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2022-09-22; Growth Management Citizens Committee; ; Committee Business
CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 1 SEPT. 22, 2022 OPEN SPACE STANDARD Fifteen percent of the total land area in the zone [Local Facility Management Zone] exclusive of environmentally constrained non-developable land must be set aside for permanent open space and must be available concurrent with development. PURPOSE OF THIS REPORT This report is informational only and is intended to help guide the Carlsbad Tomorrow – Growth Management Citizens Committee’s discussion on the Growth Management open space standard, as well as open space in Carlsbad more generally. APPLICABILITY OF THE OPEN SPACE STANDARD Open space to meet the standard is provided concurrent with approval of development projects within the Local Facility Management Zones where the standard applies, which is Local Facilities Management Zones 11 – 15 and 17 – 25. The standard does not apply in Zones 1 – 10 and 16. A map of the facility zones is provided in Attachment 1 – Local Facilities Management Zones Map. BACKGROUND The history of the open space standard is helpful in understanding its applicability today. Below is a summary of the standard’s history. It should be noted that the open space provided to meet the open space standard does not represent all of the open space in Carlsbad (see section titled Open Space Categories for more information). •Report of the Citizens Committee for the Review of the Land Use Element (July 1985) The committee delivered its report in July 1985 and its recommendations were used as the basis for developing the growth management facility standards. On the topic of open space, the committee did not recommend a growth management standard for open space; instead: o The committee determined that the amount of open space designated in the Land Use Element was an adequate amount (a minority of the committee thought there wasn’t enough open space). Information provided to the 1985 committee indicated that approximately 25 percent of the city’s total land area at that time was designated open space. Note: today, 38 percent of the city’s total land area is designated as open space (Attachment 2 – Open Space Map). o The committee recommended the General Plan Land Use Element define four categories of open space for: 1. preservation of natural resources; 2. managed production of resources; 3. outdoor recreation; and 4. public health and safety. Note: today’s General Plan Open Space and Conservation Element defines four categories of open space for: 1. Preservation of natural resources; 2. Managed production of resources; 3. Outdoor recreation; and 4. Aesthetic, cultural and educational purposes. ---- CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 1 SEPT. 22, 2022 2 The committee recommended: ▪ All four categories of open space be addressed in future master plans. ▪ Future development be prohibited from designated open space areas ▪ The city ensure public access and maintenance of accesses to lagoons and beaches ▪ The city encourage maximum parking accommodations to enhance use of the beach Note: the city implemented these recommendations through various policies and regulations. • Public Facility Standards (July 1986) and Citywide Facilities and Improvements Plan (Sept. 1986) In July 1986, the City Council adopted the Growth Management Ordinance (Carlsbad Municipal Code Title 21, Chapter 21.90) and the public facility standards for the Growth Management Program. In September 1986 the standards were incorporated in the Citywide Facilities and Improvements Plan. The adopted open space standard was “Fifteen percent of the total land area in the zone exclusive of environmentally constrained non-developable land must be set aside for permanent open space and must be available concurrent with development.” The Citywide Facilities and Improvements Plan specified that the open space standard applies in some Local Facility Management Zones (Zones 11 – 15 and 17 – 25), but not others (Zones 1 – 10 and 16) because those zones were determined to have already been developed or to have already met the standard (Attachment 1 – Local Facilities Management Zones Map). This methodology is consistent with traditional land use methodology which applies new standards prospectively. (See 2020/2021 Growth Management Program Monitoring Report p. 27; Friends of H Street v. City of Sacramento (1993) 20 Cal.App.4th 152, 169 [California's planning statutes "address future growth, and do not require local governments to bring existing neighborhoods and streets into compliance with the general plan."].) The following are some key facts during the development of the open space standard. o Following the 1985 committee report, as part of the development of the Growth Management Program, the city identified areas that were, at the time, “urbanized” (developed areas) “urbanizing” (some development or some level of planning completed, such as an existing master plan) and “future urbanizing” (very little to no development and no existing master plan). See Attachment 3 – 1986 Development Status Map and Information. ▪ A comparison of the Local Facilities Management Zones map (Attachment 1) and the 1986 Development Status Map (Attachment 3) shows that the zones where the open space standard is applicable (Zones 11 – 15 and 17 – 25) align, for the most part, with the areas identified in 1986 as “future urbanizing,” which is where future master plans would be required (e.g., Aviara, Bressi Ranch and Quarry Creek master plans) and is consistent with the 1985 committee recommendation for master plans to provide additional future open space. ▪ The “urbanized” areas were already developed, and the “urbanizing” areas had previously approved development or master plans. Although the open space standard was not applied to the “urbanizing” areas, the existing approved master plans within these areas provided open space as required by city regulations in place at the time. Prior to the Growth Management Program and the open space standard, the city’s CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 1 SEPT. 22, 2022 3 zoning ordinance required 15 percent of the total area of any master plan to be designated as open space. This 15 percent standard differs from the Growth Management open space standard because it applies to the total land area of a master plan and does not exclude environmentally constrained non-developable land. Following the adoption of the Growth Management Program, the city continued efforts to prioritize the protection of open space in Carlsbad. A summary of those efforts is provided in Attachment 4 – Summary of Carlsbad’s Open Space Preservation History. FACILITY PERFORMANCE ANALYSIS As stated above, open space to meet the standard is provided concurrent with the approval of development projects within the Local Facility Management Zones where the standard applies. As development projects are processed through the city’s review process, they are evaluated to verify that all regulations and standards are satisfied, including the growth management open space standard, if applicable. The decision-making body (Planning Commission or City Council) makes a finding that all requirements are met. To date, approved development projects and dedication of open space has been found to satisfy the open space standard in Local Facility Management Zones 11-15, 17-21, and 23-25. In Local Facility Management Zone 22, the approved development to date has not yet met the open space standard; however, as future development occurs in this zone, additional open space will be required. FUNDING AND OBTAINING OPEN SPACE Open space provided to meet the Growth Management open space standard is provided concurrent with new development, and is typically private open space (e.g., recreation areas and landscape buffers) within a development that is paid for and maintained by the developer and community (HOA). In general, cities can obtain open space through dedications or fees from developers for public facilities and can require a certain amount of land in a development be left in open space. When requiring open space on privately owned land, the city must ensure the owner is not denied a reasonable use of their land and that the owner is not denied the right to develop their property, unless the owner is willing to sell their land and is compensated. In addition to developer dedication of open space to meet the Growth Management open space standard, there are other methods the city can use to acquire open space, including: Acquisition in Fee The city purchases property at fair market value. Fund sources could include: • The General Fund ($1 million spend limit without vote) • Voter approved bond measure or special tax. An example of voter approved funding in Carlsbad is Proposition C, which was passed by the voters in 2001 and authorized the City Council to spend up to $35 million on four projects of community interest, one of which was open space and trail linkages. See Attachment X, which includes a description of Proposition C and related open space acquisition. • Require developers to pay into a fund that could be used for future purchase of open space. CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 1 SEPT. 22, 2022 4 • As discussed below, to comport with the original intent that open space can be achieved “without having to buy it,” the expenditure of open space funds would be limited by the amount received from private development projects. Negotiated Open Space The city requires open space as part of approval of a development project, such as: • Require dedication of park land or payment of a fee in-lieu of dedication. The city currently collects park fees in-lieu of dedication. • Allow a property owner to transfer the permitted density for the whole site to a smaller portion of the site in exchange for retaining the other portion in open space. The city currently allows this. • Require a percentage of development projects to be open space. In Local Facility Management Zones where the Growth Management open space standard is applicable, the city already requires 15 percent of development projects, excluding constrained lands, to be open space. • Require a development project to dedicate nondevelopable areas (e.g., steep slopes, wetlands, floodways, sensitive habitat) as open space (note: this is not Growth Management open space). While the city has identified most nondevelopable areas and has dedicated them as open space, new development projects throughout the city are evaluated to determine if any land area should be retained in open space due to environmental constraints. In 1988, the city formed a citizens committee to review the city’s open space programs; the committee’s report was completed in July 1989). As part of the committee’s work, city staff provided information on the open space standard and stated: “that the amount of open space now required under the Growth Management Plan can be achieved without having to buy it, but also that the city has pushed to the limit what can be achieved without a monetary acquisition program.” This remains true today. Examples of How the City Provides and Protects Open Space Overall The examples below (not a complete list) show that the Growth Management open space standard is not the only method the city uses to provide and protect open space. • General Plan – designates all dedicated open space areas as “open space” on the Land Use and Open Space Maps and includes policies that protect these areas from development. • Habitat Management Plan – guides the design, management, monitoring, and public use of the city’s natural open space preserve system. • Growth Management Open Space standard – in Local Facility Management Zones where the standard applies (Zones 11-15 and 17-25). • Growth Management Parks standard – parks are also considered open space. • Trails Master Plan – identifies where trails will be constructed; trails are open space. • Zoning Ordinance o Open Space Zone applied to all areas designated by the General Plan as “open space” and specifies regulations that protect these areas from development. ---- CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 1 SEPT. 22, 2022 5 o Chapter 21.210 Habitat Preservation and Management Requirements – assures compliance with the Habitat Management Plan. o Chapter 21.38 Planned Community Zone – requires 15 percent of the total area of a master plan to be open space (primarily aligns with the areas subject to the Growth Management open space standard). o Chapter 21.209 – Cannon Road Agricultural/Open Space Zone – supports continued agriculture and identifies authorized open space uses on agriculture areas south of Cannon Road and east of Paseo Del Norte. o Various other development standards that require open space, recreation areas and landscaped buffers/setbacks within development projects. OPEN SPACE CATEGORIES Open space is one of Carlsbad’s defining features and serves several different purposes. Open space to meet the growth management standard is just a part of all the open space in Carlsbad. Many open space areas are conserved as natural habitat. Other open space areas fulfill both habitat conservation and recreational needs or are specifically designated for recreational use. Land within the Carlsbad covers about 39 square miles (25,021 acres), 38 percent of which is designated as open space. About 78 percent of this open space is comprised of natural open space such as native habitats, lagoons, and streams. The city’s open space network boasts three lagoons, over 67 miles of trails, and almost seven miles of coastline. Attachment 2 – Open Space Map is a map of all dedicated open space in Carlsbad, of which some is open space dedicated to meet the open space standard in Local Facility Management Zones 11 – 15 and 17 – 25. Open space overall has been designated throughout Carlsbad in the following four categories: Table 1: Categories of Open Space # Category Description Percentage of Total Open Space 1 Protection of natural resources Plant and animal habitat, nature preserves, beaches and bluffs, wetland and riparian areas, canyons and hillsides, and water features such as lagoons and streams. Note: the Carlsbad Habitat Management Plan (2004) is the city’s primary guide on the natural habitat areas of the city that should be protected and dedicated as open space. 78% 2 Managed production of resources Agriculture areas north and south of Cannon Road, aquaculture (Hubbs SeaWorld Research Institute), water management (Maerkle Reservoir), and could include commercial fisheries, and mineral resources. 3.5% 3 Outdoor recreation Public parks and recreation areas, school playfields, golf courses, and private recreation areas in development projects. 12.5% 4 Aesthetic, cultural and educational purposes In Carlsbad this type of open space primarily consists of land use buffers and ornamental landscaping around and within development projects; other examples could include greenbelts providing separation from surrounding communities, arboreta, and botanical gardens. 6% CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 1 SEPT. 22, 2022 6 QUESTIONS ABOUT THE OPEN SPACE STANDARD There have been a number of questions about the existing standards and history of them. This section summarizes the some of those questions and the information available. Applicability of the standard Questions have been raised on why the open space standard does not apply to Local Facilities Management Zones 1 – 10 and 16. That was a determination made by the City Council when they adopted the Citywide Facilities and Improvements Plan and the open space standard in 1986. Furthermore, the 1985 committee determined that open space was adequate and that future master plans should provide more open space, which would occur in the areas identified as “future urbanizing areas” (Attachment 3 – 1986 Development Status Map and Information). Zones 1 – 10 and 16 were in areas where no new master plans were anticipated (“urbanized” areas) or in areas where there was approved development or master plans (“urbanizing” areas). The approved master plans within the “urbanizing” areas did provide open space to meet the standard applicable to them (Zoning Ordinance requirement for master plans to provide 15 percent of the master plan area as open space). Is there a 40 percent open space requirement? There have also been some misconceptions that there is a standard that requires 40 percent open space. There is no requirement or standard that requires 40 percent open space per individual projects or on a citywide basis. As explained in the 2015 General Plan Environmental Impact Report Master Response MR1-2, neither Proposition E nor the Citywide Facilities and Improvements Plan (CFIP) performance standards required 40 percent open space. Proposition E states “emphasis shall be given to ensuring good traffic circulation, schools, parks, libraries, open space, and recreational amenities.” The CFIP open space standard states “Fifteen percent of the total land area in the zone, exclusive of environmentally constrained non- developable land…concurrent with development.” The CFIP also states that LMFZ Zones 1-10 and 16 “are already developed or meet or exceed the requirement” and are not required to comply with the open space standard. Generic references to 40 percent open space, are a shorthand estimate derived by adding the 25 percent estimated constrained lands to the 15 percent CFIP open space standard. However, this shorthand estimate does not take into account that the CFIP exemption; i.e. 15 percent open space standard applied to only 14 of the 25 Local Facility Management Zones, rather than the entire city. A July 8, 1986, City Council staff report on the facility standards states: “compliance with this [open space] standard should result in approximately 35 to 40% of the total land area in the city being open space when the city is fully built out.” A couple years later, a June 27, 1988, staff report to an open space committee, stated that “staff has estimated that approximately 10,000 acres or 38.5% of the total land area in the city is projected to be set aside for open space uses. The reference to 40 percent open space was an estimate, not a standard or goal. Today, 38 percent of Carlsbad is dedicated as open space; it seems the estimate was fairly accurate. CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 1 SEPT. 22, 2022 7 Open Space in Local Facilities Management Zone 9 As noted previously, the open space standard does not apply to Local Facilities Management Zone 9 (Attachment 1 – Local Facilities Management Zones Map), which includes part of the Ponto area and the majority of the zone is subject to the Poinsettia Shores Master Plan. This is an area where the city has received community comments stating that the zone does not meet the open space standard and more open space is needed. In 1986 the City Council determined that the open space needs for Zone 9 had been met and therefore the open space standard does not apply to Zone 9. Zone 9 was an “urbanizing” area when the Growth Management Program was being developed. A master plan was approved for the area (Batiquitos Lagoon Educational Park Master Plan). The master plan met the open space standard required at the time (Zoning Ordinance), which is 15 percent of the total area of the master plan. The following is a summary of actions related to Zone 9 that relate to the open space planned in that area: • Oct. 1, 1985 – Batiquitos Lagoon Educational Park Master Plan approved by City Council and, as required by the zoning ordinance at the time, was required to provide a minimum 15 percent of the total master plan area as open space. • May 6, 1986 – City Council staff report on development of the Growth Management Program: o City council directed staff, working in conjunction with the developer of Zone 9, to finalize a pilot local facility management program to serve as a format model for programs for the other zones. The Batiquitos Lagoon Educational Park Master Plan for Zone 9 had been approved the year before and it was a recent development plan to use as a model. • June 24, 1986 – Growth Management Ordinance approved (Zoning Ordinance Chapter 21.90): o Section 21.90.030(g) allowed development of phase I of the Batiquitos Lagoon Educational Park Master Plan to proceed prior to approval of a Local Facility Management Plan for Zone 9, subject to certain conditions including that the developer agree to participate in the restoration of a significant lagoon and wetland resource area and make any dedications of property necessary to accomplish the restoration. The master plan developer did make the open space land dedications that were needed for the restoration of Batiquitos Lagoon. • Sept. 16, 1986 – City Council approves the Citywide Facilities and Improvements Plan, including the open space standard with the clarification that the standard is not applicable in Zones 1-10 and 16. • July 11, 1989 – City Council approves the Local Facilities Management Plan for Zone 9. Other than noting the existing open space within the zone, open space was not further analyzed in the plan, as the open space standard does not apply to Zone 9. • Jan. 18, 1994 – City Council adopts an ordinance approving Poinsettia Shores Master Plan, which replaced the Batiquitos Lagoon Educational Park Master Plan. The related Planning Commission staff report (Oct. 20, 1993) evaluates open space in the master plan as follows: “The Poinsettia Shores Master Plan will not adjust or modify any existing General Plan designated open space areas or boundaries. Of the project's 162.8 total acres, approximately 34.8 acres are natural lagoon/wetland habitat which have Open Space General Plan designations (planning areas "I", "K", and "L") and have already been dedicated in fee title to the State of California, State Lands CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 1 SEPT. 22, 2022 8 Commissions in accordance with previous BLEP [Batiquitos Lagoon Educational Park] approvals. The master plan has additional open space totaling approximately 11 acres comprised of a community recreation center (planning area "M") and open space areas consisting of blufftop and roadway setbacks. The total master plan open space (approximately 46 acres) represents 28% of the entire master plan area. This exceeds the [Zoning Ordinance] requirement of at least 15% of the master plan area (24.4 acres) to be set aside as open space. As outlined in the Citywide Facilities Improvement Plan and the Zone 9 LFMP, this master plan has complied with all open space requirements. The project is also consistent with the Open Space and Conservation Resource Management Plan and incorporates master plan trails and links with the Citywide Trails System as required. The master plan's frontage on the east side of Carlsbad Boulevard (planning areas "G" and "H") is the location for linkage with the Citywide Trails System. These planning areas will be required to provide for the trail link within the required 40-foot structural setback from Carlsbad Boulevard. … On August 26, 1993, the master plan's open space program was reviewed by the City's Open Space Advisory Committee and unanimously supported…” While the open space standard is not applicable to Zone 9, open space has been provided for the area, including private recreation areas, trail linkages and a significant natural open space dedication that helped in the restoration of Batiquitos Lagoon, which is a significant natural resource to the community. Options for Future Open Space As described in this report, the Growth Management open space standard is only a part of the open space system in Carlsbad. The applicability of the standard was focused on “undeveloped” areas (in 1986) where large development projects and master planned communities would be built. Most of these previously “undeveloped” areas are now developed or have approved development plans. The existing open space standard has limited applicability in the future. As the city matures, the city must consider how to continue to protect and provide open space when facing the challenges in securing vacant land available for open space; including the limitations set by new state housing laws that limit the city’s ability to reduce residential densities or change residential land to a different use. Because of the challenges in securing vacant available land for more open space than is currently planned, options for a different open space standard are limited and involve additional cost to the city. As stated above under “funding and obtaining open space,” during the city’s evaluation of its open space programs in 1988, city staff provided a report that concluded “the amount of open space now required under the Growth Management Plan can be achieved without having to buy it, but also that the city has pushed to the limit what can be achieved without a monetary acquisition program.” As a result of Proposition C (see Attachment 4 – Summary of Carlsbad’s Open Space Preservation History), the city does have an acquisition program in place. However, the city has faced challenges in acquiring lands for open space, as recommended by the Proposition C open space committee. The city actively looks for properties that could be purchased with this funding; however, a primary challenge is finding a landowner willing to sell their property at a fair market value, which is a requirement for the city. CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 1 SEPT. 22, 2022 9 Attachments Attachment 1 – Local Facilities Management Zones Map Attachment 2 – Open Space Map Attachment 3 – 1986 Development Status Map and Information Attachment 4 – Summary of Carlsbad’s Open Space Preservation History OCEANSIDE SAN MARC O S ENCINITAS }}78 MCCLELLAN-PALOMARAIRPORT Agua Hedionda Lagoon Buena VistaLagoon CalaveraLake MaerkleReservoir P a c i f i c O c e a n PacificOcean !"^ ?¸ Batiquitos Lagoon 6 25 1 2 7 14 15 5 16 17 1810 1112 8 24 133 2022 9 19 4 21 23 PALOMARAIRPORT RD CANNONRD P OI NSETTIALNPOINSETTIA LN LACOSTAAV C A R L S B AD B L ELCAMINOREAL C A MIN O V IDARO BLE R A N CHO S A N T A FERD TAMARACK AV AVIARA P Y M E L R O SE DR MARRONRD ALGA RD AVEN I D A E NCINAS PASE O D E L NORTE C A R L S B A D V I L L A G E D R OLIVENHAINRD C O LLEG E B L CARLSBAD BL Local FacilityManagement Zones Highway Major Street Planned Street Railroad Lagoon J:\cbgis\products\planning\StandardMap\LFMZ_11x17.mxd 0 3,000Feet[ ---======== C Cityof Carlsbad OCEANSIDE SAN MARCO S }}78 MCCLELLAN-PALOMARAIRPORT Agua Hedionda Lagoon Buena VistaLagoon CalaveraLake MaerkleReservoir P a c i f i c O c e a n PacificOcean §¨¦5 ·|}þ78 Batiquitos Lagoon PALOMARAIRPORTRD CANNONRD POINSETTIALN LACOSTAAV C ARL S BA D B L BATIQUITOS DR ELCAMINOREAL CAMIN O V IDAROBL E C A DENCIAST CHESTN U T A V RANCHO SANTAFE R D HILLSID E D R TAMARACK AV AV I A R A P Y CA LLEACERVO ALGA RD MEL R O S E D R ELFUERTEST ALICANTERD M ARRONRD CA MIN O JUNIPERO FA R A D AYAV CALLEBARCELONA A V E N ID A ENCINAS PASEO D E L N O RTE C A R L S B A D VIL L A G E D R OLIVENHAINRD C O LLEG E B L Future Open Spa ce a n d V isitor Services* Open Space Categories: 1 - Preserva tion of N a tura l Resources 2 - Ma n a ged Production of Resources 3 - Outdoor Recrea tion (Progra m m ed\Un progra m m ed) 4 - Aesthetic Cultura l a n d Educa tion a l Purposes La goon s City Lim its Highwa y Ma jor Street Pla n n ed Street Ra ilroa d [0 3,000 Feet PLEASE N OTE: Open spa ce a rea s on this m a p a re derived from the Sa n Diego Coun ty a ssessor pa rcelm a p from Sa n GIS.org, which is the b est m a ppin g b a se curren tly a va ila b le for a city-wide perspective.However, the pa rcel lin es a n d the open spa ce a rea s within them m ust b e con sidered a s a pproxim a tion son ly, a n d a re n ot to b e used to esta b lish defin itive lin es of own ership or la n d sta tus. THIS MAP/DATA IS PROV IDED W ITHOUT W ARRAN TY OF AN Y KIN D, EITHER EX PRESS ORIMPLIED, IN CLUDIN G BUT N OT LIMITED TO, THE IMPLIED W ARRAN TIES OF MERCHAN TABILITYAN D FITN ESS FOR A PARTICULAR PURPOSE. GIS pa rcel da ta is derived from Sa n GIS/SAN DAG down loa da b le da ta - www.sa n gis.org.Copyright Sa n GIS 2019.\\sha res\GIS_ App\cb gis\products\pla n n in g\Sta n da rdMa p\Open Spa ce11x17.m xd Open Space MapUpdated February 2021 Future open spa ce a rea is n ot coun ted in the open spa ce a crea geta b le on this m a p. For m ore in form a tion , see Gen era l Pla n La n d Usea n d Com m un ity Design Elem en t, ‘Specia l Pla n n in g Con sidera tion s:Ca rlsb a d Bouleva rd/Agua Hedion da Cen ter.’ * Acreage % of OS % of City* 7387.9 77.7% 29.5% 328.8 3.5% 1.3% 1185.8 12.5% 4.7% 602.1 6.3% 2.4%Total 9504.6 38.0% ~ ----g r-------, : i L_ _____ _ = {'city of Carlsbad .. --Developmental Status Map ■cATE_GORY I: URBANIZED §CATEGORY II: URBANIZING � CATEGORY Ill: FUTURE URBANIZING DEVELOPMENTAL STATUS CATEGORIES City divided into three categories based upon their overall developmental status, level of urbanization and existing level of adequacy of public facilities and services. The three categories and the criteria used as a guide for each one is as follows: I.Urbanized II. 1.Older developed areas of City. 2.Primarily developed or immediately contiguous or surrounded by developed areas. 3.Additional development considered infill. 4.Public facilities basically adequate for level of anticipated, additional development. 5.Infill requirements in terms of completing public facilities or infrastructure. Urbanizing 1.Some development in area. 2.Newer developing area of City. 3.Some level of planning already completed (i.e,existing master plan). 4.Adjacent to or considered a logical extention of a Category I (Urbanized) area. III.Future Urbanizing 1.Very little or no development. 2.Isolated from existing services and facilities. 3.Isolated from existing development (i.e, not immediately adjacent to or surrounded by a Category I or II area (Urbanized or Orbanizin�). 4.No existing master plan or existing master plan outdated. (; . The significance of the categories is as follows: A)Required degree of detail and level offor preparation of a Developmental andManagement Program (see Attachment 5).and planning will be required in ordermanagement program for the category inproperty is located. the sophistication Community Facilities Additional detail to prepare a which an area or Specific Public Phasing -Timing Funding Source/ Facility/Service of Public Facility Mechanism For Requirements /Service Require-Requirement (WHAT) ment (WHEN) (HOW} Category II X Cateciorv II X X Category III X X X B) X -Detailed Planning Needed City staff to prepare proposed Category I (Urbanized) areas. reviewing management programs proposed to be as follows: management program for Priority for preparing and for other categories is 1st Priority -Category II (Urbanizing) 2nd Priority -Category III (Future Urbanizing) C)Priority for determining City involvement and level ofparticipation in providing facilities or correctinginadequacies (i.e, capital facilities programming,assessment district formation, bond financing) is proposedto be as follows: 1st Priority -Category I (Urbanized) 2nd Priority -Category II (Urbanizing) 3rd Priority -Category III (Future Urbanizing) (B)and (C) above will tend to favor and encourage infilldevelopment. -- Developmental and Community Facllltles Management ·zones ZONES 1-8 URBANIZED ZONES 7-12 URBANIZING ZONES 13-25 FUTURE URBANIZING 15 18 ROAD 1 7 1 8 DE V E L O P M E N T A L �N D CO MM U N I T Y FA C I L I T I E S MA N A G E M E N T ZO N E BO UN D A R I E S Fo r de v e l o p m e n t a l an d co m m u n i t y fa c i l i t i e s ma n a g e m e n t an d pl a n n i n g p u r p o s e s th e Ci t y wa s di v i d e d in t o 25 zo n e s . Th e s e wo ul d be si m i l a r bu t on a sm al l e r sc al e to wh at so m e ci t i e s ca ll co mm u n i t y pl a n n i n g ar e a s . Th e cr i t e r i a th a t wa s us e d as a gu i d e fo r de t e r m i n i n g th e bo u n d a r i e s of th e zo n e s wa s as fo l l o w s : 1. Bo u n d a r i e s of ex i s t i n g ma s t e r pl a n s 2. Bo u n d a r i e s of pe n d i n g ma s t e r pl a n s 3. Bo u n d a r i e s of po t e n t i a l fu t u r e mast e r pl a n ar e a s 4. Av a i l a b i l i t y of pu b l i c fa c i l i t i e s an d se r v i c e s 5. Pu b l i c fa c i l i t y re l a t i o n s h i p s es p e c i a l l y th e Ci t y ' s pl a n n e d ma j o r ci r c u l a t i o n ne t w o r k 6. Sp e c i a l di s t r i c t bo u n d a r i e s wh e r e ap p r o p r i a t e 7. Lo c a t i o n w i t h re s p e c t to th e th r e e de v e l op m e n t a l st at u s ca t e g o r i e s {u r b a n i z e d , ur b a n i z i n g an d fu t u r e ur b a n i z i n g ) .. b' \ Attachment 4 Summary of Carlsbad’s Open Space History Carlsbad has a long history of prioritizing the protection of open space and natural resources and providing open spaces for community recreation. A summary and links (if available) of some of the major efforts related to open space in Carlsbad include: • Citizens Committee for the Review of the Land Use Element (1985) made recommendations on policies related to future growth, including open space. • Citywide Facilities and Improvements Program (1986), a part of the Growth Management Program (1986), sets standards for 11 public facilities, including parks and other open space. • Citizens Committee for Open Space (1988-1989) reviewed the city’s open space plans and programs and made recommendations on open space protection. • Open Space and Conservation Resource Management Plan (1992) called for development of a comprehensive open space system. • General Plan Open Space and Conservation Element (1994) included policies to guide protection and creation of open space areas, including policies that aligned with the recommendations of the Citizens Committee for Open Space. • Open Space Advisory Committee (1990-1995) reviewed and made recommendations on the open space of master plans and other major development proposals. • Proposition C (2002) authorized the City Council to spend more than $1 million to acquire open space and build trails. As of 2022, the city has spent $4.2 million on open space and trails projects, including South Shore Agua Hedionda Lagoon Trail Improvements, Arroyo Vista Trail Extension, Lake Calavera Trails, 6125 Paseo del Norte open space purchase and Aura Circle open space purchase. $1.8 million remains budgeted for future open space purchases. • Trails Program Report (2001) and Trails Implementation Plan (2002) outlined a future vision for a citywide trails plan and identified private trails to be made public and new public trails to be built. • Community Forest Management Plan (2002/2019) describes how the city will care for its trees (on city owned properties), provides a list of the tree species the city can plant in areas adjacent to public streets, and sets a goal of increasing the overall number of trees on city owned or controlled properties. • Habitat Management Plan (2004) guides the preservation and protection of sensitive biological resources within the city while allowing for continued economic development. The plan guides the design, management, monitoring, and public use of the city’s natural open space preserve system. Carlsbad is the only North County city with an approved Habitat Management Plan, which is a 50-year comprehensive biological approach to preserving natural land for plant and animal species. • Open Space Management Plan (2005) establishes procedures, standards, guidelines and conditions for long-term conservation and management of sensitive species and habitat. • Proposition C Open Space and Trails Ad Hoc Committee (2005 – 2007); established a prioritized list of potential property acquisitions for open space protection and trail linkages. The committee’s recommendations aided the City Council in the use of Proposition C funds (see “Proposition C”, above). Attachment 4 • General Plan Open Space and Conservation Element (2015) provides policies that address the communities open space needs for habitat and resource conservation, and parks and recreation. • Parks and Recreation Department Master Plan (2015, update in process) identifies needs and priorities for park and recreation facilities; provides a guide to achieve a balance of programing, facilities and amenities. • Trails Master Plan (2019) is a blueprint for how city trails will be developed and managed in the future. • Carlsbad Preserve Management Plan (2021) provides management, monitoring, and reporting guidelines for the conservation goals for certain properties owned and managed by the City of Carlsbad. CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 2 Sept. 22, 2022 PARKS STANDARD 3.0 acres of Community Park or Special Use Area per 1,000 population within the park district [city quadrant] must be scheduled for construction within a five-year period beginning at the time the need is first identified. The five-year period shall not commence prior to August 22, 2017.1 PURPOSE OF THIS REPORT This report is informational only and is intended to help guide the Carlsbad Tomorrow – Growth Management Citizens Committee’s discussion on the Growth Management park standard. BACKGROUND The city’s parks standard has evolved from the early 1980s to today but has always been based on a ratio of park land to population and includes a five-year timing threshold. When the Growth Management Program was developed, it was recognized that certain facilities could be constructed incrementally, like sewer and water utilities, while others must be constructed all at once, like parks. When a park is constructed, it must be constructed to full size or in large phases; and therefore, more time for planning, site acquisition and financing is required. The original intent of the five-year timing threshold was for the park to be in operation when the demand had reached a certain point. In 1986, it was estimated that the amount of development that would produce 1,000 population was 432 new homes; however, it isn’t financially efficient to construct a park in small increments for each 432 homes. Instead, the five-year period allowed demand to accumulate to the point that construction of a full park would be warranted. Here’s a summary of the history of the park standard: •Parks and Recreation Element Update (May 1982) In 1982, as part of an update to the city’s General Plan Parks and Recreation Element, the city decided to focus future park development on community parks and special use/resource areas, and to no longer be responsible for the construction and maintenance of smaller “neighborhood parks.” The objective was for neighborhood recreation facilities to be provided and maintained by private development, such as homeowner associations. 1 City Council Resolution No. 97-435 states that “scheduled for construction” means the improvements have been designed, a park site has been selected, and a financing plan for construction of the facility has been approved. CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 2 Sept. 22, 2022 2 A report to a citizens committee in 1985 (see Attachment 1 – Apr. 19, 1985, Report to Citizens Committee on Parks) states that a city survey indicated people wanted larger and more active park areas, which contributed to the city’s 1982 decision to provide more community parks. • Council Policy Statement No. 32 (September 1982) Policy No. 32 established the Public Facilities Management System (later replaced with the Growth Management Program) and established the minimum service levels for seven public facilities; the minimum service level for parks was “at least two acres of developed community parks, 2.5 acres of special resource areas, and 0.5 acres of special use facilities.” • Report of the Citizens Committee for the Review of the Land Use Element (July 1985) In the mid-1980s, as concern regarding growth intensified, the City Council appointed a citizens committee to the review of the General Plan Land Use Element; The committee delivered its report to the City Council in July 1985. The committee’s recommendations were used as the basis for the growth management facility standards. On the topic of parks, the committee recommended the city increase the park standard to three acres per 1,000 population. The committee also recommended: o Retaining the community parks policy and that the city be responsible for development and maintenance of the community park system. o Requiring individual developers to provide smaller parks, also referred to as “pocket parks” and active recreation facilities; maintenance of pocket parks shall be the responsibility of homeowner’s associations and remain in private ownership o Adopting a policy allowing individual communities to acquire, develop and maintain neighborhood parks. Funding to come from a special assessment district approved by voters. As part of the committee’s work, city staff provided information on various topic, including parks; see Attachment 1 – Apr. 19, 1985, Report to Citizens Committee on Parks. • Public Facility Standards (July 1986) and Citywide Facilities and Improvements Plan (Sept. 1986) In July 1986, the City Council adopted the public facility standards for the Growth Management Program; and in September 1986 the standards were incorporated in the Citywide Facilities and Improvements Plan. The adopted parks standard at this time was: o “Three acres of community park or special use area per 1,000 population within the Park District, must be scheduled for construction within a five-year period.” o “Macario Canyon” (later renamed Veteran’s Memorial Park) was identified in the Citywide Facilities and Improvements Plan as a planned community park and the estimated acreage at the time (100 acres) was divided equally among the four quadrants (25 acres each). See Attachment 2 – Park Standard Excerpt from 1986 Citywide Facilities and Improvements Program. CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 2 Sept. 22, 2022 3 After adoption of the parks standard, the city continued to charge park fees (in-lieu of park dedication) and utilized the funds for park construction. The park fee was originally established in 1966 and has been updated overtime. See Impact Fees/Facilities Financing section below for more information on park funding. • City Council Resolution No. 97-434 and 97-435 (April 1997) In April 1997, the City Council received a 10-year anniversary report on the Growth Management Program and adopted resolutions amending the population related public facility standards, including the parks standard. The revisions added the following to the park standard: o Three acres of Community Park or Special Use Area per 1,000 population within the Park District must be scheduled for construction within a five-year period or prior to construction of 1,562 dwelling units within the Park District, beginning at the time the need is first identified. The addition of a dwelling unit threshold was intended to clarify the number of homes the city estimated would be built in a five-year period, which at that time (1997) was 1,250 homes per year citywide or 312 homes per year per quadrant (park district). The threshold of 1,512 dwelling units is equal to 312 new dwellings per year for five years. • City Council Resolution No. 2017-170 (August 2017) The City Council approved an amendment to the park standard that removed the 1,562 dwelling unit threshold and added a new requirement for the five-year threshold for park construction to commence on the date the City Council approved the parks standard amendment. This amendment resulted from concerns about linking the timing of the construction of a new park to the construction of 1,562 dwelling units, as the General Plan anticipates the remaining residential capacity in certain quadrants of the city to be less than 1,562 dwelling units. If the dwelling threshold of the standard cannot be met, this technically could mean that more park acres would not be built to meet the population demand. Therefore, the park standard was amended to read as it does currently (see page 1, above). Parks Planning and Status The Carlsbad Parks & Recreation Department offers a variety of programs and services to promote health and wellness and has been nationally accredited by the Commission for Accreditation of Park and Recreation Agencies for excellence in operation and service. The City of Carlsbad’s park system includes 42 community parks and special use areas and over 67 miles of trails that provide outdoor recreational opportunities and conserve open space for residents and visitors. The Carlsbad General Plan describes community parks and special use areas, as follows: “Community parks are typically 20-50 acres in size (though there are several smaller parks “grandfathered” into this classification) and designed to serve the recreational needs of several neighborhoods, with a focus on serving families from the vicinity with daily frequency. Community parks generally provide active and passive use amenities; however, they are not limited to the exclusive use of either.” CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 2 Sept. 22, 2022 4 “Special use areas are typically between one and five acres in size, with only one or two basic uses, which can be either active or passive in orientation. Examples include, but are not limited to, swim facilities, skate parks, dog parks, tennis courts or picnic areas. School sites that operate under a joint-use facility agreement between the City of Carlsbad and a school district are also included in the inventory.” There are other types of parks not defined by the General Plan that could be utilized in future planning. Pocket parks, sometimes called Parkettes, are small parks typically less than one acre and are located within urban or suburban neighborhoods. There are several plans that guide the planning and operation of the city’s public parks and recreation system including the Citywide Facilities and Improvements Plan that specifies the parks standard; the General Plan for long range goals and policies; the Parks & Recreation Department Master Plan (which is currently being updated) to guide priorities, proposed investments and programming; and individual master plans prepared for each park that provide detailed design and construction plans. There is also a Trails Master Plan that provides a framework for the city’s comprehensive trail system. While the trails system offers recreation throughout the city, trails outside of park boundaries are not counted toward the parks standard. For additional information, see Attachment 3- Parks Planning Process. In addition to public parks provided and maintained by the city, the city’s Zoning Ordinance has standards that require recreation areas within planned developments (condominiums and small lot residential projects) and master planned communities (e.g., Bressi Ranch, Aviara, Poinsettia Shores, Villages of La Costa, Calavera Hills, etc.). These recreation areas supplement the city’s public parks and provide recreation in closer proximity to the residents of those areas. However, these recreation areas are not maintained by the city and are not included in the inventory of public parks to meet the city’s park standard. The park standard has greatly contributed to the availability of parks throughout the city. As shown in Table 1 below, all quadrants are in compliance with the park standard. The scheduling for construction of Veterans Memorial Park (Veteran’s Memorial Park Master Plan was approved by City Council on July 26, 2022) resulted in the existing and planned future park inventory for all city quadrants exceeding the projected required acreage at buildout. Attachment 4 – Carlsbad Park Inventory lists all of the park facilities and Attachment 5 – Parks Location Map shows their location. Table 1. Park Acreage by Quadrant: Performance Standards, Current Amount, Planned Amount Quadrant Current Population Current Park Acreage required Buildout Population Buildout Park Acres Required Current Park Acreage 2022 NW 31,360 94.1 39,126 117.4 131.7 NE 18,189 54.6 22,741 68.2 68.7 SW 26,337 79.0 28,834 86.5 93.6 SE 40,140 120.4 42,548 127.6 138.3 Total 116,025 348.1 133,249 399.7 432.4 CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 2 Sept. 22, 2022 5 COMMUNITY INTEREST IN A PONTO PARK Over the past several years, a community group, People for Ponto, has submitted petitions and correspondence stating that the city does not have sufficient park acres in the southwest quadrant and that the city should acquire land and build a park in the Ponto area. For more information, see Attachment 6 – Community Interest in a Ponto Public Park. POTENTIAL FUTURE PARKS The park acreage in Table 1 does not include future park projects listed in the Capital Improvements Program (major construction projects) as “partially funded” or “unfunded”. Should funding mechanisms be found, and these parks are built, the additional parks acreage would further aid in meeting/exceeding the growth management parks standard. Future parks may include: • Robertson Ranch Park (NE – 11.2 acres); partially funded in the CIP. The master planning process for this park is scheduled to begin in FY 2022-23. • Zone 5 Business Park Recreational Facility (NW – 9.3 acres); partially funded in the CIP. • Cannon Lake Park (NW – 6.8 acres); unfunded in the CIP. • South Carlsbad Coastline (SW – approximately 60 acres); not identified in the CIP; as part of current city efforts to plan the realignment of south Carlsbad Boulevard, public land will be freed up and available for other public uses, including the potential for 60 acres of park and recreation uses. The community parks and special use areas tabulated toward meeting the city’s Growth Management Program park standard are extensive, yet only represent a part of the recreational opportunities offered by the City of Carlsbad. City residents, as well as visitors, enjoy the city’s beaches, natural resource areas, golf courses, lagoons and trails, all of which do not count toward the city’s park standard; and as mentioned above, all planned developments and master planned communities offer private recreation areas for the benefit of residents in those areas. This should be considered when comparing Carlsbad’s population-based parks standard to other jurisdictions that may not have comparable definitions of what counts as parklands, or the existence of beaches, extensive trail systems, natural open spaces, and private recreation areas that provide valuable recreational opportunities. For more information, see Attachment 7 - Park Standards Benchmarking Analysis. Impact Fees/Facilities Financing City parks projects and their funding sources (Community Facility District No. 1, public facility impact fees, park development impact fees, developer contributions, and general fund) are included in the Capital Improvement Program, which is a chapter of the city’s budget document. The City of Carlsbad Community Facilities District No. 1 was established in 1991, creating a special tax lien on vacant properties throughout the city. The purpose of the CFD was to finance the construction of specific public facilities of citywide obligation and benefit, including Veterans Memorial Park. In part, parks are also funded by development impact fees paid by developers of residential projects. Carlsbad assesses park-in-lieu fees, which refers to the practice of requiring a residential developer to CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 2 Sept. 22, 2022 6 pay a fee to satisfy park needs, rather than dedicating land for parks. Park-in-lieu fees are collected by the city for the purchase and development of parkland within each quadrant of the city, and the fees are based on the acquisition cost of parkland. In concept, when enough cash has been assembled the city constructs the next capital improvement project in order of priority. This method forces the city to delay construction of various projects until funds have been collected. However, other financing methods such as reimbursement agreements, assessment districts, debt financing, or others may be used to accelerate construction. Projects in the CIP funded with park-in-lieu fees include future park site acquisition, development and restoration. Park in-lieu fees are the same in the NE, SE and SW quadrants and higher in the NW quadrant. For more information, see Attachment 7 - Park Standards Benchmarking Analysis. Carlsbad’s park-in-lieu fees have helped fund the capital cost of park development, but do not contribute to operations and maintenance. Funding for operations and maintenance of park facilities come from the general fund and may also include user fees, partnerships, special permits, rental opportunities, concessions, sponsorships, and other sources. Adjustments to user fees will be explored as a part of the Parks & Recreation Department Master Plan update. The background section refers to a 1985 citizens committee that recommended retaining the community park policy; the information the committee considered in making their recommendation included the cost of providing and maintaining neighborhood parks. As part of the committee’s work, city staff provided a “neighborhood park analysis” that identified 39 neighborhood parks would be needed throughout the city, based on a ½ mile walking distance and other criteria, and those 39 parks would cost the city (in 1985 dollars): $19.5 million (acquisition), $11.7 million (construction) and $1.5 million annually (maintenance); see Attachment 1 – Apr. 19, 1985, Report to Citizens Committee on Parks. Since 1982, the city has required private development be responsible for the cost to provide and maintain neighborhood recreation facilities. Private on-site pocket parks and recreational facilities developed as a part of master planned communities are maintained through homeowners’ association dues. Existing neighborhoods or HOAs also have the option to form assessment districts as a means to pay for additional park facilities. However, it is often challenging to gain approval of districts in developed areas with many property owners, as assessment districts require a majority of property owners within the proposed district to vote in support of the new levy. Visitor and Commuter Demand Visitors create demands on the parks system, but also generate funds for the city through payment of transient occupancy tax when staying at hotels or vacation rental properties, and sales taxes when eating or shopping at local restaurants and stores. TOT makes up 10% of the city’s General Fund. In an article published in Parks & Recreation Magazine, authors Peter Harnik and Abby Martin2 discuss the impact visitors and commuters (those who work in the city but don’t live there) may have on a city’s 2 Harnik, Peter and Abby Martin. “How Many Out-of-Towners Are in Your Park?” May 1, 2014. Parks & Recreation Magazine, National Recreation and Park’s Association. CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 2 Sept. 22, 2022 7 park system, especially related to high-profile facilities such as Chicago’s Millennium Park and San Diego’s Balboa Park. The authors also discuss how commuters may create a midday increase in usage of park systems, citing examples in the cities of Boston, Pittsburg, Atlanta, Miami and Indianapolis. Harnick and Martin note that major park attractions draw tourism to cities which in turn generate tax revenues, yet these contributions are often not quantified nor are a portion of the increased tax revenues gained directed back to the affected park system budgets. The authors recommend that cities collect data on parks-related tourism and the economic multiplier effect generated, so that a case can be made for greater revenue allocations to parks. User fees for special events and sports tournaments that use park facilities can also help sustain the parks system. In Carlsbad, the scope of work for the Parks & Recreation Master Plan Update currently underway will study how the city’s user fees compare to other regional jurisdictions. The city’s Growth Management Ordinance (Carlsbad Municipal Code Chapter 21.90) recognizes the relationship between employment uses and park needs and authorizes special facility fees to pay for improvements or facilities that are related to new industrial development. In November 1987, the City Council adopted its first park mitigation fee for nonresidential development in the Zone 5 Local Facilities Management Plan area (office and industrial area along Palomar Airport Road near the airport). Additionally, a park mitigation fee was required for nonresidential development in the Zone 13 and Zone 16 Local Facilities Management Plan areas (commercial area along Avenida Encinas between Cannon Road and Palomar Airport Road; and the business park on Faraday Avenue at the city’s eastern boundary). The Committee could consider further exploring the application of and potential future use of the nonresidential park mitigation fee. Benchmarking Compared to the median of other California cities with similar population densities (above 2,500 per square mile), Carlsbad has a lower persons-per-park ratio, meaning they provide more parks for their population (Attachment 7, Table 2). Looking more specifically at the San Diego region, Carlsbad is compared to the cities of Encinitas, Oceanside, San Marcos, Vista, Poway, Chula Vista, and San Diego. Carlsbad has more park acres per resident than Encinitas, Vista, and Chula Vista, but less park acres per resident than Oceanside, San Marcos, Poway and San Diego (Attachment 7, Table 3.1). Carlsbad also has a higher percentage of land area used for parks when compared to Encinitas, Oceanside, San Marcos, Vista and Chula Vista, but a lower percentage than Poway and San Diego (Attachment 7, Table 3.2). The City of San Diego’s high park acreage is due in part to its large inventory of open space land; just over three-quarters of its park system lands are undeveloped3. Park performance standards, set by individual city agencies, help to guide park and recreation development and levels of service, to ensure residents are being provided adequate park services. The standards also influence how much financial contributions are required through developer impact fees. 3 City of San Diego Parks Master Plan Needs + Priorities Report, April 2020. Accessed at: https://www.sandiego.gov/planning/parks-master-plan CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 2 Sept. 22, 2022 8 A population-based metric of required acres per 1,000 residents is a commonly used park performance standard. However, there is variation in what jurisdictions count toward meeting their standard. For example, some jurisdictions count regional parks and pocket or mini parks toward meeting the standard. Carlsbad only counts community parks and special use areas. Table 2 provides a summary of performance standards for selected nearby cities. For more details on benchmarking, please see Attachment 7 - Park Standards Benchmarking Analysis. Table 2. Park Performance Standards Reference City Standard (acres per 1,000 residents) Citywide Facilities and Improvements Plan (Growth Management Program) City of Carlsbad 3.0 acres applied in each park district (i.e., city quadrant) General Plan: Recreation Element (amended 2003) City of Encinitas 0.25-0.5 acres for Mini Parks 1.0-2.0 acres for Neighborhood Parks 5.0-8.0 acres for Community Parks 5.0-8.0 acres for Special Use Parks No standard for Regional Parks 2019 Parks & Recreation Master Plan City of Oceanside 5.0 acres as a planning goal - 40% public schoolground acreage credit - 40% acreage credit for Guajome Regional Park developed acres 2021 General Plan, Parks, Recreation and Community Health Element City of San Marcos 5.0 acres - provide opportunities for passive and active recreation - includes parks, trails and recreational facilities - new infill development to provide plazas, mini parks or other civic spaces as a part of parkland requirement - General Plan 2030: Resources Conservation & Sustainability Element City of Vista 2.0 acres for Neighborhood Parks 3.0 acres for Community Parks 4.0-4.9 acres overall average park standard 1991 General Plan Public: Facilities Element City of Poway 2.5 acres for Neighborhood Parks 5.0 acres for Community Parks 2018 Parks & Recreation Master Plan Update City of Chula Vista 3.0 acres Includes community, neighborhood, special purpose, including mini and urban parks. Strategy varies for eastern (new growth) and western Chula Vista. 2021 Park Master Plan and associated General Plan Amendments City of San Diego “Value-based” standard of 100 points per 1,000 people in place of its prior standard of 2.8 acres. Points are awarded based on land, experience, and equity & access. CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 2 Sept. 22, 2022 9 Development Impact Fees Development impact fees are enacted by local governments on developers to ensure new growth pays its proportionate share of needed expansions and upgrades to infrastructure and facilities. Fee rates are assessed proportional to the impact created by the new development, and the proceeds from these fees can only be spent on expanding or upgrading infrastructure that can be used by the occupants of the new development in the DIF’s “area of benefit.” Table 3 provides a summary of fees for selected cities in the San Diego region. Table 3. Park-in-Lieu fees per different cities Residential Type – Fees per dwelling unit General Rural Single-Family Multi-Family Mobile Home City of Carlsbad Note: Varies by quadrant: NE, SE, NE, SW $5,728 (NE, SE, SW) $7,649 (NW) $4,804 (≤4 units) (NE, SE, SW) $4,636 (>4 units) (NE, SE, SW) $6,414 (≤4 units) (NW) $6,190 (>4 units) (NW) $3,696 (NE, SE, SW) $4,934 (NW) City of Oceanside $4,431 City of Vista $8,086 $8,035 $5,41 City of San Marcos $6,251 $6,251 City of Poway Note: 50% reduction for an ADU $4,562 $4,562 $3,594 $3,318 City of Encinitas Note: Other fees for Open Space, Trail Development, and Community Facilities $10,751: (0.125-8.0 DU/Ac) $7,180: (8.0-25.0 DU/Ac) $6,838 City of Chula Vista Note: Varies by west of I-805 and east of I- 805 freeway $13,684 west $21,366 east $10,157 west $15,858 east $6,404 west $9,999 east City of San Diego Ranges from $11,333 to $17,989 scaled to unit size Ranges from $8,800 to $13,968 scaled to unit size, with lower fees in transit priority areas and for senior housing, and certain other reductions related to environmental justice, affordable housing or sustainability goals. County of San Diego Varies by community from $5,457 to $11,217 • Fallbrook: $7,624 • Bonsall: $8,010 • San Dieguito (includes Rancho Santa Fe): $10,245 Varies by community from $4,503 to $12,144 • Fallbrook: $8,719 • Bonsall: $6,999 • San Dieguito (includes Rancho Santa Fe): $ 11,039 CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 2 Sept. 22, 2022 10 Park Standard Options The Citywide Facilities and Improvements Plan assessed and planned for future needs resulting from anticipated “buildout” of the city based on the City’s General Plan, including refinements that resulted from the 2015 General Plan Update. The city must now consider how the Growth Management Program park standard should be implemented in response to the new state housing laws that prohibit the city from implementing housing caps and moratoria, the difficulty in relying on a static “buildout” number given changing obligations to provide housing opportunities over time, and the challenges in securing vacant land available for parks as the city matures. Possible approaches that Carlsbad could pursue are provided below. All approaches presume that payment of the park in-lieu fee is sufficient for the development project associated with the fee to proceed, and state housing laws continue to prohibit housing caps and moratoria. TIERED SYSTEM FOR IMPLEMENTING PARK STANDARD • Tier 1 would maintain the existing system for the remaining development accounted for in the Growth Management Program and 2015 General Plan. • Tier 2 would apply to all growth not accounted for by the 2015 General Plan. Tier 2 growth could only occur through an amendment to the General Plan to increase planned residential density/growth. • Flexible or modified park standard for Tier 2 growth Maintain the 3.0 acres of park land per 1,000 population standard. If sufficient park acreage is not available, allocate park fees to a fund reserved for opportunistic purchases of land, which would enable the city to take advantage of future land sales as they present themselves, or • Maintain the 3.0 acres of park per 1,000 population standard but provide more options for how that acreage standard can be met. Instead of only counting community parks and special use areas, consider counting recreational resources like public trails, and private fitness courses, pocket parks or other recreational improvements toward meeting the standard, or • Create a new parks standard that considers the recreational value and features of various park improvements, including acreage, rather than relying solely on the acreage standard. For example, a pocket park, with high-value improvements designed for intensive use, could be determined to be worth more than an equivalent acreage of grassy area, or • Combine multiple metrics, or create an entirely new park standard, such as a 10-minute walk access goal, or density of people living near a park compared to park size. BROADER PARK DISTRICTS • Consider new geographies for the collection and use of Tier 2 impact fees. Quadrants could be combined to create larger geographic districts or be eliminated altogether in favor of a citywide program. • Citywide fees can be accrued and programmed faster than would be possible than if the fees were split into districts/quadrants. CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE STAFF REPORT – Exhibit 2 Sept. 22, 2022 11 • As a practical matter, this change would acknowledge that it will take longer to accumulate funds collected through incremental infill development as opposed to what has traditionally been collected from large residential subdivisions. ADDRESSING CONCURRENCY • Eliminate requirements that link Tier 2 development to a defined list of park projects. Instead, the collection of the park-in-lieu fees would be sufficient for projects to meet their parks obligation. • The city’s FY 2022-23 Capital Improvements Program includes park projects that have been identified as “partially funded” or “unfunded.” Consider using citywide (Tier 2) park-in-lieu fees to support these projects. • Increase the utility of existing parks through increased amenities or value-added investments. • Construct new park projects as sufficient funding sources, including park-in-lieu fees, are secured OTHER POTENTIAL CONSIDERATIONS • Consider equity and environmental justice when making decisions on the use of Tier 2 funds; prioritize investments in areas of need. • Consider if co-benefits can be achieved and whether diverse funding sources could be used to support park-system investments, such as adapting to climate change vulnerabilities and contributing to stormwater requirements. For example, the Carlsbad Coastline Project is a climate adaptation project that also offers the opportunity to create new land for recreational use. • Explore pros and cons of expanding implementation of a park mitigation fee for industrial development. • Review user fee recommendations anticipated from the Parks & Recreation Department Master Plan Update, for their potential to help fund park improvements and operations. Attachments Attachment 1. Apr. 19, 1985, Report to Citizens Committee on Parks Attachment 2. Park Standard Excerpt from 1986 Citywide Facilities and Improvements Program Attachment 3. Parks Planning Process Attachment 4. Carlsbad Park Inventory Attachment 5. Parks Location Map Attachment 6. Community Interest in a Ponto Public Park Attachment 7. Park Standards Benchmarking Analysis I I I I I I I I I I I I I I I I I I I PARKS I. Issues Identified 1. Parks needed sooner. 2. Provide more usable parks. 3. Neighborhood parks needed. II. Analysis In 1982, when the revised Parks and Recreation Element was adopted, the concept of park development in Carlsbad changed. Rather than having small neighborhood, pocket parks, the program was revised to require the dedication and construction of larger, more active community parks. A city survey indicated the people wanted larger, more active, park areas. Developers are required by ordinance to dedicate a certain amount of land or pay a fee in lieu of dedicating park land. Larger, community parks which are geared toward future development in Carlsbad take longer to get and longer to build. David Bradstreet, Parks and Recreation Director, will be present at the Committee's meeting of March 25, 1985 to explain the concept in more detail or answer questions about the present status of the park development program if the Committee wants additional information. Smaller, neighborhood-type parks are not required by the city. In a planned residential development (prd) where lots are proposed that are less than the size required by the underlying zone, common recreational areas are required under city ordinance. The common area can be either passive or active or a combination of both. The area is required to be maintained by a homeowners association. For a standard single family subdivision, no common recreational facilities are required by ordinance. III. Alternatives for Addressing Park Issues 1. Establish a mechanism where large, master plan developers are required to provide community parks up-front or at an earlier point in time so that they are available when they are needed. 2. Require developers to provide smaller, active recreational areas (parks) in all developments including standard single family subdivisions. These smaller parks would be maintained by a homeowners association or through a property owners tax maintenance district. APRIL 19, 1985 TO: CITIZENS COMMITTEE FROM: LAND USE PLANNING NEIGHBORHOOD PARK ANALYSIS I. Analysis At your meeting of April 8, 1985, the Citizens Committee requested staff to prepare a neighborhood park analysis specifically addressing locations in the city which will not have public park or recreational facilities within close proximity of residential neighborhoods. The attached map was prepared by planning staff and shows these locations based upon staff's best estimates and projections (a larger, working map will be available at your meeting to provide more details of the analysis). The criteria and assumptions used by staff in preparing the map included the following: (1) Only publicly-owned and maintained facilities were included -city parks (all sizes) and public school facilities (playgrounds, athletic fields). (2) Approximate locations of future, planned facilities as shown on the land use plan were used. The exact location of some of the future schools and parks have not yet been determined. (3) Assumes all undeveloped, planned facilities will in fact be constructed. (4) 1/2 mile maximum walking distance and no crossing of a major or primary street. (5) Industrial area excluded. Based upon the above criteria, staff's analysis indicates that there are approximately thrity locations in the city wh~ch will not have public parks or recreational facilities within 1/2 mile walking distance. In order to provide these facilities, approximately thirty-nine neighborhood parks would be required. II. Cost Estimate* For thirty-nine neighborhood parks (average five acres per site): Acquisition Construction Maintenance *(1984-85 -$19,500,000 -$11,700,000 -$1,521,000 Dollars) per year I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I III. Other Background Information . The 1982 revision to the Parks and Recreation Element eliminated the city's involvement in neighborhood parks except for those which had been accepted prior to the adoption of the revised Element. Applicable policy statements from the Element are: (1) "The city should not accept land dedication under its discretionary authority unless the property is for community park land purposes." (2) "Neighborhood level recreation shall be provided by: ( 3) 0 0 Special-Use facilities which may be developed and maintained by private, public, or a joint effort of both. Those facilities owned by the city will be maintained on a regular basis as per the use requirements. Existing neighborhood parks prior to the adoption of this revised Element." "Guide industries in the provision of recreational facilities for their employees during the planning review process." On April 1, 1985, the Citizens Committee approved the following recommended policy statement "encourage developers to provide smaller, active recreational areas (parks) in developments including standard single family subdivisions. These smaller parks would be maintained by a homeowners association or through a property owners tax maintenance district". Respectfully submitted, ' MICHAEL J. HOLZMILLER Land Qse Plannirig Manager MJH/ar Attachment PARltS PERPORMAHCB STANDARD Three acre• of Comaunity Park or Special Ose Area per 1,000 population within the Park District, must be scheduled for con•truction within a five year period. ADDITIONAL PACILITY PLANNING INPORMATION A. 1 • 2. The Growth Management Park standard has been developed to address Community Park and Special Use Areas together. Combining the two will provide greater flexibility for the Parks and Recreation Department to address the future needs of each quadrant as development occurs. The Parks and Recreation Department recently prepared an analysis of existing park acreage in the city which produced the following information: INVBNTORY Buildout Assumptions: Northwest Quadrant Population Total Current 25,039 At Buildout 39,479 Northeast Quadrant Current 5,607 At Buildout 20,843 Southwest guadrant Current 5,416 At Buildout 31,775 Southeast guadrant Current 16,128 At Buildout 42,817 Existing cc:aaunity Parks and Special Use Areas: Northve■t Quadrant C01111Unity Parks (Developed) Holiday Boap Grove Laguna Riviera Magee Total Developed CoDlllunity Parks (Undeveloped) Macario Canyon -credit Cannon take Total Undeveloped Acres 5.4 27.0 6.8 3.0 Acres 25.0 6.7 Required Acres 75.12 118.44 16 .10 62.53 16.23 95.33 48.38 128.45 42.2 31.7 PARKS (Continaed) Special Use Areas Buena Vista Cannon Park Car County Chase Pield CHS Tennis Courts Barding Community Center Jefferson Elementary Kelly Elementary Magnolia Maxton Brown Maxton Brown Extension Oak Pine Elementary Pio Pico Rotary swim Complex Valley Jr. High School Total Northeast Quadrant Community Parks (Developed) Calavera Hills Phase I Larwin Total Developed Community Parks (Undeveloped) Macario Canyon -credit Calavera Hills Phase II Total Undeveloped Special Use Area Larwin Total Southve ■t Quadrant co-unity Parks (Developed) Alta■ira Total Developed community Parka (Undeveloped) Macario Canyon -credit Total Undeveloped Acres 2.3 1 • 7 1 • 0 2. 3 3.0 1 • 0 2.6 2.8 4.2 1 • 4 2 • 1 0.4 2.0 0.8 1.0 3.0 7.5 Acres 8.0 18.3 Acres 25.0 1 0. 0 Acres 4. 0 Acres 1 2. 0 Acres 25.0 3 9 • 1 26.3 35.0 4. 0 1 2 • 0 25.0 There are no Special Use Areas in the Southwest Quadrant. -34- PARKS (Continued) south•••t Quadrant coa■unity Parks (Developed) La Costa canyon Stagecoach Total Developed community Parks (Undeveloped) Macario Canyon -credit Alga Norte Carrillo Ranch Total Undeveloped Special Use Areas Cadencia Puerta Puerte Elementary tevante St. Elizabeth Total C. ADEQUACY EVALUATION Acres 9.0 28.0 Acres 25.0 23.0 10.3 Acres 4. t 3.6 2.0 8.0 1 • 0 Existing Acreage Acres Required CClllllunity Special Use Per Standard Park (Dev) Area Northwest Quadrant 75.12 42.20 39. 10 Northeast Quadrant 16 .10 26 .30 4.00 southwest Quadrant 16 .23 12.00 0 Southeast Quadrant 48.38 37.00 18.70 Citywide Totals 155.83 tt7.50 61.80 3 7. 0 58.30 18.7 Total Acreage 81 • 30 30.30 12 .oo 55.70 179.30 On a Citywide baaia, the overall parks acreage is adequate. However, the Growth Management Program requires each quadrant to provide the approp~iate acreage in relation to its residential population. Por tbat reason, the southwest quadrant does not meet the performance standard and is deficient. The three other quadrants meet the performance standard. It should be noted as shown in the existing acreage figures that in certain quadrants there exists a greater proportion of Special Use Area acreage as compared to Community Park acreage. The performance standard allows the Parks and Recreation Department the ability to more properly address the individual quadrant needs for either Community Park or Special Use Area acreage as local plans are submitted. -35- PARKS (Continued) Alternative ■ There are several alternatives which could be considered to rectify this deficiency, however, after discussing these options statt believes one of the following should be considered: 1. Amend the current Five Year C.I.P. to include funding for new park facility in the Southwest Quadrant ~hich would require deleting other projects. 2. Direct statt to attempt to resolve this deficiency based on the Local Pacility Management Plans which will be received after the approval of the Citywide Pacilities and Improvements Plan. -36- PARKS AND RECREATION-CAPITAL IMPROVEMENT PROGRAM (C.I.P.) PROJECT PROCESS MANAGEMENT, ELECTED OFFICIALS, PUBLIC AND OTHER STAKEHOLDERS’ IDEAS FOR C.I.P. PROJECT APPROVED C.I.P. PROJECT RELEASE RFQ FOR ADVERTISEMENT STAFF REPORT/ RECOMMENDATION COLLABORATE WITH PUBLIC WORKS BRANCH, COMMUNITY DEVELOPMENT DEPARTMENT, CONTRACTS DIVISION, ON PERMIT APPROVAL CONTRACT DOCUMENTS, SPECIFICATIONS AND CONSTRUCTION DOCUMENTS RFQ SCOPE OF WORK FOR CONSULTANT TEAM RFQ EVALUATION AND INTERVIEWS PLANNING COMMISSION / CITY COUNCIL APPROVE PERMITTING AND ENVIRONMENTAL FOR PARKS PROJECTS CITY COUNCIL CONTRACT APPROVAL STAFF REPORT/ RECOMMENDATION APPROVED CONCEPTUAL C.I.P. PROJECT MASTER PLAN (PROJECT SPECIFIC) PLANNING DIVISION DETERMINES PROCESS CONCEPT DEVELOPMENT CONSULT WITH PARKS ADMINISTRATION, PLANNING DIVISION, LAND DEVELOPMENT ENGINEERING DIVISION, COMMUNICATIONS DEPARTMENT EARLY ASSESSMENT REVIEW BY PLANNING DEPARTMENT C.I.P PROJECT BUDGETDEVELOP INITIAL PROJECT SCOPE EARLY ASSESSMENT APPLICATION PREPARED DETERMINE PUBLIC ENGAGEMENT PROCESS • DESIGN • CONSTRUCTION• MITIGATED NEGATIVE DECLARATION • HABITAT MANAGEMENT PLAN PERMIT • ZONING CONFORMANCE • SPECIAL USE PERMIT • GENERAL PLAN • CULTURAL • CONDITIONAL USE PERMIT • TRAFFIC ANALYSIS STUDY • VEHICLE MILES PER TRAVEL • HILLSIDE DEVELOPMENT PERMIT • COASTAL ZONE PERMIT • TRAFFIC REVIEW/IMPACT ANALYSIS • STORM WATER • GRADING PERMIT • REQUIREMENT FOR PUBLIC INPUT PROCESS • OTHERS (POTENTIALLY) • OPPORTUNITIES / CONSTRAINTS • ADVISED BY PARK MASTER PLAN • PUBLIC INPUT • INFORMED BY TECHNICAL STUDIES • SCHEDULING • ENVIRONMENTAL REVIEW • PLANNING ZONING REVIEW PARKS & RECREATION MANAGEMENT TEAM REFER TO PARKS MASTER PLAN / TRAILS MASTER PLAN PARKS & RECREATION COMMISSION SENIOR LEADERSHIP/ MANAGEMENT PARK & RECREATION COMMISSION BIDDING PROCESS STAFF REPORT/ RECOMMENDATION REVIEW MATERIALS AND EQUIPMENT SUBMITTALS MONITOR CONSTRUCTION AND ADMINISTER CONTRACT CHANGE ORDERS AS NEEDED ISSUE TASK DIRECTIVES AND PROCESS PROGRESS PAYMENTS THROUGH PROJECT COMPLETION CITY COUNCIL AWARD CONTRACTSTART CONSTRUCTION DETERMINATION OF LOWEST RESPONSIVE AND RESPONSIBLE BID CONTRACT PROCESSING AND PROJECT SCHEDULE DEVELOPMENT RIBBON CUTTING, OPEN TO PUBLIC CITY COUNCIL CITY COUNCIL CONCEPTUAL PLAN APPROVAL ENTITLEMENT APPLICATION PREPARED CITY COUNCIL APPROVAL & AUTHORIZATION TO BID ~ ♦ ♦ ♦ + • ~ ' ~ ~-If-+- ..... ~ • • ♦ ~ ' • ~ ~ ' ' ♦ + • ~ ~ • • .. • ' ' • • • ~ • ♦ .. ♦ CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE Exhibit 2, Attachment 3 Carlsbad Park Inventory Table 1. Community Parks and Special Use Areas (2022) FACILITY NAME QUADRANT ACRES Community Parks Alga Norte Community Park, including Alga Norte Dog Park SE 32.1 Aviara Community Park SW 24.3 Calavera Hills Community Park, including gateway NE 16.7 Hidden Canyon Community Park, including Ann D. L’Heureux Dog Park NE 22.0 Holiday Park NW 6.0 Hosp Grove Park NW 27.1 La Costa Canyon Community Park SE 14.7 Laguna Riviera Park NW 4.2 Leo Carrillo Ranch Historic Park SE 27.4 Magee Park NW 2.1 Pine Avenue Park NW 8.2 Poinsettia Community Park SW 41.2 Stagecoach Community Park SE 28.5 Veteran’s Memorial Park (scheduled for construction per parks standard) CITYWIDE 93.7 (23.425 per quad.) Subtotal Community Parks 348.2 Special Use Areas Aviara Oaks School Field SW 4.7 Buena Vista Elementary School Field NW 2.5 Buena Vista Reservoir Park NW 3.1 Business Park Recreational Facility (Zone 5 Park) NW 3.0 Cadencia Park SE 4.0 Calavera Hills Trailhead NE .4 Cannon Park NW 1.7 Car Country NW 1.0 Carlsbad High School Tennis Courts NW 1.7 Chase Field NW 2.7 Harding Community Center NW 1.0 Harold E. Smerdu Community Garden NW 1.3 Hope Elementary School Field NE 2.8 Hosp Grove Trailheads NW 7.6 Jefferson Elementary School Field NW 2.2 La Costa Meadows Elementary School Field/El Fuerte Park SE 4.7 Kelly Elementary School Field NW 2.9 La Costa Heights Elementary School Field SE 3.5 Magnolia Elementary School Field NW 4.0 Maxton Brown Park NW 0.9 CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE Exhibit 2, Attachment 3 FACILITY NAME QUADRANT ACRES Special Use Areas Monroe Street Swim Complex NW 2.0 Oak Park NW 0.2 Ocean Street Sculpture Park and Tamarack Picnic Facilities NW 8.8 Pio Pico Park NW 0.8 Senior Center Complex NW 3.4 Skate Park NE 3.4 Terramar North Bluff NW 1.4 Valley Junior High School Field NW 8.5 Subtotal Special Use Areas 84.2 Table 2. Anticipated Future Park Projects QUAD PARK PROJECT PARK CLASSIFICATION ESTIMATED PARK ACREAGE NW Cannon Lake Park Special Use Area 6.8 NW Business Park Recreational Facility (Zone 5 Park) Expansion Special Use Area 9.3 NE Robertson Ranch Park Special Use Area 11.2 !^ PALOMARAIRPORTRD T A M ARACKAV P OINSETTIA LN C A R L S BAD BL C A R L S B A D V IL L A G E D R RANCHOSANTA FERD M E L R O S E DR CARLSBAD BL ELCAMINOREAL OLIVENHAI N R D LACOSTAAV TAMARACK AV A VIARAPY C OLLEGEBL A L GARD COLLE GE BL CANNON R D 11 14 16 1720 21 27 36 38 43 45 37 3 41 13 12 22 10 33 39 30 31 6 19 15 32 7 34 98 23 2829 42 5 4 24 26 44 40 1825 1 35 2 0 2,000Feet I Community Park Special Use Area Future Park Growth Management Citizens CommitteeCarlsbad City Parks Document Path: J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks_Citywide_11x17.mxd, Date: 9/15/2022 Index Park Name1 HOSP GROVE PARK2 HOSP GROVE TRAILHEAD3 HIDDEN CANYON PARK4 HOPE ELEMENTARY SCHOOL FIELD5 BUENA VISTA ELEMENTARY SCHOOL FIELD6 BUENA VISTA RESERVOIR PARK7 CALAVERA HILLS TRAILHEAD8 PIO PICO PARK9 HAROLD SMERDU COMMUNITY GARDEN10 CALAVERA HILLS COMMUNITY PARK11 MAXTON BROWN PARK12 MONROE STREET POOL13 CARLSBAD HIGH SCHOOL TENNIS COURTS14 OAK PARK15 HARDING COMMUNITY CENTER16 MAGEE PARK17 HOLIDAY PARK18 MAGNOLIA ELEMENTARY SCHOOL FIELD19 SENIOR CENTER / PINE AVENUE COMMUNITY CENTER20 PINE AVENUE COMMUNITY PARK21 CHASE FIELD22 VALLEY JUNIOR HIGH SCHOOL FIELD23 ROBERTSON RANCH COMMUNITY PARK - FUTURE24 JEFFERSON ELEMENTARY SCHOOL FIELD25 FRAZEE / TAMARACK STATE BEACH FACILITIES - BLUFFS26 KELLY ELEMENTARY SCHOOL FIELD27 LAGUNA RIVERA PARK28 ZONE 5 PARK EXPANSION - FUTURE29 ZONE 5 PARK30 SKATE PARK31 VETERANS MEMORIAL PARK32 TERRAMAR NORTH BLUFF33 CANNON PARK34 CANNON LAKE PARK - FUTURE35 CAR COUNTRY PARK36 LEO CARRILLO RANCH HISTORIC PARK37 ALGA NORTE COMMUNITY PARK38 AVIARA COMMUNITY PARK 39 POINSETTIA COMMUNITY PARK40 EL FUERTE PARK / LA COSTA MEADOWS ELEMENTARY SCHOOL FIELD41 AVIARA OAKS SCHOOL FIELD42 CADENCIA PARK43 LA COSTA CANYON COMMUNITY PARK44 LA COSTA HEIGHTS ELEMENTARY SCHOOL FIELD45 STAGECOACH COMMUNITY PARK ,.. ... 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' ~~, , CALLE S USA N A CAR LS B A D V I L L A G E D R A V E N I D A D E LOUISA VAN C O UVERST WATERBU RY W Y S A N T A C L A R A W Y VIA DENISE VIAR I C A R D O V I A T O P A C I OVIA MERDE VIA PL AT O VIA C AJ ITA VIA ROSARITA VIA CRISTOBAL VIA COLIMA VIA CARDEL APPIAN RD VIA D E C A N T O VIA LIBERTAD C O N C O R D ST V I A M A S A D A V IA M A G I A VIA TULIPAN VIA P E SC A D O O LYMPIA DR V I A P A J A R O HIDDENCANYON PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd HIDDEN CANYON PARK Community Park Special Use Area Future Park T A M A R A C K A V HOPE ELEMENTARYSCHOOL FIELD N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd HOPE ELEMENTARY SCHOOL FIELD Community Park Special Use Area Future Park PIO PICO DR LAS FLORES DR BUENA VISTAELEMENTARYSCHOOL FIELD N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd BUENA VISTA ELEMENTARY SCHOOL FIELD Community Park Special Use Area Future Park BUENA VISTA WY A R L A N D R D JAMES DR LID O P L HIG H L A N D D R BUENA VISTARESERVOIR PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd BUENA VISTA RESERVOIR PARK Community Park Special Use Area Future Park PENINSULA DR COLLEGEBL CALAVERAHILLSTRAILHEAD N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd CALAVERA HILLS TRAILHEAD Community Park Special Use Area Future Park P IO P I C O D R CYNTHIA LN KNOWLES AV PIO PICO PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd PIO PICO PARK Community Park Special Use Area Future Park J E T T Y P T SANFORD LN MIDD L E T O N D R WOODSTOCK ST CAPE COD CR H A R W I C H D R TAMARACK AV E S K E R W Y PORTLAND CT A R T E S I A N W Y DOVERWY CAMBRIDGE WY EDINBURGH DR B A C K S H O R E C T H A R T FORD PL GLASGOWDR LANCASTERRD C A R L S B A D V I L L A G E D R CALAVERA HILLSCOMMUNITY PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd CALAVERA HILLS COMMUNITY PARK Community Park Special Use Area Future Park STRATFORD LN LAGUNA DR HAROLD SMERDUCOMMUNITYGARDEN N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd HAROLD SMERDU COMMUNITY GARDEN Community Park Special Use Area Future Park STATE ST L A G U N A D R MAXTONBROWN PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd MAXTON BROWN PARK Community Park Special Use Area Future Park G A Y L E W Y M O N R O E S T MONROESTREET POOL N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd MONROE STREET POOL Community Park Special Use Area Future Park BASSWOOD AV VALLEY ST CARLSBADHIGH SCHOOLTENNIS COURTS N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd CARLSBAD HIGH SCHOOL TENNIS COURTS Community Park Special Use Area Future Park PIOPICODR OAK PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd OAK PARK Community Park Special Use Area Future Park O A K A V C A R L S B A D VIL L A G E D R H A R DIN G S T J E F F E R S O N S T A LL E Y H O P E AV A L L E Y HARDINGCOMMUNITYCENTER N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd HARDING COMMUNITY CENTER Community Park Special Use Area Future Park O C E A N S T C A R LS B A D B L C Y P R E S S A V A L L E Y G A R FIE L D S T CYPRESS AV B E E C H A V MAGEE PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd MAGEE PARK Community Park Special Use Area Future Park CHESTNUT AV P IO P I C O D R H A R DIN G S T BASSWOOD AV PIN E A V EUREKA PL HOLIDAY PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd HOLIDAY PARK Community Park Special Use Area Future Park A N D R E A A V M A G N O LIA A V V A L L E Y S T MAGNOLIAELEMENTARYSCHOOL FIELD N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd MAGNOLIA ELEMENTARY SCHOOL FIELD Community Park Special Use Area Future Park H A R DIN G S T M A DIS O N S T PIN E A V W A L N U T A V J E F F E R S O N S T A L L E Y M A DIS O N S T A L L E Y J E F F E R S O N S T PINE AVENUECOMMUNITY PARK SENIOR CENTER/ PINE AVENUECOMMUNITY CENTER N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd SENIOR CENTER / PINE AVENUE COMMUNITY CENTER Community Park Special Use Area Future Park WALNU T A V M A D I S O N S T CHEST N U T A V PINE A V H A R D I N G S T JE F F E R S O N S T R O O S E V E L T S T A L L E Y M A D I S O N S T A L L E Y J E F F E R S O N S T PINE AVENUECOMMUNITY PARK CHASE FIELD SENIOR CENTER/ PINE AVENUECOMMUNITY CENTER N J:\ R e q u e s t s M a r c h 2 0 1 5 \ C o m E c o n D e v \ P l a n n i n g \ R I T M 0 0 2 9 3 5 5 _ 2 2 \ P a r k s 8 . 5 x 1 1 - M a p B o o k 2 . m x d PINE AVENUE COMMUNITY PARK Community Park Special Use Area Future Park CJ CJ CJ lll'lli(!ll!Dl,Wl!IR!UII!! COIIDPJi\!IT'I' MIR~ H A R DIN G S T C H E S T N U T A V PA L M A V M A DIS O N S T A L L E Y JE FF E R S O N S T PINE AVENUECOMMUNITY PARK CHASE FIELD N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd CHASE FIELD Community Park Special Use Area Future Park T A M A R A C K A V A N D R E A A V H I G H L A N D D R J A M E S D R J E A N N E P L G L O RIA L N V A L L E Y S T VALLEYJUNIOR HIGHSCHOOL FIELD MAGNOLIAELEMENTARYSCHOOL FIELD N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd VALLEY JUNIOR HIGH SCHOOL FIELD Community Park Special Use Area Future Park A N C H O R W Y HIBIS C U S C R JEFFERSONELEMENTARYSCHOOL FIELD N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd JEFFERSON ELEMENTARY SCHOOL FIELD Community Park Special Use Area Future Park DON RICARDO DR ELCAMINOREAL GLENAV TRAILBLAZERWY CANNONRD ROBERTSONRANCH COMMUNITYPARK - FUTURE N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd ROBERTSON RANCH COMMUNITY PARK - FUTURE Community Park Special Use Area Future Park O C E A N S T G A R FIE L D S T M A DIS O N S T R O O S E V E LT ST A L L E Y LIN C O L N S T O A K A V C H E S T N U T A V C A R L S B A D B L R O O S E V E LT S T VILLAG E C R W A L N U T A V PIN E A V C HIN Q U A PIN A V T Y L E R S T S Y C A M O R E A V W A S HIN G T O N S T M A P L E A V A C A CIA A V C H E R R Y A V J U NIP E R A V H E M L O C K A V R E D W O O D A V S E Q U OIA A V T A M A R A C K A V VILL A G E D R V I L L A G E C R PINE AVENUECOMMUNITYPARK FRAZEE / TAMARACKSTATE BEACHFACILITIES - BLUFFS FRAZEE / TAMARACKSTATE BEACHFACILITIES - BLUFFS N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd FRAZEE / TAMARACK STATE BEACH FACILITIES - BLUFFS Community Park Special Use Area Future Park C O R D O B A PL P A R K D R K E L L Y D R A U R A C R HIL L SID E D R LAGUNARIVERA PARK KELLY ELEMENTARYSCHOOL FIELD N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd KELLY ELEMENTARY SCHOOL FIELD Community Park Special Use Area Future Park PARK D R SEVILLA W Y C O R D O B A P L HIL L SID E D R ALONDRA WY K E L LY D R LAGUNARIVERA PARK KELLY ELEMENTARYSCHOOL FIELD N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd LAGUNA RIVERA PARK Community Park Special Use Area Future Park SAWYER LN CAMINOHILLSDR P R IVATEDY FA R A D A Y AV MILTON RD MORGAN RD LINDSAY DR BRYANTDR MASTERSRD N E W T O N D R ZONE 5 PARKEXPANSION- FUTURE ZONE 5 PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd ZONE 5 PARK EXPANSION - FUTURE Community Park Special Use Area Future Park FARAD AY AV CAMINO HILLS DR NE W T O N D R MILTON RD P R I V A T E D Y ZONE 5 PARKEXPANSION- FUTURE ZONE 5 PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd ZONE 5 PARK Community Park Special Use Area Future Park O RI O N W Y FARADAYAV SKATE PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd SKATE PARK Community Park Special Use Area Future Park WHITMANWY T W A I N A V PRIVATE ST DELANEYCT FARADAY AV PRIVATE DY TOLKIENWYCANNONRD VETERANSMEMORIALPARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd VETERANS MEMORIAL PARK Community Park Special Use Area Future Park C A R L S B A D B L CANNON PARK TERRAMARNORTH BLUFF N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd TERRAMAR NORTH BLUFF Community Park Special Use Area Future Park C A R L S B A D B L C A N N O N R D CANNON PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd CANNON PARK Community Park Special Use Area Future Park C A N N O N R D L O S R O B L E S D R A V E N I D A E N CIN A S E L A R B O L D R CANNON LAKEPARK - FUTURE N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd CANNON LAKE PARK - FUTURE Community Park Special Use Area Future Park C A R C O U N T R Y A L L E Y P A S E O D E L N O R T E CARCOUNTRYPARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd CAR COUNTRY PARK Community Park Special Use Area Future Park CARRILLOWY PASEO POTRERO RANCHORIOCHICO FLYING L C LN R A N C H O V A CADA R A N C H O P A N C H O R A N C H O C A B A L L O VIACONQUISTADOR P A S EO CAZADOR PRIVATE DY POINSETTIALN MELROSE DR LEO CARRILLORANCHHISTORIC PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd LEO CARRILLO RANCH HISTORIC PARK Community Park Special Use Area Future Park HA L I T E P L KYANITEPL POINSE T T I A L N MICA RD ALI C A N T E R DALGA NORTECOMMUNITYPARK N J:\ R e q u e s t s M a r c h 2 0 1 5 \ C o m E c o n D e v \ P l a n n i n g \ R I T M 0 0 2 9 3 5 5 _ 2 2 \ P a r k s 8 . 5 x 1 1 - M a p B o o k 2 . m x d ALGA NORTE COMMUNITY PARK Community Park Special Use Area Future ParkCJ CJ KIWI PL KINGBIRD LN CROSSBILL CT FAIRLEA D A V GADWALL CT PO I N S E T T I A L N A M B R O S IA LN CASSIARD ALEXANDRI CR AV I A R A CO M M U N I T Y PA R K N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd AV I A R A C O M M U N I T Y P A R K Co m m u n i t y P a r k Sp e c i a l U s e A r e a Fu t u r e P a r k □□□~(I P A S E O D E L N O R T E E L D E R C T SCRUB JAY CT T O P M A S T D R FUCHSIA LN K I T E PL TURNSTONE RD LANDS END CT HEATH CT S P A R CT GOLDENEYE VW PLUM TREE RD MERLIN DR BEACON BAY DR KETCH WY HIDDEN VALLEY RD C L O V E R CT CAMINITOMADRIGA L LIGHTHOUSE RD WHITESAIL ST R U S S E L I A CT SCAUP ST W I N D D R IF T D R C A MINITOESTRA D A SEAHORSE CT NEPETA WY MONTIA CT H Y A C I N T H C R OLEANDER W Y POINSETTIACOMMUNITYPARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd POINSETTIA COMMUNITY PARK Community Park Special Use Area Future Park URUBU ST LLAMA ST C ORINTIA ST LLAMA CT A R G O N A U T A S T ELFUERTEST CAZADERODR EL FUERTE PARK /LA COSTA MEADOWSELEMENTARY SCHOOL FIELD N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd EL FUERTE PARK / LA COSTA MEADOWS ELEMENTARY SCHOOL FIELD Community Park Special Use Area Future Park AVIARA OAKSSCHOOL FIELD N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd AVIARA OAKS SCHOOL FIELD Community Park Special Use Area Future Park BORLA PL CADENCIAST CARPA CT CADENCIA PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd CADENCIA PARK Community Park Special Use Area Future Park VENADOST BRAVAST DEL REY AV PUEBLOST C I E L O P L R A N A C T C A LLEDEFUENTE VISTAMAR PASEO VERDE SOLANO ST VISTARICA HATACARD LA COSTA CANYONCOMMUNITY PARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd LA COSTA CANYON COMMUNITY PARK Community Park Special Use Area Future Park MO R A D A S T LEVANTE ST SE R R A N O D R LA COSTA HEIGHTSELEMENTARYSCHOOL FIELD N J:\ R e q u e s t s M a r c h 2 0 1 5 \ C o m E c o n D e v \ P l a n n i n g \ R I T M 0 0 2 9 3 5 5 _ 2 2 \ P a r k s 8 . 5 x 1 1 - M a p B o o k 2 . m x d LA COSTA HEIGHTS ELEMENTARY SCHOOL FIELD Community Park Special Use Area Future Park LA COITA Hl!!!IGHTI · 111,.BIH'ii".M'f BCHOOI!. li=IIELD I I SITIO BAYA CAMINITOSIERR A CALL E C ARA CAS PRIVAT E D Y C O R T E P R O M ENADE C A L L E J A LI S C O LA COSTA AV CALLEMEJOR CAMINOPINTAD O SITIO CALMAR AVENIDAOBER T U R A TERRAZADISOMA AVENIDA NIE V E CALLESANTIAGO C A M IN O D E L O S C O C H ES CORTE VERSO C A L L E B A R C E L O N A CALLETIMITEO CAMINITOMALAGA CALLE LOMA S C A MI NIT O P U E RTO VIA MIRADOR CALLE DEL SUR CAL L E A C E R V O CALLE CANCUNACORTE MARIN C A M IN IT OTIN G O C A M I N I T OB O N A N Z A C A M I N I TO LE O N PASEO LA JOLLA CALLE ODESSA M AVERICK W Y C IR C U L O A D O R N O STAGECOACHCOMMUNITYPARK N J:\RequestsMarch2015\ComEconDev\Planning\RITM0029355_22\Parks 8.5x11 - MapBook2.mxd STAGECOACH COMMUNITY PARK Community Park Special Use Area Future Park Community Development Department | 1635 Faraday Ave. | Carlsbad, CA 92008 | www.carlsbadca.gov FACT SHEET COMMUNITY INTEREST IN A PONTO PUBLIC PARK The City of Carlsbad has received comments from community members expressing a desire for a public park on the existing vacant properties in the general area around Ponto Drive and Avenida Encinas (see image below). There has been different information shared about park needs and whether the city has met the required amount of park space outlined in the city’s Growth Management Plan for the southwest quadrant of the city. City staff provided detailed information at two City Council meetings (held Jan. 26, 2021 an July 13, 2021) about park requirements, city land acquisition limitations and private development rights. The City Council did not direct additional actions related to acquisition of parks land in the vicinity of these private properties. REPORT FINDINGS • The city has met the current Growth Management Plan performance standard for park space in the southwest quadrant. • The vacant sites in the Ponto area are zoned for residential/commercial tourism development -- the property owners have a legal right to develop those vacant sites per the approved 2015 General Plan and Local Coastal Plan, which guide how land can be used and developed in the city. • The city can only acquire private property from a willing seller, at the current fair-market value. One of the parcels has a reported asking price of around $35 million. • Funding for park acquisition, development and maintenance must come from the General Fund, which was not included in the Fiscal Year 2022-23 budget (funds from park-in-lieu fees or Community Facility District #1 fees are restricted and cannot be used). • Citywide voter approval would be required under Proposition H, a Carlsbad-specific law that requires voter approval for any capital improvement projects that cost more than $1 million in general funds, even if the city already has the money on hand. • There are currently 136 residential units planned for one of the sites. Per Senate Bill 330, the city would be required to increase the density of another property within the city to accommodate those 136 residential units if the property was acquired for park space. • The Carlsbad Sea Level Rise Vulnerability Assessment did not identify specific acreages of park or open space land that could be “lost” due to sea level rise. It only identifies areas that have the potential for erosion, flooding or inundation in the future if no actions are taken. Potential vulnerabilities identified along the beach, bluffs, campground and Carlsbad Boulevard will be addressed through future adaptation plans that will establish measures needed to prevent or minimize the loss of land due to sea level rise. • There is a city effort underway (South Carlsbad Coastline Project) to repurpose Carlsbad Boulevard to potentially create more than 60-acres of available space over a 2.7-mile stretch that could be used for bike/pedestrian paths, recreational areas beach access and open space within the southwest quadrant. {city of Carlsbad Community Development CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE Exhibit 2, Attachment 6 Park Standards Benchmarking Analysis Table 1. City of Carlsbad Information Carlsbad Info: Data Source: Total land within the city area (in acres) 25,021 Carlsbad General Plan (2015 Update) pg. 2-7 Total city area (in square miles) 39 Population 116,025 Growth Management Plan Population per square mile 2,975 Acres of land within the city designated for recreation use 2,074 Carlsbad General Plan (2015 Update) pg. 2-7 % of city land area used for P&R 8% Acres of land within the city designated for open space use 6,243 Carlsbad General Plan (2015 Update) pg. 2-7 % of city land area used for open space 25% # of City Community Parks and Special Use Areas 42 Carlsbad City Parks and Rec website Miles of Trails 67 Current Park Acreage 432.4 City Council action of July 26, 2022 – finding of compliance with Growth Management Plan/Citywide Facilities and Improvements Plan Current Park Acreage plus Planned Park Acreage 519.7 City Council action of July 26, 2022 – finding of compliance with Growth Management Plan/Citywide Facilities and Improvements Plan Table 2. National Park and Recreation Association (NRPA) Comparison1 Data City Residents per park NPRA City of Carlsbad 2,830 Takeaway: The City of Carlsbad performs better than the median CA city, i.e., provides more parks for its population. NPRA Median of CA cities with >2,500 people per sqm 4,149 1 Based on NRPA 2020 Agency Performance Report for CA agencies with jurisdictions greater than 2,500 people per sq. mile. Results yielded 20 agencies for park number and acreage comparisons, and 21 agencies for operating expenditures comparison. CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE Exhibit 2, Attachment 6 2 Table 3. Trust for Public Lands Comparisons Note: Data obtained from the Trust for Public Lands 2022 ParkServe database may not match the calculations provided by the National Park and Recreation Association or the City of Carlsbad. Number of parks, park acreage, and percent of city land used for parks are all based on the Trust for Public Lands data and may include or omit elements that differ from other data sources. Despite differences with the other data sources, numerical data has been maintained as-is in order to best relate to other Trust for Public Lands city comparisons. 3.1 Total amount of Park Acreage Data 2020 Census Population Park Acreage Acres per 1,000 residents TPL City of Carlsbad 114,411 1,162.612 10.16 TPL City of Encinitas 62,967 289.65 4.60 TPL City of Oceanside 175,694 2,141.46 12.19 TPL City of San Marcos 96,219 653.89 6.80 TPL City of Vista 100,659 459.70 4.57 TPL City of Poway 49,780 3,589.73 72.11 TPL City of Chula Vista 268,779 839.55 3.12 TPL City of San Diego 1,414,545 43,569.12 30.80 3.2 Percentage of Land within the City designated for Recreation Data % of land within the city designated for recreation use % difference TPL City of Carlsbad 14% TPL City of Encinitas 12% -14% TPL City of Oceanside 12% -14% TPL City of San Marcos 7% -50% TPL City of Vista 6% -57% TPL City of Poway 18% 29% TPL City of Chula Vista 8% -43% TPL City of San Diego 19% 36% 2 This acreage is higher than the City of Carlsbad park acres (432.4) that count toward the city’s Growth Management park standard. + + + CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE Exhibit 2, Attachment 6 3 Notes about the benchmarking data sources: National Recreation and Park Association (NRPA): https://www.nrpa.org/ The NRPA is a national organization whose Park Metrics research provides data for comparison across agencies and communities around the United States. Data is compiled from nearly 1,100 park and recreation agencies, and can be narrowed down to more focused areas such as geography, budget range, jurisdiction population, jurisdiction density, and more. Information is collected via submission responses per agency, so inclusivity details may vary from agency to agency. This is an important note when comparing specific cities. NRPA is best used to understand general trends across large geographies. Trust for Public Land (TPL): https://www.tpl.org/ The TPL ParkServe Database includes 14,000 cities, towns, and communities. Population estimates are obtained from Esri’s 2021 U.S. demographic estimates. Information about park number, acreage, amenities/facilities, etc. is either city-reported information or is obtained via available resources (municipal websites, county/state GIS data, and satellite imagery) with requested verification by the respective city. Information is updated monthly upon verification. In this dataset, “parks” are defined as publicly owned local, state, and national parks, trails, and open space; school with joint-use agreement with the local government; or privately-owned parks that are managed for full public use. Examples TPL ParkServe does not include parks in gated communities, private golf courses, private cemeteries, school parks/playgrounds without active joint-use agreements, nor zoos, museums, or professional sports stadiums. CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE Exhibit 2, Attachment 6 4 Development Impact Fees per City City of Carlsbad City of Oceanside City of San Marcos Fee Applicable to Residential Subdivisions Only: Single Family Detached & Duplex (0-lot line or attached wall) Attached Residential (4 units or less) Attached Residential (more than 4 units) Mobile Homes NE SE SW (per unit) 5,728 4,804 4,636 3,696 ~ I Current Estimate Fee or Calculate Formula NW (per unit) 7,649 6,414 6,190 4,934 ~ ~ Public Facility (Residential) $2.621 per unit Reso. i I 5-R0638-I Ord # 91-09 Public Facility $.902/ sq. fl. or $902/thousand sq. Rcso.115-R0638-1 Ord » 91-09 (Commercial/Industrial) ft. Parks (Residential only) $4,431 per unit Reso. I 15-R0638-1 Ord » 91-09 PUBLIC FACILITIES FEES (PFF) The City o' San Marcos Public Facilities Fees finance the construction of certain City facilities. Approved pursuant to Council Resolution 2008-70~7. f{>(I category Single Multi-commercial Industrial Light Business Office Family Family (per Acre) (per Acre) Industrial Park (per Dwelling Dwelling (per Acre) (per Acre) {Per (per Acre) Unit) Unit) Circulation $6,747 $4,048 $125,914 $53,974 $31,427 $92,086 $87,959 streets SR-78 $3,240 $1,923 $59,251 $25,632 $18,12'1 $'13,732 $50,730 Interchanges NPDES $7)1 $7)1 $6117 5687 S687 $687 S6R7 Technology S,,'1 S,,'1 $HS $1~8 $1'18 $1~8 $1'18 Improvements Parks S6,251 $6,251 -0--0--0--0--0- Habitat $103 $103 $198 $198 $198 $198 $198 Conservation Subtotal 516,570 512,590 S186,201 S80,639 S50.584 S136,851 S139,722 Drainage Drainage Fees assessed based on Table below CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE Exhibit 2, Attachment 6 5 City of Encinitas Parkland Acquisition and Park Development Fees Open Space Land Acquisition Trail Development Community Facilities Fees TABLE A General Plan Designation Zone Park Acquisition Fee Per DU ' Park Development Total Fee Fee Per DU Per DU Residential 0.125-0.25 DU/Ac) R $6,792.00 $3,959.00 $10.751.00 Residential 0.25-0.5 DU/Acl RR $6,792.00 $3,959.00 $10.751.00 Residential 0.5-1.0 DU/Acl RRl $6,792.00 $3,959.00 $10,751.00 Residential 1 .0-2.0 DU/Ac) RR2 $6,792.00 $3,959.00 $10.751.00 Residential 2.0-3.0 DU/Ac) R3 $6,792.00 $3,959.00 $10.751.00 Residential 3.0-5.0 DU/Ac) R5 $6,792.00 $3,959.00 $10.751.00 Residential 5.0-8.0 DU/Ac) RB $6,792.00 $3,959.00 $10,751.00 Residential 8.0-11 .o DU/Acl Rl l $4,536.00 $2,644.00 $7.180.00 Residential 11.0·15.0 DU/Acl R15 $4,536.00 $2,644.00 $7.180.00 Residential 15.0-25.0 DU/Ac) R25 $4,536.00 $2,644.00 $7,180.00 Mobile Home Park MHP $4,320.00 $2,518.00 $6,838.00 Fees per Unit or Development -Open Space Land Acquisition Development Type Zone Dev Units (1) Fune Pop per Unit (2) Equity per Capita (3) Fee per Unit (4) Residential 0.125-0.25 DU/Acl R DU 2.83 $154.88 $.438_1)() Residential 0.25-0.5 DU/Acl RR DU 2.83 $154.88 $438_1)() Residential o.s.1.0 DU/Ac RR1 DU 2.83 $154.88 $438.00 Residential 1.0-2.0 DU/Ac RR2 DU 2.83 $154.88 $438.00 Residential 2.0-3.0 DU/Ac R3 DU 2.83 $154.88 $438.00 Residential 3.0-5.0 DU/Ac Rs DU 2.83 $154.88 $438.00 Residential 5.0-8.0 DU/Ac RB DU 2.83 $154.88 $438.00 Residential 8.0-11.0 DU/Acl Rl l DU 1.89 $154.88 $293.00 Residential 11.0.15.0 DU/Acl R15 DU 1.89 $154.88 $293.00 Residential 15.0.25.0 DU/Ac) R25 DU 1.89 $154.88 $293.00 Mobile Home Park MHP DU 1.80 $154.88 $279.00 Fees per Unit ol Development -Trail Development Development Type Zone Dev Fune Pop per Equity per Capita Fee per Unit Units m Unit 121 (3) (4) Residential (0.125-0.25 DU/Ac) R DU 2.83 S59.51 $168.00 Residential (0.25-0.5 DU/Ac) RR DU 2.83 $59.51 $168.00 Residential (0.5-1.0 DU/Ac RR1 DU 2.83 S59.51 $168.00 Residential (1.0-2.0 DU/Ac RR2 DU 2.83 $59.51 $168.00 Residential 12.0-3.0 DU/Ac R3 DU 2.83 S59.51 $168.00 Residential (3.0-5.0 DU/Ac RS DU 2.83 $59.51 $168.00 Residential (5.0-8.0 DU/Ac RB DU 2.83 $59.51 $168.00 Residential /8.0-11.0 DU/Ac) R11 DU 1.89 $59.51 $112.00 Residential 111.0-15.0 DU/Acl R15 DU 1.89 $59.51 $112.00 Residential 115.0-25.0 DU/Acl R25 DU 1.89 $59.51 $112.00 Mobile Home Park MHP DU 1.80 $59.51 $107.00 Fees per Unit of Development -Community Facilities Fees Development Type Zone Dev Fune Pop per Equity per Capita Fee per Unit Units (1) Unit (2) (3) (4) Residential (0.125-0.25 DU/Ac) R DU 2.80 $204.15 $571.00 Residential (0.25-0.5 DU/Ac) RR DU 2.80 $204.15 $571.00 Residential (0.5-1.0 DU/Ac RRl DU 2.80 $204.15 $571.00 Residential (1.0-2.0 DU/Ac RR2 DU 2.80 $204.15 $571.00 Residential (2.0-3.0 DU/Ac R3 DU 2.80 $204.15 $571.00 Residential (3.0-5.0 DU/Ac RS DU 2.80 $204.15 $571.00 Residential (5.0-8.0 DU/Ac RB DU 2.80 $204.15 $571.00 Residential (8.0-11.0 DU/Ac) R11 DU 2.20 $204.15 $449.00 Residential (11 .0-15.0 DU/Ac) R15 DU 2.10 $204.15 $428.00 Residential (15.0-25.0 DU/Ac) R25 DU 2.10 $204.15 $428.00 Mobile Home Park MHP DU 1.90 $204.15 $387.00 CARLSBAD TOMORROW - GROWTH MANAGEMENT CITIZENS COMMITTEE Exhibit 2, Attachment 6 6 City of Vista City of Poway City of Chula Vista Park Fee (Effective (Effective 8/14/2020) 8/14/2021) Single Family $7,951 .56 $8,086.54 Multi-Family (per dwelling unit) $7,901.64 $8,035.77 Mobile Home $5,350.23 $5,441.05 a. Traffic and Parks Proposed Impact Fees per Unit of Develooment IExcludina Water and Sewer Fees) b Developmenl Type Development Units 1 Traffic Mitigation Park Fees Residential, Rural DU $2,095 $4,562 Residential, Single-Family DU $2,079 $4,562 Residential, Multi-Family DU $2,056 $3,594 Residential, Mobile Home DU $2,044 $3,318 Commercial KSF $3,327 Light Industrial KSF $1,386 lnduslrial Park KSF $2,133 1 Units of Development: DU = dwelling unit; KSF = 1,000 gross square feet of building area Habitat Mitigation In-Lieu Fee $17,000 Per Acre PARKLAND ACQUISITION & DEVELOPMENT The Parkland Acquisition and Development {PAD) fee consists of two fee components: land acquisition and park development. Applicable: Citywide. Parkland acquisition fees vary between eastern and western Chula Vista, as divided by 1-805. Development fees are consistent citywide. Single Family. per dwelling unit Acquisition, west of 1-805 ................................ $4,994 Acquisition, east of 1-805 ............................... $12,676 Development, citywide .................................... $8,690 Total single family fee, west of I-80S ............ $13,684 Total single family fee, east of I-80S ............. $21,366 Multifamily. per dwelling unit Acquisition, west of 1-805 ................................ $3,707 Acquisition, east of 1-805 ................................. $9,408 Development, citywide .................................... $6,450 Total multifamily fee, west of 1-805 ............. $10,157 Total multifamily fee, east of 1-805 .............. $15,858 Mobile Home, per unit Acquisition, west of 1-805 ................................ $2,337 Acquisition, east of 1-805 ................................. $5,932 Development, citywide .................................... $4,067 Total mobile home fee, west of I-80S ............ $6,404 Total mobile home fee, east of I-80S ............. $9,999 From:Lance Schulte To:Growth Management Committee; Michele Hardy; Council Internet Email; City Clerk; Kyle Lancaster; Eric Lardy; "Smith, Darren@Parks"; "Homer, Sean@Parks"; "Moran, Gina@Parks"; Boyle, Carrie@Coastal; "Prahler, Erin@Coastal"; "Ross,Toni@Coastal" Cc:info@peopleforponto.com Subject:RE: Public Input for 2022-Oct CTGMC regarding the 9/22/22 meeting & to be provided to the Carlsbad City Council andParks, Planning and Beach Preservation Commissions as citizen communications Date:Thursday, September 29, 2022 6:33:08 AM TYPO Correction to Public Input. I sincerely apologize for a typo in the public input email below that directly relates to the 2016-2017 CA Coastal Commissions direction to the regarding Ponto Coastal Recreation (i.e. Public Park) and Low-cost Visitor accommodation land use issues. This also directly relates to the CTGMC’s work in creating new Park and Open Space Standards that will alter the General Plan. The Section # is 2.7. The correct page reference to the General Plan is page 2-27, and which says: “2.7 Special Planning Considerations In several areas of the city, special planning considerations and/or objectives apply. Section 2.9 contains goals and policies that address the areas described below: Coastal Zone Planning The California Coastal Act regulates all development within the state-designated Coastal Zone. The zone extends through the length of the city, and covers approximately one-third of the city’s land area, as shown in Figure 2-2. The Coastal Act requires that individual jurisdictions adopt local coastal programs (LCP) to implement the Coastal Act. Carlsbad’s LCP consists of a separate land use plan document containing separate land use policies and an implementation plan, which primarily consists of the city’s Zoning Ordinance, as well as portions of the Grading and Drainage Ordinance and Building Codes and Regulations that are applicable to storm water management and grading; master and specific plans applicable to areas in the Coastal Zone are also part of the LCP Implementation plan. Development in the Coastal Zone must comply with the LCP in addition to the General Plan. The city’s LCP Land Use Plan will be updated consistent with this General Plan. However, to take effect, the LCP must be certified by the Coastal Commission as well as adopted by the city. Until such time that this occurs, the existing (as of 2013) LCP must be adhered to. Although the LCP covers all of Carlsbad’s Coastal Zone, the Coastal Commission retains coastal development permit authority within its original permit jurisdiction and deferred certification areas. Carlsbad continues to pursue LCP certification in the deferred certification areas in order to transfer permit authority to the city and streamline development approval. Within the Coastal Zone, no discretionary permit shall be issued by the city unless found to be consistent with the General Plan and the LCP. In the event of conflict between the provisions of the General Plan and LCP Land Use Plan, the terms of the LCP Land Use Plan shall prevail.” I sincerely apologize for this typo in the email below. Lance Schulte From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Monday, September 26, 2022 11:45 AM To: 'committee@carlsbadca.gov'; 'Michele Hardy'; 'council@carlsbadca.gov'; 'City Clerk'; 'Kyle Lancaster'; 'EricLardy'; 'Smith, Darren@Parks'; 'Homer, Sean@Parks'; 'Moran, Gina@Parks'; 'Carrie Boyle'; 'Prahler,Erin@Coastal'; 'Ross, Toni@Coastal'Cc: 'info@peopleforponto.com'Subject: Public Input for 2022-Oct CTGMC regarding the 9/22/22 meeting & to be provided to the CarlsbadCity Council and Parks, Planning and Beach Preservation Commissions as citizen communicationsImportance: High Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks, Planning and Beach Preservation Commissions, and CA Coastal Commission and CA State Parks: I apologize for the directness of this email; but standing up for truth and facts can only be done with directness. It is also important that the CA Coastal Commission knows if CA Coastal Act and Coastal Land Use issues are not being truthfully communicated by the City to Carlsbad Citizens. The CTGMC is creating Council recommendations for new land use plans regarding Park and Open Space in CA Coastal Zone in Carlsbad. Coastal Recreation (i.e. Public Parks), protection of Coastal Habitats, and providing State Park Coastal Camping access are high-priorities of the CA Coastal Act; and are considered High-Priority land uses that need to forever adequately provided Carlsbad’s Proposed Local Coastal Program Amendment & in CTGMC’s in creating new Park & Open Space Standards in Carlsbad’s Coastal Zone. I was deeply troubled that on 9/22/22 Jeff Graham, Carlsbad Community Development Director said what appears to be a misstatement of facts to the CTGMC regarding the current Local Coastal Program (LCP) and City Proposed Local Coastal Program Amendment AND Jeff’s failure to disclose the CA Coastal Commission’s (CCC) very clear communication to the City on 2016-2017 on what is the current and possible land use plan for Ponto. Carlsbad’s Ponto Vision Plan-General Plan-Master Plans-Zoning Codes are not valid/approved until the CA Coastal Commission Certifies them as being consistent with the CA Coastal Act and Policies. CA Coastal Act status is a primary land use fact and Carlsbad’s General Plan clearly states this on page Section 2-7. Please Read the paragraph on General Plan page Section 2-7. Jeff, as I heard it, made a false statement to the CTGMC that ALL the land use planning at Ponto Planning Area F was already completely done and no changes to can/need to be made. This is clearly false as the City is currently proposing an LCP Amendment to the CCC that includes significant changes to Ponto Planning Area F land use policy and zoning standards. Jeff is misrepresenting facts to Citizens, like what was done during the developers/City Ponto Vision Plan and General Plan Update. City staff misrepresentation of the facts to Citizens corrupts the Public Input Process, and in itself is a violation of the CA Coastal Act. This misrepresentation of facts is why decision making at Ponto has been so messed up. The City by withholding key Ponto facts from Citizens seems to be trying to mislead Citizens so developer proposed land use changes can be pushed through. Over 50 Official Carlsbad Public Records Requests and the data/lack of data the City provided seem to support this concern about honesty. PLEASE READ the 2 Attached Data Files! To refute Jeff’s apparent inaccurate statement to the CTGMC on 9/22/22, The CA Coastal Commission has provided very clear communication to the City on the future potential Coastal land use plan at Ponto: 7/3/17 CCC letter to City of Carlsbad Staff on the City’s proposed land use changes at Planning Area F. City Staff only for the 1st time provided this to City Council on 1/28/20: “The existing LUP includes policies that require certain visitor-serving developments and/or studies relevant to the Ponto/Southern Waterfront area. For example, Planning Area F requires the city and developer to "consider and document the need for the provision of lower cost visitor accommodations or recreational facilities (i.e. public park) on the west side of the railroad. This is an issue that the San Pacifico HOA community group is raising in regards to the Shopoff/Ponto development proposal, and this study should be undertaken as a part of the visitor serving use inventory analysis described above. If this analysis determines that there is a deficit of low cost visitor accommodations or recreation facilities in this area, then Planning Area F should be considered as a site where these types of uses could be developed.” 8/16/2017 CCC email to Carlsbad Citizens said: “The City is currently undertaking a comprehensive update to their LCP funded in part through a CCC grant. As a part of this process the City will be consolidating all previous LCP segments into a single, unified LCP. The City has received direction from both the Commission (May 2016 CCC hearing) and Commission staff, that as a part of this update the City shall undertake an inventory of visitor serving uses currently provided within the City’s Coastal Zone which will then serve to inform updates to the City’s land use and zoning maps as necessary. This inventory could have future implications for the appropriate land use and zoning associated with the Ponto area.” The CTGMC should not use false statements (9/22/22), excuses and dubious work-arounds to try to wiggle out of the responsibility to properly address the clear and obvious current higher-residential densities, and significant Park and Open Space shortfalls at Ponto/Coastal South Carlsbad. The CTGMC, Carlsbad City Council and Parks, Planning & Beach Preservation Committees it seems have an ethical, moral and generational responsibility to correct the well documented Park & Open Space shortfalls (City’s past land use planning & Growth Management Plan Standard mistakes) at Ponto, and Coastal land use plan for more loss of these land uses due to sea level rise. Thank you, Lance Schulte From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Friday, December 10, 2021 11:36 AMTo: 'City Clerk'Cc: CityCouncil@carlsbadca.gov; Carrie Boyle; Erin.Prahler@coastal.ca.gov; Ross, Toni@Coastal;info@peopleforponto.comSubject: FW: 12-13-2021 Special City Council Meeting Agenda Dear City Council: Since 2017 extensive Carlsbad Citizen input/desires (over 5,000 emails/petitions, and at many budget and Council meetings) to you has requested Ponto Park. That Citizen input/desires is based on City documented facts. Again, we ask you to start considering the facts and the overwhelming Citizens’ input/desires submitted to you over the past 4+ years. Attached are some of the relevant files we request you again receive as public input and read and consider on 12/13/21 regarding your CITY COUNCIL STRATEGIC PLAN. Thank you and Happy Holidays, Lance Schulte CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. From:Lance Schulte To:Eric Lardy; Faviola Medina Cc:Michele Hardy Subject:FW: Ponto Park & Open Space public input delivery - RE: Meeting Follow-Up Date:Tuesday, September 27, 2022 7:22:13 AM Attachments:image002.pngProtect Ponto Petition Letter.msgProtect Ponto Petition Letter.msgProtect Ponto Petition Letter.msg Faviola & Eric: We received 2 more Citizen petitions for Ponto Park since 9/24/22. So our count is 142 for the CTGMC Park/Open Space/Ponto Park issue so far. Lance From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Sunday, September 25, 2022 6:56 AMTo: 'Faviola Medina'; 'Eric Lardy'Cc: Carrie Boyle (carrie.boyle@coastal.ca.gov); 'Prahler, Erin@Coastal'; Ross, Toni@Coastal(Toni.Ross@coastal.ca.gov); 'info@peopleforponto.com'Subject: Ponto Park & Open Space public input delivery - RE: Meeting Follow-Up Thank you both for our upcoming meeting to assure public input is being completely and timely delivered as addressed to City of Carlsbad Council-Commissions-Committees by City staff. As part of our discussion I counted 140 emailed petitions (example of one attached) to the Carlsbad CTGMC, City Council, and Planning-Parks Commissions from 9/20/22 5:32pm through to 9/24/22 9:30pm. Getting confirmation that all these petitions were timely delivered as addressed is appreciated. Citizens need to know their input is being delivered. I think you both are making strides to improve and this is much appreciated. Your willingness to meet is an reflection of that effort. Thanks, Lance From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Friday, September 23, 2022 5:13 AMTo: 'Faviola Medina'Subject: RE: Meeting Follow-Up Thanks that would be great. Thanks for your considerate follow-up! Lance From: Faviola Medina [mailto:Faviola.Medina@carlsbadca.gov] Sent: Thursday, September 22, 2022 3:53 PMTo: Lance SchulteCc: Eric LardySubject: Meeting Follow-Up Good Afternoon Lance, Eric and I are both available to meet on Tuesday, September 27 at 8 a.m. Would you be available during this time? Please advise, Faviola Medina, CMC City Clerk Services Manager Office of the City Clerk 1200 Carlsbad Village Drive Carlsbad, CA 92008 P: 442-339-5989 | faviola.medina@carlsbadca.gov | www.carlsbadca.gov Facebook | Twitter | You Tube | Flickr | Pinterest | Enews|P Consider the environment before printing this e- mail Confidentiality Notice: Please note that email correspondence with the City of Carlsbad, along with any attachments, may be subject to the California Public Records Act, and therefore may be subject to disclosure unless otherwise exempt. CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. City of Carlsbad Connect, ith u Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Wednesday, September 21, 2022 1:00:35 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsI really hope that the committee really considers ALL of the yearsand years of the south Carlsbad residents requests and theirresearch of why this piece of land would be better served byproviding space for all of Carlsbad as well as San Diego countyand our tourist to enjoy forever. What a legacy this would leavethe city council to keep truly one of the very LAST piece ofproperty so close to our beautiful ocean for everyone to enjoy! Iam a 60 year old resident who really have seen growth and thisis very important to me. NameKarie Galindo Emailkdgalindo@roadrunner.com PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Sunday, September 25, 2022 9:21:46 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsPinto Park is so needed in our community. Please make ithappen NameCherie Copsey Emailcheriecopsey@hotmail.com CityCarlsbad State PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Sunday, September 25, 2022 9:28:05 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsPlease consider the People's concerns! NameMichael Armstrong Emailmarmstrong@hrec.com CityCarlsbad StateCalifornia PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. From:Lance Schulte To:Growth Management Committee; Michele Hardy; Council Internet Email; City Clerk; Kyle Lancaster; Eric Lardy; "Smith, Darren@Parks"; "Homer, Sean@Parks"; "Moran, Gina@Parks"; Boyle, Carrie@Coastal; "Prahler, Erin@Coastal"; "Ross,Toni@Coastal" Cc:info@peopleforponto.com Subject:Public Input for 2022-Oct CTGMC regarding the 9/22/22 meeting & to be provided to the Carlsbad City Council andParks, Planning and Beach Preservation Commissions as citizen communications Date:Monday, September 26, 2022 11:45:00 AM Attachments:Updated 2020 Dec 2 - Planning Area F existing LCP-LUP & CCC direction.pdfSea Level Rise and Carlsbad DLCP-LUPA planned loss of OS at Ponto - 2022 (2).pdf Importance:High Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks, Planning and Beach Preservation Commissions, and CA Coastal Commission and CA State Parks: I apologize for the directness of this email; but standing up for truth and facts can only be done with directness. It is also important that the CA Coastal Commission knows if CA Coastal Act and Coastal Land Use issues are not being truthfully communicated by the City to Carlsbad Citizens. The CTGMC is creating Council recommendations for new land use plans regarding Park and Open Space in CA Coastal Zone in Carlsbad. Coastal Recreation (i.e. Public Parks), protection of Coastal Habitats, and providing State Park Coastal Camping access are high-priorities of the CA Coastal Act; and are considered High-Priority land uses that need to forever adequately provided Carlsbad’s Proposed Local Coastal Program Amendment & in CTGMC’s in creating new Park & Open Space Standards in Carlsbad’s Coastal Zone. I was deeply troubled that on 9/22/22 Jeff Graham, Carlsbad Community Development Director said what appears to be a misstatement of facts to the CTGMC regarding the current Local Coastal Program (LCP) and City Proposed Local Coastal Program Amendment AND Jeff’s failure to disclose the CA Coastal Commission’s (CCC) very clear communication to the City on 2016-2017 on what is the current and possible land use plan for Ponto. Carlsbad’s Ponto Vision Plan-General Plan-Master Plans-Zoning Codes are not valid/approved until the CA Coastal Commission Certifies them as being consistent with the CA Coastal Act and Policies. CA Coastal Act status is a primary land use fact and Carlsbad’s General Plan clearly states this on page 2-7. Please Read the paragraph on General Plan page 2-7. Jeff, as I heard it, made a false statement to the CTGMC that ALL the land use planning at Ponto Planning Area F was already completely done and no changes to can/need to be made. This is clearly false as the City is currently proposing an LCP Amendment to the CCC that includes significant changes to Ponto Planning Area F land use policy and zoning standards. Jeff is misrepresenting facts to Citizens, like what was done during the developers/City Ponto Vision Plan and General Plan Update. City staff misrepresentation of the facts to Citizens corrupts the Public Input Process, and in itself is a violation of the CA Coastal Act. This misrepresentation of facts is why decision making at Ponto has been so messed up. The City by withholding key Ponto facts from Citizens seems to be trying to mislead Citizens so developer proposed land use changes can be pushed through. Over 50 Official Carlsbad Public Records Requests and the data/lack of data the City provided seem to support this concern about honesty. PLEASE READ the 2 Attached Data Files! To refute Jeff’s apparent inaccurate statement to the CTGMC on 9/22/22, The CA Coastal Commission has provided very clear communication to the City on the future potential Coastal land use plan at Ponto: 7/3/17 CCC letter to City of Carlsbad Staff on the City’s proposed land use changes at Planning Area F. City Staff only for the 1st time provided this to City Council on 1/28/20: “The existing LUP includes policies that require certain visitor-serving developments and/or studies relevant to the Ponto/Southern Waterfront area. For example, Planning Area F requires the city and developer to "consider and document the need for the provision of lower cost visitor accommodations or recreational facilities (i.e. public park) on the west side of the railroad. This is an issue that the San Pacifico HOA community group is raising in regards to the Shopoff/Ponto development proposal, and this study should be undertaken as a part of the visitor serving use inventory analysis described above. If this analysis determines that there is a deficit of low cost visitor accommodations or recreation facilities in this area, then Planning Area F should be considered as a site where these types of uses could be developed.” 8/16/2017 CCC email to Carlsbad Citizens said: “The City is currently undertaking a comprehensive update to their LCP funded in part through a CCC grant. As a part of this process the City will be consolidating all previous LCP segments into a single, unified LCP. The City has received direction from both the Commission (May 2016 CCC hearing) and Commission staff, that as a part of this update the City shall undertake an inventory of visitor serving uses currently provided within the City’s Coastal Zone which will then serve to inform updates to the City’s land use and zoning maps as necessary. This inventory could have future implications for the appropriate land use and zoning associated with the Ponto area.” The CTGMC should not use false statements (9/22/22), excuses and dubious work-arounds to try to wiggle out of the responsibility to properly address the clear and obvious current higher-residential densities, and significant Park and Open Space shortfalls at Ponto/Coastal South Carlsbad. The CTGMC, Carlsbad City Council and Parks, Planning & Beach Preservation Committees it seems have an ethical, moral and generational responsibility to correct the well documented Park & Open Space shortfalls (City’s past land use planning & Growth Management Plan Standard mistakes) at Ponto, and Coastal land use plan for more loss of these land uses due to sea level rise. Thank you, Lance Schulte From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Friday, December 10, 2021 11:36 AMTo: 'City Clerk'Cc: CityCouncil@carlsbadca.gov; Carrie Boyle; Erin.Prahler@coastal.ca.gov; Ross, Toni@Coastal;info@peopleforponto.comSubject: FW: 12-13-2021 Special City Council Meeting Agenda Dear City Council: Since 2017 extensive Carlsbad Citizen input/desires (over 5,000 emails/petitions, and at many budget and Council meetings) to you has requested Ponto Park. That Citizen input/desires is based on City documented facts. Again, we ask you to start considering the facts and the overwhelming Citizens’ input/desires submitted to you over the past 4+ years. Attached are some of the relevant files we request you again receive as public input and read and consider on 12/13/21 regarding your CITY COUNCIL STRATEGIC PLAN. Thank you and Happy Holidays, Lance Schulte CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. Page 1 of 5 City Staff’s comparison of Ponto Planning Area F’s existing v. Carlsbad proposed LCP LUP Policy below is not fully correct. The table below is from City of Carlsbad. The last paragraph of the Existing LCP notes “prior to any planning activity”. This “prior to any planning activity” was newer done as documented by official Carlsbad Public Records Requests 2017-260, 2017-262, R000930-072419, R001280-021720, and R001281-02170. So the City’s “General Plan update” (of just the land use map) was done in violation of the Existing LCP LUP Policy – one of the City’s Ponto planning mistakes. Citizens repeatedly asked in the above official Public Records Request to see the City’s evidence of City compliance with Planning Area F’s Existing LCP LUP Policy. The City responded with: “… you are asking the City to answer questions about information not found in the documents of existence provided. The City is unable to assist you in this manner. … ” There is no evidence that the City during both the Ponto Vision Plan and General Pan Update planning efforts informed Citizens of Planning Area F’s Existing LCP LUP Policy. Hiding information prevented Citizens knowing about the policy and providing informed input. No evidence shows the City ever complied with the requirements of the Policy. The Ponto Vision Plan and General Plan Update planning efforts were thus flawed, and counter to the LCP and CA Coastal Act. As noted in 1-5 below, the CCC has noted these mistakes dating back to 2010 with the “Ponto Beachfront Village Vision Plan” and 2015 General Plan map, and is seeking to correct them in the 2016 and 2017 communications to the City. Also some of the City’s own documents verify these facts. CCC direction on why Draft LCP description is not accurate: During the Jan 28, 2020 City Council Meeting (item #14), Carlsbad City staff for the first time as a side- bar comment admitted the City made some ‘Ponto planning errors’ going back over 15 years. Those City planning errors where first called out when the CA Coastal Commission (CCC) denied Carlsbad’s Ponto Beachfront Village Vision Plan (the referenced foundation for Carlsbad’s 2015 General Plan Update) in HOW THE EXISTING CITY OF CARI.SSAD LOCAL COASTAL PROGRAM (LCP) POllOES ARE ADDRESSED IN THE DRAFT LOCAL COASTAL PiROGRAM UPDATE Row EXISTING LCP POLICIES HOW DRAFT LCP ADDRESSES EXJSTJNG l!.CP POLICIES WEST BATIQUITOS LAGOON/SAMMIS PROPERTIES SEGMENT 10. Plannii,g Area F Planning Area Fis located at the far northwest corner of the Master Plan area west of the AT&SF Railway right·of--way, This Plannlne Area has a gross area of 11 acres and a net dewlopable area of 10.7 acres. Plannii,g Area F ca:rries a Non-Residential Reserve (NRR) General Plan designation. As part of the General Pian update, the Coastal Planning Area Fis an .. unplanned" area, tor which land uses will be determined at Commission approved residential and general a later date when more specific planning is c.arried out for areas west of the commercial land use designations on the LCP land ranrooo rlght~of·wav. A future Major Master Pl..tn Amendment will be required use map. prior to further de,velopment approvals for-Planning Area F, and shall include an This policy is updat«I to be oonsistent with the land LCP Amendment with associated en\lironmental review, if determined necessary. use map designations and the Ponto Beachfront 282 The intent of the NRR designation is not to limit the range of potential future uses Vitta.ge Vision Plan. See draft LCP policy LCP-2-P.20.A entirely to non-residential, however, since the Cit;y's current general plan does and 8. not contain an "u.nplanncd" designation, NRR was determined to be appropriate Regarding the need 10< lower oost visitor at this time. In the future, if tht' Local Coastal Program Amendment has not been accommodations or recreational facilities west of tha processed, and the City develops an .,unplanned" General Plan desi.gnation1 then railroad1 analysis and documentation wiU be this site would likely be redesignated as "unptannect.·• Future uses could include, provided in the staff report to the Ptannins but are not limited to: commercial, residential, office, and other uses, St.Jbjec.t to Commiss.ion. future review and approval, As parl of any future planning t'ffort.. tha City and Developer must consider and document the need for the provision of lower cost visitor accommodations or recreational facilit ies (i.e. public park) on the west side of the railroad. Page 2 of 5 2010 in part due to the City’s mistake. Following are 4 documents that conflict with the above City Staff interpretation of how the Draft LCP addresses Existing LCP Polies. 1) The CCC in denying in 2010 the Ponto Vision Plan (the foundation for Carlsbad’s 2015 General Plan Update at Ponto) specifically said with direct reference to Ponto Planning Area F: “Currently, this area [Planning Area F] has an Unplanned Area land use designation. In order to facilitate any type of development in this portion of the Ponto area, an LCP amendment modifying the land use will have to be brought forward to the Commission for review and approval.” “… the Commission would reject such proposed uses because there has been no evidence presented that would support the elimination of these [Planning Area F] areas for some lower cost overnight accommodations or public recreational amenities in the future. The Commission's past action of the Poinsettia Shores Master Plan specifically called for such an assessment, and none has been submitted to date. The concerns related to the lack of lower cost overnight accommodations in Area F (ref. Exhibit #7) are further discussed in the findings later.” “City is inadvertently sending a message to potential developers that 1) the identified development (townhouses) is the primary type of use the City will support, or 2) that development type is consistent with the current land use and zoning designations. Neither of those assumptions is correct. As the previously certified Poinsettia Shores Master Plan states, any type of development at this location would first require an LCP amendment to establish the land use and zoning, which would have to be certified by both the City and the Coastal Commission. Additionally, the Master Plan further states that some component of the development at this location must consider the need for the provision of lower cost accommodations or recreational facilities.” “While residential use is one of the land uses listed for this area in the Poinsettia Shores Specific Plan, it may not be the most appropriate designation. As previously stated, the project will at least need to consider the incorporation of some kind of lower cost accommodations, and any proposed zoning designation for the site will have to be found consistent with the policies contained in the Poinsettia Shores Master Plan. Furthermore, the standard of review for any change to the current land use designation is the Coastal Act, and thus will also have to be found consistent with all its applicable policies. Recently, the Commission has become concerned with the lack of lower-cost accommodations statewide. Thus, the establishment of a residential land use at this location may not be what is ultimately determined to be certified as consistent with the Poinsettia Shores Master Plan, or the Coastal Act.” “B. High-Priority Uses - Lower Cost Visitor Accommodations in ‘Area F’: The Coastal Act has numerous policies promoting public access to the beach and state: Section 30210 - In carrying out the requirement of Section 4 of Article X of the California Constitution, maximum access, which shall be conspicuously posted, and recreational opportunities Page 3 of 5 shall be provided for all the people consistent with public safety needs and the need to protect public rights, rights of private property owners, and natural resource areas from overuse. Section 30213 - Lower cost visitor and recreational facilities shall be protected, encouraged, and, where feasible, provided. Developments providing public recreational opportunities are preferred. The commission shall not: (1) require that overnight room rentals be fixed at an amount certain for any privately owned and operated hotel, motel, or other similar visitor-serving facility located on either public or private lands; or (2) establish or approve any method for the identification of low or moderate income persons for the purpose of determining eligibility for overnight room rentals in any such facilities. Section 30221 Oceanfront land suitable for recreational use shall be protected for recreational use and development unless present and foreseeable future demand for public or commercial recreational activities that could be accommodated on the property is already adequately provided for in the area. Section 30222 - The use of private lands suitable for visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have priority over private residential, general industrial, or general commercial development, but not over agriculture or coastal-dependent industry.” “… in 1996, the Poinsettia Shores Master Plan was certified as part of the City's LCP, and replaced the [Visitor serving] land use designation as an "Unplanned Area." In an attempt to maintain a lower-cost visitor-serving component at this location, the Commission, through a suggested modification, required language within the Master Plan that would serve to protect this type of use. The language in the Poinsettia Shores Master Plan, for this location, "Area F," included: As part of any future planning effort, the City and Developer must consider and document the need for the provision of lower cost accommodations or recreational facilities (i.e. public park) on the west side of the railroad.” “The Ponto Beachfront area is an area that could be considered as a high-priority location for lower cost overnight accommodations. While located across the street from a State Park (South Carlsbad State Park) containing camping facilities, during peak summer months, the campground is consistently at capacity. … If at any time in the future, this State Beach campground is converted to day use sites, the market and the need for low cost overnight accommodations will be significantly amplified. Thus the Vision Plan, as proposed by the City, cannot be found consistent with the Coastal Act.” “H. Conclusions: … concerns regarding the determination of preferred land uses in an ‘unplanned’ area, the lack of provision of lower-cost accommodations and recreational uses, … remain. All of these oversights could result in impacts to public access and recreation and other coastal resources and, therefore, the Vision Plan, as submitted, is therefore inconsistent with the Coastal Act, and therefore, shall be denied as submitted.” Page 4 of 5 2) Following is from a 7/3/17 CCC letter to City Staff on the City’s proposed land use changes at Planning Area F. City Staff for the 1st time provided this to City Council on 1/28/20: “The existing LUP includes policies that require certain visitor-serving developments and/or studies relevant to the Ponto/Southern Waterfront area. For example, Planning Area F requires the city and developer to "consider and document the need for the provision of lower cost visitor accommodations or recreational facilities (i.e. public park) on the west side of the railroad. This is an issue that the San Pacifico HOA community group is raising in regards to the Shopoff/Ponto development proposal, and this study should be undertaken as a part of the visitor serving use inventory analysis described above. If this analysis determines that there is a deficit of low cost visitor accommodations or recreation facilities in this area, then Planning Area F should be considered as a site where these types of uses could be developed.” 3) In 2017 after citizens received the City’s reply to Public Records Request 2017-260, citizens meet with CCC staff to reconfirm the City failed since before 2010 to publicly disclose and comply with Planning Area F’s LCP requirements. CCC Staff acknowledged the City has not yet complied with the LCP and in an 8/16/2017 email said: “The City is currently undertaking a comprehensive update to their LCP funded in part through a CCC grant. As a part of this process the City will be consolidating all previous LCP segments into a single, unified LCP. The City has received direction from both the Commission (May 2016 CCC hearing) and Commission staff, that as a part of this update the City shall undertake an inventory of visitor serving uses currently provided within the City’s Coastal Zone which will then serve to inform updates to the City’s land use and zoning maps as necessary. This inventory could have future implications for the appropriate land use and zoning associated with the Ponto area.” 4) In 2016, the CCC told City that Carlsbad’s proposed 2015 General Plan land use map could change based on the outcomes of both a Citywide Coastal Recreation needs Study, and also the specific Planning Area F LCP requirement to study Park needs at Ponto. 5) Currently and since 2016 the City acknowledged that the existing LCP, City and LCP Master Plan Zoning of “Non-Residential Reserve” land use needs to be changed by BOTH the City and CA Coastal Commission to only then allow any proposed development on Ponto Planning Area F. Also, since 1996 the Local Facilities Management Plan for Zone 9 (Ponto) has the planned land use and zoning of Ponto Planning Area F as “Non-Residential Reserve” that has no land use. The LFMP-Zone 9 must be amended to account for any City and CA Coastal Commission change from “Non-Residential Reserve” and address the land use impacts on all the Growth Management Program Facility Page 5 of 5 Standards in Zone9 such as the current Park deficit, and also the recently discovered false exemption of the Open Space Standard in Zone 9. The false exemption being that Zone 9 was not developed in 1986 nor have the land use changes since 1986 complied with the 15% ‘unconstrained’ Open Space Standard. The City currently and since 2016 acknowledges the existing LCP, City and LCP Master Plan Zoning of “Non-Residential Reserve” land use of Ponto Planning Area F needs to be changed by BOTH the City and CA Coastal Commission as evidenced on page 14-15 of City’s Planning Pending Applications as of November 2020 at https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=46332 as it shows: “PONTO BEACHFRONT 12/20/2016 Legislative application applied on description AMEND2017-0001 [LU Change] 1/19/17 LFMP AMENDMENT FOR ZONE 9 LCPA2016-0002 [LCP Change] 12/20/16 USES PROPOSED FOR PLANNING AREA F MP2016-0001 [Zone Change] 12/20/16 USES PROPOSED FOR PLANNING AREA F – Carlsbad City Planner = Goff” The City is apparently failing to fully disclose to Citizens these facts and the City’s prior “Ponto Planning Area F planning mistakes dating back over 10-years when the land was purchased by speculative investors. For the City’s and CA Coastal Commission’s Public Participation process to function Carlsbad Citizens need to have these facts, so they are properly informed. The overwhelming Citizen input on the need for and request the City provide Ponto Coastal Park comes from Citizens slowly in 2017 becoming aware of the City’s prior Ponto Planning Area F planning mistakes and asking the City to acknowledge and correct those mistakes. Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 1 of 7 Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Introduction: Carlsbad first documented Sea Level Rise (SLR) and associated increases in coastal erosion in a December 2017 Sea Level Rise Vulnerability Assessment (2017 SLR Assessment). Prior planning activities (2010 Ponto Vision Plan – rejected by CA Coastal Commission, and 2015 General Plan Update) did not consider SLR and how SLR would impact Coastal Open Space Land Use & CA Coastal Act ‘High-Priority’ Coastal Open Space Land Uses at Ponto. The 2017 SLR Assessment shows Open Space land and Open Space Land Uses are almost exclusively impacted by SLR at Ponto & South Coastal Carlsbad. The 2017 SLF Assessment also shows significant LOSS of Open Space land acreage and Land Uses. Most all impacted Open Space Land Uses are CA Coastal Act “High-Priority Coastal Land Uses” – Coastal Recreation (i.e. Public Park) and Low-Cost Visitor Accommodations. Existing Ponto Open Space Land Uses are already very congested (non-existent/narrow beach) and have very high, almost exclusionary, occupancy rates (Campground) due to existing population/visitor demands. Future population/visitor increases will make this demand situation worst. The significant permanent LOSS of existing Coastal Open Space land and Coastal Open Space Land Use (and land) due to SLR reduces existing supply and compounds Open Space congestion elsewhere. Prior Ponto planning did not consider, nor plan, for significant SLR and current/future “High-Priority” Coastal Open Space Land Use demands. Open Space and City Park demand at Ponto: Open Space at Ponto is primarily ‘Constrained’ as defined by the City’s Growth Management Program (GMP), and cannot be counted in meeting the City’s minimal 15% ‘Unconstrained’ GMP Open Space Standard. Per the GMP Open Space Standard, the developers of Ponto should have provided in their developments at least 30-acres of additional ‘Unconstrained’ GMP Open Space at Ponto. City GIS mapping data confirm 30-acres of GMP Standard Open Space is missing at Ponto (Local Facilities Management Plan Zone 9). The City of Carlsbad GIS Map on page 2 shows locations of Open Spaces at Ponto. This map and its corresponding tax parcel-based data file document Ponto’s non-compliance with the GMP Open Space Standard. A summary of that City GIS data file is also on page 2. The City said Ponto’s non-compliance with the GMP Open Space Standard was ‘justified’ by the City ‘exempting’ compliance with the Standard. The City ‘justified’ this ‘exemption’ for reasons that do not appear correct based on the City’s GIS map and data on page 2, and by a review of 1986 aerial photography that shows most of Ponto as vacant land. The City in the Citywide Facilities Improvement Plan (CFIP) said 1) Ponto was already developed in 1986, or 2) Ponto in 1986 already provided 15% of the ‘Unconstrained’ land as GMP Standard Open Space. Both these ‘justifications’ for Ponto ‘exemption’ in the CFIP were not correct. The legality of the City ‘exempting’ Ponto developers from the GMP Open Space Standard is subject to current litigation. The City proposes to continue to exempt future Ponto developers from providing the missing 30-acres of minimally required GMP Open Space, even though a change in Ponto Planning Area F land use from the current ‘Non-Residential Reserve” Land Use requires comprehensive Amendment of the Local Facilitates Management Plan Zone 9 to account for a land use change. City exemption is subject of litigation. Ponto (west of I-5 and South of Poinsettia Lane) currently has 1,025 homes that per Carlsbad’s minimal Park Standard demand an 8-acre City Park. There is no City Park at Ponto. Coastal Southwest Carlsbad has an over 6.5 acre Park deficit that is being met 6-miles away in NW Carlsbad. Ponto is in the middle of 6-miles of Coastline without a City Coastal Park west of the rail corridor. Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 2 of 7 City GIS map of Ponto’s (LFMP Zone 9) Open Space: Light green areas meet the City’s 15% unconstrained Growth Management Program Open Space Standard Most Ponto Open Space (pink hatch & blue [water] on map) is “Constrained” and does not meet the Standard Aviara - Zone 19, Ponto - Zone 9 and Hanover/Poinsettia Shores – Zone 22 all developed around the same time and had similar vacant lands. City required Aviara - Zone 19 east of Ponto to provide the 15% Standard Open Space. Why not Ponto? Aviara had the same lagoon waters. City required Hanover & Poinsettia Shores area Zone 22 just north of Ponto to provide the 15% Standard Open Space. Why not Ponto? Why Ponto developers were never required to comply with the 15% Standard Open Space is subject to current litigation Below is City GIS data from this map City GIS map data summary of the 15% Growth Management Standard Open Space at Ponto 472 Acres Total land in LFMP Zone 9 [Ponto] (197 Acres) Constrained land excluded from GMP Open Space 275 Acres Unconstrained land in LFMP Zone 9 [Ponto] X 15% GMP Minimum Unconstrained Open Space requirement 41 Acres GMP Minimum Unconstrained Open Space required (11 Acres) GMP Open Space provided & mapped per City GIS data 30 Acres Missing Unconstrained Open Space needed in LFMP Zone 9 [Ponto] to meet the City’s minimum GMP Open Space Standard per City’s GIS map & data 73% of the City’s minimum 15% required Open Space Standard is missing due to over development of LFMP Zone 9 [Ponto] • j ••-.•~•I ; , .... ~ .. Q)l:ltl$~C~ 0Patt(f$ ~ 1~PreseM11cno1H.111nfl-c:J Lf'MZ980unclt't O :t•WOO<J'~ c:Jcc,ens.,_~ 0 MlliJs g ,-~~ .•;;·';.,.-.-::~.;•.-' ..... N A O ,oo 200 300 .4(1(1 Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 3 of 7 Sea Level Rise impacts on Open Space and Open Space Land Use Planning at Ponto: The City’s 2015 General Plan Update did not factor in the impacts of Sea Level Rise (SLR) on Ponto’s Open Space land. In December 2017 the City conducted the first Sea Level Rise Vulnerability Assessment https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=33958. The 2017 SLR Assessment is an initial baseline analysis, but it shows significant SLR impacts on Ponto Open Space. More follow-up analysis is being conducted to incorporate newer knowledge on SLR projections and coastal land erosion accelerated by SLR. Follow-up analysis may likely show SLR impacts occurring sooner and more extreme. Troublingly the 2017 SLR Assessment shows SLR actually significantly reducing or eliminating Open Space land at Ponto. SLR is projected to only impact and eliminate Open Space lands and Open Space Land Use at Ponto. The loss of Ponto Open Space land and Land Use being at the State Campground, Beaches, and Batiquitos Lagoon shoreline. The losses of these Open Space lands and land uses would progress over time, and be a permanent loss. The 2017 SLR Assessment provides two time frames near- term 2050 that match with the Carlsbad General Plan, and the longer-term ‘the next General Plan Update’ time frame of 2100. One can think of these timeframes as the lifetimes of our children and their children (2050), and the lifetimes of our Grandchildren and their children (2100). SLR impact on Coastal Land Use and Coastal Land Use planning is a perpetual (permanent) impact that carries over from one Local Coastal Program (LCP) and City General Plan (GP) to the next Updated LCP and GP. Following (within quotation marks) are excerpts from Carlsbad’s 2017 Sea Level Rise Vulnerability Assessment: [Italicized text within brackets] is added data based on review of aerial photo maps in the Assessment. “Planning Zone 3 consists of the Southern Shoreline Planning Area and the Batiquitos Lagoon. Assets within this zone are vulnerable to inundation, coastal flooding and bluff erosion in both planning horizons (2050 and 2100). A summary of the vulnerability assessment rating is provided in Table 5. A discussion of the vulnerability and risk assessment is also provided for each asset category. 5.3.1. Beaches Approximately 14 acres of beach area is projected to be impacted by inundation/erosion in 2050. … Beaches in this planning area are backed by unarmored coastal bluffs. Sand derived from the natural erosion of the bluff as sea levels rise may be adequate to sustain beach widths, thus, beaches in this reach were assumed to have a moderate adaptive capacity. The overall vulnerability rating for beaches is moderate for 2050. Vulnerability is rated moderate for the 2100 horizon due to the significant amount of erosion expected as the beaches are squeezed between rising sea levels and bluffs. Assuming the bluffs are unarmored in the future, sand derived from bluff erosion may sustain some level of beaches in this planning area. A complete loss of beaches poses a high risk to the city as the natural barrier from storm waves is lost as well as a reduction in beach access, recreation and the economic benefits the beaches provide. 5.3.3. State Parks A majority of the South Carlsbad State Beach day-use facilities and campgrounds (separated into four parcels) were determined to be exposed to bluff erosion by the 2050 sea level rise scenario (moderate exposure). This resource is considered to have a high sensitivity since bluff erosion could significantly impair usage of the facilities. Though economic impacts to the physical structures within South Carlsbad State Beach would be relatively low, the loss of this park would be significant Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 4 of 7 since adequate space for the park to move inland is not available (low adaptive capacity). State parks was assigned a high vulnerability in the 2050 planning horizon. State park facilities are recognized as important assets to the city in terms of economic and recreation value as well as providing low-cost visitor serving amenities. This vulnerability poses a high risk to coastal access, recreation, and tourism opportunities in this planning area. In 2100, bluff erosion of South Carlsbad State Beach day-use facilities and campgrounds become more severe and the South Ponto State Beach day-use area becomes exposed to coastal flooding during extreme events. The sensitivity of the South Ponto day-use area is low because impacts to usage will be temporary and no major damage to facilities would be anticipated. Vulnerability and risk to State Parks remains high by 2100 due to the impacts to South Carlsbad State Beach in combination with flooding impacts to South Ponto. Table 5: Planning Zone 3 Vulnerability Assessment Summary [condensed & notated]: Asset Horizon Vulnerability Category [time] Hazard Type Impacted Assets Rating Beaches 2050 Inundation/Erosion, Flooding 14 acres (erosion) Moderate 2100 Inundation/Erosion, Flooding 54 acres (erosion) Moderate Public Access 2050 Inundation, Flooding 6 access points Moderate 4,791 feet of trails 2100 Inundation, Flooding 10 access points Moderate 14,049 feet of trails State Parks 2050 Flooding, Bluff Erosion 4 parcels [<18 Acres] High [Campground - 2100 Flooding, Bluff Erosion 4 parcels [>18 Acres] High Low-cost Visitor [loss of over 50% of Accommodations] the campground & its Low-cost Visitor Accommodations, See Figure 5.] Transportation 2050 Bluff Erosion 1,383 linear feet Moderate (Road, Bike, 2100 Flooding, Bluff Erosion 11,280 linear feet High Pedestrian) Environmentally 2050 Inundation, Flooding 572 acres Moderate Sensitive 2100 Inundation, Flooding 606 acres High Lands Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 5 of 7 .,,...,,~c;........,,...,, D 11~•\;ll)-<(.I>' Cb• Southern Shortfine PlanningArEa-Year 2050 CXIUOITOG 1,:::,1 .. , Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 6 of 7 [Figure 5 show the loss of over 50% of the campground and campground sites with a minimal .2 meter Sea Level Rise (SLR), and potentially the entire campground (due to loss of access road) in 2 meter SLF.]” Directions to analyze and correct current and future LOSS of Coastal Open Space Land Use at Ponto On July 3, 2017 the CA Coastal Commission provided direction to Carlsbad stating: “The existing LUP includes policies that require certain visitor-serving developments and/or studies relevant to the Ponto … area. For example, Planning Area F requires the city and developer to "consider and document the need for the provision of lower cost visitor accommodations or recreational facilities (i.e., public park) on the west side of the railroad. … this study should be undertaken as a part of the visitor serving use inventory analysis described above. If this analysis determines that there is a deficit of low cost visitor accommodations or recreation facilities in this area, then Planning Area F should be considered as a site where these types of uses could be developed.” Official Carlsbad Public Records Requests (PRR 2017-260, et. al.) confirmed Carlsbad’s Existing LCP and its Ponto specific existing LUP polices and Zoning regulations were never followed in the City’s prior Ponto planning activities (i.e. 2010 Ponto Vision Plan & 2015 General Plan Update). The projected SLR loss of recreation (beach) and low-cost visitor accommodations (campground) at Ponto should factor in this Existing LCP required analysis, and a LCP-LUP for Ponto and Ponto Planning Area F. In a February 11, 2020 City Council Staff Report City Staff stated: “On March 14, 2017, the City Council approved the General Plan Lawsuit Settlement Agreement (Agreement) between City of Carlsbad and North County Advocates (NCA). Section 4.3.15 of the Agreement requires the city to continue to consider and evaluate properties for potential acquisition of open space and use good faith efforts to acquire those properties.” {'Cityof Carlsbad C a l lfo r nl u Sea Level Rise Vulnerability Assessment Figure 5: CoSMoS Bluff Erosion Projections by 2100 (CoSMoS-COAST 2015) Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 7 of 7 In 2020 NCA recommended the City acquire Ponto Planning Area F as Open Space. The status of City processing that recommendation is unclear. However the Lawsuit Settlement Agreement and NCA’s recommendation to the City should also be considered in the required Existing LCP analysis. Summary: Tragically Carlsbad’s’ Draft Local Coastal Program – Land Use Plan Amendment (DLCP-LUPA) is actually planning to both SIGNIFICATLY REDUCE Coastal Open Space acreage, and to eliminate ‘High-Priority Coastal Open Space Land Uses at Ponto due to SLR. The Existing LCP requirements for Ponto Planning Area F to analyze the deficit of Coastal Open Space Land Use should factor in the currently planned LOSS of both Coastal Open Space acreage and Coastal Open Space Land Uses at Ponto due to SLR. As a long-range Coastal Land Use Plan this required LCP analysis needs to also consider the concurrent future increases in both population and visitor demand for those LOST Coastal Open Space acres and Coastal Open Space Land Uses. It is very troubling that demand for these CA Coastal Act ‘High-Priority’ Coastal Open Space Land Uses is increasing at the same time the current (near/at capacity) supply of these CA Coastal Act ‘High-Priority’ Coastal Open Space Land Uses is significantly decreasing due to SLR. Instead of planning for long-term sustainability of these CA Coastal Act ‘High-Priority’ Coastal Open Space Land Uses for future generations there appears to be a plan to use SLR and inappropriate (lower-priority residential) Coastal Land Use planning to forever remove those CA Coastal Act ‘High-Priority’ Coastal Open Space Land Uses from Ponto. CA Coastal Act Policies to address these issues should be thoroughly considered. 2021-2 proposed Draft Local Coastal Program – Land Use Plan Amendment (DLCP-LUPA) will likely result in City and CA Coastal Commission making updates to the 2015 General Plan, based on the existing Ponto Planning Area F LCP – LUP Policy requirements, Ponto Open Space issues, high-priority Coastal Land Use needs, and SLR issues not addressed in the 2015 General Plan. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 10:06:31 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsAs long- time(decades) resident and business owner in theimmediate Ponto area that is addressed here it is ABOUT TIMEthe City moved FOR THE GOOD OF THIS AREA. It is the LASTCHANCE we will have to preserve this precious area for thePEOPLES’ and the environment’s good!!! NameRobin Hansen Emailmermama1@mac.com CityCarlsbad PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. StateCA 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 10:13:25 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsPlease! We need space for our kids and families to enjoy theoutdoors NameIan Zakrzewski Emailianzak@yahoo.com CityCarlsbad State PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. CA 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 10:24:47 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameGregory Gould Emailgreggould_sd@yahoo.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 10:38:39 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameRobert Philion Emailjbphilion@yahoo.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 12:34:20 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameSanford Braver Emailcarlsbad3br@gmail.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Sent from People for Ponto Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Wednesday, September 21, 2022 10:41:49 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameRaymond Hughes Hughes Emailrayjay3@sbcglobal.net CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 1:18:21 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameGayle Fini Emailgfini@me.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 2:04:25 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameGregory Gould Emailgreggould_sd@yahoo.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. From:Lance Schulte To:Growth Management Committee Cc:City Clerk Subject:FW: Public comment - Parkland Imbalance & resulting VMT increase - RE: Naming and shaming in California Date:Monday, September 19, 2022 8:40:09 AM Attachments:image001.pngimage002.pngimage005.pngTPL Support for Ponto Park - 2022-3-11.pdfCARB Dashboard - Tracking Progress - Sustainable Communities California Air Resources Board - Carlsbad - 2022 Sep 11.pdf Importance:High Sorry Carlsbad Tomorrow Growth Management Committee, in rushing to get this out I only originally sent this Eric Lardy. Lance From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Monday, September 19, 2022 8:31 AMTo: council@carlsbadca.gov; 'Tom Frank'; 'Eric Lardy'; 'City Clerk'; 'Kyle Lancaster'; Carrie Boyle (carrie.boyle@coastal.ca.gov);'Prahler, Erin@Coastal'; Ross, Toni@Coastal (Toni.Ross@coastal.ca.gov)Cc: 'info@peopleforponto.com'Subject: Public comment - Parkland Imbalance & resulting VMT increase - RE: Naming and shaming in CaliforniaImportance: High Dear City Council; Traffic, Planning and Park Commissions, Carlsbad Tomorrow Growth Management Committee; and CA Coastal Commission: Please review and consider this email and data on regional VMT data in the Carlsbad Tomorrow Growth Management Committee’s Sept 22 and future meetings on Parks, and your considerations of Carlsbad General Plan & LCPA, Growth Management Standards and Park Master Plan Updates. As has been provided in many data supported Citizen desires (and Trust for Public Land ParkScore data) and again mentioned to the CTGMC in July Carlsbad’s Parkland distribution Imbalance creates multiple negative impacts to current and future generations and the environment. As mentioned to City in the “Coastal Recreation” data file and in other public input Carlsbad’s Parkland Imbalance is in conflict with CA Coastal Act Policy, and as noted to you before and again in the email below Carlsbad’s Parkland Imbalance is increasing Carlsbad’s VMT for Park access in conflict with State law to reduce VMT. As the Trust for Public Land Parkscore data show Carlsbad is a relatively poor performer in regards to both providing Park acers and fairly distributing Park acres so more Citizens and their families can walk to Parks. Carlsbad is also below average nationally in both providing Park acres and in fairly distributing Park acres. Carlsbad has one park for 2,797 residents with 2.95 acres of parkland per 1,000 residents. National Recreation and Park Association (NRPA) data show that Carlsbad is 20% below what is typical in providing the number of parks, and Carlsbad is 72% below what is typical in providing acres of parkland (https://www.nrpa.org/publications-research/research-papers/agency-performance- review/). The Trust for Public Land (TPL) also measures a City’s Park performance (https://www.tpl.org/city/carlsbad- california). TPL data show Carlsbad total Park land acers (including counting State Park land acres) is 26% below the Median for the TPL’s 100 ParkScore® cities, and 7% below the Median for the 14,000 cities and towns in the TPL ParkServe® database. The TPL also maps if a City provides/has Parks within a 10-minute walk to a Park; and Carlsbad is 33% below the Median for the TPL’s 100 ParkScore® cities and 9% below the Median for the 14,000 cities and towns in the TPL ParkServe® database. This comparative information has not been publicly addressed by Council or in the 2015 General Plan Update. As noted both the Cities of Encinitas & Oceanside and many others have a 10-minute walk to Park Standard. Carlsbad does not and thus makes Carlsbad Parks less accessible and forces more VMT on Carlsbad roadways. The CARB data so the SANDAG Regional average for Parks within walking distance is 71%, and the Statewide average is 72%. Carlsbad’s Trust for Public Land Parkscore as noted above shows Carlsbad is only 50% or almost ½ worse than both the Regional and Statewide averages for walkable access to Parks. Carlsbad requires about 50% more VMT than the Region and State for Park access. This is the Imbalance People for Ponto Citizens have repeatedly shown the City but is being ignored. Simply look at the following image from the City’s own Park Service Area Maps in the Carlsbad Park Master Plan to see the unfairness, added VMT and gross Imbalance in the Land Use Plan. The blue dot is a Park and the light blue circle is that Park’s service area. Even a 5-year child can see the unfairness and Imbalance. I hope you consider this data. Our future depends on it. Lance . From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Friday, September 9, 2022 9:01 AMTo: council@carlsbadca.gov; 'Tom Frank'; 'Eric Lardy'; 'City Clerk'Subject: FW: Naming and shaming in California Dear City Council, Traffic & Planning Commissions, and Carlsbad Tomorrow Growth Management Committee: A former professional college of mine (and former Carlsbad citizen) who is a founding member of the New Urbanism sent me the email below. It has links to some base Regional data on issues critical to Traffic and Planning Commissions, and CTGMC regarding VMT. How Carlsbad, and areas within Carlsbad, compare to Regional (SANDAG) VMT should likely be evaluated by the City. The later part of my planning career I specialized in Transit Oriented Development (redevelopment) that coordinates land use and transportation planning and investment to redesign existing development to be more livable, mobile and sustainable. I hope the Commissions, CTGMC, and Council find the data helpful. Thanks & Aloha Aina, Lance Schulte From: Peter Katz [mailto:pkatz@smartgo.network] Sent: Friday, September 9, 2022 6:15 AMTo: Peter KatzSubject: Naming and shaming in California To my CA friends (and a few others): As you may know, the State of California is a leader in adopting legislation aimed at reducing VMT(vehicle-miles traveled) and hopefully the GHG (greenhouse house gas) that results from the use of gas- powered vehicles. So how is the state (and its various geographic units) progressing toward stated goals? Not very No Coastal Park in South Carlsbad App 6 miles of Coast without a Coastal Park is a Ci & Regional need • South Carlsbad has 64,000 residents &thousands of hotel vi sitors without a Coastal park • Closest park to Ponto is Poinsettia Park, approx. 2.5 miles across 1-5 Proposed Veterans Park is approx. 6 miles away well, according to this dashboard, recently set up by California’s Air Resources Board: https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-program/dashboard-tracking-progress-sustainable Here is a sample image from the dashboard for the SF Bay region (lines in purple): I recommend you spend a minute with the dashboard to see how your region compares to the state average and with other regions. This comment from a CA-based colleague sums up the problem that Iobserved in nearly every region of the state: "Despite California’s laws and regulations around VMT/GHG reduction, macro level economic effectshave more than offset reduction goals and produced trends moving in the wrong direction. Part ofthe challenge is that the state hasn’t done enough to manage vehicle travel demand. The cost andconvenience of vehicle use have not been dampened by state or regional actions associated with SB375 or other laws." Best;Peter PS: If you haven’t been to SmartGO’s website recently, please take a look. And don’t miss the new pageon our pay-per mile (PPM) auto insurance program (https://smartgo.network/insurance-information). Multiple studies have shown VMT reduction of about 8% with such coverage, due mostly to behavior changes when people know they’re paying for every mile that's GHG and VMT Compared to SB 375 Targets LI) 0 0 N E 0% _g ·10% Q) OI C: C1) .s:;; u '#- -20% 2005 2010 MTC VMT Stat ewide VMT 2015 2020 2025 MTC 2035 Target Q 2030 2035 driven. Low mileage drivers (below 10K per year) can often save money by switching to PPM. If the approach was widely adopted in California, you’d see the lines in the chart above starting to bend downward toward the target circles, as they should be. Maybe better consumer choices will succeed in ways that government regulation has not! SmartGO Network 5268G Nicholson Ln #280 North Bethesda, MD 20895 202/486-7160 PKatz@SmartGO.network www.SmartGO.network CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content issafe. Email Phone IN THIS SECTION CONTACT Sustainable Communities & Climate Protection Program sustainablecommunities@arb.ca.gov (800) 242-4450 Dashboard - Tracking Progress - Sustainable Communities Note: This beta dashboard is a dra�. Do not cite. Introduction In 2008, the California Legislature passed the Sustainable Communities and Climate Protection Act, Senate Bill 375 (SB 375). SB 375 is a first-of-its-kind law to recognize the critical role of integrating transportation, land use, and housing decisions. The law requires each of Californiaʼs 18 metropolitan planning organizations (MPOs) to include a sustainable communities strategy (SCS) in its long-range regional transportation plan. The SCS identifies strategies to meet regional greenhouse gas (GHG) emission reduction targets set by the California Air Resources Board (CARB). In 2017, the Legislature passed Senate Bill 150 (SB 150), tasking CARB with issuing a progress report every four years that assesses progress each MPO has made in meeting the regional GHG emission reduction targets set by CARB. This dashboard showcases over two dozen data-supported metrics that CARB analyzed to support the Dra� 2022 Progress Report. How to Use This Dashboard The purpose of this dashboard is to highlight transportation, land use, and housing metrics that CARB analyzed to support the 2022 Progress Report. Users can interact with the visualizations below to filter data or reveal additional information. Filter Data Use filters at the top of each visualization to narrow down data of interest. Most visualizations allow filtering by MPO region. Some visualizations also allow filtering by year. Find Additional Information Hover or click on a chart or graphic to reveal additional information about a given metric. For details on how a metric was calculated, see the linked methodology below each visualization. Progress Toward SB 375 GHG Emission Reduction Targets Changes in transportation, land use, and housing are essential to meeting the Stateʼs climate and equity goals. Despite Dashboard - Tracking Progress - Sustainable Communities | California ... https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-pr... 1 of 10 9/11/2022, 7:06 AM Californiaʼs aggressive work on vehicle technology, advancing vehicle electrification alone will not be enough to get to carbon neutrality. CARB estimated passenger vehicle miles traveled (VMT) and associated GHG emissions compared to each MPOʼs regional GHG emission reduction targets (which are set relative to a 2005 baseline). This comparison shows that California is not on track to reduce GHG emissions from personal vehicle travel under SB 375. Actual per capita GHG emissions and VMT continue to increase throughout the state. However, per capita VMT and GHG increases have slowed down since 2017. Methodology (Appendix A) Shifting Travel Patterns DRAFT - DO NOT CITE Select Region 1 Statewide Select Region 2 (optional) San Diego Association of Governments (S… Select Metric GHG VMT GHG and VMT Compared to SB 375 Targets % C h a n g e f r o m 2 0 0 5 -25% -20% -15% -10% -5% 0% 5% 2005 2010 2015 2020 2025 2030 2035 MPO, Metric SANDAG, GHG SANDAG, VMT Statewide, GHG Statewide, VMT Dashboard - Tracking Progress - Sustainable Communities | California ... https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-pr... 2 of 10 9/11/2022, 7:06 AM I· ■ Statew ide VMT SANDAG VMT Statew ide GHG SANDAG GHG SAN DAG 2020 Target Q ■ SANDAG 2035 Target Q ■ Transportation and land use development can reduce GHG emissions by making it easier for people to get around on foot, by bike, or by transit. Travel indicators such as vehicle ownership, transit ridership, commute mode share, and commute time paint a picture of how transit, carpooling, and active transportation usage have changed relative to driving. In general, Californians continue to drive alone more and carpool less to work. Household vehicle ownership is growing, transit ridership is falling, and the small percentage of people that walk or bike to work is declining. DRAFT - DO NOT CITE Select Region 1 None Select Region 2 (optional) San Diego Association of Governments (SANDAG) Select Year 2019 Transit % of Commute Trips Commute Time (Minutes) SANDAG SANDAG Walk or Bike % of Commute Trips SANDAG 2010 2019 SANDAG Carpool % of Commute Trips Commute Time (Minutes) SANDAG Passenger VMT Per Person / Day SANDAG Vehicles Per Household SANDAG Transit Rides Per Person / Year SANDAG Drive Alone % of Commute Trips Commute Time (Minutes) SANDAG SANDAG SANDAG Dashboard - Tracking Progress - Sustainable Communities | California ... https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-pr... 3 of 10 9/11/2022, 7:06 AM 25.9 2.0 3% from 2005 .A. 4% from 2010 .A. ~ -----------75.7 27.7 ---- -== ~-◄8.6 ~28.5 ----------- ~2.8 -------■-----,.49.2 ~3.6 ----------- 29.5 -2% from 2005 T 76% Drive Alone 9%Carpool 3% Use Transit 4% Walk or Bike Methodology (Appendix A) Sustainable Regional Growth One way to reduce the need to drive long distances is to build homes, jobs, and other key destinations closer together. CARB examined changes in land use to assess whether development patterns were becoming more compact. This included evaluating changes in three types of land use: developed acres, agricultural acres, and conserved acres. Developed acres are areas that have been converted from other uses to urban land. Agricultural acres lost are areas that have been converted from agriculture to other uses. Conserved acres are areas that are protected from development of any kind. All three of these indicators vary by region, as illustrated in the maps below. Methodology (Appendix A ) Acres Developed 2004 to 2016 © Mapbox © OSM Agricultural Acres Lost 2004 to 2016 © Mapbox © OSM Acres Conserved through 2021 © Mapbox © OSM DRAFT - DO NOT CITE Acres Developed Per 1,000 Population Change -33 983 Ag Acres Lost Per 1,000 Population Change -24 778 Acres Conserved Per 1,000 Population 24 12,517 Dashboard - Tracking Progress - Sustainable Communities | California ... https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-pr... 4 of 10 9/11/2022, 7:06 AM • jL ... ·(.· 'T'' ----~"~ .r.r ,, '· ~---_ Accessible Communities When people live near shops, schools, parks, and transit, they can meet many of their daily needs without having to drive long distances. They may even be able to walk, bike, or ride a bus to their destination. For each region, CARB evaluated the percentage of the population that lived within a 15-minute walk to four key destination types: park/open space, educational facilities, transit stops, and grocery stores. Unfortunately, most residents in California lack good accessibility to key destinations: less than half of the population in every region can access all four destination types by walking. Methodology (Appendix A) DRAFT - DO NOT CITE Select Region 1 Statewide (18 MPO regions combined) Select Region 2 (optional) San Diego Association of Governments (SANDAG) Percent of Population With Access to Destinations by Foot SANDAG Statewide Education Facilities Groceries Parks Transit All Four Destination Types Education Facilities Groceries Parks Transit All Four Destination Types Dashboard - Tracking Progress - Sustainable Communities | California ... https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-pr... 5 of 10 9/11/2022, 7:06 AM 70% 63% fl t::Jjl' fl t::Jjl' 34% • ~~ 80% 72% Q ' 24% ~ A Growing Housing Market Housing development is an essential component for achieving SB 375 goals. For example, housing policies that promote multi-family units and equitable development can improve transit accessibility and help reduce trip length. CARB compared permitted new housing construction to each regionʼs housing need by income group as defined by the State Regional Housing Needs Allocation (RHNA) 5th planning cycle. Housing permitting and constructions were significantly behind regional housing allocations, especially for low-income housing. CARB also analyzed the growth rate in single-family and multi-family housing units. The state continues to build more single-family housing than multi-family housing. However, since 2013 the growth rate of new housing has started to rebound, and the share of multi-family housing units has outpaced the percentage of single-family housing units. Housing costs can be a substantial financial burden to predominantly low-income households. CARB analyzed the percentage of households that are overburdened by housing costs (defined as households that spend more than 35% of their income on housing). The percentage of overburdened households increased from 2010 to 2014 and slowly decreased in recent years. Dashboard - Tracking Progress - Sustainable Communities | California ... https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-pr... 6 of 10 9/11/2022, 7:06 AM Methodology (Appendix A) Funding and Delivering Travel Choices DRAFT - DO NOT CITE Select Region 1 Statewide Select Region 2 (optional) San Diego Association of Governments (SANDAG) New Housing Permits and Housing Need Regional Housing Needs Allocation - 5th Planning Cycle Statewide Above Moderate Income Moderate Income Low Income Very Low Income Total # Housing Units Permitted, Needed 0K 100K 200K 300K 400K 500K 600K 700K SANDAG Above Moderate Income Moderate Income Low Income Very Low Income Total # Housing Units Permitted, Needed 0K 20K 40K 60K 80K 100K 120K 140K 160K 180K 200K 0K 200K 400K 600K 800K Statewide 2005 2020 0K 20K 40K 60K SANDAG 2005 2020 Growth in Housing Units by Type # Units Added Since 2005 Housing Cost Burden % Households Spending Over 35% Income on Housing 30% 40% 50% 60% Statewide 2010 2019 30% 40% 50% 60% SANDAG 2010 2019 Multi-Family Single-Family Dashboard - Tracking Progress - Sustainable Communities | California ... https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-pr... 7 of 10 9/11/2022, 7:06 AM .....--........ 45.2% -----46.6% ■ / ■ I Housing Need (2013-2021) Funding for SCS projects comes from local, regional, state, and federal funding programs. Planned financing can explain whether a region is implementing projects and programs that reduce VMT and GHG emissions. The charts below illustrate planned spending by mode in each region according to the MPOs most recent Regional Transportation Plan (RTP). RTPs typically cover a period of two or three decades and must cover at least 20 years. MPOs have discretionary authority over only a portion of the funds in RTPs, and that portion di�ers by region. Local governments, County Transportation Commissions, and transit agencies are examples of authorities with decision- making power over funds in the RTPs. Certain funding sources also have constraints attached. With a few notable exceptions, most regions have more spending dedicated to roads than transit or active travel. Many regions continue to include significant funding for road expansion. Dashboard - Tracking Progress - Sustainable Communities | California ... https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-pr... 8 of 10 9/11/2022, 7:06 AM Methodology (Appendix A) Additional Information Select Region 1 San Diego Association of Governments (SANDAG) Select Region 2 (optional) None Regional Transportation Plan Expenditures DRAFT - DO NOT CITE Active Travel Other Roads Transit Dashboard - Tracking Progress - Sustainable Communities | California ... https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-pr... 9 of 10 9/11/2022, 7:06 AM ■ ■ ■ ■ Active Travel EV Infrastructure Gra ts For Focused Growth Innovative Mob iii y TSM /ITS SANDAG Highway Projects Road Maintenance Rural Corridors, Local Streets, Others (800) 242-4450 | helpline@arb.ca.gov 1001 I Street, Sacramento, CA 95814 P.O. Box 2815, Sacramento, CA 95812 Copyright © 2022 State of California For additional information, please see: • Dra� 2022 Progress Report for details on CARBʼs findings and methodology For assistance with web accessibility, please email webaccessibility@arb.ca.gov. Dashboard - Tracking Progress - Sustainable Communities | California ... https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-pr... 10 of 10 9/11/2022, 7:06 AM CALIFORNIA Your Actions Save Lives ALL COVID-19 UPDATES 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:City Clerk; Growth Management Committee; Michele Hardy; Council Internet Email; City Clerk; Kyle Lancaster;Eric Lardy; "Smith, Darren@Parks"; Homer, Sean@Parks; "Moran, Gina@Parks"; Boyle, Carrie@Coastal; "Prahler,Erin@Coastal"; Ross, Toni@Coastal; Tom Frank Cc:info@peopleforponto.com Subject:Public input to Carlsbad Tomorrow Growth Management Committee Sep 22 2022 meeting; and for LCPA, ParksMaster Plan Update - Parks & Open Space at Ponto-Coastal South Carlsbad Date:Monday, September 19, 2022 11:34:37 AM Importance:High Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks, Beach Preservation and Planning Commissions, , CA Coastal Commission and CA State Parks: I was out this weekend so just had time to do a quick scan and noticed some obvious missing information and ‘spin’ in the staff 'report'. I hope the CTGMC can see this and the data ‘cherry picking’ and diversions to change subjects to “recreation land” and falsely try to count or hide Park shortfalls by trying to use other 'recreation' lands areas’ as "Parks. Here is what I was able to quickly scan and note: Citizen response and Input regarding ‘Fact Sheet – Community Interest in Ponto Park” Page 1 City falsely says "City can only acquire property from a willing seller" - this is false. The City can use legal powers emanate domain and condemnation to buy property for public purpose (Parks) unless the USA & California Constitutions have been amended to only allow acquisitions from ‘willing sellers’. The Carlsbad City Council may have CHOSEEN to adopt a formal Policy/Law (or undisclosed and hidden vote) that is constraining their authority. However that City Council CHOICE does not mean the Council can CHOOSE otherwise and use legal powers emanate domain and condemnation to buy property for public purposes. Ironically the City Council has in fact used these emanate domain and condemnation powers on behalf of the Aviara Master Plan Developer to force an “unwilling seller” to sell a sewer line easement to the City for the Aviara Master Plan Developer. 1 'Park funding only comes from the City's General Fund' - this is false. Recently the Federal government provided the City of Carlsbad $ 3million to help fund Veterans Park. There are both Federal and State Grants and funding for Park acquisition. The City cites many other funding sources in its CIP, and like those other funding sources for Park acquisition, the City just does not list them. Also, the City has an Park land dedication Ordinance CMC 20.44 (per CA Quimby Act) that pre-dates growth management and requires developers to give the City Free land for use as a Park to meet the Park needs for that development. In fact 20.44 is where the 3 acre per 1,000 population Park Standard came from. 1 City fails to mention we have a 'willing seller' for 14.3 acres of vacant land at Ponto. The City cites $35 million as the price of that land. The 2-part tax-payer Cost-benefit Analysis data files sent to you should be looked at as simply buying these 14.3 acres saves tax-payers millions and is a Better Park option. P4P can show the City and you how the City could buy this property with minimal added City tax-payer cost. There are Federal and State funding (like note above) for Park acquisition. Also ALL Developers are required to give parkland for free to the City under its Park land Dedication Ordinance 20.44 and about 1.76 acres of Ponto land would be given to the City for free to be used as a Park, or the developers would have to give the City money (pay a park-in-lieu-fee) that should be sufficient to buy 1.76 acres of Park land at Ponto. 1 City Budget funding is a yearly process, and future Budgets, and even most recent Council actions, will/have changed what was in prior Budgets. Buying Ponto Park actually saves tax- payer dollars as noted in the following bullets and in the 2 files sent to the CTGMC – “2022 General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park part 1 of 2” & “City’s PCH area map w numbered notes of constraints – 2 of 2” data files. The data in these data files is from the City. As tax-payers the CTGMC should read these data files. 1 City wide approavls will also be needed for the "South Carlsbad Coastal Project (SCCP)” mentioned in the report. The SCCP is a $135 million to $150 million improvement to existing City Land and will require a City wide vote. Based on the known tax-payer Cost-Benefits of SCCP, it is not clear if votes will support this expenditure – particularly given the Citizen input the City obtained in the $50,000 survey it conducted on the SCCP, and the Council deferring the SCCP for another year. 1 The staff report incompletely says 136 dwelling units are planned for one of the sites. But the report critically failed to disclose to you that Carlsbad’s General Plan Land Use Element page 2- specifically states Carlsbad’s General Plan is not adopted UNTIL the CA COASTAL COMMISIOSN (CCC) fully CERTIFIES the current City Proposed comprehensive Local Coastal Program Amendment (LCPA). The CCC will decide if to approve-deny-approve with modification the City Proposed LCPA in 2023. As provide the CTGMC the CCC has told the City ion 2016 & 2017 that based on the Need for Coastal Recreation (i.e. Public Park) and/or Low-cost Visitor Accommodations the General Plan Land Use at Ponto may change. See the “Updated 2020 Dec 2 Planning Area F existing LCP-LUP & CCC direction to City” data file sent to the CTGMC. Read the CCC’s reasons for 2010 rejection of the Ponto Vision Plan that is the basis for the 2015 General Plan. 1 The 2017 Sea Level Rise Impact analysis did specifically cite both acres of land impacted and the type of land use that was impacted. I can send you the report if you want. I copied key acreage and land use from the SLR Analysis in the “Sea level rise and DUPA LUPA planned loss of Open Space at Ponto data file”. This data file also shows how the City falsely exempted Ponto developers from complying with the growth management 15% Useable Open Space Standard. 1 City says "South Carlsbad Coastal Project (SCCP) will Create 60 acres of available space" - this is false. The 60-acres of Space already exists. The City already owns this land. The SCCP is a $70 million (for 1-mile Manzano to Island Way segment) + $65 to $80 million (for 2.3 mile Island Way to La Costa Ave segment) for a total $135 million to $150 million project that does not buy one single square foot of new City land. Much of the City's 60-acres is already environmentally constrained by protected Habitat so will not change anything and will continue to be unusable for people use as a Park. Parks are people and Not habitat and Projected Habitat is for plants and animal and Not people. The City knows that most of these existing City owned 60-acres is not useable for people and is too narrow to be a Park. The largest part of the 60-acres is at 'the dip' in the 1-mile Manzano to Island Way segment. We ask the CTGMC to ask staff to show you a map and acreage count of that Segment, and how much acreage is planned for 1) roadway-bikeway-sidewalk, 2) Habitat, 3) useable land for people; and 4) the area that will be lost due to Sea Level Rise for each of these 3. What land uses are lost from SLR? Ask to see the same data for the existing configuration for the segment. Compare the data. Compare the total segment acres with the total 60-acres. There is no secured funding for the $135 to $150 million SCCP. The City could buy 3+ Ponto Parks for the cost of rearranging exiting features and adding a sidewalk on existing City land. The only missing feature to Complete" PCH in the two segments (total 3.3 miles) are some missing sidewalks/ped paths. Enhancements to make PCH better and safer for bikes is a very good idea, but seems like can be done within the existing PCH configuration at a fraction of the cost. See the tax-payer cost-benefit Part 1 of 2 and Part 2 of 2 SCCP/PCH Relocation data files. SCCP will also require a citizen vote to approve funds, I am also hearing that Carlsbad citizens are not that supportive of SCCP. So is the SCCP are secured funded and 'countable solution' to the documented Park deficit at Ponto & Coastal South Carlsbad? 2 City says 2,074-acres or 8% of Carlsbad is Park and recreation land (page 2-7 of General Plan). This should be itemized and mapped as the numbers likely include golf courses (mostly private) and maybe Lago land and some Lagoon waters. The City is trying to inaccurately try to use private Recreation land as a public Park. The CTGMC is supposed to compare Park Standard to Park Standards. The City’s Park Standard is fairly poor relative to Encinitas and Oceanside and many other cities, so you are being diverted from that fact. 2 432.4-acres of exiting Park & 519.7-acres of final Park based on 7/26/22 CC vote. This data should closely match the City’s General Plan Land Use data that is the data base used in the “2022 Coastal Recreation data file” sent to you. Of critical importance to the CTGMC is to note the City is apparently saying that they will only provide a final 519.7-acres of Park in City. Yet as the CTGMC knows the City CANNOT plan for Buildout or a final population. So as population continues to grow there will be less and less parkland per 1,000 population. See the “CTGMC key issues and suggestions 2022-8-8” data/suggestion file sent to you. 2 in Table 2 the City did not provide the Park Acres per 1,000 for the same City selected data set. Compare Park acres to Park acres. We provided the NRPA data in the "2022 Coastal Recreation data file" we provided the CTGMC. We also provided the even more comprehensive Trust for Public Land ParkScore data that also shows Carlsbad is below average. That more comprehensive data should be considered. See also Ponto park support letter from Trust for Public Land. CTGMC, you have a heavy burden to set Carlsbad’s Growth Management Program on a fair and sustainable course to accommodate unlimited future growth as required by the State of CA. This involves fixing past errors and fixing what was unfair and setting Standard that are continually adding more parks and Open Space as Carlsbad is forced to grow. We provided you a “CTGMC key issues and suggestions 2022-8-8” data/suggestion file that I think could help you in looking at how to set new Standards for unlimited future growth. Thank you and Aloha Aina, Lance From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Monday, September 19, 2022 9:05 AMTo: 'City Clerk'; committee@carlsbadca.gov; 'Michele Hardy'; 'council@carlsbadca.gov'; 'City Clerk'; 'KyleLancaster'; 'Eric Lardy'; 'Smith, Darren@Parks'; Homer, Sean@Parks (Sean.Homer@parks.ca.gov);'Moran, Gina@Parks'; Carrie Boyle (carrie.boyle@coastal.ca.gov); 'Prahler, Erin@Coastal'; Ross,Toni@Coastal (Toni.Ross@coastal.ca.gov); 'Tom Frank'Cc: 'info@peopleforponto.com'Subject: Public input to Carlsbad Tomorrow Growth Management Committee Sep 22 2022 meeting; andfor LCPA, Parks Master Plan Update - Parks & Open Space at Ponto-Coastal South Carlsbad Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks, Beach Preservation and Planning Commissions, , CA Coastal Commission and CA State Parks: We ask you to please consider this email and attachments in the Sept 22nd CTGMC and subsequent Land Use, Parks and Open Space discussions by the CTGMC, LCP Amendment, PCH Relocation project, Park Master Plan Update, and development proposals at Ponto. As always, and as we have repeatedly asked for since our initial 2017 letter to the City Council, People for Ponto Carlsbad Citizens asks for and are willing able to work with you to find the solutions for: • the documented Park Inequity at Ponto & Coastal South Carlsbad, • the documented missing Unconstrained Open Space at Ponto, • the future loss of 32+ acres of Coastal Open Space (State beach and Campground) due to sea level rise, • the needed upgrades to Carlsbad’s Growth Management Program and Standards (and developer required land dedications and mitigations) to account for an Unlimited population and the need for Unlimited increases in Carlsbad Parks and Open Space to address those Unlimited populations so as to assure we maintain our quality of life, • beneficial collaborations and donations, and • the wiser use of tax-payer dollars to address tax-payer needs The CTGMC and City Commission have an opportunity to do the right thing and correct the clear and obvious Park Inequity and Coastal land use Imbalance at Ponto & Coastal South Carlsbad. Please don’t kick-the-can-down-the-road and fail to consider that data and your fellow Citizen desires for a better Carlsbad. P4P Carlsbad Citizens are here to help assure we sustain and enhance our quality of life for future generations. People for Ponto love deeply Carlsbad and want to assure we leave a better Carlsbad to future generations. Sincerely and with Aloha Aina, Lance Schulte CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. From:Lance Schulte To:City Clerk; Growth Management Committee; Michele Hardy; Council Internet Email; City Clerk; Kyle Lancaster;Eric Lardy; "Smith, Darren@Parks"; Homer, Sean@Parks; "Moran, Gina@Parks"; Boyle, Carrie@Coastal; "Prahler,Erin@Coastal"; Ross, Toni@Coastal; Tom Frank Cc:info@peopleforponto.com Subject:Public input to Carlsbad Tomorrow Growth Management Committee Sep 22 2022 meeting; and for LCPA, ParksMaster Plan Update - Parks & Open Space at Ponto-Coastal South Carlsbad Date:Monday, September 19, 2022 9:04:54 AM Attachments:Citizen questions-input for CTGMC 2022 Sep 22.pdf Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks, Beach Preservation and Planning Commissions, , CA Coastal Commission and CA State Parks: We ask you to please consider this email and attachments in the Sept 22nd CTGMC and subsequent Land Use, Parks and Open Space discussions by the CTGMC, LCP Amendment, PCH Relocation project, Park Master Plan Update, and development proposals at Ponto. As always, and as we have repeatedly asked for since our initial 2017 letter to the City Council, People for Ponto Carlsbad Citizens asks for and are willing able to work with you to find the solutions for: • the documented Park Inequity at Ponto & Coastal South Carlsbad, • the documented missing Unconstrained Open Space at Ponto, • the future loss of 32+ acres of Coastal Open Space (State beach and Campground) due to sea level rise, • the needed upgrades to Carlsbad’s Growth Management Program and Standards (and developer required land dedications and mitigations) to account for an Unlimited population and the need for Unlimited increases in Carlsbad Parks and Open Space to address those Unlimited populations so as to assure we maintain our quality of life, • beneficial collaborations and donations, and • the wiser use of tax-payer dollars to address tax-payer needs The CTGMC and City Commission have an opportunity to do the right thing and correct the clear and obvious Park Inequity and Coastal land use Imbalance at Ponto & Coastal South Carlsbad. Please don’t kick-the-can-down-the-road and fail to consider that data and your fellow Citizen desires for a better Carlsbad. P4P Carlsbad Citizens are here to help assure we sustain and enhance our quality of life for future generations. People for Ponto love deeply Carlsbad and want to assure we leave a better Carlsbad to future generations. Sincerely and with Aloha Aina, Lance Schulte CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. 9/22/22 questions & input to CTGMC – Parks & Open Space unfairness at Ponto Page 1 of 8 2022 Sept. 22nd Carlsbad citizens’ data input & questions for the Carlsbad Tomorrow Growth Management Committee on fairness, and correcting below Standard and missing Parks & Open Space at Ponto People for Ponto (P4P) is an all-volunteer citizen organization founded in 2017 by the 500 home San Pacifico Community Association Board. Since 2017 Citizens from all areas of Carlsbad have joined P4P in support, as have Citizens from San Diego County, visitors to Carlsbad, along with Carlsbad visitor industry, Surfrider Foundation, Batiquitos Lagoon Foundation, and the Trust for Public Land. P4P’s mission is: Provide information to all San Pacifico residents (and surrounding neighborhoods) on the developments. Obtain and consolidate constructive feedback from the residents. Give this feedback to the residents, developers and City so that we can have productive/timely input into the projects and their designs. Act as a strong, unified voice and with the support of our residents in upcoming Planning, Council and Coastal Commission meetings. In fulfilling its mission P4P has filed over 50 official Carlsbad Public Records Requests and communicated the findings. Over 5,000 petitions, hours of citizen testimony, and hundreds of pages of data have been sent to the City of Carlsbad and Council, and CA Coastal Commission and other agencies. The main issues and desires P4P has obtained and transmitted are the same as Carlsbad Citizens have expressed for years – the need and desire for Parks and Open Space, and concerns about increasing density. Data gathered by P4P show a significant need for Park and Open Space at Ponto, and how Ponto has been developed at much higher densities than the rest of the City. Ponto has a substandard amount Growth Management required Useable Open Space. South Carlsbad (62% or 2/3’s of Carlsbad Citizens and families) have no Coastal Park. Ponto has unique and critical importance as the last major vacant Coastal land in South Carlsbad to provide a true City Park. How the Carlsbad Tomorrow Growth Management Committee and City Council, and CA Coastal Commission plan and development Ponto will forever define South Carlsbad’s future. 1. Carlsbad’s Park Master Plan maps show that Ponto is not served by Parks and states that Ponto is one of the areas where the Council should make new Park acquisitions. 14.3 acres of world-class vacant land is available at Ponto for a needed Park. P4P is concerned about using tax-payer dollars wisely. Initial P4P cost-benefit analysis using City data indicates that buying and developing a Park on the 14.3 acre site would save tax-payers $8-$32 million relative to a 2.3 mile PCH Relocation from Island Way south to La Costa Avenue. Ponto Park would also increase City land resources by 14.3 acres compared with planned City spending on the PCH Relocation that does not produce any new land. PCH Relocation is a reconfiguration of narrow strips of existing somewhat constrained City land in the PCH roadway median at a City stated tax-payer cost of $60 - $85 million ($26 to $40 million per mile). Providing about 1.6 miles of missing sidewalks in PCH costs about 1/10th the cost of PCH Relocation. The City’s 2001 ERA Financial Study of PCH Relocation provides important information about the tax-payer costs and location/amount of Park land possible from PCH Relocation. a. Will the Carlsbad Tomorrow Growth Management Committee (CTGMC) recommend to the City Council to study the cost/benefits/value of a Ponto Park acquisition v. PCH Relocation? b. Will the CTGMC support public discussion and City Council consideration of tax payer’s cost- benefit analysis of the following: i. 14.3 acre Ponto Park, ii. 2.3 miles of PCH Relocation, and iii. Providing missing sidewalks for the 2.3 miles of PCH, and additional beach parking? 9/22/22 questions & input to CTGMC – Parks & Open Space unfairness at Ponto Page 2 of 8 c. Will CTGMC support making Carlsbad’s 2001 ERA Financial Study of PCH Relocation publicly available on the CTGMC website? d. Will CTGMC support making P4P’s tax-payer Cost-Benefit analysis of Ponto Park, PCH Relocation and adding needed sidewalks available on the CTGMC website)? e. Will CTGMC support working with Carlsbad Citizens to openly study acquiring a Ponto Park site? 2. Carlsbad’s 2017 Sea Level Rise Impact Report notes Ponto will lose over 32-acres of “High-priority Coastal Open Space Land Use” due to coastal erosion and flooding - 14+ acres of beach and 18+ acres of Campground. But Carlsbad’s 2015 General Plan and Proposed Local Coastal Program Amendment couldn’t consider 2017 Sea Level Rise data. So Carlsbad’s 2015 General Plan & proposed Coastal Land Use Plan are not replacing the 32+ acers and campground that will be lost. The following images from Carlsbad’s 2017 Sea Level Rise Impact Report show the new campground bluff edge and shoreline from sea level rise vulnerability: (biyof Carlsbad L U lll->rl'!lil S,cu I evd Rise Vu/11r,wbilily A.~!>11!..wnr,11/ FiF,ure :;: CoSMoS Dluff erosion Projections by 2100 (CoSMoS CO/\ST 2015) 9/22/22 questions & input to CTGMC – Parks & Open Space unfairness at Ponto Page 3 of 8 ....... ~{Mfru<t.j' □•~•1/11)'(.0!<'0• Fiflll''< 7. !oU!hErn ShorelhePlinrii,e-An:3-Ytar ZOSC• •••• --, .•• ~ ... ..-.... JO~-( ~-.~ .,.,,,.,...,,...,n;: --"•""""'" E»ll81TE6 9/22/22 questions & input to CTGMC – Parks & Open Space unfairness at Ponto Page 4 of 8 a. Will CTGMC recommend to the City Council to revise the 2015 General Plan and proposed Coastal Land Use Plan for Ponto to address the impacts of sea level rise on Ponto Open Space and citizen desire for a Ponto Park? 3. 38% of Carlsbad families live in North Carlsbad. 62% of Carlsbad families live in South Carlsbad. There is significant inequity in the amount of City Parks and City Park Acres the City provides in North & South Carlsbad; and most significantly in what the City provides west of I-5 in Coastal North and South Carlsbad. In North Carlsbad there are 10 City Parks totalizing 37 acres west of I-5, or about 1 acre of Coastal City Park for each 1% of Carlsbad population or 1,147 Carlsbad residents. In South Carlsbad there are 0 (zero) City Parks totaling 0 (zero) acres of City Park west of I-5. For South Carlsbad citizens and their families this lack of equitable City Park acres is unfair. This is also unfair to North Carlsbad citizens by increasing traffic, parking and Park congestion. The following image compiled from Carlsbad’s Park Master Plan shows the unfairness in City Park distribution: a. Will CTGMC recommend to the City Council to provide an equal, or fairer, distribution of City Park acres west of I-5 for South Carlsbad? b. Will CTGMC support fairness in distribution of park land? No Coastal Park in South Carlsbad • Appx. 6 miles of Coast withou t a Coastal Park is a City & Reg ional need • South Carl sbad has 64,000 residents & thousands of hotel vi sitors without a Coastal park • Closest park to Ponto is Poinsettia Park, approx. 2.5 miles across 1-5 • Proposed Veterans Park is approx. 6 miles away -------- ............ ~,"' .. -~ ~~v-~ ....... "",oc-,,, '-'• •-(..-ntlo(Ul'-""P.-\l• _c..-.. ___ .. -~"'---......_._ .......... -c..-..,..,.......,__ .-c......,t~ .. .,.-...... c-.i, .... , 9/22/22 questions & input to CTGMC – Parks & Open Space unfairness at Ponto Page 5 of 8 4. Locally Carlsbad ranks relatively poorly in both providing City Park acres and distributing City Park acres so there is fair and equal access to City Parks. Carlsbad only requires 3 acres of City Park land for each 1,000 Carlsbad residents. Both the Cities of Encinitas & Oceanside require 5 acres of City Park land for each 1,000 of their residents - that is 67% more park land than Carlsbad requires. Also, Carlsbad has no requirement that City Parks be distributed to be within walking distance to homes so families can adequately access and use City Parks. Both the Cities of Encinitas & Oceanside require their City Parks to be distributed to within a 10-minute walk for all homes and families. P4P provides a 30-page ‘2022 Coastal Recreation data file’ that documents these and more Park facts. Carlsbad is also below average nationally in both providing Park acres and in fairly distributing Park acres. Carlsbad has one park for 2,797 residents with 2.95 acres of parkland per 1,000 residents. National Recreation and Park Association (NRPA) data show that Carlsbad is 20% below what is typical in providing the number of parks, and Carlsbad is 72% below what is typical in providing acres of parkland (https://www.nrpa.org/publications-research/research-papers/agency- performance-review/). The Trust for Public Land (TPL) also measures a City’s Park performance (https://www.tpl.org/city/carlsbad-california). TPL data show Carlsbad total Park land acers (including counting State Park land acres) is 26% below the Median for the TPL’s 100 ParkScore® cities, and 7% below the Median for the 14,000 cities and towns in the TPL ParkServe® database. The TPL also maps if a City provides/has Parks within a 10-minute walk to a Park; and Carlsbad is 33% below the Median for the TPL’s 100 ParkScore® cities and 9% below the Median for the 14,000 cities and towns in the TPL ParkServe® database. This comparative information has not been publicly addressed by Council or in the 2015 General Plan Update. a. Will CTGMC recommend to City Council to change/update Carlsbad’s Park Standard to at least 5 acres per 1,000 population, which would be the same as our adjacent cities of Encinitas and Oceanside? b. Will CTGMC recommend to City Council to update Carlsbad’s Park Standard to require/plan appropriately sized City Parks to serve the population within a 10-minute walk? c. Will CTGMC recommend to City Council to have a policy to work with Citizens that do not have a Park within a 10-minute walk to make sure the type, size, location, features of a Park meets their needs? 5. The 2020 Census reaffirmed City-data.com data on how densely land (population per square mile of land) is currently developed in each Quadrant of Carlsbad. The Citywide average density is around 2,800 people per square mile of land. Higher density by definition indicates more people residing within a given area of land, and demanding more Park and Open Space resources. Following is rounded Quadrant-based, and Ponto Census Block, data from https://www.city-data.com/: City Area Population per square mile % more/less densely developed than Citywide average NE Quad 2,100 25.0% less dense than City NW Quad 2,500 10.7% less dense than City 9/22/22 questions & input to CTGMC – Parks & Open Space unfairness at Ponto Page 6 of 8 Citywide 2,800 Average density of Carlsbad SW Quad 3,500 25.0% more dense than City SE Quad 3,600 28.6% more dense than City Ponto 4,100 46.4% more dense than City a. Will CTGMC recommend to City Council to update City policy so that more densely developed areas have an adequate and fair amount of Parks? b. Will CTGMC recommend to City Council a City Park and Budget policy to prioritize Park land acquisitions in more densely populated areas? c. Ponto is currently developed at over 46% higher density than the rest of the City, is not near major employment centers, and has no Parks. i. Will CTGC recommend to the City Council to update City Housing and Land Use policy to avoid increasing population density in already more densely developed areas that do not have adequate Park and Useable Open Space? 6. The City allowed Ponto developers to create higher density development at Ponto than the rest of the City. Ponto’s higher density is partially the result of the City not enforcing the City’s Growth Management Useable Open Space Standard at Ponto. Questionably the City did not require Ponto developers in Local Facilities Management Plan Zone 9 (LFMP-9) to provide the minimum Standard of 15% of all Useable land in Zone 9 as Useable Open Space. Surrounding LFMP Zones under the same/similar situations were required to provide 15% Useable Open Space. Not complying with the Growth Management Open Space Standard explains much of why Ponto is currently developed at a density that is 46.4% higher that the City. The following City GIS map and acreage calculations of Useable (“Outdoor Recreation”) Open Space and Constrained/Unusable (“Preservation & Natural Resources”) Open Space in LFMP-9 attests to the fact that Ponto is missing 30 acers of required Useable Open Space. This missing Useable Open Space, along with other issues in other areas of Carlsbad, is part of current litigation by North County Advocates - a separate citizens group. 9/22/22 questions & input to CTGMC – Parks & Open Space unfairness at Ponto Page 7 of 8 City GIS map of Ponto’s (LFMP Zone 9) Open Space: Light green areas meet the City’s 15% unconstrained Growth Management Program Open Space Standard Most Ponto Open Space (pink hatch & blue [water] on map) is “Constrained” and does not meet the Standard Aviara - Zone 19, Ponto - Zone 9 and Hanover/Poinsettia Shores – Zone 22 all developed around the same time and had similar vacant lands. City required Aviara - Zone 19 east of Ponto to provide the 15% Standard Open Space. Why not Ponto? Aviara includes the same lagoon. City required Hanover & Poinsettia Shores area Zone 22 just north of Ponto to provide the 15% Standard Open Space. Why not Ponto? Why Ponto developers were not required to comply with the 15% Useable Open Space Standard is subject to current litigation Below is City GIS data from this map City GIS map data summary of the Growth Management Standard of 15% Useable Open Space at Ponto 472 Acres Total land in LFMP Zone 9 [Ponto] (197 Acres) Constrained land excluded from Growth Management (GMP) Open Space 275 Acres Unconstrained land in LFMP Zone 9 [Ponto] X 15% GMP Minimum Unconstrained Open Space requirement 41 Acres GMP Minimum Unconstrained Open Space required (11 Acres) GMP Open Space provided & mapped per City GIS data 30 Acres Missing Unconstrained Open Space needed in LFMP Zone 9 [Ponto] to meet the City’s minimum GMP Open Space Standard per City’s GIS map & data 73% of the City’s minimum 15% required Open Space Standard is missing due to over development of LFMP Zone 9 [Ponto] • j ••-.•~•I ; , .... ~ .. ·-··· ..... Q)l:ltl$~C~ 0Patt(f$ ~ 1~PreseM11cno1H.111nfl-c:J Lf'MZ980unclt't O :t•WOO<J'~ c:Jcc,ens.,_~ 0 MlliJs g ,-~~ .•;;·';.,.-.-::~.;•.-' ..... N A O ,oo 200 300 .4(1(1 9/22/22 questions & input to CTGMC – Parks & Open Space unfairness at Ponto Page 8 of 8 Although the missing required Useable Open Space at Ponto is subject to current litigation, it is desirable for Citizens to know the CTGMC’s position on City responsibility and City recognition and correction or restitution of mistakes, and willingness to work with those impacted by possible City and/or developer mistakes. a. Does CTGMC support responsibility and integrity in City government? b. Does CTGMC support discussing and correcting City mistakes? c. Does CTGMC support discussing and working with Carlsbad Citizens impacted by possible City mistakes to find corrections? Thank you for receiving this citizen data input and answering your fellow citizens’ questions From:Lance Schulte To:City Clerk; Growth Management Committee; Michele Hardy; Council Internet Email; City Clerk; Kyle Lancaster;Eric Lardy; "Smith, Darren@Parks"; Homer, Sean@Parks; "Moran, Gina@Parks"; Boyle, Carrie@Coastal; "Prahler,Erin@Coastal"; Ross, Toni@Coastal; Tom Frank Cc:info@peopleforponto.com Subject:Public input to Carlsbad Tomorrow Growth Management Committee Sep 22 2022 meeting; and for LCPA, ParksMaster Plan Update - Parks & Open Space at Ponto-Coastal South Carlsbad Date:Monday, September 19, 2022 11:34:37 AM Importance:High Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks, Beach Preservation and Planning Commissions, , CA Coastal Commission and CA State Parks: I was out this weekend so just had time to do a quick scan and noticed some obvious missing information and ‘spin’ in the staff 'report'. I hope the CTGMC can see this and the data ‘cherry picking’ and diversions to change subjects to “recreation land” and falsely try to count or hide Park shortfalls by trying to use other 'recreation' lands areas’ as "Parks. Here is what I was able to quickly scan and note: Citizen response and Input regarding ‘Fact Sheet – Community Interest in Ponto Park” Page 1 City falsely says "City can only acquire property from a willing seller" - this is false. The City can use legal powers emanate domain and condemnation to buy property for public purpose (Parks) unless the USA & California Constitutions have been amended to only allow acquisitions from ‘willing sellers’. The Carlsbad City Council may have CHOSEEN to adopt a formal Policy/Law (or undisclosed and hidden vote) that is constraining their authority. However that City Council CHOICE does not mean the Council can CHOOSE otherwise and use legal powers emanate domain and condemnation to buy property for public purposes. Ironically the City Council has in fact used these emanate domain and condemnation powers on behalf of the Aviara Master Plan Developer to force an “unwilling seller” to sell a sewer line easement to the City for the Aviara Master Plan Developer. 1 'Park funding only comes from the City's General Fund' - this is false. Recently the Federal government provided the City of Carlsbad $ 3million to help fund Veterans Park. There are both Federal and State Grants and funding for Park acquisition. The City cites many other funding sources in its CIP, and like those other funding sources for Park acquisition, the City just does not list them. Also, the City has an Park land dedication Ordinance CMC 20.44 (per CA Quimby Act) that pre-dates growth management and requires developers to give the City Free land for use as a Park to meet the Park needs for that development. In fact 20.44 is where the 3 acre per 1,000 population Park Standard came from. 1 City fails to mention we have a 'willing seller' for 14.3 acres of vacant land at Ponto. The City cites $35 million as the price of that land. The 2-part tax-payer Cost-benefit Analysis data files sent to you should be looked at as simply buying these 14.3 acres saves tax-payers millions and is a Better Park option. P4P can show the City and you how the City could buy this property with minimal added City tax-payer cost. There are Federal and State funding (like note above) for Park acquisition. Also ALL Developers are required to give parkland for free to the City under its Park land Dedication Ordinance 20.44 and about 1.76 acres of Ponto land would be given to the City for free to be used as a Park, or the developers would have to give the City money (pay a park-in-lieu-fee) that should be sufficient to buy 1.76 acres of Park land at Ponto. 1 City Budget funding is a yearly process, and future Budgets, and even most recent Council actions, will/have changed what was in prior Budgets. Buying Ponto Park actually saves tax- payer dollars as noted in the following bullets and in the 2 files sent to the CTGMC – “2022 General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park part 1 of 2” & “City’s PCH area map w numbered notes of constraints – 2 of 2” data files. The data in these data files is from the City. As tax-payers the CTGMC should read these data files. 1 City wide approavls will also be needed for the "South Carlsbad Coastal Project (SCCP)” mentioned in the report. The SCCP is a $135 million to $150 million improvement to existing City Land and will require a City wide vote. Based on the known tax-payer Cost-Benefits of SCCP, it is not clear if votes will support this expenditure – particularly given the Citizen input the City obtained in the $50,000 survey it conducted on the SCCP, and the Council deferring the SCCP for another year. 1 The staff report incompletely says 136 dwelling units are planned for one of the sites. But the report critically failed to disclose to you that Carlsbad’s General Plan Land Use Element page 2- specifically states Carlsbad’s General Plan is not adopted UNTIL the CA COASTAL COMMISIOSN (CCC) fully CERTIFIES the current City Proposed comprehensive Local Coastal Program Amendment (LCPA). The CCC will decide if to approve-deny-approve with modification the City Proposed LCPA in 2023. As provide the CTGMC the CCC has told the City ion 2016 & 2017 that based on the Need for Coastal Recreation (i.e. Public Park) and/or Low-cost Visitor Accommodations the General Plan Land Use at Ponto may change. See the “Updated 2020 Dec 2 Planning Area F existing LCP-LUP & CCC direction to City” data file sent to the CTGMC. Read the CCC’s reasons for 2010 rejection of the Ponto Vision Plan that is the basis for the 2015 General Plan. 1 The 2017 Sea Level Rise Impact analysis did specifically cite both acres of land impacted and the type of land use that was impacted. I can send you the report if you want. I copied key acreage and land use from the SLR Analysis in the “Sea level rise and DUPA LUPA planned loss of Open Space at Ponto data file”. This data file also shows how the City falsely exempted Ponto developers from complying with the growth management 15% Useable Open Space Standard. 1 City says "South Carlsbad Coastal Project (SCCP) will Create 60 acres of available space" - this is false. The 60-acres of Space already exists. The City already owns this land. The SCCP is a $70 million (for 1-mile Manzano to Island Way segment) + $65 to $80 million (for 2.3 mile Island Way to La Costa Ave segment) for a total $135 million to $150 million project that does not buy one single square foot of new City land. Much of the City's 60-acres is already environmentally constrained by protected Habitat so will not change anything and will continue to be unusable for people use as a Park. Parks are people and Not habitat and Projected Habitat is for plants and animal and Not people. The City knows that most of these existing City owned 60-acres is not useable for people and is too narrow to be a Park. The largest part of the 60-acres is at 'the dip' in the 1-mile Manzano to Island Way segment. We ask the CTGMC to ask staff to show you a map and acreage count of that Segment, and how much acreage is planned for 1) roadway-bikeway-sidewalk, 2) Habitat, 3) useable land for people; and 4) the area that will be lost due to Sea Level Rise for each of these 3. What land uses are lost from SLR? Ask to see the same data for the existing configuration for the segment. Compare the data. Compare the total segment acres with the total 60-acres. There is no secured funding for the $135 to $150 million SCCP. The City could buy 3+ Ponto Parks for the cost of rearranging exiting features and adding a sidewalk on existing City land. The only missing feature to Complete" PCH in the two segments (total 3.3 miles) are some missing sidewalks/ped paths. Enhancements to make PCH better and safer for bikes is a very good idea, but seems like can be done within the existing PCH configuration at a fraction of the cost. See the tax-payer cost-benefit Part 1 of 2 and Part 2 of 2 SCCP/PCH Relocation data files. SCCP will also require a citizen vote to approve funds, I am also hearing that Carlsbad citizens are not that supportive of SCCP. So is the SCCP are secured funded and 'countable solution' to the documented Park deficit at Ponto & Coastal South Carlsbad? 2 City says 2,074-acres or 8% of Carlsbad is Park and recreation land (page 2-7 of General Plan). This should be itemized and mapped as the numbers likely include golf courses (mostly private) and maybe Lago land and some Lagoon waters. The City is trying to inaccurately try to use private Recreation land as a public Park. The CTGMC is supposed to compare Park Standard to Park Standards. The City’s Park Standard is fairly poor relative to Encinitas and Oceanside and many other cities, so you are being diverted from that fact. 2 432.4-acres of exiting Park & 519.7-acres of final Park based on 7/26/22 CC vote. This data should closely match the City’s General Plan Land Use data that is the data base used in the “2022 Coastal Recreation data file” sent to you. Of critical importance to the CTGMC is to note the City is apparently saying that they will only provide a final 519.7-acres of Park in City. Yet as the CTGMC knows the City CANNOT plan for Buildout or a final population. So as population continues to grow there will be less and less parkland per 1,000 population. See the “CTGMC key issues and suggestions 2022-8-8” data/suggestion file sent to you. 2 in Table 2 the City did not provide the Park Acres per 1,000 for the same City selected data set. Compare Park acres to Park acres. We provided the NRPA data in the "2022 Coastal Recreation data file" we provided the CTGMC. We also provided the even more comprehensive Trust for Public Land ParkScore data that also shows Carlsbad is below average. That more comprehensive data should be considered. See also Ponto park support letter from Trust for Public Land. CTGMC, you have a heavy burden to set Carlsbad’s Growth Management Program on a fair and sustainable course to accommodate unlimited future growth as required by the State of CA. This involves fixing past errors and fixing what was unfair and setting Standard that are continually adding more parks and Open Space as Carlsbad is forced to grow. We provided you a “CTGMC key issues and suggestions 2022-8-8” data/suggestion file that I think could help you in looking at how to set new Standards for unlimited future growth. Thank you and Aloha Aina, Lance From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Monday, September 19, 2022 9:05 AMTo: 'City Clerk'; committee@carlsbadca.gov; 'Michele Hardy'; 'council@carlsbadca.gov'; 'City Clerk'; 'KyleLancaster'; 'Eric Lardy'; 'Smith, Darren@Parks'; Homer, Sean@Parks (Sean.Homer@parks.ca.gov);'Moran, Gina@Parks'; Carrie Boyle (carrie.boyle@coastal.ca.gov); 'Prahler, Erin@Coastal'; Ross,Toni@Coastal (Toni.Ross@coastal.ca.gov); 'Tom Frank'Cc: 'info@peopleforponto.com'Subject: Public input to Carlsbad Tomorrow Growth Management Committee Sep 22 2022 meeting; andfor LCPA, Parks Master Plan Update - Parks & Open Space at Ponto-Coastal South Carlsbad Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks, Beach Preservation and Planning Commissions, , CA Coastal Commission and CA State Parks: We ask you to please consider this email and attachments in the Sept 22nd CTGMC and subsequent Land Use, Parks and Open Space discussions by the CTGMC, LCP Amendment, PCH Relocation project, Park Master Plan Update, and development proposals at Ponto. As always, and as we have repeatedly asked for since our initial 2017 letter to the City Council, People for Ponto Carlsbad Citizens asks for and are willing able to work with you to find the solutions for: • the documented Park Inequity at Ponto & Coastal South Carlsbad, • the documented missing Unconstrained Open Space at Ponto, • the future loss of 32+ acres of Coastal Open Space (State beach and Campground) due to sea level rise, • the needed upgrades to Carlsbad’s Growth Management Program and Standards (and developer required land dedications and mitigations) to account for an Unlimited population and the need for Unlimited increases in Carlsbad Parks and Open Space to address those Unlimited populations so as to assure we maintain our quality of life, • beneficial collaborations and donations, and • the wiser use of tax-payer dollars to address tax-payer needs The CTGMC and City Commission have an opportunity to do the right thing and correct the clear and obvious Park Inequity and Coastal land use Imbalance at Ponto & Coastal South Carlsbad. Please don’t kick-the-can-down-the-road and fail to consider that data and your fellow Citizen desires for a better Carlsbad. P4P Carlsbad Citizens are here to help assure we sustain and enhance our quality of life for future generations. People for Ponto love deeply Carlsbad and want to assure we leave a better Carlsbad to future generations. Sincerely and with Aloha Aina, Lance Schulte CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. FACTS: CARLSBAD TOMORROW GROWTH MANAGEMENT COMMITTEE SEPTEMBER 22, 2022 1. Zone 9 (the southwest quadrant of Carlsbad) is short 30 acres of open space per city ordinance 29.10.130. 2. City ordinance 29.10.130 states "Open Space Standard: Fifteen percent [15%] of the total unconstrained developable land area in the Local Facility Management Zone (LFMZ) must be set aside for permanent open space and must be available concurrent with development". 3. Ponto developers were falsely exempted from this standard. 4. The city's first attempt to develop this area (The Ponto Beach Village project) was denied by the Coastal Commission. 5. The Coastal Commission required the city to investigate this area for "visitor serving uses, i.e. a public park.". You are now in a position to do this! 6. There is a 14.3 acre lot available that would make a perfect coastal park in this area. This lot could be purchased at a huge taxpayer savings of $20 -$40 million compared to the currently proposed PCH relocation project that does not add a single square foot of city land. , 0,rrc~J L~'5>or,,-f'o ~+h11.-.. 7. The people for ponto group, residents in the southwest quadrant, surfriders foundation, and many other groups and citizens overwhelmingly support a coastal park at ponto. 8. We've been asking the city to work with us for over 5 years to address the open space standard and park space deficiency to no avail. 9. A Ponto park is consistent with all the elements of the community vision. We are told this document is used to make growth management decisions. This has been detailed to the mayor and city council in official meetings and ignored. 10. Please work with us to address these deficiencies. This is the southern border and entrance to Carlsbad. We, no not we, YOU have the opportunity to make something special and permanent at the southern entrance to our city. 11. The city is leaving us very few options to address our concerns with the exception of a potential lawsuit. Please do not force us down this path. Respectfully submitted by Dr. John Gama, Pharm.D, Resident of Zone 9 and Carlsbad citizen FACTS: CARLSBAD TOMORROW GROWTH MANAGEMENT COMMITTEE SEPTEMBER 22, 2022 1. Zone 9 (the southwest quadrant of Carlsbad) is short 30 acres of open space per city ordinance 29.10.130. 2. City ordinance 29.10.130 states "Open Space Standard: Fifteen percent [15%] of the total unconstrained developable land area in the Local Facility Management Zone (LFMZ) must be set aside for permanent open space and must be available concurrent with development". 3. Ponto developers were falsely exempted from this standard. 4. The city's first attempt to develop this area (The Ponto Beach Village project) was denied by the Coastal Commission. 5. The Coastal Commission required the city to investigate this area for "visitor serving uses, i.e. a public park.". You are now in a position to do this! 6. There is a 14.3 acre lot available that would make a perfect coastal park in this area. This lot could be purchased at a huge taxpayer savings of $20 -$40 million compared to the currently proposed PCH relocation project that does not add a single square foot of city land. rJ .,,J.., ~ .. t I . _ c \ .-1 I.J(1\ ~ b~> '-"'r5\)ll"-'7>~~ 7. The people for ponto gr~~~idents in the southwest quadrant, surfriders foundation, and many other groups and citizens overwhelmingly support a coastal park at ponto. 8. We've been asking the city to work with us for over 5 years to address the open space standard and park space deficiency to no avail. 9. A Ponto park is consistent with all the elements of the community vision. We are told this document is used to make growth management decisions. This has been detailed to the mayor and city council in official meetings and ignored. 10. Please work with us to address these deficiencies. This is the southern border and entrance to Carlsbad. We, no not we, YOU have the opportunity to make something special and permanent at the southern entrance to our city. 11. The city is leaving us very few options to address our concerns with the exception of a potential lawsuit. Please do not force us down this path. Respectfully submitted by Dr. John Gama, Pharm.D, Resident of Zone 9 and Carlsbad citizen Your fellow People for Ponto Citizens sent you many data files confirmed by official Carlsbad Public Records Requests including these City maps documenting the unfair distribution of Parks and that the GMP Open Space Standard was/is not met at Ponto. These Maps don't lie. They show what is true -Ponto is missing 30-acres of GMP Open Space and Ponto/Coastal South Carlsbad is UNSERVED by Parks. This is clear as day. The excuses in your report to try to wiggle out of these facts is simply trying to cover-up the on-the ground truth and reality. Your fellow Carlsbad Citizens need your help to create a much needed Ponto Park and fix the Open Space mistakes done at Ponto. We shared wonderful news that we have "willing seller" of 14 acres of Ponto land that will be a world-class Coastal Park for Carlsbad. 14 acre Ponto Park has world-class ocean/lagoon views, provides adequate dimensions to host profitable community/special events, and allows the city to apply for park grants. You have a video showing Ponto Park's greatness. And wow, we can have this 14 acres of NEW world-class City Park land at a $20-40 million tax-payer cost savings compared to the City's proposed 2.3 miles of PCH Relocation. Ponto Park saves tax-payers money and we can do so much good for other areas of Carlsbad with that savings! Carlsbad's 2001 studies show PCH Relocation does not buy one single square foot of new City land; it only rearranges Existing Facilities to maybe create a few small isolated narrow land fragments along a roadway. Ponto Park provides Citizens what they want, saves tax-payers $20-40 million, and gets 14 MORE acres of waterfront park. Coastal Park land is much needed for South Carlsbad -62% of Carlsbad's population. Carlsbad Citizens overwhelmingly asked for this Ponto Park and we ask you to put world-class Ponto Park into your GMP Update Recommendations to the Council and-save tax-payers $20-40 million. P4P Citizens can help you with revenue/grant support. You have a once in a lifetime opportunity to do something truly needed, great and world-class for Carlsbad. Please seize this wonderful opportunity. You will be forever remembered based on your decision. Don't be shortsighted. If Ponto is developed Park & Open Space opportunities will be lost forever. Please listen to your fellow citizens, look at the Maps, data and logic; be fair to South Carlsbad citizens and families;, and invest for our shared Carlsbad future. You can be great. Be great. o oa a • So a ba • • ter n , ar is ii s -- I ---------- <Cw rnre:mrtt 2_(!)l]5 <Cairr1ls;llrardl P:airrt Ma5,1te:rr llllanrn 1?,1;» 86-R9IJ c:i"rnde:d arreas airre. 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Thank you, Lance Schulte From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Monday, September 27, 2021 3:13 PMTo: 'Scott Donnell'Cc: 'Mandy.Mills@carlsbadca.org'; 'info@peopleforponto.com'Subject: RE: Our Home Our Future citizen input - Why a park is needed within walking distance to multifamily housing & why a meaningful Coastal Park is needed for Ponto/South Carlsbad - public input to DLCPA, Housing and Park planning Thanks Scott. Much appreciated If you could also please consider in your process: 1. US Census data that shows that Ponto, even with some of the remaining vacant Coastal land, has already been developed at a 39% greater residential density that the City. Given there is no Coastal Park in all of South Carlsbad the City should doubly consider the higher residential density and populations in South Carlsbad Quadrants relative to citywide averages. Denser residential development created by Carlsbad’s General Plan and GMP 1.0 basically means on-average in South Carlsbad Quadrants there are a combination of smaller backyards, less City parkland, and less open space. Common sense and good planning should provide more City Parkland for denser residential development, not less (or none). This is however not what Carlsbad’s General Plan and GMP 1.0 provided in South Carlsbad as clearly documented by City data. The following census data reconfirms South Carlsbad park inequity data/concerns People for Ponto has sent to Council: % Population Population Council ZIP Square of % of Density Density relative to District Quad Code Miles SM population Pop. (pop/SM) Citywide average 1,2 NW 92008 11 28% 27,429 24% 2,494 84% 2,1 NE 92010 8 21% 16,565 14% 2,071 70% 3,4,2 SW 92011 7 18% 24,405 21% 3,486 118% 4,3,2 SE 92009 13 33% 47,003 41% 3,616 122% City total = 39 100% 115,401 100% 2,959 100% Ponto = 0.397 1,632 4,111 139% Key Census data points: 1) 62% of Carlsbad’s population are in South Quadrants. 2) South Quadrants are 18% and 22% more Dense than the Citywide average, thus have relatively more City Park and open space needs. 3) Ponto’s 936 dwellings have a residential density of 4,111 pop/SM that is 39% more dense than the Citywide average. This makes sense when one looks at the attached Open Space data; People for Ponto Open Space map/analysis documenting missing GMP open space. This Ponto GMP Open Space shortfall is made worse by the projected/planned loss of 32+ acres Ponto Coastal Open Space Land Use due to sea level rise. The Council should know about and consider the residential density and Parks/Open Space disparities in this data and reflected by the thousands of Citizen Emails referencing this disparity. 2. the attached public input and data that you received on 11/30/20, with a particular focus on comments related to page 10-169 in the Housing Element that relate to the Ponto area: a. “Of Ponto’s 1,025 current homes, 202 in the San Pacifico Community Association were built to be affordable condominium homes with very small ‘exclusive use’ lots, zero- side yards/building setbacks and only 10-15’ wide ‘back yards’; and 384 Lakeshore Gardens homes are affordable age-restricted manufactured homes. So 586 of Ponto’s 1,025 current homes or 57% of Ponto’s housing were planned and built to be affordable. At 57% Ponto has and was developed with a consideration of affordable housing, but also was denied needed City Park facilities of at least 8-acres to meet minimum City Park Standards. Consistent with Policy 10-P.7 Ponto Planning Area F should be used to address Ponto’s ‘Park Inequity’ being ‘unserved’, and not used to increase the “over concentration” of affordable housing that was already planned and built at Ponto.” I am not against affordable housing and high density to ‘actually achieve affordable housing’, and have PMed several Housing Elements and high-density TOD land use plans and high-density projects. However, as development goes up and is more dense it is critical that Parks be provided for these dense areas and urban design requirements provide significant ground level open spaces to manage and make livable higher densities. This is the biggest issue I have in how the City is exploring densification. The City does not even mention or ask about access to Parks in your survey. Yet this is one of the most obvious and clear land use nexus with high-density residential development. The City does not appear to be presenting, discussing and addressing 3 fundamental principles of urban planning - the key requirement to require and provide sufficient Parkland within walking distance to higher density residential, provide adequate walkable parkland access to all residential neighborhoods, and for all our inland residents provide significant and sufficiently sized/dimensioned Coastal Parks to make sure inland residents, particularly those in high-density developments, have a Coastal Park to go to. Thanks, Lance From: Scott Donnell [mailto:Scott.Donnell@carlsbadca.gov] Sent: Monday, September 27, 2021 10:30 AMTo: Lance SchulteSubject: FW: Our Home Our Future citizen input - Why a park is needed within walking distance tomultifamily housing & why a meaningful Coastal Park is needed for Ponto/South Carlsbad - public input toDLCPA, Housing and Park planning Importance: High Good morning, Thank you for your comments. They will be included in the public input summary report presented to the City Council early next year. You can also provide additional input through October 1 via our online survey, available at https://www.surveymonkey.com/r/housingsites and continue to provide mail and email comments through October 22. You are also welcome to keep apprised of the project by visiting the housing plan webpage, www.carlsbadca.gov/housingplan. Further, at the bottom of this webpage is a link to sign up for email updates on the housing plan should you know other people who may want to keep tabs on the project. Last, I have forwarded your email to Mandy Mills, Housing and Homeless Services Director, as she is the current liaison to the Housing Commission. If you wish to send correspondence to the Housing commission, please copy her. Thank you. Scott Donnell Senior Planner 1635 Faraday Avenue Carlsbad, CA 92008-7314 www.carlsbadca.gov 760-602-4618 | 760-602-8560 fax | scott.donnell@carlsbadca.gov DURING THE CURRENT PUBLIC HEALTH EMERGENCY: FOR ONGOING PROJECTS, PLEASE CONTACT YOUR PROJECT PLANNER TO SCHEDULE A RESUBMITTAL DROP-OFF APPOINTMENT. FOR NEW PROJECT SUBMITTALS AND LANDSCAPE SUBMITTALS/RESUBMITTALS/ASBUILTS, PLEASE CALL OR EMAIL YOUR REQUEST FOR A SUBMITTAL DROP-OFF APPOINTMENT: Phone: 760-602-4610 Email: planning@carlsbadca.gov From: Lance Schulte <meyers-schulte@sbcglobal.net> Sent: Tuesday, September 21, 2021 8:20 AM To: Council Internet Email <CityCouncil@carlsbadca.gov>; City Clerk <Clerk@carlsbadca.gov>; Don Neu <Don.Neu@carlsbadca.gov>; Kyle Lancaster <Kyle.Lancaster@carlsbadca.gov>; Erin.Prahler@coastal.ca.gov; 'Ross, Toni@Coastal' <Toni.Ross@coastal.ca.gov>; Boyle, Carrie@Coastal <carrie.boyle@coastal.ca.gov>; Scott Donnell <Scott.Donnell@carlsbadca.gov> Cc: info@peopleforponto.com; 'Mehmood, Sohab@HCD' <Sohab.Mehmood@hcd.ca.gov>; 'McDougall, Paul@HCD' <Paul.McDougall@hcd.ca.gov>; 'McDonell, Glenn' <Glenn.McDonell@asm.ca.gov>; 'Moran, Gina@Parks' <Gina.Moran@parks.ca.gov>; 'Smith, Darren@Parks' <Darren.Smith@parks.ca.gov>; 'Homer, Sean@Parks' <Sean.Homer@parks.ca.gov> Subject: Our Home Our Future citizen input - Why a park is needed within walking distance to multifamily housing & why a meaningful Coastal Park is needed for Ponto/South Carlsbad - public input to DLCPA, Housing and Park planning Importance: High Dear Carlsbad City Council, Housing Commission, Planning Commission, and Park Commission; and CA Coastal Commission and HCD: The following is citizen feedback on Carlsbad’s 9-13-21 email to ‘Give input on locations for future housing’. It is also for consideration in Carlsbad’s Draft LCP and Parks Master Plan Amendment Processes. At the very heart of these comments is: There is finite vacant land in Carlsbad and an even smaller figment of Vacant Coastal Land in Carlsbad. This small amount of is getting smaller due to documented coastal erosion and sea level rise. Over 32 acres of high-priority Coastal Open Space Lance Use will be lost at Ponto/South Carlsbad. This very small finite vacant Coastal land is all we have to provide for the “infinite” demands for high-priority Coastal Recreation and Low-cost access to the Coast land uses from this “infinite” amount of future generations of Carlsbad and inland cities residents; and of outside Visitors to Carlsbad’s Coast. How Carlsbad, and the CA Coastal Commission and HCD, uses those precious finite fragments of vacant Coastal Land is the vital question. Since 2017 Carlsbad citizens have been asking the Council for a true, honest, open and comprehensive consideration of these issuesat Ponto. Over 4,500 emails have been sent to the Council, many City Budget Workshop requests, Hours of public testimony, and hundreds of pages of documents facts gained via official Carlsbad Public Records Requests. The proposed land use changes to high density R-23 for the 8 properties of Site 18, seem to be being operating in a ‘incomplete policy silo’ that only looks at affordable housing and is not considering needed City Park and wider Coastal Land Use issues at Ponto. This ‘policy silo process’ seems to be counter to the wise consideration and use of the last remaining vacant and redevelopable Coastal land – particularly at Ponto/South Carlsbad. Having managed creation of a Coastal City General Plan and several Housing Elements I understand and sympathize with the challenges City Staff and Council face in trying to provide for unlimited high- density residential development growth, but we need to look at preserving vacant land to provide needed City Parks to balance these high-density developments and provide needed Parks for these homes that have no/little yards. But it seems, as citizens have asked since 2017, there is better way to address those challenges. The 9/13/21 City email states: · “The city needs to identify locations for about 2,600 new homes to fulfill the state’s requirement that all cities in the region provide enough housing to meet anticipated needs. Most of these homes need to be affordable for people with moderate to low incomes, accordingto state formulas for household income levels.” Input: Per pages 33-34 of 3/23/21 2020 Housing Element Annual Progress Report to the Carlsbad City Council stated that: “Prices of Affordable Housing – Generally, the federal and state rule is that housing is affordable to a given family if the family pays no more than 30% of its monthly income for housing expenses that include the rent or mortgage payment, property taxes, insurance, utilities, and the like.” The staff report then documents that a home in Carlsbad to be affordable to Low and Moderate Incomes, requires the following home sale or rental prices: “Table 3: CY 2020 qualifying rent and utility expenses by number of bedrooms Number of bedrooms Income Group 1 bedroom 2 bedrooms 3 bedrooms 4 bedrooms Very Low $1,155 $1,444 $1,675 $1,906 Low $1,849 $2,310 $2,680 $3,050 Moderate $2,225 $2,781 $3,226 $3,671 Above Moderate > $2,225 > $ 2,781 > $ 3,226 > $ 3,671 Source: "Household Income Limits 2020", City of Carlsbad (effective April 30, 2020)” And the “for Sale Prices that are Affordable” for each income group: “Area Median Income 2020 Annual Income Affordable Purchase Price Very Low (30% to 50%) $34,651 to $57,750 $82,001 to $186,000 Low (50% to 80%) $57,751 to $92,400 $186,001 to $342,000 Moderate (80% to 120%) $92,401 to $111,250 $342,001 to $510,000 Above Moderate $111,251 or above $510,001 and above” However, Carlsbad developers seeking to justify increase residential density site in the name of ‘Affordability’ to Low or Moderate incomes are not providing homes that meet these affordable rents or purchase prices. Carlsbad’s land use regulations that promote larger unit sizes and building height and bulk work in the opposite direction and instead promote Above Moderate housing as clearly evidenced in Carlsbad’s Village where housing developed at 28-35 dwelling units per acre (that should be affordable to Low Incomes – i.e. 1-4 bedroom rent at $1,849 - $3,050, and at sales or purchase prices from $186,001 to $342,000) are instead being sold for $1.8 to $3 million as seen in the following: This data is not a criticism of expensive housing or developers seeking to maximize their profits. It simply shows that Carlsbad’s land use regulations and ‘Affordability quid-pro-quo for increasing land use density’ are not functioning as intended to promote Affordability. Carlsbad’s land use approach is simply increasing developer profit that serves to drive up land costs (land is a residual cost in land use development pro formas) and thus works to instead reduce Affordability. Simply changing land use to increase dwelling unit density to R23 or R-28-35 to provide “Affordable Housing is not really true. It is suggested that with a change in land use to increase density should be a commitment recorded on the land to actually provide the number of Affordable units being cited as the rational for increasing the density. This is an honest and accurate ‘Affordable quid pro quo’. This commitment, along with land use regulation reform, will help reduce speculative land costs that discourage Affordability. Citizens are being inaccurately told that density increases are needed to provide Affordability yet developers do not create, nor are not required to create, those Affordable units. en w <{ en 2 Bed ·oe Space 12.5 Both 12,150 Sq. F 9.)LQ $2.250.000 t ~ .... (I} .! 0 ....,, IJ'J, I"'"), co --0 N 3 Bed I 3.5 Bo I 2 7 Sq. F SOLD 3.000.000 Unaccountable density increases do however create more speculative developer profits, and increase land costs. Density increases also increases the need for City Parks (high density by its nature depends on City Parks and Open Space for livability) along with other City services and infrastructure. Yet unaccountable density increases not does not provide actual Affordable housing. So at the next City Housing Element even more Affordable Housing will be required since the prior unaccountable density increases did not create it. During this unaccountable process vacant land disappears. That vacant land is vitally needed to provide City Parks to balance and provide useable park space for residents in high density apartments/condos. The City Staff’s documents that one of the Site 18 land owners/developers are requesting an increase in land use density to R-23 that is to provide housing Affordable to Moderate Incomes. Yet there is no developer commitment or City requirement to create the numbers of Moderate Income housing identified in City Staff’s Site 18 documentation. There is no accessible City Park in the area to provide the needed City Park and open space needed for higher density development – the ‘Veterans Park solution is 6-miles away and is effectively unusable for citizens at Ponto. · “We'd like your input on 18 proposed locations for future housing chosen based on public input gathered last year.” Input: Site 18, was not a site ‘chosen based on public input gathered last year’, but was just recently chosen by a speculative developers of Site 18. As staff documents: “Staff has received a letter from one property owner expressing support for higher density.” Site 18 consists of 8 properties, so it is unclear if all 8 properties are requesting higher density. Site 18 is being proposed as a “Moderate Income housing site” (i.e. a site that will provide 90 dwelling units [DU] affordable to Moderate Incomes as noted in the City Staff’s analysis: “Potential Housing: Site 18 Site Description: Vacant Property Name: North Ponto Parcels Site Group Acres: 5.9 Potential units site can accommodate (all parcels): 90 Income Category: Moderate (based on proposed minimum density)” There is no copy of the ‘letter’ showing an accountable Affordable rational or developer commitment, or a requirement by the City that Site 18 will be developed and rented or sold to provide the 90 dwellings Affordable to Moderate Income as noted above. If the Site 18 developers would commit to recording providing that affordability it would be a responsible and accountable Affordability quid pro quo for consideration. · The City Staff report also does not discuss the various land uses changes to increase density in a properly holistic or fully comprehensive planning way. All sites should be compared on all the key metrics for suitability. For high density housing, the most fundamental metric is walkability to a meaningful City Park for outdoor recreation and breathing room. This is fundamental in that high density housing, by definition has little/no park and recreational open space - high density means many people living on a small area of land. High density without significant large and usable City Parks within walking distance simply creates dense urban environments that over time will not sustain quality of life. In addition for Site 18 and other at the Coast locations there are other land use demands of large inland populations or families and visitors come to the Coast and increase even more demands for City Parks. A comprehensibly considered Coastal Land Use Plan needs to assure vacant and redevelopable lands along the Coast provide sufficient Park land acreage for local Park needs (i.e. high density development requires more Park acreage), but also to provide extra Park acreage to address the Park needs of hundreds of thousands of inland residents and visitors to the Coast. Densifying the Coast with high density residential development runs counter to this need for Coastal Parks. The following email and attached images were submitted on 9/8/21 that illustrate the City Parks needs generated by R-23 higher density and why it is important to provide meaningful City Parks within walking distance to higher density development. Thank you for your consideration. You say it is Our Home Our Future. We hope you do the right thing for present and future generations of Carlsbad and CA citizens and visitors. Please do not let short-term and short sighted silo thinking lead to a bad decisions on the use of the last bit of vacant coastal land. Respectfully, Lance Schulte From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Wednesday, September 8, 2021 11:55 AMTo: 'CityCouncil@carlsbadca.gov'; 'City Clerk'; 'Don.Neu@carlsbadca.gov'; 'Kyle.Lancaster@carlsbadca.gov';'Erin.Prahler@coastal.ca.gov'; Ross, Toni@Coastal (Toni.Ross@coastal.ca.gov); Carrie Boyle(carrie.boyle@coastal.ca.gov); 'scott.donnell@carlsbadca.gov'Cc: 'info@peopleforponto.com'; Mehmood, Sohab@HCD (Sohab.Mehmood@hcd.ca.gov); McDougall, Paul@HCD (Paul.McDougall@hcd.ca.gov); 'McDonell, Glenn'; Moran, Gina@Parks (Gina.Moran@parks.ca.gov); Smith, Darren@Parks (Darren.Smith@parks.ca.gov); Homer, Sean@Parks (Sean.Homer@parks.ca.gov)Subject: Why a park is needed within walking distance to multifamily housing & why a meaningful Coastal Park is needed for Ponto/South Carlsbad - public input to DLCPA, Housing and Park planning Dear Carlsbad City Council, Planning Commission, Parks Commission and Housing Commission; and CACoastal Commission: I request this email and attachments be provided as official public input to the Carlsbad’s Draft LocalCoastal Program Amendment, Housing Element land use changes, Parks Master Plan Amendment, and landuse activities at Ponto and Coastal South Carlsbad. For many years Carlsbad and People for Ponto Citizens have been trying to communicate the need for ameaningful Coastal Park for South Carlsbad. There is NO City Coastal Park west of I-5/rail corridor in SouthCarlsbad (yet there are 10 such City Parks totaling over 35 acres in North Carlsbad). The Citizens andvisitors to South Carlsbad have No Coastal Park, and Ponto is the last vacant unplanned Coastal land left toprovide this needed Coastal Park. The attached images of high-density housing (R-23) in Carlsbad clearly illustrate why City Parks are neededwithin walking distance to multifamily housing. It also illustrates why meaningful Coastal Parks are neededto provide Coastal Recreation for a unlimited growing population that will primarily be housed by high-density housing that minimizes outdoor recreation space. High-density housing, by definition, provides minimal outdoor recreation space per dwelling unit. So CityParks are the only meaningful sized areas where high-density housing occupants (particularly Children) canhave room to play. This is particularly critical in regards to Coastal Parks, as Coastal Parks absorb theCoastal Park demands/needs from significant large inland and visitor populations. This critical need is madeall the more serious given sea level rise and coastal erosion impacts to Coastal Open Space. The State of California is advancing dense high-density housing to promote affordability, yet most of thebenefits of simply increasing density tend to result in increasing developer profit margins and thus increaseresidual land costs as Carlsbad has seen in Carlsbad Village. The State of California Housing Law currentlydoes not address the logical and concurrent need to both increase City Park acreage and equitablydistribute that City Park acreage within walking distance to housing – particularly high-density housing. Having a City Park within a 10-mintue walk from high-density housing is vital for the long-term viability,livability, and quality of life for high-density housing and the citizens and families that live in this housing. Hopefully the City of Carlsbad can advance the concurrent increase in City Park acreage and 10-miunte walkaccessibility in its Coastal land use, land use, housing, and parks plans. As a former city, coastal and urban planner having worked in high-density situations I have several planningpolicy ideas that maybe helpful if the City Council would like to discuss them. Thank you for your consideration. Lance Schulte From: City of Carlsbad [mailto:communications@carlsbadca.ccsend.com] On Behalf Of City of CarlsbadSent: Thursday, September 2, 2021 4:39 PMTo: info@peopleforponto.comSubject: Give input on locations for future housing Give input on locations for future housing The City of Carlsbad is seeking input on where new housing units could be built in Carlsbad to satisfy a state requirement that cities accommodate their fair share of the region’s housing needs, including homes for people of all income levels and stages of life. Eighteen proposed locations were chosen based on public input gathered last year, input from a citizens advisory committee and direction from the City Council. Of the 3,900 new housing units that make up Carlsbad’s fair share, about 2,100 need to be affordable for people with very low to moderate incomes. The city had already identified vacant residential locations and planned housing projects to help meet the state’s housing requirement, but it wasn’t enough to meet the need for 3,900 units. Review sites on an online map. Community members have three ways to provide feedback: Survey An online survey will be available through Oct. 1. Virtual public workshops (held via Zoom) Wednesday, Sept. 15, 5:30 to 7 p.m. | Register here Wednesday, Sept. 22, 5:30 to 7 p.m. | Register here City staff will provide an overview of the city’s housing plan update process and how the potential housing sites were selected. Participants will then break into smaller groups to ask questions and provide input on the potential locations. *Persons with a disability may request meeting materials in appropriate alternative formats as required by the Americans with Disabilities Act of 1990. Reasonable accommodations and auxiliary aids will be provided to effectively allow participation in the meeting(s). Please contact Sue Armstrong at 760- 434-5352 (voice), 711 (free relay service for TTY users) or sue.armstrong@carlsbadca.gov at least 48 hours prior to the meeting to discuss accessibility needs. Comments via mail or email by Oct. 22 Scott Donnell, Senior Planner, Community Development 1635 Faraday Ave., Carlsbad, CA 92008 scott.donnell@carlsbadca.gov The city is seeking input on proposed sites that would need to be rezoned, either to allow housing where it’s not allowed today or increase the number of units allowed on sites already zoned for housing. Owners and people living within 600 feet of all the potentially affected properties have been notified by mail of the potential rezoning. The city would not build housing on these sites. Instead, the city’s obligation is to identify space for housing and create policies that would facilitate new housing to be built based on different income levels and stages of life. Next steps City staff will update the map of proposed sites based on community input and then share it with the City Council in early 2022 for approval to move forward with the environmental review of those sites. · Sept. 2 - Oct. 22, 2021: Public input on potential sites for future housing · Early 2022: City Council public meeting to receive input and consider endorsing final map(s) for environmental review · Spring 2022 - Winter 2022/2023: Environmental review of housing sites and public input on environmental analysis document Background The City of Carlsbad has updated its housing plan, something required by state law to ensure the city is meeting the housing needs of all members of the community. The new plan includes policies designed to encourage the number and types of housing the state requires. It also identifies locations where new housing could be built. In all, the City of Carlsbad needs to show how about 3,900 housing units could be built over the next eight years to meet state requirements. Learn more · Map of potential housing sites · Approved housing plan (policies and strategies) · Housing plan update website · Scott Donnell, senior planner, scott.donnell@carlsbadca.gov, 760-602- 4618 Visit the Website City of Carlsbad | 1200 Carlsbad Village Drive, Carlsbad, CA 92008 Unsubscribe info@peopleforponto.com Update Profile | Constant Contact Data Notice Sent by planning@carlsbadca.gov CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. , Cifyof Carl~!Jad From:Lance Schulte To:Matthew Hall; Council Internet Email; City Clerk; Scott Chadwick; Gary Barberio; Don Neu; Kyle Lancaster; "MikePacheco"; david.decordova@carlsbadca.gov; Scott Donnell; Erin.Prahler@coastal.ca.gov; Ross, Toni@Coastal;cort.hitchens@coastal.ca.gov; Lisa Urbach; info@peopleforponto.com; Planning Cc:McDougall, Paul@HCD; Mehmood, Sohab@HCD; Bret Schanzenbach; Kathleen@carlsbad.org Subject:RE: Carlsbad Citizen Questions and request to Carlsbad City Council-Planning-Parks-Housing Commissions forCarlsbad Staff proposed Draft LCP-LUPA-Housing Element & Parks Master Plan Updates - 11-30-2020 Date:Sunday, November 29, 2020 2:14:14 PM Attachments:2020 Nov 30 - Draft Housing Element Update - People for Ponto Public Comments.pdf#1 - Carlsbad FY 2019-20 Budget Public Input Report - Summary analysis for Public Comments on Budget-DLCPA-PMU.pdf#2 - South Carlsbad Ponto Beach Park Letter of Request - SPCA 2017 Aug 17.pdf#3 - 2020-11-30 Citizen Questions and request for Carlsabd on Draft LCP-LUPA-Housing Element and ParksMaster Plan Updates.pdf#4 - 2020 Jan 28 Carlsbad CC meeting item #14 public testimony1.pdf#5 - Carlsbad 2019 proposed Draft LCP Amendment - People for Ponto additional Comments - Coastal Recreationw - 1.pdf#6 - Carlsbad 2019 proposed Draft LCP Amendment - Public Comments - Low-cost Visitor Accmodations.pdf#7 - 2020 Sept 14 public inout to Carlsbad- CCC-HCD on DLCP-LUPA-HEU-PMPU.pdf Dear Carlsbad City Council, Planning Commission, Housing Commission, Parks Commission, Housing Element Advisory Committee, CA Costal Commission & HCD: Attached is 2020 Nov 30 public input on the Draft Housing Element Update, and Draft Local Coastal Program Land Use Plan Amendment and Parks Master Plan Amendment. Because the Draft Housing Element Update refers and relates to and is thus connected with these other processes, particularly the Draft Local Coastal Program Land Use Plan Amendment process, the comments are sent to all. Thank you. Sincerely, Lance Schulte Nov 30, 2020 People for Ponto citizen public input on: Carlsbad’s Draft Housing Element Update Carlsbad Planning Commission for the Draft Local Coastal Program Land Use Plan Amendment; Carlsbad Park Commission for the Draft Parks Master Plan Update; and City Council and CA Coastal Commission for all the above Draft updates and amendments Page# Citizen concern & public input Overall Since 2017 there has been extensive Carlsbad Citizen input provided to the City Staff and City Council concerning the documented past/present ‘City Coastal land use planning mistakes’ at Planning Area F at Ponto (a site the City Staff is including in the housing inventory), and Citizens documenting and expressing the need for Ponto Park on Planning Area F and desire for the City Council to acquire it for a much needed (and only) Coastal Park for South Carlsbad. The extensive Carlsbad Citizen input to the City gathered by People for Ponto Carlsbad Citizens (as of Nov 2020) includes over 2,700 emailed requests for the Ponto Park, over 200-pages of public testimony and data documentation showing the Carlsbad Citizen need for Ponto Park, and numerous presentations to the City Council showing Ponto Park needs and Citizen’s requests for Ponto Park. Ponto Park was also by far the most cited Citizen need and request for City Council funding during both the 2019 and 2020 Budget processes. Over 90% of Citizen requests during both those City budget processes asked or Ponto Park [see attachment 1 & go to the 6/2 & 6/24/20 City Budget at https://carlsbadca.swagit.com/play/06022020-906 & https://carlsbadca.swagit.com/play/06232020-1181 and listen to and read the public testimony as the files are too big to email]. Due to the 4-person City Council and 2-2 City Council split these extensive Citizens needs and requests were not acted on. With the recent election, there is now a 5th Council person (from District 4 that includes Ponto) to provide a City Council decision on Citizen needs and desire for Ponto Park. People for Ponto citizens have asked the City Staff circulate and provide the extensive Carlsbad Citizen input, need and request for Ponto Park to Carlsbad’s Planning, Parks and Housing Commissions, and the Housing Element Advisory Committee (HEAC), so the primary CA Coastal Land Use planning issues area coordinated between the City Staff’s proposed Draft Local Coastal Program Land Use Plan Amendment, Housing Element Update, and Parks Master Plan Update processes. Unfortunately, City Staff communication, coordination and inviting People for Ponto Carlsbad Citizens to be involved when the Ponto Planning Area F land use issues are being considered by the Planning, Parks and Housing Commissions, and the Housing Element Advisory Committee does not seem to be happing. On 2017 what is now a much larger People for Ponto group of Carlsbad Citiznes asked the City Council and City Staff for a better Ponto Planning Process, and documented why Ponto Park is more consistent with Carlsbad’s Community Vision (the foundation for Carlsabd’s Genral Plan, and land use plan) [see attachment #2] In 2017 People for Ponto filed official Carlsbad Public Records Requests, and found the City make multiple ‘planning mistakes’ at Ponto, and particularly at Planning Area F with regard to non-compliance with Carlsbad exiting Local Coastal Program and also overall Growth Management Standard Open Space acreage requirements at Ponto. These have been documented to the City on several occasions and are highlighted on pages 2-5, 6-7, 11-12, and 14-16 in Attachment #3. As summarized on page 11 in Attachment #3, in 2017 the CA Coastal Commission informed the City how the City’s proposed Ponto Planning Area F General Plan Land Use designation change from the existing “Non-residential Reserve” to R-23 & General Commercial could change if ‘higher-priority’ Coastal Recreation or Low-cost Visitor Accommodations area needed at Ponto. City Staff first and only provided that information to the City Council (and one assumes also the Carlsbad Planning, Parks and Housing Commissions) on 1/28/20. On 1/28/20 City Staff introduced the Draft Local Coastal Program Land Use Plan Amendment process to the City Council. We are not sure if City Staff provided the CA Coastal Commissions’ direction tot eh City on Ponto Planning Area F to the Planning, Park, and Housing Commissions and HEAC? The CA Coastal Commission is the final land use authority at Ponto since Ponto is in the CA Coastal Zone and is governed by the CA Coastal Act, which supersedes Carlsbad’s General Plan. Land use in the CA Coastal Zone and the State law that governs land use in the CA Costal Zone, the CA Coastal Act is not constrained many CA Housing laws. This is logical as the Coast is a very limited State resource and many critical Coastal land uses can only be provided in the Coast, whereas housing can be provided over a much larger land area and based on beneficial surrounding land use adjacencies is better located in inland locations. At the above mentioned 1/28/20 City Council meeting there were numerous apparent errors, omissions or misrepresentations in the Staff Report. These errors/omissions/misrepresentations had critical reference and relevance to the Draft Housing Element and how CA Coastal Act and state housing laws interact. People for Ponto submitted written and verbal testimony at the 1/28/20 meeting on these errors/omissions/misrepresentations [see attachment #4]. The Housing Commission and HEAC, Planning Commission and Parks Commission should review and consider Attachment #4 in evaluating the Draft Housing Element Update, Draft LCP-LUPA and Draft Parks Master Plan Update. As documented in Attachment #5 Carlsbad’s 2015 General Plan clearly recognizes that Carlsbad’s General Plan land use changes to Carlsbad’s Coastal Zone from the 2015 General Plan Update are not valid until the CA Coastal Commission fully “Certifies” a Local Coastal Program Land Use Plan Amendment (LCP-LUPA). This has not yet occurred. The CA Coastal Commission will likely consider Carlsbad’s Draft LCP-LUPA in 2021-2022. As noted in Attachment #3, based on the 2010 and two 2017 communications from the CA Coastal Commission, the CA Coastal Commission may or may not “Certify” the City’s proposed, Coastal land use change at Ponto Planning Area F from it’s current “Non-residential Reserve” land use to R-23 Residential and General Commercial. People for Ponto Citizen data provided to both the City and CA Coastal Commission show Carlsbad appears to both significantly lag behind other Coastal cities in providing both Coastal Recreation (i.e. Public Park) and Low-cost Visitor Accommodation that at high-priority Coastal land uses at Ponto [see Attachments #5 & #6]. Thus the CA Coastal Commission may direct Carlsbad to change its General Plan at both Ponto Planning Area F and maybe at other areas to provide these ‘higher-priority’ Coastal land uses consistent with the CA Costal Act, and Carlsbad’s existing LCP requirements for Ponto Planning Area F. The Housing Commission and HEAC, Planning Commission and Parks Commission should review and consider Attachments #5 & #6 in evaluating the Draft Housing Element Update, Draft LCP-LUPA and Draft Parks Master Plan Update. Ponto Planning Area F is only 11-acres is size, and is the last remaining vacant and unplanned Coastal land is South Carlsbad to provide for the ‘forever supply’ of Coastal Recreation to accommodate the ‘forever increasing population and visitor demands’ of ‘High-Priority Coastal Recreation and Low-cost Visitor Accommodations’. This issues of Coastal ‘buildout’ of ‘High- priority Coastal land uses v. a forever increasing Carlsbad and CA residential population and visitor demand for those ‘High-Priority Coastal land uses was presented to and asked of Carlsbad’s City Council; Planning, Housing and Parks Commissions, HEAC, CA Coastal Commission and CA Housing and Community Development on 9/14/20 by People for Ponto Citizens [see attachment #7 on page XX below]. As yet there has been no City/State reply and City opportunity to fully discuss the issues in the 9/14/20 email. Ponto Planning Area F is the last critical and most economical area for those high-priority uses in South Carlsbad. Conversely, Planning Area F has a negligible impact on Carlsbad’s affordable housing supply as documented in the Draft Housing Element. The Draft Housing Element documents a significant oversupply of housing and most critically affordable housing opportunities without even including the potential (only if both the City ultimately proposes and CA Coastal Commission actually ‘Certifies’ a change to Ponto Area F Coastal land use to residential) for Ponto Planning area F’s residential use. As noted on the comments below relative to Draft housing Element page 10-92 and Table 10-29, the City’s proposed Planning Area F’s R-23 residential and General Commercial use would yield a potential 108-161 min-max range of dwellings. Of these 20% would be required to be affordable at the “Lower” income category since the City would have to transfer “excess Dwelling Units” to Planning Area F’s “Non-residential Reserve” Coastal land Use. This 20% is a relatively small 22-32 “Low” income units. 22-32 “Low” income units is only .40% to .59% of all the “Lower” income housing units provided by Carlsbad in the Draft Housing Element; and is only .66% to .96% of the amount of the “Excess” (beyond the RHNA requirement) Lower Income housing units” provided by Carlsbad’s Draft Housing Element. So Ponto Planning Area F has no impact on Carlsbad meeting its RNHA allocation, and has a negligible 0.66% to 0.96% impact on the amount of “Excess” (beyond the RHNA requirement) Lower Income housing units” provided by Carlsbad’s Draft Housing Element. Yet Ponto Planning Area F has a profound, critical and truly forever impact on Carlsbad’s and the State of California’s Coastal Land Use Priorities for Coastal Recreation for the 64,000 current and growing numbers of South Carlsbad residents who want and need a Coastal Park. Ponto Planning Area F is the last meaningful vacant and unplanned Coastal land is South Carlsbad to provide Coastal Park, and the most affordable and tax-payer efficient Park Carlsbad could provide. Forever squandering this last bit of precious Coastal Land for residential use so a few (86-129) can buy $ 1+ million homes, and a fewer ‘lucky’ (22-32) subsidized affordable homeowners have a coastal location; while forever denying a far greater 64,000 (and growing) South Carlsbad residents-children their only South Carlsbad Coastal Recreation (i.e. Public Ponto Park) opportunity does not make sense for ether the City or State of California. Forever squandering Ponto Planning Area F for a few years of “Excess” residential land for some very expensive luxury homes does not seem to make sense. So, the Housing Commission and HEAC should at this time remove Ponto Planning Area F from the Housing Element at this time. The City should only consider including it in the Housing Element as ‘vacant housing site’ if and after the CA Coastal Commission ‘Certifies” the City’s proposed Coastal Land Use change from the existing LCP-LUPA “Non-residential Reserve” land use to a ‘lower-Coastal-priority’ residential land. Additional Data in support of the above Citizen request, & Draft Housing Element Comments: 10-63 States: “Coastal Zone: Although sites located within the Coastal Zone, as defined in the 2019 Local Coastal Program (LCP) Land Use Plan, are not excluded, areas within the Coastal Zone have been carefully considered, as any necessary redesignations in this zone would require additional processes and time, which can be a constraint to housing development.” It is unclear what this means? Also, this section fails to disclose some very critical Coastal Zone, that are governed by the CA Coastal Act, issues relative to the CA Coastal Act’s superiority over CA Housing Laws if there is competing land use priorities or conflicts. This is logical and also written into State Law such as SB 330 (Skinner) Section 13 that states: “(2) Nothing in this section supersedes, limits, or otherwise modifies the requirements of the California Coastal Act of 1976 (Division 20 (commencing with Section 30000) of the Public Resources Code). For a housing development project proposed within the coastal zone, nothing in this section shall be construed to prohibit an affected county or an affected city from enacting a development policy, standard, or condition necessary to implement or amend a certified local coastal program consistent with the California Coastal Act of 1976 (Division 20 (commencing with Section 30000) of the Public Resources Code).” This language is consistent with CA case law, and other housing laws that recognize the obvious – there is very limited amount of Coastal land v. significant land area inland. Limited Coastal Land per the CA Coastal Act is needed for CA “High-Priority” Coastal Land Uses” - i.e. Coastal Recreation and Low-cost visitor accommodations primarily in a city such as Carlsbad. The CA Coastal Act identifies both residential and general commercial land uses as “low-priority” as these can be well provided in non-Coastal Zone areas. So although affordable housing is important there are other more appropriate locations, than on the last remaining vacant Coastal land in South Carlsbad that will be needed to address the “High-Priority” Coastal Land Uses to serve Carlsbad and California’s ‘buildout’ needs. CA case law recognizes the supremacy of the CA Coastal Act over CA Housing Laws as noted in “Kalnel Gardens, LLC v. City of Los Angeles” et. al. The Coastal Zone section on 10-63 should be clarified and acknowledge the CA Coastal Act Polices that concern California’s Coastal Land Use priorities. Given future increases in Carlsbad and CA populations (and visitors) and those populations needing increases in Coastal Land for Coastal Recreation, it is prudent for the City of Carlsbad to plan and reserve the last remaining fragments of Coastal Land for Coastal Recreation land use to address these population increases [see Attachment 7]. 10-92 Table 10-29: This table shows that Carlsbad has more than sufficient housing sites to address all its RHNA numbers in this cycle. Carlsbad and the State of California both have higher priority Coastal Land Use needs at Ponto Planning Area F then for housing. This is all the more relevant in that the housing proposed at the 11-acre Ponto Planning Area F is: relatively small and has negligible impact on overall city housing goals, would not really further Carlsbad’s nor the State of California’s affordable goals, in that housing being designed-marketed and that housing market will price and sell homes for well over $1 million per unit; and even if you build 3-5-10 stories high the market sell price would be the same or very similar, due to its Coastal location, will likely not even be exclusively used for housing, but market forces will promote more profitable short- term or medium term visitor rental use, and if for some reason the City will still be requiring the Ponto Planning Area speculative land owner to actually provide 20% of Planning Area F’s potential 108-161 min-max range of dwellings as affordable at the “Lower” income category as is currently required, this is a relatively small 22-32 “Low” income units. 22-32 “Low” income units is only .40% to .59% of all the “Lower” income housing units provided by Carlsbad and is only .66% to .96% of the amount of “Excess” Lower Income housing units” provided by Carlsbad’s land use plan. The landowner already has tried to offload their 20% Lower income requirement to an inland location around the airport but could not do so for several reasons, but likely will try again. So Ponto Planning Area F is well below 1% influence on Carlsbad housing; yet has a significant impact on Carlsbad’s and the State of California’s Coastal Land Use Priorities for Coastal Recreation. In reference to the above bullet, The current Costal Land Use for Ponto Planning Area F is “Non-Residential Reserve” and has no residential land use associated with it under Carlsbad’s General Plan as currently Certified by the CA Coastal Commission. So the City of Carlsbad currently requires under its Growth Management Plan to transfer some excess SW Quadrant dwelling units from the City’ housing unit bank to the Ponto Planning Area F site change the Area F’s land use for residential use. For this dwelling unit transfer the City requires a developer/land owner to provide 20% of the dwelling as affordable to “Low” incomes. The City has a formal agreement with the Ponto Planning Area F land owner requiring this 20% “Low” income housing on-site in exchange for City’s ‘transfer of Excess Dwelling Units’ specifically to an existing “Non- residential Reserve” Coastal land use site in Carlsbad’s current LCP. Draft Housing Element pages 10-117 to 119 documents the City’s ‘Excess Dwelling Units’ program. 10-110 Construction and Labor Costs: The Draft Housing Element states that the total cost to build housing is composed of the following cost components - 63% are construction building materials and labor, 19% are administrative legal, professional, insurance, and development fee costs, 10% are conversion (title fees, operating deficit reserve) cost, and 8% are acquisition costs (land and closing costs). Developer profit is then added on top of these costs and sets the ‘minimum price’ a developer can offer to sell/rent a housing unit. Typical minimum estimated developer profit to determine if a project is feasible is around 10%. So land cost at 8% is the lowest cost component in housing development. Developer profit can increase beyond this in a hotter housing and can reduce in a cooler market than the Developer projects in their project pro-forma. A market housing builder, understandably, looks to maximize their profit and if possible reduce risk. So should the Draft Housing Element focus on the major housing cost factors (construction costs) and possibly reduce developer risk by providing more robust policies to provide direct subsidies to market developers to pay for their developer’s 10% profit and some of the major constriction costs for in exchange for permanent affordability on the dwellings so subsidized? It may be a non-typical idea, but would kind of be like developer profit insurance, and maybe worth exploring. If a market developer is guaranteed their 10% profit on their dwelling unit costs then this would seem good for them – they are guaranteed to make their 10% profit. The challenge would be how to fund the City’s, or State HCD’s developer profit insurance pool to fund such an affordability program. 10-115 Growth Management Plan Constraints Findings: This section starts out with the following statement: “With the passage of SB 330 in 2019, a “city shall not enact a development policy, standard, or condition that would...[act] as a cap on the number of housing units that can be approved or constructed either annually or for some other time period.” This opening statement is very incomplete and misleading on four (4) major points: 1. For clarity the statement should document that SB 330 applies to Charter Cities like Carlsbad. Carlsbad Charter has specific language relative to the Growth Management Program, and this should be explained. 2. SB 330 is clearly short-term 6-year housing crisis legislation, that is set to will expire on 1/1/2025 – 5-years from now. a. This short-term 6-year applicability of SB 330 should be clearly disclosed up- front particularly if a short-term law is being used to overturn Carlsbad’s City Charter and change decades of Carlsbad infrastructure planning. It will likely take Carlsbad 5-years to create and get adopted by the City and CA Coastal Commission (for Carlsbad’s Coastal Zone) to comply with SB 330 only to have SB 330 expire. b. Also, as is logical in a short-term law that will expire in 5-years, SB 330 is only applicable to a City “enacting” such policy within the time SB 330 is law (i.e. until 1/1/2025). SB 330 language is “enact” and that word reflects future action not a past City action. SB 330 being short-term 6-year legislation uses the word ‘enact’ that refers to a future action To be apical to a past action the language would have to be ‘have enacted’ but should have clearly indicated all such past laws are now invalid until 1/1/2025. It is illogical to have a short-term crises legislation that expires in 1/1/2025 overturn over 30-years of pre-SB 330 development policies in Carlsbad and possibly other cities, particularly when the actual language of SB 330 does not clearly state so. 3. Carlsbad’s Draft Housing Element will be valid from 2021-2029 or 4-years beyond the expiration of SB 330. If the Draft Housing Element is meeting its RHNA numbers for the years 2021-2029 and not creating “a cap on the number of housing units that can be approved or constructed” during the 6-year period when SB 330 is the law (only until 1/1/2025) then there seems no Growth Management Program “Constraint” on the 2021-2029 RHNA numbers and SB 330 set to expire on 1/1/2025. 4. As noted above for page 10-63, SB 330 (Skinner) Section 13 states that: “(2) Nothing in this section supersedes, limits, or otherwise modifies the requirements of the California Coastal Act of 1976 (Division 20 (commencing with Section 30000) of the Public Resources Code). For a housing development project proposed within the coastal zone, nothing in this section shall be construed to prohibit an affected county or an affected city from enacting a development policy, standard, or condition necessary to implement or amend a certified local coastal program consistent with the California Coastal Act of 1976 (Division 20 (commencing with Section 30000) of the Public Resources Code).” This should be clearly stated. This section of the Draft Housing Element needs more research and full disclosure of the four (4) above SB 330 issues. Also the Section should address the 3 foundational issues emailed on 9/14/20 ‘Citizen public input for Housing Element & Parks Master Plan Updates, & Draft Local Coastal Program Land Use Plan Amendment’ to the ‘Carlsbad City Council, Housing-Parks-Planning Commissions & Housing Element Advisory Committee; & State of CA Coastal Commission, Parks, Housing & Community Development Department’ [Attachment7]. 10-119 Mitigating Opportunities, 2nd paragraph: the 3 foundational issues emailed on 9/14/20 ‘Citizen public input for Housing Element & Parks Master Plan Updates, & Draft Local Coastal Program Land Use Plan Amendment’ to the ‘Carlsbad City Council, Housing-Parks-Planning Commissions & Housing Element Advisory Committee; & State of CA Coastal Commission, Parks, Housing & Community Development Department’ should be address here also. How can Carlsbad or any California City plan to assure their land use plans’ “primary tenant that public facilities keep pace with growth” occur if population growth is unlimited and will increase each RHNA cycle while at the exact same time a City’s vacant land, and critical vacant Coastal Zone land, is getting smaller and will eventually effectively be gone? Without new vacant land and critical new vacant Coastal Zone Land to provide new City Parks and new Costal Recreation to ‘keep pace with growth’ in population and visitors how can Carlsbad’s and California’s quality of life be maintained or enhanced? Are City Park Standards of 3-5 acres of Parkland per 1,000 populations to become void when there is no more vacant land to provide New Parks needed for an unlimited growth in population? Will California’s Coastal Recreation resources not be allowed to concurrently grow in land area and be appropriately distributed with population and visitor growth? Will California’s beloved and economically important Coastal Recreation resources then become ‘loved to death’ by more overcrowding from unlimited population and visitor growth? Without providing concurrent, equivalent, and unlimited growth in new Coastal Recreation land for the growth of those two populations a slow, but eventual deterioration will occur. These are fundamental issues of CA State priorities, particularly between the CA Coastal Act and CA Planning and Zoning and housing laws. 10-123 California Government Code Section 65863: The California Government Code Section 65863 exceptions should all be listed, and if section 65863 supersedes the CA Coastal Act and how the CA Coastal Commission may finally decide to finally Certify Coastal land use at Ponto in he next year or so. As per Carlsbad’s General Plan the General Plan at Ponto is not adopted until the CA Coastal Commission fully Certifies or Certifies with Modifications Carlsbad’s Draft Local Coastal Program Land Use Plan Amendment. Carlsbad’s Draft Housing Element already shows “Excess” housing capacity to meet RHNA numbers limits without the need for Ponto Planning Area F. 10-149 California Coastal Commission: This section is incomplete. It is missing some key fundamental and common-sense land use principles regarding the CA Coastal Commission; CA Coastal Act; State ‘Coastal Land Use Priorities’ under the CA Coastal Act that Carlsbad needs to follow; and that CA housing law does not ‘supersede, limit, or otherwise modify the requirements of the California Coastal Act of 1976’. The fundamental and common sense land use principles are that the Coastline and Coastal Land near the Coast area a very small areas that need to provide high-priority Coastal land use to serve a magnitudes larger inland area and visitors to the coast. This very small Coastal Land needs to “forever” provide for All the Future Coastal Recreation needs for Carlsbad, Cities inland of Carlsbad, CA Citizens such as those coming from LA Metro region, and for all the out-of-state Visitors that visit Carlsbad. This is a huge amount of both Present and Future Coastal Recreation demand focused on a very small land area. Attachment #5 data documents the projection of both population and visitor growth that will increase demands for Coastal Recreation. Most all of Carlsbad’s Coastal Zone is already developed and not available to address those needs. In 2008 only 9% of Carlsbad was vacant, and maybe only ½ or less of that 9%, say only 4.5% was vacant land in the Coastal Zone. This 4.5% of vacant land is likely even a smaller percentage in 2020, and will be an even smaller in 2029 at the end of the Housing Element’s planning horizon. The Draft Housing Element does not indicate amount of Vacant Coastal Land in Carlsbad in 2020. This small remaining less than 4.5% of Carlsbad must forever provide for All the future Coastal Priority Land Use needs such as critical Coastal Recreation (i.e. Public Park) that is the lowest cost method to access and enjoy the coast. Ponto Planning Area F is the last remaining vacant land to provide for “High-Priority Coastal Recreation Land Uses” in an area in need of a Coastal Park consistent with CA Coastal Act. Housing however can be, and is better located in more inland areas where there is more land, more vacant land, more affordable land, and where there is 360 degrees of surrounding land that supports housing, such the bulk of employment and commercial centers and public services such as schools. The common-sense logic that very limited and finite Coastal Land should be used primarily for only those land uses that can only be provided by a Coastal location finally came to forefront in the 1970’s after years of sometimes poor Coastal land use decisions by Cities. In the 1970’s CA citizens and then the CA State government addressed how California’s limited Coastal Land area should be ‘Prioritized’ for use with the CA Coastal Act. In that regard the CA Coastal Act (CA PRC Section 30001.5) has the following goals: (c) Maximize public access to and along the coast and maximize public recreational opportunities in the coastal zone consistent with sound resources conservation principles and constitutionally protected rights of private property owners. (d) Assure priority for coastal -dependent and coastal-related development over other development on the coast. In support of these Goals there are numerous regulatory policies that prioritize and guide how Coastal Land should be used such as: • Section 30212.5 … Wherever appropriate and feasible, public facilities, including parking areas or facilities, shall be distributed throughout an area so as to mitigate against the impacts, social and otherwise, of overcrowding or overuse by the public of any single area. • Section 30213 … Lower cost visitor and recreational facilities shall be protected, encouraged, and, where feasible, provided. Developments providing public recreational opportunities are preferred. … • Section 30221 Oceanfront land suitable for recreational use shall be protected for recreational use and development unless present and foreseeable future demand for public or commercial recreational activities that could be accommodated on the property is already adequately provided for in the area. • Section 30222 The use of private lands suitable for visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have priority over private residential, general industrial, or general commercial development, but not over agriculture or coastal-dependent industry. • Section 30223 Upland areas necessary to support coastal recreational uses shall be reserved for such uses, where feasible. • Section 30251 … The location and amount of new development should maintain and enhance public access to the coast by … 6) assuring that the recreational needs of new residents will not overload nearby coastal recreation areas by correlating the amount of development with local park acquisition and development plans with the provision of onsite recreational facilities to serve the new development • Section 30255 Coastal-dependent developments shall have priority over other developments on or near the shoreline The CA Coastal Commission (CCC) uses the CA Coastal Act Goals and Polices in reviewing the Coastal Zone areas of Carlsbad’s General Plan and thus Coastal Zone area of the Housing Element to determine if the CCC can certify the Coastal Zone of Carlsbad’s General Plan as being in compliance with the CA Coastal Act. Carlsbad’s General Plan Land Use Element clearly states on page 2-26 that “The city’s LCP Land Use Plan will be updated consistent with this General Plan. However, to take effect, the LCP must be certified by the Coastal Commission as well as adopted by the city. Until such time that this occurs, the existing (as of 2013) LCP must be adhered to.” For one small 11-acre vacant site – Ponto Planning Area F – Carlsbad’s existing Local Coastal Program land use plan and regulations are: “Planning Area F carries a Non-Residential Reserve (NRR) General Plan designation. Planning Area F is an “unplanned” area, for which land uses will be determined at a later date when more specific planning is carried out for areas west of the railroad right-of-way. A future Major [Poinsettia Shores. aka San Pacifico Community Association] Master Plan Amendment will be required prior to further development approvals for Planning Area F, and shall include an LCP Amendment with associated environmental review, if determined necessary. … As part of any future planning effort, the City and Developer must consider and document the need for the provision of lower cost visitor accommodations or recreational facilities (i.e. public park) on the west side of the railroad.“ Although the City has twice tried to change the General Plan land use designation on Ponto’s Planning Area F to R-23 Residential and General Commercial the City has: 1. Never complied with this Coastal regulatory requirement as has been documented by official Carlsbad Public Records Requests 2017-260, 2017-262, R000930-072419, R001280-021720, & R001281-02170. 2. Never clearly and publicly disclosed and engaged Carlsbad citizens, and particularly to the San Pacifico Community Association in which Planning Area F belongs to, in “any future planning effort” and in in our Community, South Carlsbad, and Citywide “need for the provision of lower cost visitor accommodations or recreational facilities (i.e. public park) on the west side of the railroad.“ , 3. Never conducted a “Major Master Plan Amendment”, and never invited nor engaged the San Pacifico Commuinity Association that composes over 70% of the Master Plan area to be consulted on possible changes to the Community’s Master Plan, and 4. Had the City’s/Developer’s proposed land use change from Non-residential Reserve to R-23 & General Commercial denied by the CA Coastal Commission in 2010, 5. Not yet had the CA Coastal Commission yet consider/rule on Certification of Carlsbad’s proposed Draft Local Coastal Program - Land Use Plan Amendment to change Planning Area F’s existing ‘Non-residential Reserve’ Coastal land use. The City maybe submit the City’s proposal in 2021-2, 6. Received specific direction in 2016 and 2017 from the CA Coastal Commission regarding the City’s proposed land use change for Ponto Planning Area F. Specifically: a. CCC Staff acknowledged the City has not yet complied with the LCP and in an 8/16/2017 email said: “The City is currently undertaking a comprehensive update to their LCP funded in part through a CCC grant. As a part of this process the City will be consolidating all previous LCP segments into a single, unified LCP. The City has received direction from both the Commission (May 2016 CCC hearing) and Commission staff, that as a part of this update the City shall undertake an inventory of visitor serving uses currently provided within the City’s Coastal Zone which will then serve to inform updates to the City’s land use and zoning maps as necessary. This inventory could have future implications for the appropriate land use and zoning associated with the Ponto area.” b. CCC Staff sent Carlsbad City Staff on 7/3/17. City Staff provided this to City Council on 1/28/20: “The existing LUP includes policies that require certain visitor-serving developments and/or studies relevant to the Ponto/Southern Waterfront area. For example, Planning Area F requires the city and developer to "consider and document the need for the provision of lower cost visitor accommodations or recreational facilities (i.e., public park) on the west side of the railroad. This is an issue that the San Pacifico HOA community group is raising in regards to the Shopoff/Ponto development proposal, and this study should be undertaken as a part of the visitor serving use inventory analysis described above. If this analysis determines that there is a deficit of low cost visitor accommodations or recreation facilities in this area, then Planning Area F should be considered as a site where these types of uses could be developed.” Carlsbad’s Draft LCP-LUPA, Draft Housing Element Update and Parks Master Plan Update should ALL land use plan and reserve Ponto Planning Area F and the other last few remaining vacant Coastal Lands to address the ‘forever’ or ‘Buildout’ High-Priority Coastal Recreation and Visitor serving Land Use needs for Carlsbad, North San Diego County, and California. 10-169 Draft Policy 10-P.7 says “Encourage distribution of development of affordable housing throughout the city to avoid over concentration in a particular area, excluding areas lacking necessary infrastructure or services.” Carlsbad’s Park Master Plan identifies Ponto as an area lacking park services, stating and showing on maps Ponto as ‘unserved’ by City Parks, and an area of ‘Park Inequity’. Ponto currently has 1,025 homes that creates an 8-acre City Park demand (based on the City minimal 3-acres/1,000 population Park Standard) yet is ‘Unserved’ by City Parks per the City’s Park Master Plan. Ponto development and homeowners paid City park-in-lieu-fees sufficient for 8-acres of City Park. Of Ponto’s 1,025 current homes, 202 in the San Pacifico Community Association were built to be affordable condominium homes with very small ‘exclusive use’ lots, zero-side yards/building setbacks and only 10-15’ wide ‘back yards’; and 384 Lakeshore Gardens homes are affordable age-restricted manufactured homes. So 586 of Ponto’s 1,025 current homes or 57% of Ponto’s housing were planned and built to be affordable. At 57% Ponto has and was developed with a consideration of affordable housing, but also was denied needed City Park facilities of at least 8- acres to meet minimum City Park Standards. Consistent with Policy 10-P.7 Ponto Planning Area F should be used to address Ponto’s ‘Park Inequity’ being ‘unserved’, and not used to increase the “over concentration” of affordable housing that was already planned and built at Ponto. 10-171 Figure 10-13: Sites Requiring No Zone Change: Ponto Planning Area F needs to be removed form Figure 10-13. As has been previously documented Planning Area F is currently Certified in the Existing Carlsbad Local Coastal Program as “Non-residential Reserve”. Both the City’s General Plan Land Sue Element and Zoning Code clearly state the City needs to receive CA Coastal Commission ‘Certification” of Carlsbad’s Proposed Draft Local Coastal Program Land Use Plan Amendment (sometime in 2021-22) to change that existing Certification before Ponto Planning Area F’s Coastal Land Use and Zoning is fully changed to R-23 Residential and General Commercial. Based on Ponto Planning Are F’s existing Certified LCP regulations and well documented need for high-priority Coastal land uses at Ponto, it is likely Planning Area F’s ultimate land use approved by the CA Coastal Commission could change. 10-191 Program2.1: Inclusionary Housing Ordinance: this section states that “For all residential projects of fewer than seven units, payment of a fee in lieu of inclusionary units is permitted. The fee is based on a detailed study that calculated the difference in cost to produce a market rate rental unit versus a lower-income affordable unit. As of 2020, the in-lieu fee per market- rate dwelling unit was $4,515.” The City’s in-lieu-affordable-housing fees seems very inadequate, as others city’s like the City of Laguna Beach’s (I recall) $160,000 per unit in-lieu affordable housing inclusionary housing fee that actually reflects the in-lieu cost. This cost and fee should be similar to Carlsbad’s situation. If in fact the Carlsbad’s in-lieu affordable inclusionary housing cost to provide an affordable housing unit is only $4,515 per dwelling, then the City appears have sufficient resources in the as I understand $19 million Affordable Housing Inclusionary Fee accounts to provide the gap funding to ‘buy’ over 4,200 affordable dwellings. Since an in-lieu fee is to cover the costs of actually providing the affordable dwelling the fees should then be able to purchase that affordable dwelling someplace else in the housing market. There is a critical need to explain in much more detail why the in-lieu fee is what it is, if it is truly adequate in funding affordable housing “in-lieu” of a developer providing the affordable housing? If the in-lieu fee is the total cost difference between affordable and market construction then is the difference in affordable and market dwelling sales/rental price the market housing developers’ Profit? If so then developer profit is the major barrier to affordable housing, as total costs are not that much different. If so then it seems logical to address this major barrier to affordable housing. 10-192 Program2.2: Replace or Modify Growth Management Plan (GMP): As mentioned before is seems imprudent to overturn the GMP for a temporary crisis housing law (SB 330) set to expire on 1/25/20. Also, it should be clearly stated in the this section that SB 330 has limited applicability or enforceability in the CA Coastal Zone if the City is pursuing compliance with the CA Coastal Act as documented in Attachment #4. SB 330 reflects a very unusual time when national and international economic market distortion by central banks has created, historically low interest rates and resulting in historic Housing (and other) Asset (stocks and bonds) values. This manufactured temporary inflationary market stimulus is to be temporary, not long-term, and will be a temporary market distortion that will likely see asset prices ‘revert to mean’ once the cost of capital is properly priced. If SB 330 legally overrides Carlsbad’s GMP until 2025 then that is what the State is mandating Carlsbad do. However, it is very imprudent and inappropriate to use SB 330’s temporary crises language as rational for long-term changes to critical foundations of GMP. Once the temporary crises that SB 330 is designed to address is over is the time to methodically approach wise long-term and sustainable land use policy. Attachment #7: From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Monday, September 14, 2020 10:46 AM To: Council Internet Email (CityCouncil@carlsbadca.gov); Scott Chadwick (Scott.Chadwick@carlsbadca.gov); Erin Prahler (Erin.Prahler@coastal.ca.gov); Ross, Toni@Coastal (Toni.Ross@coastal.ca.gov); Cort Hitchens (cort.hitchens@coastal.ca.gov); Lisa Urbach (lisa.urbach@parks.ca.gov); 'Zachary.Olmstead@hcd.ca.gov'; 'Megan.Kirkeby@hcd.ca.gov'; 'scott.donnell@carlsbadca.gov' Cc: Brhiggins1@gmail.com; Phil Urbina (philipur@gmail.com); Lela Panagides (info@lelaforcarlsbad.com); Team Teresa for Carlsbad (teamteresaforcarlsbad@gmail.com); People for Ponto (info@peopleforponto.com); Laura Walsh (lauraw@surfridersd.org); 'Steve Puterski'; Philip Diehl (philip.diehl@sduniontribune.com) Subject: Citizen public input for Housing Elem & Parks Master Plan Updates, & Draft Local Coastal Program Land Use Plan Amendment Dear Carlsbad City Council, Housing-Parks-Planning Commissions & Housing Element Advisory Committee; & State of CA Coastal Commission, Parks, Housing & Community Development Department: As one of the many People for Ponto (www.peopleforponto.com), we wanted to make sure this email and attachments have been provided to you and that the issues/data in this email be publicly presented/discussed during both the City’s and State’s consideration of the above planning and any other related activities. 1. Legality of ‘Buildout’ and quality of life standards in both California and a City within California; and if planning for “buildout” is illegal, can we California Citizens be provide the specific citation in CA State Law that forbids the State and/or Cities within California from land use and public infrastructure planning to cap to a finite or “buildout” population/development condition. As California and Carlsbad citizens it important to know the State’s legal policy on “buildout”; and State policy laws on how are an infinite amount of Coastal Recreation and other high-priority Coastal land uses can be correspondently provided for infinite population growth within a largely developed and finite (and shrinking due to sea level rise) Coastal Zone? The following public testimony and questions were presented the 6/23/20 Carlsbad Budget meeting. Coordinated answers from the State of CA and City of Carlsbad on how State Coastal and Housing planning priorities are ordered and reconciled is important. Carlsbad has a very small fragment of remaining vacant coastal land and once it is developed it essentially lost forever. This is being planned now with the above mentioned planning efforts. Most all of Carlsbad’s Coastal lands are already developed with Low-Coastal-Priority residential land use, or off-limits due to endangered habitat preservation. Coastal Parks or Campgrounds can only be provided along the Coast and they are currently very crowded, and will continue to get more crowed and eventually degrade over time by increased population demands if new Coastal Parks and campgrounds are not created by coordinated Coastal Land Use planning by the State and City. How is the State of CA and City of Carlsbad to address maintaining our coastal quality of life (coastal recreation) with infinite population growth and rapidly shrinking coast land resources? Citizens need a coordinated State of CA and City response to: “6-23-20 City Council Budget meeting – pubic testimony by Lance Schulte: People for Ponto submitted 130-pages of public testimony on 6/2/20, would like to submit the following public input to both the 6/23/20 City Budget Meeting and the City proposed Draft Local Coastal Program Amendment – and with reference to a proposed change the land use of Planning Area F from its Existing Non-Residential Reserve land use to City proposed low-coastal priority high-density residential and general commercial land uses. Contrary to what was said by 2 Council members the City’s LCP policy covering Planning Area F is not a Citywide LCP policy, but is specific to the Sammis/Poinsettia Shores LCP area, and the policy’s scope and regulatory authority is limited by the boundaries of the Sammis/Poinsettia Shores LCP area. The Planning Area F Ponto Coastal Park is critical to the long-term economic vitality and sustainability of South Carlsbad’s neighborhoods and extensive Visitor Industry; and Carlsbad’s 1st and 3rd highest revenue sources. Beyond Ponto there is an additional and separate Citywide Coastal Recreation requirement related to CA Coastal Commission concerns about Carlsbad’s proposed LUP land use changes and proposed Local Coastal Program Amendment (LCPA) adequately providing for a Citywide ‘buildout’ need for Coastal Recreation land. It is not clear if ‘buildout’ is a set and final amount of City and State population and development or if ‘buildout’ represents accommodating an endless amount of future population and development in Carlsbad and the State of California. If ‘Buildout’ is an endless future amount of population growth and development, then how is the City planning to provide a commensurate endless amount of City Parks and Open Space? How is an endless amount of Coastal Recreation provided to accommodate endless amount of City and Statewide growth? Until these questions can be authoritatively answered by the City and State of California the preservation and acquisition of vacant Coastal land should be a City priority. Because once land is developed it will never be available for Park and Coastal Recreation use. Continual population and development growth without corresponding Park and Open Space growth will lead to a gradual but eventual undermining of the quality of life for Carlsbad and California, and our Carlsbad economy. It is for these and other important reasons People for Ponto ask the City to budget for the purchase of Planning Area F for Coastal Recreation and City Park needs – needs that City has documented exist now, and needs that will only grow more critical and important in the future. Thank you, People for Ponto love Carlsbad and our California Coast. We hope you love Carlsbad also and you take responsibility as a steward of our California Coast.” 2. Attached is and email regarding clarification of apparent City errors/misrepresentations on 1/28/20 regarding a) the CA Coastal Act’s relationship with CA Housing laws regarding CA land use priorities and requirements within the CA Coastal Zone, and b) City planning documents and City planning and public disclosure mistakes regarding Ponto. The clarification of the issues noted on 1/28/2 should be comprehensive, and holistically and consistently disclosed/discussed in each of the City’s and State’s Coastal-Land Use Planning-Parks-Housing planning efforts showing the principles and legal requirements for how potential conflicts within State/City Policies are to be resolved. 3. Similar to #2 above, People for Ponto has provided public testimony/input of over 200-pages of documented data on the need for a “Public Park” and over 2,500 Citizens’ requests for that Park. Those 200+ pages and the email requests from 2,500 citizens, and the CA Coastal Commission direction to the City as noted below should also be shared with the Carlsbad’s Planning- Parks-Housing Commissions and the City’s Housing Element as part of the respective land use-parks- housing discussions. The CA Coastal Commission has also provided direction to the City regarding some of the City’s planning mistakes at Ponto, and those directions should also be shared with the City’s Planning-Parks-Housing Commissions and Housing Element Advisory Committee regarding Coastal Land Use planning at Ponto Planning Area F. CA Coastal Commission has provided the following direction to the Carlsbad: a. Following is from a 7/3/17 CCC letter to City Staff on the City’s proposed land use changes at Planning Area F. City Staff provided this to City Council on 1/28/20: “The existing LUP includes policies that require certain visitor-serving developments and/or studies relevant to the Ponto/Southern Waterfront area. For example, Planning Area F requires the city and developer to "consider and document the need for the provision of lower cost visitor accommodations or recreational facilities (i.e., public park) on the west side of the railroad. This is an issue that the San Pacifico HOA community group is raising in regards to the Shopoff/Ponto development proposal, and this study should be undertaken as a part of the visitor serving use inventory analysis described above. If this analysis determines that there is a deficit of low cost visitor accommodations or recreation facilities in this area, then Planning Area F should be considered as a site where these types of uses could be developed.” b. In 2017 after citizens received the City’s reply to Public Records Request 2017-260, citizens meet with CCC staff to reconfirm the City failed since before 2010 to publicly disclose and comply with Planning Area F’s LCP requirements. CCC Staff acknowledged the City has not yet complied with the LCP and in an 8/16/2017 email said: “The City is currently undertaking a comprehensive update to their LCP funded in part through a CCC grant. As a part of this process the City will be consolidating all previous LCP segments into a single, unified LCP. The City has received direction from both the Commission (May 2016 CCC hearing) and Commission staff, that as a part of this update the City shall undertake an inventory of visitor serving uses currently provided within the City’s Coastal Zone which will then serve to inform updates to the City’s land use and zoning maps as necessary. This inventory could have future implications for the appropriate land use and zoning associated with the Ponto area.” Please do not misinterpret these comments as anti-housing or anti-development, it is the exact opposite, they are in support of existing and future development. It is a logical recognition of what is the best use of very limited (and shrinking) vacant Coastal Land resources. It is prudent and sustainable State and City Coastal Land Use planning to best serve all CA residents – now and in the future. Housing can be developed in many large inland areas that are better connected with job centers and transit. New Coastal Parks can only be located on the last few remaining vacant parcels within a short distance to the coast. This very small area (vis-a-vis) large inland areas must serve all the coastal Park and recreation needs of California’s almost 40 million residents and the additional millions of annual visitors to California’s coast. This very small amount of Coastal land drives a lot what makes CA desirable and successful, but it is getting very overcrowded due to population/visitor growth while at the same time shrinking due to coastal erosion and sea level rise. Squandering the few remaining Coastal vacant land resources, and not reserving (planning) these lands for more high-priority Coastal Recreation Land Uses will ultimately undermine CA both socially and economically. The attached ‘Carlsbad 2019 proposed Draft LCP Amendment’ file should be provided to and reviewed by Carlsbad’s Planning-Parks-Housing Commissions and the Housing Element Advisory committee in their consideration of Carlsbad’s proposed Housing Element update and proposed Draft LCP Land Use Plan Amendment, and also jointly by CA HCD and CCC in providing Carlsbad direction on CA Coastal Land Use priorities in the Coastal Zone relative to those two (2) City proposals. Thank you all for your consideration and comprehensive inclusion of the various issues in both the City and States upcoming evaluation of proposed Coastal land use plan, Housing Element and Parks Master Plan updates. There is precious little vacant Coastal land left and how it is planned to be used and developed is critical and needs full public disclosure/involvement and a comprehensive and coordinated approach. Sincerely, Lance Schulte www.peopleforponto.com Following are the 2 attachments to the above 9/14/20 email: 1. 4/21/20 email of Public input to Carlsbad City Council-Planning-Parks-Housing Commissions and CA Coastal Commission on DLCPA-PMU-HEU processes: Dear Carlsbad City Council, and Planning, Parks and Housing Commissions; and CA Coastal Commission: People for Ponto submits this email, and the attachment that was provided to the Carlsbad City Council for Item#14 at the 1/28/20 meeting. The attachment provided at the 1/28/20 City Council meeting has not been recorded on the Carlsbad City website that documents public input provided at that 1/28/20 meeting. Consequently we request this email and attachment be provided to the Carlsbad City Council, and Planning, Parks and Housing Commissions; and CA Coastal Commission as public input on the City Staff proposed 1) Draft Local Coastal Program Amendment, 2) Parks Master Plan Update, and 3) Housing Element Update processes. The attachment documents apparent errors, omissions, and/or misrepresentations in the 1/28/20 Item #14 Staff Report/Presentation to the City Council. We wish this email and the attached public comments be provided to the Council and Commissions addressed to in this email and be included as public comments to be addressed in the 3 planning processes listed. Thank you. Email confirmation of receipt and delivery of this email/attachment is requested. Thank you. Sincerely, Lance Schulte People for Ponto a. Attachment: Carlsbad City Council meeting of 1-28-20 agenda item #14 [typo corrected on 2-4-20]: People for Ponto apologize for this late and hastily, review and comments. We just found out about the meeting this morning. We citizens know we can together achieve great things if you allow us to work with you. Staff Report Page clarification/correction: 1 The LCP Land Use Plan Update is in fact an Amendment to an Existing LCP Land Use Plan. The Existing LCP Land Use Plan is already certified by the CA Coastal Commission as being consistent with the CA Coastal Act, except for some Amendments needed to address Sea Level Rise impacts and some other issues. The LCP Amendment proposes to change the Existing CA Coastal Commission certified LCP Land Use Plan’s “Non-residential Reserve” Land Use and Policy on Planning Area F to consider and document the need for “i.e. Public Park” at Ponto . 1 Staff summarizes the CA Coastal Act objectives to "ensure maximum public access to the coast and public recreation areas." Carlsbad’s Adopted Park Service Area/Equity Mapping shows there is no Park Service for the Ponto Area and Ponto Citizens, and no Park Service for the Coastal South Carlsbad area west of Interstate-5 and the rail corridor. The City’s mapping of land that meets the developer required Growth Management Open Space Standard of 15% Unconstrained land shows about 30-acres of this Open Space is missing at Ponto. This missing Open Space could have provided needed Park facilities that are missing at Ponto. Citizens in over 2,500 emails to the City Council have cited the need for a Public Park at Ponto as part of the Existing LCP Land Use Plan Amendment proposed at Ponto. These requests are consistent with the CA Coastal Act. 3 2nd bullet: says city staff proposes to replace, amend, or retain various Existing LCP policies, so the Staff has a documented understanding how each Existing LCP policy is being treated in the proposed Amendment. Citizens asked in Oct 20, 2019 for this ‘redline’ version of the Existing LCP Policies and Land Use Maps so citizens can understand what the Amendments are so we as citizens could then provide informed public comment. This ‘redline’ version is also important for the City Council and Planning and other Commissions so they know what Amendments to Existing City LCP Land Use policy are being proposed. Citizens again request this ‘redline’ version that it appears the staff already has; as they know what Existing LCP Land Use policies are being replaced, amended, or retained. 4 V is incomplete: the community asked on Oct 20, 2019 for 3 things: 1) a ‘redline’ version as noted above, 2) true Public Workshops to help inform and resolve community concerns about the proposed LCP land Use Plan Amendments, and 3) more public review time to provide for the above two other requests. All 3 requests should be acknowledged in the staff report. All 3 requests are rational and reasonable considering the proposed Draft LCP Land Use Plan Amendment is the “buildout” plan for Carlsbad’s Coastal Zone, and there were multiple documented fundamental “planning mistakes” regarding past City public information and participation in the Coastal Land Use planning. Providing such a process as outlined by the 3 requests would help to correct these documented public disclosure/participation and ‘planning mistakes’ that have gone on for many years. It is the right thing to do and most productive approach for all concerned. 7 Staff should accurately disclose that in 2010 the CA Coastal Commission in fact rejected the City’s proposed Ponto Beachfront Village Vision Plan for failing to disclose and comply with the then and current LCP Land Use Plan policy for Planning Area F at Ponto. Carlsbad Public Record Requests confirmed the staff did not disclose to citizens the existence LCP Land Use Plan policy for Planning Area F at Ponto, so citizens had no idea a Public Park at Planning Area F at Ponto needed to be considered. How can citizens, provide input if citizens don’t have complete and accurate information to review and comment on? 8 Staff should correctly disclose that the 2015 application at Planning Area F at Ponto is first for a Local Coastal Program Amendment and Master Plan Amendment. These are both applications to change City Land Use Plan Policy and Zoning regulations. The actual applications for ‘development’ permits can in fact not even be considered by the City until the Local Coastal Program Land Use of “Non-residential Reserve” is changed and Master Plan rezoning is approved. Only then can the ‘development’ permit application can applied for. The developer abandoned their application to change the LCP and Master Plan and then apply for developer permit review about a year ago. However, the city staff is keeping the application ‘alive’ even though there has been no progress on the application for over a year. It is unclear if the staff has authority to do this, or if the City Council has authority to withdrawal the application due to non-activity. The City has permit standards that withdraw applications if applicants make no progress on the applications after 6-months. What is troubling is that it appears the city staff proposal is to process the developer’s application to change the Existing LCP Land Use Plan for the developer. Staff notes that the Planning Area F sites now designated as Residential R-23 and General Commercial by the Carlsbad General Plan Update. However, staff fails to disclose that until the Existing LCP Land Use Plan Amendment (as proposed by City Staff) is in fact approved by both the City and the CA Coastal Commission the Existing LCP Land Use Plan for Planning Area F supersedes the City’s General Plan Update. Carlsbad’s General Plan Land Use Element clearly states this on page 2-26 stating: “The city’s LCP Land Use Plan will be updated consistent with this General Plan. However, to take effect, the LCP must be certified by the Coastal Commission as well as adopted by the city. Until such time that this occurs, the existing (as of 2013) LCP must be adhered to.” So until the City Council adopts the staff’s proposed Draft LCP Land Use Plan Amendment, AND the CA Coastal Commission “certifies” that LCP LUP Amendment; the City’s General Plan Update Land Use change cannot take effect. The General Plan Land Use at Ponto Planning Area F has in fact not been changed by the General Plan Update, but can only change with staff’s proposed Draft LCP Land Use Plan Amendment that the City Council can choose to approve or disapprove. Also official Public Records Requests have documented that the City’s General Plan Update planning process was also fundamentally flawed at Ponto. Again, like during Ponto Beachfront Village Vision Plan planning process a few years earlier the city failed to comply with the then and current LCP Land Use Plan policy for Planning Area F at Ponto. The flawed General Plan Update process at Ponto prevented Citizens from knowing the facts so they could properly participate and provide review and comment during the General Plan Update. The significant citizen comments to the City Council asking for a Ponto Coastal Park is reflective of the fundamental public disclosure and processing flaws that the city is only now acknowledging as one of the repeated ‘planning mistakes’ at Ponto. This is why citizens are asking for full disclosure of the facts and a complete planning process re-boot at Ponto. It also should be noted that the Existing LCP Land Use Policy for Planning Area F states that “as part of any future planning effort … consideration of a “Public Park” is required. CA Coastal Commission Staff has indicated the City’s proposed land use planning changes at Ponto as part of the General Plan Update are subject to change. At the bottom of the page regarding SB 330, as noted above the “residential land use designation on the site” is not in effect until the currently proposed LCP Land Use Plan Amendment is both approved the City Council AND also certified by the CA Coastal Commission, so SB 330 does not apply. Also SB 330 has specific language that exempts land use in the Coastal Zone. SB 330 (Skinner) Section 13 states: “(2) Nothing in this section supersedes, limits, or otherwise modifies the requirements of the California Coastal Act of 1976 (Division 20 (commencing with Section 30000) of the Public Resources Code). For a housing development project proposed within the coastal zone, nothing in this section shall be construed to prohibit an affected county or an affected city from enacting a development policy, standard, or condition necessary to implement or amend a certified local coastal program consistent with the California Coastal Act of 1976 (Division 20 (commencing with Section 30000) of the Public Resources Code).” This language is consistent with CA case law, and other housing laws that recognize the obvious – there is very limited amount of Coastal land v. significant land area inland. Limited Coastal Land per the CA Coastal Act is needed for “High-Priority” Coastal Land Uses” - i.e. Coastal Recreation and Low-cost visitor accommodations primarily in a city such as Carlsbad. The CA Coastal Act identifies both residential and general commercial land uses as “low-priority”. So although affordable housing is important there are other more appropriate locations, than on the last remaining vacant Coastal land in Carlsbad that will be needed to address the “High-Priority” Coastal Land Uses to serve Carlsbad and California’s ‘buildout’ needs. CA case law recognizes the supremacy of the CA Coastal Act over CA Housing Laws as noted in “Kalnel Gardens, LLC v. City of Los Angeles”. This case law data has already been provided to the City Council as part of Staff’s housing discussions over the past few years. The staff report should have disclosed the above information, as it appears SB 330 is not a factor at Ponto. 13 2005-2010 Housing Element: As noted above the General Plan Land Use Element states the General Plan Land Use Plan is not effective until the proposed Draft LCP Land Use Plan Amendment is both approved by the City Council AND certified by the CA Coastal Commission. So, the Housing Element Cannot recognizes the proposed residential use change at Ponto until then. Also as noted before there were multiple documented fundamental ‘planning mistakes’ in public disclosure, participation and process that flawed the Housing Element. It should be noted that these flaws occurred during the time the CA Coastal Commission specifically rejected the Ponto Beachfront Village Vision Plan due to those flaws. The now City acknowledged ‘planning mistakes’ at Ponto prevented Carlsbad citizens from providing informed participation during the Housing Element. Also, it is unclear why the staff misrepresented the amount of housing proposed in the Housing Element on the Ponto Planning Area F site as “the Ponto site for high density residential use at a minimum density of 20 dwellings per acre (128 units minimum)”; as this is not true. The City’s General Plan promises only the minimum 15 dwelling units/acre for the R-23 Land Use designation. See the “Ponto” unit capacity table below from the City of Carlsbad General Plan Housing Element Table B-1 on page B-2 that lists 98 dwellings for the site on the east side of Ponto Road and 11 optional dwellings on the west side of Ponto Road for 109 total units for both sites, v. the 128 units mentioned by staff. Not sure why staff misrepresented the density by 17 to 30%. 2007 Ponto Beachfront Village Vision Plan: As noted several times above there were fundamental public disclosure and participation flaws with this plan. It was rejected by the CA Coastal Commission in 2010 in part for those reasons. These flaws are confirmed by the City’s own data as a result of multiple Official Carlsbad Public Records Requests. This should be disclosed to the City Council and citizens. 14 2015 General Plan Update: As noted several times above there were also fundamental public disclosure and participation flaws with this General Plan Update with regards to Ponto. These flaws are confirmed by the City’s own data as a result of multiple Official Carlsbad Public Records Requests. This should be disclosed to the City Council and citizens. Citizens are asking the City Staff and City Council: for honesty; to fully and publicly recognize and disclose the past “planning mistakes” at Ponto, and fundamental flaws from the from those mistakes that prevented citizens from knowing about and participating in the planning process for Ponto. To keep the Existing LCP Land Use Plan at Ponto until a new open-honest and inclusive Community-based planning process can be achieved at Ponto. To be honest with respect to Park Serve Area and Equity issues at Ponto and Coastal South Carlsbad west of I-5 and the rail corridor. Consider the needs for inland South Carlsbad citizens, visitors and business to have their ONLY Coastal Park. Consider the larger regional Coastal Park need, and the forever ‘buildout’ Coastal Recreation needs for future generations. To be true and honest in translating and implementing our Community Vision 2. The 2nd attachment to the 9/14/20 email to Carlsbad City Council, Housing-Parks-Planning Commissions & Housing Element Advisory Committee; & State of CA Coastal Commission, Parks, Housing & Community Development Department: Carlsbad City Council, Housing-Parks-Planning Commissions & Housing Element Advisory Committee; & State of CA Coastal Commission, Parks, Housing & Community Development Department was a 26-page document with a Subject line and submitted as official Citizen public input for the Housing Element & Parks Master Plan Updates, & Draft Local Coastal Program Land Use Plan Amendment regarding ‘Coastal Recreation’ facts, needs, issues for Ponto Planning Area F and citywide. This document has been provided as Attachment #5. Page 1 of 11 Submitted: May 28, 2020 Dear Carlsbad City Council, Carlsbad Planning and Parks Commissions, and Coastal Commission: The City Budget should address both short-term Covid-19 impacts, and near/longer-term investments needed for Economic Recovery and Revitalization. The quality of our Carlsbad coastline, Coastal Parks and open spaces are continually rated by Carlsbad citizens and businesses as the critical foundation of our quality of life, economic strength, and tourism industry. Ponto Coastal Park is a critically needed investment, and the last opportunity for the City to make an investment for Carlsbad’s long-term sustainability. South Carlsbad Citizens, visitors, and the Visitor Industry have no Southern Coastal Park. Ponto is the only place to provide that needed investment for residents and visitors, and advance Economic Recovery and Revitalization of South Carlsbad’s significant Visitor Industry. Coastal Recreation is the major attraction for visitors. With these understandings we submit the following testimony and data from the City’s FY 2019-20 Budget Public Input Report that highlights the documented significant number of citizens asking for a Ponto Coastal Park. We also note concerns about the Report’s dilution of specific citizen input provided at both the March 4, 2019 and 2020 Citizen Workshops. Citizen input on the need for a Ponto Coastal Park was the most numerous specific place need/desire citizens mentioned in the City’s: Budget Public Input process, Draft Local Coastal Program Amendment process, and Parks Master Plan Update process. The Budget Public Input process documented 85 specific, verbatim citizen comments on Ponto area park needs and over 90% of citizen requests that Council budget to address this need. These 85 Verbatim Citizen comments (listed at the end of this testimony and data) specifically address how they would like their (Park) tax dollars budgeted. Additionally, 2,500 similar public input email/petitions were submitted as public comments on Carlsbad’s Draft Local Coastal Program Amendment and Park Master Plan Update processes spoke to the need for a Ponto Coastal Park. As you know, the 11-acre Ponto Planning Area F site is for sale. This site is similar in size/shape as Holiday Park, providing a Coastal site for similar multipurpose community functions. Carlsbad’s Local Costal Program (and thus General Plan and Zoning Code) requires the City to first consider and document the need for a “Public Park” before any land use can be planned for the Planning Area F site. The City’s Park Master Plan already documents the need for a Ponto “Public Park”, showing the area as “unserved” by City Parks and an area of Park “inequity” correlating well with Citizen input. The City also received offers of potential donations, or cost-saving collaborations from Carlsbad Citizens and non-profits to advance the much needed Ponto Coastal Park. The City disappointingly has not replied to these special opportunities. Page 2 of 11 Therefore, it is requested the City budget for a Ponto Coastal Park and contact the Planning Area F landowner regarding site purchase. Consistent with Budget Public Input Report page 3 it is requested that this this testimony and data be provided to the Planning and Parks Commissions; and Coastal Commission as public input on the City Staff’s proposed 1) City Budget, 2) Draft Local Coastal Program Amendment, and 3) Parks Master Plan Update. Thank you. People for Ponto The following data is from the Carlsbad FY 2019-20 Budget Public Input Report: https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=38546 In reading the data different text treatment is used to differentiate between actual page number and text in the Report, Important Report text, and public comments and analysis of Report text. Following is a legend to those text treatments: (p.X) is the Report page number where the information is found, and normal text is the actual Report text. Text in Bold Face is particularly important Report text. Arrow bullets and Text in Bold Italic Text are analysis and comments on the Report’s information. Introduction (p. 3): Members of the public have a right to be involved in decisions affecting their lives. It is the city’s responsibility to seek out and facilitate the involvement of those interested in or affected by a decision. The city errs on the side of reaching out to people who might not be interested, rather than potentially missing people who are. City staff provide balanced and factual information to the public and do not engage in advocacy. Public dialogue strives for a focus on values over interests and positions. Public involvement planning is coordinated across all city departments to ensure consistency and avoid process fatigue. On (p. 5) specific Verbatim Public Input was generalized by City Staff as follows: Main Themes: The following themes were a high priority overall: Neighborhood quality of life Access to nature, trails and open space Environmental sustainability Traffic and mobility Most Important Services: City services in the following areas were identified as the most important: Neighborhood quality of life Parks and recreation Law enforcement Fire and paramedic service Page 3 of 11 Environmental sustainability Specific Areas for Budget Enhancement: When asked which services they would like to see enhanced in next year’s budget, the top five responses were: Neighborhood quality of life Parks and recreation Environmental sustainability Mobility/transportation Arts and culture The lack of a Coastal Park at Ponto impacts all South Carlsbad neighborhoods’ quality of life. Carlsbad’s Park Master Plan documents that Ponto and Coastal South Carlsbad are “not served” by parks and Ponto and Coastal South Carlsbad is an area of park “inequity” The City and CA Coastal Commission are required to consider and document the need for a “Public Park” before any planning to allow any land use on Ponto Planning Area F. For over 10-years the City failed to disclose and follow this requirement – making multiple “Ponto planning mistakes”. The City will now have to correct its multiple “Ponto planning mistakes” as part of the Draft Local Coastal Program Amendment The lack of a Park at Ponto also impacts both Environmental Sustainability and Mobility/Transportation: o Prevents parks within walking distance, forces driving (and the need for more parking in our Park) to access parks. o Forces South Carlsbad Neighborhoods to drive long distances to North Carlsbad and/or Encinitas to access a Coastal Park o Congests North Carlsbad and/or Encinitas Coastal Parks with South Carlsbad Coastal Park demands o Congests North Carlsbad and/or Encinitas roadways and parking facilities with South Carlsbad Coastal Park demands. o Importantly, it would forever negatively impact the economic sustainability of Carlsbad’s Visitor industry. There are thousands of inland South Carlsbad resort/hotel rooms that have no access to a Coastal Park. This will ultimately undermine the attractiveness and competitiveness of South Carlsbad’s Visitor industry and the tax revenue the City receives from that industry. Word Maps (pp 6-8) Staff provided 3 ‘word maps’ saying the show the words mentioned at the March 4th 2020 workshop attend by 38 citizens. There is citizen concern about the accuracy of these word maps and what is conveyed on pages 6-8 of the Report. Several of those 38 citizens, provided specific written (individual index cards) and verbal (round table flip chart notes) Pubic Input several stating the need for a “Ponto Coastal Park”, another mentioned a “liner Park”, and several mentioned the “Senior Center”, all these written/verbal comments were not accurately documented or reported on pages 6-8. It appears the City Staff interrupted and translated/transformed the actual citizen comments (as documented in the index cards and flip chart notes) when creating the word maps. There is a concern that specific citizen input provided at the actual workshop was not accurately Page 4 of 11 reported in the Public Input Repot to the City Council. As citizens we are concerned that our input is accurately reported and conveyed to the City Council. Surprisingly no word map was provided in the Report for the much larger (1,330 to 1,710 person) March 5-22, 2019 Public Input process. Following is the actual word map the city showed participants at the March 4, 2019 Public Input Workshop. The image of the word map was taken with a participant’s cell phone. It summarized the magnitude of citizen needs/desires expressed at this larger Budget workshop. The word map graphic above from the March 4, 2019 Workshop although not summarized by Staff in the Report is clearly documented in the Verbatim Comments (Public Input) that was included in pages 24-91 of the Report and accounted for below. Verbatim Comments (pp 24-91): Number of times a specific Place Name was mentioned: Ponto, Zone 9, and Southwest Carlsbad: 85 times (see below for list of Verbatim Public Input) Village: 23 times, this is 27% as much as Ponto area Carlsbad Senior Center: 7 times, this is 8% as much as Ponto area Agua Hedionda Lagoon: 3 times, this is 4% as much as Ponto area New Village Arts: 3 times, this is 4% as much as Ponto area Barrio: 2 times, this is 2% as much as Ponto area Calaveras: 2 times, this is 2% as much as Ponto area Alga Norte Park: 2 times, this is 2% as much as Ponto area Page 5 of 11 Poinsettia Park: 2 times, this is 2% as much as Ponto area Veterans Park: 2 times, this is 2% as much as Ponto area Rancho Carrillo: 1 time, this is 1% as much as Ponto area Hub Park: 1 time, this is 1% as much as Ponto area Crossings Golf Course: 1 time, this is 1% as much as Ponto area Robertson Ranch: 1 time, this is 1% as much as Ponto area Palomar Airport: 1 time, this is 1% as much as Ponto area As the Budget Public Input Report suggests, reading of each of the Verbatim Comments of actual public input should be done. The place names area specific list above does not include broad places such as “beaches” the names of specific roads, and other names that appeared vague. It is clear in reading through and counting the place name references that the Ponto area expressed as Ponto, Zone 9 (i.e. Local Facilities Management Plan Zone 9), and the coastal park references to Southwest Carlsbad and South Carlsbad was by far the greatest area of public input. This makes perfect sense in that for half of the City Ponto is the last significant vacant Coastal land available to address two of Carlsbad Citizens’ most important budget concerns ‘Neighborhood quality of life’ and ‘Parks and recreation’ that relate to core community values around Carlsbad’s “Beach”, “small beach town character”, and “valued open space”. Following is the listing of the Verbatim Public Input (Appendix A in Public Input Report, pp 24- 91) that specifically referenced Ponto or a clear reference to Ponto such as Zone 9 or Coastal Park needs in Southwest Carlsbad. There are many more comments such as “The purchase of remaining open space for preservation of the last remaining coastal areas.” that logically and clearly refers to the Ponto situation. However these many additional comments were excluded from the list below since they did not specifically mention Ponto, Zone 9, or SW Carlsbad place names. Of the 85 citizen comments below specifically referencing Ponto, 77 or 90.6% were asking the City to budget for a Ponto Coastal Park. Only 8, or 9.4% of those citizen comments were not asking for a Ponto Costal Park. We are not sure if the 8 commenters knew about the City’s now acknowledged “Ponto planning mistakes” dating back over the past 10-years, as the City only first briefly acknowledged this recently on I/28/20. We have found once citizens are truly aware of the facts and prior “Ponto planning mistakes” there is almost uniform desire for a Ponto Coastal Park. There is citizen concern that these “Ponto planning mistakes” are not being fully, openly and accurately being disclosed to Citizens during the various Public Input processes, thus tainting those Public Input processes. Verbatim Ponto City Budget Public Input from pages 24-91 of FY 2019-20 Budget Public Input Report: 1. My biggest disappointment is the lack of park facilities in my section of the city, near South Ponto Beach. Lots of open land but no park within at least 2 miles. This should be a city priority 2. It used to be the beach but now Ponto & South Carlsbad are more like rocky shores. I‘d like to see the rocks cleared up and more sand added to these beaches 3. COMMENT TRAFFIC IS BEING SPAMMED HERE TO PUSH THIS PONTO PARK PLOY (PPP) Develop Ponto and have the hotel maintin our beach! It’s all rocks currently! 4. Ponto Beach. We do NOT need a commercial development or hotel there. That needs to be a park and/or open space for future generations. Page 6 of 11 5. Ponto beach. 6. Don't ruin South Ponto Beach with condos and/or hotel, need to restore the sand on the beach. 7. Like most residents and visitors I treasure the beach. I feel the highest priority should be open space and parks that serve the beach region. Particularly important is the open space still available in the Ponto region. There is ample space here for an extraordinary area of open space and even a park. There is not one of either of these in the southwest quadrant near the beach. Children cannot walk safely to a park from that area. Open space and a park in the Ponto area would serve all residents, visitors, and the business community. 8. Beaches, parks, safe neighborhoods, OPEN SPACE! Need Beach parks like Del Mar Powerhouse/Sea Grove Park & Encinitas Community Park. Ponto Beach needs some attention. 9. I love the beach and the parks and fields and open space and hiking trails in Carlsbad. I wish we had more!! We have had 3 kids in sports in Carlsbad. Currently, field/park space is very limited and often over committed. Currently, there aren't enough fields to meet the need of the community. Adding more parks and fields would create a better community in the following ways.... The sports played on these fields help keep our kids fit and healthy; It keeps kids busy and out of trouble; It fosters friendships and community; it teaches team work and fosters dedication and teaches a willingness to help others succeed; it brings in community $$ from other teams who come to play on Carlsbad fields; It's a wonderful way to showcase our city to others who will want to return thus helping grow tourism. Additional Parks would offer the same benefits. We do not need more high density building. And, Please do NOT ruin Ponto with more building!!!!!!! 10. We love the beach and the small-town feel Carlsbad has. We love the scattered open spaces and trails. Carlsbad is a great place to live and spend time outdoors, like the Ponto area. Let's keep it that way by not developing every last square foot into a condo complex, hotel or shopping mall, if that's what you want please move to Oceanside. 11. Let us protect the valuable open space that is left and not develop every square inch. Especially at the beach, let us save the land across the coast highway from Ponto Beach and make a beautiful park, not more condos and hotels. Carlsbad is in great financial shape and does not need to go after every development and tax dollar it can get. Some things are more important, like quality of life, than a fat wallet. I know that this will fall upon deaf ears amongst the two older members of the City Council, but maybe some rearranging of priorities is in order. 12. Would love to see the last areas of open land to stay that way. I have lived here for 25 years and have seen a tremendous amount of development eating away at the open beauty of the area. We have enough shopping centers and homes. Please leave the area at Ponto open and do not approve the Ponto development. 13. Keep Ponto Beach development free! 14. Preserving Open Space and Building Ponto Park in the South West Quadrant! 15. I second Tisha Klingensmith's comment and all the others regarding Ponto Beach development. 16. Preserving open space and maintaining high quality Parks and Rec with park location emphasis on geographical location. It’s time to build a park in the SW quadrant near the beach for locals and visitors alike. Veterans Park is not a solution for each quadrant’s deficiency, particularly in the south. 17. We need more parks, especially in southwest Carlsbad! 18. I agree, we need more parks and open space. I live in Zone 9 and don't have apark anywhere within walking distance. 19. We need to continue to preserve open space and NOT develop Ponto into an awful condo complex. We would love a park! Page 7 of 11 20. We need a park in the Ponto area and not a development. It is the last open space next to the beach left 21. I agree with the need to preserve open space throughout Carlsbad and NOT develop Ponto into awful condo complex. 22. We need to preserve our open space --it's what keeps the city feeling like a small town. We need more parks -esp one at Ponto in the SW quad! 23. Preserve the open space and build a park in SW quadrant at Ponto. We do not need or want any more huge developments, especially right by the beach in one of the last remaining open spaces. Once it's built, you can't un-build it. Build Ponto Park in SW quadrant. Do the right thing. Especially for our children and grandchildren. They won't thank us for building outrageously tall high density condos, hotels and unnecessary shops right by our gorgeous beaches. The only people this benefits are some wealthy developers, not the people of Carlsbad. Think long term, not short term. We have a beautiful city and community-preserve it now or it's gone forever! 24. We really need a park in the southwest quad by the beach. This could be an amazing asset (on SO many levels) for the community and visitors alike. The revenue stream would return the city investment in spades! 25. Parks. Needed in Ponto area our children in this area don’t have a close park. And the house lots in our area are small. 26. I agree that we should be very mindful that the citizens of Carlsbad voted out the retail space plan at the power plant site a few years ago. The new Ponto project should not replace that. Citizens should be part of the decision to build out that area 27. We need to preserve our open space and we need a park at Ponto! 28. We need a park in the Southwest quadrant of our community. Safety in the community Is what we like best in this area 29. Carlsbad's small town feel, friendly atmosphere and location has made it our ideal place to live for the past 20 years, We live across from South Ponto Beach and DESPERATELY need a park for our area residents. It would be sad to see the area overbuilt with high density projects and not retain some of the open space at this southern entrance to our "Village by the Sea". PLEASE help preserve some of its appeal before it is too late. 30. I love the quaintness of the Village, the open land areas, trails, small businesses and the arts. A huge NO to PONTO. Please stop the excessive building and development of the open areas of our beautiful and unique city. We have lived here for over 30 years and are sad to see so much over development. Keep our special village a village, and please don't turn it into another ordinary city. 31. Favorite is small town feel and the beach --the beach provides us with all the open space we need. The city has enough open space with all the lagoons, etc. --we don't need any more parks --especially at PONTO --I am thrilled to see and drive by every day the new resort at La Costa which is in Encinitas and that is what we need here at the South end of Carlsbad --more residential --NO more open space 32. What I love about Carlsbad is that it has a small village feel but it also has the beach and some restaurants and then little town. I really would like more to walk to around the Ponto area. Specifically I think it should be more of a beat centered area with places to grab ice cream or grab some food or a coffee and walk to the beach. 33. I love that our village that is not a strip of 101. The quaint cottages helped Carlsbad have a downtown feel. It has several streets with unique interest. I love the Trees on Grand! The landscape of the trees setting the height of the town. Unfortunately the taller buildings are killing that. Vertical dwellings are taking over.. think of the reason you travel to Europe. It's not Page 8 of 11 for Developers Generica. We also want the NRG power plant space into a Park... and... I would LOVE for the city to finish the rail trail to Ponto. Imagine taking a trail to Ponto? It would be a dream! 34. Our San Pacifico Community and the surrounding neighborhoods need a local park. So far Carlsbad has no real performing arts venue of any size to meet the needs of a city of more than 100,000. This should be a serious consideration when the new civic center is being designed. 35. We need more coastal parks and open space. Especially in zone 9 36. protect more open space, including Ponto 37. We need Veterans Park completed and Ponto park developed. Everyone in Carlsbad is engaged and we have been talking about the park deficits for a while now. Veterans park is over-due!!! 38. Our libraries are the best in the region! But I have to put them 4th to our Neighborhood quality of life, which is being impacted by huge developments destroying our property values, our piece of mind and privacy. We do need to insure that our environment is cared for, since all of these housing projects are going in. I do love our parks but we need to insure that the SW quadrant has their share of parks (think-Ponto). 39. Zone 9 (in southwest Carlsbad) does not have a park within walking distance! I hope the City can remedy this. 40. Ponto needs a park not a hotel or more condos. Please stop building on every last piece of land 41. See previous comment concerning the lack of a local, beach oriented park in the South Ponto area. Ditto a performing arts venue. 42. PLS get the Ponto Proyect development going....., that area of Carlsbad needs it asap 43. I support Ponto Development. PLs get it going... 44. Ponto has 2 miles of unobstructed beach access and a lagoon that already act as a "park within walking distance". The Ponto project was approved long ago and is part of the citizen approved master plan. Please get it done. 45. Strengthen and protect the financial stability of the City. Businesses pay a significant amount of taxes, property, sales and income and those employed spend and live here. Encourage affordable housing opportunities for everyone, think outside the box and find some unique solutions. Complete build out in areas available, Ponto Beach is a great opportunity and the project is well thought out, get it built. And please don't become a 'Nanny City' and waste time to pass frivolous laws restricting straws, plastic bags, soda consumption, etc. 46. Development of open space and parking space in the Ponto region 47. Specifically, I want the city to remedy the lack of equal access to parks and trails evident in the southwest quadrant of the city. I support a park project at Ponto: in the long run, the south coastal gateway to Carlsbad needs a welcoming park with beach access and supporting facilities. Though less extensive than Village beach areas, good design would merge a Ponto park with access to beach and access to the 'memorial area on the bluff at city border with the ecology of the Batiquitos Lagoon adjacent to make a marvelous creek to beach environment accessible for all and ever. 48. There are two miles of unobstructed beach plus the lagoon within "walking distance" of the neighborhoods near Ponto. The project was approved long ago and is part of the Master Plan approved by the citizens of Carlsbad. Zoning changes and project vote downs are often just another way to steal private property. 49. Local park deficits continue to be a problem. Let's please support Ponto Park development. We as a city are losing an unobstructed landmark in our community. Please share some of that with local residents. And, did I mention parking?? 50. The extreme southwestern (Ponto) area of Carlsbad does not have a park within walking distance -this is my top priority to fix. Page 9 of 11 51. We have wonderful neighborhood parks, but not in Ponto and it's on the beach; Veteran's Park is more of a hiker/nature lover's place to enjoy nature. 52. We need a park at Ponto - to serve not only residents, but visitors and tourists. 53. A park is much needed in SW Quadrant of the city 54. Ponto Park. So much has been done for businesses, tourism, etc. This is the last bit of Carlsbad coast line left. And the residents could use more park space in the south part of the City. I don't want to see this area developed. Carlsbad has become overdeveloped. 55. I want to see a park for the Ponto road area. I feel that that area should not be used for condo - residential development. It is so important to showcase that wonderful piece of property, which is so rare to find all up the coast of calif. and would be a welcomed park for all as you drive north into Carlsbad. ALSO I am very concerned that the Palomar Airport and the larger airplanes the new plan will bring and ask that the city stay involved to support our concerns, thank you for help I appreciate all off the councils work. 56. Ponto area open space and park development 57. Take control of our coastline, bring fire rings to Ponto beach, every family should have the experience of gathering around a roaring fire on evening. 58. Cancel the Ponto development tragedy. Build a free park and keep the free beach parking there. 59. Buy the land for open space on Ponto Drive and build a park in Zone 9 that has no park even though developers paid into the park fees for 20 + years. 60. support Ponto development 61. Now that we have removed the jetty and allowed Warm Waters to wash away, and now we are planning to build on Ponto, where will locals access the beach? If 50% of responders stated the beach is the best part of Carlsbad living, why are continually squandering this gift? I know the council would live to sell Agua Hedionda to a developer too. When will there be decisions made to maintain our quality of life? Furthermore, I selected transportation because my commute time has DOUBLED in the past 5 years. The 55mph speed limit on El Camino is a joke. It takes me 2 light cycles just to cross each intersection now due to this unmitigated growth with no regard for how people will get around. I’m continually dismayed by this city. 62. Preserve the open space at Ponto. Keep traffic under control. 63. Preserve open space in zone 9 64. Money for persevering open space in zone 9 and building parks in the SW quadrant! 65. More parks and open space in Southwest Carlsbad! 66. Why another proposed hotel at Ponto? There are an abundance of hotels & stores already available ---even more than necessary. Preserving nature & some green space is more important than more concrete & businesses with "lease available" signs everywhere! 67. Prop to aid Ponto to keep it natural, as park area & natural habitat. 68. Put budget money towards Parks and Recreation, specifically Preserving Open Space in Zone 9 and Building #PontoPark in the SW Quadrant (p 84) 69. Please put budget money towards Parks and Recreation, specifically Preserving Open Space in Zone 9 and Building #PontoPark in the SW Quadrant (p 85) 70. need a park in the southwest Carlsbad post development 71. Parks in southwest Carlsbad! 72. Zone 9’s lack of park and open space is sad. The SW quadrant needs more places to take kids to play, seniors to walk and get outside, and for the community to gather. A park at Ponto would be an ideal place for that and would make for a beautiful and welcoming entry into Carlsbad for locals and tourists. 73. We need a park site near Ponto Beach on the property now slated for a 5 star hotel which has not been built despite attempts by several developers over the last ten plus years. Page 10 of 11 74. Please spend more on Parks and Recreation. We need to Preserve Open Space in Zone 9 and Build Ponto Park in the SW Quadrant. We do not need more homes congesting the already packed Coast Hwy. Adding sand to Ponto Beach would be nice too -too rocky! 75. I'm asking the City to put budget money towards Parks and Recreation, specifically Preserving Open Space in Zone 9 and Building #PontoPark in the SW Quadrant -this will enhance the quality of life in Carlsbad, contribute to the highest and best use, meet the requirement to have a park in this area, and make the area so desirable that it will allow raising of local tax rates (I don't believe I'm saying this). Best Regards, David Johnson 76. Put some park and playgrounds in SW Carlsbad. There are none near Ponto, yet there are open spaces, near Avenida Encinas and 101. Nothing to walk to. Thank you 77. We could really use a park in southwest Carlsbad especially the San Pacifico area. Thank you 78. Work toward filling the deficit in parks and open space in the Southwest part of Carlsbad, especially Ponto. 79. Would truly love the Ponto Beach Park! As a resident of South Carlsbad we need this!!! 80. There are no Parks in South Carlsbad. We are neglected here yet I pay very high taxes. 81. Build a Park at Ponto! Keep the open space! 82. I would like to see the city buy the Ponto property and develop it into a park. 83. Build a park at ponto 84. Appropriate development of open space and park space in the Ponto region. We are currently at huge deficit of both of these in the Ponto region 85. We are very quickly running out of open space. This is probably one of the most beautiful areas in the country, we need to preserve that beauty and maintain some open space. The open land near South Ponto beach must be preserved. There are no parks in the area, developing that area would not only add to the pollution but it would sacrifice one of the most beautiful parts of Carlsbad. Towns and Cities across the country are prioritizing open space that is so important, it is time we did that in Carlsbad. We need open space near Ponto Beach. A few of the many Citizens asking the City Council to budget for a much needed Ponto Coastal Park Page 11 of 11 August 31, 2017 To: Carlsbad City Council council@carlsbadca.gov Carlsbad Parks & Recreation Commission at mike.pacheco@carlsbadca.gov Carlsbad Planning Commission at Don.Neu@carlsbadca.gov Kevin Crawford, City Manager at manager@carlsbadca.gov Chris Hazeltine, Parks & Recreation, City of Carlsbad chris.hazeltine@carlsbadca .gov Don Neu, Planning, City of Carlsbad Don.Neu@carlsbadca.gov Subject: City Park Standard in Southwest and South Carlsbad Dear Carlsbad City Council: The San Pacifico Community Association (SPCA) represents over 450 homes (around 1,000 Citizens) in the Southwest Quadrant/Park District of Carlsbad, and is the primary component and stakeholder of the Poinsettia Shores Planned Community (Poinsettia Shores Master Plan and Local Coastal Program). SPCA supported the residents in creating the Ponto Beachfront Development Review Committee (PBDRC) to: • Provide information to all San Pacifico residents (and surrounding neighborhoods) on the developments. (See www.Pontolocals.com) • Obtain and consolidate constructive feedback from the residents. Give this feedback to the residents, developers and City so that we can have productive/timely input into the projects and their designs. • Act as a strong, unified voice and with the support of our residents in upcoming Planning, Council and Coastal Commission meetings. Since PBDRC has been formed there has been a growing participation and concurrence from other Carlsbad areas and groups on the consensus PBDRC has consolidated. PBDRC and the SPCA are pleased that the City has taken action to fix a timeline defect in the Growth Management Program related to meeting a City Park standard. However there is another truly once in a lifetime opportunity to improve how the City Park standard is proposed to be met in Ponto and coastal South Carlsbad that we would like to request of the City Council. This opportunity stems from the fact that Ponto is the only vacant coastal land in South Carlsbad and is currently being evaluated for low- priority housing and other types of development. Should it be developed in this way, there will never be another opportunity to have a meaningful park in coastal Southwest Carlsbad west of Interstate 5. The request is to work with Pontolocals to provide a comprehensive and open process for citizens of the City [primarily Southwest and Southeast Carlsbad Citizens] to discuss and define possible better approaches to implement a coastal park in Southwest that can serve all of South Carlsbad. We recently had a community meeting attended by approximately 200 people and this letter reflects some of the near unanimous (90%+) concerns from that meeting. We believe these concerns are also likely to be reflective of many others living in South Carlsbad, and also in North Carlsbad. The City Park Standard is "3.0 acres of Community Park or Special Use Area per 1,000 population within the Park District". So for every 1,000 Citizens in a Park District, such as the coastal Southwest Quadrant Park District, there is to be 3 acres of City Park to meet the standard. The rational for such a location specific standard is that parks should be distributed so as to be reasonably accessible by all citizens. It is also important to have reasonable and safe park access via walking and biking, not just by motor vehicles. The staff report on correcting the timeline defect in the Park Standard stated that correcting the timeline to correct the park quadrant deficits is " ... specifically relevant to the southwest and southeast quadrants. As stated in the report a need for more park acreage in those two quadrants was identified four years ago (during FY 2012-13)." A 6.6 acre park deficit within the Southwest quadrant was identified in the Growth Management Monitoring Report for FY 2014-15. However the report indicates that "Based on the Fiscal Year 2015-16 Capital Improvement Program list of projects, Veteran's Memorial Park (91.5 acres, with 22.9 acres applied to each quadrant) is proposed to be constructed prior to buildout." Under this proposal the future Veteran's Park, that is located in the Northwest Park District and located many miles away from the coastal Southwest and Southeast Quadrants and Park Districts, would be used meet the population and citizen demand for Parks for citizens within the coastal Southwest and Southeast Quadrant's Park Districts. We know there is an outstanding opportunity for the City to do a great thing for the community and to add tremendous value to the quality of life by augmenting, enhancing, and/or adjusting planned park supply to better serve citizens and the City; and be more consistent with the General Plan and core values of the Growth Management Plan. The fundamental intent of creating four Park Districts (one for each quadrant) and managing and matching demand and supply of City Parks into smaller geographical areas (quadrant park districts) is to make the supply of City Parks reasonably accessible to their demand and more equitably distributed for citizens. Equitable distribution of City Park facilities is the right thing to do and has many citizen and city benefits: • Children and elderly can more easily walk and bike to City Parks when they are close by and within a safe walking and bicycling distance with properly designed access pathways; • Park supply created so far away from park demand creates the need to drive in a car to access the park, thus increasing vehicle miles traveled (VMT). Depending on locations this also limits park access for citizens without cars or unable to drive; • When city parks are accessible to their demand by walking/bicycling then less city park land is need to park cars. Citizens get more actual useable park space for each acre of park land; • When city parks are close to their demand busy families can quickly get to them after their workday which allows more park time for families during busy weekends; • Nearby city parks create a stronger sense of stewardship for the "neighborhoods111 park and city parks in general. Citizens watch out and care for their nearby park; • Nearby city parks that are equitably distributed and based on surrounding neighborhood demand serve to strengthen neighborhood quality and property values by providing park amenities close by. It is both a good neighborhood and economic development strategy to assure park demand and supply are locationally matched; and • Fundamentally it is the right thing to do to place park demand and supply in close proximity to each other and promote and equitable distribution public facility demand and supply. In coastal Southwest Carlsbad and South Carlsbad we have some glaring gaps in demand and supply of city parks. For instance: The Carlsbad General Plan Open Space, Conservation and Recreation Element, Figure 4-3 Parks: Shows no existing or planned coastal parks or special use areas west of Interstate 5 for all of South Carlsbad. In North Carlsbad there are 10, parks and special use areas west of Interstate 5 and on or close to the beach (9 of these are existing parks and 1 is a future park). This seems a clear and inherently unfair distribution of coastal park facilities. This unfair distribution severely reduces critical access to coastal park open space near the beach for South Carlsbad Citizens (half the City and over 26,000 homes, and over 64,000 citizens). This unserved demand for city park space in coastal South Carlsbad is evidenced by the dangerous use of the Carlsbad Boulevard [old highway 101] road shoulder and bike lanes and campground road for recreational purposes, parking demand and the frequent unauthorized recreational use of Ponto vacant land. People are using whatever land they can for needed recreational use. South Carlsbad Citizens in Aviara, La Costa, Rancho Carrillo, Bressi Ranch, La Costa Valley and all the other South Carlsbad inland neighborhoods have no coastal South Carlsbad City Beach Park areas to access the coast. Their only option is to drive significant distances (with increase VMT and greenhouse gas emissions] crosstown to access city beach parks in the North, or travel to Encinitas. This forces increased VMT and greenhouse gas emissions which is counter to both State and General Plan goals. Citizens in South Carlsbad only have a State Beach pay parking lot and a retreating primarily steep cobble beach as their "local" beach. The non-beach portion of the South Carlsbad State Beach campground is a road and lodging facility for primarily out-of-town visitors that are near this beach. It is not a city park. The Campground is not designed to serve the park needs of Carlsbad citizens, but is a great place primarily for visitors to affordably pay to spend nights camping near the beach. The lack of any park facilities at the campground is evidenced by the frequent use of the campground driveway (a significant area of the campground) by children and adults as a play area. There is an added benefit in that adding a coastal South Carlsbad Ponto Beach Park would help alleviate growing overcrowding, and increased traffic and parking congestion at North Carlsbad's coastal parks. Citizens west of Interstate 5 in South Carlsbad have very limited access to a city park. Depending on the neighborhood one lives in, access our nearest park [Poinsettia Park] is between a 2 to 4 mile trip. Residents must cross Interstate 5 using one of only two crossings in the space of over 3 miles. These crossings are on major multi-lane, higher speed roadways (Poinsettia Lane or Palomar Airport Road). The route is not the most safe or direct, and it forces one to drive in a vehicle to access a park which increases VMT. Park access for children, the elderly, and those walking dogs west of Interstate 5 in South Carlsbad is severely restricted or effectively eliminated. Coastal Southwest and all of South Carlsbad have not met their quadrant's Park area standard since 2012 (per the City's Growth Management Program). A specific comprehensive and open discussion with the Southwest and all if South Carlsbad citizens on how that deficient should be resolved should occur. The current City solution to meet local park needs of coastal Southwest and South Carlsbad with a paper allocation of park acreage in the Northwest part of the City that is many miles away does not seem right. It seems inconsistent with the core values and Vision of our City. From Carlsbad General Plan Community Vision: " ... the Carlsbad Community Vision, which is the foundation for this plan." This is the foundation for the General Plan. " ... In the future, ... social connections will be enhanced through ... more public gathering places, family- friendly activities, and open spaces within walking distance of people's homes ... " "The community is proud of the exceptional amount of open space in the city, and envisions a future of continued City commitment to open space protection and strategic acquisitions to further the city's open space system." "Parks, Fields, and Facilities for All Ages: The network of parks and recreation facilities will be improved to meet the community's active lifestyle needs. Such improvements may include the strategic addition of more parks .... New facilities will be located to maximize use and access by all neighborhoods. tailored to the needs of local populations, and designed with all ages in mind." "Beach Uses and Improvements: The beach is an important outdoor recreational resource. and protecting and enhancing access to the beach and the quality of the beach experience is a top community priority." " ... Access to the beach and the quality of the beach experience will be improved through new compatible and supportive uses on or in close proximity to the beach. which may include ... a park ... " "Tailored Tourism Strategy: Tourism is an important component of the city's economy today, and it remains an attractive economic sector for the future since it emphasizes the very resources that make the city attractive to existing residents-the ocean and beach ... " "Easy and convenient pedestrian connections will be available from every neighborhood to help children get safely to schools and parks." From General Plan Land Use Element: "Beach Access and Activity: ... the community expressed an overwhelming preference for an active waterfront development strategy. which provides opportunities for activities and uses to be more integrated with the ocean .... Access to the beach will be enhanced through ... open space. parking. and amenities ... " General Plan Land Use Policy: "2-G.20 Develop an active ocean waterfront. with new growth accommodated west of Interstate 5, to enable residents and visitors to enjoy more opportunities for ... recreating along the coastline. Develop public gathering places and recreational opportunities along the coastal corridor." The City's Park and Recreation Master Plan includes many areas of direction that strongly support a coastal park west of interstate 5 in South Carlsbad. Many of the most important park facilities and program needs identified in the City's Park and Recreation Master Plan could be most efficiently addressed with a coastal park in the Ponto area. There are also significant and unique opportunities to create both public/private and public/public partnerships that would not only help reduce City recreation costs but also expand and create unique and special recreational program opportunities currently identified in the City's Park and Recreation Master Plan. A Ponto city coastal park also implements a major General Plan policy which calls for an active waterfront and creates solutions to long standing Local Coastal Program policy and State Parks Campground issues. There are very unique and special land use compatibility opportunities and synergy from a coastal city park in south Carlsbad and Ponto area that are inline and implement high priorities identified in the City's Park and Recreation Master Plan. In summary, Carlsbad has a once in a generation opportunity to create very special coastal South Carlsbad Ponto Beach Park in South Carlsbad. This opportunity will be true to our Carlsbad Community Vision and General Plan and the heart and soul of our Growth Management Plan's standard of matching park demand with park supply within a particular park district. We believe this request benefits not only coastal Southwest Carlsbad and South Carlsbad but all of Carlsbad and is more consistent with the City General Plan, Growth Management Program, and Parks Master Plan and will result in a better, more valued and more sustainable City. We are a key Stakeholder in Ponto and the Poinsettia Shores Maser Plan and Local Coastal Program. We have been hearing similar concerns from other Carlsbad citizens about coastal beach park access and request that the City Council seize this opportunity to work with us to establish a comprehensive and open community discussion about the strategic acquisition of a coastal South Carlsbad Ponto Beach Park for South Carlsbad citizens and businesses. We also request before a solution to the 2012 Southwest quadrant park standard deficit is created we have an open citizen discussion with the Citizens of coastal Southwest Carlsbad on how that solution can better address the park demand created in the Southwest Park District with a better park supply created within that District. Like our City Park Standard says: "3.0 acres of Community Park or Special Use Area per 1,000 population within the Park District". We request that a coastal City Park West of Interstate 5 be developed in South Carlsbad to be fair and equitable and to meet the needs of South Carlsbad for a coastal City Park to serve all the Citizens of South Carlsbad. This can take advantage of special land use synergies to help promote public/private collaboration, create added property and transit occupancy tax revenues for the City by creating a valuable and synergistic amenity [where none now exists] for over half the City and over 26,000 homes, along with providing support to our City's visitor serving businesses and activities. It is the right and smart thing to do. The San Pacifico Community Association and PBDRC as key Stakeholders in Ponto wish to be a key participant any proposed City or CCC actions regarding these subjects, and would like to meet with you to see how we can discuss and advance this for the benefit of South Carlsbad Citizens. As we are citizen volunteers we sincerely appreciate advance notification to allow for preparation and coordination with our work lives and to communicate back to our members and other South Carlsbad Citizens. We wish to be notified in advance of any proposed actions related to the issues in thus letter. The San Pacifico Community Association contact information is: San Pacifico Community Association and PBDRC c/o Walters Management, Lee Leibenson 9665 Chesapeake Drive, Suite 300 San Diego, CA 92123 lleibenson@waltersmanagement.com The Ponto Beachfront Development Review Committee conducted the research cited in this letter. Along with general communications, please contact the following if you have technical questions regarding this letter. Key Committee contact information is: jeanscamp@yahoo.com sebbiessixpack@att.net; meyers-schulte@sbcglobal.net Thank you for your consideration . San Pacifico Community Association Board of Directors: Mr. Jim Nardi jtnardil@msn.com Mr. Bill Van Cleve billvancleve@prodigy.net Mr. Adriaan van Zyl Vanzyl.aakc@live.com Mr. Tony Ruffolo tonyruffolo616@gmail.com Mr. Chas Wick chaswick@reagan.com cc: Board of Directors California Coastal Commission at Erin .Prahler@coastal.ca.gov and gbuhr@coastal.ca.gov Page 1 of 16 Carlsbad Citizens’ questions for the City Council, Planning, Housing and Parks Commissions, & Housing Element Advisory Committee on South Carlsbad Coastal Park needs & Ponto Planning Area F relative to Carlsbad’s proposed Draft LCP-LUPA, Housing Element Update, & Parks Master Plan Update Submitted 2020 Nov 30 For some time all four (4) of the current City Council members have on multiple occasions publicly stated they think Carlsbad’s current General Plan and Growth Management Plan need comprehensive updating. As one of our current Council members recently said about Ponto: “I believe that our best strategy is to support a new Growth Management Plan and General Plan that will reflect the desires of today’s residents. Our old plan has served us well but has become outdated. A revised plan could address a variety of services and infrastructure, including parks. I support an updated plan that is built on the desires of our current residents.” So the City Council considering a General Plan and Growth Management Plan change as part of Staff’s proposed Draft LCP-LUPA and Housing Element relative to Ponto Planning Area F is not out of the question. There appears unanimous City Council support to consider changes to the 2015 General Plan that are ‘built on the desires of our current residents.” – “including parks.” Also in showing the 2015 General Plan is not ‘locked in stone’ the City Council and Staff have advanced some piecemeal updates to the General Plan and Growth Management Plan. City Staff’s proposed Draft Housing Element Update alone includes 13 General Plan Land Use Designation changes. But it appears the City Council has not yet provided direction to City Commissions and City Staff to start a Ponto General Plan and Growth Management Plan Update process, even though a consistent major request by significant numbers of Carlsbad Citizens since 2017. The City Council recently split 2-2 several times on providing more substantive direction to City Staff on Ponto Park land use issues, other than unanimous agreement that the 2015 General Plan Update does not seem to be working very well in some areas like Ponto. Now with a 5th Councilmember, who represents Ponto and much of South Carlsbad, this 2-2 split will be resolved. So, People for Ponto Carlsbad Citizens are asking - and it seems very logical - that the Planning Commission, Housing Commission and Housing Element Advisory Committee, hold off on making any decisions on Ponto Planning Area F until the new full City Council has the opportunity to meet, consider, publicly discuss, and provide direction to City Staff on the City Council consensus on the 2015 General Plan Update Land Use Map that all the City Council say needs some changes – most likely at Ponto. Following are some data on South Carlsbad’s Coastal Park needs & Ponto Planning Area F, and important policy questions to your Individual and collective decisions on Carlsbad’s staff proposed Draft LCP-LUPA, Housing Element Update, & Parks Master Plan Update. The data and citizen to fellow citizen policy questions are important and hope you sincerely consider them. 1. People for Ponto Carlsbad citizens have since 2017 1) documented to the City Council & CA Coastal Commission the public’s consensus need for the Planning Area F Ponto Coastal Park, 2) request the City fund Ponto Coastal Park, and 3) City fully acknowledge and fix past City Ponto planning errors Page 2 of 16 that failed to disclose to citizens the since 1996 Ponto (Poinsettia Shores [aka San Pacifico Community Association] Master Plan and Local Coastal Program (LCP) Planning Area F requirement to “prior to any planning activity” study/document the need for a “Public Park” at Ponto and involve citizens, particularly District 4 San Pacifico citizens, in that study. Over 2,500 emails and over 200 pages of public testimony have been submitted to Carlsbad City Council and CA Coastal Commission in support for a park in Ponto at Planning Area F. At City Council meetings on 1/28, 6/2, and 6/24/20 Carlsbad’s City Council was deadlocked in 2 to 2 ties on Ponto Park needs issues and thus rejected responding to citizen communications expressing the need and desires for Planning Area F Ponto Coastal Park. Data Slide #1 below shows the current LCP for San Pacifico’s Planning Area F. a. Will you consider and respect massive citizen input since 2017 that clearly documents the need and desire for Ponto Coastal Park and supports creation of Ponto Coastal Park at Planning Area F in your respective and interrelated and interconnected analysis and decisions? b. Will you acknowledge significant citizens’ input that documents the need and desire for Ponto Coastal Park and supports creation of Ponto Coastal Park at Planning Area F? c. Will you direct City staff to work as a partner with People for Ponto and Carlsbad Citizens in advancing Ponto Coastal Park at Planning Area F? 2. During the Jan 28, 2020 City Council Meeting (item #14), Carlsbad City staff for the first time as a side-bar comment admitted the City made some ‘Ponto planning errors’ going back over 15 years. Those City planning errors where first called out when the CA Coastal Commission (CCC) denied Carlsbad’s Ponto Beachfront Village Vision Plan (the referenced foundation for Carlsbad’s 2015 General Plan Update) in 2010 in part due to the City’s mistake. The CCC’s denial conflicts with the City Staff’s interruption of the City Ponto planning process. The CCC in denying in 2010 the Ponto Vision Plan (the foundation for Carlsbad’s 2015 General Plan Update at Ponto) specifically said with direct reference to Ponto Planning Area F: “Currently, this area [Planning Area F] has an Unplanned Area land use designation. In order to facilitate any type of development in this portion of the Ponto area, an LCP amendment modifying the land use will have to be brought forward to the Commission for review and approval.” “… the Commission would reject such proposed uses because there has been no evidence presented that would support the elimination of these [Planning Area F] areas for some lower cost overnight accommodations or public recreational amenities in the future. The Commission's past action of the Poinsettia Shores Master Plan specifically called for such an assessment, and none has been submitted to date. The concerns related to the lack of lower cost overnight accommodations in Area F (ref. Exhibit #7) are further discussed in the findings later.” “City is inadvertently sending a message to potential developers that 1) the identified development (townhouses) is the primary type of use the City will support, or 2) that development type is consistent with the current land use and zoning designations. Neither of those assumptions is correct. As the previously certified Poinsettia Shores Master Plan states, any type of development at this location would first require an LCP amendment to establish the land use and zoning, which would have to be certified by both the City and the Coastal Commission. Additionally, the Master Plan further states that some component of the Page 3 of 16 development at this location must consider the need for the provision of lower cost accommodations or recreational facilities.” “While residential use is one of the land uses listed for this area in the Poinsettia Shores Specific Plan, it may not be the most appropriate designation. As previously stated, the project will at least need to consider the incorporation of some kind of lower cost accommodations, and any proposed zoning designation for the site will have to be found consistent with the policies contained in the Poinsettia Shores Master Plan. Furthermore, the standard of review for any change to the current land use designation is the Coastal Act, and thus will also have to be found consistent with all its applicable policies. Recently, the Commission has become concerned with the lack of lower-cost accommodations statewide. Thus, the establishment of a residential land use at this location may not be what is ultimately determined to be certified as consistent with the Poinsettia Shores Master Plan, or the Coastal Act.” “B. High-Priority Uses - Lower Cost Visitor Accommodations in ‘Area F’: The Coastal Act has numerous policies promoting public access to the beach and state: Section 30210 - In carrying out the requirement of Section 4 of Article X of the California Constitution, maximum access, which shall be conspicuously posted, and recreational opportunities shall be provided for all the people consistent with public safety needs and the need to protect public rights, rights of private property owners, and natural resource areas from overuse. Section 30213 - Lower cost visitor and recreational facilities shall be protected, encouraged, and, where feasible, provided. Developments providing public recreational opportunities are preferred. The commission shall not: (1) require that overnight room rentals be fixed at an amount certain for any privately owned and operated hotel, motel, or other similar visitor- serving facility located on either public or private lands; or (2) establish or approve any method for the identification of low or moderate income persons for the purpose of determining eligibility for overnight room rentals in any such facilities. Section 30221 Oceanfront land suitable for recreational use shall be protected for recreational use and development unless present and foreseeable future demand for public or commercial recreational activities that could be accommodated on the property is already adequately provided for in the area. Section 30222 - The use of private lands suitable for visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have priority over private residential, general industrial, or general commercial development, but not over agriculture or coastal-dependent industry.” “… in 1996, the Poinsettia Shores Master Plan was certified as part of the City's LCP, and replaced the [Visitor serving] land use designation as an "Unplanned Area." In an attempt to maintain a lower-cost visitor-serving component at this location, the Commission, through a suggested modification, required language within the Master Plan that would serve to protect this type of use. The language in the Poinsettia Shores Master Plan, for this location, "Area F," included: As part of any future planning effort, the City and Developer must consider and Page 4 of 16 document the need for the provision of lower cost accommodations or recreational facilities (i.e. public park) on the west side of the railroad.” “The Ponto Beachfront area is an area that could be considered as a high-priority location for lower cost overnight accommodations. While located across the street from a State Park (South Carlsbad State Park) containing camping facilities, during peak summer months, the campground is consistently at capacity. … If at any time in the future, this State Beach campground is converted to day use sites, the market and the need for low cost overnight accommodations will be significantly amplified. Thus the Vision Plan, as proposed by the City, cannot be found consistent with the Coastal Act.” “H. Conclusions: … concerns regarding the determination of preferred land uses in an ‘unplanned’ area, the lack of provision of lower-cost accommodations and recreational uses, … remain. All of these oversights could result in impacts to public access and recreation and other coastal resources and, therefore, the Vision Plan, as submitted, is therefore inconsistent with the Coastal Act, and therefore, shall be denied as submitted.” The City’s past and present Ponto planning errors where not, and are still not being, fully and honestly disclosed to citizens the City’s CCC requirement on Ponto Planning Area F to “prior to ANY planning activity” (like before the Ponto Vision Plan and General Plan Update) to study Ponto’s need for a “Public Park”. The City’s past failure to accurately disclose the CCC requirements fundamentally flawed the Public Participation process by not allowing proper citizen input on the Ponto Park need. The City’s Public Participation flaws thus flawed the prior City planning efforts at Ponto. The extensive Citizen input now is a clear and obvious result of the City’s prior flawed Ponto planning process. People for Ponto Citizens had to submit and research over 40 official Carlsbad Public Records Requests to find the truth about the City’s prior flawed processes and errors at Planning Area F. The City didn’t clearly, publicly and honestly communicate to Citizens and then conduct the required Ponto Park needs before both the 2010 Ponto Vision Plan and 2015 General Plan Update as documented in Official Carlsbad Public Records Requests. In 2010 and again in 2017, the CA Coastal Commission told the City that the City is required to correct the past planning errors at Ponto Planning Area F. Please see Data Slide #2 on page 11 for the 2017 CA Coastal Commission communication. A critical part of the City’s past planning errors at Ponto were failures to ask Ponto and South Carlsbad Citizens for their input (Public Participation) on their Ponto Park needs as part of the City’s required ‘documented need’ study for Ponto, and if a park is needed, Ponto Planning Area F should be considered for the Park site. Citizens, now that they and been informed by Official Carlsbad Public Records Requests have now provided an overwhelmingly clear and Documented Need for Ponto Coastal Park. This LCP requirement is to be done “prior to any planning activity”. The City failed to do that in 2010, 2015, but now should do it and fully consider the overwhelming and documented Citizen need and desires for Ponto Park at Planning Area F. See Data Slides #2 & #3. The City has still not fully and broadly communicated to all Carlsbad Citizens these “Ponto planning mistakes”, nor yet disclosed and presented to Carlsbad Citizens and the Parks-Planning-Housing Commissions for their recommendations the Park needs studies for Ponto Planning Area F. In addition the City is also required to conduct a Citywide Coastal Recreation buildout needs-supply- demand Study as required by the CA Coastal Commission in 2016. The City has yet to disclose and Page 5 of 16 present to Carlsbad citizens and the Parks-Planning-Housing Commissions for their recommendations on this Citywide Coastal Recreation buildout needs-supply-demand Study. The City has already Documented the Park need at Ponto in its Park Master Plan - pages 86-88 shows that Ponto is both “Unserved” by City Parks, and an area of “Park Inequity”. a. Do you think it is important for citizens to fully and honestly know the City made “Ponto planning mistakes” going back before 2010 that have impacted prior Coastal land use planning and the City’s General Plan, city housing planning and City parks planning at Ponto? Given the long-term compounded nature of these City Ponto planning mistakes should the City provide a means to work with citizens, particularly the San Pacifico, Ponto and South Carlsbad Citizens most impacted by the City’s prior Ponto planning mistake? b. Due to past mistakes, will you recommend or direct staff to retain or revert to Planning Area F’s ‘existing Non-residential Reserve’ Coastal land use designation in the Exiting Local Coastal Program (i.e. Defer Certification) and amend the General Plan to reflect that retention/reversion until a new citizen-based Ponto planning process is completed? c. Will you recommend or direct City Staff to require the citizen-based planning process to substantially and directly involve San Pacifico Community, District 4, and District 3 citizens most impacted by the lack of any City Park at Ponto, and coastal (west of I-5) South Carlsbad? d. During this citizen-based Ponto planning process, will you recommend or direct City Staff to, be consistent with City and State permit streaming laws, and deny “Shopoff’s” Planning Area F land use change and development application due to applicant withdrawal (by recorded Quit Claim) and inaction since 2019? e. During the citizen-based Ponto planning process, will you recommend or direct City Staff to be consistent with the existing LCP and suspend all City Staff proposed land use changes on Planning Area F and retain the existing LCP ‘Non-Residential Reserve’ land use designation on Planning Area F? f. Do you feel it is appropriate that the City is using tax-payer dollars, to change Planning Area F’s land use from the existing Non-residential Reserve” to high-density residential on behalf of and to benefit the Shopoff developers, particularly while the City’s Ponto planning mistakes dating back to before 2010 are not being publicly disclosed and discussed, and properly considered by City Commissions and citizens? 3. Before the above mentioned Ponto (San Pacifico’s) Planning Area F Ponto Park study requirement is even presented to Citizens, the Planning, Housing and Parks Commissions, Housing Element Advisory Committee, and City Council for review and consideration, the City Staff has already proposed land use changes on Ponto/San Pacifico’s Planning Area F. The City Staff’s proposed land use change would allow building development with 486% more intensity and heights 33% taller than San Pacifico. The City never in the past 15+ years directly asked the San Pacifico Community Association for its input, nor directly invited/engaged San Pacifico Community Association involvement in the City’s proposed land use change to San Pacifico’ s Planning Area F land use from its existing “Non-residential Reserve” land use. The City’s proposed changes to San Pacifico’ s Planning Area F will fundamentally change the Character of the San Pacifico Community and neighborhood. Data Slide #4 documents both existing and City-proposed land use intensity at San Pacifico and Planning Area F. Page 6 of 16 a. Do you think changing land use to increase density by 486% and increase building heights by 33% within an established ‘planned community’ like San Pacifico is appropriate? b. Do you think the City should directly and fully inform, invite and encourage Planned Communities, communities and neighborhoods to participate in City proposed land use changes to Planning Areas in their Community or neighborhood? c. Will you recommend or require the City planning staff to directly inform and involve the Planned Communities, communities and neighborhoods impacted by City proposed changes to their Planned (and/or unplanned) Community or neighborhoods? 4. Ponto (LFMP Zone 9) does not meet the City’s Growth Management Open Space Standard, which states that when land is developed, 15% of the ‘unconstrained and developable land’ needs to be set aside as Open Space. Carlsbad has had this standard since 1987. Per the City’s Citywide Facilities Management Plan if by 1987 Ponto had already been developed or if Ponto already had 15% of its unconstrained and developable land reserved as Open Space, the City’s 1987 15% unconstrained Open Space Standard would not apply. However, City data/documentation show that neither of these 2 conditions was/is applicable, and that Ponto developers’ switched land use plans that removed Growth Management Standard Open Space and thus falsely allowed a completely different land use plan to not provide the required 15% of unconstrained land as Open Space. City data very clearly show in fact that Ponto was not developed in 1987, and City GIS mapping data also clearly shows Ponto (LFMP Zone 9) is actually missing 30 acres of unconstrained Open Space as per the Growth Management Open Space Standard. Yet, even with this City documented Open Space Standard shortfall, the City has been allowing, and continues to allow, developers to over-develop Ponto by not requiring the missing 30-acres of unconstrained Growth Management Standard Open Space be provided at Ponto. The LFMP for Zone 9 must be formally amended to account for the new added public facility impacts for the proposed change in Planning Area F land use from the existing ‘Non-residential Reserve” land use to the City staff’s proposed R-23 high-density residential and General Commercial land uses that where never planned for by the adopted LFMP Zone. See Data Slides #5, #6 and #7 showing actual City data on how the City’s Growth Management Program Open Space Performance Standard is not being met at Ponto (LFMP Zone 9), and the City’s Open Space Performance Standard and Sections 21.90.130 and 180 of the City’s Growth Management Ordinance. The City’s Growth Management Ordinance (Carlsbad Code 21.90.130 & 180) require the City Manager and City Council to address any situation where a Growth Management Standard is not being met – exactly like Ponto’s missing 30-acres of Growth Management Standard Open Space as documented in City data on Data Slides #5 & 6. To illustrate how out of compliance with the Open Space Standard LFMP Zone 9 is City and Developers are counting a Sewage pumping station (parcel 2165606400) that pumps raw sewage as Open Space. If the City’s GIS map with corresponding documentation of each Open Space parcel is desired, People for Ponto can provide and discuss that data. The City has/is being sued by others due to the City’s failure to follow the 15% unconstrained Growth Management Open Space Standard. A Ponto Park at Planning Area F would help mitigate the missing Open Space. In your recommendations or decisions for land use, housing, and parks planning do you think: a. the Growth Management Standard Open Space is important? Page 7 of 16 b. the City should follow its Growth Management Ordinance, particularly, 21.90.130 & 180 and address the 30-acres of missing Growth Management Standard Open Space at Ponto? c. the City should directly invite and involve Ponto Citizens in addressing and resolving Ponto’s missing 30-acres of Growth Management Standard Open Space? d. the City should follow the Growth Management Ordinance and suspend all development and City proposed Draft Local Coastal Program Land Use Plan changes at Ponto until Ponto’s Open Space Performance Standard deficit and issues are resolved? e. the City should temporally suspend all City proposed Draft Local Coastal Program Land Use Plan changes at Ponto until the lawsuit against the City is resolved? 5. As of 2020 there are 1,025 homes at Ponto and over 2,660 adults and children living in those homes. These homeowners already paid City taxes and Park-in-Lieu fees. The in-lieu fees and tax base is sufficient for the City to buy and build 8 acres of City Park. 8-acres of parkland would meet the minimum City park needs of Ponto’s 3-acre/1,000 population City Park standard. Carlsbad’s Park Standard is relatively low compared with the Cities of Encinitas and Oceanside. Carlsbad allows developers to provide 40% less Parkland and collects 40% less money for parks than both Oceanside and Encinitas. The City so far has not required Ponto developers to build these 8 acres of required park at Ponto, but instead took park-in-lieu fees to spend the money elsewhere. This is one reason why Ponto Planning Area F, was in 1996 Coastal land use zoned “Non-Residential Reserve” that requires before ‘any planning activity’ that proposes changing this Coastal land use zoning, that the City/Developer must consider and document the need for high-priority “Coastal Recreation (i.e. Public Park)” at Ponto and if needed Planning Area F could provide that “Coastal Recreation (i.e. Public Park)”. a. In your recommendations or decisions for land use, housing, and parks planning do you think it is appropriate to charge Carlsbad homeowners City park-in-lieu fees and then spend the money in areas where those same homeowners cannot effectively access the parks created by those fees? b. In your recommendations or decisions for land use, housing, and parks planning do you think Ponto homeowners deserve from the City an 8 acre park in Ponto that they already paid the City fees for, that the City’s Parks Master Plan identifies as an area unserved by City Parks and park inequity, and where an overwhelming amount of Carlsbad citizens have documented their need and desire for a Ponto Park? c. In your recommendations or decisions for land use, housing, and parks planning do you think Carlsbad should have the lowest park standard relative to our adjoin Coastal cities? d. In your recommendations or decisions for land use, housing, and parks planning do you think Carlsbad developers should provide 40% less parkland than Encinitas and Oceanside developers? 6. The City’s proposed Veterans Park in NW Carlsbad is being funded by fees paid by homeowners in new homes built after 1991. Since most all the homes built in Carlsbad after 1991 are in the SW, SE, and NE quadrants, most of the funding for Veterans Park is from SW, SE and NE Quadrant Homeowners. These SW, SE and NE homeowners are in Quadrants where there are current City Park acreage deficits per the City’s Growth Management Parks Standard. Many of these SW, SE, and NE neighborhoods have no City Park within 10-minute walking distance from their homes. Proposed Veterans Park is from 1 - 5 miles away (as the crow fly’s) and from 1.4 - 11.1 miles away (via City Streets) from the SW, SE, and NE Quadrant homeowners that paid for almost all of the proposed Page 8 of 16 Veterans Park. These distances make the proposed Veterans Park effectively unusable for children and most homeowners in SW, SE and NE quadrants. Along with Veterans Park, there are many other areas of the City where Carlsbad homeowners pay the City park-in-lieu fees to address the local park demands created by the new development, but no local park is created by the City. The Cities of Encinitas and Oceanside both have strong Park planning policies that direct the City to provide Parks within a 10-minute walk for all homeowners. Carlsbad has no such requirement, but only documents in its Park Master Plan areas “Unserved” by Parks and areas of “Park Inequity”. a. In your recommendations or decisions for land use, housing, and parks planning do you think City Staff should to come up with some options for a more fair and equitable use of the Veterans Park funding paid by SW, SE, and NE homeowners so that funding actually provides Parks needed in the SW, SE, and NE and that are accessible for their children? b. Both Encinitas and Oceanside have Park accessibility policies and plans to provide a City Park within a 10-minute walk from every home. In your recommendations or decisions for land use, housing, and parks planning do you think Carlsbad should have a similar park accessibility requirement so Carlsbad children and citizens have a park within walking distance from their homes? c. In your recommendations or decisions for land use, housing, and parks planning do you think City Staff should be directed to start working with Carlsbad Citizens to create a Park Master Plan that address fixing the city’s documented “Park Inequities” in various Carlsbad neighborhoods the City documents as “Unserved” by City Parks? 7. San Pacifico’s Planning Area F in Ponto is currently for sale and can be purchased for a Park. The cost would be considerably less than the City’s proposed South Carlsbad Boulevard “promenade” using the existing median of Carlsbad Blvd. The Carlsbad Blvd roadway median although wider than most roadway medians, is still relatively narrow and does not allow many open space uses other that linear walk/pathways that can be most cost effectively provided in the existing right-of-way. Mayor Matt Hall has publicly said that Ponto Park at Planning Area F would cost $20-22 million and the City’s narrow promenade would cost $75 million. If the city purchases Planning Area F, it would add 11 new acres to city-owned property, whereas the promenade (which is basically adding a walkway and parking spaces) adds 0 (zero) acres to city-owned property (the City already owns the roadway median). There is a smarter and better way. The Promenade walkway and parking can basically be provided for as little as 4%-10% of the City’s proposed $75 million Promenade cost. This is done by retaining South Carlsbad Boulevard (Historic Coast Highway 101) in its current historic configuration with natural median, and not relocating the south bound pavement to create a wide urban roadway. South Carlsbad Boulevard is one of the last substantially unaltered stretches of San Diego County’s Historic 101 dating back to the 1920’s. Data show it is not threatened by Sea Level Rise so does not need to be relocated. It seems appropriate to retain this historic street and landscape. South Carlsbad Boulevard only needs to add pedestrian paths or sidewalks to be Complete. This can cost effectively be designed and done while preserving the historic features of Historic Coast Highway 101, and creatively reusing old 101 pavement at the Campground entrance to also cost-effectively provide parking. Page 9 of 16 Based on City data an 8 foot wide concrete walkway within the wide right-of-way could be provided on both sides of South Carlsbad Boulevard for about $3 million. Parking already exists along some sections of South Carlsbad Boulevard and additional parking can be cost-effect provided on the old South Carlsbad Boulevard roadway pavement near the Campground entry. In addition if it is possible and desirable to reduce vehicle roadway capacity by over 50% and increase vehicle traffic congestion on South Carlsbad Boulevard the existing outside 2-lanes in each direction could be very cost effectively converted to on-street parking. This would provide around 6-miles of on-street parking or about 12,000 parking spaces. $72-67.5 million of tax-payer money savings can be achieved by rethinking the City’s $75 million South Carlsbad Boulevard Promenade concept while still providing the needed pedestrian path and parking. This $72-67.5 million can be used to fund the more practical, functional, beneficial and tax- payer desired Ponto Park at Planning Area F, and have about $50 million left over to fund many more Coastal Park and open space improvements in Carlsbad. Planning Area F would create a park similar in shape to Holiday Park, but more than 1.8 times larger than Holiday Park. Ponto Park at Planning Area F would create Carlsbad’s Crown Jewell Coastal Park; with ocean and sunset views, direct pedestrian access to the beach and Batiquitos Lagoon trails, and the size and shape to host Carlsbad community events. Ponto Park at Planning Area F would create a Coastal Crown Jewell Park for both Carlsbad Citizens and visitors that will last for generations. As of 2020 over 64,000 South Carlsbad Citizens and hundreds of thousands visitors in South Carlsbad’s resort hotels have no Coastal Park. This inequity damages Carlsbad’s current and long-term attractiveness and sustainability of our residential quality of life and visitor experience. Like Del Mar’s Powerhouse Park, Solana Beach’s Fletcher Cove Park, Encinitas’s Moonlight Beach Park, La Jolla’s Scripps Cove Park and La Jolla Shores Park, Coronado’s Tidelands Park and Coronado Cays Park; Ponto Park can provide Carlsbad a much needed iconic Coastal Park and community place. Ponto is also at the center of a 6-mile Regional Coastal Park gap – there is no Coastal park between Encinitas’s Moonlight Beach and Carlsbad’s small Cannon Park. Based on the data Ponto Park is a much better park space and appears to be a far better and wiser use of tax payer money. a. In your recommendations or decisions for land use, housing, and parks planning will you direct City Staff to contact the Planning Area F landowner to discuss the City being a purchaser of the site? b. In your recommendations or decisions for land use, housing, and parks planning did you know that the 400-acre Carlsbad Municipal Golf Course cost Carlsbad Taxpayers $70 million? c. In your recommendations or decisions for land use, housing, and parks planning do you think spending $75 million to add a sidewalk and some parking (aka Promenade) on narrow land the City already owns and that could alternatively be provided with a little over $3 million is a wise use in taxpayer dollars? d. In your recommendations or decisions for land use, housing, and parks planning do you think spending $20-22 million to actually buy 11-aces of new City parkland is a better use of Carlsbad’s taxpayer dollars compared to spending $75 million and NOT adding one single acre of new City land? e. In your recommendations or decisions for land use, housing, and parks planning do you think a City Park that is 1.8 times larger than Holiday Park, and with coastal views and pedestrian access to the beach and Batiquitos Lagoon would be a great benefit to the City in hosting community events like Holiday Park currently does? Page 10 of 16 Data Slide #1: San Pacifico Community – Planning Area, Coastal General Plan Land Use, & Acreage Map. Planning Area F is unplanned and zoned NRR (non-residential reserve) and will remain so until a “Park Need” Study is completed and both the City and CA Coastal Commission determine no Park is needed. Only if both the City and CA Coastal Commission determine Ponto’s park needs are met, can Planning Area F be planned and developed for something else. Source: page 20 of exiting Poinsettia Shores Master Plan/Local Coastal Program At'PRlJA. GROSS AC. 9.8 13.5 10.2 14.7 20.9 2.9 11.2 4.4 __ _..,,__ 0.9 11.3 8.4 3.7 11.9 13.8 18.3 4.6 2.3 Page 11 of 16 Data Slide #2: One of Carlsbad’s “Ponto Planning Area F planning mistakes” and CA Coastal Commission (CCC) direction to Carlsbad At the 1/28/20 (item #14) Carlsbad City Council meeting City Staff for the 1st time admitted 15+ years f some Ponto ‘planning mistakes’ on Ponto Planning Area F. This was over 10-years after the City knew of these ‘Ponto planning mistakes’ by the 2010 CA Coastal Commission (CCC) denial of the Ponto Beachfront Village Vision Plan for those mistakes and some other flaws. Following is from a 7/3/17 CCC letter to City Staff on the City’s proposed land use changes at Planning Area F. City Staff for the 1st time provided this to City Council on 1/28/20: “The existing LUP includes policies that require certain visitor-serving developments and/or studies relevant to the Ponto/Southern Waterfront area. For example, Planning Area F requires the city and developer to "consider and document the need for the provision of lower cost visitor accommodations or recreational facilities (i.e. public park) on the west side of the railroad. This is an issue that the San Pacifico HOA community group is raising in regards to the Shopoff/Ponto development proposal, and this study should be undertaken as a part of the visitor serving use inventory analysis described above. If this analysis determines that there is a deficit of low cost visitor accommodations or recreation facilities in this area, then Planning Area F should be considered as a site where these types of uses could be developed.” In 2017 after citizens received the City’s reply to Public Records Request 2017-260, citizens meet with CCC staff to reconfirm the City failed since before 2010 to publicly disclose and comply with Planning Area F’s LCP requirements. CCC Staff acknowledged the City has not yet complied with the LCP and in an 8/16/2017 email said: “The City is currently undertaking a comprehensive update to their LCP funded in part through a CCC grant. As a part of this process the City will be consolidating all previous LCP segments into a single, unified LCP. The City has received direction from both the Commission (May 2016 CCC hearing) and Commission staff, that as a part of this update the City shall undertake an inventory of visitor serving uses currently provided within the City’s Coastal Zone which will then serve to inform updates to the City’s land use and zoning maps as necessary. This inventory could have future implications for the appropriate land use and zoning associated with the Ponto area.” In 2016, the CCC told City that Carlsbad’s proposed 2015 General Plan land use map could change based on the outcomes of both a Citywide Coastal Recreation needs Study, and also the specific Planning Area F LCP requirement to study Park needs at Ponto. The City is apparently failing to fully disclose to Citizens these facts and the City’s prior “Ponto Planning Area F planning mistakes”. Page 12 of 16 Data Slide #3: from Carlsbad’s adopted Park Master Plan (see pages 86-88). Blue dots = Parks, and blue circles = areas served by Parks. City’s adopted Park service map clearly shows Park need at Ponto. No Coastal Park in South Carlsbad • 6 mites o Coas thou a Coas at Par 1s a C1 Regional need • Sou Carlsbad has 6 .000 res1den s ousands of OU a • Closes ar o Pon o 1s Po,nse a Par ap ro 2 ,tes across t- • Proposed e erans Par 1s a ro 6 1les a a Page 13 of 16 Data Slide #4: Existing and City’s Planning Area F proposed development intensity (FAR) comparisons FAR (floor area ratio) is a well-established planning method to compare land use intensity (lower FARs reflect lower intensity and higher FARs reflect higher intensity). City Staff is proposing at San Pacifico’s Planning Area F an extremely high FAR land use intensity that will radically change the established character of our San Pacifico Community. The CA Coastal Commission has State Law Polices to protect the character of Coastal communities and a requirement that new development be "visually compatible with the character of the surrounding area." It does not appear that the City’s proposed 486% increase in development intensity for San Pacifico’s Planning Area F is visually compatible with the character of San Pacifico. Comparison of FAR Data: % more intense Building FAR than San Pacifico Height San Pacifico Community - existing .31 0% 30 feet San Pacifico’s Planning Area F - City proposed change 1.79 486% 40 feet Cape Rey Resort - existing .52 70% 35 feet Encinitas Beach Hotel - in construction 1.21 295% unknown Kam Sang Resort - developer application w/ City .72 136% 35 feet Floor Area Ratio (FAR) diagram of examples of 0.5, 1.0 and 2.0 FAR Below is what the City’s proposed 1.79 FAR at Planning Area F looks like. A 40 foot tall and 1,000 feet long wall of buildings. View is looking NE from corner of Avenida Encinas/Ponto Dr. Floor Area Ratio 0.5 FAR 1 Story I~ '-.. 2Stories ~ " I " 1.0FAR ~ 1 Story 2Stories t2) '-.. 4Stories ~ ~ I " " 2.0 FAR 2Stories 4Stories ~ '~ E2J ~ I """-.. Entire Lot Area Half Lot Area Quarter lot Area Page 14 of 16 Data Slide #5: Summary of data from City’s GIS (geographical information system) computerized map Ponto Planning facts -development a ard no being e 9 [P o] excluded from Open ~::e Unconstrained land in LFMP Zone 9 [Ponto] P · · Unconstrained Open Space r1 ire t GMP Minimum Unconstrained Open Space required GMP Open Space provided & mapped per City GIS Mtmunn Unccmtlrained Open p e needed in Zone 9 [Ponto] to meet the City minimum G P Open pace Standard per City' GI S data Page 15 of 16 Data Slide #6: City GIS map – Light Green is ‘Unconstrained land’ and can be used to meet City’s Growth Management Open Space Standard. The Pink and Purple areas are ‘Constrained land and water’, respectively, and cannot be used to meet the Standard. Ponto Planning Facts - being c· s GtS map Ponto's P e 9 Gro h Manage ent Standard Open Space: Space Standard meet Open Page 16 of 16 Data Slide #7: City’s Growth Management Open Space Standard The City’s website says: “The Growth Management Program standard for Open Space requires that "15 percent of the total land area in the Local Facilities Master Plan Zone, exclusive of environmentally constrained non-developable land, must be set aside for permanent open space and must be available concurrent with development." https://www.carlsbadca.gov/cityhall/clerk/summaries/space.asp The City’s Growth Management Ordinance (Carlsbad Municipal Code 21.90) states: “21.90.130 Implementation of facilities and improvements requirements: … (b) The city-wide facilities and improvement plan and the local facility management plan process is part of the city’s ongoing planning effort. It is anticipated that amendments to the plans may be necessary. Adoption of a facilities management plan does not establish any entitlement or right to any particular general plan or zoning designation or any particular development proposal. The city-wide facilities and improvements plan and the local facilities management plans are guides to ensure that no development occurs unless adequate facilities or improvements will be available to meet demands created by development. The city council may initiate an amendment to any of the plans at any time if in its discretion it determines that an amendment is necessary to ensure adequate facilities and improvements. (c) If at any time it appears to the satisfaction of the city manager that facilities or improvements within a facilities management zone or zones are inadequate to accommodate any further development within that zone or that the performance standards adopted pursuant to Section 21.90.100 are not being met he or she shall immediately report the deficiency to the council. If the council determines that a deficiency exists then no further building or development permits shall be issued within the affected zone or zones and development shall cease until an amendment to the city- wide facilities and improvements plan or applicable local facilities management plan which addresses the deficiency is approved by the city council and the performance standard is met. (d) The city planner shall monitor the development activity for each local facilities management zone and shall prepare an annual report to the city council consisting of maps, graphs, charts, tables and text and which includes a developmental activity analysis, a facilities and improvements adequacy analysis, a facility revenue/expenditure analysis and recommendation for any amendments to the facilities management plan. The content of the annual report shall be established by the city council. (e) The city council shall annually review the city-wide facilities and improvements plan at the time it considers the city’s capital improvement budget. (Ord. 9808 § 1, 1986” & “21.90.180 Public facility reductions: Notwithstanding any previous sections of this chapter, the city council shall not materially reduce or delete any public facilities or improvements without making a corresponding reduction in residential density unless such a reduction or deletion of public facilities is ratified by a vote of the citizens of Carlsbad. (Ord. 9829 § 4, 1987)” Carlsbad City Council meeting of 1-28-20 agenda item #14 People for Ponto apologize for this late and hastily, review and comments. We just found out about the meeting this morning. We citizens know we can together achieve grate things if you allow us to work with you. Staff Report Page clarification/correction: 1 The LCP Land Use Plan Update is in fact an Amendment to an Existing LCP Land Use Plan. The Existing LCP Land Use Plan is already certified by the CA Coastal Commission as being consistent with the CA Coastal Act, except for some Amendments needed to address Sea Level Rise impacts and some other issues. The LCP Amendment proposes to change the Existing CA Coastal Commission certified LCP Land Use Plan’s “Non-residential Reserve” Land Use and Policy on Planning Area F to consider and document the need for “i.e. Public Park” at Ponto . 1 Staff summarizes the CA Coastal Act objectives to "ensure maximum public access to the coast and public recreation areas." Carlsbad’s Adopted Park Service Area/Equity Mapping shows there is no Park Service for the Ponto Area and Ponto Citizens, and no Park Service for the Coastal South Carlsbad area west of Interstate-5 and the rail corridor. The City’s mapping of land that meets the developer required Growth Management Open Space Standard of 15% Unconstrained land shows about 30-acres of this Open Space is missing at Ponto. This missing Open Space could have provided needed Park facilities that are missing at Ponto. Citizens in over 2,500 emails to the City Council have cited the need for a Public Park at Ponto as part of the Existing LCP Land Use Plan Amendment proposed at Ponto. These requests area consistent with the CA Coastal Act. 3 2nd bullet: says city staff proposes to replace, amend, or retain various Existing LCP policies, so the Staff has a documented understanding how each Existing LCP policy and how each Existing policy is being treated in the proposed Amendment. Citizens asked in Oct 20, 2019 for this ‘redline’ version of the Existing LCP Policies and Land Use Maps so citizens can understand what the Amendments are so we as citizens could then provide informed public comment. This ‘redline’ version is also important for the City Council and Planning and other Commissions so they know what Amendments to Existing City LCP Land Use policy are being proposed. Citizens again request this ‘redline’ version that it appears the staff already has as they know what Existing LCP Land Use policies are being replaced, amended, or retained. 4 V is incomplete: the community asked on Oct 20, 2019 for 3 things: 1) a ‘redline’ version as noted above, 2) true Public Workshops to help inform and resolve community concerns about the proposed LCP land Use Plan Amendments, and 3) more public review time to provide for the above two other requests. All 3 requests should be acknowledge in the staff report. All 3 requests are rational and reasonable considering the proposed Draft LCP Land Use Plan Amendment is the “buildout” plan for Carlsbad’s Coastal Zone and there were multiple documented fundamental “planning mistakes” regarding past City public information and participation in the Coastal Land Use planning. Providing such a process would help to correct these documented ‘planning mistakes’ that have gone on for many years. It is the right thing to do and most productive approach for all concerned. 7 Staff should accurately disclose that in 2010 the CA Coastal Commission in fact rejected the City’s proposed Ponto Beachfront Village Vision Plan for failing to disclose and comply with the then and current LCP Land Use Plan policy for Planning Area F at Ponto. Carlsbad Public Record Requests confirmed the staff did not disclose to citizens the existence LCP Land Use Plan policy for Planning Area F at Ponto, so citizens had no idea a Public Park at Planning Area F at Ponto needed to be considered. How can citizens, provide input if they don’t have complete and accurate to review and comment on? 8 Staff should correctly disclose that the 2015 application at Planning Area F at Ponto is first for a Local Coastal Program Amendment and Master Plan Amendment. These are both applications to change City Land Use Plan Policy and Zoning regulations. The actual applications for ‘development’ permits can in fact not even be considered by the City the Local Coastal Program Land Use of “Non-residential Reserve” is changed and Master Plan rezoning is approved. Then the ‘development’ permit application can applied for. The developer abandoned their application to change the LCP and Master Plan and then apply for developer permit review about a year ago. However, the city staff is keeping the application ‘alive’ even though there has been no progress on the application for over a year. It is unclear if the staff has authority to do this, or if the City Council has authority to withdrawal the application due to non-activity. The City has permit standards that withdraw applications if applicants make no progress on the applications after 6-months. What is troubling is that it appears the city staff proposal is to process the developer’s application to change the Existing LCP Land Use Plan for the developer. Staff notes that the Planning Area F sites now designated as Residential R-23 and General Commercial by the Carlsbad General Plan Update. However, staff fails to disclose that until the Existing LCP Land Use Plan Amended is in fact approved by the CA Coastal Commission the Existing LCP Land Use Plan for Planning Area F supersedes the City’s General Plan Update. Carlsbad’s General Plan Land Use Element clearly states this on page 2-26 “The city’s LCP Land Use Plan will be updated consistent with this General Plan. However, to take effect, the LCP must be certified by the Coastal Commission as well as adopted by the city. Until such time that this occurs, the existing (as of 2013) LCP must be adhered to.” So until the City Council adopts the staff’s proposed Draft LCP Land Use Plan Amendment, AND the CA Coastal Commission “certifies” that LCP LUP Amendment; the City’s General Plan Update Land Use change cannot take effect. The General Plan Land Use at Ponto Planning Area F has in fact not been changed by the General Plan Update, but can only change with staff’s proposed Draft LCP Land Use Plan Amendment that the City Council can choose to approve or disapprove. Also official Public Records Requests have documented that the City’s General Plan Update planning process was fundamentally flawed at Ponto. Again, like during Ponto Beachfront Village Vision Plan planning process a few years earlier the city failed to comply with the then and current LCP Land Use Plan policy for Planning Area F at Ponto. The flawed General Plan Update process at Ponto prevented Citizens from knowing the facts so they could properly participate and provide review and comment during the General Plan Update. The significant citizen comments to the City Council asking for a Ponto Coastal Park is reflective of the fundamental public disclosure and processing flaws that the city is only now acknowledging as one of the repeated ‘planning mistakes’ at Ponto. This is why citizens are asking for full disclosure of the facts and a complete planning process re-boot at Ponto. It also should be noted that the Existing LCP Land Use Policy for Planning Area F states that “as part of any future planning effort … consideration of a “Public Park” is required. CA Coastal Commission Staff has indicated the City’s proposed land use planning changes at Ponto as part of the General Plan Update are subject to change. At the bottom of the page regarding SB 330, as noted above the “residentail land use designtiaon on the site” is not in effect until the currently proposed LCP Land Use Plan Amendment is both approved the City Coucnil AND also certified byt eh CA Coastral Commission, so SB 330 does not apply. Also SB 330 has specific language that exempts land use in the Coastal Zone. SB 330 (Skinner) Section 13 states: “(2) Nothing in this section supersedes, limits, or otherwise modifies the requirements of the California Coastal Act of 1976 (Division 20 (commencing with Section 30000) of the Public Resources Code). For a housing development project proposed within the coastal zone, nothing in this section shall be construed to prohibit an affected county or an affected city from enacting a development policy, standard, or condition necessary to implement or amend a certified local coastal program consistent with the California Coastal Act of 1976 (Division 20 (commencing with Section 30000) of the Public Resources Code).” This language is consistent with CA case law, and other housing laws that recognize the obvious – there is very limited amount of Coastal land v. significant land area inland. Limited Coastal Land per the CA Coastal Act is needed for “High-Priority” Coastal Land Uses” - i.e. Coastal Recreation and Low-cost visitor accommodations. The CA Coastal Act identifies both residential and general commercial land uses as “low-priority”. So although affordable housing is important there are other more appropriate locations, than on the last remaining vacant Coastal land in Carlsbad will be needed to address the “High-Priority” Coastal Land Uses to serve Carlsbad and California’s ‘buildout’ needs. CA case law recognizes the supremacy of the CA Coastal Act over CA Housing Laws as noted in “Kalnel Gardens, LLC v. City of Los Angeles”. This case law data has already been provided to the City Council as part of Staff’s housing discussions over the past few years. The staff report should have disclosed the above information, as it appears SB 330 is not a factor at Ponto. 13 2005-2010 Housing Element: As noted above the General Plan Land Use Element states the General Plan Land Use Plan is not effective until the proposed Draft LCP Land Use Plan Amendment is both approved by the City Council AND certified by the CA Coastal Commission. So, the Housing Element Cannot recognizes the proposed residential use change at Ponto until then. Also as noted before there were multiple documented fundamental ‘planning mistakes’ in public disclosure, participation and process that flawed the Housing Element. It should be noted that these flaws occurred during the time the CA Coastal Commission specifically rejected the Ponto Beachfront Village Vision Plan due to those flaws. The now City acknowledged ‘planning mistakes’ at Ponto prevented Carlsbad citizens from providing informed participation during the Housing Element. Also, it is unclear why the staff misrepresented the amount of housing proposed in the Housing Element on the Ponto Planning Area F site as “the Ponto site for high density residential use at a minimum density of 20 dwellings per acre (128 units minimum)”; as this is not true. The City’s General Plan promises only the minimum 15 dwelling units/acre for the R-23 Land Use designation. See the “Ponto” unit capacity table below from the City of Carlsbad General Plan Housing Element Table B-1 on page B-2 that lists 98 dwellings for the site on the east side of Ponto Road and 11 optional dwellings on the west side of Ponto Road for 109 total units for both sites, v. the 128 units mentioned by staff. Not sure why staff misrepresented the density by 17 to 30%. 2007 Ponto Beachfront Village Vision Plan: As noted several times above there were fundamental public disclosure and participation flaws with this plan. It was rejected by the CA Coastal Commission in 2010 part for those reasons. These flaws are confirmed by the City’s own data as a result of multiple Official Carlsbad Public Records Requests. This should be disclosed to the City Council and citizens. 14 2015 General Plan Update: As noted several times above there were fundamental public disclosure and participation flaws with this Update with regards to Ponto. These flaws are confirmed by the City’s own data as a result of multiple Official Carlsbad Public Records Requests. This should be disclosed to the City Council and citizens. Citizens are asking the City Staff and City Council: for honesty, to fully and publicly recognize and disclose the past “planning mistakes” at Ponto, and fundamental flaws from the from those mistakes that prevented citizens from knowing about and participating in the planning process for Ponto. To keep the Existing LCP Land Use Plan at Ponto until a new open-honest and inclusive Community-based planning process can be achieved at Ponto. To be honest with respect to Park Serve Area and Equity issues at Ponto and Coastal South Carlsbad west of I-5 and the rail corridor. Consider the needs for inland South Carlsbad citizens, visitors and business to have their ONLY Coastal Park. Consider the larger regional Coastal Park need, and the forever ‘buildout’ Coastal Recreation needs for future generations. To be true and honest in translating and implementing our Community Vision Table B-1: Vacant Sites for Lower and Moderate Income Housing Unit Capacity, by Household Site Income General Plan Zoning Size Very APN Designation 1 District (Acres) Low Low Moderate 2090901100(Sunny Creek) R1 5 (12 du/ac) RD-M 9.6 --115 2161404300 (Ponto) R23 P-C 6.5 --98 GC (Mixed Use)3 P-C 3 --11 .... _, .... 6 ........ 6 6 ,..,,,.. ~~~ .......... ~ .. ~ .. ~ Page 1 of 26 Carlsbad Staff proposed Draft Local Coastal Program Amendment – People for Ponto comments Coastal Recreation: 1. Request that the City as part of its Draft LCP Public Review process broadly-publicly disclose to all Carlsbad Citizens the City’s acknowledged prior LCPA processing and planning “mistakes” regarding the requirement that the Ponto area be considered as a public park: This disclosure is needed to correct about 20 years of City misrepresentation to the public on the since 1996 and currently Existing LCP requirements at Ponto, and the City’s prior planning mistakes at Ponto. Citizens have been falsely told by the City that all the Coastal planning at Ponto was done already and that the City followed its Existing LCP regarding the need for a park at Ponto, and that this is already decided and could not be reversed. This misinformation has fundamentally stifled public review and public participation regarding the Coastal Zone. City failure to provide such a broad-public disclosure on the documented prior, and apparently current proposed, “planning mistakes” would appear to violate the principles of Ca Coastal Act Section 30006. A broad-public disclosure would for the first time allow citizens to be accurately informed on the Existing LCP requirements at Ponto so they can provide informed public review and comment regarding the need for a Coastal Park in in this last vacant ‘unplanned’ area. The requested broad-public disclosure by the City of the City past mistakes and the Existing LCP requirements at Ponto is consistent with CA Coastal Act (CCA) “Section 30006 Legislative findings and declarations; public participation - The Legislature further finds and declares that the public has a right to fully participate in decisions affecting coastal planning, conservation and development; that achievement of sound coastal conservation and development is dependent upon public understanding and support; and that the continuing planning and implementation of programs for coastal conservation and development should include the widest opportunity for public participation.” The public cannot participate as outlined in CCA Section 30006 if past City ‘mistakes’ and misrepresentations on Coastal planning at Ponto go undisclosed to the public. If the public isn’t fully informed about the 20-years of LCP planning mistakes at Ponto how could the public in the past (and now in the present) participate in the proposed LCP Amendment – Public Participation as noted in Section 30006 above is the means to sound coastal conservation and development and is “… dependent upon public understanding …”. The City’s past mistakes at Ponto need to be corrected by slightly different a Draft LCP Amendment process than currently outlined by the City; a new process is needed that clearly, opening and honestly informs and engages the public on the Existing LCP Ponto issues. The City’s current Draft LCP Amendment process fails to follow CCA Section 30006 in that most all the citizens we encounter are as yet unaware of the City’s Ponto mistakes and how they can participate in in the DLCPA process without that information. We see this daily in conversations we have with our fellow citizens. We even saw at the Oct 20, 2019 Carlsbad Planning Commission meeting that the Planning Commission was unaware of the planning mistakes at Ponto. How can a decision body of the City make a decision without knowing about these prior ‘planning mistakes’ facts that surround what they are being asked to decide on? Repeatedly since 2017 Carlsbad citizens and People for Ponto have asked the City to fully acknowledge the City’s prior flawed planning at Ponto, and to correct that with ether maintaining the Existing LCP Non-residential Reserve Land Use or restarting the Coastal Planning at Ponto with a true and accurately informed Community-based Coastal Planning process consistent with Section 30006. We request the City during the DLCPA Public Review period broadly and publicly disclose to all Carlsbad Citizens the City’s acknowledged prior LCP and other “planning efforts” public participation processing and planning “mistakes” regarding the requirement that the Ponto area be considered as a public park, and 1) provide a truly honest public participation process on that disclosure consistent with CCA Section 30006 as part of the Draft LCP Amendment process or 2) retain the Existing LCP Non-residential Reserve Land Use and require a comprehensive and honest community-based redo of Coastal Resource planning at Ponto. Page 2 of 26 2. City fully and publicly reply to and the City Council consider the 11-20-19 citizen concerns/requests regarding the City’s proposed LCP Amendment process: Lance Schulte on 1/23/20 received an email reply by the City to his follow- up email regarding the status of the 11/20/19 citizen concerns/requests public comments and letters presented to the Planning Commission. This is appreciated, however it is request that the City fully publicly reply to the 11-20-19 citizen concerns/requests regarding the City’s proposed LCP Amendment process and present the to the City Council 11/20/19 citizen concerns/requests so the City Council can consider them and provide any direction to City Staff. City Staff first presented a summary presentation of the proposed Draft LCP Amendment to the Carlsbad Planning Commission on November 20, 2019, and indicated the public comment period would close on November in less than 2-weeks. Citizens and citizen groups provided public testimony to the Planning Commission, both verbally and in two written letters. The CCC was copied on those letters. The testimony and letters noted significant concerns about the City’s proposed LCP Amendment process and made three requests: a. Disclose and provide a publically accessible ‘Redline Version’ of the Existing 2016/Proposed LCP land use Plan and Policies so everyone can see the proposed changes to the Existing LCP. b. Provide true Citizen Workshops on the major remaining vacant Coastal land that still have outstanding Citizen Concern or objections. Citizen Workshops, when done right, are valuable means to openly educate, discuss and work to consensus options. These areas, including Ponto, were/are subject to multiple lawsuits, so true open and honest public workshops would provide an opportunity to openly and honestly discuss the issues and hopefully build public consensus/support for solutions. This approach seems consistent with CCA Section 30006, and common sense. c. Extend the public comment period 6-months to allow Citizen Review of the Redline Version of the LCPA and allow time for Citizen Workshops. The City did extend the Public Review period 2-months over the holidays to January 31, 2020. This is appreciated although many think this is inadequate given the significance of the Proposed Land Use Plan Amendments, and lack of Redline Version to compare. The City and their consultants required several extra years beyond schedule prepare the proposed LCP Amendments. The extra years of City Staff work reflects on the volume of the over 500-pages in the documents and the time needed to understand the Existing LCP and then create an Amended LCP. Citizens need sufficient time, proper comparative tools (redline) and a process (workshops) to understand the proposed LCP Amendments that is reflective of extensive extra time needed by City Staff and consultants needed. Truncation of lay public review to a few months for an Amendment that took paid professionals many years to produce seems a more than a bit inappropriate. The City appears to be rejecting citizens’ request to be provided a ‘Redline Version’ of the Existing 2016/Proposed LCP land use Plan. So public review comments will tainted or will miss many issues due having to manually cross-reference a 150-page Existing LCP LUP with a Proposed 350-page Proposed LCP LUP. There will be unknown and unconsidered changes in the Draft LCP Amendment that the public and city and CCC decision makers will not know about due to the lack of ‘Redline Version’. The City also appears to reject citizen requests for true Citizen Workshops on the major remaining vacant Coastal land that still have outstanding Citizen Concern – such as Ponto. Like Coastal Recreation issue #1 above the following citizen requests appear consistent with CA Coastal Act (CCA) Section 30006, and the City’s rejection of that requests seem counter to the CA Coastal Act. We again request of the City to provide: 1) a ‘Redline Version’ to the public and decision makers, along with sufficient time to review and comment on the ‘Redline Version’; and 2) true Citizen Workshops for Ponto and the Page 3 of 26 other last remaining significant vacant Coastal lands in Carlsbad as part of the Draft LCP Amendment process, or as part of deferred LCP Amendment process for those areas. 3. Coastal Zoned land is precious: the very small amount of remaining vacant Coastal land should be reserved for “High-Priority” Coastal Recreation Land Uses under the CA Coastal Act to provide for the growing and forever ‘Buildout’ needs of Carlsbad and CA Citizens, and our visitors. a. Less than 1.8% (76 square miles) of San Diego County’s 4,207 square miles is in Coastal Zone. This small area needs to provide for all the forever Coastal needs of the County, State of CA, and Visitors. Upland Coastal Recreation (Coastal Park) land use is needed to provide land to migrate the projected/planned loss of “High- Priority” Coastal Recreation land uses due to Sea Level Rise impacts. There is only 76 miles of total coastline in San Diego County; a significant amount is publicly inaccessible military/industrial land. So how the last few portions of Coastal Land within Carlsbad (which is about 8% of San Diego County’s Coastline) is planned for the forever needs for High-Coastal-Priority Recreation Land Use is critical for Carlsbad, San Diego, and California Statewide needs into the future. b. Most all the developable Coastal land in Carlsbad is already developed with Low-Coastal-Priority residential uses. Only a very small percentage of Carlsbad’s developable Coastal land, maybe 1-2%, is still vacant. This last tiny portion of fragment of vacant developable Coastal Land should be documented in the Draft LCP and reserved for “High-Priority” Coastal Land uses – most critically Coastal Recreation – to address the growing Coastal Recreation needs from a growing population and visitors. These growing needs are all the more critical in that existing Coastal Recreation lands will be decreasing due to inundation and erosion due to DLCPA planned Sea Level Rise. c. This image of the western half of San Diego County graphically shows (in the blue line) the very small Coastal Zone Area that needs to provide the Carlsbad’s and California’s Coastal Recreational needs for all San Diego County residents and Visitors: Page 4 of 26 We request that 1) the amount and location of remaining vacant Coastal land in Carlsbad be documented and mapped and be reserved for high-priority Coastal Land Uses consistent with CCA Goals in Section 30001.5 “… (c) … maximize public recreational opportunities in the coastal zone consistent with sound resources conservation principles and constitutionally protected rights of private property owners. (d) Assure priority for coastal- dependent and coastal-related development over other development on the coast. … “; 2). This data should be used in the City’s analysis and the public’s review and discussion about the City’s proposed Draft ‘Buildout’ Land Use Plan. The City’s proposed Draft ‘Buildout’ Land Use Plan will forever lock in the amount “maximum public recreational opportunities in the coastal zone” and will be the final Coastal Land Use Plan that is supposed to “assure priority for coastal-dependent and coastal-related development over other development on the coast”. Most of Carlsbad’s Coastal Zone is already developed or committed to low-priority land uses contrary to these CCA Goals, so how we finally and forever plan to use of the last small remaining vacant Coastal Land is very important. 4. The proposed Draft LCP Amendment in Chapter 3 makes unfounded statements regarding the proposed Amendment to the LCP Land Use Plan provision of “High-Priority” Coastal Recreation land use: On page 3-3, at the beginning of the Chapter 3 – Recreation and Visitor Serving Uses the City correctly states that the CA Coastal Act (CCA) places a high priority on maximizing Recreation uses, and cites multiple CCA Sections to that effect. The City’s proposed Coastal Land Use Plan then states on page 3-5 that a high proportion of land in the City is dedicated open 0 (') m )> z c.o...,~~"t:IUJ"J ---(lli!Oaedal-Nlllalftl'uc."M:c"" Page 5 of 26 space available for passive and active use, yet provides no justification or accurate metric to support this statement. This is a critical unsubstantiated and speculative statement that is not supported by any comparative data (justifying the “high proportion” statement). The City later in Chapter 3 compared the adjoining cities of Oceanside and Encinitas to try to show how the proposed Draft LCP LUP Amendment provides higher levels of Visitor Serving Accommodations. That ‘non-common denominator’ comparison was fundamentally flawed, as noted in a prior separate Draft LCPA public review comment from People for Ponto regarding another high-priority Coastal land use (visitor accommodations) planned for in Chapter 3, but at least it was an attempt to compare. However, for the Coastal Recreation portion of Chapter 3, the City does not even attempt to provide any comparative data to support (or justify) the proposed Coastal Recreation Land Use Plan and statements. The Coastal Recreation Chapter also fails to disclose Carlsbad’s adopted City Park Master Plan (Park Service Area and Equity map) data that shows a clear conflict between the CA Coastal Act Policy Sections noted at the beginning of Chapter 3 and Chapter 3’s proposed Draft Coastal Recreation Land Use Plan. Comparative Coastal Recreation: Comparing the Land Use Plan and policies of Oceanside, Carlsbad and Encinitas, one finds Carlsbad’s proposed Coastal Recreational Plan and Policies are not “high”, but very low compared with Oceanside and Encinitas. Carlsbad has a General Plan Park Standard of 3 acres of City Park per 1,000 Population. Oceanside has a 5 acres of City Park Standard per 1,000 population, and Encinitas has a 15 acres per 1,000 population standard, and an in-lieu park fee requirement of 5 acres per 1,000 population. Carlsbad’s proposed Coastal Recreation Land Use Plan is in fact not ‘high’ but is in fact the lowest of the three cities, with Carlsbad providing only 40% of Oceanside’s park standard, and only 20% of Encinitas’s Park Standard. Citywide Carlsbad currently has 2.47 acres of developed park per 1,000 population, Oceanside currently has 3.6 acres of developed park per 1,000 population, and Encinitas currently has 5.5 acres of developed park per 1,000 population. Although this data is citywide, it shows Carlsbad’s current amount of developed parkland is less than 70% of what Oceanside currently provides, and less than 45% of what Encinitas currently provides. Carlsbad is not currently providing, nor proposing a Coastal Land Use Plan to provide, a ‘high’ proportion of Coastal Recreation Land Use compared to Oceanside and Encinitas. On page 3-5 Carlsbad may be misrepresenting city open space that is needed and used for the preservation of federally endangered species habitats and lagoon water bodies. This open space Land cannot be Used for Coastal Recreation purposes; and in fact Land Use regulations prohibit public access and Recreational Use on these Lands and water bodies to protect those endangered land and water habitats. 78% of Carlsbad’s open space is “open space for the preservation of natural resources” and cannot be used for Coastal Parks and Recreational use. Although “open space for the preservation of natural resources” does provide scenic or visual amenity, and this amenity is addressed as a different coastal resource. Visual open space is not Coastal Recreation Land Use. It appears Carlsbad is proposing in the Draft LCP Amendment to continue to, providing a ‘low’ percentage of Coastal Park Land Use and Coastal Recreation Land Use compared to adjoining cities. In addition to the comparatively low amount of Coastal Park land Carlsbad plans for, Carlsbad scores very poorly regarding the equitable and fair distribution and accessibility of Coastal Parks and Coastal Recreation Land Uses. Both the City of Oceanside and Encinitas have very robust and detailed Park and Land Use plans to promote an equitable distribution of, and good non-vehicular accessibility, to their Coastal Parks. By comparison, Carlsbad’s park land use plan scores poorly, as exemplified in Ponto and South Carlsbad. Ponto’s existing population requires about 6.6 acres of City Parkland per Carlsbad’s low 3 acres per 1,000 population standard. Yet the nearest City Park is several miles away and takes over 50 minutes to walk along major arterial roadways and across Interstate 5 to access. As such this nearest park is not an accessible park for Ponto children, and thus Ponto children have to play in Page 6 of 26 our local streets to find a significantly large open area to play in. Ponto residents have to drive their kids to get to a park increasing VMT and GHG emissions. The City’s proposed Coastal Recreation Land Use Plan ‘solution’ to Ponto’s no-park condition, along with the City’s need to add an additional 6.5 acres of new City parks in Southwest Carlsbad to comply with the Southwest Carlsbad’s 2012 population demand (at a ratio of 3-acre/1,000 population) is to provide a City Park – Veterans Park – over 6-miles away from the Ponto and Southwest Carlsbad population need. This makes a bad situation worse. The City’s proposed location is totally inaccessible to serve the needs of the population of children or anyone without a car, that it is intended to serve in South Carlsbad. This City proposed Coastal Recreation Land Use Plan ‘solution’ seems inappropriate and inconsistent with the CA Coastal Act and common sense. During the City’s Veterans Park and budget community workshops citizens expressed a desire for a Ponto Park to be the solution to our Ponto and Southwest Carlsbad Park deficits. Those citizen requests were not apparently considered as part of the City’s proposed Draft Coastal Recreation Land Use Plan. Following is an image summarizing the magnitude of citizen needs/desires expressed at the City’s Budget workshop. Note the number and size of the text citing Ponto Park and South Carlsbad that reflects the number and magnitude/intensity of citizen workshop groups’ input. The failure to acknowledge this public participation and data in the Coastal Recreation Land Use Plan Park seems in conflict with CCA Sections 30006 and 30252(6): For South Carlsbad there is a complete lack of any existing or planned City Coastal Park and park acreage west of I-5, while North Carlsbad has 9 existing and 1 planned City Coastal Parks totaling 37.8 acres of City Coastal W of I-5 North Carlsbad. Not only is this unfair to South Carlsbad, it is also unfair to North Carlsbad as it increases VMT and parking impacts in North Carlsbad because South Carlsbad is not providing the City Coastal Parks for South Carlsbad resident/visitor demands. This City Park disparity is shown on Figure 3-1 of the Coastal Recreation Land Use Plan; Page 7 of 26 however it more accurately illustrated in the following data/image from the adopted Carlsbad Park Master Plan’s “Service Area Maps (Equity Maps)”. The image below titled ‘No Coastal Park in South Carlsbad’ shows Carlsbad’s adopted “Park Service Area Maps (Equity Maps)” from the City’s Park Master Plan that says it maps “the population being served by that park type/facility.” The added text to the image is data regarding park inequity and disparity in South Carlsbad. The image compiles Carlsbad’s adopted Park “Park Service Area Maps (Equity Maps)” for Community Parks and Special Use Area Parks that are the City’s two park acreage types produced by the City’s comparatively low standard of 3 acre of City Park per 1,000 population. The City’s Park Service Area Maps (Equity Maps) shows areas and populations served by parks within the blue and red circles. City data clearly shows large areas of overlapping Park Service (areas/populations served by multiple parks) in North Carlsbad and also shows large areas in South Carlsbad with No Park Service (areas/populations unserved by any parks) and Park Inequity in South Carlsbad. It clearly shows the City’s Documented Park Need and Park inequity at Ponto. The Existing LCP LUP for Ponto’s Planning Area F in is required to “consider” and “document” the need for a “Public Park”. The City’s adopted Park Service Area Maps (Equity Maps) clearly shows the inequity of Coastal City Park between North and South Carlsbad, and the need for Coastal Parks in South Carlsbad – particularly at Ponto. The City’s proposed Draft ‘Buildout’ Coastal Recreation Land Use Plan instead proposes to lock-in documented City Public Coastal Park inequity and unserved Coastal Park demand at Ponto and South Carlsbad forever. It does so by proposing the last vacant undeveloped/unplanned Coastal land – Ponto Planning Area F - in the unserved Ponto and South Carlsbad coastline areas instead of being planned for much needed City Park and Coastal Recreation use be converted to even more low-priority residential and general commercial land uses. These ‘low-priority” residential uses, by the way, further increase City Park and Coastal Recreation demand and inequity in Coastal South Carlsbad. This is wrong, and a proposed ‘forever-buildout’ wrong at the most basic and fundamental levels. The proposed Draft Coastal Recreation Land Use Plan by NOT providing documented needed City parks for vast areas of Coastal South Carlsbad is inconsistent with the CA Coastal Act policies and Existing LCP LUP requirements for Ponto Planning Area F; and also inconsistent with fair/equitable/commonsense land use and park planning principles, inconsistent with CA Coastal Commission social justice goals, inconsistent with social equity, inconsistent with VMT reduction requirements, and inconsistent with common fairness. A different Coastal Recreation Land Use Plan should be provided that provides for a socially equitable distribution of Coastal Park resources so as to would allow children, the elderly and those without cars to access Coastal Parks. The proposed Draft ‘Buildout’ Coastal Recreation Land Use Plan forever locking in the unfair distribution of City Parks appears a violation of the not only CCA Sections 30213, 30222, 30223, and 30252(6) but also the fundamental values and principles of the CA Coastal Act. The Draft also appears a violation of Carlsbad’s Community Vision. Page 8 of 26 A different Coastal Recreation Land Use Plan is required to provide a more equitable distribution of City Parks with non-vehicular accessibility. Such a different plan would advance State and City requirements to reduce vehicle Miles Traveled (VMT) and greenhouse gas emissions that contribute to climate change and sea level rise impacts. Please note that the data for the above basic comparison comes from City of Carlsbad, Oceanside and Encinitas General Plan and Park Master Plan documents. Data shows the proposed Coastal Recreation Plan conflicts with the CA Coastal Act policy Sections. As mentioned page 3-3 correctly states that the CA Coastal Act (CCA) places a high priority on maximizing Recreation Land Uses, and pages 3-5 list multiple CA Coastal Act (CCA) policy Sections that confirm this. However, given the significant statewide importance of Coastal Recreation Land Use, the City proposed ‘Buildout’ Coastal Recreation Land Use Plan does not appear to adequately address and implement these CCA Policies, and most noticeably in the Ponto area of South Carlsbad. Coastal Recreation is a significant Statewide High-Priority Land Use under the CCA. For a substantially developed non-coastal-industry city like Carlsbad Coastal Recreation is likely the biggest land use issue. This issue is even more elevated due to the fact that there are only a few small areas left of undeveloped Coastal land on which to provide Coastal Recreation, and Carlsbad is proposing a Coastal ‘Buildout’ Land Use Plan on those areas. The use of the last few remaining vacant portions of Coastal land for Coastal Recreation Land Use is the most important land use consideration in the proposed Draft LCP Land Use Plan Amendment as population and visitor growth will increase demands for Coastal Recreation. It is thus very surprising, and disturbing that the proposed Coastal Recreation Land Use Plan is so short, lacks any comparative and demand projection data, lacks any resource demand/distribution and social equity data, and lacks any rational and clear connection with CCA Policy and the proposed ‘Buildout’ Coastal Land Use plan. This is all the more troubling given that: The Ponto area represents the last significant vacant undeveloped/unplanned land near the coast in South Carlsbad that can provide a meaningful Coastal Park. The fact that the City’s Existing LCP requires the city consider and document the need for a “i.e. Public Park” on Ponto’s Planning Area F prior to the City proposing a change of Planning Area F’s “Non-residential No Coastal Park in South Carlsbad ppx. 6 miles of Coast without a Coastal Park is a Ci Regional need • South Carlsbad has 6 ,000 residents & thousands of hotel visitors ithout a Coastal park • Closest park to Ponto is Poinsettia Park, approx. 2.5 miles across 1-5 • Proposed Veterans Park is approx. 6 miles away Page 9 of 26 Reserve” land use designation. The City has repeatedly failed to comply with this LCP LUP requirement, and worse has repeatedly failed to honestly inform citizens of this LCP LUP requirement at Planning Area F before it granted any land use. The City, apparently implementing speculative developer wishes, has repeatedly proposed changing Planning Area F’s Coastal Land Use designation to “low-priority” residential and general commercial land uses without publically disclosing and following the Existing LCP LUP. The City’s currently developed parks in the southern portion of the City do not meet the city’s comparatively low public park standard of only 3 acres per 1,000 population. Since 2012 there has been City park acreage shortfall in both SW and SE Carlsbad. The Existing population of Ponto (west of I-5 and south of Poinsettia Lane) requires about 6.6 acres of Public Park based on the City’s comparatively low public park standard of 3 acres per 1,000 population. There is no Public Park in Ponto. Adding more population at Ponto will increase this current park demand/supply disparity. Carlsbad and other citizens have since 2017 expressed to the City the strong need for a Coastal Park at Ponto, and requested the City to provide a true citizen-based planning process to consider the Public Park need at Ponto. The Citizens’ requested process is fully in-line with CCA Goals, Public Participation Policy, Land Use Policies, and the Existing LCP Land Use Plan/requirements for Planning Area F and is the most appropriate means to consider and document the need for a Public Park at Ponto as required by the Existing LCP Land Use Plan. Planning Area F is for sale, and a non-profit citizens group has made an offer to purchase Planning Area F for a much needed Coastal Park for both Ponto and inland South Carlsbad residents and visitors. How should these facts be considered by the City and CCC? Carlsbad has no Coastal Parks west of I-5 and the railroad corridor for the entire southern half of Carlsbad’s 7-mile coastline. The southern half of Carlsbad’s coastline is 5.7% of the entire San Diego County coastline and represents a significant portion of regional coastline without a meaningful Coastal Park west of I-5 and the Railroad corridor. The City’s proposed Coastal Recreation Land Use Plan provides No Documentation, No Rational, and No Supporting or Comparative Data to show the proposed Coastal Recreation Land Use Plan in fact complies with the CA Coastal Act. 5. There is no Coastal Recreation/Park west of interstate 5 for all South Carlsbad, or half of the entire City. This is obviously an unfair and inequitable distribution of Coastal Recreation/Park resources that should be corrected by changes to the Draft LCP Land Use Amendment: The following image (which was sent to the City and CCC on several prior communications) was first requested by former Carlsbad Councilman Michael Schumacher during a People for Ponto presentation/request at the Oct 23, 2018 City Council meeting. The data compiled in the image shows how the South Coastal Carlsbad (Ponto) is not served by a Park per the City’s adopted Parks Master Plan. The blue dots on the map are park locations and blue circle(s) show the City’s Park Master Plan adopted Park Service Areas and Park Equity. This data, from pages 87-88 of the City of Carlsbad Parks Master Plan, shows all City Parks (both Community Parks and Special Use Areas in Coastal Carlsbad (except Aviara Park east of Poinsettia Park and west of Alga Norte Park). The text on the left margin identifies the South Carlsbad Coastal Park (west of I-5) gap along with the number of South Carlsbad Citizens (over half the City’s population) without a Coastal Park. The left margin also identifies more local issues for the over 2,000 Ponto area adults and children. For Ponto residents the nearest Public Park and City proposed ‘solution’ to the South Carlsbad and Ponto Public Park deficit are miles away over high- speed/traffic roadways and thus somewhat hazardous to access and effectively unusable by children/the elderly or Page 10 of 26 those without cars. Having been a 20-year resident of Ponto I regularly see our children have to play in the street as there are no Public Park with large open fields to play at within a safe and under 1-hour walk away. Ponto citizens have submitted public comments regarding this condition and the lack of a Park at Ponto Ponto is at the center of regional 6-mile Coastal Park Gap. A Coastal Park in this instance being a Public Park with practical green play space and a reasonable connection with the Coast (i.e. located west of the regional rail and Interstate-5 corridors). The following image shows this larger regional Coastal Park Gap centered on the Ponto Area, and the nearest Coastal Parks – Cannon Park to the north, and Moonlight Park to the south. Regionally this image shows Ponto is the last remaining significant vacant Coastal land that could accommodate a Coastal Park to serve the Coastal Park current needs of over existing 2,000 Ponto residents, 64,000 existing South Carlsbad residents, and a larger regional population. It is also the only area to serve the Coastal Park needs for the thousands of hotel rooms in Upland Visitor Accommodations in South Carlsbad. No Coastal Park in South Carlsbad • Appx. 6 miles of Coast without a Coastal Park is a City & Regional need • South Carlsbad has 64,000 residents & thousands of hotel visitors without a Coastal park • Closest park to Ponto is Poinsettia Park, approx. 2.5 miles across 1-5 • Proposed Veterans Park is approx. 6 miles away ....... __ ------ " ~ c-c-,.. ......... __ ...__.. __ ... _.._ "'-'""•W"tl, ...... _,...,. c-..~-n.o,..,.,oc-,.,~, .. '"°"" ~ nwi,o.,c,,.,...,,,.,,... so.n.c..-___ .. -C-C.-\'- ~ ..... -.. -~ ........... __ _ .-CMliloNlt~ ---.-.c.o.&tl••·· Page 11 of 26 As People for Ponto first uncovered and then communicated in 2017 to the City and CCC; Carlsbad’s Existing (since 1994) Local Coastal Program LUP currently states (on page 101) that Ponto’s Planning Area F: carries a Non-Residential Reserve (NRR) General Plan designation. Carlsbad’s Existing Local Coastal Program Land Use Plan states: “Planning Area F carries a Non-Residential Reserve (NRR) General Plan designation. Planning Area F is an “unplanned” area …” and requires that: “… As part of any future planning effort, the City and Developer must consider and document the need for the provision of lower cost visitor accommodations or recreational facilities (i.e. public park) on the west side of the railroad.” CA Coastal Commission actions, Carlsbad Public Records Requests 2017-260, 261, and 262, and 11/20/19 City Planner statements confirm the City never fully communicated to Carlsbad Citizens the existence of this LCP requirement nor did the City comply with the requirements. Of deep concern is that the City is now (as several times in the past) still not honestly disclosing to citizens and implementing this Existing LCP requirement as a true and authentic ‘planning effort’. The lack of open public disclosure and apparent fear of true public workshops and Public Comment about the Existing Planning Area F LCP requirements are troubling. The point of a ‘planning effort’ is to openly and publically present data, publically discuss and explore possibilities/opportunities, and help build consensus on the best planning options. Citizens are concerned the city has already made up its mind and there is no real “planning effort” in the proposed Draft LCP Amendment process, just a brief Staff Report and at the end provide citizens 3-minutes to comment on the proposal. This is not the proper way to treat the last remaining significant vacant land is South Carlsbad that will forever determine the Coastal Recreation environment for generations of Carlsbad and California citizens and visitors to come. The following data/images show how Ponto is in the center of the 6-mile (west of I-5 and Railroad corridor) regional Coastal Park gap. Ponto is the last remaining vacant and currently “unplanned” Coastal land that is available to address this regional Coastal Park Gap. How Bonte Serves Reg ion Page 12 of 26 How Ponto Serves Region cont. • RellwesCoa&tll Patu:c1.41emon In t,lortb Cartsbad, Encinitas/illdSolana aeactt • Al"" Lllll l!lllfy II.,.,.,. Coastal Park as seen by: -Ponto Beach R11rkingcongestion -current trespass use of Planning Area Fas a Park How Ponto Serves Region cont. • A PQnlo Pad( hl!lps add! ess2050 and beyond Regional Populationand VlsitMGrowth demands for Coastal Parks • A Ponto Park provides the lowest- Page 13 of 26 How Ponto Serves Region e-0n,. .. Vital park and open $paceamenltyfcw VlsitorSl!fVinll bu&inc esand aa:ommodatlons • 6.6 acre uniqueCity Coastal Park venue to stage special events: Runs, bike rides, triathlons, How Ponto Serves Region ,on,. • Critkal Park space for So. Carlsbad SbltelleKII Campground • Provldesabig training and staging space for Junior lifeguards • Dogwalktrail Page 14 of 26 One possible Concept image of a potential Ponto Coastal Park at Planning Area F is illustrated below. The potential for a Ponto Coastal Park is real. The speculative land investment fund (Lone Star Fund #5 USA L.P. and Bermuda L.P.) that currently owns Planning Area F is selling the property, and is available for the City of Carlsbad to acquire to address the documented demand/need for a City Park and City Park inequity at Ponto and in Coastal South Carlsbad. A Ponto Beachfront Park 501c3 is working to acquire donations to help purchase the site for a Park. These situations and opportunities should be publicly discussed as part of the City Staff’s proposed Local Coastal Program Land Use Plan Amendment. Ponto Coastal Park Concept • Awncept-but shows potential recreational opportunities • Provides vital parkland support for beach & ope n play fie lds • Concept plan a gift from san Pacifico Page 15 of 26 6. Projected increases in California, San Diego County and Carlsbad population and visitor growth increases the demand for High-Priority-Coastal Recreation land use: a. Increasing Citizen demand for Coastal Recreational land needs to be addressed with increased Coastal Recreation land: San Diego County Citizen Population - source: SANDAG Preliminary 2050 Regional Growth Forecast 1980 1,861,846 1990 2,498,016 2000 2,813,833 2010 3,095,313 2020 3,535,000 = 46,500 Citizens per mile of San Diego County coastline 2030 3,870,000 2040 4,163,688 2050 4,384,867 = 57,700 Citizens per mile of San Diego County coastline 2020 to 2050 = 24% increase in San Diego County population. Citizen Population will continue beyond 2050. Carlsbad may plan for ‘Buildout’ in 2050, but what is San Diego County’s ‘Buildout’? There is a common-sense need to increase the amount of Coastal Recreation Land Use in the Proposed LCP Amendment to the Land Use Plan for this growing population. If we do not increase our supply of Coastal Recreational Resources for these increased demands our Coastal Recreation Resources will become more overcrowded, deteriorated and ultimately diminish the Coastal Recreation quality of life for Citizens of Carlsbad and California. Ponto sits in the middle of an existing 6-mile regional Coastal Park Gap (no Coastal Park west of Interstate 5) and there is No Coastal Park in all of South Carlsbad to address the Coastal Recreation needs of the 64,000 South Carlsbad Citizens. Page 16 of 26 b. Increasing Visitor demand for Coastal Recreational land needs to be addressed with increased Coastal Recreation land: Yearly Visitors to San Diego County – source: San Diego Tourism Authority; San Diego Travel Forecast, Dec, 2017 2016 34,900,000 2017 34,900,000 2018 35,300,000 2019 35,900,000 2020 36,500,000 = average 100,000 visitors per day, or 2.83% of County’s Population per day, or 1,316 Visitors/coastal mile/day in 2020 2021 37,100,000 2022 37,700,000 This is growth at about a 1.6% per year increase in visitors. Projecting this Visitor growth rate from 2020 to 2050 results in a 61% or 22,265,000 increase in Visitors in 2050 to: 2050 58,765,000 = average 161,000 visitors per day, or 3.67% of the County’s projected 2050 Population per day, or 2,120 Visitors/coastal mile/day in 2050. The number of Visitors is likely to increase beyond the year 2050. There is a common-sense need to increase the amount of Coastal Recreation Land Use in the Proposed LCP Amendment to the Land Use Plan for these projected 2050 61% increase, and beyond 2050, increases in Visitor demand for Coastal Recreational Resources. Increasing Coastal Recreation land is a vital and critically supporting Land Use and vital amenity for California’s, the San Diego Region’s and Carlsbad’s Visitor Serving Industry. Ponto sits in the middle of an existing 6-mile regional Coastal Park Gap (no Coastal Park west of Interstate 5). There are thousands of hotel rooms in South Carlsbad that have NO Coastal Park to go to in South Carlsbad. This needs correcting as both a Coastal Act and also a City economic sustainability imperative. c. We request that the as part of the public’s review, the City Staff proposed Draft LCP Amendment to the Land Use Plan clearly document if and/or how future forever ‘Buildout” City, Regional and Statewide population and visitor population demand for Coastal Recreation and City Coastal Parks are adequately provided for both in amount and locational distribution in the Carlsbad proposed Amendment of the LCP Land Use Plan. 7. Carlsbad’s Draft Local Coastal Program Land Use Plan Amendment says it plans to a year 2050 buildout of the Coastal Zone. The Draft Local Coastal Program Land Use Plan Amendment then is the last opportunity to create a Coastal Land Use Plan to provide “High-Priority” Coastal Recreation Land Use, and will forever impact future generations of California, San Diego County, and Carlsbad Citizens and Visitors: a. The Draft LCPA indicates in 2008 only 9% of All Carlsbad was vacant land. Less is vacant now in 2019. Carlsbad’s Coastal Zone is 37% of the City, so vacant unconstrained land suitable for providing Coastal Recreation is likely only 3-4%. The prior request for a full documentation of the remaining vacant Coastal lands will provide a better understanding needed to begin to make the final ‘buildout’ Coastal Land Use Plan for Carlsbad. The Draft LCPA does not indicate the amount and locations of currently vacant unconstrained Coastal Land in Carlsbad. This final limited vacant land resource should be clearly documented and mapped in the DLCPA as it represents the real focus of the DLCPA – the Coastal Plan for these remaining Page 17 of 26 undeveloped lands. These last remaining vacant lands should be primarily used to provide for and equitably distribute “High-Priority” Coastal Recreation Land Uses consistent with CCA Sections: i. Section 30212.5 “… Wherever appropriate and feasible, public facilities, including parking areas or facilities, shall be distributed throughout an area so as to mitigate against the impacts, social and otherwise, of overcrowding or overuse by the public of any single area.”; ii. Section 30213 “… Lower cost visitor and recreational facilities shall be protected, encouraged, and, where feasible, provided. Developments providing public recreational opportunities are preferred. …”; iii. Section 30222 “The use of private lands suitable for visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have priority over private residential, general industrial, or general commercial development, but not over agriculture or coastal-dependent industry.” iv. Section 30223 “Upland areas necessary to support coastal recreational uses shall be reserved for such uses, where feasible” , v. Section 30251 … The location and amount of new development should maintain and enhance public access to the coast by … 6) assuring that the recreational needs of new residents will not overload nearby coastal recreation areas by correlating the amount of development with local park acquisition and development plans with the provision of onsite recreational facilities to serve the new development” Adopted City Park Service Area and Park Equity maps discussed earlier document the proposed Draft LCP Amendment’s inconstancy with the above CCA Policy Sections. The locations and small amounts remaining vacant Coastal lands provide the last opportunities to correct the inconsistencies of City proposed Draft “buildout” LCP Land Use Plan Amendment with these Coastal Act Policies. Currently and since 1996 there has been LCP LUP Policy/regulations for Ponto Planning Area F that require consideration of a “Public Park” prior to changing the existing “unplanned Non-residential Reserve” Land Use designation. A map and data base of vacant developable Coastal land should be provided as part of the Draft LCPA and the Draft LCPA. This map and data base should document the projected/planned loss of Coastal land use due to Sea Level Rise. Draft LCPA projects Sea Level Rise will eliminate several beaches and High-Priority Coastal Land Uses like Coastal Lagoon Trails and the Campground. b. The LCP Land Use Plan should plan and reserve the very limited vacant developable Coastal land for the long-term ‘Buildout’ needs of “High-Priority” Coastal Recreation Land Use. Vacant developable Coastal land is too scarce to be squandered for “low-priority” uses. Sea Level Rise will reduce “High-Priority” Coastal Uses. So how vacant developable Upland area should be preserved for “High-Priority” Coastal Uses is a key requirement to be fully documented and discussed in the Draft LCPA. If not one of two thing will eventually happen 1) any new Coastal Park land will require very expensive purchase and demolition of buildings or public facilities to create any new Coastal Park land to meet existing and growing demand; or 2) Coastal Recreation will hemmed-in my “low-priority” uses and thus force Coastal Recreation to decrease and become increasing concentrated and overcrowded in its current locations; and thus will promote the eventual deterioration of our current Coastal Recreation resources. A plan that fails to fix Coastal Park deficits and then increase Costal Parks in pace with increased population/visitor demand is a plan that can only result in degradation. How the Draft LCPA documents and addresses the land use planning of the last small portions of vacant developable Coastal land is critical for the future and future generations. Page 18 of 26 8. Citizens of South Carlsbad are concerned about the City’s multiple prior flawed Ponto planning processes or ‘mistakes’ the City has made yet is basing the City Staff’s proposed Draft LCP LUP. The concerns being the City is not openly and honestly communicating information to citizens and the public, and not allowing a reasonable and appropriate community-based planning process to address the documented Park, Coastal Recreation and unconstrained open space needs in South Carlsbad. One of these groups of citizens has created a www.peopleforponto.com website to try to research and compile information and hopefully provide a better means for citizens to understand facts and then express their concerns/desires to the City of Carlsbad (City) and CA Coastal Commission (CCC). Over 2,000 emails have sent to the City and CCC regarding Coastal Land Use Planning Issues at Ponto. The San Pacifico Planned Community (i.e. San Pacifico Community Association) has also, since 2015, sent numerous emailed letters to the City and CCC noting the significant concerns about changes in Coastal planning the City is proposing for our Planned Community. Repeatedly over 90% of surveyed citizens (results emailed prior to both the City and CCC) have expressed the vital need and desire for a Coastal Park at Ponto to serve the current and future Coastal Recreation needs for all both Ponto and South Carlsbad and for larger regional and State Coastal Recreational needs. This desire is supported by data, CA Coastal Act Policy, and also Carlsbad’s Community Vision – the foundation for the City’s General Plan. Ponto is the last remaining vacant Coastal area available to provide for those needs in South Carlsbad and for a regional 6-mile stretch of coastline. Citizens have expressed deep concern about the City’s flawed prior Coastal planning efforts for Coastal Recreation at Ponto, including two repeated LCP Amendment “mistakes” (Ponto Beachfront Village Vision Plan in 2010 and General Plan Update in 2015) when the City twice failed to publicly disclose/discuss and then follow the Existing LCP requirements at Ponto – specifically for Planning Area F. People for Ponto had to use multiple Carlsbad Public Records Requests in 2017 to find these “mistakes”. CCC Staff was helpful in both confirming the City “mistakes” and communicating back to the City. As citizens we are still unclear has to how/why these two repeated “mistakes” happened. There is citizen concern that the City is again repeating these two prior “mistakes” by not at the beginning of the Public Comment Period clearly and publicly disclosing the Planning Area F LCP requirements to citizens as part of the current LCP Amendment process, and also by not implementing the exiting LCP requirement PRIOR to proposing an Amended Coastal Land Use Plan for Ponto. The City in its proposed LCP Amendment process is putting-the-cart-before-the-horse with respect to honest and open consideration, documentation and public discussion of the need for high-priority Coastal Recreation land use required of Planning Area F at Ponto. The City is also not clearly letting all Carlsbad citizens know about the Existing LCP requirements for Ponto’s Planning Area F so they can be informed to reasonably participate in public review and comment regarding amending that LCP requirement, and the need for Coastal Recreation land uses in South Carlsbad. Since 2017 there has been repeated citizen requests to the City (copies were provided to the CCC) to fix these multiple fundamental/foundational flaws by in the City’s prior Coastal Recreation and Public Parks and Open Space at planning, and the currently Proposed Draft LCP Land Use Plan Amendment. Since 2017 there have also been repeated citizen requests to the City to provide a truly open, honest, inclusive community-based planning process and workshops with the accurate and honest information, prior to forming a proposed Draft LCP Land Use Plan Amendment. As citizens we believe we can constructively work with the City and CCC towards a consensus or viable options on these important Coastal Recreation issues if the City allows and encourages such an open, honest and inclusive process. We request the City respond to the requests submitted to the City since 2017, and again request such a process from the City before any LCP Amendment is first considered by the Planning Commission and City Council. Such a requested process benefits all. Page 19 of 26 9. Why the Draft LCPA Land Use Plan for Ponto should provide for the current and future Coastal Park and Recreation needs for South Carlsbad, the San Diego Region and California. a. Ponto, is one of last remaining vacant and undeveloped Coastal lands in North County b. Ponto is the last remaining undeveloped Coastal land in South Carlsbad c. Ponto has the last unplanned Planning Area of the Existing Poinsettia Shores Planned Community & Local Coastal Program that can be planned for high-priority Coastal Recreation land use. This Existing LCP requires Planning Area F be considered for a “Public Park”. d. Following is a map of the Ponto area in South Carlsbad: Following is the LCP Land Use map from the Existing Poinsettia Shores Master Plan & Local Coastal Program adopted in 1996. This is the Land Use map that the City is proposing to change in the proposed LCP Amendment to the Land Use Plan. As the Existing LCP Land Use map shows most all the land is ‘low-priority’ residential use at an RM Residential medium density, a small portion is ‘high-priority’ Visitor Serving TC/C Tourist Commercial. Most all the Open Space is constrained and undevelopable land (the steep CSS habitat bluffs above Batiquitos Lagoon) or water Page 20 of 26 (the lagoon water). This land/water is owned by the State of California, like the inner lagoon east of I-5. Only Planning Area M at 2.3 acres is unconstrained Open Space and it provides a small private internal recreation facility for the approximately 450 homes and 1,000 people in the Planned Community. This small recreation area is a City requirement for ‘planned developments’ to off-set loss open space from planned development impacts on housing quality. Planned developments can propose designs that reduce normal setback and open space areas – they bunch together buildings to increase development – such as the smaller lot sizes, and extensive use of “zero-setbacks” to reduce typical lot sizes that occurs at Poinsettia Shores. A private recreation facility in any of the City’s planned developments is never considered a replacement for required City Parks. Planned Developments, like unplanned developments, are required to dedicate Park land to the City, or pay a Park In-Lieu fee to the City so the City provide the developer’s obligation to provide City Park acreage to address the population increase of their proposed planned development. For Poinsettia Shores’ population the City’s minimum City Park Standard would require developers set aside 3 acres of City Park land for local park needs. For the larger Ponto area population about 6.6 acres of City Park Land is required. The Existing LCP reserves Planning Area F as an unplanned “Non-residential Reserve” Land Use until the Public Park needs for Ponto are considered and documented. Only then can the NRR land use be changed. 10. Developers have overbuilt in the Ponto area of the Coastal Zone. The City of Carlsbad has under questionable circumstances is currently choosing to ‘exempted’ Ponto developers from providing the minimum amount of unconstrained Open Space according to the City’s developer required Open Space Public Facilities Standard. The legality of these confusing circumstances is subject to a lawsuit against the City. However the City’s computerize mapping system has documented that the Ponto area of the Coastal Zone is missing about 30-acres of Unconstrained Open Space that can be used to fulfill the City’s Open Space Performance Standard that states that 15% of unconstrained and developable land must be preserved by developers as Open Space. Following is a Page 21 of 26 summary of data from the City data regarding the missing Open Space at Ponto (Local Facility Management Plan Zone 9, LFMP Zone 9) in the Coastal Zone pursuant to the City’s Open Space Performance Standard. If it is desirable People for Ponto can provide the City GIS map and parcel-by-parcel data base on which the following summary is based: City of Carlsbad GIS data calculations of Open Space at Ponto area of Coastal Zone: 472 Acres = Total land in LFMP Zone 9 [Ponto area] per City of Carlsbad GIS data (197 Acres) = Constrained land/water/infrastructure that is excluded from the City’s Open Space Standard 275 Acres = Unconstrained land in LFMP Zone 9 (Ponto) subject to the City’s Open Space Standard X 15% = Minimum unconstrained Open Space requirement per the City Open Space Standard 41 Acres = Minimum unconstrained Open Space required in LFMP Zone 9 (11 Acres) = Actual unconstrained Open Space provided & mapped by City in LFMP Zone 9 30 Acres = Missing unconstrained Open Space needed in LFMP Zone 9 [Ponto area of Coastal Zone] to meet the City’s minimum GMP Open Space Standard. 73% of the required Open Space Standard is missing. Thus the Ponto area of the Coastal Zone appears overdeveloped with 30 additional acres of “low-priority” residential land uses due to developers’ non-compliance to the City’s Open Space Public Facility Performance Standard’s Minimum developer required Open Space requirement. As noted a citizens group has a pending lawsuit with the City over the City’s current ‘exempting’ Ponto and future developers from meeting the Open Space Standard. 11. The prior pre-1996 LCP for Ponto – the Batiquitos Lagoon Educational Park Master Plan & LCP (BLEP MP/LCP) had significant Open Space and recreational areas. These significant Open Space and Recreational areas where removed with BLEP MP/LCP’s replacement in 1996 by the currently existing Poinsettia Shores Master & LCP (PSMP/LCP) and its City Zoning and LCP LUP requirements that reserved Planning Area F with the current “Non-residential Reserve” Land Use designation. Since the BLEP MP/LCP it appears developers and the City of Carlsbad have worked to remove “High-Priority” Coastal land uses (i.e. Coastal Recreation and Park uses) out of the Ponto area and replaced them with more “low-priority” residential and general commercial land uses. For example: a. Planning Area F used to be designated “Visitor Serving Commercial” as part of the original 1980’s BLEP MP/LCP for Ponto. b. In 1996 the BLEP MP LCP was changed by developer application to the now current PSMP LCP, and the LCP LUP designation changed from “Visitor Serving Commercial” to “Non-Residential Reserve” with the requirement to study and document the need for “High-Priority” Coastal Recreation (i.e. Public Park) and/or Low-cost visitor accommodations prior to any change to Planning Area F’s “Non-residential Reserve” LCP land use. c. In 2005 the City started to try to change Planning Area F to low-priority residential and general commercial land use in the City’s Ponto Beachfront Village Vision Plan (PBVVP). At this time the City made its first documented Coastal ‘planning mistake’ by not disclosing to the public the existence of Planning Area F’s LCP requirements and then also not following those LCP requirements. The City’s planning process seemed focused on addressing developer’s land use desires, and increasing land use intensity to boost “Tax- increment financing” as the City had established a Redevelopment Project Area at Ponto. A short time after the State of CA dissolved Redevelopment Agencies due in part to such abuses by cities. The CCC formally rejected the PBVVP in 2010, citing the City’s failure to follow the LCP requirements for Planning Area F. d. Five years later in 2015 the City again adopted a proposed General Plan Update to again change Planning Area F to low-priority residential and general commercial land use. The General Plan Update cited the City’s PBVVP that was in fact rejected by the CCC only a few years before. The City again repeated their PBVVP’s Page 22 of 26 Coastal land use ‘planning mistake’ by again not disclosing to the public the existence of Planning Area F’s LCP requirements and then not following those LCP requirements. It is unclear why the City did this only 5- years after the CCC specifically rejected the Ponto Beachfront Village Vision Plan for those same reasons. e. In 2017 citizens found and then confirmed these Ponto Coastal ‘planning mistakes’ by the City through multiple official Carlsbad Public Records Requests and CCC Staff confirmation. The CCC readily identified the mistakes, but the City’s 2019 proposed Draft LCP Land Use Plan and planning process still has yet fully disclose these prior Coastal ‘planning mistakes’ to ALL citizens of Carlsbad - the failure to disclose and follow the Planning Area F LCP LUP and City Zoning requirements. Full City disclosure is needed now to try to correct many years of City misrepresentation to citizens on LCP required Coastal land Use planning at Ponto. It is needed now so the public is aware at the start of the Public Comment Period. In 2017 citizens began asking the City fix the City’s over 12-years of misinformation and planning mistakes by ‘restarting’ Coastal land use planning at Ponto with an open and honest community-based Coastal planning process. These citizens’ requests have been rejected. f. In 2019 the City Staff proposed citywide Draft LCP land Use Plan Amendment that again proposed to change Planning Area F to “low-priority” residential and general commercial land use, without First disclosing the Planning Area F LCP requirements with corresponding analysis of the Need for Coastal Recreation (i.e. Public Park) and/or low-cost visitor accommodations at Planning Area F and providing that Documented analysis for public review/Consideration/comment. This seems like another 3rd repeat of the prior two Coastal planning mistakes by the City. In 2019, again citizens asked for a reset and a true community-based process for the last remaining significant vacant Coastal lands – including Ponto. Again the City rejected citizens’ requests. g. In 2020 thousands of public requests again asked, and are currently asking, for a reset and a true community-based process for the last remaining significant vacant Coastal lands – including Ponto. Again these requests are being rejected. Based on the significant citizen concern and the documented prior ‘planning mistakes’ at Ponto it appears reasonable and responsible for Ponto’s Planning Area F to ether: i. Retain its current Existing LCP LUP land Use of “Non-Residential Reserve” until such time as the City’s past Ponto Beachfront Village Vision Plan and General Plan Update planning mistakes and other issues subject to current planning lawsuits against the City are resolved with a true, honest and open community-based Coastal planning process asked for by citizens since 2017. Or ii. Propose in the Draft LCP Land Use Plan Amendment to re-designated Planning Area F back to a Visitor Serving Commercial and Open Space (“i.e. Public Park”) to provide both “High-Priory” coastal uses v. low-priority residential/general commercial uses due to the documented Coastal Recreation and Low-cost visitor accommodation needs for both citizens and visitors at Ponto and South Carlsbad. 12. Questionable logic and inconsistency in proposed Draft land use map and policies: Chapter 2 Figure 2-2B & C on pages 2-19 & 20 proposes to Amend the existing LCP Land Use Plan Map, and policies LCP-2-P.19 and 20 on pages 2- 27 to 2-29 propose Amendments to existing LCP policy and create a new added layer of policy referencing a Ponto/Southern Waterfront. The proposed Land Use Map and Policies serve to firmly plan for “low-priority” residential and general commercial land uses at Ponto with a clear regulatory Land Use Plan Map showing these land uses and by specific regulatory policy (LCP-2-20) that clearly requires (by using the words “shall”) these “low priority” uses. In contrast the “High-Priority” Coastal Recreation and Coastal Park land uses that would be designated as Open Space are not mapped at all in Figure 2-2B & C; and the proposed policy LCP-2-P.19 is both misleading and specifically does Not Require any “High-Priority” Coastal Recreation and Coastal Park land Use at Ponto and South Carlsbad. In fact page 2-22 specifically indicates two “may” criteria that would first need to occur Page 23 of 26 in the positive before any potential Coastal Recreation and Coastal Park Land could then theoretically even be possible. It is highly probable that it is already known by the City that the proposed relocation of Carlsbad Boulevard (Coast Highway) is not very feasible and not cost effective, and will not yield (due to environmental habitat constraints, narrowness of the roadway median, and other design constraints) any significant dimensions of land that could potentially be designated Open Space and realistically be used as a Park. The blank outline map (Figure 2-2B &C) provides no mapped Open Space Land Use designation, other than for the currently existing State Campgrounds’ low-cost visitor accommodations, so the proposed Land Use Plan Map is Not providing/mapping any new Open Space land use to address Coastal Recreation and Coastal Park needs. The Draft LCP Land Use Plan Amendment’s proposed/projected/planned Sea Level Rise and associated coastal erosion appears to indicate that this “High-Priority” low-cost visitor accommodation (Campground) land use designated as Open Space will be reduced in the ‘Buildout’ condition due to coastal erosion. So the Draft LCP Land Use Plan is actually planning for a Reduction in Open Space Land Use in South Carlsbad and Ponto. Both the blank outline map and the proposed Land Use Map Figure 2-1 DO NOT clearly map and designate both South Carlsbad’s Draft LCP Planned Loss of the Open Space Land Use and also any New or replacement unconstrained land as Open Space land use for Coastal Recreation and Coastal Park. This is an internal inconsistency in Land Use Mapping that should be corrected in two ways: 1) Showing on all the Land Use (Figure 2-1), Special Planning Area (Figure 2-2B & C), and other Draft LCP Maps the Draft LCP’s planned loss of land area in those maps due to the Draft LCP’s planned loss of land due to Sea Level Rise and Coastal Land Erosion. This is required to show how land use boundaries and Coastal Recourses are planned to change over time. or 2) Provide detailed Land Use Constraint Maps for the current Carlsbad Boulevard right-of-way that the City “may” or ‘may not’ choose (per the proposed “may” LCP-2-P.19 policy) use to explore to address the City’s (Park Master Plan) documented Coastal Recreation and Coastal Park land use shortages in Coastal South Carlsbad and Ponto. Clearly showing the potential residual Unconstrained Land within a Carlsbad Boulevard relocation that have any potential possibility to add new Open Space Land Use Designations (for Coastal Recreation) is needed now to judge if the policy is even rational, or is it just a Trojan horse. The proposed internal inconsistency in mapping and policy appears like a plan/policy ‘shell game’. The proposed Land Use Plan Maps and Policies should be consistent and equality committed (mapped-shall v. unmapped-may) to be a feasible and actual Plan. If not then there is No real Plan. There is no Regulatory Policy requirement in LCP-2-P.19 to even require the City to work on the two “may” criteria. The City could choose to bury the entire Carlsbad Boulevard relocation concept and be totally consistent with Policy LCP-2-P.19 and the LCP. As such the language on 2-22, Figure 2-2C (and the proposed Land Use Map), and policy LCP-2-P.19 and 20 appear conspire to create a shell game or bait-and-switch game in that only “low-priority” residential and general commercial uses are guaranteed (by “shall” policy) winners, and “high-priority” Coastal Recreation and Coastal Park Land Uses are at best a non-committal ‘long-shot” (“may” policy) that the city is specifically not providing a way to ever define, or commit to implement. The proposed Draft LCP Land Use Plan Coastal Recreation and Coastal Park statements for Ponto are just words on paper that are designed to have no force, no commitment, no defined outcome, and no defined requirement to even have an outcome regarding the documented “High-Priority” Coastal Recreation and Costal Park needs at Ponto, Coastal South Carlsbad and the regional 6-mile Coastal Park gap centered around Ponto. Page 24 of 26 Policy LCP-2-P.19 falsely says it “promotes development of recreational use” but does not in fact do that. How is development of ‘recreational use promoted’ when the Use is both unmapped and no regulatory policy requirement and commitment (no “shall” statement) to ‘promote’ that Use is provided? Policy LCP-2-19.19 appears a misleading sham that does not ‘promote’ or require in any way “High-Priority” Coastal Recreation and Park Land Use at Ponto. There should be open and honest public workshops before the Draft LCP Amendment goes to its first public hearing to clearly define the major environmental constraints and cost estimates involving possible relocation of Carlsbad Boulevard and constructing needed beach access parking, and sufficient and safe sidewalks and bike paths along Carlsbad Boulevard; and then map the amount and dimensions of potential ‘excess land’ that maybe available for possible designation as Open Space in the City General Plan and Local Coastal Program. The City should not repeat the mistakes at the Carlsbad Municipal Golf Course (resulting in the most expensive to construct municipal course in the USA) by not defining and vetting the concept first. A preliminary review of City GIS data appears the amount, dimensions and locations of any potential ‘excess’ land maybe modest at best. However before the City proposes a ‘Buildout’ Coastal Land Use Plan this critical information should be clearly provided and considered. It is likely the City’s Carlsbad Boulevard relocation concept is unfeasible, inefficient, too costly, and yields too little actual useable ‘excess land’ to ever approach the Coastal Recreation and Coastal Park needs for South Carlsbad. This may already be known by the City, but it surely should be publicly disclosed and discussed in the DLPCA. The proposed Coastal Land Use Plan to address Carlsbad’s, San Diego County’s and California’s High-Priority Coastal Recreation Land Use and Coastal Park needs should NOT be vague “may” policy that appears to be purposely designed/worded to not commit to actually providing any “High-Priority” Coastal Recreation and Coastal Park land uses on the map or in policy commitments. The Land Use Plan and Policy for High-Priority Coastal Recreation and Coastal Park Land Use should be definitive with triggered “shall” policy statements requiring and assuring that the ‘Forever’ “High-Priority” Coastal Recreation and Coastal Park needs are properly and timely addressed in the City’s proposed ‘Buildout’ Coastal Land Use Plan. This “shall” policy commitment should be clearly and consistently mapped to show the basic feasibility of the planned outcomes and the resulting actual Land that could feasibly implement the planned outcome. Providing safe and sufficient sidewalks, bike paths, and public parking along Carlsbad Boulevard: Providing safe and sufficient sidewalks, bike paths, and public parking along Carlsbad Boulevard are Coastal Access and Completes Streets issues. South Carlsbad Boulevard now and has for decades been a highly used Incomplete Street that is out of compliance with the City’s minimum Street Standards for pedestrian and bike access and safety. The Coastal Access portion of the Draft Land Use Plan should strongly address the Complete Street requirements for South Carlsbad Boulevard. Those policy commitments should be reference in Policy LCP-2-P.19 and 20 as Carlsbad Boulevard in South Carlsbad is the most Complete Street deficient portion of Carlsbad Boulevard. Forever Coastal Access parking demand and the proposed LCP Amendment’s Land Use Plan to supply parking for those demands should also be addressed as part of the Coastal Access and Complete Streets issues for South Carlsbad Boulevard. If much needed Coastal Access Parking is provided on South Carlsbad Boulevard as part of a “maybe” implemented realignment, most of the “maybe” realignment land left after constraints are accommodated for and buffered will likely be consumed with these parking spaces and parking drive aisles/buffer area needed to separate high-speed vehicular traffic from parking, a buffered bike path, and a sufficiently wide pedestrian sidewalk or Coastal Path. After accommodating these much needed Complete Street facilitates there will likely be little if any sufficiently dimensioned land available for a Coastal Recreation and a Coastal Park. The needed Coastal Access and Complete Street facilities on South Carlsbad Boulevard are very much needed, but they are NOT a Coastal Park. Page 25 of 26 As mentioned the proposed Draft Coastal Land Use Plan’s Maps and Policies are very specific in providing for the City’s proposed LCP Land Use changes to ‘low-priority” Residential and General Commercial’ on Planning Area F (proposed to be renamed to Area 1 and 2). It is curious as to why the proposed Draft LCP Land Use Plan Amendment has no Land Use Map and minor vague unaccountable Land Use Policy concerning ‘High-priority Coastal Recreation Land Use’ at Ponto, while the very same time proposing very clear Land Use Mapping and detailed unambiguous “shall” land use policy requirements for ‘low-priority” Residential and General Commercial land use at Ponto. Why is the City Not committing and requiring (in a Land Use Map and Land Use Policy) to much needed ‘High-priority” Coastal Recreation and Coastal Park Land Use’ needs at Ponto the same detail and commitment as the City is providing for “low-priority” uses? This is backwards and inappropriate. It is all the more inappropriate given the ‘Buildout’ Coastal Land Use Plan the City is proposing at Ponto. These issues and plan/policy commitments and non-commitments will be ‘forever’ and should be fully and publicly evaluated as previously requested, or the Exiting LCP Land Use Plan of “Non-residential Reserve” for Planning Area F should remain unchanged and until the forever-buildout Coastal Recreation and Coastal Park issues can be clearly, honestly and properly considered and accountably planned for. This is vitally important and seems to speak to the very heart of the CA Coastal Act, its founding and enduring principles, and its policies to maximize Coastal Recreation. People for Ponto and we believe many others, when they are aware of the issues, think the City and CA Coastal Commission should be taking a long- term perspective and be more careful, thorough, thoughtful, inclusive, and in the considerations of the City’s proposal/request to permanently convert the last vacant unplanned (Non-residential Reserve) Coastal land at Ponto to “low-priority” land uses and forever eliminate any Coastal Recreation and Coastal Park opportunities. 13. Public Coastal View protection: Avenida Encinas is the only inland public access road and pedestrian sidewalk to access the Coast at Ponto for one mile in each direction north and south. It is also hosts the regional Coastal Rail Trail in 3’ wide bike lanes. There exist now phenomenal coastal ocean views for the public along Avenida Encinas from the rail corridor bridge to Carlsbad Boulevard. It is assumed these existing expansive public views to the ocean will be mostly eliminated with any building development seaward or the Rail corridor. This is understandable, but an accountable (‘shall”) Land Use Plan/Policy addition to proposed Policy LCP-2-P.20 should be provided for a reasonable Public Coastal View corridor along both sides of Avenida Encinas and at the intersection with Carlsbad Boulevard. Public Coastal view analysis, building height-setback standards along Avenida Encinas, and building placement and site design and landscaping criteria in policy LCP-2-P.20 could also considered to reasonably provide for some residual public coastal view preservation. 14. Illogical landscape setback reductions proposed along Carlsbad Boulevard, and Undefined landscape setback along the Lagoon Bluff Top and rail corridor in Policy LCP-2-P.20: Logically setbacks are used in planning to provide a buffering separation of incompatible land uses/activities/habitats. The intent of the setback separation being to protect adjacent uses/activities/habitats from incompatibility, nuisance or harassment by providing a sufficient distance/area (i.e. setback) between uses/activities/habitats and for required urban design aesthetics – almost always a buffering landscaping. Policy LCP-2-P.20. A.4 and C.3 says the required 40’ landscape setback along Carlsbad Boulevard “maybe reduced due to site constraints or protection of environmental resources.” The ability to reduce the setback is illogical in that setbacks are intendent to protect environmental resources and provide a buffer for constraints. In the Carlsbad Boulevard right-of-way there is documented sensitive environmental habitat, along with being a busy roadway. How could reducing the protective 40’ setback in anyway better protect that habitat or provide a better landscaped compatibility or visual aesthesis buffer along Carlsbad Boulevard? It is illogical. If anything the minimum 40’ landscaped setback should likely be expanded near “environmental resources”. Regarding reducing the minimum 40’ landscape setback for “site constraints” there is no definition of what a “site constraint” is or why it (whatever it may be) justifies a reduction of the minimum landscaped setback. Page 26 of 26 Is endangered species habitat, or a hazardous geologic feature, or a slope, or on-site infrastructure considered a “site constraint”? There should be some explanation of what a “site constraint” is and is not, and once defined if it warrants a landscape setback reduction to enhance the buffering purpose of a landscape setback. Or will a reduction only allow bringing the defined constraint closer to the adjacent uses/activities/habitats that the landscape setback is designed to buffer. It is good planning practice to not only be clear in the use of terms; but also, if a proposed reduction in a minimum standard is allowed, to define reasonably clear criteria for that reduction/modification and provide appropriate defined mitigation to assume the intended performance objectives of the minimum landscape setback are achieved. Policy LCP-2-P.20.C.4 is missing a critical Bluff-Top landscape setback. It seems impossible that the DLCPA is proposing no Bluff-Top setback from the lagoon bluffs and sensitive habitat. The Batiquitos Lagoon’s adjoining steep sensitive habitat slopes directly connect along the Bluff-top. Batiquitos Lagoon’s and adjoining steep sensitive habitat is a sensitive habitat that requires significant setbacks as a buffer from development impacts. Setbacks similar to those required for the San Pacifico area inland of the rail corridor, should be provided unless updated information about habitat sensitivity or community aesthetics requires different setback requirements. Policy LCP-2-P.20 does not include a landscape setback standard adjacent to the rail corridor. This is a significant national transportation corridor, part of the 2nd busiest rail corridor in the USA. Train travel along this corridor is planned to increase greatly in the years to come. Now there is significant noise, Diesel engine pollution, and extensive ground vibration due to train travel along the rail corridor. Long freight trains which currently run mostly at night and weekends are particularly noisy and heavy, and create significant ground vibration (underground noise). These issues are best mitigated by landscape setbacks and other buffers/barriers. A minimum setback standard for sufficient landscaping for a visual buffer and also factoring appropriate noise and ground vibration standards for a buildout situation should be used to establish an appropriate landscape setback that should be provided along the rail corridor. Carlsbad’s landscape aesthetics along the rail corridor should be factored into how wide the setback should be and how landscaping should be provided. An example for the landscape aesthetic portion of the setback standard could be landscape design dimensions of the San Pacifico community on the inland side of the rail corridor. However, noise and vibrational impacts at San Pacifico are felt much further inland and appear to justify increased setbacks for those impacts. From:Lance Schulte To:Growth Management Committee; Michele Hardy; Council Internet Email; City Clerk; Kyle Lancaster; Eric Lardy; "Smith, Darren@Parks"; Homer, Sean@Parks; "Moran, Gina@Parks"; Boyle, Carrie@Coastal; "Prahler, Erin@Coastal"; Ross,Toni@Coastal Cc:info@peopleforponto.com Subject:public input on Carlsbad Parkland Dedication Ordinance and City losses Date:Sunday, September 11, 2022 11:38:53 AM Attachments:image013.pngimage014.pngimage015.pngimage016.pngimage017.emzimage018.pngimage019.pngimage020.pngimage021.pngimage022.pngExample of Carlsbad Parkland Dedication Ordinace - Ponto Site 18 - 2022 Sep.pdf Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks, Housing and Planning Commissions, , CA Coastal Commission and CA State Parks: Please consider this data file and public input email/attachment in the CTGMC, Housing Element and Parks Master Plan Updates, Proposed Local Coastal Program Amendment, and the Ponto Site 18 proposed land use changes and development application. ‘Example of Carlsbad’s Park-in-lieu Fee failing to actually provide the required Parkland or improvements The example is for Ponto Site 18 one of the City’s proposed General Plan & Local Coastal Program land use changes to provide RHNA required housing sites for the years 2021-2029. Ponto Site 18 is the Ponto Storage site and surrounding lots. Ponto Site 18’s map and City description is provided on pages 4-5 below. The example shows Carlsbad loses significant amounts of money, and more critically loses precious and irreplaceable Parkland that developers are required to provide for free. These City loses are absorbed by current and future Carlsbad tax-payers. For the relatively small 5 acre and 86 dwelling unit Ponto Site 18 proposal the loss to Carlsbad is $ 1.084 million in lost parkland value. Below is the spreadsheet calculation of that loss. Beyond showing a typical over $ 1 million loss per 86 dwellings, there is added concern for the CTGMC in that this example is a proposed Carlsbad General Plan & Local Coastal Program Land Use Change to try to accommodate the years 2021-2029 the RHNA requirement to add/increase Residential use. Every 8 years we are/will be changing our General Plan land use to add more high-density housing and increasing City Park demand particularly for areas developed more densely. If these higher-density projects do not dedicate actual City Park within walking distance not only is Carlsbad loosing over $1 million per 86 dwellings, we are losing free and easy opportunities to get City Parkland dedicated for free per CMC 20.44, and will slowly be degrading our Quality of Life in these areas and also Citywide. Calculation of Ponto Site 18 Parkland dedication requirement and City losses from the Park-in-lieu Fee: Following this calculation: · on page 3-4 are the relevant excerpts of Carlsbad’s Dedication of Land for Recreational Purposes Ordinance 20.44, and · on page 5-6 is the City’s map and description of the proposed Ponto Site 18 land use change Ponto 5lte 18-Fenton proposed d!!V!! lop me nt's Park 1.3111d dedication re qui rernent 47% of tntal 44% of tmal 10J% Sp Opt>:-€ SpliD?tt_:J? Sp iD0-!6E /MJ aru/fact/ta ble/ $ba Fenton Is pmposlng91%ofthe proJe.ct wlth 3or4 be.drool"\"Ssothe pmJe.ctw lll ha ,e Mgher oc,cupanr:y. and li kely mo re children. per housing unit than the Cityw ide "1/erage of 2. fi<U>eo _J)le er housing unit .:ak all X X 3a___ : o.~l!2. aues of Park la r,d re qui red tor Fe nton's prop0$ed 86 DU p roje,ct ba$!?d on citywide a,,rerage populatlo n per DU X ~ ifil _ J,::' f e~:-t J)-:'l .3!f,::' 29,670 sq1mefeet of Parklaoo required for Fenton's proposed86DU proje,ct ba-$!!don Citywide average pop ulation per DU l a<:reof Fe.nton's un~vac:ant 'Ice plant lots' betw""n PCH ,&. Ponto Drlvett'31 can provide Fenton's Park lar>d requirement ~ :!'.:-'&F.<95 p:1 otyr'1ast,;;, Fe1= s : . e. coraJst,;;,,I\ et ~e F,s;; fortl"o:,;,Jr !;SDU·pro)ert ~ ;,:i Es ..ate s F mst fe'r,to ::,a d fo1 Po ,to s S !.4!!::!,4B ((',OSI ,:,f 29,6;,J SF of Por, <> S e LB la t'-l: for tL Po to s e LB ;...ar('re ;;,5 w.e ~ tla sr,t proposal : S ( J.IJl4,,783j Dollars the city Is looslr1g In P<Yk land val ueand not recelvlr1g In Its Park-In-lieu Fee, so this Isa gift to the deue loper -73% %of lost Parle laoovalueclty lslooslngaoo not receiving In ltsPIL Fee, so ililslsacltyglft tothted!!V!!loper ~ !.COJ,OJJ pEJ ar,re, (Dsl t,o ;;ve-l pa Pa• I e 6 ,;, • Vista Re0e<NO Pa! 4.3,SW .-re f1:,::t p:-ir atre s 22..95 C-ost oe,·· .. ft. 2.9,6;,J _ r,;;,f.,;;,;,tof Par Da _ to F..;r. ,o a• propose · 65 DUp oJmbas_ s 6!!1.131 cost to develop Fenton's 29,filllsq. ft. of Parle LaBd D'!dlcatlonasa Park S (282.4.!ilj Dollars Cltyloosesf rom Park-In-lieu Fees not even bell'lgadequate to cover Actual M inimal Park Development Costs https:ljl ibrar,,,.qcode.us/1 ib/carlsbad ca/pub/municip al code/it em/title 20-ch apt er 20 44 20.44 Dedication of Land for Recreational Faciliites 20M.01:0 Pu rpose. This chapter is e nacted pursuantto the authori ty granted by Se ction 66477 of the Government Code o the St at e of California. The park and recreation al faci I ities forwhi ch dedicat ion of I and and/or payme nt of a ee is re qui red by this chapter are in accordance w i,th the recreat ional e le me nt of the general pl an of the City o Carlsbad. (Ord. 9614 § 1, 1982; Ord. 9190 § 2) 20.44.,Q40 St andards and formu la for dedication of I and. If the decision-making authority for the t entat ive map or te ntative parcel map det e rmines that a park or recreational facility is t o be locat ed in who le or in part within the proposed subdivision t o serve the immediate and fut ure needs of the residents of the subdivision, the subdivider shall, at the time of the fil ing of the final or parcel map, dedicate land for such fa ci lity pursuant t o the follo wing standards and formula: The ormul a · or determining acreage to be de di catecl shal I be as ol I ows: Average no. o persons per dwel Ii ng unit (based on most recent e cleral census) X 3 park acres per 1,000 populat ion X Total numbe r o clw el Ii ng un it s The total numbe r of clw el Ii ng units shal I be the numbe r permitte d by the city on the property in the subcl ivi sion atthe t i me the final map or parcel map is fi l eel for approva l, less any existing residential units in single-famil ydet ached or duplex dwe lli r,gs. The park land de d ication requirement w ill be revi ew ed annua lly effective July 1, and adjuste d as necessary by resolution of the city council to refl ect the I at est fe deral census dat a. (Orel. CS-192 § 49, 2012; Ord. CS-162 § 1, 2'011; Ord. S-757 §1, 2'005; Ord . . 5-588 § 1, 2001; Ord. 9831 § 1. 1987; Orel. 9770 § 11985; Ord. 9724 § 1, 1984; Ord . 9644 § 1. 1982; Orel. 20.44.050St anclarcl s for fees in I ieu of I and clecl i cation. A. If the decision-making authority fo r t he te ntative map or te ntative parcel map dete rmines that there is no park or recreat ional faci lity t o be locat ed in who le o r in part within t he proposed subdivision, the subdivider shall, in lieu of dedicating land, pay a fee equal to the value of the land prescribed for dedication in Section 20.44.040 and in an amount det ermined in accordance with the provisions of Section 20.44.080. B. If the proposed subclivi si on cont ains 50 parcels or less, only the payment o fees sh al I be re qui red exceptthat whe n a condominium project, st ock cooperat ive, or co mmunity apartment project exceeds 50 clwel Ii ng unit s, cl edicati o n of I and may be requi reel notwithstancli r,g thatthe number of parcels may be I ess than 50. 2'0M.060 Det ermination o I and or fee. A. Whethe r the decision-making authority fo r the te ntative map or te ntative parcel map requires land dedicati on or elects to accept payment of a fee in lieu the reof, or a combinat ion of bot h, shall be determ ined by the deci sion-making authority at the time of approval of t he te ntative map orte ntative parcel ma p. In making that det erminatio n, t he decision-making authority shall m nsider the foll owing: 1 Park and recreation eleme nt of the general pl an; 2 Topography, geology, access and location of land in the subdivi sion avail able for de dicat ion; 3 Size and shape o the subdivision and land avai I able for dedicatio n; 4 The feasi bi I ity of cle cli cat ion; 5 Avail abi I ity o previously acqui red park property. B. The det e rm ination oft he city counci I as to whether I and sh al I be dedicated, or whe the r a fee sh al I be charged, or a com bi natio n the reo , shal I be final and co nclusive. (Ord . CS-192 § 49, 2012; Ord. 9614 § 1, 1982; Orel . 9190 § 6) 2D.44.080Amount offee in Ii eu o I and cleclicat i on. A. Wh en a fee is required to be paid in li eu of land dedication, the amount of the fee shall be based upon the fair marketvalue of the amou nt of land which would otherwise be required t o be dedicat ed pursuant t o Section 20.44.040. lhe fair market value shall be dete rmined by the city council usingthe foll owing method: 1 The ci ty manager may from ti me t o t i me survey the market value of unclevel oped property w ithin the city. This survey may be prepare d through vari ous means incl ucli ng, but not Ii mite cl to, selection of several real estat e pro essional s w ithin Ca rl sbacl to provide current est imates of undeve loped property values with each oft he city's four quadrants. 2 The cound I shall adopt a resolution establi shing the value of one acre of park I ancl in each quadrant after consi de ri ngthe results o this survey and any other relevant informat ion. B. Subclivi cl ers obje cti ngto such valuat ion, may, atthei r own expe nse, obtain an appraisa l of the property by a qual ifi e el real estat e appraiser approved by the city, which apprais al may be accepted by the city counci I if found to be reasonable. If accepted, the fee shal I be based on that appraisal. (Orel. 5-lf0 § 1, 1990; Ord. 9831§ 1, 1987; Ord. 9781 § 1, 1985; Orel . 9614 § 1, 1982; 0 rd. 919::l § 8) 2,0.44.090 Lim itation on use of I and and fees. The I and and ees receive d under this chapter shal I be used for the purpose of clevelopi ng new or re habi I itati ng exi sti t1g park and recreation al faci I iti es which serve the populat ion within the park quadrant within which the subclivi si on for which th e fees are received is I ocat ecl and the I ocati on of the I and and amount offees shal I bear a reasonable relationship to the use of the park and recreation al faci I iti es by the future inhabitants ofthe subdivision. (Ord. S,-842 § 1, 2007; Ord. 9680 § 12, 1983; Orel . 9190 §11) 2,0.44.:W0Ti me of commencement of faci I ities. l he city council shall develop a schedule specifying how, when and where it will use the land orfees or both to develop park orrecreat ional fa cilit ies to serve the residents of the park quadrant in which the subdivisions are located. Any fees co llected pursuant t o this chapte r shall be co mmitted within five years after the payment of such fees or the iss uance of building permits on one-half of the lot s created by the subdivision, which eve r occurs lat er. POTENTIAL HOUSING SITES Si e Number: 18-North ·Ponto Parcel§: SITE DESCFUPTIO 1ght vaca 11t and undl!ru l,zl!!d PIDp!!ftil!s In t Pon11:i• are , •locatl!d sou o I! Cap Aey C.ul,.sbad S ach ho1_e1 nd e. st or Carlibad Baul· rd 1h il!e ~ , !K'c:ti!d b Ponlo Ori • 'orth of Ponto DriY ne 1hr u111:k!rutllil:ed pi!rC !Ii conralnl ii mini ~tor , misceilaneo~s bu l'dJ!ijjS 11d 1111\er-srorage u~ an nearfy ¥ -!01:lth, ;icro,-s Po11t0 DrlW!:, iS ii cluster of e 1ma!I' v~cant p,ro l'l "1 tot l ]\ISi over an .nrl!-, Slur topo8J !ilhV ks IN'leor.,i"" fl e p lrHJd due 10 envlronm nrally ru.ltive h-abi r road oomdor-All th!! pa rce~ a re loc.a,td ou rd n t path. Th@ 5 ti! does !21 fndude a 11acanl ll•~Cfl! rcl!I Ion I! 111!1' !id or Porno Drlw ancl front nc AV1!11 d~ EnciM1. ihe p ~ wPI nni 1uea F," 5ITE FEAfU ES • V c.inl/undffllti l d -Ut!I -s C(l!Uibl • In he C'l»5tal Zone 1sts or a m off cl~tk.il nd 1101"1--rl!'.51 . nd ll!i-1! d S!ll,n till t J:lllrtc!II hil\11! II spl I lflill 011 o VC I 11, or Commern I) a.nd R-15 (11.5 to 15 dwelltng un •/.ct, The one pilrtel ra,lroadcorriclor 11fflia11 ,~ IHS-lhe IHS ~an;Jlion oft nap single f mm, or anached co11dorni11 urn d~ lop nt. r of fhre vaca11t p.i o Ori¥1l k d~n ted I Comrne nil Commeid I per d ran cf commerc111I uses. 1,1 lw perm -p opm' to de,;;elo~d in a mi I, with /jmlted re< bo~l! l1u-t Door romrnerd~I. S ff l'las fN:l!I\I cl a ttt from Ol"N!-?f(Y,pe!l'ty ownN e,tpflill ng Uipport fM 1'1111)'1 r dl!M!ly, El cepl fer 1h11 VC-tJei1!1J1t1led p11r11on o -th Is, wh[d, ili cfp;i a p.Jrtei$ to ~-l3 h i;o J/1~-ft-ll ii a res! d~lg11;1r 0<1 id bf ~~nolds-. 111 R·l 1111 11cw1,10\J!cl pe ~i y rl!nl!l! l d ~Hyp cal of l'lillJOn o atl 1!1"1tt' ll(OQ'II! i!C). lh~ .· 115' loc~n-e a11y des,t nation, ;1me,nf!m-11u to lie Ge,,,:ra,I Pl.ln1 l.oc.il c.outi'II Pl'O!lralll. ror, 1111., F'olnserii.i 5hor i ~ er Pla11i ,11111:l lhl! Ponto ~achrront Vllla,111! Y™on Pl n wouTd t,e required. Th mMdm nLs w01.1ld ulro Ol Counc:11 ;md C.fi om1.i ~st I Commlsiiori ilPPfll'lill. Please consider this email and attachments, and know P4P Carlsbad Citizens are here to help assure we sustain and enhance our quality of life for future generations. People for Ponto love deeply Carlsbad and want to assure we leave a better Carlsbad to future generations. Sincerely and with Aloha Aina, Lance Schulte CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. POTENTIAL HOUSING SITES Sit · Numb · r: 1.8-North Ponto Parcels ~Genlral ........... Cllttanlllllilldanllll Oppodunlty Income mtlllV'Y of unlls(baled on minimum Zl&OlD-01, 16-010-02. 216-01 D-03. ~ 16-0l0-lli1, 216-010-0S, 214-100-25, 2!4-160-2B. 214-171 • 1 A·lS !Rei. 11t1 1 a-is diJ/ c), VC IV or Commer~ 1)/R, 5, GC tG@n~ra11 CornllU!rtl IJ l\pl)ru·"' ly .s,.m b lba,ecl Of! the 1&liiog R-15 di!i gnalk)ri and !1m 11d 11!,S clmllal p rm fl don GC 111aled pr0,x-r1 e,sJ GMP Quadnnl Pwa!SIN itv of -.. .......... 6 d Soul Wffi •-nie-YC det!gllatio11, ~fdl applks ro two propt!rllt:s, Is not anr,c)poc d' Lo ,llon a/Id wr:illld remt:1ifl "' lll SOffll! f«dr/o,i, APPfO lmati!fy 90 uniu [.i 1 du/ ct• •fllo .-,~rrJ is dct~rrlllnnlfrom por-tfOIIJ of propttt.y dnl!JflOftd \IC, Page 1 of 5 Example of Carlsbad’s Park-in-lieu Fee failing to actually provide the required Parkland or improvements The example is for Ponto Site 18 one of the City’s proposed General Plan & Local Coastal Program land use changes to provide RHNA required housing sites for the years 2021-2029. Ponto Site 18 is the Ponto Storage site and surrounding lots. Ponto Site 18’s map and City description is provided on pages 4-5 below. The example shows Carlsbad loses significant amounts of money, and more critically loses precious and irreplaceable Parkland that developers are required to provide for free. These City loses are absorbed by current and future Carlsbad tax-payers. For the relatively small 5 acre and 86 dwelling unit Ponto Site 18 proposal the loss to Carlsbad is $ 1.084 million in lost parkland value. Below is the spreadsheet calculation of that loss. Beyond showing a typical over $ 1 million loss per 86 dwellings, there is added concern for the CTGMC in that this example is a proposed Carlsbad General Plan & Local Coastal Program Land Use Change to try to accommodate the years 2021-2029 the RHNA requirement to add/increase Residential use. Every 8 years we are/will be changing our General Plan land use to add more high-density housing and increasing City Park demand particularly for areas developed more densely. If these higher-density projects do not dedicate actual City Park within walking distance not only is Carlsbad loosing over $1 million per 86 dwellings, we are losing free and easy opportunities to get City Parkland dedicated for free per CMC 20.44, and will slowly be degrading our Quality of Life in these areas and also Citywide. Page 2 of 5 Calculation of Ponto Site 18 Parkland dedication requirement and City losses from the Park-in-lieu Fee: Following this calculation: on page 3-4 are the relevant excerpts of Carlsbad’s Dedication of Land for Recreational Purposes Ordinance 20.44, and on page 5-6 is the City’s map and description of the proposed Ponto Site 18 land use change Ponto Site 18 - Fenton proposed development's Park land dedication requirement Park land dedication requirement per CMC 20.44 https://library.qcode.us/lib/carlsbad_ca/pub/municipal_code/item/title_20-chapter_20_44 US Census data https://www.census.gov/quickfacts/fact/table/carlsbadcitycalifornia/POP060210#POP060210 Carlsbad Park Dedication Requirement is 3 acres of land per 1,000 population of the proposed development. Population of proposed development is based on population per household based on latest US Census data 2020 US Census data is 2.64 people per household FYI, Carlsbad 3 acres /1,000 is comparatively very low both locally and nationally. And there is no 'walkably requirement'. 5 acres /1,000 population is what Encinitas and Oceanside require along with a 10-minute walk location requirement. Fenton owns almost 6 acres of land in Site 18, 4.64 acres of which they want to develop now, and the other 1+ acre part they want to develop later. 8 2-bedroom homes =9%of total units proposed 40 3-bedroom homes =47%of total units proposed 38 4-bedroom homes =44%of total units proposed 86 100% Fenton Park land dedication requirement per CMC 20.44 calculation 86 DU of Fenton proposed development X 2.64 average population per DU per 2020 US Census =227 estimated population of Fenton project / 1,000 population that needs 3 acers of Park land per CMC 20.44 =0.22704 percentage of 3 acres of Park land required for 227 people X 3 acres of Park land required per 1,000 people =0.68112 acres of Park land required for Fenton's proposed 86 DU project based on Citywide average population per DU X 43,560 square feet per acre =29,670 square feet of Park land required for Fenton's proposed 86 DU project based on Citywide average population per DU 1 acre of Fenton's unused vacant 'ice plant lots' between PCH & Ponto Drive that can provide Fenton's Park land requirement 398,696$ per City Master Fee Schedule. Consistent with what Fenton said was would be the 'Park-in-lieu Fee for their 86 DU project 50$ Estimated SF cost Fenton paid for Ponto Site 18 or $ 2.18 million per acre 1,483,479$ cost of 29,670 SF of Ponto Site 18 land to satisfy Fenton's Park land requirement for the Ponto Site 18 5-acre 86 dweling unit land use cahnge and development proposal: (1,084,783)$ Dollars the City is loosing in Park land value and not receiving in its Park-in-lieu Fee, so this is a gift to the developer -73% % of lost Park land value City is loosing and not receiving in its PIL Fee, so this is a City gift to the developer 1,000,000$ per acre cost to develop a Park like Buena Vista Reservoir Park 43,560 square feet per acre 22.96$ Cost per sq. ft. 29,670 square feet of Park land required for Fenton's proposed 86 DU project based on Citywide average population per DU 681,120$ Cost to develop Fenton's 29,670 sq. ft. of Park Land Dedication as a Park (282,424)$ Dollars City looses from Park-in-lieu Fees not even being adequate to cover Actual Minimal Park Development Costs on the 4.64 acre site change VC-Visitor Commercial/R-15 (15 dwellings per acre) General Plan land use and Zoning to 100% residential and develop at 19.125 dwellings per acre on 4.64 acres. On the 1+ acre site, instead of providing their required Park land dedication, Fenton is proposing to develop the remaining 1 acre area (between PCH & Ponto Drive) as General Commercial. Instead of providing the required Park Land dedication, Fenton is proposing to develop the remaining 1 acre area (between Pecha and Ponto Drive) as General Commercial. Site 18 (Fenton) development proposal for the 4.64 acre portion is development of 86 household units (over 19 dwelling units per acre in in higher occupancy units than typical) consisting of: Fenton is proposing 91% of the project with 3 or 4 bedrooms so the project will have higher occupancy, and likely more children, per housing unit than the Citywide average of 2.64 people per housing unit Page 3 of 5 https://library.qcode.us/lib/carlsbad_ca/pub/municipal_code/item/title_20-chapter_20_44 20.44 Dedication of Land for Recreational Faciliites 20.44.010 Purpose. 20.44.040 Standards and formula for dedication of land. The formula for determining acreage to be dedicated shall be as follows: Average no. of persons per dwelling unit (based on most recent federal census) × 3 park acres per 1,000 population × Total number of dwelling units 20.44.050 Standards for fees in lieu of land dedication. A. B. 20.44.060 Determination of land or fee. A. 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. 20.44.080 Amount of fee in lieu of land dedication. A. 1 2 B. 20.44.090 Limitation on use of land and fees. 20.44.100 Time of commencement of facilities. The city council shall develop a schedule specifying how, when and where it will use the land or fees or both to develop park or recreational facilities to serve the residents of the park quadrant in which the subdivisions are located. Any fees collected pursuant to this chapter shall be committed within five years after the payment of such fees or the issuance of building permits on one-half of the lots created by the subdivision, whichever occurs later. 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) 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: 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. 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. 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) 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) This chapter is enacted pursuant to the authority granted by Section 66477 of the Government Code of the State of California. The park and recreational facilities for which dedication of land and/or payment of a fee is required by this chapter are in accordance with the recreational element of the general plan of the City of Carlsbad. (Ord. 9614 § 1, 1982; Ord. 9190 § 2) If the decision-making authority for the tentative map or tentative parcel map determines that a park or recreational facility is to be located in whole or in part within the proposed subdivision to serve the immediate and future needs of the residents of the subdivision, the subdivider shall, at the time of the filing of the final or parcel map, dedicate land for such facility pursuant to the following standards and formula: The total number of dwelling units shall be the number permitted by the city on the property in the subdivision at the time the final map or parcel map is filed for approval, less any existing residential units in single-family detached or duplex dwellings. The park land dedication requirement will be reviewed annually effective July 1, and adjusted as necessary by resolution of the city council to reflect the latest federal census data. (Ord. CS-192 § 49, 2012; Ord. CS-162 § 1, 2011; Ord. NS-757 § 1, 2005; Ord. NS-588 § 1, 2001; Ord. 9831 § 1, 1987; Ord. 9770 § 1, 1985; Ord. 9724 § 1, 1984; Ord. 9644 § 1, 1982; Ord. If the decision-making authority for the tentative map or tentative parcel map determines that there is no park or recreational facility to be located in whole or in part within the proposed subdivision, the subdivider shall, in lieu of dedicating land, pay a fee equal to the value of the land prescribed for dedication in Section 20.44.040 and in an amount determined in accordance with the provisions of Section 20.44.080. If the proposed subdivision contains 50 parcels or less, only the payment of fees shall be required except that when a condominium project, stock cooperative, or community apartment project exceeds 50 dwelling units, dedication of land may be required notwithstanding that the number of parcels may be less than 50. 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: Page 4 of 5 Upper area proposed for land use change & higher density Part of Lower area can (should) be dedicated to provided needed parkland POTENTIAL HOUSING SITES Site Number: 18 -North Ponto Parcels SITE OESCRIPTlON The site is a group of eight vacant and underutilized properties in the Ponto area, located south of the Cape Rey Carlsbad Beach hotel and east of Carlsbad Boulevard, The site Is bisected by Ponto Drive, North of Ponto Drive are three underutilized parcels containing a mini storage, miscellaneous buildings and other storage uses on nearly five acres. To the south, across Ponto Drive, ls a cluster of five small vacant properties total Just over an acre. Site topography Is generally flat. Some of the parcels may be constrained due to environmentally sensitive habitat. One parcel is alongside the railroad corridor. All the parcels are located outside the McClellan-Palomar Airport flight path. The site does !1Q! include a vacant 11-acre parcel along either side of Ponto Drive and fronting Avenida Encinas. The parcel is commonly referred to as "Planning Area F." SITE FEATURES • Vacant/underutilized • Utilities accessible • In the Coastal Zone • Site constraints SITE OPPORTUNITY ( City of Carlsbad The site consists of a mix of residential and non-residential land use designations. Two of the eight parcels have a split land use designation of VC (Visitor Commercial) and R-15 (11.S to 15 dwelling units per acre, or du/ac). The one parcel alongside the railroad corridor is designated R-15. The R-15 designation often applies to small lot single family or detached or attached condominium development. The cluster of five vacant parcels south of Ponto Drive Is designated Ge (General Commercial). General Commercial permits a broad range of commercial uses. It also permits properties to be developed in a mixed-use format, with limited residential above first floor commercial. Staff has received a letter from one property owner expressing support for higher density. Except for the VC•deslgnated portion of the two parcels, which is not anticipated to change, the redesignation of all parcels to R-23 ls contemplated. R-23 is a residential designation the state Identifies as suitable for moderate income households. The R-23 designation would permit a density range of 19 to 23 dwelling units per acre (du/ac). This density is typical of two-and three-story apartment and condominium developments. To change any designation, amendments to the General Plan, local Coastal Program, zoning, Poinsettia Shores Master Plan, and the Ponto Beachfront Village Vision Plan would be required. These amendments would require City Council and California Coastal Commission approval. Page 5 of 5 POTENTIAL HOUSING SITES Site Number: 18 -North Ponto Parcels 216-010-01, 216-010-02, Parah Numbers 216-010-03, 216-010-04, 216-010-05, 214-160-25, 214-160-28, 214-171-11 Dwnenhlp Private (separate ownershfp) R-15 (Resfdential 8-15 du/ac), CUnent General Plan VC (Visitor Commercfal)/R· Deslpallons 15, GC (General Commercial) Approximately 44 units CUmnt Ralclentlal (based on the existing R-15 designation and limited Oppom,nlty residential permitted on GC-designated properties) Income catesorv of units (baled Moderate on minimum clensltv) GMP Quadrant Parc:al 5128 Proposed Ganeral Plan Dulplatlon Proposed Residential Opportunity Southwest t_City of Carlsbad Approximately 6 acres (all --,\ R-23 (Residential, 19 to 23 du/ac)• *The VC designation, which applies to two properties, Is not antic/pated to change and would remain In the some location. Approximately 90 units (at 19 du/ac)• "No yield is determined from portions of property designated vc. From:Lance Schulte To:Growth Management Committee; Michele Hardy; Council Internet Email; City Clerk; Kyle Lancaster; Eric Lardy;"Smith, Darren@Parks"; Homer, Sean@Parks; "Moran, Gina@Parks"; Boyle, Carrie@Coastal; "Prahler,Erin@Coastal"; Ross, Toni@Coastal Cc:info@peopleforponto.com Subject:public input on proper recording and consideration of July Public input to Carlsbad Tomorrow GrowthManagement Committee - General Plan Land Use Plan Imbalance - Parks & Traffic Date:Sunday, September 11, 2022 7:58:42 AM Attachments:image003.pngSan Diego County cities lose affordable housing lawsuit cbs8.com.pdf Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks, Housing and Planning Commissions, , CA Coastal Commission and CA State Parks: I was unable to attend the August meeting, but found my public input at the July meeting was not fully reflected/recorded in the minutes. I would like to request that my public comments submitted in July as evidenced on https://carlsbadca.new.swagit.com/videos/178280 at 4:40 to 7:43 be more properly and accurately documented. I also, saw in the August meeting what appeared to be the staff response to my July comments on the General Plan land use plan imbalances. But Staff ONLY replied to the Jobs/Housing Imbalance and did not include the Parks/Housing Imbalance that has been a critical concerns to may Carlsbad Citizens. Carlsbad’s General Plan Land Use Element page 2-23 specifically discusses Job/Housing Balance. This should be reviewed and compared with Staff’s August presentation to the CTGMC. The Park/Housing Imbalance that I mentioned in July is clearly seen in the following Park Service Area Map from the City’s Park Master Plan and in the US Census data that show Ponto and South Carlsbad currently developed at much higher densities that the Citywide average. Both these facts were presented to the City and CCC several times before, but appear to being ignored by in the City’s consideration of the issues and public citizen input. See: Coastal Recreation data file Housing density Imbalance – more housing density at Ponto and in South Carlsbad. No Parks in Ponto and large areas mapped UNSERVED by Parks in South Carlsbad : % of % of Population Population Council ZIP Square City’s City Density Density relative to District Quad Code Miles SM population Pop. (pop/SM) Citywide average 1,2 NW 92008 11 28% 27,429 24% 2,494 84% 2,1 NE 92010 8 21% 16,565 14% 2,071 70% 3,4,2 SW 92011 7 18% 24,405 21% 3,486 118% 4,3,2 SE 92009 13 33% 47,003 41% 3,616 122% City total = 39 100% 115,401 100% 2,959 100% Ponto = 0.397 1,632 4,111 139% See: 9/27/2021 email resent to City and to you on 9/11/2022 The City and US Census data is very clear, and is the point we People for Ponto Carlsbad Citizens are trying to make to you that Carlsbad’s General Plan is unfairly Imbalanced with regard to Park/Housing distribution. This Park/Housing Imbalance will harm Carlsbad in many ways if not corrected. It is also Imbalanced in Jobs/Housing. o Coasta1 Par 11n So th Cairlsbad p 6 · iles o ,Co1ast · hout a coas; al Par is a Cii · RegionaI1 need • Sou h Carlsbad has 6 .000 residen s , ousands of hotel . · sitors . , oul a Coas alpalik • CEosestparkto Ponto is Poinse ·a :Par ' appro 2.5 miles across 1- Proposed Veterans Par is appro 6 m·1es a .a --------- I also stated the fact that the concept of Carlsbad “Buildout” is a fallacy as every 8-years Carlsbad receives a new requirement to change the General Plan/Local Coastal Plan add more residential land use. See the attached article about existing ‘built-out’ cities in SD County that are being required to significantly add new residential land use to their existing ‘built-out’ cities. The article points to where Carlsbad is will be in 2029. How the CTGMC assures the City will ADD new Parkland to fix the current Park/Housing Imbalance, and add new parks (due to conversion of developed land to Parks like what was done at Pine Park) for new Housing is a critical Quality of Life issue for current and future generations of Carlsbad Citizens and their families. Our future housing develop will be higher-density that does not have backyards and significant grassy open space to play. Carlsbad’s City Parks will provide the open significant open green play and recreation places. Carlsbad’s Parks need to be fairly distributed so they are within walking distance to all current and future residents. I will send you a important Data File on Carlsbad’s Parkland Dedication Ordinance that is an important means for new develop to provide their required Parkland if properly administrated. I will also send you an important Draft Data File on relative VMT and logically appears to show how Carlsbad’s Park/Housing Imbalance increases Carlsbad’s VMT relative to the region. Please know your fellow People for Ponto Citizens deeply care for Carlsbad and want to maintain and enhance Carlsbad’s Quality of Life. We hope you care, will listen to the facts and desires we present you, and will work address the clear and time sensitive need for Ponto Park. Sincerely and with Aloha Alina for Carlsbad, Lance From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Monday, August 8, 2022 10:07 AMTo: committee@carlsbadca.gov; 'Michele Hardy'; 'council@carlsbadca.gov'; 'City Clerk'; 'Kyle Lancaster';'Eric Lardy'; 'Smith, Darren@Parks'; Homer, Sean@Parks (Sean.Homer@parks.ca.gov); 'Moran,Gina@Parks'; Carrie Boyle (carrie.boyle@coastal.ca.gov); 'Prahler, Erin@Coastal'; Ross, Toni@Coastal(Toni.Ross@coastal.ca.gov)Cc: 'info@peopleforponto.com'Subject: Public input to Carlsbad Tomorrow Growth Management Committee, LCPA, Parks Master PlanUpdate - Parks & Open Space at Ponto-Coastal South Carlsbad Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks and Planning Commissions, , CA Coastal Commission and CA State Parks: We ask you to please consider this email and attachments in the Upcoming Parks and Open Space discussions by the CTGMC, LCP Amendment, PCH Relocation project, Park Master Plan Update, and development proposals at Ponto. As always, and as we have repeatedly asked for since our initial 2017 letter to the City Council, People for Ponto Carlsbad Citizens asks for and are willing able to work with you to find the solutions for: · the documented Park Inequity at Ponto & Coastal South Carlsbad, · the documented missing Unconstrained Open Space at Ponto, · the future loss of 32+ acres of Coastal Open Space (State beach and Campground) due to sea level rise, · the needed upgrades to Carlsbad’s Growth Management Program and Standards (and developer required land dedications and mitigations) to account for an Unlimited population and the need for Unlimited increases in Carlsbad Parks and Open Space to address those Unlimited populations so as to assure we maintain our quality of life, · beneficial collaborations and donations, and · the wiser use of tax-payer dollars to address tax-payer needs The attached PowerPoint file has important information and images for people not as familiar with Ponto, and the attached YouTube video helps show what a great park Ponto Park will be https://youtu.be/bQuIyLcuyEc Please consider this email and attachments, and know P4P Carlsbad Citizens are here to help assure we sustain and enhance our quality of life for future generations. People for Ponto love deeply Carlsbad and want to assure we leave a better Carlsbad to future generations. Sincerely and with Aloha Aina, Lance Schulte CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. INVESTIGATIONS The San Diego County cities say SANDAG used an unfair vote that increased number of new housing required in their city. An appellate court rejected those claims. SAN DIEGO COUNTY, Calif. — Coronado, Lemon Grove, Imperial Beach, and Solana Beach have lost a legal battle over new housing guidelines that were approved by the San Diego Regional Association of Governments (SANDAG). On June 20, an appellate court rejected the appeal from the four cities, meaning the case is now dismissed. The cities sued SANDAG in September 2020. In the lawsuit, the cities say the regional planning agency used a weighted vote to increase the requirements for new housing in each of the 18 cities in the county. Representatives from the cities say that as part of the weighted vote, larger cities get more say in regards to what happens in smaller cities where conditions are different. RELATED: 'Using public land for public good' | County leaders announce plan to bring affordable housing to San Diego Coronado, Lemon Grove, Imperial Beach, and Solana Beach lose legal battle over affordable housing requirements Author: Dorian Hargrove Published: 5:49 PM PDT June 22, 2022 Updated: 12:20 PM PDT June 27, 2022 00:00 /02:48 San Diego County cities lose affordable housing lawsuit | cbs8.com https://www.cbs8.com/article/news/investigations/four-san-diego-county... 1 of 4 9/11/2022, 5:42 AM 0 0 WATCH RELATED: County leaders announce plan to bring affordable housing to San Diego According to the September 2020 complaint, each city said the number of new housing units jumped drastically since the previous housing determination. In Coronado, the previous Regional Housing Needs Assessment (RHNA) plan which was adopted in 2011 determined that the city needed to build 50 affordable housing units. For the 2020 revision, that number spiked to 912 units to be built by 2029. In Imperial Beach, the number of new affordable housing units jumped from 254 new affordable units to 1,375 in the new plan. Attorneys for Imperial Beach called the new guidelines, "unreachable."Based upon the 1,375 units allocated, Imperial Beach would need approximately 172 housing units constructed each year," reads the 2020 lawsuit. "This yearly allocation is patently unrealistic give that Imperial Beach is a built-out city." RELATED: ‘The buck stops with me’ | SANDAG CEO responds to credit card misuse, toll road mistake WATCH RELATED: SANDAG CEO responds to credit card misuse In Lemon Grove, the 2011's affordable housing plan determined that the city needed to build 309 new units. In the following plan, the number rose to 1,359. And, for Solana Beach, the new affordable housing requirement went from 340 in 2011 to 875 in the 2020 plan. 'Using public land for public good' | County leaders announce plan to bring affor… Audit: SANDAG improperly used credit cards to spend taxpayer money San Diego County cities lose affordable housing lawsuit | cbs8.com https://www.cbs8.com/article/news/investigations/four-san-diego-county... 2 of 4 9/11/2022, 5:42 AM a a Attorneys for the cities argued that SANDAG's board of directors approved the plan relying solely on the weighted vote for each city. That means smaller cities such as Coronado, Lemon Grove, Imperial Beach, and Solana Beach had little say compared to San Diego and other larger cities. SANDAG ultimately won the legal dispute by arguing that the courts could not overturn the Regional Housing Needs Assessment and that only state lawmakers could change the law. A San Diego Superior Court judge agreed. And, on June 20 an appellate court also agreed, delivering the final blow to the lawsuit from the four municipalities. "We conclude that the trial court properly sustained SANDAG’s demurrer without leave to amend on the ground that judicial review of SANDAG’s RHNA allocation is not permitted," reads the June 20 appellate ruling. Attorneys for the four cities did not respond to CBS 8's request for comment. "People become homeless here they don't come from other places. The only way to solve that is to provide enough housing so the people who live, work here and serve these communities are actually able to afford to live here," said Stephen Russell, president and CEO of the San Diego Housing Federation. He said the housing assessment calculates the number of affordable housing units based on an array of factors including the types of jobs in the area. "One of the things that has driven the calculations has been what we call job fit," he said. "Communities actually provide housing for the folks who are working in those communities and that the housing should fit the wage profiled of folks working there." People who work on Coronado wouldn't have to commute each day to go to their lower-wage jobs if more housing was available on the island, he said. EEDDIITTOORR''SS NNOOTTEE:: AA pprreevviioouuss vveerrssiioonn ooff tthhiiss aarrttiiccllee cciitteedd tthhee llaawwssuuiitt aanndd iinncclluuddeedd tthhee ddrraafftt RRHHNNAA nnuummbbeerr ooff 11,,000011 nneeww uunniittss ffoorr CCoorroonnaaddoo.. SSAANNDDAAGG ssaayyss CCoorroonnaaddoo iiss rreeqquuiirreedd ttoo bbuuiilldd aa ttoottaall ooff 991122 nneeww uunniittss,, wwiitthh 448811 uunniittss ffoorr vveerryy llooww aanndd llooww--iinnccoommee hhoouussiinngg.. San Diego County cities lose affordable housing lawsuit | cbs8.com https://www.cbs8.com/article/news/investigations/four-san-diego-county... 3 of 4 9/11/2022, 5:42 AM LOADING NEXT ARTICLE... San Diego County cities lose affordable housing lawsuit | cbs8.com https://www.cbs8.com/article/news/investigations/four-san-diego-county... 4 of 4 9/11/2022, 5:42 AM From:Madeleine Szabo To:Council Internet Email; Planning; Growth Management Committee; eric.larson@carsbadca.gov; Don Neu; EricLardy Subject:Design standards for new developments Date:Wednesday, September 14, 2022 9:25:51 AM Dear Carlsbad City Council Members, Growth Management Citizens Committee,Carlsbad Planning Department, In recent years, it appears that the City has abandoned design standards thatdevelopers must follow. Why is the City not following guidelines of setback, trees,and parklike amenities? The original Bressi Ranch commercial center (with Trader Joe's and Stater Brothers)was built with attention to beautiful architecture with pleasant sidewalks, parks, tablesand benches, flower gardens, and many trees. The shopping extension built a fewyears ago with Sprouts and CVS across the street from Bressi is "concrete city" withvery few trees or gardens or community parklike structures or easy walkability. Thenew adjacent residential development is directly on the road and typifies urbansprawl, not in keeping with Envision Carlsbad standards. Residents are concerned about the change in the character of Carlsbad. Carlsbadshould promote guidelines that include architecture and landscaping that isaesthetically pleasing. Developers must follow the standards of our EnvisionCarlsbad values and not advance overdevelopment, crowded conditions, increasedtraffic, and humdrum impersonal architecture. The City must preserve and enhance the small town feel and neighborhood identity,not urban sprawl and institutional sterile architecture. New developments mustcontribute to livability and feeling of a community neighborhood. New developments must adhere to contemporary community design concepts thatemphasize walkability with stores that are situated as individual buildings connectedwith wide sidewalks, with special paved pedestrian crossings and landscaped curbextensions. Developments should be built at a scale that is attractive and follows thesmall town feel and beach character of the community. Specifically Marja Acres that is under development now needs scrutiny. City Planningmust monitor the design and ensure that it is in keeping with Carlsbad's communitycharacter. Are setbacks so close to the road that feelings of choking urbanization andlack of community prevail? Will it follow the new Bressi Ranch development alongGateway Road (hopefully not the new urban standard? The Carlsbad Planning Department should always maintain the core value of smalltown, beach community character to the physical design of new developments. Special attention must be given to the attractiveness and charm of thecommunity. Keep the Carlsbad standards of "Small Town Feel, Beach CommunityCharacter and Connectedness; Neighborhood Revitalization, Community Design and Livability". Respectfully submitted, Madeleine Szabo5338 Forecastle CourtCarlsbad, CA 92008203-516-8857 bcc: Concerned Carlsbad Residents Friends of Carlsbad Scenic Corridor CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. To: From: Subject: Growth Management Committee Mike Howes 40% OPEN SPACE= URBAN LEGEND Over the recent years the City has been criticized for not providing 40% open space as "promised" by Carlsbad's Growth Management Plan {GMP). None of the people making these criticisms had any involvement with the creation of Carlsbad's Growth Management Plan and most did not even live in Carlsbad at that time. Neither the ordinance that established the Growth Management Plan nor the Citywide Facilities Plan required 40% open space. Furthermore, Proposition E, the initiative approved by the voters in 1986 that ratified the city's GMP, did not contain a 40% open space requirement. This was clearly explained by City staff during the Envision Carlsbad process. As noted by the title, the Growth Management Plan was a plan to manage the growth of Carlsbad and ensure that public facilities were in place before or concurrent with development. It was not an open space plan; open space was just one of the 11 public facilities addressed by the Growth Management Plan. It was never a goal of the Growth Management Plan to ensure that 40% of Carlsbad would be preserved as open space. WHERE DID 40% COME FROM? When staff was preparing the Growth Management Plan the City was divided into 25 Local Facilities Districts. The boundaries of these districts were based on property ownership, the amount of development in a particular area and the stage of planning that was occurring for a particular portion of the City. At that time in 1986, around 36 years ago, there was far less development than currently exists. Bressi Ranch, Rancho Carrillo, La Costa Valley, Kelly Ranch, La Costa Oaks, LEGOLAND/Carlsbad Ranch, Zone 20, Poinsettia Shores, Poinsettia Properties, most of Aviara and many other areas were vacant land or farmland at that time. As mentioned above, part of the Growth Management Plan did address open space and required that each of the 25 Local Facilities Management Zones provide a minimum of 15% open space when they developed. At that time, it was determined that Zones 1, 2,3,4,5,6,7,8,9,10, and 16 were already developed, met or exceeded the requirement or had approved Master Plans or Tentative Maps. Attached are some pages from the Citywide Facilities and Improvement Plan that addressed open space. As Staff planners we calculated how much open space existed in the developed areas of the City, how much more would come from approved Master Plans, the acreage of planned future City parks and how much additional open space acreage would be provided when each of the undeveloped Local Facility Management Zones provided their 15% open space. This had never been done before on a Citywide basis. Based on this it was estimated that about 37%-38% of the City would be open space. This estimate was made using paper maps, engineer scales and pocket calculators, we did not have computers, the Internet, GIS, or Google Maps at that time. It was our best estimate using the technology that was available 36 years ago. The City Council and other civic leaders were proud of how much open space Carlsbad would provide in comparison to other cities in North County. As mentioned above, this estimate had never been done before. Even Council members forgot that the original estimate was 37-38% and started saying close to 40% or a goal of 40% of the City as open space at final buildout. Eventually many people that had no knowledge of the Growth Management Plan or its history just heard 40% open space and it assumed a life of its own. As stated above, the goal of the Growth Management Plan was to address the timely provision of public facilities, not guarantee 40% open space. If the City only has 37-38% open space at buildout, staff did a great job trying to predict the future. No one ever meant to mislead that public and guarantee 40% open space, the City staff was just doing the best they could with the technology we had at the time. If we could have predicted the stock market with the same level of accuracy, we would all have been very wealthy individuals years ago. Attachments City of Carlsbad Growth Management Program Citywide Facilities and Improvements Plan September 16, 1986 Amended January 9, 1990 Amended April 22, t 997 Amended September 22, 2015 Amended August 22, 2017 SECTION Ill. REQUIREMENTS FOR LOCAL FACILITY MANAGEMENT PLANS RELATIONSHIP TO THE CITY Yit DE FA CI LIT re S AND :-, . IMPROVEMENTS PLAN As part of the ov•rall Growth Management Program the City was broken dovn 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 econoaically 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 of the Citywide Facilities Improvements Plan and shall implement the Citywide Facilities 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 OPEN SPACE PERFORMANCE S~ANDARD: Pifteen percent of the total land area in the zone exclusive of environmentally constrained non- developable land ·must be set aside for permanent open space and must be available concurrent with development. ADDITIONAL FACILITY PLANNING INPORMATON: The preceding map highlights those areas of the city which will be required to comply with the open space performance standard. The other areas of the city are already developed or meet or exceed the requirement. Local Pacility Management Zones 1, 2, 3, 4, S, 6, 7, 8, 9, 10, and 16 already meet the standard while Zones 11, 12, 13, 14, 15, 17, 18, 19, 20, 21, 22, 23, 24, and 25 must detail in their local plan how they will meet this standard. -43- rm ~OIN■ETTIA LN • ··-··· . .......: .. --~-::-:;.$·!~::-~❖-: \j}fa AREAS WHERE US,. ADDfflONAL PERMANENT OPEN t!PACE 10 IE PROVIDED EXCLUSIVE OF ENVIAONMENTAU Y CONSTRAINED LAN> -42- .. FIGURE 14 OPEN SPACE -S~f'TEMBEA 18, 1986 .. }.::. :· :::::::::::: City tf Carlsbad Community Parks vs. Neighborhood Parks -HISTORY Recently there has been some comment about the lack of neighborhood parks in the City. When I first started working for Carlsbad in 1980 the City did not have any of the large Community Parks that currently exist through out the City. There were a few neighborhood parks, most of which did not have any ballfields. The citizens of Carlsbad told the City Council that they wanted large multi-use parks with ballfields, they did not want any more neighborhood parks. The City did not want beach parks or trails, the emphasis was ballfields in large multi-use parks. Based on the wishes of the citizens of Carlsbad, the City Council directed the Parks & Recreation Department along with the Planning Department that in the future the City only wanted large Community Parks. That is why in each quadrant of the City there are at least one or often two large Community Parks instead of a number of small neighborhood parks. This is what the citizens of Carlsbad wanted. At that time most of the undeveloped portions of the City were zoned P- C, Planned Community which required the preparation of a Master Plan. The Master Plan ordinance along with the Planned Development Ordinance required that each of the Master Plans provide a common HOA recreation area. Most of the large Master Plans within the City have Common HOA recreation areas . Examples of this would be the common HOA recreation areas in Bressi Ranch, San Pacifico or La Costa Valley. The City believed that these common HOA recreation areas within the Master Plans would function as neighborhood parks at no cost to the City since almost all of them were within a mile of the residents of their Master Plan. From:Lance Schulte To:Growth Management Committee; Michele Hardy; Council Internet Email; City Clerk; Kyle Lancaster; Eric Lardy;"Smith, Darren@Parks"; Homer, Sean@Parks; "Moran, Gina@Parks"; Boyle, Carrie@Coastal; "Prahler,Erin@Coastal"; Ross, Toni@Coastal Cc:info@peopleforponto.com Subject:Public Input for 2022-9-2 CTGMC & to be provided to the Carlsbad City Council and Parks, Planning and BeachPreservation Commissions as citizen communications Date:Thursday, September 22, 2022 9:04:40 AM Attachments:2022-9-22 CTGMC meeting - verbal public input on New Standards - Lance Schulte.pdf2022-9-22 CTGMC meeting - public input on Zone 9 GMP Open Space.pdf Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks, Planning and Beach Preservation Commissions, , CA Coastal Commission and CA State Parks: Please review and consider this email & two attached information files as public input. The CTGMC, Carlsbad City Council and Parks, Planning & Beach Preservation Committees have a responsibility to correct the well documented Park & Open Space shortfalls (City’s past land use planning & Growth Management Plan Standard mistakes) at Ponto, and Coastal land use plan for more loss of these land uses due to sea level rise. Thank you, Lance Schulte Reference: Email comments to committee@carlsbadca.gov Comments received by 2:30 p.m. the day of the meeting will be shared with the committee prior to the meeting. When e-mailing comments, if the comment relates to a specific item on the agenda, please identify in the subject line the agenda item to which your comments relate. All comments received will be included as part of the official record. CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. 2022 Sep 22 CTGMC – City creating New Standards for existing development Page 2 of the Staff Report has a fundamental incomplete and misleading statement regarding New Standards and the work of the CTGMC, on all future Quality of Life Standards. In the ’friends of H street …’ citation implies that City is prevented from applying ‘new standards’ to existing and future development. This is false. A City is NOT PREVENTED from applying new standards, and new standards for existing developed areas. Carlsbad and other cities do this all the time. It is just that the method of implementing New Standards to new or existing development varies – new development meets the new standard, and a program is created to help bring existing development up to the New Standard. In fact the City’s 1986 Growth Management Plan (GMP) did exactly this - applying New Standards to all the existing development in the City. The GMP also created a GM Plan to bring older existing development up to those new standards. In 1986 New Library, Fire, City Hall, Street (LOS), and other New Standards were applied to existing development and made a requirement of new development to provide. The 1986 GMP was a Plan to bring the existing developed City up to the New GMP Standards. We had to create new fire stations, a new library, new parks and other facilities for the existing development in the City in a way that met the New GMP Standards. If you use page 2’s false-logic/inference on New Standards then the 1986 GMP’s New Standards should not have been done – they were not ‘Required’. Recently the City applied New Standards to the City’s already existing/developed streets – guiding City redesign/reconstruction to a New Standard of ‘complete streets’ and changing developed roadways to provide better bike, pedestrian, and transit facilities. The CTGMC has a Fundamental Choice - set New Standards to enhance and sustain our Quality of Life (including useable Open Space); or choose to give up and let our Quality of Life slowly erode (like our beaches and coastal Open Space land uses) as we are required to change our Land Use Plan to add more housing/population every 8-year’s. Like we did in 1986 with GMP, the CTGMC can create New Standards and apply them to existing development. The CTGMC can fix false exemptions and instead work to achieve our Quality of Life Standards. Fixing false exemptions is the right, just, smart, and sustainable thing to do. We can help you right the Open Space & Park wrongs at Ponto – we have very workable solutions. Please do the right thing, collaboratively work with your fellow citizens. See the 7-page “CTGMC key issues and suggestions -6/25/2022” forwarded to you by staff on August 2nd. 2022 Sep 22 CTGMC – missing Zone 9 GMP Open Space Page 1 of 2 2022 Sep 22 CTGMC – missing Zone 9 GMP Open Space Page 7 of the staff report is incomplete and fails to disclose some key facts. The report alludes to how the City and BLEP MP Developer colluded to exempt the BLEP MP from the GMP Open Space Standard to get the State Title to the Lagoon/bluffs so the State’s Lagoon dredging could more easily advance. The City also allowed the BLEP developer to construct Phase 1 (Rosalena) without providing a Coastal Commission required Bluff Top Trail. Ask Rosalena about this. In 1985 prior to BLEP being annexed all the Lagoon and Bluff areas were already General Planned and Zoned Open Space (constrained Open Space). The BLEP Master Plan simply noted these already ‘pre-zoned constrained Open Spaces. The 1986 BLEP Master Plan did include extensive GMP Open Space (i.e. unconstrained open space) – 30’ wide landscaped setbacks, multiple private recreation facilities, and most critically a 12.8 acre Recreation Commercial land use area (with grassy fields, pool, tennis courts, etc.) - basically a quasi-park for expanded Ponto area. The BLEP Land Use Plan had significant GMP Open Space. In 1994 the City made a mistake when it replaced the BLEP Land Use Plan and eliminated the 12.8 Recreation Commercial land use and other GMP Open Space and replace Open Space with Residential Land Use – the San Pacifico Community (SPC). The SPC Developer and City did an illegal ‘shell game’. If BLEP’s 12.8 Recreation Commercial land use and other GMP compliant Open Spaces were provided in the SPC Master Plan we would not see in the City’s own mapping that shows 30-acres GMP Open Space is missing in Zone 9. The developer and City pulled a fast one to violate the GMP Open Space Standard and falsely count ‘constrained Open Space’ as required ‘unconstrained GMP Open Space’. Our Quality of Life suffers and Citizens end-up paying the cost – ask Rosalena Citizens. Currently the last adopted LFMP for Zone 9 (Ponto) will need to be amended to account for the City’s proposed 11.1 acre land use plan/zoning changes from Non- Residential Reserve to Residential/General Commercial, but only if the CA Coastal Commission approves this land use change in 2023. The Commission will decide if there is sufficient “Coastal Recreation (i.e. Pubic Park) and Low-cost Visitor 2022 Sep 22 CTGMC – missing Zone 9 GMP Open Space Page 2 of 2 Accommodation” land uses at Ponto to justify the Developer’s (City’s) proposed 11.1 acre change. The City made mistakes in Zone 9 that are clearly seen in City maps and is trying to cover them up. The GMP Open Space was NOT provided and in 1986 Zone 9 was not developed; and in fact Zone 9 land use was completely changed in 1994 without carrying over/providing the unconstrained GMP Open Space acreage that was in BLEP. CTGMC please work with P4P to fix this mistake before it is too late. From:John To:Growth Management Committee Subject:Improvements Date:Wednesday, September 21, 2022 11:37:37 PM The most beautiful part of Carlsbad is the drive down 101 overlooking the ocean. This view could be vastly improved by replacing the hideous white fence that blocks that view with a couple of horizontal strands of stainless steel cable that would not block the view or better still eliminate it entirely. I am old enough to remember how it used to be and it saddens me every time I take that drive. Other cities along our coast have retained their views. Why not investigate what they have done and make this improvement to restore Carlsbad to it’s former glory. Respectfully, John M Walker Sent from Mail for Windows CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. From:chrisr@batiquitoslagoon.org To:Growth Management Committee Subject:Growth Management Citizens Committee Meeting - Public Comment on Open Space and Parks Date:Wednesday, September 21, 2022 11:33:17 PM The Batiquitos Lagoon Foundation (BLF) is a 501(c)(3) non-profit public benefit corporation formed on January 7, 1983 with a mission to preserve, protect and enhance the Batiquitos Lagoon Ecological Reserve (BLER) and associated watershed. The Foundation has always believed that maximizing public access and awareness of the Batiquitos Lagoon will ensure its protection and viability as a natural resource. In 1996, the Foundation received a grant from the California Coastal Conservancy to develop a Trail Alignment and Visitor Center Feasibility Plan. The Plan was completed in June 1997. Since then it has served as BLF’s conceptual blueprint for a public access pedestrian trail between El Camino Real and the ocean (“La Costa to the Coast”) and has been incorporated into the City of Carlsbad Trails Master Plan. Implementing this vision has been a long and arduous process. There are a great number of property owners, land features, easements, access points, development types and other relevant influences around the lagoon. The vision is far from complete, but much progress has been made. Today, BLF has title to 25 acres of open space bordering the Batiquitos Lagoon Ecological Reserve (BLER) and holds easements on an additional 103 acres. The purpose of this public comment is to urge the City of Carlsbad act on a unique opportunity: to acquire the 14.3 acre site in southwest Carlsbad referred to as Planning Area G & H for use as a coastal park. The site is currently for sale. It is adjacent to the Batiquitos Lagoon Ecological Reserve. It includes Federally protected habitat. It sits at the western terminus of the La Costa to the Coast trail and could potentially accommodate a proposed Coastal Science and Cultural Center. This is a very special site that needs to preserved for future generations of public use. Please give it serious consideration. Sincerely, Chris Ross President and Board Member Batiquitos Lagoon Foundation www.batiquitoslagoon.org CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Wednesday, September 21, 2022 10:41:49 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameRaymond Hughes Hughes Emailrayjay3@sbcglobal.net CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Wednesday, September 21, 2022 11:01:25 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameMM Kent Emailmmkent@gmail.com CityCarlsbad StateCa PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Wednesday, September 21, 2022 1:52:08 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameDennis Hoover Emailhooverphoto@duck.com CityCarlsbad StateCalifornia PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 6:06:57 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameLauren Robertson Emaillauren.petry@gmail.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 6:09:32 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsPonto Park is a must for our San Pacifico neighborhood! Pleaseaddress all 11 issues to PROTECT PONTO NameShirley Hudson Emailskeatinghudson@yahoo.com CityCarlsbad State PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. California 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 6:12:37 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsI have looked at this side of Carlsbad since 2000 and love it forthe open natural space. The City needs space like this as it ispriceless. NameCherie Mclarty Emailcherie.mclarty@yahoo.com CityCarlsbad PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. StateCa 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 6:24:40 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameShawn Harrity-Phillips Emailsharrityphillips@gmail.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 6:34:36 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameMary Dressel Emaildressel.mary@gmail.com CityCarlsbad StateCa PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 7:04:45 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsWe need more pickle ball courts NameTim Gagner Emailtimgagner15@gmail.com CityCarlsbad StateCa PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 7:11:36 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsSan Pacifico is a safe and friendly family neighborhood pleasekeep it that way safe for our children to ride their bikes withoutvisitors coming in and out that we do not know safe for us to gofor a dog walk alone please think of the many families that livehere and the effect this will have on their lives Namepaulina miller Emailpmillerca@cox.net CityCarlsbad PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. StateCalifornia 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 7:38:38 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsPonto is last open coastal land. Please let’s not ruin it with giantapartments. We have a lack of open space and a local park inSW Carlsbad. We have been asking for a local park close to 7years. We use parks in Encinitas but have been paying fees toCarlsbad City for many years. NameFarhad Sharifi Emailfhsharifi@gmail.com CityCarlsbad PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. StateCalifornia 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 7:50:15 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameJulia Jansson Emailjulia@soilretention.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 7:50:42 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameNick Jansson Emailjulia@soilretention.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 8:18:16 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsPlease honor my support based upon this petition NameDiane Rivera Emaildianariver@aol.com CityCarlsbad StateCalifornia PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 8:13:19 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsI agree that Ponto needs a park instead of housing, however i donot believe in the current and future drought situation that puttinggrass down in any of it is wise. NameLori hiers Emaillahiers@me.com CityCarlsbad PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. StateCA 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 8:12:46 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameDimitrios Tzachanis Emaildtzachanis@hotmail.com CityCarlsbad StateCalifornia PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 8:45:29 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameTodd K Emailtoddkeehan@yahoo.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 8:45:56 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameLauren K Emaill.keehan@yahoo.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 9:04:14 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsPonto Park!!!! NameAshlee Stapleton Emailashleestapleton@gmail.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 9:25:11 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameRyan Armstrong Emailryan.strong1999@yahoo.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 9:29:27 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameAndrew Sybrandy Emailasybrandy@pacificgyre.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Thursday, September 22, 2022 9:35:21 AM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameJennifer Baer Emailjenniferrose@roadrunner.com CityCarlsbad StateCalifornia PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. 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. From:LoLo D To:Growth Management Committee Subject:Comments for Committee Business Date:Thursday, September 22, 2022 2:16:12 PM Dear Carlsbad Growth Management Citizens Committee, I am writing to provide my input regarding the land located along Carlsbad Boulevard (PCH) between Avenida Encinas and Ponto Drive. I understand developers are seeking to build onmuch of this currently vacant land, creating hotel rooms, timeshares, retail space, restaurants, and other commercial uses. The last report I saw involved thousands of hotel rooms andtimeshares, several restaurants, and hundreds of thousands square feet in retail space. While this may look stupendous on paper, such development would be a disaster for the immediateregion and for Carlsbad overall. Such development would harm Carlsbad by:1. Substantially reducing or eliminating any of the area to be used as a park.As noted in other documents, Carlsbad falls woefully below its own standard of needed park space per resident. Creating a park on this land will help preserve the beautiful coastline andwill provide needed habitat for the many species that live there. 2. Creating far more car trips, traffic congestion, and pollution than the area can handle Traffic during rush hour and high tourist season is already an issue. With no adequate masstransit in this area, how are users of all these hotel rooms, timeshares, restaurants, and shops supposed to get there? By car, of course! They are not going to use a bike - where would theypark it securely? Why be all sweaty going to dinner? How would they carry home any purchases? There is no way Carlsbad Boulevard can absorb all the traffic a large scaledevelopment would create. In addition, there is already talk of reducing the traffic lanes to one in each direction. During the summer, cars will be backed up to Oceanside headingsouthbound and well into Leucadia going northbound. What a great way to "enjoy" the coast. 3. Substantially increasing the danger to cyclists and pedestrians along this stretch ofCarlsbad Boulevard.As traffic loads increase, the danger to other road users increases. Drivers going slow are more likely to text and drive. In addition, drivers perceive the road changes to have been"demanded" by cyclists and other users, and therefore, often take out their frustrations on those users by passing too closely and failing to yield when required. I am strongly in favor of developing this currently vacant land into a park. A park willnot generate the high volume of car trips that would be caused by other development. A park will serve all residents of Carlsbad and will make the coast accessible to all, not just thoseborn rich or already earning well into the 6 figures. Respectfully submitted, Lorraine Daly Carlsbad, CA 92011 -- "Failure is often just as illuminating as success" From:DeAnn Weimer To:Growth Management Committee Cc:Eric Lardy Subject:Re: The 5-Minute Fix: How DeSantis’s migrant stunt is playing out Date:Thursday, September 22, 2022 1:57:29 PM Sept. 22, 2022 Carlsbad Tomorrow Growth Management Committee 1635 Faraday Avenue Carlsbad, CA 92008 Re: Open Space and Parks Dear Carlsbad Tomorrow Growth Management Committee Members, Today you take up the issue of performance standards for parks and open space in Carlsbad – an issue that perhaps more than any other will most impact the quality of life in our community for decades. It is also an opportunity to learn from past mistakes, and provide the guardrails and accountability needed to avoid encumbering our future by repeating historical missteps. First, we would like to thank you for the time you are spending privately and publicly understanding the challenges, while protecting and advancing the decades of work by Carlsbad citizens passionate about the quality of life for all of us – whether we are bipedal, four footed, winged, legless, aquatic or rooted. Secondly, we would encourage you to be laser focused as you articulate both the vision and the best practices that will underpin that vision. -- As with any business, responsibilities must be clearly understood. It is the task of a committee such as this to set the goals and objectives that will both define what success looks like for a community with Carlsbad’s attributes, and the principles that must be in place to achieve that success. Separately, it will be the responsibility of operations, of the professional staff led by elected officials, to do the blocking and tackling around funding and expenses that will best achieve the goals you set. Your role is analogous to that of a board of directors, guiding, setting the tone. The c-suite executives, or their equivalents, have a different responsibility, i.e., meeting expectations. And just as with any business, it is important that the lines between these responsibilities are not blurred. --Accordingly, Citizens For North County (CNC), a 501C4, supports the view expressed in Hosp Grove comments that this committee sets standards, and the people will vote for funding. In numerous elections, Carlsbad residents have shown they are overwhelmingly willing to pay for open space. --Similarly, we support the passionate pleas to prioritize a park for Ponto. It is essential that this already densely populated southwest coastal area have a walkable park. Further, it is necessary that this park and trail system be part of the ring of trails that should connect all our neighborhoods with one another. Most importantly, no piece of property in this city has been more contested than the area around the Agua Hedionda Lagoon and the Flower Fields. On multiple occasions over decades, Carlsbad residents have stepped into the voting booth to protect and preserve this open space, fighting off millions of dollars spent by special interests and non-residents. To do this, thousands of citizens have spent thousands of volunteer hours and money to preserve this space, knowing it is the geographical lynchpin to achieving walkable mobility goals, open space habitat protection, and parkland for residents from north to south, east to west. Its role as the corner stone of our future must be reiterated in your vision. This brings us to ways to inform and improve accountability standards incorporated into the vision statement: --Unfortunately for Carlsbad, when voters allocate money for open space, the funds are rat holed, instead of being used expediently for the intended land preservation acquisitions. The result is voter goals are not achieved within a generation, and the buying power of the funds is diminished. To discourage poor capital allocation decisions, Citizens For North County proposes including a standard that allocates half of all voter-approved funding for open space and parkland within five years of the election date. --Carlsbad also needs improved tracking of infringement on existing open space and parkland allocations. As you are aware, Ponto’s open space and parkland shortfall is due to a failure of the city to consistently require developers to meet Carlsbad requirements. Mistakes are made. Sometimes the mistakes are glaring, such as Ponto. More often the mistakes are smaller. They fall into two buckets: A. Miscalculations at the time of the initial development proposal for undeveloped land; and B. Miscalculations made after initial proposals have been abandoned (such as Ponto), or after properties come up for redevelopment. At a more granular level, particularly in residential situations, unapproved changes have occurred but not been caught for years. Or one city department, such as building, mistakenly approves changes impacting open space because they are not aware of incursions. CNC supports creation of a biennial audit of these errors, and a requirement that the lost square footage be replaced at a 3:1 ratio by the city within three years as part of its land acquisition program. Understandably, when the city makes a mistake, too often it cannot reverse it without risking legal liability with the developer/owner. Unfortunately, the community loses protected areas, but is not notified of the losses whether incremental or large. Addressing these losses – within the Local Facility Management Zone – should be a basic accountability standard. --Documenting commitments involving SDG&E cooperation also requires an accountability standard. Many of our parks, trails and open space areas include or touch property SDG&E holds via easement or ownership. Access to these areas for trail extensions, wildlife corridors, etc., is critical to the functionality of the mobility or open space objectives. When this access fails to materialize whether along a lagoon or elsewhere, these failures should be reported on a biennial basis to Carlsbad residents. Thank you for your time and attention to these concerns. Regards, De’Ann Weimer on behalf of Citizens For North County On Thursday, September 22, 2022 at 01:43:03 PM PDT, The Washington Post <email@washingtonpost.com>wrote: Sign up for this newsletter Read online Ii] Ii] Ii] The Washington Post The 5-Minute Fix Keeping up with politics is easy now. Presented by Instagram By Amber Phillips with Caroline Anders Email When Ron DeSantis, Florida’s Republican governor, chartered a flight sending migrants from San Antonio to Martha’s Vineyard last week, it raised a lot of questions. Who paid for it? (Florida.) Were the migrants lied to? (It depends whom R you ask, but many of the migrants say they were misled.) Can he do that? (That isn’t clear yet, but the move has prompted a criminal investigation and several lawsuits.) The first, most pressing question right now is whether he lied: Some of the migrants say they were given misleading information to persuade them to take the flight, such as promises of jobs and housing that one lawsuit filed by the migrants called “boldfaced lies.” (By contrast, some of the migrants controversially bused by Texas to D.C. said they were grateful for the ride.) DeSantis hasn’t directly rebutted accusations he lied. He defends himself by saying the program was “all voluntary” and ultimately got the migrants to a better place. “They’re given a good ride,” he said. “It’s a humane thing to do.” DeSantis in Bradenton, Fla., this week. (Thomas Simonetti for The Washington Post) Another question is what laws, if any, he might have broken? Some experts said what DeSantis did bear a lot of resemblance to human trafficking. Others say that could be a hard case to make, because the migrants signed consent forms. The sheriff from San Antonio, where Florida officials traveled to find the migrants, opened a criminal investigation and said he thinks the travelers were lured under false pretenses. “If you think about what smugglers do, it’s not that different,” said Nelson Wolff, a local official in Texas. Also a question: Did DeSantis inappropriately use Florida taxpayer money for this? ADVERTISEMENT Content from Instagram Supervision tools help you see who your teen interacts with. With Family Center, parents participating in supervision can see their teens’ followers and following activity and see who they report—giving parents peace of mind while respecting their teens’ autonomy. Discover the right tools for you and your family, and set them up today. The politics of this are nothing but divisive: DeSantis promised more flights to liberal cities are to come. He probably won’t win over any swing voters for his November reelection by doing this. But if you’re trying B to out-Trump Donald Trump in, say, a Republican presidential primary, well, this could help. Nationally, this could help his party on the margins to take back control of Congress. Immigration has the potential to be a troublesome issue for Democrats in the midterm elections. How to fix the U.S. immigration system has tripped up politicians on both sides for decades. Other than Trump’s wall proposal, major overhauls just haven’t been a priority on either side. And that could put Democrats campaigning in conservative areas this November on the defensive, since their party is the one in charge right now. A quick Mar-a-Lago investigation update For now, the government’s investigation of whether Trump broke laws by taking government documents with him out of the White House has been allowed to continue. It’s an investigation that has potentially serious legal consequences for Trump and/or his lawyers, since the government justified its raid of Mar-a-Lago by arguing there was probable cause crimes were committed. Lately, Trump has been losing two legal battles on this front: ADVERTISEMENT 1. Federal judges just said the investigation should go on: These judges, which included Trump appointees, temporarily reversed another judge’s controversial decision to pause the investigation so that a special master could evaluate whether Trump can claim ownership over any of the documents. The new decision thoroughly rebuked Judge Aileen Cannon’s reasoning, writes The Post’s Aaron Blake. 2. The ownership argument: Even if Trump took the appropriate paperwork steps to declassify hundreds of government documents he took with him from the White House — and it’s looking as if he didn’t, given his latest defense is he could declassify them simply “by thinking about it” — that wouldn’t make these documents his, the special master recently argued. Potential nuclear secrets are still government secrets, whether a former president thinks so or not. The special master appears to be putting pressure on Trump to put evidence behind his defenses. Reader question: What is the deal with the Justice Department’s rule on pausing investigations that could be political right before an election? Trump lawyers in New York this week. (Brittainy Newman/AP) Trump lawyers in New York this week. (Brittainy Newman/AP) So there is no rule that the federal government has to stop politically related investigations before an election. But the Justice Department believes it’s good practice to avoid the appearance of influencing voters, so much so that it’s been a norm for decades. ADVERTISEMENT Following it means that any big, public action in any kind of remotely political investigation would be a no-go in the 60-day period before an election. We’re in that period now, fewer than 60 days out from the midterms. This guideline probably applies to investigations of Trump and his allies’ involvement in Jan. 6, Trump taking classified documents to Mar-a-Lago and anything that may still be ongoing regarding Hunter Biden. It doesn’t mean those investigations will be put on pause, just that you probably won’t see anyone charged in them or other big developments. All that said, the government can decide to ignore that custom if it thinks something is important enough. And this is only a guideline for federal investigations. New York's attorney general, who announced a lawsuit against Trump yesterday, is under so such restriction. Ask me a political question any time. Read these next Q&A: What questions do you have about the new lawsuit against Trump By Jonathan O'Connell and Shayna Jacobs ● Read more » Herschel Walker’s struggles show GOP’s deeper challenge in Georgia By Cleve R. Wootson Jr. ● Read more » ANALYSIS Do people really support GOP governors sending migrants across the U.S.? By Aaron Blake ● Read more » PERSPECTIVE Will Gun Owners Fight for Stronger Gun Laws? By Rebecca Tuhus-Dubrow ● Read more » U.S. watchdog estimates $45.6 billion in pandemic unemployment fraud By Tony Romm ● Read more » ANALYSIS The GOP claim that Democrats support abortion ‘up to moment of birth’ By Glenn Kessler ● Read more » What are you curious about in politics? Read more » We think you’ll like this newsletter Check out Must Reads for a curated selection of our bestjournalism in your inbox every Saturday, plus a peek behindthe scenes into how one story came together. Sign up » Iii Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Tuesday, September 20, 2022 5:47:24 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameFrances Walters Emailfatt3@aol.com CityEncinitas StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Sent from People for Ponto Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Tuesday, September 20, 2022 11:07:35 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsI think it is time the City of Carlsbad City manager investigatewhy the Planning Department keeps hiding the 5000+ petitionsfrom Residents of SW Carlsbad who need a Park for our kids thatwe paid for when we bought our houses NameChas Wick Emailchaswick@reagan.com CityCarlsbad PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Tuesday, September 20, 2022 9:55:21 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameGail Norman Emailgnorman_ca@yahoo.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Sent from People for Ponto Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Tuesday, September 20, 2022 9:20:51 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameLeigh Frazza Emailleigh.frazza@yahoo.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Sent from People for Ponto Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Tuesday, September 20, 2022 9:20:13 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameKelley Frazza Emailkafrazza@yahoo.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Sent from People for Ponto Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Tuesday, September 20, 2022 8:54:11 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the Additional CommentsWe demand a park! Think of your stewardship’s impact on sevengenerations from now! Will they feel/care about the increase intax base? No. Will they appreciate part of their community opento all? Yes! NameJohn Gabriel Emailjohnrgabriel@gmail.com CityCarlsbad PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Tuesday, September 20, 2022 8:42:52 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameCollin Schaefer Emailcollin.schaefer@ymail.com CityCarlsbad StateCA PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Sent from People for Ponto Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Tuesday, September 20, 2022 8:41:59 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameTodd Schaefer Emailtoddkschaefer@gmail.com CityCarslbad Stateca PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Sent from People for Ponto Protect Ponto Petition: Dear Carlsbad Growth Management Committee, City Council, andCalifornia Coastal Commission: Since 2017 the City received over 5,000 petitions, written and verbaltestimony regarding the need for Ponto Park and the Park and UseableOpen Space unfairness at Ponto and Coastal South Carlsbad. The Citystaff should provide the Growth Management Committee all that citizeninput since 2017. – The City’s 2017 & 2020 Sea Level Rise Report shows Ponto will loseover 32-acres of “High-priority Coastal Land Use” due to coastal erosionand flooding. (14+ acres of Coastal Recreationand 18+ acres ofCampground will be lost) in Carlsbad’s General Plan. – Carlsbad’s Growth Management Program and 2015 General Plan did notconsider this critical 2017 & 2020 Sea Level Rise data and new actionsand a new Plan are needed to address the 32+ acre loss AND increasedpopulation/visitor demand for “High-priority Coastal Land Uses”. – Carlsbad’s Growth Management Program and General Plan also did notincorporate requirements for unlimited population growth that will needeven more City and Coastal Recreation land – “High-priority Coastal LandUses”. – There is a current Growth Management Program 6.6-acre City parkdeficit in Coastal Southwest Carlsbad, and a 30-acreUnconstrained/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 CoastalCommission to: From:People for Ponto PetitionTo:petition@peopleforponto.comSubject:Protect Ponto Petition LetterDate:Tuesday, September 20, 2022 8:37:20 PM 1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acrePark to serve minimal neighborhood needs based on Ponto buildout andCity’s current minimal Park Standard). Ponto Park should be anappropriately wide, viable, flat and fully useable multi-use grassed field –allow kids space to play informal sports. No thin strip of non-park land. 2) Address loss of 32+ acres of Coastal Open Space Land from sea levelrise by providing for Non-neighborhood City and State buildout-populationand visitor demands for both Coastal Recreation land use and the loss ofthe Campground. Provide sufficient Coastal Recreation and Low-costVisitor Accommodation land use to address the CA Coastal Act andCity/State ‘unlimited buildout population/visitor demand’, and planned lossof current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City onPonto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act &Commission relative to the State’s recent requirement for unlimited Cityand State population growth. Document, plot the Seal Level Riseinundation and coastal erosion/bluff hazard areas in Carlsbad’s GeneralPlan including the Land Use Map, PCH Relocation Project maps, and inthe PCH Project replace all 32+ acres of high-priority Coastal land use thatwill be lost to sea level rise and coastal erosion, and increase the supply ofthese high-priority Coastal land uses to address State required unlimitedincreases in City/State population and visitor demands. 5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposedPCH Relocation, to assure tax-payers (City and/or State) are getting thebest and most sustainable value for their tax-payer dollars. The City shoulduse tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CACoastal Commission, and the Letters from Carlsbad visitor industry,Surfrider Foundation, and Batiquitos Lagoon Foundation. 7) Within the Local Facilities Management Plan Zone 9 portion fullyprovide the 30-acers of documented missing Unconstrained GrowthManagement Open Space that developers were supposed to provide. Alsofully disclose and incorporate the Ponto Open Space recommendationsfrom North County Advocates per City’s lawsuit settlement.Fully preserve or mitigate sensitive habitat areas within and adjacent to the NameAmy Schaefer Emailamy.c.schaefer@sbcglobal.net CityCarlsbad StateCa PCH Project area. 8) Fully provide required storm water quality purification and dentitionbasins in the PCH Project before project waters and waters passingthrough the project area are discharged into the ocean and BatiquitosLagoon. 9) I am concerned about the PCH Modification Project more than doublingtraffic congestion along Coast Highway for an extremely costly walkway,when the same walkway and other needed Coastal land uses can beprovided for a fraction of the cost along existing Coast Highway. It is notappropriate to try to pass off a walkway as “linear park”. 10) Lastly as requested since 2017, directly engage and specificallyinvolve the San Pacifico Community Association and Ponto Community inthat portion of the City’s PCH Project of planning and design of land use inthat community. 11) We request the above 11 citizen issues be fully addressed by theGrowth Management Committee, City Council, and CA CoastalCommission regarding Park-UseableOpen Space and Coastal Land Use issues and City Capital ImprovementProjects at Ponto and Coastal South Carlsbad. Sent from People for Ponto