HomeMy WebLinkAboutLCPA 90-08; Carlsbad Ranch Specific Plan; Local Coastal Program Amendment (LCPA) (8)-.
June 3, 1993 I! ",; 5'
Mr. Bill Ponder Coastal Planner
California Coastal Commission
3111 Camino Del Rio North, Suite 200 San Diego, California 92108-1725
Re: Amendment 1-93, Carlsbad LCP Application 6-93-34 Carlsbad Ranch Specific Plan and Tentative Map
Dear Mr. Ponder:
The staff report proposes application of 430171.5 of the Coastal Act to uses proposed in the Specific Plan in areas of the
agricultural preserve, and to require mitigation, including payment
of a mitigation fee of $5,000-$10,000 per acre:
(1) 24.5 acres to be designated as open space and restricted to a public golf driving range or agricultural production.
(2) 3.4 acres to be utilized as a farm road, pedestrian link, and drainage course on the west face of the Ranch.
(3) 2.0 acres to be utilized as an east-west non-arterial
road with direct access to the agricultural operation packing sheds.
.54 acres to be utilized as a desiltation basin, in part, to reduce clean-out needs of an existing drainage
facility with riparian growth.
(4)
All of these uses are consistent with the basic goals of 830001.5
of the Coastal Act, as well as 430242.
(1) Drivina Range. As the EIR discussed, 24.5 acres will be used as a temporary public recreational use, fixed in
time by a Conditional Use Permit required for its approval and, therefore, no permanent loss of agricultural land will occur. The use will require continued preparation, cultivation and care of the land
in a manner consistent with agricultural production.
5600 AVENIDA ENCINAS SUITE 100 CARLSBAD, CALIFORNIA 92008 U.S.A.
/mal ~7i-c;~nn FAX (fii~) nqi-wwc)
Mr. Bill Ponder
Coastal Planner
California Coastal Commission
June 3, 1993
2
The use is one contemplated by the Williamson Act, the California constitutional provision sDecificallv adopted to preserve agricultural lands. Consistent application
of the State provisions intended to protect agricultural lands mandates a similar interpretation of the Coastal Act provisions relating to conversion.
Moreover, the change in land use designation to open space assures that no structures or uses which are
inconsistent with agricultural activities can occur on the land area.
The Coastal Act (Q30210, et.al.) clearly sets out
policies favoring recreational opportunities. While it
does not give such uses priority over agricultural uses, it does not subordinate recreational uses; instead it looks to balance and to encourage both uses. To treat this temporary use as a conversion requiring mitigation
would effectively prevent the creation of a public recreational opportunity and would subordinate recreation to agriculture rather than balancing the goals.
Here, the proposed Local Coastal Plan Amendment calls for a tailored plan which strikes that balance preserving the land for both uses and allowing public recreational uses within specific time constraints to be reviewed by the
City.
Moreover, the provision of such recreational
opportunities in immediate proximity to other visitor-
serving uses will enhance overall public access to
coastal resources.
Under these circumstances, we believe that no conversion of agricultural lands as contemplated in the requirements for mitigation has occurred. Consequently, we request the staff recommendations be modified to reflect a requirement for mitigation only in the event a use change from public open space recreational use or agricultural production use; not for the temporary use for public recreation. ?
(2) Farm Road/Pedestrian Link. The west face of the Ranch has been a landmark growing area for flowers, particularly Ranunculus which provide a spectacular show of color each Spring. As the area around the Carlsbad
Ranch has urbanized, and the number of visitors to San
Diego has increased, the attraction of these highly visible open fields has increased.
Mr. Bill Ponder Coastal Planner California Coastal Commission June 3, 1993
3
This visibility has enhanced the long-term viability of
the farming operation in this area by providing supplemental income in direct sales of cut flowers for the farmer, and some increase in demand at the retail level for bulbs.
However, the fields and farm roads necessary for operation have become inundated by tourists interfering with good farm practice (see enclosed photo example). Total fencing is not a practical barrier, and the use of a farm road designed to provide a controlled opportunity for these visitors, while retaining the ability to utilize as necessary to farm operations, was viewed as a necessary element in resolving the urban/rural conflict.
(3)
The path, as designed, may be closed at both ends during significant planning and harvest periods, and serves as an all weather link for farm vehicles.
It also permits creation of enhanced drainage facilities
to which the planting rows can be oriented. This drainage management is crucial to long-term soil
conservation. The experience this past Winter with failure of the drainage facilities and loss of farm road access because of erosion only highlighted the relevance
of this improved facility to long-term farming viability. Nearly 15 acres of crops and top soil was lost because of the facility failure.
The effort to dress the farm road, to give it visual identity, and permit its pedestrian use when not required for farming access should not be viewed as an activity inconsistent with the agricultural use, but rather as a method of mitigating the visual impacts of a necessary
. farm activity.
We request the staff recommendation be modified to reflect the above by deleting the requirement for
mitigation and, if deemed appropriate, add an additional
condition confirming access and use of the farm road at
all times by farm vehicles. ?
The East-West Road (Road BL. As urban uses have intensified about the Carlsbad Ranch, the roadway linkages from the Carlsbad Ranch agricultural operations to the remaining agricultural areas in Carlsbad, both within and outside the coastal zone is becoming limited to major and secondary arterials (i.e., Palomar Airport Road, Cannon Road, Paseo Del Norte). The traffic on these roads is often inconsistent with slow moving farm vehicles.
Mr. Bill Ponder
Coastal Planner
California Coastal Commission
June 3, 1993
4
All of the farmers of the Carlsbad Ranch have operations elsewhere in Carlsbad, and move equipment between locations on surface streets.
We believe that the absence of non-circulation element
roadways linking agricultural areas may isolate and thus discourage continued production on the Carlsbad Ranch.
Road B is designed to parallel Palomar Airport Road and Cannon Road on an east-west axis and link with non-major roadways. Since a grade separated crossing of the major north-south road (Road A) has been included, Road B will become an alternative for the entire agricultural operation of the Carlsbad Ranch.
Thus, we believe that it also represents additional mitigation for urban conflicts which exist beyond our control, and which otherwise may significantly affect long-term agricultural viability.
While it is not a road required to accommodate circulation of the proposed urban development, we recognize that it will carry urban as well as agricultural traffic.
Consequently, we request that the staff recommendationbe modified to acknowledge the consistency with continued agricultural operation. At a minimum, equal weight should be given and the required mitigation reduced to
50%.
(4) The Desiltation Basin. While we acknowledge that the new
desiltation basin represents a conversion from agriculture, we believe that amendment of the LCP should specifically exclude this area from application of the Mello I1 provisions. Such an approach is consistent with the overall mixed use concept since creation of the new basin allows a diversion and detention of storm drainage from the' existing major facility which serves the agricultural areas.
' This existing major facility has 'some riparian growth associated with it. This growth must be removed on a regular basis in order to accommodate the flood protection necessary forthe city's master drainage plan.
While the application proposed removal of the existing
drainage facility and replacement with the desiltation basin, staff has recommended that, as a condition to the application, the area and its riparian growth be retained.
c
Mr. Bill Ponder Coastal Planner California Coastal Commission
June 3, 1993
5
Without the additional new facility, usual and necessary removal of the growth would be necessary. With construction of the new facility, full clean-out, and ,removal of the existing facility may be unnecessary. Thus, the new facility provides a basis for preservation of native riparian vegetation (see page 10, Staff
Report). Consequently, since the creation of a new
detention basis permits preservation of native vegetation
which would be removed regardless of development,
mitigation for using a portion of the agricultural designated land for a detention basin is inappropriate.
Moreover, the location is in an area of sleep slope which
cannot now be farmed. Thus, its use as a desiltation basis will not cause for loss of land in current production.
We have sought to implement a mixed-use plan which has a potential
for sustainable agriculture. Our objective has been to anticipate
the urban/rural interface, and to accommodate it in a manner which enhances the long-term sustainability of agriculture and
preservation of agricultural land. The imposition of a mitigation requirement as proposed in the staff reports will impair some of these efforts.
For the reasons set forth above, we urge that the staff recommendations be modified and reflect the unique approach inherent in the mixed use concept for this property.
Please give me a call if you have any questions. #
CCWsf Enc .
1-80-248 1-90-019