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Home My WebLink AboutLCPA 90-08B; Carlsbad Ranch Specific Plan; Local Coastal Program Amendment (LCPA) (3).. e. -. PETE WILSON, Governor STATE OF CALIFORNIA-THE RESOURCES AGENCY CALIFORNIA COASTAL COMMISSION SAN DIEGO COAST AREA 3111 CAMINO DEL RIO NORTH, SUITE 200 SAN DIEGO, CA 92108-1725 (619) 521-8036 June 16, 1995 Don Neu Senior P1 anner Ci ty of Carl sbad Planning Department 2075 Las Palmas Drive Car 1 s bad, CA 92009-1 576 Re: Carl sbad RanchKoastal Issues Dear Mr. Neu, In response to your letter, dated May 23, 1995, regarding low-cost visitor accommodations and agricultural preservation issues on the Carlsbad Ranch property, we provide the following comments. we did meet with you and Mike Howes/Hofman Planning Associates in April 1995 to discuss some specific coastal issues related to the Carlsbad Ranch revisions being considered. For the record, our discussion at that time did not solely focus on the provision of low income transient lodging as might otherwise be perceived from your 5/23/95 letter. At that meeting, we discussed a broader range of concerns arising out of Sections 30210 and 30213 of the Coastal Act. Specifically, those sections provide: As you mentioned in your letter, Section 30214 In carrying out the requirement of Section 4 of Article X of the California Constitution, maximum access, which shall be conspicuously posted, and recreational opportunities snai 1 be provided for ai 1 the people consistent with public safety needs and the need to protect public rights, rights of private property owners, and natural resource areas from overuse. Section 30213 (in part) Lower cost vi si tor and recreational faci 1 i ties shall be protected, encouraged, and, where feasi bl e, provided. Developments provi di ng pub1 i c recreational opportunities are preferred. During the meeting, we thus reviewed the Coastal Act's mandate for the provi sion of affordable vi si tor accommodations, as we1 1 as low-cost recreational faci 11 ties, and the Coastal Commission' s recent concerns over the privatization of visi tor-serving uses and public recreational facilities. Don Neu June 16, 1995 Page 2 Before I proceed to address the particulars of the hotel/motel units survey conducted by Hofman Planning Associates, I would like to reiterate this office's other concerns which were discussed at that meeting. First, as you can see from Section 30213 of the Act, it addresses both the provision of lower cost vi si tor and recreational faci 1 i ties and it establishes a preference for those developments which provide public recreational opportunities. We therefore emphasized the need for City and project proponent to incorporate lower cost public recreational opportunities to the fullest extent possible. While we acknowledge that the Legoland Park is a commercial recreational use, it does not address public recreational needs directly. At the meeting, it was stated that the proposed resort's golf course would be open to the general public; this project element begins to address Section 30213 of the Act more directly. quite costly considering both equipment and playing fees. Therefore, we again urged the City and project proponent to consider ways in which broader public recreational opportunities could be provided. In particular, we suggested the inclusion of an extensive public trail system, with lagoon overlooks, intermittent seating areas and appropriate support faci 1 i ti es, whi ch could be designed in concert with the proposed golf course as a public recreational use. However, golfing is not the sport for everyone and tends to be After discussing the means to promote public recreational use in the proposal, we then proceeded to identify a second concern for the Coastal Commission which is an increasing privatization of public facilities or visitor-oriented uses. In both expansions to or redevelopment of existing public recreational sites or visitor uses (ie. Pebble Beach and Marineland resort), the Coastal Commission has begun to question changes in use or operation, such as exclusionary membership requirements or restricted public accessibility, which serve to privatize an otherwi se proposed pub1 i c faci 1 i ty or vi si tor accommoda- tion. Therefore, should a facility be proposed as a public use or visitor accommodation, it is our expectation that it will operate and remain as a use available to the general public without limitations. On such proposals, we advised you that the Coastal Commission has begun requiring a deed restriction to be recorded against the property declaring a project's exclusive use for the general public and acknowledging that any future conversions or use restrictions would require prior review by the Coastal Commission. Finally, relative to the mandate in Section 30213 for the provision of lower cost vi si tor faci 1 i ti es, we di scussed some land use a1 ternatives and precedential permit decisions by the Coastal Commission in our meeting. As I recall, we discussed the direct provision of lower cost hotel/motel units accounting for about 25% of the total units proposed either on-site or at an acceptable off-si te location as part of any proposal. Alternatively, we also reviewed the possibility of in-lieu fees to support construction of a hostel or campground facility, as well as the provision of parklands as a form of off-setting public benefit. However, as we sat and discussed this issue, both Don Neu June 16, 1995 Page 3 you and Mike Howes felt that the City already supported a broad range of visitor accommodations in terms of room rates and inquired whether or not such documentation could be accepted in the place of any other direct provision or alternate benefits. At that time, we indicated we would be willing to review any documentation the City or project proponent submitted relative to this issue. In response to the specific hotel/motel units survey provided by Hofman Planning Associates (HPA), we would make the following comments. In the survey's attachment from the Chamber's Economic Bulletin, the classes of hotel/motel rooms were specified by average room rates. However, in the HPA analysis, the room rates were aggregated such that a hotel/motel unit costing up to $56.90 was counted as an "economy unit" even though a $56.90 room charge was shown in the Chamber's Bulletin as the average room rate for a mid-mice unit. In addition, the HPA survey included some accounting errors for both the mid-pri ce category and the total number of accommodations. Nonetheless, we re-eval uated the basic hotel /motel unit counts against the Bull eti n' s average room rates and still found that 433 units or 40% of the 1,050 total units surveyed would qualify as budget or economy class vi si tor accommodations. A copy of our revised evaluation is attached for your review. In addition, the survey points out and we acknowledge the 226 campground spaces at Carlsbad State Beach which provide lower cost visitor accommodations. Therefore, based on this information, our staff would support the City's position that there are sufficient numbers of lower cost visi tor accommodations presently available in the City's coastal zone and no further consideration is necessary. The second issue you requested our input on deals with agricultural lands preservation and the proposed Wi 11 iamson Act contract cancellations on Carlsbad Ranch parcels. agricultural lands present on the Ranch, the most pertinent Chapter 3 policy is Section 30242 of the Act. It states: Given our understanding that there are no prime All other lands suitable for agricultural use shall not be converted to nonagri cultural uses unless (1 1 continued or renewed agri cul tural use is not feasible, or (2) such conversion would preserve prime agricultural land or concentrate development consistent with Section 30250. Any such permitted conversion shall be compatible with continued agricultural use on surrounding 1 ands . As you are aware, the historic approach developed by the City and Commission to address agricultural land preservation in the Mello I1 LCP was to ensure the preservation of prime agricultural lands throughout the coastal zone by providing for the appropriate and orderly conversion of designated, but non- prime, coastal agricultural lands in the City. provides for the conversion of designated coastal agricultural lands based on The certified Mello I1 LCP c Don Neu June 16, 1995 Page 4 a determination that the conversion would preserve prime agricultural lands within the coastal zone statewide or it would concentrate new development consistent with Section 30250 of the Coastal Act or conversion is appropriate because continued or renewed agriculture is infeasible. designated non-prime agricultural lands is then subject to one of three conversion options including direct mitigation, a feasibility analysis or payment of a conversion fee ranging from $5,000 to $10,000 per net converted acre. Conversion of However, Carlsbad Ranch was specifically addressed in a different manner. the Ranch, there were two basic options, both of which retained agricultural uses over the majority of the site. The second option, and the one utilized within the presently certified Carlsbad Ranch Specific Plan, is the "mixed use" concept where speci fi c acreages were reserved for continued agri cul tural production while other areas were permitted to convert to urban uses. In the Commission's original action on the Carlsbad Ranch Specific Plan, it required the incorporation of the three conversion options contained in the Mello I1 LCP into the Specific Plan because the plan provided for the conversion of additional designated agricultural 1 ands beyond the boundaries origi nal ly established for the Ranch. For Although there has been a heightened interest in agricultural preservation issues on the part of current Coastal Commission members, this office will adhere to the policy direction established in the currently certified Mello I1 LCP and Carlsbad Ranch Specific Plan which is to consider the possible conversion of designated agricultural lands subject to compliance with one of the three specified conversion options. While we are prepared to support agricultural land use changes subject to the conversion options, it will still be incumbent on the City and project proponent to demonstrate that agricultural conversion is appropriate in order to support retained agricultural use either elsewhere in the coastal zone or on the Ranch or that conversion serves to concentrate urban development in an appropriate manner. Alternatively, the burden would be to demonstrate that agricultural cperations are no longer vi ab1 e. In addition, for those areas to be retained in agriculture, the amended specific plan should still address necessary buffering and means to reduce conflicts between urban and agricultural uses which could lead to future proposals for add! tional agricultural land conversions. Lastly, relative to agricultural land conversion, consistent with the Commission's previous action on the Ranch, staff would not accept the golf course as an alternative form of continued "agriculture" even though the Williamson Act contracts may allow it as an interim use. We would therefore recommend that any proposed conversion of designated agricultural lands to urban uses, including the proposed golf course, beyond the boundaries in the presently adopted specific plan be subject to compliance with the identified conversion options. I hope that this letter serves to adequately respond to your 5/23/95 inquiry. . Don Neu June 16, 1995 Page 5 Although I have attempted to provide you with specific direction and confirmation of our staff's position on these issues, it is important for me to stress that this direction is strictly from staff and there are no guarantees on what ultimately the Coastal Commission itself may decide. As the decisionmaking body, the Commissioners may reach different conclusions. With that caveat, I hope this letter clarifies our staff position on these matters. If you have any questions, please don't hesitate to contact Bill Ponder or me at the above office. Sincerely, /I Deborah N. Lee Assistant District Director cc : Chri s Cal ki ns , Carl tas Company Bill Hofman, HPA Mike Howes, HPA Mike Holzmiller Gary Wayne Chuck Damm iROR L 2. 1.1988 1914s - - I P. 5 I I I PROPERTY ADR OCC # OF ROOMS BUDGE" I 'f Carlsbad Lodge S26.SO 53.7% 55 Motel 6 - Carlabad Village Drive $28.37 62.4% 109 YW~I- ( 3 23 1 * MOW 6 - RainUct $28.90 61.716 ECONOMY A- .._*--wLI.L.y--LL----- .------ 1- Inns of America ' s37.60 63.6h ___-- -.-_1---* lrn--.---d €w(rn) Pea SOUP Anderson's S66.58 59.4 9b ~ -I. _*-- 144__4_ MIP-fi4&3 ss3.72-- 64.2 I l26 - - ' 48 43 F - A1_Lu-_L, -- --. - L~mvel Lodge ! MID PRICE FWnada-Poinsettia $57.50 65.9k -* $67;42 -*34.8% L-- - &ner I;bdge-" I...- I UPSCALE I @? Beach View Lodge sn.w 76%' 74 7 I Carlobad Inn S83.72 84.6% 58 LTmarack Beach R~fia----386~..-4.,dA- 72.4% 23, j Uf!@5t54&(170) -.-Lcl A - 5-66 S98.40 83;6k-- eh-Te-.-- cn- - I- ---- c_ ---III.uI*LL __ ~ - Id 1-1 -- I I ?%V&Y (49) TOTAL # OF ACCOMMODATIONS AVERAOE DAILY RATE AVERAGEOCCUPANCY 66.8% I lo 50 B;ued on the information provided above, 550 or over half of the accommodations available in the Coartal Zone of Carlsbad can be classified as being either budget or economy The remaining 491 unh would fall into either the mid price or upscale category. None of the -- currently available accommodations would fall into the, luxury category. You should note that the upde unib have lhe highest occupancy rate. Thia would scum to indicate that there is more of a demand for the higher priced accommodations. Another factor that should be kept in mind when reviewing thew figures is that it cosu approximately This chart doer not include the 226 spaces of the Carlabad State Beach Campground. These 3plces mt for S16$21 a night depending on whether they are on the ocean or strat side. If thew: 226 spaccs weft added to the total approximately 43% of the accommodations in the Coastal portlon of Carlsbad would fall into the budget category. The accommodations being proposed by the Carlsbad kanch will allow the City to increase tho number of upscale units and provide some units that would fall into tho luxury category. 433 h) 2% SlS420 to ~crvtcS a room each night. I t I