HomeMy WebLinkAboutLCPA 93-02; Residential Density Increases; Local Coastal Program Amendment (LCPA) (8)December 5, 1994
California Coastal Commission
3 11 1 Camino Del Rio North, Suite 200
San Diego, CA 92108-1725
Attention: Deborah Lee, Director
SUBJECT: CITY OF CARLSBAD LOCAL COASTAL PROGRAM AMENDMENT -
LCPA #1-94(C) - RESIDENTIAL DENSITY INCREASES - AFFORDABLE
HOUSING
Dear Ms. Lee:
The City of Carlsbad requests that LCPA #1-94(C) be withdrawn. As discussed in your letter
to the City, dated November 28,1994, we agree that this Local Coastal Program Amendment
request should also include the proposed implementing ordinance (ZCA 92-02 - Development
Standards Modifications for Affordable Housing). We do however want to clan@ that the
proposed LCPA, which includes; (1) a new land use policy to allow residential density increases
above the maximum densities permitted by the City’s existing Local Coastal Program segments
to enable the development of lower-income affordable housing and (2) implementing ordinance
(ZCA 92-02/NS-207), which allows development standards modifications (including density
increases) to enable the development of affordable housing through processing of a site
development plan, is unrelated to the City’s Residential Density Bonus Ordinance (ZCA 91-
05/NS-233).
While both ordinances would allow greater residential densities to enable the achievement of
affordable housing, the standards and regulations associated with each alternative differ
considerably. For example, the City’s Density Bonus Ordinance (ZCA 91-05) implements the
specific regulations and processing requirements of State Government Code Section 65915 (State
Density Bonus Law) and requires the City to grant a minimum 25% density bonus and at least
one additional incentive in return for a developer guaranteeing to reserve a certain percentage of
the total units as affordable to low, very-low or senior citizen households for a period of 30
years, Again, this ordinance is not a unique City initiated proposal but rather a State mandate.
In comparison, the primary objective of ZCA 92-O2/NS-207 is to allow development standards
modifications to lower the costs (reduce the affordability gap) of developing affordable housing
(Housing Element Program 2.2). The modification of development standards lowers development
costs through : (1) the actual development cost savings associated with the reduced development
standards and (2) the ability to develop an additional number of dwelling units on a project site
than could normally be achieved through strict adherence to the development standards.
2075 Las Palmas Drive - Carlsbad, California 92009-1 576 - (61 9) 438-1 161 @
c-
LCPA 9441 - RESIDENTJAL DENSITY INCREASES - AFFORDABLE HOUSING
DECEMBER 1,1994
ZCA 92-02/NS-207 also implements Housing Element Program 3.74 which specifies that in
order to enable the development of affordable housing, the City adopt a mechanism (in this case
a Site Development Plan) to allow discretionary consideration of density increases above the
maximum now permitted by the General Plan. Unlike State Density Bonus Law, this Housing
Element Program, as implemented through ZCA 9242, does not include limitations on the
maximum density increase (25%) which the City could grant, percentage affordability restrictions
(20% low income or 10% very-low income), or affordability tenure (30 years).
In summary, ZCA 92-02 provides the City with additional flexibility which may be necessary
to negotiate successful affordable housing projects. Notwithstanding the City's commitment to
implement State Density Bonus Law through City ordinance, the State Department of Housing
and Community Development (HCD) determined that because of the City's overall extremely
lowdensity General Plan, that Housing Element Program 3.7.i.(implemented through ZCA 92-02)
was necessary both to achieve affordable housing and HCD's certification of the City's Housing
Element.
The City will be resubmitting both sections (land use policy and ZCA 92-02) of LCPA #1-94(C)
in the near future. The City agrees with you that given the circumstances concerning the original
application, submitted in January, 1994, that the resubmittal not be considered as a new
amendment request counted against the limit of three major amendments idenwid in the Coastal
Act. Prior to making any decisions on whether to process the City's Density Bonus Ordinance
(or Inclusionary Housing Ordinance) concurrently, it may be beneficial for us to meet and
discuss. Please give me a call if you have any comments or questions. Otherwise, I will contact
you or Bill Ponder to set up a meeting on this matter.
Sincerely,
CHRIS DECERBO
Senior Planner
c. GaryWayne
Bill Ponder