HomeMy WebLinkAbout2021-10-21; SANDAG 2021 Regional Transportation Plan Draft EIR Comment Letter (Districts -All); Barberio, GaryTo the members of the:
CITY COUNCIL
Date tiCA /cc ./
CM _LACM /ocM (3) L
Council Memorandum
Oct. 21, 2021
To:
From:
Via:
Honorable Mayor Hall and Members of the City Council
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Jeff Murphy, Community Development Director
Tom Frank, Transportation Director/C~gineer
{city of
Carlsbad
Memo ID#·2021195
Re:
Geoff Patnoe, Assistant City Manager~
SAN DAG 2021 Regional Transportation Plan Draft EIR Comment Letter (Districts -All)
This memorandum provides an update to a previous Council Memorandum dated Aug. 12, 2021
(Attachment A), with information on staff's recent comment letter (Attachment B) on the San
Diego Association of Governments (SAN DAG) draft Environmental Impact Report (EIR) proposed
for the 2021 Regional Transportation Plan (RTP), a long-term blueprint of the region's
transportation system.
Background
RTPs are long-range planning documents (usually 30 years) that define how regions will make
future transportation investments, based on regional goals and estimates of available funding.
Federal regulations require that long-range RTPs be updated every four years.
Beginning in 2016, SAN DAG began the process of updating its RTP for the San Diego region.
During development of this draft RTP, an interim plan was adopted in 2019 to comply with
federal requirements but did not make substantial revisions to the previously adopted plan. This
new RTP, once adopted, will become the region's long-term plan to be implemented
incrementally through the Regional Transportation Improvement Program (RTIP).
Federal transportation legislation requires that regionwide transportation planning be
coordinated with local agencies and other stakeholders. It also implements requirements for
SAN DAG under Senate Bill 375 to reduce greenhouse gas targets adopted by the California Air
Resources Board. An informational website, which includes the draft RTP and draft EIR, is
available at https://sdforward.com/.
Discussion
The draft 2021 RTP was the result of years of planning, data analysis and community engagement
where SAN DAG reimagined a more transformative transportation system, a sustainable pattern
of growth and development, and innovative demand and management strategies (referred to as
"5 big moves"). The draft 2021 RTP was circulated for public review and comment from
Community Services and Public Works Branches
Community Development and Transportation Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-4600 t
Council Memo -SAN DAG 2021 RTP Draft EIR Comment Letter {Districts -All)
Oct. 21, 2021
Page 2
May 28, 202}, to Aug. 6, 2021. The city provided comments to SAN DAG on Aug. 6, 2021, which
were provided to City Council in a Council Memorandum dated Aug. 12, 2021 {Attachment A).
On Aug. 27, 2021, SAN DAG released the draft EIR for the 2021 RTP for a 45-day public review
period. The draft EIR failed to address the issues raised in the city's Aug. 6, 2021 letter. In
response, the city provided a comment letter on Oct. 11, 2021 {Attachment B), that highlights all
of the same points as the previous letter, with the following additional comments/concerns:
1) Procedures related to CEQA, and the timeline that hinders public input since the
comments on the draft RTP were not responded to or incorporated into the draft EIR;
2) Evaluation of impacts to existing Land Use Plans, and the lack of a reasonable range of
alternatives that show what would occur if funding or land use assumptions are not
made; and,
3) Lack of sufficient detail in the chapters related to transportation, hazards, noise or other
planned growth in the draft EIR.
Next Steps
According to the latest correspondence with SAN DAG, the SAN DAG Board of Directors will be
asked to adopt the RTP on Dec. 10, 2021. City staff will continue to review all project-related
materials and recommend changes at each milestone as necessary to ensure that regional goals,
policies and priorities are fiscally responsible, safety-conscious, sustainable, context-sensitive and
collaborative.
Attachments: A. Council Memorandum dated Aug. 12, 2021
B. City of Carlsbad letter dated Oct. 11, 2021
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Laura Rocha, Deputy City Manager, Administrative Services
Robby Contreras, Assistant City Attorney
Ron Kemp, Assistant City Attorney
Mike Strong, Assistant Director of Community Development
Nathan Schmidt, Transportation Planning & Mobility Manager
Don Neu, City Planner
Eric Lardy, Principal Planner
To the members of the:
'!if-IT;( COUNCIL
Date~CA X, CC .:k...
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Council Memorandum
Aug.12,2021
To:
From:
Via:
Honorable Mayor Hall and Mem of the City Council
Gary Barberio, Deputy City Ma ager, ommunity Services Branch
Paz Gomez, Deputy City Manag , Pu lie Works Branch
Jeff Murphy, Community Develop
Torn Frank, Transportation Directo /Cu+-.,....,.1!,,1.!,!
Geoff Patnoe, Assistant City Mana er
Attachment A
{cityof
Carlsbad
Memo ID #2021154
Re: Draft SAN DAG 2021 Regional Trans rtation Plan Comment Letter (Districts -All)
This memorandum provides information on staff's recent comment letter (Attachment A) on the
San Diego Association of Governments (SAN DAG) proposed 2021 Regional Transportation Plan
{RTP), a long-term blueprint of the region's transportation system.
Background
RTPs are long-range planning documents (usually 30 years) that define how regions will make
future transportation investments, based on regional goals and estimates of available funding.
Federal regulations require that long-range RTPs be updated every four years. Beginning in 2016,
SAN DAG began the process of updating its RTP for the San Diego region. During development of
this draft RTP, an interim plan was adopted in 2019 to comply with federal requirements but did
not make substantial revisions to the previously adopted plan. The new RTP plan, once adopted,
will become the region's long-term plan to be implemented incrementally through the Regional
Transportation Improvement Program (RTIP).
Federal transportation legislation requires that regionwide transportation planning be
coordinated with local agencies and other stakeholders. To that end, the draft 2021 RTP was
circulated for public review and comment from May 28, 2021 to Aug. 6, 2021. Comments that
were received during the public review period will be reviewed and incorporated, as appropriate,
into the environmental analysis and/or final RTP.
Discussion
The draft 2021 RTP was the result of years of planning, data analysis and community engagement
where SAN DAG reimagined a more transformative transportation system, a sustainable pattern
of growth and development, and innovative demand and management strategies, referred to as
"5 big moves". The draft 2021 RTP also implements requirements for SANDAG under Senate Bill
375 to reduce greenhouse gas targets adopted by the California Air Resources Board. An
informational website, which includes the draft 2021 RTP plan, is available at
https:ljsdforward.com/.
Community Services and Public Works Branches
Community Development and Transportation Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-4600 t
Council Memo -Draft SAN DAG 2021 RTP Comment Letter (Districts -All)
Aug. 12,2021
Page 2
To facilitate interagency consultation, city staff from the Community Development and
Transportation Departments reviewed available project materials and transmitted comments in a
letter on Aug. 6, 2021 (Attachment A). Below is a summary of the major issues/concerns and
recommendations provided in staff's Aug. 6, 2021, comment letter:
1) The draft 2021 RTP inventories and assesses existing and future conditions in each city.
However, despite previously providing information to SAN DAG staff, the assumptions
they used in the draft 2021 RTP for "existing" and "planned" land use and transportation
in the City of Carlsbad are not consistent with our adopted land use and transportation
policies (e.g., forecasted housing and roadway capacities). For example:
• SAN DAG projects over 700 new residential units will be constructed adjacent to
the McClellan-Palomar Airport Runway (residential use is not currently planned in
this area under the city's General Plan nor allowed by the Federal Aviation
Administration)
• Roughly 2,800 units are assumed to be developed on existing lands that are either
currently developed as hotel resorts or are dedicated open space
• SAN DAG assumes a declining population of roughly 2,300 persons in areas outside
of the city's local mobility hubs (most of the city) due to children who have grown
up and left their parents' homes. This assumption is being applied regionwide,
where they assume a reduction of approximately 85,000 persons throughout San
Diego
2) The land use assumptions, many of which are not substantially supported with facts, are
used to justify reduction targets in greenhouse gas emissions and vehicle miles travelled.
If their assumptions do not occur on the macro or micro level, which staff finds that it is
very likely that they will not be achieved, the draft 2021 RTP will adversely impact any
. public and private projects that are required to use the regional transportation models for
California Environmental Quality Act (CEQA) purposes (e.g., future General Plan
amendments, private development projects). Existing land use and transportation plans
and studies should serve as the starting point to best understand how new goals, policies
and priorities may target transportation investments and best increase real choices in
travel modes. It should be clear how the draft 2021 RTP expects these changes to occur,
instead of modeling a scenario constructed in order to meet reduction goals.
3) Since the transportation system provides access and mobility to the traveling public and
land uses impose demands on the system, the draft 2021 RTP should address ifthere are
changes in ridership behavior which may have occurred because of the COVID-19
pandemic.
4) The draft 2021 RTP needs to more extensively address the disruption that is expected
from automated/shared vehicle technologies and conduct an alternatives analysis. For
example, autonomous vehicles are expected to have a huge impact on mobility demands
Council Memo -Draft SAN DAG 2021 RTP Comment Letter (Districts -All)
Aug. 12,2021
Page 3
in the future, but the draft 2021 RTP does not provide enough analysis on how it will
impact future transportation needs.
5) Emphasis is being placed on regional rail improvements for a high-speed rail system,
including improvements to the LOSSAN Rail Corridor. More information 1s needed on the
anticipated alignment, segments and cost estimates. The portion of the corridor in the
City of Carlsbad will likely need to 'be a special study area.
6) The appendix in the draft 2021 RTP only lists potential projects; it does not show
potential alignments, right of way needed or coordination with specific agencies. More
information needs to be provided in the draft 2021 RTP on project implementation
phasing (both short-range and long-range improvements), unfunded projects and various
funding mechanisms that can bridge the unfunded gaps.
7) The draft 2021 RTP was released without the benefit of availability of the Draft
Environmental Impact Report (Draft EIR), which staff were told would be released later
this summer. The quick release of the Draft EIR following the due date of comments for
the draft 2021 RTP makes it practically impossible to make changes to the Draft EIR
before it is released. SAN DAG should clarify how these comments will be addressed in the
Draft EIR required topic areas of CEQA.
Next Steps
SAN DAG reports that the Draft EIR will be released in summer 2021. According to the work
program schedule, the SANDAG Board of Directors will be asked to adopt the draft RTP in late
2021. City staff will continue to review all project-related materials and recommend changes at
each milestone as necessary to ensure that regional goals, policies and priorities are fiscally
responsible, safety-conscious, sustainable, context-sensitive and collaborative.
Attachment: A. City of Carlsbad letter dated Aug. 6, 2021
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Laura Rocha, Deputy City Manager, Administrative Services
Robby Contreras, Assistant City Attorney
Ron Kemp, Assistant City Attorney
Mike Strong, Assistant Director of Community Development
Nathan Schmidt, Transportation Planning & Mobility Manager
Don Neu, City Planner
Eric Lardy, Principal Planner
Oct. 11, 2021
SANAG Regional Plan EIR
San Diego Association of Governments
401 B Street, Suite 800
San Diego CA 92101
C/O Kirsten Uchitel, Associate Planner.
Via: _RegionalPlanEIR@sandag.org
Attachment B
(city of
Carlsbad
RE: City of Carlsbad Comments on Draft Environmental Impact Report for the 2021 Regional Plan
Dear Ms. Uchitel:
The City of Carlsbad ("city") appreciates the opportunity to provide comments on the draft Program
Environmental Impact Report ("PEIR") for the 2021 Regional Plan ("Plan"), dated Aug. 27, 2021. This is
an important plan for the region and will guide the next phase of growth for the member agencies of the
San Diego Association of Governments ("SAN DAG"), including the city. An effectively designed and
implemented regional transportation plan would help ensure improved transportation options for area
residents, businesses and other community members, as well as meaningful reductions in greenhouse
gas ("GHG") emissions and improved quality of life as we grow our communities.
The city previously submitted comments on the Plan to SAN DAG staff on August 6, 2021 (Attachment 1),
expressing multiple concerns about the Plan, its implementation and its potential impacts on the
environment. Additionally, the city sent a follow up letter on September 30, 2021 (Attachment 2), to
clarify the city does not wish to remove El Camino Real (project CB32) from the Regional Arterials
Project List. Copies of the citys prior letters are included here as Attachment 1 and Attachment 2,
respectively. Both letters are incorporated herein by this reference as additional comments on the
adequacy of the PEIR and should be included in the administrative record of SANDAG's proceedings
concerning the Plan and the PEIR.
The California Environmental Quality Act ("CEQA") is intended "to afford the fullest possible protection
to the environment within the reasonable scope of the statutory language." (Friends of Mammoth v.
Board of Supervisors (1972) 8 Cal.App.3d 247, 259.) With narrow exceptions, CEQA requires an EIR
whenever a public agency proposes to approve or to carry out a project or activity that may have a
significant effect on the environment. (CEQA Guidelines§ 15002(f).) The basic purpose of an EIR is to
provide public agencies and the public in general with detailed information about the effect that a
proposed project or activity is likely to have on the environment and to identify ways in which the
significant effects might be reduced or avoided. (Public Resources Code § 21061; CEQA Guidelines §
15003.) The EIR and its associated process create layers of accountability and must "reflect a good faith
effort at full disclosure.'1 (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal. App. 3d 692, 712,
citing CEQA Guidelines§ 15151.) The EIR process must provide meaningful information for an
environmental assessment so that the public will know the basis on which decisions are made on a
proposed project or activity and can respond accordingly to action with which it disagrees.
Transportation & Community Development Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2710 t
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 2
In this case, the city seeks to ensure that SAN DAG prepares an environmental document that is
adequate, complete and fully discloses the potential significant adverse effects of the Plan. Further, to
implement the principles of CEQA, SAN DAG should not truncate the requisite cumulative impact analysis
(CEQA Guidelines section 15168(b}(2)), use improper baselines {CEQA Guidelines section 15152), or
foreclose the consideration of any alternative or mitigation measure that would ordinarily be part of
CEQA review of a regional plan (CEQA Guidelines section 15004(b)(2}(B)). If the EIR fails to provide
decision-makers and the public with all of the relevant information regarding a project that is necessary
for informed decision-making and public participation, the environmental document is flawed and
deficient and the agency's decision will be set aside (Kings County Farm Bureau v. City of Hanford, supra,
221 Cal. App. 3d at p. 712).
CEQA prescribes review procedures a public agency must follow before approving or carrying out
proposed projects. Those procedures emphasize the importance of public participation in the CEQA
· process, including mandatory opportunities for public review and comment and the lead agency's
obligation to provide meaningful responses to comments received. A Notice of Preparation (NOP) was
issued on November 14, 2016 and a public scoping meeting was held on December 8, 2016. Although
the early consultation with affected agencies and organizations was appreciated, and a necessary
procedural step per CEQA Guidelines section 15082, SAN DAG subsequently made a material change in
the scope of the project to encompass the vision of 5 Big Moves, without providing an opportunity for
additional scoping and consultation with the public and affected agencies. SAN DAG failed to re-engage
the public and affected agencies to provide them with sufficient information regarding the revised Plan
and its potential enviro_nmental effects to enable them to make a meaningful response about the scope
and content of the anticipated environmental work. Due to this procedural error, the public and
affected agencies have been denied the opportunity to provide SAN DAG with specific detail about the
significant environmental issues and reasonable alternatives and mitigation measures that needed to be
explored in the draft PEIR, early enough in the CEQA process for SAN DAG to have considered their
comments in preparing the draft PEIR. In addition, SAN DAG failed to comply with CEQA by conducting
the scoping and public review process for the Plan and the draft PEIR separately, which has resulted in a
disconnected, piecemeal and rushed process in which previous comments on the Plan were not
responded to or incorporated into the draft PEIR.
The disjointed and rushed process for public participation continues to the present. According to
SAN DAG staff, responses to comments on the Plan will be published at the end of October, several
weeks after public and agency comments are due on the draft PEIR. Thus, the public and affected
agencies like the city must submit comments on the PEIR without knowing whether or how SANDAG has
responded to previous comments on the Plan. SAN DAG has already indicated that the SAN DAG Board
will review and consider the Plan and the Final PEIR in December 2021. Thus, there appears to be
insufficient time for SAN DAG to evaluate comments received on the draft PEIR, prepare meaningful
responses and make those responses available as required by CEQA Guidelines sections 15087 and
15088. As such, SAN DAG is foreclosing on a "meaningful public participation process" and subjecting
itself to a claim that SAN DAG is prejudicing the outcome of the environmental review process by
ensuring there is little opportunity for public comments to influence the Plan's program and design.
("Environmental review derives its vitality from public participation" (Ocean View Estates Homeowners
Assn. V. Montecito Water Dist. (2004) 116 Cal. App. 4th 396, 400.) If the issues that were addressed in
the city's August 6, 2021 comment letter on the Plan (Attachment 1) are not addressed in the PEIR, the
PEIR will be insufficient as an informative document and it will reduce the validity and efficacy o.fthe
Plan, including its use of faulty assumptions regarding land use and population growth to comply with
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 3
state and federal mandates, such as the Sustainable Communities Strategy and greenhouse gas
reduction targets. These faulty assumptions misrepresent the vital land use-transportation planning
connections and do nothing to reduce greenhouse gasses and will instead result in unplanned increases
to traffic, greenhouse gases, and result in increased housing unaffordability.
While the city supports the main concepts of the Vision in the Regional Plan, the 5 Big Moves, there
needs to be an adequate analysis on how the Plan will be implemented, and what will occur if there are
changes to the projected growth, technology, and/or state law imp9cting existing conditions. The city's
residents, businesses, and property owners would have benefited from more time to read the details in
the Plan and draft EIR. After years of public outreach that lacked detail of the assumptions and projects
proposed in the Plan, the Plan is riow being rushed to decision by the SAN DAG Board of Directors by the
end of 2021. This is a procedural error and not adequate for the purposes of CEQA.
The city also restates its prior request that the following language be added to the Regional Plan for
additional clarification on land use authority: "Land use authority is reserved to local jurisdictions
because they are best positioned to effectively implement the objectives outlined in the Plan through
understanding of the unique needs of their communities and geographies." This language is needed to
clarify that land use authority rests with the local jurisdiction. Although this principle should be obvious,
the inconsistencies between the Plan and the city's General Plan discussed below suggest that it has
been ignored. Further the draft EIR should identify how the Program EIR will be utilized for streamlining
with later activities and/or for use with subsequent El Rs and negative declarations in compliance with
CEQA Guidelines section 15168{c) and (d).
In addition, the city has the following substantive comments on the adequacy of the PEIR:
1. The PEIR fails to disclose the Plan's inconsistencies with the Carlsbad General Plan and to analyze
the related potential environmental impacts. The Legislature has declared a policy "to protect
California's land resource, to ensure its preservation and use in ways which are economically and
socially desirable in an attempt to improve the quality of life in California." {Gov. Code§ 65030.) To
further this policy, each of the state's cities and counties is required to adopt a comprehensive, long-
term general plan for the physical development of that city or county. (Gov. Code§ 65300.)
Accordingly, the city adopted a General Plan in compliance with state law and most recently
updated it in 2015. the city's General Plan "sets forth land use compatibility policies applicable to
future development in the vicinity." These policies are designed to ensure that future land uses in
the surrounding area will be compatible with the realistically foreseeable activity in the city.
Growth projections for the region are based on population, vehicle trends and land use plans
developed by the cities and the County of San Diego ("County") as part of their general plans. Many
different regional documents rely on the same information to develop water demand projections,
air quality performance standards, emission inventories, and emission reductions. The Plan would
result in an increase in residential land use resulting in corresponding increases in indirect and
cumulative vehicle miles traveled ("VMT"), GHG emissions and air pollutant emissions, as well as
inconsistencies with RAQS, SIP, and regional traffic modeling. This is not disclosed in the draft PEIR.
CEQA Guidelines section 15125(a) requires El Rs to contain a description of the physical
. environmental conditions in the vicinity of the project, as they exist at the time the NOP is
published, or if no NOP is published, at the time environmental analysis is commenced, from both a
local and regional perspective. Existing general plans, including their Land Use Elements, should
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page4
have been utilized for this baseline analysis and to derive future population and housing estimates.
The draft PEIR is legally inadequate because it fails to plainly identify the specific assumptions
included in its baseline for land use. (San Joaquin Rescue Center v. County of Merced {2007) 149 Cal.
App. 4th 645.)
In the draft PEIR, SANDAG should have evaluated and clearly articulated the Plan's potential impacts
on land use. Instead, the PEIR states that: "The forecasted development of the proposed Plan is
based on the Series 14 Regional Growth Forecast SCS land use pattern, which is, in turn, based on
the adopted general plans of the cities and County of San Diego and on the most recent planning
assumptions, considering local general plans and other factors, as required by SB 375." This
statement is incorrect. The Plan is inconsistent with .the city's General Plan because it proposes
residential land uses where such uses are not authorized by the General Plan. The PEIR appears to
ignore this inconsistency in concluding there will be less than significant impacts for the years 2025,
2035 or 2050.
The city has two mobility hubs in the proposed Plan and draft PEIR: McClellan-Palomar Airport, the
fifth largest employment center in the region; and Carlsbad State Beach and Carlsbad Village as "Tier
3 and Tier 4" employment centers. Attachment.1 shows a summary of the Mobility Hubs and
housing units assumed in the Series 14 Growth Forecast for the year 2050. The assumptions in the
updated Series 14 Growth Forecast contain inconsistencies with respect to at least three locations in
which density is shown to be inconsistent with the city's General Plan, the Airport Land Use
Compatibility Plan and good planning principles. These three problematic areas are:
a. 736 units on parcels immediately adjacent to the McClellan-Palomar Airport runway. The
location of the airport within this mobility hub was shared with SAN DAG staff multiple times
at workshops. This is inconsistent with the regulations provided by the San Diego County
Regional Airport Authority and conflicts with standard planning principles for siting housing
away from hazards;
b. 2,755 units on existing developed resort properties and open space dedicated lands
adjacent to Lego land; and
c. 65 units in a preserved open space area.
The Plan proposes residential uses in areas which are not designated for such uses in the city's
General Plan. This inconsistency results iri potential significant impacts with respect to land use,
public safety and noise. {See CEQA Guidelines, Appendix G, §§ IX{e), Xl{b), Xlll(c).) Because
residential use is not authorized in those locations in the city's General Plan, the Plan's assumption
that residential use will occur there results in an overstatement of the extent to which other
impacts, such as those associated with VMT, GHG and other pollutant emissions, will be reduced
and understates those potential impacts of the Plan. The only meaningful evaluation of the Plan's
potential impacts is a brief qualitative description of the City of San Diego's community plan process.
However, the PEIR does not meaningfully address the inconsistency with the general plans of the
other 17 member jurisdictions, which if not implementing this plan will cause a significant
environmental impact due to the conflic:t with any land use plan, policy or regulation adopted for
the purpose of avoiding or mitigating an environmental effect.
As noted above, the Land Use, Hazards and Noise sections of the draft PEIR must include an
evaluation of the inconsistencies with local land use plans. Multiple areas in Carlsbad are controlled
as to their use and activity density and intensity through their spatial association with the McClellan-
Palomar Airport. The McClellan-Palomar Airport is defined by the Federal Aviation Administration
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 5
("FAA") as a commercial service airport that, in addition to private aircraft, has regularly scheduled
commercial flights. The McClellan-Palomar Airport Land Use Compatibility Plan ("ALUCP") is
prepared according to FAA requirements and adopted by the San Diego County Regional Airport
Authority acting as the Airport Land Use Commission for the County of San Diego. Further detail on
this is included in the city's August 6, 2021 comment letter (Attachment 1).
2. Additionally, looking at data provided by SAN DAG, it is now clear why the citywide numbers only
show moderate increases in population. Our analysis has shown that there is an assumed reduction
of population by 2,310 persons in the areas within the city but outside of the mobility hubs. This is
likely due to assumed reductions in persons per household over time, but SAN DAG should clarify the
source and reasonableness of this assumption. If housing is provided outside the Mobility Hubs
consistent with these areas, is it still reasonable to assume persons per household will be reduced in
2050? The PEIR also fails to consider the effect of Senate Bill 9 ("SB 9"), which will allow duplex or
quadplex development in any area previously zoned for single family use. As a result of the new law,
housing growth would be expected to increase in single-family residential areas. By failing to take
into account the effect on population growth of developing additional housing outside the Mobility
Hubs, the PEIR results once again in an understatement of the Plan's potential impacts and an
overstatement of the Plan's beneficial effects on VMT, GHG and other pollutant emissions.
Furthermore, this reduction in population is not limited to the city of Carlsbad. There is an
approximately 85,000 person reduction in population assumed outside of mobility hubs regionwide.
SAN DAG nee.ds to address if that is a reasonable assumption and if this will result in other impacts to
public and private projects that will rely on this growth forecast, and the associated Activity Based
Model (2+) to project future impacts to transportation, GHG, air quality and noise.
3. A project will normally have a significant effect on the environment if it will conflict with adopted
environmental plans and goals of the community where it is located (see Appendix G to the CEQA
Guidelines). The facts and analysis in the PEIR don't support a finding of less than significant impact
for consistency with general plans beyond the year 2025, where at least there is a correlation,
intentional or otherwise, with the current Regional Housing Needs Allocation that each jurisdiction
is planning for. Beyond 2025, the assumptions in the land use chapter have had a more in-depth
analysis, and if not substantiated, should be designated as significant and unavoidable. If there are
impacts determined to be significant and unavoidable, mitigation measures should be designed to
lessen the impact; the current draft EIR includes no related mitigation measures. In Citizens for a
Sustainable Treasure Island v. City and County of San Francisco (2014) 227 Cal. App. 4th 1036, the
Court of Appeal for the First Appellate District held that an EIR must satisfy the substantial evidence
standard of review as to all of the required elements of an EIR; address the environmental impacts
of the proposed project to a degree of specificity consistent with the underlying activity being
approved; and properly allow for supplemental review that may be necessary in the future.
Therefore, the draft PEIR must be revised to explain the nature and magnitude of a proposed
project or activity with respect to land use and planning checklist criteria (Appendix G to the CEQA
Guidelines).
4. Since these projections are related to the GHG reductions and compliance with Senate Bill 375, it
puts the entire evaluation and basis for compliance into question. If these assumptions are not
made, it will have significant impacts to the GHG emissions, and the metric tons of annual emissions
that comprise over 40 percent of the regional total. As currently drafted, the Plan's land use
assumptions related to GHG contributions do not comply with other specific state and federal
mandates including SB 375, which achieves targets set by the California Air Resources Board and
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 6
compliance with federal civil rights (Title VI) requirements, environmental justice considerations, air
quality conformity, and public participation. Please refer to Attachment 1 for more background
discussion about the city's concerns regarding the technical methodology used to estimate GHG
emissions from the sustainable communities strategy. Pursuant to CEQA, the environmental
baseline for GHG emissions shall be established based upon the physical conditions at the project
site at the time of the NOP, or no NOP, at the time the environmental analysis commenced. The
environmental setting requirements of CEQA Guidelines section 15125, which directs SAN DAG to
. utilize existing general plan land use maps, helps establish the basis for compliance with
Government Code section 65080(b)(2)(H) and (J) as those land use map regulations existed at the
time of the NOP or when the environmental analysis commenced; and should have been used as the
most recent planning assumptions to develop per capital passenger vehicle-related greenhouse gas
emissions targets for 2035 set by the California Air Resources Board.
5. The Transportation chapter of the draft EIR lacks sufficient detail and explanation to adequately
understand and provide comment on the transportation analysis that was used to determine the
project impacts and related performance metrics such as Average Daily Trips (ADT), VMT and travel
mode share. The following comments are intended to provide this additional information and a
better understanding of the identified transportation impacts:
a. The analysis methodology used for the Transportation chapter does not provide a description
of how the ABM2+ analysis outputs such as Average Daily Trips (ADT), Mode Share, and
Vehicle Miles Traveled (VMT) are calculated for each of the travel modes. Without this
information, it is difficult to understand how the transportation network improvements
impact these analysis metrics for future year conditions and for consideration of potential
project mitigations.
b. Section 4.16.4 "Transportation Environmental Impact and Mitigation Measures" should
provide a description of the proposed transportation projects for each travel mode by horizon
year with (eference to Appendix B of the EIR document.
c. In order to directly compare the project list with the project impacts found in section 4.16.4, it
is recommended to reorganize the tables found in Appendix B by travel mode and horizon
year with indication of project mileage
d. Does the EIR consider the long term or permanent impact of COVID-19 on travel behavior
patterns throughout the region? Was the ABM2+ model adjusted to account for changes in
travel behavior due to the COVID-19 pandemic? Were additional adjustments made to key
mode choice variables such as rates for tele-work, vehiclf:! ownership, and traveler sensitivity
to use transit or carpool as a result of these travel behavior changes?
e. As mentioned above, significant issues need to be addressed in the Plan which should also be
addressed in the EIR including:
i. Grade separation in Carlsbad from Cannon Road to the northern border.
ii. The impacts of implementing roundabouts in the Complete Corridors.
iii. Alternative analysis for moving the grade separated 110mph transit leap commuter rail
to the east thereby reducing all the negative impacts of having the current North
County Transit District (NCTD) alignment running along the sensitive coastline, lagoons
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 7
and coastal open space, and coastal village land use that promote mobility and look to
reduce bifurcation issues caused by the current at grade NCTD alignment. The
potential bifurcation issues also constitute a potential significant impact on land use in
that the Plan will exacerbate the alignment's effect on dividing the established
downtown Carlsbad community.
6. The alternatives analysis does not describe a range of reasonable alternatives to the project because
it does not include an analysis of an alternative that evaluates what will occur if the faulty land use,
and therefore transportation, assumptions do not occur. The alternatives are constructed to reduce
impacts through even more focused growth in Mobility Hubs and through increased value pricing
and revenue generation. While it may be true these would reduce impacts, it does not provide
policy makers or members of the public a reasonable range of alternatives as required by CEQA.
Additionally, due to the aforementioned SB 9 being signed by the Governor, the reduction in
population assumed in suburban areas outside of the mobility hubs is both inconsistent with reality
and with planning principles required by the California Department of Housing and Community
Development to not concentrate all future growth in certain locations. CEQA and the CEQA
Guidelines require that an EIR describe all reasonable alternatives to the project and any feasible
mitigation measures (Laurel Heights Improvement Assn. v. Regents of University of California (1988}
47 Cal. 3d 400, 404). Because the draft PEIR does not discuss future land use conflicts with
applicable general plans, it fails to disclose ways to reduce or eliminate the environmental impacts
of the project and to respond to the major environmental issues identified during the planning
process (as a project alternative or as a mitigation measure) pursuant to Public Resources Code
section 21002 (see Friends of the Old Trees v. Department of Forestry & Fire Protection (1997) 52 Cal.
App. 4th 1383). The draft PEIR's analysis of the project alternatives and mitigation measures is
incomplete and, therefore, inadequate.
Section 15126 of the CEQA Guidelines requires that all aspects of a project must be considered
when evaluating its impact on the environment, including planning, acquisition, development, and
operation. The implementation and challenges to fund the Plan have not been appropriately
discussed. One of the project alternatives should accommodate transportation investments that can
be reasonably funded within the horizon of the plan under the current ("known") funding
mechanisms. Because the draft EIR does not discuss a financially constrained alternative, the
analysis of the project alternatives and mitigation measures is incomplete, and therefore,
inadequate.
7. Where regional planning processes have not resulted in the adoption of plans or regulations relating
to the environment, CEQA requires public agencies to engage in an analysis of the impacts of the
proposed project on the environment. (Public Resources Code§§ 21000; 21002.1; 21003.l(b);
21080(d); 21081; 21082.2(a).) Although there is a general analysis of projected growth in the region,
there is a lack of detail with respect to growth inducement or reasonably foreseeable future projects
implementing Public Resources Code section 21155 -21155.4 (CEQA streamlining for SCS
consistency) and/or other reasonably foreseeable development that may result. The provision or
improvement of transportation infrastructure, utilities, water and sewer service to an area can
induce growth by removing impediments to development. Once services are extended or improved
in an area, economic incentives for development exist. The basic elements and principles of the Plan
have been designed to facilitate future smart growth and concentrate population growth in areas
that would be efficiently served by transportation facilities. The smart growth concept is the basis
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 8
for the framework for prioritizing public land use and transportation investments in the region. The
smart growth concept identifies areas where smart growth development exists or could be built and
provides a basis for planning transportation facilities and transit services in the proposed Plan.
Smart growth areas identified receive prioritized infrastructure investments and transit services to
support smart growth. This carries true to those smart growth areas that are accommodated by
existing general plans, and for other areas that are not covered by existing general plans. CEQA
requires that an EIR discuss the ways in which the proposed project could foster economic or
population growth or the construction of additional housing, either directly or indirectly, in the
environment surrounding the project. CEQA requires this discussion to include ways in which a
project would remove obstacles to population growth or encourage and facilitate other activities
that could significantly affect the environment (CEQA Guidelines section 15126.2(d)). The level of
detail should reflect the level contained in the plan or plan element being considered (Rio Vista
Farm Bureau Center v. County of Solano (1992) 5 Cal.App.4th 351), inclusive of new smart growth
areas as designated.
City staff looks forward to working with SAN DAG on improving mobili,ty and land use access in the region
and building sustainable, equitable and healthy modes of transportation. We appreciate the opportunity
to comment on the Plan that will help the region realize these goals. While at the same time, city staff
also looks forward to helping SAN DAG advance a legally adequate PEIR to support the disclosure and
decision-making process. Since the major premise of CEQA is that it "be interpreted in such manner as
to afford the fullest possible protection to the environment within the reasonable scope of the statutory
language" (Friends of Mammoth v. Board of Supervisors, supra, 247, 259), SAN DAG should take all action
necessary to alert the decision-makers and the public to the environmental changes associated with the
project (County of Inyo v. Yorty (1973) 32 Cal. App. 3d 795, 810). There is no shortcut to CEQA-the EIR
process protects not only the environment by also informed self-government (Laurel Heights
Improvement Assn. v. Regents of University of California, supra, 376, 392). The SAN DAG Board must
certify that the final PEIR has been completed in compliance with CEQA and that it considered all of the
information in the final EIR before approving or disapproving the project. As of this writing, the draft
PEIR is not in compliance with CEQA.
If you have any questions related to comments on the transportation network, please contact Tom
Frank, Transportation Director/City Engineer, at Tom.Frank@carlsbadca.gov or, if you need additional
information related to comments on the land use assumptions, please contact Eric Lardy, Principal
Planner, at Eric.Lardy@carlsbadca.gov.
JEFF MURPHY
Community Development Director
TOM FRANK
Transportation Director/City Engineer
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 9
Attachments:
1. City of Carlsbad Comment Letter on Draft Regional Plan (Aug. 6, 2021)
2. City of Carlsbad Comment Letter -Regional Arterials (Sept. 30, 2021)
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Director, Community Development
Don Neu, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager
Jason Geldert, Engineering Manager
Eric Lardy, Principal Planner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Aug.6,2021
San Diego Association of Governments
401 B Street, Suite 800
San Diego CA 92101
Via: SDForward@sandag.org
RE: City of Carlsbad Comments on Draft 2021 Regional Plan
To Whom it May Concern,
ATTACHMENT 1
{cityof
Carlsbad
The City of Carlsbad appreciates the opportunity to provide comments on the draft 2021 Regional Plan
("Plan"). This is an important plan for this region and will guide the next phase of growth for the
member agencies of the San Diego Association of Governments ("SAN DAG"). An effectively designed
and implemented regional transportation plan would help ensure improved transportation options for
area residents, businesses and other community members; meaningful reductions in greenhouse gas
("GHG") emissions; and improved quality of life as we grow our communities.
The City of Carlsbad ("city") is submitting comments based on the policies, projects, programs and other
improvements included in•the Plan. Our agency's comment letter is divided into two sections. The first
section seeks clarity and other considerations that pertain to our agency's review of the Plan. The
second section identifies the city's preliminary comments and recommendations.
Implementing the regional transportation network outlined in the Plan requires municipalities to
support the regional vision and deliver on local infrastructure and services like the priority bus routes,
local bus services, and pedestrian and cycling connections to major transit infrastructure. These
components, which are delivered by municipalities, are essential to creating a coherent and
comprehensive local transportation network that feeds into regional services. For that reason, an
effective public review of the Plan should involve a transparent and thorough process for identifying and
evaluating potential hazards, physical changes to the environment and indirect (off-site and cumulative)
impacts that might result from implementation activities that may reasonably occur with the Plan.
The city's residents, businesses and other community members will greatly benefit from the
involvement and technical assistance from the prospective Draft Environmental Impact Report ("EIR,,).
Therefore, what follows in this correspondence represents our agency's preliminary comments and
recommendations. The city reserves the right to add, amend, change or replace comments and
recommendations based on additional review and understanding of the Plan and the environmental
analysis provided under the California Environmental Quality Act ("CEQA1').
The city thanks SAN DAG staff for meeting with city staff on Aug. 2, 2021, to discuss some of these
comments in advance of this letter. Following that meeting, SAN DAG provided language that they may
recommend adding to the Regional Plan for additional clarification on land use authority. The language
is, "Land use authority is reserved to local jurisdictions because they are best positioned to effectively
implement the objectives outlined in the Plan through understanding of the unique needs of their
communities and geographies." This language will be helpful to clarify that land use authority rests with
Transportation & Community Development Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2710 t
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page 2
the local jurisdiction. The city still offers the following comments with the intent to support
development of a defensible and realistic regional plan.
SECTION 1: CLARITY AND OTHER CONSIDERATIONS
City staff have attended the series of workshops that SAN DAG hosted during the public review period,
and respectfully starts this section with several questions related to the process of the Plan and the
Draft EIR. By way of introduction, a jurisdiction's General Plan, such as the city's General Plan, identifies
the expected population of the city and any lands outside of the city limits but within their Sphere of
Influence where future growth is anticipated to occur. The city's General Plan identifies the subject area
adjacent to the McClellan-Palomar Airport for development under the designation for limited and light
industrial use.
For future land use planning, land use assumptions must reasonably proxy and be generally consistent
with local planning standards and programs, to be considered growth accommodating rather than
growth inducing. SAN DAG has the authority under Government Code Section 65584 to determine
existing and projected housing needs, as well as the share of housing needs to be allocated to cities and
counties, but it is unclear if SAN DAG has jurisdiction to allocate new housing growth to areas in a
manner not consistent with Government Code Section 65584. Attachment 1 includes additional
information on the applicabie Government Code and standards. Therefore, and as indicated above, the
build-out of properties within the Business Park and flight activity zone must be done in accordance with
the city's General Plan Land Use Diagram, as amended, in accordance with city approval.
The initial questions on the planning process associated with developing the Plan are provided below:
1. The SAN DAG website states, "The SAN DAG Sustainable Communities Strategy and Final EIR from
its 2015 Regional Plan will remain valid and in compliance for purposes of state funding
eligibility and other state and federal consistency purposes until the SAN DAG Board of Directors
adopts a new Regional Plan and EIR, provided those actions are completed by the end of
December 2021." SAN DAG needs to clarify how the Draft EIR, Response to Comments and
Adoption will be completed this year and what will occur if they are not completed by the end of
this year. Additionally, please clarify when the Draft EIR will be available; it is difficult to
completely assess the full impacts of this plan when the public review of the documents is
piecemealed.
a. SAN DAG should clarify how public comments on the Plan are going to be addressed in
the Draft EIR prior to its release.
b. In the Draft EIR, SAN DAG needs to clearly articulate the impacts to land use and if the
Plan will cause a significant environmental impact due to a conflict with any land use
plan, policy or regulation adopted for the purpose of avoiding or mitigating an
environmental effect. Appendix F: Regional Growth Forecast and Sustainable
Communities Strategy Land Use Pattern appears to be inconsistent with the city's
General Plan and rezone program to accommodate the Regional Housing Needs
Assessment, as well as the general plans of other jurisdictions such as the cities of
Coronado, Del Mar and the County of San Diego. The Draft EIR should clarify how
implementation of this Plan can occur if those changes are not made.
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug.6,2021
Page 3
2. The city has three mobility hubs, associated with the Employment Centers Published supporting
the SANDAG Regional Plan.1 McClellan-Palomar Airport is the fifth largest employment center in
the region, with Carlsbad State Beach and Carlsbad Village as "Tier 3 and Tier 4" employment
centers. The city thanks SAN DAG for providing data for analysis to determine impacts and
provide for accurate comments on the Plan. Attachment 2 shows a summary of the Mobility
Hubs and housing units assumed in the Series 14 Growth Forecast for the year 2050. In
summary:
a. The assumptions in the updated Series 14 Growth Forecast contain inconsistencies with
the city's General Plan. The Carlsbad Palomar Major Employment Mobility Hub does
include increases in density beyond what the citywide numbers appear to show when
they are looked at in more detail.
i. There are three locations in which density is shown to be inconsistent with good
planning principles, the city's General Plan and the Airport Land Use
Compatibility Plan. The three most problematic areas {shown in Attachment 3)
are:
1. 736 units on parcels immediately adjacent to the McClellan-Palomar
Airport runway. The location of the airport within this mobility hub was
shared with SAN DAG staff multiple times at workshops. This is
inconsistent with the regulations provided by the San Diego County
Regional Airport Authority and conflicts with standard planning
principles for siting housing away from hazards.
2. 2,755 units on existing developed resort properties and open space
dedicated lands adjacent to Legoland.
3. 65 units in a preserved open space area .
ii. SAN DAG should provide additional detail why units were assumed in these
areas, what planning principles those decisions were based on, and how
SAN DAG expects this to be implemented.
iii. Concentration of units in the mobility hubs alone appears to conflict with the
direction received from the California Department of Housing and Community
Development {"HCD") to implement new Affirmatively Furthering Fair Housing
{"AFFH"), which seeks to combat housing discrimination, eliminate racial bias,
undo historic patterns of segregation, and lift barriers that restrict access in
order to foster inclusive communities and achieve racial equity, fair housing
choice and opportunity for all Californians. The allocations of land use provided
by SAN DAG seem to focus all the higher density housing into one area of the
city. (This is one of the largest points of analysis that each jurisdiction in the
region needs to respond to in order to receive a certified Housing Element.)
b. Additionally, looking at the detailed data provided by SAN DAG, it is now clear why the
citywide numbers only show moderate increases in population. Our analysis has shown
that there is an assumed reduction of population by 2,310 persons in the areas within
the city but outside of the mobility hubs. This is likely due to assumed reductions in
persons per household over time, but SAN DAG should clarify the source and
reasonableness of this assumption. If housing is not provided consistent with these
areas, is it still reasonable to assume persons per household will be reduced in 2050?
1 SAN DAG Website: Employment Centers SAN DAG :: PROJECTS :: San Diego's Regional Planning Agency
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page4
c. Furthermore, this reduction in population is not limited to the City of Carlsbad. There is .
an approximately 85,000 reduction in population assumed outside of mobility hubs
regionwide. SAN DAG needs to address if that is a reasonable assumption and if this will
result in other impacts to public and private projects that will rely on this growth
forecast, and the associated Activity Based Model (2+) to project future impacts to
transportation, GHG, air quality and noise.
d. The forecast has decreased in future population based on current trends, but it is not
clear if there is enough housing provided with reductions and increases in some
jurisdictions. Will the reduced amount of housing that will be provided result in an
increased exacerbation of the affordability crisis?
e. There is a lack of clarity about how the Plan would be implemented at the municipal
level. SAN DAG should develop an approach for engaging with municipalities to ensure
local support for delivering the regional transportation network. Staff from local
jurisdiction have the knowledge and ability to share where there are land use
assumptions that conflict with planning and zoning laws. Our analysis focused on the
City of Carlsbad, but if these types of assumptions are made regionwide, it presents
flaws in the overall analysis. These flaws put the assumed reductions in vehicle miles
traveled ("VMT") and ability to implement the Regional Plan into question.
3. The area designated is controlled for use and activity density and intensity through its spatial
association with the McClellan-Palomar Airport. The McClellan-Palomar Airport is defined by the
Federal Aviation Administration ("FAA") as a commercial service airport that, in addition to
private aircraft, has regularly scheduled commercial flights to Los Angeles International Airport
("LAX"). The McClellan-Palomar Airport Land Use Compatibility Plan ("ALUCP") is prepared
according to FAA requirements and adopted by the San Diego County Regional Airport Authority
acting as the Airport Land Use Commission for the County of San Diego.
a. The ALUCP provides measures to minimize the public's exposure to excessive noise and
safety hazards within areas around the airport and identifies areas likely to be impacted
by noise and flight activity created by aircraft operations at the airport. These impacted
areas include the Airport11nfluence Area ("AIA"), the Clear Zone and the Flight Activity
Zone.
b. Within the AIA, the ALUCP establishes six safety zones for the purpose of evaluating
safety compatibility of new/future land use actions. The safety zone boundaries depict
relative risk of aircraft accidents occurring near the airport and are derived from general
aviation aircraft accident location data and data regarding the airport's runway
configuration and airport operational procedures. The ALUCP limits development
intensities in these zones by imposing floor area and lot coverage maximums, by
incorporating risk reduction measures in the design and construction of buildings,
and/or by restricting certain uses altogether. For example, all residential and virtually all
non-residential uses are considered incompatible land uses in some zones, while
considered to be either compatible or conditionally compatible with the airport in other
zones. Attachment 4 shows the McClellan-Palomar Airport, noise contours and
SANDAG's proposed housing units.
c. If the proposed SAN DAG land use assumptions are endorsed, an amendment to the
city's General Plan would be required to change the land use designation to Mixed-Use
Commercial or residential land uses within the existing Business Park in order to
effectuate the underlying assumptions of SANDAG staff. This is not a realistic
, City of Carlsbad Comments on Draft 2021 Regional Plan
Aug.6,2021
Page 5
assumption. Further, the protected airspace referenced in the AIA and the ALUCP must
also be amended based on SANDAG's regional planning assumptions. (The FAA
establishes airspace protection zones in the airspace above and surrounding airports in
order to protect aircraft from obstructions such as buildings, towers, etc. in navigable
airspace.)
d. When a General Plan is adopted or amended, the allowable growth pattern of an area is
identified and the expansion or updating of the va rious land uses as specified in the
General Plan can occur throughout the planning horizon. Without such growth
considerations, the expansion or intensification of existing land uses could be
considered 11growth inducing." Unplanned and uncontrolled growth may have significant
adverse impacts on the environment. CEQA requires a discussion of how a "project"
could increase population, employment or housing growth in surrounding areas and the
impacts resulting from this growth. The CEQA Guidelines indicate that a "project" would
normally have a significant effect on the environment if it would induce substantial
growth or a substantial concentration of population.
4. At this point, it is not clear if SANDAG's assumptions adequately contemplate the development
patterns included in the Sustainable Communities Strategy ("SCS"}/Regional Transportation Plan
(
11RTP"), and Regional Air Quality Strategy ("RAQS"), local climate action planning business-as-
usual estimates, sub-regional traffic modeling, or the airspace assumptions of AIA and the
ALUCP.
5. The city seeks clarity on the Plan's underlying assumptions made to justify the proposed
extensive high-speed rail network considering the significant changes in travel behavior which
have occurred throughout the region as a result of the COVID-19 pandemic and due to the
advancements in disruptive technologies such as telecommuting, autonomous vehicles,
microtransit, etc.
a. Recent North County Transit District ("NCTD") Coaster ridership data show riders are
not returning to riding the Coaster in comparison to other modes of travel as shown in
Attachment 5.
b. This question is consistent with comments made by SANDAG's panel expert Bob Poole .
regarding the impact of the COVID-19 pandemic on transit ridership and mega-transit
projects. (See comments by Bob Poole during the March 12, 2021 presentation to
SAN DAG starting at timestamp 1:30 p.m.: https://youtu.be/g-e6bNY5J 8?t=5410}
6. The city seeks clarity on why an alternatives analysis was not conducted with consideration of
other transit alternatives such as automated /shared vehicle technologies and personalized zero
emissions transit programs that are capable of utilizing the existing regional freeway
infrastructure in response to these recent developments explained in the above comment.
7. The city seeks clarity on why the Plan does not incorporate policies to promote roundabouts
over signalized intersections and include a budget line item under the Complete Corridors to
fund the construction of roundabouts at new locations and to replace signalized intersections
when found feasible. This clarification would support the Federal Highway Administration
(11FHWA")'s project for Accelerating Roundabout Implementation in the United States and the
County of s·an Diego Air Pollution Control Board's support for implementing roundabouts to
address GHG and reduce fatalities.
8. The city seeks clarity on the project phasing proposed within the Plan. Specifically, the city is
seeking to understand the timing of implementation of unfunded TransNet projects related to
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug.6,2021
Page 6
the new projects presented within the Regional Plan. To support this, the city is requesting that
SAN DAG input the information requested in Table 1 (Attachment 6).
9. The city seeks specific data on the proposed 200 miles of rail service contemplated in the Plan.
To support this, the city is requesting that SAN DAG input the information requested in Table 3
(Attachment 7). Specific questions:
a. Please provide more information about the scope of the high-speed rail alignments,
potential vehicle technologies and their cost estimates.
b. Will the Coaster keep the same rail alignment?
c. What funding is programmed or planned for the Carlsbad Village railroad trench and the
other projects along the current NCTD/Coaster Service right-of-way?
d. Will some of the tracks be at grade with fencing and trains traveling at 110 miles per
hour speeds?
SECTION 2: COMMENTS AND RECOMMENDATIONS
In addition to the comments on process and the Draft EIR provided above, city staff remain concerned
that there is not enough detail on the feasibility of implementation of this significant shift in
transportation strategy. On specific content in the plans, we outline our recommendations and
comments below:
1. Paying for the Plan:
The draft 2021 Regional Plan sets out an ambitious plan to build and operate a region-wide
system of transportation projects, programs and other improvements. This is a substantial role
for SAN DAG to play in supporting both the construction and operation of these projects,
programs and other improvements. SAN DAG should set annual revenue targets to directly fund
everything and should approve any recommended sustainable revenue tools to help meet these
targets. Many of the funding strategies will require legislative changes, or voter-approved
taxation. SAN DAG should clarify what will occur if the funding is not available, if opposition to
projects stops them from construction, and if General Plans in the region are not modified to
implement the Plan.
2. Appendix D: Sustainable Community Strategy Documentation:
Appendix D includes the Sustainable Communities Strategy, which outlines assumptions
included in the Activity Based Model 2+ ("ABM 2+"), updated for this. This model will be
necessary for use by publicly and privately initiated land use projects preparing documents for
consistency with VMT/CEQA Guidelines and Traffic Impact Analysis ("TIA") Evaluations. City staff
respectfully request direction from SAN DAG on how to conduct modeling with the service
bureau and how to factor in these assumptions applied to ABM 2+. Specifically, the addition of
pricing, parking costs for coastal communities, 10% teleworking and micromobility. SAN DAG
should provide direction on how this could be worked into General Plans that are updated every
5-20 years.
3. Appendix A: Transportation Projects, Programs, and Phasing:
Trips to and from school sites result in a significant congestion, VMT generation, and peak hour
delay throughout the region. Additional funding and projects should be recommended with a
specific focus on improving safety and multi modal access in and around school sites along with
programs to incentivize non-single occupancy vehicle trips to schools.
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page 7
Table A.11: Given the proven success of the Carlsbad Connector microtransit pilot program, the
city agrees with the Plan's recommendations to provide similar on-demand microtransit systems
throughout North County at all mobility hub sites and major transit centers.
Table A.13: The segment of El Camino Real between Poinsettia Lane and Camino Vida Roble is
proposed to be widened from two to three lanes to prime arterial standards. With the adoption
of the city's General Plan, the city has determined that the widening of this portion of El Camino
Real is not feasible due to constrained right-of-way and would result in negative impacts to
other travel modes. City staff recommend removal of this proposed project recommendation
CB32 (that is, a 'do nothing' scenario, or appraise and evaluate different mobility projects
and/or alternative designs).
The preferred lnterstate-5 freeway alternative identified in the North Coast Corridor ("NCC")
Final EIR/EIS is the refined 8+4 Buffer alternative, with four freeway lanes and two managed
lanes in each direction and completion by 2035. Appendix A, Table A.5 describes NCC project IDs
CC004, 007 -009 as "8F to 6F+4ML" with completion by 2050. While this might lead to further
study, it is not clear why there is a different freeway configuration (i.e., reduction in freeway
lanes) proposed. How does a reduction in lanes continue to meet NCC potential project benefits
of maintaining or improving traffic operations and improving the safe and efficient regional
movement of people and goods?
4. Active Transportation:
The city appreciates the Regional Plan's overall approach of providing a connected network of
high-quality bicycle facilities throughout the region. Regional bikeways are recommended
throughout the city including along Palomar Airport Road which will provide a key east-west
connection and El Camino Real which will provide a new north-south bikeway connection
through the city. Both roadways are proposed to include "on-street bikeways". Due to the high
traffic volumes and vehicle speeds experienced along most of both corridors, the city
recommends considering "off-street bikeways" or Class I facilities where feasible in order to
stimulate the shift from personal motor vehicle use to people choosing to bike.
It is extremely important that municipal transportation plans align with regional transportation
plans to achieve regional goals for land use and transportation and to promote the region
working together to build a cohesive regional transportation network. Considering there are
currently no mechanisms in place to ensure municipalities coordinate local transportation plans
with regional planning documents, the Plan should provide an approach on how SAN DAG plans
to engage with municipalities, especially in areas of potential disagreement or conflict (as
aforementioned in this subsection and others). It is also recommended that the Plan provide
additional direction regarding the application of protected bikeways in a variety of applicable
contexts. While vertical measures such as soft hit posts may be appropriate in lower volume and
lower speed roadways, arterial roadways with high traffic volumes and high speeds warrant
much more substantial physical protection from vehicles. In addition, special consideration
should be given at intersections and driveways which may be impacted due to the additional
width and visibility impacts created by protected bikeways.
City staff look forward to working with SAN DAG on improving mobility and land use access in the region
and building sustainable, equitable and healthy modes of transportation, and we appreciate the
opportunity to comment on the Plan that will help the region realize these goals.
City of Carl.sbad Comments on Draft 2021 Regional Plan
Aug. 6,2021
Page 8
If you have any questions related to comments on the transportation network, please contact Tom
Frank, Transportation Director/City Engineer, at Tom .Frank@carlsbadca .gov or if you need additional
information related to comments on the land use assumptions, please contact Eric Lardy, Principal
Planner, at Eric.Lardy@ carlsbadca.gov.
Sincerely,
For
JEFF MURPHY
Community Development Director
TOM FRANK
Transportation Director/City Engineer
Attachments:
1. Government Code 65020 (S.B. 375) Summary
2. City of Carlsbad Mobility Hubs
3. City of Carlsbad -Palomar Airport Road Mobility Hub Analysis
4. Palomar-Mclellan Airport Flight Paths
5. Recent NCTD Coaster Ridership Data
6. Table 1-Project Data Request
7. Table 3 -Detail of Proposed Rail Lines
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Director, Community Development
Don Neu, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager
Jason Geldert, Engineering Manager
Eric Lardy, Principal Planner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Attachment 1: Government Code 65020 (S.B. 375) Summary
Government Code section ("GOV§") 65080, also referred to as California Senate Bill 375 (Steinberg, 2008)
("SB 375"), is one area of law that provides SAN DAG with guidance to which a regional transportation plan
must be developed.
Among other things, the regional transportation plan that is developed "shall be an internally consistent
document" (GOV § 65080 (b)) and shall include a "sustainable communities strategy prepared by each
metropolitan planning organizations as follows" (GOV§ 65080 (b)(2)(B)):
Each metropolitan planning organization shall prepare a sustainable communities strategy, subject
to the requirements of Part 450 of Title 23 of, and Part 93 of Title 40 of, the Code of Federal
Regulations, including the requirement to utilize the most recent planning assumptions considering
local general plans and other factors. The sustainable communities strategy shall (i) identify the
general location of uses, residential densities, and building intensities within the region, (ii) identify
areas within the region sufficient to house all the population of the region, including all economic
segments of the population, over the course of the planning period of the regional transportation
plan taking into account net migration into the region, population growth, household formation
and employment growth, (iii) identify areas within the region sufficient to house an eight-year
projection of the regional housing need for the region pursuant to Section 65584, (iv) identify a
transportation network to service the transportation needs of the region, (v) gather and consider
the best practically available scientific information regarding resource areas and farmland in the
region as defined in subdivisions (a) and (b) of Section 65080.01 , (vi) consider the state housing
goals specified in Sections 65580 and 65581, (vii) set forth a forecasted development pattern for
the region, which, when integrated with the transportation network, and other transportation
measures and policies, will reduce the greenhouse gas emissions from automobiles and light trucks
to achieve, if there is a feasible way to do so, the greenhouse gas emission reduction targets
approved by the state board, and (viii) allow the regional transportation plan to comply with Section
176 of the federal Clean Air Act ( 42 U.S.C. Sec. 7506 ).
The 2021 draft Regional Transportation Plan includes a Sustainable Communities Strategy ("SCS"), as
required by SB 375 for the San Diego region (herein after called "draft Regional Plan"). The draft Regional
Plan indicates that "SB 375 requires the SCS to include a pattern for forecasted growth and development
that accomplishes the following: 1) When combined with the transportation network, the SCS will achieve
the regional GHG emission-reduction targets; 2). The SCS accommodates the Regional Housing Needs
Assessment ("RHNA") Determination; and 3) The SCS utilizes the most recent planning assumptions.
(Reference p. 19 of the 2021 Regional Plan.)
Predicting the effect of transportation plans or projects on land uses and land use planning is critical to
developing context sensitive solutions for t ransportation projects. Therefore, utilization of the most
recent planning assumptions is not only necessary but is required as specifically stated therein GOV §
65080. If inconsistencies are found in the land use assumptions or adverse impacts are anticipated,
SAN DAG should be actively engaged in the development of measures to address these issues.
The SANDAG Board of Directors approved the final RHNA plan with the final housing unit allocation on
July 10, 2020, which was based on the most recent land use planning assumptions and an adopted
methodology to allocate housing in accordance with GOV §§ 65584.04(d and m). The City of Carlsbad
received a total RHNA allocation of 3,873 units as a result of RHNA plan adoption. The adopted April 6,
2021 city's Housing Element accommodates its housing needs through current zoning and other programs
City of Carlsbad Comment Letter August 6, 2021
Attachment 1: Government Code 65020 (S.B. 375) Summary
as needed to meet the city's RHNA obligation at all income levels. The land use inputs derived from this
local pianning document constitutes the most recent land use assumptions. On July 13, 2021 the
Department of Housing and Community Development found "the adopted housing element is in
substantial compliance with State Housing Element Law (Article 10.6 of the Gov. Code).
The most recent planning assumptions are critical for the development of the draft Regional Plan as the
document must comply with other specific state and federal mandates including a SCS per California
Senate Bill 375, which achieves GHG emissions reduction targets set by the California Air Resources Board
and compliance with federal civil rights (Title VI) requirements, environmental justice considerations, air
quality conformity, and public participation. To monitor compliance and attainment of state reduction
goals in GHG, GOV§ 65080 (b)(2)) requires that:
(HJ Prior to adopting a sustainable communities strategy, the metropolitan planning organization
shall quantify the reduction in greenhouse gas emissions projected to be achieved by the
sustainable communities strategy and set forth the difference, if any, between the amount of that
reduction and the target for the region established by the state board.
(J)(i) Prior to starting the public participation process adopted pursuant to subparagraph (F), the
metropolitan planning organization shall submit a description to the state board of the technical
methodology it intends to use to estimate the greenhouse gas emissions from its sustainable
communities strategy and, if appropriate, its alternative planning strategy.
There is inevitably some uncertainty regarding the use of projected future conditions. However, what is
certain is that the project will not operate under the conditions that exist today. There will be new
residential and employment growth in the intervening years between now and the proposed build-out of
the draft Regional Plan. Nonetheless, projections utilized should represent the best available information
assembled by the local agencies with jurisdiction and expertise. Judgments about land use assumptions
utilized in the draft Regional Plan should be based on and supported by facts, adopted plans, and "most
recent planning assumptions," rather than speculation and personal opinions. The land use assumptions
for "uses, residential densities, and building intensities within the region" (as required by GOV § 65080
(b)(2)(B)(i)) should also be the same, as that provided to the state board (as required per GOV§§ 65080
(b)(2)(H and J) in estimating and analyzing GHG from the SCS and the effect on growth and whether the
effects of that growth would be significant in the context of the region's plans, natural setting, and growth
patterns. Ultimately, the SCS must demonstrate whether SANDAG can meet the per capita passenger
vehicle-related GHG emissions targets for 2035 set by the California Air Resources Board ("CARB").
SB 375 directs CARB to accept or reject the determination of SANDAG that its SCS submitted to CARB
would, if implemented, achieve the region's GHG emissions reduction targets. CAR B's technical evaluation
of SANDAG's draft Regional Plan would be based on all the evidence provided, including the models, the
data inputs and assumptions, the SCS strategies, and the performance indicators.
The transportation and planning assumptions are also extremely important as it is relied on for other
master planning exercises. The Regional Air Quality Strategy ("RAQS") relies on information from CARB
and SAN DAG for information regarding projected growth in the cities and San Diego County. This in turn
is utilized to address other state requirements, including the San Diego portion of the California State
Implementation Plan ("SIP") and promulgating their own rules and regulations regarding air quality in the
region or to address federal requirements.
City of Carlsbad Comment Letter August 6, 2021
Attachment 1: Government Code 65020 {S.B. 375) Summary
The analysis of land use impacts for transportation projects is guided by FHWA Technical Advisory T 6640.8
and the CEQA Guidelines.
Under the FHWA Technical Advisory T 6640.8 (G){l), Guidance for Preparing and Processing
Environmental, states:
This discussion [of land use] should identify the current development trends and the State and/or
local government plans and policies on land use and growth in the area which will be impacted by
the proposed project. These plans and policies are normally reflected in the area's comprehensive
development plan, and include land use, transportation, public facilities, housing, community
services, and other areas.
The land use discussion should assess the consistency of the alternatives with the comprehensive
development plans adopted for the area and (if applicable) other plans used in the development
of the transportation plan required by Section {23 U.S. Code §] 134. The secondary social,
economic, and environmental impacts of any substantial, foreseeable, induced development
should be presented for each alternative, including adverse effects on existing communities.
Where possible, the distinction between planned and unplanned growth should be identified.
There is also a requirement to analyze the land use planning inconsistencies per CEQA Guidelines §
15126.2(a), which specifies that an EIR for a proposed project include:
The Significant Environmental Effects of the Proposed Project. An EIR shall identify and focus on
the significant effects of the proposed project on the environment. In assessing the impact of a
proposed project on the environment, the lead agency should normally limit its examination to
changes in the existing physical conditions in the affected area as they exist at the time the notice
of preparation is published, or where no notice of preparation is published, at the time
environmental analysis is commenced. Direct and indirect significant effects of the project on the
environment shall be clearly identified and described, giving due consideration to both the short-
term and long-term effects. The discussion should include relevant specifics of the area, the
resources involved, physical changes, alterations to ecological systems, and changes induced in
population distribution, population concentration, the human use of the land (including
commercial and residential development), health and safety problems caused by the physical
changes, and other aspects of the resource base such as water, historical resources, scenic quality,
and public services. The EIR shall also analyze any significant environmental effects the project
might cause or risk exacerbating by bringing development and people into the area affected. For
example, the EIR should evaluate any potentially significant direct, indirect, or cumulative
environmental impacts of locating development in areas susceptible to hazardous conditions (e.g.,
floodplains, coastlines, wildfire risk areas}, including both short-term and long-term conditions, as
identified in authoritative hazard maps, risk assessments or in land use plans addressing such
hazards areas.
Since the new land use assumptions are being utilized, as described by this letter, the EIR that is prepared
shall also analyze any significant environmental effects the project might cause by bringing development
and people into the area affected. The following are the basic steps in analyzing land use impacts as part
of the community impact assessment process:
City of Carlsbad Comment Letter August 6, 2021
Attachment 1: Government Code 65020 (S.B. 375) Summary
1. Inventory the existing land use patterns (including undeveloped land), development trends, and
transportation systems. The inventory of existing land uses should include the following land use
types: residential, commercial, industrial, recreational, institutional, public services, community
services, emergency services, transportation, utilities, agriculture, and undeveloped land in the
study area. The study area should include the surrounding community that is generally
associated with the project area within which community impacts could occur. The inventory
should also address development trends and identify recent developments in the study area to
include the development's name, size, status (planned, built, under construction), and the
jurisdiction in which it is located. A map showing the location of existing and planned land uses
in the area should also be prepared.
2. Determine whether the project is consistent with local and regional policies that govern land use
and development. For the consistency analysis, the policies and programs considered in the
analysis should include: transportation plans and programs (MTPs/RTPs and MTIPs/RTIPs),
regional growth plans, local General Plans that establish land use and growth management
policies for the study area, and any specific or pipeline development proposals. This analysis
should also include a discussion of consistency with the Coastal Zone Management Act of 1972,
California Coastal Act of 1976, the National Wild and Scenic Rivers Act (16 USC 1271) and the
California Wild and Scenic Rivers Act (Pub. Res. Code § 5093.50 et seq.). After preparing a
preliminary list of relevant plans to be considered in the analysis, the SAN DAG planner should
meet with the staff of the various agencies to review the list to determine if it is complete and
revise the list as necessary.
3. Assess the changes that would occur in land uses and growth with and without the project.
4. The draft Regional plan and each project alternative should be considered separately since the
results may be different.
5. Develop measures to avoid, minimize, and/or mitigate potential adverse effects.
The resulting environmental analysis should identify the current development trends and the State and/or
local government plans and policies on land use and growth in the area which will be impacted by the
proposed project. These plans and policies are normally reflected in local General Plans. If found to be
consistent, then the findings fn the EIR should be documented in the report and no further analysis or
action is necessary. When found not to be inconsistent with a policy or program, then consideration must
be given to modifying the draft Reginal Plan alternative to make it consistent, or measures to address the
inconsistency must be developed. SAN DAG should be actively engaged in the development of measures
to address these issues and be prepared to assess the consistency of the draft Regional Plan and
alternatives with the comprehensive development plans adopted for the area and (if applicable) other
plans used in the development of the transportation plan required by Section 23 U.S. Code§ 134. For any
new land use growth assumptions, the secondary social, economic, and environmental impacts of any
substantial, foreseeable, induced development should be presented for the draft Regional Plan and each
alternative, including adverse effects on existing communities. The results should be shared with the
public during the public involvement process, e.g., at community meetings, etc. Public input should be
considered by SANDAG and if necessary, the findings of the analysis should be revised to reflect
information gained through the public involvement process.
City of Carlsbad Comment Letter August 6, 2021
I SANDAG Mobility Hubs I
0 • ~ Mobility Hub MGRAs with 2016-2050 Increased Unit Change
-Carlsbad Mobility Hubs
D Carlsbad MGRAs
~-·.:, Carlsbad Quadrant
II Carlsbad Boundary
N
A 0 2
Miles
Hub Name Hub Type Total Total Total Total Total Jobs Total
Population Houses Population Houses 2025 Population
2016 2016 2025 2025 2035
Carlsbad Coastal 14087 6430 15095 6539 9290 16177
Village
Carlsbad Major 12853 5475 12275 5461 61074 19465
Palomar Employmen
Center
N/A Outside of 86239 34247 88793 35855 13896 84039
Hubs
N/A All of 113179 46152 116163 47855 84260 119681
Carlsbad
Total Total Jobs Total
Houses 2035 Population
2035 2050
7075 9667 17293
8503 67005 21080
35855 14345 83929
51433 91017 122302
Total Total Jobs
Houses 2050
2050
7607 10044
9265 72900
35855 14900
52727 97844
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS
FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to use~ of this map, or any other party, far any loss or damages,
consequential or ather-Nise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. ln using this map, user further agree to indemnify, defend, and hold harmless the City
of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
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Carlsbad Village Mobility Hub MGRAs
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[Z] Mobility Hub MGRAs with
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CJ Carlsbad Mobility Hubs
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N c::::J Carlsbad Boundary
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The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUS
FOR PARTICULAR PURPOSE AND/OR Af.JY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad
consequential or otherwise, including but not limited to time, money, or good'Mll, arising from the use, operation or modification of the map. In
of Carlsbad for any and all liability of any nature arising out of or resuhing from the lack of accuracy or correctness of the map, or the use of the
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FALL OTHER WARRANTI R MERCHANTABIL , FITNESS
users of this map, or any at rty, for any loss or d ages,
, user further agree to indem efend, and hold ha ss the City
The City of Carlsbad disclaims any responsibllity for the accuracy o'
of Carlsbad become liable to users of this map, or any other party, f1
any nature arising out of or resulting from the lack of accuracy or car
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MGRA Closer Look
N
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~ : :, Carlsbad Quadrant
CJ carlsbadMobilityHubs
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General Plan Land Use
D L, Local Shopping Center
D OS, Open Space
D P,Public
D PI, Planned Industrial
D Pl/O, Planned Industrial/Office
D R, Regional Commercial
D R-1.5, Residential 0-1.5 du/ac
D R-lS, Residential 8-15 du/ac
D R-23, Residential 15-23 du/ac
D R-4, Residential 0-4 du/ac
D R-8, Residential 4-8 du/ac
D TC, Transportation Corridor
D VC, Visitor Commercial
~ VC/O5, Visitor Commercial/Open Space
N
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~: -~ carlsbad Quadrant
c:J CarlsbadMobilityHubs
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CJ R-15, Residential 8-15 du/ac
CJ R-4, Residential 0-4 du/ac
E:::J VC/OS, Visitor Commercial/Open
Space
MGRA: 14249
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE ANO IN LIEU OF A\L OTHE;
of Carlsbad become liable to users of th!s map, or any other party, for any loss or damages, consequential or otherwise, Including but not limited to time, money, or'goodwlll,
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
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mar;
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N
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c:::J carlsbad Boundary
;:_: ·: carlsbad Quadrant
D CarlsbadMobilityHubs
D Carlsbad MGRAs
c:::J carlsbad Palomar MGRAs with
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D OS, Open Space
D R-15, Residential 8-15 du/ac
D R·4, Residential 0-4 du/ac
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~ VSC/OS, Visitor Commercial/Open
pace
MGRA: 14251
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU ~OTHER WARRANTIES ~MERCHANTABtl.lTV, FITNESS FOR PARTICULAR PURPOSE ANO/OR AN'f OTHER TYPE WHE°lHER EXPRESSED OR IMPLIED. fn no eventwH the Ctty
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, Including but not limited to lime, money~goodwfll. arisk,g from the use~ratlon or modffitation of the map. In U&lng thf8 map, uaer further 1QJee. to indemnify, defend. ~hold harmless the CRy of Carlsbad for any and an Rabfflty of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
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~ '1rl
N
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MGRA: 14265
mali
ment
for the accuracy or corr-of this map. THE FOREGOING WARRANTY 19, EXCUJSIVE ANO IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILllY, FITNESS FOR PARTICULAR PURPOSE AND/OR /WY OTHER TYPE WHETHER EXPRESSED OR IMPUEO. In no event
,, or any olher party, for any ro.. or damB11eo, oonaequenHal or olherwlae, In~ bUt not llmlted to lime, money, or gcodwlU, arising ln>m lhe use, operation or modilloatfon of the map, In U8lng lhla map, u .. , IUTther agree to indemnify, derend, and hold hllmlleaa lhe City of cartsl>ad for any and 01
of accuracy or correctneu of the map, or the uae of the map.
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(i) . .
N
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c:::::I Carlsbad Boundary
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MGRA: 17984
~ /
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The City of Carlsbad disclaims any responsibility for the ac~racy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE ANO IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED.ln~t shall the City
of Carlsbad become liabJe to users of this map, or any olhe party, for any loss or damages, consequential or otherwise, Including but not limited to lime, money, or goodwiU, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any an"a-a!Hlab]!!y of any nature arising out of or resulting from the lack of accur y or correctness of the map, or the use or the map.
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(i) . .
.
N
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0 0.02 0.04
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;-
c:::J Carlsbad Boundary
~: ·_, Carlsbad Quadrant
CJ CarlsbadMobilityHubs
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/
MGRA: 22902
/
//
//
Tha Clly of Carlsbad -any •-11>11KY re, Iha accuracy or OOrreclONS of this map. THE FOREGOING WARRAN"TY IS EXCLUSIVE ANO IN ueu OF AU. OTHER or Cllffllbad baoome flable to "'"''" of this map, or any olhe< party, tor any losa or damageo, oonsequenHal or othe!wlse. Including but not llmlted lo time, money. or gcoct,\fll. any natin arising out of or resulltng from the lack ot accuracy or correctneH of the map. or the use or the map.
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---~
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~::, Cartsbad Quadrant
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The City olcartsbad dlsclalma any !8$pOIISIJllllr lorthe accuracy or-oflhla maq,.
ofClltobad becom&-lo users ollhla ._, or any olher party, for any loss ordamagea. •nv nature arising out or or res.-ing from the facfc ol acouracy or OOITOdneu DI Iha map. or
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------
I
AND IN LIE'l7'0F AU. OTHER WARRAHTIESOR MERCHANTAIIIUTY, RTNE8S FOR PARTICPI-AA PURPOSE AND/OR Alt< OTHER lYPE WHETHER EXPRESSED OR IMPUED-In )Ip event-the Clly
lo time, money. orgood\,11. ariafng lnlm the use, --or-olthe map. In ~thlB map, -fllltheragrao lo lndemnlly, defend, and hold harmfes&theClly o1Carf&badlo1'(my ffll aff ~ of
0. ~
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c:::J Carlsbad Boundary
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c:::J Carlsbad Palomar MGRAs with
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The City or carlabacl -any r._..iblllly lorllle aocuracy Of --of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND~ LIEU OF ALL ~Atffll!B OR MERCI-IANTABII.ITY, FITNESS fOR PARTICIJlAR PURPOSE ANO/OR Atl< OTHER TYPE of Clllllbad become Pable lo IISll8 of this map, or any other party, for any losa or da-. OON9quenHal or otherw!ae. lnclUdlng blll not llmltl!d lo y.rne, money, or~-orlslng~ use, Qllelallon or modlficalion otthe map. In uaing 1111& map, .-fulther agree lo Indemnify, del'end, any neture arising out or or roaulllng from the lack ol aocunacy o, -of the map, or the use of Ille map.
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N
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~: "! Carlsbad Quadrant
D CarlsbadMobilityHubs
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c::J Carlsbad Palomar MGRAs with
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D R-1.5, Residential 0-1.5 du/ac
D R-15, Residential 8-15 du/ac
0 0.02 0.04 D R-4, Residential 0-4 du/ac -=== Miles
MGRA: 22917
The City or Cariabad dlsdaims any·~ for the 80CUf8"1' 0, -of this map. THE FOREGOING WARRPHTY IS EXCLUSIVE ANO IN LlEtJ 0F AU. OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE ANO/OR Af('/ OTHER TYPE WHETHER EJ<PR of Cal11bad -.io liable to users of this map, or any olher party. for any los8 or damageo, oonsaquenlial or olherwfse, lncludfng but not limlled to time, money, or goact.\111, iirlslng fn,m !he use, operation o, modllicalion of the mep. In using !his map, wer further agree to Indemnify, deftmd, and hold
any nature arising out of or resultlng from the lade of accurac:y or correctnen of the map, or the use of the map.
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~ ~
N
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N
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D OS, Open Space
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0 0.03 0.05 D VC, Visitor Commercial
Miles
MGRA: 22926
TheCtlyo!Carl9bldd-any ~ lorlhe
of Catllbed beoome Uabla to usera of this map, or any other pa1.7,,
,""I nature arising out or or rastang lroro Iha-of aocuraey or
-of this map. THE FOREGOING WARRNITY rs EXCLUSIVE AND IN LIEU OF ALL any fos& or~. oonsoquentlal or.-., lndudlng but notllmft4d lolfme, money, or orlhe map, er Hlo uae of the map.
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1YPE WHETHER EXPRESSED OR IMPUEO. In no -.t &flallllle Ctly ,, del'em:I. and hold harmleas Ille City of Callsbad for any and all llabfflly of
~ \l?I
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MGRA: 22928
IS EXCLUSIVE ANO IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABIUlY, FITNESS FOR PARTlCIJlAR PURPOSEANOIOR N« C1 , lnokldlng bUt notlmllod IDIJme, money. orgooch,411_ arllqf from llleuae, ~ or madlliGalion ollllemap. In ualng lllfa map. ,_furtheragn,e ta TYPE WHETHER 6XPRESSED OR IMPLIEO. In no evental1altha Cly
defend, and holdl1annfo&s lhe City of~ for any and 81.-Y of
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MGRA: 22930
of CO!llbtld becoma liable to use"' ol this map,'or a party, tor 11\j/ loss., damagea, connquenllal or otherwise, Including but not llmlted lo time, money, or Toa Cly of Ca-disdalma any reaponalblly~lho acc or-ofthia fflll>. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL
iffff nat..,. ariafng out of or l'Ollllllng from the I aacun,cy or -of the map. or tho -otlhe map.
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D PI, Planned Industrial
MGRA: 22931
aiisbad disdaims any ""'flOllell>II ror lhe acouraey or correclnoss of this map. Tl-tE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF AU. OTHER WARRANT1E8 OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR /,N'/OTHER iVPE WHElliER EXPRESSED OR IMPUl!O. In ""event lllatl lhe Clfy
of CIIT1llbad beoome liable to users 01 this map, or any other patty. far any loss or __ , oonsequenHal or otherwlae. lnoludlng but not llmlled to time, money, or goom,fll, arising tiom the use, ope.-. or morlffioBllon al lhe map, In Ullng this map, unr lwther agree to lndamnlly, defend, and hold harmles& the City 01 Carlsbad ror any and all llablllly or
any nalU111 arising out of or resulting from tho lad< of accuracy or t:Dl190lneaa or the map, er the uae of the map.
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D CarlsbadMobilityHubs
D Carlsbad MGRAs
c::::J Carlsbad Palomar MGRAs with
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CJ P,Public
D PI, Planned Industrial
D PI/0, Planned Industrial/Office
q natun, arising out of or resulllng ~om Ille lack of accuracy or-
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MGRA: 22933
WARRANTY IS EXCLUSIVE AND IN LIEU OF AU.OTHER W<\RRAN!lES OR MERCHANTABILITY. FITNESS FOR PARTICUI.AR PURPOSE AND/OR Afff OTHER lVPE WHETtER EXPRE8BEO OR IMPUED. In no event lhalthe Clly ·, lnolUding butnot lhriled tolllne, fflDl1IIII, orgo-, arisflvfft>mUle use, oi,en,Uonor modit!calon of Ille map. In U8lng lhlamap, uaer fllrlller agrealo Indemnify, delend, and hDld harmfes&the Clly a!Cerlsl!adfur any and all Rabllltyof
~
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~ •• ·_. Carlsbad Quadrant
D CarlsbadMobilityHubs
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General Plan Land Use
D OS, Open Space
D PI, Planned Industrial
D VC, Visitor Commercial
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MGRA: 22934
AND/OR >Hf OTHER TYPE WliETHl!R EXPREllSEDOR IMPUED. In no event-the Clly
U8el fulther -h> lndemnl!y, dalend, and hold harmless the Clly of Carlsbad !Or any and 1111 llal>lllty of
•,_J_
MGRA: 22936
8 C::, °'"'"'"""'""' Cl carlsbadMobilityHubs
D carlsbad MGRAs
c:::J Carlsbad Palomar MGRAs with
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N General Plan Land Use
A D OS, Open Space
c:J P,Public
D PI, Planned Industrial
0 0.01 0.03 D PI/O, Planned Industrial/Office I \ ~
Miles
The Clly of Carlsbad dlaolatms any ~ for lhe accuracy or -of this map. THE FOREGOING WARRANlY IS EXCWSIVE ANO IN LIEU OF AU. OTHER WARRANTIES OR MERCHANTABIUTY, FITNESS FOR PARTICULAR PURPOSE AND/OR Afi'/ OTHER 1VPE WHETHER EXPRESSED OR IMPLIED. In no -.t &hal the C,ty of Callobad become llable kl 111118 of tt1i9 map, or any other party, for any loss ordamageo, oonsequenlial or-, lnclUdlng but not..,_ kltllne, money. or~. arfslng fnlm lf1e use, _,,aon ormodilicalon of lhe map. In uai,g thla map, ...,fullhef agreo lo-mnl!y. defand, and hokl hefmfess the CRy of ~far any and al llalllllty or any nature arming out or or ""'ldllng lfom the lack of accul1IC\' or-of the map, or the use of !he map.
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D carlsbad MGRAs
CJ carlsbad Palomar MGRAs with
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General Plan Land Use
P, Public
D PI, Planned Industrial
MGRA: 22937
The City of Cartsbad dlsclalma any re&pon8lbBlly for the 8CCll"IICY or -olthiB map. 11-IE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL 011-IER WARRAHTieS OR MERCHANTAllll.llY, FITNESS FOR PARTICUI..AR PURPOSE niDIOR Alff OTHER TYPE WHETHER EXPRESSED OR IMPUEO. In no event -the Cly DI Calllbad become.-lo....,. ollhls map, orany olher porty, for any lo&s "'...,,_· oonsequential or olheroolae, lnoludlng but notllmlled lo 111nt,, money, orgoodwll, arisfng llom the use, --or-of the map. In Ullngthm _, .-ftnlher-i,ee lo lndomnlly, -.i, -hllld .__ the Clly of Cmlsbadfar any ond allllalllllty or any nature arising out DI or resulllng ln>m the-of accuracy or correclnesa olthe map. or the 111e of the map.
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i_ •• "j carlsbad Quadrant
CJ CarlsbadMobilityHubs
D Carlsbad MGRAs
MGRA: 22941
c::J carlsbad Palomar MGRAs with
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N General Plan Land Use
A D OS, Open Space
D PI, Planned Industrial
D R, Regional Commercial
0 0.02 0.04 CJ VC, Visitor Commercial
Miles
TheClly o1Carlabad-any,apol1llbllilylorlhe-.racy or or ClltlbOd beoome-to usaro ol Chlo ffllP. ·or any other parly, for an•
any nature arlalng out ol or rosulllog ft'om lho lack ol aocuracy or
ol 111ia map. THE FOREGOING WARRANlY IS EXCWSI\IE ANO IN LIBJ OF At.I. Oll!ER ordamagoo. consoquenllal or otherwlae, lnotllding but not llmlled to flme, RIDflllY, or goodwill,
.ollhe map. or Iha ... ol lhe map.
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PURPOSE AND/OR NfY OTHE.R TVPE WHETHER EXPRE88EO OR IMPUED. In no event-the Clly
mop. uaer IUrlher 111111ee ID Indemnify, defend, and lu>ld harmled lho City ol Carlabad for any and all~ ol
~ ~
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~: ~ carlsbad Quadrant
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D OS, Open Space
D PI, Planned Industrial
CJ VC, Visitor Commercial
MGRA: 22947
dledalma any rnponlil)lllly l'cr lhe-uracy 01 aorreclness olthla map. THE FOREGOING WARRAIITY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABIUTY, RTNE8$ FOR PARTICLILAR PURPOSE ANOtqR Atff OTHER TYPE WHETHER EXPRESSED OR IMPUED. In no event ""811 the Cl1y ,me liable lo uae .. of thle map, or any o1her pally, for any Ian or damages, aonuquenllal 01 olharwlse, Including but not llmbd ID time, money. 01 good'MII, arising I""" lhe -operaUon or modfflaalfon ol lhe map. In uol!lg thla ffllll, uaer IU!lher ljfaree ID lndemnlft, defend, and hOld harmlen 1he Cl1y of C8rlabad for any and llil llablltty of out of or mulling ~om lhe lackol """"""'I' or-ollhe map, or the use of lhe map.
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Carlsbad Palomar Mobility Hub MGRAs Near Airport
60 d8 cNE:L-
Notes
1. 2010 McClellan-Palomar Airport ALUCP Policy 3.3.3 prohibits residential uses on properties, or portions of properties,
with airport noise exposures greater than 65 dB CNEL.
2. 2010 McClellan-Palomar Airport ALUCP Policy 3.4.4 prohibits residential uses on properties, or portions of properties,
within airport safety zones 1, 2 and 5.
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c:::I MGRAs with 2016-2050
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c:::I Airport MGRA
ALUCP 2010 Safety Zones:
D Zone 1
D Zone2
D Zone3
D Zone4
D zones
D Zone6
' , T~ty of Carlsbad ai,c1aims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MEj~HANTABILITY, FITNESS FOR PARTICULAR PURPOSE ANO/OR ANY OTHER TYPE WHETHER EXPRESSED DR IMPLIED. In no event shall the City , ef Carlsbad become tiabi. to users of this map, or any other party, for any loss or damages,""Consequentlal or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using thls map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability ol any nature arising out of oi"J~Ulting from~ lack of accuracy or correctness of the map, or the use of the map. ~ ~ I
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Attachment 5
PLEASE NOTE: PRELIMINARY RIDERSHIP DATA-UNAUDITED AND SUBJECT TO ADJUSTMENTS
I Month COASTER· TOTAL RIDERSHIP
FY21 FY20 Variance %
July 10,263 149,515 (139,252) (93.1%)
Aug 9,412 133,482 (124,070) (92.9%)
Sept 10,020 114,233 (104,213) (91 .2%)
Oct 10,968 111,045 (100,077) (90.1%)
Nov 9,232 94,551 (85,319) (90.2%)
Dec 7,519 83,951 (76,432) (91.0%)
Jan 6,848 98,791 (91 ,943) (93.1%)
Feb 7,866 91 ,845 (83,979) (91.4%)
Mar 11 ,203 46,510 (35,307) (75.9%)
Apr 15,184 5,244 9,940 189.5%
May 19,214 6,207 13,007 209.6%
June** 44,978 8,734 36,244 415.0% **Not final as of July 19, 2021
YTDTotal 162,707 0 (781,401)
FY Total 162,707 944,108
I Month COASTER • WEEKDAY
FY21 FY20 Variance %
July 10,263 131,218 (120,955) {92.2%)
Aug 9,412 112,100 (102,688) (91 .6%)
Sept 10,020 92,159 (82,139) (89.1%)
Oct 10,968 105,601 (94,633) (89.6%)
Nov 9,232 80,912 (71 ,680) (88.6%)
Dec 7,519 75,534 (68,015) (90.0%)
Jan 6,848 89,920 (83,072) (92.4%)
Feb 7,866 84,613 (76,747) (90.7%)
Mar 11,203 44,368 (33,165) (74.7%)
Apr 15,184 5,244 9,940 189.5%
May 17,221 6,207 11,014 177.4%
June** 35,192 8,734 26,458 302.9% **Not final as of July 19, 2021
YTDTotal 150,928 0 (685,682)
FY Total 150,928 836,610
I Month COASTER-SATURDAY
FY21 FY20 Variance %
July -9,415 (9,415) (100.0%)
Aug -14,348 (14,348) (100.0%)
Sept -8,449 (8,449) (100.0%)
Oct -3,247 (3,247) (100.0%)
Nov -8,385 (8,385) (100.0%)
Dec -4,387 (4,387) (100.0%)
Jan -3,218 (3,218) (100.0%)
Feb -5,181 (5,181) (100.0%)
Mar -665 (665) (100.0%)
Apr -0 0
May 1,387 0 1,387
June** 5,881 0 5,881 **Not final as of July 19, 2021
YTDTotal 7,268 0 (50,027)
FY Total 7,268 57,295
I Month COASTER· SUNDAY
FY21 FY20 Variance %
July -8,882 (8,882) (100.0%)
Aug -7,034 (7,034) (100.0%)
Sept -13,625 (13,625) (100.0%)
Oct -2,197 (2,197) (100.0%)
Nov -5,254 {5,254) (100.0%)
Dec -4,030 {4,030) (100.0%)
Jan -5,653 (5,653) (100.0%)
Feb -2,051 (2,051) (100.0%)
Mar -1,477 (1 ,477) {100.0%)
Apr -0 0
May 606 0 606
June** 3,905 0 3,905 **Not final as of July 19, 2021
YTD Total 4,511 0 (45,692)
FY Total 4,511 50,203
ATTACHMENT 6-Project Data Request
Table 1: Proiect lnf1 tion R t
Estimated Current Draft RTP Assumed
Project Total Project Planned Year of Assumed Year Federal/State
Cost Construction of Construction Matching Funding (%)
San Dieguito Lagoon Double Track
and Platform
Batiquitos Lagoon Double Track and
Bridge Replacement
Eastbrook to Shell Double Track
Carlsbad Village Trench
La Costa to Swami Double Track
San Onofre Bridqe Replacements
Rose Canyon Bridqe Replacements ----. ---
ATTACHMENT 7-Detail of Proposed Rail Lines
Table 3: Detail of P d Rail L'
Average Interoperable
Rail Mode (CR, Directional % of Directional Number Distance Average with
LR, HSR, Miles Miles Grade of Between Speed COASTER
Hybrid) Separated/Tunnel Stations Stations Operated equipment
(Y/N)
New Rail Line
Sept. 30, 2021
San Diego Association of Governments
401 B street, Suite 800
San Diego, CA 92101
Via: SDForward@sandag.org
RE: City of Carlsbad Comments on Draft 2021 Regional Plan
To whom it may concern,
ATTACHMENT 2
(city of
Carlsbad
This letter serves to inform SANDAG that the City does not wish to remove project CB32 from
the Regional Arterials Project list.
Please disregard the comment rega rding project CB32 from the attached letter sent to SAN DAG
on Aug. 6, 2021.
Thank you for bringing this to ou r attention, and please contact me if you have any other
questions regarding the 2021 Regional Plan comment letter.
Best Regards,
Tom Frank, PE
Transportation Di rector/City Engi neer
Attachment A: Letter to SAN DAG dated Aug. 6, 2021 •
cc: Scott Chadwick, City Manager
Cel ia Brewer, City Attorney
Geoff Patnoe, Assista nt City Manager
Ron Kemp, Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public works
Mike Strong, Assistant Director, Community Development
Public Works Branch -Transportation Department
1635 Faraday Avenue I Ca rlsbad, CA 92008 I 760-602-2766
cc: Don Neu, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager
Jason Geldert, Engineering Manager
Eric Lardy, Principal Planner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Public Works Branch -Transportation Department
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2766
( City of
Carlsbad