per acre. With a .57-acre lot, 14 units
would be the maximum allowed for the site (.57 x 23 = 13.1, rounded up). Therefore, one
unit set aside for very low-income is seven percent of the maximum allowed of 14 units,
and results in 25 percent density bonus. The 25 percent is applied to the maximum density
allowed; or 14 units, and results in 3.5 density bonus units, rounded up to four units for a
total of 18 units allowed onsite. The project proposes 16 units, which is less than the
allowed maximum density per the density bonus law. The applicant may elect to accept a
lesser percentage of density bonus than the project is entitled to, but no reduction will
be permitted in the percentages of required affordable units contained in California
Government Code Section 65915, subdivisions (b), (c), and (f).
d. Incentives/Concessions: When an application proposes incentives or concession for a
housing development, the density bonus report shall include the following minimum
information for each incentive requested and shown on the site plan:
i. The required development standards and the requested development
standards/incentive.
ii. Reasonable documentation to show that the requested incentive will result in
identifiable and actual cost reductions to provide for affordable housing costs.
iii. Based on the site plan and project description, the proposed project would
receive one incentive/concession by restricting seven percent to very low-income
households.
iv. The project proposes an incentive to purchase housing credits for an off-site
combined inclusionary housing project. St_aff does not support the proposed
incentive and finds the purchase of housing credits to meet the inclusionary
housing requirement does not meet Government Code 65915 (k) and (I)
definition of a concession or incentive because it is not a request for a reduction
in site development standards; nor does the project include a request for
approval for mixed-use, and it is not a regulatory incentive or concession that
results in identifiable and actual cost reductions to provide for affordable housing
costs. Staff recommends if the purchasing of credits is proposed, to do so in
accordance with CMC Chapter 21.85 -lnclusionary Housing and City Council
Policy no. 57 and 58 which can be found online at:
https://www.carlsbadca.gov/cityhall/clerk/municipalcode/council.asp
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e. Waiver of Development Standards: When an application proposes waivers of
development standards, the density bonus report shall also include the following
minimum information for each waiver requested and shown on the site plan:
i. The required development standard and the requested development standard.
ii. Reasonable documentation that the development standards for which a waiver
is requested will have the effect of physically precluding the construction of the
project at the densities or with the concessions or incentives permitted.
iii. The project proposes five possible waivers of development standards which
includes no community recreational space, no guest parking, a reduced side yard
setback of 5 feet in lieu of 10 feet, a possible reduction for the rear yard setback,
and a possible increase in height. The proposed waivers pertaining to reduced
setbacks and no community recreational space would be considered if the
waivers do not create an adverse impact upon public health and safety or the
physical environment; however, compatibility with the adjacent uses such as
separation and building massing should be considered in the proposal of waivers
to development standards. Please see comment "f' below for more information
regarding staff's recommendation for the waivers for no guest parking and
height.
f. Density Bonus in Coastal Zone: In accordance with CMC Section 21.876.070 -Local
Coastal Program Consistency, state density bonus law provides that it shall not supersede
or in any way alter or lessen the effect or application of the California Coastal Act.
Development in the Coastal Zone that includes a request for a density bonus, incentive(s),
waiver(s), parking reductions shall be consistent with all applicable requirements of the
certified Carlsbad Local Coastal Program (LCP) with the exception to density. The project
site is located within the Mello II segment of the coastal zone. The policies within the
Mello II segment of the LCP pertain to limiting height for view preservation and providing
onsite guest parking for access to recreation within the coastal zone. The project site is
also located within the Beach Area Overlay Zone and is subject to the requirements in
CMC Chapter 21.82, which provides specific development standards that are consistent
with the policies of the LCP. The BAOZ limits building height to a maximum of 30 feet if a
3/12 roof is provided and 24 feet if less than a 3/12 roof is provided. Building height is
measured from existing grade or finished grade, whichever is lower. In addition, the BAOZ
requires 0.25 guest parking spaces for projects with 11 units or more. Staff does not
support a waiver for height exceeding the BAOZ height requirement, or the waiver to
provide zero onsite guest parking because it is inconsistent with the city's LCP.
g. Requested Parking Reduction: The Density Bonus Report must provide a table showing
the parking required by the zoning regulations, parking proposed under Section 65915,
subdivision (p}, and reasonable documentation that the project is eligible for the
requested parking reduction.
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h. Design and Quality: Affordable units shall be comparable in exterior appearance and
overall quality of construction to the market rate units in the same housing development.
Interior finishes and amenities may differ from those provided in the market rate units,
but neither the workmanship nor the products may be of substandard or inferior quality
as determined by the city. In addition, the number of bedrooms of the affordable units
shall at least be equal to the minimum number of bedrooms of the market rate units.
Please refer to CMC Section 21.86.100 (found in the updated density bonus ordinance
provided in the link above) for the comprehensive list of housing standards for density
bonus projects.
7. R-3/Planned Development. Attached multi-family residential dwelling units designed as airspace
condominiums require the approval of a Planned Development (PUD), pursuant to CMC Chapter
21.45, Planned Development Ordinance. Specifically, the proposed project shall comply with Table C
-General Development Standards and Table E -Condominium Projects. Please see comment no. 9
below for a Planned Development analysis. The site plan provided does not provide adequate detail
to complete a full analysis; however, the comments are provided as guidance in the design of the
project for a formal application submittal.
8. Planned Development Ordinance. Please be aware of the following requirements. The comments
provided below are not inclusive of all requirements per CMC Chapter 21.45, Planned Development
Ordinance. Please refer to CMC Chapter 21.45 for all requirements.
Table C -General Development Standards
a. Drive-aisles: The plans show the drive-aisle is designed to be used for vehicle back-
up/maneuvering and shall require a minimum 24-foot width. The plans meet this
requirement; however, additional width may be required for emergency vehicle
maneuvering. In addition, it is required that drive-aisles be enhanced with decorative paving.
Plans submitted for a formal review must identify areas of the required decorative paving.
b. Visitor Parking: Projects with 11 units or more require 0.25 space per unit and when
calculating the required number, if the calculation results in a fractional number, it is
required to round the number up to the nearest whole number .. The location of visitor
parking is subject to Table C, C.7 of CMC Chapter 21.45. Please refer to the referenced code
section for more details.
c. Community Recreational Space: Projects with 11 or more units must provide passive or
active recreation facilities per CMC Chapter 21.45, Table C, C.9. The plans submitted for the
preliminary review does not show any community recreational space; however, this required
development standard must be noted in the density bonus report as it is a waiver request.
d. Lighting: Lighting for adequate pedestrian and vehicular safety shall be provided. Plans
submitted for a formal review must identify the location of lighting provided onsite.
----------------.. ·-···
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Table E -Condominium Projects
a. Architectural Requirements: The project is required to comply with City Council Policy No.
44 -Neighborhood Architectural Design Guidelines and City Council Policy No. 66 -Livable
Neighborhoods pursuant to CMC Chapter 21.45 -Planned Developments. For detailed
information regarding the requirements, the policies may be found online at:
i. City Council Policy No. 44:
http://edocs.carlsbadca.gov/HPRMWebDrawer/RecordHTML/392081
ii. City Council Policy No. 66:
http://edocs.carlsbadca.gov/HPRMWebDrawer/RecordHTML/392162
b. Maximum Coverage: The project is subject to a maximum lot coverage of 60 percent of the
net developable acreage. Plans submitted with a formal application will require lot coverage
calculations.
c. Maximum Building Height: The project is located in the RH General Plan designation and
within the Beach Area Overlay Zone (BAOZ). Table E, E.4 -Maximum Building Height,
footnote 1 states that building height shall be subject to the requirements of CMC Chapter
21.82. Pursuant to CMC Section 21.82.050-Building Height, the structures shall not exceed
30 feet if a minimum 3/12 roof pitch is provided or 24 feet if less than a 3/12 roof pitch is
provided. The plans submitted with a formal application is required to provide a roof plan
with pitch details in order to analyze compliance with the height requirement.
d. Setbacks from Front and Drive-Aisle: A residential structure from a private or public street
must maintain a 10-foot setback. The plans provided for the preliminary review show a lD-
foot setback which meets this requirement. Please note, there are setback requirements
taken from a drive-aisle for different parts of the structure. See Table E, E.5 for more
information.
e. Interior Side and Rear Setbacks: The building setback from an interior side and rear perimeter
property line shall be the same as the underlying zone for the interior side and rear yard
·setback.As such, the underlying zone is R-3 and requires a side yard setback that is at least
10 percent of the width of the lot, not less than five feet and not to exceed 10 feet. The
minimum required rear yard setback is 20 feet.
f. Parking: Units with two or more bedrooms require two spaces per unit. As designed,the
project provides for an enclosed two-car garage per unit and meets this requirement. Each
garage must have interior dimensions of a minimum 20 feet wide by 20 feet in depth.
Required parking spaces shall be located no more than 150 feet as measured in a logical
walking path from the entrance of the units.
g. Private Recreational Space: Multiple-family dwellings require a minimum total area of 60
square feet either in a patio, porch or balcony configuration. The minimum depth of the
private recreational space must be six feet. In addition, projects with 11 or more units that
are within the RH General Plan designation such as this project, may opt to provide an
additional 75 square feet of community recreation space per unit, subject to the standards
in Table C of CMC Chapter 21.45 -Planned Developments, in lieu of providing the per unit
private recreational space.
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9. Landscaping. Prior to a formal submittal, conceptual landscape exhibits shall be prepared in
accordance with the General Requirements listed in Section 3 of the City of Carlsbad Landscape
Manual (February 2016). The Landscape Manual may be obtained at the Planning Division front
counter or found online at:
htto://www.carlsbadca.gov/civicax/fi1ebank/blobdload.aspx?Blob1D=24086
10. Biological Resources Assessment. A formal submittal of this project will need to include· a biological
resources technical report prepared by a registered biologist in accordance with the specific
requirements of CMC Chapter 21.210, the Habitat Management Plan for Natural Communities in the
City of Carlsbad (a.k.a. the Habitat Management Plan (HMP)), and the Mello II Segment of the LCP.
For guidelines on the required contents of the biology letter, please reference the "Guidelines for
Biological Studies", which can be obtained at the Planning Division's front counter or referenced
online at:
http://www.carlsbadca.gov/civicax/filebank/blobdload.asox?Blob1D=24331
11. Cultural Resources Assessment. The project is located in an area of known of high sensitivity for
paleontology, archaeological, and architectural historical resources. Please submit a cultural
resources assessment prepared by a qualified professional. The study shall comply with the city's
Tribal, Cultural and Paleontological Resources Guidelines. Please be advised the Guidelines require a
Luise no Native American monitor present fo'r any field survey or work conducted by an archaeologist.
Please see link below for additional information.
httos://www.carlsbadca.gov/civicax/fi1ebank/blobdload.aspx?Blob1D=34010
12. Noise Analysis. The project is requi'red to submit a noise study consistent with the City of Carlsbad
Noise Guidelines Manual to identify the need for any noise attenuation of the building. The guidelines
can be referenced on line at:
htto://www.carlsbadca.gov/civicax/fi1ebank/blobdload.asox?Blob1D=24094
13. Stakeholder Outreach. The project is subject to City Council Policy No. 84, Development Project Public
Involvement. A notice sign is required to be posted onsite by the applicant and an early public notice
is required to be prepared by the applicant and mailed to all owners within a 600-foot radius of the
property. In addition, enhanced stakeholder outreach and a follow-up summary report are required.
The policy and guidelines can be found online at:
City Council Policy No. 84:
https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?Blob1D=35578
Guidelines for Project Public Involvement:
httos://www.carlsbadca.gov/civicax/filebank/blobdload.asox?Blob1D=24117
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Applicant Questions followed by Staff Responses:
1. Fire Department requirements regarding turn-around, 150-foot maximum backup, 150-foot hose pull,
etc.
Staff Response: Please see Fire Department comment provided below under the Fire section. For
more information, please contact Randy Metz, Fire Marshal. His contact information is provided
at the end of this letter.
2. Please comment on request to use an incentive to pay for one housing credit.
Staff Response: Please refer to Planning comments no. 7d.
3. Please comment on waivers of development requested.
Staff Response: Please refer to Pla.nning comments no. 7e and 7f.
4. Does the city agree with the proposed density bonus calculation?
Staff Response: Please refer to Planning comment no. 7c.
5. Is a Phase 1 Environmental Assessment part of the application?
Staff Response: A Phase 1 Environment Assessment is not required for this project at application
submittal.
6. Would this property qualify for an Infill Exemption as it relates to an EIR?
Staff Response: California Environmental Quality Act (CEQA) requirements are undetermined at
the preliminary review stage. A CEQA determination will be completed after a complete analysis
of a formally submitted application.
7. Will a biological survey be required for this project?
Staff Response: See Planning comment no. 11.
8. Will a historical study be required for this project?
Staff Response: See Planning comment no. 12 for more information.
9. Will o traffic study be required for this project?
Staff Response: See Land Development Engineering's comment no. 21 for more information.
All necessary application forms, submittal requirements, and fee information are available at the Planning
counter located in the Faraday Building at 1635 Faraday Avenue or online at
http://www.carlsbadca.gov/services/depts/planning/default.asp. You may also access the General Plan
Land Use Element and the Zoning Ordinance online at the website address shown; select Department
Listing; select Planning Home Page. Please review all information carefully before submitting.
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Land Development Engineering:
1. Process a tentative subdivision map to create 16 airspace condominium units.
2. Complete a Storm Water Standards Questionnaire Form E-34 to determine storm water quality
requirements for this project. The questionnaire is available in the City website at:
http://www.ca rlsbadca .gov/ services/de pts/la ndev / e ngi neeri ng.asp
3. Based on the preliminary plans, it appears the project qualifies as a Priority Development Project
{PDP) and will be required to submit a preliminary Storm Water Quality Management Plan {SWQMP)
with any discretionary application. The SWQMP shall be prepared in accordance with the City of
Carlsbad BMP Manual (latest version). Use the City of Carlsbad SWQMP template for priority
development project (Form E-35) available in the City website. The project SWQMP will determine
the pollutant control BMP requirements. Note that this project is subject to hydromodification
standards.
4. A preliminary hydrology study will be required to determine the pre-development and post-
development discharge flows. Provide preliminary recommendations on the proposed storm drain
system to serve this project and to mitigate any increase in flows.
5. Provide a preliminary Geotechnical study that identifies feasibility and recommendations for the
proposed development including design recommendations proposed pollutant control BMPs and
hydromodification facilities ..
6. A recent Preliminary Title Report (PTR) will be required with formal project application submittal.
7. All easements and encumbrances identified in the PTR must be indicated on the site plan.
8. Show complete property boundary data on the site plan, including bearings, distances, and curve data.
9. Provide typical street cross section of Garfield Street showing existing improvements (pavement,
curb, gutter, sidewalk, centerline, street lights, fire hydrants, water, sewer, etc.).
10. On the site plan, show and identify all existing surface improvements (curb, gutter, sidewalk, paving,
manholes, inlets, street lights, adjacent driveways, vaults, transformers, etc.) and all existing utilities
(including water main, water services, water meters, sewer main, sewer laterals, storm drain pipes,
etc. and their appurtenances) along Garfield Street. Reference city approved improvement plan
drawing numbers of the existing utilities for references.
11. Show the location of the proposed water service, water meter with backflow preventer and fire
service with double detector check valve assembly. A single master water meter and backflow will
serve the project. Plot individual water services from the backflow to each unit on the tentative map.
12. Show the location of the proposed sewer lateral to serve the project. Show the invert elevations to
indicate gravity flow.
13. Show lo'cation of the.electrical transformer that will serve the project outside of the public Right-of-
Way.
14. Plot the corner sight distance at the driveway entrance on Garfield Street per CalTrans standards.
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15. Provide a preliminary grading plan to clearly show difference between proposed and existing grading,
walls, drainage, storm drain, BM P's etc. for the project.
16. Show existing buildings and improvements for the adjacent lots.
17. Provide multiple cross-sections of the site to demonstrate differences in grade, including adjacent
properties, buildings, walls and adjacent streets.
18. Meet with the Fire Department to identify the necessary fire protection measures required for this
project (access, fire hydrants, sprinkler system, on-site circulation, emergency access, etc.)
19. The minimum driveway width for a multi-family residential development is 24 feet.
20. Plot location and dimensions of all accessways and pathways as required for compliance with Title 24
-State Accessibility Requirements.
21. Provide discussions summarizing the applicability of relevant screening criteria to this project as
required by Section 3.2 of the (VMT) Guidelines. Include discussion of the project's trip generation,
average daily traffic (ADT) calculations and how it applies to the VMT screening criteria (see section
3.2.1).
22. Please be advised that in order to make a more in-depth review of the proposed development, a more
complete design of the project is required.
Building Division:
1. CBC Chapter 11A Accessibility provision must be considered in the project design.
1. Fire access is acceptable. NFPA 13R fire sprinkler system is required. Entire driveway will need to be
established as a fire lane with proper signage and striping. Fire land plan shall be submitted to the Fire
Department for review and approval prior to issuance of building permit.
If you would like to schedule a meeting to discuss this letter with the commenting departments, please
contact Jessica Evans at the number below. You may also contact each department individually as follows:
• Planning Division: Jessica Evans, Associate Planner, at (760) 602-4631
• Land Development Engineering: Allison McLaughlin, Associate Engineer, at (760) 602-2732
• Fire Department: Randy Metz, Fire Marshal, at (760) 602-4661
• Building Division: Jason Pasuit, Building and Code Enforcement Manager, at (760) 602-2788
DON NEU, AICP
City Planner
DN:JE:cf
c: Tom St. Clair, 5315 Avenida Encinas #200, Carlsbad, CA 92008
Allison McLaughlin, Project Engineer
Fire Prevention
HPRM/File Copy/Data Entry