HomeMy WebLinkAbout2022-05-26; Growth Management Citizens Committee; ; Committee BusinessCA Review ______
Meeting Date: May 26, 2022
To: Growth Management Citizens Committee
Staff Contact: Eric Lardy, Principal Planner
Eric.Lardy@carlsbadca.gov
Sarah Lemons, Communication & Engagement
Sarah.Lemons@carlsbadca.gov
Subject Committee Business
Recommended Action
Receive presentations from city staff and consultants and discuss the following topics:
•City of Carlsbad Budget. Receive a presentation from city staff on the city budget and
financing. (Staff contact: Zach Korach, Finance Director).
•Financing and Growth Management. Receive a presentation from city consultants on the
economic rationale for how jurisdictions approach growth management, basis for public
facility demand forecasts, and approaches to allocating fiscal costs of public facilities.
(Consultant: Nancy Bragado, Bragado Planning) (Exhibit 1)
•City Administrative Facilities Performance Standard. Receive a presentation from city staff
on current City Administration Facilities Performance Standards (background, current
status, funding source, and other considerations). Group discussion on the standards: Is this
standard important to quality of life in Carlsbad? Should this standard be re-evaluated in
any way? (Staff contact: Eric Lardy, Principal Planner) (Exhibit 2)
•Additional Growth Management Topics. Receive an update on what topics will be
addressed by city staff at future committee meetings and additional resources provided on
others.
Fiscal Analysis
This action has no fiscal impact.
Environmental Evaluation
In keeping with California Public Resources Code Section 21065, this action does not constitute a
“project” within the meaning of the California Environmental Quality Act in that it has no potential
to cause either a direct physical change in the environment, or a reasonably foreseeable indirect
physical change in the environment. Therefore, it does not require environmental review.
Public Notification and Outreach
This item was noticed in keeping with the Ralph M. Brown Act and it was available for public
viewing and review at least 72 hours before the scheduled meeting date.
Exhibits
1.Growth Management: Economic & Fiscal Considerations
2.City Administrative Facilities Performance Standard
GROWTH MANAGEMENT CITIZENS COMMITTEE @) Staff Report
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CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE
STAFF REPORT
May 26, 2022
Prepared by CITECON
Exhibit 1 – Growth Management: Economics & Fiscal Considerations
Economic Rationale for Growth Management
Many cities and counties with land use authority and responsibility for providing public facilities and
services to its citizens manage their growth to maintain a desired quality-of-life as expressed in their
comprehensive plans and policies.
Types of growth management plans can vary significantly, but the economic rationale is to achieve a
higher level of total public value or utility by managing and mitigating impacts (what economists may call
“externalities”) and their costs that decision-makers – people, developers, investors, public agencies, etc.
–may not account for on their own unless they must address these costs through fees, taxes, and
regulations.
For example, a large land developer will acquire property, obtain entitlements and financing, design and
engineer the site plan, provide infrastructure connections, prepare the land, construct, market the
development, and sell units to end builders and occupants, while providing sufficient returns to pay debt
and equity investors given the project’s risk. These costs are incurred by the people who benefit directly
from the development and are expected. Yet, the occupants of the development generate additional
indirect costs, such as off-site impacts to transportation networks, use of public facilities, public safety,
parks and open space, stormwater management, utility systems and water resources, air and other
environmental quality, etc., and the services to operate and maintain these systems. These costs are
shared with other developments and members of the broader public, including existing and future
residents, workers, and visitors.
If these costs are not estimated and assigned, development and their occupants may not factor them into
their decision-making. If they don’t, public benefits and quality-of-life values may be diminished. If they
do through growth management, not only are public facilities and benefits funded, but developers and
occupants will have an incentive to seek efficiencies, mitigate impacts and costs through design, plan for
co-benefits that reduce impacts and costs per unit, provide amenities that reduce their impacts and fees,
seek creative lower-cost substitutes and generally be more sustainable. Therefore, the economic purpose
of growth management is not just the provision of public facilities that mitigate impacts and enhance
public value, but to internalize public costs so that economic decision-makers, i.e., developers and
investors, recognize these costs and have an incentive to be more socially efficient in their planning,
engineering, design, and construction.
A challenge in structuring an effective growth management program is how to measure and allocate
public demand, benefits, and costs. There is no one standard model, but most systems rely on three
principles:
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•Transparent metrics for measuring quality-of-life objectives
•A rational and reasonable nexus to allocate costs and responsibilities to those who benefit
•A fair share allocation benefits and costs that does not disproportionately burden certain
populations or locations, and recognizes intentional subsidies put in place to achieve other public
policies and objectives
The City of Carlsbad’s Growth Management Plan has historically used these three principles to provide for
facilities costs and manage growth since it was established. But due to changing state laws and types of
growth the city will expect, it is time to re-evaluate the program, including the economics.
Basis for Public Facility Demand Forecasts
One factor that generates demand for public facilities is the population of a community. In the Carlsbad’s
Growth Management Plan, the standards for three public facilities (administrative facilities, libraries and
parks) are based on population demand. For example, the administrative facilities standard is 1,500
square feet per 1,000 population. Planning (siting, designing, financing) public facilities is done far in
advance of constructing the facility; therefore, it is helpful if the method to estimate future population
demand is consistent from year to year with limited variables. For Growth Management facility planning
purposes, the city’s method to estimate population demand is based on population data from the U.S.
Census – total population (114,746 per 2020 Census) divided by total residential units (47,734 per 2020
Census), which results in an average persons per dwelling (2.404). Every ten years, as the Census is
conducted, the city updates the population and persons per dwelling estimates for the next 10-year
period, usually occurring when results are available a couple years after the census is collected. The city
recently updated its population estimates in the FY 2020-2021 Growth Management Plan Status Report
to reflect the 2020 Census; the report updates the persons per dwelling to 2.404 (previously 2.358, per
the 20210 Census). When the 2.404 persons per dwelling is applied to the total current dwellings in
Carlsbad (46,694 per the FY 2020-2021 report), the current population estimate is 116,025, including
accessory dwellings and professional care facilities (note: the population information provided to the
committee in April 2021 is from the FY 2019-2020 calculation, which is based on the 2010 Census).
The city’s method to estimate population for public facility planning is transparent and easy to administer
consistently from year to year. Other methods of estimating population utilize a household size rather
than persons per total residential units. A household is defined as the number of “occupied” residential
units, not total residential units. Total residential units exceed households by a vacancy factor. For long
range planning purposes, the Carlsbad General Plan utilizes this household and vacancy factor method to
estimate what the total population will be when all residential land uses planned by the General Plan are
built (buildout). Using the General Plan method, Carlsbad’s buildout population is estimated to be
133,249, which includes changes in planned residential land uses since the 2015 General Plan was
adopted. This will be higher when the city completes the Housing Element Rezone program to add
approximately 2,700 units to the general plan.1
1 https://www.carlsbadca.gov/departments/community-development/planning/housing-plan-update
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Methods to estimate population vary among various sources. For example, the San Diego Association of
Governments (SANDAG) used a different method than the city when they conducted the most recent
Regional Transportation Plan.
Trends in population are also factored into future estimates. Based on the latest estimates for California
cities, it is not clear what the current trends will be for household population in coastal cities. Some
projections show reduced household populations in single-family homes in later years of demographic
projections. This committee will have additional information on demographics at a later meeting, and the
city will invite SANDAG demographers to a future meeting to share best available information on current
and future demographic trends.
In terms of vacancy rates, a healthy residential market, for example, would have a vacancy rate of say 5%
by convention, allowing enough vacant inventory to provide housing options for people looking for
homes, either for the first time in Carlsbad or to relocate from their current home (rental or for-sale).
According to CoStar, the 2022 Q2 vacancy rate for multi-family housing in San Diego county is 2.6%;
Carlsbad’s is 1.4%. Rate.com reports a 1.3% vacancy rate for ownership housing. These low vacancy rates
indicate a tight market and higher residential costs as demand exceeds available supply.
The Influence of Household Size
Average household size is the average number of people per household (occupied residential unit,
excluding group, institutional housing). There are several factors that influence household sizes, including
the number of families with children, age distribution of the population and head of households, culture
(some cultures value accommodating extended families and multiple generations out of choice than
others), income distribution, divorce rates, residential product types available, market supply shortages
that induce co-habitation and sometimes overcrowding, and other factors. No surprise that this
combination of variables changes over time.
While it would be challenging to consistently model changes in demand variables over time, the U.S.
Census does report average household size for multi-family (generally smaller than average), single-family
housing (generally larger than average), and the population living in group quarters, such as Institutional
(including correctional facilities, nursing homes, or mental hospitals), and Non-Institutional (including
education dormitories, military barracks, group homes, missions, or shelters). The detailed Census
estimates average household size by selected characteristics.
Demand forecasts for some public facilities are tied more to households and some to population. For
example, car ownership and travel demand may relate more to households than population. Demand for
parks and libraries may relate more to population.
While development impact fees under growth management are assessed on total new residential units,
vacant and occupied, actual demand is generated by occupied units or households. However, housing
occupancy fluctuates and, therefore, to ensure adequate public facilities for the population of all
residential units (existing and future), the city plans for facilities based on a population estimate that
utilizes an average persons per dwelling for all dwellings, as described above.
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Other Influences on Demand for Public Facilities
Other factors that influence demand for housing and therefore public facilities and services include
demographics, income distribution, seasonal vs. full-time housing inventory, location within the city, and
demand generated by visitors and people working in Carlsbad who are not residents.
The number of jobs within a jurisdiction is an important generator of housing demand, and therefore
demand for public facilities and services. Carlsbad has become an important and growing employment
center in the region, particularly in North County. Historically, Carlsbad has not developed fully the
number of residential units to potentially accommodate its job inventory, partly relying on other cities to
provide some of its workers’ housing needs, but Carlsbad’s ratio of homes to workers has improved
significantly over the past two decades. According to CITECON, based on the U.S. Census and Bureau of
Labor Statistics data as reported by YCharts, Carlsbad’s estimated ratio of occupied homes per job within
Carlsbad in the year 2000 was 0.68, well below the countywide average of 0.95. By the year 2022, it is
estimated that Carlsbad’s ratio has improved to 0.82, almost as high as the countywide average of 0.85.
Regionally, the ratio of homes to workers has fallen. While this may reflect an increase in workers per
household, this may also indicate a growing percentage of workers living outside the region in southern
Riverside County, southern Orange County, and Tijuana, to commute to their jobs in San Diego County.
As work habits enabled by communication technology evolves to a hybrid model for some sectors where
more people divide their workweek between working from home and at work, the percentage of workers
choosing to live outside the region for more affordable housing may continue to grow. Still, for growth
management in the future, including beyond the current Regional Housing Needs Assessment allocation
and Housing Element cycle, job growth in the city will be an increasingly important variable for housing
demand allocations, especially as State and Regional climate policies encourage more housing
opportunities closer to work centers to reduce average vehicle-miles-travelled and associated greenhouse
gas emissions.
Allocating Fiscal Costs
Growth management plans, including Carlsbad’s, tend to manage growth in two ways – total development
at “build-out” and over time. Both are tied to an estimated capacity given General Plan policies, public
facilities, and performance metrics. The notion of “buildout” implies that once the city achieves that
amount – or carrying capacity - and facilities are funded and provided, no more growth is to occur.
Development over time is tied to a policy of “concurrency” which means that adequate public facilities
must be provided per the growth management plan and a development phasing plan within a given period
before or after the granting of permits to ensure that the facilities are in place in time.
Development is capped in this fashion regardless of market demand. As explained in the April
memorandum, State law now prohibits residential caps at buildout and over time due to the declared
housing crisis. The Carlsbad City Council has amended its Growth Management Plan to comply. As a
practical matter, housing demand will likely continue to grow as the region’s and Carlsbad’s economies
grow, and more jobs are generated. While there are plenty of examples of cities that have lost jobs and
population – such as St. Louis, Detroit, and Gary for example – or cities in growth regions that naturally
grow slowly because of limited job growth within them – North San Diego County and Carlsbad are
expected to continue to grow over the next several decades according to the San Diego Association of
Governments (SANDAG) forecasts.
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There are two basic approaches for allocating costs – average and marginal.
Average Cost Approach
Carlsbad’s current Growth Management Plan cost allocation is generally an “average cost”
approach, common for growth management cities that are primarily developing greenfield land
(such as master plan developments) for the first time. Public facilities are planned, costs are
estimated, then costs are allocated to units over time, accounting for inflation, charged primarily
through impact fees and, for some facilities, special tax districts such as Mello-Roos Community
Facilities Districts. Developers may receive a credit against their fees if they finance and build the
required facility directly at the required standard. Developers may choose to do this if they are
able to provide a facility more efficiently. Since all development built the first time on a piece of
land benefits from the planned facilities, an average cost approach is common.
Marginal Cost Approach
Another method is a “marginal cost” approach. This is more common in older growth
management cities that are experiencing growth primarily through redevelopment and targeted
infill development of properties that had already been developed. Redeveloped properties are
often changing uses, say from an obsolete commercial or light industrial use to a residential
mixed-use, are intensifying use of an existing building, say the adaptive reuse of a building
originally built for another purpose, or are intensifying the use, say by utilizing surface parking to
build higher density housing with structured parking.
In these situations, the amount of development in a community relative to the existing supply is
often small, say less than 1 percent, in any given year. Demand for public facilities at the margin
may be lower or higher depending on the context and the prior average cost approach may not
be accurate. For these, an evaluation of marginal costs may be a more appropriate method.
Even if costs are accurately calibrated, the revenues accumulated from infill and redevelopment
in some communities may not be sufficient except over a long period of time or if a major
redevelopment project is undertaken in a low-density area. The City of San Diego has this issue
with park fees collected at a community level in its older community plan areas. In this case, cities
sometimes choose to expand the geographic area in which fees collected may be spent.
A Combined Tier Approach?
A city such as Carlsbad that is still building its last phases of its first generation of development,
to be followed by additional development after the original buildout number is reached, may
consider a combined two-tiered method for allocating costs. A first tier in accordance with the
original Growth Management Plan’s average cost allocation approach, and a second tier in
accordance with a new marginal cost approach for growth occurring after the original buildout
number is reached, one that plans for greater cost efficiencies for marginal growth.
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Importance of Standards
Costs are estimated for the public facilities planned. The public facilities planned are tied to performance
standards. Therefore, standards have a direct influence on costs. There is no one set of standards used
by all jurisdictions; each determine their standards based on their contexts and priorities. Most standards
are tied to a jurisdiction’s comprehensive or general plan, technical requirements for facility performance
and engineering, compliance with local, state, and federal regulations, and other policies and strategies,
such as climate action plans, economic development strategies, and health and safety objectives. The
city’s existing 11 performance standards relate back to things the city directly controls and measures in
its general plan, but also includes things (such as schools) that the city doesn’t directly control and have
other fee programs (such as school fees) and funding allocation (through portions of property taxes).
Influences on these standards and costs include, but are not limited to, the following:
•Geography served – facilities that serve a larger geography may incur higher costs due to size, but
may have more sources of funding that reduces cost per payer
•Development patterns – more compact development tends to reduce costs per unit, such as for
lane-miles of roads or water consumption, and enable more active mobility such as walking and
biking that increases costs for bike and pedestrian facilities but reduces costs for roads
•Plan & design efficiencies – designs that maintain solar access to reduce heating requirements, or
shading to reduce air-conditioning requirements may enable greater use of passive energy
sources and reduce energy demand per household or capita
•Location efficiencies – more development near transit corridors connected to job centers or
housing within employment centers may reduce vehicle trips and road demand
•Co-benefits – designing linear open space corridors and parks to serve stormwater management,
habitat provision, and trails that connect to the broader circulation system may address multiple
public facility needs with the same right-of-way, or combining libraries and recreation centers
may have building and land cost efficiencies
•Equity – fair distribution of public facilities, such as parks, libraries, bike lanes and sidewalks may
reduce trips and enhance access to healthier living patterns, potentially reducing public health
costs in the long-run
As the city evaluates its future growth management, an opportunity exists to revisit standards that create
greater efficiencies and benefits.
Sources of Fiscal Funding
Growth generates fiscal impacts for 1) Capital improvements, and 2) Ongoing operations & maintenance
of those improvements and public services. In addition to providing funding through conventional means
(such as indirect increases in property and sales tax) growth directly can provide services through:
Impact Fees
The primary source of funding growth management capital improvements in California are impact fees,
enabled through the Mitigation Fee Act (1987), assigned to internalize and mitigate the costs of off-site
impacts and proportional demands for public facilities. The assessment of impact fees requires a nexus
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analysis, (per Gov. Code §66001(a) and (b)), the methodology of which is proscribed in California under
AB602 (2021). The nexus is the relationship between what the payer pays and their share of benefit that
is “roughly proportional” based on the Supreme Court ruling in Nollan vs. California Coastal Commission
and Dolan vs. City of Tigard. Consequently, costs cannot be apportioned based on ability to pay or
property valuation and cannot charge new growth to fund deficits to serve existing population/units.
Mello-Roos Community Facilities Districts
Another source often used are Mello-Roos Community Facility Districts (CFDs), special tax districts that
can apply to both capital costs and specified operations & maintenance expenses, enabled by the Mello-
Roos Community Facilities Act of 1982. While CFDs may be formed by voters in existing communities,
they are more commonly used for infrastructure to support greenfield developments, or a few targeted
sites, given that it is easier to conduct formation when there are fewer than 12 property owners. In this
case, the vote is by acreage; therefore, the owners of larger properties within the district can ensure
adoption. CFDs may also be dis-contiguous parcels and formed with other jurisdictions with a Joint-
Powers Agreement.
Carlsbad uses both Impact Fees and CFDs. CFD 1 funds civic facilities, street system improvements, and
interstate interchanges that benefit a large portion, but not all, of the city. CFD 3 Improvement Areas 1
& 2 fund drainage, landscaping, sewer, street, street lighting, utility, and water improvements for a
smaller area.
Assessment Districts
Assessment districts are formed to fund specific public improvements and require a more direct link
between the benefit and assessment paid than some other mechanisms. Carlsbad utilizes Lighting and
Landscape Districts and Benefit Assessment Districts to fund certain public improvements and their
maintenance. These fund streetscape, medians, sidewalks, street lighting and landscaping to enhance the
city’s urban design and safety. Combined, the two districts cover most of the city. Carlsbad also formed
Benefit Area No. 1 – Buena Vista Channel Maintenance District to manage drainage into the Buena Vista
Lagoon.
Other Mechanisms
While jurisdictions in other states often fund community infrastructure with property tax assessments,
Proposition 13’s limitation on annual increases in property tax assessments discourage use of property
taxes for these purposes. Cities in California generally use their property tax revenue to fund city general
fund operations.
Other funding mechanisms for public facilities are used in California, such as general obligation bonds,
other special tax districts, tax increment, business improvement districts, benefit assessments, special
purpose taxes, state and federal grants and subventions (such as gas tax dollars), negotiated or formula-
based value capture techniques, tax sharing agreements, joint power authorities, public-private-
partnership (P3) financing, revenue bonds and certificates-of-participation, and other sources. Most of
the tax-based mechanisms require voter approval, a super majority if proposed by the government for a
specific purpose or facility, simple majority if proposed by citizens referendum. Enhanced Infrastructure
Financing tax increment districts (EIFDs) is a form of tax increment used in a few places, such as the City
of San Diego’s border area and West Sacramento’s river corridor, but, unlike previous California
Redevelopment, requires other taxing jurisdictions to agree to participate rather than collect tax
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increment by formula. Tools such as negotiated development agreements, value capture mechanisms
such as incentive zoning, and P3 financing are contractual arrangements entered into voluntarily and
generally can be established by City Council action after a public hearing process.
While most of these mechanisms fund capital improvements, some have the flexibility or specific purpose
to fund operations & maintenance. Typically, a city’s general fund revenues from property taxes, sales
taxes, transient-occupancy taxes, state grants, and user fees cover most general fund costs of government
services, operations & maintenance.
Which mechanisms to consider that would augment the city’s Growth Management program going
forward will be discussed in more detail at future committee meetings that focus on developing strategy
recommendations.
Influence on Land Values
In allocating costs to establish impact fees, special taxes, or other mechanisms, an important
consideration is how the fees may affect housing and land values. One opinion is that higher impact fees
increase the cost of housing as costs are passed on to the homebuyer or renter. Another opinion is that
developers already price homes as high as the market will bear, and that rather than increase prices
further to cover higher fees, developers re-calculate the residual land value associated with higher fees
and reduce the amount they are willing to pay the original owner of the property they would like to
develop. Consequently, land values adjust.
Timing is a consideration. Developers who have already purchased their land do not have the option to
pay less unless it’s a term in their purchase or option agreement. Developers who have not yet purchased
a property can adjust what they are willing to pay, but if it drops below what the property owner is willing
to accept, the property owner may choose not to sell, reducing the inventory of land to increase housing
supply. For these reasons, some jurisdictions phase in increases in impact fees, say over a two to three-
year period, so as not to penalize developers that have already purchased their property to redevelop.
Countering these potential downward pressures on property values, or market acceptance of higher home
and rental prices, is the value of benefits derived from the public facility improvements made.
Conclusion
There are many ways to establish funding programs and establish structures for development to provide
capital and ongoing resources. They need to be specifically adapted for each organization’s context since
their economic tax base, future development, employment, and political will all vary. These are
considerations and topics that can be discussed in more detail during conversations about the existing 11
Performance Standards, and future standards that may be recommended to the City Council.
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CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE
STAFF REPORT – Exhibit 2
May 26, 2022
City Administrative Facilities
1,500 sq. ft. per 1,000 population must be scheduled for construction within a five-year
period or prior to construction of 6,250 dwelling units, beginning at the time the need is
first identified.
BACKGROUND
The origin of the city administrative facilities standard, and other facility standards, dates back to the early
1980s. A precursor to the Growth Management Plan was City Council Policy No. 32 Public Facilities
Management System (adopted in 1982), which established the initial facility standards for various
facilities, including administrative facilities. Per the policy, a minimum of 115,000 square feet was needed
to serve a target population of 100,000 (1,150 sq. ft. per 1,000 population). That standard was established
by estimating the number of city employees needed to serve a target population size and then estimating
the amount of administrative facility space needed for the employees. When the Growth Management
Plan and Citywide Facilities and Improvements Plan were adopted in 1986, the administrative facilities
standard was updated to what it is today.
FACILITY PERFORMANCE ANALYSIS
Based on the most recent population estimate (June 30, 2021) of 116,025, the current demand for
administrative facilities is 174,038 square feet. To date, city administrative facilities exceed the
performance standard. The existing inventory of city and Carlsbad Municipal Water District buildings
(leased and owned) occupied for administrative services are included in Table 7:
Facility Address Square
Feet
City Hall Complex 1200 Carlsbad Village Drive 16,000
Faraday Administration Building 1635 Faraday Ave. 68,000
Fleet Service Center 2480 Impala Drive 10,540
Water District (Maintenance & Operations) 5950 El Camino Real 18,212
Parks Yard (Maintenance & Operations) 1166 Carlsbad Village Drive 4,012
Public Works Operations 405 Oak Ave. 9,950
Safety Center (Police and Fire administration) 2560 Orion Way 55,027
First Responder Safety Training Center 5750 Orion Way 15,090
Senior Center (Parks & Recreation administration) 799 Pine Ave. 5,770
Harding Community Center (Parks & Recreation administration) 3096 Harding St. 1,335
Total 203,936
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Buildout Facility Adequacy Analysis
Based on the current General Plan residential land use designations, the projected buildout population is
133,249, the demand for city administrative facilities will be 199,874 square feet. The existing 203,936
square feet of administrative facilities exceeds the growth management performance standard at
buildout and there are current projects that will impact and provide additional space once completed.
•New Orion Center Project
A development proposal is underway for the Orion Center project, which will centralize the
city’s maintenance and operations functions into a single location on Orion Way. The goal for
the facility is to accommodate the existing and future needs for the following departments:
Public Works (Utilities/CMWD, General Services and Construction Management & Inspection)
and Parks & Recreation (Parks Maintenance). The proposed project will free up three existing
city facilities for redevelopment: 5950 El Camino Real, 405 Oak Street, and 1166 Carlsbad
Village Drive. The new buildings will provide 85,320 square feet of administrative space, which
will be a net increase of 53,146 square feet over the three existing sites which will no longer
be needed.
•New City Hall Project
The City of Carlsbad currently operates out of more than a dozen locations, some of which
are approaching the end of their useful life. Having most city staff in one location will make
doing city business more efficient for workers and the community. That’s why the city is
planning a new consolidated city hall where the main administrative functions of the city
could operate out of one location that also provides better meeting spaces including a larger
City Council chamber and shared indoor and/or outdoor community spaces.
The new city hall project is in the process of identifying spatial requirements for city staff to
determine the size of the new city hall, and site criteria to determine which of four potential
locations is best suited for the new city hall and civic center. The initial project has three
phases, including the 1) Space Needs Analysis Report, 2) Site Criteria Evaluation, and 3) Best
Professional Recommendation. The City Council approved Phases 1 and 2 on September 17,
2019, with the third phase anticipated to be presented to City Council by the end of June
2022.
OTHER STANDARDS AND JURIDICTION REVIEWS
This is a performance standard that is unique to the City of Carlsbad. While there are many regulations
that describe how to construct a building and requirements when one is chosen (such as requirements
for LEED construction). Additionally, it is not clear what the changes in the workforce will be that continue
to occur coming out of the pandemic environment. Many cities have goals to reduce footprints and have
alternative schedules for the positive impacts to reduce greenhouse gas emissions. Technology changes
have also occurred in recent years, shifting more services online. The future for the demands for this
metric is unclear.
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Date: April 26, 2022
To: Growth Management Citizens Committee (and members of the public)
From: Steve Linke, Traffic & Mobility Commission Vice-Chair and Growth Management Citizens
Committee primary member
Subject: April 28, 2022 Growth Management Citizens Committee Meeting written comments
Given time limitations of large committee meetings like ours, this communication is intended to provide
some recommendations and questions/suggested future topics. Following those, I provide some
background, history, and concerns that put them into context. I will detail additional concerns and
consequences in communications for future meetings.
Recommendations and questions/suggested future topics
Recommendation: Our committee should ensure that validated measurement methods and Growth
Management Plan (GMP) performance standards that reflect reality are locked down for all public
facilities—not methods that can be continually tweaked to artificially achieve success.
Recommendation: Exemption of any public facilities from a GMP performance standard should require a
proportional alternative mitigation plan with identified funding and a timeline—not simple
abandonment.
Recommendation: If we move away from the “performance standard” system, any new system should
be overtly mandatory and not include soft language that implies voluntary compliance.
Recommendation: Impact fees/programs (e.g., traffic impact), housing fees, and other developer costs,
like review and permitting fees, have been allowed to sit without meaningful updates for extended
periods of time. These should be considered globally with the GMP and updated regularly to reflect
current needs and costs.
Question or suggested future topic: The new state laws that prevent residential development moratoria
have a sunset clause, and they do not seemingly prevent commercial development moratoria. They also
continue to allow various impact fees. How can these be used to maximize GMP requirements?
Question or suggested future topic: Please explain the protocol staff uses to determine a “nexus”
between a development project and its obligation to fund a public facility improvement, as well as the
method used to calculate its “proportional funding.”
Question or suggested future topic: Given the fact that the vast majority of remaining development in
Carlsbad will be “in-fill” (rather than “vacant land”), and the fact that in-fill projects are largely being
exempted from having to conduct GMP and CEQA studies—combined with the alleged difficulty in
making a funding “nexus”—what are the prospects of the funding of the various public facilities by
future development, and how can GMP requirements be maximized?
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Background
One of the eleven public facilities included in the GMP is circulation (also known as traffic,
transportation, streets, or mobility), which currently includes vehicle, pedestrian, bicycle, and transit
modes of travel. I have been studying this topic for over a decade, and I have spent the last three years
on the Traffic & Mobility Commission intent on reforming the transportation review process in Carlsbad.
I also have reviewed the GMP and CEQA transportation portions of all development applications and
City projects over the past three years. My comments here are focused on transportation, but the
concepts may apply more generally to other facilities, as well.
The performance measure for circulation is called level of service (LOS). Generally, LOS is reported for
each street segment (facility) on a scale of “A” through “F”—calculated from the volume of vehicles
relative to the capacity of the street, or the average length of time it takes vehicles to traverse an
intersection or street corridor—the worse the congestion, the lower the grade. An LOS grade of “D”
during peak hours is required to achieve the minimum GMP performance standard.
The way the GMP is supposed to work for circulation is that, when a development project is proposed, a
transportation impact study predicts the direct impacts the project will have on the LOS of nearby
street/mobility facilities. The approval of the project is then supposed to be conditioned upon funding
any improvements necessary to maintain the minimum LOS standard, such as street widening,
intersection improvements, etc.
In addition, the City is required by the GMP to conduct its own annual LOS assessments (the Traffic
Monitoring Program) to prospectively identify emerging problems that arise due to the cumulative,
indirect impacts of developments on the overall citywide mobility network. These results are supposed
to be used to add additional mobility projects and the associated costs to the City’s Traffic Impact Fee
(TIF) Program, which is intertwined with the GMP. A separate traffic impact fee is then charged to all
developers based on the type of development (residential vs. commercial) and the number of vehicle
trips they generate, in order to fund the TIF Program projects to help maintain the minimum GMP
standard citywide.
Further, if annual monitoring reveals a facility that is already deficient (fails to meet the minimum GMP
standard of LOS “D”), then there is supposed to be a moratorium on all development in the
corresponding zone until a mobility project that will address the deficiency is identified and has an
approved plan, funding, and timeline.
Troubled history of Carlsbad’s vehicle LOS performance standard
Back in 1988, when the GMP was first being implemented, a group of transportation experts developed
guidelines for Carlsbad to calculate vehicle LOS. The guidelines were derived from the Highway Capacity
Manual (HCM), the gold standard reference for transportation engineers based on decades of research
and validation, with additional tuning to Carlsbad’s suburban streets. In 1989, Carlsbad’s “Citizens
Committee to Study Growth,” an early predecessor to our committee, reviewed and recommended
those guidelines.
3
Unfortunately, staff ignored the recommendation of the citizens committee and never used the
validated vehicle LOS guidelines. Instead, they created their own custom methods that included
exaggerated capacities for all of Carlsbad’s streets and intersections, and which vastly under-estimated
congestion.1
Consultants included a disclaimer in their first several annual traffic monitoring reports from 1989 into
the early 1990s, pointing out the severe limitations of the methods. In 1993-94 and 2000, traffic
consultants suggested reducing the exaggerated capacities or using an HCM-based method to get more
accurate results. In 2011, I also presented extensive data at public meetings demonstrating the
inaccuracy of the methods. In spite of all of this, staff continued to use their inaccurate methods
through 2018 when presenting traffic data to the traffic commission and council.
The 2015 General Plan Update (GPU) required a switch to valid vehicle LOS methods based on the HCM,
and multiple traffic consultants have now re-confirmed that Carlsbad’s old vehicle LOS methods had not
reflected reality by under-estimating congestion. After avoiding required vehicle LOS monitoring for a
few years, a valid HCM-based method was finally established in 2018 and phased in slowly over the next
few years.
Not surprisingly, we went from all street facilities meeting the minimum GMP performance standard
(LOS “A” through “D”) with the old Carlsbad methods to having 30+ street facilities identified as GMP-
deficient (LOS “E” or “F”) with the valid method—a reality that drivers see every day during peak hours.
These deficiencies actually started accumulating back around 2008 and really started accelerating
around 2012.
Funding for street projects and/or alternative strategies to address these emerging deficiencies could
have been secured by adding them to the TIF Program. However, the inaccurate LOS methods masked
the deficiencies, and there was a failure to regularly update the TIF project list—despite a requirement
in the Municipal Code, and despite previous warnings by council that it would unduly burden future
taxpayers with the impacts of developments. I will address this topic more in the future.
The staff report for Thursday’s meeting claims that the circulation system is meeting the GMP
performance standard (page 5), but that is extremely misleading. The only way it is being met is because
the City Council has “exempted” those 30+ street facilities from having to meet the performance
standard as each deficiency is reported to them. The adoption of the exemption process effectively
means that there is no longer any GMP vehicle LOS performance standard.
Troubled history of the pedestrian, bicycle, and transit LOS standards
The 2015 GPU also introduced a new system to measure LOS for pedestrian, bicycle, and transit travel
on streets newly prioritized for those modes—called multimodal level of service (MMLOS). Vehicle LOS
tends to degrade over time as growth occurs and vehicle volumes increase, allowing anticipation of the
1 For those curious and adventurous enough to delve deep into the weeds on this topic, see my 7/9/2019 letter to
the City Council at tinyurl.com/yckpt9k9.
4
need for developers and/or the City to fund improvement projects to increase street/turn lane capacity
over time. In contrast, MMLOS is determined from a point system based on amenities or quality (e.g.,
sidewalk width, buffers for bike lanes, bus stop benches, safety lighting, etc.)—regardless of whether
there are any changes in the numbers of users.
The unintended consequence of this approach is that all pedestrian, bicycle, and transit facility GMP
deficiencies across the city will suddenly pop into existence immediately upon the first annual
monitoring. And, as the staff report states: “…development cannot be required to pay for existing
deficiencies.” Therefore, the city itself would be on the hook to fund all projects to achieve the
minimum GMP standards all at once.
I pointed out this fatal flaw in the approach in conversations and letters with staff during the public
review period leading up to the 2015 GPU, but I was assured it would work. It did not. It has been over
six years since adoption of the GPU that added a requirement for MMLOS monitoring, but no such
monitoring has been included in any GMP annual reports. The City even claimed recently that it was
never their intent to maintain LOS “D” as part of monitoring, even though that intent seems very clear in
the GPU and its public review.
Although there has been no annual city monitoring, preliminary MMLOS point systems have been
applied to development applications for the last few years. However, similar to the old vehicle LOS
methods, they are largely designed not to fail, and they have been modified multiple times without
public review. One example is that the transit LOS point system was modified to award the minimum 60
points necessary to achieve LOS “D” simply based on the City’s adoption of a Transportation Demand
Management (TDM) ordinance, even though that ordinance does little to nothing to improve transit
conditions. It is simply a workaround to get a passing grade to meet the minimum GMP performance
standard.
The outcome of all this is that few pedestrian and transit upgrades have been funded by developers,
except a few limited sidewalk gap closures and bus stop benches, and no bicycle upgrades have been
funded. Staff also has added that a “nexus” cannot be established for the developments to fund such
projects in most cases, but there has been no explanation on how staff makes their nexus
determinations or how “proportional funding” is determined.
The Traffic & Mobility Commission has been working with staff on the MMLOS system for the last couple
of years, and it might be addressed again at our commission meeting next week, but the outcome is
uncertain.
From:Growth Management Committee
To:descor2002
Subject:RE: 1300 housing units planned for north carlsbad??
Date:Thursday, May 26, 2022 9:48:38 AM
Mr. Correia,
Thank you for your inquiry. On Feb. 15, 2022, the City Council directed staff to study two maps that
identified potential sites throughout Carlsbad for new housing. The maps include sites in the
northwest quadrant (north of Palomar Airport Road and west of El Camino Real) and the northeast
quadrant (north of Palomar Airport Road and east of El Camino Real). If all the sites identified on the
maps are developed residentially, staff estimates up to 1,730 new homes could be built in the
northwest quadrant and 668 new homes could be constructed in the northeast quadrant. The
majority of these would be built at densities considered appropriate for persons with lower incomes.
By state law, the city must identify sites throughout the city to accommodate housing at all
affordability levels. The number of units to accommodate are forecasted by the state and distributed
to Carlsbad and other San Diego jurisdictions by the San Diego Association of Governments.
In 2023, the City Council is expected to consider staff recommendations to redesignate sites to
accommodate much of the new housing (some of the identified sites already have appropriate
designations). If the City Council acts to redesignate them, the action will simply result in approval of
appropriate land use and zoning designations to permit residential development. It will then be up
to developers to actually propose projects and construct homes on the site. The actual number of
units built and their affordability will likely vary from staff’s estimates when and if actual projects are
submitted. We expect, for example, that only 15-20% of the new housing built will be affordable to
persons with lower incomes.
As far as your question about managed growth, state law prohibits the city from applying limitations
on the number of homes that can be built in Carlsbad. This prohibition affects the dwelling unit caps
established for each city quadrant by the Growth Management Plan (GMP). While the law precludes
the city’s ability to enforce the caps, it does not affect other GMP provisions, such as those
establishing standards for traffic, sewer capacity, and fire response times. City staff is studying the
impacts of the new housing, including on infrastructure such as water and sewer, and will present
that information when the City Council considers redesignating sites in 2023.
More information on housing, relevant state laws and the city’s effort to address them is available at
https://www.carlsbadca.gov/departments/community-development/planning/housing-plan-update.
The Feb. 15, 2022, City Council staff report on potential housing sites to accommodate the new
housing is also available at https://records.carlsbadca.gov/WebLink/DocView.aspx?
id=6247842&dbid=0&repo=CityofCarlsbad&searchid=ee00bd5c-101f-4029-a13c-80b848933595.
If you have any questions on the housing plan, please contact Scott Donnell, Senior Planner at
scott.donnell@carlsbadca.gov. Additional information on the Growth Management Committee and
future meeting agendas is available here: https://www.carlsbadca.gov/city-hall/meetings-
agendas/boards-commissions/growth-management-committee.
From: descor2002 <descor2002@yahoo.com>
Sent: Tuesday, May 24, 2022 11:46 AM
To: Growth Management Committee <Committee@carlsbadca.gov>
Subject: 1300 housing units planned for north carlsbad??
Hi,
Is there any update on whether or not 1300 very low/low income housing units are planned for north
carlsbad?
Thats an incredibly high number...is this true? How is this managed growth if this is true?
thank you.
Desmond Correia
617 256 4885
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From:phillip rogul
To:Growth Management Committee
Subject:A Carlsbad Resident"s personal comments for todays Growth Management Citizens Committee meeting today @
5pm @ Faraday Admin Center
Date:Thursday, May 26, 2022 10:29:25 AM
I am a local Carlsbad resident, who arrived here (fortuitously) from ST Louis Misery in 1978.
I’m presently the chair of the Carlsbad Sustainability Coalition - established in 2008 by Carlsbad residents Jay
Klopfenstein and Don Christiansen. CSC functions to build on the original work of City of Carlsbad’s program
“Envision Carlsbad”, which brought together local citizens (about 50-70) to work with city staff to identify the
community’s hopes and aspirations for the future of Carlsbad back in 2006-2007.
Our CSC has refocused that original mission to directly address the most critical issue facing our world - the
acceleration of global warming. We are continuing to explore what we can and should do here locally in Carlsbad to
catalyze the implementation of renewable energy systems. Building local renewable energy systems are crucial to
help us transition away from the widespread use of fossil fuels causing global warming.
I would like to strongly encourage this committee to consider our community as a potential center for distributed
renewable energy via implementing this proposed 40-acre Maerkle Reservoir solar energy project.
With the recent adoption of “community choice energy” which is now called our Clean Energy Alliance, we have
the perfectly positioned piece of city-owned property which is ideal for the building of locally generated renewable
solar energy. A project such as this proposed local Maerkle reservoir has been considered (over the last decade) as
an ideal site for solar energy production . I’d like to please encourage this committee to strongly encourage our City
Council & Staff to fully support this effort.
A local renewable energy expert and friend, Dr Phil Watts, has developed a comprehensive plan for the
development of this particular reservoir site. Please review and consider his professional approach, which provides
for the financing of this project along with his recommended engineering strategy .
City of Carlsbad has often proclaimed their “world class leadership" over a wide range of important areas of
concern. This Maerkle Reservoir project offers our city an excellent opportunity to step forward and be the actual
SD County renewable energy leader in this most critical moment of global warming.
Thanks so much for your time, and your continuing work on this committee.
Sincerely yours,
Phil Rogul
Carlsbad Sustainability Coalition - since 2008
760-804-1870
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II n ,magine
mi1 carlsbad
CARLSBAD'S NEW CITY HALL / CIVIC CENTER
Geo-Centric or Historic Heart
Jan 1 2021
Ask pretty much anyone, they will say Carlsbad is a very nice place. People
from other areas usually say "you are fortunate if Carlsbad is where you call
home. To continue that status the City Council now has a major question
needing to be answered. That question is where to place our new and
final City Hall and how to also make it a Civic Center. Not an easy
decision so we ask that the following input be considered. We all know the
City has been defined on paper as having four different zip code quadrants
separated by our two largest roadways. It is now defined by four voting
districts mostly cutting east to west. We also know that the major
residential areas are positioned north and south generally separated by
the airport and its influence on adjacent land uses. We know that the vast
majority of Carlsbad was laid out and built under the land planning model of
"suburban-ization" This doctrine came about in the early 1950s. It's where
all different land uses are separated in their own areas. This separation was
meant to reduce the possible conflicts between different uses which had been
somewhat common up to that time. This separation requires one additional
element that would make it possible for this new form of town planning. It
requires a full network of roadways for the automobile to tie all areas together
into a workable land use fabric. However, one area of Carlsbad is different
as it was laid out and built under a different land planning program now
referred to as "Traditional Town Planning". That area was the city's
starting point, a start that took place much earlier. Its planning program built
a relatively small multi-use core area on a tight grid of Main Street type
thoroughfares. This gives that area, the Village-Barrio, a different and
unique character in all of Carlsbad.
Now the question of where to put our City Hall. An opportunity to create
a new Flagship facility with civic amenities that will be embraced as a proud
symbol representing our community. It should be a model of City government
efficiency and professionalism. A symbolic element that reinforces its
general location as a "point of focus" for the community, a Town Center.
CITY HALL -2 AREA LOCATIONS/ 4 CANDIDATE SITES Jan 1 2021
MID CITY -Two sites that are geo-centric to be more equal distant from both
south and north areas of town.
NORTH WEST CORNER-The two sites that will support of the City's Historic
Heart Neighborhood (the Village/ South Village -our Historic Barrio).
OUR CRITERIA FOR EVALUATING THESE POTENTIAL SITES * City Hall as a highly productive and stimulating work place environment * · Accessability for Employees, Business Guest & the Community * Presences/Imagery -A Flagship facility with high visibility that
represents our community Pride * Civic Amenities for the community * Its relationships with its surrounding area Synergy & Symbiotic
(2+2=5)
Back to Carlsbad being a great place to live. Taking this as a given can we
now pause and reflect on all that we have, all that we done but also do some
objective evaluation of what we may have missed, what we may be
lacking? This review should influence the evaluation of where our ultimate
City Hall should be placed. What ingredient might be needed to strengthen
our community, to its sense of place, its sense of identity and pride. The
element that should have come out of that objective evaluation as missing is
a Town Center. As far as we know a Town Center has never been put on
any map, never been part of any plan in all of our town planning. We submit
that a recognizable Town Center is very important to a city the size of
Carlsbad adding to our community's sense of place, identity and pride.
All along our town planning journey we have had the "Historic Heart",
the starting point of town but we really never saw the need to fully wrap
our arms around it. To elevate it as our point of focus for the full community
as a recognized Town Center. "It is up there in the far corner", "shouldn't a
town center be in the center of town?" It's our starting point and hence it was
logically located on the coast line, on the regional highway, on the rail line.
Yes today it is the NW corner of our town just one of the city's four corners.
The flip side of this can be expressed in one word, "Car-nitas". This term, we
have heard, is used by some who live in south Carlsbad but have a Encinitas
state of mind. Why do these people relate more to Encinitas, certainly it has
nothing to do with their City Hall.
Page 2
However, this should be seen as a tear in our community's fabric of
cohesiveness and belonging. Some believe the fix is to place our "seat of
power" the City Hall in the center of town so it is seen as equal in its reach and
representation. "That makes sense on paper", as they say, if centered it is
equal right?. However the next question is, does that get us where we should
want to be, is it really just that simple, we think not. Rarely is a City Hall on
its own a Town Center, an important part yes but as a stand alone facility it
is hard pressed to pull that kind of weight. Make it a Civic Center by adding
civic amenities, like a learning center/Library with auditorium or exhibit hall,
already done at "the Dove" along with another civic staple a Federal Post
Office, or may be give it a larger performing arts venue. An objective
evaluation will show that it will be very difficult if not impossible to create a true
Town Center at the mid City sites. As we know, we already own land in the
Center of town. Rather than place a stand alone City Hall at Farmers, as an
island in the employment center sea. May be we make that site a different
feature for the community, a larger performing arts venue, say an
amphitheater. May be not, as we did have one of these proposed in our town
some time back. But due to the cold shoulder reaction it received here that
proposal moved on to Poway. It then lost out in a head to head competition
with a proposal for a theater in Chula Vista. How many of us in Carlsbad want
to travel to Chula Vista or even S. D. State to go to a performance in an
amphitheater? But nice if we had that venue close in.
If we can agree that our community will benefit significantly by having a
strong Town Center, a point of focus for all of us. If we can agree to have
a Town Center as a new and major goal (a Council Goal) and also agree that
the City Hall should be placed at our Town Center. We should take into
consideration how the four candidate sites for City Hall measure up to a set of
criteria for this role as a flagship facility, as an important part of the
community's Town Center. As has been expressed, if a mid city locations
have little chance to become a strong and meaningful Town Center then
where? The Village also does not currently carry that weight. However, unlike
mid town it does have that potential, it's just not there yet. So the real question
here is what must we do to make it so. To make the Village a true Town
Center that has that weight, that gravity to draw all of us to it, even those
"Car-nitas". But that is a topic for another session, another paper. A
session to tackle that question, and to ask if we have that kind of vision,
that kind of resolve to strengthen Carlsbad as a community made whole
with a compelling Town Center?
Page 3
II 6':l lmagine
i&i carlsbad
WHAT MAKES FOR A SUCCESSFUL TOWN CENTER ,lao1 2D21
A Center with many activities and services creating a significant draw that
becomes a local attraction, a destination for the entire community.
A Center that provides a special setting assisted by its character and
ambiance enhancing the community's sense of place, identity and pride.
A Center that is easy to locate, offers easy access and has adequate
fundamentals for all its uses and planned events.
A Center that can host a full range of special events throughout the year.
A Center where there are strong public/private partnerships and many active
community groups.
A Center strengthened by the inclusion of the town's Seat of Power (City Hall)
placed at a location of prominence and status. A flagship facility that also
offers as many features for community use as its layout can accommodate.
A Center with a high level of authenticity and/or heritage, it is optimal if the
location has an innate quality to it. Something special took place there,
something special was built there, something was started at this location that
has meaning to the community. This should enhance its prominence and
status adding depth in the community's sense of time, sense of longevity.
A Center with ample public land, although the center can include a mix of both
public and private properties, it must be rich in our public domain. Allowing
easy public movement unencumbered by private rights. A location where
there are also ample areas for the public to gather. Where one gathering
location is widely held to be the venue for public expression. Where the
community comes together to hold a hand over heart, where they push both
hands high into the air with movement and rhythm, where, after sunset, they
hold lights tight in hand as an expression of a collective spirit.
Page 4
From:Lance Schulte
To:Eric Lardy; Council Internet Email; City Clerk; Kyle Lancaster; Boyle, Carrie@Coastal; "Prahler, Erin@Coastal";Ross, Toni@Coastal; Don Neu
Cc:info@peopleforponto.com
Subject:Public input to Carlsbad Tomorrow Growth Management Committee & CCC - Parks & Unconstrained-UseableOpen Space facilities
Date:Monday, May 30, 2022 1:23:48 PM
Attachments:Carlsbad 2019 proposed Draft LCP Amendment - People for Ponto 2021-Oct Updated Public Comments - CoastalRecreation.pdfSea Level Rise and Carlsbad DLCP-LUPA planned loss of OS at Ponto - 2022.pdf2022-June General Comparative cost-benifits of Completing PCH-PCH Modification-Ponto Park - Part 1 of 2.pdfCity"s PCH area map w numbered notes of Constraints - 2 of 2.pdfCarlsbad FY 2019-20 Budget Public Input Report - Summary analysis for Public Comments on Budget-DLCPA-PMU.pdf
Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad Council and Parks and Planning
Commissions, & CA Coastal Commission:
The Committee is tasked with recommending to the Council proposed changes to City Park and City
Unconstrained/Useable Open Space Standards within the Growth Management Program Update.
Because Carlsbad is quickly running out of vacant land, the Committee’s recommendations are
critical for very obvious reasons. The Committee will be recommending (for all future generations)
the final methods to supply Citizen desired Parks and Unconstrained/Useable Open Space. It is
important the Committee wisely represent the interests of those future generations. The Park and
Open Space supply solutions for future generations will amend Carlsbad’s updated 2015 General
Plan and the “as of 2013” Local Coastal Program.
Since 2017 many People for Ponto Carlsbad Citizens have overwhelming expressed their need and
desire for:
1. Fairness, and a true adequately sized and dimensioned Ponto Park to address City Park
Master Plan documented “lack of Park Service and Park Inequity” in this area, and
2. Correcting the City’s documented 30-acre shortfall in required Unconstrained and Useable
Open Space in the Ponto area, and
3. Correcting the City’s planned loss of 32+ acres of Coastal Open Space at Ponto (the State
Campground and Beach) first documented in 2017 and thus not a part of the City’s General
Plan & Growth Management Program.
Since 2017, over 5,000 Carlsbad Citizen and visitor petitions have been sent to the City & Coastal
Commission expressing the desire and need of both Citizens and visitors to have these Parks and
Open Space issues addressed. The Council has been narrowing deferring addressing these issues
and noted waiting for the Carlsbad Tomorrow Growth Management Committee to consider both the
data and Citizen and visitor desires.
Attached are 5 data files sent to the City by Carlsbad People for Ponto. The data files were sent as
comments to the City’s proposed Local Coastal Program (LCP) Amendment that seeks to change
Carlsbad’s 2013 LCP with the outdated 2015 General Plan, Carlsbad’s Park Master Plan Update
process, and the Growth Management Program that your Committee will be making
recommendations to change. People for Ponto Carlsbad Citizens conducted over 50 official Carlsbad
Public Records Requests to compile this data. We provide these data files in preparation of your
June 23rd meeting.
1. Coastal Recreation and comparative Park data: Summary data on
supply/demand/distribution-fairness of City Parks in Carlsbad, unflattering comparative data
on how much parkland and where Carlsbad provides Parks relative to Encinitas and
Oceanside and national averages, documents Carlsbad’s Park Master Plan mapping Park
distribution unfairness at Ponto, and documenting that many Carlsbad’s Park acres are
Unusable for people because they are constrained habitat land protected from human
use/intrusion.
2. Sea Level Rise & Carlsbad planned loss of Open Space at Ponto: A) Summary data on how
sea level rise (SLR) will remove Open Space at Ponto. B) City GIS maps/data that shows 30-
aceres of required Unconstrained/Useable Open Space was not provided at Ponto (Zone 9)
by using false exemptions while similar and adjacent Local Facility Management Zones (19 &
22) provided their required Unconstrained/Useable Open Space. C) City maps and data
tables documenting the both loss of Open Space at Ponto from SLR and the missing Growth
Management Open Space at Ponto.
3. Updated 2022-June Comparative Cost-Benefits of PCH Modification and Ponto Park: A)
Summary City data comparing the Citizen and tax-payer Cost-Benefit of Park and Useable
Open Space alternatives at Ponto. The data file initially compared cost-benefits of the 11-
acre Ponto Planning Area F and pre-2022 City Cost data. However in May 2022 the City
updated its PCH Relocation costs, and a willing seller of 14.3 acres of adjacent land (Ponto
Planning Area G, H, and I; aka Kam Sang) was listed for sale. B) The Kam Sang list price of
$2.7 million per acre or a bit more than the $2.4 to $1.4 million per acre price of recent
Ponto land sales noted in the file but are close. C) The City’s updated PCH Relocation Costs
are similar. The Cost-Benefit Comparison still shows purchasing Ponto Park land is still a
better value for Carlsbad Citizens, and saves tax-payers money. The Comparison references
a City map and data showing sea level rise impact areas, and the City’s PCH Relocation
environmental and design constraints.
4. Citizens’ City Budget Ponto Park need-requests: A) Summary data and verbatim
documentation of Carlsbad Citizens requests to budget to address the need for Ponto Park,
and Open Space issues at Ponto. B) The volume of Citizen input on Ponto Park and Open
Space, and the actual verbatim Carlsbad Citizen comments should be considered. C) In
addition since 2017 when Carlsbad Citizen first became aware of several Ponto Planning
Mistakes by the City:
a. false Growth Management Unconstrained/Useable Open Space ‘Standard
exemption’ at Ponto
b. failure in the 2010 Ponto Vision Plan that is the basis for the 2015 General Plan
Update, and the failure of the 2015 General Plan Update to follow the 1996 Local
Coastal Program Land Use Policy for Planning Area F that required the City to
consider and document the need for Coastal Recreation (i.e. Public Park) and Low-
cost Visitor Accommodation land use prior to proposing a change in the Non-
residential Reserve land use policy. Failing to fully disclose the Coastal
Commission’s rejection of the Ponto Vision Plan in 2010 because of these reasons,
and not disclosing 2016, 2017 and 2022 directions to the City..
c. SW Quadrant Park deficits going back to 2012
d. Not considering 2017 Sea Level Rise Impact Report that shows the loss of 32+ acres
of high-priority Coastal Open Space land uses at Ponto.
e. As a corollary example, the City has additional history in collaborating with
developers to skirt standards and allow development without developers providing
their required public facilities - the Rosalena HOA Trail segment of the Batiquitos
Lagoon Bluff-top trail at Ponto is a classic example. This example resulted in
delaying construction of the public trail by over 35-years and ended up costing
about 75 Carlsbad homeowners over $1 million in additional costs. It almost
resulted in no trail being built and City and/or developer pocketing money meant to
pay for the trail. This scenario could happen a far larger scale and cost if Ponto
developers are not required to provide the missing 30acres of required Useable
Open Space at Ponto
Carlsbad People for Ponto Citizens have asked the City to provide the Citizen input since 2017 for all
things Ponto related. Reviewing the public record of 5,000+ citizen communications since 2017
reveals only maybe a dozen (mostly developer paid or supported) are not in support of Ponto Park.
Your fellow Carlsbad Citizens ask the Growth Management Committee to read their input and to
consider future generations.
Thank you for serving on the Growth Management Committee. You each have a large and vital task,
as your recommendations will be the beginnings of what (due to Carlsbad running out of vacant
land) will be the ‘final glide path’ that forever defines Carlsbad’s Quality of Life. After your
recommendations, there will only be added population demands on the public facilities. As more
infill development is added and there may be no vacant land to provide needed supplies of facilities
like Parks and Unconstrained/Useable Open Space.
I speak from having already professionally followed the path you are on. After working on Carlsbad’s
Growth Management Program in the mid-1980s I addressed this same issues for the then new City
of Dana Point that (in 1989) was at a similar stage of ‘near buildout as Carlsbad is now.
Based on my professional experience I implore you seriously and fully consider that data and desires
your fellow Carlsbad People for Ponto Citizens have provided you and the City. Based on where
Carlsbad is we, and you, will only get this one chance to get it right.
Sincerely,
Lance Schulte
35-year Carlsbad resident
former Carlsbad Growth Management and Dana Point city planner
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Page 1 of 30
Carlsbad proposed Draft Local Coastal Program Amendment – People for Ponto Updated Public Comments 10/12/2021
Updated Pubic Comments Coastal Recreation submitted on Oct 12th 2021:
On 10/8/21 the Carlsbad City Council and CA Coastal Commission were emailed data from an Official Carlsbad Public
Records Request (# R002393-092121) on the City of Carlsbad’s past compliance/noncompliance with the currently
exiting Mello II LCP Land Use Policies # 6-2, 6-4 & 6-10 Certified in the mid-1980s. The City’s documents show:
For Policy 6-2 the 200-300 acre Park called out in Policy 6-2 has been reduced to Veterans Park’s 91.5 acres,
of which only 54% or 49.5 acres is even useable as a Park. The City provided no documents on how a 200-
300 acre park called for in Policy 6-4 is now only 49.5 useable acres.
For Policy 6-4 there were no City documents were provided. There was no City Public discussion,
consideration, or City compliance with Policy 6-4 since the mid-1980’s.
For Policy 6-10 concerns providing Low Cost Visitor Accommodations. Public Parks are the lowest cost (free)
Visitor accommodating land use there is.
The 3 existing LCP Land Use Policies are important for Carlsbad, and California’s, Coastal land use resources. There
appears little to no discussion of the City’s past apparent failure to implementation of these 3 LCP LUPs in the current
City consideration of changes to the LCP.
Following is a copy of Public Records Request # R002393-092121: “Carlsbad’s Local Coastal Program (LCP) for the Mello
II Segment of Carlsbad’s Coastal Zone has long established land use Policies 6-2, 6-4 & 6-10 that were adopted by
Carlsbad and Certified by the CA Coastal Commission in the early/mid-1980’s. Mello II LCP Policies 6-2, 6-4 & 6-10 are
shown on page 86-87 of Carlsbad’s 2016 compiled LCP and are:
“POLICY 6-2 REGIONAL PARK: If the population of Carlsbad increases in accordance with SANDAG's projected
Series V Population Forecasts, it is estimated that Carlsbad will need to develop a new regional park
containing 200 to 300 acres in order to adequately serve the public. A location for a new regional park must,
therefore, be established. Consideration should be given to a facility within the Aqua Hedionda Specific Plan
Area, or adjacent lands. The Batiquitos Lagoon area should also be considered.
POLICY 6-4 NEED FOR ADDITIONAL OVERNIGHT CAMPING: Additional overnight camping facilities, the main
source of lower cost visitor and recreational facilities, are needed throughout the San Diego coastal region.
Additional facilities of this kind should be provided in a regional park within the Carlsbad area. This can be
accomplished in conjunction with an eventual Batiquitos Park, within the Aqua Hedionda Specific Plan Area,
and/or along with the development of private recreational facilities.
POLICY 6-10 LOWER COST VISITOR-SERVING RECREATIONAL USES: Lower cost visitor and recreational
facilities shall be protected, encouraged, and, where feasible, provided. Encourage a range of affordability
for overnight visitor accommodations. Evaluate the affordability of any new or redeveloped overnight visitor
accommodations, including amenities that reduce the cost of stay. Mitigation may be applied to protect and
encourage affordable overnight accommodations”
The public record request is to see documents of:
Page 2 of 30
City Staff reports, presentations and communications to the Carlsbad Planning and Parks Commissions, and
City Council regarding the City’s consideration and implementation of these 3 specific (6-2, 6-4, and 6-10)
Mello II LCP land use policies; and
Carlsbad Planning and Parks Commissions, and City Council minutes, resolutions and ordinances
documenting City of Carlsbad consideration and implementation of these 3 specific (6-2, 6-4, and 6-10)
Mello II LCP land use policies.”
Updated Pubic Comments Coastal Recreation submitted on January 2021:
Over 11-months ago in a 1/29/20 1:56PM email People for Ponto Carlsbad citizens first provided the City of Carlsbad
both data and comments on 14 critical Coastal Recreation issues (see pages 5-30 below). The data and the 14 critical
issues do not seem to be receiving appropriate disclosure/presentation/discussion/consideration in the Dec 2, 2020
Staff Report to the Planning Commission. To assure the 26-pages of citizen data and requests in the 1/29/20 email was
received by the Planning Commission the file was re-emailed on 12/22/20 12:24pm and specifically addressed to City
Council, City Clerk, Planning Commission, Parks Commission, Housing Commission, HEAC, CA Coastal Commission, and
CA HCD. As citizens we request each of these 14 data points (with supporting data) be honestly considered.
In reading the Dec 2 Staff Report citizens conducted additional analysis of City Park data. That research further
reinforces and documents the 14 Critical Coastal Recreation issues and highlights the relatively poor amount of City Park
and Coastal Recreation planned by Carlsbad’s Staff proposed Draft LCP-LUPA. We hope the City Council and City
Commissions, and CA Coastal Commission & HCD will consider this additional analysis of City data and citizen input:
Coastal Zone data Carlsbad Oceanside Encinitas note or source
Coastline miles 6.4 3.9 6.0 Carlsbad Draft LCPA 201, Google Maps
Coastal Zone Acres 9,219 1,460 7,845 & Oceanside & Encinitas LCPs
Coastal Zone Acres 100% 16% 85% % relative to Carlsbad
City Park Standard data
City Park Standard 3 5 5 required park acres / 1,000 population
Park Standard % 100% 167% 167% % is relative to Carlsbad
Oceanside & Encinitas 'require' and plan for 67% MORE Parkland than Carlsbad
Carlsbad 'requires' and plans for ONLY 60% as much Parkland as Oceanside & Encinitas
Carlsbad only requires developers provide 60% of the parkland (or in-lieu fees) as Oceanside & Encinitas require
Encinitas has a ‘Goal’ to provide 15 acres of Park land per 1,000 population
Developed City Park 2.47 3.65 5.5 acres / 1,000 population
Developed Park 100% 148% 223% % is relative to Carlsbad
Oceanside provides 48% MORE developed park land than Carlsbad
Encinitas provide 123% MORE developed park land than Carlsbad
Carlsbad ONLY provides 68% and 45% as much Parks as Oceanside & Encinitas respectively
National Recreation & Park Asso. Metric: a typical City provides 1 park / 2,281 pop. & 9.9 Park acres / 1,000 population
Carlsbad (3 acre) Park Standard is ONLY 30% of what a typical City provides nationally
Carlsbad requires developers to provide, 70% LESS Park acres than typical City provides nationally
National Recreation & Park Asso., Trust for Public Land, et. al.: 10 minute (1/2 mile) Walk to a Park Planning Goal
Page 3 of 30
Both Oceanside and Encinitas plan parks to be within a 10-minute (1/2 mile) walk to homes.
Carlsbad DOES NOT plan Parks within walking distance to homes
Carlsbad is NOT providing equitable and walking/biking access to Parks
Some Carlsbad Parks that are not fully useable as Parks:
total Unusable
Existing Parks with park park % of park
Unusable Open Space acreage acres acres unusable reason unusable
Alga Norte - SE quadrant 32.1 10.7 33% 1/3 of park is a Parking lot not a park
In many other Carlsbad Parks a significant
percentage of those Parks are consumed by
paved parking lots and unusable as a Park.
Hidden Hills - NE quadrant 22.0 12.7 58% city identified unusable habitat open space
La Costa Canyon SE quadrant 14.7 8.9 61% city identified unusable habitat open space
Leo Carrillo - SE quadrant 27.4 16.5 60% city identified unusable habitat open space
Poinsettia - SW quadrant 41.2 11.1 27% city identified unusable habitat open space
Existing Park subtotal 137.4 59.9 44% 44% of these Parks are unusable as Parkland
Anticipated Future Park
development projects
Park - quadrant
Veterans - NW 91.5 49.5 54% estimated unusable habitat open space
Cannon Lake - NW 6.8 3.4 50% estimated unusable water open space
Zone 5 Park expansion - NW 9.3 0 0 appears 100% useable as a Park
Robertson Ranch - NE 11.2 0 0 appears 100% useable as a Park
Future park subtotal 118.8 52.9 45% 45% of Future Parks are unusable as Parks
Unusable Open Space acres
in Existing & Future Parks 256.2 112.8 44% 112.8 acres or 44% is unusable as Parks
112.8 acres or 44% of the Existing & Future Parks are unusable Open Space and can’t be used as Parkland
Based on City's minimum 3-acres/1,000 population Park Standard, 112.8 acres of Unusable Parkland means
37, 600 Carlsbad Citizens (or 32.5% of Carlsbad's current population of 112,877) will be denied Parkland that
they can actually use as a Park.
112.8 acres of Existing & Future unusable ‘park’ / 3 acre park standard x 1,000 population = 37,600 Carlsbad
citizens without useable parkland per City minimum standard.
59.9 acres of Existing unusable ‘park’ / 3 acre park standard x 1,000 population = 19,967 Carlsbad citizens and
their children are currently being denied useable park land. 19,967 is 17.7% of Carlsbad’s current population.
In addition to these 19,967 existing citizens and their children denied park land, the City needs to develop
additional Park acreage in the NE, SW and SE quadrants to cover current shortfalls in meeting in the minimal 3
acre/1,000 population park standard for the current populations in the NE, SW and SE quadrants.
The current NE, SW and SE quadrants park acreage shortfalls are in addition to the 19,967 Carlsbad citizens
and their children that do not have the minimum 3 acres of parkland per 1,000 population
Current FY 2018-19 MINIMUM park acreage shortfalls are listed below. They are:
o 4.3 acres for 1,433 people in NE quadrant,
o 6.8 acres for 2,266 people in SW quadrant, and
o 2.3 acres for 767 people in SE quadrant
Shortfall (excess) in
Current Quadrant
Park standard by
Page 4 of 30
population Future Park
acres need acres % existing Park shortfalls are for NE, SW & SE quadrants
NW quadrant (-14.2) (-4,733) 107.6 91% Current NW parks are 14.2 acres over min. standard &
capacity for 4,733 more people at min. park standard.
91% of all Future City Parks are in NW quadrant
NE quadrant 4.3 1,433 11.2 9% Future Park will exceed minimum NE park standard
SW quadrant 6.8 2,266 0 0% No min. parks for 2,266 people in SW quad. Park deficit
SE quadrant 2.3 767 0 0% No min. parks for 767 SE quadrant Park deficit
A Park Standard minimum is just a “Minimum”. City policy allows the City to buy/create parks above the City’s current 3
acre/1,000 pop. MINIMUM (and lowest) Park Standard of surrounding Coastal cities. Carlsbad already did this in the NW
quadrant. It then added 3.1 more NW quadrant Park acres as part of the Poinsettia 61 Agreement. Poinsettia 61:
converted 3.1 acres of NW City land planned/zoned for Residential use to Open Space Park land use/zoning,
facilitated a developer building condos (increasing park demand) in the SW quadrant,
required the SW Quadrant developer pay $3 million to build the 3.1 acre NW quadrant park, and
required the SW Quadrant developer pay to convert 3.1 acres of NW Quadrant & 5.7 acres of SW Quadrant City
Park land to habitat that will be unusable as a City Park.
So Poinsettia 61 increased SW Quadrant development (that both increased SW Park Demand and expanded the current
SW Quadrant Park deceit) while simultaneously using SW Quadrant development to pay for the conversion of 3.1 acres
of residential land in the NW Quadrant to City Park (the NW Quadrant already has surplus park land per the City’s
minimum standard).
People for Ponto strongly supports creating City Parks above the City’s current low 3-acre per 1,000 population
minimum, as the City’s minimum standard is relatively low and substandard relative to other cities; many Carlsbad parks
have significant acreage that is in fact ‘unusable’ as a park. Most importantly People for Ponto Citizens think it is very
important to prioritize providing City Parks in areas of Park Inequity that are unserved by City Parks. However it seems
very unfair to the SW Quadrant citizens to be so unserved and starved of the bare minimum of City Parks while at the
same time funding City Parks in excess of City standard in other Quadrants.
The Poinsettia 61 illustrates a larger unfair (and dysfunctional) distribution of Quadrant based City Park demand and
supply that is keenly evident in the demands/supply funding and location disparity of Veterans Park. Most all the
development impact and park demand that paid Veterans Park fees came from the SW, SE and NE Quadrants yet the
Veterans Park (supply) is not in those SW, SE and NE Quadrants. This inequity is counter to the implicit City requirement
that City Parks be provided within the Quadrant of their Park demand. It is logical and proper that City Parks be
provided and equitably distributed to be close to the development and population that generated the demand for that
Park.
The City Park inequity at Ponto and in other Coastal areas of the City is counter to several CA Coastal Act policies;
counter to good city planning and good CA Coastal planning; is highly detrimental to the City, City and CA citizens in the
long-term; fails to properly distribute and match the location supply with the location of demand for Parks; and is
counter to basic fundamental issues of fairness. Since 2017 People for Ponto has tried to get the City Council and City
Staff to address this inequity, specifically at Ponto, and to do so in a way that embraces a true and honest Citizen-based
planning process.
Page 5 of 30
Carlsbad Staff proposed Draft Local Coastal Program Amendment – People for Ponto comments submitted 1/29/2020
Coastal Recreation:
2. Request that the City as part of its Draft LCP Public Review process broadly-publicly disclose to all Carlsbad Citizens
the City’s acknowledged prior LCPA processing and planning “mistakes” regarding the requirement that the Ponto
area be considered as a public park: This disclosure is needed to correct about 20 years of City misrepresentation to
the public on the since 1996 and currently Existing LCP requirements at Ponto, and the City’s prior planning mistakes
at Ponto. Citizens have been falsely told by the City that all the Coastal planning at Ponto was done already and that
the City followed its Existing LCP regarding the need for a park at Ponto, and that this is already decided and could
not be reversed. This misinformation has fundamentally stifled public review and public participation regarding the
Coastal Zone. City failure to provide such a broad-public disclosure on the documented prior, and apparently
current proposed, “planning mistakes” would appear to violate the principles of Ca Coastal Act Section 30006. A
broad-public disclosure would for the first time allow citizens to be accurately informed on the Existing LCP
requirements at Ponto so they can provide informed public review and comment regarding the need for a Coastal
Park in in this last vacant ‘unplanned’ area. The requested broad-public disclosure by the City of the City past
mistakes and the Existing LCP requirements at Ponto is consistent with CA Coastal Act (CCA) “Section 30006
Legislative findings and declarations; public participation - The Legislature further finds and declares that the public
has a right to fully participate in decisions affecting coastal planning, conservation and development; that
achievement of sound coastal conservation and development is dependent upon public understanding and
support; and that the continuing planning and implementation of programs for coastal conservation and
development should include the widest opportunity for public participation.” The public cannot participate as
outlined in CCA Section 30006 if past City ‘mistakes’ and misrepresentations on Coastal planning at Ponto go
undisclosed to the public. If the public isn’t fully informed about the 20-years of LCP planning mistakes at Ponto
how could the public in the past (and now in the present) participate in the proposed LCP Amendment – Public
Participation as noted in Section 30006 above is the means to sound coastal conservation and development and is
“… dependent upon public understanding …”. The City’s past mistakes at Ponto need to be corrected by slightly
different a Draft LCP Amendment process than currently outlined by the City; a new process is needed that clearly,
opening and honestly informs and engages the public on the Existing LCP Ponto issues. The City’s current Draft LCP
Amendment process fails to follow CCA Section 30006 in that most all the citizens we encounter are as yet unaware
of the City’s Ponto mistakes and how they can participate in in the DLCPA process without that information. We see
this daily in conversations we have with our fellow citizens. We even saw at the Oct 20, 2019 Carlsbad Planning
Commission meeting that the Planning Commission was unaware of the planning mistakes at Ponto. How can a
decision body of the City make a decision without knowing about these prior ‘planning mistakes’ facts that surround
what they are being asked to decide on? Repeatedly since 2017 Carlsbad citizens and People for Ponto have asked
the City to fully acknowledge the City’s prior flawed planning at Ponto, and to correct that with ether maintaining
the Existing LCP Non-residential Reserve Land Use or restarting the Coastal Planning at Ponto with a true and
accurately informed Community-based Coastal Planning process consistent with Section 30006.
We request the City during the DLCPA Public Review period broadly and publicly disclose to all Carlsbad Citizens the
City’s acknowledged prior LCP and other “planning efforts” public participation processing and planning “mistakes”
regarding the requirement that the Ponto area be considered as a public park, and 1) provide a truly honest public
participation process on that disclosure consistent with CCA Section 30006 as part of the Draft LCP Amendment
process or 2) retain the Existing LCP Non-residential Reserve Land Use and require a comprehensive and honest
community-based redo of Coastal Resource planning at Ponto.
Page 6 of 30
3. City fully and publicly reply to and the City Council consider the 11-20-19 citizen concerns/requests regarding the
City’s proposed LCP Amendment process: Lance Schulte on 1/23/20 received an email reply by the City to his follow-
up email regarding the status of the 11/20/19 citizen concerns/requests public comments and letters presented to
the Planning Commission. This is appreciated, however it is request that the City fully publicly reply to the 11-20-19
citizen concerns/requests regarding the City’s proposed LCP Amendment process and present the to the City Council
11/20/19 citizen concerns/requests so the City Council can consider them and provide any direction to City Staff.
City Staff first presented a summary presentation of the proposed Draft LCP Amendment to the Carlsbad Planning
Commission on November 20, 2019, and indicated the public comment period would close on November in less than
2-weeks. Citizens and citizen groups provided public testimony to the Planning Commission, both verbally and in
two written letters. The CCC was copied on those letters. The testimony and letters noted significant concerns
about the City’s proposed LCP Amendment process and made three requests:
Disclose and provide a publically accessible ‘Redline Version’ of the Existing 2016/Proposed LCP land use
Plan and Policies so everyone can see the proposed changes to the Existing LCP.
Provide true Citizen Workshops on the major remaining vacant Coastal land that still have outstanding
Citizen Concern or objections. Citizen Workshops, when done right, are valuable means to openly educate,
discuss and work to consensus options. These areas, including Ponto, were/are subject to multiple lawsuits,
so true open and honest public workshops would provide an opportunity to openly and honestly discuss the
issues and hopefully build public consensus/support for solutions. This approach seems consistent with CCA
Section 30006, and common sense.
Extend the public comment period 6-months to allow Citizen Review of the Redline Version of the LCPA and
allow time for Citizen Workshops.
The City did extend the Public Review period 2-months over the holidays to January 31, 2020. This is appreciated
although many think this is inadequate given the significance of the Proposed Land Use Plan Amendments, and lack
of Redline Version to compare. The City and their consultants required several extra years beyond schedule prepare
the proposed LCP Amendments. The extra years of City Staff work reflects on the volume of the over 500-pages in
the documents and the time needed to understand the Existing LCP and then create an Amended LCP. Citizens
need sufficient time, proper comparative tools (redline) and a process (workshops) to understand the proposed LCP
Amendments that is reflective of extensive extra time needed by City Staff and consultants needed. Truncation of
lay public review to a few months for an Amendment that took paid professionals many years to produce seems a
more than a bit inappropriate. The City appears to be rejecting citizens’ request to be provided a ‘Redline Version’
of the Existing 2016/Proposed LCP land use Plan. So public review comments will tainted or will miss many issues
due having to manually cross-reference a 150-page Existing LCP LUP with a Proposed 350-page Proposed LCP LUP.
There will be unknown and unconsidered changes in the Draft LCP Amendment that the public and city and CCC
decision makers will not know about due to the lack of ‘Redline Version’.
The City also appears to reject citizen requests for true Citizen Workshops on the major remaining vacant Coastal
land that still have outstanding Citizen Concern – such as Ponto. Like Coastal Recreation issue #1 above the
following citizen requests appear consistent with CA Coastal Act (CCA) Section 30006, and the City’s rejection of that
requests seem counter to the CA Coastal Act.
We again request of the City to provide: 1) a ‘Redline Version’ to the public and decision makers, along with
sufficient time to review and comment on the ‘Redline Version’; and 2) true Citizen Workshops for Ponto and the
Page 7 of 30
other last remaining significant vacant Coastal lands in Carlsbad as part of the Draft LCP Amendment process, or as
part of deferred LCP Amendment process for those areas.
4. Coastal Zoned land is precious: the very small amount of remaining vacant Coastal land should be reserved for
“High-Priority” Coastal Recreation Land Uses under the CA Coastal Act to provide for the growing and forever
‘Buildout’ needs of Carlsbad and CA Citizens, and our visitors.
Less than 1.8% (76 square miles) of San Diego County’s 4,207 square miles is in Coastal Zone. This small area
needs to provide for all the forever Coastal needs of the County, State of CA, and Visitors. Upland Coastal
Recreation (Coastal Park) land use is needed to provide land to migrate the projected/planned loss of “High-
Priority” Coastal Recreation land uses due to Sea Level Rise impacts. There is only 76 miles of total coastline
in San Diego County; a significant amount is publicly inaccessible military/industrial land. So how the last
few portions of Coastal Land within Carlsbad (which is about 8% of San Diego County’s Coastline) is planned
for the forever needs for High-Coastal-Priority Recreation Land Use is critical for Carlsbad, San Diego, and
California Statewide needs into the future.
Most all the developable Coastal land in Carlsbad is already developed with Low-Coastal-Priority residential
uses. Only a very small percentage of Carlsbad’s developable Coastal land, maybe 1-2%, is still vacant. This
last tiny portion of fragment of vacant developable Coastal Land should be documented in the Draft LCP and
reserved for “High-Priority” Coastal Land uses – most critically Coastal Recreation – to address the growing
Coastal Recreation needs from a growing population and visitors. These growing needs are all the more
critical in that existing Coastal Recreation lands will be decreasing due to inundation and erosion due to
DLCPA planned Sea Level Rise.
This image of the western half of San Diego County graphically shows (in the blue line) the very small Coastal
Zone Area that needs to provide the Carlsbad’s and California’s Coastal Recreational needs for all San Diego
County residents and Visitors:
Page 8 of 30
We request that 1) the amount and location of remaining vacant Coastal land in Carlsbad be documented and
mapped and be reserved for high-priority Coastal Land Uses consistent with CCA Goals in Section 30001.5 “… (c) …
maximize public recreational opportunities in the coastal zone consistent with sound resources conservation
principles and constitutionally protected rights of private property owners. (d) Assure priority for coastal-
dependent and coastal-related development over other development on the coast. … “; 2). This data be used in
the City’s analysis and the public’s review and discussion about the City’s proposed Draft ‘Buildout’ Land Use Plan.
The City’s proposed Draft ‘Buildout’ Land Use Plan will forever lock in the amount “maximum public recreational
opportunities in the coastal zone” and will be the final Coastal Land Use Plan that is supposed to “assure priority for
coastal-dependent and coastal-related development over other development on the coast”. Most of Carlsbad’s
Coastal Zone is already developed or committed to low-priority land uses contrary to these CCA Goals, so how we
finally and forever plan to use of the last small remaining vacant Coastal Land is very important.
5. The proposed Draft LCP Amendment in Chapter 3 makes unfounded statements regarding the proposed
Amendment to the LCP Land Use Plan provision of “High-Priority” Coastal Recreation land use: On page 3-3, at the
beginning of the Chapter 3 – Recreation and Visitor Serving Uses the City correctly states that the CA Coastal Act
(CCA) places a high priority on maximizing Recreation uses, and cites multiple CCA Sections to that effect. The City’s
proposed Coastal Land Use Plan then states on page 3-5 that a high proportion of land in the City is dedicated open
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Page 9 of 30
space available for passive and active use, yet provides no justification or accurate metric to support this statement.
This is a critical unsubstantiated and speculative statement that is not supported by any comparative data (justifying
the “high proportion” statement). The City later in Chapter 3 compared the adjoining cities of Oceanside and
Encinitas to try to show how the proposed Draft LCP LUP Amendment provides higher levels of Visitor Serving
Accommodations. That ‘non-common denominator’ comparison was fundamentally flawed, as noted in a prior
separate Draft LCPA public review comment from People for Ponto regarding another high-priority Coastal land use
(visitor accommodations) planned for in Chapter 3, but at least it was an attempt to compare. However, for the
Coastal Recreation portion of Chapter 3, the City does not even attempt to provide any comparative data to support
(or justify) the proposed Coastal Recreation Land Use Plan and statements. The Coastal Recreation Chapter also fails
to disclose Carlsbad’s adopted City Park Master Plan (Park Service Area and Equity map) data that shows a clear
conflict between the CA Coastal Act Policy Sections noted at the beginning of Chapter 3 and Chapter 3’s proposed
Draft Coastal Recreation Land Use Plan.
Comparative Coastal Recreation: Comparing the Land Use Plan and policies of Oceanside, Carlsbad and Encinitas,
one finds Carlsbad’s proposed Coastal Recreational Plan and Policies are not “high”, but very low compared with
Oceanside and Encinitas. Carlsbad has a General Plan Park Standard of 3 acres of City Park per 1,000 Population.
Oceanside has a 5 acres of City Park Standard per 1,000 population, and Encinitas has a 15 acres per 1,000
population standard, and an in-lieu park fee requirement of 5 acres per 1,000 population. Carlsbad’s proposed
Coastal Recreation Land Use Plan is in fact not ‘high’ but is in fact the lowest of the three cities, with Carlsbad
providing only 40% of Oceanside’s park standard, and only 20% of Encinitas’s Park Standard. Citywide Carlsbad
currently has 2.47 acres of developed park per 1,000 population, Oceanside currently has 3.6 acres of developed
park per 1,000 population, and Encinitas currently has 5.5 acres of developed park per 1,000 population. Although
this data is citywide, it shows Carlsbad’s current amount of developed parkland is less than 70% of what Oceanside
currently provides, and less than 45% of what Encinitas currently provides. Carlsbad is not currently providing, nor
proposing a Coastal Land Use Plan to provide, a ‘high’ proportion of Coastal Recreation Land Use compared to
Oceanside and Encinitas.
On page 3-5 Carlsbad may be misrepresenting city open space that is needed and used for the preservation of
federally endangered species habitats and lagoon water bodies. This open space Land cannot be Used for Coastal
Recreation purposes; and in fact Land Use regulations prohibit public access and Recreational Use on these Lands
and water bodies to protect those endangered land and water habitats. 78% of Carlsbad’s open space is “open
space for the preservation of natural resources” and cannot be used for Coastal Parks and Recreational use.
Although “open space for the preservation of natural resources” does provide scenic or visual amenity, and this
amenity is addressed as a different coastal resource. Visual open space is not Coastal Recreation Land Use. It
appears Carlsbad is proposing in the Draft LCP Amendment to continue to, providing a ‘low’ percentage of Coastal
Park Land Use and Coastal Recreation Land Use compared to adjoining cities.
In addition to the comparatively low amount of Coastal Park land Carlsbad plans for, Carlsbad scores very poorly
regarding the equitable and fair distribution and accessibility of Coastal Parks and Coastal Recreation Land Uses.
Both the City of Oceanside and Encinitas have very robust and detailed Park and Land Use plans to promote an
equitable distribution of, and good non-vehicular accessibility, to their Coastal Parks. By comparison, Carlsbad’s park
land use plan scores poorly, as exemplified in Ponto and South Carlsbad. Ponto’s existing population requires about
6.6 acres of City Parkland per Carlsbad’s low 3 acres per 1,000 population standard. Yet the nearest City Park is
several miles away and takes over 50 minutes to walk along major arterial roadways and across Interstate 5 to
access. As such this nearest park is not an accessible park for Ponto children, and thus Ponto children have to play in
Page 10 of 30
our local streets to find a significantly large open area to play in. Ponto residents have to drive their kids to get to a
park increasing VMT and GHG emissions. The City’s proposed Coastal Recreation Land Use Plan ‘solution’ to Ponto’s
no-park condition, along with the City’s need to add an additional 6.5 acres of new City parks in Southwest Carlsbad
to comply with the Southwest Carlsbad’s 2012 population demand (at a ratio of 3-acre/1,000 population) is to
provide a City Park – Veterans Park – over 6-miles away from the Ponto and Southwest Carlsbad population need.
This makes a bad situation worse. The City’s proposed location is totally inaccessible to serve the needs of the
population of children or anyone without a car, that it is intended to serve in South Carlsbad. This City proposed
Coastal Recreation Land Use Plan ‘solution’ seems inappropriate and inconsistent with the CA Coastal Act and
common sense. During the City’s Veterans Park and budget community workshops citizens expressed a desire for a
Ponto Park to be the solution to our Ponto and Southwest Carlsbad Park deficits. Those citizen requests were not
apparently considered as part of the City’s proposed Draft Coastal Recreation Land Use Plan. Following is an image
summarizing the magnitude of citizen needs/desires expressed at the City’s Budget workshop. Note the number
and size of the text citing Ponto Park and South Carlsbad that reflects the number and magnitude/intensity of citizen
workshop groups’ input. The failure to acknowledge this public participation and data in the Coastal Recreation
Land Use Plan Park seems in conflict with CCA Sections 30006 and 30252(6):
For South Carlsbad there is a complete lack of any existing or planned City Coastal Park and park acreage west of I-5,
while North Carlsbad has 9 existing and 1 planned City Coastal Parks totaling 37.8 acres of City Coastal W of I-5
North Carlsbad. Not only is this unfair to South Carlsbad, it is also unfair to North Carlsbad as it increases VMT and
parking impacts in North Carlsbad because South Carlsbad is not providing the City Coastal Parks for South Carlsbad
resident/visitor demands. This City Park disparity is shown on Figure 3-1 of the Coastal Recreation Land Use Plan;
Page 11 of 30
however it more accurately illustrated in the following data/image from the adopted Carlsbad Park Master Plan’s
“Service Area Maps (Equity Maps)”. The image below titled ‘No Coastal Park in South Carlsbad’ shows Carlsbad’s
adopted “Park Service Area Maps (Equity Maps)” from the City’s Park Master Plan that says it maps “the population
being served by that park type/facility.” The added text to the image is data regarding park inequity and disparity in
South Carlsbad. The image compiles Carlsbad’s adopted Park “Park Service Area Maps (Equity Maps)” for
Community Parks and Special Use Area Parks that are the City’s two park acreage types produced by the City’s
comparatively low standard of 3 acre of City Park per 1,000 population. The City’s Park Service Area Maps (Equity
Maps) shows areas and populations served by parks within the blue and red circles. City data clearly shows large
areas of overlapping Park Service (areas/populations served by multiple parks) in North Carlsbad and also shows
large areas in South Carlsbad with No Park Service (areas/populations unserved by any parks) and Park Inequity in
South Carlsbad. It clearly shows the City’s Documented Park Need and Park inequity at Ponto. The Existing LCP LUP
for Ponto’s Planning Area F in is required to “consider” and “document” the need for a “Public Park”. The City’s
adopted Park Service Area Maps (Equity Maps) clearly shows the inequity of Coastal City Park between North and
South Carlsbad, and the need for Coastal Parks in South Carlsbad – particularly at Ponto. The City’s proposed Draft
‘Buildout’ Coastal Recreation Land Use Plan instead proposes to lock-in documented City Public Coastal Park
inequity and unserved Coastal Park demand at Ponto and South Carlsbad forever. It does so by proposing the last
vacant undeveloped/unplanned Coastal land – Ponto Planning Area F - in the unserved Ponto and South Carlsbad
coastline areas instead of being planned for much needed City Park and Coastal Recreation use be converted to
even more low-priority residential and general commercial land uses. These ‘low-priority” residential uses, by the
way, further increase City Park and Coastal Recreation demand and inequity in Coastal South Carlsbad. This is
wrong, and a proposed ‘forever-buildout’ wrong at the most basic and fundamental levels. The proposed Draft
Coastal Recreation Land Use Plan by NOT providing documented needed City parks for vast areas of Coastal South
Carlsbad is inconsistent with the CA Coastal Act policies and Existing LCP LUP requirements for Ponto Planning Area
F; and also inconsistent with fair/equitable/commonsense land use and park planning principles, inconsistent with
CA Coastal Commission social justice goals, inconsistent with social equity, inconsistent with VMT reduction
requirements, and inconsistent with common fairness. A different Coastal Recreation Land Use Plan should be
provided that provides for a socially equitable distribution of Coastal Park resources so as to would allow children,
the elderly and those without cars to access Coastal Parks. The proposed Draft ‘Buildout’ Coastal Recreation Land
Use Plan forever locking in the unfair distribution of City Parks appears a violation of the not only CCA Sections
30213, 30222, 30223, and 30252(6) but also the fundamental values and principles of the CA Coastal Act. The Draft
also appears a violation of Carlsbad’s Community Vision.
Page 12 of 30
A different Coastal Recreation Land Use Plan is required to provide a more equitable distribution of City Parks with
non-vehicular accessibility. Such a different plan would advance State and City requirements to reduce vehicle Miles
Traveled (VMT) and greenhouse gas emissions that contribute to climate change and sea level rise impacts. Please
note that the data for the above basic comparison comes from City of Carlsbad, Oceanside and Encinitas General
Plan and Park Master Plan documents.
Data shows the proposed Coastal Recreation Plan conflicts with the CA Coastal Act policy Sections. As mentioned
page 3-3 correctly states that the CA Coastal Act (CCA) places a high priority on maximizing Recreation Land Uses,
and pages 3-5 list multiple CA Coastal Act (CCA) policy Sections that confirm this. However, given the significant
statewide importance of Coastal Recreation Land Use, the City proposed ‘Buildout’ Coastal Recreation Land Use Plan
does not appear to adequately address and implement these CCA Policies, and most noticeably in the Ponto area of
South Carlsbad. Coastal Recreation is a significant Statewide High-Priority Land Use under the CCA. For a
substantially developed non-coastal-industry city like Carlsbad Coastal Recreation is likely the biggest land use issue.
This issue is even more elevated due to the fact that there are only a few small areas left of undeveloped Coastal
land on which to provide Coastal Recreation, and Carlsbad is proposing a Coastal ‘Buildout’ Land Use Plan on those
areas. The use of the last few remaining vacant portions of Coastal land for Coastal Recreation Land Use is the most
important land use consideration in the proposed Draft LCP Land Use Plan Amendment as population and visitor
growth will increase demands for Coastal Recreation. It is thus very surprising, and disturbing that the proposed
Coastal Recreation Land Use Plan is so short, lacks any comparative and demand projection data, lacks any resource
demand/distribution and social equity data, and lacks any rational and clear connection with CCA Policy and the
proposed ‘Buildout’ Coastal Land Use plan. This is all the more troubling given that:
The Ponto area represents the last significant vacant undeveloped/unplanned land near the coast in South
Carlsbad that can provide a meaningful Coastal Park.
The fact that the City’s Existing LCP requires the city consider and document the need for a “i.e. Public Park”
on Ponto’s Planning Area F prior to the City proposing a change of Planning Area F’s “Non-residential
No Coastal Park in South Carlsbad
• ppx. 6 miles of Coast
without a Coastal Park is a
Ci & Regional need
• South Carlsbad has 64,000
residents & thousands of
hotel visitors without a
Coastal park
• Closest park to Ponto is
Poinsettia Park, appro 2.5
miles across 1-5
• Proposed Veterans Park is
approx. 6 miles away
Page 13 of 30
Reserve” land use designation. The City has repeatedly failed to comply with this LCP LUP requirement, and
worse has repeatedly failed to honestly inform citizens of this LCP LUP requirement at planning Area F
before it granted any land use. The City, apparently implementing speculative developer wishes, has
repeatedly proposed changing Planning Area F’s Coastal Land Use designation to “low-priority” residential
and general commercial land uses without publically disclosing and following the Existing LCP LUP.
The City’s currently developed parks in the southern portion of the City do not meet the city’s
comparatively low public park standard of only 3 acres per 1,000 population. Since 2012 there has been
City park acreage shortfall in both SW and SE Carlsbad.
The Existing population of Ponto (west of I-5 and south of Poinsettia Lane) requires about 6.6 acres of Public
Park based on the City’s comparatively low public park standard of 3 acres per 1,000 population. There ois
no Public Park in Ponto. Adding more population at Ponto will increase this current park demand/supply
disparity.
Carlsbad and other citizens have since 2017 expressed to the City the strong need for a Coastal Park at
Ponto, and requested the City to provide a true citizen-based planning process to consider the Public Park
need at Ponto. The Citizens’ requested process is fully in-line with CCA Goals, Public Participation Policy,
Land Use Policies, and the Existing LCP Land Use Plan/requirements for Planning Area F and is the most
appropriate means to consider and document the need for a Public Park at Ponto as required by the Existing
LCP Land Use Plan.
Planning Area F is for sale, and a non-profit citizens group has made an offer to purchase Planning Area F for
a much needed Coastal Park for both Ponto and inland South Carlsbad residents and visitors. How should
these facts be considered by the City and CCC?
Carlsbad has no Coastal Parks west of I-5 and the railroad corridor for the entire southern half of Carlsbad’s
7-mile coastline.
The southern half of Carlsbad’s coastline is 5.7% of the entire San Diego County coastline and represents a
significant portion of regional coastline without a meaningful Coastal Park west of I-5 and the Railroad
corridor.
The City’s proposed Coastal Recreation Land Use Plan provides No Documentation, No Rational, and No
Supporting or Comparative Data to show the proposed Coastal Recreation Land Use Plan in fact complies
with the CA Coastal Act.
6. There is no Coastal Recreation/Park west of interstate 5 for all South Carlsbad, or half of the entire City. This is an
obviously unfair and inequitable distribution of Coastal Recreation/Park resources that should be corrected by
changes to the Draft LCP Land Use Amendment: The following image (which was sent to the City and CCC on several
prior communications) was first requested by former Carlsbad Councilman Michael Schumacher during a People for
Ponto presentation/request at the Oct 23, 2018 City Council meeting. The data compiled in the image shows how
the South Coastal Carlsbad (Ponto) is not served by a Park per the City’s adopted Parks Master Plan. The blue dots
on the map are park locations and blue circle(s) show the City’s Park Master Plan adopted Park Service Areas and
Park Equity. This data, from pages 87-88 of the City of Carlsbad Parks Master Plan, shows all City Parks (both
Community Parks and Special Use Areas in Coastal Carlsbad (except Aviara Park east of Poinsettia Park and west of
Alga Norte Park). The text on the left margin identifies the South Carlsbad Coastal Park (west of I-5) gap along with
the number of South Carlsbad Citizens (over half the City’s population) without a Coastal Park. The left margin also
identifies more local issues for the over 2,000 Ponto area adults and children. For Ponto residents the nearest Public
Park and City proposed ‘solution’ to the South Carlsbad and Ponto Public Park deficit are miles away over high-
speed/traffic roadways and thus somewhat hazardous to access and effectively unusable by children/the elderly or
Page 14 of 30
those without cars. Having been a 20-year resident of Ponto I regularly see our children have to play in the street as
there are no Public Park with large open fields to play at within a safe and under 1-hour walk away. Ponto citizens
have submitted public comments regarding this condition and the lack of a Park at Ponto
Ponto is at the center of regional 6-mile Coastal Park Gap. A Coastal Park in this instance being a Public Park with
practical green play space and a reasonable connection with the Coast (i.e. located west of the regional rail and
Interstate-5 corridors). The following image shows this larger regional Coastal Park Gap centered on the Ponto Area,
and the nearest Coastal Parks – Cannon Park to the north, and Moonlight Park to the south.
Regionally this image shows Ponto is the last remaining significant vacant Coastal land that could accommodate a
Coastal Park to serve the Coastal Park current needs of over existing 2,000 Ponto residents, 64,000 existing South
Carlsbad residents, and a larger regional population. It is also the only area to serve the Coastal Park needs for the
thousands of hotel rooms in Upland Visitor Accommodations in South Carlsbad.
No Coastal Park in South Carlsbad
• Appx. 6 miles of Coast
without a Coastal Park is a
City & Regional need
• South Carlsbad has 64,000
residents & thousands of
hotel visitors with out a
Coastal park
• Closest park to Ponto is
Poinsettia Park, approx. 2.5
miles across 1-5
• Proposed Veterans Park is
approx. 6 miles away --
< ~ -V -~ .._. ___ ..._ ...............
~ .... c...i.ihfl .. _S.... ~~-._.-n.,..,..,o'-"""'-'11•-
~ n.Wlet<-~•""'-•• ,_~ __ .,,,,.,. ..
~~~\_., ---·--.. -c--.... ... ~---.-~,c~ ...,. __ ... c....t.1, ... ,
Page 15 of 30
As People for Ponto first uncovered and then communicated in 2017 to the City and CCC; Carlsbad’s Existing (since 1994)
Local Coastal Program LUP currently states (on page 101) that Ponto’s Planning Area F: carries a Non-Residential
Reserve (NRR) General Plan designation. Carlsbad’s Existing Local Coastal Program Land Use Plan states: “Planning Area
F carries a Non-Residential Reserve (NRR) General Plan designation. Planning Area F is an “unplanned” area …” and
requires that: “… As part of any future planning effort, the City and Developer must consider and document the need
for the provision of lower cost visitor accommodations or recreational facilities (i.e. public park) on the west side of
the railroad.” CA Coastal Commission actions, Carlsbad Public Records Requests 2017-260, 261, and 262, and 11/20/19
City Planner statements confirm the City never fully communicated to Carlsbad Citizens the existence of this LCP
requirement nor did the City comply with the requirements. Of deep concern is that the City is now (as several times in
the past) still not honestly disclosing to citizens and implementing this Existing LCP requirement as a true and authentic
‘planning effort’. The lack of open public disclosure and apparent fear of true public workshops and Public Comment
about the Existing Planning Area F LCP requirements are troubling. The point of a ‘planning effort’ is to openly and
publically present data, publically discuss and explore possibilities/opportunities, and help build consensus on the best
planning options. Citizens are concerned the city has already made up its mind and there is no real “planning effort” in
the proposed Draft LCP Amendment process, just a brief Staff Report and at the end provide citizens 3-minutes to
comment on the proposal. This is not the proper way to treat the last remaining significant vacant land is South
Carlsbad that will forever determine the Coastal Recreation environment for generations of Carlsbad and California
citizens and visitors to come.
The following data/images show how Ponto is in the center of the 6-mile (west of I-5 and Railroad corridor) regional
Coastal Park gap. Ponto is the last remaining vacant and currently “unplanned” Coastal land that is available to address
this regional Coastal Park Gap.
How Ponte Serves Reg ion
Ponto ls in middle
resiCJnalCoastal
ParkGap
COIISUII P,
-8.6% of SD County
coast ·ne
A Ponto Coastal Park
r26,000
64,000
in South
Page 16 of 30
How Ponto Serves Region cont.
• RellevesCollStal
Park congestion in
North carlsbad,
EncinitasandSolana
Beach
• A1eat.v11enlly m:~t~b
Coastal Parkas seen
by:
-Ponto Beach
parking congestion
-current trespass
use of Planning
Area F asa Park
How Ponto Serves Region cont.
• A Ponto Park helps
address2050 and
beyond Regional
Population and
Visitor Growth
demands for Coastal
Pam
• A Ponto Park
provides the lowest-
oost coastal access
Page 17 of 30
How Ponto Serves Region cont.
• Vital park and open
space amenity for
Visitor serving
busin esand
aa:ommodatlons
• 6.6 acre unlqueCity
Coastal Park venue
to stage special
events: Runs, bike
rides, triathlons,
How Ponto Serves Region cont.
• Ottical Park space
for So. carlsbad
state Beach
campground
• Provides a big
training and staging
space for Junior
lifeguards
• Dogwalktrail
Page 18 of 30
One possible Concept image of a potential Ponto Coastal Park at Planning Area F is illustrated below. The potential for a
Ponto Coastal Park is real. The speculative land investment fund (Lone Star Fund #5 USA L.P. and Bermuda L.P.) that
currently owns Planning Area F is selling the property, and is available for the City of Carlsbad to acquire to address the
documented demand/need for a City Park and City Park inequity at Ponto and in Coastal South Carlsbad. A Ponto
Beachfront Park 501c3 is working to acquire donations to help purchase the site for a Park. These situations and
opportunities should be publicly discussed as part of the City Staff’s proposed Local Coastal Program Land Use Plan
Amendment.
Ponto Coastal Park Concept
• A concept-but
shows potential
recreational
opportunities
• Provides vital
parkland support for
beach & ope n play
fie lds
• Concept plan a gift
from San Pacifico
Page 19 of 30
7. Projected increases in California, San Diego County and Carlsbad population and visitor growth increases the
demand for High-Priority-Coastal Recreation land use:
Increasing Citizen demand for Coastal Recreational land needs to be addressed with increased Coastal
Recreation land:
San Diego County Citizen Population - source: SANDAG Preliminary 2050 Regional Growth Forecast
1980 1,861,846
1990 2,498,016
2000 2,813,833
2010 3,095,313
2020 3,535,000 = 46,500 Citizens per mile of San Diego County coastline
2030 3,870,000
2040 4,163,688
2050 4,384,867 = 57,700 Citizens per mile of San Diego County coastline
2020 to 2050 = 24% increase in San Diego County population.
Citizen Population will continue beyond 2050. Carlsbad may plan for ‘Buildout’ in 2050, but what is San
Diego County’s ‘Buildout’? There is a common-sense need to increase the amount of Coastal Recreation
Land Use in the Proposed LCP Amendment to the Land Use Plan for this growing population. If we do not
increase our supply of Coastal Recreational Resources for these increased demands our Coastal Recreation
Resources will become more overcrowded, deteriorated and ultimately diminish the Coastal Recreation
quality of life for Citizens of Carlsbad and California. Ponto sits in the middle of an existing 6-mile regional
Coastal Park Gap (no Coastal Park west of Interstate 5) and there is No Coastal Park in all of South Carlsbad
to address the Coastal Recreation needs of the 64,000 South Carlsbad Citizens.
Page 20 of 30
Increasing Visitor demand for Coastal Recreational land needs to be addressed with increased Coastal
Recreation land:
Yearly Visitors to San Diego County – source: San Diego Tourism Authority; San Diego Travel Forecast, Dec, 2017
2016 34,900,000
2017 34,900,000
2018 35,300,000
2019 35,900,000
2020 36,500,000 = average 100,000 visitors per day, or 2.83% of County’s Population per day, or
1,316 Visitors/coastal mile/day in 2020
2021 37,100,000
2022 37,700,000
This is growth at about a 1.6% per year increase in visitors. Projecting this Visitor growth rate from 2020 to
2050 results in a 61% or 22,265,000 increase in Visitors in 2050 to:
2050 58,765,000 = average 161,000 visitors per day, or 3.67% of the County’s projected 2050
Population per day, or 2,120 Visitors/coastal mile/day in 2050.
The number of Visitors is likely to increase beyond the year 2050. There is a common-sense need to
increase the amount of Coastal Recreation Land Use in the Proposed LCP Amendment to the Land Use Plan
for these projected 2050 61% increase, and beyond 2050, increases in Visitor demand for Coastal
Recreational Resources. Increasing Coastal Recreation land is a vital and critically supporting Land Use and
vital amenity for California’s, the San Diego Region’s and Carlsbad’s Visitor Serving Industry. Ponto sits in
the middle of an existing 6-mile regional Coastal Park Gap (no Coastal Park west of Interstate 5). There are
thousands of hotel rooms in South Carlsbad that have NO Coastal Park to go to in South Carlsbad. This
needs correcting as both a Coastal Act and also a City economic sustainability imperative.
We request that the as part of the public’s review, the City Staff proposed Draft LCP Amendment to the Land
Use Plan clearly document if and/or how future forever ‘Buildout” City, Regional and Statewide population
and visitor population demand for Coastal Recreation and City Coastal Parks are adequately provided for
both in amount and locational distribution in the Carlsbad proposed Amendment of the LCP Land Use Plan.
8. Carlsbad’s Draft Local Coastal Program Land Use Plan Amendment says it plans to a year 2050 buildout of the
Coastal Zone. The Draft Local Coastal Program Land Use Plan Amendment then is the last opportunity to create a
Coastal Land Use Plan to provide “High-Priority” Coastal Recreation Land Use, and will forever impact future
generations of California, San Diego County, and Carlsbad Citizens and Visitors:
The Draft LCPA indicates in 2008 only 9% of All Carlsbad was vacant land. Less is vacant now in 2019.
Carlsbad’s Coastal Zone is 37% of the City, so vacant unconstrained land suitable for providing Coastal
Recreation is likely only 3-4%. The prior request for a full documentation of the remaining vacant Coastal
lands will provide a better understanding needed to begin to make the final ‘buildout’ Coastal Land Use Plan
for Carlsbad. The Draft LCPA does not indicate the amount and locations of currently vacant unconstrained
Coastal Land in Carlsbad. This final limited vacant land resource should be clearly documented and mapped
in the DLCPA as it represents the real focus of the DLCPA – the Coastal Plan for these remaingn undeveloped
Page 21 of 30
lands. These last remaining vacant lands should be primarily used to provide for and equitably distribute
“High-Priority” Coastal Recreation Land Uses consistent with CCA Sections:
i. Section 30212.5 “… Wherever appropriate and feasible, public facilities, including parking areas or
facilities, shall be distributed throughout an area so as to mitigate against the impacts, social and
otherwise, of overcrowding or overuse by the public of any single area.”;
ii. Section 30213 “… Lower cost visitor and recreational facilities shall be protected, encouraged, and,
where feasible, provided. Developments providing public recreational opportunities are
preferred. …”;
iii. Section 30222 “The use of private lands suitable for visitor-serving commercial recreational
facilities designed to enhance public opportunities for coastal recreation shall have priority over
private residential, general industrial, or general commercial development, but not over
agriculture or coastal-dependent industry.”
iv. Section 30223 “Upland areas necessary to support coastal recreational uses shall be reserved for
such uses, where feasible” ,
v. Section 30251 … The location and amount of new development should maintain and enhance public
access to the coast by … 6) assuring that the recreational needs of new residents will not overload
nearby coastal recreation areas by correlating the amount of development with local park
acquisition and development plans with the provision of onsite recreational facilities to serve the
new development”
Adopted City Park Service Area and Park Equity maps discussed earlier document the proposed Draft LCP
Amendment’s inconstancy with the above CCA Policy Sections. The locations and small amounts remaining
vacant Coastal lands provide the last opportunities to correct the inconsistencies of City proposed Draft
“buildout” LCP Land Use Plan Amendment with these Coastal Act Policies.
Currently and since 1996 there has been LCP LUP Policy/regulations for Ponto Planning Area F that require
consideration of a “Public Park” prior to changing the existing “unplanned Non-residential Reserve” Land
Use designation. A map and data base of vacant developable Coastal land should be provided as part of the
Draft LCPA and the Draft LCPA. This map and data base should document the projected/planned loss of
Coastal land use due to Sea Level Rise. Draft LCPA projects Sea Level Rise will eliminate several beaches and
High-Priority Coastal Land Uses like Coastal Lagoon Trails and the Campground.
The LCP Land Use Plan should plan and reserve the very limited vacant developable Coastal land for the
long-term ‘Buildout’ needs of “High-Priority” Coastal Recreation Land Use. Vacant developable Coastal land
is too scarce to be squandered for “low-priority” uses. Sea Level Rise will reduce “High-Priority” Coastal
Uses. So how vacant developable Upland area should be preserved for “High-Priority” Coastal Uses is a key
requirement to be fully documented and discussed in the Draft LCPA. If not one of two thing will eventually
happen 1) any new Coastal Park land will require very expensive purchase and demolition of buildings or
public facilities to create any new Coastal Park land to meet existing and growing demand; or 2) Coastal
Recreation will hemmed-in my “low-priority” uses and thus force Coastal Recreation to decrease and
become increasing concentrated and overcrowded in its current locations; and thus will promote the
eventual deterioration of our current Coastal Recreation resources. A plan that fails to fix Coastal Park
deficits and then increase Costal Parks in pace with increased population/visitor demand is a plan that can
Page 22 of 30
only result in degradation. How the Draft LCPA documents and addresses the land use planning of the last
small portions of vacant developable Coastal land is critical for the future and future generations.
9. Citizens of South Carlsbad are concerned about the City’s multiple prior flawed Ponto planning processes or
‘mistakes’ the City has made yet is basing the City Staff’s proposed Draft LCP LUP. The concerns being the City is not
openly and honestly communicating information to citizens and the public, and not allowing a reasonable and
appropriate community-based planning process to address the documented Park, Coastal Recreation and
unconstrained open space needs in South Carlsbad. One of these groups of citizens has created a
www.peopleforponto.com website to try to research and compile information and hopefully provide a better means
for citizens to understand facts and then express their concerns/desires to the City of Carlsbad (City) and CA Coastal
Commission (CCC). Over 2,000 emails have sent to the City and CCC regarding Coastal Land Use Planning Issues at
Ponto. The San Pacifico Planned Community (i.e. San Pacifico Community Association) has also, since 2015, sent
numerous emailed letters to the City and CCC noting the significant concerns about changes in Coastal planning the
City is proposing for our Planned Community.
Repeatedly over 90% of surveyed citizens (results emailed prior to both the City and CCC) have expressed the vital
need and desire for a Coastal Park at Ponto to serve the current and future Coastal Recreation needs for all both
Ponto and South Carlsbad and for larger regional and State Coastal Recreational needs. This desire is supported by
data, CA Coastal Act Policy, and also Carlsbad’s Community Vision – the foundation for the City’s General Plan.
Ponto is the last remaining vacant Coastal area available to provide for those needs in South Carlsbad and for a
regional 6-mile stretch of coastline. Citizens have expressed deep concern about the City’s flawed prior Coastal
planning efforts for Coastal Recreation at Ponto, including two repeated LCP Amendment “mistakes” (Ponto
Beachfront Village Vision Plan in 2010 and General Plan Update in 2015) when the City twice failed to publicly
disclose/discuss and then follow the Existing LCP requirements at Ponto – specifically for Planning Area F. People for
Ponto had to use multiple Carlsbad Public Records Requests in 2017 to find these “mistakes”. CCC Staff was helpful
in both confirming the City “mistakes” and communicating back to the City. As citizens we are still unclear has to
how/why these two repeated “mistakes” happened. There is citizen concern that the City is again repeating these
two prior “mistakes” by not at the beginning of the Public Comment Period clearly and publicly disclosing the
Planning Area F LCP requirements to citizens as part of the current LCP Amendment process, and also by not
implementing the exiting LCP requirement PRIOR to proposing an Amended Coastal Land Use Plan for Ponto. The
City in its proposed LCP Amendment process is putting-the-cart-before-the-horse with respect to honest and open
consideration, documentation and public discussion of the need for high-priority Coastal Recreation land use
required of Planning Area F at Ponto. The City is also not clearly letting all Carlsbad citizens know about the Existing
LCP requirements for Ponto’s Planning Area F so they can be informed to reasonably participate in public review and
comment regarding amending that LCP requirement, and the need for Coastal Recreation land uses in South
Carlsbad. Since 2017 there has been repeated citizen requests to the City (copies were provided to the CCC) to fix
these multiple fundamental/foundational flaws by in the City’s prior Coastal Recreation and Public Parks and Open
Space at planning, and the currently Proposed Draft LCP Land Use Plan Amendment. Since 2017 there have also
been repeated citizen requests to the City to provide a truly open, honest, inclusive community-based planning
process and workshops with the accurate and honest information, prior to forming a proposed Draft LCP Land Use
Plan Amendment. As citizens we believe we can constructively work with the City and CCC towards a consensus or
viable options on these important Coastal Recreation issues if the City allows and encourages such an open, honest
and inclusive process. We request the City respond to the requests submitted to the City since 2017, and again
request such a process from the City before any LCP Amendment is first considered by the Planning Commission and
City Council. Such a requested process benefits all.
Page 23 of 30
10. Why the Draft LCPA Land Use Plan for Ponto should provide for the current and future Coastal Park and Recreation
needs for South Carlsbad, the San Diego Region and California.
Ponto, is one of last remaining vacant and undeveloped Coastal lands in North County
Ponto is the last remaining undeveloped Coastal land in South Carlsbad
Ponto has the last unplanned Planning Area of the Existing Poinsettia Shores Planned Community & Local
Coastal Program that can be planned for high-priority Coastal Recreation land use. This Existing LCP requires
Planning Area F be considered for a “Public Park”.
Following is a map of the Ponto area in South Carlsbad:
Following is the LCP Land Use map from the Existing Poinsettia Shores Master Plan & Local Coastal Program adopted
in 1996. This is the Land Use map that the City is proposing to change in the proposed LCP Amendment to the Land
Use Plan. As the Existing LCP Land Use map shows most all the land is ‘low-priority’ residential use at an RM
Residential medium density, a small portion is ‘high-priority’ Visitor Serving TC/C Tourist Commercial. Most all the
Page 24 of 30
Open Space is constrained and undevelopable land (the steep CSS habitat bluffs above Batiquitos Lagoon) or water
(the lagoon water). This land/water is owned by the State of California, like the inner lagoon east of I-5. Only
Planning Area M at 2.3 acres is unconstrained Open Space and it provides a small private internal recreation facility
for the approximately 450 homes and 1,000 people in the Planned Community. This small recreation area is a City
requirement for ‘planned developments’ to off-set loss open space from planned development impacts on housing
quality. Planned developments can propose designs that reduce normal setback and open space areas – they bunch
together buildings to increase development – such as the smaller lot sizes, and extensive use of “zero-setbacks” to
reduce typical lot sizes that occurs at Poinsettia Shores. A private recreation facility in any of the City’s planned
developments is never considered a replacement for required City Parks. Planned Developments, like unplanned
developments, are required to dedicate Park land to the City, or pay a Park In-Lieu fee to the City so the City provide
the developer’s obligation to provide City Park acreage to address the population increase of their proposed planned
development. For Poinsettia Shores’ population the City’s minimum City Park Standard would require developers
set aside 3 acres of City Park land for local park needs. For the larger Ponto area population about 6.6 acres of City
Park Land is required. The Existing LCP reserves Planning Area F as an unplanned “Non-residential Reserve” Land
Use until the Public Park needs for Ponto are considered and documented. Only then can the NRR land use be
changed.
11. Developers have overbuilt in the Ponto area of the Coastal Zone. The City of Carlsbad has under questionable
circumstances is currently choosing to ‘exempted’ Ponto developers from providing the minimum amount of
unconstrained Open Space according to the City’s developer required Open Space Public Facilities Standard. The
legality of these confusing circumstances is subject to a lawsuit against the City. However the City’s computerize
mapping system has documented that the Ponto area of the Coastal Zone is missing about 30-acres of
Unconstrained Open Space that can be used to fulfill the City’s Open Space Performance Standard that states that
Page 25 of 30
15% of unconstrained and developable land must be preserved by developers as Open Space. Following is a
summary of data from the City data regarding the missing Open Space at Ponto (Local Facility Management Plan
Zone 9, LFMP Zone 9) in the Coastal Zone pursuant to the City’s Open Space Performance Standard. If it is desirable
People for Ponto can provide the City GIS map and parcel-by-parcel data base on which the following summary is
based:
City of Carlsbad GIS data calculations of Open Space at Ponto area of Coastal Zone:
472 Acres = Total land in LFMP Zone 9 [Ponto area] per City of Carlsbad GIS data
(197 Acres) = Constrained land/water/infrastructure that is excluded from the City’s Open Space Standard
275 Acres = Unconstrained land in LFMP Zone 9 (Ponto) subject to the City’s Open Space Standard
X 15% = Minimum unconstrained Open Space requirement per the City Open Space Standard
41 Acres = Minimum unconstrained Open Space required in LFMP Zone 9
(11 Acres) = Actual unconstrained Open Space provided & mapped by City in LFMP Zone 9
30 Acres = Missing unconstrained Open Space needed in LFMP Zone 9 [Ponto area of Coastal Zone] to meet the
City’s minimum GMP Open Space Standard. 73% of the required Open Space Standard is missing.
Thus the Ponto area of the Coastal Zone appears overdeveloped with 30 additional acres of “low-priority” residential
land uses due to developers’ non-compliance to the City’s Open Space Public Facility Performance Standard’s
Minimum developer required Open Space requirement. As noted a citizens group has a pending lawsuit with the
City over the City’s current ‘exempting’ Ponto and future developers from meeting the Open Space Standard.
12. The prior pre-1996 LCP for Ponto – the Batiquitos Lagoon Educational Park Master Plan & LCP (BLEP MP/LCP) had
significant Open Space and recreational areas. These significant Open Space and Recreational areas where removed
with BLEP MP/LCP’s replacement in 1996 by the currently existing Poinsettia Shores Master & LCP (PSMP/LCP) and
its City Zoning and LCP LUP requirements that reserved Planning Area F with the current “Non-residential Reserve”
Land Use designation. Since the BLEP MP/LCP it appears developers and the City of Carlsbad have worked to
remove “High-Priority” Coastal land uses (i.e. Coastal Recreation and Park uses) out of the Ponto area and replaced
them with more “low-priority” residential and general commercial land uses. For example:
Planning Area F used to be designated “Visitor Serving Commercial” as part of the original 1980’s BLEP
MP/LCP for Ponto.
In 1996 the BLEP MP LCP was changed by developer application to the now current PSMP LCP, and the LCP
LUP designation changed from “Visitor Serving Commercial” to “Non-Residential Reserve” with the
requirement to study and document the need for “High-Priority” Coastal Recreation (i.e. Public Park) and/or
Low-cost visitor accommodations prior to any change to Planning Area F’s “Non-residential Reserve” LCP
land use.
In 2005 the City started to try to change Planning Area F to low-priority residential and general commercial
land use in the City’s Ponto Beachfront Village Vision Plan (PBVVP). At this time the City made its first
documented Coastal ‘planning mistake’ by not disclosing to the public the existence of Planning Area F’s LCP
requirements and then also not following those LCP requirements. The City’s planning process seemed
focused on addressing developer’s land use desires, and increasing land use intensity to boost “Tax-
increment financing” as the City had established a Redevelopment Project Area at Ponto. A short time after
the State of CA dissolved Redevelopment Agencies due in part to such abuses by cities. The CCC formally
rejected the PBVVP in 2010, citing the City’s failure to follow the LCP requirements for Planning Area F.
Page 26 of 30
Five years later in 2015 the City again adopted a proposed General Plan Update to again change Planning
Area F to low-priority residential and general commercial land use. The General Plan Update cited the City’s
PBVVP that was in fact rejected by the CCC only a few years before. The City again repeated their PBVVP’s
Coastal land use ‘planning mistake’ by again not disclosing to the public the existence of Planning Area F’s
LCP requirements and then not following those LCP requirements. It is unclear why the City did this only 5-
years after the CCC specifically rejected the Ponto Beachfront Village Vision Plan for those same reasons.
In 2017 citizens found and then confirmed these Ponto Coastal ‘planning mistakes’ by the City through
multiple official Carlsbad Public Records Requests and CCC Staff confirmation. The CCC readily identified the
mistakes, but the City’s 2019 proposed Draft LCP Land Use Plan and planning process still has yet fully
disclose these prior Coastal ‘planning mistakes’ to ALL citizens of Carlsbad - the failure to disclose and follow
the Planning Area F LCP LUP and City Zoning requirements. Full City disclosure is needed now to try to
correct many years of City misrepresentation to citizens on LCP required Coastal land Use planning at Ponto.
It is needed now so the public is aware at the start of the Public Comment Period. In 2017 citizens began
asking the City fix the City’s over 12-years of misinformation and planning mistakes by ‘restarting’ Coastal
land use planning at Ponto with an open and honest community-based Coastal planning process. These
citizens’ requests have been rejected.
In 2019 the City Staff proposed citywide Draft LCP land Use Plan Amendment that again proposed to change
Planning Area F to “low-priority” residential and general commercial land use, without First disclosing the
Planning Area F LCP requirements with corresponding analysis of the Need for Coastal Recreation (i.e. Public
Park) and/or low-cost visitor accommodations at Planning Area F and providing that Documented analysis
for public review/Consideration/comment. This seems like another 3rd repeat of the prior two Coastal
planning mistakes by the City. In 2019, again citizens asked for a reset and a true community-based process
for the last remaining significant vacant Coastal lands – including Ponto. Again the City rejected citizens’
requests.
In 2020 thousands of public requests again asked, and are currently asking, for a reset and a true
community-based process for the last remaining significant vacant Coastal lands – including Ponto. Again
these requests are being rejected. Based on the significant citizen concern and the documented prior
‘planning mistakes’ at Ponto it appears reasonable and responsible for Ponto’s Planning Area F to ether:
i. Retain its current Existing LCP LUP land Use of “Non-Residential Reserve” until such time as the
City’s past Ponto Beachfront Village Vision Plan and General Plan Update planning mistakes and
other issues subject to current planning lawsuits against the City are resolved with a true, honest
and open community-based Coastal planning process asked for by citizens since 2017. Or
ii. Propose in the Draft LCP Land Use Plan Amendment to re-designated Planning Area F back to a
Visitor Serving Commercial and Open Space (“i.e. Public Park”) to provide both “High-Priory” coastal
uses v. low-priority residential/general commercial uses due to the documented Coastal Recreation
and Low-cost visitor accommodation needs for both citizens and visitors at Ponto and South
Carlsbad.
13. Questionable logic and inconsistency in proposed Draft land use map and policies: Chapter 2 Figure 2-2B & C on
pages 2-19 & 20 proposes to Amend the existing LCP Land Use Plan Map, and policies LCP-2-P.19 and 20 on pages 2-
27 to 2-29 propose Amendments to existing LCP policy and create a new added layer of policy referencing a
Ponto/Southern Waterfront. The proposed Land Use Map and Policies serve to firmly plan for “low-priority”
residential and general commercial land uses at Ponto with a clear regulatory Land Use Plan Map showing these
land uses and by specific regulatory policy (LCP-2-20) that clearly requires (by using the words “shall”) these “low
Page 27 of 30
priority” uses. In contrast the “High-Priority” Coastal Recreation and Coastal Park land uses that would be
designated as Open Space are not mapped at all in Figure 2-2B & C; and the proposed policy LCP-2-P.19 is both
misleading and specifically does Not Require any “High-Priority” Coastal Recreation and Coastal Park land Use at
Ponto and South Carlsbad. In fact page 2-22 specifically indicates two “may” criteria that would first need to occur
in the positive before any potential Coastal Recreation and Coastal Park Land could then theoretically even be
possible. It is highly probable that it is already known by the City that the proposed relocation of Carlsbad Boulevard
(Coast Highway) is not very feasible and not cost effective, and will not yield (due to environmental habitat
constraints, narrowness of the roadway median, and other design constraints) any significant dimensions of land
that could potentially be designated Open Space and realistically be used as a Park.
The blank outline map (Figure 2-2B &C) provides no mapped Open Space Land Use designation, other than for the
currently existing State Campgrounds’ low-cost visitor accommodations, so the proposed Land Use Plan Map is Not
providing/mapping any new Open Space land use to address Coastal Recreation and Coastal Park needs. The Draft
LCP Land Use Plan Amendment’s proposed/projected/planned Sea Level Rise and associated coastal erosion appears
to indicate that this “High-Priority” low-cost visitor accommodation (Campground) land use designated as Open
Space will be reduced in the ‘Buildout’ condition due to coastal erosion. So the Draft LCP Land Use Plan is actually
planning for a Reduction in Open Space Land Use in South Carlsbad and Ponto. Both the blank outline map and
the proposed Land Use Map Figure 2-1 DO NOT clearly map and designate both South Carlsbad’s Draft LCP Planned
Loss of the Open Space Land Use and also any New or replacement unconstrained land as Open Space land use for
Coastal Recreation and Coastal Park. This is an internal inconsistency in Land Use Mapping that should be corrected
in two ways:
1) Showing on all the Land Use (Figure 2-1), Special Planning Area (Figure 2-2B & C), and other Draft LCP Maps
the Draft LCP’s planned loss of land area in those maps due to the Draft LCP’s planned loss of land due to
Sea Level Rise and Coastal Land Erosion. This is required to show how land use boundaries and Coastal
Recourses are planned to change over time. or
2) Provide detailed Land Use Constraint Maps for the current Carlsbad Boulevard right-of-way that the City
“may” or ‘may not’ choose (per the proposed “may” LCP-2-P.19 policy) use to explore to address the City’s
(Park Master Plan) documented Coastal Recreation and Coastal Park land use shortages in Coastal South
Carlsbad and Ponto. Clearly showing the potential residual Unconstrained Land within a Carlsbad Boulevard
relocation that have any potential possibility to add new Open Space Land Use Designations (for Coastal
Recreation) is needed now to judge if the policy is even rational, or is it just a Trojan horse.
The proposed internal inconsistency in mapping and policy appears like a plan/policy ‘shell game’. The proposed
Land Use Plan Maps and Policies should be consistent and equality committed (mapped-shall v. unmapped-may) to
a feasible and actual Plan. If not then there is No real Plan.
There is no Regulatory Policy requirement in LCP-2-P.19 to even require the City to work on the two “may” criteria.
The City could choose to bury the entire Carlsbad Boulevard relocation concept and be totally consistent with Policy
LCP-2-P.19 and the LCP. As such the language on 2-22, Figure 2-2C (and the proposed Land Use Map), and policy
LCP-2-P.19 and 20 appear conspire to create a shell game or bait-and-switch game in that only “low-priority”
residential and general commercial uses are guaranteed (by “shall” policy) winners, and “high-priority” Coastal
Recreation and Coastal Park Land Uses are at best a non-committal ‘long-shot” (“may” policy) that the city is
specifically not providing a way to ever define, or commit to implement. The proposed Draft LCP Land Use Plan
Coastal Recreation and Coastal Park statements for Ponto are just words on paper that are designed to have no
force, no commitment, no defined outcome, and no defined requirement to even have an outcome regarding the
Page 28 of 30
documented “High-Priority” Coastal Recreation and Costal Park needs at Ponto, Coastal South Carlsbad and the
regional 6-mile Coastal Park gap centered around Ponto.
Policy LCP-2-P.19 falsely says it “promotes development of recreational use” but does not in fact do that. How is
development of ‘recreational use promoted’ when the Use is both unmapped and no regulatory policy requirement
and commitment (no “shall” statement) to ‘promote’ that Use is provided? Policy LCP-2-19.19 appears a misleading
sham that does not ‘promote’ or require in any way “High-Priority” Coastal Recreation and Park Land Use at Ponto.
There should be open and honest public workshops before the Draft LCP Amendment goes to its first public hearing
to clearly define the major environmental constraints and cost estimates involving possible relocation of Carlsbad
Boulevard and constructing needed beach access parking, and sufficient and safe sidewalks and bike paths along
Carlsbad Boulevard; and then map the amount and dimensions of potential ‘excess land’ that maybe available for
possible designation as Open Space in the City General Plan and Local Coastal Program. The City should not repeat
the mistakes at the Carlsbad Municipal Golf Course (resulting in the most expensive to construct maniple course in
the USA) by not defining and vetting the concept first. A preliminary review of City GIS data appears the amount,
dimensions and locations of any potential ‘excess’ land maybe modest at best. However before the City proposes a
‘Buildout’ Coastal Land Use Plan this critical information should be clearly provided and considered. It is likely the
City’s Carlsbad Boulevard relocation concept is unfeasible, inefficient, too costly, and yields too little actual useable
‘excess land’ to ever approach the Coastal Recreation and Coastal Park needs for South Carlsbad. This may already
be known by the City, but it surely should be publicly disclosed and discussed in the DLPCA.
The proposed Coastal Land Use Plan to address Carlsbad’s, San Diego County’s and California’s High-Priority Coastal
Recreation Land Use and Coastal Park needs should NOT be vague “may” policy that appears to be purposely
designed/worded to not commit to actually providing any “High-Priority” Coastal Recreation and Coastal Park land
uses on the map or in policy commitments. The Land Use Plan and Policy for High-Priority Coastal Recreation and
Coastal Park Land Use should be definitive with triggered “shall” policy statements requiring and assuring that the
‘Forever’ “High-Priority” Coastal Recreation and Coastal Park needs are properly and timely addressed in the City’s
proposed ‘Buildout’ Coastal Land Use Plan. This “shall” policy commitment should be clearly and consistently
mapped to show the basic feasibility of the planned outcomes and the resulting actual Land that could feasibly
implement the planned outcome.
Providing safe and sufficient sidewalks, bike paths, and public parking along Carlsbad Boulevard: Providing safe and
sufficient sidewalks, bike paths, and public parking along Carlsbad Boulevard are Coastal Access and Completes
Streets issues. South Carlsbad Boulevard now and has for decades been a highly used Incomplete Street that is out
of compliance with the City’s minimum Street Standards for pedestrian and bike access and safety. The Coastal
Access portion of the Draft Land Use Plan should strongly address the Complete Street requirements for South
Carlsbad Boulevard. Those policy commitments should be reference in Policy LCP-2-P.19 and 20 as Carlsbad
Boulevard in South Carlsbad is the most Complete Street deficient portion of Carlsbad Boulevard. Forever Coastal
Access parking demand and the proposed LCP Amendment’s Land Use Plan to supply parking for those demands
should also be addressed as part of the Coastal Access and Complete Streets issues for South Carlsbad Boulevard. If
much needed Coastal Access Parking is provided on South Carlsbad Boulevard as part of a “maybe” implemented
realignment, most of the “maybe” realignment land left after constraints are accommodated for and buffered will
likely be consumed with these parking spaces and parking drive aisles/buffer area needed to separate high-speed
vehicular traffic from parking, a buffered bike path, and a sufficiently wide pedestrian sidewalk or Coastal Path.
After accommodating these much needed Complete Street facilitates there will likely be little if any sufficiently
Page 29 of 30
dimensioned land available for a Coastal Recreation and a Coastal Park. The needed Coastal Access and Complete
Street facilities on South Carlsbad Boulevard are very much needed, but they are NOT a Coastal Park.
As mentioned the proposed Draft Coastal Land Use Plan’s Maps and Policies are very specific in providing for the
City’s proposed LCP Land Use changes to ‘low-priority” Residential and General Commercial’ on Planning Area F
(proposed to be renamed to Area 1 and 2). It is curious as to why the proposed Draft LCP Land Use Plan
Amendment has no Land Use Map and minor vague unaccountable Land Use Policy concerning ‘High-priority Coastal
Recreation Land Use’ at Ponto, while the very same time proposing very clear Land Use Mapping and detailed
unambiguous “shall” land use policy requirements for ‘low-priority” Residential and General Commercial land use at
Ponto. Why is the City Not committing and requiring (in a Land Use Map and Land Use Policy) to much needed
‘High-priority” Coastal Recreation and Coastal Park Land Use’ needs at Ponto the same detail and commitment as
the City is providing for “low-priority” uses? This is backwards and inappropriate. It is all the more inappropriate
given the ‘Buildout’ Coastal Land Use Plan the City is proposing at Ponto. These issues and plan/policy commitments
and non-commitments will be ‘forever’ and should be fully and publicly evaluated as previously requested, or the
Exiting LCP Land Use Plan of “Non-residential Reserve” for Planning Area F should remain unchanged and until the
forever-buildout Coastal Recreation and Coastal Park issues can be clearly, honestly and properly considered and
accountably planned for. This is vitally important and seems to speak to the very heart of the CA Coastal Act, its
founding and enduring principles, and its policies to maximize Coastal Recreation. People for Ponto and we believe
many others, when they are aware of the issues, think the City and CA Coastal Commission should be taking a long-
term perspective and be more careful, thorough, thoughtful, inclusive, and in the considerations of the City’s
proposal/request to permanently convert the last vacant unplanned (Non-residential Reserve) Coastal land at Ponto
to “low-priority” land uses and forever eliminate any Coastal Recreation and Coastal Park opportunities.
14. Public Coastal View protection: Avenida Encinas is the only inland public access road and pedestrian sidewalk to
access the Coast at Ponto for one mile in each direction north and south. It is also hosts the regional Coastal Rail
Trail in 3’ wide bike lanes. There exist now phenomenal coastal ocean views for the public along Avenida Encinas
from the rail corridor bridge to Carlsbad Boulevard. It is assumed these existing expansive public views to the ocean
will be mostly eliminated with any building development seaward or the Rail corridor. This is understandable, but
an accountable (‘shall”) Land Use Plan/Policy addition to proposed Policy LCP-2-P.20 should be provided for a
reasonable Public Coastal View corridor along both sides of Avenida Encinas and at the intersection with Carlsbad
Boulevard. Public Coastal view analysis, building height-setback standards along Avenida Encinas, and building
placement and site design and landscaping criteria in policy LCP-2-P.20 could also considered to reasonably provide
for some residual public coastal view preservation.
15. Illogical landscape setback reductions proposed along Carlsbad Boulevard, and Undefined landscape setback along
the Lagoon Bluff Top and rail corridor in Policy LCP-2-P.20: Logically setbacks are used in planning to provide a
buffering separation of incompatible land uses/activities/habitats. The intent of the setback separation being to
protect adjacent uses/activities/habitats from incompatibility, nuisance or harassment by providing a sufficient
distance/area (i.e. setback) between uses/activities/habitats and for required urban design aesthetics – almost
always a buffering landscaping. Policy LCP-2-P.20. A.4 and C.3 says the required 40’ landscape setback along
Carlsbad Boulevard “maybe reduced due to site constraints or protection of environmental resources.” The ability
to reduce the setback is illogical in that setbacks are intendent to protect environmental resources and provide a
buffer for constraints. In the Carlsbad Boulevard right-of-way there is documented sensitive environmental habitat,
along with being a busy roadway. How could reducing the protective 40’ setback in anyway better protect that
habitat or provide a better landscaped compatibility or visual aesthesis buffer along Carlsbad Boulevard? It is
Page 30 of 30
illogical. If anything the minimum 40’ landscaped setback should likely be expanded near “environmental
resources”. Regarding reducing the minimum 40’ landscape setback for “site constraints” there is no definition of
what a “site constraint” is or why it (whatever it may be) justifies a reduction of the minimum landscaped setback.
Is endangered species habitat, or a hazardous geologic feature, or a slope, or on-site infrastructure considered a
“site constraint”? There should be some explanation of what a “site constraint” is and is not, and once defined if it
warrants a landscape setback reduction to enhance the buffering purpose of a landscape setback. Or will a
reduction only allow bringing the defined constraint closer to the adjacent uses/activities/habitats that the
landscape setback is designed to buffer. It is good planning practice to not only be clear in the use of terms; but
also, if a proposed reduction in a minimum standard is allowed, to define reasonably clear criteria for that
reduction/modification and provide appropriate defined mitigation to assume the intended performance objectives
of the minimum landscape setback are achieved.
Policy LCP-2-P.20.C.4 is missing a critical Bluff-Top landscape setback. It seems impossible that the DLCPA is
proposing no Bluff-Top setback from the lagoon bluffs and sensitive habitat. The Batiquitos Lagoon’s adjoining steep
sensitive habitat slopes directly connect along the Bluff-top. Batiquitos Lagoon’s and adjoining steep sensitive
habitat is a sensitive habitat that requires significant setbacks as a buffer from development impacts. Setbacks
similar to those required for the San Pacifico area inland of the rail corridor, should be provided unless updated
information about habitat sensitivity or community aesthetics requires different setback requirements.
Policy LCP-2-P.20 does not include a landscape setback standard adjacent to the rail corridor. This is a significant
national transportation corridor, part of the 2nd busiest rail corridor in the USA. Train travel along this corridor is
planned to increase greatly in the years to come. Now there is significant noise, Diesel engine pollution, and
extensive ground vibration due to train travel along the rail corridor. Long freight trains which currently run mostly
at night and weekends are particularly noisy and heavy, and create significant ground vibration (underground noise).
These issues are best mitigated by landscape setbacks and other buffers/barriers. A minimum setback standard for
sufficient landscaping for a visual buffer and also factoring appropriate noise and ground vibration standards for a
buildout situation should be used to establish an appropriate landscape setback that should be provided along the
rail corridor. Carlsbad’s landscape aesthetics along the rail corridor should be factored into how wide the setback
should be and how landscaping should be provided. An example for the landscape aesthetic portion of the setback
standard could be landscape design dimensions of the San Pacifico community on the inland side of the rail corridor.
However, noise and vibrational impacts at San Pacifico are felt much further inland and appear to justify increased
setbacks for those impacts.
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 1 of 7
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto
Introduction:
Carlsbad first documented Sea Level Rise (SLR) and associated increases in coastal erosion in a
December 2017 Sea Level Rise Vulnerability Assessment (2017 SLR Assessment). Prior planning activities
(2010 Ponto Vision Plan – rejected by CA Coastal Commission, and 2015 General Plan Update) did not
consider SLR and how SLR would impact Coastal Open Space Land Use & CA Coastal Act ‘High-Priority’
Coastal Open Space Land Uses at Ponto. The 2017 SLR Assessment shows Open Space land and Open
Space Land Uses are almost exclusively impacted by SLR at Ponto & South Coastal Carlsbad. The 2017
SLF Assessment also shows significant LOSS of Open Space land acreage and Land Uses. Most all
impacted Open Space Land Uses are CA Coastal Act “High-Priority Coastal Land Uses” – Coastal
Recreation (i.e. Public Park) and Low-Cost Visitor Accommodations. Existing Ponto Open Space Land
Uses are already very congested (non-existent/narrow beach) and have very high, almost exclusionary,
occupancy rates (Campground) due to existing population/visitor demands. Future population/visitor
increases will make this demand situation worst. The significant permanent LOSS of existing Coastal
Open Space land and Coastal Open Space Land Use (and land) due to SLR reduces existing supply and
compounds Open Space congestion elsewhere. Prior Ponto planning did not consider, nor plan, for
significant SLR and current/future “High-Priority” Coastal Open Space Land Use demands.
Open Space and City Park demand at Ponto:
Open Space at Ponto is primarily ‘Constrained’ as defined by the City’s Growth Management Program
(GMP), and cannot be counted in meeting the City’s minimal 15% ‘Unconstrained’ GMP Open Space
Standard. Per the GMP Open Space Standard, the developers of Ponto should have provided in their
developments at least 30-acres of additional ‘Unconstrained’ GMP Open Space at Ponto. City GIS
mapping data confirm 30-acres of GMP Standard Open Space is missing at Ponto (Local Facilities
Management Plan Zone 9).
The City of Carlsbad GIS Map on page 2 shows locations of Open Spaces at Ponto. This map and its
corresponding tax parcel-based data file document Ponto’s non-compliance with the GMP Open Space
Standard. A summary of that City GIS data file is also on page 2. The City said Ponto’s non-compliance
with the GMP Open Space Standard was ‘justified’ by the City ‘exempting’ compliance with the
Standard. The City ‘justified’ this ‘exemption’ for reasons that do not appear correct based on the City’s
GIS map and data on page 2, and by a review of 1986 aerial photography that shows most of Ponto as
vacant land. The City in the Citywide Facilities Improvement Plan (CFIP) said 1) Ponto was already
developed in 1986, or 2) Ponto in 1986 already provided 15% of the ‘Unconstrained’ land as GMP
Standard Open Space. Both these ‘justifications’ for Ponto ‘exemption’ in the CFIP were not correct.
The legality of the City ‘exempting’ Ponto developers from the GMP Open Space Standard is subject to
current litigation.
The City proposes to continue to exempt future Ponto developers from providing the missing 30-acres of
minimally required GMP Open Space, even though a change in Ponto Planning Area F land use from the
current ‘Non-Residential Reserve” Land Use requires comprehensive Amendment of the Local Facilitates
Management Plan Zone 9 to account for a land use change. City exemption is subject of litigation.
Ponto (west of I-5 and South of Poinsettia Lane) currently has 1,025 homes that per Carlsbad’s minimal
Park Standard demand an 8-acre City Park. There is no City Park at Ponto. Coastal Southwest Carlsbad
has an over 6.5 acre Park deficit that is being met 6-miles away in NW Carlsbad. Ponto is in the middle
of 6-miles of Coastline without a City Coastal Park west of the rail corridor.
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 2 of 7
City GIS map of Ponto’s (LFMP Zone 9)
Open Space:
Light green areas meet the City’s 15%
unconstrained Growth Management
Program Open Space Standard
Most Ponto Open Space (pink hatch &
blue [water] on map) is “Constrained”
and does not meet the Standard
Aviara - Zone 19, Ponto - Zone 9 and
Hanover/Poinsettia Shores – Zone 22
all developed around the same time
and had similar vacant lands.
City required Aviara - Zone 19 east of
Ponto to provide the 15% Standard
Open Space. Why not Ponto? Aviara
had the same lagoon waters.
City required Hanover & Poinsettia
Shores area Zone 22 just north of
Ponto to provide the 15% Standard
Open Space. Why not Ponto?
Why Ponto developers were never
required to comply with the 15%
Standard Open Space is subject to
current litigation
Below is City GIS data from this map
City GIS map data summary of the 15% Growth Management Standard Open Space at Ponto
472 Acres Total land in LFMP Zone 9 [Ponto]
(197 Acres) Constrained land excluded from GMP Open Space
275 Acres Unconstrained land in LFMP Zone 9 [Ponto]
X 15% GMP Minimum Unconstrained Open Space requirement
41 Acres GMP Minimum Unconstrained Open Space required
(11 Acres) GMP Open Space provided & mapped per City GIS data
30 Acres Missing Unconstrained Open Space needed in LFMP Zone 9 [Ponto] to meet the City’s
minimum GMP Open Space Standard per City’s GIS map & data
73% of the City’s minimum 15% required Open Space Standard is missing due to over
development of LFMP Zone 9 [Ponto]
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Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 3 of 7
Sea Level Rise impacts on Open Space and Open Space Land Use Planning at Ponto:
The City’s 2015 General Plan Update did not factor in the impacts of Sea Level Rise (SLR) on Ponto’s
Open Space land. In December 2017 the City conducted the first Sea Level Rise Vulnerability
Assessment https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=33958. The 2017 SLR
Assessment is an initial baseline analysis, but it shows significant SLR impacts on Ponto Open Space.
More follow-up analysis is being conducted to incorporate newer knowledge on SLR projections and
coastal land erosion accelerated by SLR. Follow-up analysis may likely show SLR impacts occurring
sooner and more extreme.
Troublingly the 2017 SLR Assessment shows SLR actually significantly reducing or eliminating Open
Space land at Ponto. SLR is projected to only impact and eliminate Open Space lands and Open Space
Land Use at Ponto. The loss of Ponto Open Space land and Land Use being at the State Campground,
Beaches, and Batiquitos Lagoon shoreline. The losses of these Open Space lands and land uses would
progress over time, and be a permanent loss. The 2017 SLR Assessment provides two time frames near-
term 2050 that match with the Carlsbad General Plan, and the longer-term ‘the next General Plan
Update’ time frame of 2100. One can think of these timeframes as the lifetimes of our children and
their children (2050), and the lifetimes of our Grandchildren and their children (2100). SLR impact on
Coastal Land Use and Coastal Land Use planning is a perpetual (permanent) impact that carries over
from one Local Coastal Program (LCP) and City General Plan (GP) to the next Updated LCP and GP.
Following (within quotation marks) are excerpts from Carlsbad’s 2017 Sea Level Rise Vulnerability
Assessment:
[Italicized text within brackets] is added data based on review of aerial photo maps in the Assessment.
“Planning Zone 3 consists of the Southern Shoreline Planning Area and the Batiquitos Lagoon. Assets
within this zone are vulnerable to inundation, coastal flooding and bluff erosion in both planning
horizons (2050 and 2100). A summary of the vulnerability assessment rating is provided in Table 5. A
discussion of the vulnerability and risk assessment is also provided for each asset category.
5.3.1. Beaches
Approximately 14 acres of beach area is projected to be impacted by inundation/erosion in 2050. …
Beaches in this planning area are backed by unarmored coastal bluffs. Sand derived from the natural
erosion of the bluff as sea levels rise may be adequate to sustain beach widths, thus, beaches in this
reach were assumed to have a moderate adaptive capacity. The overall vulnerability rating for beaches
is moderate for 2050.
Vulnerability is rated moderate for the 2100 horizon due to the significant amount of erosion expected
as the beaches are squeezed between rising sea levels and bluffs. Assuming the bluffs are unarmored in
the future, sand derived from bluff erosion may sustain some level of beaches in this planning
area. A complete loss of beaches poses a high risk to the city as the natural barrier from storm waves is
lost as well as a reduction in beach access, recreation and the economic benefits the beaches provide.
5.3.3. State Parks
A majority of the South Carlsbad State Beach day-use facilities and campgrounds (separated into
four parcels) were determined to be exposed to bluff erosion by the 2050 sea level rise scenario
(moderate exposure). This resource is considered to have a high sensitivity since bluff erosion
could significantly impair usage of the facilities. Though economic impacts to the physical structures
within South Carlsbad State Beach would be relatively low, the loss of this park would be significant
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 4 of 7
since adequate space for the park to move inland is not available (low adaptive capacity). State
parks was assigned a high vulnerability in the 2050 planning horizon. State park facilities are recognized
as important assets to the city in terms of economic and recreation value as well as providing low-cost
visitor serving amenities. This vulnerability poses a high risk to coastal access, recreation, and
tourism opportunities in this planning area.
In 2100, bluff erosion of South Carlsbad State Beach day-use facilities and campgrounds become
more severe and the South Ponto State Beach day-use area becomes exposed to coastal flooding
during extreme events. The sensitivity of the South Ponto day-use area is low because impacts to usage
will be temporary and no major damage to facilities would be anticipated. Vulnerability and risk to State
Parks remains high by 2100 due to the impacts to South Carlsbad State Beach in combination
with flooding impacts to South Ponto.
Table 5: Planning Zone 3 Vulnerability Assessment Summary [condensed & notated]:
Asset Horizon Vulnerability
Category [time] Hazard Type Impacted Assets Rating
Beaches 2050 Inundation/Erosion, Flooding 14 acres (erosion) Moderate
2100 Inundation/Erosion, Flooding 54 acres (erosion) Moderate
Public Access 2050 Inundation, Flooding 6 access points Moderate
4,791 feet of trails
2100 Inundation, Flooding 10 access points Moderate
14,049 feet of trails
State Parks 2050 Flooding, Bluff Erosion 4 parcels [<18 Acres] High
[Campground - 2100 Flooding, Bluff Erosion 4 parcels [>18 Acres] High
Low-cost Visitor [loss of over 50% of
Accommodations] the campground &
its Low-cost Visitor
Accommodations,
See Figure 5.]
Transportation 2050 Bluff Erosion 1,383 linear feet Moderate
(Road, Bike, 2100 Flooding, Bluff Erosion 11,280 linear feet High
Pedestrian)
Environmentally 2050 Inundation, Flooding 572 acres Moderate
Sensitive 2100 Inundation, Flooding 606 acres High
Lands
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 5 of 7
.,,...,,~c;........,,...,,
D 11~•\;ll)-<(.I>' Cb•
Southern Shortfine PlanningArEa-Year 2050
CXIUOITOG
1,:::,1 .. ,
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 6 of 7
[Figure 5 show the loss of over 50% of the campground and campground sites with a minimal .2 meter
Sea Level Rise (SLR), and potentially the entire campground (due to loss of access road) in 2 meter SLF.]”
Directions to analyze and correct current and future LOSS of Coastal Open Space Land Use at Ponto
On July 3, 2017 the CA Coastal Commission provided direction to Carlsbad stating:
“The existing LUP includes policies that require certain visitor-serving developments and/or
studies relevant to the Ponto … area. For example, Planning Area F requires the city and
developer to "consider and document the need for the provision of lower cost visitor
accommodations or recreational facilities (i.e., public park) on the west side of the railroad. …
this study should be undertaken as a part of the visitor serving use inventory analysis described
above. If this analysis determines that there is a deficit of low cost visitor accommodations or
recreation facilities in this area, then Planning Area F should be considered as a site where these
types of uses could be developed.”
Official Carlsbad Public Records Requests (PRR 2017-260, et. al.) confirmed Carlsbad’s Existing LCP and
its Ponto specific existing LUP polices and Zoning regulations were never followed in the City’s prior
Ponto planning activities (i.e. 2010 Ponto Vision Plan & 2015 General Plan Update). The projected SLR
loss of recreation (beach) and low-cost visitor accommodations (campground) at Ponto should factor in
this Existing LCP required analysis, and a LCP-LUP for Ponto and Ponto Planning Area F.
In a February 11, 2020 City Council Staff Report City Staff stated:
“On March 14, 2017, the City Council approved the General Plan Lawsuit Settlement Agreement
(Agreement) between City of Carlsbad and North County Advocates (NCA). Section 4.3.15 of the
Agreement requires the city to continue to consider and evaluate properties for potential
acquisition of open space and use good faith efforts to acquire those properties.”
{'Cityof
Carlsbad
C a l lfo r nl u Sea Level Rise Vulnerability Assessment
Figure 5: CoSMoS Bluff Erosion Projections by 2100
(CoSMoS-COAST 2015)
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 7 of 7
In 2020 NCA recommended the City acquire Ponto Planning Area F as Open Space. The status of City
processing that recommendation is unclear. However the Lawsuit Settlement Agreement and NCA’s
recommendation to the City should also be considered in the required Existing LCP analysis.
Summary:
Tragically Carlsbad’s’ Draft Local Coastal Program – Land Use Plan Amendment (DLCP-LUPA) is actually
planning to both SIGNIFICATLY REDUCE Coastal Open Space acreage, and to eliminate ‘High-Priority
Coastal Open Space Land Uses at Ponto due to SLR.
The Existing LCP requirements for Ponto Planning Area F to analyze the deficit of Coastal Open Space
Land Use should factor in the currently planned LOSS of both Coastal Open Space acreage and Coastal
Open Space Land Uses at Ponto due to SLR. As a long-range Coastal Land Use Plan this required LCP
analysis needs to also consider the concurrent future increases in both population and visitor demand
for those LOST Coastal Open Space acres and Coastal Open Space Land Uses.
It is very troubling that demand for these CA Coastal Act ‘High-Priority’ Coastal Open Space Land Uses is
increasing at the same time the current (near/at capacity) supply of these CA Coastal Act ‘High-Priority’
Coastal Open Space Land Uses is significantly decreasing due to SLR. Instead of planning for long-term
sustainability of these CA Coastal Act ‘High-Priority’ Coastal Open Space Land Uses for future
generations there appears to be a plan to use SLR and inappropriate (lower-priority residential) Coastal
Land Use planning to forever remove those CA Coastal Act ‘High-Priority’ Coastal Open Space Land Uses
from Ponto. CA Coastal Act Policies to address these issues should be thoroughly considered.
2021-2 proposed Draft Local Coastal Program – Land Use Plan Amendment (DLCP-LUPA) will likely result
in City and CA Coastal Commission making updates to the 2015 General Plan, based on the existing
Ponto Planning Area F LCP – LUP Policy requirements, Ponto Open Space issues, high-priority Coastal
Land Use needs, and SLR issues not addressed in the 2015 General Plan.
2022-June General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park – part 1 Page 1 of 5
2022-June General Comparative tax-payer Costs/Benefits of Completing PCH, PCH Modification, and
14.3 acre Ponto Park to address planned loss of 30+ acres of Coastal Open Space Land Use at
Ponto/WestBL/South Carlsbad: Part 1 of 2
Key points regarding tax-payer Cost/Benefit comparison:
City Park Fairness: Ponto/Coastal South Carlsbad has ZERO Parks and ZERO Park acres v. 10 Coastal Parks
totaling 37 acres in North Carlsbad. South Carlsbad is home to 62% of Carlsbad citizens and the City major
visitor industries, and they have no Coastal Park. North Carlsbad is home to 38% of Carlsbad citizens have the
entire City’s Coastal Parks. The City also falsely allowed Ponto Developers to NOT provide the required 15%
unconstrained Growth Management Open Space required by other adjacent developers in Carlsbad.
Consequently Ponto is already developed at a density 35% higher than the rest of City.
What is missing from South PCH: The only missing components of a Carlsbad Livable (Complete) Street are
adequate Coastal sidewalks/pedestrian paths. Better safer protected bike paths for the volume of bike traffic on
a higher-speed roadway are highly desired. Both these missing features can be cost-efficiently provided in the
existing PCH configuration. The City had over 35-years to provide the missing sidewalks on PCH and should have
added sidewalks years ago.
Generalized Costs: Costs initially came from publicly stated costs by Mayor Hall in a 2019 at Meet the Mayor
Realtor luncheon at Hilton Garden Inn, the City’s 2001 PCH Feasibility Analysis for PCH Relocation, the earlier
$13 million per mile cost for the simpler .85 mile City CIP #6054 PCH Modification Project at Terramar, general
City cost data from official public records requests, and vacant Ponto land costs of $1.4 to $2.4 million per acre
from recent recorded land sales at Ponto.
In May, 2022 the City released an updated cost increase for the .85 mile Terramar PCH Modification of $22.4
million per mile; and an updated cost of between $85 - $60 million for the 2.3 mile South PCH Relocation
Proposal that comes to $40 to 26.1 million per mile. Kam Sang listed their 14.3 acre vacant site at Ponto for sale
for $2.7 million per acre in May. The Kam Sang list price is a bit higher that recent Ponto land costs, but the Kam
Sang site is of significantly higher quality being adjacent to Batiquitos Lagoon, and with 270 degree lagoon and
ocean views.
Generalized Benefits: The number of acres and the quality and usability of each of those acres, and the number
of new added beach parking for each of the known Option’s define each Option’s benefits. There may be other
unknown Options that have different benefits. The City’s 2001 PCH Relocation Feasibility Analysis’s highest Park
and Open Space Option (2001 ERA Financial Analysis “Alternative 1-parks and open space scheme”) only made
possible a 4-acre Active Park north of Palomar Airport Road in North Carlsbad. The City’s 2013 PCH Relocation
Concept design eliminated that 4-acre Active Park and only showed a few small open space areas with picnic
tables. Any PCH Modification benefits are limited by existing PCH constraints. See attached Part 2: City PCH map
with numbered notes on various existing environmental and land use constraints from the City’s 2013 PCH
Modification Design.
PCH Modification limitations: Most critically PCH Modification does NOT add any new City land. Rearranging
existing PCH land may add some usability beyond the usability of existing parkway areas along PCH. However
significant land in PCH right-of-way is already constrained by habitat, slopes, and water quality detention basins.
Past City Studies in 2001 and 2013 showed relatively modest changes in useable acreage from major PCH
Modifications. Forever removing 2-travel lanes (over 50% of PCH capacity due to removing passing ability) will
2022-June General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park – part 1 Page 2 of 5
create Terramar like traffic congestion, but could repurpose that City pavement for open space. Any net usable
land in the PCH median will be relativity narrow and may be modest once all constraints are accounted for. PCH
Modification should be accurately compared with the existing usable and open space parkway areas in the
existing PCH configuration and Ponto Park situation. See attached Part 2: City PCH map with numbered notes on
various existing land use constraints from the City’s 2013 PCH Modification Design.
Four (4) Comparative tax-payer Cost/Benefits:
1. Completing PCH & adding missing sidewalk/path and additional public parking and bike safety:
4 vehicle lanes and 2 bike lanes 177 parking spaces currently exist along South Carlsbad Blvd
The only missing component of “Complete/Livable Street” is a pedestrian sidewalk/path on about 70% of PCH
Total Cost to provide missing sidewalks per City data = $3-5 million (based on path width)
Costs for desirable safety upgrade to existing bike lanes are not known
Cost to add more Beach parking on City owned abandoned PCH North and South of Poinsettia ranges from:
273 additional spaces = $ 0.76 million
546 additional spaces = $ 1.1 million
Plus an estimated $1.5 million for 2 signalized intersection upgrades for full 4-way access
Cost per parking space is estimated at $19,275 to $13,899 per additional parking space
Total cost: $ 3.8 to 6.1 million to provide missing sidewalk/path and add more parking + unknown amount for
any desired upgrades to existing bike lanes
2. ‘2013 2.3 mile PCH Modification Proposal’ [AECOM 11/26/2013 Alternative Development Meeting]
Total Cost is $75 million per Mayor Matt Hall, but updated by City to $85-60 Million or $40-26.1 million per mile.
The costs appear consistent with 20-years of cost inflation of the basic (unmitigated environmental and traffic)
2001 costs of $26.5 to 37.3 million (in 2001 dollars) identified by the City’s 2001 Feasibility Analysis by ERA. The
City’s 2001 ERA Analysis indicated fully mitigated costs will be higher.
Total $85 to 60 million PCH Modification cost comes to:
$ 21 to 6 million per acre to reuse existing City land into narrow open space areas (from portions of city
roadway)
$872,093 per additional parking space
86 additional parking spaces created = 263 replacement spaces - 177 existing spaces removed
Includes multi-use pathway (sidewalk) within primarily native/natural landscaping.
Possible 50% reduction in vehicle lanes (from 4 to 2 lanes) with corresponding traffic congestion like at
Terramar. Not clear if Citizens and tax-payers will approve spending $85 - 60 million to double traffic
congestion.
Includes about 4 - 10 acres for possible narrow passive Park area identified in City’s 2001 PCH Modification
Feasibility Analysis by ERA. However City’s 2013 PCH Modification (AECOM) plans look like smaller acreage
is provided.
Does not purchase any new City land (only reconfigures existing City land) so requires Carlsbad Citizens to
vote to expend funds per Proposition H, and as noted in the City’s 2001 Feasibility Analysis likely will not
qualify for regional, State or Federal tax-payer funding.
2013 PCH Modification proposal could not/did not consider and map City’s 2017 sea level rise data to show
what areas would be lost due to sea level rise and account for any added cost and issues.
2022-June General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park – part 1 Page 3 of 5
3. 14.3 acre Ponto Coastal Park
Total Cost: $52.3 million that includes $38 million (full list price) to purchase 14.3 acres plus $1 million per
acre to landscape/irrigate like the recent development cost for Buena Vista Reservoir Park (aka Poinsettia 61).
$ 3.7 million per acre is the cost for buying 14.3 acres of New City land and developing a true City Park.
Ponto Park purchase:
- is $3.7 million per New Added Park Acre v. $21 to $6 million per acre to NOT buy new land but simply
repurposed existing City land in PCH,
- Saves tax-payers $17.3 million to $2.3 million per acre,
- Saves tax-payers $32.7 to $7.7 million, and
- Provides up to 278% to 43% more Parkland than the 2.3 mile ‘PCH Modification option’
Includes adding 14.3-acres of new and viable parkland similar to (but twice as large) as Carlsbad’s Holiday
Park. Site includes habitat and habitat connection to Batiquitos Lagoon, and lagoon and ocean view tails
that connect to the ocean and eventually east along Batiquitos Lagoon to El Camino Real.
Since an Open Space land purchase per Proposition C acquisition voters exempted such purchases from
Proposition H. NCA already recommended vacant Ponto land be considered for City purchase as Open
Space per the City’s obligations under a lawsuit settlement.
Ponto Park’s cost savings over ‘2.3 mile PCH Modification’ = $32.7 to 7.7 million
Ponto Park’s + adding missing sidewalks cost savings over ‘PCH Modification’ = $28.7 to 2.7 million
Ponto Park’s + adding missing sidewalks + 273 additional parking spaces cost savings over “PCH
Modification’ = $28 to 2 million
Ponto Park’s + adding missing sidewalks + 546 additional parking spaces cost savings over “PCH
Modification’ = $27.6 to 1.6 million
4. Combining both #1-PCH Completion and #3-Ponto Park:
Combining #1 and #3 creates at cost effective and more beneficial Coastal Park-Coastal Parking-Completes
Streets solution. This solution actually adds 14.3-acres of New City land for a needed Park, provides for a
Complete PCH without increasing traffic congestion, does not forever congest PCH travel if future PCH traffic
increases, adds comparatively more beach parking, and preserves PCH land and provides the City with
Coastal land use and sea level rise planning flexibility to address future needs by not forever committing the
City’s PCH land to a Final solution. See map on page 4 showing land use synergy of combining #1 and #3.
$27.6 to 1.6 million in tax-payer cost savings are estimated from combining #1 & #3 compared to the
estimated $85 - 60 million PCH Modification of 2.3 miles. Combining #1 and #3 provides all the PCH
Modification features, added beach parking benefits, and Adds 14.3 acres of New City land for parks,
provides the City 100% of the flexibility it will need to address sea level rise, and do so for a reduced cost
to tax-payers. Page 5 shows the synergistic beach parking and Ponto Park relationship. The new 14.3 acre
Kam Sang Ponto Park site is just south of the 11-acre Planning Area F site and between Avenida Encinas and
Batiquitos Lagoon.
a. Ponto Park’s location allows it to use the 337-610 parking spaces created by #1 above (177 existing +
273 to 546 new parking spaces). The 337-610 parking spaces will allow Ponto Park to effectively
host Carlsbad’s special community events.
b. Acquiring Ponto Park’s 14.3-acres provides both the City and State of CA with important future land
use options to address the Sea Level Rise and Coastal Erosion (SLR) planned by the City. These
options are created by leaving the exiting South Carlsbad Blvd right-of-way substantially the same
(except for adding needed sidewalks and using the existing Old paved roadway for parking) thus
allowing future upland relocation of the Campground. If $85 to $60 million is spent on #2 the
2022-June General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park – part 1 Page 4 of 5
likelihood this very expensive City expenditure would never be abandoned by the City to allow
relocation of the Campground.
c. Carlsbad’ 2017 Sea Level Rise study shows SLR will eliminate ½ of the State Campground – a high-
priority Coastal land use under the CA Coastal Act. The CA Coastal Act calls for “upland” relocation
of high-priority Coastal land uses due to SLR impacts. Ponto Park could also provide for “upland”
relocation of the State Campground.
Part 2 of this Comparative analysis is a separate 2-page map and data file. This Part 2 file consists of the City’s
PCH map of a reduced one lane in each direction (greater than 50% roadway capacity reduction) PCH
configuration that maximizes potential ‘excess right-of-way’. That map has numbered notes to marking
locations of PCH environmental and design constraints from the City’s 2013 PCH Relocation design, maps the
City’s 2017 Sea Level Rise Impact Areas, and for reference outlines the easterly 6.5 acre portion of the 11-acre
Planning Area F site for acreage comparison purposes.
2022-June General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park – part 1 Page 5 of 5
Map 1: Cost effectively using Old carl.sbad 8lvd pavement for beach, campground &
Ponto Park p.ar~ng-vehide access at Breakwater Rd, Poinsettia Lane, and Ponto Drive
between the
centers of
parking and
Ponto Park
cent1al roadway
linking inland South
Carlsbad to the Coast. ,._L....
Page 1 of 2
City’s PCH Modification Proposal Area Map with notes on usability Constraints and Issues: P4P Input 2 of 2
The City’s map below is marked with the following numbered list of Area Constraints and Issues. The Constraints are from the City’s 2013 PCH
Modification designs, the City’s older 2017 Sea Level Rise Impact Study, and on-site observations. The Constraints will limit any fundamental
change to the existing PCH landscape. For instance existing slope and habitat area will remain or have to be relocated which will limit the use of any
excess land area from PCH Modification. These Constraints will then reduce from 62 acres the actual number of unconstrained and acres that are
actually useable and can be used for different uses than currently exist.
1. Loss of the last section of Old "Historic 101" design, ambiance, and openness. Will it be replaced with typical urban arterial design?
2. Freshwater habitat
3. Sewer pumping facility
4. City's 2013 PCH plan for RESTORED RIPARIAN HABITAT
5. Sea Level Rise 2 meter Impact Area
6. City's 2013 PCH plan for BIO SWALE AND RESTORED RIPARIAN HABITAT
7. Existing beach parking to be retained
8. Least Tern habitat
9. Major storm water detention basin
10. Water
11. Slopes will likely need retaining walls to move road inland closer to proposed Kam Sang Resort
12. Endangered Species Habitat
13. City's 2013 PCH plan for COASTAL SAGE SCRUB RESTORATION
14. City's 2013 PCH plan for NATIVE GRASSLAND RESTORATION
15. City's 2013 PCH plan for BIO SWALE AND RESTORED RIPARIAN HABITAT
16. Eliminating access road for homes/businesses south of Cape Rey Resort. Who pays to replace?
17. Removes Cape Rey Resort developer required GMP Open Space for this LFMP. This GMP Open Space will have to be replaced. Who Pays?
18. City's 2013 PCH plan for L.I.D. BASIN / BIO SWALE
19. City left several acres vacant for 20+ years. This area can cost-effectively provide 200-500 more parking spaces w/o any PCH relocation.
20. Unusual jog in roadway. Is this viable?
21. City's 2013 PCH plan for RESTORED NATIVE LANDSCAPE
22. Habitat & need to provide major storm water quality detention basin before discharging urban and creek runoff into ocean.
23. Slopes will likely need retaining walls to move road inland closer to mobile home community.
24. Steep unusable slopes needed for Palomar Airport Road overpass over railroad corridor.
For a Cost/Benefit reference point, the City’s PCH Modification at Terramar (CIP project #6054 from Cannon to Manzano) that is less constrained
and simpler than South Carlsbad is projected to cost around $13 million per mile. Vacant primarily unconstrained land sale costs at Ponto are
documented at around $1.4 to $2.4 million per acre. Honest Cost/Benefit of these two options should be a public tax-payer discussion.
Page 2 of 2
* For comparative visual reference the * area is the 6.5 acre eastern portion of Planning Area F.
*.
*.
0 250 500 I .000 Feet
I I I I I I I
July 13, 2021
cartsbad Boulevard Realignment: Right-of-Way and Available Land Analysis"
c::::I Proposed ROW (Approximately 43 acres)
c:::I Area Available for Other Uses (Approximately 62 a°ff~fu #l 4
• Anafrsis is based on aeriail imageiy. Rjght-of•way boundaries and ..ae..ges are approxim.rte and in~:ed for planning leYel anal,sis only.
EXHJBIT 17
Paee 47 of 53
Page 1 of 11
Submitted: May 28, 2020
Dear Carlsbad City Council, Carlsbad Planning and Parks Commissions, and Coastal Commission:
The City Budget should address both short-term Covid-19 impacts, and near/longer-term investments
needed for Economic Recovery and Revitalization.
The quality of our Carlsbad coastline, Coastal Parks and open spaces are continually rated by Carlsbad
citizens and businesses as the critical foundation of our quality of life, economic strength, and tourism
industry. Ponto Coastal Park is a critically needed investment, and the last opportunity for the City to
make an investment for Carlsbad’s long-term sustainability. South Carlsbad Citizens, visitors, and the
Visitor Industry have no Southern Coastal Park. Ponto is the only place to provide that needed
investment for residents and visitors, and advance Economic Recovery and Revitalization of South
Carlsbad’s significant Visitor Industry. Coastal Recreation is the major attraction for visitors.
With these understandings we submit the following testimony and data from the City’s FY 2019-20
Budget Public Input Report that highlights the documented significant number of citizens asking for a
Ponto Coastal Park. We also note concerns about the Report’s dilution of specific citizen input provided
at both the March 4, 2019 and 2020 Citizen Workshops.
Citizen input on the need for a Ponto Coastal Park was the most numerous specific place need/desire
citizens mentioned in the City’s:
Budget Public Input process,
Draft Local Coastal Program Amendment process, and
Parks Master Plan Update process.
The Budget Public Input process documented 85 specific, verbatim citizen comments on Ponto area park
needs and over 90% of citizen requests that Council budget to address this need. These 85 Verbatim
Citizen comments (listed at the end of this testimony and data) specifically address how they would like
their (Park) tax dollars budgeted. Additionally, 2,500 similar public input email/petitions were
submitted as public comments on Carlsbad’s Draft Local Coastal Program Amendment and Park Master
Plan Update processes spoke to the need for a Ponto Coastal Park.
As you know, the 11-acre Ponto Planning Area F site is for sale. This site is similar in size/shape as
Holiday Park, providing a Coastal site for similar multipurpose community functions.
Carlsbad’s Local Costal Program (and thus General Plan and Zoning Code) requires the City to first
consider and document the need for a “Public Park” before any land use can be planned for the Planning
Area F site.
The City’s Park Master Plan already documents the need for a Ponto “Public Park”, showing the area as
“unserved” by City Parks and an area of Park “inequity” correlating well with Citizen input.
The City also received offers of potential donations, or cost-saving collaborations from Carlsbad Citizens
and non-profits to advance the much needed Ponto Coastal Park. The City disappointingly has not
replied to these special opportunities.
Page 2 of 11
Therefore, it is requested the City budget for a Ponto Coastal Park and contact the Planning Area F
landowner regarding site purchase.
Consistent with Budget Public Input Report page 3 it is requested that this this testimony and data be
provided to the Planning and Parks Commissions; and Coastal Commission as public input on the City
Staff’s proposed 1) City Budget, 2) Draft Local Coastal Program Amendment, and 3) Parks Master Plan
Update.
Thank you.
People for Ponto
The following data is from the Carlsbad FY 2019-20 Budget Public Input Report:
https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=38546
In reading the data different text treatment is used to differentiate between actual page number and
text in the Report, Important Report text, and public comments and analysis of Report text. Following is
a legend to those text treatments:
(p.X) is the Report page number where the information is found, and normal text is the actual
Report text.
Text in Bold Face is particularly important Report text.
Arrow bullets and Text in Bold Italic Text are analysis and comments on the Report’s
information.
Introduction (p. 3):
Members of the public have a right to be involved in decisions affecting their lives.
It is the city’s responsibility to seek out and facilitate the involvement of those interested in or
affected by a decision. The city errs on the side of reaching out to people who might not be
interested, rather than potentially missing people who are.
City staff provide balanced and factual information to the public and do not engage in advocacy.
Public dialogue strives for a focus on values over interests and positions.
Public involvement planning is coordinated across all city departments to ensure consistency and
avoid process fatigue.
On (p. 5) specific Verbatim Public Input was generalized by City Staff as follows:
Main Themes: The following themes were a high priority overall:
Neighborhood quality of life
Access to nature, trails and open space
Environmental sustainability
Traffic and mobility
Most Important Services: City services in the following areas were identified as the most important:
Neighborhood quality of life
Parks and recreation
Law enforcement
Fire and paramedic service
Page 3 of 11
Environmental sustainability
Specific Areas for Budget Enhancement: When asked which services they would like to see enhanced in
next year’s budget, the top five responses were:
Neighborhood quality of life
Parks and recreation
Environmental sustainability
Mobility/transportation
Arts and culture
The lack of a Coastal Park at Ponto impacts all South Carlsbad neighborhoods’ quality of life.
Carlsbad’s Park Master Plan documents that Ponto and Coastal South Carlsbad are “not
served” by parks and Ponto and Coastal South Carlsbad is an area of park “inequity”
The City and CA Coastal Commission are required to consider and document the need for a
“Public Park” before any planning to allow any land use on Ponto Planning Area F. For over
10-years the City failed to disclose and follow this requirement – making multiple “Ponto
planning mistakes”. The City will now have to correct its multiple “Ponto planning mistakes”
as part of the Draft Local Coastal Program Amendment
The lack of a Park at Ponto also impacts both Environmental Sustainability and
Mobility/Transportation:
o Prevents parks within walking distance, forces driving (and the need for more parking
in our Park) to access parks.
o Forces South Carlsbad Neighborhoods to drive long distances to North Carlsbad and/or
Encinitas to access a Coastal Park
o Congests North Carlsbad and/or Encinitas Coastal Parks with South Carlsbad Coastal
Park demands
o Congests North Carlsbad and/or Encinitas roadways and parking facilities with South
Carlsbad Coastal Park demands.
o Importantly, it would forever negatively impact the economic sustainability of
Carlsbad’s Visitor industry. There are thousands of inland South Carlsbad resort/hotel
rooms that have no access to a Coastal Park. This will ultimately undermine the
attractiveness and competitiveness of South Carlsbad’s Visitor industry and the tax
revenue the City receives from that industry.
Word Maps (pp 6-8)
Staff provided 3 ‘word maps’ saying the show the words mentioned at the March 4th 2020 workshop
attend by 38 citizens.
There is citizen concern about the accuracy of these word maps and what is conveyed on
pages 6-8 of the Report.
Several of those 38 citizens, provided specific written (individual index cards) and verbal
(round table flip chart notes) Pubic Input several stating the need for a “Ponto Coastal Park”,
another mentioned a “liner Park”, and several mentioned the “Senior Center”, all these
written/verbal comments were not accurately documented or reported on pages 6-8. It
appears the City Staff interrupted and translated/transformed the actual citizen comments
(as documented in the index cards and flip chart notes) when creating the word maps. There
is a concern that specific citizen input provided at the actual workshop was not accurately
Page 4 of 11
reported in the Public Input Repot to the City Council. As citizens we are concerned that our
input is accurately reported and conveyed to the City Council.
Surprisingly no word map was provided in the Report for the much larger (1,330 to 1,710
person) March 5-22, 2019 Public Input process. Following is the actual word map the city
showed participants at the March 4, 2019 Public Input Workshop. The image of the word
map was taken with a participant’s cell phone. It summarized the magnitude of citizen
needs/desires expressed at this larger Budget workshop.
The word map graphic above from the March 4, 2019 Workshop although not summarized by Staff in
the Report is clearly documented in the Verbatim Comments (Public Input) that was included in pages
24-91 of the Report and accounted for below.
Verbatim Comments (pp 24-91): Number of times a specific Place Name was mentioned:
Ponto, Zone 9, and Southwest Carlsbad: 85 times (see below for list of Verbatim Public Input)
Village: 23 times, this is 27% as much as Ponto area
Carlsbad Senior Center: 7 times, this is 8% as much as Ponto area
Agua Hedionda Lagoon: 3 times, this is 4% as much as Ponto area
New Village Arts: 3 times, this is 4% as much as Ponto area
Barrio: 2 times, this is 2% as much as Ponto area
Calaveras: 2 times, this is 2% as much as Ponto area
Alga Norte Park: 2 times, this is 2% as much as Ponto area
ire abate
Page 5 of 11
Poinsettia Park: 2 times, this is 2% as much as Ponto area
Veterans Park: 2 times, this is 2% as much as Ponto area
Rancho Carrillo: 1 time, this is 1% as much as Ponto area
Hub Park: 1 time, this is 1% as much as Ponto area
Crossings Golf Course: 1 time, this is 1% as much as Ponto area
Robertson Ranch: 1 time, this is 1% as much as Ponto area
Palomar Airport: 1 time, this is 1% as much as Ponto area
As the Budget Public Input Report suggests, reading of each of the Verbatim Comments of
actual public input should be done. The place names area specific list above does not include
broad places such as “beaches” the names of specific roads, and other names that appeared
vague. It is clear in reading through and counting the place name references that the Ponto
area expressed as Ponto, Zone 9 (i.e. Local Facilities Management Plan Zone 9), and the
coastal park references to Southwest Carlsbad and South Carlsbad was by far the greatest
area of public input. This makes perfect sense in that for half of the City Ponto is the last
significant vacant Coastal land available to address two of Carlsbad Citizens’ most important
budget concerns ‘Neighborhood quality of life’ and ‘Parks and recreation’ that relate to core
community values around Carlsbad’s “Beach”, “small beach town character”, and “valued
open space”.
Following is the listing of the Verbatim Public Input (Appendix A in Public Input Report, pp 24-
91) that specifically referenced Ponto or a clear reference to Ponto such as Zone 9 or Coastal
Park needs in Southwest Carlsbad. There are many more comments such as “The purchase of
remaining open space for preservation of the last remaining coastal areas.” that logically and
clearly refers to the Ponto situation. However these many additional comments were
excluded from the list below since they did not specifically mention Ponto, Zone 9, or SW
Carlsbad place names.
Of the 85 citizen comments below specifically referencing Ponto, 77 or 90.6% were asking the
City to budget for a Ponto Coastal Park. Only 8, or 9.4% of those citizen comments were not
asking for a Ponto Costal Park. We are not sure if the 8 commenters knew about the City’s
now acknowledged “Ponto planning mistakes” dating back over the past 10-years, as the City
only first briefly acknowledged this recently on I/28/20. We have found once citizens are truly
aware of the facts and prior “Ponto planning mistakes” there is almost uniform desire for a
Ponto Coastal Park. There is citizen concern that these “Ponto planning mistakes” are not
being fully, openly and accurately being disclosed to Citizens during the various Public Input
processes, thus tainting those Public Input processes.
Verbatim Ponto City Budget Public Input from pages 24-91 of FY 2019-20 Budget Public Input Report:
1. My biggest disappointment is the lack of park facilities in my section of the city, near South
Ponto Beach. Lots of open land but no park within at least 2 miles. This should be a city priority
2. It used to be the beach but now Ponto & South Carlsbad are more like rocky shores. I‘d like to
see the rocks cleared up and more sand added to these beaches
3. COMMENT TRAFFIC IS BEING SPAMMED HERE TO PUSH THIS PONTO PARK PLOY (PPP) Develop
Ponto and have the hotel maintin our beach! It’s all rocks currently!
4. Ponto Beach. We do NOT need a commercial development or hotel there. That needs to be a
park and/or open space for future generations.
Page 6 of 11
5. Ponto beach.
6. Don't ruin South Ponto Beach with condos and/or hotel, need to restore the sand on the beach.
7. Like most residents and visitors I treasure the beach. I feel the highest priority should be open
space and parks that serve the beach region. Particularly important is the open space still
available in the Ponto region. There is ample space here for an extraordinary area of open space
and even a park. There is not one of either of these in the southwest quadrant near the beach.
Children cannot walk safely to a park from that area. Open space and a park in the Ponto area
would serve all residents, visitors, and the business community.
8. Beaches, parks, safe neighborhoods, OPEN SPACE! Need Beach parks like Del Mar
Powerhouse/Sea Grove Park & Encinitas Community Park. Ponto Beach needs some attention.
9. I love the beach and the parks and fields and open space and hiking trails in Carlsbad. I wish we
had more!! We have had 3 kids in sports in Carlsbad. Currently, field/park space is very limited
and often over committed. Currently, there aren't enough fields to meet the need of the
community. Adding more parks and fields would create a better community in the following
ways.... The sports played on these fields help keep our kids fit and healthy; It keeps kids busy
and out of trouble; It fosters friendships and community; it teaches team work and fosters
dedication and teaches a willingness to help others succeed; it brings in community $$ from
other teams who come to play on Carlsbad fields; It's a wonderful way to showcase our city to
others who will want to return thus helping grow tourism. Additional Parks would offer the
same benefits. We do not need more high density building. And, Please do NOT ruin Ponto with
more building!!!!!!!
10. We love the beach and the small-town feel Carlsbad has. We love the scattered open spaces and
trails. Carlsbad is a great place to live and spend time outdoors, like the Ponto area. Let's keep it
that way by not developing every last square foot into a condo complex, hotel or shopping mall,
if that's what you want please move to Oceanside.
11. Let us protect the valuable open space that is left and not develop every square inch. Especially
at the beach, let us save the land across the coast highway from Ponto Beach and make a
beautiful park, not more condos and hotels. Carlsbad is in great financial shape and does not
need to go after every development and tax dollar it can get. Some things are more important,
like quality of life, than a fat wallet. I know that this will fall upon deaf ears amongst the two
older members of the City Council, but maybe some rearranging of priorities is in order.
12. Would love to see the last areas of open land to stay that way. I have lived here for 25 years and
have seen a tremendous amount of development eating away at the open beauty of the area.
We have enough shopping centers and homes. Please leave the area at Ponto open and do not
approve the Ponto development.
13. Keep Ponto Beach development free!
14. Preserving Open Space and Building Ponto Park in the South West Quadrant!
15. I second Tisha Klingensmith's comment and all the others regarding Ponto Beach development.
16. Preserving open space and maintaining high quality Parks and Rec with park location emphasis
on geographical location. It’s time to build a park in the SW quadrant near the beach for locals
and visitors alike. Veterans Park is not a solution for each quadrant’s deficiency, particularly in
the south.
17. We need more parks, especially in southwest Carlsbad!
18. I agree, we need more parks and open space. I live in Zone 9 and don't have apark anywhere
within walking distance.
19. We need to continue to preserve open space and NOT develop Ponto into an awful condo
complex. We would love a park!
Page 7 of 11
20. We need a park in the Ponto area and not a development. It is the last open space next to the
beach left
21. I agree with the need to preserve open space throughout Carlsbad and NOT develop Ponto into
awful condo complex.
22. We need to preserve our open space --it's what keeps the city feeling like a small town. We
need more parks -esp one at Ponto in the SW quad!
23. Preserve the open space and build a park in SW quadrant at Ponto. We do not need or want
any more huge developments, especially right by the beach in one of the last remaining open
spaces. Once it's built, you can't un-build it. Build Ponto Park in SW quadrant. Do the right
thing. Especially for our children and grandchildren. They won't thank us for building
outrageously tall high density condos, hotels and unnecessary shops right by our gorgeous
beaches. The only people this benefits are some wealthy developers, not the people of Carlsbad.
Think long term, not short term. We have a beautiful city and community-preserve it now or it's
gone forever!
24. We really need a park in the southwest quad by the beach. This could be an amazing asset (on
SO many levels) for the community and visitors alike. The revenue stream would return the city
investment in spades!
25. Parks. Needed in Ponto area our children in this area don’t have a close park. And the house lots
in our area are small.
26. I agree that we should be very mindful that the citizens of Carlsbad voted out the retail space
plan at the power plant site a few years ago. The new Ponto project should not replace that.
Citizens should be part of the decision to build out that area
27. We need to preserve our open space and we need a park at Ponto!
28. We need a park in the Southwest quadrant of our community. Safety in the community Is what
we like best in this area
29. Carlsbad's small town feel, friendly atmosphere and location has made it our ideal place to live
for the past 20 years, We live across from South Ponto Beach and DESPERATELY need a park for
our area residents. It would be sad to see the area overbuilt with high density projects and not
retain some of the open space at this southern entrance to our "Village by the Sea". PLEASE
help preserve some of its appeal before it is too late.
30. I love the quaintness of the Village, the open land areas, trails, small businesses and the arts. A
huge NO to PONTO. Please stop the excessive building and development of the open areas of
our beautiful and unique city. We have lived here for over 30 years and are sad to see so much
over development. Keep our special village a village, and please don't turn it into another
ordinary city.
31. Favorite is small town feel and the beach --the beach provides us with all the open space we
need. The city has enough open space with all the lagoons, etc. --we don't need any more parks
--especially at PONTO --I am thrilled to see and drive by every day the new resort at La Costa
which is in Encinitas and that is what we need here at the South end of Carlsbad --more
residential --NO more open space
32. What I love about Carlsbad is that it has a small village feel but it also has the beach and some
restaurants and then little town. I really would like more to walk to around the Ponto area.
Specifically I think it should be more of a beat centered area with places to grab ice cream or
grab some food or a coffee and walk to the beach.
33. I love that our village that is not a strip of 101. The quaint cottages helped Carlsbad have a
downtown feel. It has several streets with unique interest. I love the Trees on Grand! The
landscape of the trees setting the height of the town. Unfortunately the taller buildings are
killing that. Vertical dwellings are taking over.. think of the reason you travel to Europe. It's not
Page 8 of 11
for Developers Generica. We also want the NRG power plant space into a Park... and... I would
LOVE for the city to finish the rail trail to Ponto. Imagine taking a trail to Ponto? It would be a
dream!
34. Our San Pacifico Community and the surrounding neighborhoods need a local park. So far
Carlsbad has no real performing arts venue of any size to meet the needs of a city of more than
100,000. This should be a serious consideration when the new civic center is being designed.
35. We need more coastal parks and open space. Especially in zone 9
36. protect more open space, including Ponto
37. We need Veterans Park completed and Ponto park developed. Everyone in Carlsbad is engaged
and we have been talking about the park deficits for a while now. Veterans park is over-due!!!
38. Our libraries are the best in the region! But I have to put them 4th to our Neighborhood quality
of life, which is being impacted by huge developments destroying our property values, our piece
of mind and privacy. We do need to insure that our environment is cared for, since all of these
housing projects are going in. I do love our parks but we need to insure that the SW quadrant
has their share of parks (think-Ponto).
39. Zone 9 (in southwest Carlsbad) does not have a park within walking distance! I hope the City can
remedy this.
40. Ponto needs a park not a hotel or more condos. Please stop building on every last piece of land
41. See previous comment concerning the lack of a local, beach oriented park in the South Ponto
area. Ditto a performing arts venue.
42. PLS get the Ponto Proyect development going....., that area of Carlsbad needs it asap
43. I support Ponto Development. PLs get it going...
44. Ponto has 2 miles of unobstructed beach access and a lagoon that already act as a "park within
walking distance". The Ponto project was approved long ago and is part of the citizen approved
master plan. Please get it done.
45. Strengthen and protect the financial stability of the City. Businesses pay a significant amount of
taxes, property, sales and income and those employed spend and live here. Encourage
affordable housing opportunities for everyone, think outside the box and find some unique
solutions. Complete build out in areas available, Ponto Beach is a great opportunity and the
project is well thought out, get it built. And please don't become a 'Nanny City' and waste time
to pass frivolous laws restricting straws, plastic bags, soda consumption, etc.
46. Development of open space and parking space in the Ponto region
47. Specifically, I want the city to remedy the lack of equal access to parks and trails evident in the
southwest quadrant of the city. I support a park project at Ponto: in the long run, the south
coastal gateway to Carlsbad needs a welcoming park with beach access and supporting facilities.
Though less extensive than Village beach areas, good design would merge a Ponto park with
access to beach and access to the 'memorial area on the bluff at city border with the ecology of
the Batiquitos Lagoon adjacent to make a marvelous creek to beach environment accessible for
all and ever.
48. There are two miles of unobstructed beach plus the lagoon within "walking distance" of the
neighborhoods near Ponto. The project was approved long ago and is part of the Master Plan
approved by the citizens of Carlsbad. Zoning changes and project vote downs are often just
another way to steal private property.
49. Local park deficits continue to be a problem. Let's please support Ponto Park development. We
as a city are losing an unobstructed landmark in our community. Please share some of that with
local residents. And, did I mention parking??
50. The extreme southwestern (Ponto) area of Carlsbad does not have a park within walking
distance -this is my top priority to fix.
Page 9 of 11
51. We have wonderful neighborhood parks, but not in Ponto and it's on the beach; Veteran's Park
is more of a hiker/nature lover's place to enjoy nature.
52. We need a park at Ponto - to serve not only residents, but visitors and tourists.
53. A park is much needed in SW Quadrant of the city
54. Ponto Park. So much has been done for businesses, tourism, etc. This is the last bit of Carlsbad
coast line left. And the residents could use more park space in the south part of the City. I don't
want to see this area developed. Carlsbad has become overdeveloped.
55. I want to see a park for the Ponto road area. I feel that that area should not be used for condo -
residential development. It is so important to showcase that wonderful piece of property, which
is so rare to find all up the coast of calif. and would be a welcomed park for all as you drive
north into Carlsbad. ALSO I am very concerned that the Palomar Airport and the larger airplanes
the new plan will bring and ask that the city stay involved to support our concerns, thank you for
help I appreciate all off the councils work.
56. Ponto area open space and park development
57. Take control of our coastline, bring fire rings to Ponto beach, every family should have the
experience of gathering around a roaring fire on evening.
58. Cancel the Ponto development tragedy. Build a free park and keep the free beach parking there.
59. Buy the land for open space on Ponto Drive and build a park in Zone 9 that has no park even
though developers paid into the park fees for 20 + years.
60. support Ponto development
61. Now that we have removed the jetty and allowed Warm Waters to wash away, and now we are
planning to build on Ponto, where will locals access the beach? If 50% of responders stated the
beach is the best part of Carlsbad living, why are continually squandering this gift? I know the
council would live to sell Agua Hedionda to a developer too. When will there be decisions made
to maintain our quality of life? Furthermore, I selected transportation because my commute
time has DOUBLED in the past 5 years. The 55mph speed limit on El Camino is a joke. It takes me
2 light cycles just to cross each intersection now due to this unmitigated growth with no regard
for how people will get around. I’m continually dismayed by this city.
62. Preserve the open space at Ponto. Keep traffic under control.
63. Preserve open space in zone 9
64. Money for persevering open space in zone 9 and building parks in the SW quadrant!
65. More parks and open space in Southwest Carlsbad!
66. Why another proposed hotel at Ponto? There are an abundance of hotels & stores already
available ---even more than necessary. Preserving nature & some green space is more important
than more concrete & businesses with "lease available" signs everywhere!
67. Prop to aid Ponto to keep it natural, as park area & natural habitat.
68. Put budget money towards Parks and Recreation, specifically Preserving Open Space in Zone 9
and Building #PontoPark in the SW Quadrant (p 84)
69. Please put budget money towards Parks and Recreation, specifically Preserving Open Space in
Zone 9 and Building #PontoPark in the SW Quadrant (p 85)
70. need a park in the southwest Carlsbad post development
71. Parks in southwest Carlsbad!
72. Zone 9’s lack of park and open space is sad. The SW quadrant needs more places to take kids to
play, seniors to walk and get outside, and for the community to gather. A park at Ponto would
be an ideal place for that and would make for a beautiful and welcoming entry into Carlsbad for
locals and tourists.
73. We need a park site near Ponto Beach on the property now slated for a 5 star hotel which has
not been built despite attempts by several developers over the last ten plus years.
Page 10 of 11
74. Please spend more on Parks and Recreation. We need to Preserve Open Space in Zone 9 and
Build Ponto Park in the SW Quadrant. We do not need more homes congesting the already
packed Coast Hwy. Adding sand to Ponto Beach would be nice too -too rocky!
75. I'm asking the City to put budget money towards Parks and Recreation, specifically Preserving
Open Space in Zone 9 and Building #PontoPark in the SW Quadrant -this will enhance the quality
of life in Carlsbad, contribute to the highest and best use, meet the requirement to have a park
in this area, and make the area so desirable that it will allow raising of local tax rates (I don't
believe I'm saying this). Best Regards, David Johnson
76. Put some park and playgrounds in SW Carlsbad. There are none near Ponto, yet there are open
spaces, near Avenida Encinas and 101. Nothing to walk to. Thank you
77. We could really use a park in southwest Carlsbad especially the San Pacifico area. Thank you
78. Work toward filling the deficit in parks and open space in the Southwest part of Carlsbad,
especially Ponto.
79. Would truly love the Ponto Beach Park! As a resident of South Carlsbad we need this!!!
80. There are no Parks in South Carlsbad. We are neglected here yet I pay very high taxes.
81. Build a Park at Ponto! Keep the open space!
82. I would like to see the city buy the Ponto property and develop it into a park.
83. Build a park at ponto
84. Appropriate development of open space and park space in the Ponto region. We are currently
at huge deficit of both of these in the Ponto region
85. We are very quickly running out of open space. This is probably one of the most beautiful areas
in the country, we need to preserve that beauty and maintain some open space. The open land
near South Ponto beach must be preserved. There are no parks in the area, developing that
area would not only add to the pollution but it would sacrifice one of the most beautiful parts of
Carlsbad. Towns and Cities across the country are prioritizing open space that is so important, it
is time we did that in Carlsbad. We need open space near Ponto Beach.
A few of the many Citizens asking the City Council to budget for a much needed Ponto Coastal Park
Page 11 of 11
1
Eric Lardy
From:Don Christiansen <donaldchristiansen@gmail.com>
Sent:Wednesday, June 1, 2022 12:37 PM
To:Growth Management Committee
Subject:Citizen feedback for Carlsbad Tomorrow Committee
Fellow Carlsbad Tomorrow Committee Members,
The Carlsbad citizens I've talked with about Carlsbad Tomorrow Growth Management are much more interested in the
future reliability of water and power, the Carlsbad Airport, location of the new City Hall/Civic Center, the old Farmers
building, AND especially the future land use of the old power plant site than (for instance) the appropriate ratio of City
office space per 1,000 population.
This article was in today's San Diego Union‐Tribune:
http://enewspaper.sandiegouniontribune.com/infinity/article_share.aspx?guid=9761d45a‐61d0‐4f02‐a4de‐
4ac92f6d661f
Under all is the land.
All the best,
Don Christiansen
CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is
safe.
National Recreation & Park Association (NRPA) Agency Performance Review – Carlsbad Parks Page 1 of 4
National Recreation & Park Association (NRPA) Agency Performance Review – Carlsbad Parks
https://www.nrpa.org/publications-research/research-papers/agency-performance-review/
The following in quotation marks is from the NRPA Agency Performance Review. Under each quote is
how Carlsbad compares with this nationwide park data base.
“The typical park and recreation agency offers one park for every 2,323 residents served, with 10.4 acres
of parkland per 1,000 residents. But park and recreation agencies are as diverse as the communities that
they serve, and what works well for one agency may not be best for your agency. Therefore, park and
recreation professionals need data to identify the best practices to optimally serve their community.”
Carlsbad has one park for 2,797 residents with 2.95 acres of parkland per 1,000 residents.
Carlsbad is 20% below typical in providing the number of parks, and
Carlsbad is 72% below typical in providing acres of parkland.
Carlsbad data is from 2020 US Census, Carlsbad General Plan & data from new Buena Vista Reservoir Park in NW
quadrant. City also counts school playgrounds as Parks, even though these are not 100% available for park use.
The NRPA Agency Performance Review also provides finer-grained data on a City’s relative performance
based on population, population per square mile (aka population density), and City Park Budget size.
Carlsbad’s 2020 population of 114,746 places it in the 100,000 to 250,000 category, Carlsbad’s
population per square mile of 2,792.2 places it in the ‘over 2,500’ category, and Carlsbad 2022-23 Park
Budget of $2,601,669 places it in the $1 to $5 million budget category. NRPA data for these categories
is:
“Based on Lower quartile median upper quantile
Total city population:
Residents per park 2,205 3,170 5,852
Acres of park/1,000 residents 4.6 8.9 16.3”
Carlsbad is:
12% better than the median in providing the number of parks per residents
67% worse than the median in providing acres of park per resident
“Population/sq. mile (population density):
Residents per park 1,382 2,261 3,908
Acres of park/1,000 residents 3.9 7.9 14.5”
Carlsbad is:
24% worse than the median in providing the number of parks per residents
63% worse than the median in providing acres of park per resident
“City Park budget:
Residents per park 1,174 1,941 4,288
Acres of park/1,000 residents 5.1 10.6 18.3”
Carlsbad is:
44% better than the median in providing the number of parks per residents
72% worse than the median in providing acres of park per resident
National Recreation & Park Association (NRPA) Agency Performance Review – Carlsbad Parks Page 2 of 4
It is unclear in the NRPA data if the nationwide data includes and count school playgrounds as a park, (like Carlsbad
does) even though school playgrounds are 100% available as parkland. The City’s use of School facilities that are
outside of the City Park System and City Park Budget to count as Parks may distort data comparisons.
The NRPA Agency Performance Review has no comparative data on the accessibility of Parks. The NRPA
website references the Trust for Public Land’s (TPL) Park Score data for Park accessibility data. The Trust
for Public Land’s Park Score for Carlsbad is at https://www.tpl.org/city/carlsbad-california . Carlsbad’s
TPL Park Score data indicates:
For a 10-minute walk to a Park, Carlsbad is:
33% below the Median for the TPL’s 100 ParkScore® cities:
9% below the Median for the 14,000 cities and towns in the TPL ParkServe® database
For overall Park acreage, Carlsbad is:
26% below the Median for the TPL’s 100 ParkScore® cities:
7% below the Median for the 14,000 cities and towns in the TPL ParkServe® database
The TPL database includes all parks within a city, including non-City parks. For instance TLP includes the State
Campground as a Park; even though the Campground is a ‘low-cost visitor accommodation’ there is no park within
the Campground. The TPL also counts restricted habitat areas within City Parks that cannot be used as parks.
The NRPA does provide information in support of park accessibility as noted in the following clips and
links:
“10-Minute Walk Campaign NRPA, The Trust for Public Land, and the Urban Land Institute have joined
forces to ensure there is a great park within a 10-minute walk of every person across America. More
than 220 mayors have committed to expanding equitable park access through local policy changes,
master planning efforts and increased funding.” https://www.nrpa.org/publications-
research/evaluation-resource-hub/park-check/resources/
“NRPA Park Check Principles, Access: Everyone deserves access to a high-quality park that is within a 10-
minute walk of where they live. It is important that all members of the community, including lower-
income residents, have walkable park access.” https://www.nrpa.org/publications-research/evaluation-
resource-hub/park-check/principles/
“Ashburn, Va. (Sept. 24, 2018) — According to a recent report published by the National Recreation and
Park Association (NRPA), the majority (85 percent) of Americans support efforts, such as the 10-Minute
Walk campaign, to ensure every person has access to a great park within a 10-minute walk of their
home. Currently, 3 in 4 Americans say they live within walking distance of a local park or other
recreational facility and, on average, visit their local park and recreation facilities more than twice a
month. … A report issued by NRPA — in partnership with the Center for Regional Analysis at George
Mason University — demonstrates the vast economic impact of local parks nationwide. Operations and
capital spending for local parks generates more than $154 billion in economic activity and supports
more than 1.1 million jobs. This is a conservative estimate that does not capture parks’ other economic
benefits:
Higher real estate values
Health and wellness benefits
Conservation/Resiliency benefits
Tourism
National Recreation & Park Association (NRPA) Agency Performance Review – Carlsbad Parks Page 3 of 4
Economic development”
https://www.nrpa.org/about-national-recreation-and-park-association/press-room/americans-agree-
every-person-deserves-access-to-a-great-park-within-a-10-minute-walk/
“Ashburn, Va. (Feb. 11, 2019) — As part of the 10-Minute Walk campaign, which aims to address the
fact that 1 in 3 Americans don’t have a park within a 10-minute walk (or half-mile) of home, the National
Recreation and Park Association (NRPA), along with The Trust for Public Land (TPL) and the Urban Land
Institute (ULI), has selected 10 campaign cities nationwide to receive grant funding totaling $400,000.
This funding will be used to support city planning and policy efforts that help increase access to high-
quality, close-to-home parks and public green space.” https://www.nrpa.org/about-national-recreation-
and-park-association/press-room/new-grant-funding-supports-10-cities-participating-in-10-minute-
walk-campaign/
The City’s Park Master Plan (pages 86-xx) maps Park Service Areas and areas Unserved by City Parks.
Following is a compilation the City parkland and the City areas Served (circled) and Unserved (outside
the circles) by City Parks. This data was compiled and submitted to City in a ‘Coastal Recreation data
file’ on 1/29/20 by People for Ponto Carlsbad Citizens, along with submitting over 5,000 petitions
regarding many comparative shortfalls in City Parkland:
No Coastal Park in South Carlsbad
• ppx. 6 mites of Coast
ithout a Coastal Par is a
Ci Regional need
• South Carlsbad has 6 ,000
residents thousands of
hotel · sitors ithout a
Coastal par
• Closest par to Ponto is
Poinsettia Par appro 2.
miles across 1-5
• Proposed Veterans Par is
appro 6 miles a ay
~
National Recreation & Park Association (NRPA) Agency Performance Review – Carlsbad Parks Page 4 of 4
Data Sources:
https://www.census.gov/quickfacts/fact/table/carlsbadcitycalifornia/PST045221
https://www.carlsbadca.gov/departments/community-development/planning/general-plan
https://www.carlsbadca.gov/departments/parks-recreation/parks-community-centers/parks/future-
park-planning/buena-vista-reservoir-park
https://www.tpl.org/city/carlsbad-california
https://www.carlsbadca.gov/departments/parks-recreation/parks-community-centers/parks-master-
plan
March 111th, 2022
Carlsbad City Council
1200 Carlsbad Village Drive
Carlsbad, CA 92008
Re: Support creation of Ponto Park – a needed park for South Carlsbad
Dear Mayor Hall,
The Trust for Public Land (TPL) is strongly supporting the efforts of ‘People for Ponto’ and thousands of
Carlsbad residents to build Ponto Park in the 11-acre coastal parcel known as ‘Planning Area F’ in South
Carlsbad. For over 40-years TPL has been designing and building parks in California and although we
have world-class parks and beaches, the fact remains 3.2 million Californians don’t have access to a ark,
and some of those Californians are residents of South Carlsbad. While the National Recreation and Park
Association calls for 10-acres of park lands per 1000 residents as standard metric for healthy and vibrant
cities, Carlsbad has a comparatively and relatively low park standard of only 3-acres/1,000 population
and no requirement to provide accessible parks within walking distance.
And according to our own Trust for Public Land 2020-21 ‘City Parkscore’, Carlsbad is also below national
averages both providing park land acreage and in providing residents a park within a 10-minute walk.
The City of Carlsbad’s Park Master Plan on pages 86-89 documents park service and park
equity/inequity. Carlsbad’s Park Master Plan documents that Ponto area has no park and all of South
Carlsbad (over 61% of the entire city population) has no Coastal Park while . Carlsbad provides 10 City
Coastal Parks (totaling over 35-acres) in North Carlsbad, while South Carlsbad has no coastal parks to
serve the 64,000 residents, many of which are children. Ponto Park at 11-acre Planning Area F is the last
remaining reasonable bit of vaca nt and currently unplanned Coastal land to provide a Coastal Park for
South Carlsbad. Ponto Park would also be in the middle of a 6-mile long section of North San Diego
County coastline without Coastal Park, and would help address a regional need for a Costal Park for
these 6-miles of coastline.
The CA Coastal Act has numerous policies that support the creation of Ponto Park and Coastal
Recreation land use. The City of Carlsbad’s history of following these CA Coastal Act polies now and over
the past 40-years in its Local Coastal Program should be considered now in the City’s proposed Local
Coastal Program Amendment. Over the past 40-years Carlsbad and California residents have forever
lost numerous opportunities to create vital Coastal Parks and Coastal Recreation for our growing
population.
In addition to the clear need for coastal parks in South Carlsbad, the citizens are overwhelmingly
supporting the creation of Ponto Park in Planning area F. As you know during the
past 2-years during the City Budget and Local Coastal Program Amendment processes, residents strongly
demonstrated their desire that the City Council purchase and build Ponto Park. In 2019, 2020 and 2021
over 90% of citizen input expressed need was for Ponto Park, along with extensive verbal and written
citizen testimony.
As COVID-19 vividly pointed out, parks are not an amenity, but a key component to human physical and
mental health. Parks also provide environmental benefits and contribute to cleaner air and water,
climate adaptation and social cohesion. TPL think you have a great opportunity to address equity and
access to park space and improving the lives of thousands of Carlsbad residents and strongly urge you to
support the building of Ponto Park for families and community.
Sincerely.
Rico Mastrodonato
Government Relations Director