HomeMy WebLinkAbout2022-07-28; Growth Management Citizens Committee; ; Committee Business (2)CA Review ______
Meeting Date: July 28, 2022
To: Growth Management Citizens Committee
Staff Contact: Eric Lardy, City Planner
Eric.Lardy@carlsbadca.gov
Sarah Lemons, Communication & Engagement
Sarah.Lemons@carlsbadca.gov
Subject
Committee Business
Recommended Action
Receive presentation from city staff and discuss the following topic:
• Committee “Housekeeping Items”. Chair to address recent public comment items, potential
use of subcommittees, additional topic prioritization, and overall project schedule.
• Mobility & Circulation Performance Standard. Receive a presentation from city staff and
consultants on the existing standard for mobility and circulation. Group discussion on the
standard: Is this standard important to quality of life in Carlsbad? Should this standard be re-
evaluated in any way? (Nathan Schmidt, City of Carlsbad Transportation & Mobility Manager,
and Stephen Cook, Intersecting Metrics) (Exhibit 1)
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. Circulation Performance Standard
GROWTH MANAGEMENT CITIZENS COMMITTEE @) Staff Report
CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE
STAFF REPORT – Discussion Item 3 Exhibit 1
JULY 28, 2022
Circulation
Implement a comprehensive livable streets network that serves all users of the system – vehicles,
pedestrians, bicycles, and public transit. Maintain LOS D or better for all prioritized modes of
travel, as identified in the General Plan Mobility Element, excluding LOS exempt intersections and
streets approved by the City Council.
CURRENT GROWTH MANAGEMENT PLAN
The main goals of the city’s Growth Management Plan (GMP) are to Provide a framework in which
new growth should occur and to ensure that new development pays its own way. The GMP was
originally established in 1986 and had subsequent updates as part of the 1994 and 2015 General
Plan Update process. The 2015 General Plan update1 established a livable streets approach to
mobility, which emphasized a multi-modal approach to transportation and planned to implement
a Complete Streets network throughout the city, which will help to accommodate all modes of
travel (auto, transit, bicycle, and pedestrian). The circulation standard (outlined above) was
established in 2015 to be consistent with the General Plan livable streets approach.
Livable Streets
The city’s approach to provide livable streets recognizes that optimum service levels cannot be
provided for all travel modes on all streets within the city. This is due to competing interests that
arise when different travel modes mix. For example, pedestrian friendly streets typically have
slow vehicle travel speeds, short-distance pedestrian crossings, and include some type of buffer
between the vehicle travel way and the pedestrian walkway. However, automobile friendly
streets typically have wide travel lanes, multiple turn lanes (increasing the pedestrian crossing
distance), and high automobile speeds. Therefore, the General Plan Mobility Element utilizes a
livable streets approach to provide a balanced mobility system that identifies, based on the
location and type of street (street typology), the travel modes for which service levels should be
enhanced and maintained per the multi-modal level of service (MMLOS) standard specified in
the city’s Citywide Facilities and Improvements Plan (part of GMP).
Transportation System Management & Transportation Demand Management Programs
The 2015 General Plan update identified a series of roadways within the city that would need to
be widened beyond six-lanes, which is generally the maximum width of a surface level roadway,
to maintain a LOS D or better. Since the further widening of these roadways is not feasible,
policies were included within the General Plan to develop techniques to better manage the
transportation system as a whole, including the development of citywide transportation system
management strategies (TSM) and transportation demand management (TDM) strategies.
1 https://www.carlsbadca.gov/home/showpublisheddocument/3422/637434861095100000
CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE
STAFF REPORT – Discussion Item 3 Exhibit 1
JULY 28, 2022
2
TSM strategies look to implement technology to improve traffic signal coordination, which
increases roadway efficiency and capacity. The same signal coordination technology can also be
used to improve transit service speed and reliability. Finally, TSM strategies include the
enhancement of signal detection for vehicles, buses, bikes, and pedestrians. This results in
increased safety and access for all modes of travel, as it reduces and better manages the conflict
points between modes. As part of the TSM program, the city allows developments to purchase
updated signal controllers as mitigation along roadways that cannot feasibly be widened due to
right-of-way or other constraints.
The city developed a TDM Handbook2 in August 2019 which sets new TDM requirements for
new development. The TDM Handbook outlines several measures that can be implemented to
reduce the demand of vehicular traffic associated with a project. These measures include
bicycle infrastructure, carpool/vanpool programs, incentive programs, alternative work
schedules, providing on-site amenities, and encouraging the use of transit. New non-residential
developments that generate 110 daily employee trips or more are now required to develop and
submit a TDM plan with the city. Residential projects which are determined to add trips to
GMP exempt roadway segments are also required to implement TDM. These developments are
also required to submit annual monitoring reports to the city to review the plan’s effectiveness.
HOW ROADWAY IMPROVEMENTS ARE FUNDED
The city’s transportation network is funded through the following primary sources:
• Grant Funding – The city applies for local, state, and federal grants to assist with the
funding of a variety of transportation infrastructure projects. Most grant funding sources
focus on safety and sustainability, thus grant funding is primarily only available for multi-
modal infrastructure such as bike and pedestrian facilities.
• Required Developer Improvements – Land development projects are required to conduct
a Local Mobility Analysis study to determine if the project will cause or worsen sub-
standard operations (LOS E or F) on a roadway, based on the city’s MMLOS standards. A
Local Mobility Analysis evaluates the effects of new developments on the local
transportation network and is required for development projects that generate more
than 11 peak hour trips or 110 daily trips. If a project is found to cause or worsen sub-
standard operations, it is generally required to implement the infrastructure needed to
restore operations to pre-development conditions. Development projects are also
generally required to improve the roadway along its frontage to its ultimate condition, as
prescribed within the General Plan.
2 https://www.carlsbadca.gov/home/showpublisheddocument/310/637425981338370000
CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE
STAFF REPORT – Discussion Item 3 Exhibit 1
JULY 28, 2022
3
• Fee Programs – The city’s Transportation Impact Fee (TIF) Program and SANDAG’s
Regional Transportation Improvement Program (RTCIP) impose fees on new
developments to pay their fair-share to build out the city’s transportation network.
• Tax Funding (Sales Tax and Gas Tax) – Transnet3 is a half-cent sales tax that was voted
into place in 1987 by San Diego County voters to help fund regional transportation
infrastructure. The State of California has a 50.5 cent per gallon gas tax which helps to
fund regional transportation infrastructure as well as helps to fund the maintenance of
local roadways. The City of Carlsbad receives local allocations of both programs to assist
with transportation infrastructure and roadway maintenance.
HOW TRANSPORTATION ANALYSIS HAS CHANGED
Discretionary actions, including development projects and transportation projects, are required
to be evaluated under the California Environmental Quality Act (CEQA). Historically, the
evaluation of transportation impacts has been based on automobile delay and a “Level of
Service” or LOS standard to measure that delay. In 2018, the CEQA was updated consistent with
Senate Bill (SB) 743 (2013), which changed the way transportation impacts are evaluated under
the CEQA, as follows:
• Vehicle miles traveled (VMT). As of July 1, 2020, automobile delay and LOS are no longer
used as the performance measure to determine the transportation impacts of land
development projects under CEQA. Instead, VMT is now required to be one of the metrics
used to determine transportation related impacts. The stated intent of SB 743 was to bring
CEQA transportation analyses into closer alignment with other statewide policies regarding
greenhouse gases, complete streets, and smart growth. Using VMT as a performance
measure instead of LOS is intended to discourage suburban sprawl, reduce greenhouse gas
emissions, and encourage the development of smart growth, complete streets and
multimodal transportation networks. The requirements under SB-743 were codified under
Section 15064.3 of the CEQA guidelines as part of the December 2018 code update.
In response to SB-743 and the 2018 CEQA update, the City of Carlsbad developed new VMT
Analysis Guidelines in September 20204. These guidelines set new VMT based significance
standards in place to analyze and identify transportation related impacts within the city. The
City of Carlsbad based their transportation impact significance standards on the guidance
provided by the State of California in the Technical Advisory on Evaluating Transportation
Impacts in CEQA5, December 2018. The city’s significance thresholds for land development
projects are summarized below:
3 https://www.keepsandiegomoving.com/transnet-about.aspx
4 https://www.carlsbadca.gov/home/showpublisheddocument/312/637425981341500000
5 https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf
CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE
STAFF REPORT – Discussion Item 3 Exhibit 1
JULY 28, 2022
4
o Residential Projects: A significant transportation impact occurs if the project VMT per
capita exceeds a level 15% below the city average VMT per capita.
o Office Projects: A significant transportation impact occurs if the project VMT per
employee exceeds a level 15% below the regional average VMT per employee.
o Regional Retail Projects: A significant transportation impact occurs if the project results
in a net increase in VMT.
o Industrial Projects: A significant transportation impact occurs if the project VMT per
employee exceeds the average regional VMT per employee.
City average VMT per capita and regional average VMT per employee values are determined
using the SANDAG regional travel demand model6. Each project is able to use this process to
determine if additional analysis is needed or “screened out” meaning that a project is
determined to not have a significant impact and no additional analysis is required. Projects
that need to conduct additional analysis have several models and methods that they can use
to evaluate impacts to VMT.
• Significance thresholds for transportation infrastructure projects. Transportation
infrastructure projects that reduce or have no impact on VMT, such as pedestrian and bicycle
facilities, are presumed to reduce VMT and therefore presumed to have a no impact or a less
than significant impact. Transportation projects that induce VMT may have an impact and
need to be evaluated.
6https://sandag.maps.arcgis.com/apps/webappviewer/index.html?id=bb8f938b625c40cea14c8258355
19a2b
Dear Committee Members.
I have been giving much thought to Jeff Segal's comments at our June 23rd
meeting regarding the timeline of topics that were set in advance of our first
committee meeting. Most specifically, the concern that we are to develop
recommendations on performance standards to include in the new plan on
September 22, 2022.
I understand that the topics discussed have been necessary for background
and understanding but a lot of topics to get through and digest.
In the interest of brevity, I am suggesting that a short survey be sent to
each member to include the following:
List each current performance standard and ask if it should: 1) stay the
same 2) be updated or 3) eliminated
If the answer to the above is to be updated, list 3-5 bullet points with those
ideas/comments.
Identify new performance standards. List 3-5 bullet points on what should
be included at a minimum (the committee can address them in more depth
at a meeting).
When a standard is being updated or a new standard is identified, the
committee should keep in mind the following: 1) that there is funding
availability 2) the standard aligns with the city council goals 3) there are
reasonable cost vs. benefits estimates and 4) that it adheres to the recently
passed CA Senate bills that focus on increasing housing (thus) affecting the
metrics on all performance standards.
Thank you all for your time and effort with the committee. It is much
appreciated by me and I know the residents of Carlsbad.
Kind Regards,
Mary Ryan
District 2 Committee Member
Dear Carlsbad Growth Management Committee, City Council, and
California Coastal Commission:
Since 2017 the City received over 5,000 petitions, written and verbal
testimony regarding the need for Ponto Park and the Park and Useable
Open Space unfairness at Ponto and Coastal South Carlsbad. The City
staff should provide the Growth Management Committee all that citizen
input since 2017.
– The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will lose
over 32-acres of “High-
priority Coastal Land Use” due to coastal erosion and flooding. (14+ acres
of Coastal Recreation
and 18+ acres of Campground will be lost) in Carlsbad’s General Plan.
– Carlsbad’s Growth Management Program and 2015 General Plan did not
consider this critical 2017 & 2020 Sea Level Rise data and new actions
and a new Plan are needed to address the 32+ acre loss AND increased
population/visitor demand for “High-priority Coastal Land Uses”.
– Carlsbad’s Growth Management Program and General Plan also did not
incorporate requirements for unlimited population growth that will need
even more City and Coastal Recreation land – “High-priority Coastal Land
Uses”.
– There is a current Growth Management Program 6.6-acre City park
deficit in Coastal Southwest Carlsbad, and a 30-acre
Unconstrained/Useable Coastal
open-space deficit in Zone 9 (Ponto area – west of I-5 and south of
Poinsettia) that only gets
worse as we lose 32+ acres of Coastal Open Space lands from Sea Level
Rise.
Accordingly, I am making my position known and requesting that
I want the Growth Management Committee, City Council and CA Coastal
Commission to:
From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, June 16, 2022 11:15:02 PM
Address the true neighborhood Park needs for Ponto (minimal 6-7 acre
Park to serve minimal neighborhood needs based on Ponto buildout and
City’s current minimal Park Standard). Ponto Park should be an
appropriately wide, viable, flat and fully useable multi-use grassed field –
allow kids space to play informal sports. No thin strip of non-park land.
Address loss of 32+ acres of Coastal Open Space Land from sea level rise
by providing for Non-neighborhood City and State buildout-population and
visitor demands for both Coastal Recreation land use and the loss of the
Campground. Provide sufficient Coastal Recreation and Low-cost Visitor
Accommodation land use to address the CA Coastal Act and City/State
‘unlimited buildout population/visitor demand’, and planned loss of current
supply due to planned sea level rise.
Disclose and address 2017 CA Coastal Commission direction to City on
Ponto Vision Plan and Planning Area F Existing LCP in the PCH Project.
Fully address Sea Level Rise impacts consistent with CA Coastal Act &
Commission relative to the State’s recent requirement for unlimited City
and State population growth. Document, plot the Seal Level Rise
inundation and coastal erosion/bluff hazard areas in Carlsbad’s General
Plan including the Land Use Map, PCH Relocation Project maps, and in
the PCH Project replace all 32+ acres of high-priority Coastal land use that
will be lost to sea level rise and coastal erosion, and increase the supply of
these high-priority Coastal land uses to address State required unlimited
increases in City/State population and visitor demands.
Fully disclose and consider the 2022-June General Comparative tax-payer
Costs/Benefits Analysis of Ponto Park-PCH completion-proposed PCH
Relocation, to assure tax-payers (City and/or State) are getting the best
and most sustainable value for their tax-payer dollars. The City should use
tax-payer money wisely.
Incorporate the 5,000+ written/emailed petitions to the Council & CA
Coastal Commission, and the Letters from Carlsbad visitor industry,
Surfrider Foundation, and Batiquitos Lagoon Foundation.
Within the Local Facilities Management Plan Zone 9 portion fully provide
the 30-acers of documented missing Unconstrained Growth Management
Open Space that developers were supposed to provide. Also fully disclose
and incorporate the Ponto Open Space recommendations from North
County Advocates per City’s lawsuit settlement.
Fully preserve or mitigate sensitive habitat areas within and adjacent to the
PCH Project area.
Fully provide required storm water quality purification and dentition basins
in the PCH Project before project waters and waters passing through the
project area are discharged into the ocean and Batiquitos Lagoon.
I am concerned about the PCH Modification Project more than doubling
traffic congestion along Coast Highway for an extremely costly walkway,
when the same walkway and other needed Coastal land uses can be
provided for a fraction of the cost along existing Coast Highway. It is not
appropriate to try to pass off a walkway as “linear park”.
Lastly as requested since 2017, directly engage and specifically involve
the San Pacifico Community Association and Ponto Community in that
portion of the City’s PCH Project of planning and design of land use in that
community.
We request the above 11 citizen issues be fully addressed by the Growth
Management Committee, City Council, and CA Coastal Commission
regarding Park-Useable Open Space and Coastal Land Use issues and
City Capital Improvement Projects at Ponto and Coastal South
CarlsabdCarlsbad.
Sent from People for Ponto
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
From:Lance Schulte
To:Eric Lardy; Council Internet Email; City Clerk; Boyle, Carrie@Coastal; "Prahler, Erin@Coastal"; Ross,Toni@Coastal; Kyle Lancaster; Don Neu
Cc:info@peopleforponto.com
Subject:citizen input for Carlsbad Tomorrow Growth Management Committee (et. al.) regarding Parks - Park landdedication requirements for developers - an example of Ponto Site 18
Date:Thursday, July 14, 2022 9:05:43 AM
Attachments:image002.png
Dear Carlsbad City Council, Carlsbad Tomorrow Growth Management Committee, Carlsbad Park and
Planning Commissions, and CA Coastal Commission:
This email is a follow-up to the July 7th email below, and only in regards to item #2 that deals with
Park land dedication rules of 20.44 of the Carlsbad Municipal Code. Please include this email as
public input to the Carlsbad Tomorrow Growth Management Committee (CTGMC), Parks Master
Plan Update, Local Coastal Program Amendment, and Ponto Site 18 development file. Sorry for the
length of this email, due to documentation to counter staff’s incomplete information.
Role of Carlsbad Ordinance 20.44 - DEDICATION OF LAND FOR RECREATIONAL FACILITIES
The primary 20.44 requirement for developers to (at no cost to the City) provide land to the City to
meet the development’s demand for more City park acres, and the specific Park demand/supply
situation at Ponto that clearly justifies the City Council pursuant to Council’s (not staff’s) authority
under 20.44 to 1) require development to provide (dedicate without cost to the City) land for City
Park that is sufficient to meet that development’s park land demand (in the example of Ponto Site 18
that land area is 0.6118 acres), and 2) that pursuant to Council authority in 20.44, it is fiscally
prudent and much better for the City and Citizens of Carlsbad to accept ‘free’ land v. receive a “park
land in-lieu-fee” that only provides for 27% of the required land area called out in 20.44 and is thus
ultimately results in a tax-payer subsidy of development. Tax-payer subsidy of development is also
counter to the purpose of the City’s Growth Management Program.
Staff misrepresentation of Citizen input
Some staff misrepresented my and other Carlsbad Citizens when staff said their Thursday, July 7,
2022 4:05 PM below: “The comment (citizen’s 7/4/2022 8:33am email) claims that there is a
requirement for the city to build a park in the southwest quadrant.” What we said in our Mon
7/4/2022 8:33 AM emails was:
“2. Ponto needs a 6-7 acre Neighborhood Park to serve Neighborhood needs based on
the current Ponto population & City’s minimal Parkland Standard of 3 acre per 1,000
population. The SW Quadrant needs a new 6-7 acre City Park to make up for the Park
acreage Deficit in the SW Quadrant since 2012. South Carlsbad (62% of the Carlsbad’s
population) needs a significant Coastal Park, as there is no City Park west of I-5 in South
Carlsbad. Ponto is at the center of a 6-mile Regional Coastal Park gap. Ponto is the last
remaining vacant land that can provide a true Park. Carlsbad’s Park Master Plan maps Ponto
as an ‘area unserved by parks, and an area that the City should provide new parks’.
Since 2017 Carlsbad citizens have sent over 5,000 petitions to the City and CA Coastal
Commissions regarding the need for a Neighborhood Ponto Park, and larger Coastal Park for
South Carlsbad’s (and region’s) inland population. Citizens also called out flaws in the City’s
Ponto planning that failed to and consider and document these Park needs (and the need for
“Low-cost Visitor Accommodation” land use). Citizens shared these citizen concerns and
data to Fenton. Citizens asked Fenton to provide their required City Park land dedication in
actual Park Land at Ponto. Carlsbad’s park land dedication ordinance is CMC 20.44. Fenton
and People for Ponto Citizens have indicated they would like together [meet] with the City to
define how Fenton can provide Fenton’s fair-share of actual Ponto Park land. Fenton’s fair-
share would be about .7 acre of Parkland. Fenton is trying to set a meeting with the City to
do that.”
We Citizens are saying we NEED a Ponto Park adequate for local Ponto Citizen needs, AND also a
park adequate to serve the Coastal Park needs for All South Carlsbad (inland citizens) and address a
regional 6-mile long Coastal Park gap centered around Ponto. Sadly, current City ‘requirements’ fail
to recognize these NEEDS. The CTMC is charged with addressing these NEEDS and suggesting
changes to City ‘requirements’.
As a citizen, I am troubled by the some City Staff not being able to read what is being sent to them.
Most troubling is some staff misrepresentations to Citizens serving as the City Council, City
Commissions and Citizens Committees on what your fellow Carlsbad Citizens are communicating to
you. It seems from a Citizen perspective that some staff are biased against citizens and citizen input
that maybe contrary to what some staff want to do. As Citizens elected and appointed officials
charged with directing, recommending, questioning, and overseeing City Policy and staff we hope
you assure your processes, and City Staff serving you, provide an honest and truthful consideration
of fellow Citizens’ input.
Staff misrepresentation of Growth Management Program and Ordinance
Also of critical Citizen concern is that some City Staff are fundamentally misrepresenting what
Carlsbad’s Growth Management fundamentally is - setting MINIMUM required public facilities
thresholds (aka MINIMUM Performance standards) below which development will be halted. All of
Carlsbad’s Growth Management resolves around this fundamental Principle - the GM Performance
Standards are ONLY MINIMUMS that define when development must stop until that public facility is
raised ABOVE the MINIMUM Performance Standard. Some City Staff are inaccurately presenting GM
Performance Standards as the Ultimate, Final or Maximum desired level of a public facility to define
Carlsbad’s Quality of Life. Any facility above the MINIMUM Performance Standard is simply above
the ‘failure level’ where development stops until we are above the Performance Standard threshold.
Some of City Staff’s misrepresentation of Performance Standards is very serious, and needs firm
correcting. Reading the ballots establishing Growth Management and the City’s own FY 2019-20
Growth Management Plan Monitoring Report confirms that: ““FAILURE TO MEET PRERFORMANCE
STANDARD: The Growth Management Plan requires development activity to stop if a performance
standard is not being met.” The Growth Management Performance Standard line is a ‘failure line’,
not a Maximum or Average level of Quality of Life we all voted for and aspire to. Some City Staff
sadly thing that anything above failure (an F-grade defined by the GM Performance Standard) is
success and deserves an A-grade.
The Growth Management Plan or City Growth Management Ordnance 21.90 does not restrict the
City Council in any way from providing Public Facilities ABOVE the Growth Management (Minimum)
Performance Standard: ““21.90.140 Obligation to pay fees or install improvements required by any
other law. - Nothing in this chapter [Growth Management Ordinance 21.90 and the Plans it is
based on] shall be construed as relieving a builder, developer or subdivider from any public
improvement requirement, dedication requirement or fee requirement which is imposed pursuant
to Titles 13, 18, 20 or 21 of this code or pursuant to any city council policy. (Ord. 9808 § 1, 1986)”
This portion of Carlsbad law is supported by multiple City Council actions to exceed the MINIMUM
Performance Standards, such as the ‘oversupply’ (relative to the MINIMUM Park Standard) of City
Parks in the NW Quadrant. The Growth Management Plan plans for the NW Quadrant to have far
more Park acreage than required by the MINIMUM (you have been provided this data in the Coastal
Recreation data file). The SW and SE (and to a lesser extent the NE) Quadrants are failing to meet
the MINIMUM, but the City uses an ‘accounting trick’ to say that Parks that are in the NW Quadrant
are ‘on-paper’ in the SW, SE, NE Quadrant so a permanent future “Park failure” in the SW and SE
Quadrants are covered up in accounting. But the reality on-the-ground for Citizens and their
children is the reality – permanent Park actual acreage/access failure in the SW & SE Quadrants. The
City’s ‘accounting trick’ thus CREATES AN ACTUAL PREFOMANCE STANDARD FAILIURE in the SW & SE
Quadrants that Citizens and their families actually experience. You have seen the pictures of families
having to play in streets, railroad right-of-way, and trespass on other vacant Ponto land to use as a
Park; and been provided the 5,000+ emails as testament to these facts.
The fact is that the SW, SE and NE Quadrants do not have their MINIMUM required Park acreage
Performance Standard actually within their Quadrants. The City used an ‘accounting trick’ to cover
the that do not their bare MINIMUM of Park acres.
City Council regularly directs actions and funds to Oversupply (exceed) the Minimum Performance
Standard for most all Growth Management public facilities
The Council recently acted to increase this ‘oversupply’ of Park land in NW Quadrant with the new
Buena Vista Reservoir Park. This Park was NEVER in the Growth Management Plan nor was it
REQUORED to meet a MINIMUM Performance Standard. Sadly (for South Carlsbad Citizens) SW
Carlsbad (that has had a 6.5 acre MINIMUM Park Deficit since 2015) has had to absorb more
development and that SW Quad development paid for the NW Quadrant Buena Vista Reservoir Park
via “Poinsettia 61”. The City Council has also increased public facilities beyond the MINIMUM
Performance Standard on multiple other occasion such as the recent Fire Service investments
beyond the Performance Standard, and all over the City with City Administrative Facilities, Water,
sewer, most Streets, and other public facilities in the City that are being provided Over and Above
the MINIMUM Performance Standards (failure/no further development threshold) established for
those facilities.
Carlsbad Citizens, in over 5,000 petitions and overwhelming input at numerous public meetings,
clearly is documenting the NEED for the City Council to do (and direct Staff to do) what Carlsbad has
done before:
· provide for Park acreages and Parks at Ponto and SW Quad that are above the Minimum Performance
Standard (failure threshold),
· properly address the current 6-7 acre Park Deficit that has existed in the SW Quadrant since 2012 with a
park WITHIIN the SW Quadrant,
· Properly address Carlsbad Citizens overwhelming desire for a True Ponto Park,
· Get rid of accounting tricks that falsely say that Parks actually in the NW Quadrant are ‘considered to be in
the SW, SE, and NE Quadrants’
· Require developers to provide their fair-share of actual Park Land per 20.44. Do this at Ponto! Park land
is needed AT Ponto.
· Listen to Citizens, don’t fight and try to crush Citizens’ input and requests for you to address critical
Quality of Life issues
City Council (not City Staff) Authority under Carlsbad Ordinance 20.44 - DEDICATION OF LAND FOR
RECREATIONAL FACILITIES
As noted in my Thursday, July 7, 2022 5:17 PM email below, some City staff are also misdirecting
issues and incomplete in their assessment on the City’s Dedication of Land for Recreational Facilities
Ordnance 20.44, and in what appear to be some staff trying to assume and take over the City
Council’s authority to make Park decisions under 20.44. Following is CMC 22.44.060 that clearly
spells out the City Authority responsible for determining if Park land dedication or a “fee-in-lieu’ is
used. In the case of if only a SDP and CDP applications are needed for Ponto Site 18 development
that ‘decision making authority’ would be Carlsbad Planning Commission, or if/when appealed to the
City Council, the City Council.
20.44.060 Determination of land or fee.
A. Whether the decision-making authority for the tentative map or tentative parcel
map requires land dedication or elects to accept payment of a fee in lieu thereof, or a
combination of both, shall be determined by the decision-making authority at the time of
approval of the tentative map or tentative parcel map. In making that determination, the
decision-making authority shall consider the following:
1 Park and recreation element of the general plan;
2 Topography, geology, access and location of land in the subdivision available for
dedication;
3 Size and shape of the subdivision and land available for dedication;
4 The feasibility of dedication;
5 Availability of previously acquired park property.
B. The determination of the city council as to whether land shall be dedicated, or
whether a fee shall be charged, or a combination thereof, shall be final and conclusive. (Ord.
CS-192 § 49, 2012; Ord. 9614 § 1, 1982; Ord. 9190 § 6)
20.44.060 requires (shall) “consideration” of factors, but Council has discretion on how it ‘considers’
factors. “Consideration” is by definition a respectful, thoughtful, reflection and deliberation of
issues. “Consideration” is NOT a straight-jacket. The City Council has already provided critical Policy
direction to Staff to form the Carlsbad Tomorrow Growth Management Committee because
according to the City’s website “the city is entering a new phase where different tools will be
needed to effectively manage growth.” And that “The city is now in the beginning stages of
creating a new approach to managing growth in Carlsbad, starting with a citizens committee.” So
the decision whether to do what Park land dedication ordnances are intended to do receive land
dedicated to the City by developers to offset that developer’s impact on Parks is solely the City
Councils, and the City Council has started a processes to create new Park Standards and
requirements. The CTGMC is charged with considering past and future Park Standards and Park
Growth Management standards. The Ordinance allows the City Council to consider this and past
information at the time the entire development application comes before the Council for approval,
denial, or conditioning.
An example Carlsbad Ordinance 20.44 - DEDICATION OF LAND FOR RECREATIONAL FACILITIES using
as example the Fenton Ponto Site 18 development proposal:
Fenton recently purchased most of Ponto Site 18. They are proposing to develop most (4.64 acres),
but not all their land. Fenton wants to reserve some (about 1 acre) of their Ponto Site 18 vacant
land for future development. Fenton has land resources to provide actual Land as the DEDICATION
OF LAND FOR RECREATIONAL FACILITIES per 20.44.
Dedication of Land for Recreational Facilities calculation:
86 (DU of Fenton proposed development) X 2.64 (Carlsbad’s average population per DU per 2020 US
Census) = 227 (population of Fenton project)
227 ÷ 1,000 (population that needs a minimum of 3 acers of Park land per CMC 20.44) = 0.22704
(the percentage of the 3 acres of Park land minimally required for 227 people)
0.22704 X 3 acres (minimally required Park land per 1,000 people) = 0.68112 acres of Park land is
minimally required for Fenton's proposed 86 home based on City’s minimum
requirement
Fenton recent land purchase cost is about $2.178 million per acre. So Fenton’s 0.68112 acre
minimum park site requirement’s land cost is $1.484 million. However, the City’s “Park in-lieu-fee”
for Fenton’s proposal is only $4,636 per home or $398,696. So the City’s Park in-lieu-fee only
covers 27% of the Park land value the City would receive if the City accepted land under 20.44.
Cost of City failure to acquire ‘free Park land’ from developers, ‘in-lieu fees loose significant value
adding to tax-payer liabilities, and failure to get free park Land dedication loses critically important
opportunities to provided needed park:
The Fenton example shows that getting for free land is a much better deal for the City and Citizens.
It seems fiscally irresponsible for the City Council not to acquire Free park land per 20.44. The City
would be losing $1.085 million per acre by accepting “Park in-lieu-fees” that are inadequate to pay
for the cost of park land that the City would otherwise be provided free by a developers in their Park
land dedication. The City’s “Park in-lieu-fee” is basically a developer/development subsidy by the
City and the City’s tax-payers. This subsidy will ultimately be paid by Carlsbad tax-payers. This is
one reason that developers love to pay ‘in-lieu-fees” as these fees never cover the developer’s full
cost to mitigate their development’s impact on and obligations to a community/City. This subsidy
dynamic of “in-lieu-fees” is well known but, cities tend to hide this information from citizens. Recall
the history of Affordable Housing in-lieu-fees and update a while back. Per 20.44.08 the Park in-lieu-
fee” is supposed to cover the fair-market value to buy the land that would otherwise be dedicated
(for free) to the City. As shown above the City’s current Park-in-lieu-fee is not doing that:
20.44.080 Amount of fee in lieu of land dedication.
A. When a fee is required to be paid in lieu of land dedication, the amount of the
fee shall be based upon the fair market value of the amount of land which would
otherwise be required to be dedicated pursuant to Section 20.44.040. The fair
market value shall be determined by the city council using the following method:
1 The city manager may from time to time survey the market value of undeveloped
property within the city. This survey may be prepared through various means
including, but not limited to, selection of several real estate professionals within
Carlsbad to provide current estimates of undeveloped property values with each of
the city’s four quadrants.
2 The council shall adopt a resolution establishing the value of one acre of park land
in each quadrant after considering the results of this survey and any other relevant
information.
B. Subdividers objecting to such valuation, may, at their own expense, obtain an
appraisal of the property by a qualified real estate appraiser approved by the city, which
appraisal may be accepted by the city council if found to be reasonable. If accepted, the fee
shall be based on that appraisal. (Ord. NS-120 § 1, 1990; Ord. 9831 § 1, 1987; Ord. 9781 § 1,
1985; Ord. 9614 § 1, 1982; Ord. 9190 § 8)
A critical consideration for Carlsbad is that we are rapidly running out ‘relatively cheaper’ vacant
land like at Ponto, and the City is better off getting developers to provide actual park land, or if
an “in-lieu-fee” is paid that fee should accurately represent 100% of the actual cost to buy the
acreage of park land within a 10-minute walk of that development. The City should not subsidize
development and make parks inaccessible and outside of the 10-minute walk to the developments
generating the need for park land. These facts/issues should be consider by the CTGMC in
formulating recommendations to City Council on Growth Management and Park land dedication.
I am using the Fenton proposal as an example of Park Standard issues and the shortcomings of
Carlsbad’s current Park standards the CTGMC is charged with studying and making update
recommendations to the Council. People for Ponto Carlsbad Citizens are trying to collaboratively
work with Fenton to get park land at Ponto dedicated. This initial Park land dedication can be the
beginnings of a much needed and larger Ponto Park to address the acute park needs at Ponto and in
Coastal South Carlsbad that are documented by the City, Carlsbad Citizens, and many others. Fenton
has graciously offered to try to set a meeting between People for Ponto Citizens-City-Fenton to see
how Fenton’s Ponto park land dedication requirements can be met in Ponto. We are hopeful Fenton
will provide a 0.68112 acre Park site as the ‘down payment’ for a much needed larger Ponto Park.
We are hopeful the City Council will direct City Staff to work with Carlsbad Citizens to effect this.
Thank you for your consideration. Please know P4P citizens truly care and love Carlsbad and want to
leave a better Carlsbad to future generation. P4P citizens have a lot of successful and creative
expertise and can help the City in these issues.
Sincerely and with Aloha Aina,
Lance Schulte
From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Thursday, July 7, 2022 5:17 PMTo: 'Jason Goff'Cc: 'Eric Lardy'; 'Cliff Jones'; Carrie Boyle (carrie.boyle@coastal.ca.gov); 'Prahler, Erin@Coastal'; Ross,Toni@Coastal (Toni.Ross@coastal.ca.gov); 'info@peopleforponto.com'Subject: RE: CITY RESPONSE RE: EMAIL DATED JULY 4, 2022 - public input on CDP 2022-0023 & SDP2022-0003 - Ponto Site 18 - 4 major issues - CCC needs to be contacted
Jason, City Council, and Carlsbad Tomorrow Growth Management Committee:
Thanks.
Regarding #1: Thank you. Is it possible to receive a copy of the CCC’s response to your
communication?
Regarding #2: Your reading of 20.44, is incomplete. It also seems you are also incorrectly speaking
‘as the City Council’ on what is a City Council decision based on 20.44 and that has yet to be
rendered by the Council regarding this development proposal. 20.44 does NOT explicitly disallow
Dedication of Ponto land for a needed Ponto Park from and for a Ponto development. Not acquiring
Park land or not using park land “in-lieu-fees” at Ponto to provide a Park at Ponto for a Ponto
development is further removed from the intent and purpose of the Park land dedication ordinance.
What is the City Council’s and City staff’s intent to use Park land dedication ‘In-lieu-fees’ for to serve
the Park needs of this Ponto development? There is a 6.5+ acre Park deficit in the SW Quadrant.
Where will the Park for this Ponto development be provided - 6-miles away in the NW Quadrant’s
Veterans Park?
If you read 20.44 how the Council chooses to require park land dedication or accept a Park land
dedication ‘In-lieu-fee’ is a City Council policy decision that is made when the project is being heard
for consideration. Your 20.44 citation even supports the dedication of park land at Ponto by the
proposed development as such a land dedication would be the best way to “... shall bear a
reasonable relationship to the use of the park and recreational facilities by the future inhabitants of
the subdivision.” As clearly documented in the City Park Master Plan, Ponto is an area of the City
‘unserved by Parks’ and an ‘area the City should look to provide new Parks’. Again, per 20.44 it is
The City Council’s policy decision/direction as to if the City wants park land dedicated at Ponto for
Ponto development or it wants to receive a park land dedication ‘in-lieu-fee’. The City Council
should make that policy decision/directive to staff if it wants park land or equivalent park land ‘in-
lieu-fees’.
Also, the City is formally in the process of re-evaluating the Growth Management Parks Standard.
Citation of past GM Park Standard compliance reports to City Council when the City Council has
already provided direction to staff and acknowledged such Standards should be studied and
potentially updated or replaced should have been acknowledged, and is a critical aspect of
information City Council should consider as part of a 20.44 Council determination of whether to
require Park land at Ponto for Pont Park impacts or accept a park land ‘in-lieu-fee’ for Ponto Park
impacts. This issues seems appropriate for the Citizens Carlsbad Tomorrow Growth Management
Committee to provide input to the City Council on.
Regarding #4: What will be the City’s response and responsibilities if/when parking impacts spill on
to City Streets and Public beach parking (from inadequate City parking requirements)?
From: Jason Goff [mailto:Jason.Goff@carlsbadca.gov] Sent: Thursday, July 7, 2022 4:05 PMTo: Lance SchulteCc: Eric Lardy; Cliff JonesSubject: CITY RESPONSE RE: EMAIL DATED JULY 4, 2022 - public input on CDP 2022-0023 & SDP2022-0003 - Ponto Site 18 - 4 major issues - CCC needs to be contacted
Dear Mr. Schulte,
Thank you for the email comments on the project known as FPC Residential (SDP 2022-0003/CDP
2022-0023). The following is the City’s response to the email comments received on July 4, 2022
(attached):
City’s Response to Comment No. 1:
The comment claims that the project should be required to apply for various amendments to the
city’s land use documents. However, the applicant is proposing a development project that is
consistent with the current land use designations for the property; therefore, amendments to the
General Plan, Zoning and Local Coastal Program Land Use and Zoning designations are not included.
As previously noted, the property is currently designated a combination of VC (Visitor Serving
Commercial) and R-23 (19 to 23 dwelling units per acre). The comment implies that the current
project requires written confirmation from the Coastal Commission to process consistent with these
designations. The city disagrees. The city’s review of current policies indicates that the combo
districts in Ponto can be built as one or the other land use or as a combination of both with the area
of each land use delineated on the land use map (typically determined at the time of a development
proposal).
Additionally, the hotel north of the subject Ponto combo district is on parcels that were also
previously a combination district; however, the parcels were built entirely with visitor serving uses
(parcels redesignated VC during GP update but were previously TR/RMH).
Development of the property is subject to the city’s review and approval. The city has authority to
issue Coastal Development Permits (CDPs) in this area, and therefore, Coastal Commission approval
of the project is not required. In addition, the property is not within the Coastal Commission’s appeal
jurisdiction and the city’s approval of a CDP on the property is not appealable to the Coastal
Commission. This information has been shared with Coastal Commission staff.
City’s Response to Comment No. 2:
The comment claims that there is a requirement for the city to build a park in the southwest
quadrant. There is not a requirement for construction of a park in this area. As reported in the city’s
latest Growth Management Plan (GMP) Annual Report and further detailed to the City Council on
January 26, 2021, and July 13, 2021, the city is in compliance with the GMP’s performance standards
for open space and parks and there is not a requirement to purchase additional park land in the
southwest quadrant. We acknowledge the conversations with the citizens and developer relating to
applying park fees for park space in this area. However, Carlsbad Municipal Code § 20.44.090
governs the use of the collected fee and states the land and fees received under this chapter shall be
used for the purpose of developing new or rehabilitating existing park and recreational facilities
which serve the population within the park quadrant within which the subdivision for which the fees
are received is located and the location of the land and amount of fees shall bear a reasonable
relationship to the use of the park and recreational facilities by the future inhabitants of the
subdivision. (Ord. NS-842 § 1, 2007; Ord. 9680 § 12, 1983; Ord. 9190 § 11). As currently written, the
code does not explicitly allow for park fees to be dedicated to a specific park or area within the
quadrant.
Link to latest GMP Annual Report:
https://www.carlsbadca.gov/home/showpublisheddocument/8573/637744924012530000
Link to January 13, 2021, City Council Staff Report:
https://records.carlsbadca.gov/WebLink/DocView.aspx?
id=5244472&dbid=0&repo=CityofCarlsbad&searchid=4d4f5873-14c1-42fb-a3c6-d6da0037b658
Link to July 13, 2021, City Council Staff Report:
https://records.carlsbadca.gov/WebLink/DocView.aspx?
id=5432896&dbid=0&repo=CityofCarlsbad&searchid=8e946f0a-1e58-462f-98f5-11d939f53b36
City’s Response to Comment No. 3:
Comment highlights the existence of the SoCal Gas natural gas easement. This is acknowledged. Staff
is aware of the SoCal Gas natural gas easement and pipeline running north-south through the
subject site as well as along the west side of the railroad right-of-way, which is also located directly
adjacent to other residential land uses throughout the city. The applicant was notified in the first
review of the project application as to the gas line’s presence and is presently working with SoCal
Gas and the city to provide proper setbacks to ensure that the public’s health and safety is
maintained.
City’s Response to Comment No. 4:
Regarding concerns with parking adequacy, the city’s municipal code section covering parking ratios
associated with multiple-family residential dwellings (apartments only) and required visitor parking is
outlined in § 21.44.020.B.Table A. This section of the municipal code is used throughout the city,
including the coastal zone pursuant to our local coastal plan, for required parking associated with
apartments and visitor parking needs. While the applicant can voluntarily add additional parking
stalls, the city cannot legally require more parking spaces than what current code requires.
Thank you,
Jason Goff
Community Development Department
Jason Goff | Senior Planner
Planning Division
1635 Faraday Avenue
Carlsbad, CA 92008
442-339-2643 | jason.goff@carlsbadcagov
FOR SUBMITTAL APPOINTMENTS PLEASE CALL OR EMAIL YOUR REQUEST:
Phone: 442-339-2600 (select Option 2)
Email: planning@carlsbadca.gov
www.carlsbadca.gov
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Comments on PCH Relocation & design Options offered – Manzano to Island Way – 2022 July
Comments on all three Options:
1. PCH Relocation as noted in the City’s 2001 Study was focused on allowing the City to develop
PCH Median land for commercial uses and advance the City acquiring in-trade State land
(primarily the Manzano site just south of the Terramar neighborhood) for commercial
development. The land trade would then allow the Carlsbad Campground to move inland along
PCH so as to move out of the “Coastal hazard zone” of coastal erosion, bluff erosion and now
sea level rise and climate changes that will accelerate these Coastal Hazards. There are several
vacant areas in all three Options that are similar to the areas proposed for commercial
development in the City 2001 PCH Study. Although the 1-mile PCH Relocation proposal includes
the Manzano Site and covers the northern tip of the Campground, a clear explanation if the
original intents of PCH Relocation are still part of the City’s proposal – commercial development
of PCH median land.
2. The City should map and enumerate the actual length of PCH roadway facilities – vehicle lanes,
bike lanes, sidewalks that are in the “Coastal hazard zone”. For instance if only a couple
hundred feet of the southbound lanes of PCH at “the dip” bridge are in the “Coastal hazard
zone”, it may be more cost effective to simply address Relocation of that segment.
3. Was a simple and likely far less costly PCH redesign that simply lifted up and/or moved inland
those PCH roadway facilities – vehicle lanes, bike lanes, sidewalks that are in the “Coastal hazard
zone” considered and designed? Why?
4. Clearly provide a ‘profile of the Existing Condition’ of PCH lanes, bike lanes, pedestrian paths for
the various segments of the Study Area. It should be clear to citizens what we have now and
what new added features each design provides for the various segments.
5. A basic traffic study showing impact to both link and intersection Vehicle LOS and Vehicle speed
should be conducted now so citizens clearly understand what the vehicle LOS and speed
consequences from existing PCH and all PCH Relocation designs.
6. Clearly describe what the “Coastal hazard zone” is, and if it conforms to the latest CCC
requirements of SLR analysis and Coastal planning.
7. Clearly describe what the “Las Encinas Creek restoration area” is and clearly outline the
boarders of the “Las Encinas Creek restoration area”.
8. Use wider landscaped medians to provide areas for shade, a coastal tree-scape and soften the
extensive hardscape. The proposed minimal 4’ wide median in all three Options is a very ‘urban
roadway’ design and very out of character with our existing Historic 101 and well regarded wide
and natural landscaped PCH median. The proposed minimal 4’ wide and landscaped median is
grossly out-of-character, particularly when seen in profile with the continuous/adjoining
pavement.
9. A clear map and itemization of all existing parking spaces should be conducted and names or
letters used to identify each existing parking area.
10. All new parking areas should be named or a numbered to correspond to the Existing Parking lot
name or letter. For example Existing Turnarounds lot A, Proposed Turnarounds Lot A-1
11. An Existing and Proposed Parking map and accounting of the number of spaces should be
provided so citizens know where and how many beach parking spaces we have and where and
how many proposed spaces there are and the net difference between existing and proposed.
12. Move “Retain existing parking” at “turnarounds” inland to be outside of “Coastal hazard zone”,
and use old PCH pavement as parking spaces.
13. Provide a plan to transfer the spaces in the “existing parking to remain” at the “glider port” to
the “Turnarounds” parking area. Label the “glider port”
Page 2 of 2
14. Move “Retain existing parking” at the north end of the Campground (north of Island Way) inland
to be next to the PCH Roadway so vehicles do not have to cross the “Class 1 shared path for
pedestrians, slower moving mobility options“, and to place this parking outside of “Coastal
hazard zone”.
Comments on Option 1: 4-lane road with traffic signals:
1. Replace all 4 traffic signals with 4 traffic circles. For PAR use separate ‘free-right’ lanes outside
of traffic circle to reduce volume in the circle. This design is used at LEGOLAND. Given T-
intersections using free-right or straight through bi-pass lanes will allow better flow.
2. A narrow 4’ wide median maybe needed on the Bridge, but an honest consideration of a
separate 2-lane bridge or 2 2-lane bridges that provides more separation between NB and SB
lanes should be explored.
Comments on Option 2: 2-lane road with roundabouts & Option 3: 2-lane road with roundabout and one
enhanced pedestrian crossing:
1. A 50% reduction in vehicle travel lanes will have a dramatic impact on current and future vehicle
and transit capacity on PCH. This impact is over 50% in that by removing the 2nd passing lane
and ability to pass, all vehicle speeds are reduced the ‘slowest’ vehicle in the lane. This will have
significant impacts not only to citizens in their vehicles, but also to transit vehicles as they will be
slowed down due to more than doubling lane congestion, being slowed down in trying to re-
enter the single lane after dropping/picking up passengers, and by the slower speeds that will
accompany the 50% lane reduction to a single lane in each direction and by reducing the existing
wide landscape median with a minimal 4’ wide urban street median.
2. A 50% reduction in vehicle travel lanes will have a dramatic impact on the City’s current and
future Emergency Vehicles (police-fire-ambulance-lifeguard) travel speeds on PCH. This impact
is over 50% in that by removing the 2nd passing lane and ability to pass, all vehicle speeds are
reduced the ‘slowest’ vehicle in the lane. As noted before this will have significant impacts to
Emergency Vehicles as they will be slowed down due to more than doubling lane congestion,
and maybe completely stopped as the most likely Emergency will be on the single PCH lane and
all traffic will be stopped. The adjacent 11’ wide bike lane and buffer area is narrow and limits
Emergency Vehicles using that bike lane area as a ‘passing lane’ around stopped vehicles, or for
vehicles to pull over into the bike lane to try to let Emergency Vehicles pass.
3. The City has noted wanting to provide a new Emergency Vehicle Services operation along PCH,
noted the higher Emergency incidence along PCH, and noted the very high cost to buy, build,
equip, provide personal to operate, and post-service pension costs to provide an additional
fire/EMT and/or Lifeguard operation along PCH. If PCH travel is slowed down, or more
emergency incidents be created by a reducing PCH to one-lane in each direction with a minimal
4’ median would a 2nd Emergency Vehicle Services operation along PCH be needed?
4. Given the State of California’s requirement that Carlsbad and all other areas of the State provide
for unlimited population growth and that PCH vehicle, transit, bike and pedestrian volumes will
have commensurate increases into the future, and that PCH Relocation and lane reduction
would be very expensive ($70 million from 2022 CIP Council meetings April 20 & 26, and May 3,
2022) and forever City commitment it would be difficult to under consider the impacts and
consequences of forever reducing lanes while Carlsbad has to accommodate forever unlimited
population and traffic growth.
From:Lance Schulte
To:Council Internet Email; City Clerk; Tom Frank; Nathan Schmidt; Kyle Lancaster; Don Neu; Eric Lardy; Boyle,Carrie@Coastal; "Prahler, Erin@Coastal"; Ross, Toni@Coastal
Subject:Public input to 1-mile PCH Relocation Proposal - FW: public input to 7-5-22 Traffic Committee meeting - South
Carlsbad Boulevard Climate Adaptation Project
Date:Sunday, July 17, 2022 6:05:10 PM
Attachments:Comments on PCH Relocation and design Options offered - 2022 July.pdf
Dear Carlsbad City Council, Traffic, Parks, Planning Commission; Carlsbad Tomorrow Growth
Management Committee; & CA Coastal Commission:
I was unable to attend July 5th meeting. However today I had time to watch the July 5th Traffic
Committee meeting but did not see the issues noted in the July 4th email and attachment noted. I
am not sure if the July 4th input (attached and below) was considered, but was encouraged by the
Traffic Commission’s call for data, comprehensiveness, congestion considerations; and logical and
principled desire to make ‘data driven decisions’.
The Traffic Commission’s concerns reflected some of the attached and below concerns. Of key
concern is rushing in asking for ‘incremental’ decisions on what is to be a critical MM (vehicle, bike,
ped, Transit vehicle, and emergency vehicle) Traffic corridor without a verified Multi-modal Traffic
LOS (vehicle, bike, ped, Transit vehicle, and emergency vehicle) data that not only covers the ‘pre-
Covid’ condition, but addresses also addresses the “Forever/Final/Buildout MM Traffic Volumes”
that any major reconfiguration of PCH will have to perform within.
I can appreciate and sympathize with staff in their rush, but potentially tragically, in that rush (solely
driven by timing of a grant and grant funds) to be forcing Citizen Commissions to make disconnected
decisions without critical data and a comprehensive perspective on such an important issue seems
both unfair and “penny wise and pound foolish”, “putting the cart before the horse”, “jumping
before looking” or any other common sense truth about rushed uninformed actions. In retrospect
maybe planning a Joint Commission meeting on this issue after all the critical data was compiled may
have been a better processing approach.
To the July 4th email/attachments of issues and data I hoped the City’s Commissions and City Council
would have considered on July 5th etc. I add the following:
1. Study keeping existing PAR/PCH design (free flowing) and simply move SB PCH lane (and
bike/ped improvements) inland before “turnarounds” to merge with the PAR to SB PCH lane
to a 4-lane PCH at So Lamar (option 2 design - south of So Lamar). I think this was what one
Traffic Commissioner was suggesting.
2. The Staff report used traffic volumes for a location about 2-miles away (PCH/Avenida
Encinas) v. using traffic counts for PCH/Cannon Road & Terramar that is a lot closer, is
directly impacted by any induced congestion from NB PCH Traffic entering Terramar and the
PPCH/Cannon intersection and by possible congestion backups into Terramar and the
PCH/Cannon intersection from removing the current SB free flow of traffic until you reach
Solamar. Terramar congestion is bad and potentially congesting 1-mile of PCH directly south
of congested Terramar seems will make Terramar congestion worse and likely extend
congestion further south (possibly to Island Way). Terramar also represents how pedestrian
traffic across PCH impacts PCH non-pedestrian congestion.
3. Taking MM Traffic counts (vehicle-bike-ped-transit-emergency vehicle) at Carlsbad’s current
3-way & 1-lane PCH/State Street Traffic roundabout would give an ‘on-the-ground’ model on
which to test the same type of roundabouts in the two roundabout based alternatives and
then MM Traffic Model the future/final/buildout growth in all MM volumes on such 3-way 1-
lane roundabouts. Any major PCH redesign/relocation will be a permanent/final/forever
decision so making 100% sure we know how it will work in the future is critical.
4. Conduct a documented MM (vehicle-bike-ped-transit-emergency vehicle) Traffic LOS
analysis of 3-way 1-lane PCH/State Street Roundabout for existing, pre-Covid, and
future/final/buildout growth in volumes, so we have an understanding of how present MM
LOS differs from Pre-Covid and future/final/buildout growth MM LOS.
5. Calibrate the above MM LOS models to a) the current MM Traffic Counts at the 1-mile
PAR/PCH volumes and then adjust for both b) Pre-Covid volumes and also to c) projected
final/Forever Carlsbad MM Traffic volumes based on 2015 General Plan and updated
projections used to define Carlsbad’s ‘buildout MM Traffic Volumes’ at and along PAR and
PCH for the 1-mile PAR/PCH segment; and how it impacts the current, pre-Covid and
future/final/buildout growth MM LOS at Terramar.
6. Provide a clear understanding of how Transit services will be impacted by delay, congestion
and removing a NB and SB passing-lane in the 2-lane (50%) reduced proposals. Confirmation
from the NCTD as to the Transit Service impacts should be provided to the public and City
decision makers.
7. Provide a clear understanding of how Emergency vehicles, response times and services will
be impacted by delay, congestion and removing a NB and SB passing-lanes in the 2-lane
(50%) reduced proposals. Emergency vehicles will not be able to pass congested traffic,
which seems like a significant impact in an area the City is spending millions in capital and
forever operational and pension costs to provide another fire station along PCH for the
current 4-lane (with passing lanes) condition. Will the proposed PCH reconfigurations force
the City to have to provide another fire station along PCH due to potential increases in
congestion and inability to pass congestion during emergencies? City decision makers
should have that data so they can make data driven decisions relative to emergency services.
I hope this email and attachment are provided to you and that you honestly and sincerely consider
it.
I am not against a possible 2-lane PCH if it Preforms Better both now and forever into the future.
The concerns are that we do not yet have the data to judge if the limited options (or other viable
options) Preform Better and will be Preform Better forever for Carlsbad. We also seem to be
shortchanging (or glossing over) significant citizen and stakeholder concerns/issues in the
incremental rush.
Thank you for your thoughtful consideration.
Lance Schulte
From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net]
Sent: Monday, July 4, 2022 3:39 PMTo: traffic@carlsbadca.gov; 'Nathan Schmidt'Cc: 'City Clerk'; council@carlsbadca.gov; 'info@peopleforponto.com'Subject: public input to 7-5-22 Traffic Committee meeting - South Carlsbad Boulevard ClimateAdaptation Project
Dear Carlsbad Traffic Commission:
We hope you had a wonderful 4th of July, and ask you please sincerely consider the attached
questions/comments regarding on 7-5-22 and on other meetings regarding the South Carlsbad
Boulevard Climate Adaptation Project.
I travel PCH often from South to North Carlsbad – car, bike and walk. It is my main travel and
exercise corridor. The congestion at Terramar as 4-lanes are compressed into 2-lanes is kind of a
nightmare at times and will get more traffic from continued growth. Proposing to permanently and
irreversibly doubling that nightmare and congestion with some of the designs needs serious and very
well vetted public discussion. Providing needed pedestrian sidewalks/paths is critical, and providing
safer bike lanes are appreciated, but permanently eliminating over 50% of vehicle capacity and
expanding congestion does not seem to make any common sense. The Roadway options also
urbanize (see the profiles) PCH and fundamentally change the open wide median and rural Old
Carlsbad and Old California Character of our Historic 101.
Having worked as a City Planner for several Coastal cities, and having lived on the coast for my entire
adult life, I speak with some experience about the folly that can occur by abandoning capacity, and
by unneeded lane reduction that is not fully and properly analyzed and public vetted with a specific
focus on the long-term transportation demands. With a price-tag of $70 million per mile, to in 2 of
the options permanently reduce by over 50% vehicle transportation capacity, we hope your
considerations are very thorough and future orientated.
It is in-fad to promote vehicle congestion, to slow traffic, and max-out LOS to close to failure as a
wise use of pavement. This is counter to what most all people want. Imagine how difficult and
unpleasant it is to travel in a congested lane, and how frustrating and ‘LA like’ it is to travel in a
congested network. We may be using pavement efficiently, but we pay the price in our mobility,
travel experience, and road rage. Roads should work for people, not people having to work
frustratingly on congested roads.
Thank you for your consideration,
Lance Schulte
From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Sunday, July 3, 2022 4:50 PMTo: 'Katie Hentrich'Cc: 'James Wood'; 'Tom Frank'; 'Nikki Matosian'; 'Nichols, Katie@SCC'Subject: RE: South Carlsbad Boulevard Climate Adaptation Project
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City of Carlsbad
1635 Faraday Ave.
Carlsbad, CA 92008
www.carlsbadca.gov
442-339-2623 | katie.hentrich@carlsbadca.gov
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TO:
From:
Subject:
Date:
Growth Management Committee
Mike Howes
Growth Management Background & History
July 22, 2022
Following is a very brief, simplified history of Carlsbad's Growth Management Program from someone
that was there throughout the entire process. I was only a part of the process; it was a team effort by a
number of individuals.
Unfortunately, during our first meeting there was only a very superficial discussion of the history and
creation of Carlsbad's Growth Management Ordinance and Program. It might be easier to update the
Growth Management Program if everyone had a better understanding of why it was created in the first
place and what would have occurred if it did not happen. Also, what it addresses and what it does not
address. None of the staff were around at that time and only a few of us that are on the Committee
were present and involved during the creation of Carlsbad's Growth Management Ordinance.
Development in the 1980's
Most committee members do not realize that during the past 5-10 years Carlsbad has been going
through a period of relatively slow growth. At one of our previous meetings staff pointed out that
during the past five years only around 500 building permits were issued. During the 1980's the City was
approving tentative maps for 2600-2900 units a year. Builders were then rushing to final the tentative
maps and obtain building permits. The City was approving more units in one year than they have in the
past 10 years. Staff was concerned about the rate of growth and the lack of ability to get some of the
public facilities we believed were needed for the City. We were able to get frontage improvements for
roads adjacent to a project site, but it was difficult to get offsite improvements. Often developers of
large projects would say that the buildout of their project might take up to 10 years and the needed
public facilities would come towards the end of the project and up front.
Proposition E
Some of Carlsbad's citizens were also getting concerned about the rate of growth. In 1985 a citizen's
initiative created a ballot measure to limit the number of residential permits to 1000 the first year
{1987), 750 the second year and 500 for the following 8 years to slow the rate of growth. This was a
very simplistic, na·ive concept that did nothing to address the impacts of commercial or industrial
development or do anything to address the need for public facilities. All it would have done is create a
beauty contest for residential projects and increase the price of housing for a 10-year period. Most
people do not realize that the demand for residential units is created by non-residential development
which creates jobs. Other that retirees, people do not move to Carlsbad, buy a million-dollar house and
then look for a job.
City Response to Proposition E
Fortunately, the City Council and staff realized that this initiative would have a negative impact on the
City and do nothing to ensure the provision of the needed public facilities. They appointed a citizen's
committee to consider alternatives to counter this initiative while ensuring the provision of public
1
facilities concurrently with future development. Based on their input staff was directed to work with
consultants prepare a Growth Management Program addressing 11 public facilities: City Administrative
Facilities, Library, Wastewater Treatment Capacity, Parks, Circulation, Fire, Open Space, Schools, Sewer
Collection System, Water Distribution System and Drainage.
We did not have a pattern to follow and had to figure it out as we went along. At the same time, we
were working with developers pushing to get their projects to a hearing before the election. We had to
get the program prepared so it could get on the ballot as Measure G to counter the housing cap
initiative. We also did not have a blank slate to work with. Some of the public facilities were already in
place while others were in the planning phase or just shown as potentials on the General Plan. We also
had to determine the future buildout of residential units for the City to determine the size of some of
the facilit ies that were based on population such as libraries, parks and administrative facilities. This led
to the creation of Quadrant Caps (maximum number of residential units in each quadrant of the City.)
Existing Districts within the City
To complicate matters we had to deal with three sewer districts, three water districts and three school
districts. At one of our previous meetings there was some questions from members of the Committee
as to why there were different districts within the City limits of Carlsbad. These district boundaries were
formed before Carlsbad's existing boundaries were created when those areas were part of the County.
It would have been easier if those boundaries could have been eliminated and all the area covered by
those districts become part of a Carlsbad district. However, changing district boundaries is very difficult
and time-consuming requiring hearings before LAFCO, Local Agency Formation Committee. In addition,
districts, especially school districts are opposed to reducing their boundaries and would have opposed
any changes.
Quadrant Caps
As a part of the Growth Management Program staff had to determine the maximum buildout of the City.
This was done by counting the number of existing units, counting all the units in approved, but unbuilt
tentative maps, and calculating the number of potential units in the residential areas without any
approvals based on the control yield point of each General Plan residential designation. Figure 3 from
the Growth Management Program shows the number of units estimated for each quadrant of the City.
(Figure 3 also shows how few of our existing major roadways actually existed in 1986.) Added up this
came out to 54,599 dwelling units. Based on an average of 2.471 persons per household this resulted in
a buildout population of 134,914 residents (Figure 5). This is the number that the City has been working
with for the past few decades when determining the need for public facilities since this number was
included in the Prop G ballot measure approved by the citizens of Carlsbad.
Many of us involved with the planning process on a daily basis have known for years that the housing
crisis in California and changing laws were going to force the City to revise and update the Growth
Management Program. In 2019 the State passed SB 330 that prohibited cities from establishing a
housing cap. This message has been passed down to the City via letters from the State informing
Carlsbad that the requirements of SB 330 superseded the growth cap created by Carlsbad's Growth
Management Program. This is one of the main reasons that this committee has been formed.
Local Facility Management Zones
2
As a part of the City's Growth Management Program, I drew a map, which was later approved by the
City Council, that divided the City into 25 Zones each of which had to prepare a Local Facilities
Management Plan, LFMP. Each LFMP showed how development in each of the Zones would comply
with and implement the Citywide Growth Management Program, see attached map. Zones 1-6 were the
developed portions of Carlsbad at that time. Zones 7-12 were classified as developing because they had
some level of development or planning. Zones 13-25 were classified as undeveloped areas because at
that time there were no plans for development in those areas. Staff was directed to prepare the Local
Facilities Management Plans for Zones 1-6, the developed areas of the City in 1986. The other Local
Facilities Management Plans were prepared by property owners and submitted for City review as a part
of the develop plans for that particular part of the City. Many of these Local Facilities Management
Plans coincided with the boundaries of Master Plans, such as Calavera Hills, Rancho Carrillo, Bressi
Ranch, or Aviara.
The Future
It is now our responsibility to update it for the coming years with the understanding that we do not
have a completely blank slate to work with. Most of the City has already been developed and there is
relatively little raw land left to develop and other than the Sunny Creek area (Zone 15), Village/Barrio
and redevelopment of Plaza Camino Real most of the future development will be smaller infill sites. Any
new standards recommended by this committee can only apply to new development, which as
mentioned above is only going to occur in a few areas ofthe City.
This is the major difference between 1986 and the current time. When the Growth Management Plan
was created most of the City was undeveloped. We need to remember that it is not legally possible to
make new development make up for existing deficiencies. Per State Law, new projects can only be
required to mitigate for the impacts created by their own development. The Growth Management
Program does not address changes to land use or designate City Administrative sites or Park sites. This
was done by other documents such as the General Plan, Parks Master Plan or Citywide Drainage Plan.
The Growth Management Program and Local Facilities Management Plans showed how future
development would provide these facilities in accordance with other approved City documents.
Conclusion
This is a very simplified explanation of the history of Carlsbad's Growth Management Program and how
it has been implemented over the past 35 years. It is not a perfect document, but it has given Carlsbad
some of the best public facilities in North County. We did the best we could with the information we
had and the technology that was available at that time. The Program was innovative enough that it
received a number of awards from planning groups when it was created. Hopefully this explanation is
useful to some of you that were not around during the development of the Growth Management
Program.
Attachments:
Local Facility Management Zones
Dwelling Units by Quadrant
Projected Dwelling Unit and Population Buildout
3
SECTION Ill. REQUIREMENTS FOR LOCAL FACILITY
MANAGEMENT PLANS RELATIONSHIP
T O T H E C I T Y W I O E F A C I L I T rE S A N D
IMPROVEMENTS PLAN
As part of the overall Growth Management Program the City was
broken down into 2'5' Local Pacility Management zones (See
Pigure 1). The boundaries for each of the 25 Local Facility
Management Zones were established based upon logical facilities
and improvements planning, construction and service relationships
to ensure the economically efficient and timely installation of
required public facilities and improvements. After the adoption
of the Citywide Pacilities and Improvements Plan and prior to any
development occurring in any of these zones, a Local Facility
Management Plan must be submitted and approved. The plan must be
consistent with all aspects ~f the Citywide Facilities
Improvements Plan and shall implement the Citywide Pacilities and
Improvements Plan within the zone. It must ensure that each
public facility and improvement meets the adopted performance
standard prior to allowing any development.
LOCAL FACILITY
MANAGEMENT ZONES
-3-
FIGURE I
NORTHEAST
2.876.
FUTURE 6,188
TOTAL 9,042
NORTHWEST . '
EXISTING 9,526
Fl.JTURE 5,844
TOTAL 15,370
IIOIN■&TTIA LN •
SOUTHWEST
FUTURE 10,887
TOT AL 12,858
DWELLING UNITS BY QUADRANT .. .
-a-
FIGURE 3
DENSITY CONTROL
September e., 988
SOUTHEAST.
EXISTING 6,527
FUTURE
TOTAL
4
City of Carlsbad
Revised 1 /9/90
CITY OF CARLSBAD
FIGURE 5
SEPTEMBER 16, 1986
Projected Dwelling Unit and Population at Buildout
LAND USE NET
ACRES
I CONTROL D.U.s at POPULATION YIELD BUILDOUT at BUILDOUT
---
RL 1,364 1 1,364 3,371
-----
RLM 6,895 3.2 i2,065 54,~i2
RM 2,376 6 14,252 35,218
RMH 1,081 11.5 12,430 30,713
RH (& RVH) 233 19 4,488 11,090
NON-RES 6,680
18,629 54,599 134,914
ASSUMPTIONS 2.311s
1) PERSONS PER DWELLING UNIT 2~471 AS PER
THE STATE DEPT. OF FINANCE
-10-Amended 4/22/9i Q
liity of -arlsbad
1
July 25, 2022
To: Carlsbad Tomorrow Committee
From: Committee Member Steve Linke (Traffic & Mobility Commission)
Re: GMP circulation performance standards
SIGNIFICANCE
In Carlsbad’s recent annual resident satisfaction surveys, transportation issues consistently ranked in the
top two or three priorities/quality of life issues—along with police/fire and parks/open space. However,
the satisfaction rate was much lower for transportation.
About 50% of greenhouse gas generation comes from surface transportation. Thus, improving both
vehicle traffic flow and conditions to encourage non-single occupancy vehicle alternatives (walking,
biking, transit, ride-sharing, telecommuting, etc.) is critical for the environment.
SUMMARY
The current Growth Management Plan (GMP) performance standard for circulation facilities is a level of
service (LOS) grade “D” (on a scale of “A” through “F”). Prior to the 2015 General Plan update, this
standard was applied only to vehicle LOS. The update re-prioritized each street to specific modes of
travel—vehicle, pedestrian, bicycle, and/or transit—and LOS “D” is supposed to be maintained for each
prioritized mode on the corresponding street.
Unlike all of the other GMP facilities we have discussed, our streets have been consistently failing their
standard for many years. Four general approaches have been employed that camouflage the
deficiencies and help avoid identification of mandatory improvements by developers and the city:
1. The analysis methods adopted by the city to determine the LOS grades have been designed to
virtually never result in grades worse than “D,” and exceptions and changes to the analysis
rules are routinely made without public review.
2. The City Council now has the authority to simply exempt street facilities from the GMP
standard when they fail the performance standard (32 facilities and counting have been
exempted so far, representing a large portion of our arterial system).
3. The city has simply skipped or delayed monitoring of facilities and travel modes that would
fail.
4. Legal arguments have emerged claiming the city never intended to enforce the LOS “D”
standard through annual monitoring, and that the city may not be willing or able to create a
“nexus” to enforce it with developers either.
Going forward, the LOS “D” performance standard itself is fine, but, given the above four loophole areas,
it is rendered virtually meaningless. I have been working on these issues for the past 11 years—the last
three on the Traffic & Mobility Commission. My hope is that this committee will be provided reliable
professional guidance on how to navigate these problems, and then make a forceful recommendation to
close the loopholes to the maximum extent possible.
2
DISCUSSION
During its 2015 adoption process, the General Plan Mobility Element was promoted as the new “Bible”
(i.e., “authoritative text”) guiding how the GMP would be applied to circulation facilities going forward.
It was to be a transformative reimagining of our transportation network by requiring citywide
maintenance of the new performance standards and developer funding of projects.
It was supposed to ensure the completion of our arterial street network through widening of the last
several streets to their ultimate two or three-lane directional widths, completion of the Poinsettia Lane
and College Boulevard gap closures, and implementation of an advanced traffic signal control system.
And it was simultaneously supposed to foster an aggressive shift to non-single occupancy vehicle travel
modes through improvements to pedestrian, bicycle, and transit facilities/services and other so-called
Transportation Demand Management (TDM) strategies.
The reality has been underwhelming. I detailed some of the following in my April 26th and May 23rd
letters to this committee, but here are some highlights and additional examples.
VEHICLE LOS
GMP monitoring methods designed not to fail
Before the 2015 update, the city knowingly used vehicle LOS analysis methods for annual GMP
monitoring (the “Carlsbad methods”) that generated unrealistically good LOS grades, rather than using
the validated methods recommended by the original GMP citizen advisory committee.
After complaining about this for several years, an industry-validated vehicle LOS methodology was
finally required in 2015. Applying the new method to historical annual GMP monitoring traffic count
data shows that LOS “D” failures began occurring on Carlsbad streets going back to at least 2008.
Demonstrating the virtually worthless nature of the original Carlsbad methods, a majority of
streets/intersections degraded an average of two letter grades, and many went from “A” to “E” or “F.”
Exemptions and promises made
Knowing that many streets would fail the LOS “D” GMP performance standard when the new validated
LOS method was applied, the 2015 update introduced the power to “exempt” deficient street segments
from the GMP standard. Many promises were made to justify and quell concerns about exemptions.
For example, exemptions were projected to be very limited and were not going to be done until
completion of the gap closures, and, even then, the exempted segments were not to be forgotten: The
vehicle capacities of the streets were to be increased through widening to their final widths, intersection
improvements (e.g., turn-lane additions and lengthening), and traffic signal coordination; and an
aggressive Mobility Element-specific TDM program would be implemented, along with an update to the
Traffic Impact Fee (TIF) program for funding.
Promises broken
The reality has been very different. The monitoring was delayed for a few years, and then done in a
piecemeal fashion over the next several years to soften the blow of the numerous deficiencies and
exemptions that have accumulated, now representing a significant portion of our arterial system.
3
While the Poinsettia Lane gap closure is complete, the College Boulevard gap closure was just put on
indefinite hold, and it has been proposed to remove it entirely from the General Plan, despite the heavy
congestion and GMP exemptions of the adjacent arterials, which would be alleviated by its completion.
Further, with some exceptions, there has been significant resistance to studying or making the capacity-
increasing improvements. Exemptions are often proposed without capacity studies and/or
recommendations against making such improvements. Intersection analysis has even been removed
from Carlsbad’s Transportation Impact Analysis Guidelines, despite the 2015 testimony that most
congestion arises there and the promises to make improvements.
Perhaps most disturbingly, it has been seven years, but no Mobility Element-specific TDM program or
TIF program update has yet been implemented to shift travelers to different modes—let alone programs
that could have meaningful impacts on congestion.
MULTIMODAL (PEDESTRIAN, BICYCLE, AND TRANSIT) LEVEL OF SERVICE (MMLOS)
Skipped monitoring
There have been six annual GMP monitoring reports since the requirement to assess MMLOS was
adopted in the 2015 update. However, not one of the reports has included MMLOS monitoring—just
repetitive excuses and broken promises about including them before the next report comes out. I
relayed the Traffic & Mobility Commission’s concerns on this subject to the City Council a couple of
weeks ago.
Exceptions and methodological changes without public review
Unlike vehicle LOS, which is based on traffic volumes and street capacities, MMLOS analyses are based
on amenities/quality (e.g., widths of sidewalks, types of bike lanes, presence of benches/shelters at bus
stops, etc.). Carlsbad is trying to use point systems that assign MMLOS letter grades based on a 100-
point scale, with a score of “60” being required to achieve LOS “D.”
There have been multiple iterations of the point systems since 2015, and I would argue that we are
falling into the same trap as the pre-2015 vehicle LOS methods—concocting “Carlsbad methods” that
are designed not to fail, making them meaningless in the quest to drive infrastructure improvements.
One example of the implications of the changing MMLOS methods on the final LOS grades is the
Poinsettia gap closure. In one traffic study, the pedestrian LOS was calculated as “F,” and the bicycle LOS
was “D.” However, in a subsequent traffic study—done by the same consultant using exactly the same
input data—both the pedestrian and bicycle LOS results were “A” or “B.” The only difference between
the two studies was that staff had changed the point values for the amenities.
Another example is that, in 2019, staff began assigning 60 transit LOS points (just enough to achieve LOS
“D”) based on the City Council’s adoption of a Climate Action Plan TDM Program. That effectively
provided a blanket, citywide passing grade for transit, even though that program provides zero
improvements to the transit system. This ridiculous move appears to have been at least partially
rescinded but is indicative of the mindset that has been driving MMLOS method development.
Yet another example is a car dealership project being developed near a transit-prioritized street. The
applicant made the inexplicable argument that it was exempt from having to conduct a transit LOS
analysis, because there are no current transit stops within the prescribed distance from their project
(one-half mile). However, the very lack of stops means the developer needs to make improvements to
4
transit or implement alternatives to bring the LOS to “D”—not be exempt because service is currently
abysmal. Yet, staff and the Planning Commission allowed the project to go forward without the required
MMLOS analysis or improvements.
Adopted standards vs. methods
The approach for Vehicle Miles Traveled (VMT) analysis under CEQA has been similar. Similar to the LOS
“D” standard officially adopted by council for the GMP, certain “thresholds” have been officially adopted
for VMT. For both GMP/MMLOS and CEQA/VMT, staff has given themselves broad discretion to change
the methods and allow case-by-case exceptions to the methods without public review or council
adoption. Then, it can be argued at the final decision-making meetings before the Planning Commission
or City Council that the adopted MMLOLS standard or VMT threshold is being met, and that any changes
or exceptions to the methods used for the calculations and conclusions were at staff’s discretion.
Again, I cannot overemphasize how the performance standard itself (LOS grade of “D”) becomes
meaningless when broad discretion is provided to manipulate the methods (e.g., the number of MMLOS
points assigned for each amenity) used to calculate the grades.
Legal arguments minimizing potential impact of MMLOS
City GMP monitoring
The 2015 updates to the General Plan and the GMP implementing document state the following:
Implement the city’s MMLOS methodology and maintain LOS D or better for each mode of
travel for which the MMLOS standard is applicable...
The proposed General Plan requires a LOS D or better…for the prioritized travel mode.
However, in the last couple of years as I have been raising this issue, staff has adopted the legal stance
that the city never really intended to maintain the MMLOS D standard for any parts of the city that were
already developed in 2015. But that is not how the language reads or how the MMLOS system was
presented. Because the city is largely built-out, this stance would make MMLOS largely irrelevant, even
if reasonable point systems could be adopted.
Developer nexus
The MMLOS system was presented by staff in 2015 as a means to create the required nexus to condition
developments to fund projects for the prioritized modes. Recently, though, staff also has started
suggesting that it may not be plausible to use MMLOS to assess the impacts of individual developments,
because any identified deficiencies could be considered “pre-existing,” and a nexus cannot be
established.
Despite promises in 2015 that the system would bring crosswalks, curb extensions, improved bike lanes,
transit benches and shelters, pedestrian-scale lighting, etc., my analysis of dozens of development
applications over the past three years indicates the following. Through the GMP, the city is only willing
to require sidewalk completion on the same block as the development, and, in some cases, a bench
being added next to an otherwise standalone, pre-existing bus stop sign within one-half mile—even if
buses rarely stop there.
WE CAN DO BETTER THAN THIS!
RESPONSE TO DISTRICT 2 COMMITTEE MEMBER MARY RYAN’S NOTE ON GROWTH MANAGEMENT
PERFORMANCE STANDARDS
HERE IS MY RESPONSE TO MS. RYAN’S NOTE
1. City Administrative Facilities. Current standard based on population ratio to floor area is useless.
Need depends on the scope of city services provided. As Carlsbad has a water department and I
presume staff to operate this service, office space would need to be provided. Cities can also choose to
contract out certain services, such as landscape and park maintenance to the private sector as it does
waste disposal, this requiring little or no administrative facilities. In addition, having space, such as the
Dove Library auditorium allows for such spaces to serve multiple functions, such as doubling as meeting
chamber space for the city council and various commissions. To me, this standard is useless in its
current form.
2. Schools. How much larger will the city grow, population wise, once all developable residential land is
built out using the newest mandates from the State?? Does the type of dwelling impact the expected
population per dwelling unit? Condos and apartments usually have fewer bedrooms and thus fewer
persons per dwelling unit. How do we factor in senior living facilities, of which Carlsbad has quite a few?
As for the ebb and flow of school age children over the years, my experience in five different cities from
the 1960’s to the present demonstrates that generational turnover is a real thing, especially among
single family residences. School age populations in established neighborhoods will ebb and flow about
every fifteen to twenty years. The current standard should remain in place, as it is the only practical
method to tie school capacity with residential development. However, city may need to factor in
potential impact of new law on auxiliary unit legislation’s expansion.
3. Drainage. NO CHANGE PROPOSED.
4. Wastewater Treatment. NO CHANGE PROPOSED.
5. Sewer Collection System. NO CHANGE PROPOSED.
6. Water Distribution System. Consider storage capacity expansion to 14 days based on water
conservation needs throughout the State, including Carlsbad.
7. Circulation. TDM Handbook has requirement for annual monitoring reports for certain residential
developments. This seems to be impractical unless the city is requiring all such developments to 1. Have
Private streets, 2. a functioning HOA, and 3. Having the requirement written into the development’s
CCR’s with the city as a reporting organization similar to doing an annual financial audit. What are
components of the “Local Mobility Analysis”? What are the assumptions behind the 11 peak hour trips
or 110 daily trips given the perhaps permanent impacts on offices being used less frequently on a per
employee basis as a side effect of the COVID pandemic? What standards are in the General Plan
Mobility Element and should they be revisited on the same basis as above? Tax Funding (Transnet).
How much of the ½ cent sales tax does Carlsbad get? Is it based on getting ½ a cent on all sales taxes
paid in Carlsbad, or is it on a per capita basis?? How would this figure in with jobs in businesses which
are not retail establishments, such as offices and corporations, hotels, Legoland, etc.? Same thing with
the gas tax. How much does Carlsbad get and how is its share determined?? How does this tie to future
development, both residential and commercial?? What is the SANDAG regional travel demand model?
How is it calculated? What other models currently exit? How do they differ?
8. Library. Has this been realized with the presence of the three libraries in Carlsbad?? Personal
experience in visiting the libraries frequently is they are not overcrowded. In addition, the creation of
eBooks, such as Kindle has reduced need to visit the library to check out books.
9. Fire. This standard begs the question of why leaving 1,500 d.u.s per fire station outside the 5-minute
response time window is an acceptable standard. If my math is right, this means that almost 10% of all
d.u.s will be outside the 5-minute limit. Since three of the station service areas are aggregated, it seems
to me that at least one more fire station, somewhere near the former power plant property needs to be
constructed, if the map shows things correctly, and a second station needs to be constructed in the
station 5 and 6 area where some 1,500+ plus units are outside the 5-minute response time window.
10. Open Space. In my part of the city (the southwest quadrant) this Performance Standard has not
come even close to being met. City brags about the “fact” that 40% of the city is “open space”. But in
that amount as all of the lagoons which can never be anything but, unless their outlets are dammed and
the lagoons are drained. Also, involving the general fund requirement as a part of the funding seems to
suggest that all open space acquisition would be exempted from the Measure C $1million general fund
voter requirement. Is this the case? Also, in my view, a significate percentage of what is being counted
as “parks” to meet the 3.0 acres per 1,000 population requirement is actually an open space area
adjacent to a park. Poinsettia Park is but one example.
11. Parks. 3.0 acres per 1,000 has not been met by the city. Again, especially in my quadrant of the
city. Standard needs to be increased to 5.0 acres per 1,000 as Oceanside and Encinitas have done. If we
want to be the best city in north county, that is the least we can do. Also, the City’s emphasis on
“community” size parks makes the goal set by The National Recreation and Parks Association, The Trust
for Public Land and the Urban Land Institute of having a park within a 10-minute walk of every person in
the city impossible to meet. Further, the emphasis on these larger parks means that much more of the
acreage of the park is taken up with parking lots. Having to drive to the nearest park is about as anti-
environmental as one can get and also is counter to trying to achieve the Growth Management
Circulation Performance Standard. That conflict needs to be removed by adopting the 5-acre 10-minute
walk as the standard.
HARRY PEACOCK
DISTRICT 4 COMMITTEE MEMBER
JULY 25, 2022