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Home My WebLink About2019-11-20; Planning Commission; ; LCPA 15-0007 (DEV 15-0061) – Overview of Local Coastal Program Land Use Plan Update Item No. Application complete date: N/A P.C. AGENDA OF: November 20, 2019 Project Planner: Jennifer Jesser Project Engineer: N/A SUBJECT: LCPA 15-0007 (DEV 15-0061) – Overview of Local Coastal Program Land Use Plan Update – Staff presentation of an introduction to the draft Local Coastal Program Land Use Plan update. I. RECOMMENDATION That the Planning Commission: receive a staff presentation introducing the draft Local Coastal Program Land Use Plan update and ask questions of staff to clarify understanding of the draft plan. This is an informational item only; the Planning Commission is not being asked to make any decision on the draft plan. II. PROJECT DESCRIPTION AND BACKGROUND The draft Local Coastal Program (LCP) Land Use Plan (previously distributed to the Planning Commission and available at www.carlsbadca.gov/coastalupdate) reflects a comprehensive update to the plan. The objectives of the update are to update the document to be consistent with the California Coastal Act and recent guidance from the California Coastal Commission, as well as the Carlsbad Community Vision and the city’s General Plan (adopted in 2015). The California Coastal Act of 1976 was approved by a voter initiative to “ensure maximum public access to the coast and public recreation areas.” Ever since, cities along the California coast (within the Coastal Zone) have been required to prepare a Local Coastal Program to show how the cities will implement the act. In Carlsbad, about 37% of the city is in the Coastal Zone (Figure 1-2 of the draft LCP Land Use Plan shows the Coastal Zone boundary in Carlsbad). The Coastal Act requires that a LCP Land Use Plan address the following topics: • Public Access: Protection of public access to the sea, coastal beaches and recreational opportunities • Recreation: Protection of certain water-oriented activities and land for recreational use • Marine Environment: Protection of marine resources, including biological productivity and water quality • Land Resources: Environmentally sensitive habitat areas, agriculture, archaeological and paleontological resources • Development: Location, scenic and visual qualities, maintenance and enhancement of public access, minimization of adverse impacts, public facilities to meet needs of development, and priority of coastal-dependent development 1 LCPA 15-0007 (DEV 15-0061) OVERVIEW OF LOCAL COASTAL PROGRAM LAND USE PLAN UPDATE November 20, 2019 Page 2 In December 2017, the City of Carlsbad Sea Level Rise Vulnerability Assessment was completed and is incorporated as Appendix B of the draft LCP Land Use Plan. The update of the LCP Land Use Plan, including the sea level rise assessment, were prepared in consultation with local Coastal Commission staff and are based, in part, on adopted and draft guidance from the California Coastal Commission: • California Coastal Commission Sea Level Rise Policy Guidance; August 2015; revised November 2018 (https://www.coastal.ca.gov/climate/slrguidance.html) • Draft California Coastal Commission Residential Adaptation Policy Guidance – Interpretive Guidelines for Addressing Sea Level Rise in Local Coastal Programs; March 2018 (https://documents.coastal.ca.gov/assets/climate/slr/vulnerability/residential/RevisedDraftResi dentialAdaptationGuidance.pdf) • California Coastal Commission Local Coastal Program (LCP) Update Guide Part I – Updating LCP Land Use Plan (LUP) Policies; April 2007; revised July 2013 (https://www.coastal.ca.gov/rflg/lcp- planning.html) III. OVERVIEW OF LCP LAND USE PLAN UPDATE A. Why Update the LCP Land Use Plan? The primary reasons for updating the LCP Land Use Plan are: • California Coastal Commission and Ocean Protection Council grants: In November and December 2014, the Coastal Commission and Ocean Protection Council awarded the city two grants ($228,000 total) to conduct a sea level rise analysis and update the Local Coastal Program. • Current conditions and Coastal Commission guidance – the LCP Land Use Plan has not been comprehensively updated since original adoption in the 1980’s and does not adequately address all current topics/requirements – such as sea level rise hazards. The Coastal Commission has, in recent years, provided guidance on information to be addressed in a LCP update. • Consistency with Carlsbad Community Vision and General Plan – in 2015, a comprehensive update to the General Plan was adopted, which incorporates the community vision. Updating the LCP Land Use Plan ensures consistency with the vision and General Plan. • Obsolete/repetitive policies – the existing LCP land use plans contain site-specific policies that have been implemented (through development) or are repeated numerous times for various sites throughout the Coastal Zone (e.g. existing policies related to water quality protection are repeated multiple times on a site-specific basis). The draft LCP Land Use Plan proposes to replace most of these obsolete/repetitive site-specific policies with policies that protect coastal resources and access to the coast on a Coastal Zone-wide basis. However, site/area-specific policies that are still relevant and unique to a site/area are addressed in the draft LCP Land Use Plan. LCPA 15-0007 (DEV 15-0061) OVERVIEW OF LOCAL COASTAL PROGRAM LAND USE PLAN UPDATE November 20, 2019 Page 3 B. Draft LCP Land Use Plan Description The draft LCP Land Use Plan contains the following chapters: Table 1: Draft LCP Land Use Plan Chapters Description Chapter Description 1 Introduction Introduces and describes the purpose and organization of the LCP Land Use Plan. 2 Land Use Describes how land and development are regulated in Carlsbad’s Coastal Zone consistent with the California Coastal Act. It includes the LCP Land Use Map, land use designations, standards for density, and land-use related policies. 3 Recreation and Visitor- Serving Uses Describes Carlsbad’s existing public recreational resources and visitor- serving uses and attractions and identifies policies to ensure that community members have continued access to coastal recreational opportunities and accommodations. 4 Coastal Access Describes Carlsbad’s existing and future coastal access network and provides policies that ensure coastal access is protected and enhanced, consistent with the Coastal Act. 5 Agricultural, Cultural and Scenic Resources Describes the agricultural, cultural, and scenic resources found in Carlsbad’s Coastal Zone and provides policies that guide the city in the protection of such resources. 6 Environmentally Sensitive Habitat Areas and Water Quality Describes the natural coastal resources found in Carlsbad’s Coastal Zone, which include environmentally sensitive habitat area (ESHA) and marine and coastal water quality. Also provides policies that guide the city in the protection of such resources. 7 Coastal Hazards Identifies the coastal hazards (sea level rise, flood, geologic, and fire) and provides policies that guide new development to reduce risks to life and property and to avoid substantial changes to natural land forms. 8 Glossary Defines terms used in the LCP Land Use Plan that are technical or specialized, or that may not reflect common usage. 9 Appendix A North Coast Corridor Public Works Plan Overlay Carlsbad’s portion of the North Coast Corridor Public Works Plan/Transportation and Resource Enhancement Program (NCC PWP/TREP), which is a plan prepared by Caltrans and SANDAG to authorize transportation, community and resource enhancement along the I-5 and railroad corridor from La Jolla to Oceanside. Appendix B City of Carlsbad Sea Level Rise Vulnerability Assessment A Carlsbad-specific sea level rise analysis that evaluates the degree to which community assets are susceptible to accommodate adverse effects of projected sea level rise. C. Draft LCP Land Use Plan Highlights Attachment 1 highlights and describes some of the key topics addressed in the draft LCP Land Use Plan. This information will be included in staff’s presentation at the Planning Commission’s meeting. LCPA 15-0007 (DEV 15-0061) OVERVIEW OF LOCAL COASTAL PROGRAM LAND USE PLAN UPDATE November 20, 2019 Page 4 IV. ENVIRONMENTAL REVIEW This is an information item only. Pursuant to Public Resources Code section 21065, this action does not constitute a "project" within the meaning of CEQA 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, and therefore does not require environmental review. ATTACHMENTS: 1. Highlights of Local Coastal Program Land Use Plan Update Attachment 1 Highlights of Local Coastal Program Land Use Plan Update CHAPTER 1 – INTRODUCTION Chapter Highlight Description History The introduction describes the history of Carlsbad’s LCP, which resulted in six separate LCP land use plans that applied to six geographic segments of the city’s Coastal Zone. The six segments are proposed to be merged into one single LCP land use plan that applies Coastal Zone-wide. Site/area-specific policies, which are still relevant, are reflected in the proposed draft LCP. Coastal Act Requirements and Permitting Authority This chapter describes the purpose and components of a local coastal program, as required by the Coastal Act. Also, information and maps are included that clarify the areas where the city has the authority to issue coastal development permits and where the Coastal Commission has permit authority. Implementation The documents that implement the policies of the LCP Land Use Plan are listed. CHAPTER 2 – LAND USE Chapter Highlight Description General Plan Consistency Most changes to LCP land use policies are proposed to make the LCP consistent with the General Plan land use policies. Special Planning Considerations Consistent with the General Plan, the LCP Land Use Plan includes policies for areas with “special planning considerations,” which include: •Cannon Road Open Space, Farming, and Public Use Corridor • Carlsbad Boulevard/Agua Hedionda Center • Village and Barrio •Ponto/Southern Waterfront •Murphy See the draft LCP Land Use Plan for figures showing the location of these areas – Figures 2-2A, 2-2B and 2-2C. Ponto Beachfront Village Vision Plan Consistent with the General Plan and Ponto Beachfront Village Vision Plan, policies are included that incorporate the land use related guidelines from the Ponto Beachfront Village Vision Plan. Note: The property at the northeast corner of Carlsbad Boulevard and Avenida Encinas is currently designated R-23 (Residential 15-23 dwellings per acre) and GC (General Commercial) on the General Plan and LCP land use maps. In 2015, a development application was submitted to the city for review; since that time, some of the residents of the San Pacifico neighborhood (east of the project site) have submitted comments to the city expressing concerns about the proposed development, as well as the amount of open space and parks in the southwest portion of the city. The most recent comments urge the city to designate the site as a park. As part of the public hearing staff report to the Planning Commission on the draft LCP Land Use Plan (which will be scheduled in early 2020), staff will include an analysis of the need for recreation and visitor-serving uses in the area, as well as the need for other uses, such as housing. Highlights of Local Coastal Program Land Use Plan Update 2 CHAPTER 2 – LAND USE (continued) Chapter Highlight Description Coastal- Dependent Uses Consistent with the Coastal Act, new policies are added to the LCP that support coastal- dependent uses, which include fishing, marinas/boating, aquaculture, and water desalination facilities. Land Use Designation Changes Changes to LCP land use/zone designations are proposed as shown below. These changes were approved by the city as part of the 2015 General Plan update. However, the Coastal Commission deferred their decision on these land use/zone changes until the city provided more information on the need for visitor commercial uses and the types of uses that would be allowed on these sites. This information will be included in the Planning Commission’s future public hearing staff report and will be submitted to the Coastal Commission after City Council approval of the LCP Land Use Plan. Existing LCP Land Use U – Utility; TS – Tourist Services Proposed LCP Land Use VC – Visitor Commercial; OS – Open Space Existing LCP Zoning PU – Public Utility Proposed LCP Zoning CT – Commercial Tourist; OS – Open Space Highlights of Local Coastal Program Land Use Plan Update 3 CHAPTER 3 – RECREATION AND VISITOR-SERVING USES Chapter Highlight Description Recreation The Coastal Act addresses the protection of recreational uses, including water-oriented activities, fishing, boating, and recreational facilities. The policies of this chapter support the protection of these uses. Timeshares A new policy is added to the LCP that prohibits new timeshares (or similar limited-use accommodations) on land designated VC (Visitor Commercial). This prohibition is proposed in response to Coastal Commission concerns that such uses may be considered more of a residential use and limit the general public’s access to the coast. Low-Cost Visitor Accommodations In response to Coastal Commission guidance, new policies are proposed that protect existing lower-cost visitor accommodations. “Lower-cost overnight accommodations” is defined; and any proposal to remove existing lower-cost accommodations is required to mitigate the loss of the accommodations at a 1:1 ratio. CHAPTER 4 – COASTAL ACCESS Chapter Highlight Description Access to the Coast Consistent with the Coastal Act, policies address the provision and protection of accessways to the coast - pedestrian access, bicycle and vehicle access, including parking. Trails Consistent with the recently adopted city Trails Master Plan, a trails map and design guidelines are added to the LCP. Livable Streets Consistent with the General Plan, livable streets policies are added to the LCP, which address a balanced, multi-modal transportation system. CHAPTER 5 – AGRICULTURAL, CULTURAL, AND SCENIC RESOURCES Chapter Highlight Description Agriculture The highlight regarding agriculture, is that no change is proposed to existing policies and requirements that address the protection and conversion of agriculture. Additional information is added to clarify the various past city and state actions that apply to agriculture in Carlsbad. Cultural Resources Policies are updated consistent with the Carlsbad Tribal, Cultural, and Paleontological Resources Guidelines, adopted by the city in 2017. Scenic Resources Consistent with Coastal Commission guidance, new policies are added to the LCP that address the protection of public coastal views. The draft plan includes maps that clarify what coastal views are to be protected and from which public viewing points. On some properties, particularly those between the ocean/lagoon and a public street, park or trail, the draft policies specify restrictions on building location, landscaping, signs, and lighting. Highlights of Local Coastal Program Land Use Plan Update 4 CHAPTER 6 – ENVIRONMENTALLY SENSITIVE HABITAT AREAS AND WATER QUALITY Chapter Highlight Description Protection of Sensitive Habitat The highlight regarding protection of environmentally sensitive habitat, is that no change is proposed to the city’s current policies, which consist primarily of the city’s Habitat Management Plan (HMP). Additional policies are proposed that clarify how to protect sensitive habitat that is not within the boundaries of the HMP. Water Quality Policies are updated to be consistent with current regional and city water quality protection standards. CHAPTER 7 – COASTAL HAZARDS Chapter Highlight Description Sea Level Rise Hazards New information and policies are added to the LCP that address sea level rise hazards and adaptation. The new policies are based on Coastal Commission guidance and the results of the Carlsbad Sea Level Rise Vulnerability Assessment. Sea level rise policies address the following: Siting new development New development is required to be located and designed to minimize risks from hazards (erosion, flooding, inundation), ensure structural stability and protection of coastal resources. Shoreline Armoring Consistent with the Coastal Act, draft policies clarify the limited circumstances when shoreline armoring could be permitted in Carlsbad, and the requirements to minimize impacts to coastal resources. Moving Development Away from Hazards Policies are included in the draft LCP that identify the circumstances when development must be removed or modified to avoid risks to public health and safety, and to avoid impacts to public trust resources. FEMA Flood Hazards Policies are updated to reflect current Federal Emergency Management Agency (FEMA) requirements. Also, consistent with Coastal Commission guidance, the policies clarify that development of permanent structures is prohibited in the 1-percent-annual- chance-flood area (100-year flood area). Geologic Hazards Policies updated consistent with the General Plan and Coastal Commission guidance. Fire Hazards Policies updated consistent with the General Plan; also, the city’s “fuel modification zones” maps have been included in the chapter to clarify fire safety requirements. Highlights of Local Coastal Program Land Use Plan Update 5 CHAPTER 8 – GLOSSARY Chapter Highlight Description Definition of terms This is a new section of the LCP, which defines terms used throughout the document. APPENDIX A – NORTH COAST CORRIDOR PWP OVERLAY Chapter Highlight Description No Change No changes are proposed to the existing LCP Appendix A, which is incorporated as Appendix A in the draft LCP update. Appendix A consists of Carlsbad’s portion of the North Coast Corridor Public Works Plan/Transportation and Resource Enhancement Program (NCC PWP/TREP), which is a plan prepared by Caltrans and SANDAG to authorize transportation, community and resource enhancement along the I-5 and railroad corridor from La Jolla to Oceanside. APPENDIX B – CITY OF CARLSBAD SEA LEVEL RISE VULNERABILITY ASSESSMENT Chapter Highlight Description Informs policies in Chapter 7 Policies in Chapter 7 (Coastal Hazards) apply to lands located in sea level rise hazard areas identified in the City of Carlsbad Sea Level Rise Vulnerability Assessment. The vulnerability assessment includes maps that show the hazard areas (flood, inundation and erosion) that are projected in years 2050 and 2100. These hazard areas indicate when properties are subject to the sea level rise hazard policies in Chapter 7. This is part of the data People for Ponto has provided since 2017 to the Carlsbad City Council, Planning & Parks Commissions; and CA Coastal Commission regarding the Coastal 11-acre Planning Area F site at Ponto and LFMP Zone 9. For the 11-acre Planning Area F site at Ponto, Carlsbad’s Existing (since 1994) Local Coastal Program (p. 101) LUP currently states for Planning Area F: carries a Non-Residential Reserve (NRR) General Plan designation. Carlsbad’s Local Coastal Program 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 and Carlsbad Public Records Requests 2017-260, 261,and 262 confirm the City and Developer never did this! The City did not disclose to Citizens the existence of this Existing LCP LUP policy nor follow the LCP LUP policy during BOTH the Ponto Beachfront Village Vision Plan and General Plan Update planning processes. Those processes are fundamentally flawed. They are built on missing information and missing Citizen input. The image below was requested by former Carlsbad Councilman Michael Schumacher at the Oct 23, 2018 City Council meeting. It shows how the South Coastal Carlsbad (Ponto) is not served by a Park per the City’s adopted Parks Master Plan. It shows the nearest Poinsettia Park’s official Park Service Area relative to the Ponto/South Coastal Carlsbad Park gap and deficit. The blue dots are park locations and blue circle(s) show the City’s Adopted Park Service Areas. This data, from pages 87-88 of the City of Carlsbad Parks Master Plan. The City data below 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 above information (along with a lot of other relevant data) was never disclosed to Citizens nor discussed or considered relative to City planning efforts at Ponto. The LCPA Public Review should be extended to allow time for City Staff to provide Redline version of the Existing LCP and the corresponding Draft LCPA LUP changes, full public review of this Redline Draft, and open and honest Community-based planning Workshops for specific areas of vacant Coastal Land - including a Ponto specific LCPA Community Workshop(s) to resolve issues. www.peopleforponto.com From:Don Neu To:Planning Commission Cc:Ronald Kemp; Jennifer Jesser; Melissa Flores Subject:FW: Carlsbad LCPA Public Comment & Information to be provided the Planning Commission for the 10-20-19meeting on the LCPA Date:Tuesday, November 19, 2019 3:21:07 PM Attachments:Coastal South Carlsabd-Ponto Park gap-deficit map - LCP issues - reqested LCPA process.pdf Commissioners, Forwarded to you is an email and attachment from a resident. The information is provided as requested by the resident. Hard copies of the email and attachment will be provided at the meeting. The presentation tomorrow night is informational only and no action or recommendation is being requested from the Planning Commission at this time. Don Don Neu, AICP City Planner Planning Division 1635 Faraday Ave. Carlsbad, CA 92008 760-602-4601| don.neu@carlsbadca.gov PLEASE CALL OR EMAIL YOUR REQUEST FOR SUBMITTAL APPOINTMENT Phone: 760-602-2723 Email: devappt@carlsbadca.gov From: Lance Schulte [] Sent: Tuesday, November 19, 2019 2:33 PM To: Don Neu <Don.Neu@carlsbadca.gov>; Jennifer Jesser <Jennifer.Jesser@carlsbadca.gov> Cc: Council Internet Email <CityCouncil@carlsbadca.gov>; People for Ponto <info@peopleforponto.com>; Cort Hitchens <cort.hitchens@coastal.ca.gov>; Erin Prahler <Erin.Prahler@coastal.ca.gov>; Gabriel Buhr <gbuhr@coastal.ca.gov> Subject: Carlsbad LCPA Public Comment & Information to be provided the Planning Commission for the 10-20-19 meeting on the LCPA Don & Jennifer: Please include this email and the attached as Public Comment on the Draft LCPA LUP, and also can you please provide to the Planning Commission for their 11-20-19 meeting regarding the Draft LCPA LUP. Confirmation on both requests is appreciated. An Oct 31, 2019 I email I requested but never received (other than acknowledgement of receipt) an answer to the following request: “Regarding the LCPA public review process, I also wanted to see if citizens could be provided: 1. an editable version of the LCPA can be provided to facilitate cut/paste of text/images into public comments, and 2. if an editable side-by-side existing LCP text and proposed LCPA text file is available? This would allow citizens a clear understanding of the proposed changes to the existing LCP text and allow citizens to effectively compare and provide comments? These simple to provide tools would be very helpful to citizens wishing to understand and comment on the proposed Amendments to the current LCP.” Is it possible to provide Citizens and City Commissioners and the City Council of Staff’s Redline (editable side-by-side version of the Existing LCP with corresponding changes in the Proposed LCPA)? A Redline allows Citizens to directly compare the Existing LCP with the replacement LCPA. Producing a Redline is part of the staff work needed to create a Draft Amendment so should not be difficult to provide, and is typically provided as part of the Public Review process, so all Proposed LCP changes can be clearly compared and evaluated. Thanks, Lance Batiquitos Lagoon Foundation Preserve, Protect, and Enhance November 20, 2019 Chairwoman Carolyn Luna and Commissioners Planning Commission City of Carlsbad Faraday Administration Center 1633 Faraday Avenue Carlsbad, CA 92008 Subject: Planning Commission Department Report Agenda Item 1., LCPA 15-0007 (DEV 15- 0061) Overview of Local Coastal Program (LCP) Land Use Plan Update, Scheduled for Hearing Wednesday, November 20, 2019 at 6:00 PM., City Council Chambers Dear Chairwoman Luna and Commissioners: The Batiquitos Lagoon Foundation (BLF) is pleased to offer our comments for your consideration during the subject hearing. The draft Local Coastal Program Land Use Plan and Polices Amendment being reviewed and discussed represents the proposed change to the coastal plan and policies that will forever define our City's most precious and limited resource - our coast and coastal lands. The issues are so significant that a fully transparent document comparing the existing and proposed LCP Amendments (LCPA), coupled with sufficient t ime for citizens, City Commissions, business and community organizations, and the City Council to FULLY understand the existing LCP and proposed LCPA, and community workshops (not just presentations to citizens with a public comment period) to fully discuss the land use plan and policy implications on future generations. The BLF very strongly recommends that the Planning Commission provide a recommendation to the City Council for a Work Program for the proposed draft Local Coastal Program Amendment Work program that includes: 1. A red line Version of the Existing 2016/Proposed LCP land use Plan and Policies. 2. A series of facilitated citizen workshops on the major remaining vacant coastal land that still have outstanding citizen concerns and objections. Citizen workshops, when done properly, offer a valuable means to openly educate, discuss and work to consensus options in a very transparent fashion. t 7 L/ J I 7 '-f 1 P. 0 . Box 13~ Carlsbad, California 92013-~ • 760.931.0800 • www.batiqu itosfou ndation.org Page 2 3. Extend the public comment period 6-months to allow for citizen review of the red line version of the LCPA and for a series of facilitated citizen workshops to ensure document completeness and continuity. Our rationale for our 3 requests is: 1. There is no red line version on the existing/proposed LCP that allows anyone -citizen, Commissioner-Council member -to truly understand both the existing Coastal Plan and Policy and each proposed changes to it. Without this understanding, a truly informed processing of the proposed draft LCP Amendment is not possible by citizens or decision- makers. A redline ❖ersion of proposed comprehensive amendment of major land use planning and policy documents is normal. A redline version is a fundamental prerequisite for honest, open and accurate public review and comment on a document that will forever change Carlsbad and Carlsbad's coastal lands. We ask that you require staff provide a publicly accessible red line version of the existing 2016/Proposed Amendment to LCP Land Use Plan and Policies. 2. There is significant outstanding citizen concern about Carlsbad's coastal lands. Carlsbad is substantially developed and the little remaining vacant coastal land represents the last opportunity for Carlsbad to assure it has enough of the right Coastal Priory land uses to meet the needs of future Carlsbad citizens and visitors. The Proposed LCPA represents a Forever decision on our little re mailing vacant coastal land. Such an important decision should be based on a consensus decision by Carlsbad and its citizens. Get any of this wrong and it is a Forever mistake with no vacant land to fix it the future. The few significant-sized vacant coastal lands that need focused individual citizen workshops as part of the LCPA process are: • Strawberry Fields Area at Aqua Hedionda Lagoon • Encina Power Plant property near the Poinsettia Coaster Station • The Ponto area All three of these were/are subject to multiple lawsuits by citizens and organizations, and thus clearly represent areas that require more citizen evaluation and discussion to build true and lasting citizen consensus. 3. The Existing 2016 LCP is 150-pages long; the proposed draft LCPA is 360-pages long with numerous tables, exhibits and graphics that must be analyzed for completeness and consistency. Everyone -citizens, organizations, commissions, and the City Council needs more than 30-days to review the existing and proposed side-by-side to read/understand the proposed changes and formulate questions and comments. A 6- month extension to fully read, understand, and analyze the existing/proposed LCP and Page 3 also to provide time for the aforementioned citizen workshops is, in our opinion, well worth the time spent! Thank you in advance for your consideration and we very strongly recommend you support and recommend the 6-month extension and holding a facilitated series of public workshops. Please feel free to contact me at (760) 710-9644 (Mobile phone) or email at sandguist2@earthlink.net, or BLF Board Member, David Hill, (619) 540-1778 (Mobile phone) or email dashill4551@gmail.com, if you have any questions or require any further information. We look forward to hearing from you! Sincerely,(}. j i . Sandquist President and Board Member cc: Gary Barberio, Deputy City Manager, Community Services Scott Chadwick, City Manager Jennifer Jesser, Planner Elaine Lu key, Chief Operations Officer Mayor and City Council Don Neu, City Planner Erin Prahler, California Coastal Commission Melanie Saucier, Associate Planner