HomeMy WebLinkAbout2022-12-15; Growth Management Citizens Committee; ; Committee BusinessCA Review ______
Meeting Date: Dec. 15, 2022
To: Growth Management Citizens Committee
Staff Contact: Eric Lardy, City Planner
Eric.Lardy@carlsbadca.gov
Sarah Lemons, Communication & Engagement
Sarah.Lemons@carlsbadca.gov
Subject Committee Business
Recommended Action
Receive presentations and discuss the following topics:
• Walkability. Participate in a committee discussion to determine direction regarding
establishing a new standard for walkability.
• Circulation/Mobility Standard. Participate in a committee discussion to determine direction
regarding the Circulation/Mobility standard – keep as is, remove or update (Exhibit 1).
Transportation staff will be available for questions.
• Technology/Wi-Fi. Participate in a committee discussion to determine direction regarding
establishing a new standard for technology/Wi-Fi. Chief Innovation Officer will be available
for questions.
• Water Supply. Participate in a committee discussion to determine direction regarding
establishing a new standard for water supply. Public Works staff will be available for
questions.
• Water Distribution Standard. Participate in a committee discussion to determine direction
regarding the Water Distribution standard – keep as is, remove or update (Exhibit 2). Library
staff will be available for questions. Public Works staff will be available for questions.
• Recycled Water. Participate in a committee discussion to determine direction regarding
establishing a new standard for recycled water. Public Works staff will be available for
questions.
• Sewer Collection System Standard. Participate in a committee discussion to determine
direction regarding the Sewer Collection System standard – keep as is, remove or update
(Exhibit 3). Public Works staff will be available for questions.
• Wastewater Treatment Standard. Participate in a committee discussion to determine
direction regarding the Wastewater Treatment standard – keep as is, remove or update
(Exhibit 4). Public Works staff will be available for questions.
• Drainage Standard. Participate in a committee discussion to determine direction regarding
the Drainage standard – keep as is, remove or update (Exhibit 5). Public Works staff will be
available for questions.
Fiscal Analysis
This action has no fiscal impact.
GROWTH MANAGEMENT CITIZENS COMMITTEE @) Staff Report
Environmental Evaluation
In keeping with California Public Resources Code Section 21065, this action does not constitute a
“project” within the meaning of the California Environmental Quality Act in that it has no potential to
cause either a direct physical change in the environment, or a reasonably foreseeable indirect physical
change in the environment. Therefore, it does not require environmental review.
Public Notification and Outreach
This item was noticed in keeping with the Ralph M. Brown Act and it was available for public
viewing and review at least 72 hours before the scheduled meeting date.
Exhibits
1. Circulation/Mobility Standard – Summary of Previous Committee Discussion and Options
2. Water Distribution Standard – Summary of Previous Committee Discussion and Options
3. Sewer Collection Standard – Summary of Previous Committee Discussion and Options
4. Wastewater Treatment Standard – Summary of Previous Committee Discussion and Options
5. Drainage Standard – Summary of Previous Committee Discussion and Options
Circulation - Discussed July 28, 2022, and August 25, 2022
Implement a comprehensive livable streets network that serves all users of the system – vehicles, pedestrians,
bicycles and public transit. Maintain LOS (Level of Service) D or better for all modes that are subject to this multi-
modal level of service (MMLOS) standard, as identified in Table 3-1 of the General Plan Mobility Element, excluding
LOS exempt intersections and streets approved by the City Council.
Key Takeaways from Committee Discussion
on Standard Options for Consideration
•Identify reasons why a Multimodal Level of Service
(MMLOS) hasn’t been reported for monitoring
purposes.
o Consider that MMLOS is a new
methodology unique to the city of
Carlsbad and was adopted with the
General Plan update and is being updated
internally to meet the needs of our city.
•Develop a local level of service (LOS) standard for
projects without Vehicle Miles Traveled (VMT)
monitoring that are exempt from CEQA
requirements.
•Keep MMLOS as the standard
•Consider methods or ways for the city or
developer to measure or monitor Personal Miles
Traveled (PMT) to understand how all users of the
system utilize our transportation network versus
only motorized vehicle drivers
•Consider concerns about timing and complexity;
and whether the PMT model is flexible.
o Solana Beach uses PMT and was briefly
described. Committee would like to hear
more about how this works in Solana
Beach.
•Provide an opportunity for the Committee to learn
more about Solana Beach PMT operations.
•Remain cognizant of the need for flexibility
•Consider the potential merits of developing a
“shopping” list of custom standards instead of a
single standard.
•New options presented tonight are exciting
•Conduct a study to determine whether the current
LOS standards are being implemented
appropriately.
•Review exemptions from the current vehicle LOS
standard and determine whether there is a
missing link between multimodal transportation
and increased multimodal safety rather than
simply number of cars on the road
1. Keep standard in as exists Growth Management
Program.
2. Remove standard from Growth Management Program.
3.Change standard (increase, decrease, modify metric,
etc.).
Staff recommends that the circulation standard be
changed to use Personal Miles Traveled as the
measurement and the Multimodal Transportation Impact
Fee to fund future mobility projects and accommodate
future growth.
This means that by measuring all the ways people get
around – walking, biking or driving – the city would be able
to better prioritize existing projects with new
development.
Instead of charging developers a fee based solely on cars,
the city would be able to collect development fees to help
fund other mobility improvements for all the ways people
travel around Carlsbad, like bike infrastructure and wider
sidewalks.
Exhibit 1Carlsbad -v-~
TOMORR W
• Develop a plan for the PMT model to be updated
regularly to reflect future mobility options and
advancements in technology
• Identify funding and next steps for developing and
a real and comprehensive nexus study.
• Identify ways to target the standard to specific
needs while also looking at the bigger multi-modal
vision/system.
• Consider using both direct mitigation and indirect
mitigation.
Notes or Resources
Approved minutes from the July 28, 2022 Growth Management Citizens Committee meeting.
Approved minutes from the August 25, 2022 Growth Management Citizens Committee meeting.
PowerPoint presentation from July 28, 2022 Growth Management Citizens Committee meeting.
PowerPoint presentation from August 25, 2022 Growth Management Citizens Committee meeting.
Agenda packet (staff report for Circulation item begins on page 13) from the July 28, 2022 Growth Management
Citizens Committee meeting.
Sustainable Mobility Plan
Nexus/Funding Sources
• Community Facility District #1
• Bridge and Thoroughfare Districts
• Assessment districts, developer contributions
• Gas taxes
• Traffic Impact Fees
• County transportation taxes
• Federal and state grants
• Public Facility Impact Fees
• General fund
Water Distribution System - Discussed June 23, 2022
Line capacity to meet demand as determined by the appropriate water district must be provided concurrent with
development. A minimum of 10-day average storage capacity must be provided prior to any development.
Key Takeaways from Committee Discussion
on Standard Options for Consideration
•Consider the cost of storing water versus treating
additional water. Discussion on if reservoir size is
large enough for recycled water activity.
•Consider what the maximum water consumption
the city would be able to accommodate.
•Evaluate if the performance standard assumes
water will always be available.
•Assess city’s water sourcing criteria. Discussion
that Carlsbad is an importer of water.
•Consider a standard that maximizes use of
recycled water, graywater, etc. The city can use
while still conserving water.
•Consider cost impacts of conservation-related
standards.
•This standard seeks to understand the purveyance
of water, not the availability of water.
•Provide standards and/or impacts of the other two
water districts that serve the City of Carlsbad.
1. Keep standard as it exists in Growth Management
Program.
2. Remove standard from Growth Management Program.
3. Change standard (increase, decrease, modify metric,
etc.).
Staff recommends retaining the portion of the standard
requiring line capacity concurrent with development.
Staff recommends removing the minimum 10-day
storage capacity requirement; it is not directly related to
the provision of water supply related to growth within
the city.
Notes or Resources
Approved minutes from the June 23, 2022 Growth Management Citizens Committee meeting.
PowerPoint presentation from the June 23, 2022 Growth Management Citizens Committee meeting.
Agenda packet (staff report for the Water Distribution Facilities item begins on page 19) from the June 23, 2022
Growth Management Citizens Committee meeting.
Nexus/Funding Sources
•Developer fees
•Developer contributions
•User fees
Exhibit 2Carlsbad -v-~
TOMORR W
Sewer Collection System - Discussed June 23, 2022
Trunk-line capacity to meet demand, as determined by the appropriate sewer districts, must be provided
concurrent with development.
Key Takeaways from Committee Discussion
on Standard Options for Consideration
•Consider how the influx in ADUs (accessory
dwelling units) impacts pipes, the water
treatment plant and water usage; need to be sure
these units are captured
•Consider adding ADUs into future land use master
plans and overall city projections.
•Consider effective ways to estimate how much
capacity we need, and the type of infrastructure
future facilities will need. Assess how to best
estimate peak capacity in future.
•Assess legal ramifications if the city cannot keep
up sewer performance with housing demands
imposed by the state. Assess if we are still legally
required to grow.
•Assess if climate change threatens any city assets
or infrastructure. Climate change is a bigger threat
to water supply.
•Re-evaluate the fee structure for infill and sewer
connections.
1. Keep standard as it exists in Growth Management
Program.
Staff recommends retaining this standard in the Growth
Management Program in order to continue to require
sewer line connection and capacity concurrent with
development.
2. Remove standard from Growth Management Program.
3.Change standard (increase, decrease, modify metric,
etc.).
Notes or Resources
Approved minutes from the June 23,2022 Growth Management Citizens Committee meeting.
PowerPoint presentation from the June 23,2022 Growth Management Citizens Committee meeting.
Agenda packet (staff report for Sewer Collection item begins on page 16) from the June 23, 2022 Growth
Management Citizens Committee meeting.
Nexus/Funding Sources
•Developer fees
•Developer contributions
•User fees
Exhibit 3Carlsbad -v-~
TOMORR W
Wastewater Treatment - Discussed June 23, 2022
Sewer plant capacity is adequate for at least a five-year period.
Key Takeaways from Committee Discussion
on Standard Options for Consideration
•Determine if performance standards are the same
as the Leucadia District and other water districts.
Define how that process works.
•Consider effects of housing growth on sewage –
determine what happens when we are at capacity.
•Evaluate how growth outside of Carlsbad affects
plant capacity.
•Assess connection between recycled water
facilities and the water performance standards.
Evaluate need for a new recycled water
performance standard or other conservation
activities. Make standard more than just capacity.
•Evaluate potential for the city to sell extra capacity
with facilities to nearby cities.
•Evaluate if there is a potable reuse opportunity -
turning tertiary treated recycled water into
potable drinking water. Discuss expense of this
option.
1. Keep standard as exists in Growth Management
Program.
2. Remove standard from Growth Management Program.
Staff recommends removal of this standard from the
Growth Management Program. Sufficient planning
processes and efforts exist to maintain sewer system
capacity through the involvement within the Joint
Powers Authority and the city capacity.
3.Change standard (increase, decrease, modify metric,
etc.).
Notes or Resources
Approved minutes from the June 23, 2022, Growth Management Citizens Committee meeting.
PowerPoint presentation from the June 23, 2022, Growth Management Citizens Committee meeting.
Agenda packet (staff report for the Wastewater Treatment item begins on page 14) from the June 23, 2022, Growth
Management Citizens Committee meeting.
Nexus/Funding Sources
•Developer fees
•Developer contributions
•User fees
Exhibit 4Carlsbad -v-~
TOMORR W
Drainage - Discussed June 23, 2022
Drainage facilities must be provided as required by the city concurrent with development.
Key Takeaways from Committee Discussion
on Standard Options for Consideration
•Identify water quality considerations and develop
them into an integrated standard.
•Consider the percentage of graywater captured, as
well as other environmental conservation
measures.
•Consider a feasibility study and quantifying the
percent of graywater captured for reuse.
•Determine how water quality measures are
currently funded? Find out if there is an impact fee
and whether this is managed by the city’s
Environmental Sustainability Department.
•Consider updating the impact fee timeline more
frequently, potentially every five to 10 years
rather than 15.
•Consider control of stormwater important for
nearby beaches; and how to retrofit existing
facilities to accommodate stormwater flow.
•Consider ways to quantify the impacts of climate
change and review existing drainage standards for
100-year flood events and sea level rise based on
FEMA numbers.
•Consider differences with infill and what drainage
standards are necessary to account for the
differences.
1. Keep standard as it exists in Growth Management
Program.
Staff recommends that the drainage standard remain as
is in the Growth Management Program because it has
worked to support continued management of drainagefacilities in the city.
2. Remove standard from Growth Management Program.
3.Change standard (increase, decrease, modify metric,
etc.).
Notes or Resources
Approved minutes from the June 23, 2022, Growth Management Citizens Committee meeting.
PowerPoint presentation from the June 23, 2022, Growth Management Citizens Committee meeting.
Agenda packet (staff report for Drainage item begins on page 12) from the June 23, 2022, Growth Management
Citizens Committee meeting.
Nexus/Funding Sources
•Drainage area impact fees
•Gas taxes
•General fund
Exhibit 5Carlsbad -v-~
TOMORR W
From:Lance Schulte
To:Growth Management Committee; City Clerk; Council Internet Email; Michele Hardy; Eric Lardy
Cc:Boyle, Carrie@Coastal; "Prahler, Erin@Coastal"; Ross, Toni@Coastal; "Moran, Gina@Parks"; Homer,
Sean@Parks; "Smith, Darren@Parks"; info@peopleforponto.com
Subject:Public input for next Carlsbad Tomorrow Growth Management Committee meeting - Lawsuit over Carlsbad"sgrowth management plan will proceed - The San Diego Union-Tribune
Date:Monday, December 5, 2022 10:48:51 AM
Dear Carlsbad Tomorrow Growth Management Committee & City Council:
In advance of the next Carlsbad Tomorrow Growth Management Committee (CTGMC)
meeting please read the San Diego Union-Tribute article (see link below) regarding another
citizens’ group that has identified problems with the how the City has implemented voter
approved Growth Management in Carlsbad.
People for Ponto Carlsbad citizens (P4P) in conducting multiple official Public Records
Requests found the City falsely chose not to require Ponto developers to comply with the
Growth Management Open Space Standard like adjacent Aviara and Poinsettia developers
(LFMP Zones 19 & 22) were required to provide. P4P has provided the CTGMC the City’s own
maps and data that clearly show the City falsely ‘exempted’ Ponto developers from providing
the minimum 15% Unconstrained or Useable Open Space as required by Growth
Management. The false exemption was/is a clear violation of the Carlsbad Growth
Management Ordinance and Growth Management Open Space Standard. If Ponto developers
were required – like the adjacent developers of Aviara and Poinsettia – to provide the
required 15% Unconstrained or Useable Open Space the significant Ponto Park and South
Carlsbad Coastal Park needs and issues would be substantially moderated. ‘Unconstrained or
Useable’ Growth Management Open Space land use would also provide land that likely would
meet the CA Coastal Act and Carlsbad’s Local Coastal Program land use needs at Ponto for
“Coastal Recreation (i.e. Public Park)” and maybe “Low-cost Visitor Accommodations (i.e.
Campground)” relocation/expansion.
https://www.sandiegouniontribune.com/communities/north-county/carlsbad/story/2022-01-
02/lawsuit-over-carlsbads-growth-management-plan-will-proceed
Although the story above is old, and not a P4P effort or Ponto specific effort, it shows that
other groups have found similar “problems” like at Ponto with how the City did not and still
does not provide Growth Management required Park and Useable Open Space. Hopefully the
Citizens Carlsbad Tomorrow Growth management Committee will correct these errors and
make recommendations to acquire Ponto Park and for the City to provide the missing 30-acres
of Useable GM Open Space at Ponto.
P4P Carlsbad Citizens are not aware that the CTGMC has ever discussed the past (settled) or
current (active) citizens lawsuits regarding City implementation compliance with voter
approved Growth Management. But it seems like the facts/issues of both Growth
Management lawsuits are important to for the CTGMC to be aware of, discuss, and provide
data to support Growth Management recommendations to the Council. The CTGMC has a
duty, as noted in its mission (on CTGMC website), to understand and honestly consider these
issues as it makes its recommendations.
Thank you. You are responsible for Carlsbad Tomorrow!
Ponto vacant land is the best, and last viable and cost-effective opportunity we all get to
address the clearly documented South Carlsbad and Ponto Coastal Park needs and Ponto’s
false exemption of Growth Management required Unconstrained/Useable Coastal Open
Space. Your fellow citizens ask you to care about Carlsbad’s future and responsibly address
the Coastal Park and Open Space shortfalls at Ponto/South Carlsbad.
Thank you and Aloha Aina,
Lance
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From:Harry Peacock
To:Eric Lardy
Subject:Memo on my thoughts so far in developing the new Carlsbad Tomorrow document
Date:Tuesday, December 13, 2022 3:31:20 PM
Attachments:Growth Management Issues to Address.docx
Please see the attached memo from me to the Committee. I would like to have this sent out intime for tomorrow's meeting rather than me having to read this entire document as a general
statement of how I think we should address various issues.
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December 13, 2022
From: Harry Peacock, District 4 Representative, Carlsbad Tomorrow.
To: Carlsbad Tomorrow Committee.
Subject: My Thoughts on Things to Consider in Developing the New Growth Management Plan.
1. Housing vs. jobs (job types vs. housing affordability and locations). City needs to establish a real
balance which will reduce traffic demand problems which has major impact on air quality and global
warming. For example, city has the 2nd the greatest number of hotel rooms in San Diego County which
means there are a large number of low paying “hospitality” jobs in the city. Are we focusing on ways to
provide appropriate housing in the vicinity of the hotels to meet needs of those workers so they don’t
have to commute to their jobs? Using some of the vacant parcels on Palomar Airport Road. Also the
area north of the Porsche dealership and just across the street from Poinsettia Station for
affordable/multi-family housing could help address this problem as it would be near the many jobs at
the car dealers, the Kaiser clinic and the several hotels north of Poinsettia Road and the Poinsettia
neighborhood shopping center.
2. Traffic management through housing/business locations (i.e., balanced land use). Change land use
plan to bring jobs/housing into balance and housing and park access into balance. Adopt walkability
system for all future traffic planning and Traffic Demand Management.
3. Parks. Even distribution and more, than at present. Ponto is most needed location and will also help
address sea level rise problem and improve air quality be reducing vehicle travel to parks. Veteran’s
Park, as an example, is planned to provide neighborhood park needs for South Carlsbad (62% of the
population) yet this park is between 3 and 6 miles away from that population requiring excessive VMT
to connect to the park. This also requires that a significant portion of the park be devoted to providing a
parking lot. The current focus on “community size” parks require a significant portion of the park land
to be devoted to parking. Therefore, it is not unreasonable to subtract parking areas from being
included as “park” acreage and should not be counted as parks for the standard of park acreage per
1,000 people. There are several parks north of Cannon Road and west of I-5 totaling some 35 acres.
There are no parks at all south of Cannon Road and west of I-5. This puts more pressure on north city
beaches and parks which could be mitigated by acquiring land for a park at Ponto. Currently, lack of a
park in the Ponto area is part of litigation the city is already facing. Residents of the Ponto area,
specifically the San Pacifico Community have been specifically DENIED their local needed park area. The
rest of the city has benefited from the development of this area as it has provided its own recreation
facilities, has private streets which the city does not have to sweep, maintain or repair and has still paid
the same level of park-in-lieu fees as all other residential developments. In the future, city should
factor in hotel rooms and air B and Bs into the park acreage to people ratio. Also need to accept that
the city no longer has control over buildout.
4. Sea Level Rise (SLR) and need to replace and add facilities for beach access, public recreation, and
visitor serving commercial uses must be addressed in the new Plan.
a. City’s 2010 Ponto Vision Plan (rejected by the Coastal Commission) and 2015 General Plan update did
not consider SLR and how it would impact Coastal Open Space Land Use & Coastal Act “High-Priority”
Coastal Open Space Land Uses at Ponto. The 2017 Assessment shows Open Space land acreage and
Land Use impact in Carlsbad will occur almost exclusively at Ponto & South Coastal Carlsbad. How will
the city manage the continued growth in population, both within the city and within surrounding areas if
much of the land the beach-oriented activities now take place on are no longer useable? More demand-
yet less space to accommodate that demand.
b. Carlsbad Blvd. Redesign it in a manner to provide for campground site relocation, increased day use
parking, using the existing-abandoned Old South Carlsbad Blvd. right-of-way N & S of Poinsettia. Result
would be that 177 parking spaces would remain and 273 additional single-loaded 90-degree parking
spaces & a 2-way drive aisle of + 20’ for multi-use pathway or 546 additional double-loaded 90-degree
spaces & 2-way drive isle. Estimated cost for 273 to 546 new parking spaces and sidewalks on both
sides of Carlsbad Blvd would range from between $5.3 million to $7.6 million. The City’s current plan
AECOM of 11/26/13 is estimated to cost $75 million per Mayor Hall. The current plan would net only 86
more parking spaces instead of between 273 and 546. With the $70 million savings, the city can acquire
the 11-acre Ponto parcel for less than $10 million and provide much of the land needed to mitigate the
loss of camp sites and beach access lost to SLR.
5. Population density should be determined by occupant capacity of any given dwelling unit. We know
based on census data that this number will fluctuate over any given period of time, but the capacity that
is built into each unit must be the basis for providing services and facilities. A standard to apply would
appear to me to be 1.5 persons per bedroom rather than estimated population divided by estimated
dwelling units. This is an obvious paradigm shift in thinking necessitated by the State mandating
residential development requirements. To ignore it would be a major error in truly managing the
impacts of growth. This would recognize that the term “build-out” is no longer valid for any purpose
because of the State’s removal of local control over develop.
6. Agree there are two different types of open space, those that are useable by people for recreation
purposes and those that are unusable and undevelopable and reserved for protective habitat. Areas in
various current parks are counted as park “acreage” when in fact they are unusable and are more
appropriately defined as open space.
7. Open Space – habitat lands that can’t be used by people should not be counted as park acreage (for
example, 50% of Veteran’s Park is unusable by people due to protected habitat constraints).
8. Open Space – provide addition open space when redesigning or redeveloping streetscapes into
landscaped parkways that will qualify as “useable Open Space” per the GMP standard of Open Space.
9. Increase Park acreage per 1,000 population to 4-1 and add a 15-minute walk goal. Apply to city
facilities only as others have use restrictions, like the golf courses and resort/hotel facilities where you
have to pay to use the space and private neighborhood recreation facilities. For example, Lakeshore
Gardens and San Pacifico in my part of town have private community swimming pools and San Pacifico
has a basketball court, a volley ball court and two tennis courts which were paid for by the purchasers of
the homes in those neighborhoods. Asking those citizens to also pay for, what is for them, redundant
facilities, especially when they have no public park within over two miles of those neighborhoods is
discriminatory, plain and simple.
10. Paths and trails and mobility improvements. Path and trails are not always just for recreation
purposes. For example, the City failed to make a required pedestrian trail be constructed which
connects the trail system on the north side of Batiquitos Lagoon west of the freeway under the freeway
connecting that trail to the trail system on the east side of the freeway. This trail could also be designed
to be used by bicyclists. This would allow pedestrians and cyclists to avoid all the streets, intersections,
etc. crossing I-5 at Poinsettia. In fact, the bike trail segment was supposed to be part of the current I-5
widening to the point that the design and engineering had already been done before SANDAG scaled
back the I-5 widening so now the bike lane will not be built until 2050. City could build the path and
SANDAG would have to eventually pay the city back for the cost-plus accrued interest until SANDAG
pays back in 2050. This also begs the question of how do we make sure the city doesn’t fail to live up to
its regulatory role in making sure that what it is requiring is actually going to be done?
11. Have as our target that this is how we hope to see Carlsbad in the year 2050 and make assumptions
on that basis.
12. Include a standard on communications. My part of the city (the far southwest corner) has poor cell
phone service. Many times, workers coming to our neighborhood find they have no cell service from
their cell phone provider.
13. Address how to provide adequate electric vehicle charging station access.
14. Declare that “parks” are part of “open space” and change the Parks Master Plan, etc. to so reflect
what State Law states to remove the apparent current confusion over the intent of Measure C which
exempts trails and open space acquisitions from the general fund voting requirement.
15. Add fire stations to the current five in the city. One to serve beaches better by being placed near
the Carlsbad Blvd./Cannon Road intersection and the other in the southeast quadrant of the city which
currently has the greatest number of residents who fall outside of the five-minute response standard.
16. Establish some solar power facilities to service the city so that new development does not increase
demand on current fossil fuel electricity generation. Consider using developer fees to help pay for this if
facilities are not mandated on site for new developments, both residential and commercial.
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; melanie@melanieforcarlsbad.com
Cc:info@peopleforponto.com
Subject:Public input to the next upcoming meetings of Carlsbad Tomorrow Growth Management Committee, CarlsbadCity Council and Parks and Planning Commissions - LCPA and Growth Management-Parks Master Plan Updates -Parks & Open Space
Date:Tuesday, December 13, 2022 11:37:02 AM
Attachments:CTGMC key issues and suggestions -2022-12-6.pdf
Dear Carlsbad Tomorrow Growth Management Committee, Carlsbad City Council, Parks and
Planning Commissions, , CA Coastal Commission and CA State Parks:
As the City has requested specific reference regarding public input, I ask you to please deliver to the
those address this email and attachment as public input for:
1. the CTGMC’s 12/15/22 meeting,
2. the next Carlsbad Council meeting,
3. the next Carlsbad Planning and Parks Commission meetings on the Parks Master Plan and
Growth Management Program Updates, Ponto Planning Area F and Site 18 land use changes,
and Local Coastal Program Amendments, and
4. as public input to the CCC on Carlsbad proposed Local Coastal Program, and
5. as public input to Carlsbad’s proposed Local Coastal Program Amendment.
The initial version of attached file was sent to you 8/8/22. The attached updated file should replace
that older file as there is new data on significant tax-payer cost savings from Pronto Park relative to
PCH Relocation, and updated examples of how Coastal Open Space can be cost-effectively
persevered and increased. Both Coastal Parks and Open Space are important Carlsbad and State of
CA issues.
· Parks: Updated data shows that a 11.1 acre Ponto Park would now cost less $20 million to
buy and build. This is less than a City Pool Renovation. Carlsbad’s Old City Council planned
to spend $65 to $80 million in Carlsbad tax-payer dollars to address the Citywide need for a
significant Coastal Park in South Carlsbad with a 2.3 mile PCH Relocation. The City identified
in 2001 other pay-payer funds were highly unlikely. $65 to $80 million would only ‘free-up’
15.8 acres of narrow PCH Median (City documented “Surplus Land Area #4 & #5”). As
People for Ponto Citizens have been saying for years that Ponto Park is the better Park
solution to the documented Coastal South Carlsbad Park needs – a citywide need. The
CTGMC should include that citywide Park need and the logical, better and tax-payer
responsible Ponto Park solution to that citywide Park need in your CTGMC recommendations
to City Council.
· Open Space: Updated data shows how documented GM Open Space shortfalls can be
properly and responsibly address in a collaborative citizen-based “Local Facilities Zone
Useable Open Space Correction Plan” approached. Also the need to maintain the 15% GM
(Useable) Open Space Standard will be critical in the future to maintain Open Space and
prevent future conversion of Open Space to residential land use as part of Housing Plan
updates.
For the CTGMC; Parks and Open Space are the 2 most critical/special of 6 Key Growth Management
Program Update Issues and Suggestions the CTGMC should take to properly address these 6 key
Growth Management Issues.
• Please read the Updated data and Suggestions.
• Please responsibly address the Growth Management issues of a citywide Park need
for Coastal South Carlsbad as listed in the attached Suggestions. Include a South
Carlsbad Coastal Park in your recommendations to the City Council. Acknowledge
Ponto Park as the best and most tax-payer efficient solution to address that
documented citywide park need.
• Please in your recommendations to City Council retain and enforce the Open Space
Standard, and fix past errors made in falsely exempting certain developers in certain
areas in the City from complying with the Growth Management Open Space
Standard that other developers in other areas are required to provide.
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.
Happy holidays and with Aloha Aina,
Lance Schulte
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CTGMC key issues and suggestions – People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 1 of 9
CTGMC needed actions: 6 key issues and suggestions – from People for Ponto Carlsbad Citizens
8/8/22 1st submittal, 12/12/22 updated 2nd submittal
Following are 6 key major Growth Management Standards issues of citywide relevance that the Carlsbad
Tomorrow Growth Management Committee (CTGMC) needs to act on, and citizen “Suggestions to
CTGMC” on how to honestly and responsibly act on these 6 key issues in the CTGMC’s recommendations
to the New City Council. This Update includes new information (pp 5-6) on the improved affordability of
Ponto Park, and on how GM Open Space shortfall can be repaired. We hope the CTGMC will act
honestly to make recommendations that truly and responsibly address known documented shortfalls in
both Parks and GM Open Space. Responsible recommendations by the CTGMC can provide a
sustainable Quality of Life to future Carlsbad generations and visitors. Only you own your
recommendations.
1. The State of CA is forcing Carlsbad and all cities/counties in CA to provide for unlimited or Infinite
Population and Visitor growth. So there will be an Infinite population & visitor demands for Parks,
Open Space, water, and demands on our roads/transportation systems, and other Growth
Management (GM) Quality of Life facilities. These infinite increases in population and visitor
demand will come from high density development that requires more public Parks and Open Space
to balance the high-densities. Carlsbad’s new GM Standards will have to provide for a system of
Infinite proportional increases in the supply of Parklands, Open Spaces, water, transportation
facility capacity, etc. or our Quality of Life will diminish.
a. Suggestions to CTGMC:
i. Completely restructure the General Plan, Local Coastal Program and GM Program to
clearly recognize these facts and State requirements to proportionately provide
public facilities to maintain/improve Carlsbad GM Quality of Life Standards for this
Infinite growth of Population and Visitor demands.
ii. Being a Coastal city Carlsbad has an added responsibility to proportionately
maintain/improve providing High-Priority Coastal land uses (Coastal Recreation
{i.e. Public Parks} and Low-cost Visitor Accommodations) needed at a regional and
statewide level to address visitor needs for Coastal Recreation, access, and
affordable accommodations. Carlsbad needs to work with the State of CA Coastal
Commission to completely restructure Carlsbad’s Coastal Land Use Plan to
addresses the State’s requirement to provide an Infinite amount high-priority
Coastal land uses for those Infinite Population and Visitor demands.
iii. Trying to ignore these Infinite demands for Carlsbad’s Quality of Life facilities –
like Parks and Open Spaces is a path to disaster and the ultimate degradation of
Carlsbad’s Quality of Life.
2. Carlsbad has a huge Jobs v. Housing supply imbalance – far too many jobs around the airport for
our amount of housing. This creates negative and costly land use and transportation planning
distortions that radiate from the Airport Central Jobs through Carlsbad in all directions. CA
Housing law penalizes umbalanced cities like Carlsbad by requiring more housing in Carlsbad to
bring jobs/housing ratio into balance. Carlsbad can correct this imbalance by 1 of 2 ways: 1) greatly
increase housing supply (and thus increase the need and City expense for more GM Quality of Life
facilities), or2) more logically and cost effectively greatly decrease the amount of Jobs land use, so
Carlsbad’s housing supply is in balance with jobs. These jobs will move to surrounding Cities that
have more housing than jobs. Rebalancing by reducing jobs land use creates added benefits for
Carlsbad and our region by reducing Carlsbad’s peak-hour job commute traffic volumes and
CTGMC key issues and suggestions – People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 2 of 9
vehicle miles traveled (VMT), and by reducing the costs Carlsbad (and other cities and the region)
have to pay to accommodate inter-city commute traffic. If Carlsbad reduces jobs land use will also
reduce the amount of housing the State of California and SANDAG requires Carlsbad provide in its
Housing Element thus reducing forcing incompatible high-density development into established
neighborhoods and pressure to convert useable GM Open Space lands to housing land use.
a. Suggestions to CTGMC:
i. Carlsbad can logically and cost effectively balance Jobs/housing supply by
updating Growth Management Policy to reduce jobs to be in balance with housing
by changing some of Carlsbad’s General Plan land use around the airport into
several high-density residential mixed-use Villages. The City has started some of
this, but can expand this effort but has not planned creating mixed-use village
environments. These high-density villages will reduce jobs and provide both high-
quality and high-density (affordable) housing within walking/biking distance to the
major job center and new neighborhood commercial and Park uses in the Villages.
ii. Prioritize transportation investments in safe bike paths, walking paths between
Carlsbad’s Central Jobs Core around the airport and Carlsbad’s housing, particularly
strongly connecting these new high-density mixed-use villages with the Central Jobs
Core.
iii. Update General Plan land use and housing policy to reduce concentrations of
higher-density housing except around the airport jobs core.
iv. Recognize the central Airport jobs core is ‘Carlsbad’s New Urban Downtown and
“Transect Plan” accordingly toward lower densities on the City periphery.
3. Although some very critical areas (such as the Coastal lands at Ponto) are still vacant and can be
wisely used for critical GM Quality of Life needs, much of Carlsbad is largely developed.
Redevelopment of developed land will require creating increased supplies of Parkland, Open
Spaces, transportation capacity, and other Quality of Life facilities.
a. Suggestions to CTGMC:
i. Completely rethink all City planning on existing vacant lands to assure that
remaining vacant land is planned and being used wisely and fairly distributed to
address critical Quality of Life needs in those areas, and not squandered on
redundant land use. The location of vacant land to address critical Park & Open
Space needs should be preserved with land use planning.
ii. Work with the State and CA Coastal Commission to preserve our Finite vacant
Coastal lands for High-Priority Coastal Land Uses (Coastal Recreation {i.e. Public
Parks} and Low-cost Visitor Accommodations and services) for the Infinite
population and visitor demands both internal and external to Carlsbad that are/will
be placed on them.
iii. Fully and at the very beginning of any Carlsbad General Plan, Local Coastal Program
and Growth Management Program actions going forward fully disclose, map and
require consideration of the impact of future sea level rise and coastal erosion on
Coastal land acres and land uses. Carlsbad has lost and will accelerate loosing acres
of Coastal land and High-priority Coastal Land Uses. Carlsbad must know, see, and
discuss these losses BEFORE making any land use decisions in Carlsbad’s Coastal
Zone and any vacant Coastal Land.
4. Carlsbad General Plan & Growth Management Plan do not provide a fair distribution of
adequately sized City Parks for all Carlsbad families. Veterans Park is a classic example. What will
CTGMC key issues and suggestions – People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 3 of 9
be the City’s largest park is only about 1-mile away from three other major City Parks (Zone 5, and
the future Robinson Ranch and Hub Parks). This is a poor and unfair distribution and a misallocation
City Park land resources. Saying Veterans Park is ‘the park to serve SW, SE, and NE Carlsbad families’
(the overwhelming major/majority funders of veterans Park) when those families are upwards of 6-
miles away on major commercial arterials that kids can’t logically/safely use is false and unfair.
Most all the funding (developer fees) to build Veterans Park come from the SW, SE and NW Carlsbad
but those areas are denied the Park the paid for. Veterans Park is inaccessible by almost all its
intended users except by driving their cars and then storing their cars in parking lots on Parkland
thus making less park land available for actual park use – this makes little common sense and is a
great waste of tax-payer funds. This is dysfunctional along with being very unfair to families in SW,
SE and NE Quadrats that are denied park acres near their homes which they funded. Carlsbad’s
Park Master Plan maps ‘Park Service’ areas of existing known Park Inequity or Unfairness
(dysfunction), to show where new City Park investments should be made (See City map image
with notes below).
The Trust for Public Land provides a Park-Score to compare both a City’s amount of park acres and
the ‘fairness’ of access (within a 10-minute walk) to parks. Carlsbad is below national averages in
both park acres and fair access to parks. Carlsbad is also well below what our adjacent Coastal
cities of Encinitas and Oceanside provide. Carlsbad only requires 3 acres of Park land per 1,000
population, while Encinitas and Oceans require 5 acres - 67% more than Carlsbad – of parkland.
Also, Encinitas and Oceanside require parks to be within a 10-mintue walk to their citizens and
families. Carlsbad has no such requirement.
a. Suggestions to CTGMC:
No Coastal Park in South Carlsbad
• Appx. 6 miles of Coast
with out a Coastal Park is a
City & Reg ional 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
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CTGMC key issues and suggestions – People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 4 of 9
Carlsbad should change its General Plan, Parks and Growth Management Standards and
CMC 20.44 to:
i. Be Above Average Nationally in both providing park acreage and in locating
adequate park acreage to be within a 10-minute walk to all neighborhoods.
ii. Raise its minimum park acreage standard to 5 acers per 1,000 population, versus
the current low 3 acres per 1,000. Carlsbad should be at least as good as Encinitas
and Oceanside in requiring 5 acres, not 40% below what our adjacent Cities
require/provide.
iii. Raise its park location standard to require an adequately sized park be provided to
serve the neighborhood population within a 10-minute walk for all
neighborhoods.
iv. Prioritize City Policy and Park Budgets and investments to achieve park fairness in
‘Park Unserved areas’ identified by Carlsbad’s Park Master Plan.
v. Per Carlsbad’s Municipal Code Chapter 20.44- DEDICATION OF LAND FOR
RECREATIONAL FACILITIES to require developers in ‘Park Unserved areas’ and in
areas that do not have an adequately sized (5 acres per 1,000 population) park
within a 10-minute walk to provide their developments required Park land acre
dedication in actual Park land within a 10-minute walk to their development.
vi. Update the City’s Park-in-lieu fee to assure the fee is adequate to actually buy the
amount of park land a developer is to provide within a 10-miunte walk of their
development. The City’s current ‘Park-in-lieu-fee’ is far too low and inadequate to
actually buy land in area surrounding the proposed development.
vii. Only allow developers to pay a Park-in-lieu-fee where there is an adequately sized
park (provide 5 acres per 1,000 population) within a 10-minute walk of their
development, and growth management planned future development in that area
will not require more park land to provide 5 acres per 1,000 population) within a
10-minute walk.
viii. Consider updating Park policy to provide more multi-use flexibility in park land acres
and development on Parks. Many Carlsbad Park acres are developed/dedicated to a
single-purpose use, and unavailable for other park uses.
ix. Consider eliminating car parking lots from land that can be counted as parkland; or
by significantly limiting park land used for parking to around 5%.
x. Eliminate the counting of ‘GM Constrained and Unusable land’ and Protected
Endangered Species Habitat land as Park land. GM Constrained/Unusable lands
are undevelopable. Protected Habitat lands are by definition not useable for
development by people. Habitat is dedicated for plants and animals. Parks are
open spaces dedicated intended for people. Parkland calculations should exclude
Unusable lands and Protected Habitat lands and only count 100% people Useable
land as Park land. Where Park land abuts Habitat land a sufficient buffer space shall
be provided to prevent people mixing with animals (ex. Rattlesnakes, etc.) and
animals from people (habitat disturbance or destruction). This buffer area should
not be counted as Park or Habitat acres, but as natural/developed buffer open
space acres, and can be counted as part of the City’s 15% Growth Management
‘Aesthetic open Space’.
5. Carlsbad’s Coast is the most, if not the most, important feature of Carlsbad; and is consistently
identified by citizens and businesses and our Community Vision. Carlsbad’s Coastal Parks (west of
the I-5 corridor) are grossly unfairly distributed. Carlsbad’s Coastal Parks do not fairly match the
CTGMC key issues and suggestions – People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 5 of 9
locational needs of the population. North Carlsbad that is 38% of Carlsbad’s population and has
10 Coastal Parks totaling 37+ acres in size. South Carlsbad that is 62% of Carlsbad’s population has
0 [ZERO] Coastal Parks totaling 0 [ZERO] acres. Again, Carlsbad’s Park Master Plan maps this
citywide unfairness (dots show park locations and circles show the area served by each park) and
says that the City should look at buying and building New Parks in these areas that are unserved by
City Parks (are not covered by a circle). The GM Update should correct this citywide unfair
distribution of City Parks by making plans for new Park purchases to create City Parks in these
unserved areas of Park Inequity.
To address citywide Coastal Park unfairness the current City Council wants to spend $60-85 million
in Carlsbad tax-payer funds to Relocate 2.3 miles of constrained Pacific Coast Highway median to try
to make some of the narrow PCH median ‘useable’ by people. 2001 and 2013 City PCH Relocation
studies identified only a small amount of ‘people-useable acres’ would be created next to PCH. The
$60-85 million tax-payer cost ($26-37 million per mile) does NOT add one single square foot of new
City land, it only inefficiently rearranges a small amount PCH median. The City can most tax-payer
cost effectively provide needed sidewalks and bike improvements along the outside edges of PCH
without PCH Relocation. The City’s 2001 PCH Relocation Financial Study and 2013 PCH Relocation
Design both indicated minimal useable land could be achieved by Relocation, and that the very high
tax-payer cost to do so would be very difficult to fund. The City has known for well over 20-years
that PCH Relocation is a high-cost and a poor solution to address the Citywide Coastal Park
unfairness in South Carlsbad.
However, a better and far less costly solution to correct Citywide Coastal Park unfairness and
provide a much needed South Carlsbad Coastal Park is to simply buy currently vacant land that is
for sale. The City did this (although the City actually bought existing homes) when it expanded Pine
Park. Carlsbad tax-payers have used the City’s own data to compare the tax-payer Cost/Benefits
of simply purchasing vacant land v. trying to rearrange existing City owned land at PCH. Simply
buying vacant land saves tax-payers saves tax-payers over $32.7 to $7.7 million. Please read the
following data files:
2022-June General Comparative tax-payer Costs/Benefits of Completing PCH, 2.3 miles of
PCH Modification (Island Way to La Costa Ave.), and 14.3 acre Ponto Park (Kam Sang) to
address planned loss of 30+ acres of Coastal Open Space Land Use at Ponto in South
Carlsbad: Part 1 of 2.
City’s PCH Modification Proposal Area Map with notes on usability Constraints and Issues:
P4P Input: Part 2 of 2
The most recent (9/19/22) land sale of 11.1 acre Ponto Planning Area F was less than $8
million (less than $706,000 per acre).
Buying and developing this 11.1 acre Ponto Park would cost less than $20 million
assuming a 10% profit to the new land-owner, and $1 million per acre park construction
cost like our newest Buena Vista Reservoir Park. The cost to help correct a Citywide
Coastal Park unfairness by simply buying & building a much needed 11.1 acre Ponto Coastal
Park would cost tax-payers less than the recently approved Measure J City Monroe Street
Pool Renovation. Investing less than $20 million ($1.8 million per acre) to buy and build an
11.1 acre Ponto Coastal Park is a great tax-payer value v. $65-80 million in tax-payer funds
to rearrange 15.8 acres of narrow strips of constrained PCH median (City documented
“Surplus Land Area #4 &5”) for some minimal people use at a tax-payer cost of $4-5 million
per acre. The overall and per acre costs of buying/building Ponto Park are over 2 to 3
times better value for tax-payers than PCH Relocation/rearrangement.
CTGMC key issues and suggestions – People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 6 of 9
The City Council could/can buy land for Open Space (Parks are the most useable of the City’s
4 Open Space categories) under voter approved Prop C Open Space land acquisition
authority. The City has been advised to buy Ponto Park under Prop C per the City’s
settlement of a Growth Management law suit.
The Park and Coastal Park Inequity at Ponto and Coastal South Carlsbad is clearly a citywide issue.
Park and Coastal Park Inequity at Ponto and Coastal South Carlsbad as it is unfair to the vast
majority of Carlsbad citizens and their families as 62% of Carlsbad is in South Carlsbad. Park and
Coastal Park Inequity at Ponto and Coastal South Carlsbad is unfair to our major Visitor serving
industries (and tax generators) in South Carlsbad. Park and Coastal Park Inequity at Ponto and
Coastal South Carlsbad are clearly inconsistent with the CA Coastal Act, Carlsbad’s Community
Vision, and common sense. The Coastal South Carlsbad Park Inequity is also unfair to North
Carlsbad because South Carlsbad’s Coastal Park demand is being forced into Coastal North Carlsbad
and congesting those parks, and adding to Coastal North Carlsbad traffic and parking impacts. It
also increases greenhouse gases and VMT as it forces longer vehicle trips.
a. Suggestions to CTGMC:
i. 11.1 acre Ponto Planning Area F has a specific Local Coastal Program Land Use Policy
that says The City of Carlsbad must for the Ponto Area LCP ‘Consider and Document
the need for Coastal Recreation (i.e. Public Park) and or Low-Cost Visitor
Accommodations west of the railroad tracks (at Ponto) prior to any Land Use
change. The discussion of Parks by the CTGMC is such a situation that requires the
CTGMC to consider this adopted LCP Land Use Policies. Official public records
requests have shown the City never followed this LCP Land Use Policy
Requirement during the 2005 Ponto Vision Plan and 2015 General Plan Update,
and in 2010 the CA Coastal Commission rejected the Ponto Vision Plan and told
the City in 2017 that that land uses at Ponto could change based on the need for
Coastal Recreation and/or Low Cost Visitor Accommodations. The Mello II LCP
that covers most of Carlsbad’s Coastal Zone also has Land Use Policy 6.2 for the City
to consider a major park in the Batiquitos (Ponto/South Carlsbad) area. The City has
only implemented 1/6 to 1/3 of this policy. The CTGMC should fully evaluate the
citywide/South Carlsbad and local Ponto need for Coastal Parks as required by the
City’s adopted LCPs and CA Coastal Act.
ii. Carlsbad’s 2015 General Plan Update and Growth Management Plan (GMP) did not,
and was not updated to, consider the 2017 Sea Level Rise (SLR) Impact report
showing the loss/impact on 32+ acres of Carlsbad’s Coastal Land Use acreage in
South Carlsbad – primarily Open Space Land Use (beach and Campground). Both
the General Plan (and Local Coastal Program Land Use Plan) and GMP should be
updated to account for the loss and replacement of these 32+ acres of high-
priority Coastal Open Space Land Use due to SLR. The updates and the CTGMC
should use the newest CA Coastal Commission SLR Guidelines/science, not the old
guidelines used in 2017. Carlsbad’s LCP and CA Coastal Act Land Use Polies call for
‘upland relocation’ to replace the SLR loss of high-priority Coastal Land Uses.
iii. The availability over the past several years of the last two sufficiently sized vacant
lands suitable for a Ponto/South Carlsbad Coastal Park is a citywide issue. If these
last two vacant lands are lost to development forever future generations will have
lost the last opportunity for the needed South Carlsbad Coastal Park. The 5/3/22
Citizen requests for the City to jointly study acquisition of one or both these last
vacant lands for a needed (and only possible) true and meaningful Coastal Park for
CTGMC key issues and suggestions – People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 7 of 9
South Carlsbad should be recommended by the CTGMC. The CTGMC should
recommend Carlsbad’s GMP be updated to incorporate Parkland acquisition of
these last opportunities to provide the needed Coastal Park for South Carlsbad.
6. Carlsbad Growth Management Open Space Standard is that 15% of all the Useable (unconstrained
and fully buildable) areas is to be preserved as Useable Open Space, and that all the 25 Local Facility
Management Plans (LFMP) show how that 15% is provided. The City says:
Yet the City has mapped and documented that this 15% Useable Open Space Performance Standard
was not complied with. The City also acknowledges that without changes to current City planning
the 15% Useable Open Space Performance Standard will never be complied with. The City
acknowledges that only 13% has/will under current plans ever be provided. This missing 2% equals
501 acers of lost GM Open Space the GMP promised citizens. Carlsbad law the Growth
Management Ordinance 21.90, and section ‘21.90.130 Implementation of facilities and
improvements requirements’; provide guidance on how non-compliance with a Performance
Standards is to be handled.
a. Suggestions to CTGMC:
i. Retain the GM Open Space Standard of 15% of all unconstrained and developable
land is maintained as Open Space. If the City removes the Open Space Standard, it
will allow and encourage land use changes to remove GM Open Space and replace
with development.
ii. The CTGMC should make a recommendation that an inventory of all 25 LFMP
Zones be conducted and an inventory of each LFMP Zones provision of at least
15% Useable Open Space shall be compiled. No LFMP Zone shall be allowed to be
“exempt” from this inventory. The City’s computerized GIS mapping system makes
it easy and clear as shown in the following City GIS map for LFMP Zone 9 (aka
Ponto).
OPEN SPACE
A. Performance Standard
Fifteen percent of t he total land uea in t he Local Facility Menagement Zone (LFMZ) exclusive
of environmentally const rained non-developable land must be set aside for permanent open
space and must be a11ai I able concurrent with development.
CTGMC key issues and suggestions – People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 8 of 9
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]
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CTGMC key issues and suggestions – People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 9 of 9
iii. In instances like LFMP Zone 9 (above image) that clearly did not provide at least 15%
Useable Open Space and/or were falsely “exempted” the CTGMC should
recommend that a Local Facilities Zone Useable Open Space Correction Plan shall
be developed that explores the GM Open Space use/reuse of City land, land use
planning requirements, and/or possible acquisitions of remaining vacant land acres
to make up for any shortfall in meeting the 15% Useable Open Space in that a Zone.
An example of this in LFMP Zone 9 is that the City’s regional Rail Trail will convert 2-
lanes of almost all of Avenida Encinas to wider buffered bike lanes and an adequate
portion of the converted 2 vehicle lanes can be landscaped (v. just painting strips as
a buffer) to provide a safer/better bike lane buffer within a GM compliant Open
Space. 2 vehicle lanes in Windrose Circle could also be similarly landscaped and
converted to GM complaint Open Space. This is just one example of a cost-effective
means to add GM Open Space that developers were falsely allowed to remove.
iv. A Local Facilities Zone Useable Open Space Correction Plan should involve a
Citizens Advisory Committee composed of citizens within the impacted Zone and
appointed by the Council Members representing the Zone, and a representative of
each vacant land owner over of over 1-acre in size.
v. Consistent with the Growth Management Ordinance land use changes and
development applications within a Local Facilities Zone Useable Open Space
Correction Plan Zone shall be deferred until the applications can considered with (or
after adoption of) a Local Facilities Zone Useable Open Space Correction Plan.
From:Don Christiansen
To:Growth Management Committee
Subject:Colorado River users meet amid crisis concerns--Note the nexus with electric power
Date:Wednesday, December 14, 2022 10:33:13 AM
G'Day fellow Growth Management Committee members!
I think the following article in today's UT was timely and relevant to tomorrow's meeting.
Please note the following quote: "Lake Powell's drop last March to historically low water levels raised worries about losing
the ability---perhaps with the next few months---to produce hydropower that today servesabout 5 million customers in seven states."
At next month's meeting we will be discussing Local electric power generation.
http://enewspaper.sandiegouniontribune.com/infinity/article_share.aspx?guid=e0c7dd45-
2294-4e8e-b363-0a677405977c
All the best,
Don ChristiansenCarlsbad Tomorrow Committee member
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1
Date: December 14, 2022
To: Growth Management Citizens Committee (and members of the public)
From: Steve Linke, Traffic & Mobility Commission
Subject: Circulation performance standard
Summary
• Staff’s proposed update to the Traffic Impact Fee (TIF) Program appears reasonable, and
our committee should support the approach and recommend it be reviewed by the
Traffic & Mobility Commission as soon as possible.
• However, the impact fee is only one component of the General Plan and Growth
Management Plan (GMP) circulation requirements; it is not a “performance standard”;
and it only addresses general, indirect impacts of developments.
• The other major component is the multimodal (pedestrian, bicycle, transit, and vehicle)
level of service (LOS) framework, which works in parallel with the impact fee. The
General Plan requires this approach, and our committee should recommend that it be
fully implemented to address the direct, site-specific impacts of developments.
• To strengthen the LOS framework, our committee also should recommend that staff, in
conjunction with the Traffic & Mobility Commission, completes the establishment of the
pedestrian, bicycle, and transit LOS systems and requires the study of vehicle congestion
mitigation at intersections.
Impact fee component of growth management
For the impact fee, a list is compiled of the larger improvement projects around the city that
will complete the proposed mobility network in a general fashion. Then, the projected costs are
divided up such that developers pay pre-determined fees based on the number and type
residential units or commercial square footage they are adding.
The update, which is now finally in progress after promises back in 2015 when the General Plan
was updated, will shift the focus from vehicle projects to pedestrian and bicycle projects. It also
will shift the fee basis from the number of vehicle trips to person miles traveled (PMT), all of
which is reasonable.
Looking at the Solana Beach program, on which our update is apparently based, the program is
otherwise largely indistinguishable from Carlsbad’s current TIF Program. For example, Solana
Beach’s PMT-based impact fee programs charges a one-time flat fee of $1,288 for each
predicted residential person trip. And the number of predicted person trips is virtually identical
to the predicted vehicle trips that Carlsbad currently uses.
The key point here, though, is that this is not a growth management “performance standard”
2
and only addresses indirect cumulative citywide effects of development. It does not necessarily
account for specific needs in and around individual project sites. Also, this is a general fee that
goes into a pooled fund that finances citywide projects, and the fund likely will be insufficient to
finance the projects without city (taxpayer) involvement.
LOS component of growth management
As I have detailed in previous communications, under growth management, developers also
must pay their fair shares to fund projects that mitigate their direct impacts to the areas in and
around the project site. Based on the General Plan and GMP, these direct impacts are
determined by assessing pedestrian, bicycle, transit, and/or vehicle LOS as the performance
standard, depending on which modes are prioritized on the streets surrounding the project.
Some developments may be in areas that are not congested and have ample multimodal
facilities, in which case they would only pay the standard impact fee to mitigate their
cumulative indirect effects. Other developments that add significant new users of the various
modes to localized areas that are congested or lack sufficient multimodal facilities would be
required to fund additional local improvements to mitigate their direct impacts.
For example, developments could be required to make improvements like high-visibility
crosswalks, painted bike lanes, transit shelters, etc. Vehicle-wise, developments in the College
Boulevard extension area would be required to fund part of that project, and developments
that add traffic to congested intersections may be required to fund turn-lane enhancements, as
has been the practice in Carlsbad for the last 30+ years.
Further, given the 2015 General Plan update, developments that add vehicle traffic to streets
that have been exempted from growth management due to over-congestion should be
required to implement measures to reduce vehicle usage—Transportation Demand
Management (TDM)—although that still has not been fully implemented.
Conclusion
The Solana Beach municipal code and impact fee program call the program a means of
mitigating overall cumulative impacts that would be difficult to mitigate on a project-by-project
basis, and they go on to say that the impact fee is not meant to replace exactions or other
measures required to mitigate site-specific impacts of developments.
Thus, these parallel “impact fee” and “direct mitigation” approaches continue to be the
standard to account for all development impacts.