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Home My WebLink AboutLCPA 90-08B; Carlsbad Ranch Specific Plan; Local Coastal Program Amendment (LCPA) (5)STATE OF CALI-MA-THE RESOURCES AGENCY PETE WILSON, Gorrrmor CALIFORNIA COASTAL COMMISSION SAN MEGO COAST AREA 3111 CAMlNO DEL RIO NORTH, SUITE 200 SAN MEGO, CA 92108-1725 (619) 521-8036 December 20, 1995 Don Neu Senior P1 anner Ci ty of Carl sbad P1 anni ng Department 2075 Las Palmas Drive Carl s bad, CA 92009-1 576 Re: DEIR for Carlsbad Ranch Specific Plan Amendment I apologize for the lateness of these comments. subject document and has the following comments. comments on the proposed amendment to the Carlsbad Ranch Specific Plan on June 16, 1995 (Carlsbad RanchKoastal Issues) and on September 15, 1995 (Carlsbad Ranch Specific Plan Amendment-Legoland Comments). Staff has reviewed the We previously provided The DEIR addresses the proposed amendment to the certified Carlsbad Ranch Specific Plan. The proposed land uses for the amended specific plan include a mix of non-residential uses in nine planning areas, including office, research and development, related 1 ight manufacturing, commercial, hotel, destination resort, golf course, agriculture, a vocational school campus and Legoland on a total of 471.2 acres. Airport Road, south of the future Cannon Road extension (except for an area totaling approximately 24.2 acres located on the north side of Cannon Road). The project is generally located north of Palomar The certified Coastal Resource Protection Overlay Zone of the Mello I1 LUP protects dual criteria slopes and Policies 3-7 and 3-8 require that riparian resources outside the lagoon ecosystems shall be protected and preserved. Regarding dual criteria slopes, the overlay protects slopes of 25% grade and over unless the application of this policy would preclude reasonable use of the property, in which case an encroachment not to exceed 10% of the steep slope area over 25% may be permitted. The overlay also provides that this policy does not apply to circulation element roads, the development of utility systems or encroachments on slopes over 25% which may be developed to provide access to flatter areas if there i s no 1 ess environmental ly-damagi ng alternative available. The DEIR indicates that approximately 1.1 acres of Diegan coastal sage scrub would be impacted on a manufactured slope adjacent to Palomar Airport Road. The document does not indicate why the slope would be impacted, only that the impacts should be mitigated at an off-site location. Historically, the application of sensitive slope preservation policies has been 1 imi ted to natural ly-vegetated, undisturbed, steep slope areas. However, many communi ties, the resource agencies and Commission staff, as we1 1, have all questioned whether or not those provisions are adequate given that high Don Neu December 20, 1995 Page 2 quality habitat may also be found on non-steep areas and information supporting the establishment of larger habitat preserves as the best means to preserve ecosystems. the application of the certified LCP policy on dual criteria slopes as it relates to the habitat impacts of disturbing this manufactured slope adjacent to Palomar Airport Road as part of the final analysis. Therefore, please present the City' s i nterpretation of Policy 3-7 of the Mello I1 LUP requires the preservation of riparian resources outside lagoon ecosystems and provides that no direct impacts may be allowed except for the expansion of circulation element roads and installation of utilities. The DEIR indicates the riparian and freshwater marsh plants located in the south central portion of the site will be preserved in an open space deed restriction; however, the document does not indicate if a buffer will be created around these resources consistent with Policy 3-8 of the Mello I1 LUP. Policy 3-8 requires buffer zones of 50 feet to be maintained around riparian areas and 100 feet around identified wetland areas (freshwater marsh), unless it is demonstrated that a buffer of lesser width will protect the resources. As such, the final EIR should address the project's cons! stency with the above buffer standards. Fish and Game and the U.S. Fish and Wildlife Service must be consulted in such buffer determinations. The California Department of Regarding public access/circulation/parking, traffic analyses were done for Year 2000 and Year 2010 (Buildout) conditions. The DEIR states that, if Cannon Road is not extended to El Camino Real by the Year 2000, mitigation measures would be necessary in 1997 to 1-5, Palomar Airport Road and College Boulevard (1 .e. the restriping of Palomar Airport Road and College Boulevard approaches at select locations to create additional through lanes), as well as implementation of a Congestion Management Plan to assure adequate traffic flow in the project area. affect public circulation/access on Palomar Airport Road, the main road serving the subject site, and the major east/west roadway that provides public access to the shoreline from inland areas. In addition, the DEIR states that the project is anticipated to result in an increased demand for parking in the beach areas as a result of the additional visitors to the City, but this increase is considered insignificant. The final document should quantify this projected demand under bui ldout conditions and recommend mi tigation measures (i.e. shuttle system or providing parking on City lands near the beach, etc.) to assure that public access/parking would not be adversely affected by the project. The final EIR should indicate how this scenario would Regarding visual issues, in LCPA #1-93, the Commission found that, although the specific plan contained a number of provisions to mitigate the visual impacts of new development on this ridgeline site, concerns remained over the visual impact of the hotel in what is now proposed as Planning Area #3. The Commission found the hotel's accent feature must be restricted in bulk to no more than three percent (3%) of the hotel's overall roof surface. The final Don Neu December 20, 1995 Page 3 EIR should address this concern for the hotel and specifically discuss any other proposed changes to building height standards relative to potential vi sua1 impacts. Our June 1995 letter identified the Coastal Act's mandate for the provision of affordable visitor accommodations, as well as low-cost recreational faci 1 i ti es, and the Coastal Commi ssion' s recent concerns over the privatization of visitor-serving uses and public recreational facilities. Our letter identified the need for the amended plan to promote broad recreational use, such as providing a public trail system which could be designed in concert with the proposed golf course as a public recreational use. letter suggested inclusion of lagoon overlooks as part of the trail system. The golf course layout should be designed to be subordinate to the natural environment and accommodate public access, rather than the golf course design being the justification for any resource impacts or restrixtion upon public accessibility. As identified in the letter, the public trail system should include i ntermi ttent seating areas and appropriate support faci 1 i ti es so that it complements the golf course as another recreational facility. does not address these concerns; the final document should therefore be revised to be found consistent with the visitor-serving provisions of the Coastal Act. Our The DEIR The above comments have been prepared based on the information available at this time. Additional issues may result from further public review and input. Ultimately, the Coastal Commission itself is the decision-making body on the proposed specific plan and perhaps the coastal development permit(s1. Please call me at the above number if you need further information or have comments . Sincerely h@- Bill Ponder Coastal P1 anner BP: bp: (0756A) cc: Chris Calkins, Carltas Company Bill Hofman, HPA Mi chael Hol zmi 11 er Lauren Sevri n Chuck Damm