HomeMy WebLinkAbout2023-04-20; Growth Management Citizens Committee; ; Committee BusinessMeeting Date: April 20, 2023
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
Discuss the following topics:
•Quality of Life Topic: beach access and public access. Review and discuss proposed language
from committee members for inclusion in the quality of life recommendations, including
appropriate title for the document. Updated quality of life recommendations available HERE.
•Review Draft Committee Report. Review and discuss the final draft committee report on the
recommendations for a new plan to manage growth in the future. Address requested
committee edits. Take a vote on approval of the report. Report available HERE.
Fiscal Analysis
This action has no fiscal impact.
Environmental Evaluation
In keeping with California Public Resources Code Section 21065, this action does not constitute a
“project” within the meaning of the California Environmental Quality Act in that it has no potential to
cause either a direct physical change in the environment, or a reasonably foreseeable indirect physical
change in the environment. Therefore, it does not require environmental review.
Public Notification and Outreach
This item was noticed in keeping with the Ralph M. Brown Act and it was available for public
viewing and review at least 72 hours before the scheduled meeting date.
GROWTH MANAGEMENT CITIZENS COMMITTEE @) Staff Report
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Growth Management Citizens Committee
DRAFT REPORT
APRIL 2023
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TABLE OF CONTENTS
Executive summary .................................................................................................................. 5
History ...................................................................................................................... 8
Growth Management Program ................................................................................ 8
Carlsbad Tomorrow: Growth Management Citizens Committee ........................... 18
Committee recommendations ............................................................................... 24
Performance standard recommendations.......................................................... 24
Supplemental quality of life recommendations ................................................. 39
Next steps .............................................................................................................. 42
Committee work plan ............................................................................................ 44
Appendices
1.Committee reference materials
2.Committee meeting materials
3.Public comments
4.Resource documents (city plans and policies)
5.Website resources
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Executive summary
Ideally situated in north San Diego County, Carlsbad residents enjoy a great climate, beautiful
beaches and lagoons and abundant natural open spaces. A thriving and diverse business
community, well-planned neighborhoods and infrastructure that has kept pace with
development all speak to the city’s high standards and excellent quality of life. The city’s
Growth Management Program has played an important role in providing services and
regulating growth, which have helped preserve this quality of life.
The first step of a multi-year process to create a new approach to managing growth included
the creation of the resident-led Carlsbad Tomorrow Growth Management Citizens Committee
by the City Council. The committee met from March 2022 – April 2023 to review and identify
key elements of a new plan to manage growth in a way that maintains excellent quality of life
and ensures compliance with state laws.
The mission of the Carlsbad Tomorrow Growth Management Citizens Committee is to promote
balanced consideration of a range of perspectives on issues affecting the future growth and
quality of life in Carlsbad and to identify the key elements of a new plan to manage growth in
Carlsbad in a way that maintains an excellent quality of life while also complying with state law.
Why now?
The City of Carlsbad’s growth management program was created in the late 80s and is largely
credited with maintaining the city’s excellent quality of life, well-planned infrastructure and
financial health over the past 35+ years.
In recent years, new state laws have been passed that render some parts of the city’s
growth management program unenforceable, including putting a limit on how many
new homes can be built in the city.
The state laws are meant to address a critical statewide shortage of housing by making
it more difficult for cities to deny new housing projects.
About the committee
Over the course of 15 meetings, the Carlsbad Tomorrow Growth Management Citizens
Committee learned about and discussed each of the existing growth management program’s 11
public facility “performance standards,” along with other issues the group felt were important
to maintaining Carlsbad’s quality of life.
Performance standards refer to the level of service for public facilities such as roads,
sewer pipes, parks and libraries, that needs to be maintained to meet the needs of new
residents and ensure Carlsbad’s excellent quality of life.
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Under the current growth management program, developers either pay fees toward or
build the infrastructure and amenities needed to maintain these standards based on the
new residents who will live in their housing.
About this report
The purpose of this report is to communicate the committee’s recommendations for City
Council’s consideration.
Recommended Growth Management standards
The committee is recommending removing standards related to fire stations, schools, and city
administrative facilities because other plans are already in place to ensure the city’s needs are
met in the future. The committee recommends keeping standards for the following, which
address:
Libraries
Parks
Open space
Traffic and mobility
Water distribution system
Sewer collection system
Drainage
The committee’s specific recommendations for standards on each of these topics are addressed
later in this report.
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“Standards” are typically tied to development fees. The committee understood there are
implications with fees and that new development cannot be required to pay for existing
deficiencies. The next step is to complete technical nexus studies to determine how these
standards can be maintained, at what cost, and what percentage could be paid for or provided
by developers.
[TITLE TBD – accompanying document]
The committee also explored several issues that were ultimately deemed to be outside the
scope of a Growth Management Program but important to the city’s future quality of life. A
summary of these issues recommended for City Council’s consideration are detailed later in this
report and include:
Arts and culture Open space
Energy
Updates to Proposition H
Public facility fees
Seniors/aging community
Homelessness Transportation and mobility
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History
In the 1980s, concerns about the pace of development took center stage, with debates over
how and how much the city should grow. At that time, based on land use plans in place,
Carlsbad would reach about 250,000 in population once all the major residential development
was complete. To address concerns, the city worked with the community to craft an approach
to managing growth, including housing caps, standards for public facilities and fees to ensure
new growth paid its own way.
The ensuing years have validated this community-driven and developer-funded approach.
Carlsbad’s infrastructure has remained a top priority, with an expansive road network and a
vast array of pipes and other infrastructure that have been well-planned and regularly
maintained.
The city features over two dozen public parks, three public pools, nearly 70 miles of city trails,
and three well-utilized libraries that foster life-long learning and community connection. Long a
top concern, open space in Carlsbad has been preserved, even as the city approaches the upper
limit of homes envisioned under the Growth Management Program.
Now, 37 years later, the large developable areas in Carlsbad are mostly built and the city is
about 85% to 90% built out. The city’s focus is shifting toward infill development and long-term
maintenance needs. At the same time, new state laws to promote more affordable housing
mean Carlsbad may no longer enforce the housing caps that had long been a key pillar of its
growth management program. So instead of closing the book on new growth, Carlsbad finds
itself entering a new chapter.
Moving forward, the hurdles of maintaining an excellent quality of life in Carlsbad will be
different, but the goal remains the same. The city and the community will work together to
retain those things that make Carlsbad so special, even as the city continues to welcome new
residents in the future.
Growth Management Program
In 1984, Carlsbad’s population increased by 9%, the largest increase for any city in San Diego
County and the 10th largest in the state. At that time, the city was averaging about 2,000 new
home building permits a year. As community concerns about growth increased, the City Council
convened a citizens committee to help update its General Plan, which led to recommendations
on how growth should be managed moving forward.
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In 1985, the City Council issued a six-month moratorium on new development to allow time to
create a comprehensive approach to managing growth. What later became known as the
Growth Management Program consists of four main parts:
A growth management ordinance
A citywide facilities and improvements plan
11 facilities performance standards
A ballot measure approved by voters
Growth management ordinance
In June 1986, the City Council approved an ordinance establishing a Growth Management
Program for the City of Carlsbad, with the following goals:
Provide quality housing opportunities for all economic sectors of the community
Provide a balanced community with adequate commercial, industrial, recreational and
open space areas to support the residential areas of the city
Ensure that public facilities and improvements meeting city standards are available
concurrent with the need created by new development
Balance the housing needs of the region against the public service needs of Carlsbad
residents and available fiscal and environmental resources
Encourage infill development in urbanized areas before allowing extensions of public
facilities and improvements to areas which have yet to be urbanized
Ensure that all development is consistent with the Carlsbad general plan
Prevent growth unless adequate public facilities and improvements are provided in a
phased and logical fashion as required by the general plan
Control of the timing and location of development by tying the pace of development to
the provision of public facilities and improvements at the time
Citywide Facilities and Improvements Plan
The growth management ordinance also called for a citywide facilities and improvements plan,
dubbed the “What, When and How” plan by the city’s planning director at the time. The plan
spelled out what would be needed to maintain these standards as the city grew, when the
improvements would be needed and how they would be paid for.
Local Facility Management Zones
Because different parts of Carlsbad would have different needs, the growth management
ordinance also required the city to establish local zones based on the following criteria:
Service areas or drainage basins
Extent to which facilities or improvements are in place or available
Ownership of property
Boundaries of existing master plans
Boundaries of pending master plans
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Boundaries of potential future master plan areas
Boundaries of approved tentative maps
Public facilities relationships, the relationship to the city’s planned major road network
Special district service territories
Approved fire, drainage, sewer, or other facilities or improvement master plans
The city created 25 Local Facility Management Zones. Each zone was required to have its own
Local Facilities Management Plan prior to any new development, describing how required
public facilities would be provided, when they would be needed and how they would be
funded.
--Highway
-·---Major Street
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--Railroad
1111 Lagoon
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Carlsbad
Local Facility
Management Zones
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Current standards
The growth management ordinance also required that the city develop minimum standards the
following facilities would need to meet to maintain Carlsbad’s quality of life for all economic
sectors of the Carlsbad community:
City administrative facilities
1,500 square feet per 1,000 population must be scheduled for
construction within a five-year period or prior to construction of
6,250 dwelling units, beginning at the time the need is first
identified.
Libraries
800 square feet per 1,000 population must be scheduled for
construction within a five-year period or prior to construction of
6,250 dwelling units, beginning at the time the need is first
identified.
Parks
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 beginning from the time the
need is first identified.
Open space
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.
Circulation (mobility)
Implement a comprehensive livable streets network that serves all
users of the system – vehicles, pedestrians, bicycles and public
transit. Maintain a Level of Service D or better for all modes that
are subject to the Multi-Modal Level of Service standard, as
identified in Table 3-1 of the General Plan Mobility Element,
excluding Level of Service exempt intersections and streets
approved by the City Council.
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Fire response
No more than 1,500 dwelling units outside of a five-minute
response time.
Schools
School capacity to meet projected enrollment within the zone as
determined by the appropriate school district must be provided
prior to projected occupancy.
Drainage
Drainage facilities must be provided as required by the city
concurrent with development.
Water distribution system
Line capacity to meet demand as determined by the appropriate
water district must be provided concurrent with development. A
minimum 10-day average storage capacity must be provided prior
to any development.
Sewer collection system
Trunk line capacity to meet demand as determined by the
appropriate sewer district must be provided concurrent with
development.
Wastewater treatment capacity
Sewer plant capacity is adequate for at least a five-year period.
Ballot measures
After the City Council adopted the growth management ordinance, a group of residents put an
initiative on the November 1986 ballot that proposed to strictly limit new home development
for 10 years. This was characterized at the time as the “no growth” approach, compared to the
city’s “managed growth” strategy. The City of Carlsbad put forth a competing ballot measure
that included three main parts:
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Affirming the basic principle of the growth management ordinance it had passed earlier
in the year – that new home development will not be approved unless the public
facilities required to serve new residents are provided concurrently with the need.
Prohibiting the approval of new residential development in excess of the limit
established in the growth management ordinance without a public vote.
Allowing the city to add public facilities, but not reduce them without a corresponding
reduction in the total number of homes allowed.
Both measures passed, but the city’s measure got more votes, so it prevailed.
In early 1987, the City Council formally added the following housing caps to the growth
management ordinance (see image below). Housing caps were assigned by dividing the city into
fourths and considering how many homes had already been built in each, so, in the end,
housing would be spread throughout the city.
Density control map (adopted in 1986)
PROP E -CITY CARLSBAD -GROWTH MANAGEMENT (COUNCIL)
YES 9652
NO 6997
57.97
4 2 .03
PROP G -CITY CARLSBAD -BUILDING LIMITATION INITIATIVE
YES 8593 51 .57
NO 8070 48.43
l
2
3
4
5
6
7
8
9
10
111
12
B 1:s l .. 141 "'<
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Putting it all together
With development standards in place, detailed public facility improvement plans completed
and funding sources identified, Carlsbad’s growth resumed. If public facilities in any one of the
25 local facility management zones fell short, development could be halted until the public
facilities were in place. Developers paid fees to cover the facilities and services needed by the
new residents their homes would bring. Staff monitors the status of the facility standards and
provides annual reports to the City Council and the public.
The city’s award-winning growth management program has been recognized statewide as a
unique and successful model for managing growth. Residents have given the city’s quality of
life high ratings year after year in city surveys, and Carlsbad has remained a very desirable place
to live and do business.
The city has remained financially healthy while gaining high quality residential communities and
the roads, libraries and other infrastructure needed to support them.
Planning for the future
As described in the history section above, the Growth Management Program was established
during a time of rapid growth. From 1980 to 1990, Carlsbad’s population increased 78% and
from 2010 to 2020, by comparison, Carlsbad’s population increased only 9%. Carlsbad’s
population growth is slowing as developable area becomes more limited.
*This is our current best estimate of “buildout” based on the current dwelling units estimated to remain to be built
in the General Plan, using the same persons per household assumptions as the 2020 census. Changes to the
General Plan, state law or demographics over time will impact this number either positively or negatively. This is
estimated to occur between 2030 and 2050.
Carlsbad is now transitioning into a time when most of the major planned residential
development is complete. Housing laws have changed. Carlsbad’s infrastructure is aging and
needs to be maintained. The city has become a major employment center, and community
priorities have evolved.
For all these reasons, the growth management strategies that worked well to make Carlsbad
the special place it is today must also change and evolve.
Year Carlsbad population Percentage increase
1980 35,490 78% 1990 63,126
2010 105,328 9% 2020 114,746
2030+* 133,515 16%
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Changes in laws, regulations and policies
The state of California has declared a housing crisis in the state and passed several new laws
designed to make it easier to build housing, largely by reducing local cities’ control over the
approval process.
In 2017 the California Legislature passed SB 166, known as the No Net Loss Law, which requires
local jurisdictions to ensure that their Housing Element inventories can accommodate, at all
times throughout the planning period, their remaining unmet share of the regional housing
need.
In 2019, the legislature passed SB 330, the Housing Crisis Act of 2019, which prohibits local
jurisdictions from imposing moratoriums or new restrictions on housing development. This
extends to using residential housing caps or other limits to regulate the number of housing
units built within a jurisdiction.
In light of these new laws, the California Department of Housing and Community Development
has taken the following positions on what that means for Carlsbad:
Failure to meet the Growth Management Program performance standards cannot be
used as a basis for implementing a moratorium that precludes meeting Carlsbad’s share
of the regional housing need.
The Growth Management Program caps on housing cannot prevent the city from
achieving consistency with the Housing Element inventory and SB 166.
In 2020 and 2021, the Carlsbad City Council adopted resolutions finding that housing caps and
moratoriums on new housing are unenforceable due to the new state laws. It is likely that new
state mandates, legislation or programs around housing may still be on the horizon.
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City of Carlsbad plans and policies
In addition to the Growth Management Program, there are a number of other plans and
policies that help guide growth and land-use planning within the city, while keeping in mind the
values and priorities of the Carlsbad community.
General Plan
City decision-makers rely on the General Plan, approved in 2015, for making decisions about
land use and providing public facilities like roads, parks and fire stations. It is also a policy
document that guides decisions related to protecting, enhancing, and providing those things
the community values most, such as open space, habitat conservation, beach preservation, arts
and community character. State law requires all cities and counties to have a General Plan.
The General Plan includes a housing plan, called a Housing Element, designed to provide the
city with a coordinated and comprehensive strategy for promoting the production of safe,
decent and affordable housing within the community. State law requires housing elements to
be updated every eight years to reflect a community’s changing housing needs and to align with
new state laws.
In July 2021, the state approved Carlsbad's new Housing Element, which details how Carlsbad
will accommodate projected housing needs through 2029. Carlsbad must also designate space
for about 3,900 new housing units, of which about 2,100 units need to be affordable for people
with very low to moderate incomes. Although Carlsbad can accommodate some of the housing
units on property already designated for homes, the city needs to rezone additional sites to
accommodate about 2,700 higher density housing units by April 2024 to meet state
requirements. It is unknown how many additional housing units the state will require the city to
accommodate in the future (after 2029).
During the committee’s deliberations, it was acknowledged that the city can no longer limit the
number of homes in the city, and therefore, it is difficult to determine exactly what the future
public facility needs will be. The committee also considered that even though there will be
additional housing development, there will be limited future development overall, which limits
the facility impact fees that will be collected to fund future construction of public facilities.
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Carlsbad Community Vision
Carlsbad and the General Plan are guided by nine core values that make up the community’s
vision for the future. These values were adopted by the City Council in 2010, following a
collaborative process with the community and have been reaffirmed over the years through
regular check-ins and ongoing community engagement. The Carlsbad Tomorrow Growth
Management Citizens Committee regularly looked to the city’s vision and core principles for
guidance throughout their process.
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Small town feel, beach community character and connectedness
Enhance Carlsbad's defining attributes-its small town feel and beach community character. Build on the city's culture
of civic engagement, volunteerism and philanthropy.
Open space and the natural environment
Prioritize protection and enhancement of open space and the natural environment. Support and protect Carlsbad's
unique open space and agricultural heritage.
Access to recreation and active, healthy lifestyles
Promote active lifestyles and community health by furthering access to trails, parks, beaches and other recreation
opportunities.
The local economy, business diversity and tourism
Strengthen the city's strong and diverse economy and its position as an employment hub in north San Diego County.
Promote business diversity, increased specialty retail and dining opportunities, and Carlsbad's tourism.
Walking, biking, public transportation and connectivity
Increase travel options through enhanced walking, bicycling and public transportation systems. Enhance mobility
through increased connectivity and intelligent transportation management.
Sustainability
Build on the city's sustainability initiatives to emerge as a leader in green development and sustainability. Pursue public/
private partnerships, particularly on sustainable water, energy, recycling and foods.
History, the arts and cultural resources
Emphasize the arts by promoting a multitude of events and productions year-round, cutting-edge venues to host world-
class performances, and celebrate Carlsbad's cultural heritage in dedicated facilities and programs.
High quality education and community services
Support quality, comprehensive education and life-long learning opportunities, provide housing and community
services for a changing population, and maintain a high standard for citywide public safety.
Neighborhood revitalization, community design and livability
Revitalize neighborhoods and enhance citywide community design and livability. Promote a greater mix of uses citywide,
more activities along the coastline and link density to public transportation. Revitalize the downtown Village as a
community focal point and a unique and memorable center for visitors, and rejuvenate the historic Barrio neighborhood.
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Carlsbad Tomorrow: Growth Management Citizens
Committee
Committee members
The first step of a multi-year process to create a new approach to managing growth included
the creation of the Carlsbad Tomorrow Growth Management Citizens Committee. The
committee met from March 2022 – April 2023 to review and identify key elements of a new
plan to manage growth that maintains excellent quality of life and ensures compliance with
state laws.
Member Alternate
Jeff Segall, At Large Ron Withall, At Large
Scott White, At Large Patrick Goyarts, At Large
Eric Larson, District 1 1 Jan Neff-Sinclair, District 1
Stephen “Hap” L’Heureux, District 1 Casey Carstairs, District 1
Mike Howes, District 2 2 Don Christiansen, District 2
Mary Ryan, District 2 Terence Green, District 2
Frank Caraglio, District 3 Thierry Ibri, District 3
Frances Schnall, District 3 Matthew Reese, District 3
Harry Peacock, District 4 Erin Nell, District 4
Annika Jimenez, District 4 Angela O’Hara, District 4
Gita Nassiri, Arts Commission Nora Jimenez George, Arts Commission
Fred Briggs, Beach Preservation Commission Lisa Stark, Beach Preservation Commission
Chad Majer, Historic Preservation Commission Jamie Jacobs, Historic Preservation Commission
John Nguyen-Cleary, Housing Commission Allen Manzano, Housing Commission
William Sheffler, Library Board of Trustees Art Larson, Library Board of Trustees
Amy Allemann, Parks & Recreation Commission Marissa Steketee, Parks & Recreation Commission
Joseph Stine, Planning Commission Kevin Sabellico, Planning Commission
Patricia Mehan, Senior Commission 3 Nelson Ross, Senior Commission 4 (resigned)
Steve Linke, Traffic & Mobility Commission William Fowler, Traffic & Mobility Commission
1 Chair
2 Vice Chair
3 Member through November 2022 (deceased)
4 Member through August 20222 (resigned)
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How the committee was formed
In March 2022, the City Council appointed 38 residents (19 primary members and 19 alternates)
to serve on the committee.
Fifty-seven people applied to serve on the committee. Members were chosen by the City
Council to get a cross section of community perspectives, including residents from each of the
Carlsbad’s four City Council districts, as well as members of appointed commissions.
The Mayor nominated four community members (two primary members and two
alternates) to represent the city at large.
Each City Council member nominated four community members (two primary members
and two alternates) to represent their council district.
Each of the city’s advisory commissions nominated two of their members (one primary
and one alternate).
From the appointed primary committee members, the Mayor designated Eric Larson (District 1)
as the Chair and Mike Howes (District 2) as the Vice Chair.
At Large
2 primaries
2 alternates
• • • • ----
Arts Commission
1 primary
1 alternate
• • --
Planninc
Commission
1 primary
1 alternate
• • --
District 1 District 2 District 3 District 4
2 primaries 2 primaries 2 primaries 2 primaries
2 alternates 2 alternates 2 alternates 2 alternates
• • • • • • • • • • • • • • • • ----------------
Beach Preservation Historic Preservation Housinc Commission library Board of
Commission
1 primary
1 alternate
• • --
Parks & Recreation
Commission
1 primary
1 alternate
•• --
Commission 1 primary
1 primary
1 alternate
• • --
1 alternate
• • --
Senior Commission
1 primary
1 alternate
• • --
Trustees
1 primary
1 alternate
• • --
Traffic & Mobility
Commission
1 primary
1 alternate
• • --
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One Senior Commission member originally selected resigned at the beginning of the
committee’s process. The other Senior Commission member unfortunately passed away before
the committee’s work was complete. The committee decided not to replace the Senior
Commission members since only a few meetings remained and the committee was so far along
in the process.
Committee charter
To achieve the committee’s mission, the City Council asked members to:
Become familiar with the issues that affect future growth and quality of life in Carlsbad
Attend periodic meetings over a period of time (approximately 1 year)
Listen to and respect diversity in perspectives, facts and opinions
Provide constructive feedback to city staff and consultants on process and draft work
products
In decision-making, balance individual and group stakeholder goals with the larger
public interest and legal requirements
Work collaboratively with other committee members in reaching decisions and making
recommendations to the City Council
Encourage community participation at committee meetings
The committee’s charter (Appendix 1) laid out information including how often the committee
would meet, what constituted a quorum (ten members), the role of the Chair and Vice Chair,
how to follow open-meeting requirements, how the committee would handle information
sharing and more.
The committee was tasked with focusing on input, review and "buy-in" to carry out its mission,
rather than deliberating on precise details.
Committee mission
The mission of the Carlsbad Tomorrow Growth Management Citizens Committee is to
promote balanced consideration of a range of perspectives on issues affecting the future
growth and quality of life in Carlsbad and to identify the key elements of a new plan to
manage growth in Carlsbad in a way that maintains an excellent quality of life while also
complying with state law.
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Process
Over the course of 15 meetings and more than 50 hours of meeting time, the committee
discussed each of the existing Growth Management Program’s 11 performance standards,
along with other topics the group felt were important to maintaining Carlsbad’s quality of life,
and decided on recommendations for future standards to reflect the community’s current
needs and priorities. All meetings were held in public, with an opportunity for input from the
community.
A trained facilitator helped manage the committee meetings to encourage a collaborative
process, ensure the mission was achieved, and committee-developed ground rules were
enforced. The facilitator worked hand-in-hand with the committee chair and city staff.
From the outset, the committee agreed to abide by the following discussion process:
The committee would establish ground rules about how members should conduct
themselves during meetings.
The preferred decision-making process is collaborative problem solving.
Consensus of the committee takes precedence over individual preferences.
When there isn’t a consensus, the Chair may call for majority vote of the committee;
however, alternative perspectives will be documented.
City staff is present at all meetings to assist the Chair and committee as needed.
Ground rules
The committee established the following ground rules for how members should conduct
themselves during meetings:
Encourage diversity of ideas; every idea is a good idea during brainstorming.
Avoid applying personal biases based on geography, organization affiliation, etc. – think
about the city as a whole.
Establish and follow general time limits for discussion items.
Always be respectful.
Be prepared by reading materials and thinking about topics ahead of meetings.
Encourage all to speak – both primary and alternate members.
Actively search for ways to identify gaps in data and make requests based on those
gaps.
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Meeting participation
The committee met once a month, except for two meetings held in January 2023. Full
participation of committee members was essential to the effectiveness of the committee, and
members were expected to attend all committee meetings. During meeting discussions and
dialogue, primary committee members were given the first opportunity to comment and ask
questions. Following that exchange, alternates were then invited to also provide comments and
ask questions as time allowed for the agenda item.
If a primary committee member was unable to attend a meeting, they were expected to notify
city staff as soon as possible, and the designated alternate would participate in his or her place
during that meeting.
The alternate was encouraged to actively participate in the meeting as a primary member
provided they were adequately briefed as to the status of prior discussions and decisions.
Open meeting requirements
All committee meetings and committee members were subject to the open meeting
requirements of the Ralph M. Brown Act (Brown Act). The Brown Act imposes public notice and
access requirements on committee meetings, and places certain limitations on when and how
committee members may communicate with one another. New committee members were
given a briefing by the City Attorney's office about the basic requirements of the Brown Act.
Work product
The committee's work concluded with this committee-supported report recommending to the
City Council what key elements and standards should be included in a new plan to manage
growth to comply with state law and maintain the city’s excellent quality of life.
The committee also identified several issues, services and policies important to Carlsbad’s
future quality of life, but should not be performance standards.
The committee’s work product summarized in this report includes:
Recommended growth management standards
Review of topics discussed, but not recommended for standards
Name TBD: Supplemental quality of life recommendations (not standards)
An overview of the committee’s work plan and actions taken by the committee at each meeting
is included at the end of this report.
The Carlsbad Tomorrow Growth Management Citizens Committee is the first stage of a multi-
year process to create a new approach to managing growth in Carlsbad. The City Council will
consider the committee's recommendations and direct the next steps to create a new Growth
Management Program. After the City Council receives the committee’s report and provides
direction on next steps, the next phase of the process will begin, with more opportunities for
public engagement.
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COMMITTEE PROCESS
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Committee recommendations
The Carlsbad Tomorrow Growth Management Citizens Committee was charged with
identifying key elements of a new plan to manage growth in Carlsbad in a way that maintains
an excellent quality of life while also complying with state law.
Performance standard recommendations
Over the course of 15 meetings, the committee received in-depth presentations from
department heads, Fire and Police Chiefs, and other internal and external experts about each of
the existing Growth Management Program’s 11 performance standards, along with other topics
the group felt were important to maintaining Carlsbad’s quality of life. Performance standards
refer to the level of service that needs to be maintained to ensure Carlsbad’s excellent quality
of life.
The committee then discussed each of these topics, focusing on whether they were still critical
to maintaining Carlsbad’s quality of life and, if so, what the standard should be moving forward
based on the community’s current needs and priorities. The committee also considered
whether the topic was best addressed as a performance standard or if they were adequately
addressed in other existing city policies and plans.
All recommendations were made without a financial or impact analysis, as committee members
understood that the City Council may direct staff to investigate those issues as it proceeds with
next steps.
For each of the city’s existing 11 public facility performance standards, the committee
determined whether the standard should be kept as is, modified or removed from the Growth
Management Program, as summarized below. Additional detail on each standard can be found
on pages 26-37.
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Current Growth Management Program public
facility
Committee recommendation for current
public facility standard
Libraries
Keep as is
Parks
Keep as is
Circulation (mobility)
Keep as is
Drainage
Keep as is
Sewer collection system
Keep as is
Water distribution system
Modify
Open Space
Modify
Wastewater treatment capacity
Remove
City administrative facilities
Remove
Fire
Remove
Schools
Remove
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LIBRARY FACILITIES STANDARD
Standard (current retained)
800 sq. ft. of library facilities per 1,000 population must be scheduled for construction
within a five-year period or prior to construction of 6,250 dwelling units, beginning at the
time the need is first identified.
Rationale
The City of Carlsbad’s library system is well-utilized by the community and will continue to
contribute greatly to quality of life as the city manages future growth.
Technological advances have not minimized the need for physical library space. Instead,
modern libraries are focused on more flexible spaces that can adapt readily to changing
community priorities and needs.
The library industry has moved away from formulaic calculations per capita to determine
space needs, but has not replaced it with a new standard. As such, the committee
recommends that the library standard remain as was written in the original Growth
Management Program.
Status
Based on the 2020-2021 Growth Management Monitoring Report, Carlsbad libraries have
the resources needed to provide an excellent level of service.
Based on the June 30, 2021 population estimate of 116,025, the growth management
standard requires 92,820 sq. ft. of public library space. The city’s current 99,993 sq. ft. of
library facilities adequately meets the growth management standard.
Facility Square Feet
Dove Library (includes the Schulman
Auditorium and Cannon Art Gallery)
64,000
Cole Library
24,600
Learning Center
11,393
Total 99,993
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PARKS STANDARD
Standard (current retained)
3.0 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 beginning at the time
the need is first identified.
Additional recommendation
The committee is requesting that the City Council direct staff to evaluate the feasibility of
creating and implementing a distance based standard to any publicly accessible park.
Rationale
Access to parks contributes to public health, social connectivity and overall quality of life
while managing growth.
The city’s parks standard has evolved from the early 1980s, but has always been based on
a ratio of park land to population, with a five-year timeframe to meet the standard. The
five-year period allows demand to accumulate to the point that construction of a new
park would be warranted.
As the committee evaluated the current parks standard, they reviewed how Carlsbad
compares with neighboring cities, discussed alternative ways to inventory park land in the
city, and questioned whether counting acreage by quadrant is the most effective way to
achieve park goals. Additionally, the committee stressed the importance of close access to
a park as contributing to quality of life.
Alternative perspectives
Some committee members preferred a citywide standard of 4 acres per 1,000 population
excluding acreage inaccessible to people, and/or restricting the acreage of Veterans Memorial
Park to the northwest quadrant given its scope. In the end, the majority voted to retain the
existing standard. To address the access to parks, a majority of the committee also voted to
request that City Council direct staff to evaluate the feasibility of a standard based upon a
distance measure to any publicly accessible park.
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Status
The city is currently exceeding the parks performance standard and is projected to exceed
the standard at complete buildout of housing units, currently estimated at 133,515
persons, as reflected in the chart below. More information on population estimates is on
page 14.
1 Existing park acreage inventory for each quadrant includes an equal proportion (23.4 acres) of Veterans
Memorial Park. Although located in the northwest quadrant, because of its size, centralized location and
citywide significance, the park fulfills citywide park facility needs. The city’s intention for the park to be a
citywide park facility dates to the adoption of the Growth Management Program in 1986.
Quadrant Park acreage inventory
existing1
Current park acreage
required by standard
Park acreage required by
standard at city buildout
NW 131.7 94.1 117.4
NE 68.7 54.6 68.2
SW 93.6 79.0 86.5
SE 138.3 120.4 127.6
Total 432.4 348.1 399.7
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MOBILITY STANDARD
Standard (current retained)
Implement a comprehensive livable streets network that serves all users of the system –
vehicles, pedestrians, bicycles and public transit. Maintain a Level of Service D or better
for all modes that are subject to the Multi-Modal Level of Services standard, as identified
in Table 3-1 of the General Plan Mobility Element, excluding Level of Service exempt
intersections and streets approved by the City Council.
Rationale
The ability to move safely and conveniently throughout the city will remain critical to
quality of life and the local economy as the city manages future growth.
The committee believes vehicle traffic congestion needs to be addressed, and streets
should better accommodate all modes of travel.
The 2015 General Plan update calls for a multimodal Complete Streets network
throughout the city, which will accommodate all modes of travel (auto, transit, bicycle,
and pedestrian). These modes will be prioritized differently, depending on the size and
purpose of each street.
The city is currently developing a multimodal impact fee to fund the transformation of city
streets to meet current and future demands. Once complete, the proposed standard can
be reviewed to ensure alignment with the new impact fee program.
Alternate perspectives
Some committee members preferred a staff recommendation to change the standard to
one that relied and built upon the Sustainable Mobility Plan’s new multi-modal
transportation impact fee to address citywide improvements, rather than the existing
level of service related standard. The majority of the committee voted to recommend the
current standard be kept in place.
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Status
Based on the 2020-2021 Growth Management Monitoring Report, all the deficient
roadway facilities identified in the report were previously determined by City Council to
be deficient and exempt per General Plan Mobility Policy 3-P.10. The Multimodal Level of
Service analysis continues to be developed with the Traffic & Mobility Commission. The
committee was unable to reference a completed Multimodal Level of Service analysis to
inform non-vehicle based performance standard possibilities. The initial Multimodal Level of
Service will be presented to the Traffic & Mobility Commission in the spring of 2023.
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DRAINAGE STANDARD
Standard (current retained)
Drainage infrastructure must be provided as required by the city concurrent with
development.
Rationale
Adequate drainage infrastructure will continue to contribute to Carlsbad’s quality of life
as the city manages growth by improving public safety, safeguarding the environment
and protecting property from flooding.
Unlike some other performance standards, drainage infrastructure needs are specific to
individual projects.
City subject matter experts have assured the committee that this standard could be
applied effectively to the types of development expected in the future.
Status
Based on the 2020-2021 Growth Management Monitoring Report, the growth
management drainage standard has been met consistently.
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SEWER COLLECTION
SYSTEM STANDARD
Standard (current retained)
Trunk line capacity to meet demand, as determined by the appropriate wastewater
districts, must be provided concurrent with development.
Rationale
Evaluating, maintaining and increasing the city’s wastewater collection and conveyance
system as development occurs is essential to preserving public health, the environment
and quality of life.
The City of Carlsbad, Leucadia Wastewater District and Vallecitos Water District provide
this service within the city’s boundaries.
The city develops and assesses wastewater system capacity every five years through a
master planning process that considers General Plan land use designations, development
density and population projections. The latest master plan was completed in 2019.
Unlike some other performance standards, wastewater collection system needs are
specific to individual projects.
The city requires studies during discretionary project review for sewer system sizing to
determine what infrastructure, if any, must be built concurrently with the project.
Status
Based on the 2020-2021 Growth Management Monitoring Report, all three agencies
provided wastewater collection service have adequate conveyance capacity in place to
meet Carlsbad’s wastewater collection demands.
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WATER DISTRIBUTION
SYSTEM STANDARD
Proposed new standard
Concurrent with development, coordinate with the appropriate water district to ensure
water pipelines have capacity to meet increased demand.
Current standard
Line capacity to meet demand as determined by the appropriate water district must be
provided concurrent with development. A minimum 10-day average storage capacity
must be provided prior to any development.
Rationale
Reliable delivery of safe drinking water is essential for public health, quality of life and the
city’s economy as the city manages future growth.
Carlsbad Municipal Water District, which is a subsidiary district of the City of Carlsbad,
Olivenhain Municipal Water District (southern Carlsbad) and Vallecitos Water District
(parts of eastern Carlsbad) distribute water within the city’s boundaries.
These water districts prepare water master plans to forecast future infrastructure needs,
among other things.
When a residential development project is proposed, city staff consult the appropriate
water master plan to check pipeline sizes and facility capacities. If needed, developers will
be required to build projects identified in the master plan concurrently with the project.
The committee recommends removing the storage requirement because the standard is
not intended to address water supply, just infrastructure. Additionally, the city has
developed adequate storage capacity since the original standard was developed.
Status
Based on the 2020-2021 Growth Management Monitoring Report, all three water districts
serving Carlsbad have plans in place to ensure water distribution capacity will keep pace
with development.
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OPEN SPACE STANDARD
Proposed new standard
In all Local Facility Management Zones, open space shall be provided consistent with city
policies and regulations, including for protection of natural resources, provision of
outdoor recreation, production of resources, and for aesthetic, cultural and educational
purposes.
In Local Facilities Management Zones 11 - 15 and 17 - 25, 15% 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. Local Facility
Management Zones 1 - 10 and 16 are exempt from this 15% open space requirement,
pursuant to the Citywide Facilities and Improvements Plan adopted by the City Council in
1986.
Note: when the 15% open space standard was originally adopted in 1986, Local Facility
Management Zones 1-10 and 16 were urbanized (developed), were urbanizing (had
approved development/master plans) or were non-residential, and the Citywide Facilities
and Improvements Plan adopted by the City Council did not apply the open space
standard to those areas.
Current standard
Fifteen percent of the total land area in the 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.
Rationale
Much of project-based open space is achieved through zoning – private open
space, setbacks, lot coverage, which apply citywide.
Open space is currently provided in all Local Facility Management Zones (refer to map on
page 10).
While the city continues to allocate funds for acquisition of open space, challenges exist in
securing vacant available land for more open space than is currently planned, and options
for a different open space standard are limited and involve additional cost to the city.
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Alternate perspectives
When the Growth Management Program was first implemented, several zones were
exempted from the open space standard based on their 1986 planning and development
status. Because planning changes and redevelopment have and likely will continue to alter
the status in the exempt zones over time, some committee members preferred to look at
ways to reverse the exemptions, apply a citywide standard, and/or look into linkage fees.
The majority of the committee preferred to keep the original standard in place while
adding a statement highlighting existing city open space policies that apply to all zones.
Status
Local Facility
Management Zone #
Is zone exempt from open
space standard? Why?
Open space is what percent
of total acres in zone?1
Percentage of citywide
open space1
1 Yes – Urbanized 21.1% 2.9%
2 Yes – Urbanized 15.8% .5%
3 Yes – Urbanized 9.4% .2%
4 Yes – Urbanized 20.2% .4%
5 Yes – Urbanized 24.6% 2.4%
6 Yes – Urbanized 20.4% 2.1%
7 Yes – Urbanizing 42.4% 1.4%
8 Yes – Urbanizing 80.1% 2.4%
9 Yes – Urbanizing 44.1% .8%
10 Yes – Urbanizing 60.5% 1.9%
11 No – Future Urbanizing 48.5% 4.4%
12 No – Future Urbanizing 20.8% .6%
13 No – Future Urbanizing 47.0% 1.4%
14 No – Future Urbanizing 68.3% 2.3%
15 No – Future Urbanizing 55.0% 3.4%
16 Yes – Not residential 53.1% .9%
17 No – Future Urbanizing 38.2% .9%
18 No – Future Urbanizing 38.3% 1.4%
19 No – Future Urbanizing 62.9% 4.1%
20 No – Future Urbanizing 32.1% 1%
21 No – Future Urbanizing 44.3% .5%
22 No – Future Urbanizing 17.2% .3%
23 No – Future Urbanizing 64.8% .7%
24 No – Future Urbanizing 41.0% .3%
25 No – Future Urbanizing 77.4% .9%
Total 38% of total city acres
1 The open space percentage represents all open space, including open space provided to meet the 15%
growth management standard and other open space, such as environmentally constrained open space.
Please refer page 10 for a map of Local Facility Management Zones.
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STANDARDS RECOMMENDED FOR REMOVAL
By consensus, the committee recommended the following four current performance standards
be removed from the Growth Management Program.
WASTEWATER TREATMENT STANDARD
Current standard
Sewer plant capacity is adequate for at least a five-year period.
Rationale
Sufficient planning processes and efforts exist to maintain sewer system and treatment
plant capacity through the city’s involvement with the Encina Joint Powers Authority,
which operates the Encina Wastewater Authority treatment plant that serves Carlsbad.
The Encina Wastewater Authority adequately provides essential services for preserving
public health, protecting the local ocean environment and providing valuable wastewater
infrastructure for the region.
The Encina Wastewater Authority’s long-term Capital Improvement Program ensures the
wastewater treatment plant serving Carlsbad is able to handle future growth and meet
increasingly stringent environmental regulations.
CITY ADMINISTRATIVE FACILITIES STANDARD
Current standard
1,500 sq. ft. per 1,000 population must be scheduled for construction within a five-year
period or prior to construction of 6,250 dwelling units, beginning at the time the need is
first identified.
Rationale
This standard is no longer reflective of modern business operations and is unnecessary
with the new civic center and city hall project authorized in August 2022 to move
forward. With the construction of the new civic center, the standard would be exceeded.
As the city has reached a stage where it is focused on maintaining infrastructure and
having less rapid growth, this standard is determined unnecessary for the city to continue
to provide operational facilities.
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FIRE STANDARD
Current standard
No more than 1,500 dwelling units outside of a five-minute response time.
Rationale
After consultation with the City of Carlsbad Fire Chief, the committee found the existing
standard did not provide the best method for the city to evaluate fire service
performance.
Best practices for evaluating the effectiveness of a Fire Department include a variety of
performance standards and ever-evolving metrics that are not related to future
development.
These practices are occurring in metrics that the Fire Department annually prepares and
presents to the City Council as part of the annual budget process to ensure high-quality
Fire Department services are maintained.
Related considerations
Following consultation with both the Fire and Police Chiefs, the committee also
considered whether there should be a separate police performance standard or an overall
public safety standard that incorporates both police and fire. Ultimately, the committee
determined the levels of service for police and fire were adequately addressed through
other existing city and departmental policies and plans.
SCHOOLS STANDARD
Current standard
School capacity to meet projected enrollment within the Local Facility Management Zone
as determined by the appropriate school district must be provided prior to projected
occupancy.
Rationale
The standard was deemed to be unnecessary as schools maintain their own standards and
state law already requires annual coordination.
The city has no control over schools and/or the development of schools.
Development is required to provide evidence that schools have capacity for its residents
and pay fees to the applicable school district. School districts complete facilities plans that
include city growth projections.
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Additional topics considered by the committee
In addition to the existing 11 public facility performance standards, the committee identified
and discussed the following topics to determine if they should be considered as part of a future
Growth Management Program. After consideration of the topics below, the committee
determined that most of the topics are adequately addressed by other policies, programs and
regulations, and that none of the topics should be included as a standalone standard in a future
Growth Management Program.
Behavioral health
Physical health
Walkability
Public safety
Homelessness
Seniors/aging community
• Senior Center operations
Arts and culture
Energy and power
• Local power generation
• Renewable energy
• Reservoir solar panels
Water
• Sources and supplies
• Desalination
• Water quality
• Stormwater
• Recycled water
Environmental sustainability
• Climate change
• Sea level rise
Technology
Cellular service/ Wi-Fi access
Village development
Request for a park at Ponto
Updates to Proposition H and fees
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However, the committee determined some of the topics should receive more consideration by
the City Council and be considered in future city strategic planning efforts. The topics that the
committee recommend be addressed as important quality of life issues, but not as standards in
the Growth Management Program are listed below. These are described in more detail on
pages 39-42 and were also provided to the City Council as a separate report.
Arts and culture Open space
Energy
Updates to Proposition H
Public facility fees
Seniors/aging community
Homelessness Transportation and mobility
These committee discussions and public input provided are summarized in the meeting
minutes, which are included in the appendices.
Supplemental quality of life recommendations
ARTS AND CULTURE
The arts are fundamentally intertwined with the City of Carlsbad’s quality of life as they
give the city a defining character and create a sense of place through aesthetics and
culturally enriching programs and events for all residents. A culturally thriving community
is directly related to economic growth; hence, the arts should be given higher priority by
the City Council in the Strategic Plan and Operating Budget.
The committee believed that a 750-seat cultural performing arts center would enhance
the quality of life in Carlsbad and believed serious consideration should be given by the
City Council to incorporate this in either the plans for a new city hall complex or to look at
other potential appropriate locations in the city to construct such a facility.
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CARLSBAD ENERGY ADVISORY GROUP
The committee recommended the creation of a group of 5-7 citizens charged with
providing the Mayor and City Council with an annual summary of all energy-related
activities impacting the city’s residents and businesses. Topics included but are not limited
to:
• Electric commodity providers
• Energy reliability and safety
• SDG&E undergrounding programs
• Carlsbad’s peaker-style power plant operations
• Renewable energy production (new solar installations, quantity of energy produced,
new technological advancements)
• Feasibility of microgrids
• Energy storage
• Energy costs and sources
FEES
The committee recommended the city evaluate all public facility impact fees on a regular
basis (no more than every five years) and update as needed.
HOMELESSNESS
Homelessness is an important issue that impacts the quality of life for the residents of
Carlsbad and should remain a priority for the City Council in the Strategic Plan and
Operating Budget. The committee recognized the complex challenges of addressing the
impacts of homelessness and supports the continued efforts of the city’s
Homeless Outreach Team and affordable housing programs, as well as the Homelessness
Action Plan.
OPEN SPACE
The committee recommended the City Council elevate the topic of open space by adding
to the purview of the Parks & Recreation Commission to address open space needs
throughout the city, address potential open space deficits and evaluate opportunities to
acquire more open space by updating the list of candidate properties for proactive open
space acquisition and by developing a plan that prioritizes zones with less unconstrained
open space or that are subject to loss due to sea level rise.
Adopt a policy that discourages exceptions to development standards that would
decrease open space.
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PROPOSITION H
During committee deliberation it was discussed that Proposition H, as implemented by
Carlsbad Municipal Code Chapter 1.24, has not been updated since it was passed by
voters in the 1980s. The committee recommended the City Council consider a ballot
measure increasing the expenditure limit due to increased project costs, and indexing it to
something like the Consumer Price Index so it can increase over time.
Additionally, the committee recommended the city set aside funding for public safety
capital improvement projects, such as fire stations, and specify in a future ballot measure
that certain types of projects don’t require voter approval to exceed the spending limit of
$1 million.
SENIORS/AGING COMMUNITY
The quality of life and needs of Carlsbad’s senior community and aging population is
important. The committee recognized and supported the city’s continued efforts to
ensure the needs of seniors are met, such as through the City of Carlsbad Age-Friendly
Action Plan, City of Carlsbad Parks & Recreation Department senior programs and Senior
Center, and the City of Carlsbad Senior Commission.
Carlsbad’s senior community and aging population should remain a priority for the City
Council in the Strategic Plan and Operating Budget.
TRANSPORTATION AND MOBILITY
The committee recommended the city leverage the Sustainable Mobility Plan and
Multimodal Transportation Impact Fee to implement future multimodal transportation
projects that provide the greatest benefit to the community;
• Review of current facilities,
• Relationship between existing traffic operations, changing commute patterns,
regional traffic volume growth, traffic safety and new disruptive trends in mobility
technologies, and
• Development of standards and a fee structure for private development to provide a
fair share to partially fund the buildout of the city’s multimodal transportation
network.
Require new development to conduct intersection Level of Service and Multimodal Level-
of-Service analysis to determine direct project impacts in accordance with the city’s Local
Mobility Analysis Guidelines. Update the Multimodal Transportation Impact Fee and
include Local Mobility Assessment with Level of Service for all modes.
Complete the city’s typology-based street network, as described in the General Plan
Mobility Element.
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Improve traffic signal synchronization to improve vehicle mobility and reduce the
potential environmental impacts from vehicle emissions related to the stop-and-go and
idling at intersections.
Next steps
After the City Council receives the committee’s report and provides direction on next steps, the
next phase of the multi-year process will begin. This could consist of nexus studies to determine
options for how various performance standards could be funded going forward.
Carlsbad’s Growth Management Program established that new development must provide the
public infrastructure and facilities necessary to serve the residents who will live in the new
homes created. Developers either build the improvements themselves or pay fees to the city so
the city can provide them. Throughout the process, the committee voiced concern about
possible burdens that the Growth Management Program might place on developers who would
pass increased costs on to new homebuyers or renters, thereby making projects more costly
and less affordable. The committee was concerned requirements could actually prevent
development rather than managing it.
While recognizing these dilemmas, funding strategies and financial implications were not topics
the City Council asked the committee to address and the committee did not have the data to
make such recommendations at this stage of the process. A future step in the process will
address funding options and nexus studies.
STEPS IN THE PROCESS
Growth Management Program Update
Citizens City Council
Committee gives
develops direction on
recommended next steps.
framework and
standards
••• ~--~ ~ -
Mar 2022 -Mar 2023 April 2023
Start updating
documents
Revise Growth
Management
Ordinance
Create new Citywide
Facility Financing Plan
+ 1 to 3 years
-•
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The committee’s work is concluded with this report, marking the completion of the first stage
of a multi-year process to create a new approach to managing growth in Carlsbad.
Funding models
The funding models described below are provided for informational purposes only and were not
explored by the committee as part of their mission.
How standards can be funded
Impact fees are enabled through the Mitigation Fee Act (1987), codified in California
Government Code §66000 – 66025. The law requires conducting a nexus study, which
is the relationship between what the payer pays and their “roughly proportional” share
of benefit. New development cannot be required to pay for existing deficiencies.
Developer exactions may also occur through development agreements, facilities
benefit assessments, subdivision improvements and in-lieu fees, California
Environmental Quality Act in-lieu mitigation fees, and utility and school district fees.
The cost of facilities may be passed on to individual property owners through special
districts, such as Mello-Roos Community Facilities Districts.
Use of general funds, voter-approved bond measures, state and federal funds, grants,
and user fees all play important roles in funding various types of public facilities. Most
tax-based mechanisms require voter approval.
How impact fees are determined
Impact fees may be calculated using an average or marginal cost approach, and with
consideration for impacts on citywide systems.
Average Cost Fees. Impact fees in new growth (master planned community)
jurisdictions are typically assessed based on an “average cost” approach, where costs to
serve all development at buildout are estimated, then allocated to units over time.
Marginal Cost Fees. For infill development, it may be appropriate to determine the
demand for and cost of public facilities based on the amount of new development
relative to existing supply. Demand for public facilities at the margin may be lower or
higher depending on the context.
Systems-Based Fees. Fees may be designed to address growing citywide needs for
facilities such as parks and multi-mobility infrastructure, and to prioritize the use of
funds in areas of greatest need.
Key policy considerations related to funding
Development impact fees are an important funding source, but they may add to the
cost of housing and limit supply. Impact fees cannot make up deficits in program
funding from existing residents. Broad based financing sources, such as taxes, bonds,
commercial development fees, transit occupancy taxes, and user fees, can help reduce
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reliance on impact fees and avoid creating constraints to housing development, but are
challenging to put in place.
Carlsbad’s approach to impact fees could include continued application of existing
impact fees as currently required by the Growth Management Program, along with new
impact fees for infill development using a marginal cost approach, considering broader
areas of benefit, and evaluating system-wide needs and mitigation opportunities.
As an alternative to housing caps, progress toward the city’s growth and financing goals
can be achieved through coordinated use of impact fees, the General Plan and zoning
regulations, capital improvement programs, public facilities plans, strategic use of public
funding, and continued regional coordination and infrastructure investments.
Regular monitoring of growth and public facilities, with associated fee updates and
capital improvement planning, can also contribute to concurrency goals.
Overall solutions to funding public facilities and achieving concurrency would benefit
from a toolbox approach where a variety of approaches, including developer and public
funding, are strategically applied to address growth management goals.
Committee work plan
The committee met 15 times over approximately one year. Below is an overview of the
committee’s work plan and actions taken by the committee at each meeting.
March 30, 2022 Committee Meeting
Committee receives briefing on Brown Act and public records laws.
Committee establishes ground rules.
Committee receives presentation about the city Growth Management
Program history and background.
April 28, 2022 Committee Meeting
Committee receives and discusses the following presentations:
• Public facility performance standards
• How other cities manage growth
• How the community can provide input into the committee’s work
Committee provides feedback on general topics affecting Carlsbad’s
future quality of life.
Committee chooses the name Carlsbad Tomorrow Growth Management
Citizens Committee.
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May 26, 2022 Committee Meeting
Committee receives and discusses the following presentations:
• City budget and financing
• Basis for public facility demand forecasts and approaches to
allocating fiscal costs of public facilities
• Current city administration facilities performance standard
• Existing city programs, policies and projects related to the list of
topics affecting Carlsbad’s quality of life generated at the
previous meeting
Committee provides input on additional information needs.
June 23, 2022 Committee Meeting
Committee receives and discusses the following presentations:
• Schools performance standard
• Drainage facilities performance standard
• Wastewater treatment performance standard
• Sewer collection performance standard
• Water distribution performance standard
Committee provides input on additional information needs
July 28, 2022 Committee Meeting
Committee receives and discusses the following presentations:
• Fire performance standard
• Mobility performance standard
• SANDAG demographics/growth projections for Carlsbad
Aug. 25, 2022 Committee Meeting
Committee receives and discusses the following presentations:
• Mobility performance standard (continued from July meeting)
• Libraries performance standard
• Population projections for Carlsbad (SANDAG versus city
projections)
• Committee meeting schedule and upcoming topics
Sept. 22, 2022 Committee Meeting
Committee receives and discusses the following presentations:
• Parks performance standard
• Open space performance standard
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Oct. 12, 2022 Committee Meeting
Committee discusses 23 potential new topics to be considered for its
recommended performance standards.
Recommends removing eight topics from further committee
consideration, recommends five be included only in a separate “quality
of life memo” to City Council, and requests that 10 topics be brought
back to the committee for additional consideration.
Nov. 30, 2022 Committee Meeting
Committee reviews and provides input on a sample table of contents and
a sample page of the Growth Management Citizens Committee Report.
Committee receives and discusses the following presentations:
• Fire performance standard
• Police
• Libraries performance standard
• City administrative facilities performance standard
• Schools performance standard
• Arts and culture
Committee recommends the following:
• Keep the libraries performance standard as is in the Growth
Management Program
• Remove the city administrative facilities performance standard
• Remove the schools performance standard
Committee directs staff to bring back ideas/language for a potential arts
and culture performance standard.
Committee directs staff to collaborate on ideas/recommendations for
how to approach public safety (Police and Fire together).
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Dec. 15, 2022 Committee Meeting
Committee receives and discusses the following presentations:
• Walkability
• Mobility performance standard options and multimodal
transportation impact fee
• Technology/Wi-Fi
• Water supply
• Water distribution performance standard
• Recycled water
• Sewer collection performance standard
• Wastewater treatment performance standard
• Drainage facilities performance standard
Committee recommends the following:
• Remove the 10-day storage capacity for the water distribution
performance standard. Leave the remainder of the standard as is
in the Growth Management Program.
• Keep sewer collection performance standard as is in the Growth
Management Program
• Remove wastewater treatment performance standard
• Keep drainage facilities performance standard as is in the Growth
Management Program
Directs staff to bring back revised options/language for a mobility
performance standard that reflects feedback from the committee.
Jan. 11, 2023 Committee Meeting
Committee receives and discusses revised options and
recommendation(s) provided by staff on the following:
• Open space performance standard
• Parks performance standard
Directs staff to bring back more information on local facility zones
exempted from the original open space performance standard and
revised language/options for a standard based on feedback from the
committee.
Directs staff to bring back revised options/language for a parks
performance standard that reflects feedback from the committee.
Decides not to replace Senior Commission committee members as the
Growth Management Committee is so far along in the process.
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Jan. 26, 2023 Committee Meeting
Committee recommends the following:
• Remove the fire performance standard
• Do not add a police performance standard
• Do not add an arts and culture performance standard
• Keep mobility performance standard as is in the Growth
Management Program
• Keep the parks performance standard as is in the Growth
Management Program
• Request City Council direct staff to evaluate the feasibility of
creating and implementing a standard based upon a specific
distance between public parks and housing
Feb. 17, 2023
Committee receives draft standard recommendation pages and quality of life
memo outline with materials for Feb. 23 committee meeting.
Feb. 23, 2023 Committee Meeting
Committee receives and discusses the following presentations:
• Climate Action Plan
• Renewable energy, local power and sustainability
• Open space zones and performance standard options
Committee recommends the following:
• Add language to the open space performance standard to reflect
open space currently required in all zones (through city policies
and regulations outside of the performance standard); otherwise
keep the performance standard as is in the Growth Management
Program
Provides feedback to staff on quality of life memo outline.
Provides feedback to staff on draft standard recommendation pages.
March 14, 2023
Committee receives draft final committee report and draft quality of life
memo with materials for March 23 committee meeting.
March 14 – March 23, 2023
Committee and public review draft documents (report and memo).
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March 23, 2023 Committee Meeting
Committee members share feedback on draft final committee report and
draft quality of life memo.
Committee decides which changes to make to documents (by consensus
and/or voting).
April 20, 2023 Committee Meeting
Committee members share final feedback on final documents.
Committee decides which changes to make, if any, to documents.
Committee votes to finalize document (noting changes, if any).
Committee work concludes.
May 2023
City Council considers the committee’s recommendations and provides
direction on next steps.
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Growth Management Citizens Committee
[DOCUMENT TITLE]
APRIL 2023
[Document Title]
April 20, 2023
Page 2
[Page intentionally left blank]
[Document Title]
April 20, 2023
Page 3
Introduction
In March 2022, the City Council established the Carlsbad Tomorrow: Growth Management
Citizens Committee with the mission to “…promote balanced consideration of a range of
perspectives on issues affecting the future growth and quality of life in Carlsbad and to identify
the key elements of a new plan to manage growth in Carlsbad in a way that maintains an
excellent quality of life while also complying with state law.”
The City Council formed the committee on March 8, 2022. During the committee’s conversations
and deliberations through a series of 15 meetings from March 2022 to April 2023, the committee
decided on recommendations for key elements of a new plan to manage growth (provided in a
separate report to the City Council). The committee also identified topics that are of importance
to Carlsbad’s quality of life but are not recommended to be included as standards in a growth
management program (Attachment A). The committee recommends that the City Council
consider these quality‐of‐life topics in decisions that affect the future of Carlsbad.
This [document] reflects the committee’s recommendations, developed based on consensus, to
the City Council on important topics that affect Carlsbad’s quality‐of‐life but are not
recommended to be included as standards in a growth management program.
MEMORANDUM
March 23, 2023
To: Honorable Mayor Blackburn and Members of the City Council
From: Carlsbad Tomorrow: Citizens Committee on Growth Management
Via: Eric Lardy, City Planner
Re: Recommendations related to quality of life and city operations raised during the
Carlsbad Tomorrow Committee process
In March 2022, the City Council established the Carlsbad Tomorrow: Growth Management
Citizens Committee with the mission to “…promote balanced consideration of a range of
perspectives on issues affecting the future growth and quality of life in Carlsbad and to identify
the key elements of a new plan to manage growth in Carlsbad in a way that maintains an
excellent quality of life while also complying with state law.”
This memorandum identifies the committee’s recommendations to the City Council on important
topics that affect Carlsbad’s quality‐of‐life but are not recommended to be included as standards
in a growth management program (Attachment A).
[Document Title]
April 20, 2023
Page 4
Background
In 1986 the Carlsbad City Council passed a growth management ordinance and the Carlsbad
Voters passed Proposition E, which affirmed the growth management program and established
caps on the number of housing units that could be built in Carlsbad. A key component of the
program is that public facilities are required to be provided concurrent with and funded by
development. The program also included provisions that created a moratorium on development
if the standards were not met. This program was successfully implemented for approximately 30
years.
Recent changes to state law have resulted in changes to some of the original requirements of the
program, specifically that the dwelling unit caps and moratorium provisions are no longer
enforceable. In 2017 the California Legislature passed Senate Bill (SB) 166, known as the No Net
Loss Law, which requires local jurisdictions to ensure that their Housing Element inventories can
accommodate, at all times throughout the planning period, their remaining unmet share of the
regional housing need. In 2019, the legislature passed SB 330, the Housing Crisis Act of 2019,
which prohibits local jurisdictions from imposing moratoriums on housing development and
using residential housing caps or other limits to regulate the number of housing units built within
a jurisdiction. The City Council passed resolutions that suspended portions of the growth
management program in 2020 and 2021.
Discussion
Considering these changes in state law and required actions, a City Council goal for fiscal year
2021‐2022 was to “engage the community through a citizens committee to create a new plan to
manage growth in Carlsbad in a way that maintains an excellent quality of life.” The City Council
approved a charter for the Growth Management Plan Advisory Committee on Sept. 28, 2021. The
committee is comprised of 19 primary and 19 alternate members; 9 of which are selected by the
boards and commissions that advise the city on a variety of related topics. The remaining 10
members and alternates represent the four City Council districts and the city at‐large.
The charter for the committee states that, “The committee’s work will conclude with a
committee‐supported report recommending to the City Council the key elements of what should
be included in a new plan to manage growth and achieve an excellent quality of life while
maintaining compliance with state law.”
The City Council formed the committee on March 8, 2022. During the committee’s conversations
and deliberations through a series of 15 meetings from March 2022 to April 2023, the committee
decided on recommendations for new standards that would be included in a “plan to manage
growth” (provided in a separate report to the City Council). The committee also identified topics
that are of importance to Carlsbad’s quality of life but are not recommended to be included as
standards in a growth management plan (Attachment A). The committee recommends that the
City Council consider these quality‐of‐life topics in decisions that affect the future of Carlsbad.
Next Steps
[Document Title]
April 20, 2023
Page 5
City staff will continue to implement the FY 2022‐23 Operating Budget, Strategic Digital
Transformation Investment Program, and Capital Improvement Program, Future Operational
Plans, and any other plans and programs adopted by the City Council. City Staff will also
implement any additional direction received.
Attachments: A. Quality of Life Statements
cc: Scott Chadwick, City Manager
Cindie McMahon, City Attorney
Ron Kemp, Senior Assistant City Attorney
[Document Title]
April 20, 2023
Page 6
[DOCUMENT TITLE]QUALITY OF LIFE
STATEMENTS
The committee recommends the City Council consider the following statements
[statements/comments/title] on topics that are not directly associated with a growth
management standard but are tied to the quality of life within the city.
ARTS AND CULTURE (PROPOSED)
The arts are fundamentally intertwined with the City of Carlsbad’s quality of life as they give
the city a defining character and create a sense of place through aesthetics and culturally
enriching programs and events for all residents. A culturally thriving community is directly
related to economic growth; hence, the arts should be given higher priority by the City
Council in the Strategic Plan and Operating Budget.
The Committee believed that a 750‐seat cultural performing arts center would enhance the
quality of life in Carlsbad and believed serious consideration should be given by the City
Council to incorporate this in either the plans for a new city hall complex or to look at other
potential appropriates locations in the city to construct such a facility.
For more information about the committee's discussion on arts and culture, see the
committee’s minutes for meetings held on Nov. 30, 2022, and Jan. 26, 2023, and March 23,
2023. Additionally, the City of Carlsbad Arts & Culture Master Plan and the City of Carlsbad
Library & Cultural Arts programs and services have information on existing programs.
CARLSBAD ENERGY ADVISORY GROUP
The committee recommended the creation ofs a group of 5‐7 citizens charged with
providing the Mayor and City Council with an annual summary of all energy‐related
activities impacting the city’s residents and businesses. Topics included but are not limited
to:
o Electric commodity providers
o Energy reliability and safety
o SDG&E uUndergrounding programs
o Carlsbad’s peaker‐style power plant operations
o Renewable energy production (new solar installations, quantity of energy
produced, new technological advancements)
o Feasibility of microgrids
o Battery Energy storage
o Energy cost and sources
[Document Title]
April 20, 2023
Page 7
See the committee’s minutes for meeting held on Feb. 23, 2023.
FEES
The committee recommendeds the city evaluate all public facility impact fees on a regular
basis (no more than every five years) and update as needed. See the committee’s minutes
for meeting held on Dec. 15, 2022.
HOMELESSNESS
Homelessness is an important issue that impacts the quality of life for the residents of
Carlsbad and should remain a priority for the City Council in the Strategic Plan and
Operating Budget. The committee recognizesd the complex challenges of addressing the
impacts of homelessness and supports the continued efforts of the city’s Homeless
Outreach Team and affordable housing programs, as well as the Homelessness Action Plan.
See the committee’s minutes for the meeting held on Oct. 12, 2022.
OPEN SPACE
The committee has made a recommendation to modify the existing Growth Management
Open Space Standard (provided in a separate report).
Additionally, the committee recommendeds that the City Council addelevate the topic of
open space by adding it to the purview of the Parks & Recreation Commission to address
open space needs throughout the city; including, address potential open space deficits and
evaluate opportunities to acquire more open space updating the list of candidate
properties for proactive open space acquisition and by developing a plan that prioritizes
zones with less unconstrained open space or that are subject to loss due to sea level rise.
Adopt a policy that discourages exceptions to development standards that would decrease
open space.
See the committee’s minutes for meetings held on Sept. 22, 2022, Jan. 11, 2023, and Feb.
23, 2023, and March 23, 2023.
[Document Title]
April 20, 2023
Page 8
PROPOSITION H
During committee deliberation it was discussed that Proposition H, as implemented by
Carlsbad Municipal Code Chapter 1.24, has not been updated since it was passed by voters
in the 1980s. The committee recommended the City Council and it may be time to consider
a ballot measure increasing the expenditure limit due to increased project costs, and
indexing it to something like the Consumer Price Index so it can increase over time.
Additionally, the committee recommended the city set aside funding for public safety
capital improvement projects, such as fire stations, and specify in a future ballot measure
that certain types of projects don’t require voter approval to exceed the spending limit ($1
million).
See the committee’s minutes for meetings held on Oct. 12, 2022, and Jan. 26, 2023.
SENIORS / AGING COMMUNITY
The quality of life and needs of Carlsbad’s senior community and aging population is
important. The committee recognizeds and supporteds the city’s continued efforts to
ensure the needs of seniors are met, such as through the City of Carlsbad Age‐Friendly
Action Plan, City of Carlsbad Parks & Recreation Department senior programs and Senior
Center and the City of Carlsbad Senior Commission.
Carlsbad’s senior community and aging population should remain a priority for the City
Council in the Strategic Plan and Operating Budget.
See the committee’s minutes for the meeting held on Oct. 12, 2022.
[Document Title]
April 20, 2023
Page 9
TRANSPORTATION AND MOBILITY
The committee has made a recommendation to retain the existing Growth Management
Circulation (Mobility) Standard (provided in a separate report).
Additionally, on Jan. 26, 2023, the committee by consensus recommended that a statement
be added to this quality‐of‐life document to recommend that the city:
UtilizeLeverage the Sustainable Mobility Plan and Multimodal Transportation Impact Fee
to implement future multimodal transportation projects that provide the greatest
benefit to the community;
o Review of current facilities,
o Relationship between existing traffic operations, changing commute patterns,
regional traffic volume growth, traffic safety and new disruptive trends in mobility
technologies, and
o Development of standards and a fee structure for private development to provide
a fair share to partially fund the buildout of the city’s multimodal transportation
network.
Require new development to conduct intersection Level of Service and Multimodal
Level‐of‐Service analysis to determine direct project impacts in accordance with the
city’s Local Mobility Analysis Guidelines.
Complete the city’s typology‐based street network, as described in the General Plan
Mobility Element.
Update the Multimodal Transportation Impact Fee and include Local Mobility
Assessment with Level of Service for all modes.
Improve traffic signal synchronization to improve vehicle mobility and reduce the
potential environmental impacts from vehicle emissions related to the stop‐and‐go and
idling at intersections.
See the committee’s minutes for meetings held on July 28, 2022, Aug. 25, 2022, Dec. 15,
2022, and Jan. 26, 2023, and March 23, 2023.
Proposed Draft Language for the Carlsbad Tomorrow Quality of Life Memo
Essential to Carlsbad's civic identity is its seven miles of pristine coastline and beaches. The
coast is Carlsbad’s single most important defining character and is the heart to our quality of
life for all who live, work and recreate here.
The Envision Carlsbad Community Vision recognizes that “…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. In the future, the beach will be maintained as a
safe, accessible, and attractive recreational resource through partnerships with regional and
State agencies, and other organizations. 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.”
Other sections of the Envision Carlsbad report emphasize the importance of the small-town
feel, beach community character and connectedness of Carlsbad, and the importance of
walking and biking trails.
It is recognized that Carlsbad’s beaches and beach-front areas are under assault from
both man-made and environmental conditions that are severely depleting those
resources at a time when demand for such recreational space is increasing rapidly.
Shoreline preservation, beach erosion, sea-level rise and continuing adverse
weather-related influences are all causing great impacts for beach use and access, as
witnessed during the winter and spring storms that batter our coastline periodically,
and as recently as 2023.
The Carlsbad Tomorrow Committee strongly recommends that the City Council give top
priority to the expansion, protection, and enhancement of public access to, and community
use of, the shoreline at beach level and on the bluffs overlooking the beach in decisions
concerning active and passive park use, open space, enhanced pedestrian and bikes trails,
periodic sand replenishment, a dog beach area, park and/or outdoor venue areas for
community events, parking, lifeguard coverage, beach showers, and public restroom facilities.
Commercial/residential development permitted for such areas should be planned to return
substantial public recreational benefit.
1
Date: April 13, 2023
To: Carlsbad Tomorrow/Growth Management Citizens Committee
From: Steve Linke, Traffic & Mobility Commission primary representative
Subject: April 20, 2023 report review/proposed amendments
QUALITY OF LIFE TOPICS
Recommended document title
QUALITY OF LIFE RECOMMENDATIONS
Proposition H (Page 8)
The second bullet point contains a reference to the current $1 million limit, but I think it is even
more important to make that reference in the first bullet point, proposed as follows:
During committee deliberation it was discussed that the Proposition H limit of $1 million
on general fund capital expenditures, as implemented by Carlsbad Municipal Code
Chapter 1.24, has not been updated since it was passed by voters in 1982the 1980s…
GROWTH MANAGEMENT REPORT
Executive Summary (Page 6)
Add “Wasterwater Treatment Capacity” to the list of standards being recommended for
removal (only three of the four are currently listed).
Parks Standard (Pages 27-28)
The footnote for the Status table on Page 28 (agreed upon by consensus of the committee at
our meeting last month) included only the fact that the acreage of Veteran’s Memorial park
was being split equally among all four quadrants, even though the park is located entirely
within the northwest quadrant. Staff’s inclusion of the following additional language was not
discussed, which requires a re-opening of this topic:
…because of its size, centralized location and citywide significance, the park fulfills
citywide park facility needs. The city’s intention for the park to be a citywide park facility
dates to the adoption of the Growth Management Program in 1986.
The fact is, in 1986, the park’s Master Plan included an approximately 500-acre swath of land
that extended from just east of the strawberry fields to what is now College Boulevard and far
south of what is now Faraday Avenue (all of the yellow dotted line parcels on the following
map). City documents in that time period likened this sprawling future park complex to
“Balboa Park in San Diego and Golden Gate Park in San Francisco”!
2
Just within the approximately 100-acre portion that will now become Veteran’s Memorial Park
(red shaded area in the above image), the Master Plan—as it existed in 1986—included a
conference center, an interpretive center, an athletic center, an artisans village, tennis courts,
baseball/softball fields, and garden, picnic, and hiking areas. In a 1989 update, the athletic
center and artisans village were replaced with an amphitheater and cultural arts center. Other
parts of the 500-acre park were slated for a boating facility and beach access at the lagoon,
soccer fields, a botanical center, an agricultural preserve, restaurant and concession areas,
etc. See Attachment 1 for the 1989 Master Plan map.
The sheer size of the territory and all of these extensive buildings and activity areas were what
justified the proposed park’s classification as a regional park like Balboa Park that was worthy of
citywide treatment for growth management purposes. Attachment 2 shows how the city was
classifying what was then called Macario Canyon Park (Entry #18 on the second page) relative
to other parks, based on acreage and amenities.
However, over time, multiple parcels that were going to be leased (SDG&E and Kelly properties
to the west) were eliminated, and a large portion south of Faraday Avenue was converted to
the golf course. The final ~100-acre portion shaded in red (50% park/50% protected habitat)
largely only includes picnic and hiking areas, a playground, and a bike park—none of the
previously planned major amenities listed above.
3
During final review, the traffic study and the Planning Commission acknowledged that, Veterans
Memorial Park will now act more like a small community park—with less user trips (and only
trips redistributed from other parks), fewer amenities, and much smaller activities than many of
Carlsbad’s other community parks, like Alga Norte, Poinsettia, Stagecoach, etc., which are only
counted in their own quadrants.
Accordingly, I propose that the “Alternative Perspective” on the Veterans Memorial Park issue
on Page 27 be expanded to better convey the discussion and separate votes that occurred on
these matters at our 1/26/2023 meeting, as follows:
Alternative perspectives
• Some committee members preferred a citywide standard of 4 acres per 1,000
population.
• Some committee members preferred excluding acreage inaccessible to people and
restricting the acreage of Veterans Memorial Park to the northwest quadrant given
the significant reduction in its scope and elimination of the planned buildings and
activity areas that originally classified it as a citywide/regional park in 1986.
• In the end, the majority voted to retain the existing standard.
• To address the access to parks, a majority of the committee also voted to request
that City Council direct staff to evaluate the feasibility of a standard based upon a
distance measure to any publicly accessible park.
Open Space (Page 35)
The “Status” heading implies that the table beneath it directly addresses current compliance
with the performance standard, which it does not. There was supposed to be a statement
added to create transparency about that. However, the tiny footnote added to the bottom is
not obvious and is very confusing.
In the spirit of true transparency and ease of understanding, I propose that the “Status”
heading be changed to “Total open space inventory,” and that the footnote be replaced with
the following text directly under the new heading in the larger main paragraph font, as follows:
Total open space inventory
Note: The open space percentages in the following table represent total open space in
each zone, not just the unconstrained developable portion required to meet the 15%
performance standard.
Attachment 1: 1989 Macario Canyon Park Master Plan
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20
From:Don Christiansen
To:Growth Management Committee
Subject:SAN DIEGO Community Power commits to 100% renewable energy by 2035
Date:Wednesday, April 19, 2023 11:49:59 AM
http://enewspaper.sandiegouniontribune.com/infinity/article_share.aspx?guid=83a88161-ed84-46be-8c83-
d4a416896fb6
"The resolution didn’t provide a detailed list of actions needed to meet that
target. But San Diego Community Power spokesperson Jen LeBron said the
agency has a purchase agreement with Viking Solar Energy Generation and
Battery Storage Project in Imperial Valley and is reviewing proposals from
other solar developers, with projects planned for 2026 through 2028. It is also
pursuing infill and rooftop solar projects on warehouses and homes."
CAUTION: Do not open attachments or click on links unless you recognize the sender and
know the content is safe.
Dear Committee Members,
We should do more in our final work product to address the concerns of numerous Carlsbad residents
regarding the provision of a park at Ponto or preservation of the current open space in that area. Let me
start by reiterating our committee mission below, which twice mentions Quality of Life (QOL) within it.
The mission of the Carlsbad Tomorrow Growth Management Citizens Committee is to promote balanced
consideration of a range of perspectives on issues affecting the future growth and quality of life in
Carlsbad and to identify the key elements of a new plan to manage growth in Carlsbad in a way that
maintains an excellent quality of life while also complying with state law.
As committee members, an important purpose is to collectively ensure that we represent the residents
of Carlsbad as we amend the existing growth management plan to comply with the law, all while placing
a strong emphasis on maintaining and further enhancing our current QOL.
Despite hearing the comments of numerous Ponto Park advocates from the public in emails and at our
meetings, and also being provided with copies of several thousand signed petitions advocating for such,
the word “Ponto” only shows up once in our proposed final work product. This seems to ignore the
commentary provided by a large subset of residents, especially since the southwest region of quadrant 4
clearly does not meet the specs for provision of parks in the current growth management plan.
During the meetings, it was stated it was not within our purview to address specific entities such as
Ponto Park or open space in particular areas. I never completely understood the logic behind that
position as this topic is a very important general QOL consideration for all residents and visitors. An
important distinction is that the land on the east side of the Coast Highway between La Costa Avenue
and the Cape Rey Hilton is one of the only remaining open space areas left on our coast.
As rightly acknowledged by committee members Jeff Segall, Fred Briggs, and Allen Manzano in their
recently submitted joint statement related to Carlsbad beaches for the QOL memo, “Essential to
Carlsbad's civic identity is its seven miles of pristine coastline and beaches. The coast is Carlsbad’s single
most important defining character and is the heart to our quality of life for all who live, work and
recreate here.”
Anecdotally, I conducted my own straw poll asking over 100 residents from all four city quadrants what
they would like to see happen with this coastal area moving forward. Not a single individual preferred to
see commercial development preside over installation of a park there or just leaving the land the way it
is now as natural open space.
If the City Council were to act now in favor of maintaining the natural scenic beauty of this land as
opposed to supporting its commercial development, the QOL associated with this outcome could be
preserved forever. To that end, I propose that our final work product to the City Council include this as
one of our recommendations. The wording could be something like the below in either the Plan or QOL
memo.
The committee strongly recommends that the City Council take aggressive and timely action toward
maintaining the existing open space on the east side of the Coast Highway between La Costa Avenue
and the Cape Rey Hilton by either: (1) providing a Ponto Park, or; (2) by leaving the area as natural
open space. This enhancement to Carlsbad’s future QOL, as opposed to allowing commercial
development of the area, would be highly desirable to residents from all quadrants as well as visitors
to the area.
Thank you for your consideration,
Frank Caraglio
Council District 3 Primary Member
From:Lance Schulte
To:Growth Management Committee; Council Internet Email; City Clerk; Kyle Lancaster; Eric Lardy; "Smith,Darren@Parks"; Homer, Sean@Parks; "Sean Adams"; "Moran, Gina@Parks"; Boyle, Carrie@Coastal; "Prahler,Erin@Coastal"; Ross, Toni@Coastal
Cc:info@peopleforponto.com
Subject:Public input for Carlsbad LCPA-Parks Master Plan & Growth Management Plan Updates - do the right and smartthing for our future
Date:Thursday, April 20, 2023 8:27:05 AM
Attachments:Carlsbad is below National Average & worst of 24 SoCal Coastal cities in providing Parks in a 10-minute walk toresidents.pdfTPL Support for Ponto Park - 2022-3-11.pdfCTGMC key issues and suggestions -2022-12-6.pdfHistory of Open Space at Ponto - 2022-1-26.pdfSea Level Rise and Carlsbad DLCP-LUPA planned loss of OS at Ponto - 2022.pdf2022 General Comparative cost-benifits of Completing PCH-PCH Modification-Ponto Park - Part 1 of 2 (2).pdfCarlsbad 2019 proposed Draft LCP Amendment - People for Ponto 2021-Oct Updated Public Comments - CoastalRecreation.pdf
Dear Carlsbad City Council, Carlsbad Tomorrow Growth Management Committee, Parks and
Planning Commissions, and 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 February 2023 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, and Carlsbad’s Ponto Planning Area F and Site 18
planning and development applications, and
4. as public input to the CA Coastal Commission on Carlsbad’s proposed Local Coastal Program
Amendment.
In looking over the CTGMC’s proposed report and recommendations, it appears the attached data
and issues from over 5,000+ emails and extensive numbers of Carlsbad Citizens verbal comments
provided city staff and the CTGMC have not been addressed.
Failure of the city staff and city to address these issues and providing a much needed and TRUE and
significant Ponto Park (the last vacant land and opportunity to provide a true and meaningful Coastal
Park) will undermine the Coastal Recreation needs (and future economic and social sustainability) of
Carlsbad and future CA residents and visitors. Ponto has the last remaining vacant and unplanned
Coastal land for a 6-mile length of coast that is without Coastal Park. Buying Ponto Park is the far
better and magnitude CHEAPER means to provide a significant Coastal Park for this 6-mile length of
Coast (and ALL South Carlsbad) that is without a Coastal Park.
The CTGMC needs to responsibly address the data and issues thousands of Carlsbad and North
County Citizens and visitors have sent you. CTGMC and staff failure to address these issues will
forever negativity impact forever our quality of life and eliminate the last viable, least constrained,
and tax-payer effective option (Buying Ponto Park) for or future.
The CTGMC and city staff Own your decisions. Go down in history as being wise, true and doing the
right thing for the future. Don’t fail to address the FACTS and do nothing but kick-the-can-down-the
road. We are running out of road and going over the cliff; as Seal Level Rise erodes our Coastal
Recreation lands and our last vacant inland areas are vanishing. Your time is now or never to do the
right (and most tax-payer efficient) think – buy Ponto Park!
Lance Schulte
From: Lance Schulte [mailto:meyers-schulte@sbcglobal.net] Sent: Sunday, February 5, 2023 3:53 PMTo: 'committee@carlsbadca.gov'; 'Michele Hardy'; 'council@carlsbadca.gov'; 'City Clerk'; 'Kyle Lancaster';'Eric Lardy'; 'Smith, Darren@Parks'; 'Homer, Sean@Parks'; 'Moran, Gina@Parks'; 'Carrie Boyle'; 'Prahler,Erin@Coastal'; 'Ross, Toni@Coastal'; 'melanie@melanieforcarlsbad.com'Cc: 'info@peopleforponto.com'Subject: Public input for Carlsbad LCPA-Parks Master Plan & Growth Management Plan Updates -Carlsbad below national average and lowest So CA Coastal city in providing Parks within 10-minute walk
Dear Carlsbad City Council, Carlsbad Tomorrow Growth Management Committee, Parks and
Planning Commissions, and 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 February 2023 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, and Carlsbad’s Ponto Planning Area F and Site 18
planning and development applications, and
4. as public input to the CA Coastal Commission on Carlsbad’s proposed Local Coastal Program
Amendment.
For years Carlsbad Citizens have told the City that there is a need for a Park at Ponto:
· to provide for documented Coastal Recreation (i.e. Public Park) land use at Ponto,
· to correct for the conversion of a 12.8 acre Recreation Commercial land use to Residential
use and the elimination of planned Coastal Open Space at Ponto,
· to correct the Carlsbad’s Park Master Plan documented lack of Park Service at Ponto,
· to provide South Carlsbad (62% of Carlsbad’s total population and the City’s major Coastal
visitor and transit occupancy tax generator) with their ONLY Coastal Park west of I-5. The
City unfairly, and contrary to CA Coastal Act Policy disproportionally provides 10 parks
totaling 37 acres west of I-5 in Coastal North Carlsbad for 38% of the population but 0 (zero)
Coastal Parks and 0 (zero) Coastal park acres west of I-5 in Coastal South Carlsbad for 62% of
the population,
· to provide for an existing 6.5 acre local Neighborhood (i.e. Special use area) Park need at
Ponto, and
· to provide a City Park within a 10-minute walk for Ponto residents.
Failure to correct this documented City Park unfairness is very damaging to the citizens, City
finances, South Carlsbad’s and California’s visitor industry. The Coastal Recreation data file sent to
you earlier documents some of the key facts.
However, we conducted some additional Trust for Public Land 10-minute walk data collection that
the City Council, CTGMC, Parks and Planning Commissions and CA Coastal Commission need to also
consider. That data is below and in the attached file, and again with last year’s Trust for Public Land
Ponto Park support letter (again attached) that reflects on Carlsbad poor performance relative to the
24 So Cal Coastal Cities (165 miles of coastline) from Malibu to the Mexican border in providing
Parks within a 10-minute walk. The data and links to the data source is:
Carlsbad is 10% below the national average for cities & the
worst of 24 Coastal So California cities - 165 miles of coastline -
in providing Parks within a 10-minute walk to residents
The Trust for Public Land documents a city’s 10-minute walk to Park at
https://www.tpl.org/parkserve
The Average USA City provides Parks within 10-minute walk to 55% of residents [10% above
Carlsbad].
Carlsbad provides Parks within 10-minute walk to 49.9% of residents [10% below National
Average].
New York City provides Parks within 10-minute walk to 99% of residents.
The Trust of Public Land submitted a letter to the City of Carlsbad, CA
Coastal Commission, and CA State Park supporting Ponto Park
Carlsbad is the worst of 24 Southern CA Coastal cities (from Malibu south to Imperial
Beach along 165 miles of coastline) in providing Parks within 10-minute walk to residents:
1. Palos Verdes Estates provides Parks within 10-minute walk to 100% of residents
2. El Segundo provides Parks within 10-minute walk to 100% of residents
3. Hermosa Beach provides Parks within 10-minute walk to 100% of residents
4. Redondo Beach provides Parks within 10-minute walk to 98% of residents
5. Manhattan Beach provides Parks within 10-minute walk to 95% of residents
6. Del Mar provides Parks within 10-minute walk to 93% of residents
7. Dana Point provides Parks within 10-minute walk to 89% of residents
8. Huntington Beach provides Parks within 10-minute walk to 85% of residents
9. Long Beach provides Parks within 10-minute walk to 84% of residents
10. Laguna Beach provides Parks within 10-minute walk to 82% of residents
11. Santa Monica provides Parks within 10-minute walk to 82% of residents
12. San Diego provides Parks within 10-minute walk to 81% of residents
13.Coronado provides Parks within 10-minute walk to 76% of residents
14. Newport Beach provides Parks within 10-minute walk to 76% of residents
15. Imperial Beach provides Parks within 10-minute walk to 74% of residents
16. Encinitas provides Parks within 10-minute walk to 68% of residents
17. Los Angeles provides Parks within 10-minute walk to 63% of residents
18. Solana Beach provides Parks within 10-minute walk to 63% of residents
19. Oceanside provides Parks within 10-minute walk to 58% of residents
20. Seal Beach provides Parks within 10-minute walk to 57% of residents
21. Malibu provides Parks within 10-minute walk to 53% of residents
22. San Clemente provides Parks within 10-minute walk to 52% of residents
23. Rancho Palos Verdes provides Parks within 10-minute walk to 50% of residents
24. Carlsbad provides Parks within 10-minute walk to 49.9% of residents.
Carlsbad is the lowest & most unfair to citizens of the 24 Southern California Coastal
cities along 165 miles of coast from Malibu to Imperial Beach.
Source of data: Trust for Public land parkscores
Trust for Public Land’s 10-minute walk to Park Maps/data:
Carlsbad = https://parkserve.tpl.org/mapping/index.html?CityID=0611194#reportTop
Encinitas = https://parkserve.tpl.org/mapping/index.html?CityID=0622678
Irvine = https://parkserve.tpl.org/mapping/index.html?CityID=0636770
Please, Please, please, consider and discuss this data, and
1. Create a 10-minute walk to City Park Standard in the
a. Parks Master Plan,
b. Growth Management Plan Update, and
c. Local Coastal Program Update.
2. Create a Park Policy that requires developers to dedicate Park Land (not pay Park-in-lieu-
fees) in areas that do not a minimum of 3 acers of City Park for each in 1,000 population
within a 10-minute walk of the developer’s proposed development (see attached CTGMC
Key Issues & Suggestions file for details and Open Space suggestions)
3. Fix Coastal South Carlsbad’s documented City Park inequity/unfairness with a significant and
real Ponto Park
4. Save tax-payers tens of millions in dollars by cost effectively purchasing vacant land at Ponto
for a Park, v. trying to maybe make a few bits of narrow PCH roadway median as a pseudo-
park
· Do you want Carlsbad to be the worst city in Coastal Southern California in providing accessible
Parks within a 10-minute walk to residents?
· Do you want Carlsbad to fail to upgrade its park standards while other cities updated their park
Standards and make their cities more desirable?
· Do you want to undermine the quality of life for Carlsbad citizens and their children by not
providing a park within a 10-minute walk to their home?
· Do you want to force Carlsbad families to have to drive to park?
· Do you want to slowly undermine a key visitor serving industry in South Carlsbad by not
providing a significant and true and meaningful Coastal Park in South Carlsbad?
· Do you want tax-payers to pay tens of millions more to try to maybe try to make a few narrow
portions of PCH median useable to people?
Please take responsibility and full ownership of your decisions on these important issues and
questions. The individual decisions you make will likely be the last ones made. Once vacant land like
at Ponto is developed it will be forever lost to address the critical, well documented Park and Coastal
Park needs at Ponto as overwhelmingly communicated by Carlsbad Citizens and visitor businesses,
and other citizens.
Please be wise and think about the future your decisions will bring.
Thank you,
Lance Schulte
PS: The initial version of the “CTGMC key issues and Suggestions 2022-12-6” file (attached) 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
CAUTION: Do not open attachments or click on links unless you recognize the sender and
know the content is safe.
Carlsbad is 10% below the national average for cities & the worst of
24 Coastal So California cities - 165 miles of coastline - in providing
Parks within a 10-minute walk to residents
The Trust for Public Land documents a city’s 10-minute walk to Park at https://www.tpl.org/parkserve
The Average USA City provides Parks within 10-minute walk to 55% of residents [10% above Carlsbad].
Carlsbad provides Parks within 10-minute walk to 49.9% of residents [10% below National Average].
New York City provides Parks within 10-minute walk to 99% of residents.
The Trust of Public Land submitted a letter to the City of Carlsbad, CA Coastal
Commission, and CA State Park supporting Ponto Park
Carlsbad is the worst of 24 Southern CA Coastal cities (from Malibu south to Imperial Beach along 165
miles of coastline) in providing Parks within 10-minute walk to residents:
1. Palos Verdes Estates provides Parks within 10-minute walk to 100% of residents
2. El Segundo provides Parks within 10-minute walk to 100% of residents
3. Hermosa Beach provides Parks within 10-minute walk to 100% of residents
4. Redondo Beach provides Parks within 10-minute walk to 98% of residents
5. Manhattan Beach provides Parks within 10-minute walk to 95% of residents
6. Del Mar provides Parks within 10-minute walk to 93% of residents
7. Dana Point provides Parks within 10-minute walk to 89% of residents
8. Huntington Beach provides Parks within 10-minute walk to 85% of residents
9. Long Beach provides Parks within 10-minute walk to 84% of residents
10. Laguna Beach provides Parks within 10-minute walk to 82% of residents
11. Santa Monica provides Parks within 10-minute walk to 82% of residents
12. San Diego provides Parks within 10-minute walk to 81% of residents
13. Coronado provides Parks within 10-minute walk to 76% of residents
14. Newport Beach provides Parks within 10-minute walk to 76% of residents
15. Imperial Beach provides Parks within 10-minute walk to 74% of residents
16. Encinitas provides Parks within 10-minute walk to 68% of residents
17. Los Angeles provides Parks within 10-minute walk to 63% of residents
18. Solana Beach provides Parks within 10-minute walk to 63% of residents
19. Oceanside provides Parks within 10-minute walk to 58% of residents
20. Seal Beach provides Parks within 10-minute walk to 57% of residents
21. Malibu provides Parks within 10-minute walk to 53% of residents
22. San Clemente provides Parks within 10-minute walk to 52% of residents
23. Rancho Palos Verdes provides Parks within 10-minute walk to 50% of residents
24. Carlsbad provides Parks within 10-minute walk to 49.9% of residents.
Carlsbad is the lowest & most unfair to citizens of the 24 Southern California Coastal cities along
165 miles of coast from Malibu to Imperial Beach.
Source of data: Trust for Public land parkscores
Trust for Pulic Land’s 10-minute walk to Park Maps/data:
Carlsbad = https://parkserve.tpl.org/mapping/index.html?CityID=0611194#reportTop
Encinitas = https://parkserve.tpl.org/mapping/index.html?CityID=0622678
Irvine = https://parkserve.tpl.org/mapping/index.html?CityID=0636770
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.
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 1 of 7
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto
Introduction:
Carlsbad first documented Sea Level Rise (SLR) and associated increases in coastal erosion in a
December 2017 Sea Level Rise Vulnerability Assessment (2017 SLR Assessment). Prior planning activities
(2010 Ponto Vision Plan – rejected by CA Coastal Commission, and 2015 General Plan Update) did not
consider SLR and how SLR would impact Coastal Open Space Land Use & CA Coastal Act ‘High-Priority’
Coastal Open Space Land Uses at Ponto. The 2017 SLR Assessment shows Open Space land and Open
Space Land Uses are almost exclusively impacted by SLR at Ponto & South Coastal Carlsbad. The 2017
SLF Assessment also shows significant LOSS of Open Space land acreage and Land Uses. Most all
impacted Open Space Land Uses are CA Coastal Act “High-Priority Coastal Land Uses” – Coastal
Recreation (i.e. Public Park) and Low-Cost Visitor Accommodations. Existing Ponto Open Space Land
Uses are already very congested (non-existent/narrow beach) and have very high, almost exclusionary,
occupancy rates (Campground) due to existing population/visitor demands. Future population/visitor
increases will make this demand situation worst. The significant permanent LOSS of existing Coastal
Open Space land and Coastal Open Space Land Use (and land) due to SLR reduces existing supply and
compounds Open Space congestion elsewhere. Prior Ponto planning did not consider, nor plan, for
significant SLR and current/future “High-Priority” Coastal Open Space Land Use demands.
Open Space and City Park demand at Ponto:
Open Space at Ponto is primarily ‘Constrained’ as defined by the City’s Growth Management Program
(GMP), and cannot be counted in meeting the City’s minimal 15% ‘Unconstrained’ GMP Open Space
Standard. Per the GMP Open Space Standard, the developers of Ponto should have provided in their
developments at least 30-acres of additional ‘Unconstrained’ GMP Open Space at Ponto. City GIS
mapping data confirm 30-acres of GMP Standard Open Space is missing at Ponto (Local Facilities
Management Plan Zone 9).
The City of Carlsbad GIS Map on page 2 shows locations of Open Spaces at Ponto. This map and its
corresponding tax parcel-based data file document Ponto’s non-compliance with the GMP Open Space
Standard. A summary of that City GIS data file is also on page 2. The City said Ponto’s non-compliance
with the GMP Open Space Standard was ‘justified’ by the City ‘exempting’ compliance with the
Standard. The City ‘justified’ this ‘exemption’ for reasons that do not appear correct based on the City’s
GIS map and data on page 2, and by a review of 1986 aerial photography that shows most of Ponto as
vacant land. The City in the Citywide Facilities Improvement Plan (CFIP) said 1) Ponto was already
developed in 1986, or 2) Ponto in 1986 already provided 15% of the ‘Unconstrained’ land as GMP
Standard Open Space. Both these ‘justifications’ for Ponto ‘exemption’ in the CFIP were not correct.
The legality of the City ‘exempting’ Ponto developers from the GMP Open Space Standard is subject to
current litigation.
The City proposes to continue to exempt future Ponto developers from providing the missing 30-acres of
minimally required GMP Open Space, even though a change in Ponto Planning Area F land use from the
current ‘Non-Residential Reserve” Land Use requires comprehensive Amendment of the Local Facilitates
Management Plan Zone 9 to account for a land use change. City exemption is subject of litigation.
Ponto (west of I-5 and South of Poinsettia Lane) currently has 1,025 homes that per Carlsbad’s minimal
Park Standard demand an 8-acre City Park. There is no City Park at Ponto. Coastal Southwest Carlsbad
has an over 6.5 acre Park deficit that is being met 6-miles away in NW Carlsbad. Ponto is in the middle
of 6-miles of Coastline without a City Coastal Park west of the rail corridor.
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 2 of 7
City GIS map of Ponto’s (LFMP Zone 9)
Open Space:
Light green areas meet the City’s 15%
unconstrained Growth Management
Program Open Space Standard
Most Ponto Open Space (pink hatch &
blue [water] on map) is “Constrained”
and does not meet the Standard
Aviara - Zone 19, Ponto - Zone 9 and
Hanover/Poinsettia Shores – Zone 22
all developed around the same time
and had similar vacant lands.
City required Aviara - Zone 19 east of
Ponto to provide the 15% Standard
Open Space. Why not Ponto? Aviara
had the same lagoon waters.
City required Hanover & Poinsettia
Shores area Zone 22 just north of
Ponto to provide the 15% Standard
Open Space. Why not Ponto?
Why Ponto developers were never
required to comply with the 15%
Standard Open Space is subject to
current litigation
Below is City GIS data from this map
City GIS map data summary of the 15% Growth Management Standard Open Space at Ponto
472 Acres Total land in LFMP Zone 9 [Ponto]
(197 Acres) Constrained land excluded from GMP Open Space
275 Acres Unconstrained land in LFMP Zone 9 [Ponto]
X 15% GMP Minimum Unconstrained Open Space requirement
41 Acres GMP Minimum Unconstrained Open Space required
(11 Acres) GMP Open Space provided & mapped per City GIS data
30 Acres Missing Unconstrained Open Space needed in LFMP Zone 9 [Ponto] to meet the City’s
minimum GMP Open Space Standard per City’s GIS map & data
73% of the City’s minimum 15% required Open Space Standard is missing due to over
development of LFMP Zone 9 [Ponto]
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Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 3 of 7
Sea Level Rise impacts on Open Space and Open Space Land Use Planning at Ponto:
The City’s 2015 General Plan Update did not factor in the impacts of Sea Level Rise (SLR) on Ponto’s
Open Space land. In December 2017 the City conducted the first Sea Level Rise Vulnerability
Assessment https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=33958. The 2017 SLR
Assessment is an initial baseline analysis, but it shows significant SLR impacts on Ponto Open Space.
More follow-up analysis is being conducted to incorporate newer knowledge on SLR projections and
coastal land erosion accelerated by SLR. Follow-up analysis may likely show SLR impacts occurring
sooner and more extreme.
Troublingly the 2017 SLR Assessment shows SLR actually significantly reducing or eliminating Open
Space land at Ponto. SLR is projected to only impact and eliminate Open Space lands and Open Space
Land Use at Ponto. The loss of Ponto Open Space land and Land Use being at the State Campground,
Beaches, and Batiquitos Lagoon shoreline. The losses of these Open Space lands and land uses would
progress over time, and be a permanent loss. The 2017 SLR Assessment provides two time frames near-
term 2050 that match with the Carlsbad General Plan, and the longer-term ‘the next General Plan
Update’ time frame of 2100. One can think of these timeframes as the lifetimes of our children and
their children (2050), and the lifetimes of our Grandchildren and their children (2100). SLR impact on
Coastal Land Use and Coastal Land Use planning is a perpetual (permanent) impact that carries over
from one Local Coastal Program (LCP) and City General Plan (GP) to the next Updated LCP and GP.
Following (within quotation marks) are excerpts from Carlsbad’s 2017 Sea Level Rise Vulnerability
Assessment:
[Italicized text within brackets] is added data based on review of aerial photo maps in the Assessment.
“Planning Zone 3 consists of the Southern Shoreline Planning Area and the Batiquitos Lagoon. Assets
within this zone are vulnerable to inundation, coastal flooding and bluff erosion in both planning
horizons (2050 and 2100). A summary of the vulnerability assessment rating is provided in Table 5. A
discussion of the vulnerability and risk assessment is also provided for each asset category.
5.3.1. Beaches
Approximately 14 acres of beach area is projected to be impacted by inundation/erosion in 2050. …
Beaches in this planning area are backed by unarmored coastal bluffs. Sand derived from the natural
erosion of the bluff as sea levels rise may be adequate to sustain beach widths, thus, beaches in this
reach were assumed to have a moderate adaptive capacity. The overall vulnerability rating for beaches
is moderate for 2050.
Vulnerability is rated moderate for the 2100 horizon due to the significant amount of erosion expected
as the beaches are squeezed between rising sea levels and bluffs. Assuming the bluffs are unarmored in
the future, sand derived from bluff erosion may sustain some level of beaches in this planning
area. A complete loss of beaches poses a high risk to the city as the natural barrier from storm waves is
lost as well as a reduction in beach access, recreation and the economic benefits the beaches provide.
5.3.3. State Parks
A majority of the South Carlsbad State Beach day-use facilities and campgrounds (separated into
four parcels) were determined to be exposed to bluff erosion by the 2050 sea level rise scenario
(moderate exposure). This resource is considered to have a high sensitivity since bluff erosion
could significantly impair usage of the facilities. Though economic impacts to the physical structures
within South Carlsbad State Beach would be relatively low, the loss of this park would be significant
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 4 of 7
since adequate space for the park to move inland is not available (low adaptive capacity). State
parks was assigned a high vulnerability in the 2050 planning horizon. State park facilities are recognized
as important assets to the city in terms of economic and recreation value as well as providing low-cost
visitor serving amenities. This vulnerability poses a high risk to coastal access, recreation, and
tourism opportunities in this planning area.
In 2100, bluff erosion of South Carlsbad State Beach day-use facilities and campgrounds become
more severe and the South Ponto State Beach day-use area becomes exposed to coastal flooding
during extreme events. The sensitivity of the South Ponto day-use area is low because impacts to usage
will be temporary and no major damage to facilities would be anticipated. Vulnerability and risk to State
Parks remains high by 2100 due to the impacts to South Carlsbad State Beach in combination
with flooding impacts to South Ponto.
Table 5: Planning Zone 3 Vulnerability Assessment Summary [condensed & notated]:
Asset Horizon Vulnerability
Category [time] Hazard Type Impacted Assets Rating
Beaches 2050 Inundation/Erosion, Flooding 14 acres (erosion) Moderate
2100 Inundation/Erosion, Flooding 54 acres (erosion) Moderate
Public Access 2050 Inundation, Flooding 6 access points Moderate
4,791 feet of trails
2100 Inundation, Flooding 10 access points Moderate
14,049 feet of trails
State Parks 2050 Flooding, Bluff Erosion 4 parcels [<18 Acres] High
[Campground - 2100 Flooding, Bluff Erosion 4 parcels [>18 Acres] High
Low-cost Visitor [loss of over 50% of
Accommodations] the campground &
its Low-cost Visitor
Accommodations,
See Figure 5.]
Transportation 2050 Bluff Erosion 1,383 linear feet Moderate
(Road, Bike, 2100 Flooding, Bluff Erosion 11,280 linear feet High
Pedestrian)
Environmentally 2050 Inundation, Flooding 572 acres Moderate
Sensitive 2100 Inundation, Flooding 606 acres High
Lands
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 5 of 7
.,,...,,~c;........,,...,,
D 11~•\;ll)-<(.I>' Cb•
Southern Shortfine PlanningArEa-Year 2050
CXIUOITOG
1,:::,1 .. ,
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 6 of 7
[Figure 5 show the loss of over 50% of the campground and campground sites with a minimal .2 meter
Sea Level Rise (SLR), and potentially the entire campground (due to loss of access road) in 2 meter SLF.]”
Directions to analyze and correct current and future LOSS of Coastal Open Space Land Use at Ponto
On July 3, 2017 the CA Coastal Commission provided direction to Carlsbad stating:
“The existing LUP includes policies that require certain visitor-serving developments and/or
studies relevant to the Ponto … area. For example, Planning Area F requires the city and
developer to "consider and document the need for the provision of lower cost visitor
accommodations or recreational facilities (i.e., public park) on the west side of the railroad. …
this study should be undertaken as a part of the visitor serving use inventory analysis described
above. If this analysis determines that there is a deficit of low cost visitor accommodations or
recreation facilities in this area, then Planning Area F should be considered as a site where these
types of uses could be developed.”
Official Carlsbad Public Records Requests (PRR 2017-260, et. al.) confirmed Carlsbad’s Existing LCP and
its Ponto specific existing LUP polices and Zoning regulations were never followed in the City’s prior
Ponto planning activities (i.e. 2010 Ponto Vision Plan & 2015 General Plan Update). The projected SLR
loss of recreation (beach) and low-cost visitor accommodations (campground) at Ponto should factor in
this Existing LCP required analysis, and a LCP-LUP for Ponto and Ponto Planning Area F.
In a February 11, 2020 City Council Staff Report City Staff stated:
“On March 14, 2017, the City Council approved the General Plan Lawsuit Settlement Agreement
(Agreement) between City of Carlsbad and North County Advocates (NCA). Section 4.3.15 of the
Agreement requires the city to continue to consider and evaluate properties for potential
acquisition of open space and use good faith efforts to acquire those properties.”
{'Cityof
Carlsbad
C a l lfo r nl u Sea Level Rise Vulnerability Assessment
Figure 5: CoSMoS Bluff Erosion Projections by 2100
(CoSMoS-COAST 2015)
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 7 of 7
In 2020 NCA recommended the City acquire Ponto Planning Area F as Open Space. The status of City
processing that recommendation is unclear. However the Lawsuit Settlement Agreement and NCA’s
recommendation to the City should also be considered in the required Existing LCP analysis.
Summary:
Tragically Carlsbad’s’ Draft Local Coastal Program – Land Use Plan Amendment (DLCP-LUPA) is actually
planning to both SIGNIFICATLY REDUCE Coastal Open Space acreage, and to eliminate ‘High-Priority
Coastal Open Space Land Uses at Ponto due to SLR.
The Existing LCP requirements for Ponto Planning Area F to analyze the deficit of Coastal Open Space
Land Use should factor in the currently planned LOSS of both Coastal Open Space acreage and Coastal
Open Space Land Uses at Ponto due to SLR. As a long-range Coastal Land Use Plan this required LCP
analysis needs to also consider the concurrent future increases in both population and visitor demand
for those LOST Coastal Open Space acres and Coastal Open Space Land Uses.
It is very troubling that demand for these CA Coastal Act ‘High-Priority’ Coastal Open Space Land Uses is
increasing at the same time the current (near/at capacity) supply of these CA Coastal Act ‘High-Priority’
Coastal Open Space Land Uses is significantly decreasing due to SLR. Instead of planning for long-term
sustainability of these CA Coastal Act ‘High-Priority’ Coastal Open Space Land Uses for future
generations there appears to be a plan to use SLR and inappropriate (lower-priority residential) Coastal
Land Use planning to forever remove those CA Coastal Act ‘High-Priority’ Coastal Open Space Land Uses
from Ponto. CA Coastal Act Policies to address these issues should be thoroughly considered.
2021-2 proposed Draft Local Coastal Program – Land Use Plan Amendment (DLCP-LUPA) will likely result
in City and CA Coastal Commission making updates to the 2015 General Plan, based on the existing
Ponto Planning Area F LCP – LUP Policy requirements, Ponto Open Space issues, high-priority Coastal
Land Use needs, and SLR issues not addressed in the 2015 General Plan.
Page 1 of 30
Carlsbad Draft Local Coastal Program Amendment – Coastal Recreation Land Use
People for Ponto Updated Public Comments 10/12/2021
Updated Pubic Comments Coastal Recreation submitted on Oct 12th 2021:
On 10/8/21 the Carlsbad City Council and CA Coastal Commission were emailed data from an Official Carlsbad Public
Records Request (# R002393-092121) on the City of Carlsbad’s past compliance/noncompliance with the currently
exiting Mello II LCP Land Use Policies # 6-2, 6-4 & 6-10 Certified in the mid-1980s. The City’s documents show:
For Policy 6-2 the 200-300 acre Park called out in Policy 6-2 has been reduced to Veterans Park’s 91.5 acres,
of which only 54% or 49.5 acres is even useable as a Park. The City provided no documents on how a 200-
300 acre park called for in Policy 6-4 is now only 49.5 useable acres.
For Policy 6-4 there were no City documents were provided. There was no City Public discussion,
consideration, or City compliance with Policy 6-4 since the mid-1980’s.
For Policy 6-10 concerns providing Low Cost Visitor Accommodations. Public Parks are the lowest cost (free)
Visitor accommodating land use there is.
The 3 existing LCP Land Use Policies are important for Carlsbad, and California’s, Coastal land use resources. There
appears little to no discussion of the City’s past apparent failure to implementation of these 3 LCP LUPs in the current
City consideration of changes to the LCP.
Following is a copy of Public Records Request # R002393-092121: “Carlsbad’s Local Coastal Program (LCP) for the Mello
II Segment of Carlsbad’s Coastal Zone has long established land use Policies 6-2, 6-4 & 6-10 that were adopted by
Carlsbad and Certified by the CA Coastal Commission in the early/mid-1980’s. Mello II LCP Policies 6-2, 6-4 & 6-10 are
shown on page 86-87 of Carlsbad’s 2016 compiled LCP and are:
“POLICY 6-2 REGIONAL PARK: If the population of Carlsbad increases in accordance with SANDAG's projected
Series V Population Forecasts, it is estimated that Carlsbad will need to develop a new regional park
containing 200 to 300 acres in order to adequately serve the public. A location for a new regional park must,
therefore, be established. Consideration should be given to a facility within the Aqua Hedionda Specific Plan
Area, or adjacent lands. The Batiquitos Lagoon area should also be considered.
POLICY 6-4 NEED FOR ADDITIONAL OVERNIGHT CAMPING: Additional overnight camping facilities, the main
source of lower cost visitor and recreational facilities, are needed throughout the San Diego coastal region.
Additional facilities of this kind should be provided in a regional park within the Carlsbad area. This can be
accomplished in conjunction with an eventual Batiquitos Park, within the Aqua Hedionda Specific Plan Area,
and/or along with the development of private recreational facilities.
POLICY 6-10 LOWER COST VISITOR-SERVING RECREATIONAL USES: Lower cost visitor and recreational
facilities shall be protected, encouraged, and, where feasible, provided. Encourage a range of affordability
for overnight visitor accommodations. Evaluate the affordability of any new or redeveloped overnight visitor
accommodations, including amenities that reduce the cost of stay. Mitigation may be applied to protect and
encourage affordable overnight accommodations”
Page 2 of 30
The public record request is to see documents of:
City Staff reports, presentations and communications to the Carlsbad Planning and Parks Commissions, and
City Council regarding the City’s consideration and implementation of these 3 specific (6-2, 6-4, and 6-10)
Mello II LCP land use policies; and
Carlsbad Planning and Parks Commissions, and City Council minutes, resolutions and ordinances
documenting City of Carlsbad consideration and implementation of these 3 specific (6-2, 6-4, and 6-10)
Mello II LCP land use policies.”
Updated Pubic Comments on Coastal Recreation submitted on January 2021:
Over 11-months ago in a 1/29/20 1:56PM email People for Ponto Carlsbad citizens first provided the City of Carlsbad
both data and comments on 14 critical Coastal Recreation issues (see pages 5-30 below). The data and the 14 critical
issues do not seem to be receiving appropriate disclosure/presentation/discussion/consideration in the Dec 2, 2020
Staff Report to the Planning Commission. To assure the 26-pages of citizen data and requests in the 1/29/20 email was
received by the Planning Commission the file was re-emailed on 12/22/20 12:24pm and specifically addressed to City
Council, City Clerk, Planning Commission, Parks Commission, Housing Commission, HEAC, CA Coastal Commission, and
CA HCD. As citizens we request each of these 14 data points (with supporting data) be honestly considered.
In reading the Dec 2 Staff Report citizens conducted additional analysis of City Park data. That research further
reinforces and documents the 14 Critical Coastal Recreation issues and highlights the relatively poor amount of City Park
and Coastal Recreation planned by Carlsbad’s Staff proposed Draft LCP-LUPA. We hope the City Council and City
Commissions, and CA Coastal Commission & HCD will consider this additional analysis of City data and citizen input:
Coastal Zone data Carlsbad Oceanside Encinitas note or source
Coastline miles 6.4 3.9 6.0 Carlsbad Draft LCPA 201, Google Maps
Coastal Zone Acres 9,219 1,460 7,845 & Oceanside & Encinitas LCPs
Coastal Zone Acres 100% 16% 85% % relative to Carlsbad
City Park Standard data
City Park Standard 3 5 5 required park acres / 1,000 population
Park Standard % 100% 167% 167% % is relative to Carlsbad
Oceanside & Encinitas 'require' and plan for 67% MORE Parkland than Carlsbad
Carlsbad 'requires' and plans for ONLY 60% as much Parkland as Oceanside & Encinitas
Carlsbad only requires developers provide 60% of the parkland (or in-lieu fees) as Oceanside & Encinitas require
Encinitas has a ‘Goal’ to provide 15 acres of Park land per 1,000 population
Developed City Park 2.47 3.65 5.5 acres / 1,000 population
Developed Park 100% 148% 223% % is relative to Carlsbad
Oceanside provides 48% MORE developed park land than Carlsbad
Encinitas provide 123% MORE developed park land than Carlsbad
Carlsbad ONLY provides 68% and 45% as much Parks as Oceanside & Encinitas respectively
National Recreation & Park Asso. Metric: a typical City provides 1 park / 2,281 pop. & 9.9 Park acres / 1,000 population
Carlsbad (3 acre) Park Standard is ONLY 30% of what a typical City provides nationally
Carlsbad requires developers to provide, 70% LESS Park acres than typical City provides nationally
Page 3 of 30
National Recreation & Park Asso., Trust for Public Land, et. al.: 10 minute (1/2 mile) Walk to a Park Planning Goal
Both Oceanside and Encinitas plan parks to be within a 10-minute (1/2 mile) walk to homes.
Carlsbad DOES NOT plan Parks within walking distance to homes
Carlsbad is NOT providing equitable and walking/biking access to Parks
Some Carlsbad Parks that are not fully useable as Parks:
total Unusable
Existing Parks with park park % of park
Unusable Open Space acreage acres acres unusable reason unusable
Alga Norte - SE quadrant 32.1 10.7 33% 1/3 of park is a Parking lot not a park
In many other Carlsbad Parks a significant
percentage of those Parks are consumed by
paved parking lots and unusable as a Park.
Hidden Hills - NE quadrant 22.0 12.7 58% city identified unusable habitat open space
La Costa Canyon SE quadrant 14.7 8.9 61% city identified unusable habitat open space
Leo Carrillo - SE quadrant 27.4 16.5 60% city identified unusable habitat open space
Poinsettia - SW quadrant 41.2 11.1 27% city identified unusable habitat open space
Existing Park subtotal 137.4 59.9 44% 44% of these Parks are unusable as Parkland
Anticipated Future Park
development projects
Park - quadrant
Veterans - NW 91.5 49.5 54% estimated unusable habitat open space
Cannon Lake - NW 6.8 3.4 50% estimated unusable water open space
Zone 5 Park expansion - NW 9.3 0 0 appears 100% useable as a Park
Robertson Ranch - NE 11.2 0 0 appears 100% useable as a Park
Future park subtotal 118.8 52.9 45% 45% of Future Parks are unusable as Parks
Unusable Open Space acres
in Existing & Future Parks 256.2 112.8 44% 112.8 acres or 44% is unusable as Parks
112.8 acres or 44% of the Existing & Future Parks are unusable Open Space and can’t be used as Parkland
Based on City's minimum 3-acres/1,000 population Park Standard, 112.8 acres of Unusable Parkland means
37,600 Carlsbad Citizens (or 32.5% of Carlsbad's current population of 112,877) will be denied the minimum
amount of Parkland that they can actually use as a Park.
59.9 acres of Existing unusable ‘park’ / 3 acre park standard x 1,000 population = 19,967 Carlsbad citizens and
their children are currently being denied useable park land. 19,967 is 17.7% of Carlsbad’s current population.
In addition to these 19,967 existing citizens and their children denied park land, the City needs to develop
additional Park acreage in the NE, SW and SE quadrants to cover current shortfalls in meeting in the minimal 3
acre/1,000 population park standard for the current populations in the NE, SW and SE quadrants.
The current NE, SW and SE quadrants park acreage shortfalls are in addition to the 19,967 Carlsbad citizens
and their children that do not have the minimum 3 acres of parkland per 1,000 population
Current FY 2018-19 MINIMUM park acreage shortfalls are listed in the table below. They are:
o 4.3 acres for 1,433 people in NE quadrant,
o 6.8 acres for 2,266 people in SW quadrant, and
o 2.3 acres for 767 people in SE quadrant
Shortfall (excess) in
Current Quadrant
Min. Park standard by
population Future Park
Page 4 of 30
acres need acres % existing Park shortfalls are for NE, SW & SE quadrants
NW quadrant (-14.2) (-4,733) 107.6 91% Current NW parks are 14.2 acres over min. standard &
capacity for 4,733 more people at min. park standard.
91% of all Future City Parks are in NW quadrant
NE quadrant 4.3 1,433 11.2 9% Future Park will exceed minimum NE park standard
SW quadrant 6.8 2,266 0 0% No min. parks for 2,266 people in SW quad. Park deficit
SE quadrant 2.3 767 0 0% No min. parks for 767 SE quadrant Park deficit
A Park Standard minimum is just a “Minimum”. City policy allows the City to buy/create parks above the City’s current 3
acre/1,000 pop. MINIMUM (and lowest) Park Standard of surrounding Coastal cities. Carlsbad already did this in the NW
quadrant. It then added 3.1 more NW quadrant Park acres as part of the Poinsettia 61 Agreement. Poinsettia 61:
converted 3.1 acres of NW City land planned/zoned for Residential use to Open Space Park land use/zoning,
facilitated a developer building condos (increasing park demand) in the SW quadrant,
required the SW Quadrant developer pay $3 million to build the 3.1 acre NW quadrant park, and
required the SW Quadrant developer pay to convert 3.1 acres of NW Quadrant & 5.7 acres of SW Quadrant City
Park land to habitat that will be unusable as a City Park.
So Poinsettia 61 increased SW Quadrant development (that both increased SW Park Demand and expanded the current
SW Quadrant Park deceit) while simultaneously using SW Quadrant development to pay for the conversion of 3.1 acres
of residential land in the NW Quadrant to City Park (the NW Quadrant already has surplus park land per the City’s
minimum standard).
People for Ponto strongly supports creating City Parks above the City’s current low 3-acre per 1,000 population
minimum, as the City’s minimum standard is relatively low and substandard relative to other cities; many Carlsbad parks
have significant acreage that is in fact ‘unusable’ as a park. Most importantly People for Ponto Citizens think it is very
important to prioritize providing City Parks in areas of Park Inequity that are unserved by City Parks. However it seems
very unfair to the SW Quadrant citizens to be so unserved and starved of the bare minimum of City Parks while at the
same time funding City Parks in excess of City standard in other Quadrants.
The Poinsettia 61 illustrates a larger unfair (and dysfunctional) distribution of Quadrant based City Park demand and
supply that is keenly evident in the demands/supply funding and location disparity of Veterans Park. Most all the
development impact and park demand that paid Veterans Park fees came from the SW, SE and NE Quadrants yet the
Veterans Park (supply) is not in those SW, SE and NE Quadrants. This inequity is counter to the implicit City requirement
that City Parks be provided within the Quadrant of their Park demand. It is logical and proper that City Parks be
provided and equitably distributed to be close to the development and population that generated the Park demand.
The City Park inequity at Ponto and in other Coastal areas of the City is counter to several CA Coastal Act policies;
counter to good city planning and good CA Coastal planning. Park Inequity is highly detrimental to the City, and City and
CA citizens in the long-term; fails to properly distribute and match the location supply with the location of demand for
Parks; and is counter to basic fundamental issues of fairness. Since 2017 People for Ponto has tried to get the City
Council and Staff to address this inequity, specifically at Ponto, and to do so in a way that embraces a true and honest
Citizen-based planning process.
Page 5 of 30
Carlsbad Staff proposed Draft Local Coastal Program Amendment – People for Ponto comments submitted 1/29/2020
Coastal Recreation:
2. Request that the City as part of its Draft LCP Public Review process broadly-publicly disclose to all Carlsbad Citizens
the City’s acknowledged prior LCPA processing and planning “mistakes” regarding the requirement that the Ponto
area be considered as a public park: This disclosure is needed to correct about 20 years of City misrepresentation to
the public on the since 1996 and currently Existing LCP requirements at Ponto, and the City’s prior planning mistakes
at Ponto. Citizens have been falsely told by the City that all the Coastal planning at Ponto was done already and that
the City followed its Existing LCP regarding the need for a park at Ponto, and that this is already decided and could
not be reversed. This misinformation has fundamentally stifled public review and public participation regarding the
Coastal Zone. City failure to provide such a broad-public disclosure on the documented prior, and apparently
current proposed, “planning mistakes” would appear to violate the principles of Ca Coastal Act Section 30006. A
broad-public disclosure would for the first time allow citizens to be accurately informed on the Existing LCP
requirements at Ponto so they can provide informed public review and comment regarding the need for a Coastal
Park in in this last vacant ‘unplanned’ area. The requested broad-public disclosure by the City of the City past
mistakes and the Existing LCP requirements at Ponto is consistent with CA Coastal Act (CCA) “Section 30006
Legislative findings and declarations; public participation - The Legislature further finds and declares that the public
has a right to fully participate in decisions affecting coastal planning, conservation and development; that
achievement of sound coastal conservation and development is dependent upon public understanding and
support; and that the continuing planning and implementation of programs for coastal conservation and
development should include the widest opportunity for public participation.” The public cannot participate as
outlined in CCA Section 30006 if past City ‘mistakes’ and misrepresentations on Coastal planning at Ponto go
undisclosed to the public. If the public isn’t fully informed about the 20-years of LCP planning mistakes at Ponto
how could the public in the past (and now in the present) participate in the proposed LCP Amendment – Public
Participation as noted in Section 30006 above is the means to sound coastal conservation and development and is
“… dependent upon public understanding …”. The City’s past mistakes at Ponto need to be corrected by slightly
different a Draft LCP Amendment process than currently outlined by the City; a new process is needed that clearly,
opening and honestly informs and engages the public on the Existing LCP Ponto issues. The City’s current Draft LCP
Amendment process fails to follow CCA Section 30006 in that most all the citizens we encounter are as yet unaware
of the City’s Ponto mistakes and how they can participate in in the DLCPA process without that information. We see
this daily in conversations we have with our fellow citizens. We even saw at the Oct 20, 2019 Carlsbad Planning
Commission meeting that the Planning Commission was unaware of the planning mistakes at Ponto. How can a
decision body of the City make a decision without knowing about these prior ‘planning mistakes’ facts that surround
what they are being asked to decide on? Repeatedly since 2017 Carlsbad citizens and People for Ponto have asked
the City to fully acknowledge the City’s prior flawed planning at Ponto, and to correct that with ether maintaining
the Existing LCP Non-residential Reserve Land Use or restarting the Coastal Planning at Ponto with a true and
accurately informed Community-based Coastal Planning process consistent with Section 30006.
We request the City during the DLCPA Public Review period broadly and publicly disclose to all Carlsbad Citizens the
City’s acknowledged prior LCP and other “planning efforts” public participation processing and planning “mistakes”
regarding the requirement that the Ponto area be considered as a public park, and 1) provide a truly honest public
participation process on that disclosure consistent with CCA Section 30006 as part of the Draft LCP Amendment
process or 2) retain the Existing LCP Non-residential Reserve Land Use and require a comprehensive and honest
community-based redo of Coastal Resource planning at Ponto.
Page 6 of 30
3. City fully and publicly reply to and the City Council consider the 11-20-19 citizen concerns/requests regarding the
City’s proposed LCP Amendment process: Lance Schulte on 1/23/20 received an email reply by the City to his follow-
up email regarding the status of the 11/20/19 citizen concerns/requests public comments and letters presented to
the Planning Commission. This is appreciated, however it is request that the City fully publicly reply to the 11-20-19
citizen concerns/requests regarding the City’s proposed LCP Amendment process and present the to the City Council
11/20/19 citizen concerns/requests so the City Council can consider them and provide any direction to City Staff.
City Staff first presented a summary presentation of the proposed Draft LCP Amendment to the Carlsbad Planning
Commission on November 20, 2019, and indicated the public comment period would close on November in less than
2-weeks. Citizens and citizen groups provided public testimony to the Planning Commission, both verbally and in
two written letters. The CCC was copied on those letters. The testimony and letters noted significant concerns
about the City’s proposed LCP Amendment process and made three requests:
Disclose and provide a publically accessible ‘Redline Version’ of the Existing 2016/Proposed LCP land use
Plan and Policies so everyone can see the proposed changes to the Existing LCP.
Provide true Citizen Workshops on the major remaining vacant Coastal land that still have outstanding
Citizen Concern or objections. Citizen Workshops, when done right, are valuable means to openly educate,
discuss and work to consensus options. These areas, including Ponto, were/are subject to multiple lawsuits,
so true open and honest public workshops would provide an opportunity to openly and honestly discuss the
issues and hopefully build public consensus/support for solutions. This approach seems consistent with CCA
Section 30006, and common sense.
Extend the public comment period 6-months to allow Citizen Review of the Redline Version of the LCPA and
allow time for Citizen Workshops.
The City did extend the Public Review period 2-months over the holidays to January 31, 2020. This is appreciated
although many think this is inadequate given the significance of the Proposed Land Use Plan Amendments, and lack
of Redline Version to compare. The City and their consultants required several extra years beyond schedule prepare
the proposed LCP Amendments. The extra years of City Staff work reflects on the volume of the over 500-pages in
the documents and the time needed to understand the Existing LCP and then create an Amended LCP. Citizens
need sufficient time, proper comparative tools (redline) and a process (workshops) to understand the proposed LCP
Amendments that is reflective of extensive extra time needed by City Staff and consultants needed. Truncation of
lay public review to a few months for an Amendment that took paid professionals many years to produce seems a
more than a bit inappropriate. The City appears to be rejecting citizens’ request to be provided a ‘Redline Version’
of the Existing 2016/Proposed LCP land use Plan. So public review comments will tainted or will miss many issues
due having to manually cross-reference a 150-page Existing LCP LUP with a Proposed 350-page Proposed LCP LUP.
There will be unknown and unconsidered changes in the Draft LCP Amendment that the public and city and CCC
decision makers will not know about due to the lack of ‘Redline Version’.
The City also appears to reject citizen requests for true Citizen Workshops on the major remaining vacant Coastal
land that still have outstanding Citizen Concern – such as Ponto. Like Coastal Recreation issue #1 above the
following citizen requests appear consistent with CA Coastal Act (CCA) Section 30006, and the City’s rejection of that
requests seem counter to the CA Coastal Act.
We again request of the City to provide: 1) a ‘Redline Version’ to the public and decision makers, along with
sufficient time to review and comment on the ‘Redline Version’; and 2) true Citizen Workshops for Ponto and the
Page 7 of 30
other last remaining significant vacant Coastal lands in Carlsbad as part of the Draft LCP Amendment process, or as
part of deferred LCP Amendment process for those areas.
4. Coastal Zoned land is precious: the very small amount of remaining vacant Coastal land should be reserved for
“High-Priority” Coastal Recreation Land Uses under the CA Coastal Act to provide for the growing and forever
‘Buildout’ needs of Carlsbad and CA Citizens, and our visitors.
Less than 1.8% (76 square miles) of San Diego County’s 4,207 square miles is in Coastal Zone. This small area
needs to provide for all the forever Coastal needs of the County, State of CA, and Visitors. Upland Coastal
Recreation (Coastal Park) land use is needed to provide land to migrate the projected/planned loss of “High-
Priority” Coastal Recreation land uses due to Sea Level Rise impacts. There is only 76 miles of total coastline
in San Diego County; a significant amount is publicly inaccessible military/industrial land. So how the last
few portions of Coastal Land within Carlsbad (which is about 8% of San Diego County’s Coastline) is planned
for the forever needs for High-Coastal-Priority Recreation Land Use is critical for Carlsbad, San Diego, and
California Statewide needs into the future.
Most all the developable Coastal land in Carlsbad is already developed with Low-Coastal-Priority residential
uses. Only a very small percentage of Carlsbad’s developable Coastal land, maybe 1-2%, is still vacant. This
last tiny portion of fragment of vacant developable Coastal Land should be documented in the Draft LCP and
reserved for “High-Priority” Coastal Land uses – most critically Coastal Recreation – to address the growing
Coastal Recreation needs from a growing population and visitors. These growing needs are all the more
critical in that existing Coastal Recreation lands will be decreasing due to inundation and erosion due to
DLCPA planned Sea Level Rise.
This image of the western half of San Diego County graphically shows (in the blue line) the very small Coastal
Zone Area that needs to provide the Carlsbad’s and California’s Coastal Recreational needs for all San Diego
County residents and Visitors:
Page 8 of 30
We request that 1) the amount and location of remaining vacant Coastal land in Carlsbad be documented and
mapped and be reserved for high-priority Coastal Land Uses consistent with CCA Goals in Section 30001.5 “… (c) …
maximize public recreational opportunities in the coastal zone consistent with sound resources conservation
principles and constitutionally protected rights of private property owners. (d) Assure priority for coastal-
dependent and coastal-related development over other development on the coast. … “; 2). This data be used in
the City’s analysis and the public’s review and discussion about the City’s proposed Draft ‘Buildout’ Land Use Plan.
The City’s proposed Draft ‘Buildout’ Land Use Plan will forever lock in the amount “maximum public recreational
opportunities in the coastal zone” and will be the final Coastal Land Use Plan that is supposed to “assure priority for
coastal-dependent and coastal-related development over other development on the coast”. Most of Carlsbad’s
Coastal Zone is already developed or committed to low-priority land uses contrary to these CCA Goals, so how we
finally and forever plan to use of the last small remaining vacant Coastal Land is very important.
5. The proposed Draft LCP Amendment in Chapter 3 makes unfounded statements regarding the proposed
Amendment to the LCP Land Use Plan provision of “High-Priority” Coastal Recreation land use: On page 3-3, at the
beginning of the Chapter 3 – Recreation and Visitor Serving Uses the City correctly states that the CA Coastal Act
(CCA) places a high priority on maximizing Recreation uses, and cites multiple CCA Sections to that effect. The City’s
proposed Coastal Land Use Plan then states on page 3-5 that a high proportion of land in the City is dedicated open
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Page 9 of 30
space available for passive and active use, yet provides no justification or accurate metric to support this statement.
This is a critical unsubstantiated and speculative statement that is not supported by any comparative data (justifying
the “high proportion” statement). The City later in Chapter 3 compared the adjoining cities of Oceanside and
Encinitas to try to show how the proposed Draft LCP LUP Amendment provides higher levels of Visitor Serving
Accommodations. That ‘non-common denominator’ comparison was fundamentally flawed, as noted in a prior
separate Draft LCPA public review comment from People for Ponto regarding another high-priority Coastal land use
(visitor accommodations) planned for in Chapter 3, but at least it was an attempt to compare. However, for the
Coastal Recreation portion of Chapter 3, the City does not even attempt to provide any comparative data to support
(or justify) the proposed Coastal Recreation Land Use Plan and statements. The Coastal Recreation Chapter also fails
to disclose Carlsbad’s adopted City Park Master Plan (Park Service Area and Equity map) data that shows a clear
conflict between the CA Coastal Act Policy Sections noted at the beginning of Chapter 3 and Chapter 3’s proposed
Draft Coastal Recreation Land Use Plan.
Comparative Coastal Recreation: Comparing the Land Use Plan and policies of Oceanside, Carlsbad and Encinitas,
one finds Carlsbad’s proposed Coastal Recreational Plan and Policies are not “high”, but very low compared with
Oceanside and Encinitas. Carlsbad has a General Plan Park Standard of 3 acres of City Park per 1,000 Population.
Oceanside has a 5 acres of City Park Standard per 1,000 population, and Encinitas has a 15 acres per 1,000
population standard, and an in-lieu park fee requirement of 5 acres per 1,000 population. Carlsbad’s proposed
Coastal Recreation Land Use Plan is in fact not ‘high’ but is in fact the lowest of the three cities, with Carlsbad
providing only 40% of Oceanside’s park standard, and only 20% of Encinitas’s Park Standard. Citywide Carlsbad
currently has 2.47 acres of developed park per 1,000 population, Oceanside currently has 3.6 acres of developed
park per 1,000 population, and Encinitas currently has 5.5 acres of developed park per 1,000 population. Although
this data is citywide, it shows Carlsbad’s current amount of developed parkland is less than 70% of what Oceanside
currently provides, and less than 45% of what Encinitas currently provides. Carlsbad is not currently providing, nor
proposing a Coastal Land Use Plan to provide, a ‘high’ proportion of Coastal Recreation Land Use compared to
Oceanside and Encinitas.
On page 3-5 Carlsbad may be misrepresenting city open space that is needed and used for the preservation of
federally endangered species habitats and lagoon water bodies. This open space Land cannot be Used for Coastal
Recreation purposes; and in fact Land Use regulations prohibit public access and Recreational Use on these Lands
and water bodies to protect those endangered land and water habitats. 78% of Carlsbad’s open space is “open
space for the preservation of natural resources” and cannot be used for Coastal Parks and Recreational use.
Although “open space for the preservation of natural resources” does provide scenic or visual amenity, and this
amenity is addressed as a different coastal resource. Visual open space is not Coastal Recreation Land Use. It
appears Carlsbad is proposing in the Draft LCP Amendment to continue to, providing a ‘low’ percentage of Coastal
Park Land Use and Coastal Recreation Land Use compared to adjoining cities.
In addition to the comparatively low amount of Coastal Park land Carlsbad plans for, Carlsbad scores very poorly
regarding the equitable and fair distribution and accessibility of Coastal Parks and Coastal Recreation Land Uses.
Both the City of Oceanside and Encinitas have very robust and detailed Park and Land Use plans to promote an
equitable distribution of, and good non-vehicular accessibility, to their Coastal Parks. By comparison, Carlsbad’s park
land use plan scores poorly, as exemplified in Ponto and South Carlsbad. Ponto’s existing population requires about
6.6 acres of City Parkland per Carlsbad’s low 3 acres per 1,000 population standard. Yet the nearest City Park is
several miles away and takes over 50 minutes to walk along major arterial roadways and across Interstate 5 to
access. As such this nearest park is not an accessible park for Ponto children, and thus Ponto children have to play in
Page 10 of 30
our local streets to find a significantly large open area to play in. Ponto residents have to drive their kids to get to a
park increasing VMT and GHG emissions. The City’s proposed Coastal Recreation Land Use Plan ‘solution’ to Ponto’s
no-park condition, along with the City’s need to add an additional 6.5 acres of new City parks in Southwest Carlsbad
to comply with the Southwest Carlsbad’s 2012 population demand (at a ratio of 3-acre/1,000 population) is to
provide a City Park – Veterans Park – over 6-miles away from the Ponto and Southwest Carlsbad population need.
This makes a bad situation worse. The City’s proposed location is totally inaccessible to serve the needs of the
population of children or anyone without a car, that it is intended to serve in South Carlsbad. This City proposed
Coastal Recreation Land Use Plan ‘solution’ seems inappropriate and inconsistent with the CA Coastal Act and
common sense. During the City’s Veterans Park and budget community workshops citizens expressed a desire for a
Ponto Park to be the solution to our Ponto and Southwest Carlsbad Park deficits. Those citizen requests were not
apparently considered as part of the City’s proposed Draft Coastal Recreation Land Use Plan. Following is an image
summarizing the magnitude of citizen needs/desires expressed at the City’s Budget workshop. Note the number
and size of the text citing Ponto Park and South Carlsbad that reflects the number and magnitude/intensity of citizen
workshop groups’ input. The failure to acknowledge this public participation and data in the Coastal Recreation
Land Use Plan Park seems in conflict with CCA Sections 30006 and 30252(6):
For South Carlsbad there is a complete lack of any existing or planned City Coastal Park and park acreage west of I-5,
while North Carlsbad has 9 existing and 1 planned City Coastal Parks totaling 37.8 acres of City Coastal W of I-5
North Carlsbad. Not only is this unfair to South Carlsbad, it is also unfair to North Carlsbad as it increases VMT and
parking impacts in North Carlsbad because South Carlsbad is not providing the City Coastal Parks for South Carlsbad
resident/visitor demands. This City Park disparity is shown on Figure 3-1 of the Coastal Recreation Land Use Plan;
Page 11 of 30
however it more accurately illustrated in the following data/image from the adopted Carlsbad Park Master Plan’s
“Service Area Maps (Equity Maps)”. The image below titled ‘No Coastal Park in South Carlsbad’ shows Carlsbad’s
adopted “Park Service Area Maps (Equity Maps)” from the City’s Park Master Plan that says it maps “the population
being served by that park type/facility.” The added text to the image is data regarding park inequity and disparity in
South Carlsbad. The image compiles Carlsbad’s adopted Park “Park Service Area Maps (Equity Maps)” for
Community Parks and Special Use Area Parks that are the City’s two park acreage types produced by the City’s
comparatively low standard of 3 acre of City Park per 1,000 population. The City’s Park Service Area Maps (Equity
Maps) shows areas and populations served by parks within the blue and red circles. City data clearly shows large
areas of overlapping Park Service (areas/populations served by multiple parks) in North Carlsbad and also shows
large areas in South Carlsbad with No Park Service (areas/populations unserved by any parks) and Park Inequity in
South Carlsbad. It clearly shows the City’s Documented Park Need and Park inequity at Ponto. The Existing LCP LUP
for Ponto’s Planning Area F in is required to “consider” and “document” the need for a “Public Park”. The City’s
adopted Park Service Area Maps (Equity Maps) clearly shows the inequity of Coastal City Park between North and
South Carlsbad, and the need for Coastal Parks in South Carlsbad – particularly at Ponto. The City’s proposed Draft
‘Buildout’ Coastal Recreation Land Use Plan instead proposes to lock-in documented City Public Coastal Park
inequity and unserved Coastal Park demand at Ponto and South Carlsbad forever. It does so by proposing the last
vacant undeveloped/unplanned Coastal land – Ponto Planning Area F - in the unserved Ponto and South Carlsbad
coastline areas instead of being planned for much needed City Park and Coastal Recreation use be converted to
even more low-priority residential and general commercial land uses. These ‘low-priority” residential uses, by the
way, further increase City Park and Coastal Recreation demand and inequity in Coastal South Carlsbad. This is
wrong, and a proposed ‘forever-buildout’ wrong at the most basic and fundamental levels. The proposed Draft
Coastal Recreation Land Use Plan by NOT providing documented needed City parks for vast areas of Coastal South
Carlsbad is inconsistent with the CA Coastal Act policies and Existing LCP LUP requirements for Ponto Planning Area
F; and also inconsistent with fair/equitable/commonsense land use and park planning principles, inconsistent with
CA Coastal Commission social justice goals, inconsistent with social equity, inconsistent with VMT reduction
requirements, and inconsistent with common fairness. A different Coastal Recreation Land Use Plan should be
provided that provides for a socially equitable distribution of Coastal Park resources so as to would allow children,
the elderly and those without cars to access Coastal Parks. The proposed Draft ‘Buildout’ Coastal Recreation Land
Use Plan forever locking in the unfair distribution of City Parks appears a violation of the not only CCA Sections
30213, 30222, 30223, and 30252(6) but also the fundamental values and principles of the CA Coastal Act. The Draft
also appears a violation of Carlsbad’s Community Vision.
Page 12 of 30
A different Coastal Recreation Land Use Plan is required to provide a more equitable distribution of City Parks with
non-vehicular accessibility. Such a different plan would advance State and City requirements to reduce vehicle Miles
Traveled (VMT) and greenhouse gas emissions that contribute to climate change and sea level rise impacts. Please
note that the data for the above basic comparison comes from City of Carlsbad, Oceanside and Encinitas General
Plan and Park Master Plan documents.
Data shows the proposed Coastal Recreation Plan conflicts with the CA Coastal Act policy Sections. As mentioned
page 3-3 correctly states that the CA Coastal Act (CCA) places a high priority on maximizing Recreation Land Uses,
and pages 3-5 list multiple CA Coastal Act (CCA) policy Sections that confirm this. However, given the significant
statewide importance of Coastal Recreation Land Use, the City proposed ‘Buildout’ Coastal Recreation Land Use Plan
does not appear to adequately address and implement these CCA Policies, and most noticeably in the Ponto area of
South Carlsbad. Coastal Recreation is a significant Statewide High-Priority Land Use under the CCA. For a
substantially developed non-coastal-industry city like Carlsbad Coastal Recreation is likely the biggest land use issue.
This issue is even more elevated due to the fact that there are only a few small areas left of undeveloped Coastal
land on which to provide Coastal Recreation, and Carlsbad is proposing a Coastal ‘Buildout’ Land Use Plan on those
areas. The use of the last few remaining vacant portions of Coastal land for Coastal Recreation Land Use is the most
important land use consideration in the proposed Draft LCP Land Use Plan Amendment as population and visitor
growth will increase demands for Coastal Recreation. It is thus very surprising, and disturbing that the proposed
Coastal Recreation Land Use Plan is so short, lacks any comparative and demand projection data, lacks any resource
demand/distribution and social equity data, and lacks any rational and clear connection with CCA Policy and the
proposed ‘Buildout’ Coastal Land Use plan. This is all the more troubling given that:
The Ponto area represents the last significant vacant undeveloped/unplanned land near the coast in South
Carlsbad that can provide a meaningful Coastal Park.
The fact that the City’s Existing LCP requires the city consider and document the need for a “i.e. Public Park”
on Ponto’s Planning Area F prior to the City proposing a change of Planning Area F’s “Non-residential
No Coastal Park in South Carlsbad
• ppx. 6 miles of Coast
without a Coastal Park is a
Ci & Regional need
• South Carlsbad has 64,000
residents & thousands of
hotel visitors without a
Coastal park
• Closest park to Ponto is
Poinsettia Park, appro 2.5
miles across 1-5
• Proposed Veterans Park is
approx. 6 miles away
Page 13 of 30
Reserve” land use designation. The City has repeatedly failed to comply with this LCP LUP requirement, and
worse has repeatedly failed to honestly inform citizens of this LCP LUP requirement at planning Area F
before it granted any land use. The City, apparently implementing speculative developer wishes, has
repeatedly proposed changing Planning Area F’s Coastal Land Use designation to “low-priority” residential
and general commercial land uses without publically disclosing and following the Existing LCP LUP.
The City’s currently developed parks in the southern portion of the City do not meet the city’s
comparatively low public park standard of only 3 acres per 1,000 population. Since 2012 there has been
City park acreage shortfall in both SW and SE Carlsbad.
The Existing population of Ponto (west of I-5 and south of Poinsettia Lane) requires about 6.6 acres of Public
Park based on the City’s comparatively low public park standard of 3 acres per 1,000 population. There ois
no Public Park in Ponto. Adding more population at Ponto will increase this current park demand/supply
disparity.
Carlsbad and other citizens have since 2017 expressed to the City the strong need for a Coastal Park at
Ponto, and requested the City to provide a true citizen-based planning process to consider the Public Park
need at Ponto. The Citizens’ requested process is fully in-line with CCA Goals, Public Participation Policy,
Land Use Policies, and the Existing LCP Land Use Plan/requirements for Planning Area F and is the most
appropriate means to consider and document the need for a Public Park at Ponto as required by the Existing
LCP Land Use Plan.
Planning Area F is for sale, and a non-profit citizens group has made an offer to purchase Planning Area F for
a much needed Coastal Park for both Ponto and inland South Carlsbad residents and visitors. How should
these facts be considered by the City and CCC?
Carlsbad has no Coastal Parks west of I-5 and the railroad corridor for the entire southern half of Carlsbad’s
7-mile coastline.
The southern half of Carlsbad’s coastline is 5.7% of the entire San Diego County coastline and represents a
significant portion of regional coastline without a meaningful Coastal Park west of I-5 and the Railroad
corridor.
The City’s proposed Coastal Recreation Land Use Plan provides No Documentation, No Rational, and No
Supporting or Comparative Data to show the proposed Coastal Recreation Land Use Plan in fact complies
with the CA Coastal Act.
6. There is no Coastal Recreation/Park west of interstate 5 for all South Carlsbad, or half of the entire City. This is an
obviously unfair and inequitable distribution of Coastal Recreation/Park resources that should be corrected by
changes to the Draft LCP Land Use Amendment: The following image (which was sent to the City and CCC on several
prior communications) was first requested by former Carlsbad Councilman Michael Schumacher during a People for
Ponto presentation/request at the Oct 23, 2018 City Council meeting. The data compiled in the image shows how
the South Coastal Carlsbad (Ponto) is not served by a Park per the City’s adopted Parks Master Plan. The blue dots
on the map are park locations and blue circle(s) show the City’s Park Master Plan adopted Park Service Areas and
Park Equity. This data, from pages 87-88 of the City of Carlsbad Parks Master Plan, shows all City Parks (both
Community Parks and Special Use Areas in Coastal Carlsbad (except Aviara Park east of Poinsettia Park and west of
Alga Norte Park). The text on the left margin identifies the South Carlsbad Coastal Park (west of I-5) gap along with
the number of South Carlsbad Citizens (over half the City’s population) without a Coastal Park. The left margin also
identifies more local issues for the over 2,000 Ponto area adults and children. For Ponto residents the nearest Public
Park and City proposed ‘solution’ to the South Carlsbad and Ponto Public Park deficit are miles away over high-
speed/traffic roadways and thus somewhat hazardous to access and effectively unusable by children/the elderly or
Page 14 of 30
those without cars. Having been a 20-year resident of Ponto I regularly see our children have to play in the street as
there are no Public Park with large open fields to play at within a safe and under 1-hour walk away. Ponto citizens
have submitted public comments regarding this condition and the lack of a Park at Ponto
Ponto is at the center of regional 6-mile Coastal Park Gap. A Coastal Park in this instance being a Public Park with
practical green play space and a reasonable connection with the Coast (i.e. located west of the regional rail and
Interstate-5 corridors). The following image shows this larger regional Coastal Park Gap centered on the Ponto Area,
and the nearest Coastal Parks – Cannon Park to the north, and Moonlight Park to the south.
Regionally this image shows Ponto is the last remaining significant vacant Coastal land that could accommodate a
Coastal Park to serve the Coastal Park current needs of over existing 2,000 Ponto residents, 64,000 existing South
Carlsbad residents, and a larger regional population. It is also the only area to serve the Coastal Park needs for the
thousands of hotel rooms in Upland Visitor Accommodations in South Carlsbad.
No Coastal Park in South Carlsbad
• Appx. 6 miles of Coast
without a Coastal Park is a
City & Regional need
• South Carlsbad has 64,000
residents & thousands of
hotel visitors with out a
Coastal park
• Closest park to Ponto is
Poinsettia Park, approx. 2.5
miles across 1-5
• Proposed Veterans Park is
approx. 6 miles away --
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Page 15 of 30
As People for Ponto first uncovered and then communicated in 2017 to the City and CCC; Carlsbad’s Existing (since 1994)
Local Coastal Program LUP currently states (on page 101) that Ponto’s Planning Area F: carries a Non-Residential
Reserve (NRR) General Plan designation. Carlsbad’s Existing Local Coastal Program Land Use Plan states: “Planning Area
F carries a Non-Residential Reserve (NRR) General Plan designation. Planning Area F is an “unplanned” area …” and
requires that: “… As part of any future planning effort, the City and Developer must consider and document the need
for the provision of lower cost visitor accommodations or recreational facilities (i.e. public park) on the west side of
the railroad.” CA Coastal Commission actions, Carlsbad Public Records Requests 2017-260, 261, and 262, and 11/20/19
City Planner statements confirm the City never fully communicated to Carlsbad Citizens the existence of this LCP
requirement nor did the City comply with the requirements. Of deep concern is that the City is now (as several times in
the past) still not honestly disclosing to citizens and implementing this Existing LCP requirement as a true and authentic
‘planning effort’. The lack of open public disclosure and apparent fear of true public workshops and Public Comment
about the Existing Planning Area F LCP requirements are troubling. The point of a ‘planning effort’ is to openly and
publically present data, publically discuss and explore possibilities/opportunities, and help build consensus on the best
planning options. Citizens are concerned the city has already made up its mind and there is no real “planning effort” in
the proposed Draft LCP Amendment process, just a brief Staff Report and at the end provide citizens 3-minutes to
comment on the proposal. This is not the proper way to treat the last remaining significant vacant land is South
Carlsbad that will forever determine the Coastal Recreation environment for generations of Carlsbad and California
citizens and visitors to come.
The following data/images show how Ponto is in the center of the 6-mile (west of I-5 and Railroad corridor) regional
Coastal Park gap. Ponto is the last remaining vacant and currently “unplanned” Coastal land that is available to address
this regional Coastal Park Gap.
How Ponte Serves Reg ion
Ponto ls in middle
resiCJnalCoastal
ParkGap
COIISUII P,
-8.6% of SD County
coast ·ne
A Ponto Coastal Park
r26,000
64,000
in South
Page 16 of 30
How Ponto Serves Region cont.
• RellevesCollStal
Park congestion in
North carlsbad,
EncinitasandSolana
Beach
• A1eat.v11enlly m:~t~b
Coastal Parkas seen
by:
-Ponto Beach
parking congestion
-current trespass
use of Planning
Area F asa Park
How Ponto Serves Region cont.
• A Ponto Park helps
address2050 and
beyond Regional
Population and
Visitor Growth
demands for Coastal
Pam
• A Ponto Park
provides the lowest-
oost coastal access
Page 17 of 30
How Ponto Serves Region cont.
• Vital park and open
space amenity for
Visitor serving
busin esand
aa:ommodatlons
• 6.6 acre unlqueCity
Coastal Park venue
to stage special
events: Runs, bike
rides, triathlons,
How Ponto Serves Region cont.
• Ottical Park space
for So. carlsbad
state Beach
campground
• Provides a big
training and staging
space for Junior
lifeguards
• Dogwalktrail
Page 18 of 30
One possible Concept image of a potential Ponto Coastal Park at Planning Area F is illustrated below. The potential for a
Ponto Coastal Park is real. The speculative land investment fund (Lone Star Fund #5 USA L.P. and Bermuda L.P.) that
currently owns Planning Area F is selling the property, and is available for the City of Carlsbad to acquire to address the
documented demand/need for a City Park and City Park inequity at Ponto and in Coastal South Carlsbad. A Ponto
Beachfront Park 501c3 is working to acquire donations to help purchase the site for a Park. These situations and
opportunities should be publicly discussed as part of the City Staff’s proposed Local Coastal Program Land Use Plan
Amendment.
Ponto Coastal Park Concept
• A concept-but
shows potential
recreational
opportunities
• Provides vital
parkland support for
beach & ope n play
fie lds
• Concept plan a gift
from San Pacifico
Page 19 of 30
7. Projected increases in California, San Diego County and Carlsbad population and visitor growth increases the
demand for High-Priority-Coastal Recreation land use:
Increasing Citizen demand for Coastal Recreational land needs to be addressed with increased Coastal
Recreation land:
San Diego County Citizen Population - source: SANDAG Preliminary 2050 Regional Growth Forecast
1980 1,861,846
1990 2,498,016
2000 2,813,833
2010 3,095,313
2020 3,535,000 = 46,500 Citizens per mile of San Diego County coastline
2030 3,870,000
2040 4,163,688
2050 4,384,867 = 57,700 Citizens per mile of San Diego County coastline
2020 to 2050 = 24% increase in San Diego County population.
Citizen Population will continue beyond 2050. Carlsbad may plan for ‘Buildout’ in 2050, but what is San
Diego County’s ‘Buildout’? There is a common-sense need to increase the amount of Coastal Recreation
Land Use in the Proposed LCP Amendment to the Land Use Plan for this growing population. If we do not
increase our supply of Coastal Recreational Resources for these increased demands our Coastal Recreation
Resources will become more overcrowded, deteriorated and ultimately diminish the Coastal Recreation
quality of life for Citizens of Carlsbad and California. Ponto sits in the middle of an existing 6-mile regional
Coastal Park Gap (no Coastal Park west of Interstate 5) and there is No Coastal Park in all of South Carlsbad
to address the Coastal Recreation needs of the 64,000 South Carlsbad Citizens.
Page 20 of 30
Increasing Visitor demand for Coastal Recreational land needs to be addressed with increased Coastal
Recreation land:
Yearly Visitors to San Diego County – source: San Diego Tourism Authority; San Diego Travel Forecast, Dec, 2017
2016 34,900,000
2017 34,900,000
2018 35,300,000
2019 35,900,000
2020 36,500,000 = average 100,000 visitors per day, or 2.83% of County’s Population per day, or
1,316 Visitors/coastal mile/day in 2020
2021 37,100,000
2022 37,700,000
This is growth at about a 1.6% per year increase in visitors. Projecting this Visitor growth rate from 2020 to
2050 results in a 61% or 22,265,000 increase in Visitors in 2050 to:
2050 58,765,000 = average 161,000 visitors per day, or 3.67% of the County’s projected 2050
Population per day, or 2,120 Visitors/coastal mile/day in 2050.
The number of Visitors is likely to increase beyond the year 2050. There is a common-sense need to
increase the amount of Coastal Recreation Land Use in the Proposed LCP Amendment to the Land Use Plan
for these projected 2050 61% increase, and beyond 2050, increases in Visitor demand for Coastal
Recreational Resources. Increasing Coastal Recreation land is a vital and critically supporting Land Use and
vital amenity for California’s, the San Diego Region’s and Carlsbad’s Visitor Serving Industry. Ponto sits in
the middle of an existing 6-mile regional Coastal Park Gap (no Coastal Park west of Interstate 5). There are
thousands of hotel rooms in South Carlsbad that have NO Coastal Park to go to in South Carlsbad. This
needs correcting as both a Coastal Act and also a City economic sustainability imperative.
We request that the as part of the public’s review, the City Staff proposed Draft LCP Amendment to the Land
Use Plan clearly document if and/or how future forever ‘Buildout” City, Regional and Statewide population
and visitor population demand for Coastal Recreation and City Coastal Parks are adequately provided for
both in amount and locational distribution in the Carlsbad proposed Amendment of the LCP Land Use Plan.
8. Carlsbad’s Draft Local Coastal Program Land Use Plan Amendment says it plans to a year 2050 buildout of the
Coastal Zone. The Draft Local Coastal Program Land Use Plan Amendment then is the last opportunity to create a
Coastal Land Use Plan to provide “High-Priority” Coastal Recreation Land Use, and will forever impact future
generations of California, San Diego County, and Carlsbad Citizens and Visitors:
The Draft LCPA indicates in 2008 only 9% of All Carlsbad was vacant land. Less is vacant now in 2019.
Carlsbad’s Coastal Zone is 37% of the City, so vacant unconstrained land suitable for providing Coastal
Recreation is likely only 3-4%. The prior request for a full documentation of the remaining vacant Coastal
lands will provide a better understanding needed to begin to make the final ‘buildout’ Coastal Land Use Plan
for Carlsbad. The Draft LCPA does not indicate the amount and locations of currently vacant unconstrained
Coastal Land in Carlsbad. This final limited vacant land resource should be clearly documented and mapped
in the DLCPA as it represents the real focus of the DLCPA – the Coastal Plan for these remaingn undeveloped
Page 21 of 30
lands. These last remaining vacant lands should be primarily used to provide for and equitably distribute
“High-Priority” Coastal Recreation Land Uses consistent with CCA Sections:
i. Section 30212.5 “… Wherever appropriate and feasible, public facilities, including parking areas or
facilities, shall be distributed throughout an area so as to mitigate against the impacts, social and
otherwise, of overcrowding or overuse by the public of any single area.”;
ii. Section 30213 “… Lower cost visitor and recreational facilities shall be protected, encouraged, and,
where feasible, provided. Developments providing public recreational opportunities are
preferred. …”;
iii. Section 30222 “The use of private lands suitable for visitor-serving commercial recreational
facilities designed to enhance public opportunities for coastal recreation shall have priority over
private residential, general industrial, or general commercial development, but not over
agriculture or coastal-dependent industry.”
iv. Section 30223 “Upland areas necessary to support coastal recreational uses shall be reserved for
such uses, where feasible” ,
v. Section 30251 … The location and amount of new development should maintain and enhance public
access to the coast by … 6) assuring that the recreational needs of new residents will not overload
nearby coastal recreation areas by correlating the amount of development with local park
acquisition and development plans with the provision of onsite recreational facilities to serve the
new development”
Adopted City Park Service Area and Park Equity maps discussed earlier document the proposed Draft LCP
Amendment’s inconstancy with the above CCA Policy Sections. The locations and small amounts remaining
vacant Coastal lands provide the last opportunities to correct the inconsistencies of City proposed Draft
“buildout” LCP Land Use Plan Amendment with these Coastal Act Policies.
Currently and since 1996 there has been LCP LUP Policy/regulations for Ponto Planning Area F that require
consideration of a “Public Park” prior to changing the existing “unplanned Non-residential Reserve” Land
Use designation. A map and data base of vacant developable Coastal land should be provided as part of the
Draft LCPA and the Draft LCPA. This map and data base should document the projected/planned loss of
Coastal land use due to Sea Level Rise. Draft LCPA projects Sea Level Rise will eliminate several beaches and
High-Priority Coastal Land Uses like Coastal Lagoon Trails and the Campground.
The LCP Land Use Plan should plan and reserve the very limited vacant developable Coastal land for the
long-term ‘Buildout’ needs of “High-Priority” Coastal Recreation Land Use. Vacant developable Coastal land
is too scarce to be squandered for “low-priority” uses. Sea Level Rise will reduce “High-Priority” Coastal
Uses. So how vacant developable Upland area should be preserved for “High-Priority” Coastal Uses is a key
requirement to be fully documented and discussed in the Draft LCPA. If not one of two thing will eventually
happen 1) any new Coastal Park land will require very expensive purchase and demolition of buildings or
public facilities to create any new Coastal Park land to meet existing and growing demand; or 2) Coastal
Recreation will hemmed-in my “low-priority” uses and thus force Coastal Recreation to decrease and
become increasing concentrated and overcrowded in its current locations; and thus will promote the
eventual deterioration of our current Coastal Recreation resources. A plan that fails to fix Coastal Park
deficits and then increase Costal Parks in pace with increased population/visitor demand is a plan that can
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only result in degradation. How the Draft LCPA documents and addresses the land use planning of the last
small portions of vacant developable Coastal land is critical for the future and future generations.
9. Citizens of South Carlsbad are concerned about the City’s multiple prior flawed Ponto planning processes or
‘mistakes’ the City has made yet is basing the City Staff’s proposed Draft LCP LUP. The concerns being the City is not
openly and honestly communicating information to citizens and the public, and not allowing a reasonable and
appropriate community-based planning process to address the documented Park, Coastal Recreation and
unconstrained open space needs in South Carlsbad. One of these groups of citizens has created a
www.peopleforponto.com website to try to research and compile information and hopefully provide a better means
for citizens to understand facts and then express their concerns/desires to the City of Carlsbad (City) and CA Coastal
Commission (CCC). Over 2,000 emails have sent to the City and CCC regarding Coastal Land Use Planning Issues at
Ponto. The San Pacifico Planned Community (i.e. San Pacifico Community Association) has also, since 2015, sent
numerous emailed letters to the City and CCC noting the significant concerns about changes in Coastal planning the
City is proposing for our Planned Community.
Repeatedly over 90% of surveyed citizens (results emailed prior to both the City and CCC) have expressed the vital
need and desire for a Coastal Park at Ponto to serve the current and future Coastal Recreation needs for all both
Ponto and South Carlsbad and for larger regional and State Coastal Recreational needs. This desire is supported by
data, CA Coastal Act Policy, and also Carlsbad’s Community Vision – the foundation for the City’s General Plan.
Ponto is the last remaining vacant Coastal area available to provide for those needs in South Carlsbad and for a
regional 6-mile stretch of coastline. Citizens have expressed deep concern about the City’s flawed prior Coastal
planning efforts for Coastal Recreation at Ponto, including two repeated LCP Amendment “mistakes” (Ponto
Beachfront Village Vision Plan in 2010 and General Plan Update in 2015) when the City twice failed to publicly
disclose/discuss and then follow the Existing LCP requirements at Ponto – specifically for Planning Area F. People for
Ponto had to use multiple Carlsbad Public Records Requests in 2017 to find these “mistakes”. CCC Staff was helpful
in both confirming the City “mistakes” and communicating back to the City. As citizens we are still unclear has to
how/why these two repeated “mistakes” happened. There is citizen concern that the City is again repeating these
two prior “mistakes” by not at the beginning of the Public Comment Period clearly and publicly disclosing the
Planning Area F LCP requirements to citizens as part of the current LCP Amendment process, and also by not
implementing the exiting LCP requirement PRIOR to proposing an Amended Coastal Land Use Plan for Ponto. The
City in its proposed LCP Amendment process is putting-the-cart-before-the-horse with respect to honest and open
consideration, documentation and public discussion of the need for high-priority Coastal Recreation land use
required of Planning Area F at Ponto. The City is also not clearly letting all Carlsbad citizens know about the Existing
LCP requirements for Ponto’s Planning Area F so they can be informed to reasonably participate in public review and
comment regarding amending that LCP requirement, and the need for Coastal Recreation land uses in South
Carlsbad. Since 2017 there has been repeated citizen requests to the City (copies were provided to the CCC) to fix
these multiple fundamental/foundational flaws by in the City’s prior Coastal Recreation and Public Parks and Open
Space at planning, and the currently Proposed Draft LCP Land Use Plan Amendment. Since 2017 there have also
been repeated citizen requests to the City to provide a truly open, honest, inclusive community-based planning
process and workshops with the accurate and honest information, prior to forming a proposed Draft LCP Land Use
Plan Amendment. As citizens we believe we can constructively work with the City and CCC towards a consensus or
viable options on these important Coastal Recreation issues if the City allows and encourages such an open, honest
and inclusive process. We request the City respond to the requests submitted to the City since 2017, and again
request such a process from the City before any LCP Amendment is first considered by the Planning Commission and
City Council. Such a requested process benefits all.
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10. Why the Draft LCPA Land Use Plan for Ponto should provide for the current and future Coastal Park and Recreation
needs for South Carlsbad, the San Diego Region and California.
Ponto, is one of last remaining vacant and undeveloped Coastal lands in North County
Ponto is the last remaining undeveloped Coastal land in South Carlsbad
Ponto has the last unplanned Planning Area of the Existing Poinsettia Shores Planned Community & Local
Coastal Program that can be planned for high-priority Coastal Recreation land use. This Existing LCP requires
Planning Area F be considered for a “Public Park”.
Following is a map of the Ponto area in South Carlsbad:
Following is the LCP Land Use map from the Existing Poinsettia Shores Master Plan & Local Coastal Program adopted
in 1996. This is the Land Use map that the City is proposing to change in the proposed LCP Amendment to the Land
Use Plan. As the Existing LCP Land Use map shows most all the land is ‘low-priority’ residential use at an RM
Residential medium density, a small portion is ‘high-priority’ Visitor Serving TC/C Tourist Commercial. Most all the
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Open Space is constrained and undevelopable land (the steep CSS habitat bluffs above Batiquitos Lagoon) or water
(the lagoon water). This land/water is owned by the State of California, like the inner lagoon east of I-5. Only
Planning Area M at 2.3 acres is unconstrained Open Space and it provides a small private internal recreation facility
for the approximately 450 homes and 1,000 people in the Planned Community. This small recreation area is a City
requirement for ‘planned developments’ to off-set loss open space from planned development impacts on housing
quality. Planned developments can propose designs that reduce normal setback and open space areas – they bunch
together buildings to increase development – such as the smaller lot sizes, and extensive use of “zero-setbacks” to
reduce typical lot sizes that occurs at Poinsettia Shores. A private recreation facility in any of the City’s planned
developments is never considered a replacement for required City Parks. Planned Developments, like unplanned
developments, are required to dedicate Park land to the City, or pay a Park In-Lieu fee to the City so the City provide
the developer’s obligation to provide City Park acreage to address the population increase of their proposed planned
development. For Poinsettia Shores’ population the City’s minimum City Park Standard would require developers
set aside 3 acres of City Park land for local park needs. For the larger Ponto area population about 6.6 acres of City
Park Land is required. The Existing LCP reserves Planning Area F as an unplanned “Non-residential Reserve” Land
Use until the Public Park needs for Ponto are considered and documented. Only then can the NRR land use be
changed.
11. Developers have overbuilt in the Ponto area of the Coastal Zone. The City of Carlsbad has under questionable
circumstances is currently choosing to ‘exempted’ Ponto developers from providing the minimum amount of
unconstrained Open Space according to the City’s developer required Open Space Public Facilities Standard. The
legality of these confusing circumstances is subject to a lawsuit against the City. However the City’s computerize
mapping system has documented that the Ponto area of the Coastal Zone is missing about 30-acres of
Unconstrained Open Space that can be used to fulfill the City’s Open Space Performance Standard that states that
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15% of unconstrained and developable land must be preserved by developers as Open Space. Following is a
summary of data from the City data regarding the missing Open Space at Ponto (Local Facility Management Plan
Zone 9, LFMP Zone 9) in the Coastal Zone pursuant to the City’s Open Space Performance Standard. If it is desirable
People for Ponto can provide the City GIS map and parcel-by-parcel data base on which the following summary is
based:
City of Carlsbad GIS data calculations of Open Space at Ponto area of Coastal Zone:
472 Acres = Total land in LFMP Zone 9 [Ponto area] per City of Carlsbad GIS data
(197 Acres) = Constrained land/water/infrastructure that is excluded from the City’s Open Space Standard
275 Acres = Unconstrained land in LFMP Zone 9 (Ponto) subject to the City’s Open Space Standard
X 15% = Minimum unconstrained Open Space requirement per the City Open Space Standard
41 Acres = Minimum unconstrained Open Space required in LFMP Zone 9
(11 Acres) = Actual unconstrained Open Space provided & mapped by City in LFMP Zone 9
30 Acres = Missing unconstrained Open Space needed in LFMP Zone 9 [Ponto area of Coastal Zone] to meet the
City’s minimum GMP Open Space Standard. 73% of the required Open Space Standard is missing.
Thus the Ponto area of the Coastal Zone appears overdeveloped with 30 additional acres of “low-priority” residential
land uses due to developers’ non-compliance to the City’s Open Space Public Facility Performance Standard’s
Minimum developer required Open Space requirement. As noted a citizens group has a pending lawsuit with the
City over the City’s current ‘exempting’ Ponto and future developers from meeting the Open Space Standard.
12. The prior pre-1996 LCP for Ponto – the Batiquitos Lagoon Educational Park Master Plan & LCP (BLEP MP/LCP) had
significant Open Space and recreational areas. These significant Open Space and Recreational areas where removed
with BLEP MP/LCP’s replacement in 1996 by the currently existing Poinsettia Shores Master & LCP (PSMP/LCP) and
its City Zoning and LCP LUP requirements that reserved Planning Area F with the current “Non-residential Reserve”
Land Use designation. Since the BLEP MP/LCP it appears developers and the City of Carlsbad have worked to
remove “High-Priority” Coastal land uses (i.e. Coastal Recreation and Park uses) out of the Ponto area and replaced
them with more “low-priority” residential and general commercial land uses. For example:
Planning Area F used to be designated “Visitor Serving Commercial” as part of the original 1980’s BLEP
MP/LCP for Ponto.
In 1996 the BLEP MP LCP was changed by developer application to the now current PSMP LCP, and the LCP
LUP designation changed from “Visitor Serving Commercial” to “Non-Residential Reserve” with the
requirement to study and document the need for “High-Priority” Coastal Recreation (i.e. Public Park) and/or
Low-cost visitor accommodations prior to any change to Planning Area F’s “Non-residential Reserve” LCP
land use.
In 2005 the City started to try to change Planning Area F to low-priority residential and general commercial
land use in the City’s Ponto Beachfront Village Vision Plan (PBVVP). At this time the City made its first
documented Coastal ‘planning mistake’ by not disclosing to the public the existence of Planning Area F’s LCP
requirements and then also not following those LCP requirements. The City’s planning process seemed
focused on addressing developer’s land use desires, and increasing land use intensity to boost “Tax-
increment financing” as the City had established a Redevelopment Project Area at Ponto. A short time after
the State of CA dissolved Redevelopment Agencies due in part to such abuses by cities. The CCC formally
rejected the PBVVP in 2010, citing the City’s failure to follow the LCP requirements for Planning Area F.
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Five years later in 2015 the City again adopted a proposed General Plan Update to again change Planning
Area F to low-priority residential and general commercial land use. The General Plan Update cited the City’s
PBVVP that was in fact rejected by the CCC only a few years before. The City again repeated their PBVVP’s
Coastal land use ‘planning mistake’ by again not disclosing to the public the existence of Planning Area F’s
LCP requirements and then not following those LCP requirements. It is unclear why the City did this only 5-
years after the CCC specifically rejected the Ponto Beachfront Village Vision Plan for those same reasons.
In 2017 citizens found and then confirmed these Ponto Coastal ‘planning mistakes’ by the City through
multiple official Carlsbad Public Records Requests and CCC Staff confirmation. The CCC readily identified the
mistakes, but the City’s 2019 proposed Draft LCP Land Use Plan and planning process still has yet fully
disclose these prior Coastal ‘planning mistakes’ to ALL citizens of Carlsbad - the failure to disclose and follow
the Planning Area F LCP LUP and City Zoning requirements. Full City disclosure is needed now to try to
correct many years of City misrepresentation to citizens on LCP required Coastal land Use planning at Ponto.
It is needed now so the public is aware at the start of the Public Comment Period. In 2017 citizens began
asking the City fix the City’s over 12-years of misinformation and planning mistakes by ‘restarting’ Coastal
land use planning at Ponto with an open and honest community-based Coastal planning process. These
citizens’ requests have been rejected.
In 2019 the City Staff proposed citywide Draft LCP land Use Plan Amendment that again proposed to change
Planning Area F to “low-priority” residential and general commercial land use, without First disclosing the
Planning Area F LCP requirements with corresponding analysis of the Need for Coastal Recreation (i.e. Public
Park) and/or low-cost visitor accommodations at Planning Area F and providing that Documented analysis
for public review/Consideration/comment. This seems like another 3rd repeat of the prior two Coastal
planning mistakes by the City. In 2019, again citizens asked for a reset and a true community-based process
for the last remaining significant vacant Coastal lands – including Ponto. Again the City rejected citizens’
requests.
In 2020 thousands of public requests again asked, and are currently asking, for a reset and a true
community-based process for the last remaining significant vacant Coastal lands – including Ponto. Again
these requests are being rejected. Based on the significant citizen concern and the documented prior
‘planning mistakes’ at Ponto it appears reasonable and responsible for Ponto’s Planning Area F to ether:
i. Retain its current Existing LCP LUP land Use of “Non-Residential Reserve” until such time as the
City’s past Ponto Beachfront Village Vision Plan and General Plan Update planning mistakes and
other issues subject to current planning lawsuits against the City are resolved with a true, honest
and open community-based Coastal planning process asked for by citizens since 2017. Or
ii. Propose in the Draft LCP Land Use Plan Amendment to re-designated Planning Area F back to a
Visitor Serving Commercial and Open Space (“i.e. Public Park”) to provide both “High-Priory” coastal
uses v. low-priority residential/general commercial uses due to the documented Coastal Recreation
and Low-cost visitor accommodation needs for both citizens and visitors at Ponto and South
Carlsbad.
13. Questionable logic and inconsistency in proposed Draft land use map and policies: Chapter 2 Figure 2-2B & C on
pages 2-19 & 20 proposes to Amend the existing LCP Land Use Plan Map, and policies LCP-2-P.19 and 20 on pages 2-
27 to 2-29 propose Amendments to existing LCP policy and create a new added layer of policy referencing a
Ponto/Southern Waterfront. The proposed Land Use Map and Policies serve to firmly plan for “low-priority”
residential and general commercial land uses at Ponto with a clear regulatory Land Use Plan Map showing these
land uses and by specific regulatory policy (LCP-2-20) that clearly requires (by using the words “shall”) these “low
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priority” uses. In contrast the “High-Priority” Coastal Recreation and Coastal Park land uses that would be
designated as Open Space are not mapped at all in Figure 2-2B & C; and the proposed policy LCP-2-P.19 is both
misleading and specifically does Not Require any “High-Priority” Coastal Recreation and Coastal Park land Use at
Ponto and South Carlsbad. In fact page 2-22 specifically indicates two “may” criteria that would first need to occur
in the positive before any potential Coastal Recreation and Coastal Park Land could then theoretically even be
possible. It is highly probable that it is already known by the City that the proposed relocation of Carlsbad Boulevard
(Coast Highway) is not very feasible and not cost effective, and will not yield (due to environmental habitat
constraints, narrowness of the roadway median, and other design constraints) any significant dimensions of land
that could potentially be designated Open Space and realistically be used as a Park.
The blank outline map (Figure 2-2B &C) provides no mapped Open Space Land Use designation, other than for the
currently existing State Campgrounds’ low-cost visitor accommodations, so the proposed Land Use Plan Map is Not
providing/mapping any new Open Space land use to address Coastal Recreation and Coastal Park needs. The Draft
LCP Land Use Plan Amendment’s proposed/projected/planned Sea Level Rise and associated coastal erosion appears
to indicate that this “High-Priority” low-cost visitor accommodation (Campground) land use designated as Open
Space will be reduced in the ‘Buildout’ condition due to coastal erosion. So the Draft LCP Land Use Plan is actually
planning for a Reduction in Open Space Land Use in South Carlsbad and Ponto. Both the blank outline map and
the proposed Land Use Map Figure 2-1 DO NOT clearly map and designate both South Carlsbad’s Draft LCP Planned
Loss of the Open Space Land Use and also any New or replacement unconstrained land as Open Space land use for
Coastal Recreation and Coastal Park. This is an internal inconsistency in Land Use Mapping that should be corrected
in two ways:
1) Showing on all the Land Use (Figure 2-1), Special Planning Area (Figure 2-2B & C), and other Draft LCP Maps
the Draft LCP’s planned loss of land area in those maps due to the Draft LCP’s planned loss of land due to
Sea Level Rise and Coastal Land Erosion. This is required to show how land use boundaries and Coastal
Recourses are planned to change over time. or
2) Provide detailed Land Use Constraint Maps for the current Carlsbad Boulevard right-of-way that the City
“may” or ‘may not’ choose (per the proposed “may” LCP-2-P.19 policy) use to explore to address the City’s
(Park Master Plan) documented Coastal Recreation and Coastal Park land use shortages in Coastal South
Carlsbad and Ponto. Clearly showing the potential residual Unconstrained Land within a Carlsbad Boulevard
relocation that have any potential possibility to add new Open Space Land Use Designations (for Coastal
Recreation) is needed now to judge if the policy is even rational, or is it just a Trojan horse.
The proposed internal inconsistency in mapping and policy appears like a plan/policy ‘shell game’. The proposed
Land Use Plan Maps and Policies should be consistent and equality committed (mapped-shall v. unmapped-may) to
a feasible and actual Plan. If not then there is No real Plan.
There is no Regulatory Policy requirement in LCP-2-P.19 to even require the City to work on the two “may” criteria.
The City could choose to bury the entire Carlsbad Boulevard relocation concept and be totally consistent with Policy
LCP-2-P.19 and the LCP. As such the language on 2-22, Figure 2-2C (and the proposed Land Use Map), and policy
LCP-2-P.19 and 20 appear conspire to create a shell game or bait-and-switch game in that only “low-priority”
residential and general commercial uses are guaranteed (by “shall” policy) winners, and “high-priority” Coastal
Recreation and Coastal Park Land Uses are at best a non-committal ‘long-shot” (“may” policy) that the city is
specifically not providing a way to ever define, or commit to implement. The proposed Draft LCP Land Use Plan
Coastal Recreation and Coastal Park statements for Ponto are just words on paper that are designed to have no
force, no commitment, no defined outcome, and no defined requirement to even have an outcome regarding the
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documented “High-Priority” Coastal Recreation and Costal Park needs at Ponto, Coastal South Carlsbad and the
regional 6-mile Coastal Park gap centered around Ponto.
Policy LCP-2-P.19 falsely says it “promotes development of recreational use” but does not in fact do that. How is
development of ‘recreational use promoted’ when the Use is both unmapped and no regulatory policy requirement
and commitment (no “shall” statement) to ‘promote’ that Use is provided? Policy LCP-2-19.19 appears a misleading
sham that does not ‘promote’ or require in any way “High-Priority” Coastal Recreation and Park Land Use at Ponto.
There should be open and honest public workshops before the Draft LCP Amendment goes to its first public hearing
to clearly define the major environmental constraints and cost estimates involving possible relocation of Carlsbad
Boulevard and constructing needed beach access parking, and sufficient and safe sidewalks and bike paths along
Carlsbad Boulevard; and then map the amount and dimensions of potential ‘excess land’ that maybe available for
possible designation as Open Space in the City General Plan and Local Coastal Program. The City should not repeat
the mistakes at the Carlsbad Municipal Golf Course (resulting in the most expensive to construct maniple course in
the USA) by not defining and vetting the concept first. A preliminary review of City GIS data appears the amount,
dimensions and locations of any potential ‘excess’ land maybe modest at best. However before the City proposes a
‘Buildout’ Coastal Land Use Plan this critical information should be clearly provided and considered. It is likely the
City’s Carlsbad Boulevard relocation concept is unfeasible, inefficient, too costly, and yields too little actual useable
‘excess land’ to ever approach the Coastal Recreation and Coastal Park needs for South Carlsbad. This may already
be known by the City, but it surely should be publicly disclosed and discussed in the DLPCA.
The proposed Coastal Land Use Plan to address Carlsbad’s, San Diego County’s and California’s High-Priority Coastal
Recreation Land Use and Coastal Park needs should NOT be vague “may” policy that appears to be purposely
designed/worded to not commit to actually providing any “High-Priority” Coastal Recreation and Coastal Park land
uses on the map or in policy commitments. The Land Use Plan and Policy for High-Priority Coastal Recreation and
Coastal Park Land Use should be definitive with triggered “shall” policy statements requiring and assuring that the
‘Forever’ “High-Priority” Coastal Recreation and Coastal Park needs are properly and timely addressed in the City’s
proposed ‘Buildout’ Coastal Land Use Plan. This “shall” policy commitment should be clearly and consistently
mapped to show the basic feasibility of the planned outcomes and the resulting actual Land that could feasibly
implement the planned outcome.
Providing safe and sufficient sidewalks, bike paths, and public parking along Carlsbad Boulevard: Providing safe and
sufficient sidewalks, bike paths, and public parking along Carlsbad Boulevard are Coastal Access and Completes
Streets issues. South Carlsbad Boulevard now and has for decades been a highly used Incomplete Street that is out
of compliance with the City’s minimum Street Standards for pedestrian and bike access and safety. The Coastal
Access portion of the Draft Land Use Plan should strongly address the Complete Street requirements for South
Carlsbad Boulevard. Those policy commitments should be reference in Policy LCP-2-P.19 and 20 as Carlsbad
Boulevard in South Carlsbad is the most Complete Street deficient portion of Carlsbad Boulevard. Forever Coastal
Access parking demand and the proposed LCP Amendment’s Land Use Plan to supply parking for those demands
should also be addressed as part of the Coastal Access and Complete Streets issues for South Carlsbad Boulevard. If
much needed Coastal Access Parking is provided on South Carlsbad Boulevard as part of a “maybe” implemented
realignment, most of the “maybe” realignment land left after constraints are accommodated for and buffered will
likely be consumed with these parking spaces and parking drive aisles/buffer area needed to separate high-speed
vehicular traffic from parking, a buffered bike path, and a sufficiently wide pedestrian sidewalk or Coastal Path.
After accommodating these much needed Complete Street facilitates there will likely be little if any sufficiently
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dimensioned land available for a Coastal Recreation and a Coastal Park. The needed Coastal Access and Complete
Street facilities on South Carlsbad Boulevard are very much needed, but they are NOT a Coastal Park.
As mentioned the proposed Draft Coastal Land Use Plan’s Maps and Policies are very specific in providing for the
City’s proposed LCP Land Use changes to ‘low-priority” Residential and General Commercial’ on Planning Area F
(proposed to be renamed to Area 1 and 2). It is curious as to why the proposed Draft LCP Land Use Plan
Amendment has no Land Use Map and minor vague unaccountable Land Use Policy concerning ‘High-priority Coastal
Recreation Land Use’ at Ponto, while the very same time proposing very clear Land Use Mapping and detailed
unambiguous “shall” land use policy requirements for ‘low-priority” Residential and General Commercial land use at
Ponto. Why is the City Not committing and requiring (in a Land Use Map and Land Use Policy) to much needed
‘High-priority” Coastal Recreation and Coastal Park Land Use’ needs at Ponto the same detail and commitment as
the City is providing for “low-priority” uses? This is backwards and inappropriate. It is all the more inappropriate
given the ‘Buildout’ Coastal Land Use Plan the City is proposing at Ponto. These issues and plan/policy commitments
and non-commitments will be ‘forever’ and should be fully and publicly evaluated as previously requested, or the
Exiting LCP Land Use Plan of “Non-residential Reserve” for Planning Area F should remain unchanged and until the
forever-buildout Coastal Recreation and Coastal Park issues can be clearly, honestly and properly considered and
accountably planned for. This is vitally important and seems to speak to the very heart of the CA Coastal Act, its
founding and enduring principles, and its policies to maximize Coastal Recreation. People for Ponto and we believe
many others, when they are aware of the issues, think the City and CA Coastal Commission should be taking a long-
term perspective and be more careful, thorough, thoughtful, inclusive, and in the considerations of the City’s
proposal/request to permanently convert the last vacant unplanned (Non-residential Reserve) Coastal land at Ponto
to “low-priority” land uses and forever eliminate any Coastal Recreation and Coastal Park opportunities.
14. Public Coastal View protection: Avenida Encinas is the only inland public access road and pedestrian sidewalk to
access the Coast at Ponto for one mile in each direction north and south. It is also hosts the regional Coastal Rail
Trail in 3’ wide bike lanes. There exist now phenomenal coastal ocean views for the public along Avenida Encinas
from the rail corridor bridge to Carlsbad Boulevard. It is assumed these existing expansive public views to the ocean
will be mostly eliminated with any building development seaward or the Rail corridor. This is understandable, but
an accountable (‘shall”) Land Use Plan/Policy addition to proposed Policy LCP-2-P.20 should be provided for a
reasonable Public Coastal View corridor along both sides of Avenida Encinas and at the intersection with Carlsbad
Boulevard. Public Coastal view analysis, building height-setback standards along Avenida Encinas, and building
placement and site design and landscaping criteria in policy LCP-2-P.20 could also considered to reasonably provide
for some residual public coastal view preservation.
15. Illogical landscape setback reductions proposed along Carlsbad Boulevard, and Undefined landscape setback along
the Lagoon Bluff Top and rail corridor in Policy LCP-2-P.20: Logically setbacks are used in planning to provide a
buffering separation of incompatible land uses/activities/habitats. The intent of the setback separation being to
protect adjacent uses/activities/habitats from incompatibility, nuisance or harassment by providing a sufficient
distance/area (i.e. setback) between uses/activities/habitats and for required urban design aesthetics – almost
always a buffering landscaping. Policy LCP-2-P.20. A.4 and C.3 says the required 40’ landscape setback along
Carlsbad Boulevard “maybe reduced due to site constraints or protection of environmental resources.” The ability
to reduce the setback is illogical in that setbacks are intendent to protect environmental resources and provide a
buffer for constraints. In the Carlsbad Boulevard right-of-way there is documented sensitive environmental habitat,
along with being a busy roadway. How could reducing the protective 40’ setback in anyway better protect that
habitat or provide a better landscaped compatibility or visual aesthesis buffer along Carlsbad Boulevard? It is
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illogical. If anything the minimum 40’ landscaped setback should likely be expanded near “environmental
resources”. Regarding reducing the minimum 40’ landscape setback for “site constraints” there is no definition of
what a “site constraint” is or why it (whatever it may be) justifies a reduction of the minimum landscaped setback.
Is endangered species habitat, or a hazardous geologic feature, or a slope, or on-site infrastructure considered a
“site constraint”? There should be some explanation of what a “site constraint” is and is not, and once defined if it
warrants a landscape setback reduction to enhance the buffering purpose of a landscape setback. Or will a
reduction only allow bringing the defined constraint closer to the adjacent uses/activities/habitats that the
landscape setback is designed to buffer. It is good planning practice to not only be clear in the use of terms; but
also, if a proposed reduction in a minimum standard is allowed, to define reasonably clear criteria for that
reduction/modification and provide appropriate defined mitigation to assume the intended performance objectives
of the minimum landscape setback are achieved.
Policy LCP-2-P.20.C.4 is missing a critical Bluff-Top landscape setback. It seems impossible that the DLCPA is
proposing no Bluff-Top setback from the lagoon bluffs and sensitive habitat. The Batiquitos Lagoon’s adjoining steep
sensitive habitat slopes directly connect along the Bluff-top. Batiquitos Lagoon’s and adjoining steep sensitive
habitat is a sensitive habitat that requires significant setbacks as a buffer from development impacts. Setbacks
similar to those required for the San Pacifico area inland of the rail corridor, should be provided unless updated
information about habitat sensitivity or community aesthetics requires different setback requirements.
Policy LCP-2-P.20 does not include a landscape setback standard adjacent to the rail corridor. This is a significant
national transportation corridor, part of the 2nd busiest rail corridor in the USA. Train travel along this corridor is
planned to increase greatly in the years to come. Now there is significant noise, Diesel engine pollution, and
extensive ground vibration due to train travel along the rail corridor. Long freight trains which currently run mostly
at night and weekends are particularly noisy and heavy, and create significant ground vibration (underground noise).
These issues are best mitigated by landscape setbacks and other buffers/barriers. A minimum setback standard for
sufficient landscaping for a visual buffer and also factoring appropriate noise and ground vibration standards for a
buildout situation should be used to establish an appropriate landscape setback that should be provided along the
rail corridor. Carlsbad’s landscape aesthetics along the rail corridor should be factored into how wide the setback
should be and how landscaping should be provided. An example for the landscape aesthetic portion of the setback
standard could be landscape design dimensions of the San Pacifico community on the inland side of the rail corridor.
However, noise and vibrational impacts at San Pacifico are felt much further inland and appear to justify increased
setbacks for those impacts.
Carlsbad is 10% below the national average for cities & the worst of
24 Coastal So California cities - 165 miles of coastline - in providing
Parks within a 10-minute walk to residents
The Trust for Public Land documents a city’s 10-minute walk to Park at https://www.tpl.org/parkserve
The Average USA City provides Parks within 10-minute walk to 55% of residents [10% above Carlsbad].
Carlsbad provides Parks within 10-minute walk to 49.9% of residents [10% below National Average].
New York City provides Parks within 10-minute walk to 99% of residents.
The Trust of Public Land submitted a letter to the City of Carlsbad, CA Coastal
Commission, and CA State Park supporting Ponto Park
Carlsbad is the worst of 24 Southern CA Coastal cities (from Malibu south to Imperial Beach along 165
miles of coastline) in providing Parks within 10-minute walk to residents:
1. Palos Verdes Estates provides Parks within 10-minute walk to 100% of residents
2. El Segundo provides Parks within 10-minute walk to 100% of residents
3. Hermosa Beach provides Parks within 10-minute walk to 100% of residents
4. Redondo Beach provides Parks within 10-minute walk to 98% of residents
5. Manhattan Beach provides Parks within 10-minute walk to 95% of residents
6. Del Mar provides Parks within 10-minute walk to 93% of residents
7. Dana Point provides Parks within 10-minute walk to 89% of residents
8. Huntington Beach provides Parks within 10-minute walk to 85% of residents
9. Long Beach provides Parks within 10-minute walk to 84% of residents
10. Laguna Beach provides Parks within 10-minute walk to 82% of residents
11. Santa Monica provides Parks within 10-minute walk to 82% of residents
12. San Diego provides Parks within 10-minute walk to 81% of residents
13. Coronado provides Parks within 10-minute walk to 76% of residents
14. Newport Beach provides Parks within 10-minute walk to 76% of residents
15. Imperial Beach provides Parks within 10-minute walk to 74% of residents
16. Encinitas provides Parks within 10-minute walk to 68% of residents
17. Los Angeles provides Parks within 10-minute walk to 63% of residents
18. Solana Beach provides Parks within 10-minute walk to 63% of residents
19. Oceanside provides Parks within 10-minute walk to 58% of residents
20. Seal Beach provides Parks within 10-minute walk to 57% of residents
21. Malibu provides Parks within 10-minute walk to 53% of residents
22. San Clemente provides Parks within 10-minute walk to 52% of residents
23. Rancho Palos Verdes provides Parks within 10-minute walk to 50% of residents
24. Carlsbad provides Parks within 10-minute walk to 49.9% of residents.
Carlsbad is the lowest & most unfair to citizens of the 24 Southern California Coastal cities along
165 miles of coast from Malibu to Imperial Beach.
Source of data: Trust for Public land parkscores
Trust for Pulic Land’s 10-minute walk to Park Maps/data:
Carlsbad = https://parkserve.tpl.org/mapping/index.html?CityID=0611194#reportTop
Encinitas = https://parkserve.tpl.org/mapping/index.html?CityID=0622678
Irvine = https://parkserve.tpl.org/mapping/index.html?CityID=0636770
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.
Page 1 of 30
Carlsbad Draft Local Coastal Program Amendment – Coastal Recreation Land Use
People for Ponto Updated Public Comments 10/12/2021
Updated Pubic Comments Coastal Recreation submitted on Oct 12th 2021:
On 10/8/21 the Carlsbad City Council and CA Coastal Commission were emailed data from an Official Carlsbad Public
Records Request (# R002393-092121) on the City of Carlsbad’s past compliance/noncompliance with the currently
exiting Mello II LCP Land Use Policies # 6-2, 6-4 & 6-10 Certified in the mid-1980s. The City’s documents show:
For Policy 6-2 the 200-300 acre Park called out in Policy 6-2 has been reduced to Veterans Park’s 91.5 acres,
of which only 54% or 49.5 acres is even useable as a Park. The City provided no documents on how a 200-
300 acre park called for in Policy 6-4 is now only 49.5 useable acres.
For Policy 6-4 there were no City documents were provided. There was no City Public discussion,
consideration, or City compliance with Policy 6-4 since the mid-1980’s.
For Policy 6-10 concerns providing Low Cost Visitor Accommodations. Public Parks are the lowest cost (free)
Visitor accommodating land use there is.
The 3 existing LCP Land Use Policies are important for Carlsbad, and California’s, Coastal land use resources. There
appears little to no discussion of the City’s past apparent failure to implementation of these 3 LCP LUPs in the current
City consideration of changes to the LCP.
Following is a copy of Public Records Request # R002393-092121: “Carlsbad’s Local Coastal Program (LCP) for the Mello
II Segment of Carlsbad’s Coastal Zone has long established land use Policies 6-2, 6-4 & 6-10 that were adopted by
Carlsbad and Certified by the CA Coastal Commission in the early/mid-1980’s. Mello II LCP Policies 6-2, 6-4 & 6-10 are
shown on page 86-87 of Carlsbad’s 2016 compiled LCP and are:
“POLICY 6-2 REGIONAL PARK: If the population of Carlsbad increases in accordance with SANDAG's projected
Series V Population Forecasts, it is estimated that Carlsbad will need to develop a new regional park
containing 200 to 300 acres in order to adequately serve the public. A location for a new regional park must,
therefore, be established. Consideration should be given to a facility within the Aqua Hedionda Specific Plan
Area, or adjacent lands. The Batiquitos Lagoon area should also be considered.
POLICY 6-4 NEED FOR ADDITIONAL OVERNIGHT CAMPING: Additional overnight camping facilities, the main
source of lower cost visitor and recreational facilities, are needed throughout the San Diego coastal region.
Additional facilities of this kind should be provided in a regional park within the Carlsbad area. This can be
accomplished in conjunction with an eventual Batiquitos Park, within the Aqua Hedionda Specific Plan Area,
and/or along with the development of private recreational facilities.
POLICY 6-10 LOWER COST VISITOR-SERVING RECREATIONAL USES: Lower cost visitor and recreational
facilities shall be protected, encouraged, and, where feasible, provided. Encourage a range of affordability
for overnight visitor accommodations. Evaluate the affordability of any new or redeveloped overnight visitor
accommodations, including amenities that reduce the cost of stay. Mitigation may be applied to protect and
encourage affordable overnight accommodations”
Page 2 of 30
The public record request is to see documents of:
City Staff reports, presentations and communications to the Carlsbad Planning and Parks Commissions, and
City Council regarding the City’s consideration and implementation of these 3 specific (6-2, 6-4, and 6-10)
Mello II LCP land use policies; and
Carlsbad Planning and Parks Commissions, and City Council minutes, resolutions and ordinances
documenting City of Carlsbad consideration and implementation of these 3 specific (6-2, 6-4, and 6-10)
Mello II LCP land use policies.”
Updated Pubic Comments on Coastal Recreation submitted on January 2021:
Over 11-months ago in a 1/29/20 1:56PM email People for Ponto Carlsbad citizens first provided the City of Carlsbad
both data and comments on 14 critical Coastal Recreation issues (see pages 5-30 below). The data and the 14 critical
issues do not seem to be receiving appropriate disclosure/presentation/discussion/consideration in the Dec 2, 2020
Staff Report to the Planning Commission. To assure the 26-pages of citizen data and requests in the 1/29/20 email was
received by the Planning Commission the file was re-emailed on 12/22/20 12:24pm and specifically addressed to City
Council, City Clerk, Planning Commission, Parks Commission, Housing Commission, HEAC, CA Coastal Commission, and
CA HCD. As citizens we request each of these 14 data points (with supporting data) be honestly considered.
In reading the Dec 2 Staff Report citizens conducted additional analysis of City Park data. That research further
reinforces and documents the 14 Critical Coastal Recreation issues and highlights the relatively poor amount of City Park
and Coastal Recreation planned by Carlsbad’s Staff proposed Draft LCP-LUPA. We hope the City Council and City
Commissions, and CA Coastal Commission & HCD will consider this additional analysis of City data and citizen input:
Coastal Zone data Carlsbad Oceanside Encinitas note or source
Coastline miles 6.4 3.9 6.0 Carlsbad Draft LCPA 201, Google Maps
Coastal Zone Acres 9,219 1,460 7,845 & Oceanside & Encinitas LCPs
Coastal Zone Acres 100% 16% 85% % relative to Carlsbad
City Park Standard data
City Park Standard 3 5 5 required park acres / 1,000 population
Park Standard % 100% 167% 167% % is relative to Carlsbad
Oceanside & Encinitas 'require' and plan for 67% MORE Parkland than Carlsbad
Carlsbad 'requires' and plans for ONLY 60% as much Parkland as Oceanside & Encinitas
Carlsbad only requires developers provide 60% of the parkland (or in-lieu fees) as Oceanside & Encinitas require
Encinitas has a ‘Goal’ to provide 15 acres of Park land per 1,000 population
Developed City Park 2.47 3.65 5.5 acres / 1,000 population
Developed Park 100% 148% 223% % is relative to Carlsbad
Oceanside provides 48% MORE developed park land than Carlsbad
Encinitas provide 123% MORE developed park land than Carlsbad
Carlsbad ONLY provides 68% and 45% as much Parks as Oceanside & Encinitas respectively
National Recreation & Park Asso. Metric: a typical City provides 1 park / 2,281 pop. & 9.9 Park acres / 1,000 population
Carlsbad (3 acre) Park Standard is ONLY 30% of what a typical City provides nationally
Carlsbad requires developers to provide, 70% LESS Park acres than typical City provides nationally
Page 3 of 30
National Recreation & Park Asso., Trust for Public Land, et. al.: 10 minute (1/2 mile) Walk to a Park Planning Goal
Both Oceanside and Encinitas plan parks to be within a 10-minute (1/2 mile) walk to homes.
Carlsbad DOES NOT plan Parks within walking distance to homes
Carlsbad is NOT providing equitable and walking/biking access to Parks
Some Carlsbad Parks that are not fully useable as Parks:
total Unusable
Existing Parks with park park % of park
Unusable Open Space acreage acres acres unusable reason unusable
Alga Norte - SE quadrant 32.1 10.7 33% 1/3 of park is a Parking lot not a park
In many other Carlsbad Parks a significant
percentage of those Parks are consumed by
paved parking lots and unusable as a Park.
Hidden Hills - NE quadrant 22.0 12.7 58% city identified unusable habitat open space
La Costa Canyon SE quadrant 14.7 8.9 61% city identified unusable habitat open space
Leo Carrillo - SE quadrant 27.4 16.5 60% city identified unusable habitat open space
Poinsettia - SW quadrant 41.2 11.1 27% city identified unusable habitat open space
Existing Park subtotal 137.4 59.9 44% 44% of these Parks are unusable as Parkland
Anticipated Future Park
development projects
Park - quadrant
Veterans - NW 91.5 49.5 54% estimated unusable habitat open space
Cannon Lake - NW 6.8 3.4 50% estimated unusable water open space
Zone 5 Park expansion - NW 9.3 0 0 appears 100% useable as a Park
Robertson Ranch - NE 11.2 0 0 appears 100% useable as a Park
Future park subtotal 118.8 52.9 45% 45% of Future Parks are unusable as Parks
Unusable Open Space acres
in Existing & Future Parks 256.2 112.8 44% 112.8 acres or 44% is unusable as Parks
112.8 acres or 44% of the Existing & Future Parks are unusable Open Space and can’t be used as Parkland
Based on City's minimum 3-acres/1,000 population Park Standard, 112.8 acres of Unusable Parkland means
37,600 Carlsbad Citizens (or 32.5% of Carlsbad's current population of 112,877) will be denied the minimum
amount of Parkland that they can actually use as a Park.
59.9 acres of Existing unusable ‘park’ / 3 acre park standard x 1,000 population = 19,967 Carlsbad citizens and
their children are currently being denied useable park land. 19,967 is 17.7% of Carlsbad’s current population.
In addition to these 19,967 existing citizens and their children denied park land, the City needs to develop
additional Park acreage in the NE, SW and SE quadrants to cover current shortfalls in meeting in the minimal 3
acre/1,000 population park standard for the current populations in the NE, SW and SE quadrants.
The current NE, SW and SE quadrants park acreage shortfalls are in addition to the 19,967 Carlsbad citizens
and their children that do not have the minimum 3 acres of parkland per 1,000 population
Current FY 2018-19 MINIMUM park acreage shortfalls are listed in the table below. They are:
o 4.3 acres for 1,433 people in NE quadrant,
o 6.8 acres for 2,266 people in SW quadrant, and
o 2.3 acres for 767 people in SE quadrant
Shortfall (excess) in
Current Quadrant
Min. Park standard by
population Future Park
Page 4 of 30
acres need acres % existing Park shortfalls are for NE, SW & SE quadrants
NW quadrant (-14.2) (-4,733) 107.6 91% Current NW parks are 14.2 acres over min. standard &
capacity for 4,733 more people at min. park standard.
91% of all Future City Parks are in NW quadrant
NE quadrant 4.3 1,433 11.2 9% Future Park will exceed minimum NE park standard
SW quadrant 6.8 2,266 0 0% No min. parks for 2,266 people in SW quad. Park deficit
SE quadrant 2.3 767 0 0% No min. parks for 767 SE quadrant Park deficit
A Park Standard minimum is just a “Minimum”. City policy allows the City to buy/create parks above the City’s current 3
acre/1,000 pop. MINIMUM (and lowest) Park Standard of surrounding Coastal cities. Carlsbad already did this in the NW
quadrant. It then added 3.1 more NW quadrant Park acres as part of the Poinsettia 61 Agreement. Poinsettia 61:
converted 3.1 acres of NW City land planned/zoned for Residential use to Open Space Park land use/zoning,
facilitated a developer building condos (increasing park demand) in the SW quadrant,
required the SW Quadrant developer pay $3 million to build the 3.1 acre NW quadrant park, and
required the SW Quadrant developer pay to convert 3.1 acres of NW Quadrant & 5.7 acres of SW Quadrant City
Park land to habitat that will be unusable as a City Park.
So Poinsettia 61 increased SW Quadrant development (that both increased SW Park Demand and expanded the current
SW Quadrant Park deceit) while simultaneously using SW Quadrant development to pay for the conversion of 3.1 acres
of residential land in the NW Quadrant to City Park (the NW Quadrant already has surplus park land per the City’s
minimum standard).
People for Ponto strongly supports creating City Parks above the City’s current low 3-acre per 1,000 population
minimum, as the City’s minimum standard is relatively low and substandard relative to other cities; many Carlsbad parks
have significant acreage that is in fact ‘unusable’ as a park. Most importantly People for Ponto Citizens think it is very
important to prioritize providing City Parks in areas of Park Inequity that are unserved by City Parks. However it seems
very unfair to the SW Quadrant citizens to be so unserved and starved of the bare minimum of City Parks while at the
same time funding City Parks in excess of City standard in other Quadrants.
The Poinsettia 61 illustrates a larger unfair (and dysfunctional) distribution of Quadrant based City Park demand and
supply that is keenly evident in the demands/supply funding and location disparity of Veterans Park. Most all the
development impact and park demand that paid Veterans Park fees came from the SW, SE and NE Quadrants yet the
Veterans Park (supply) is not in those SW, SE and NE Quadrants. This inequity is counter to the implicit City requirement
that City Parks be provided within the Quadrant of their Park demand. It is logical and proper that City Parks be
provided and equitably distributed to be close to the development and population that generated the Park demand.
The City Park inequity at Ponto and in other Coastal areas of the City is counter to several CA Coastal Act policies;
counter to good city planning and good CA Coastal planning. Park Inequity is highly detrimental to the City, and City and
CA citizens in the long-term; fails to properly distribute and match the location supply with the location of demand for
Parks; and is counter to basic fundamental issues of fairness. Since 2017 People for Ponto has tried to get the City
Council and Staff to address this inequity, specifically at Ponto, and to do so in a way that embraces a true and honest
Citizen-based planning process.
Page 5 of 30
Carlsbad Staff proposed Draft Local Coastal Program Amendment – People for Ponto comments submitted 1/29/2020
Coastal Recreation:
2. Request that the City as part of its Draft LCP Public Review process broadly-publicly disclose to all Carlsbad Citizens
the City’s acknowledged prior LCPA processing and planning “mistakes” regarding the requirement that the Ponto
area be considered as a public park: This disclosure is needed to correct about 20 years of City misrepresentation to
the public on the since 1996 and currently Existing LCP requirements at Ponto, and the City’s prior planning mistakes
at Ponto. Citizens have been falsely told by the City that all the Coastal planning at Ponto was done already and that
the City followed its Existing LCP regarding the need for a park at Ponto, and that this is already decided and could
not be reversed. This misinformation has fundamentally stifled public review and public participation regarding the
Coastal Zone. City failure to provide such a broad-public disclosure on the documented prior, and apparently
current proposed, “planning mistakes” would appear to violate the principles of Ca Coastal Act Section 30006. A
broad-public disclosure would for the first time allow citizens to be accurately informed on the Existing LCP
requirements at Ponto so they can provide informed public review and comment regarding the need for a Coastal
Park in in this last vacant ‘unplanned’ area. The requested broad-public disclosure by the City of the City past
mistakes and the Existing LCP requirements at Ponto is consistent with CA Coastal Act (CCA) “Section 30006
Legislative findings and declarations; public participation - The Legislature further finds and declares that the public
has a right to fully participate in decisions affecting coastal planning, conservation and development; that
achievement of sound coastal conservation and development is dependent upon public understanding and
support; and that the continuing planning and implementation of programs for coastal conservation and
development should include the widest opportunity for public participation.” The public cannot participate as
outlined in CCA Section 30006 if past City ‘mistakes’ and misrepresentations on Coastal planning at Ponto go
undisclosed to the public. If the public isn’t fully informed about the 20-years of LCP planning mistakes at Ponto
how could the public in the past (and now in the present) participate in the proposed LCP Amendment – Public
Participation as noted in Section 30006 above is the means to sound coastal conservation and development and is
“… dependent upon public understanding …”. The City’s past mistakes at Ponto need to be corrected by slightly
different a Draft LCP Amendment process than currently outlined by the City; a new process is needed that clearly,
opening and honestly informs and engages the public on the Existing LCP Ponto issues. The City’s current Draft LCP
Amendment process fails to follow CCA Section 30006 in that most all the citizens we encounter are as yet unaware
of the City’s Ponto mistakes and how they can participate in in the DLCPA process without that information. We see
this daily in conversations we have with our fellow citizens. We even saw at the Oct 20, 2019 Carlsbad Planning
Commission meeting that the Planning Commission was unaware of the planning mistakes at Ponto. How can a
decision body of the City make a decision without knowing about these prior ‘planning mistakes’ facts that surround
what they are being asked to decide on? Repeatedly since 2017 Carlsbad citizens and People for Ponto have asked
the City to fully acknowledge the City’s prior flawed planning at Ponto, and to correct that with ether maintaining
the Existing LCP Non-residential Reserve Land Use or restarting the Coastal Planning at Ponto with a true and
accurately informed Community-based Coastal Planning process consistent with Section 30006.
We request the City during the DLCPA Public Review period broadly and publicly disclose to all Carlsbad Citizens the
City’s acknowledged prior LCP and other “planning efforts” public participation processing and planning “mistakes”
regarding the requirement that the Ponto area be considered as a public park, and 1) provide a truly honest public
participation process on that disclosure consistent with CCA Section 30006 as part of the Draft LCP Amendment
process or 2) retain the Existing LCP Non-residential Reserve Land Use and require a comprehensive and honest
community-based redo of Coastal Resource planning at Ponto.
Page 6 of 30
3. City fully and publicly reply to and the City Council consider the 11-20-19 citizen concerns/requests regarding the
City’s proposed LCP Amendment process: Lance Schulte on 1/23/20 received an email reply by the City to his follow-
up email regarding the status of the 11/20/19 citizen concerns/requests public comments and letters presented to
the Planning Commission. This is appreciated, however it is request that the City fully publicly reply to the 11-20-19
citizen concerns/requests regarding the City’s proposed LCP Amendment process and present the to the City Council
11/20/19 citizen concerns/requests so the City Council can consider them and provide any direction to City Staff.
City Staff first presented a summary presentation of the proposed Draft LCP Amendment to the Carlsbad Planning
Commission on November 20, 2019, and indicated the public comment period would close on November in less than
2-weeks. Citizens and citizen groups provided public testimony to the Planning Commission, both verbally and in
two written letters. The CCC was copied on those letters. The testimony and letters noted significant concerns
about the City’s proposed LCP Amendment process and made three requests:
Disclose and provide a publically accessible ‘Redline Version’ of the Existing 2016/Proposed LCP land use
Plan and Policies so everyone can see the proposed changes to the Existing LCP.
Provide true Citizen Workshops on the major remaining vacant Coastal land that still have outstanding
Citizen Concern or objections. Citizen Workshops, when done right, are valuable means to openly educate,
discuss and work to consensus options. These areas, including Ponto, were/are subject to multiple lawsuits,
so true open and honest public workshops would provide an opportunity to openly and honestly discuss the
issues and hopefully build public consensus/support for solutions. This approach seems consistent with CCA
Section 30006, and common sense.
Extend the public comment period 6-months to allow Citizen Review of the Redline Version of the LCPA and
allow time for Citizen Workshops.
The City did extend the Public Review period 2-months over the holidays to January 31, 2020. This is appreciated
although many think this is inadequate given the significance of the Proposed Land Use Plan Amendments, and lack
of Redline Version to compare. The City and their consultants required several extra years beyond schedule prepare
the proposed LCP Amendments. The extra years of City Staff work reflects on the volume of the over 500-pages in
the documents and the time needed to understand the Existing LCP and then create an Amended LCP. Citizens
need sufficient time, proper comparative tools (redline) and a process (workshops) to understand the proposed LCP
Amendments that is reflective of extensive extra time needed by City Staff and consultants needed. Truncation of
lay public review to a few months for an Amendment that took paid professionals many years to produce seems a
more than a bit inappropriate. The City appears to be rejecting citizens’ request to be provided a ‘Redline Version’
of the Existing 2016/Proposed LCP land use Plan. So public review comments will tainted or will miss many issues
due having to manually cross-reference a 150-page Existing LCP LUP with a Proposed 350-page Proposed LCP LUP.
There will be unknown and unconsidered changes in the Draft LCP Amendment that the public and city and CCC
decision makers will not know about due to the lack of ‘Redline Version’.
The City also appears to reject citizen requests for true Citizen Workshops on the major remaining vacant Coastal
land that still have outstanding Citizen Concern – such as Ponto. Like Coastal Recreation issue #1 above the
following citizen requests appear consistent with CA Coastal Act (CCA) Section 30006, and the City’s rejection of that
requests seem counter to the CA Coastal Act.
We again request of the City to provide: 1) a ‘Redline Version’ to the public and decision makers, along with
sufficient time to review and comment on the ‘Redline Version’; and 2) true Citizen Workshops for Ponto and the
Page 7 of 30
other last remaining significant vacant Coastal lands in Carlsbad as part of the Draft LCP Amendment process, or as
part of deferred LCP Amendment process for those areas.
4. Coastal Zoned land is precious: the very small amount of remaining vacant Coastal land should be reserved for
“High-Priority” Coastal Recreation Land Uses under the CA Coastal Act to provide for the growing and forever
‘Buildout’ needs of Carlsbad and CA Citizens, and our visitors.
Less than 1.8% (76 square miles) of San Diego County’s 4,207 square miles is in Coastal Zone. This small area
needs to provide for all the forever Coastal needs of the County, State of CA, and Visitors. Upland Coastal
Recreation (Coastal Park) land use is needed to provide land to migrate the projected/planned loss of “High-
Priority” Coastal Recreation land uses due to Sea Level Rise impacts. There is only 76 miles of total coastline
in San Diego County; a significant amount is publicly inaccessible military/industrial land. So how the last
few portions of Coastal Land within Carlsbad (which is about 8% of San Diego County’s Coastline) is planned
for the forever needs for High-Coastal-Priority Recreation Land Use is critical for Carlsbad, San Diego, and
California Statewide needs into the future.
Most all the developable Coastal land in Carlsbad is already developed with Low-Coastal-Priority residential
uses. Only a very small percentage of Carlsbad’s developable Coastal land, maybe 1-2%, is still vacant. This
last tiny portion of fragment of vacant developable Coastal Land should be documented in the Draft LCP and
reserved for “High-Priority” Coastal Land uses – most critically Coastal Recreation – to address the growing
Coastal Recreation needs from a growing population and visitors. These growing needs are all the more
critical in that existing Coastal Recreation lands will be decreasing due to inundation and erosion due to
DLCPA planned Sea Level Rise.
This image of the western half of San Diego County graphically shows (in the blue line) the very small Coastal
Zone Area that needs to provide the Carlsbad’s and California’s Coastal Recreational needs for all San Diego
County residents and Visitors:
Page 8 of 30
We request that 1) the amount and location of remaining vacant Coastal land in Carlsbad be documented and
mapped and be reserved for high-priority Coastal Land Uses consistent with CCA Goals in Section 30001.5 “… (c) …
maximize public recreational opportunities in the coastal zone consistent with sound resources conservation
principles and constitutionally protected rights of private property owners. (d) Assure priority for coastal-
dependent and coastal-related development over other development on the coast. … “; 2). This data be used in
the City’s analysis and the public’s review and discussion about the City’s proposed Draft ‘Buildout’ Land Use Plan.
The City’s proposed Draft ‘Buildout’ Land Use Plan will forever lock in the amount “maximum public recreational
opportunities in the coastal zone” and will be the final Coastal Land Use Plan that is supposed to “assure priority for
coastal-dependent and coastal-related development over other development on the coast”. Most of Carlsbad’s
Coastal Zone is already developed or committed to low-priority land uses contrary to these CCA Goals, so how we
finally and forever plan to use of the last small remaining vacant Coastal Land is very important.
5. The proposed Draft LCP Amendment in Chapter 3 makes unfounded statements regarding the proposed
Amendment to the LCP Land Use Plan provision of “High-Priority” Coastal Recreation land use: On page 3-3, at the
beginning of the Chapter 3 – Recreation and Visitor Serving Uses the City correctly states that the CA Coastal Act
(CCA) places a high priority on maximizing Recreation uses, and cites multiple CCA Sections to that effect. The City’s
proposed Coastal Land Use Plan then states on page 3-5 that a high proportion of land in the City is dedicated open
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Page 9 of 30
space available for passive and active use, yet provides no justification or accurate metric to support this statement.
This is a critical unsubstantiated and speculative statement that is not supported by any comparative data (justifying
the “high proportion” statement). The City later in Chapter 3 compared the adjoining cities of Oceanside and
Encinitas to try to show how the proposed Draft LCP LUP Amendment provides higher levels of Visitor Serving
Accommodations. That ‘non-common denominator’ comparison was fundamentally flawed, as noted in a prior
separate Draft LCPA public review comment from People for Ponto regarding another high-priority Coastal land use
(visitor accommodations) planned for in Chapter 3, but at least it was an attempt to compare. However, for the
Coastal Recreation portion of Chapter 3, the City does not even attempt to provide any comparative data to support
(or justify) the proposed Coastal Recreation Land Use Plan and statements. The Coastal Recreation Chapter also fails
to disclose Carlsbad’s adopted City Park Master Plan (Park Service Area and Equity map) data that shows a clear
conflict between the CA Coastal Act Policy Sections noted at the beginning of Chapter 3 and Chapter 3’s proposed
Draft Coastal Recreation Land Use Plan.
Comparative Coastal Recreation: Comparing the Land Use Plan and policies of Oceanside, Carlsbad and Encinitas,
one finds Carlsbad’s proposed Coastal Recreational Plan and Policies are not “high”, but very low compared with
Oceanside and Encinitas. Carlsbad has a General Plan Park Standard of 3 acres of City Park per 1,000 Population.
Oceanside has a 5 acres of City Park Standard per 1,000 population, and Encinitas has a 15 acres per 1,000
population standard, and an in-lieu park fee requirement of 5 acres per 1,000 population. Carlsbad’s proposed
Coastal Recreation Land Use Plan is in fact not ‘high’ but is in fact the lowest of the three cities, with Carlsbad
providing only 40% of Oceanside’s park standard, and only 20% of Encinitas’s Park Standard. Citywide Carlsbad
currently has 2.47 acres of developed park per 1,000 population, Oceanside currently has 3.6 acres of developed
park per 1,000 population, and Encinitas currently has 5.5 acres of developed park per 1,000 population. Although
this data is citywide, it shows Carlsbad’s current amount of developed parkland is less than 70% of what Oceanside
currently provides, and less than 45% of what Encinitas currently provides. Carlsbad is not currently providing, nor
proposing a Coastal Land Use Plan to provide, a ‘high’ proportion of Coastal Recreation Land Use compared to
Oceanside and Encinitas.
On page 3-5 Carlsbad may be misrepresenting city open space that is needed and used for the preservation of
federally endangered species habitats and lagoon water bodies. This open space Land cannot be Used for Coastal
Recreation purposes; and in fact Land Use regulations prohibit public access and Recreational Use on these Lands
and water bodies to protect those endangered land and water habitats. 78% of Carlsbad’s open space is “open
space for the preservation of natural resources” and cannot be used for Coastal Parks and Recreational use.
Although “open space for the preservation of natural resources” does provide scenic or visual amenity, and this
amenity is addressed as a different coastal resource. Visual open space is not Coastal Recreation Land Use. It
appears Carlsbad is proposing in the Draft LCP Amendment to continue to, providing a ‘low’ percentage of Coastal
Park Land Use and Coastal Recreation Land Use compared to adjoining cities.
In addition to the comparatively low amount of Coastal Park land Carlsbad plans for, Carlsbad scores very poorly
regarding the equitable and fair distribution and accessibility of Coastal Parks and Coastal Recreation Land Uses.
Both the City of Oceanside and Encinitas have very robust and detailed Park and Land Use plans to promote an
equitable distribution of, and good non-vehicular accessibility, to their Coastal Parks. By comparison, Carlsbad’s park
land use plan scores poorly, as exemplified in Ponto and South Carlsbad. Ponto’s existing population requires about
6.6 acres of City Parkland per Carlsbad’s low 3 acres per 1,000 population standard. Yet the nearest City Park is
several miles away and takes over 50 minutes to walk along major arterial roadways and across Interstate 5 to
access. As such this nearest park is not an accessible park for Ponto children, and thus Ponto children have to play in
Page 10 of 30
our local streets to find a significantly large open area to play in. Ponto residents have to drive their kids to get to a
park increasing VMT and GHG emissions. The City’s proposed Coastal Recreation Land Use Plan ‘solution’ to Ponto’s
no-park condition, along with the City’s need to add an additional 6.5 acres of new City parks in Southwest Carlsbad
to comply with the Southwest Carlsbad’s 2012 population demand (at a ratio of 3-acre/1,000 population) is to
provide a City Park – Veterans Park – over 6-miles away from the Ponto and Southwest Carlsbad population need.
This makes a bad situation worse. The City’s proposed location is totally inaccessible to serve the needs of the
population of children or anyone without a car, that it is intended to serve in South Carlsbad. This City proposed
Coastal Recreation Land Use Plan ‘solution’ seems inappropriate and inconsistent with the CA Coastal Act and
common sense. During the City’s Veterans Park and budget community workshops citizens expressed a desire for a
Ponto Park to be the solution to our Ponto and Southwest Carlsbad Park deficits. Those citizen requests were not
apparently considered as part of the City’s proposed Draft Coastal Recreation Land Use Plan. Following is an image
summarizing the magnitude of citizen needs/desires expressed at the City’s Budget workshop. Note the number
and size of the text citing Ponto Park and South Carlsbad that reflects the number and magnitude/intensity of citizen
workshop groups’ input. The failure to acknowledge this public participation and data in the Coastal Recreation
Land Use Plan Park seems in conflict with CCA Sections 30006 and 30252(6):
For South Carlsbad there is a complete lack of any existing or planned City Coastal Park and park acreage west of I-5,
while North Carlsbad has 9 existing and 1 planned City Coastal Parks totaling 37.8 acres of City Coastal W of I-5
North Carlsbad. Not only is this unfair to South Carlsbad, it is also unfair to North Carlsbad as it increases VMT and
parking impacts in North Carlsbad because South Carlsbad is not providing the City Coastal Parks for South Carlsbad
resident/visitor demands. This City Park disparity is shown on Figure 3-1 of the Coastal Recreation Land Use Plan;
Page 11 of 30
however it more accurately illustrated in the following data/image from the adopted Carlsbad Park Master Plan’s
“Service Area Maps (Equity Maps)”. The image below titled ‘No Coastal Park in South Carlsbad’ shows Carlsbad’s
adopted “Park Service Area Maps (Equity Maps)” from the City’s Park Master Plan that says it maps “the population
being served by that park type/facility.” The added text to the image is data regarding park inequity and disparity in
South Carlsbad. The image compiles Carlsbad’s adopted Park “Park Service Area Maps (Equity Maps)” for
Community Parks and Special Use Area Parks that are the City’s two park acreage types produced by the City’s
comparatively low standard of 3 acre of City Park per 1,000 population. The City’s Park Service Area Maps (Equity
Maps) shows areas and populations served by parks within the blue and red circles. City data clearly shows large
areas of overlapping Park Service (areas/populations served by multiple parks) in North Carlsbad and also shows
large areas in South Carlsbad with No Park Service (areas/populations unserved by any parks) and Park Inequity in
South Carlsbad. It clearly shows the City’s Documented Park Need and Park inequity at Ponto. The Existing LCP LUP
for Ponto’s Planning Area F in is required to “consider” and “document” the need for a “Public Park”. The City’s
adopted Park Service Area Maps (Equity Maps) clearly shows the inequity of Coastal City Park between North and
South Carlsbad, and the need for Coastal Parks in South Carlsbad – particularly at Ponto. The City’s proposed Draft
‘Buildout’ Coastal Recreation Land Use Plan instead proposes to lock-in documented City Public Coastal Park
inequity and unserved Coastal Park demand at Ponto and South Carlsbad forever. It does so by proposing the last
vacant undeveloped/unplanned Coastal land – Ponto Planning Area F - in the unserved Ponto and South Carlsbad
coastline areas instead of being planned for much needed City Park and Coastal Recreation use be converted to
even more low-priority residential and general commercial land uses. These ‘low-priority” residential uses, by the
way, further increase City Park and Coastal Recreation demand and inequity in Coastal South Carlsbad. This is
wrong, and a proposed ‘forever-buildout’ wrong at the most basic and fundamental levels. The proposed Draft
Coastal Recreation Land Use Plan by NOT providing documented needed City parks for vast areas of Coastal South
Carlsbad is inconsistent with the CA Coastal Act policies and Existing LCP LUP requirements for Ponto Planning Area
F; and also inconsistent with fair/equitable/commonsense land use and park planning principles, inconsistent with
CA Coastal Commission social justice goals, inconsistent with social equity, inconsistent with VMT reduction
requirements, and inconsistent with common fairness. A different Coastal Recreation Land Use Plan should be
provided that provides for a socially equitable distribution of Coastal Park resources so as to would allow children,
the elderly and those without cars to access Coastal Parks. The proposed Draft ‘Buildout’ Coastal Recreation Land
Use Plan forever locking in the unfair distribution of City Parks appears a violation of the not only CCA Sections
30213, 30222, 30223, and 30252(6) but also the fundamental values and principles of the CA Coastal Act. The Draft
also appears a violation of Carlsbad’s Community Vision.
Page 12 of 30
A different Coastal Recreation Land Use Plan is required to provide a more equitable distribution of City Parks with
non-vehicular accessibility. Such a different plan would advance State and City requirements to reduce vehicle Miles
Traveled (VMT) and greenhouse gas emissions that contribute to climate change and sea level rise impacts. Please
note that the data for the above basic comparison comes from City of Carlsbad, Oceanside and Encinitas General
Plan and Park Master Plan documents.
Data shows the proposed Coastal Recreation Plan conflicts with the CA Coastal Act policy Sections. As mentioned
page 3-3 correctly states that the CA Coastal Act (CCA) places a high priority on maximizing Recreation Land Uses,
and pages 3-5 list multiple CA Coastal Act (CCA) policy Sections that confirm this. However, given the significant
statewide importance of Coastal Recreation Land Use, the City proposed ‘Buildout’ Coastal Recreation Land Use Plan
does not appear to adequately address and implement these CCA Policies, and most noticeably in the Ponto area of
South Carlsbad. Coastal Recreation is a significant Statewide High-Priority Land Use under the CCA. For a
substantially developed non-coastal-industry city like Carlsbad Coastal Recreation is likely the biggest land use issue.
This issue is even more elevated due to the fact that there are only a few small areas left of undeveloped Coastal
land on which to provide Coastal Recreation, and Carlsbad is proposing a Coastal ‘Buildout’ Land Use Plan on those
areas. The use of the last few remaining vacant portions of Coastal land for Coastal Recreation Land Use is the most
important land use consideration in the proposed Draft LCP Land Use Plan Amendment as population and visitor
growth will increase demands for Coastal Recreation. It is thus very surprising, and disturbing that the proposed
Coastal Recreation Land Use Plan is so short, lacks any comparative and demand projection data, lacks any resource
demand/distribution and social equity data, and lacks any rational and clear connection with CCA Policy and the
proposed ‘Buildout’ Coastal Land Use plan. This is all the more troubling given that:
The Ponto area represents the last significant vacant undeveloped/unplanned land near the coast in South
Carlsbad that can provide a meaningful Coastal Park.
The fact that the City’s Existing LCP requires the city consider and document the need for a “i.e. Public Park”
on Ponto’s Planning Area F prior to the City proposing a change of Planning Area F’s “Non-residential
No Coastal Park in South Carlsbad
• ppx. 6 miles of Coast
without a Coastal Park is a
Ci & Regional need
• South Carlsbad has 64,000
residents & thousands of
hotel visitors without a
Coastal park
• Closest park to Ponto is
Poinsettia Park, appro 2.5
miles across 1-5
• Proposed Veterans Park is
approx. 6 miles away
Page 13 of 30
Reserve” land use designation. The City has repeatedly failed to comply with this LCP LUP requirement, and
worse has repeatedly failed to honestly inform citizens of this LCP LUP requirement at planning Area F
before it granted any land use. The City, apparently implementing speculative developer wishes, has
repeatedly proposed changing Planning Area F’s Coastal Land Use designation to “low-priority” residential
and general commercial land uses without publically disclosing and following the Existing LCP LUP.
The City’s currently developed parks in the southern portion of the City do not meet the city’s
comparatively low public park standard of only 3 acres per 1,000 population. Since 2012 there has been
City park acreage shortfall in both SW and SE Carlsbad.
The Existing population of Ponto (west of I-5 and south of Poinsettia Lane) requires about 6.6 acres of Public
Park based on the City’s comparatively low public park standard of 3 acres per 1,000 population. There ois
no Public Park in Ponto. Adding more population at Ponto will increase this current park demand/supply
disparity.
Carlsbad and other citizens have since 2017 expressed to the City the strong need for a Coastal Park at
Ponto, and requested the City to provide a true citizen-based planning process to consider the Public Park
need at Ponto. The Citizens’ requested process is fully in-line with CCA Goals, Public Participation Policy,
Land Use Policies, and the Existing LCP Land Use Plan/requirements for Planning Area F and is the most
appropriate means to consider and document the need for a Public Park at Ponto as required by the Existing
LCP Land Use Plan.
Planning Area F is for sale, and a non-profit citizens group has made an offer to purchase Planning Area F for
a much needed Coastal Park for both Ponto and inland South Carlsbad residents and visitors. How should
these facts be considered by the City and CCC?
Carlsbad has no Coastal Parks west of I-5 and the railroad corridor for the entire southern half of Carlsbad’s
7-mile coastline.
The southern half of Carlsbad’s coastline is 5.7% of the entire San Diego County coastline and represents a
significant portion of regional coastline without a meaningful Coastal Park west of I-5 and the Railroad
corridor.
The City’s proposed Coastal Recreation Land Use Plan provides No Documentation, No Rational, and No
Supporting or Comparative Data to show the proposed Coastal Recreation Land Use Plan in fact complies
with the CA Coastal Act.
6. There is no Coastal Recreation/Park west of interstate 5 for all South Carlsbad, or half of the entire City. This is an
obviously unfair and inequitable distribution of Coastal Recreation/Park resources that should be corrected by
changes to the Draft LCP Land Use Amendment: The following image (which was sent to the City and CCC on several
prior communications) was first requested by former Carlsbad Councilman Michael Schumacher during a People for
Ponto presentation/request at the Oct 23, 2018 City Council meeting. The data compiled in the image shows how
the South Coastal Carlsbad (Ponto) is not served by a Park per the City’s adopted Parks Master Plan. The blue dots
on the map are park locations and blue circle(s) show the City’s Park Master Plan adopted Park Service Areas and
Park Equity. This data, from pages 87-88 of the City of Carlsbad Parks Master Plan, shows all City Parks (both
Community Parks and Special Use Areas in Coastal Carlsbad (except Aviara Park east of Poinsettia Park and west of
Alga Norte Park). The text on the left margin identifies the South Carlsbad Coastal Park (west of I-5) gap along with
the number of South Carlsbad Citizens (over half the City’s population) without a Coastal Park. The left margin also
identifies more local issues for the over 2,000 Ponto area adults and children. For Ponto residents the nearest Public
Park and City proposed ‘solution’ to the South Carlsbad and Ponto Public Park deficit are miles away over high-
speed/traffic roadways and thus somewhat hazardous to access and effectively unusable by children/the elderly or
Page 14 of 30
those without cars. Having been a 20-year resident of Ponto I regularly see our children have to play in the street as
there are no Public Park with large open fields to play at within a safe and under 1-hour walk away. Ponto citizens
have submitted public comments regarding this condition and the lack of a Park at Ponto
Ponto is at the center of regional 6-mile Coastal Park Gap. A Coastal Park in this instance being a Public Park with
practical green play space and a reasonable connection with the Coast (i.e. located west of the regional rail and
Interstate-5 corridors). The following image shows this larger regional Coastal Park Gap centered on the Ponto Area,
and the nearest Coastal Parks – Cannon Park to the north, and Moonlight Park to the south.
Regionally this image shows Ponto is the last remaining significant vacant Coastal land that could accommodate a
Coastal Park to serve the Coastal Park current needs of over existing 2,000 Ponto residents, 64,000 existing South
Carlsbad residents, and a larger regional population. It is also the only area to serve the Coastal Park needs for the
thousands of hotel rooms in Upland Visitor Accommodations in South Carlsbad.
No Coastal Park in South Carlsbad
• Appx. 6 miles of Coast
without a Coastal Park is a
City & Regional need
• South Carlsbad has 64,000
residents & thousands of
hotel visitors with out a
Coastal park
• Closest park to Ponto is
Poinsettia Park, approx. 2.5
miles across 1-5
• Proposed Veterans Park is
approx. 6 miles away --
< ~ -V -~ .._. ___ ..._ ...............
~ .... c...i.ihfl .. _S.... ~~-._.-n.,..,..,o'-"""'-'11•-
~ n.Wlet<-~•""'-•• ,_~ __ .,,,,.,. ..
~~~\_., ---·--.. -c--.... ... ~---.-~,c~ ...,. __ ... c....t.1, ... ,
Page 15 of 30
As People for Ponto first uncovered and then communicated in 2017 to the City and CCC; Carlsbad’s Existing (since 1994)
Local Coastal Program LUP currently states (on page 101) that Ponto’s Planning Area F: carries a Non-Residential
Reserve (NRR) General Plan designation. Carlsbad’s Existing Local Coastal Program Land Use Plan states: “Planning Area
F carries a Non-Residential Reserve (NRR) General Plan designation. Planning Area F is an “unplanned” area …” and
requires that: “… As part of any future planning effort, the City and Developer must consider and document the need
for the provision of lower cost visitor accommodations or recreational facilities (i.e. public park) on the west side of
the railroad.” CA Coastal Commission actions, Carlsbad Public Records Requests 2017-260, 261, and 262, and 11/20/19
City Planner statements confirm the City never fully communicated to Carlsbad Citizens the existence of this LCP
requirement nor did the City comply with the requirements. Of deep concern is that the City is now (as several times in
the past) still not honestly disclosing to citizens and implementing this Existing LCP requirement as a true and authentic
‘planning effort’. The lack of open public disclosure and apparent fear of true public workshops and Public Comment
about the Existing Planning Area F LCP requirements are troubling. The point of a ‘planning effort’ is to openly and
publically present data, publically discuss and explore possibilities/opportunities, and help build consensus on the best
planning options. Citizens are concerned the city has already made up its mind and there is no real “planning effort” in
the proposed Draft LCP Amendment process, just a brief Staff Report and at the end provide citizens 3-minutes to
comment on the proposal. This is not the proper way to treat the last remaining significant vacant land is South
Carlsbad that will forever determine the Coastal Recreation environment for generations of Carlsbad and California
citizens and visitors to come.
The following data/images show how Ponto is in the center of the 6-mile (west of I-5 and Railroad corridor) regional
Coastal Park gap. Ponto is the last remaining vacant and currently “unplanned” Coastal land that is available to address
this regional Coastal Park Gap.
How Ponte Serves Reg ion
Ponto ls in middle
resiCJnalCoastal
ParkGap
COIISUII P,
-8.6% of SD County
coast ·ne
A Ponto Coastal Park
r26,000
64,000
in South
Page 16 of 30
How Ponto Serves Region cont.
• RellevesCollStal
Park congestion in
North carlsbad,
EncinitasandSolana
Beach
• A1eat.v11enlly m:~t~b
Coastal Parkas seen
by:
-Ponto Beach
parking congestion
-current trespass
use of Planning
Area F asa Park
How Ponto Serves Region cont.
• A Ponto Park helps
address2050 and
beyond Regional
Population and
Visitor Growth
demands for Coastal
Pam
• A Ponto Park
provides the lowest-
oost coastal access
Page 17 of 30
How Ponto Serves Region cont.
• Vital park and open
space amenity for
Visitor serving
busin esand
aa:ommodatlons
• 6.6 acre unlqueCity
Coastal Park venue
to stage special
events: Runs, bike
rides, triathlons,
How Ponto Serves Region cont.
• Ottical Park space
for So. carlsbad
state Beach
campground
• Provides a big
training and staging
space for Junior
lifeguards
• Dogwalktrail
Page 18 of 30
One possible Concept image of a potential Ponto Coastal Park at Planning Area F is illustrated below. The potential for a
Ponto Coastal Park is real. The speculative land investment fund (Lone Star Fund #5 USA L.P. and Bermuda L.P.) that
currently owns Planning Area F is selling the property, and is available for the City of Carlsbad to acquire to address the
documented demand/need for a City Park and City Park inequity at Ponto and in Coastal South Carlsbad. A Ponto
Beachfront Park 501c3 is working to acquire donations to help purchase the site for a Park. These situations and
opportunities should be publicly discussed as part of the City Staff’s proposed Local Coastal Program Land Use Plan
Amendment.
Ponto Coastal Park Concept
• A concept-but
shows potential
recreational
opportunities
• Provides vital
parkland support for
beach & ope n play
fie lds
• Concept plan a gift
from San Pacifico
Page 19 of 30
7. Projected increases in California, San Diego County and Carlsbad population and visitor growth increases the
demand for High-Priority-Coastal Recreation land use:
Increasing Citizen demand for Coastal Recreational land needs to be addressed with increased Coastal
Recreation land:
San Diego County Citizen Population - source: SANDAG Preliminary 2050 Regional Growth Forecast
1980 1,861,846
1990 2,498,016
2000 2,813,833
2010 3,095,313
2020 3,535,000 = 46,500 Citizens per mile of San Diego County coastline
2030 3,870,000
2040 4,163,688
2050 4,384,867 = 57,700 Citizens per mile of San Diego County coastline
2020 to 2050 = 24% increase in San Diego County population.
Citizen Population will continue beyond 2050. Carlsbad may plan for ‘Buildout’ in 2050, but what is San
Diego County’s ‘Buildout’? There is a common-sense need to increase the amount of Coastal Recreation
Land Use in the Proposed LCP Amendment to the Land Use Plan for this growing population. If we do not
increase our supply of Coastal Recreational Resources for these increased demands our Coastal Recreation
Resources will become more overcrowded, deteriorated and ultimately diminish the Coastal Recreation
quality of life for Citizens of Carlsbad and California. Ponto sits in the middle of an existing 6-mile regional
Coastal Park Gap (no Coastal Park west of Interstate 5) and there is No Coastal Park in all of South Carlsbad
to address the Coastal Recreation needs of the 64,000 South Carlsbad Citizens.
Page 20 of 30
Increasing Visitor demand for Coastal Recreational land needs to be addressed with increased Coastal
Recreation land:
Yearly Visitors to San Diego County – source: San Diego Tourism Authority; San Diego Travel Forecast, Dec, 2017
2016 34,900,000
2017 34,900,000
2018 35,300,000
2019 35,900,000
2020 36,500,000 = average 100,000 visitors per day, or 2.83% of County’s Population per day, or
1,316 Visitors/coastal mile/day in 2020
2021 37,100,000
2022 37,700,000
This is growth at about a 1.6% per year increase in visitors. Projecting this Visitor growth rate from 2020 to
2050 results in a 61% or 22,265,000 increase in Visitors in 2050 to:
2050 58,765,000 = average 161,000 visitors per day, or 3.67% of the County’s projected 2050
Population per day, or 2,120 Visitors/coastal mile/day in 2050.
The number of Visitors is likely to increase beyond the year 2050. There is a common-sense need to
increase the amount of Coastal Recreation Land Use in the Proposed LCP Amendment to the Land Use Plan
for these projected 2050 61% increase, and beyond 2050, increases in Visitor demand for Coastal
Recreational Resources. Increasing Coastal Recreation land is a vital and critically supporting Land Use and
vital amenity for California’s, the San Diego Region’s and Carlsbad’s Visitor Serving Industry. Ponto sits in
the middle of an existing 6-mile regional Coastal Park Gap (no Coastal Park west of Interstate 5). There are
thousands of hotel rooms in South Carlsbad that have NO Coastal Park to go to in South Carlsbad. This
needs correcting as both a Coastal Act and also a City economic sustainability imperative.
We request that the as part of the public’s review, the City Staff proposed Draft LCP Amendment to the Land
Use Plan clearly document if and/or how future forever ‘Buildout” City, Regional and Statewide population
and visitor population demand for Coastal Recreation and City Coastal Parks are adequately provided for
both in amount and locational distribution in the Carlsbad proposed Amendment of the LCP Land Use Plan.
8. Carlsbad’s Draft Local Coastal Program Land Use Plan Amendment says it plans to a year 2050 buildout of the
Coastal Zone. The Draft Local Coastal Program Land Use Plan Amendment then is the last opportunity to create a
Coastal Land Use Plan to provide “High-Priority” Coastal Recreation Land Use, and will forever impact future
generations of California, San Diego County, and Carlsbad Citizens and Visitors:
The Draft LCPA indicates in 2008 only 9% of All Carlsbad was vacant land. Less is vacant now in 2019.
Carlsbad’s Coastal Zone is 37% of the City, so vacant unconstrained land suitable for providing Coastal
Recreation is likely only 3-4%. The prior request for a full documentation of the remaining vacant Coastal
lands will provide a better understanding needed to begin to make the final ‘buildout’ Coastal Land Use Plan
for Carlsbad. The Draft LCPA does not indicate the amount and locations of currently vacant unconstrained
Coastal Land in Carlsbad. This final limited vacant land resource should be clearly documented and mapped
in the DLCPA as it represents the real focus of the DLCPA – the Coastal Plan for these remaingn undeveloped
Page 21 of 30
lands. These last remaining vacant lands should be primarily used to provide for and equitably distribute
“High-Priority” Coastal Recreation Land Uses consistent with CCA Sections:
i. Section 30212.5 “… Wherever appropriate and feasible, public facilities, including parking areas or
facilities, shall be distributed throughout an area so as to mitigate against the impacts, social and
otherwise, of overcrowding or overuse by the public of any single area.”;
ii. Section 30213 “… Lower cost visitor and recreational facilities shall be protected, encouraged, and,
where feasible, provided. Developments providing public recreational opportunities are
preferred. …”;
iii. Section 30222 “The use of private lands suitable for visitor-serving commercial recreational
facilities designed to enhance public opportunities for coastal recreation shall have priority over
private residential, general industrial, or general commercial development, but not over
agriculture or coastal-dependent industry.”
iv. Section 30223 “Upland areas necessary to support coastal recreational uses shall be reserved for
such uses, where feasible” ,
v. Section 30251 … The location and amount of new development should maintain and enhance public
access to the coast by … 6) assuring that the recreational needs of new residents will not overload
nearby coastal recreation areas by correlating the amount of development with local park
acquisition and development plans with the provision of onsite recreational facilities to serve the
new development”
Adopted City Park Service Area and Park Equity maps discussed earlier document the proposed Draft LCP
Amendment’s inconstancy with the above CCA Policy Sections. The locations and small amounts remaining
vacant Coastal lands provide the last opportunities to correct the inconsistencies of City proposed Draft
“buildout” LCP Land Use Plan Amendment with these Coastal Act Policies.
Currently and since 1996 there has been LCP LUP Policy/regulations for Ponto Planning Area F that require
consideration of a “Public Park” prior to changing the existing “unplanned Non-residential Reserve” Land
Use designation. A map and data base of vacant developable Coastal land should be provided as part of the
Draft LCPA and the Draft LCPA. This map and data base should document the projected/planned loss of
Coastal land use due to Sea Level Rise. Draft LCPA projects Sea Level Rise will eliminate several beaches and
High-Priority Coastal Land Uses like Coastal Lagoon Trails and the Campground.
The LCP Land Use Plan should plan and reserve the very limited vacant developable Coastal land for the
long-term ‘Buildout’ needs of “High-Priority” Coastal Recreation Land Use. Vacant developable Coastal land
is too scarce to be squandered for “low-priority” uses. Sea Level Rise will reduce “High-Priority” Coastal
Uses. So how vacant developable Upland area should be preserved for “High-Priority” Coastal Uses is a key
requirement to be fully documented and discussed in the Draft LCPA. If not one of two thing will eventually
happen 1) any new Coastal Park land will require very expensive purchase and demolition of buildings or
public facilities to create any new Coastal Park land to meet existing and growing demand; or 2) Coastal
Recreation will hemmed-in my “low-priority” uses and thus force Coastal Recreation to decrease and
become increasing concentrated and overcrowded in its current locations; and thus will promote the
eventual deterioration of our current Coastal Recreation resources. A plan that fails to fix Coastal Park
deficits and then increase Costal Parks in pace with increased population/visitor demand is a plan that can
Page 22 of 30
only result in degradation. How the Draft LCPA documents and addresses the land use planning of the last
small portions of vacant developable Coastal land is critical for the future and future generations.
9. Citizens of South Carlsbad are concerned about the City’s multiple prior flawed Ponto planning processes or
‘mistakes’ the City has made yet is basing the City Staff’s proposed Draft LCP LUP. The concerns being the City is not
openly and honestly communicating information to citizens and the public, and not allowing a reasonable and
appropriate community-based planning process to address the documented Park, Coastal Recreation and
unconstrained open space needs in South Carlsbad. One of these groups of citizens has created a
www.peopleforponto.com website to try to research and compile information and hopefully provide a better means
for citizens to understand facts and then express their concerns/desires to the City of Carlsbad (City) and CA Coastal
Commission (CCC). Over 2,000 emails have sent to the City and CCC regarding Coastal Land Use Planning Issues at
Ponto. The San Pacifico Planned Community (i.e. San Pacifico Community Association) has also, since 2015, sent
numerous emailed letters to the City and CCC noting the significant concerns about changes in Coastal planning the
City is proposing for our Planned Community.
Repeatedly over 90% of surveyed citizens (results emailed prior to both the City and CCC) have expressed the vital
need and desire for a Coastal Park at Ponto to serve the current and future Coastal Recreation needs for all both
Ponto and South Carlsbad and for larger regional and State Coastal Recreational needs. This desire is supported by
data, CA Coastal Act Policy, and also Carlsbad’s Community Vision – the foundation for the City’s General Plan.
Ponto is the last remaining vacant Coastal area available to provide for those needs in South Carlsbad and for a
regional 6-mile stretch of coastline. Citizens have expressed deep concern about the City’s flawed prior Coastal
planning efforts for Coastal Recreation at Ponto, including two repeated LCP Amendment “mistakes” (Ponto
Beachfront Village Vision Plan in 2010 and General Plan Update in 2015) when the City twice failed to publicly
disclose/discuss and then follow the Existing LCP requirements at Ponto – specifically for Planning Area F. People for
Ponto had to use multiple Carlsbad Public Records Requests in 2017 to find these “mistakes”. CCC Staff was helpful
in both confirming the City “mistakes” and communicating back to the City. As citizens we are still unclear has to
how/why these two repeated “mistakes” happened. There is citizen concern that the City is again repeating these
two prior “mistakes” by not at the beginning of the Public Comment Period clearly and publicly disclosing the
Planning Area F LCP requirements to citizens as part of the current LCP Amendment process, and also by not
implementing the exiting LCP requirement PRIOR to proposing an Amended Coastal Land Use Plan for Ponto. The
City in its proposed LCP Amendment process is putting-the-cart-before-the-horse with respect to honest and open
consideration, documentation and public discussion of the need for high-priority Coastal Recreation land use
required of Planning Area F at Ponto. The City is also not clearly letting all Carlsbad citizens know about the Existing
LCP requirements for Ponto’s Planning Area F so they can be informed to reasonably participate in public review and
comment regarding amending that LCP requirement, and the need for Coastal Recreation land uses in South
Carlsbad. Since 2017 there has been repeated citizen requests to the City (copies were provided to the CCC) to fix
these multiple fundamental/foundational flaws by in the City’s prior Coastal Recreation and Public Parks and Open
Space at planning, and the currently Proposed Draft LCP Land Use Plan Amendment. Since 2017 there have also
been repeated citizen requests to the City to provide a truly open, honest, inclusive community-based planning
process and workshops with the accurate and honest information, prior to forming a proposed Draft LCP Land Use
Plan Amendment. As citizens we believe we can constructively work with the City and CCC towards a consensus or
viable options on these important Coastal Recreation issues if the City allows and encourages such an open, honest
and inclusive process. We request the City respond to the requests submitted to the City since 2017, and again
request such a process from the City before any LCP Amendment is first considered by the Planning Commission and
City Council. Such a requested process benefits all.
Page 23 of 30
10. Why the Draft LCPA Land Use Plan for Ponto should provide for the current and future Coastal Park and Recreation
needs for South Carlsbad, the San Diego Region and California.
Ponto, is one of last remaining vacant and undeveloped Coastal lands in North County
Ponto is the last remaining undeveloped Coastal land in South Carlsbad
Ponto has the last unplanned Planning Area of the Existing Poinsettia Shores Planned Community & Local
Coastal Program that can be planned for high-priority Coastal Recreation land use. This Existing LCP requires
Planning Area F be considered for a “Public Park”.
Following is a map of the Ponto area in South Carlsbad:
Following is the LCP Land Use map from the Existing Poinsettia Shores Master Plan & Local Coastal Program adopted
in 1996. This is the Land Use map that the City is proposing to change in the proposed LCP Amendment to the Land
Use Plan. As the Existing LCP Land Use map shows most all the land is ‘low-priority’ residential use at an RM
Residential medium density, a small portion is ‘high-priority’ Visitor Serving TC/C Tourist Commercial. Most all the
Page 24 of 30
Open Space is constrained and undevelopable land (the steep CSS habitat bluffs above Batiquitos Lagoon) or water
(the lagoon water). This land/water is owned by the State of California, like the inner lagoon east of I-5. Only
Planning Area M at 2.3 acres is unconstrained Open Space and it provides a small private internal recreation facility
for the approximately 450 homes and 1,000 people in the Planned Community. This small recreation area is a City
requirement for ‘planned developments’ to off-set loss open space from planned development impacts on housing
quality. Planned developments can propose designs that reduce normal setback and open space areas – they bunch
together buildings to increase development – such as the smaller lot sizes, and extensive use of “zero-setbacks” to
reduce typical lot sizes that occurs at Poinsettia Shores. A private recreation facility in any of the City’s planned
developments is never considered a replacement for required City Parks. Planned Developments, like unplanned
developments, are required to dedicate Park land to the City, or pay a Park In-Lieu fee to the City so the City provide
the developer’s obligation to provide City Park acreage to address the population increase of their proposed planned
development. For Poinsettia Shores’ population the City’s minimum City Park Standard would require developers
set aside 3 acres of City Park land for local park needs. For the larger Ponto area population about 6.6 acres of City
Park Land is required. The Existing LCP reserves Planning Area F as an unplanned “Non-residential Reserve” Land
Use until the Public Park needs for Ponto are considered and documented. Only then can the NRR land use be
changed.
11. Developers have overbuilt in the Ponto area of the Coastal Zone. The City of Carlsbad has under questionable
circumstances is currently choosing to ‘exempted’ Ponto developers from providing the minimum amount of
unconstrained Open Space according to the City’s developer required Open Space Public Facilities Standard. The
legality of these confusing circumstances is subject to a lawsuit against the City. However the City’s computerize
mapping system has documented that the Ponto area of the Coastal Zone is missing about 30-acres of
Unconstrained Open Space that can be used to fulfill the City’s Open Space Performance Standard that states that
Page 25 of 30
15% of unconstrained and developable land must be preserved by developers as Open Space. Following is a
summary of data from the City data regarding the missing Open Space at Ponto (Local Facility Management Plan
Zone 9, LFMP Zone 9) in the Coastal Zone pursuant to the City’s Open Space Performance Standard. If it is desirable
People for Ponto can provide the City GIS map and parcel-by-parcel data base on which the following summary is
based:
City of Carlsbad GIS data calculations of Open Space at Ponto area of Coastal Zone:
472 Acres = Total land in LFMP Zone 9 [Ponto area] per City of Carlsbad GIS data
(197 Acres) = Constrained land/water/infrastructure that is excluded from the City’s Open Space Standard
275 Acres = Unconstrained land in LFMP Zone 9 (Ponto) subject to the City’s Open Space Standard
X 15% = Minimum unconstrained Open Space requirement per the City Open Space Standard
41 Acres = Minimum unconstrained Open Space required in LFMP Zone 9
(11 Acres) = Actual unconstrained Open Space provided & mapped by City in LFMP Zone 9
30 Acres = Missing unconstrained Open Space needed in LFMP Zone 9 [Ponto area of Coastal Zone] to meet the
City’s minimum GMP Open Space Standard. 73% of the required Open Space Standard is missing.
Thus the Ponto area of the Coastal Zone appears overdeveloped with 30 additional acres of “low-priority” residential
land uses due to developers’ non-compliance to the City’s Open Space Public Facility Performance Standard’s
Minimum developer required Open Space requirement. As noted a citizens group has a pending lawsuit with the
City over the City’s current ‘exempting’ Ponto and future developers from meeting the Open Space Standard.
12. The prior pre-1996 LCP for Ponto – the Batiquitos Lagoon Educational Park Master Plan & LCP (BLEP MP/LCP) had
significant Open Space and recreational areas. These significant Open Space and Recreational areas where removed
with BLEP MP/LCP’s replacement in 1996 by the currently existing Poinsettia Shores Master & LCP (PSMP/LCP) and
its City Zoning and LCP LUP requirements that reserved Planning Area F with the current “Non-residential Reserve”
Land Use designation. Since the BLEP MP/LCP it appears developers and the City of Carlsbad have worked to
remove “High-Priority” Coastal land uses (i.e. Coastal Recreation and Park uses) out of the Ponto area and replaced
them with more “low-priority” residential and general commercial land uses. For example:
Planning Area F used to be designated “Visitor Serving Commercial” as part of the original 1980’s BLEP
MP/LCP for Ponto.
In 1996 the BLEP MP LCP was changed by developer application to the now current PSMP LCP, and the LCP
LUP designation changed from “Visitor Serving Commercial” to “Non-Residential Reserve” with the
requirement to study and document the need for “High-Priority” Coastal Recreation (i.e. Public Park) and/or
Low-cost visitor accommodations prior to any change to Planning Area F’s “Non-residential Reserve” LCP
land use.
In 2005 the City started to try to change Planning Area F to low-priority residential and general commercial
land use in the City’s Ponto Beachfront Village Vision Plan (PBVVP). At this time the City made its first
documented Coastal ‘planning mistake’ by not disclosing to the public the existence of Planning Area F’s LCP
requirements and then also not following those LCP requirements. The City’s planning process seemed
focused on addressing developer’s land use desires, and increasing land use intensity to boost “Tax-
increment financing” as the City had established a Redevelopment Project Area at Ponto. A short time after
the State of CA dissolved Redevelopment Agencies due in part to such abuses by cities. The CCC formally
rejected the PBVVP in 2010, citing the City’s failure to follow the LCP requirements for Planning Area F.
Page 26 of 30
Five years later in 2015 the City again adopted a proposed General Plan Update to again change Planning
Area F to low-priority residential and general commercial land use. The General Plan Update cited the City’s
PBVVP that was in fact rejected by the CCC only a few years before. The City again repeated their PBVVP’s
Coastal land use ‘planning mistake’ by again not disclosing to the public the existence of Planning Area F’s
LCP requirements and then not following those LCP requirements. It is unclear why the City did this only 5-
years after the CCC specifically rejected the Ponto Beachfront Village Vision Plan for those same reasons.
In 2017 citizens found and then confirmed these Ponto Coastal ‘planning mistakes’ by the City through
multiple official Carlsbad Public Records Requests and CCC Staff confirmation. The CCC readily identified the
mistakes, but the City’s 2019 proposed Draft LCP Land Use Plan and planning process still has yet fully
disclose these prior Coastal ‘planning mistakes’ to ALL citizens of Carlsbad - the failure to disclose and follow
the Planning Area F LCP LUP and City Zoning requirements. Full City disclosure is needed now to try to
correct many years of City misrepresentation to citizens on LCP required Coastal land Use planning at Ponto.
It is needed now so the public is aware at the start of the Public Comment Period. In 2017 citizens began
asking the City fix the City’s over 12-years of misinformation and planning mistakes by ‘restarting’ Coastal
land use planning at Ponto with an open and honest community-based Coastal planning process. These
citizens’ requests have been rejected.
In 2019 the City Staff proposed citywide Draft LCP land Use Plan Amendment that again proposed to change
Planning Area F to “low-priority” residential and general commercial land use, without First disclosing the
Planning Area F LCP requirements with corresponding analysis of the Need for Coastal Recreation (i.e. Public
Park) and/or low-cost visitor accommodations at Planning Area F and providing that Documented analysis
for public review/Consideration/comment. This seems like another 3rd repeat of the prior two Coastal
planning mistakes by the City. In 2019, again citizens asked for a reset and a true community-based process
for the last remaining significant vacant Coastal lands – including Ponto. Again the City rejected citizens’
requests.
In 2020 thousands of public requests again asked, and are currently asking, for a reset and a true
community-based process for the last remaining significant vacant Coastal lands – including Ponto. Again
these requests are being rejected. Based on the significant citizen concern and the documented prior
‘planning mistakes’ at Ponto it appears reasonable and responsible for Ponto’s Planning Area F to ether:
i. Retain its current Existing LCP LUP land Use of “Non-Residential Reserve” until such time as the
City’s past Ponto Beachfront Village Vision Plan and General Plan Update planning mistakes and
other issues subject to current planning lawsuits against the City are resolved with a true, honest
and open community-based Coastal planning process asked for by citizens since 2017. Or
ii. Propose in the Draft LCP Land Use Plan Amendment to re-designated Planning Area F back to a
Visitor Serving Commercial and Open Space (“i.e. Public Park”) to provide both “High-Priory” coastal
uses v. low-priority residential/general commercial uses due to the documented Coastal Recreation
and Low-cost visitor accommodation needs for both citizens and visitors at Ponto and South
Carlsbad.
13. Questionable logic and inconsistency in proposed Draft land use map and policies: Chapter 2 Figure 2-2B & C on
pages 2-19 & 20 proposes to Amend the existing LCP Land Use Plan Map, and policies LCP-2-P.19 and 20 on pages 2-
27 to 2-29 propose Amendments to existing LCP policy and create a new added layer of policy referencing a
Ponto/Southern Waterfront. The proposed Land Use Map and Policies serve to firmly plan for “low-priority”
residential and general commercial land uses at Ponto with a clear regulatory Land Use Plan Map showing these
land uses and by specific regulatory policy (LCP-2-20) that clearly requires (by using the words “shall”) these “low
Page 27 of 30
priority” uses. In contrast the “High-Priority” Coastal Recreation and Coastal Park land uses that would be
designated as Open Space are not mapped at all in Figure 2-2B & C; and the proposed policy LCP-2-P.19 is both
misleading and specifically does Not Require any “High-Priority” Coastal Recreation and Coastal Park land Use at
Ponto and South Carlsbad. In fact page 2-22 specifically indicates two “may” criteria that would first need to occur
in the positive before any potential Coastal Recreation and Coastal Park Land could then theoretically even be
possible. It is highly probable that it is already known by the City that the proposed relocation of Carlsbad Boulevard
(Coast Highway) is not very feasible and not cost effective, and will not yield (due to environmental habitat
constraints, narrowness of the roadway median, and other design constraints) any significant dimensions of land
that could potentially be designated Open Space and realistically be used as a Park.
The blank outline map (Figure 2-2B &C) provides no mapped Open Space Land Use designation, other than for the
currently existing State Campgrounds’ low-cost visitor accommodations, so the proposed Land Use Plan Map is Not
providing/mapping any new Open Space land use to address Coastal Recreation and Coastal Park needs. The Draft
LCP Land Use Plan Amendment’s proposed/projected/planned Sea Level Rise and associated coastal erosion appears
to indicate that this “High-Priority” low-cost visitor accommodation (Campground) land use designated as Open
Space will be reduced in the ‘Buildout’ condition due to coastal erosion. So the Draft LCP Land Use Plan is actually
planning for a Reduction in Open Space Land Use in South Carlsbad and Ponto. Both the blank outline map and
the proposed Land Use Map Figure 2-1 DO NOT clearly map and designate both South Carlsbad’s Draft LCP Planned
Loss of the Open Space Land Use and also any New or replacement unconstrained land as Open Space land use for
Coastal Recreation and Coastal Park. This is an internal inconsistency in Land Use Mapping that should be corrected
in two ways:
1) Showing on all the Land Use (Figure 2-1), Special Planning Area (Figure 2-2B & C), and other Draft LCP Maps
the Draft LCP’s planned loss of land area in those maps due to the Draft LCP’s planned loss of land due to
Sea Level Rise and Coastal Land Erosion. This is required to show how land use boundaries and Coastal
Recourses are planned to change over time. or
2) Provide detailed Land Use Constraint Maps for the current Carlsbad Boulevard right-of-way that the City
“may” or ‘may not’ choose (per the proposed “may” LCP-2-P.19 policy) use to explore to address the City’s
(Park Master Plan) documented Coastal Recreation and Coastal Park land use shortages in Coastal South
Carlsbad and Ponto. Clearly showing the potential residual Unconstrained Land within a Carlsbad Boulevard
relocation that have any potential possibility to add new Open Space Land Use Designations (for Coastal
Recreation) is needed now to judge if the policy is even rational, or is it just a Trojan horse.
The proposed internal inconsistency in mapping and policy appears like a plan/policy ‘shell game’. The proposed
Land Use Plan Maps and Policies should be consistent and equality committed (mapped-shall v. unmapped-may) to
a feasible and actual Plan. If not then there is No real Plan.
There is no Regulatory Policy requirement in LCP-2-P.19 to even require the City to work on the two “may” criteria.
The City could choose to bury the entire Carlsbad Boulevard relocation concept and be totally consistent with Policy
LCP-2-P.19 and the LCP. As such the language on 2-22, Figure 2-2C (and the proposed Land Use Map), and policy
LCP-2-P.19 and 20 appear conspire to create a shell game or bait-and-switch game in that only “low-priority”
residential and general commercial uses are guaranteed (by “shall” policy) winners, and “high-priority” Coastal
Recreation and Coastal Park Land Uses are at best a non-committal ‘long-shot” (“may” policy) that the city is
specifically not providing a way to ever define, or commit to implement. The proposed Draft LCP Land Use Plan
Coastal Recreation and Coastal Park statements for Ponto are just words on paper that are designed to have no
force, no commitment, no defined outcome, and no defined requirement to even have an outcome regarding the
Page 28 of 30
documented “High-Priority” Coastal Recreation and Costal Park needs at Ponto, Coastal South Carlsbad and the
regional 6-mile Coastal Park gap centered around Ponto.
Policy LCP-2-P.19 falsely says it “promotes development of recreational use” but does not in fact do that. How is
development of ‘recreational use promoted’ when the Use is both unmapped and no regulatory policy requirement
and commitment (no “shall” statement) to ‘promote’ that Use is provided? Policy LCP-2-19.19 appears a misleading
sham that does not ‘promote’ or require in any way “High-Priority” Coastal Recreation and Park Land Use at Ponto.
There should be open and honest public workshops before the Draft LCP Amendment goes to its first public hearing
to clearly define the major environmental constraints and cost estimates involving possible relocation of Carlsbad
Boulevard and constructing needed beach access parking, and sufficient and safe sidewalks and bike paths along
Carlsbad Boulevard; and then map the amount and dimensions of potential ‘excess land’ that maybe available for
possible designation as Open Space in the City General Plan and Local Coastal Program. The City should not repeat
the mistakes at the Carlsbad Municipal Golf Course (resulting in the most expensive to construct maniple course in
the USA) by not defining and vetting the concept first. A preliminary review of City GIS data appears the amount,
dimensions and locations of any potential ‘excess’ land maybe modest at best. However before the City proposes a
‘Buildout’ Coastal Land Use Plan this critical information should be clearly provided and considered. It is likely the
City’s Carlsbad Boulevard relocation concept is unfeasible, inefficient, too costly, and yields too little actual useable
‘excess land’ to ever approach the Coastal Recreation and Coastal Park needs for South Carlsbad. This may already
be known by the City, but it surely should be publicly disclosed and discussed in the DLPCA.
The proposed Coastal Land Use Plan to address Carlsbad’s, San Diego County’s and California’s High-Priority Coastal
Recreation Land Use and Coastal Park needs should NOT be vague “may” policy that appears to be purposely
designed/worded to not commit to actually providing any “High-Priority” Coastal Recreation and Coastal Park land
uses on the map or in policy commitments. The Land Use Plan and Policy for High-Priority Coastal Recreation and
Coastal Park Land Use should be definitive with triggered “shall” policy statements requiring and assuring that the
‘Forever’ “High-Priority” Coastal Recreation and Coastal Park needs are properly and timely addressed in the City’s
proposed ‘Buildout’ Coastal Land Use Plan. This “shall” policy commitment should be clearly and consistently
mapped to show the basic feasibility of the planned outcomes and the resulting actual Land that could feasibly
implement the planned outcome.
Providing safe and sufficient sidewalks, bike paths, and public parking along Carlsbad Boulevard: Providing safe and
sufficient sidewalks, bike paths, and public parking along Carlsbad Boulevard are Coastal Access and Completes
Streets issues. South Carlsbad Boulevard now and has for decades been a highly used Incomplete Street that is out
of compliance with the City’s minimum Street Standards for pedestrian and bike access and safety. The Coastal
Access portion of the Draft Land Use Plan should strongly address the Complete Street requirements for South
Carlsbad Boulevard. Those policy commitments should be reference in Policy LCP-2-P.19 and 20 as Carlsbad
Boulevard in South Carlsbad is the most Complete Street deficient portion of Carlsbad Boulevard. Forever Coastal
Access parking demand and the proposed LCP Amendment’s Land Use Plan to supply parking for those demands
should also be addressed as part of the Coastal Access and Complete Streets issues for South Carlsbad Boulevard. If
much needed Coastal Access Parking is provided on South Carlsbad Boulevard as part of a “maybe” implemented
realignment, most of the “maybe” realignment land left after constraints are accommodated for and buffered will
likely be consumed with these parking spaces and parking drive aisles/buffer area needed to separate high-speed
vehicular traffic from parking, a buffered bike path, and a sufficiently wide pedestrian sidewalk or Coastal Path.
After accommodating these much needed Complete Street facilitates there will likely be little if any sufficiently
Page 29 of 30
dimensioned land available for a Coastal Recreation and a Coastal Park. The needed Coastal Access and Complete
Street facilities on South Carlsbad Boulevard are very much needed, but they are NOT a Coastal Park.
As mentioned the proposed Draft Coastal Land Use Plan’s Maps and Policies are very specific in providing for the
City’s proposed LCP Land Use changes to ‘low-priority” Residential and General Commercial’ on Planning Area F
(proposed to be renamed to Area 1 and 2). It is curious as to why the proposed Draft LCP Land Use Plan
Amendment has no Land Use Map and minor vague unaccountable Land Use Policy concerning ‘High-priority Coastal
Recreation Land Use’ at Ponto, while the very same time proposing very clear Land Use Mapping and detailed
unambiguous “shall” land use policy requirements for ‘low-priority” Residential and General Commercial land use at
Ponto. Why is the City Not committing and requiring (in a Land Use Map and Land Use Policy) to much needed
‘High-priority” Coastal Recreation and Coastal Park Land Use’ needs at Ponto the same detail and commitment as
the City is providing for “low-priority” uses? This is backwards and inappropriate. It is all the more inappropriate
given the ‘Buildout’ Coastal Land Use Plan the City is proposing at Ponto. These issues and plan/policy commitments
and non-commitments will be ‘forever’ and should be fully and publicly evaluated as previously requested, or the
Exiting LCP Land Use Plan of “Non-residential Reserve” for Planning Area F should remain unchanged and until the
forever-buildout Coastal Recreation and Coastal Park issues can be clearly, honestly and properly considered and
accountably planned for. This is vitally important and seems to speak to the very heart of the CA Coastal Act, its
founding and enduring principles, and its policies to maximize Coastal Recreation. People for Ponto and we believe
many others, when they are aware of the issues, think the City and CA Coastal Commission should be taking a long-
term perspective and be more careful, thorough, thoughtful, inclusive, and in the considerations of the City’s
proposal/request to permanently convert the last vacant unplanned (Non-residential Reserve) Coastal land at Ponto
to “low-priority” land uses and forever eliminate any Coastal Recreation and Coastal Park opportunities.
14. Public Coastal View protection: Avenida Encinas is the only inland public access road and pedestrian sidewalk to
access the Coast at Ponto for one mile in each direction north and south. It is also hosts the regional Coastal Rail
Trail in 3’ wide bike lanes. There exist now phenomenal coastal ocean views for the public along Avenida Encinas
from the rail corridor bridge to Carlsbad Boulevard. It is assumed these existing expansive public views to the ocean
will be mostly eliminated with any building development seaward or the Rail corridor. This is understandable, but
an accountable (‘shall”) Land Use Plan/Policy addition to proposed Policy LCP-2-P.20 should be provided for a
reasonable Public Coastal View corridor along both sides of Avenida Encinas and at the intersection with Carlsbad
Boulevard. Public Coastal view analysis, building height-setback standards along Avenida Encinas, and building
placement and site design and landscaping criteria in policy LCP-2-P.20 could also considered to reasonably provide
for some residual public coastal view preservation.
15. Illogical landscape setback reductions proposed along Carlsbad Boulevard, and Undefined landscape setback along
the Lagoon Bluff Top and rail corridor in Policy LCP-2-P.20: Logically setbacks are used in planning to provide a
buffering separation of incompatible land uses/activities/habitats. The intent of the setback separation being to
protect adjacent uses/activities/habitats from incompatibility, nuisance or harassment by providing a sufficient
distance/area (i.e. setback) between uses/activities/habitats and for required urban design aesthetics – almost
always a buffering landscaping. Policy LCP-2-P.20. A.4 and C.3 says the required 40’ landscape setback along
Carlsbad Boulevard “maybe reduced due to site constraints or protection of environmental resources.” The ability
to reduce the setback is illogical in that setbacks are intendent to protect environmental resources and provide a
buffer for constraints. In the Carlsbad Boulevard right-of-way there is documented sensitive environmental habitat,
along with being a busy roadway. How could reducing the protective 40’ setback in anyway better protect that
habitat or provide a better landscaped compatibility or visual aesthesis buffer along Carlsbad Boulevard? It is
Page 30 of 30
illogical. If anything the minimum 40’ landscaped setback should likely be expanded near “environmental
resources”. Regarding reducing the minimum 40’ landscape setback for “site constraints” there is no definition of
what a “site constraint” is or why it (whatever it may be) justifies a reduction of the minimum landscaped setback.
Is endangered species habitat, or a hazardous geologic feature, or a slope, or on-site infrastructure considered a
“site constraint”? There should be some explanation of what a “site constraint” is and is not, and once defined if it
warrants a landscape setback reduction to enhance the buffering purpose of a landscape setback. Or will a
reduction only allow bringing the defined constraint closer to the adjacent uses/activities/habitats that the
landscape setback is designed to buffer. It is good planning practice to not only be clear in the use of terms; but
also, if a proposed reduction in a minimum standard is allowed, to define reasonably clear criteria for that
reduction/modification and provide appropriate defined mitigation to assume the intended performance objectives
of the minimum landscape setback are achieved.
Policy LCP-2-P.20.C.4 is missing a critical Bluff-Top landscape setback. It seems impossible that the DLCPA is
proposing no Bluff-Top setback from the lagoon bluffs and sensitive habitat. The Batiquitos Lagoon’s adjoining steep
sensitive habitat slopes directly connect along the Bluff-top. Batiquitos Lagoon’s and adjoining steep sensitive
habitat is a sensitive habitat that requires significant setbacks as a buffer from development impacts. Setbacks
similar to those required for the San Pacifico area inland of the rail corridor, should be provided unless updated
information about habitat sensitivity or community aesthetics requires different setback requirements.
Policy LCP-2-P.20 does not include a landscape setback standard adjacent to the rail corridor. This is a significant
national transportation corridor, part of the 2nd busiest rail corridor in the USA. Train travel along this corridor is
planned to increase greatly in the years to come. Now there is significant noise, Diesel engine pollution, and
extensive ground vibration due to train travel along the rail corridor. Long freight trains which currently run mostly
at night and weekends are particularly noisy and heavy, and create significant ground vibration (underground noise).
These issues are best mitigated by landscape setbacks and other buffers/barriers. A minimum setback standard for
sufficient landscaping for a visual buffer and also factoring appropriate noise and ground vibration standards for a
buildout situation should be used to establish an appropriate landscape setback that should be provided along the
rail corridor. Carlsbad’s landscape aesthetics along the rail corridor should be factored into how wide the setback
should be and how landscaping should be provided. An example for the landscape aesthetic portion of the setback
standard could be landscape design dimensions of the San Pacifico community on the inland side of the rail corridor.
However, noise and vibrational impacts at San Pacifico are felt much further inland and appear to justify increased
setbacks for those impacts.
General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park – part 1 Page 1 of 4
2022 General Comparative tax-payer Costs/Benefits of Completing PCH, PCH Modification,
and Ponto Park to address planned loss of 30+ acres of Coastal Open Space Land Use at
Ponto/West BL/South Carlsbad: Part 1 of 2
Key base facts regarding tax-payer Cost/Benefit comparison:
City Coastal Park Fairness: Ponto/Coastal South Carlsbad has ZERO Parks and ZERO Park acres v. 10
Coastal Parks in North Carlsbad. 62% of Carlsbad citizens and major visitor industries live in South
Carlsbad with no Coastal Park. 38% of Carlsbad citizens have the entire City’s Coastal Parks. The City
also falsely allowed Ponto Developers to NOT PROVIDE the required 15% unconstrained Open Space
required by other developers in Carlsbad. Consequently Ponto is already developed at a density 35%
higher than the rest of City.
What is missing from South PCH: The only missing components of a Carlsbad Livable (Complete) Street
are adequate Coastal sidewalks/pedestrian paths. Better safer protected bike paths for the volume of
bike traffic on a higher-speed roadway are highly desired. Both these missing features can be (and
should have already long ago been) provided in the existing PCH configuration.
Generalized Costs: Costs come from publicly stated costs by Mayor Hall in a 2019 at Meet the Mayor
Realtor luncheon at Hilton Garden Inn, City PCH Modification Cost Studies for South PCH, $13 million per
mile cost for the simpler City CIP #6054 PCH Modification Project at Terramar, general City cost data
from official public records requests, and vacant Ponto land costs of $1.4 to $2.4 million per acre from
recent recorded land sales at Ponto.
Generalized Benefits: The number of acres and the quality and usability of each of those acres, and the
number of new added beach parking for each of the known Option’s define each Option’s benefits.
There may be other unknown Options that have different benefits. The City’s 2001 PCH Modification
Studies’ highest Park and Open Space Option (2001 ERA Financial Analysis “Alternative 1-parks and open
space scheme”) only made possible a 4-acre Active Park north of Palomar Airport Road in North
Carlsbad. The City’s 2013 PCH Concept design eliminated that 4-acre Active Park and only showed a few
small open space areas with picnic tables. Any PCH Modification Benefits are limited by existing PCH
constraints. See attached Part 2: City PCH map with numbered notes on various existing land use
constraints from the City’s 2013 PCH Modification Design.
PCH Modification: PCH Modification does not add any new City land. Rearranging PCH land may add
some usability beyond the usability of existing parkway areas along PCH. However significant land in
PCH right-of-way is already constrained by habitat, slopes, and water quality detention basins. Past City
Studies in 2001 and 2013 showed relatively modest changes in useable acreage from major PCH
Modifications. Forever removing 2-travel lanes (over 50% of PCH capacity due to removing passing
ability) will create Terramar traffic congestion, but could repurpose that City pavement for open space.
Any net usable amount of open space land will however be relativity narrow and may be modest once
all constraints are accounted for. PCH Modification should be accurately compared with the existing
usable and open space parkway areas in the existing PCH configuration and Ponto Park situation. See
attached Part 2: City PCH map with numbered notes on various existing land use constraints from the
City’s 2013 PCH Modification Design.
General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park – part 1 Page 2 of 4
Comparative tax-payer Cost/Benefits:
1. Completing PCH & adding missing sidewalk/path and additional public parking and bike safety:
177 existing parking spaces along South Carlsbad Blvd
Existing 4 vehicle lanes and 2 bike lanes
The only missing component of “Complete/Livable Street” is a pedestrian sidewalk/path
Total Cost to provide missing sidewalks per City data = $3-5 million (based on path width)
Costs for desirable safety upgrade to existing bike lanes are not known
Cost to add more Beach parking in abandoned PCH North and South of Poinsettia ranges from:
273 additional spaces = $ 0.76 million
546 additional spaces = $ 1.1 million
Plus an estimated $1.5 million for 2 signalized intersection upgrades for full 4-way access
Cost per parking space is estimated at $19,275 to $13,899 per additional parking space
Total cost: $ 3.8 to 6.1 million to provide missing sidewalk/path and add more parking + unknown
amount for any desired upgrades to existing bike lanes
2. ‘2013 PCH Modification Proposal’ [AECOM 11/26/2013 Alternative Development Meeting]
Total Cost is $75 million per Mayor Matt Hall. PCH Modification would be most the expensive City
project so far. $75 million current cost appears consistent with 20-years of cost inflation of the basic
(unmitigated environmental and traffic) 2001 costs of $26.5 to 37.3 million (in 2001dollars) identified by
the City. The City’s 2001 Study indicated fully mitigated costs will be higher.
Total $75 million PCH Modification cost comes to:
$ 18.7 to 7.5 million per acre for narrow open space areas (from portions of city roadway)
$872,093 per additional parking space
86 additional parking spaces created = 263 replacement spaces - 177 existing spaces removed
Includes multi-use pathway (sidewalk) within primarily native/natural landscaping.
Possible 50% reduction in vehicle lanes (from 4 to 2 lanes) with corresponding traffic congestion like
at Terramar. Not clear if Citizens will approve spending $75 million to double traffic congestion.
Includes about 4 - 10 acres for possible narrow passive Park area identified in City’s 2001 PCH
Modification Studies. However City’s 2013 PCH Modification (AECOM) plans look like smaller
acreage is provided.
Does not purchase any new land (only reconfigures existing City land) so requires Carlsbad Citizens
to vote to expend funds per Proposition H.
2013 PCH Modification proposal did not consider and map City’s 2017 sea level rise data to show
what areas would be lost due to sea level rise and account for any added cost and issues.
3. Ponto Coastal Park
Total Cost: $20 – 22 million to purchase and build 11-acres as Mayor Matt Hall has publicly stated
$ 2 to 1.8 million per acre (per Mayor) for new and fully useable City Park area
175% to 10% more total park land than ‘PCH Modification options’
Includes adding 11-acres of new and viable parkland similar in shape (but larger in size) than
Carlsbad’s Holiday Park. Site includes both habitat and E-W and N-S connections.
General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park – part 1 Page 3 of 4
Since an Open Space land purchase per Proposition C acquisition voters exempted such purchases
from Proposition H. NCA recommend the site be considered for purchase as Open Space per the
City’s obligations under a lawsuit settlement.
Ponto Park’s cost savings over ‘PCH Modification’ = $55 to 53 million
Ponto Park’s + adding missing sidewalks cost savings over ‘PCH Modification’ = $51 to 47 million
Ponto Park’s + adding missing sidewalks + 273 additional parking spaces cost savings over “PCH
Modification’ = $50.4 to 46.1 million
Ponto Park’s + adding missing sidewalks + 546 additional parking spaces cost savings over “PCH
Modification’ = $50.1 to 45.8 million
4. Combining both #1-PCH Completion and #3-Ponto Park:
Combining #1 and #3 creates at cost effective and more beneficial Coastal Park-Coastal Parking-
Completes Streets solution. This solution actually adds 11-acres of new City land for a needed Park,
provides for a Complete PCH without increasing traffic congestion, does not forever congest PCH
travel if future PCH traffic increases, adds comparatively more beach parking, and provides the City
with Coastal land use and sea level rise planning flexibility to address future needs by not forever
committing the City’s PCH land to a Final solution. See map on page 4 showing land use synergy of
combining #1 and #3.
$50.4 to 45.8 million in tax-payer cost savings are estimated from combining #1 & #3 compared to
the estimated $75 million PCH Modification concept. Combining #1 and #3 provide all the
features provided by more Benefits for a reduced
a. Ponto Park’s location allows it to use the 337-610 parking spaces created by #1 above (177
existing + 273 to 546 new parking spaces). The 337-610 parking spaces will allow Ponto Park
to effectively host Carlsbad’s special community events.
b. Acquiring Ponto Park’s 11-acres provides both the City and State of CA with important
future land use options to address the Sea Level Rise and Coastal Erosion (SLR) planned by
the City. These options are created by leaving the exiting South Carlsbad Blvd right-of-way
substantially the same (except for adding needed sidewalks and using the existing Old paved
roadway for parking) thus allowing future upland relocation of the Campground. If
$75,000,000 is spent on #2 the likelihood this very expensive City expenditure would never
be abandoned by the City to allow relocation of the Campground.
c. Carlsbad’ 2017 Sea Level Rise study shows SLR will eliminate ½ of the State Campground – a
high-priority Coastal land use under the CA Coastal Act. The CA Coastal Act calls for
“upland” relocation of high-priority Coastal land uses due to SLR impacts. Ponto Park could
also provide for “upland” relocation of the State Campground.
Part 2 of this Comparative analysis is a separate 2-page data file. This Part 2 file consists of the City’s
PCH map with numbered notes to documented City data on PCH design constraints, mapping the City’s
2017 Sea Level Rise Impact Areas, and outlining the easterly 6.5 acre portion of the 11-acre Planning
Area F site that could be Ponto Park for acreage comparison purposes.
General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park – part 1 Page 4 of 4
Map 1: cast effectivefy using Old carfsbad 8Jvd pavement for beach, campground &
Ponto Pan parking -ll'ehide access at Breakwater Rd, Poinsettia Lane, and Ponto Drive
between the
C4!nters o f
parking and
Ponto Park
cent ral roadway
Linking inland Sout h
Cartsbad to ltte Coast • ... .___
Page 1 of 20
History of the false exemption of the Growth Management Open Space Standard provided Ponto
developers in Local Facility Management Plan Zone 9 (LFMP-9):
The history of how required Growth Management Open Space (i.e. unconstrained/developable land)
that should have been dedicated Open Space was, and is now being proposed to be, inappropriately
converted to Residential land use by a Perpetuating a False Exemption of the Open Space Standard
provided Ponto Developers. This False Exemption needs correction and restitution. Ponto’s False
Exemption of the Open Space Standard and the ‘amendment shell-game’ GM Open Space history is a
critical warning sign to the Carlsbad Tomorrow Growth Management Committee, Planning Commission
and City Council. Ponto is a critical warning that a strong, accountable and accurate Open Space
Standard needs to be established for Carlsbad Tomorrow, AND a Growth Management Open Space
restitution plan needs to be established and funded that corrects the False Exemption for Ponto
Developers. If Ponto Developers were required like other similar developers at the time (Aviara and
Poinsettia Shores, “urbanizing La Costa Zones 11 & 12, etc.) to provide the required Growth
Management Open Space some of the critical Coastal Recreation and Coastal Park issues and extensive
Carlsbad Citizen needs/demands/desires at Ponto could likely have already been addressed.
How citizens found out about the False Exemption provided Ponto Developers:
In 2017 for the 1st time the city provided the GIS maps/data base accounting of Open Space in the City.
The City did this a part of settlement to a North County Advocates citizens’ lawsuit. The City Open Space
maps/data base allowed Carlsbad Citizens for the 1st time the ability to see and confirm what Open
Space was produced by Growth Management (GM). The City’s Open Space map/data based for Ponto
(LFMP-9) documented that about 30-acres of GM Open Space was missing (see; Carlsbad Official Public
Records Request - PRR 2017-164). As required by GM, and as Staff has said, to count as GM Open Space
it must be dedicated and ‘unconstrained/developable land’ to meet the GM Open Space Standard.
Being able to see for the 1st time the missing GM Open Space was one of the key awakenings that
started People for Ponto Carlsbad Citizens. Below is the City’s Open Space Map for LFMP-9, with notes.
We have the City’s parcel-based Open Space data base that confirms all the numerical data in the notes.
Page 2 of 20
City GIS map of Ponto’s (LFMP Zone 9)
Open Space:
Light green areas meet the City’s 15%
unconstrained Growth Management
Program Open Space Standard
Most Ponto Open Space (pink hatch &
blue [water] on map) is “Constrained”
and does not meet the Standard
Aviara - Zone 19, Ponto - Zone 9 and
Hanover/Poinsettia Shores – Zone 22
all developed around the same time
and had similar vacant lands.
City required Aviara - Zone 19 east of
Ponto to provide the 15% Standard
Open Space. Why not Ponto? Aviara
had the same lagoon waters.
City required Hanover & Poinsettia
Shores area Zone 22 just north of
Ponto to provide the 15% Standard
Open Space. Why not Ponto?
Why Ponto developers were never
required to comply with the 15%
Standard Open Space is subject to
current litigation
Below is City GIS data from this map
City GIS map data summary of the 15% Growth Management Standard Open Space at Ponto
472 Acres Total land in LFMP Zone 9 [Ponto]
(197 Acres) Constrained land excluded from GMP Open Space
275 Acres Unconstrained land in LFMP Zone 9 [Ponto]
X 15% GMP Minimum Unconstrained Open Space requirement
41 Acres GMP Minimum Unconstrained Open Space required
(11 Acres) GMP Open Space provided & mapped per City GIS data
30 Acres Missing Unconstrained Open Space needed in LFMP Zone 9 [Ponto] to meet the City’s
minimum GMP Open Space Standard per City’s GIS map & data
73% of the City’s minimum 15% required Open Space Standard is missing due to over
development of LFMP Zone 9 [Ponto]
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Page 3 of 20
So were did the missing GM Open Space go?
In early 1985 prior to the Ponto’s developer (SAMMIS) annexing Ponto into the City of Carlsbad, San
Diego County’s LAFCO (local agency formation commission) General Planned and pre-zoned, Ponto’s
Batiquitos Lagoon waters and the lagoon bluff slopes as Open Space. This Open Space was “Constrained
Open Space” – State jurisdictional waters, and steep slopes with Coastal Sage Scrub (CSS) habitat. These
already pre-zoned constrained/non-developable Open Spaces were accounted for as part of the City’s
25% pre-Growth Management Plan Open Space, and per Growth Management can’t be counted in
meeting the 15% Growth Management Open Space Standard. The pre-zoned Open Space is shown in
the City’s Open Space map and properly marked as “Preservation of Natural Resources” Open Space
land. This already pre-zoned Constrained (non-developable, aka ‘Preservation of Natural Resources’)
Open Space land at Ponto was documented in the proposed SAMMIS Batiquitos Lagoon Educational
Park (BLEP) Master Plan MP-175 as Areas N, O, and P in the Land Use Summary below.
On Oct, 1 1985 Carlsbad approved SAMIS’s Master Plan and EIR to develop Ponto. SAMIS’s BLEP Master
Plan MP-175. Following are BLEP MP-175’s General Plan & Land Use Summary maps:
GENERAL PLAN
TS/C
TRAVEL SERVICE COMNERCIAL
22.6 AC
BATIOUITOS LAGOON EDUCATIONAL PARK
: SAMMIS PROPERTIES
EXHIBIT 1-C
Page 4 of 20
The BLEP MP-175 did include a variety of GM compliant Open Space.
12.8 acre Recreation Commercial land use that was playfields and Coastal Recreation site for
MP-175 and South Carlsbad. This is a Critical GM Open Space that was never dedicated.
A minimum 30’ wide landscaped Open Space on both sides of Windrose Circle that circled the
Area P. Windrose Circle was bordered on each side by 30’ of landscaped Open Space.
Additional minimum 30’ wide landscaped setbacks between buildings in Area A
2.8 acres of private recreation open space for the maximum amount of residential units
45’ to 50’ landscaped setbacks from the Batiquitos Lagoon Bluff edge (this was later developed
with Residential land use in some areas of Ponto).
75’ landscaped separation between Areas C and D
70’ landscaped separation between Areas D and E
25’ landscaped setback along Avenida Encinas for Area E
30’ to 80’ landscape setback between Lakeshore Gardens and Area F
25’ landscaped setback along Avenida Encinas for Area F
50’ landscaped setback between Areas F and I
75’ landscaped separation between Areas G and H
50’ to 80’ landscape setback for Area I between Lakeshore Gardens and between Area F
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CONCEPTUAL LAND USE PLAN
CONCEPTUAL
LANO USE SUMMARY ~-.i:~
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EXHISIT 111-B
Page 5 of 20
So, prior to Ponto being annexed into the City of Carlsbad in the mid-1980’s and prior to Growth
Management the Batiquitos Lagoon and lagoons bluff slopes (constrained and unusable due to habitat
and slope constraints) were already pre-zoned Open Space and General Planned as Constrained Habitat
Open Space. This constrained Open Space did not and cannot meet the 15% GM Open Space Standard.
In 1986 Citizens voted for the City’s version of Growth Management that included at New Standard for
Useable Open Space. The new standard was that 15% of all unconstrained useable/developable land
within a Local Facility Management Zone was to be dedicated as Open Space. Once the vote was in the
City adopted the Growth Management Ordinance 21.90 of Carlsbad’s Municipal Code (City Council
Ordinance No. 9791. (Ord. 9829 § 1, 1987; Ord. 9808 § 1, 1986)).
In adopting the Growth Management Ordinance 21.90.010 the Council Clearly stated:
(b) The city council of the city has determined despite previous city council actions, including
but not limited to, amendments to the land use, housing, and parks and recreation elements of
the general plan, amendments to city council Policy No. 17, adoption of traffic impact fees, and
modification of park dedication and improvement requirements, that the demand for facilities
and improvements has outpaced the supply resulting in shortages in public facilities and
improvements, including, but not limited to, streets, parks, open space, schools, libraries,
drainage facilities and general governmental facilities. The city council has further determined
that these shortages are detrimental to the public health, safety and welfare of the citizens of
Carlsbad.
(c) This chapter is adopted to ensure the implementation of the policies stated in subsection
(a), to eliminate the shortages identified in subsection (b), to ensure that no development
occurs without providing for adequate facilities and improvements, …”
The Citizens and Council recognized that prior City plans were not adequate to address the current (and
future) needs for facilities. Upon adoption of the New Growth Management Standards certain facilities
were already below-Standard simply based on the existing development and population. Growth
Management required additional facilities simply to bring the then current development/population up
to the New Minimum Standards. I am personally familiar with 3 GM Standards in LFMP-6 (old La Costa)
that I worked on – Library, Fire, and Park where already below-Standard i.e. existing
development/population in Old La Costa required more facilities to meet the new Growth Management
Standards. We worked to provide these new facilities for the existing development/population (i.e. fix
the Standard deficits) and then to also plan even more additional facilities at a ratio that met the New
Standards for the additional future development in Old La Costa. I can provide you some interesting
stories on that.
I also recall working on the surrounding La Costa LRMP Zones 11 & 12 that Like Ponto/FMP-9 were
considered “Cat II: Urbanizing” yet Unlike Ponto/LFMP-9 LFMP Zone 11 & 12 were not falsely exempted
Page 6 of 20
for the GMP Open Space Standard and had to provide the GM Open Space Standard of 15% of the
unconstrained/developable lands as dedicated Useable Open Space.
The Citizens vote on Proposition E and the subsequent Growth Management Ordinance 21.90 are the
rules on which the Growth Management Plans (both Citywide and 25 Local Facility Plans) are required to
follow.
To create the Citywide and the Local plans (Zones 1-6) for the largely developed areas the City needed
to temporarily pause development activity to allow time for city staff to Draft the Growth Management
Plan (my work as a city planner at the time was re-directed to draft growth management plans). So the
Growth Management Ordinance 21.90.030, established a Temporary Development Moratorium to
pause development processing activity while the Growth Management Plan was being Drafted.
Following is that language of 21.90.030. Notes are shown as italicized text within [example]:
“21.90.030 General prohibition—Exceptions.
(a) Unless exempted by the provisions of this chapter, no application for any building
permit or development permit shall be accepted, processed or approved until a city-wide
facilities and improvements plan has been adopted and a local facilities management plan for
the applicable local facilities management zone has been submitted and approved according
to this chapter. [Clearly indicates the exemptions in 21.90.030 are only from the temporary
development moratorium created by 21.90.]
(b) No zone change, general plan amendment, master plan amendment or specific plan
amendment which would increase the residential density or development intensity established
by the general plan in effect on the effective date of this chapter shall be approved unless an
amendment to the citywide facilities management plan and the applicable local facilities
management plan has first been approved. [FYI, this provision of 21.90.030 has direct
implications with respect of currently City/developer proposed General Plan/Zoning
code/Local Coastal Program Amendments now being pursued by the City at Ponto Planning
Area F and Ponto Site 18. The City did not and has not yet amended the CFMP and LFMP-9 to
increase the City/developer proposed residential density or development intensity at Ponto]
(c) The classes of projects or permits listed in this subsection shall be exempt from the
provisions of subsection (a). Development permits and building permits for these projects
shall be subject to any fees established pursuant to the city-wide facilities and improvement
plan and any applicable local facilities management plan. [Then lists various exemptions from
the temporary development processing/building permit moratorium in 21.90. The BLEP MP’s
exemption from the temporary moratorium is (g)]
(g) The city council may authorize the processing of and decision making on building
permits and development permits for a project with a master plan approved before July 20,
1986, subject to the following restrictions [this only applies to the “approved before July 20,
1986” BLEP MP, and NOT to any subsequent Master Plan Amendment]:
Page 7 of 20
(1) The city council finds that the facilities and improvements required by the master plan
are sufficient to meet the needs created by the project and that the master plan developer
has agreed to install those facilities and improvements to the satisfaction of the city council.
[The Ponto developer needed to provide the 12.8 acre Recreation Commercial land use and
install the GM compliant Open Space required in the 1986 MP175 but did not]
(2) The master plan developer shall agree in writing that all facilities and improvement
requirements, including, but not limited to, the payment of fees established by the city-wide
facilities and management plan and the applicable local facilities management plan shall be
applicable to development within the master plan area and that the master plan developer
shall comply with those plans. [this required the LFMP-9/BLEP MP to have 1) already been
fully developed or 2) have already have dedicated 15% of the LFMP-9 as Growth Management
compliant Open Space (i.e. Unconstrained and developable) to qualify for the Open Space
exemption later falsely noted in the city-wide facilities and management plan. As clearly
documented the BLEP MP did not meet the requirements to qualify for Open Space Standard
Exemption in the city-wide facilities and management plan. The section also requires “all
facilities” (including Open Space) requirements in the Citywide Growth Management Standard
to apply to BLEP MP, not provide a means for a false exemption of the Open Space Standard]
(3) The master plan establishes an educational park and all uses within the park comprise
an integral part of the educational facility. [“all uses” including the 12.8 acre Recreation
Commercial land use and all the other GM compliant Open Spaces are an integral part.
However the 12.8 acre open space land use was never built and the BLEP MP GM compliant
Open Space never dedicated.]
(4) Building permits for the one hundred twenty-nine [129] unit residential portion of
Phase I of the project may be approved provided the applicant has provided written evidence
that an educational entity will occupy Phase I of the project which the city council finds is
satisfactory and consistent with the goals and intent of the approved master plan. [Clearly
indicates the 21.90.030 exemption is only for building permits for Phase I of the BLEP MP. Of the
129 units only the 75 unit Rosalena development applied for and received building permits under
this exemption. There are some very interesting issues related to this Rosalena Phase I
development relative to GM complaint Open Space along the bluff edge that can be expanded on
later if the CTGMC has questions.]
(5) Prior to the approval of the final map for Phase I the master plan developer shall have
agreed to participate in the restoration of a significant lagoon and wetland resource area and
made any dedications of property necessary to accomplish the restoration. [Again clearly notes
the exemption only allows a final map for Phase I to be processed. The “lagoon and wetland
resource area” are part of the same constrained/undevelopable lands already pre-zoned prior
to the BLEP MP being incorporated into the City of Carlsbad]”
Page 8 of 20
The Aviara Master Plan (directly adjacent and east of Ponto) and was also being developed at the same
time as Ponto/BLEP MP. 21.90.030 also provided the Aviara Master Plan a similar exemption (h) and
similar lagoon related quid-pro-quo for that exemption. But Aviara did not receive a GM Open Space
Standard Exemption. :
“(iv) Prior to any processing on the [Aviara] master plan the applicant shall grant an easement
over the property necessary for the lagoon restoration and the right-of-way necessary for the
widening of La Costa Avenue and its intersection with El Camino Real. (Ord. NS-63 § 1, 1989;
Ord. 9837 § 1, 1987; Ord. 9808 § 1, 1986)”
Some City staff have incorrectly stated to the City Council that they believe 21.90.030 exempts
Ponto/LFMP-9 from the Growth Management Ordinance/Program or Growth Management Open Space
Standard. RESOLUTION NO. 8666- A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD,
CALIFORNIA APPROVING TWO AGREEMENTS FOR BATIQUITOS LAGOON EDUCATIONAL PARK also shows
the 21.90.030 exemption was only for development permits during the temporary building moratorium.
In 1986 the City falsely exempted in the Citywide Facilities Plan all Ponto developers from providing 15%
of their useable/developable land as GM required Open Space. The City’s documented/adopted rational
in the Citywide Plan was that Ponto/LFMP-9 was 1) in 1986 already developed, or 2) in 1986 the
developer had already met the GM Open Space Standard by having already dedicated 15% of the
useable land as Open Space. Both situations were/are false. Any air photo map or even the 1986 LFMP-
9 clearly states Ponto was NOT developed in 1986, as only the Lakeshore Gardens existed and the
Ralphs Center was just starting construction. Also the City’s GIS Open Space mapping (see above) shows
that SAMMIS the Ponto developer (BLEP Master Plan MP-175) in 1986 had Not dedicated as Open Space
15% of the useable land as Growth Management compliant Open Space as shown/described in the BLEP
MP (i.e. the 12.8 Acre Recreation Commercial site and all the landscaped open space setbacks required
in the BLEP MP-175. If that 15% was dedicated in 1986 it would show-up on the City’s inventory of
Dedicated Open Space now. So how did this occur?
How Ponto’s planned GM Open Space was eliminated and replaced with Residential land use:
In late 1980’s SAMMIS the BLEP MP-175 developer started building the 75-home Rosalena Development
as the first part of Phase I of the BLEP MP. The City (based on my recollection was very desirous to
develop the BLEP MP) and required special time limits on the BLEP MP to actually advance building the
‘Educational Park’ with all the “initiated” land uses (including GM compliant Open Space) within a
certain period of time. SAMIS was having financial issues and difficulty delivering the BLEP MP land
uses. Amendments (A, B, and C) to BLEP MP reflected on these difficulties:
MP 175(A) to allow minor accessory structures within the rear yards of all Phase I single family
lots located in Planning Area “C”. [This is the Rosalena development that was part of Phase I for
BLEP MP. This amendment has implications on the landscaped Open Space setback along the
Batiquitos Lagoon bluff top, and the required Coastal access trail required by the Coastal
Page 9 of 20
Development Permit for Rosalena. This is an interesting history that can be explained later if the
CTGMC would like.]
MP 175(B) to realign Carlsbad Blvd., between North Batiquitos Lagoon and west of I-5 to
accommodate the Sammis Development was WITHDRAWN January 12, 1990, and
MP 175(C) a request for 5-year extension of time for Master Plan approval related to
educational uses on this project was Approved Planning Commission Resolution No. 2841, April
19, 1989 and approved City Council Ordinance No. NS-83, September 5, 1990.
SAMMIS went bankrupt around 1990 and Kaiza Development purchased the BLEP MP. Kaiza completed
the Rosalena development started by SAMMIS. Kaiza then sought to completely change the planned
land uses on all the remaining unconstrained/developable land in the BLEP MP.
General Plan and Master Plan Amendments eliminated/reduced BLEP’s Growth Management compliant
Open Space and replace with Residential uses in the “amended” Poinsettia Shores Master Plan:
When Kaiza acquired the BLEP MP-175 and its vacant land only the State Campground, Lakeshore
Gardens, Ralphs Center, and now Rosalena were approved/existing developments at Ponto. Kaiza
proposed a Master Plan Amendment to delete the BLEP MP-175 and all its developable land uses,
except for the only portion of Phase I developed – the 75 unit Rosalena subdivision. The pre-BLEP MP
pre-zoned (and General Planned) constrained/undevelopable Lagoon waters and lagoon bluff Open
Spaces and the CA Coastal Act (LCP) required bluff top setbacks were the only Open Spaces retained in
Kaiza’s proposed General Plan land use and Master Plan Amendments.
Most all of the BLEP MP-175 (and Ponto/LFMP-9) land area was still undeveloped at the time Kaiza
proposed changing all the General Plan land uses at Ponto and eliminating the usable Open Space in
BLEP MP.
Kaiza’s General Plan land use and Master Plan ‘Amendments’ made radical land use changes that
converted some critical Useable GM Open Space to residential land use and also reduced some GM
Open Space provided in BLEP MP. Following is Kaiza’s Amended General Plan land use map and bullet
summary of the major Open Space changes without getting into a very detailed forensic analysis:
Eliminated the 12.8 acre Recreation Commercial land use.
Eliminated the minimum 30’ wide landscaped Open Space on both sides of Windrose Circle for
the large unbuilt portions of Windrose Circle
Reduced by 10’ the landscaped Open Space on the smaller built portion of Windrose Circle
Eliminated on 40.3 acres the additional minimum 30’ wide landscaped setbacks between
buildings
Reduced BLEP’s 2.8 acres of private recreation open space to 2.3 acres
Except for the Rosalena (BLEP Area C) and (PSMP Area J), maintained the 45’ to 50’ landscaped
setbacks from the Batiquitos Lagoon Bluff edge
Eliminated the 75’ landscaped separation between BLEP MP Areas C and D
Page 10 of 20
Eliminated the 70’ landscaped separation between BLEP MP Areas D and E
Maintained the 25’ landscaped setback along Avenida Encinas. [However new Master Plan
Amendments MP-175L propose reducing the setback to 10’ on the undeveloped frontage of
Avenida between PCH and the railroad tracks]
Placed a road in most of the 80’ landscape setback between Lakeshore Gardens
Eliminated the 50’ landscaped setback between BLEP MP Areas F and I
Eliminated the 75’ landscaped separation between BLEP MP Areas G and H
Added a 20’ wide by 1,000’ long landscaped strip for an HOA trail
Kaiza’s Master Plan Amendment MP 175 (D) eliminated the 12.8 acre Open Space land use (with an
associated General Plan Amendment to add more residential land use) and reduced the other useable
Open Spaces required in the BLEP MP. When the 1994 Kaiza MP 175 (D) General Plan Amendments
were proposed, it seemed they voided the ‘1986 GM Open Space exemption’ that was clearly specific
only to the 1986 BLEP MP land uses and regulation. Although this was a false exempted, the exemption
only applied to the complete/integrated land use and open space provided in the 1986 BLEP MP. The
1986 exemption specific to BLEP MP could not apply to a different and later 1994 General Plan land use
plan that eliminated the 12.8 acre Recreation Commercial (Open Space) site to add residential land use
Al'PROA.
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 20
and that also reduced the GM compliant Open Space provided in the 1986 BLEP MP. 21.90.030(b) notes
that:
“(b) No zone change, general plan amendment, master plan amendment or specific plan
amendment which would increase the residential density or development intensity established by
the general plan in effect on the effective date of this chapter shall be approved unless an
amendment to the citywide facilities management plan and the applicable local facilities
management plan has first been approved.”
The 1994 Kaiza General Plan land use and Master Plan (MP 175(D)) Amendments removed 12.8 acres of
Recreation Commercial (GM compliant Open Space) to add residential land use. This violated
21.90.030(b) by doing so without a first providing a Citywide Facilities Plan Amendment that analyzed
the actual amount of GM compliant Open Space being proposed in the 1994 Kaiza MP 175(D) relative to
the 1986 BLEP MP on which the 1986 GM Open Space exemption for LFMP-9 was based. MP 175(D) is
noted in the MP as follows:
“MP 175 (D) Kaiza Poinsettia Master Plan To replace educational uses with residential land uses
And rename to Poinsettia Shores Master Plan (was) Approved Planning Commission Resolution
No. 3552, November 3, 1993, Approved City Council Ordinance No. NS-266, January 18, 1994.”
Kaiza’s MP 175(D) inaccurately and bizarrely claimed BLEP MP’s prior false exemption from the GM
Open Space Standard as the justification that Kaiza’s new 1994 Open Space land use changes that seem
to reduce the amount of GM complaint Open Space in the 1986 BLEP MP are also exempt from the GM
Open Space Standard. Kaiza’s MP 175(D) claims the pre-Growth Management and pre-BLEP MP
Constrained/Undevelopable lagoon waters and bluff habitat that per the 15% Growth Management
Open Space Standard CAN NOT be counted as meeting the 15% GM Open Space Standard can be
magically counted as meeting the 15% GM Open Space Standard. The GM Open Space Standard
specifically states that only Unconstrained/Developable lands CAN BE counted as meeting the GM
Open Space Standard. The stated principles of Growth Management, the Growth Management
Ordnance 21.90 and the Growth Management Open Space Standard DO NOT allow a developer or the
City to count already documented Constrained and unbuildable habitat (and water) as Unconstrained
and developable land. You can’t just turn ‘an apple into a banana by saying it’, or turn
‘Constrained/Undevelopable land into Unconstrained/Developable land by just saying it.
Compliance with the law in this Open Space issue is a part of a current lawsuit by North County
Advocates a group of Citizens watchdogs. The City has unsuccessfully tried to diminish this lawsuit. A
judge/jury will determine the outcome.
Additional MP 175 Amendments have been proposed by and approved to further modify land use and
regulatory limitations at Ponto. These include:
MP 175(E) Poinsettia Shores Master Plan, Redefinition of minor amendment to provide a
flexible regulatory procedure to encourage creative and imaginative planning of coordinated
communities, WITHDRAWN November 1, 1994
Page 12 of 20
MP 175(F) Poinsettia Shores Master Plan minor amendment to actualize off-site option for
provision of 90 affordable housing dwelling units, Approved Planning Commission Resolution
No. 3774, April 19, 1995
MP 175(G) Poinsettia Shores Master Plan minor amendment to adopt Coastal Commission
Suggested modifications, Approved Planning Commission Resolution No. 3922, June 5, 1996
Approved City Council July 16, 1996, NS-367
MP 175(H) Poinsettia Shores Master Plan - major amendment FOR HOTEL AND TIMESHARE
USES, WITHDRAWN January 16, 2003
MP 175(I) Poinsettia Shores Master Plan – Rosalena Trail Amendment, WITHDRAWN January
8, 2002
MP 175(J) Poinsettia Shores Master Plan – major amendment for Carlsbad Coast Residential
project to allow RM land use on Poinsettia Shores, WITHDRAWN January 8, 2002
MP 175 (K) Poinsettia Shores Master Plan – Ponto Area Specific Plan Mixed use consisting of
residential, commercial and retail uses, WITHDRAWN August 19, 2004
MP 175(L) Poinsettia Shores Master Plan – Major amendment for commercial and residential
development on Planning Area F, Still being proposed by developers and being processed by
the City.
The false exemption for the BLEP MP based LFMP-9 should never have occurred. However,
completely eliminating BLEP MP’s OpenSpace land use (12.8 acre Recreation Commercial) and
reducing BLEP MP’s required Open Space while at the same time claiming the false BLEP MP Open
Space Exemption is a violation of common sense, 21.90, and the very founding principles Growth
Management.
The CA Coastal Commission in MP 175 (G) in part recognized the elimination of the 12.8 acre Recreation
Commercial land use and maybe some of the Open Space land use changes and added the following
land use regulations for 11.1 acre Planning Area F in the Carlsbad’s Local Coastal Program LCP). The LCP
as per State Law and referenced in Carlsbad’s General Plan is the controlling land use regulation over the
General Plan, Poinsettia Shores Master Plan and in the Coastal Zone:
“PLANNING AREA F: Planning Area F is located at the far northwest corner of the Master Plan
area west of the AT&SF Railway right-of-way. This Planning Area has a gross area of 11 acres and
a net developable area of 10.7 acres. 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 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.
The intent of the NRR designation is not to limit the range of potential future uses entirely to
nonresidential, however, since the City's current general plan does not contain an “unplanned”
designation, NRR was determined to be appropriate at this time. In the future, if the Local
Coastal Program Amendment has not been processed, and the City develops an “unplanned”
Page 13 of 20
General Plan designation, then this site would likely be redesignated as “unplanned.” Future
uses could include, but are not limited to: commercial, residential, office, and other uses,
subject to future review and approval.
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.”
In 2010 the CA Coastal Commission in 2010 rejected the Ponto Beachfront Village Vision Plan on which
MP 175(K) was based. MP 175(K) was withdrawn.
On July 3, 2017 the CA Coastal Commission provided direction to the City of Carlsbad regarding MP
175(G), Carlsbad’s 2015 General Plan Update, Carlsbad proposed Local Coastal Program Amendment
Land Use Plan (LUP) . CA Coastal Commission wrote to the City the following. Notes on the context of
communication are in bracketed italics [example]:
“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. [the discussion of the need for the City to conduct a citywide analysis of the location and
amount of these uses in the Coastal Zone to assure the City General Plan within the Coastal Zone
is providing the adequate amounts and locations of these land uses to fulfill the long-term
population/visitor needs for these uses according to the CA Coastal Act] 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 the City conducted the first Sea Level Rise (SLR) Vulnerability Assessment
https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=33958 . That first initial analysis,
shows significant SLR impacts that will reduce existing Ponto Open Space - the State beach and
Campground and along the Batiquitos Lagoon. The City identified SLR impacts on Ponto Open Space are
summarized in the next section of this history.
In 2023 the CA Coastal Commission will consider the data and public input and decide the appropriate
land use for 11.1 acre Planning Area F based the CA Coastal Act and Coastal Act land use policies.
You can determine the Open Space and Park Quality of Life Standards that will be applied to this and
other future land uses.
City assessment of Sea Level Rise impacts on reducing Ponto Open Space
Page 14 of 20
The City’s 2017 SLR assessment shows SLR will significantly reduce or eliminate only existing Open Space
land at Ponto. The City’s assessment quantifies the speratic/episodic loss of Ponto/Coastal South
Carlsbad Open Space land and land uses being at the State Campground, Beaches, and Batiquitos
Lagoon shoreline – about 32 acres by the year 2100, this would be an average loss of 17,000 square feet
of Open Space per year. Following (within quotation marks) is a description, quantification and images
of the City’s projected loss of Ponto/Coastal South Carlsbad Open Space land and land use due to SLR.
[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
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
Page 15 of 20
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)
Page 16 of 20
Environmentally 2050 Inundation, Flooding 572 acres Moderate
Sensitive 2100 Inundation, Flooding 606 acres High
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Page 17 of 20
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Figure 5: CoSMoS Bluff Erosion Projections by 2100
(CoSMoS-COPST 2015)
Page 18 of 20
[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.]”
This 2017 SLR data and quantified losses of Ponto/Coastal South Carlsbad Open Space land and land
uses was not considered in the City’s rejected (by CCC) Ponto Beachfront Village Vision Plan. The Ponto
Vision Plan is the basis for the City’s 2015 General Plan Update that is now being proposed in the City’s
Local Coastal Program Amendment now before the CA Coastal Commission.
Summary:
LFPM-9 was clearly not developed in 1986, and did not then or now dedicate 15% of the
unconstrained/developable land as Open Space as required by the Growth Management Open Space
Standard. These two reasons for the City to “exempt” LFMP-9 from Open Space Standard were/are
False. Saying Constrained/undevelopable land can be counted as Unconstrained/developable land is also
false and clearly not allowed according to the Growth Management Ordinance, Standards, principles,
and common-sense honesty to Carlsbad Citizens. LFMP-9, as the City’s own maps/data base show is
clearly missing 30-acres of GM Open Space. In addition in 2017 we learned that Ponto/Coastal South
Carlsbad will lose about 32 acres of existing Open Space due to SLF.
Closing thoughts:
Growth Management is based on the type/amount/location of General Plan land use designations, the
development potential of those land use designations in creating the demand for the
type/amount/location of facilities, and supply of the type/amount/distribution of facilities – like Open
Space and Parks. If the type/amount/location of supply of facilities does not meet the demand for those
facilities then growth management fails and Quality of Life is reduced.
Quality of Life Standards are used to assure supply and demand for facilities is properly balanced with
respect to type/amount/location.
Ponto is clearly unbalanced. The Ponto Census Track is at a 40% higher population density than the rest
of Carlsbad, yet is Ponto is NOT meeting the Open Space Standard and has NO Park (see City Open Space
maps and Park Master Plan). Ponto and all South Carlsbad have higher population demand for Parks
and Open Space facilities yet Ponto (that is the only place to provide Coastal Park and Open Space needs
for South Carlsbad) has lower or none of those two most critical GM Facilities needed to balance and
mitigate the 40% higher population density at Ponto and also the higher residential density in South
Carlsbad.
Ponto and Coastal South Carlsbad also have additional State and regional responsibilities to provide
Coastal Recreation and Open Space for populations of people and visitors from outside of Ponto and
Carlsbad.
Page 19 of 20
This failure to honestly and adequately balance the type/amount/location higher population density by
providing higher levels of Parks and Open Space in those areas will lead to a slow and but eventual
reduction of the Quality of Life for those areas.
Common sense and the Carlsbad’s Growth Management law say if you change the land use (like what
was done and is still being proposed at Ponto) you change the type/amount/location of potential
development and population and the Growth Management impacts. Land use changes require and
honest/accurate/balanced update to Citywide and Local Growth Management Plans to accurately reflect
those changes and provide an updated plan to provide facilities that meet the Standards for those land
use changes. This is the fundamental heart of any Growth Management.
The Carlsbad Tomorrow Growth Management Committee, and City Commissions and Council are all
now facing the same issues and responsibility that we faced in the 1980’s at the beginning of Growth
Management. We established New Quality of Life Standards – for Open Space and Parks – that required
New investments in Parks and Open Space by both the City and developers.
Open Space and Parks have always been identified as most critical for Carlsbad’s quality of life. The
Carlsbad Tomorrow Growth Management Committee, and City Commissions and Council, and Carlsbad
Citizens are all at a critical crossroad.
Do we, or don’t we, enforce and set new standards that achieve the quality of life we desire?
Do we or don’t we, fix existing past errors and below desired standard situations?
Do we or don’t we, roll-up our sleeves a work together to a better Quality of Life?
As a long-time Carlsbad Citizen I am extremely disappointed by some who say we can’t fulfill our
Community Vision, we can’t fix things, can’t make things better, and can’t add more Parks and Useable
Open Space. This can’t attitude is not out Community Vision. We can and we did before, and we can do
it again and better.
Great cities for hundreds of years have Upgraded their Quality of Life Facility Standards, made and
implemented/funded facilities to fix things up to those Standards. A City is just like a business or person
- If you don’t improve you decline. Examples of Upgrading and funding to New Parks and Open Space
are many but include – Carlsbad’s Buena Vista Reservoir Park, additions to Pine Park, Village H Park, and
Aura Circle Open Space acquisition; and SDSU’s major new Park at the redeveloped Qualcomm Stadium
site.
Now like at the beginning of Carlsbad Growth Management the City can “despite previous city council
actions” make improvements to its Growth Management and Quality of Life Standards to address past
and future needs. Following illustrates existing R-23 (up to 23 dwellings per acre) development in
Carlsbad – most of our future residential development will be required to be like this or more dense.
Page 20 of 20
High-density housing can be great, but it requires MORE Parks and MORE useable Open Space within
walking distance to balance the density and provide large places for families and kids to really play. In
Carlsbad’s high-density residential future with no backyards and stacked flat multi-family homes the
need for both more Parks and Useable Open Space is much greater than in 1980’s.
The time to fix the Parks and Useable Open Space problems at Ponto (LFMP-9) is now. Already Ponto is
developed at a density that is 40% great than the rest of Carlsbad. New proposed and even higher-
density developments (developer driven Amendments) propose to make Ponto even more dense, yet
there are not Parks at Ponto and Ponto is missing 30-acres of Useable Open Space past developers
should have provided.
A doable, time-tested, accountable, tax-payer saving, strongly citizen desired, accountable, and honest
way to fix this was presented to you in 8/8/22 and 12/27/22 emails with attached “CTGMP Key Issues
and Suggestions – 2022-12-6”. Over 5,000 petitions expressing the need to fix the Park and Open Space
problems at Ponto have been sent to the City and the City should have provided these to you in
considering Park and Open Space issues.
Ponto Park and Open Space needs your help fixing NOW. If not Carlsbad Tomorrow will be less than it is
today, and tragically will have failed our Community Vision.
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 1 of 7
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto
Introduction:
Carlsbad first documented Sea Level Rise (SLR) and associated increases in coastal erosion in a
December 2017 Sea Level Rise Vulnerability Assessment (2017 SLR Assessment). Prior planning activities
(2010 Ponto Vision Plan – rejected by CA Coastal Commission, and 2015 General Plan Update) did not
consider SLR and how SLR would impact Coastal Open Space Land Use & CA Coastal Act ‘High-Priority’
Coastal Open Space Land Uses at Ponto. The 2017 SLR Assessment shows Open Space land and Open
Space Land Uses are almost exclusively impacted by SLR at Ponto & South Coastal Carlsbad. The 2017
SLF Assessment also shows significant LOSS of Open Space land acreage and Land Uses. Most all
impacted Open Space Land Uses are CA Coastal Act “High-Priority Coastal Land Uses” – Coastal
Recreation (i.e. Public Park) and Low-Cost Visitor Accommodations. Existing Ponto Open Space Land
Uses are already very congested (non-existent/narrow beach) and have very high, almost exclusionary,
occupancy rates (Campground) due to existing population/visitor demands. Future population/visitor
increases will make this demand situation worst. The significant permanent LOSS of existing Coastal
Open Space land and Coastal Open Space Land Use (and land) due to SLR reduces existing supply and
compounds Open Space congestion elsewhere. Prior Ponto planning did not consider, nor plan, for
significant SLR and current/future “High-Priority” Coastal Open Space Land Use demands.
Open Space and City Park demand at Ponto:
Open Space at Ponto is primarily ‘Constrained’ as defined by the City’s Growth Management Program
(GMP), and cannot be counted in meeting the City’s minimal 15% ‘Unconstrained’ GMP Open Space
Standard. Per the GMP Open Space Standard, the developers of Ponto should have provided in their
developments at least 30-acres of additional ‘Unconstrained’ GMP Open Space at Ponto. City GIS
mapping data confirm 30-acres of GMP Standard Open Space is missing at Ponto (Local Facilities
Management Plan Zone 9).
The City of Carlsbad GIS Map on page 2 shows locations of Open Spaces at Ponto. This map and its
corresponding tax parcel-based data file document Ponto’s non-compliance with the GMP Open Space
Standard. A summary of that City GIS data file is also on page 2. The City said Ponto’s non-compliance
with the GMP Open Space Standard was ‘justified’ by the City ‘exempting’ compliance with the
Standard. The City ‘justified’ this ‘exemption’ for reasons that do not appear correct based on the City’s
GIS map and data on page 2, and by a review of 1986 aerial photography that shows most of Ponto as
vacant land. The City in the Citywide Facilities Improvement Plan (CFIP) said 1) Ponto was already
developed in 1986, or 2) Ponto in 1986 already provided 15% of the ‘Unconstrained’ land as GMP
Standard Open Space. Both these ‘justifications’ for Ponto ‘exemption’ in the CFIP were not correct.
The legality of the City ‘exempting’ Ponto developers from the GMP Open Space Standard is subject to
current litigation.
The City proposes to continue to exempt future Ponto developers from providing the missing 30-acres of
minimally required GMP Open Space, even though a change in Ponto Planning Area F land use from the
current ‘Non-Residential Reserve” Land Use requires comprehensive Amendment of the Local Facilitates
Management Plan Zone 9 to account for a land use change. City exemption is subject of litigation.
Ponto (west of I-5 and South of Poinsettia Lane) currently has 1,025 homes that per Carlsbad’s minimal
Park Standard demand an 8-acre City Park. There is no City Park at Ponto. Coastal Southwest Carlsbad
has an over 6.5 acre Park deficit that is being met 6-miles away in NW Carlsbad. Ponto is in the middle
of 6-miles of Coastline without a City Coastal Park west of the rail corridor.
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 2 of 7
City GIS map of Ponto’s (LFMP Zone 9)
Open Space:
Light green areas meet the City’s 15%
unconstrained Growth Management
Program Open Space Standard
Most Ponto Open Space (pink hatch &
blue [water] on map) is “Constrained”
and does not meet the Standard
Aviara - Zone 19, Ponto - Zone 9 and
Hanover/Poinsettia Shores – Zone 22
all developed around the same time
and had similar vacant lands.
City required Aviara - Zone 19 east of
Ponto to provide the 15% Standard
Open Space. Why not Ponto? Aviara
had the same lagoon waters.
City required Hanover & Poinsettia
Shores area Zone 22 just north of
Ponto to provide the 15% Standard
Open Space. Why not Ponto?
Why Ponto developers were never
required to comply with the 15%
Standard Open Space is subject to
current litigation
Below is City GIS data from this map
City GIS map data summary of the 15% Growth Management Standard Open Space at Ponto
472 Acres Total land in LFMP Zone 9 [Ponto]
(197 Acres) Constrained land excluded from GMP Open Space
275 Acres Unconstrained land in LFMP Zone 9 [Ponto]
X 15% GMP Minimum Unconstrained Open Space requirement
41 Acres GMP Minimum Unconstrained Open Space required
(11 Acres) GMP Open Space provided & mapped per City GIS data
30 Acres Missing Unconstrained Open Space needed in LFMP Zone 9 [Ponto] to meet the City’s
minimum GMP Open Space Standard per City’s GIS map & data
73% of the City’s minimum 15% required Open Space Standard is missing due to over
development of LFMP Zone 9 [Ponto]
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Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 3 of 7
Sea Level Rise impacts on Open Space and Open Space Land Use Planning at Ponto:
The City’s 2015 General Plan Update did not factor in the impacts of Sea Level Rise (SLR) on Ponto’s
Open Space land. In December 2017 the City conducted the first Sea Level Rise Vulnerability
Assessment https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?BlobID=33958. The 2017 SLR
Assessment is an initial baseline analysis, but it shows significant SLR impacts on Ponto Open Space.
More follow-up analysis is being conducted to incorporate newer knowledge on SLR projections and
coastal land erosion accelerated by SLR. Follow-up analysis may likely show SLR impacts occurring
sooner and more extreme.
Troublingly the 2017 SLR Assessment shows SLR actually significantly reducing or eliminating Open
Space land at Ponto. SLR is projected to only impact and eliminate Open Space lands and Open Space
Land Use at Ponto. The loss of Ponto Open Space land and Land Use being at the State Campground,
Beaches, and Batiquitos Lagoon shoreline. The losses of these Open Space lands and land uses would
progress over time, and be a permanent loss. The 2017 SLR Assessment provides two time frames near-
term 2050 that match with the Carlsbad General Plan, and the longer-term ‘the next General Plan
Update’ time frame of 2100. One can think of these timeframes as the lifetimes of our children and
their children (2050), and the lifetimes of our Grandchildren and their children (2100). SLR impact on
Coastal Land Use and Coastal Land Use planning is a perpetual (permanent) impact that carries over
from one Local Coastal Program (LCP) and City General Plan (GP) to the next Updated LCP and GP.
Following (within quotation marks) are excerpts from Carlsbad’s 2017 Sea Level Rise Vulnerability
Assessment:
[Italicized text within brackets] is added data based on review of aerial photo maps in the Assessment.
“Planning Zone 3 consists of the Southern Shoreline Planning Area and the Batiquitos Lagoon. Assets
within this zone are vulnerable to inundation, coastal flooding and bluff erosion in both planning
horizons (2050 and 2100). A summary of the vulnerability assessment rating is provided in Table 5. A
discussion of the vulnerability and risk assessment is also provided for each asset category.
5.3.1. Beaches
Approximately 14 acres of beach area is projected to be impacted by inundation/erosion in 2050. …
Beaches in this planning area are backed by unarmored coastal bluffs. Sand derived from the natural
erosion of the bluff as sea levels rise may be adequate to sustain beach widths, thus, beaches in this
reach were assumed to have a moderate adaptive capacity. The overall vulnerability rating for beaches
is moderate for 2050.
Vulnerability is rated moderate for the 2100 horizon due to the significant amount of erosion expected
as the beaches are squeezed between rising sea levels and bluffs. Assuming the bluffs are unarmored in
the future, sand derived from bluff erosion may sustain some level of beaches in this planning
area. A complete loss of beaches poses a high risk to the city as the natural barrier from storm waves is
lost as well as a reduction in beach access, recreation and the economic benefits the beaches provide.
5.3.3. State Parks
A majority of the South Carlsbad State Beach day-use facilities and campgrounds (separated into
four parcels) were determined to be exposed to bluff erosion by the 2050 sea level rise scenario
(moderate exposure). This resource is considered to have a high sensitivity since bluff erosion
could significantly impair usage of the facilities. Though economic impacts to the physical structures
within South Carlsbad State Beach would be relatively low, the loss of this park would be significant
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 4 of 7
since adequate space for the park to move inland is not available (low adaptive capacity). State
parks was assigned a high vulnerability in the 2050 planning horizon. State park facilities are recognized
as important assets to the city in terms of economic and recreation value as well as providing low-cost
visitor serving amenities. This vulnerability poses a high risk to coastal access, recreation, and
tourism opportunities in this planning area.
In 2100, bluff erosion of South Carlsbad State Beach day-use facilities and campgrounds become
more severe and the South Ponto State Beach day-use area becomes exposed to coastal flooding
during extreme events. The sensitivity of the South Ponto day-use area is low because impacts to usage
will be temporary and no major damage to facilities would be anticipated. Vulnerability and risk to State
Parks remains high by 2100 due to the impacts to South Carlsbad State Beach in combination
with flooding impacts to South Ponto.
Table 5: Planning Zone 3 Vulnerability Assessment Summary [condensed & notated]:
Asset Horizon Vulnerability
Category [time] Hazard Type Impacted Assets Rating
Beaches 2050 Inundation/Erosion, Flooding 14 acres (erosion) Moderate
2100 Inundation/Erosion, Flooding 54 acres (erosion) Moderate
Public Access 2050 Inundation, Flooding 6 access points Moderate
4,791 feet of trails
2100 Inundation, Flooding 10 access points Moderate
14,049 feet of trails
State Parks 2050 Flooding, Bluff Erosion 4 parcels [<18 Acres] High
[Campground - 2100 Flooding, Bluff Erosion 4 parcels [>18 Acres] High
Low-cost Visitor [loss of over 50% of
Accommodations] the campground &
its Low-cost Visitor
Accommodations,
See Figure 5.]
Transportation 2050 Bluff Erosion 1,383 linear feet Moderate
(Road, Bike, 2100 Flooding, Bluff Erosion 11,280 linear feet High
Pedestrian)
Environmentally 2050 Inundation, Flooding 572 acres Moderate
Sensitive 2100 Inundation, Flooding 606 acres High
Lands
Sea Level Rise and Carlsbad’s DLCP-LUPA’s projected/planned Loss of Open Space at Ponto Page 5 of 7
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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.
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
To: Growth Management Committee
From: Jeff Segal
Subject: Recommended Growth Management Standards
Date: 4-20-23
Page 6
Recommended Growth Management Standards
The committee heard thorough presentations from staff, listened to community input, and
reviewed and explored current Growth Management Standards as well as a number of
potential new standards (see page 38 under Additional topics considered by the committee),
but after extensive discussion on many of the topics, did not recommend any new standards, in
part because members felt a financing mechanism could not be established due to the limited
number of dwelling units to be built as of the time of this report or because infrastructures
were already built out.
The committee felt any new concepts, while not rising to the level of a standard, should be
considered in a separate Quality of Life (new name) document which is included in this report
as well as a separate document to the City Council. The committee felt that these topics were
especially important to the quality of life in Carlsbad and wanted the City Council to understand
this separately from Growth Management Report.
Of the 11 current standards, the committee recommended keeping 7 of the standards listed
below. The committee also recommended modifing two standards (Open Space and Water
Distribution System) and recommended removing four (Fire, Schools, Water Treatment
Capacity and City Administrative Facilities).
<<List the Standards Here>>
“Standards” are typically……
Page 17
Carlsbad Community Vision
Mention Envision Carlsbad, a citizen lead effort…..
Page 22
Somewhere under Meeting participation state:
To: Growth Management Committee
From: Jeff Segal
Subject: Recommended Growth Management Standards
Date: 4-20-23
Only primary committee members were allowed to vote on proposals and recommendations.
Alternates could do so, only when filling in for their primary members. Many votes were by
consensus, however on a number of issues, a roll call vote was taken when the committee was
split on an issue.
On second to last paragraph, change end of report to beginning on page 44.
Page 38
Add Police and Public Safety to the list with a note (see Fire Department standard discussion on
page 37).
Page 39
Move Supplemental quality of life recommendations heading to top of page.
While standard could not be developed in some of these areas, the committee determined
some of the topics should receive more consideration by the City Council and be considered in
future city strategic planning issues, but not as standards in the Growth Management Program.
These are described in more detail on pages 39-42 and were also provided to the City Council in
a separate document.
<<List the 8 or 9 areas here>>
These committee discussions on additional topics and quality of life issues as well as public
input are summarized in the meeting minutes, which are included in the appendices.
Page 41
Add $1 million in the first paragraph under Proposition H.
From:Lance Schulte
To:Growth Management Committee; Council Internet Email; City Clerk; Kyle Lancaster; Eric Lardy; "Smith,Darren@Parks"; "Homer, Sean@Parks"; "Sean Adams"; "Moran, Gina@Parks"; Boyle, Carrie@Coastal; "Prahler,Erin@Coastal"; "Ross, Toni@Coastal"
Cc:info@peopleforponto.com
Subject:Thank you and Public input for Carlsbad LCPA-Parks Master Plan & Growth Management Plan Updates - do theright and smart thing for our future
Date:Tuesday, April 25, 2023 12:16:02 PM
Dear Carlsbad Tomorrow Growth Management Committee:
Thank you for your service.
Your recommendations are a first initial step in the right direction to acknowledge and recommend
correction of the documented existing, and growing, Park and Useable Open Space shortfalls and
inequities at Ponto and South Carlsbad. The unfairness (both amount and location) of these city
facility impacts over 62% of Carlsbad’s families and the majority of Carlsbad’s visitor industry. Thus
this inequitable distribution/location and shortage of these facilities greatly negatively impacts all of
Carlsbad’s social quality of life and our City’s fiscal sustainability. This unfairness is amplified at
Ponto due to the current 40% higher population density at Ponto then the rest of Carlsbad due to
past conversion of prior Ponto Useable Open Space land uses to Residential by the City on behalf of
past, and current, developer requests. Failure to adequately correct these city Park and Useable
Open Space facility locational inequities in Coastal South Carlsbad will over time undermine and
degrade Carlsbad’s comparative positions relative to other cities.
It is illogical, and many Carlsbad citizens think very inappropriate, that the Committee was prevented
from making logical and reasoned location specific recommendations regarding the inadequate
distribution and amount of Growth Management Park and Open Space facilities and land uses at
Ponto and Coastal South Carlsbad. All City Growth Management Facilities and land uses are by
definition location specific. City parks, open space, fire stations, school, drainage-sewer-storm water
facilities, and roads all have location specific “service areas” based on the magnitude of surrounding
population demands (aka Carlsbad homes, neighborhoods and communities) that need those
services. If a neighborhood needs an accessible/useable city park for children to play, or a
neighbored needs an intersection/ road to correct neighborhood congestion the solution is location
(neighborhood) specific. Providing a park or roadway improvements miles away and saying that
solves that neighborhood’s park and intersection/road problems is dishonest and a
misallocation/waste of tax-payer money by not solving those neighborhood location specific City
facility problems.
In the mid-1980’s when I was involved in Carlsbad’s initial Growth Management Plans we had to
address location specific Growth Management facility shortfalls and provide location specific Growth
Management facility corrections. Locations of facilities are clearly seen and discussed in the initial
Growth Management Plans as new correcting city facilities were plotted and planned for under
Growth Management. Why the CTGMC was prevented to do the same type of analysis makes no
sense.
Not honestly addressing and making logical (and tax-payer responsible) location specific
recommendations to correct this unfairness and dysfunction is counter to good planning practice.
Failure to honestly correct this unfairness ignores fundamental moral and ethical principles. All
Carlsbad neighborhoods should have fair, equitable, adequate sized and located City Quality of Life
facilities. Failure to address locational specific City park facility shortfalls and unfairness results in
substandard neighborhoods and communities whose children and families are forced to use Streets,
railroad right-of-way, or destroy protected habitat land to use as people Parks. Your fellow citizens
have told you this and you have been shown the pictures. This will only get worse with increased
resident and visitor population increases, if not corrected now.
We hope you will be positively engaged in a responsible and honest follow-up by the City Council
and CA Coastal Commission to use tax-payer money wisely (i.e. the cost effective purchase of vacant
land at Ponto) to correct the Coastal Park and Useable Coastal Open Space unfairness documented,
and extensively communicated to the Committee, City Council and Commissions, and CA Coastal
Commission.
The City allowed (and is proposing more) Ponto developers to change Useable Open Space land use
to increase residential development density to over 40% higher than the rest of Carlsbad. Correcting
the Park, Useable Open Space, and development density imbalances is needed now while we have
cost-effective vacant unplanned land at Ponto.
We all Own our actions, or inactions, in how we take the next positive steps to address the well
documented unfairness and corrosive situation that, if uncorrected, will degrade “Carlsbad
Tomorrow” and our Coastline for current and future generations.
Thank you again for your service on the Carlsbad Tomorrow Growth Management Committee. Our
work for a new and better Carlsbad Tomorrow is just starting.
Again Mahalo Nui Loa, and Aloha Aina,
Lance Schulte
Copy: Carlsbad City Council, Planning and Parks Commissions, and CA Coastal Commission
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