HomeMy WebLinkAbout2023-12-07; SANDAG 2021 Regional Plan Amendment / 2025 Regional Plan (Districts – All); Barberio, GaryTo the members of the:
CllYCOUNCIL
Date P-\112~A / CC ~ /
CML_ACM~M(3)L
December 7, 2023
Council Memorandum
To:
From:
Honorable Mayor Blackburn and Members of the City Council
Gary Barberio, Deputy City Manager, Community Services
Jeff Murphy, Community Development2-5ector
{city of
Carlsbad
Memo ID# 2023122
Via
Re:
Geoff Patnoe, Assistant City Manager ~
SAN DAG 2021 Regional Plan Amendment/2025 Regional Plan (Districts -All)
Th is memorandum provides information about the city's continuing involvement in the San Diego
Association of Governments' (SAN DAG) 2021 Regiona l Plan (RP) Amendment, the 2025 RP and an
update to the City Council Memorandum dated October 21, 2021 (Attachment A).
Background
RPs are long-range planning documents, usually 30 years, that define how regions will make future
transportation investments, based on regional goals, and estimates of avai lable funding. Federal
regulations require that long-range RPs be updated every four years.
The 2021 RP
As reported under the "Next Steps" section of the City Council Memorandum dated
October 21, 2021, the SAN DAG Board of Directors was scheduled to consider the 2021 RP and
associated Environmental Impact Report (EIR) at their December 10, 2021, meeting. After
substantial public testimony, the SAN DAG Board of Directors ultimately approved the 2021 RP as
recommended by SAN DAG staff, which failed to address the city's previously documented
concerns.
At the time of adoption, the 2021 RP included a regional Road User Charge (RUC)1 as one of the
region's projected funding sources. This item was strongly opposed by stakeholders and many
jurisdictions and, as a result, the SAN DAG Board of Directors directed SANDAG staff at the same
December 10, 2021, meeting to amend the approved 2021 RP and re move the RUC. The process of
amending the 2021 RP required that SAN DAG staff revise their environmental analysis, referred to
as a Supplemental Environmental Impact Report (SEIR), and follow a coordinated procedure
involving data analysis, interagency consultation, and community engagement.
1 The RUC is a "user pays system" where all drivers pay to maintain roads based on how much they drive rather than
how much gas they purchase. Under this system, all drivers share roadway maintenance and repair costs based on
what they use.
Community Services Branch
Community Development Department
1635 Faraday Avenue I Carlsbad, CA 92008 I 442-339-2600 t
Council Memo -SAN DAG 2021 Regional Plan Amendment/2025 Regional Plan {Districts -All)
December 7, 2023
Page 2
SAN DAG phased the public comment period for the 2021 RP Amendment in two parts: one for
review of the amended RP (which focused solely on the RUC) and a second for review of the SEIR.
City staff submitted a comment letter on the 2021 RP Amendment on August 8, 2023, (Attachment
B), and a second comment letter on the SEIR on August 28, 2023, (Attachment C). The comments
provided were largely a duplication of the comments city staff provided to SAN DAG staff in August
2021, which were not addressed when the SANDAG Board of Directors approved the 2021 RP.
All comments and responses (Attachment D) were presented to the SAN DAG Board of Directors at
their October 13, 2023, meeting where they voted to approve the 2021 RP Amendment and certify
the Final SEIR {Attachment E). The 2021 RP Amendment can be found at:
https://www.sandag.org/regional-plan/2021-regional-plan/amendment-to-2021-regional-plan
Refer to the "Discussion" section below for information on SAN DAG staff's response to city
comments.
The 2025 RP
In 2023, SAN DAG held several public outreach events and input opportunities as part of the 2025
RP preparation. In response to a Notice of Preparation2 issued by SAN DAG in January 2023, city
staff participated in public scoping meetings for the RP's Program Environmental Impact Report
(PEIR) and provided a letter commenting on what the PEIR should consider {Attachment F). The
provided comments mirror many of the comments included in both the 2021 RP and 2021 RP
Amendment comment letters.
In June 2023, city staff attended the 2025 RP kickoff meeting. The event provided an overview of
the 2025 RP and featured an open question and answer session. SANDAG staff discussed what had
been learned from the 2021 RP and what feedback they are planning to integrate into the
upcoming RP. SAN DAG staff indicated that after receiving comments from stakeholders and the
public, the agency will be focused on developing a variety of near and long-term proposals to
address access, safety, and affordability as well as ensuring that there is consistency between the
RP and local jurisdictions' General Plans. Recently, the SAN DAG Board of Directors at their
September 22, 2023, meeting provided direction to SAN DAG staff to develop a concept for the
2025 RP that does not include or reintroduce a regional RUC or any other per-mile charge.
For each RP, SAN DAG creates a new computer growth model that shows housing and population
forecasts and the envisioned regional transportation network in future years. For the 2025 RP,
SAN DAG is developing the "Series 15" growth model.
Discussion
The 2021 RP Amendment
City staff's full comments as submitted in the August 8, 2023, and August 28, 2023, comment
letter are provided in Attachments B and C, and SAN DAG staff's responses to the SEIR comments
are provided in Attachment D. But, in summary, the 2021 RP Amendment focused on the RUC
2 A Notice of Preparation (NOP) is a notice sent by the lead agency (in this case SAN DAG) to notify the public,
responsible agencies, and impacted jurisdictions that they plan to prepare an EIR for their project. This is early
notification required under the California Environmental Quality Act (CEQA).
Council Memo -SAN DAG 2021 Regiona l Plan Amendment/2025 Regional Plan (Districts-All)
December 7, 2023
Page 3
changes and did not address city staff's concerns with the original 2021 RP. These concerns
primarily related to two consequential components of the RP: 1) Inconsistencies between the RP's
land use patterns and the city's approved General Plan land uses; and 2) The suitability of certain
factors used in the RP's population growth forecasts. City staff also submitted comments related
to the technical sufficiency of the 2021 RP Amendment SEIR.
These comments notwithstanding, SAN DAG staff have stated that they will address these concerns
in the 2025 RP update, the development of which is on-going and is expected to be finalized within
the next two years.
The 2025 RP
Through much of 2023, SAN DAG staff has worked with local jurisdictions, including Carlsbad, to
obtain feedback on the data and assumptions that will be used in Series 15 growth model. This
process starts with land use factors and then considers transportation network factors. To date,
city staff have provided approximately 130 site-specific comments to address errors and potential
discrepancies related to land use, constraints, parcel buildout status, project locations and status,
and regulatory residential capacity. The process for land use data collection and verification
concluded on November 2, 2023, and city staff will continue to consult with SAN DAG as it develops
the data and will provide accurate information related to the city's General Plan. At this early
stage, city staff does not have any issues or concerns to raise to City Council's attention. More
information will become available as the regional model components are developed further and
outputs are made available for review.
It is worth noting that recent economic and demographic forecasting from the California
Department of Finance, which helps form the basis for the 2025 RP, forecasts a decline in
population starting in 2035 (Attachment G). This is a first in San Diego. Further, the 2021 RP
forecasts (Series 14) not only assumed growth, but substantial growth, throughout the forecast
time horizon of 2050. As such, the difference between the two models for the forecast year of
2050 varies by approximately 400,000 people. While the impacts of this change on the 2025 RP are
unclear, they are likely to be wide-ranging. Staff will communicate any pertinent information
about the RP's forecasts and land use and transportation network assumptions as they become
available later this winter and spring.
Next Steps
SAN DAG anticipates the following future actions related to the preparation of the 2025 RP:
• All of 2024/early 2025: Validation and evaluation of land use and transportation network
information provided by member agencies, development and evaluation of PEIR
alternatives, and preparation of environmental documentation for public review
• Spring/Summer 2025: Draft PEIR release for public review
• Fall 2025: Final PEIR and response to comments release for public review
• Winter 2025: SAN DAG Board considers approval of the final 2025 RP and PEIR
Council Memo -SAN DAG 2021 Regional Plan Amendment/2025 Regional Plan (Districts-All)
December 7, 2023
Page 4
As with past RP's, city staff will continue to facilitate interagency consultation by participating in
community engagement events and reviewing all project-related materials and recommend
changes at each milestone, as necessary, to ensure that re.gional goals, policies, and priorities are
fiscally responsible, sustainable, context-sensitive and collaborative.
Attachment: A. City Council Memorandum -Dated October 21, 2021
https://records.carlsbadca.gov/Weblink/DocView.aspx?id=5493674&dbid=0&r
epo=CityofCarlsbad
(Due to the size of Attachment A, a hard copy is on file in the Office of the
City Council, as reference)
B.City of Carlsbad letter dated August 8, 2023 (Amendment to the RP)
(Due to the size of Attachment B, a hardcopy is on file in the Office of the
City Council, as reference)
C.City of Carlsbad letter dated August 28, 2023 (Draft SEIR for Amendment to the
RP; Without Attachment)
D.SAN DAG Responses to the August 28, 2023, Carlsbad Draft SEIR comment letter
E.Adopted SAN DAG 2021 RP Amendment (Without Attachments)
F.City of Carlsbad letter dated March 6, 2023 (Notice of Preparation for an EIR)
G.SANDAG Series 15 Regional Growth Forecast Slides
cc: Scott Chadwick, City Manager
Cindie McMahon, City Attorney
Ron Kemp, Senior Assistant City Attorney
Gina Herrerra, Assistant City Attorney
Paz Gomez, Deputy City Manager, Public Works
Tom Frank, Transportation Director
Tina Ray, Communication & Engagement Director
Mike Strong, Assistant Community Development Director
Eric Lardy, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager
Jason Geldert, Engineering Manager
Robert Efird, Principal Planner
Scott Donnell, Senior Planner
Nicole Morrow, Assistant Planner
•
•
..
Attachment A
To the members of the:
CITY COUNCIL
Date ~CA /cc ./
cM _LAcM ✓ocM (3)L
Council Memorandum
Oct. 21, 2021
To:
From:
Via:
Honorable Mayor Hall and Members of the City Council
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Jeff Murphy, Community Development Director
Tom Frank, Transportation Director/C~gineer
{city of
Carlsbad
Memo ID# 2021195
Re:
Geoff Patnoe, Assistant City Manager~
SAN DAG 2021 Regional Transportation Plan Draft EIR Comment Letter (Districts -All)
This memorandum provides an update to a previous Council Memorandum dated Aug. 12, 2021
(Attachment A), with information on staff's recent comment letter (Attachment B) on the San
Diego Association of Governments (SAN DAG) draft Environmental Impact Report (EIR) proposed
for the 2021 Regional Transportation Plan (RTP), a long-term blueprint of the region's
transportation system.
Background
RTPs are long-range planning documents (usually 30 years) that define how regions will make
future transportation investments, based on regional goals and estimates of available funding.
Federal regulations require that long-range RTPs be updated every four years.
Beginning in 2016, SAN DAG began the process of updating its RTP for the San Diego region.
During development of thi_s draft RTP, an interim plan was adopted in 2019 to comply with
federal requirements but did not make substantial revisions to the previously adopted plan. This
new RTP, once adopted, will become the region's long-term plan to be implemented
incrementally through the Regional Transportation Improvement Program (RTIP).
Federal transportation legislation requires that regionwide transportation planning be
coordinated with local agencies and other stakeholders. It also implements requirements for
SAN DAG under Senate Bill 375 to reduce greenhouse gas targets adopted by the.California Air
Resources Board. An informational website, which includes the draft RTP and draft EIR, is
available at https://sdforward.com/.
Discussion
The draft 2021 RTP was the result of years of planning, data analysis and community engagement
where SAN DAG reimagined a more transformative transportation system, a sustainable pattern
of growth and development, and innovative demand and management strategies (referred to as
"5 big moves"). The draft 2021 RTP was circulated for public review and comment from
Community Services and Public Works Branches
Community Development and Transportation Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-4600 t
Council Memo -SAN DAG 2021 RTP Draft EIR Comment Letter (Districts -All)
Oct. 21, 2021
Page 2
May 28, 202t, to Aug. 6, 2021. The city provided comments to SAN DAG on Aug. 6, 2021, which
were provided to City Council in a Council Memorandum dated Aug. 12, 2021 (Attachment A).
On Aug. 27, 2021, SAN DAG released the draft EIR for the 2021 RTP for a 45-day public review
period. The draft EIR failed to address the issues raised in the city's Aug. 6, 2021 letter. In
response, the city provided a comment letter on Oct. 11, 2021 (Attachment B), that highlights all
of the same points as the previous letter, with the following additional comments/concerns:
1) Procedures related to CEQA, and the timeline that hinders public input since the
comments on the draft RTP were not responded to or incorporated into the draft EIR;
2) Evaluation of impacts to existing Land Use Plans, and the lack of a reasonable range of
alternatives that show what would occur if funding or land use assumptions are not
made; and,
3} Lack of sufficient detail in the chapters related to transportation, hazards, noise or other
planned growth in the draft EIR.
Next Steps
According to the latest correspondence with SAN DAG, the SAN DAG Board of Directors will be
asked to adopt the RTP on Dec. 10, 2021. City staff will continue to review all project-related
materials and recommend changes at each milestone as necessary to ensure that regional goals,
policies and priorities are fiscally responsible, safety-conscious, sustainable, context-sensitive and
collaborative.
Attachments: A. Council Memorandum dated Aug. 12, 2021
B. City of Carlsbad letter dated Oct. 11, 2021
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Laura Rocha, Deputy City Manager, Administrative Services
Robby Contreras, Assistant City Attorney
Ron Kemp, Assistant City Attorney
Mike Strong, Assistant Director of Community Development
Nathan Schmidt, Transportation Planning & Mobility Manager
Don Neu, City Planner
Eric Lardy, Principal Planner
To the members of the:
,,f.lT{ COUNCIL
Date~ CA X.. CC _L
CM ~ACM ...::k_ DCM (3) ~
Aug.12,2021
Council Memorandum
To: Honorable Mayor Hall and Mem of the City Council
From: Gary Barberio, Deputy City Ma ager, ommunity Services Branch
Paz Gomez, Deputy City Manag , Pu lie Works Branch
Jeff Murphy, Community Develop
Torn Frank, Transportation Directo /C~~~
Via: Geoff Patnoe, Assistant City Mana er
Attachment A
{cityof
Carlsbad
Memo ID #2021154
Re: Draft SAN DAG 2021 Regional Trans rtation Plan Comment Letter {Districts -All)
This memorandum provides information on staffs recent comment letter (Attachment A) on the
San Diego Association of Governments (SAN DAG) proposed 2021 Regional Transportation Plan
(RTP), a long-term blueprint of the region's transportation system.
Background
RTPs are long-range planning documents (usually 30 years) that define how regions will make
future transportation investments, based on regional goals and estimates of available funding.
Federal regulations require that long-range RTPs be updated every four years. Beginning in 2016,
SAN DAG began the process of updating its RTP for the San Diego region. During development of
this draft RTP, an interim plan was adopted in 2019 to comply with federal requirements but did
not make substantial revisions to the previously adopted plan. The new RTP plan, once adopted,
will become the region's long-term plan to be implemented incrementally through the Regional
Transportation Improvement Program (RTIP).
Federal transportation legislation requires that regionwide transportation planning be
coordinated with local agencies and other stakeholders. To that end, the draft 2021 RTP was
circulated for public review and comment from May 28, ·2021 to Aug. 6, 2021. Comments that
were received during the public review period will be reviewed and incorporated, as appropriate,
into the environmental analysis and/or final RTP. •
Discussion
The draft 2021 RTP was the result of years of planning, data analysis and community engagement
where SAN DAG reimagined a more transformative transportation system, a sustainable pattern
of growth and development, and innovative demand and management strategies, referred to as
"5 big moves". The draft 2021 RTP also implements requirements for SAN DAG under Senate Bill
375 to reduce greenhouse gas targets adopted by the California Air Resources Board. An
informational website, which includes the draft 2021 RTP plan, is available at
https :lj sdforwa rd. com/.
Community Services and Public Works Branches
Community Development and Transportation Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-4600 t
Council Memo -Draft SAN DAG 2021 RTP Comment Letter (Districts-All)
Aug. 12, 2021
Page 2
To facilitate interagency consultation, city staff from the Community Development and
Transportation Departments reviewed available project materials and transmitted comments in a
letter on Aug. 6, 2021 (Attachment A). Below is a summary of the major issues/concerns and
recommendation·s provided in staff's Aug. 6, 2021, comment letter:
1) The draft 2021 RTP inventories and assesses existing and future conditions in each city.
However, despite previously providing information to SAN DAG staff, the assumptions
they used in the d~aft 2021 RTP for "existing'' and "planned" land use and transportation
in the City of Carlsbad are not consistent with our adopted land use and transportation
pollcies (e.g., forecasted housing and roadway capacities). For example:
• SAN DAG projects over 700 new residential units will be constructed adjacent to
the McClellan-Palomar Airport Runway (residential use is not currently planned in
this area under the city's General Plan nor allowed by the Federal Aviation
Administration)
• Roughly 2,800 units are assumed to be developed on existing lands that are either
currently developed as hotel resorts or are dedicated open space
• SAN DAG assumes a declining population of roughly 2,300 persons in areas outside
of the city's local mobility hubs (most of the city) due to children who have grown
up and left their parents' homes. This assumption is being applied regionwide,
where they assume a reduction of approximately 85,000 persons throughout San
Diego
2) The land use assumptions, many of which are not substantially supported with facts, are
used to justify reduction targets in greenhouse gas emissions and vehicle miles travelled.
If their assumptions do not occur on the macro or micro level, which staff finds that it is
very likely that they will not be achieved, the draft 2021 RTP will adversely impact any
. public and private projects that are required to use the regional transportation models for
California Environmental Quality Act (CEQA) purposes (e.g., future General Plan
amendments, private development projects). Existing land use and transportation plans
and studies should serve as the starting point to best understand how new goals, policies
and priorities may target transportation investments and best increase real choices in
travel modes. It should be clear how the draft 2021 RTP expects these changes to occur,
instead of modeling a scenario constructed in order to meet reduction goals.
3) Since the transportation system provides access and mobility to the traveling public and
land uses impose demands on the system, the draft 2021 RTP should address if there are
changes in ridership behavior which may have occurred because of the COVID-19
pandemic.
4) The draft 2021 RTP needs to more extensively address the disruption that is expected
from automated/shared vehicle technologies and conduct an alternatives analysis. For
example, autonomous vehicles are expected to have a huge impact on mobility demands
Council Memo -Draft SAN DAG 2021 RTP Comment Letter (Districts -All)
Aug. 12, 2021
Page 3
in the future, but the draft 2021 RTP does not provide enough analysis on how it will
impact future transpC?rtation needs.
5) Emphasis is being placed on regional rail improvements for a high-speed rail system,
including improvements to the LOSSAN Rail Corridor. More information is ne~ded on the
anticipated alignment, segments and cost estimates. The portion of the corridor in the
City of Carlsbad will likely need to 'be a special study area.
6) The appendix in the draft 2021 RTP only lists potential projects; it does not show
potential alignments, right of way needed or coordination with specific agencies . More
information needs to be provided in the draft 2021 RTP on project implementation
phasing (both short-range and long-range improvements), unfunded projects and various
. funding mechanisms that can bridge the unfunded gaps.
7) The draft 2021 RTP was released without the benefit of availability of the Draft
Environmental Impact Report (Draft EIR), which staff were told would be released later
this summer. The quick release of the Draft EIR following the due date of comments for
the draft 2021 RTP makes it practically impossible to make changes to the Dra~ EIR
before it is released. SAN DAG should clarify how these comments will be addressed in the
Draft EIR required topic areas of CEQA.
Next Steps
SAN DAG reports that the Draft EIR will be released in summer 2021. According to the work
program schedule, the SAN DAG Board of Directors will be asked to adopt the draft RTP in late
2021. City staff will continue to review all project-related materials and recommend changes at
each milestone as necessary to ensure that regional goals, policies and priorities are fiscally
responsible, safety-conscious, sustainable, context-sensitive and collaborative.
Attachment: A. City of Carlsbad letter dated Aug. 6, 2021
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Laura Rocha, Deputy City Manager, Administrative Services
Robby Contreras, Assist~nt City Attorney
Ron Kemp, Assistant City Attorney
Mike Strong, Assistant Director of Community Development
Nathan Schmidt, Transportation Planning & Mobility Manager .
Don Neu, City Planner
Eric Lardy, Principal Planner
Oct. 11, 2021
SANAG Regional Plan EIR
San Diego Association of Governments
401 B Street, Suite 800
San Diego CA 92101
C/O Kirsten Uchitel, Associate Planner.
Via: _RegionalPlanEIR@sandag.org
Attachment B
(city of
Carlsbad
RE: City of Carlsbad Comments on Draft Environmental Impact Report for the 2021 Regional Plan
Dear Ms. Uchitel:
The City of Carlsbad ("city") appreciates the opportunity to provide comments on the draft Program
Environmental Impact Report ("PEIR") for the 2021 Regional Plan ("Plan"), dated Aug. 27, 2021. This is
an important plan for the region and will guide the next phase of growth for the member agencies of the
San Diego Association of Governments ("SAN DAG"), including the city. An effectively designed and
implemented regional transportation plan would help ensure improved transportation options for area
residents, businesses and other community members, as well as meaningful reductions in greenhouse
gas ("GHG") emissions and improved quality of life as we grow our communities.
The city previously submitted comments on the Plan to SANDAG staff on August 6, 2021 (Attachment 1),
expressing multiple concerns about the Plan, its implementation and its potential impacts on the
environment. Additionally, the city sent a follow up letter on September 30, 2021 (Attachment 2), to
clarify the city does not wish to remove El Camino Real (project CB32) from the Regional Arterials
Project List. Copies of the city's prior letters are included here as Attachment 1 and Attachment 2,
respectively. Both letters are incorporated herein by this reference as additional comments on the
adequacy of the PEIR and should be included in the administrative record of SANDAG's proceedings
concerning the Plan and the PEIR.
The California Environmental Quality Act ("CEQA") is intended "to afford the fullest possible protection
to the environment within the reasonable scope of the statutory language." (Friends of Mammoth v.
Board of Supervisors (1972) 8 Cal.App.3d 247, 259.) With narrow exceptions, CEQA requires an EIR
whenever a public agency proposes to approve or to carry out a project or activity that may have a
significant effect on the environment. (CEQA Guidelines§ 15002(f).) The basic purpose of an EIR is to
provide public agencies and the public in general with detailed information about the effect that a
proposed project or activity is likely to have on the environment and to identify ways in which the
significant effects might be reduced or avoided. (Public Resources Code § 21061; CEQA Guidelines§
15003.) The EIR and its associated process create layers of accountability and must "reflect a good faith
effort at full disclosure." (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal. App. 3d 692, 712,
citing CEQA Guidelines§ 15151.) The EIR process must provide meaningful information for an
environmental assessment so that the public will know the basis on which decisions are made on a
proposed project or activity and can respond accordingly to action with which it disagrees.
Transportation & Community Development Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2710 t
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 2
In this case, the city seeks to ensure that SAN DAG prepares an environmental document that is
adequate, complete and ft.illy discloses the potential significant adverse effects of the Plan. Further, to
implement the principles of CEQA, SANDAG should not truncate the requisite cumulative impact analysis
(CEQA Guidelines section 15168(b)(2)), use improper baselines (CEQA Guidelines section 15152), or
foreclose the consideration of any alternative or mitigation measure that would ordinarily be part of
CEQA review of a regional plan (C:EQA Guidelines section 15004(b)(2)(B)). If the EIR fails to provide
decision-makers and the public with all of the relevant information regarding a project that is necessary
for informed decision-making and public participation, the environmental document is flawed and
deficient and the agency's decision will be set aside (Kings County Farm Bureau v. City of Hanford, supra,
221 Cal. App. 3d at p. 712).
CEQA prescribes review procedures a public agency must follow before approving or carrying out
proposed projects. Those procedures emphasize the importance of public participation in the CEQA
process, including mandatory opportunities for public review and comment and the lead agency's
obligation to provide meaningful responses to comments received. A Notice of Preparation (NOP) was
-issued on November 14, 2016 and a public scoping meeting was held on December 8, 2016. Although
the early consultation with affected agencies and organizations was appreciated, and a necessary
procedural step per CEQA Guidelines section 15082, SAN DAG subsequently made a material change in
the_ scope of the project to encompass the vision of 5 Big Moves, without providing an opportunity for
additional scoping and consultation with the public and affected agencies. SANDAG failed to re-engage
the public and affected agencies to provide them with sufficient information regarding the revised Plan
and its potential environmental effects to enable them to make a meaningful response about the scope
and content of the anticipated environmental work. Due to this procedural error, the public and
affected agencies have been denied the opportunity to provide SAN DAG with specific detail about the
significant environmental issues and reasonable alternatives and mitigation measures that needed to be
explored in the draft PEIR, early enough in the CEQA process for SAN DAG to have considered their
comments in preparing the draft PEIR. In addition, SANDAG failed to comply with CEQA by conducting
the scoping and public review process for the Plan and the draft PEIR separately, which has resulted in a
disconnected, piecemeal and rushed process in which previous comments on the Plan were not
responded to or incorporated into the draft PEIR.
The disjointed and rushed process for public participation continues to the present. According to
SAN DAG staff, responses to comments on the Plan will be published at the end of October, several
weeks after public and agency comments are due on the draft PEIR. Thus, the public and affected
agencies like the city must submit comments on the PEIR without knowing whether or how SANDAG has
responded to previous comments on the Plan. SAN DAG has already indicated that the SANDAG Board
will review and consider the Plan and the Final PEIR in December 2021. Thus, there appears to be
insufficient time for SANDAG to evaluate comments received on the draft PEIR; prepare meaningful
responses and make those responses available as required by CEQA Guidelines sections 15087 and
15088. As such, SAN DAG is foreclosing on a "meaningful public participation process" and subjecting
itself to a claim that SAN DAG is prejudicing the outcome of the environmental review process by
ensuring there is little opportunity for public comments to influence the Plan's program and design.
("Enviro.nmental review derives its vitality from public participation" (Ocean View Estates Homeowners
Assn. V. Montecito Water Dist. (2004) 116 Cal. App. 4th 396, 400.) If the issues that were addressed in
the city's August 6, 2021 comment letter on the Plan (Attachment 1) are not addressed in the PEIR, the
PEIR will be insufficient as an informative document and it will reduce the validity and efficacy o.f the
Plan, including its use of faulty assumptions r!=!garding land use and population growth to comply with
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 3
state and federal mandates, such as the Sustainable Communities Strategy and greenhouse gas
reduction targets. These faulty assumptions misrepresent the vital land use-transportation planning
connections and do nothing to reduce greenhouse gasses and will instead result in unplanned increases
to traffic, greenhouse gases, and result in increased housing unaffordability.
While the city supports the main concepts of the Vision in the Regional Plan, the 5 Big Moves, there
needs to be an adequate analysis on how the Plan will be implemented, and what will occur if there are
changes to the projected growth, technology, and/or state law impacting existing conditions. The city's
residents, businesses, and property owners would have benefited from more time to read the details in
the Plan and draft EIR. After years of public outreach that lacked detail of the assumptions and projects
proposed in the Plan, the Plan is riow being rushed to decision by the SANDAG Board of Directors by the
end of 2021. This is a procedural error and not adequate for the purposes of CEQA.
The city also restates its prior request that the following language be added to the Regional Plan for
additional clarification on land use authority: "Land use authority is reserved to local jurisdictions
because they are best positioned to effectively implement the objectives outlined in the Plan through
understanding of the unique needs of their communities and geographies." This language is needed to
clarify that land use authority rests with the local jurisdiction. Although this principle should be obvious,
the inconsistencies between the Plan and the city's General Plan discussed below suggest that it has
been ignored. Further the draft EIR should identify how the Program EIR will be utilized for streamlining
with later activities and/or for use with subsequent El Rs and negative declarations in compliance with
CEQA Guidelines section 15168(c) and (d).
In addition, the dty has the following substantive comments on the adequacy of the PEIR:
1. The PEIR fails to disclose the Plan's inconsistencies with the Carlsbad General Plan and to analyze
the related potential environmental impacts. The Legislature has declared a policy "to protect
California's land resource, to ensure its preservation and use in ways which are economically and
socially desirable in an attempt to improve the quality of life in California." (Gov. Code§ 65030.) To
further this policy, each of the state's cities and counties is required to adopt a comprehensive, long-
term general plan for the physical development of that city or county. (Gov. Code§ 65300.)
Accordingly, the city adopted a General Plan in compliance with state law and most recently
updated it in 2015. the city's General Plan "sets forth land use compatibility policies applicable to
future development in the vicinity." These policies are designed to ensure that future land uses in
the surrounding area will be compatible with the realistically foreseeable activity in the city.
Growth projections for the region are based on population, vehicle trends and land use plans
developed by the cities and the County of San Diego ("County'') as part of their general plans. Many
different regional documents rely on the same information to develop water demand projections,
air quality performance standards, emission inventories, and emission reductions. The Plan would
result in an increase in residential land use resulting in corresponding increases in indirect and
cumulative vehicle miles traveled ("VMr'), GHG emissions and air pollutant emissions, as well as
inconsistencies with RAQS, SIP, and regional traffic modeling. This is not disclosed in the draft PEIR.
CEQA Guidelines section 15125(a) requires EIRs to contain a description of the physical
. environmental conditions in the vicinity of the project, as they exist at the time the NOP is
published, or if no NOP is published, at the time environmental analysis is commenced, from both a
local and regional perspective. Existing general plans, including their Land Use Elements, should
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page4
. .
have been utilized for this baseline analysis and to derive future population and housing estimates.
The draft PEIR is legally inadequate because it fails to plainly identify the specific assumptions
included in its baseline for land use. (San Joaquin Rescue Center v. County of Merced (2007) 149 Cal.
App. 4th 645.)
In the draft PEIR, SAN DAG should have evaluated and clearly articulated the Plan's potential impacts
on land use. Instead, the PEIR states that: "The forecasted development of the proposed Plan is
based on the Series 14 Regional Growth Forecast SCS land use pattern, which is, in turn, based on
the adopted general plans of the cities and County of San Diego and on the most recent planning
assumptions, considering local general plans .and other factors, as required by SB 375." This
statement is incorrect. The Plan is inconsistent with _the city's General Plan because it proposes
residential land uses where such uses are not authorized by the General Plan. The PEIR appears to
ignore this inconsistency in concluding there will be le~s than significant impacts for the years 2025,
2035 or 2050.
The city has two mobility hubs in the proposed Plan and draft PEIR: McClellan-Palomar Airport, the
fifth largest employment center in the region; and Carlsbad State Beach and Carlsbad Village as ''Tier
3 and Tier 4" employment centers. Attachment 1 shows a summary of the Mobility Hubs and
housing units assumed in the Series 14 Growth Forecast for the year 2050. The assumptions in the
updated Series 14 Growth Fprecast contain inconsistencies with respect to at least three locations in
which density is shown to be inconsistent with the city's General Plan, the Airport Land Use
Compatibility Plan and good planning principles. These three problematic areas are:
a. 736 units on parcels immediately adjacent to the McClellan-Palomar Airport runway. The
location of the airport within this mobility hub was shared with SANDAG staff multiple times
at workshops. This is inconsistent with the regulations provided by the San Diego County
Regional Airport Authority and conflicts with standard planning principles for siting housing
away from hazards;
b. 2,755 units on existing developed resort properties and open space dedicated lands
adjacent to Legoland; and
c. 65 units in a preserved open space area.
The Plan proposes residential uses in areas which are not designated for such uses in the city's
General Plan. This inconsistency results in potential sigoificant impacts with respect to land use,
public safety and noise. (See CEQA Guidelines, Appendix G, §§ IX(e), Xl(b), Xlll(c).) Because
residential use is not authorized in those locations in the city's General Plan, the Plan's assumption
that residential use will occur there results in an overstatement of the extent to which other
impacts, such as those associated with VMT, GHG an·d other pollutant emissions, will be reduced
and understates those potential impacts of the Plan. The only meaningful evaluation of the Plan's
potential impacts is a brief qualitative description of the City of San Diego's community plan process.
However, the PEIR does not meaningfully address the inconsistency with the general plans of the
other 17 member jurisdictions, which if not implementing this plan will cause a significant
environmental impact due to the conflict with any land use plan, policy or regulation adopted for
the purpose of avoiding or mitigating an environmental effect.
As noted above, the Land Use, Hazards and Noise sections of the draft PEIR must include an
evaluation of the inconsistencies with local land use plans. Multiple areas in Carlsbad are controlled
as to their use and activity density and intensity through their spatial association with the McClellan-
Palomar Airport. The McClellan-Palomar Airport is defined by the Federal Aviation Administration I l
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 5
("FAA") as a commercial service airport that, in addition to private aircraft, has regularly scheduled
commercial flights. The McClellan-Palomar Airport Land Use Compatibility Plan ("ALUCP") is
prepared according to FAA requirements and adopted by the San Diego County Regional Airport
Authority acting as the Airport Land Use Commission for the County of San Diego. Further detail on
this is included in the city's August 6, 2021 comment letter (Attachment 1).
2. Additionally, looking at data provided by SANDAG, it is now clear why the citywide numbers only
show moderate increases in population. Our analysis has shown that there is an assumed reduction
of population by 2,310 persons in the areas within the city but outside of the mobility hubs. This is
likely due to assumed reductions in persons per household over time, but SAN DAG should clarify the
source' and reasonableness of this assumption. If housing is provided outside the Mobility Hubs
consistent with these areas, is it still reasonable to assume persons per household will be reduced in
2050? The PEIR also rails to consider the effect of Senate Bill 9 ("SB 9"), which will allow duplex or
quadplex development in any area previously zoned for single family use. As a result of the new law,
hou~ing growth would be expected to increase in single-family residential areas. By failing to take
into account the effect on population growth of developing additional housing outside the Mobility
Hubs, the PEIR results once again in an u~derstatement of the Plan's potential impacts and an
overstatement of the Plan's beneficial effects on VMT, GHG and other pollutant emissions.
Furthermore, this reduction in population is not limited to the city of Carlsbad. There is an
approximately 85,000 person reduction in population assumed outside of mobility hubs regionwide.
SAN DAG nee_ds to address if that is a reasonable assumption and if this will result in other impacts to
public and private projects that will rely on this growth forecast, and the associated Activity Based
Model (2+) to project future impacts to transportation, GHG, air quality and noise.
3. A project will normally have a significant effect on the environment if it will conflict with_ adopted
environmental plans and goals of the community where it is located (see Appendix G to the CEQA
Guidelines). The facts and analysis in the PEIR don't support a finding of less than significant impact
for consistency with general plans beyond the year 2025, where at least there is a correlation,
intentional or otherwise, with the current Regional Housing Needs Allocation that each jurisdiction
is planning for. Beyond 2025, the assumptions in the land use chapter have had a more in-depth
analysis, and if not substantiated, should be designated as significant and unavoidable. If there are
impacts determined to be significant and unavoidable, mitigation measures should be designed to
lessen the impact; the current draft EIR includes no related mitigation measures. In Citizens for a
Sustainable Treasure Island v. City and County of San Francisco (2014) 227 Cal. App. 4th 1036, the
Court of Appeal for the First Appellate District held that an EIR must satisfy the substantial evidence
standard of review as to all of the required elements of an EIR; address the environmental impacts
of the proposed project to a degree of specificity consistent with the underlying activity being
approved; and properly allow for supplemental review that may be necessary in the future.
Therefore, the draft PEIR must be revised to explain the nature and magnitude of a proposed
project or activity with respect to land use and planning checklist criteria (Appendix G to the CEQA
Guidelines).
4. Since these projections are related to the GHG reductions and compliance with Senate Bill 375, it
puts the entire evaluation and basis for compliance into question. If these assumptions are not
made, it will have significant impacts to the GHG emissions, and the metric tons of annual emissions
that comprise over 40 percent of the regional total. As currently drafted, the Plan's land use
assumptions related to GHG contributions do not comply with other specific state and federal
mandates including SB 375, which achieves targets set by the California Air Resources Board and
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 6
compliance with federal civil rights (Title VI) requirements, environmental justice considerations, air
quality conformity, and public participation. Please refer to Attachment 1 for more background
discussion about the city's concerns regarding the technical methodology used to estimate GHG
emissions from the sustainable communities strategy. Pursuant to CEOA, the environmental
baseline for GHG emissions shall be established based upon the physical conditions at the project
site at the time of the NOP, or no NOP, at the time the environmental analysis commenced. The
environmental setting requirements of CEQA Guidelines section 15125, which directs SAN DAG to
utilize existing general plan land use maps, helps establish the basis for compliance with
Government Code section 65080(b)(2)(H) and (J) as those land use map regulations existed at the
time of the NOP or when the environmental analysis commenced; and should have been used as the
most recent planning assumptions to develop per capital passenger vehicle-related greenhouse gas
emissions targets for 2035 set by the California Air Resources Board.
5. The Transportation chapter of the draft EIR lacks sufficient detail and explanation to adequately
understand and provide comment_on the transportation analysis that was used to determine the
project impacts and related performance metrics such as Average Daily Trips (ADT), VMT and travel
mode share. }"he following comments are intended to provide this additional information and a
better understanding of the identified transportation impacts:
a. The analysis methodology used for the Transportation chapter does not provide a description
of how the ABM2+ analysis outputs such as Average Daily Trips (ADT), Mode Share, and
Vehicle .Miles Traveled (VMT) are calculated for each of the travel modes. Without this
information, it is difficult to understand how the transportation network improvements
impact these analysis metrics for future year conditions and for consideration of potential
project mitigations.
b. Section 4.16.4 "Transportation Environmental Impact and Mitigation Measures" should
provide a description ofthe proposed transportation projects for each travel mode by horizon
year with ~eference to Appendix B of the EIR document.
c. In order to directly compare the project list with the project impacts found in section 4.16.4, it
is recommended to reorganize the tables found in Appendix B by travel mode and horizon
year with indication of project mileage
d. Does the EIR consider the long term or permanent impact of COVID-19 on travel behavior
patterns throughout the region? Was the ABM2+ model adjusted to account for changes in
travel behavior due to the COVID-19 pandemic? Were additional adjustments made to key
mode choice variables such as rates for tele-work, vehiclE;? ownership, and traveler sensitivity
to use transit or carpool as a result of these travel behavior changes?
e. As mentioned above, significant issues need to be addressed in the Plan which should also be
addressed in the EIR including:
i. Grade separation in Carlsbad from Cannon Road to the northern border.
ii. The impacts of implementing roundabouts in the Complete Corridors.
iii. Alternative analysis for moving the grade separated 110mph transit leap commuter rail
to the east thereby reducing all the negative impacts of having the current North
·county Transit District (NCTD) alignment running along the sensitive coastline, lagoons
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 7
and coastal open space, and coastal village_ land use that promote mobility and look to
reduce bifurcation issues caused by the current at grade NCTD alignment. The
potential bifurcation issues also constitute a potential significant impact on land use in
that the Plan will exacerbate the alignment's effect on dividing the established
downtown Carlsbad community.
6. The alternatives analysis does not describe a rarige of reasonable alternatives to the project because
it does not include an analysis of an alternative that evaluates what will occur if the faulty land use,
and therefore transportation, assumptions do not occur. The alternatives are constructed to reduce
impacts through even more focused growth in Mobility Hubs and through increased value pricing
and revenue generation. While it may be true t.hese would reduce impacts, it does not provide
policy makers or members of the public a reasonable range of alternatives as required by CEQA.
Additionally, due to the aforementioned SB 9 being signed by the Governor, the reduction in
population assumed in suburban areas outside of the mobility hubs is both inconsistent with reality
a·nd with planning principles required by the California Department of Housing and Comml!nity
Development to not concentrate all future growth in certain locations. CEQA and the CEQA
Guidelines require that an EIR describe all reasonable alternatives to the project and any feasible
mitigation measures (Laurel Heights Improvement Assn. v. Regents of University of California (1988)
47 Cal. 3d 400,404). Because the draft PEIR does not discuss future land use conflicts with
applicable general plans, it fails to disclose ways to reduce or eliminate the environmental impacts
of the project and to respond to the major environmental issues identified during the planning
process (as a project alternative or as a mitigation measure) pursuant to Public Resources Code
section 21002 (see Friends of the Old Trees v. Department of Forestry & Fire Protection ( 1997) 52 Cal.
App. 4th 1383). The draft PEI R's analysis of the project alternatives and mitigation measures is
incomplete and, therefore, inadequate.
Section 15126 of the CEQA Guidelines requires that all aspects of a project must be considered
when evaluating its impact on the environment, including planning, acquisition, development, and
operation. The implementation and challenges to fund the Plan have not been appropriately
discussed. One of the project alternatives should accommodate transportation investments that can
be reasonably funded within the horizon of the plan under the current ("known") funding
mechanisms. Because the draft EIR does not discuss a financially constrained alternative, the
analysis of the project alternatives and mitigation measures is incomplete, and therefore,
inadequate.
7. Where regional planning processes have not resulted in the adoption of plans or regulations relating
to the environment, CEQA requires public agencies to engage in an analysis of the impacts of the
proposed project on the environment. (Public Resources Code§§ 21000; 21002.1; 21003.l(b);
21080(d); 21081; 21082.2(a).) Although there is a general analysis of projected growth in the region,
there is a lack of detail with respect to growth inducement or reasonably foreseeable future projects
implementing Public Resources Code section 21155 -21155.4 (CEQA streamlining for SCS
consistency) and/or other reasonably foreseeable development that may result. The provision or
improvement of transportation infrastructure, utilities, yv-ater and sewer service to an area can
induce growth by removing impediments to developmeht. Once services are extended or improved
in an area, economic incentives for development exist. The basic elements and principles of the Plan
have been designed to facilitate future smart growth and concentrate population growth in areas
that would be efficiently served by transportation facilities. The smart growth concept is the basis
City of Carlsbad Comments on Draft l:nvironmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 8
for the framework for prioritizing public la'nd use and transportation investments in the region. The
smart growth concept identifies areas where smart growth development exists or could be built and
provides a basis for planning transportation facilities and transit services in the proposed Plan.
Smart growth areas identified receive prioritized infrastructure investments and transit services to
support smart growth. This carries true to those smart growth areas that are accommodated by
existing general plans, and for other areas that are not covered by existing general plans. CEQA
requires that an EIR discuss the ways in which the proposed project could foster economic or
population growth or the construction of additional housing, -either directly or indirectly, in the
environment surrounding the project. CEQA requires this discussion to include ways in which a
project would remove obstacles to population growth or encourage and facilitate other activities
that could significantly affect the environment (CEQA Guidelines section 15126.2(d)). The level of •
detail should reflect the level contained in the plan or plan element being considered (Rio Vista
Farm Bureau Center v. County of Solano (1992) 5 Cal.App.4th 351), inclusive of new smart growth
areas as designated.
City staff looks forward to working with SANDAG on improving mobility and land use access in the region
and building sustainable, equitable and healthy modes of transportation. We appreciate the opportunity
to comment on the Plan that will help the region realize these goals. While at the same time, city staff
also looks forward to helping SAN DAG advance a legally adequate PEIR to support the disclosure and
decision-making process. Since the major premise of CEQA is that it "be interpreted in such manner as
to afford the fullest possible protection to the environment within the reasonable scope of the statutory
language" (Friends of Mammoth v. Board of Supervisors, supra, 247, 259), SAN DAG should take all action
necessary to alert the decision-makers and the public to the environmental changes associated with the
project (County of Inyo v. Yorty (1973) 32 Cal. App. 3d 795, 810). There is no shortcut to CEQA-the EIR
process protects not only the environment by also informed self-government (Laurel Heights
Improvement Assn. v. Regents of University of California, supra, 376, 392). The SAN DAG Board must
certify that the final PEIR has been completed in compliance with CEQA and that it considered all of the
information in the final EIR before approving or disapproving the project. As of this writing, the draft
PEIR is not in compliance with CEQA.
If you have any questions related to comments on the transportation network, please contact Tom
Frank, Transportation Director/City Engineer, at Tom.Frank@carlsbadca.gov or, if you need additional
information related to comments on the land use assumptions, please contact Eric Lardy, Principal
Planner, at Eric.Lardy@carlsbadca.gov.
JEFF MURPHY
Community Development Director
TOM FRANK
Transportation Director/City Engineer
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan
Oct. 11, 2021
Page 9
Attachments:
1. City of Carlsbad Comment Letter on Draft Regional Plan (Aug. 6, 2021)
2. City of Carlsbad Comment Letter-Regional Arterials· (Sept. 30, 2021)
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Assistant City Attorney
Robby Contreras, Assistant City Attorney .
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Director, Community Development
Don Neu, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager
Jason Geldert, Engineering Manager
Eric Lardy, Principal Planner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Aug.6,2021
San Diego Association of Gov~rnments
401 B Street, Suite 800
San Diego CA 92101
Via : SD Forward@sandag.org
RE: City of Carlsbad Comments on Draft 2021 Regional Plan
To Whom it May Concern,
ATTACHMENT 1
{cityof
Carlsbad
The City of Carlsbad appreciates the opportunity to provide comments on the draft 2021 Regional Plan
("Plan"). This is an important plan for this region and will guide the next phase of growth for the
member agencies of the San Diego Association of Governments ("SAN DAG"). An effectively designed
and implemented regional transportation plan would help ensure improved transportation options for
area residents, businesses and other community members; meaningful reductions in greenhouse gas
("GHG") emissions; and improved quality of life as we grow our communities.
The City of Carlsbad ("city") is submitting comments based on the policies, projects, programs and other
improvements included in•the Plan. Our agency's comment letter is divided into two sections. The first
section seeks clarity and other considerations that pertain to our agency's review of the Plan. The
second section identifies the city's preliminary co.mments and recommendations.
Implementing the regional transportation network outlined in the Plan requires municipalities to
support the regional vision and deliver on local Infrastructure and services like the priority bus routes,
local bus services, and pedestrian and cycling connections to major transit infrastructure. These
components, which are delivered by municipalities, are essential to creating a coherent and
comprehensive local transportation network that feeds into regional services. For that reason, an
effective public review of the Plan should involve a transparent and thorough process for identifying and
evaluating potential hazards, physical changes to the environment and indirect (off-site and cumulative)
impacts that might result from implementation activities that may reasonably occur with the Plan.
The city's residents, businesses and other community members will greatly benefit from the
Involvement and technical assistance from the prospective Draft Environmental Impact Report ("EIR").
Therefore, what follows in this correspondence represents our agency's preliminary comments and
recommendations. The city reserves the right to add, amend, change or replace comments and
recommendations based on additional review and understanding of the Plan and the environmental
analysis provided under the California Environmental Quality Act ("CEOA'').
The city thanks SAN DAG staff for meeting with city staff on Aug. 2, 2021, to discuss some of these
comments in advance of this letter. Following that meeting, SAN DAG provided language that they may
recommend adding to the Regional Plan for additional clarification on land use authority. The language
is, "Land use authority is reserved to local jurisdictions because they are best positioned to effectively
implementthe objectives outlined in the Plan through understanding of the unique needs of their
communities and geographies." This language will be helpful to clarify that land use authority rests with
Transportation & Community Development Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2710 t
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page 2
the local jurisdiction. The city still offers the following comments with the intent to support
development of a defensible and realistic regional plan.
SECTION 1: CLARITY AND OTHER CONSIDERATIONS
City staff have attended the series of workshops that SANDAG hosted during the public review period,
and respectfully starts this section with several questions related to the process of the Plan and the
Draft EIR. By way of introduction, a jurisdiction's General Plan, such as the city's General Plan, identifies
the expected population of the city and any lands outside of the city limits but within their Sphere of
Influence where future growth is anticipated to occur. The city's General Plan identifies the subject area
adjacent to the McClellan~Palomar Airport for development under the designation for limited and light
industrial use.
For future land use planning, land use assumptions must reasonably proxy and be generally consistent
with local planning standards and programs, to be considered growth accommodating rather than
growth inducing. SAN DAG has the authority under Government Code Section 65584 to determine
existing and projected housing needs, as well as the share of housing needs to be allocated to cities and
counties, but it is unclear if SAN DAG has jurisdiction to allocate new housing growth to areas in a
manner not consistent with Government Code Section 65584. Attachment 1 includes additional
information on the applicable Government Code and standards. Therefore, and as indicated above, the
build-out of properties within the Business Park and flight activity zone must be done in accordance with
the city's General Plan Land Use Diagram, as amended, in accordance with city approval.
The initial questions on the planning process associated with developing the Plan are provided below:
1. The SANDAG website states, ''The SANDAG Sustainable Communities Strategy and Final EIR from
its 2015 Regional Plan will remain valid and in compliance for purposes of state funding
eligibility and other state and federal consistency purposes until the SAN DAG Board of Directors
adopts a new Regional Plan and EIR, provided those actions are completed by the end of
December 2021." SAN DAG needs to clarify how the Draft EIR, Response to Comments and
Adoption will be completed this year and what will occur if they are not completed by the end of
this year. Additionally, please clarify when the Draft EIR will be available; it is difficult to
completely assess the full impacts of this plan when the public review of the documents is
piecemealed.
a. SANDAG should clarify how public comments on the Plan are going to be addressed in
the Draft EIR prior to its release.
b. In the Draft EIR, SAN DAG needs to clearly articulate the impacts to land use and if the
Plan will cause a significant environmental impact due to a conflict with any land use
plan, policy or regulation adopted for the purpose of avoiding or mitigating an
environmental effect. _Appendix F: Regional Growth Forecast and Sustainable
Communities Strategy Land Use Pattern appears to be inconsistent with the city's
General Plan and rezone program to accommodate the Regional Housing Needs
Assessment, as well as the general plans of other jurisdictions such as the cities of
Coronado, Del Mar and the County of San Diego. The Draft EIR should clarify how
implementation of this Plan can occur if those changes are not made.
City of Carlsbad Comments on Draft 2021 Regional_ Plan
Aug. 6, 2021
Page 3
2. The city has three mobility hubs, associated with the Employment Centers Published supporting
the SANDAG Regional Plan.1 McClellan-Palomar Airport is the fifth largest employment center in
the region, with Carlsbad State Beach and Carlsbad Village as "Tier 3 and Tier 4" employment
centers. The city thanks SAN DAG for providing data for analysis to determine impacts and
provide for accurate comments on the Plan. Attachment 2 shows a summary of the Mobility
Hubs and housing units assumed in the Series 14 Growth Forecast for the year 2050. In
summary:
a. The assumptions in the updated Series 14 Growth Forecast contain inconsistencies with
the city's General Plan. The Carlsbad Palomar Major Employment Mobility Hub does
include increases in density beyond what the citywide numbers appear to show when
they are looked at in more detail.
I. There are three locations in which density is shown to be inconsistent wi~h good
planning principles, the city's General Plan and the Airport Land Use
Compatibility Plan. The three most problematic areas (shown in Attachment 3)
are:
1. 736 units on parcels immediately adjacent to the McClellan-Palomar
Airport runway. The location ofthe airport within this mobility hub was
shared with SANDAG staff multiple times at workshops. This is
inconsistent with the regulations provided by the San Diego County
Regional Airport Authority and conflicts with standard planning
principles for siting housing away from hazards.
2. 2,755 units on existing developed resort properties and open space
dedicated lands adjacent to Legoland.
3. 65 units in a preserved open space area.
ii. SAN DAG should provide additional detail why units were assumed in these
areas, what planning principles those decisions were based on, and how
SAN DAG expects this to be implemented.
iii. Concentration of units in the mobility hubs alone appears to conflict with the
direction received from the California Department of Housing and Community
Development ("HCD'') to implement new Affirmatively Furthering Fair Housing
("AFFH"), which seeks to combat housing discrimination, eliminate racial bias,
undo historic patterns of segregation, and lift barriers that restrict access in
order to foster inclusive communities and achieve racial equity, fair housing
choice and opportunity for all Californians. The allocations of land use provided
by SAN DAG seem to focus all the higher density housing into one area of the
city. (This is one of the largest points of analysis that each jurisdiction in the
region needs to respond to in order to receive a certified Housing Element.)
b. Additionally, looking at the detailed data provided by SAN DAG, it is now clear why the
citywide numbers only show moderate increases in population. Our analysis has shown
that there is an assumed reduction of population by 2,310 persons in the areas within
the city but outside of the mobility hubs. This is likely due to assumed reductions in
persons per household over time, but SAN DAG should clarify the source and
reasonableness of this assumption. If housing is not provided consistent with these
areas, is it still reasonable to assume persons per household will be reduced in 2050?
1 SAN DAG Website: Employment Centers SAN DAG :: PROJECTS :: San Diego's Regional Planning Agency
I
I
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page4
c. Furthermore, this reduction in population is not limited to the City of Carlsbad. There is •
an approximately 85,000 reduction in population assumed outside of mobility hubs
regionwide. SAN DAG needs to address if that is a reasonable assumption and if this will
result in other impacts to public and private projects that will rely on this growth
forecast, and the associated Activity Based Model (2+) to project future Impacts to
transportation, GHG, air quality and noise.
d. The forecast has decreased in future population based on current trends, but it is not
clear if there is enough housing provided with reductions and increases in some
jurisdictions. Will the reduced amount of housing that will be provided result in an
increased exacerbation of the affordability crisis?
e. There is a lack of clarity about how the Plan would be implemented at the municipal
level. SANDAG should develop an approach for engaging with municipalities to ensure
local support for delivering the regional transportation network. Staff from local
jurisdiction have the knowledge and ability to share where there are land use
assumptions that conflict with planning and zoning laws. Our analysis focused on the
City of Carlsbad, but if these types of assumptions are made regionwide, it presents
flaws in the overall analysis. These flaws put the assumed reductions in vehicle miles
traveled (''VMT") and ability to implement the Regional Plan into question.
3. The area designated is controlled for use and activity density and intensity through its spatial
association with the McClellan-Palomar Airport. The McClellan-Palomar Airport is defined by the
Federal Aviation Administration ("FAA") as a commercial service airport that, in addition to
private aircraft, has regularly scheduled commercial flights to Los Angeles International Airport
("LAX"). The McClellan-Palomar Airport Land Use Compatibility Plan ("ALUCP") is prepared
according to FAA requirements and adopted by the San Diego County Regional Airport Authority
acting as the Airport Land Use Commission for the County of San Diego.
a. The ALUCP provides measures to minimize the public's exposure to excessive noise and
safety hazards within areas around the airport and identifies areas likely to be impacted
by noise and flight activity created by aircraft operations at the airport. These impacted
areas include the Airport11nfluence Area ("AIA"), the Clear Zone and the Flight Activity
Zone. •
b. Within the AIA, the ALUCP establishes six safety zones for the purpose of evaluating
safety compatibility of new/future land use actions. The safety zone boundaries depict
relative risk of aircraft accidents occurring near the airport and are derived from general
aviation aircraft accident location data and data regarding the airport's runway
configuration and airport operational procedures. The ALUCP limits development
intensities in these zones by imposing floor area and lot coverage maximums, by
incorporating risk reduction measures in the design and construction of buildings,
and/or by restricting certain uses altogether. For example, all residential and virtually all
non-residential uses are considered incompatible land uses in some zones, while
considered to be either compatible or conditionally compatible with the airport in other
zones. Attachment 4 shows the McClellan-Palomar Airport, noise contours and
SANDAG's proposed housing units.
c. If the proposed SAN DAG land use assumptions are endorsed, an amendment to the
city's General Plan would be required to change the land use designation to Mixed-Use
Commercial or residential land uses within the existing Business Park In order to
effectuate the underlying assumptions of SANDAG staff. This is not a realistic
I
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug.6,2021
Page 5
assumption. Further, the protected airspace referenced In the AIA and the ALUCP must
also be amended based on SANDAG's regional planning assumptions. (The FAA
establishes airspace protection zones in the airspace above and surrounding airports in
order to protect aircraft from obstructions such as buildings, towers, etc. in navigable
airspace.)
d. When a General Plan is adopted or amended, the allowable growth pattern of an area is
identified and the expansion or updating of the various land uses as specified in the
General Plan can occur throughout the planning horizon. Without such growth
considerations, the expansion or intensification of existing land uses could be
considered "growth inducing." Unplanned and uncontrolled growth may have significant
adverse impacts on the environment. CEOA requires a discussion of how a "project"
could increase population, employment or housing growth in surrounding areas and the
Impacts resulting from this growth. The CEOA Guidelines indicate that a "project" would
normally have a significant effect on the environment if it would induce substantial
growth or a substantial concentration of population.
4. At this point, it is not clear if SANDAG's assumptions adequately contemplate the development
patterns included in the Sustainable Communities Strategy {"SCS")/Regional Transportation Plan
("RTP"), and Regional Air Quality Strategy ("RAQS"), local climate action planning business-as -
usual estimates, sub-regional traffic modeling, or the airspace assumptions of AIA and the
ALUCP.
5. The city seeks clarity on the Plan's underlying assumptions made to justify the proposed
extensive high-speed rail network considering the significant changes in travel behavior which
have occurred throughout the region as a result of the COVID-19 pandemic and due to the
advancements in disruptive technologies such as telecommuting, autonomous vehicles,
microtransit, etc.
a. Recent North County Transit District ("NCTD") Coaster ridership data show riders are
not returning to riding the Coaster in comparison to other modes of travel as shown in
Attachment 5.
b. This question is consistent with comments made by SANDAG's panel expert Bob Poole .
regarding the impact of the COVID-19 pandemic on transit ridership and mega-transit
projects. {See comments by Bob Poole during the March 12, 2021 presentation to
SANDAG starting at timestamp 1:30 p.m.: https://youtu.be/g-e6bNYSJ 8?t=5410)
6. The city seeks clarity on why an alternatives analysis was not conducted with consideration of
other transit alternatives such as automated /shared vehicle technologies and personalized zero
emissions transit programs that are capable of utilizing the existing regional freeway
infrastructure in response to these recent developments explained in the above comment.
7. The city seeks clarity on why the Plan does not incorporate policies to promote roundabouts
over signalized intersections and include a budget line item under the Complete Corridors to
fund the construction of roundabouts at new locations and to replace signalized intersections
when found feasible. This clarification would support the Federal Highway Administration
("FHWA")'s project for Accelerating Roundabout Implementation in the United States and the
County of s·an Diego Air Pollution Control Board's support for implementing roundabouts to
address GHG and reduce fatalities.
8. The city seeks clarity on the project phasing proposed within the Plan. Specifically, the city is
seeking to understand the timi~g of implementation of unfunded TransNet projects related to
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page 6
the new projects presented within the Regional Plan. To support this, the city is requesting that
SAN DAG input the information requested in Table 1 (Attachment 6). '
9. The city seeks specific data on the proposed 200 miles of rail service contemplated in the Plan.
To support this, the city is requesting that SAN DAG input the information requested in Table 3
(Attachment 7). Specific questions:
a. Please provide more information about the scope of the high-speed rail alignments,
potential vehicle technologies and their cost estimates.
b. Will the Coaster keep the same rail alignment?
c. What funding is programmed or planned for the Carlsbad Village railroad trench and the
other projects along the current NCTD/Coaster Service right-of-way?
d. Will some of the tracks be at grade with fencing and trains traveling at 110 miles per
hour speeds?
SECTION 2: COMMENTS AND RECOMMENDATIONS
In addition to the comments on process and the Draft EIR provided above, city staff remain concerned
that there is not enough detail on the feasibility of implementation of this significant shift in
transportation strategy. On specific content in the plans, we outline our recommendations and
comments below:
1. Paying for the Plan:
The draft 2021 Regional Plan sets out an ambitious plan to build and operate a region-wide
system of transportation projects, programs and other improvements. This is a substantial role
for SAN DAG to play in supporting both the construction and operation of these projects,
programs and other improvements. SANDAG should set annual revenue targets to directly fund
everything and should approve any recommended sustainable revenue tools to help meet these
targets. Many of the f~nding strategies will require legislative changes, or voter-approved
taxation. SAN DAG should clarify what will occur if the funding is not available, if opposition to
projects stops them from construction, and if General Plans in the region are not modified to
implement the Plan .
2. Appendix D: Sustainable Community Strategy Documentation:
Appendix D includes the Sustainable Communities Strategy, which outlines assumptions
included in the Activity Based Model 2+ ("ABM 2+"), updated for this. This model will be
necessary for use by publicly and privately initiated land use projects preparing documents for
consistency with VMT/CEQA Guidelines and Traffic Impact Analysis ("TIA") Evaluations. City staff
respectfully request direction from SAN DAG on how to conduct modeling with the service
bureau and how to factor in these assumptions applied to ABM 2+. Specifi~ally, the addition of
pricing, parking costs for coastal communities, 10% teleworking and micromobility. SAN DAG
should provide direction on how this could be worked into General Plans that are updated every
5-20 years.
3. Appendix A: Transportation Projects, Programs, and Phasing:
Trips to and from school sites result in a significant congestion, VMT generation, and peak hour
delay throughout the region. Additional funding and projects should be recommended with a
specific focus on improving safety and multimodal access in and around school sites along with
programs to incentivize non-single occupancy vehicle trips to schools.
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page7
Table A.11: Given the proven success of the Carlsbad Connector microtransit pilot program, the
city agrees with the Plan's recommendations to provide similar on-demand microtransit systems
throughout North County at all mobility hub sites and major transit centers.
Table A.13: The segment of El Camino Real between Poinsettia Lane and Camino Vida Roble is
proposed to be widened from two to three.lanes to prime arterial standards. With the adoption
of the city's General Plan, the city has determined that the widening of this portion of El Camino
Real is not feasible due to constrained right-of-way and would result in negative impacts to
9thertravel modes. City staff recommend removal of this proposed project recommendation
CB32 (that is, a 'do nothing' scenario, or appraise and evaluate different moblllty projects
and/or alternative designs).
The preferred lnterstate-5 freeway alternative identified in the North Coast Corridor ("NCC")
Final EIR/EIS is the refined 8+4 Buffer alternative, with four freeway lanes and two managed
lanes in each direction and completion by 2035. Appendix A, Table A.5 describes NCC project IDs
CC004, 007 -009 as "SF to 6F+4ML" with completion by 2050. While this might lead to further
study, it is not clear why there is a different freeway configuration (i.e., reduction in freeway
lanes) proposed. How does a reduction in lanes continue to meet NCC potential project benefits
of maintaining or improving traffic operations and improving the safe and efficient regional
movement of people and goods?
4. Active Transportation:
The city appreciates the Regional Plan's overall approach of providing a connected network of
high-quality bicycle facilities throughout the region. Regional bikeways are recommended
throughout the city including along Palomar Airport Road which will provide a key east-west
connection and El Camino Real which will provide a new north-south bikeway connection
through the city. Both roadways are proposed to include "on-street bikeways". Due to the high
traffic volumes and vehicle speeds experienced along most of both corridors, the city
recommends considering "off-street bikeways" or Class I facilities where feasible in order to
stimulate the shift from personal motor vehicle use to people choosing to bike.
It is extremely important that municipal transportation plans align with regional transportation
plans to achieve regional goals for land use and transportation and to promote the region
working together to build a cohesive regional transportation network. Considering there are
currently no mechanisms in ";:,lace to ensure municipalities coordinate local transportation plans
with regional planning documents, the Plan should provide an approach on how SAN DAG plans
to engage with municipaliti_es, especially in areas of potential disagreement or conflict (as
aforementioned in this subsection and others). It Is also recommended that the Plan provide
additional direction regarding the application of protected bikeways In a variety of applicable
contexts. While vertical measures such as soft hit posts may be appropriate in lower volume and
lower speed roadways, arterial roadways with high traffic volumes and high speeds warrant
much more substantial physical protection from vehicles. In addition, special consideration
should be given at intersections and driveways which may be impacted due to the additional
width and visibility impacts created by protected bikeways.
City staff look forward to working with SANDAG on improving mobility and land use access in the region
and building sustainable, equitable and healthy modes of transportation, and we appreciate the
opportunity to comment on the Plan that will help the region realize these goals.
City of Carl_sbad Comments on Draft 2021 Regional Plan
Aug.6,2021
Page 8
If you have any questions related to comments on the transportation network. please contact Tom
Frank, Transportation Director/City Engineer, at Tom .Frank@carlsbadca.gov or if you need additional
Information related to comments on the land use assumptions, please contact Eric Lardy, Principal
Planner, at Eric.Lardy@carlsbadca.gov.
Sincerely,
ft/VOS
For
JEFF MURPHY
Community Development Director
-7-?~
TOM FRANK
Transportation Director/City Engineer
Attachments:
1. Government Code 65020 (S.B. 375) Summary
2. City of Carlsbad Moblllty Hubs
3. City of Carlsbad -Palomar Airport_ Road Mobility Hub Analysis
4. Palomar-Mclellan Airport Flight Paths
5. Recent NCTD Coaster Ridership Data
6. Table 1-Project Data Request
7. Table 3 -Detail of Proposed Rail Lines
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberio, Deputy city Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Director, Community Development
Don Neu, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager
Jason Geldert, Engineering Manager
Eric Lardy, Principal Planner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Attachment 1: Government Code 65020 (S.B. 375) Summary
Government Code section ("GOV§") 65080, also referred to as California Senate Bill 375 (Steinberg, 2008)
("SB 375"), is one area of law that provides SAN DAG with guidance to which a regional transportation plan
must be developed.
Among other things, the regional transportation plan that is developed "shall be an internally consistent
document" (GOV § 65080 (b)) and shall include a "sustainable communities strategy prepared by each
metropolitan planning organizations as follows" (GOV§ 65080 (b)(2)(B)):
Each metropolitan planning organization shall prepare a sustainable communities strategy, subject
to the requirements of Part 450 of Title 23 ot and Part 93 of Title 40 ot the Code of Federal
Regulations, including the requirement to utilize the most recent planning assumptions considering
local general plans and other factors. The sustainable communities strategy shall (i} identify the
general location of uses, residential densities, and building intensities within the region, (ii} identify
areas within the region sufficient to house all the population of the region, including all economic
segments of the population, over the course of the planning period of the regional transportation
plan taking into account net migration into the region, population growth, household formation
and employment growth, (iii) identify areas within the region sufficient to house an eight-year
projection of the regional housing need for the region pursuant to Section 65584, (iv) identify a
transportation network to service the transportation needs of the region, (v) gather and consider
the best practically available scientific information regarding resource areas and farmland in the
region as defined in subdivisions (a) and (b) of Section 65080.01 , (vi) consider the state housing
goals specified in Sections 65580 and 65581, (vii) set forth a forecasted development pattern for
the region, which, when integrated with the transportation network, and other transportation
measures and policies, will reduce the greenhouse gas emissions from automobiles and light trucks
to achieve, if there is a feasible way to do so, the greenhouse gas emission reduction targets
approved by the state board, and (viii) allow the regional transportation plan to comply with Section
176 of the federal Clean Air Act ( 42 U.S. C. Sec. 7506 ).
The 2021 draft Regional Transportation Plan includes a Sustainable Communities Strategy ("SCS"), as
required by SB 375 for the San Diego region (herein after called "draft Regional Plan"). The draft Regional
Plan indicates that "SB 375 requires the SCS to include a pattern for forecasted growth and development
that accomplishes the following: 1) When combined with the transportation network, the SCS will achieve
the regional GHG emission-reduction targets; 2). The SCS accommodates the Regional Housing Needs
Assessment ("RHNA") Determination; and 3) The SCS utilizes the most recent planning assumptions.
(Reference p. 19 of the 2021 Regional Plan.)
Predicting the effect of transportation plans or projects on land uses and land use planning is critical to
developing context sensitive solutions for transportation projects. Therefore, utilization of the most
recent planning assumptions is not only necessary but is required as specifically stated therein GOV §
65080. If inconsistencies are found in the land use assumptions or adverse impacts are anticipated,
SAN DAG should be actively engaged in the development of measures to address these issues.
The SANDAG Board of Directors approved the final RHNA plan with the final housing unit allocation on
July 10, 2020, which was based on the most recent land use planning assumptions and an adopted
methodology to allocate housing in accordance with GOV §§ 65584.04(d and m). The City of Carlsbad
received a total RHNA allocation of 3,873 units as a result of RHNA plan adoption. The adopted April 6,
2021 city's Housing Element accommodates its housing needs through current zoning and other programs
City of Carlsbad Comment Letter August 6, 2021
Attachment 1: Government Code 65020 (S.B. 375) Summary
as needed to meet the city's RHNA obligation at all income levels. The land use inputs derived from this
local planning document constitutes the most recent land use assumptions. On July 13, 2021 the
Department of Housing and Community Development found "the adopted housing element is in
substantial compliance with State Housing Element Law (Article 10.6 of the Gov. Code).
The most recent planning assumptions are critical for the development of the draft Regional Plan as the
document must comply· with other specific state and federal mandates including a SCS per California
Senate Bill 375, which achieves GHG emissions reduction targets set by the California Air Resources Board
and compliance with federal civil rights (Title VI) requirements, environmental justice considerations, air
quality conformity, and public participation. To monitor compliance and attainment of state reduction
goals in GHG, GOV§ 65080 (b)(2)) requires that:
(H) Prior to adopting a sustainable communities strategy, the metropolitan planning organization
shall quantify the reduction in greenhouse gas emissions projected to be achieved by the
sustainable communities strategy and set forth the difference, if any, between the amount of that
reduction and the target for the region established by the state board.
(J)(i) Prior to starting the public participation process adopted pursuant to subparagraph (F}, the
metropolitan planning organization shall submit a description to the state board of the technical
methodology it intends to use to estimate the greenhouse gas emissions from its sustainable
communities strategy and, if appropriate, its alternative planning strategy.
There is inevitably some uncertainty regarding the use of projected future conditions. However, what is
certain is that the project will not operate under the conditions that exist today. There will be new
residential and employment growth in the intervening years between now and the proposed build-out of
the draft Regional Plan. Nonetheless, projections utilized should represent the best available information
assembled by the local agencies with jurisdiction and expertise. Judgments about land use assumptions
utilized in the draft Regional Plan should be based on and supported by facts, adopted plans, and "most
recent planning assumptions," rather than speculation and personal opinions. The land use assumptions
for "uses, residential densities, and building intensities within the region" (as required by GOV§ 65080
(b)(2)(B)(i)) should also be the same, as that provided to the state board (as required per GOV §§ 65080
(b)(2)(H and J) in estimating and analyzing GHG from the SCS and the effect on growth and whether the
effects of that growth would be significant in the context of the region's plans, natural setting, and growth
patterns. Ultimately, the SCS must demonstrate whether SANDAG can meet the per capita passenger
vehicle-related GHG emissions targets for 2035 set by the California Air Resources Board ("CARB").
SB 375 directs CARB to accept or reject the determination of SANDAG that its SCS submitted to CARB
would, if implemented, achieve the region's GHG emissions reduction targets. CAR B's technical evaluation
of SANDAG's draft Regional Plan would be based on all the evidence provided, including the models, the
data inputs and assumptions, the SCS strategies, and the performance indicators.
The transportation and planning assumptions are also extremely important as it is relied on for other
master planning exercises. The Regional Air Quality Strategy ("RAQS") relies on information from CARB
and SAN DAG for information regarding projected growth in the cities and San Diego County. This in turn
is utilized to address other state requirements, including the San Diego portion of the California State
Implementation Plan ("SIP") and promulgating their own rules and regulations regarding air quality in the
region or to address federal requirements.
City of Carlsbad Comment Letter August 6, 2021
Attachment 1: Government Code 65020 (S.B. 375) Summary
The analysis of land use impacts for transportation projects is guided by FHWA Technical AdvisoryT 6640.8
and the CEQA Guidelines.
Under the FHWA Technical Advisory T 6640.8 (G)(l), Guidance for Preparing and Processing
Environmental, states:
This discussion [of land use] should identify· the current development trends and the State and/or
local government plans and policies on land use and growth in the area which will be impacted by
the proposed project. These plans and policies are normally reflected in the area's comprehensive
development plan, and include land use, transportation, public facilities, housing, community
services, and other areas.
The land use discussion should assess the consistency of the alternatives with the comprehensive
development plans adopted for the area and (if applicable) other plans used in the development
of the transportation plan required by Section {23 U.S. Code §] 134. The secondary social,
economic, and environmental impacts of any substantial, foreseeable, induced development
should be presented for each alternative, including adverse effects on existing communities.
Where possible, the distinction between planned and unplanned growth should be identified.
There is also a requirement to analyze the land use planning inconsistencies per CEQA Guidelines §
15126.2(a), which specifies that an EIR for a proposed project include:
The Significant Environmental Effects of the Proposed Project. An £JR shall identify and focus on
the significant effects of the proposed project on the environment. In assessing the impact of a
proposed project on the environment, the lead agency should normally limit its examination to
changes in the existing physical conditions in the affected area as they exist at the time the notice
of preparation is published, or where no notice of preparation is published, at the time
environmental analysis is commenced. Direct and indirect significant effects of the project on the
environment shall be clearly identified and described, giving due consideration to both the short-
term and long-term effects. The discussion should include relevant specifics of the area, the
resources involved, physical changes, alterations to ecological systems, and changes induced in
population distribution, population concentration, the human use of the land (including
commercial and residential development), health and safety problems caused by the physical
changes, and other aspects of the resource base such as water, historical resources, scenic quality,
and public services. The EIR shall also analyze any significant environmental effects the project
might cause or risk exacerbating by bringing development and people into the area affected. For
example, the £JR should evaluate any potentially significant direct, indirect, or cumulative
environmental impacts of locating development in areas susceptible to hazardous conditions (e.g.,
floodplains, coastlines, wildfire risk areas), including both short-term and long-term conditions, as
identified in authoritative hazard maps, risk assessments or in land use plans addressing such
hazards areas.
Since the new land use assumptions are being utilized, as described by this letter, the EIR that is prepared
shall also analyze any significant environmental effects the project might cause by bringing development
and people into the area affected. The following are the basic steps in analyzing land use impacts as part
of the community impact assessment process:
City of Carlsbad Comment Letter August 6, 2021
Attachment 1: Government Code 65020 (S.B. 375) Summary
1. Inventory the existing land use patterns (including undeveloped land), development trends, and
transportation systems. The inventory of existing land uses should include the following land use
types: residential, commercial, industrial, recreational, institutional, public services, community
services, emergency services, transportation, utilities, agriculture, and undeveloped land in the
study area. The study area should include the surrounding community that is generally
associated with the project area within which community impacts could occur. The inventory
should also address development trends and identify recent developments in the study area to
include the development's name, size, status (planned, built, under construction), and the
jurisdiction in which it is located. A map showing the location of existing and planned land uses
in the area should also be prepared.
2. Determine whether the project is consistent with local and regional policies that govern land use
and development. For the consistency analysis, the policies and programs considered in the
analysis should include: transportation plans and programs (MTPs/RTPs and MTIPs/RTIPs),
regional growth plans, local General Plans that establish land use and growth management
policies for the study area, and any specific or pipeline development proposals. This analysis
should also include a discussion of consistency with the Coastal Zone Management Act of 1972,
California Coastal Act of 1976, the National Wild and Scenic Rivers Act (16 USC 1271) and the
California Wild and Scenic Rivers Act (Pub. Res. Code§ 5093.50 et seq.). After preparing a
preliminary list of relevant plans to be considered in the analysis, the SAN DAG planner should
meet with the staff of the various agencies to review the list to determine if it is complete and
revise the list as necessary.
3. Assess the changes that would occur in land uses and growth with and without the project.
4. The draft Regional plan and each project alternative should be considered separately since the
results may be different.
5. Develop measures to avoid, minimize, and/or mitigate potential adverse effects.
The resulting environmental analysis should identify the current development trends and the State and/or
local government plans and policies on land use and growth in the area which will be impacted by the
proposed project. These plans and policies are normally reflected in local General Plans. If found to be
consistent, then the findings fn the EIR should be documented in the report and no further analysis or
action is necessary. When found not to be inconsistent with a policy or program, then consideration must
be given to modifying the draft Reginal Plan alternative to make it consistent, or measures to address the
inconsistency must be developed. SANDAG should be actively engaged in the development of measures
to address these issues and be prepared to assess the consistency of the draft Regional Plan and
alternatives with the comprehensive development plans adopted for the area and (if applicable) other
plans used in the development of the transportation plan required by Section 23 U.S. Code§ 134. For any
new land use growth assumptions, the secondary social, economic, and environmental impacts of any
substantial, foreseeable, induced development should be presented for the draft Regional Plan and each
alternative, including adverse effects on existing communities. The results should be shared with the
public during the public involvement process, e.g., at community meetings, etc. Public input should be
considered by SANDAG and if necessary, the findings of the analysis should be revised to reflect
information gained through the public involvement process.
City of Carlsbad Comment Letter August 6, 2021
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Notes
1. 2010 McClellan-Palomar Airport ALUCP Policy 3.3.3 prohibits residential uses on properties, or portions of properties,
with airport noise exposures greater than 65 dB CNEL.
2, 2010 McClellan-Palomar Airport ALUCP Policy 3.4.4 prohibits residential uses on properties, or portions of properties,
within airport safety zones 1, 2 and 5.
, , , , ,
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D Zone 1
0Zone2
0Zone3
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Ozones
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' , T lty of Carlsbad ~\claims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY 18 EXCLUSIVE ANO IN LIEU OF ALL OTHER WARRANTIES OR MEg!tHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no eventahall the City 1
Carlsbad become llablt to users of this map, or any other party, for any loss or dama~, consequential or otherwise, lnctudlng but not limited to time, money, or goodwfll, arising from the use, operation or modincation of the map. In ualng thla map, user further agree to Indemnify, defend, and hold harmleH the Clfy ofCarlabad ror any and all llabUlty ot
any nature arising out of o~qisultlng from the lack of accuracy or correctness of the map, or the use of the map. , ' •
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Attachment 5
PLEASE NOTE: PRELIMINARY RIDERSHIP DATA-UNAUDITED AND SUBJECT TO ADJUSTMENTS
I .... ~-TOfM.ltlD!UHIP
ffl1 ..,.. ·v...-"' July 10,263 149,515 (139,252) (93.1%)
Aug 9,412 133,482 (124,070) (92.9%)
Sept 10,020 114,233 (104,213) (91.2%)
Oct 10,968 111,045 (100,0TT) (90.1%)
Nov 9,232 94,551 (85,319) (90.2%)
Dec 7,519 83,951 (76,432) (91 .0%)
Jan 6,848 98,791 (91 ,943) (93.1%)
Feb 7,866 91,845 (83,979) (91.4%)
Mar 11,203 46,510 (35,307) (75.9%)
Apr 15,184 5,244 9,940 189.5%
May 19,214 6,207 13,007 209.6%
June .. 44,978 8,734 36,244 415.0% .. Not final as of July 19, 2021
YTDTotal 162,707 0 (781,401)
FY Total 162,707 944,108
I .. .\ l!KfUMY .,._ "20 ~ s
July 10,263 131,218 (120,955) (92.2%)
Aug 9,412 112,100 (102,688) (91.6%)
Sept 10,020 92,159 (82,139) (89.1%)
Oct 10,968 105,601 (94,633) (89.6%)
Nov 9,232 80,912 (71 ,680} (88.6%)
Dec 7,519 75,534 (68,015) (90.0%)
Jan 6,848 89,920 (83,072) (92.4%)
Feb 7,866 B4,613 (76,747) (90.7%)
Mar 11,203 44,368 (33,165) (74.7%)
Apr 15,184 5,244 9,940 189.5%
May 17,221 6,207 11,014 1TT.4%
June** 35,192 8,734 26,458 302.9% "*Not final as of July 19, 2021
YTDTotal 150,928 0 (685,682)
FY Total 150,928 836,610
1 11111111111 ~~M'RIRDIIV ,_ ,_ ---~
July . 9,415 (9,415) (100.0%)
Aug -14,348 (14,348) (100.0%)
Sept -8,449 (8,449) (100.0%)
Oct -3,247 (3,247) (100.0%)
Nov . 8,385 (8,385) (100.0%)
Dec -4,387 (4,387) (100.0%)
Jan -3,218 (3,218) (100.0%)
Feb -5,181 (5,181) (100.0%)
Mar -665 (665) (100.0%)
Apr -0 0
May 1,387 0 1,387
June** 5,881 0 5,881 ••Not final as of July 19, 2021
YTDTotal 7,268 0 (50,027)
FYTotal 7,268 57,295
I Month OOA$11.R-lllliliv..Y
PU'I PVIO .~ 1'
July . 8,882 (8,882) (100.0%)
Aug . 7,034 (7,034) (100.0%)
Sept . 13,625 (13,625) (1 00.0%)
Oct . 2,197 (2,197) (100.0%)
Nov . 5,254 (5,254) (100.0%)
Dec . 4,030 (4,030} (100.0%)
Jan -5,653 (5,653) (1 00.0%)
Feb . 2,051 (2,051) (1 00.0%)
Mar . 1,4n (1,477) (1 00.0%)
Apr . 0 0
May 606 0 606
June .. 3,905 0 3,905 0 Not final as of July 19, 2021
YTD Total 4,511 0 (45,692)
FY Total 4,511 50,203
ATTACHMENT 6-Project Data Request
Table 1: Project Information Request
Estimated Current Draft RTP Assumed
Project Total Project Planned Year of Assumed Year Federal/State
Cost Construction of Construction Matchina Fundina (%)
San Dieguito Lagoon Double Track
and Platform
Batiquitos Lagoon Double Track and
Bridqe Replacement
Eastbrook to Shell Double Track
Carlsbad Villaqe Trench
La Costa to Swami Double Track
San Onofre Bridoe Replacements
Rose Canyon Bridqe Replacements
ATTACHMENT 7-Detail of Proposed Rail Lines
Table 3: Detail of Proposed Rail Lines
Average Interoperable
Rail Mode (CR, Directional % of Directional Number Distance Average with
LR, HSR, Miles Miles Grade of Between Speed COASTER
Hybrid) Separated/Tunnel Stations Stations Operated equipment
(Y/N)
New Rail Line
Sept. 30, 2021
San Diego Association of Governments
401 B street, Suite 800
San Diego, CA 92101
Via: SDForward@sandag.org
RE: City of Carlsbad Comments on Draft 2021 Regional Plan
To whom it may concern,
ATTACHMENT 2
(city of
Carlsbad
This letter serves to inform SANDAG that the City does not wish to remove project CB32 from
the Regional Arterials Project list.
Please disregard the comment regarding project CB32 from the attached letter sent to SAN DAG
on Aug. 6, 2021.
Thank you for bringing this to our attention, and please contact me if you have any other
questions regarding the 2021 Regional Plan comment letter.
Best Regards,
Tom Frank, PE
Transportation Director/City Engineer
Attachment A: Letter to SAN DAG dated Aug. 6, 2021
I
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public works
Mike Strong, Assistant Director, Community Development
Public Works Branch -Transportation Department
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2766
cc: Don Neu, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager
Jason Geldert, Engineering Manager
Eric Lardy, Principal ~lanner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Public Works Branch -Transportation Department
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2766
( City of
Carlsbad
Aug.8,2023
San Diego Association of Governments
401 B Street, Suite 800
San Diego CA 92101
Via: RegionalPlanAmendment@sandag.org
RE: City of Carlsbad Comments on the Amendment to the 2021 Re gional Plan
To Whom it May Concern,
( City of Carlsbad
The City of Carlsbad appreciates the opportunity to provide comments on the proposed amendment to
the 2021 Regional Plan ("Plan Amendment"). This is an important plan for this region and guides the
next phases of growth for the member agencies of the San Diego Association of Governments
(11SANDAG11). An effectively designed and implemented regional transportation plan ensures improved
transportation options for area resi.dents, businesses and other community members; meaningful
reductions in greenhouse gas ("GHG") emissions; and improved quality of life as we grow our
communities.
The City of Carlsbad ("city") is submitting the following comments based on the policies, projects,
programs and other improvements included in the Plan Amendment. The city reserves the right to add,
amend, change or replace comments and recommendations based on additional review and
understanding of the Plan Amendment and the environmental analysis provided under the California
Environmental Quality Act ('1CEQA11).
SECTION 1: LAND USE
1.Alternatives included in the approved 2021 Regional Plan assumed housing in locations that
were inconsistent with the city's land use plans; this was discussed in detail in the city's August
6, 2021/September 30, 2021, comments on the draft 2021 Regional Plan (Attachment 1).
Consistent with those comments, city staff recommend the Plan Amendment:
a.Consider the city's land use plans, including the General Plan, Habitat Management
Plan, and Local Coastal Program.
b.Consider the McClellan-Palomar Airport Land Use Compatibility Plan (adopted by the
county Airport Land Use Commission and amended Dec. 1, 2011) and the constraints
identified therein.
2.City staff are encouraged by recent conversations with SAN DAG staff that the proposed 2025
Regional Plan will consider the city's land use documents. Doing so is recommended and
expected and will help ensure better accuracy of data and assumptions.
SECTION 2: COMMENTS AND RECOMMENDATIONS
City staff remain concerned that there is not enough detail on the feasibility of implementation of this
significant shift in transportation strategy. On specific content in the plans, we outline our
recommendations and comments below:
Transportation & Community Development Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2710 t
Attachment B
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City of Carlsbad Comments on the Amendment to the 2021 Regional Plan
Aug.8,2023
Page 2
1.Paying for the Plan:
The 2021 Regional Plan sets out an ambitious plan to build and operate a region-wide system of
transportation projects, programs and other improvements. This is a substantial role for
SAN DAG to play in supporting both the construction and operation of these projects, programs
and other improvements. SAN DAG should set annual revenue targets to directly fund everything
and should approve any recommended sustainable revenue tools to help meet these targets.
Many of the funding strategies will require legislative changes, or voter-approved taxation.
SAN DAG should clarify what will occur if the funding is not available, if opposition to projects
stops them from construction, and if General Plans in the region are not modified to implement
the Plan/Plan Amendment.
2.Appendix D: Sustainable Community Strategy Documentation:
Appendix D includes the Sustainable Communities Strategy, which outlihes assumptions
included in the Activity Based Model 2+ ("ABM 2+"). This model will be necessary for use by
publicly and privately initiated land use projects preparing documents for consistency with
VMT/CEQA Guidelines and Traffic Impact Analysis ("TIA") Evaluations. City staff respectfully
request direction from SAN DAG on how to conduct modeling with the service bureau and how
to factor in these assumptions applied to ABM 2+. Specifically, the addition of pricing, parking
costs for coastal communities, 10% teleworking and micromobility. SAN DAG should provide
direction on how this could be worked 'into General Plans that are updated every 5-20 years.
The plan should provide a process for implementing all phases of the Build North County
Corridor (NCC) managed lanes project and the supporting active transportation infrastructure
projects. It is also recommended that the plan pivot from the existing low ridership fixed routes
transit services to flexible fleets along the 1-5 and SR-78 corridors to maximize the objectives of
the plan. As stated in the Regional Plan, priority Flexible Fleet will help make the region more
accessible, equitable, and environmentally friendly.
3. Appendix A: Transportation Projects, Programs, and Phasing:
Trips to and from school sites result in a significant congestion, VMT generation, and peak hour
delay throughout the region. Additional funding and projects should be recommended with a
specific focus on improving safety and multi modal access in and around school sites along with
programs to incentivize non-single occupancy vehicle trips to schools.
Table A.11: Given the proven success of the Carlsbad Connector microtransit pilot program, the
city agrees with the Plan/Plan Amendment's recommendations to provide similar on-demand
microtransit systems throughout North County at all mobility hub sites and major transit
centers.
The preferred lnterstate-5 freeway alternative identified in the North Coast Corridor ("NCC")
Final EIR/EIS is the refined 8+4 Buffer alternative, with four freeway lanes and two managed
lanes in each direction and completion by 2035. Appendix A, Table A.5 describes NCC project IDs
CC004, 007 -009 as "8F to 6F+4Ml" with completion by 2050. While this might lead to further
study, it is not clear why there is a different freeway configuration (i.e., reduction in freeway
lanes) proposed. How does a reduction in lanes continue to meet NCC potential project benefits
of maintaining or improving traffic operations and improving the safe and efficient regional
movement of people and goods?
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City of Carlsbad Comments on the Amendment to the 2021 Regional Plan
Aug.8,2023
Page 3
4.Active Transportation:
The city appreciates the Plan/Plan Amendment's overall approach of providing a connected
network of high-quality bicycle facilities throughout the region. Regional bikeways are
recommended throughout the city including along Palomar Airport Road which will provide a
key east-west connection and El Camino Real which will provide a new north-south bikeway
connection through the city. Both roadways are proposed to include "on-street bikeways". Due
to the high traffic volumes and vehicle speeds experienced along most of both corridors, the city
recommends considering "off-street bike.ways'' or Class I facilities where feasible in order to
stimulate the shift from personal motor vehicle use to people choosing to bike.
It is extremely important that municipal transportation plans align with regional transportation
plans to achieve regional goals for land use and transportation and to promote the region
working together to build a cohesive regional transportation network. Considering there are
currently no mechanisms in place to ensure municipalities coordinate local transportation plans
with regional planning documents, the Plan should provide an approach on how SANDAG plans
to engage with municipalities, especially in areas of potential disagreement or conflict (as
aforementioned in this subsection and others). It is also recommended that the Plan
Amendment provide additional direction regarding the application of protected bikeways in a
variety of applicable contexts. While vertical measures such as soft hit posts may be appropriate
in lower volume and lower speed roadways, arterial roadways with high traffic volumes and high
speeds warrant much more substantial physical protection from vehicles. In addition, special
consideration should be given at intersections and driveways which mc1y be impacted due to the
additional width and visibility impacts created by protected bikeways.
City staff look forward to working with SAN DAG on improving mobility and land use access in the region
and building sustainable, equitable and healthy modes of transportation, and we appreciate the
opportunity to comment on the Plan Amendment that will help the region realize these goals.
If you have any questions related to comments on the transportation network, please contact Tom
Frank, Transportation Director/City Engineer, atTom.Frank@carlsbadca.gov or if you need additional
information related to comments on the land use assumptions, please contact Eric Lardy, City Planner,
at Eric.Lardy@carlsbadca.gov.
JEFF MURPHY
Community Development Director
TOM FRANK
Transportation Director/City Engineer
City of Carlsbad Comments on the Amendment to the 2021 Regional Plan
Aug. 8,2023
Page 4
Attachment:
1.City of Carlsbad comments on draft 2021 Regional Plan dated August 6, 2021
cc: Scott Chadwick, City Manager
Cindie McMahon, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Senior Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberio, Deputy City Manager, Comtnunity Services
Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Director, Community Development
Eric Lardy, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager
Jason Geldert, Engineering Manager
Robert Efird, Principal Planner
Scott Donnell, Senior Planner
Nicole Morrow, Assistant Planner ..
(city ofCarlsbad
Sept. 30, 2021
San Diego Association of Governments
401 B street, Suite 800
San Diego, CA 92101
Via: SDForward@sandag.org
RE: City of Carlsbad Comments on Draft 2021 Regional Plan
To whom it may concern,
This letter serves to inform SAN DAG that the City does not wish to remove project CB32 from
the Regional Arterials Project list.
Please disregard the comment regarding project CB32 from the attached letter sent to SAN DAG
on Aug. 6, 2021.
Thank you for bringing this to our attention, and please contact me if you have any other
questions regarding the 2021 Regional Plan comment letter.
Best Regards,
Tom Frank, PE
Transportation Director/City Engineer
Attachment A: Letter to SAN DAG dated Aug. 6, 2021
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberib, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public works
Mike Strong, Assistant Director, Community Development
Public Works Branch -Transportation Department
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2766
Attachment 1
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Attachment A
Aug.6,2021
San Diego Association of Governments
401 B Street, Suite 800
San Diego CA 92101
Via: SDForward@sandag.org
RE: City of Carlsbad Comments on Draft 2021 Regional Plan
To Whom it May Concern,
(Cityof
Carlsbad
The City of Carlsbad appreciates the opportunity to provide comments on the draft 2021 Regional Plan
("Plan"). This is an important plan for this region and will guide the next phase of growth for the
member agencies of the San Diego Association of Governments (11SANDAG"). An effectively designed
and implemented regional transportation plan would hell) ensure improved transportation options for
area residents, businesses and other community members; meaningful reductions in greenhouse gas
("GHG") emissions; and improved quality of life as we grow our communities.
The City of Carlsbad ("city") is submitting comments based on the policies, projects, programs and other
improvements included in the Plan. Our agency's comment letter is divided into two sections. The first
section seeks clarity and other considerations that pertain to our agency's review of the Plan. The
second section identifies the city's preliminary comments and recommendations.
Implementing the regional transportation network outlined in the Plan requires municipalities to
support the regional vision and deliver on local infrastructure and services like the priority bus routes,
local bus services, and pedestrian and cycling connections to major transit infrastructure. These
components, which are delivered by municipalities, are essential to creating a coherent and
comprehensive local transportation network that feeds into regional services. For that reason, an
effective public review of the Plan should involve a transparent and thorough process for identifying and
evaluating potential hazards, physical changes to the environment and indirect (off-site and cumulative)
impacts that might result from implementation activities that may reasonably occur with the Plan.
The city's residents, businesses and other community members will greatly benefit from the
involvement and technical assistance from the prospective Draft Environmental Impact Report ("EIR").
Therefore, what follows in this correspondence represents our agency's preliminary comments and
recommendations. The city reserves the right to add, amend, change or replace comments and
recommendations based on additional review and understanding of the Plan and the environmental
analysis provided under the California Environmental Quality Act ("CEQA").
The city thanks SAND AG staff for meeting with city staff on Aug. 2, 2021, to discuss some of these
comments in advance of this letter. Following that meeting, SAN DAG provided language that they may
recommend adding to the Regional Plan for additional clarification on land use authority. The language
is, "Land use authority is reserved to local jurisdictions because they are best positioned to effectively
implement the objectives outlined in the Plan through understanding of the unique needs of their
communities and geographies." This language will be helpful to clarify that .land use authority rests with
Transportation & Community Development Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602~2710 t
Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plah
Aug. 6,2021
Page 2
the local jurisdiction. The city still offers the followin_g comments with the intent to support
development of a defensible and realistic regional plan.
SECTION 1: CLARITY AND OTHER CONSIDERATIONS
City staff have attended the series of workshops that SAN DAG hosted during the public review period,
and respectfully starts this section with several questions related to the process of the Plan and t he
Draft EIR. By way of introduction, a jurisdiction's General Plan, such as the city's General Plan, identifies
the expected population of the city and any lands outside of t he city limits but within their Sphere of
Influence where future growth is anticipated to occur, The city's General Plan identifies the subject area
adjacent to the McClellan-Palomar Airport for development under the designation for limited and light
industrial use.
For future land use planning, land use assumptions must reasonably proxy and be generally consistent
with local planning standards and programs, to be considered growth accommodating rather than
growth inducing. SAN DAG has the authority under Government Code Section 65584 to determine
existing and projected housing needs, as well as the share of housing needs to be allocated to cities and
counties, but it is unclear if SAN DAG has jurisdiction to allocate new housing growth to areas in a
manner not consistent with Government Code Section 65584. Attachment 1 includes additional
information on the applicable Government Code and standards. Therefore, and as indicated above, the
build-out of properties within the Business Park and flight activity zone must be done in accordance with
the city's General Plan Land Use Diagram, as amended, in accordance with city approval.
The initial questions on the planning process associated with developing the Plan are provided below:
1. The SAN DAG website states, "The SAN DAG Sustainable Communities Strategy and Final EIR from
its 2015 Regional Plan will remain valid and in compliance for purposes of state funding
eligibility and other state and federal consistency purposes until the SAN DAG B0cird of Directors
adopts a new Regional Plan and EIR, provided those actions are completed by the end of
December 2021.'' SAN DAG needs to clarify how the Draft EIR, Response to Comments and
Adoption will be completed this year and what will occur if they are not completed by the end of
this year. Additionally, please clarify when the Draft EIR will be available; it is difficult to
completely assess the full impacts of this plan when the public review of the documents is
piecemealed.
a. SAN DAG should clarify how public comments on the Plan are going to be addressed in
the Draft EIR prior to its release.
b. In the Draft EIR, SAN DAG needs to clearly articulate the impacts to land use and if the
Plan will cause a significant environ mental impact due to a conflict with any land use
plan, policy or regulation adopted for the purpose of avoiding or mitigating an
environmental effect. Appendix F: Regional Growth Forecast and Sustainable
Communities Strategy Land Use Pattern appears to be inconsistent with the city's
General Plan and rezone program to accommodate the Regional Housing Needs
Assessment, as well as the general plans of other jurisdictions such as the cities of
Coronado, Del Mar and the County of San Diego. The Draft EIR should clarify how
implementation of this Plan can occur if those changes are not made.
Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug.6,2021
Page 3
2. The city has three mobility hubs, associated with the Employment Centers Published supporting
the SAN DAG Regional Plan.l McClellan-Palomar Airport is the fifth largest employment center in
the region, with Carlsbad State Beach and Carlsbad Village as "Tier 3 and Tier 4" employment
centers. The city thanks SAN DAG for providing data for analysis to determine impacts and
provide for accurate comments on the Plan. Attachment 2 shows a summary of the Mobility
Hubs and housing units assumed in the Series 14 Growth Forecast for the year 2050. In
summary:
a. The assumptions in the updated Series 14 Growth Forecast contain inconsistencies with
the city's General Plan. The Carlsbad Palomar Major Employment Mobility Hub does
include increases in density beyond what the citywide numbers appear to show when
they are looked at in more detail.
i. There are three locations in which density is shown to be inconsistent with good
planning principles, the city's General Plan and the Airport Land Use
Compatibility Plan. The three most problematic areas (shown in Attachment 3)
are:
1. 736 units on parcels immediately adjacent to the McClellan-Palomar
Airport runway. The location of the airport within this mobility hub was
shared with SAN DAG staff multiple times at workshops. This is
inconsistent with the regulations provided by the San Diego County
Regional Airport Authority and conflicts with standard planning
principles for siting housing away from hazards.
2. 2,755 units on existing developed resort properties and open space
dedicated lands adjacent to Legoland.
3. 65 units in a preserved open space area.
ii, SAN DAG should provide additional detail why units were assumed in these
areas, what planning principles those decisions were based on, and how
SAN DAG expects this to be implemented.
iii. Concentration of units in the mobility hubs alone appears to conflict with the
direction received from the California Department of Housing and Community
Development ("HCD") to implement new Affirmative'ly Furthering Fair Housing
("AFFH"), which seeks to combat housing discrimination, eliminate racial bias,
undo historic patterns of segregation, and lift barriers that restrict access in
order to foster inclusive communities and achieve racial equity, fair housing
choice and opportunity for all Californians. The allocations of land use provided
by SAN DAG seem to focus all the higher density housing into one area of the
city. (This is one of the largest points of analysis that each jurisdiction in the
region needs to respond to in order to receive a certified Housing Element.)
b. Additionally, looking at the detailed data provided by SAN DAG, it is now clear why the
citywide numbers only show moderate increases in population. Our analysis has shown
that there is an assumed reduction of population by 2,310 persons in the areas within
the city but outside of the mobility hubs. This is likely due to assumed reductions in
persons per household over time, but SAN DAG should clarify the source and
reasonableness of this assumption. If housing is not provided consistent with these
areas, is it still reasonable to assume persons per household will be reduced in 2050?
1 SAN DAG Website: Employment Centers SAN DAG :: PROJECTS:: San Diego's Regional Planning Agency
Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page 4
c. Furthermore, this reduction in population is not limited to the City of Carlsbad. There is •
an approximately 85,000 reduction in population assumed outside of mobility hubs
regionwide. SAN DAG needs to address if that is a reasonable assumption and if this will
result in other impacts to public and private projects that will rely on this growth
forecast, and the associated Activity Based Model (2+) to project future impacts to
transportation, GHG, air quality and noise.
d. The forecast has decreased in future population based on current trends, but it is not
clear if there is enough housing provided with reductions and increases in some
jurisdictions. Will the reduced amount of housing that will be provided result in an
increased exacerbation of the affordability crisis?
e. There is a lack of clarity about how the Plan would be implemented at the municipal
level. SAN DAG should develop an approach for engaging with municipalities to ensure
local support for delivering the regional tra)1sportation network. Staff from local
jurisdiction have the knowledge and ability to share where there are land use
assumptions that conflict with planning and zoning laws. Our analysis focused on the
City of Carlsbad, but if these types of assumptions are made regionwide, it presents
flaws in the overall analysis. These flaws put the assumed reductions in vehicle miles
traveled ("VMT") and ability to implement the Regional Plan into question.
3. The area designated is controlled for use and activity density and intensity through its spatial
association with the McClellan-Palomar Airport. The McClellan-Palomar Airport is defined by the
Federal Aviation Administration ("FAA") as a commercial service airport that, in addition to
private aircraft, has regularly scheduled commercial flights to Los Angeles International Airport
("LAX"). The McClellan-Palomar Airport Land Use Compatibility Plan ("ALUCP") is prepared
according to FAA requirements and adopted by the San Diego County Regional Airport Authority
c'lcting as the Airport Land Use Commission for the County of San Diego.
a. The ALUCP provides measures to minimize the public's exposure to excessive noise and
safety hazards within areas around the airport and identifies areas likely to be impacted
by noise and flight activity created by aircraft operations at the airport. These impacted
areas include the Airport1Influence Area ("AIA"), the Clear Zone and the Flight Activity
Zone.
b. Within the AIA, the ALUCP establishes six safety zones for the purpose of evaluating
safety compatibility of new/future land use actions. The safety zone boundaries depict
relative risk of aircraft accidents occurring near the airport and are derived from general
aviation aircraft accident location data and data regarding the airport's runway
configuration and airport operational procedures. The ALUCP limits development
intensities in these zones by imposing floor area and lot coverage maximums, by
incorporating risk reduction measures in the design and construction of buildings,
and/or by restricting certain uses altogether. For example, all residential and virtually all
non-residential uses are considered incompatible land uses in some zones, while
considered to be either compatible or conditionally compatible with the airport in other
zones. Attachment 4 shows the McClellan-Palomar Airport, noise contours and
SANDAG's proposed housing units.
c. If the proposed SAN DAG land use assumptions are endorsed, an amendment to the
city's General Plan would be required to change the land use designation to Mixed-Use
Commercial or residential land uses within the existing Business Park in order to
effectuate the underlying assutnptions of SAN DAG staff. This is not a realistic
Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6,2021
Page 5
assumption. Further, the protected airspace referenced in the AIA and the ALUCP must
also be amended based on SANDAG's regional planning assumptions. (The FAA
establishes airspace protection zones in the airspace above and surrounding airports in
order to protect aircraft from obstructions such as buildings, towers, etc. in navigable
airspace.)
d. When a General Plan is adopted or amended, the allowable growth pattern of an area is
identified and the expansion or updating of the various land uses as specified in the
General Plan can occur throughout the planning horizon. Without such growth
considerations, the expansion or intensification of existing land uses could be
considered "growth inducing." Unplanned and uncontrolled growth may have significant
adverse impacts on the environment. CEQA requires a discussion of how a "project"
could increase population, employment or housing growth in surrounding areas and the
tmpacts resulting from this growth. The CEQA Guidelines indicate that a "project" would
normally have a significant effect on the environment if it would induce substantial
growth or a substantial concentration of population.
4. At this point, it is not clear if SANDAG's assumptions adequately contemplate the development
patterns included in the Sustainable Communities Strategy ("SCS")/Regional Transportation Plan
("RTP"), and Regional Air Quality Strategy ("RAQS"), local climate action planning business-as-
usual estimates, sub-regional traffic modeling, or the airspace assumptions of AIA and the
ALUCP.
5. The city seeks clarity on the Plan's underlying assumptions made to justify the proposed
extensive high-speed rail network considering the significant changes in travel behavior which
have occurred throughout the region as a result of the COVID-19 pandemic and due to the
advancements in disruptive technologies such as telecommuting, autonomous vehicles,
microtransit, etc.
a. Recent North County Transit District ("NCTD") Coaster ridership data show riders are
not returning to riding the Coaster in comparison to other modes of travel as shown in
Attachment 5.
b. This question is consistent with comments made by SANDAG's panel expert Bob Poole
regarding the impact of the COVID-19 pandemic on transit ridership and mega-transit
projects. (See comments by Bob Poole during the March 12, 2021 presentation to
SANDAG starting at timestamp 1:30 p.m,: https://youtu.be/q-eGbNYSJ 8?t-S410)
6. The city seeks clarity on why an alternatives analysis was not conducted with consideration of
other transit alternatives such as automated /shared vehicle technologies and personalized zero
emissions transit programs that are capable of utilizing the existing regional freeway
infrastructure in response to t hese recent developments explained in the above comment.
7. The city seeks clarity on why the Plan does not incorporate policies to promote roundabouts
over signalized intersections and include a budget line item under the Complete Corridors to
fund the construction of roundabouts at new locations and to replace signalized intersections
when found feasible. This clarification would support the Federal Highway Administration
("FHWA")'s project for Accelerating Roundabout Implementation in the United States and the
County of San Diego Air Pollution Control Board's support for implementing roundabouts to
address GHG and reduce fatalities.
8. The city seeks clarity on the project phasing proposed within the Plan. Specifically, the city is
seeking to understand the timing of implementation of unfunded Trans Net projects related to
Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page 6
the new projects presented within the Regional Plan. To support this, the city is requesting that
SANDAG input the information requested in Table 1 (Attachment 6).
9. The city seeks specific data on the proposed 200 miles of rail service contemplated in the Plan.
To support this, the city is requesting that SAN DAG input the information requested in Table 3
(Attachment 7). Specific questions:
a. Please provide more information about the scope of the high-speed rail alignments,
potential vehicle technologies and their cost estimates.
b. Will the Coaster keep the same rail alignment?
c. What funding is programmed or planned for the Carlsbad Village railroad trench and the
other projects along the current NCTD/Coaster Service right-of~way?
d. Will some of the tracks be at grade with fencing and trains traveling at 110 miles per
hour speeds?
SECTION 2: COMMENTS AND RECOMMENDATIONS
In addition to the comments on process and the Draft EIR provided above, city staff remain concerned
that there is not enough detail on the feasibility of implementation of this significant shift in
transportation strategy. On specific content in the plans, we outline our recommendations and
comments below:
1. Paying for the Plan:
The draft 2021 Regional Plan sets out an ambitious plan to build and operate a region-wide
system of transportation projects, programs and other improvements. This is a substantial role
for SAN DAG to play in supporting both the construction and operation of these projects,
programs and other improvements. SAN DAG should set annual revenue targets to directly fund
everything and should approve any recommended sustainable revenue tools to help meet these
targets. Many of the funding strategies will require legislative changes, or voter-approved
taxation. SAN DAG should clarify what will occur if the funding is not available, if opposition to
projects stops them from construction, and if General Plans in the region are not modified to
implement the Plan.
2. Appendix D: Sustainable Community Strategy Documentation:
Appendix D includes the Sustainable Communities Strategy, which outlines assumptions
included in the Activity Based Model 2+ ("ABM 2+"), updated for this. This model will be
necessary for use by publicly and privately initiated land use projects preparing documents for
consistency with VMT/CEQA Guidelines and Traffic Impact Analysis ("TIA") Evaluations. City staff
respect fully request direction from SAN DAG on how to conduct modeling with the service
bureau and how to factor in these assumptions applied to ABM 2+. Specifically, the addition of
pricing, parking costs for coastal communities, 10% teleworking and micromobility. SAN DAG
should provide direction on how this could be worked into General Plans that are updated every
5-20 years.
3. Appendix A: Transportation Projects, Programs, and Phasing:
Trips to and from school sites result in a significant congestion, VMT generation, and peak hour
delay throughout the region. Additional funding and projects should be recommended with a
specific focus on improving safety and multimodal access in and around school sites along with
programs to incentivize non~single occupancy vehicle trips to schools.
Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page 7
Table A.11: Given the proven success of the Carlsbad Connector microtransit pilot program, the
city agrees with the Plan's recommendations to provide similar on-demand microtransit syst ems
throughout North Count y at all mobility hub sites and major transit centers.
Table A.13: The segment of El Camino Real between Poinsettia Lane and Camino Vida Roble is
proposed to be widened from two to three lanes to prime arterial standards. With the adoption
of the city's General Plan, the city has determined that the widening of this portion of El Camino
Real is not feasible due to constrained right-of-way and would result in negative impacts to
other travel modes. City staff recommend removal of this proposed project recommendation
CB32 (that is, a 'do nothing1 scenario, or appraise and evaluate different mobility projects
and/or alternative designs).
The preferred lnterstate-5 freeway alternative identified in the North Coast Corridor ("NCC")
Final EIR/EIS is the refined 8+4 Buffer alternative, with four freeway lanes and two managed
lanes in each direction and completion by 2035. Appendix A, Table A.5 describes NCC project IDs
CC004, 007 -009 as "8F t o 6F+4MLJI with completion by 2050. While this might lead to further
study, it is not clear why there is a different freeway configuration (i.e., reduction in freeway
lanes) proposed. How does a reduction in lanes continue to meet NCC potential project benefits
of maintaining or improving traffic operations and improving the safe and efficient regional
movement of people and goods?
4. Active Transportation:
The city appreciates the Regional Plan's overall approach of providing a connected network of
high-qL1ality bicycle facilities throughout the region. Regional bikeways are recommended
throughout the city including along Palomar Airport Road which will provide a key east-west
connection and El Camino Real which will provide a new north-south bikeway connection
through the city. Both roadways are proposed to include "on-street blkeways". Due to the high
traffic volumes and vehicle speeds experienced along most of both corridors, t he city
recommends considering "off-street bikeways" or Class I facilities where feasible in order to
stimulate the shift from personal motor vehicle use to people choosing to bike.
It is extremely important that municipal transportation plans align with regional transportat ion
plans to achieve regional goals for land use and transportation and to promote the region
working together to build a cohesive regional transportation network. Considering there are
currently no mechanisms in place to ensure municipalities coordinate local transportation plans
with regional planning documents, the Plan should provide an approach on how SAN DAG plans
to engage with municipalities, especially in areas of potential disagreement or conflict (as
aforementioned in this subsection and others). It is also recommended that the Plan provide
additional direction regarding the application of protected bikeways in a variety of applicable
contexts. While vertical measures such as soft hit posts may be appropriate in lower volume and
lower speed roadways, arterial roadways with high traffic volumes and high speeds warrant
much more substantial physical protection from vehicles. In addition, special consideration
should be given at intersections and driveways which may be impacted due to the additional
width and visibility impacts created by protected bikeways.
City staff look forward to working with SAN DAG on improving mobility and land use access in the region
and building sustainable, equitable and healthy modes of transportation, and we appreciate the
opportunity to comment on the Plan that will help the region realize these goals.
Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6,2021
Page 8
If you have any questions related to comments on the transportation network, please contact Tom
Frank, Transportation Director/City Engineer, at Tom.Frank@carlsbadca.gov or if you need additional
information related to comments on the land use assumptions, please contact Eric Lardy, Principal
Planner, at Eric.Lardy@carlsbadca.gov.
Sincerely,
For
JEFF MURPHY
Community Development Director
TOM FRANI<
Transportation Director/City Engineer
Attachments:
1. Government Code 65020 (S.B. 375) Summary
2. City of Carlsbad Mobility Hubs
3. City of Carlsbad -Palomar Airport Road Mobility Hub Analysis
4. Palomar-Mclellan Airport Flight Paths
5. Recent NCTD Coaster Ridership Data
6. Table 1-Project Data Request
7. Table 3 -Detail of Proposed Rail Lines
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistaht City Manager
Ron l(emp, Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Director, Community Development
Don Neu, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager
Jason Geldert, Engineering Manager
Eric Lardy1 Principal Planner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Attachment 1: Government Code 65020 (S.B. 375) Summary
City of Carlsbad Comment Letter August 6, 2021
Government Code section (“GOV §”) 65080, also referred to as California Senate Bill 375 (Steinberg, 2008)
(“SB 375”), is one area of law that provides SANDAG with guidance to which a regional transportation plan
must be developed.
Among other things, the regional transportation plan that is developed “shall be an internally consistent
document” (GOV § 65080 (b)) and shall include a “sustainable communities strategy prepared by each
metropolitan planning organizations as follows” (GOV § 65080 (b)(2)(B)):
Each metropolitan planning organization shall prepare a sustainable communities strategy, subject
to the requirements of Part 450 of Title 23 of, and Part 93 of Title 40 of, the Code of Federal
Regulations, including the requirement to utilize the most recent planning assumptions considering
local general plans and other factors. The sustainable communities strategy shall (i) identify the
general location of uses, residential densities, and building intensities within the region, (ii) identify
areas within the region sufficient to house all the population of the region, including all economic
segments of the population, over the course of the planning period of the regional transportation
plan taking into account net migration into the region, population growth, household formation
and employment growth, (iii) identify areas within the region sufficient to house an eight‐year
projection of the regional housing need for the region pursuant to Section 65584, (iv) identify a
transportation network to service the transportation needs of the region, (v) gather and consider
the best practically available scientific information regarding resource areas and farmland in the
region as defined in subdivisions (a) and (b) of Section 65080.01 , (vi) consider the state housing
goals specified in Sections 65580 and 65581, (vii) set forth a forecasted development pattern for
the region, which, when integrated with the transportation network, and other transportation
measures and policies, will reduce the greenhouse gas emissions from automobiles and light trucks
to achieve, if there is a feasible way to do so, the greenhouse gas emission reduction targets
approved by the state board, and (viii) allow the regional transportation plan to comply with Section
176 of the federal Clean Air Act ( 42 U.S.C. Sec. 7506 ).
The 2021 draft Regional Transportation Plan includes a Sustainable Communities Strategy (“SCS”), as
required by SB 375 for the San Diego region (herein after called “draft Regional Plan”). The draft Regional
Plan indicates that “SB 375 requires the SCS to include a pattern for forecasted growth and development
that accomplishes the following: 1) When combined with the transportation network, the SCS will achieve
the regional GHG emission–reduction targets; 2). The SCS accommodates the Regional Housing Needs
Assessment (“RHNA”) Determination; and 3) The SCS utilizes the most recent planning assumptions.
(Reference p. 19 of the 2021 Regional Plan.)
Predicting the effect of transportation plans or projects on land uses and land use planning is critical to
developing context sensitive solutions for transportation projects. Therefore, utilization of the most
recent planning assumptions is not only necessary but is required as specifically stated therein GOV §
65080. If inconsistencies are found in the land use assumptions or adverse impacts are anticipated,
SANDAG should be actively engaged in the development of measures to address these issues.
The SANDAG Board of Directors approved the final RHNA plan with the final housing unit allocation on
July 10, 2020, which was based on the most recent land use planning assumptions and an adopted
methodology to allocate housing in accordance with GOV §§ 65584.04(d and m). The City of Carlsbad
received a total RHNA allocation of 3,873 units as a result of RHNA plan adoption. The adopted April 6,
2021 city’s Housing Element accommodates its housing needs through current zoning and other programs
Attachment A
Attachment 1: Government Code 65020 (S.B. 375) Summary
City of Carlsbad Comment Letter August 6, 2021
as needed to meet the city’s RHNA obligation at all income levels. The land use inputs derived from this
local planning document constitutes the most recent land use assumptions. On July 13, 2021 the
Department of Housing and Community Development found “the adopted housing element is in
substantial compliance with State Housing Element Law (Article 10.6 of the Gov. Code).
The most recent planning assumptions are critical for the development of the draft Regional Plan as the
document must comply with other specific state and federal mandates including a SCS per California
Senate Bill 375, which achieves GHG emissions reduction targets set by the California Air Resources Board
and compliance with federal civil rights (Title VI) requirements, environmental justice considerations, air
quality conformity, and public participation. To monitor compliance and attainment of state reduction
goals in GHG, GOV § 65080 (b)(2)) requires that:
(H)Prior to adopting a sustainable communities strategy, the metropolitan planning organization
shall quantify the reduction in greenhouse gas emissions projected to be achieved by the
sustainable communities strategy and set forth the difference, if any, between the amount of that
reduction and the target for the region established by the state board.
(J)(i) Prior to starting the public participation process adopted pursuant to subparagraph (F), the
metropolitan planning organization shall submit a description to the state board of the technical
methodology it intends to use to estimate the greenhouse gas emissions from its sustainable
communities strategy and, if appropriate, its alternative planning strategy.
There is inevitably some uncertainty regarding the use of projected future conditions. However, what is
certain is that the project will not operate under the conditions that exist today. There will be new
residential and employment growth in the intervening years between now and the proposed build‐out of
the draft Regional Plan. Nonetheless, projections utilized should represent the best available information
assembled by the local agencies with jurisdiction and expertise. Judgments about land use assumptions
utilized in the draft Regional Plan should be based on and supported by facts, adopted plans, and “most
recent planning assumptions,” rather than speculation and personal opinions. The land use assumptions
for “uses, residential densities, and building intensities within the region” (as required by GOV § 65080
(b)(2)(B)(i)) should also be the same, as that provided to the state board (as required per GOV §§ 65080
(b)(2)(H and J) in estimating and analyzing GHG from the SCS and the effect on growth and whether the
effects of that growth would be significant in the context of the region’s plans, natural setting, and growth
patterns. Ultimately, the SCS must demonstrate whether SANDAG can meet the per capita passenger
vehicle‐related GHG emissions targets for 2035 set by the California Air Resources Board (“CARB”).
SB 375 directs CARB to accept or reject the determination of SANDAG that its SCS submitted to CARB
would, if implemented, achieve the region’s GHG emissions reduction targets. CARB’s technical evaluation
of SANDAG’s draft Regional Plan would be based on all the evidence provided, including the models, the
data inputs and assumptions, the SCS strategies, and the performance indicators.
The transportation and planning assumptions are also extremely important as it is relied on for other
master planning exercises. The Regional Air Quality Strategy (“RAQS”) relies on information from CARB
and SANDAG for information regarding projected growth in the cities and San Diego County. This in turn
is utilized to address other state requirements, including the San Diego portion of the California State
Implementation Plan (“SIP”) and promulgating their own rules and regulations regarding air quality in the
region or to address federal requirements.
Attachment A
Attachment 1: Government Code 65020 (S.B. 375) Summary
City of Carlsbad Comment Letter August 6, 2021
The analysis of land use impacts for transportation projects is guided by FHWA Technical Advisory T 6640.8
and the CEQA Guidelines.
Under the FHWA Technical Advisory T 6640.8 (G)(1), Guidance for Preparing and Processing
Environmental, states:
This discussion [of land use] should identify the current development trends and the State and/or
local government plans and policies on land use and growth in the area which will be impacted by
the proposed project. These plans and policies are normally reflected in the area's comprehensive
development plan, and include land use, transportation, public facilities, housing, community
services, and other areas.
The land use discussion should assess the consistency of the alternatives with the comprehensive
development plans adopted for the area and (if applicable) other plans used in the development
of the transportation plan required by Section [23 U.S. Code §] 134. The secondary social,
economic, and environmental impacts of any substantial, foreseeable, induced development
should be presented for each alternative, including adverse effects on existing communities.
Where possible, the distinction between planned and unplanned growth should be identified.
There is also a requirement to analyze the land use planning inconsistencies per CEQA Guidelines §
15126.2(a), which specifies that an EIR for a proposed project include:
The Significant Environmental Effects of the Proposed Project. An EIR shall identify and focus on
the significant effects of the proposed project on the environment. In assessing the impact of a
proposed project on the environment, the lead agency should normally limit its examination to
changes in the existing physical conditions in the affected area as they exist at the time the notice
of preparation is published, or where no notice of preparation is published, at the time
environmental analysis is commenced. Direct and indirect significant effects of the project on the
environment shall be clearly identified and described, giving due consideration to both the short‐
term and long‐term effects. The discussion should include relevant specifics of the area, the
resources involved, physical changes, alterations to ecological systems, and changes induced in
population distribution, population concentration, the human use of the land (including
commercial and residential development), health and safety problems caused by the physical
changes, and other aspects of the resource base such as water, historical resources, scenic quality,
and public services. The EIR shall also analyze any significant environmental effects the project
might cause or risk exacerbating by bringing development and people into the area affected. For
example, the EIR should evaluate any potentially significant direct, indirect, or cumulative
environmental impacts of locating development in areas susceptible to hazardous conditions (e.g.,
floodplains, coastlines, wildfire risk areas), including both short‐term and long‐term conditions, as
identified in authoritative hazard maps, risk assessments or in land use plans addressing such
hazards areas.
Since the new land use assumptions are being utilized, as described by this letter, the EIR that is prepared
shall also analyze any significant environmental effects the project might cause by bringing development
and people into the area affected. The following are the basic steps in analyzing land use impacts as part
of the community impact assessment process:
Attachment A
Attachment 1: Government Code 65020 (S.B. 375) Summary
City of Carlsbad Comment Letter August 6, 2021
1.Inventory the existing land use patterns (including undeveloped land), development trends, and
transportation systems. The inventory of existing land uses should include the following land use
types: residential, commercial, industrial, recreational, institutional, public services, community
services, emergency services, transportation, utilities, agriculture, and undeveloped land in the
study area. The study area should include the surrounding community that is generally
associated with the project area within which community impacts could occur. The inventory
should also address development trends and identify recent developments in the study area to
include the development’s name, size, status (planned, built, under construction), and the
jurisdiction in which it is located. A map showing the location of existing and planned land uses
in the area should also be prepared.
2.Determine whether the project is consistent with local and regional policies that govern land use
and development. For the consistency analysis, the policies and programs considered in the
analysis should include: transportation plans and programs (MTPs/RTPs and MTIPs/RTIPs),
regional growth plans, local General Plans that establish land use and growth management
policies for the study area, and any specific or pipeline development proposals. This analysis
should also include a discussion of consistency with the Coastal Zone Management Act of 1972,
California Coastal Act of 1976, the National Wild and Scenic Rivers Act (16 USC 1271) and the
California Wild and Scenic Rivers Act (Pub. Res. Code § 5093.50 et seq.). After preparing a
preliminary list of relevant plans to be considered in the analysis, the SANDAG planner should
meet with the staff of the various agencies to review the list to determine if it is complete and
revise the list as necessary.
3.Assess the changes that would occur in land uses and growth with and without the project.
4.The draft Regional plan and each project alternative should be considered separately since the
results may be different.
5.Develop measures to avoid, minimize, and/or mitigate potential adverse effects.
The resulting environmental analysis should identify the current development trends and the State and/or
local government plans and policies on land use and growth in the area which will be impacted by the
proposed project. These plans and policies are normally reflected in local General Plans. If found to be
consistent, then the findings in the EIR should be documented in the report and no further analysis or
action is necessary. When found not to be inconsistent with a policy or program, then consideration must
be given to modifying the draft Reginal Plan alternative to make it consistent, or measures to address the
inconsistency must be developed. SANDAG should be actively engaged in the development of measures
to address these issues and be prepared to assess the consistency of the draft Regional Plan and
alternatives with the comprehensive development plans adopted for the area and (if applicable) other
plans used in the development of the transportation plan required by Section 23 U.S. Code § 134. For any
new land use growth assumptions, the secondary social, economic, and environmental impacts of any
substantial, foreseeable, induced development should be presented for the draft Regional Plan and each
alternative, including adverse effects on existing communities. The results should be shared with the
public during the public involvement process, e.g., at community meetings, etc. Public input should be
considered by SANDAG and if necessary, the findings of the analysis should be revised to reflect
information gained through the public involvement process.
Attachment A
Carlsbad
Village
(Coastal)
Carlsbad Palomar
(Major Employment
Center)1 2
1
125
65 10
248
5
79521
581
228
1010 217 4916241517851
SE
NW
NE
SW
Carlsbad
Village
Coastal 14087 6430 15095 6539 9290 16177 7075 9667 17293 7607 10044
Carlsbad
Palomar
Major
Employment
Center
12853 5475 12275 5461 61074 19465 8503 67005 21080 9265 72900
N/A Outside of
Hubs
86239 34247 88793 35855 13896 84039 35855 14345 83929 35855 14900
N/A All of
Carlsbad
113179 46152 116163 47855 84260 119681 51433 91017 122302 52727 97844
Hub Name Hub Type Total
Population
2016
Total
Houses
2016
Total
Population
2025
Total
Houses
2025
Total Jobs
2025
Total
Population
2035
Total
Houses
2035
Total Jobs
2035
Total
Population
2050
Total
Houses
2050
Total Jobs
2050
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESSFOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages,consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the Cityof Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
SANDAG Mobility Hubs
#Mobility Hub MGRAs with 2016-2050 Increased Unit Change
Carlsbad Mobility Hubs
Carlsbad MGRAs
Carlsbad Quadrant
Carlsbad Boundary
0 21
Miles
Attachment A
3
83
34 21
50
14
2
2
1
1
4
38
5
35
18 27
72
72
50 227 36
63 8
92328603615141
231411158161117
87
2
171
11
24
83
32
8
6
4
1
3 1
2
36
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS
FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages,
consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City
of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
#Mobility Hub MGRAs with
2016-2050 Increased Unit Change
Carlsbad Mobility Hubs
Carlsbad MGRAs
Carlsbad Boundary
0 0.50.25
Miles
Carlsbad Village Mobility Hub MGRAs
Attachment A
Carlsbad
Village
(Coastal)
Carlsbad Palomar
(Major Employment
Center)
1
2
1
125
65 10
248
5
79
521
581
228
1010 217
49
162
415 178 51
SE
NW
NE
SW
Copyright nearmap 2015
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with 2016-2050 Increased Unit Change
General Plan Land Use
L, Local Shopping Center
OS, Open Space
P, Public
PI, Planned Industrial
PI/O, Planned Industrial/Office
R, Regional Commercial
R-1.5, Residential 0-1.5 du/ac
R-15, Residential 8-15 du/ac
R-23, Residential 15-23 du/ac
R-4, Residential 0-4 du/ac
R-8, Residential 4-8 du/ac
TC, Transportation Corridor
VC, Visitor Commercial
VC/OS, Visitor Commercial/Open Space
0 0.250.13
Miles
MGRA Closer Look Attachment A
R-4
OS
Carlsbad Palomar
(Major Employment
Center)
1 Unit
Change 2 Unit Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
R-15, Residential 8-15 du/ac
R-4, Residential 0-4 du/ac
VC/OS, Visitor Commercial/Open
Space
0 0.010.01
Miles
MGRA: 14249 Attachment A
R-4
OS Carlsbad Palomar
(Major Employment
Center)
1 Unit Change
2 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
R-15, Residential 8-15 du/ac
R-4, Residential 0-4 du/ac
TC, Transportation Corridor
VC/OS, Visitor Commercial/Open
Space
0 0.040.02
Miles
MGRA: 14251 Attachment A
VC TC
R-8
Carlsbad Palomar
(Major Employment
Center)
1 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
R-8, Residential 4-8 du/ac
TC, Transportation Corridor
VC, Visitor Commercial0 0.010.01
Miles
MGRA: 14265 Attachment A
L
R-23
Carlsbad Palomar
(Major Employment
Center)
125 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
L, Local Shopping Center
PI, Planned Industrial
R-23, Residential 15-23 du/ac
0 0.020.01
Miles
MGRA: 17984 Attachment A
OS
Carlsbad Palomar
(Major Employment
Center)
65 Unit
Change
5 Unit Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
R-15, Residential 8-15 du/ac
0 0.040.02
Miles
MGRA: 22902
Majority owned by
State of CA
Small portion owned by Kelly Land Co. and Agua Hedionda
Lagoon Foundation
Attachment A
OS
PI
R-4
Carlsbad Palomar
(Major Employment
Center)
10 Unit
Change
248 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
R-4, Residential 0-4 du/ac
0 0.040.02
Miles
MGRA: 22906 Attachment A
OS
PI
R-4
Carlsbad Palomar
(Major Employment
Center)
10 Unit
Change
248 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
R-4, Residential 0-4 du/ac
0 0.030.01
Miles
MGRA: 22910 Attachment A
OS
OS
R-4
OS
Carlsbad Palomar
(Major Employment
Center)
65 Unit
Change
5 Unit Change
217 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
R-1.5, Residential 0-1.5 du/ac
R-15, Residential 8-15 du/ac
R-4, Residential 0-4 du/ac0 0.040.02
Miles
MGRA: 22917 Attachment A
PI
OS
Carlsbad Palomar
(Major Employment
Center)
79 Unit
Change217 Unit
Change
162 Unit
Change 178 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
0 0.030.01
Miles
MGRA: 22925 Attachment A
PI
VC
OS
Carlsbad Palomar
(Major Employment
Center)
521 Unit
Change
581 Unit
Change
1010 Unit
Change
415 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
R, Regional Commercial
VC, Visitor Commercial0 0.050.03
Miles
MGRA: 22926
Owned by Gemological Institute
of America
Owned by
CB Ranch
Enterprises
OS
Attachment A
OS
VC
PI
Carlsbad Palomar
(Major Employment
Center)
5 Unit
Change
521 Unit
Change
581 Unit
Change
1010 Unit
Change
415 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
VC, Visitor Commercial
0 0.040.02
Miles
MGRA: 22928Owned by M and A Gabaee
OS
Owned by Grand
Pacific Carlsbad LP
VC designation
does not allow residential uses
Attachment A
PI
PI/O
OS
OS
Carlsbad Palomar
(Major Employment
Center)
5 Unit
Change
79 Unit
Change217 Unit
Change
162 Unit
Change
178 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
PI/O, Planned Industrial/Office
0 0.030.01
Miles
MGRA: 22930 Attachment A
PI
Carlsbad Palomar
(Major Employment
Center)
49 Unit
Change
51 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
PI, Planned Industrial
0 0.020.01
Miles
MGRA: 22931 Attachment A
PI
PI/O
OS
Carlsbad Palomar
(Major Employment
Center)
79 Unit
Change
217 Unit
Change
162 Unit
Change
178 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
P, Public
PI, Planned Industrial
PI/O, Planned Industrial/Office0 0.030.01
Miles
MGRA: 22933 Attachment A
OS
VCPI
Carlsbad Palomar
(Major Employment
Center)
521 Unit
Change
581 Unit
Change
1010 Unit
Change
415 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
VC, Visitor Commercial
0 0.020.01
Miles
MGRA: 22934 Attachment A
OS
PI
Carlsbad Palomar
(Major Employment
Center)
79 Unit
Change
217 Unit
Change
162 Unit
Change
178 Unit
Change
51 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
P, Public
PI, Planned Industrial
PI/O, Planned Industrial/Office0 0.030.01
Miles
MGRA: 22936 Attachment A
PI
Carlsbad Palomar
(Major Employment
Center)
49 Unit
Change
178 Unit
Change
51 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
P, Public
PI, Planned Industrial
0 0.010.01
Miles
MGRA: 22937 Attachment A
PI
VC
VC
OS
Carlsbad Palomar
(Major Employment
Center)
521 Unit
Change
581 Unit
Change
228 Unit
Change
1010 Unit
Change415 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
R, Regional Commercial
VC, Visitor Commercial0 0.040.02
Miles
MGRA: 22941 Attachment A
PI
VCCarlsbad Palomar
(Major Employment
Center)
581 Unit
Change
228 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
VC, Visitor Commercial
0 0.020.01
Miles
MGRA: 22947 Attachment A
70 dB
C
N
E
L
65 dB CN
E
L
60
d
B
C
N
E
L
70 dB CNEL
65 dB CNEL
60 dB CNEL
75+
d
B CN E L
79
217
49
162
178
51
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City
of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of
any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.
Carlsbad Quadrant
MGRAs with 2016-2050
Increased Unit Change
Airport MGRA
ALUCP 2010 Safety Zones:
Zone 1
Zone 2
Zone 3
Zone 4
Zone 5
Zone 6
0 0.080.04
Miles
Notes
1. 2010 McClellan-Palomar Airport ALUCP Policy 3.3.3 prohibits residential uses on properties, or portions of properties,
with airport noise exposures greater than 65 dB CNEL.
2. 2010 McClellan-Palomar Airport ALUCP Policy 3.4.4 prohibits residential uses on properties, or portions of properties,
within airport safety zones 1, 2 and 5.
Carlsbad Palomar Mobility Hub MGRAs Near AirportAttachment A
Attachment 5
PLEASE NOTE: PRELIMINARY RIDERSHIP DATA ‐ UNAUDITED AND SUBJECT TO ADJUSTMENTS
Month
FY21 FY20 Variance %
July 10,263 149,515 (139,252) (93.1%)
Aug 9,412 133,482 (124,070) (92.9%)
Sept 10,020 114,233 (104,213) (91.2%)
Oct 10,968 111,045 (100,077) (90.1%)
Nov 9,232 94,551 (85,319) (90.2%)
Dec 7,519 83,951 (76,432) (91.0%)
Jan 6,848 98,791 (91,943) (93.1%)
Feb 7,866 91,845 (83,979) (91.4%)
Mar 11,203 46,510 (35,307) (75.9%)
Apr 15,184 5,244 9,940 189.5%
May 19,214 6,207 13,007 209.6%
June**44,978 8,734 36,244 415.0%**Not final as of July 19, 2021
YTD Total 162,707 0 (781,401)
FY Total 162,707 944,108
Month
FY21 FY20 Variance %
July 10,263 131,218 (120,955) (92.2%)
Aug 9,412 112,100 (102,688) (91.6%)
Sept 10,020 92,159 (82,139) (89.1%)
Oct 10,968 105,601 (94,633) (89.6%)
Nov 9,232 80,912 (71,680) (88.6%)
Dec 7,519 75,534 (68,015) (90.0%)
Jan 6,848 89,920 (83,072) (92.4%)
Feb 7,866 84,613 (76,747) (90.7%)
Mar 11,203 44,368 (33,165) (74.7%)
Apr 15,184 5,244 9,940 189.5%
May 17,221 6,207 11,014 177.4%
June**35,192 8,734 26,458 302.9%**Not final as of July 19, 2021
YTD Total 150,928 0 (685,682)
FY Total 150,928 836,610
Month
FY21 FY20 Variance %
July - 9,415 (9,415) (100.0%)
Aug - 14,348 (14,348) (100.0%)
Sept - 8,449 (8,449) (100.0%)
Oct - 3,247 (3,247) (100.0%)
Nov - 8,385 (8,385) (100.0%)
Dec - 4,387 (4,387) (100.0%)
Jan - 3,218 (3,218) (100.0%)
Feb - 5,181 (5,181) (100.0%)
Mar - 665 (665) (100.0%)
Apr - 0 0
May 1,387 0 1,387
June**5,881 0 5,881 **Not final as of July 19, 2021
YTD Total 7,268 0 (50,027)
FY Total 7,268 57,295
Month
FY21 FY20 Variance %
July - 8,882 (8,882) (100.0%)
Aug - 7,034 (7,034) (100.0%)
Sept - 13,625 (13,625) (100.0%)
Oct - 2,197 (2,197) (100.0%)
Nov - 5,254 (5,254) (100.0%)
Dec - 4,030 (4,030) (100.0%)
Jan - 5,653 (5,653) (100.0%)
Feb - 2,051 (2,051) (100.0%)
Mar - 1,477 (1,477) (100.0%)
Apr - 0 0
May 606 0 606
June**3,905 0 3,905 **Not final as of July 19, 2021
YTD Total 4,511 0 (45,692)
FY Total 4,511 50,203
COASTER - TOTAL RIDERSHIP
COASTER - WEEKDAY
COASTER - SATURDAY
COASTER - SUNDAY
Attachment A
T bl 1 P . t I f a e ro1ec n orma 10n f R eques
Project
San Dieguito Lagoon Double Track and Platform
Batiquitos Lagoon Double Track and
Bridqe Replacement
Eastbrook to Shell Double Track
Carlsbad Villaqe Trench
La Costa to Swami Double Track
San Onofre Bridge Replacements
Rose Canyon Bridqe Replacements
ATTACHMENT 6 - Project Data Request
t
Estimated Current Draft RTP Assumed
Total Project Planned Year of Assumed Year Federal/State Cost Construction of Construction Matching Funding (%)
Attachment A
ATTACHMENT 7 - Detail of Proposed Rail Lines
T bl 3 D t ·1 f P a e e a1 o ropose al mes d R ·1 L"
Average Interoperable
Rail Mode (CR, Directional % of Directional Number Distance Average with
LR, HSR, Miles Miles Grade of Between Speed COASTER Hybrid) Separated/Tunnel Stations Stations Operated equipment
(Y/N) New Rail Line
Attachment A
August 28, 2023
SANAG Regional Plan SEIR
C/O Kirsten Uchitel, Associate Planner
San Diego Association of Governments
401 B Street, Suite 800
San Diego CA 92101
Via: RegionalPlanSEIR@sandag.org
Attachment C
( City of
Carlsbad
RE: CITY OF CARLSBAD COMMENTS ON DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT
FOR THE PROPOSED AMENDMENT TO THE 2021 REGIONAL PLAN
Dear Ms. Uchitel:
The City of Carlsbad ("city") appreciates the opportunity to provide comments on the draft
Supplemental Environmental Impact Report ("SEIR") for the proposed amendment to the 2021 Regional
Plan ("Plan Amendment"). The SEIR is dated July 2023. The Regional Plan ("Plan") is an important plan
for the region and will guide the next phase of growth for the member agencies of the San Diego
Association of Governments ("SAN DAG"), including the city. An effectively designed and implemented
regional transportation plan would help ensure improved transportation options for area residents,
businesses and other community members, as well as meaningful reductions in greenhouse gas ("GHG")
emissions and improved quality of life as we grow our communities.
The California State Legislature created specific provisions to promote streamlining environmental
review for certain types of projects. Determining in a particular situation whether it is appropriate to
prepare a subsequent or supplemental EIR is a project-specific consideration, based on many factors.
Pursuant to CEQA Guidelines section 15163(b), "[a] supplement to the EIR need only the information
necessary to make the previous EIR adequate for the project as revised." CEQA Guidelines section 15163
provides, in pertinent part: "(a) The lead or responsible agency may choose to prepare a supplement to
an EIR rather than a subsequent EIR if: (1) Any of the conditions described in Section 15162 would
require the preparation of a subsequent EIR, and (2) Only minor additions or changes would be
necessary to make the previous EIR adequately apply to the project in the changed situation. Thus,
CEQA Guidelines section 15163 applies when an EIR can be made adequate by additions or changes that
respond to a limited set of issues, whereas a subsequent EIR is necessary when the previous EIR must be
rewritten from the ground up to make its environmental analysis adequate. For the reasons stated in
this letter, a subsequent EIR or new EIR is appropriate. There is no support to proceed under CEQA's
supplemental review provisions because the original environmental document does not retain
informational va lue to the ongoing decision-making process. It is only logical that SAN DAG start from the
beginning under CEQA section 21151 by conducting an initial study to determine whether the project
may have substantial effects on the environment. Failure to satisfy this CEQA obligation constitutes a
prejudicial abuse of discretion, which is precisely what CEQA seeks to avoid, and it undermines the
public's ability to obtain a fully informed evaluation of the project.
Transportation & Community Development Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 442-339-2600 t
City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed
Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 2
The city previously submitted comments on the Program Environmental Impact Report ("PEIR") for the
Plan on Oct. 11, 2021. As the proposed SEIR is a supplement to that document and is largely based on
the information, assumptions and analysis therein (e.g., regarding land use), many of the comments
remain valid and are repeated in this letter.
The city seeks to ensure that SAN DAG prepares an environmental document that is adequate, complete
and fully discloses the potential significant adverse effects of the Amended Plan. To implement the
principles of CEQA, SAN DAG should correct previous deficiencies and not truncate the requisite
cumulative impact analysis {CEQA Guidelines section 15168{b)(2)), use improper baselines (CEQA
Guidelines section 15152), or foreclose the consideration of any alternative or mitigation measure that
would ordinarily be part of CEQA review of a regional plan (CEQA Guidelines section 15004(b)(2)(B)). The
former EIR failed to provide decision-makers and the public with all of the relevant information
regarding the project that is necessary for informed decision-making and public participation.
CEQA prescribes review procedures a public agency must follow before approving or carrying out
proposed projects. Those procedures emphasize the importance of public participation in the CEQA
process, including mandatory opportunities for public review and comment and the lead agency's
obligation to provide meaningful responses to comments received. SAN DAG failed to comply with CEQA
by conducting the public review process for the Amended Plan and the SEIR separately though with
some overlap, which has resulted in a disconnected, piecemeal and rushed process in which comments
made on the Amended Plan were not responded to or incorporated into the SEIR.
The public and affected agencies like the city must submit comments on the SEIR without knowing
whether or how SAN DAG has responded to previous comments on the Amended Plan. SAN DAG has
already indicated that the SAN DAG Board is expected to review and consider the Amended Plan and the
Final SEIR on October 27, 2023. Thus, there appears to be insufficient time for SANDAG to evaluate
comments received on the SEIR, prepare meaningful responses and make those responses available as
required by CEQA Guidelines sections 15087 and 15088. As such, SAN DAG is foreclosing on a
"meaningful public participation process" and subjecting itself to a claim that SAN DAG is prejudicing the
outcome of the environmental review process by ensuring there is little opportunity for public
comments to influence the Amended Plan's program and design. ("Environmental review derives its
vitality from public participation" (Ocean View Estates Homeowners Assn. V. Montecito Water Dist.
(2004) 116 Cal. App. 4th 396, 400.)
If the issues that were addressed in the city's August 8, 2023 comment letter on the Amended Plan
(Attachment 1) are not addressed in the SEIR, the SEIR will.be insufficient as an informative document
and it will reduce the validity and efficacy of the Amended Plan, including its use of faulty assumptions
regarding land use and population growth to comply with state and federal mandates, such as the
Sustainable Communities Strategy and GHG reduction targets. These faulty assumptions misrepresent
the vital land use-transportation planning connections and do nothing to reduce GHG and will instead
result in unplanned increases to traffic, GHG, and result in increased housing unaffordability.
While the city supports the main concepts of the Vision in the Regional Plan, the 5 Big Moves, there
needs to be an adequate analysis on how the Amended Plan will be implemented, and what will occur if
there are changes to the projected growth, technology, and/or state law impacting existing conditions.
City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed
Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 3
The city appreciates SAN DAG adding language, as the city requested, that provides additional
clarification on land use authority. This language is needed to clarify that land use authority rests with
the local jurisdiction. Although this principle should be obvious, the inconsistencies between the
Amended Plan and the city's General Plan discussed below suggest that it has been ignored.
While the proposed amendment is focused on the removal of the regional road usage charge from the
2021 Regional Plan, the Amended Plan also provides updated regional employment figures, revenue
assumptions, traffic volumes, etc., all of which are significant changes and/or new information of
substantial importance. In addition, the city made the following substantive comments on the adequacy
of the PEIR in its Oct. 11, 2021, letter on that document. These comments remain valid and highlight
significant concerns that stem largely from faulty land use assumptions contained in the PE IR and 2021
Regional Plan, which the SEIR does not modify.
1. The PEIR/SEIR fail to disclose the Plan's and Amended Plan's inconsistencies with the Carlsbad
General Plan and to analyze the related potential environmental impacts. The Legislature has
declared a policy "to protect California's land resource, to ensure its preservation and use in ways
which are economically and socially desirable in an attempt to improve the quality of life in
California." (Gov. Code§ 65030.) To further this policy, each of the state's cities and counties is
required to adopt a comprehensive, long-term general plan for the physical development of that city
or county. (Gov. Code § 65300.) Accordingly, the city adopted a General Plan in compliance with
state law and most recently updated it in 2015. the city's General Plan "sets forth land use
compatibility policies applicable to future development in the vicinity." These policies are designed
to ensure that future land uses in the surrounding area will be compatible with the realistically
foreseeable activity in the city.
2. Growth projections for the region are based on population, vehicle trends and land use plans
developed by the cities and the County of San Diego (''County") as part of their general plans. Mariy
different regional documents rely on the same information to develop water demand projections,
air quality performance standards, emission inventories, and emission reductions. The Amended
Plan would result in an increase in residential land use resulting in corresponding increases in
indirect and cumulative vehicle miles traveled ("VMT"). GHG emissions and air pollutant emissions,
as well as inconsistencies with RAQS, SIP, and regional traffic modeling. This was not disclosed in the
PEIR and thus influences the analysis in the SEIR. CEQA Guidelines section 15125(a) requires EIRs to
contain a description of the physical environmental conditions in the vicinity of the project, as they
exist at the time the NOP is published, or if no NOP is published, at the time environmental analysis
is commenced, from both a local and regional perspective. Existing general plans, including their
Land Use Elements, should have been utilized for this baseline analysis and to derive future
population and housing estimates.
In the PEIR, SAN DAG should have evaluated and clearly articulated the Plan's potential impacts on
land use. Instead, the PEIR states that: "The forecasted development of the proposed Plan is based
on the Series 14 Regional Growth Forecast SCS land use pattern, which is, in turn, based on the
adopted general plans of the cities and County of San Diego and on the most recent planning
assumptions, considering local general plans and other factors, as required by SB 375." This
statement is incorrect. Thus, the Amended Plan is inconsister,t with the city's General Plan because
it proposes residential land uses where s~ch uses are not authorized by the General Plan. The city's
City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed
Amendment to the 2021 Regional Plan
August 28, 2023
Pa e4
comments on the PEIR indicated that it appeared to ignore this inconsistency in concluding there
would be less than significant impacts for the years 2025, 2035 or 2050.
The city has two mobility hubs in the Plan and PEIR: McClellan-Palomar Airport, the fifth largest
employment center in the region; and Carlsbad State Beach and Carlsbad Village as "Tier 3 and Tier
4" employment centers. The city's Aug. 6, 2021 comments on the PEIR included an attachment that
showed a summary of the Mobility Hubs and housing units assumed in the Series 14 Growth
Forecast for the year 2050. The assumptions in the updated Series 14 Growth Forecast contain
inconsistencies with respect to at least three locations in which density is shown to be inconsistent
with the city's General Plan, the Airport Land Use Compatibility Plan and good planning principles.
These three problematic areas are:
a. 736 units on parcels immediately adjacent to the McClellan-Palomar Airport runway. The
location of the airport within this mobility hub was shared with SANDAG staff multiple times
at workshops. This is inconsistent with the regulations provided by the San Diego County
Regional Airport Authority and conflicts with standard planning principles for siting housing
away from hazards;
b. 2,755 units on existing developed resort properties and open space dedicated lands
adjacent to Legoland; and
c. 65 units in a preserved open space area.
Since it does not change the Plan's land use assumptions, the Amended Plan continues to propose
residential uses in areas which are not designated for such uses in the city's General Plan and the
McClellan-Palomar Airport Land Use Compatibility Plan, as discussed below. This inconsistency
results in potential significant impacts with respect to land use, public safety and noise. (See CEQA
Guidelines, Appendix G, §§ IX(e), Xl(b), Xlll(c).) Because residential use is not authorized in those
locations in the city's General Plan, the Amended Plan's assumption that residential use will occur
there results in an overstatement of the extent to which other impacts, such as those associated
with VMT, GHG and other pollutant emissions, will be reduced and understates those potential
impacts of the Amended Plan. If the SEIR does not meaningfully address the inconsistency with the
general plans of all member jurisdictions, which if not implementing this plan will cause a significant
environmental impact due to the conflict with any land use plan, policy or regulation adopted for
the purpose of avoiding or mitigating an environmental effect.
Multiple areas in Carlsbad are controlled as to their use and activity density and intensity through
their spatial association with the McClellan-Palomar Airport, and some of these areas restrict
residential use. The McClellan-Palomar Airport is defined by the Federal Aviation Administration
("FAA") as a commercial service airport that, in addition to private aircraft, has regularly scheduled
commercial flights. Further detail on thiswas included in the city's August 6, 2021, comment letter
on the draft Plan, part of Attachment 1 to this letter.
3. Table 4.5-1 indicates changes in demand for all modes of travel from the approved Plan to the
Amended Plan under 2025 conditions. Given that the SEIR states that the roadway user charge
would not be implemented until year 2035 conditions please explain why there would be any
changes under the 2025 scenario.
4. As expressed in comments on the EIR, the analysis methodology used for the Transportation chapter
does not provide a description of how the ABM2+ analysis outputs such as Average Daily Trips
City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed
Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 5
(ADT), Mode Share, and Vehicle Miles Traveled (VMT) are calculated for each of the travel modes.
Without this information, it is difficult to understand how the transportation network improvements
impact these analysis metrics for future year conditions and for consideration of potential project
mitigations. The document link provided in response to this prior comment in the footnote with
descriptions of the ABM2+ model outputs is not currently active.
5. The SEIR should evaluate the impact of the reduction in total funding resulting from the removal of
the road usage charge. This evaluation should encompass the Regional Plan's reduced capacity to
execute projects, including but not limited to additional roadways, transit systems, and active
transportation. Furthermore, the analysis should address how the curtailment of projects could
influence broader shifts in travel modes, vehicle miles traveled (VMT), and resulting GHG emissions.
6. The alternatives analysis does not describe a range of reasonable alternatives to the project because
it does not include an analysis of an alternative that evaluates what will occur if the faulty land use,
and therefore transportation, assumptions do not occur. The alternatives are constructed largely to
reduce impacts through even more focused growth in Mobility Hubs and through increased value
pricing and revenue generation. While it may be true these would reduce impacts, it does not
provide policy makers or members of the public a reasonable range of alternatives as required by
CEQA. Additionally, due to SB 9, which became effective Jan. 1, 2022, the reetuction in population
assumed in suburban areas outside of the mobility hubs is both inconsistent with reality and with
planning principles required by the California Department of Housing and Community Development
to not concentrate all future growth in certain locations.
CEQA and the CEQA Guidelines require that an EIR describe all reasonable alternatives to the project
and any feasible mitigation measures (Laurel Heights Improvement Assn. v. Regents of University of
California (1988) 47 Cal. 3d 400, 404). Because the SEIR does not discuss future land use conflicts
with applicable general plans (as well as other city land use documents, such as the Local Coastal
Program, Habitat Management Plan and McClellan-Palomar Airport Land Use Compatibility Plan), it
fails to disclose ways to reduce or eliminate the environmental impacts of the project and to
respond to the major environmental issues identified during the planning process (as a project
alternative or as a mitigation measure) pursuant to Public Resources Code section 21002 (see
Friends of the Old Trees v. Department of Forestry & Fire Protection (1997) 52 Cal. App. 4th 1383).
The SEIR's analysis of the project alternatives and mitigation measures is incomplete and, therefore,
inadequate.
Section 15126 of the CEQA Guidelines requires that all aspects of a project must be considered
when evaluating its impact on the environment, including planning, acquisition, development, and
operation. The implementation and challenges to fund the Amended Plan have not been
appropriately discussed. One of the project alternatives should accommodate transportation
investments that can be reasonably funded within the horizon of the plan under the current
("known") funding mechanisms. Because the SEIR does not discuss a financially constrained
alternative, the analysis of the project alternatives and mitigation measures is incomplete, and
therefore, inadequate.
City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed
Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 6
In addition to the comments above, SEIR Alternative 3, the same as described in Chapter 6 of the
approved Plan PEIR, includes the road usage charge. Following adoption of the approved Plan, the
SAN DAG Board directed staff to prepare a focused amendment to the approved Plan that deletes
the regional road usage charge. SEIR Section 2.3, Project Objectives, notes, "the proposed
Amendment [to the 2021 Regional Plan] has the additional objective of removing the regional road
usage charge while continuing to meet State and federal planning requirements, regional GHG
reduction targets, and federal air quality conformity standards." As Section 6 states, Section 15126.6
of the CEQA Guidelines requires that an EIR "describe a range of reasonable alternatives to the
project ... which would feasibly attain most of the basic objectives of the project..." Alternative 3's
inclusion of the road usage charge conflicts with the fundamental reason for the Amended Plan. This
alternative should be replaced or modified to exclude the road user charge.
7. The alternatives analysis also does not satisfy federal requirements. Federal legislation requires that
the Plan include a financially constrained scenario (23 USC 134(h)(2)(B)). "Financially constrained"
means that the RTP only includes projects that the region can afford to complete with existing
revenues or with revenues that are reasonably expected to be available. The RTP must consider not
only the cost of expanding the transportation system to meet future demand, but also the cost of
maintaining the existing system. Costs must not exceed likely revenues. To date, there has been no
such evaluation in the alternatives section. Although there is no mandate to include project
alternatives in a Supplemental EIR, the SEIR must include financially constrained scenario to fulfill
the federal requirement that the Amended Plan be financially constrained (i.e., budgeted). The
removal of the road usage charge from the network has been replaced with speculative financing
options. Rather, SANDAG must estimate revenues that are reasonably expected to be available from
known federal, state, local, and private resources for transportation funding to implement the
proposed projects.
Projecting revenues and expenditures over this length of a planning period will be difficult. The
analysis should rely partly on historical funding patterns from state and federal sources. In addition,
the year of expenditure must be considered when estimates for capital projects are developed (this
is required by the Federal Surface Transportation Act).
8. Where regional planning processes have not resulted in the adoption of plans or regulations relating
to the environment, CEQA requires public agencies to engage in an analysis of the impacts of the
proposed project on the environment. (Public Resources Code§§ 21000; 21002.1; 21003.l(b);
21080(d); 21081; 21082.2(a).) Although there is a general analysis of projected growth in the region,
there is a lack of detail with respect to growth inducement or reasonably foreseeable future projects
implementing Public Resources Code section 21155 -21155.4 (CEQA streamlining for SCS
consistency) and/or other reasonably foreseeable development that may result. The provision or
improvement of transportation infrastructure, utilities, water and sewer service to an area can
induce growth by removing impediments to development. Once services are extended or improved
in an area, economic incentives for development exist. The basic elements and principles of the
Amended Plan have been designed to facilitate future smart growth and concentrate population
growth in areas that would be efficiently served by transportation facilities. The smart growth
concept is the basis for the framework for prioritizing public land use and transportation
investments in the region. The smart growth concept identifies areas where smart growth
development exists or could be built and provides a basis for planning transportation facilities and
City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed
Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 7
transit services in the Amended Plan. Smart growth areas identified receive prioritized infrastructure
investments and transit services to support smart growth. This carries true to those smart growth
areas that are accommodated by existing general plans, and for other areas that are not covered by
existing general plans. CEQA requires that an EIR discuss the ways in which the proposed project
could foster economic or population growth or the construction of additional housing, either
directly or indirectly, in the environment surrounding the project. CEQA requires this discussion to
include ways in which a project would remove obstacles to population growth or encourage and
facilitate other activities that could significantly affect the environment (CEQA Guidelines section
15126.2(d)). The level of detail should reflect the level contained in the plan or plan element being
considered (Rio Vista Farm Bureau Center v. County of Solano (1992) 5 Cal.App.4th 351), inclusive of
new smart growth areas as designated.
City staff looks forward to working with SAN DAG on improving mobility and land use access in the region
and building sustainable, equitable and healthy modes of transportation. We appreciate the opportunity
to comment on the Amended Plan that will help the region realize these goals. While at the same time,
city staff also looks forward to helping SAN DAG advance a legally adequate environmental document to
support the disclosure and decision-making process. Since the major premise of CEQA is that it "be
interpreted in such manner as to afford the fullest possible protection to the environment within the
reasonable scope of the statutory language" (Friends of Mammoth v. Board of Supervisors, supra, 247,
2S9), SAN DAG should take all action necessary to alert the decision-makers and the public to the
environmental changes associated with the project (County of Inyo v. Yorty (1973) 32 Cal. App. 3d 795,
810). There is no shortcut to CEQA -the EIR process protects not only the environment but also
informed self-government (Laurel Heights Improvement Assn. v. Regents of University of California,
supra, 376, 392). The SAN DAG Board must certify that the final SEIR has been completed in compliance
with CEQA and that it considered all of the information in the final SEIR before approving or
disapproving the project. As of this writing, the SEIR is not in compliance with CEQA.
If you have any questions related to comments on the transportation network, please contact Tom
Frank, Transportation Director/City Engineer, at Tom.Frank@carlsbadca.gov or, if you need additional
information related to comments on the land use assumptions, please contact Eric Lardy, City Planner,
at Eric.lardy@carlsbadca.gov.
Sincerely,
/()/JS A,fl/:6S{f2$6 {"6p.-
JEFF MURPHY
Community Development Director
TOM FRANK
Transportation Director/City Engineer
SD:mh
City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed
Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 8
Attachment:
1. Aug. 8, 2023, City of Carlsbad Comment Letter on the Amendment to the 2021 Regional Plan
(includes Aug. 6, 2021, comment letter on Draft Regional Plan and Sept. 30, 2021, clarification
letter)
cc: Scott Chadwick, City Manager
Cindie McMahon, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Senior Assistant City Attorney
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Community Development Director
Eric Lardy, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager
Jason Geldert, Engineering Manager
Robert Efird, Principal Planner
Scott Donnell, Senior Planner
Nicole Morrow, Assistant Planner
COMMENT LETTER 4: CITY OF CARLSBAD
August 28, 2023
SANAG Regionill Plan 5[1R
C/OiCir.stenUthitel,l\ssoci11t.el'i~nner
Si!nO.-egoA.ssociaUonofGovernments
4010Street,Suite800
SanDiegoCA92lOI
V-ia:RegK1ualPlar-iSl:IR@:\<t1ll'l,\p.ltP.
Commen1Letter4
(City of
Carlsbad
Rf; CJTV OF CARLS DAD COMMENTS ON DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT
FOR llff PROPOSED AMENDMENT TO THE 2.0Zl REGION Al. PlAN
OearMs.l>c.hitel:
TI,e C!ty of Carlsbad ("cit(') apprecla1es the opporrunity to provide ccmmenu on the dra~
Supplemenl~I Environmental lmpa::t Report ("SEIRn) for the rm:.posed amendment to the 2021 Region.ti
Plan ( .. Pl.10 Amendment~). The SEIR ii dated July 2.023. The Regional Plan j"Plari"I is an important plan
4.1 forth= region and will gulcle the ne(t phase. of growth for the member al!endes of the San Oi!go
Asscciation of Govemmeno: j"SANDflG"). including the city. An effe<.ti\Pely designetl ;,nd implemented
r~eii:mal transportition plan would help en;uri:-improved tr.msportation options for area r!!sldents,
businesses-ilm:I other commuriity membe~s, as we!l 115 meaningful r~uct!ons in t:reenh:iuse gas /"GHG")
em·1s~ions and lmpravt>d quality af1ife as W?-crow our communil1!."~
The Cilitomia Sure legislature created specific provisions to promo~ streilmlinlng erwlronme11tal
re11ie".Y for r.ertain ty/,e~ of r,rnjeos_ fleterminmg io a parlkularsituation whether II is appropriate to
prepare a subsequent or supplemental EIR is a project-specific crmslderatlon, based on marry fatbrs.
Pursuant to CEQAGuldelln~ section 15l53(b)1 "!al supplement to !he ElR need on!y ttie information
,umi~s.ary In m~k~ the previa1,s FIRadE:"quale f•r !Ile µruji:c\ .i~ re'lisetJ." CEQA Guidel!nes serUon 15163
1Jro11ides, In pertir.ent part; "{a) The lead or responsible agencymaychoo;;e to prepare a supplement l:>
an EIR rat.her than a subseque.nt EIF. if: (1) /,ny of the condition~ descrlbeC In SE'.cticn 15162 wnuld
re.t1uire the preparation of a ~l1bw111ue11t E1R, :and (2) Only minor addition~ or chang~ would l:>e
4_2 nece;sarv to mak~ the pre.vious tlll adequately :1,ply to the project ln the changed sltiJ;nion. Thus,
CEQA Guidelines sec.tion l 5163 apphes when an EIR can IH! mad~ adequa!e hy ;Hid1tiollS or dl;irige.~ l1Ia\
responiJ to a limited sel of issue~. w~reasa subseq11ent EIR is ne~;;~ary when the previous EIR mun be
rewritten from the ground up to m:1ke its envir;;nmental analj•s!s adequate. For the reasons stated in
this lrtrer, a subsequ<!nl EIR or new ElR isapproprbte.. There ls nosupµorl to prQ("eet:I ur1tle-r CEQA'~
s<.1pplemental review pro11i~lons because tne or!ginal eri11ironmental doc1.1ment does nol retain
Information al value to tile onsoirtB decislon·making process. It is •ntv log/ca! that SANIAG start from ttie
be!;irming underCEQA ~ectIon 21151 by cond1..1rl•n& ,1n initial stull1• le detennine whl!thi:r U,i: pro~d
rr.ay have substantial effects on 1he environment. Failur.-: to satisfy this CEQA obl!gation constitlJ!e> a
orejudJcla1 abuse ofdl.metlon, which is precisely what CEQA 5eekl t:i a11oid, and it undermine! the
public'sabilltyloobt<1inahilly!nformedevalu.JtionofthC?project.
Tr.in-.portati1111 & Commtmity Development Deparfm!".nts
U,.3..S F;iraday Av1mue 'C...rl~bad, C~ 92008 •1tJ2-J39-26Utl t
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-55
Attachment D
Appendix F.l: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-1
This comment includes opening remarks and notes the importance of
the approved Plan. No further response is required.
RESPONSE TO COMMENT 4-2
The basic purposes of the CEQA are to inform government decision
makers and the public about potential significant environmental
impacts of projects, identify ways the impacts can be reduced or
avoided, prevent significant avoidable environmental damage
through alternatives and mitigation, and disclose to the public the
reason that decision makers approved a project that may result in
unavoidable significant impacts. Under CEQA, a lead agency may
choose to prepare a supplement to an EIR when substantial changes
are proposed that may result in new significant environmental effects
or a substantial increase in the severity of previously identified
significant effects, but only minor additions or changes would be
necessary to make the previous EIR adequately apply to the project in
the changed situation. Pursuant to CEOA Guidelines Section 15163, a
supplement to an EIR "need contain only the information necessary
to make the previous EIR adequate for the project as revised."
Section 1, Introduction, includes a brief discussion explaining why the
impacts on 14 of the 19 Appendix G resource areas would not be
significant with the project modifications in the proposed
Amendment. The lead agency is required to consider the information
in the previous EIR as revised by the supplemental EIR, along with any
other relevant information, in making its decisions on the project
approval. SAN DAG is the lead agency for the proposed Amendment
and Draft SEIR.
qry of Carlsbad Comments ai Draft Supp!ementil Erwlronme:nral Impact Report for the proposl!d
Amendment ro the 2021 Rl!gion;1I Plil:l
August 28, 2023
4-3 Plan on Oct.11, 2021. As the proposed SEIR is a supplemimt to that document and is lars:ely baS2d on I The city previous¥ subrnilled comments on the Program Environmental Impact Report rPE:111~) fer the
the information, a~m,tions and an:alysis therein (e.g., regarding laild use), rnar,1• cf lh~ comments
remain valid and are repeated in lhls letter.
I
The city seiclls to en5<lre that SAN DAG. prepares .1n 1mviron.nient;i! docu.menl th~t is at.leql.lale. roruplete
am tully r1:sclos6 !he potent!al slgnrflc.int adverse erfocts of the Amended Plan. To !mpleml!nl th.e
principles cfCEQA, SANDA.G should torrect previous deficiencies and nol lruncate the requisite
o.,mulativl! im~ct an.iiy'\ls {CEttAGu1deiinesser;ti1m 15l58{b)(l)), 1.15e improper baserines {CfQA
A-4 Guideli11es sc-ctio11 15152), or roredo~ the consideration or any alternc1tive or m!tigatkm measure that
wot1ld ordlnarny be port of CfQA review af a regrona! plan (CCOA Guldeltnes section 15Q0,1(b}(2){8)). The
former EIR failed to provide liecision-makers ....ct lhl' public with al or tlloc' 1 e-lev:1nl i11fonnalio11
rt'Jl,or"ng lhe p,oject that is rieceSSilry rOt" informed decision-making and publJc particlpation.
CEO.Aprescribe5 review procedure; .i public agency mus! follow hl!'!'Ofi" aµprrno!nior carryi111:out
IITTIP(Y.ied projects. Those p1ocedures emphasize the Import1111ce of public pa!tlclpatlon lo the er.QA
proce55, tncludlng mandatory cpponunities for public fe'ew and comment ..-v;j the lead .igentV's
4-5 obflg;,iti•n 10 provide meanlnf;ful respm1ses lD comments received. SANDAG failed lo comply with CEQA
by conducllng the public review process for the Amended Plan arn:l tlie SEIi! separately though with
some overlap, Whlch has resulted In a disconnected, piecemeal and rushed proc:E!ss ill wh.ic:h comment~
made on the Amended Pl.in were r,■l re~polldcd ti;i or lncorpi;iraled into the SEIR.
The, ptiblfc and affected agencies like the c!tv must 1ubmitcommentson the SEIR without knowing
whether or how SAN DAG ha-. re,.ponded lo prc\tious comments on the Amended Plan. SAND AG has
all'l!ady Indicated that the SANDAGBoard Is expected to review and considertheAme:nded Plan and the
Final SElR on October 27, 2023. Thus, there appears lo be insufficier'lt time f17 SAND AG to evaluale
comnll.'11ts received on the SEiR,. prepare meaningful responses and make those responses avallable a.s
4-0 required by CEQA Guidelines sections 15081 a'1d 1508.S. As Stich, SAND AG Is foreclosing CJ'! a
"mea:iingful publlc: panicipallot1 process" and subj~ ,tsl."!ftc a daim lid SANDAG 15 prejullicing the
01Jtcom,; of the environmental review procGs by(:nsuring Uiere ls litt!! owortunity far public
comments to Influence lhe Amended Pl~n·s prog~ and design. ("Environmental re View derives Its
vitality from pubHc particip.ition~ {9ceDn Vi-ts.toles Homeown!!nA.ssn. V. Montedro Water Di~
(2004} 116 Cal. App. 4th 396, 400.j
I If the im11:is 1ha1 Wef"P. artdrP.SSed ln lhe city's August 8, 2023comment letter on the Amended P.1.in
!Att.-dimenl 1) are ncd addressed in the SEIR, the 5EIR wm be Insufficient ~s an lnfonnatlve documeril
l!ll.!. It wlll r~uce the validity and effic;.cy of the, Amended Plan, it1Cluding its use of fau!1y assumptions
4-7 regarding land u-SP. ~11d fl('pul.al Ion i.rowUi t■ c:umply with natc and fl:'deral mar.dates. su:h as thl!
Sustainable Communities Strategy and GHG reduction targets. Thes@ bulty ;;i,;surnptlons misrepresent
the, vital land use-transportation planning ccnnectiol'IS and do nothinc to reduce, GHG and. will instpad
re.suit in unpl,mned im::n;a.s.es to !r.affir, GHG, olf'IJ result in incre,11sed hou5ini: unaffordabilrty.
I While the city supporu the milin corn:..epts of ttJI! Vision in the Region.11 P'l~n, I tie!> fli& Moves, lhel'l!
4-8 needs to be an adec,i;ile ,m.i1yii~ on how the .A1n~nUed Plan wiH be implemented, and what will or cur if
lhere are changes to the projec!edgrowth, technology, and/or state law Impacting e;,:lsting coriditions.
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-56
Appendix F.1: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-3
This comment states that many comments from the City's
October 11, 2021, letter are repeated in this letter. No further
response is required.
RESPONSE TO COMMENT 4-4
This comment addresses the City's comments on the approved Plan
and Final PEIR and does not pertain to the proposed Amendment or
adequacy of the Draft SEIR.
The Final PEIR informed decisionmakers and the public generally of
the significant environmental effects of the approved Plan, identified
ways to minimize the significant effects, and described reasonable
alternatives to the approved Plan (CEQA Guidelines Section 15121(a)).
The Final PEIR properly considered cumulative impacts (CEQA
Guidelines Section 15168(b)(2)), identified a baseline (CEQA
Guidelines Section 15125), described a range of reasonable
alternatives to the approved Plan (CEQA Guidelines Section 15126.6),
and described feasible mitigation measures that would minimize
significant adverse.environmental impacts (CEQA Guidelines
Section 15126.4).
RESPONSE TO COMMENT 4-5
The comment mischaracterizes the CEQA requirements for review of
the Draft SEIR. There is no CEQA requirement to conduct the public
comment period for the Draft SEIR required by CEQA Guidelines
Section 15087 simultaneously with the public comment period
required by Government Code Section 65080 for the proposed
Amendment. There is also no CEQA requirement for comments on
the Draft SEIR to be responded to before publishing, or incorporated
into, the Draft SEIR. The Draft SEIR properly evaluates the Draft
Amendment and preparation of each has run concurrently consistent
with CEQA Guidelines Section 15004. SANDAG has evaluated
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-57
Appendix F.l: Response to Comments on the Draft SEIR
comments received on significant environmental issues and prepared
written responses consistent with CEQA Guidelines Section 15088.
Responses to comments received on the Draft SEIR are included in
this Appendix (Appendix F.l of this SEIR).
RESPONSE TO COMMENT 4-6
This comment mischaracterizes the process for public participation in
the Draft and Final El Rs. There is no CEQA requirement to conduct the
public comment period for the Draft SEIR required by CEQA
Guidelines Section 15087 simultaneously with the public comment
period required by Government Code Section 65080 for the proposed
Amendment. There is also no CEQA requirement for comments on
the Draft Amendment to be responded to before publishing, or
incorporated into, the Draft SEIR. The Draft SEIR properly evaluates
the Draft Amendment and preparation of each has run concurrently
consistent with CEQA Guidelines Section 15004. SAN DAG has
evaluated comments received on significant environmental issues and
prepared written responses consistent with CEQA Guidelines Section
15088. Responses to comments received on the Draft SEIR are
included in this Appendix (Appendix F.l of this SEIR), and responses to
comments received on the proposed Amendment are included in
Appendix F.2 of this SEIR.
Specific to public outreach conducted by SAN DAG, there have been
extensive opportunities for meaningful public participation in the
proposed Amendment and Draft SEIR. SAN DAG initiated the SEIR
scoping process on December 9, 2022, through the circulation of an
NOP. Receipt of the NOP by the State Clearinghouse at the California
Office of Planning and Research on December 9, 2022, initiated a 30-
day comment period that ended January 9, 2023. The NOP provided
formal notification to all federal, State, and local agencies involved
with funding, and to other interested organizations and members of
the public, that an SEIR would be prepared for the proposed
Amendment. The NOP was intended to encourage interagency
communication concerning the proposed Amendment and provide
sufficient background information so that agencies, organizations,
and individuals could respond to SAN DAG with specific comments and
questions on the scope and content of this SEIR.
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-58
Appendix F.1: Response to Comments on the Draft SEIR
The NOP is provided in full in Appendix A-1. The written comments
are provided in full in Appendix A-2.
Consistent with CEQA (PRC Section 21083.9), SAN DAG noticed and
held a public scoping meeting on December 21, 2022, at SANDAG's
office at 401 B Street, San Diego, CA 92101. The purpose was to
receive perspective and input from agencies, organizations, and
individuals on the scope and content of the environmental
information to be addressed in the Draft SEIR. To support the
development of the proposed Amendment, SAN DAG implemented a
public outreach and involvement program consistent with State and
federal requirements. Early in the planning process, SAN DAG
developed a Public Involvement Strategy (Strategy) to guide the
public outreach program. The Strategy identifies public engagement
techniques to involve the public and collect input for the proposed
Amendment, including public meetings, social media, visualizations,
and other approaches to outreach.
The Draft SEIR for the proposed Amendment was released to the
public on July 13, 2023, and was available for a 47-day public review
period, consistent with CEQA which requires a 45-day public review.
SAN DAG published a public notice for the Draft SEIR public review
period in local newspapers on or about July 12, 14, 21, and 28, 2023.
SANDAG also filed a Notice of Completion (NOC) with the State
Clearinghouse to indicate the availability of the Draft SEIR for public
review and comment on July 13, 2013. The Draft SEIR was distributed
to the agencies, organizations, and individuals that provided written
comments on the NOP, the SAN DAG Board of Directors, SAN DAG
member agencies, and other interested parties and stakeholders.
Agencies, organizations, and individuals were invited to provide
written comments on the Draft SEIR during the public review period
from July 12 to August 28, 2023.
The Draft SEIR and all appendices were available for review online at
www.sandag.org, at SANDAG offices located at 401 B Street, Suite
800, San Diego, California 92101, and at the San Diego Central Library
located at 330 Park Boulevard, San Diego, California 92101. The
Central Library will facilitate inter-library transfers upon request by a
member of the public in order to provide access at local libraries.
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-59
Appendix F.1: Response to Comments on the Draft SEIR
On a case-by case basis, the San Diego Central Library can also digitize
documents and transfer them to other libraries. There will be a
further opportunity for public participation on October 13, 2023, at
the SANDAG Board of Directors meeting where decision makers will
consider certification of the SEIR and adoption of the proposed
Amendment.
RESPONSE TO COMMENT 4-7
The City's August 8, 2023, comment letter on the proposed
Amendment addressed the approved Plan and does not pertain to
the adequacy of the Draft SEIR. At the direction of the SAN DAG Board
of Directors, the proposed Amendment is narrowly focused on
removing the regional road usage charge while meeting state and
federal requirements. The Amendment includes no changes to land
use.
This comment incorrectly asserts that the previously approved Plan
uses faulty land use assumptions. Government Code Section
65080{b)(2l(B) provides that an SCS "use most recent planning
assumptions considering local general plans and other factors." It also
requires that the SCS "set forth a forecasted development pattern for
the region, which, when integrated with the transportation network
and other transportation measures and policies, will reduce the
greenhouse gas emissions from automobiles and light trucks to
achieve, if there is a feasible way to do so, the greenhouse gas
emission reduction targets approved by the state board." The SCS
projects development that would achieve the State-mandated GHG
emissions reduction target when integrated with the transportation
investments, programs, and policies in the approved Plan, as
amended.
RESPONSE TO COMMENT 4-8
SAN DAG is typically required to update the Regional Plan every four
years to account for the changes since the last Plan was adopted,
including projected growth, technology and/or state law, as
mentioned by the commenter. Those assumptions will be updated as
needed in developing the 2025 Regional Plan.
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-60
Appendix F.l : Response to Comments on the Draft SEIR
With respect to implementation, Appendix B, Implementation
Actions, of the approved Plan as revised by Attachment A to the
Amendment, Errata to the 2021 Regional Plan, provides SANDAG's
strategy for implementing the proposed Amendment.
Cit)' of Carlsbo1d Comments on Draft Supplemental Environmental Imp.1ct P.eport for the proposed
Amendment to the 2021. Region.ii Pl.in
,\u(lust28,2023 '.,
4-9 darifiCiltion on land use authority. Ttis l;111gu~111: is needed to cfailfy tr.ft !,md u;;e authority rests ,1ith I Thctitvappreciates SANDAG al'!d!ng language, as the cityreques1ed, that provides: additiomil
4-11
4-12
the local 1urisdlc;i0n. Ahl'lo1igh this principle should be obvious, the lnconslste;ndes between lhe
Amended P!i111 and thecJty's:General Plandiscussedbelow;;ugge;;t thafit has beeJi ignored.
Whl!.> the prapo;;ed ilmendme/lt Is focuwd on the rl!ITTJval of the region.;! road usage charg!': from the
2021 Reg;onal Plan, the Amended Pl;m also provides updilt&! regional employment flgure.s, revenue
auumptiort5, traffic volume,, etc., aU ofwhicli are slsnlficantchange5 and/or new Information o[
substantial Importance. In addit,on, the city made the fellowing sub.mint Ive tomments on the a::iequaq1
of the Pf IP. in its Oct, 11, 2021, letter ol'I that document These i::omments remair1 valid and hiBhlisht
sie;11lflcarn concerns that s!em largely horn faulty land use assumptions contained in the PEIR and 2021
AeglonalPlan,wh!chth.-SElRdoesnotmodJfy.
1. The PEIRiSE!R foll to disclose the Plan'; and Amended Plan's Inconsistencies wllh the Ci!rl!ibad
General Ptm ilnd to ilrn.lyze the re1a1ed potMtlal environmental impact'l. The legislature has
declare.a a poITq• "to protect C.1llfarnia'~ !ancl resource, 10 ensure il'> preservation ~nd use ln ways
which are economically and socl;i.l(y desirable In ;i.n ,;ntemptto ll'Tlprove the qualitv of life in
c.,torni.a." (Gov. Code§ 65030.J To furth~rthis polcy, each of the stale·~ cl1ies ao-.J counties is
requin2d to adopt acomprehen§ive, lon11-1erm a:eneral plan for the physical dewelopment of that city
ortounty. (Gov. Code§ 65300.) Acco1dlr.£ly. the city adopted a G,e,neral Plan in compUa11ce with
staU! law and mostrecent>v updaLed it in 2015 lhe clly's: General Plan "sets forth land use
ccmpatlbl!l~• poltcles applicable to ruture develnpmenl In the vicinity.•~ policies are deslin!!:d
to ensure that ft.!rure land uses ln the surrounding are~ will he compal!ble with the rcatistlcatly
rores.:oeableactfllltyinthedty.
2. Growth projections for the rei:ion .t1e bi!!ted oo popul11tion, vehlde trend5and land u5e plans
de11elope,cl by the cltles:arid the Counly of S,m Diego 1~county-j as part of theirgen~ral plans. Many
d!Rerentre11lon.1I docume:,t; 1erv on the same lrirormation to develop water demand oroJectlons,
air quality pe<f.ormance ~tandMds, ernluion inventnrl6, and emission reductiofl~-The Amended
P!anwould resul1 inanlncreaselnresidet11i.ll landuseresultingincorrespondingincreasesin
Indirect and cumulative vehide miles traveled {"VMT"), GHG emissions and air pelhrtant emissions,
as well ilS Inconsistencies-wllh RAQS,SlP, a!ld regio11.tl traffic modeling. ThiswasflOl dbclcsed in the
PEIR and th Lis influences the an.2ly~is ln the S£1R.. CEQA Guidelinessec1ion l5l 2S{a) reQuires E!Rs to
conl~iil a rlescrij'.>tion cf the physi::al e11vircmm~nhl conditions ill !he vicinity cf the project, as they
ex Isl ill the time the NOP-ls pubrisheli, or If no NOP is published, Bt the time environmental an<1lysis
Is commence-d, from both a locat and regional perspective. histing i:eneral plans, inclvding their
land Us.eF.lernent\, should have beer. utira:ed fOf this baseline /Jll.tlysisandu:rderivefut.ure
popula1ionand housingestirr,ates
In 1he PEIR, )A.tJDAG ;hould ha Ye ev1luated and clearly articulated ttie Plan's potential imp~c.l.!-on
~no' use. instead. the PEJR na1e~ tli:.r:. '"The tol"eca~ted de.11ebpment of the propo~ed P!,m iS b.iowd
on the Series 14 Regional Growth Forecast SCS la!id use pattern, which is, JI turn, :>ased co the
adopti::d general plans ol'the cl ties and County of San Diego ~nd en !he most recent planning
assumptions, considering local general pl~,u .and other racte1s, a~ requirl"d by SS 375. • Thi5
statement Is i11correct. Tin.Ii, the Amended Plan Is inamsisto?f)t wi.lh the city"s Get1eral Plan hecau~e
it prapo;es 1esldent:al l;;nd uie~where such u~es are not auU,orized by lhe General Pliln. Th~city's
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-61
Appendix F.l: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-9
This comment does not pertain to the proposed Amendment or the
adequacy of the Draft SEIR. At the direction of the SAN DAG Board of
Directors, the proposed Amendment is narrowly focused on removing
the regional road usage charge while meeting state and federal
requirements. The Amendment includes no changes to land use.
The comment inaccurately suggests that the City's General Plan was
ignored in developing the previously approved Plan. SAND AG relied
upon local general plans and other factors to develop the forecasted
development pattern for the region consistent with Government
Code Section 65080(b)(2)(B). Consistency of the approved Plan with
relevant general plans is analyzed in Section 4.11, Land Use, of the
Final PEIR. Due to the programmatic nature of the EIR analysis, the
Final PEIR did not call out specific policies from local jurisdictions'
general plans or other local planning documents. Consistency of
individual second-tier projects with these policies would be
considered during project-specific CEQA reviews.
RESPONSE TO COMMENT 4-10
The basic purposes of the CEQA are to inform government decision
makers and the public about potential significant environmental
impacts of projects, identify ways the impacts can be reduced or
avoided, prevent significant avoidable environmental damage
through alternatives and mitigation, and disclose to the public the
reason that decision makers approved a project that may result in
unavoidable significant impacts.
Under CEQA, a lead agency may choose to prepare a supplement to
an EIR when substantial changes are proposed that may result in new
significant environmental effects or a substantial increase in the
severity of previously identified significant effects, but only minor
additions or changes would be necessary to make the previous EIR
adequately apply to the project in the changed situation. Pursuant to
CEQA Guidelines Section 15163, a supplement to an EIR "need
contain only the information necessary to make the previous EIR
adequate for the project as revised." Section 1, Introduction, includes
a brief discussion explaining why the impacts on 14 of the 19
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-62
Appendix F.l: Response to Comments on the Draft SEIR
Appendix G resource areas would not be significant with the project
modifications in the proposed Amendment. The lead agency is
required to consider the information in the previous EIR as revised by
the supplemental EIR, along with any other relevant information, in
making its decisions on the project approval. SAN DAG is the lead
agency for the proposed Amendment and Draft SEIR.
This comment also refers to the City's comments on the approved
Plan. At the direction of the SAN DAG Board, the proposed
Amendment is narrowly focused on removing the regional road usage
charge while meeting state and federal requirements. The
Amendment includes no changes to land use.
This comment incorrectly asserts that the previously approved Plan
uses faulty land use assumptions. Government Code Section
65080(b)(2)(B) provides that an SCS "use most recent planning
assumptions considering local general plans and other factors." It also
requires that the SCS "set forth a forecasted development pattern for
the region, which, when integrated with the transportation network
and other transportation measures and policies, will reduce the
greenhouse gas emissions from automobiles and light trucks to
achieve, if there is a feasible way to do so, the greenhouse gas
emission reduction targets approved by the state board."
The SCS projects development that would achieve the State-
mandated GHG emissions reduction target when integrated with the
transportation investments, programs, and policies in the approved
Plan, as amended.
RESPONSE TO COMMENT 4-11
This comment refers to the City's comments on the previously
approved Plan. At the direction of the SAN DAG Board, the proposed
Amendment is narrowly focused on removing the regional road usage
charge while meeting state and federal requirements. The
Amendment includes no changes to land use.
Consistency of the approved Plan with relevant general plans and
LCPs is analyzed in Section 4.11 of the Draft PEIR. Due to the
programmatic nature of the Final PEIR analysis, the Final PEIR does
not call out specific policies from local jurisdictions' general plans,
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-63
Appendix F.l: Response to Comments on the Draft SEIR
LCPs, or other local planning documents. Consistency of individual
second-tier projects with these policies would be considered during
project-specific CEQA reviews.
Government Code Section 65080{b)(2)(B) provides that an SCS "use
most recent planning assumptions considering local general plans and
other factors." It also requires that the SCS "set forth a forecasted
development pattern for the region, which, when integrated with the
transportation network and other transportation measures and
policies, will reduce the greenhouse gas emissions from automobiles
and light trucks to achieve, if there is a feasible way to do so, the
greenhouse gas emission reduction targets approved by the state
board." The SCS projects development that would achieve the State-
mandated GHG emissions reduction target when integrated with the
transportation investments, programs, and policies in the approved
Plan, as amended.
RESPONSE TO COMMENT 4-12
This comment inaccurately asserts that the Draft SEIR does not
disclose analysis of VMT, GHG and air pollutant emissions, and
inconsistencies with RAQs, SIP, and regional traffic modeling. The
Draft SEIR evaluates each and the relevant identified impacts in
Sections 4.1 (Air Quality), 4.3 (Greenhouse Gas Emissions), and 4.5
(Transportation), as well as Chapter 5 (Cumulative Impact Analysis),
among others.
This comment also refers to the City's comments on the approved
Plan. At the direction of the SAN DAG Board of Directors, the
proposed Amendment is narrowly focused on removing the regional
road usage charge while meeting state and federal requirements. The
Amendment includes no changes to land use.
The comment inaccurately suggests that the City's General Plan has
been ignored in the previously approved Plan. SANDAG relied upon
local general plans and other factors to develop the forecasted
development pattern for the region consistent with Government
Code Section 65080(b)(2)(B). The thresholds for land use analysis in
Appendix G of the CEQA Guidelines include an evaluation of whether
the project causes a significant environmental impact due to a conflict
with a land use plan, policy, or regulation adopted for the purpose of
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-64
Appendix F.l: Response to Comments on the Draft SEIR
avoiding or mitigating an environmental effect. A conflict alone does
not necessarily result in a significant environmental impact. As stated
above, consistency of the approved Plan with relevant general plans
is analyzed in Section 4.11 of the Final PEIR. Due to the programmatic
nature of the EIR analysis, the Final PEIR does not call out specific
policies from local jurisdictions' general plans or other local planning
documents. Consistency of individual second-tier projects with these
policies would be considered during subsequent project-specific
CEQA reviews.
City of C'.arhbad Comments on Drah Sllj)pl!!ml!lltal fn,..ironrrumtal Impact Repo;t for tN! propost>d
Amendment to !he 2021 Reg~I Plan
A11g.11sl 28, 2023 ,, 4
4-12 I comrne11lson Lhe ?EIR indlcaredttat irappe.ared to ignore I his inconslstencyi ncoocludfng there
cont would be leu than significant Impacts far lhe ye;us ZOZS. 203-5 or 20S0
4-13
The city has two mobllily hubs in lhe Plan artd PEIR; McCleUa.n-Paloma:r Airport, the fl~h \;,ug1m
employmt<nl tenter in U•.e regio11; and Carlsbad Stat~ Beach •md Catlsbad Village ;is ,;-ier 3 and Tier
4~ employment. centers. Th! city's Aug. 6, 2021commenlsuu lhl' PEIR Included an attachment that
showed a wmmarv aflhe Mobility Hubs and housifl@ units assumed in thl!Series l<1 Growth
Forecast for the vear 2050. The assurnptlon! in the iJp::lated series 14 Growth Foreusl contain
incor.sistendes v.1th !"eSpl!Ct to al lean three lacalions ir, WtiichdertSity is5hov.m to be lnconsistent
with the city's Gene""al Plan, the Ai1pnr1 llllrd Use CompatlbllitY Plan and good planning prlnc'iple-$.
Thesethreeprobleni.11!c,ire;u:!!'e:
a. 736 lll'llts on parcels lmmedlate.ly adjacootto th! McC!ellan•Pill•niar A.ir,ort runwil\'· The
location of the alrpoitwithin this mob/Illy hub was shtlff!d with SAND AG staff multiple times
at workshops. Thili is inconsistent with tl1e regUl;itlons pro'Jlded by the San •\ego Ct>\!rty
Refiorial Airport Authority and ccrrlli.ro with sti!ndard planning principles fOf siting housing
awayfrom h;nards;
b. Z,755 units on e.ldstirig ftvclopell resort properties and open space ciedh:ate.d tarods
adjacentlolegoland;and
c. 6Suniti !n a pr-5eNetl open spa::e affia.
Since lt does r,otch;inge the.Flan's land use assumplioros, !he Amended f>l.an contfnuesio propose
resldentlal uses in areas wh,ch arr ool design.stet! for such uses In the city's Ger\el'al Plan and U1e
McClell,rn-Palomar Aifport land Use CompatlbiUtY Plan, as di!.cussed belilw, This inco~lstency'
resulb In potel"lti.if sl11nificant imp.acts with ~-:• lo land 1-Ge, public safety 2r1d noise, (See CEO.A
Guidelil'\e~, Appel'\di11 G, §§ U(te), Xl/b), Xlll(c}.) Because re;fdenlial 1.151! is not illlllthorized in 1h~
loc.ations in the city's General l'larl, the Amended Pl:an's nwmption that reside11tial use wiU occur
there reSl.ilts in an overstatement of the extent to which other imp!lcb, such u those :usociated
with Vlv1T, GHG and 0U1er'pol!uti!lltemiuiora, wfll be redlced and tinder.states tho~'! potential
impact5 of the Ameni::led Plan. lf lhe S~li\ d•es not meaningfully .-iddres5 the Jn,onslslenc~ with th!
genera! plans of all member jurisdictiC!f't5, which If not implementing this-plan wlll c;iuse a signifitant
envlranraenut impac::t i.Jue to the conflict with illrty Ulncl use plan, poli,y or regulalion.adopled tor
the purpose ofa,.,oidins or mitigattns: an environmenta!df.ect.
Multiple areas Ir, carlsbad we contro!led as to their l£e .:ind activity density ;rid !11tenslty through
tile tr spatial assor.:ialion with I.he M::C!e!lan·?i!lorrrar Airport, and some of these areas reslticl
resid~tia! use. The McCler.an-Palomar Airport is defined by the Feder;il Avfdtion AdmlrJlstr.atlon
("'f"AA ") as a commercial s!!Nice .Jirpnrt that. in ~diliori to prl\•a~e alrmh, has regularly sched1Jled
commercial flights. Further tlelail orithiswas indudedin the city's AIJjl;ust 6, 2021, r:omment Jetter
on ltle drafl Pl.in, part ofAttachment.1 lo this li!mer.
Tl!bJe 4.5-1 indicatES chanees h demarod for aJ mode, oftraY!lfrom lhe app,ov11d iJlari lo lhe
Amended Plan under lOZS condltlons. Gi'len that tre SElR ~te:s that tht> roathv.>'f user charge
would not be lmplerntmted IMttil yw;r 2rtl5 ruHitlon; please explain why the.-~ would be ariv
chan,gesur,di!rthe.lOZSsccnario.
I 4 tu l!'Kpres.sed in commerits on the EIR, the andfySis melhodo!oe:Y used for the Transportation chapte; 4-15 • does net prGl'ide a descriplion ofh:lwthe ABM2t arlil!ysis outpUts su:h asAvera~c. Daily Trips
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report PageF.1-65
Appendix F.l : Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-13
This comment refers to the City's comments on the approved Plan. At
the direction of the SAN DAG Board of Directors, the proposed
Amendment is narrowly focused on removing the regional road usage
charge while meeting state and federal requirements. The
Amendment includes no changes to land use.
Government Code Section 65080(b)(2)(B) provides that an SCS "use
most recent planning assumptions considering local general plans and
other factors." It also requires that the SCS "set forth a forecasted
development pattern for the region, which, when integrated with the
transportation network and other transportation measures and
policies, will reduce the GHG Emissions from automobiles and light
trucks to achieve, if there is a feasible way to do so, the greenhouse
gas emission reduction targets approved by the state board." The SCS
projects development that would achieve the State-mandated GHG
emissions reduction target when integrated with the transportation
investments, programs, and policies in the approved Plan, as
amended.
This comment mischaracterizes the impact of the land use
assumptions underlying the previously approved Plan on the VMT,
GHG, and air quality resource analyses included i'1 the Final PEIR. The
approved Plan focuses growth and development in the Mobility Hub
areas. The allocation of housing units to subregional areas represents
general areas projected for future growth, not specific parcels, for
future housing development or housing unit type. Specifically,
outputs are generated at the Master Geographic Reference Area
(MGRA)-level for use as inputs to SANDAG's Activity Based Model
(ABM). MGRAs are comparable in size to census blocks and cover the
entire region. A number of land uses at the parcel level, aggregated
up, comprise these general areas and VMT, GHG, and air quality
impacts are analyzed at the regional level consistent with the
programmatic nature of the Final PEIR.
For Carlsbad, the SCS land use pattern forecasts 6,575 housing units
from 2016 to 2050, which is within the total housing unit capacity of
the City's general plan as provided to SAN DAG (6,992 housing units)
and accommodates the City's RHNA allocation of 3,873 housing units
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-66
Appendix F.1: Response to Comments on the Draft SEIR
by 2035. The precise zoning at the parcel level is within local
jurisdictions' land use authority. As such, future development projects
would undergo separate, project-specific environmental review, and
any impacts associated with conflicts with land use plans, policies or
regulations, including the general plan and any applicable airport land
use compatibility plans, would be evaluated and mitigated when the
timing, location, and other specifications of a specific project have
been defined.
RESPONSE TO COMMENT 4-14
In 2022, anomalous traffic counts and employment at some large
employment location sites and Traffic Analysis Zones (TAZs) were
identified and corrected, and the Series 14 Regional Growth Forecast
was updated to incorporate these corrections. The corrected inputs
resulted in slight changes to regional employment figures and more
concentrated employment across a handful of sectors at a limited
number of employment locations; previously employment had been
more dispersed across the region. These corrections resulted in a
regional vehicle miles traveled (VMT) increase.
ABM 2+ model runs for the Amendment also reflect corrections made
to one of the special market models included in ABM2+, the
crossborder model. The crossborder model measures the impact of
Mexican resident travel on the San Diego transportation network. In
2022, a software bug was discovered in the crossborder model that
affected the number of crossings via Otay Mesa East and resulting
traffic volumes on SR 11. The software bug was fixed, improving the
accuracy of traffic volumes on SR 11. The fix had minor impacts on
regional VMT.
RESPONSE TO COMMENT 4-15
For additional information about modeling procedures, please see
Appendix S, Travel Demand Modeling Tools, of the approved Plan and
Attachment B, Air Quality Planning and Transportation Conformity, of
the proposed Amendment. A detailed description of the background,
data sources, methodologies, and outputs associated with ABM2+ can
also be found at https://github.com/SANDAG/ABM/wiki.
;;~: I
City af Cartsbad UJmme/lt': on Dutt SupplEme.nlal Environrmental Impact Repon: for the proposed
Amornlment to the 20Zl Reg!ona! Plan
August2B,2023
Pa1e5
(A.OT), Mode Sh..re, J!'ll Ve hid~ Miles Traveled {VMT) are calculated !or each ol the uave! mode~
Without this information, it ls difficult to understand how ll'letra11sp1;1rtatlon network Improvements
/mpacr the~e analys!• metrics for futureye4r conditions and for comlderatlan ofpotenti11! proJ«t
mitigations, The document link provided In response to this prior comment ln the foot;.ote with
descriptions of the ASMl .. model output$. is not currentl1• active
1
5 TheSEIR should ev11\ltte the lrr,pact of the reduction in tot.ii funding rcsulling from the removal of
• 1he road usage charge. This-1.'valualion !i:hould encompass the Regkmacl Plan's reduced Cilpacity to
4-16 exe.:ute projects, including but not timltcdto additional roadw;iys, transit ~ys1cms, and ~ctive
tnmsportation. furthermore. the anc11v.sis-5hould address haw1hc curt.Jflmcnt of projects could
!nflucnc::ebroadershift:s in tr.tvel madets, vehide milestra11eleC {VMT), and re suiting GHG E:missions.
6. Thi'! altemallves analnis"d= oot desxribe a rang I! of reasonable alternatives to the JNO.Jf:ct because
it does not (nelude an ana\ysh of an alternative thilt evaluates whlll wiU o~ur if the faulty land use,
and therefore tr;i,nsportation, auumptlons do nol occur. The alternatives are constnJcted l11rgely to
reduce impacts through even more focused growth in Mobility Hubs and through increased value
pricing and reYl!flue ~ner.!ltion. Wh~e it l'Tll!Y be true: tt.,,..le 'IYOUld r!:'duce impacts, it does not
provide policy rnakeu or members or the publlc a reasonableranj;e of alternatives a~ required by
CEQA. Additionally, due to SB 9, wtiith beCMne effective Jan. l, 2022, the reduction in popul11tio11
a5sumed iri iuburban areas outside of the mobility hubs L!; both inconsistent with reality ood with
planning principles required by the l:.l!itomia Departmeol of Housing and Community DeYe.loprnen!
tonottoncen\rcteallfuturegrowthinc.ettainlocatlons.
CfQA and the CEQA Guideiines re11uire that an Elfl. describe al! re:1som1ble alternativ2s to the ~oject
,rnd any feasible mitigation meil~u,u (la11rtl l~ighcs lmprovementArsn. v, Reoents J/Universityof
C.Glijarnla (1988) 47 Cal.3d 40D, 404J. Because the SEIR c:loes notdisc.us.sfulure lar"!d LM conflicts
with applicable general plans (as well as other::ity land use document~. sc1ch as tht Lo~l Coastal
Program, Habitat Management Pilln and Mca~Jan-Palomar Airport Ulnd Use Compatibility Plan), it
f,1iils to disdose Wi\'l to reduce or eliminate the en11ironmental impacts tif the proje-ct and to
respond to the majorenvironment.il issu~ identified during the planning process /a> a project
altemalive or as ii mitQ;ation measure] pursuant to Public Re;ourc~ Code section 21002 (see
Friencb oft he Old in= v. Deportment of Forestry& Fire Protection (1937) 52 C:il. App. 4U1 1383).
The SEIR's ~m,lys\~ of the project alternatives andmit~ationme.;sures is incomplete and, therefore,
inadequate.
Section 15-116 of the CTQA Guidelines rCQuires that all a~pects of a project must be considered
wherr ev;i.lu.,ting its impact on the environment, Including planni11g, acquisition, deYelopmeot, and
operation. The implementation and challenges to fund the Amemlf'd Plan have not been
appropri.itely disOJssed. One of the project altunatives 5hou!d accommodate tr.rnsportation
investments that can be re:a5onablvfunded withfn ttie horilon of the plan under the curref\l
/~knownff) funding mechanisms. Bec:iuse !he SEfR does not ::liscuss a financlallv constrained
alle:-native, the analvsU of the project.iltcrn~tive~ and mititallon measures 1$ incomplete, and
therefore,inac:lequ<1te.
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1•67
Appendix F .1: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-16
The regional road usage charge was not intended to be implemented
until 2030, and as such was only a revenue source for the final
20 years of the approved Plan.
Updated revenue assumptions for the Amendment provide sufficient
revenues to fund the projects in the approved Plan, including historic
levels of infrastructure investment from the federal and state
government resulting from the Infrastructure Investment and Jobs
Act (IIJA, also known as the Bipartisan Infrastructure Law).
RESPONSE TO COMMENT 4-17
CEQA requires the consideration of alternatives to the proposed
Amendment and the analysis of impacts associated with those
alternatives. By comparing the proposed Amendment to the
alternatives, the advantages of each can be weighed and analyzed.
Section 15126.6 of the CEQA Guidelines requires that an EIR "describe
a range of reasonable alternatives to the project, or to the location of
• the project, which would feasibly attain most of the basic objectives
of the project but would avoid or substantially lessen any of the
significant effects of the project and evaluate the comparative merits
of the alternatives." An EIR must discuss alternatives to a project in its
entirety and is not required to discuss alternatives to each particular
component of a project. Also, an EIR need not evaluate in detail
alternatives that would not substantially lessen the proposed
project's significant environmental impacts. Finally, CEQA Guidelines
Section 15126.6 specifically states that "[a]n EIR need not consider
every conceivable alternative to a project."
This comment also inaccurately characterizes the discussion in Laurel
Heights Improvement Assn. v. Regents of University of California
(1988} 47 Cal. 3d 376. The Court does not state that CEQA requires an
EIR to describe all reasonable alternatives to the project. Rather, the
Court in Laurel Heights stated that "[a]n El R's discussion of
alternatives must contain analysis sufficient to allow informed
decision making" (Laurel Heights Improvement Assn. v. Regents of
University of California /1988) 47 Cal. 3d 376, 404). As mentioned
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-68
Appendix F.1: Response to Comments on the Draft SEIR
above, CEQA Guidelines Section 15126.6 specifically states that "[a]n
EIR need not consider every conceivable alternative to a project."
The Draft SEIR Alternatives were developed as alternate means of
achieving most of the basic project objectives for the Final PEIR.
Those objectives are found in Chapter 2, Project Description, of the
Final PEIR.
The proposed Amendment has the additional objective of removing
the regional road usage charge while continuing to meet State and
federal planning requirements, regional GHG reduction targets, and
federal air quality conformity standards. As discussed in Chapter 6,
Alternatives Analysis, of the Draft SEIR, five alternatives were
considered in detail:
Alternative 1: No Project (the approved Plan). The No Project
Alternative assumes that all of the plans and policies included in the
approved Plan would be implemented, including the regional road
usage charge, and is further described in Chapter 2, Project
Description, of the approved Plan Final PEIR.
Alternative 2: 2019 Transportation Network With New Value Pricing
and User Fee Policies. Alternative 2 is the same as described in
Chapter 6, Alternatives Analysis, of the approved Plan Final PEIR.
Alternative 3: All Growth In Mobility Hubs and More Progressive
Value Pricing And User Fee Policies. Alternative 3 is the same as
described in Chapter 6 of the approved Plan Final PEIR.
Alternative 4: Progressive Pricing and No Regional Road Usage
Charge. Alternative 4 consists of the approved Plan transportation
network and land use pattern included in the SCS, with more
progressive toll pricing and parking costs. Alternative 4 does not
include the regional road usage charge.
Alternative 5: All Growth In Mobility Hubs, Progressive Pricing, and No
Regional Road Usage Charge. Alternative 5 consists of the approved
Plan transportation network, a land use pattern focusing all regional
growth in mobility hubs, with more progressive toll pricing and
parking costs. Alternative 5 does not include a regional road usage
charge.
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-69
Appendix F.1: Response to Comments on the Draft SEIR
This comment also restates the City's comments on the approved
Plan. At the direction of the SANDAG Board of Directors, the
proposed Amendment is narrowly focused on removing the regional
road usage charge while meeting state and federal requirements. The
Amendment includes no changes to land use.
This comment incorrectly asserts that the Final PEIR uses faulty land
use assumptions. Government Code Section 65080(b)(2)(B) provides
that an SCS "use most recent planning assumptions considering local
general plans and other factors." It also requires that the SCS "set
forth a forecasted development pattern for the region, which, when
integrated with the transportation network and other transportation
measures and policies, will reduce the greenhouse gas emissions from
automobiles and light trucks to achieve, if there is a feasible way to
do so, the greenhouse gas emission reduction targets approved by
the state board." The SCS projects development that would achieve
the State-mandated GHG emissions reduction target when integrated
with the transportation investments, programs, and policies in the
approved Plan, as amended.
With respect to SB 9, which took effect on January 1, 2022, the Series
14 Regional Growth Forecast incorporates assumptions about ADUs
occurring in the local jurisdictions as potential future capacity for
housing unit development. ADUs were assumed to be available on
5 percent of all single-family lots in the region that were 5,000 square
feet or larger. This equates to about 20,000 additional units of
housing unit capacity throughout the region outside of the rural
villages in the unincorporated area. The Series 15 Regional Growth
Forecast is currently being developed in coordination with local
jurisdictions and may include updated assumptions surrounding ADU
development.
Consistency of the approved Plan with relevant general plans is
analyzed in Section 4.11 of the Final PEIR. Due to the programmatic
nature of the PEIR analysis, the Final PEIR does not call out specific
policies from local jurisdictions' general plans or other local planning
documents. Consistency of individual second-tier projects with these
policies would be considered during subsequent project-specific
CEQA reviews.
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-70
Appendix F.l: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-18
This comment mischaracterizes the requirements for a financially
constrained RTP and inaccurately states that the implementation and
challenges to fund the proposed Amendment have not been
appropriately discussed. Federal and State laws require SAN DAG to
develop a regional plan built on reasonable assumptions of the
revenues that will be available during the period covered by that plan
(Government Code Section 65080(bl(4); 23 CFR 450.322(fl(10l(ii)).
New funding sources are revenues that do not currently exist or that
may require additional steps before the MPO or transit agency can
commit such funding to a transportation project. (2017 RTP
Guidelines for MPOs). Strategies for ensuring their availability must
be identified and future revenues may be projected based on
historical trends, including consideration of past legislative or
executive actions (2017 RTP Guidelines for MPOs). The level of
uncertainty in projects based on historical trends is generally greatest
for revenues in the "outer years" (10 years or more) of an RTP.
Appendix Vof the approved Plan as revised by Attachment A to the
Amendment, Errata to the 2021 Regional Plan, explains the
anticipated revenues to fund implementation of the proposed
Amendment. Table V.3 as revised by Attachment A to the
Amendment describes the availability assumptions for new revenue
sources identified in Appendix V.
As explained in Response to Comment 4-19, the Draft SEIR does
evaluate a reasonable range of alternatives that achieve most of the
basic project objectives and that are potentially feasible.
4-19
4-21
Cily ofQirbb,1d Comments<1n Draft Suppl!mlentat rn11ironmental Impact Report for the pr•posed
.Amendment to the 202l Regional Plan
ALJ(:Ust28,20B --~·------------------
h addition 10 the cornmenl:!i .:ibovc, SEIR Alternatl-.,e 3, the same ;u-described In Chapter 5 of the
appn:,ved Plan PEIR, lnclude.s ~ road usage charge, l:cllowing adorllon of the appro11ed Plan, the
SAN DAG Board dlrect!:d staff to prepai·e a focused ;3.'llendment to the approv!d Plan that deletes
the reg1onal road usaee ch.rge. SEIR. Sett loo 2.3, Pro Jett Obj!ctives, roles, "'t~ proposed
Ainendment [to the 2021 ~gionaJ Plan] hu th!! additlonal olrjf!Cl,ve of removing the regional road
usage charge whlle tontinulncto meet State and fe<Jcral planning requirements, regional GHG
reduction largels, and federal air quality conformity srandards. • As 5€:cticm 6 states, Section 1512fi.6'
or the CEQI\ Guideli~ requires that an ClR "describe a range of reasonable altemati\.es \.D lhe
project. . .wh!ch would feasibly att.i!n mosr ofthe basit objectiv~ oflhe proj!!ct .. " Alternative 3's
Inclusion of the road usaged>.1fJ:ec•nflictswitf1 the foncla.m~t;iJ ruion fOftheAmended Plan,. This
altemative should be replaced ormodlf,ed to exclude the road us€rchati;:e.
7. The atternatlves analysis also doas not ntisfy federal requiremenu. Federal legl.sl2tion require1th~1
lhe Plan include a tinanclal!y constrained scenario (2J USC l3'1(h]{2)(6)). "Finar,6alty conslrained"'
means that the fl:TP on!y inc.ludes pro}ects that lhe regiun can afford to complete with e)drtinf
re"enue.s. or with reve.,iucs that o1re reasonably upected to be av affable. Th!' RTP must coru.ider nol
oo!y \he cost of ellpanding the 1ransportat!on system to meet future demand, but also the cost of
mainta!rilng the Histing system. Costs must nc.l ex,:;eed ~kely reve11ues. To date, there has been no
such evatu;i\!on in the allemilti-Jes section. Al&.ouah there IJi no mandate to include p,-oject
.illern.rtives In a Supplemental ElR, Ifie SEI!\ must inc!11de financially constrained scer.;r,rlo·to fulflD
the fed er.ii requirement that thl.' Amerided !'I.in be flnanciat111 coortrafned ~.,., budgeted). The
removal or the road kJSiJ!l.e charge from the nt?Wcrk has been replaced w;th sptculative financirig
op(lons. ilather, SANO AG must estimate rev,nue; that are r~onably eipected to be avallable ftGTl
known feder;;I, state, local, ar.d private resoutc!!s tor lransportatlon fundfr1g to lm~lement the
proposed µ,·oje.c!S.
Project/nil revenues aod P.rpeniillures over UU lenfflh oh planning period wll be d:ffirul.t. T~
analysis should rely partly on hirtarlca\ funding patterns from state .nd teaefili source~~ aCditlon.
the year of expenditure must be considered when estimates 101 c.ipital projectsare developed {this
Is required bytfie Federil.lSk.!rf;iceTran~portalion Act).
8. Where reglorial planning proc,es.se5 ~ve rd ri!sulled in lhe adoption of plil.ns or resutatiotlS reining
to the e11vironmenr, CEQA requir~ public agencfe,s to engage In an anztvsis afthe imp aces of1he
p,oposed project on lhe t:!nvircom~nt, (Publk Resources Code§§ 21000; 21007..J; 21003.l(b):
21080(d); 21081; l108Z.2(a).) Although there 15, a gel'lera1 anal'fs!s of projected growth in the region,
there!s it Lick of detail witt, re:.pect to gro·,,,.....h inducement orreasonably-fo,-eseeable future projer.ls
Implementing Public Resources Code section 211~5-21155.4 (CEQA streamlining for SCS
corisistency) and/or other reasonablv fOll'.seeolJll• de11elQpment that may rewlt. The provisl:inot
Improvement of1ransportation inrrastructure. ut!litles, water and sewer service le an arP..1 Cilll
iriduce growth by removing Impediments to developmer,t. ence ,;ervices are c11ler,ded or improved
in an area., economic incenti11es fordevelopml'.nl e•i51. The basic e1'!11lents and pr!ncip!es of the
Amended Plan h.ive bl'cn ~<:Signe.ti to facilltate. future smart grC1.,th and c~ncentrate population
growth in i:reas thilt would~ efficiently set\/ed by transpQrl11liori fad!iUe5. The smart growth
concept ii the ba..<is for the framework forprioriliti11g public land use aru:I transportiltlon
inve!;tnHmls in the recion. The smart growth concept ldmtifies areas where !.mart growth
development exists or could b! bk.littand provides ;i basis fllf p!annin&: tri'll1sportation fac.intle~al'!d
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1·71
Appendix F.1: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-19
The basic purposes of the CEOA are to inform government decision
makers and the public about potential significant environmental
impacts of projects, identify ways the impacts can be reduced or
avoided, prevent significant avoidable environmental damage
through alternatives and mitigation, and disclose to the public the
reason that decision makers approved a project that may result in
unavoidable significant impacts.
CEOA requires the consideration of alternatives to the proposed
Amendment and the analysis of impacts associated with those
alternatives. By comparing the proposed Amendment to the
alternatives, the advantages of each can be weighed and analyzed.
Section 15126.6 of the CEOA Guidelines requires that an EIR "describe
a range of reasonable alternatives to the project, or to the location of
the project, which would feasibly attain most of the basic objectives
of the project but would avoid or substantially lessen any of the
significant effects of the project and evaluate the comparative merits
of the alternatives."
Five alternatives were analyzed in the Draft SEIR, including the No
Project Alternative, to afford decision makers with information about
the potential environmental impacts of the proposed Amendment.
The SEIR carried forward two of the alternatives analyzed in the Final
PEIR, as well as analyzing the No Project Alternative and two new
alternatives based on the additional objective of the proposed
Amendment to remove the regional road usage charge.
RESPONSE TO COMMENT 4-20
The regional road usage charge was not intended to be implemented
until 2030, and as such was only a revenue source for the final
20 years of the approved Plan. Updated revenue assumptions for the
Amendment provide sufficient revenues to fund the projects in the
approved Plan, including historic levels of infrastructure investment
from the federal and state government resulting from the
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-72
Appendix F.l: Response to Comments on the Draft SEIR
Infrastructure Investment and Jobs Act (IIJA, also known as the
Bipartisan Infrastructure Law).
This comment also mischaracterizes the requirements for a financially
constrained RTP and inaccurately states that the implementation and
challenges to fund the proposed Amendment have not been
appropriately discussed. Federal and State laws require SAN DAG to
develop a regional plan built on reasonable assumptions of the
revenues that will be available during the period covered by that plan
(Government Code Section 65080(b)(4); 23 CFR 450.322(f)(lO)(ii)).
New funding sources are revenues that do not currently exist or that
may require additional steps before the MPO or transit agency can
commit such funding to transportation project (2017 RTP Guidelines
for MPOs). Strategies for ensuring their availability must be identified
and future revenues may be projected based on historical trends,
including consideration of past legislative or executive actions (2017
RTP Guidelines for MPOs). The level of uncertainty in projects based
on historical trends is generally greatest for revenues in the "outer
years" (10 years or more) of an RTP. Appendix V of the approved Plan,
as revised by Attachment 1 to the proposed Amendment, explains the
anticipated revenues to fund implementation of the proposed
Amendment. Table V.3 in the approved Plan, as revised by
Attachment 1 of the proposed Amendment, describes the availability
assumptions for new revenue sources identified in Appendix V.
IIJA authorized $1.2 trillion for transportation and infrastructure
spending with $550 billion of that figure going toward "new"
investments and programs. The federal and state discretionary
programs near-term estimates have been updated accordingly to
assume historkal leveraging rates of local TransNet revenue.
The total estimate of near-term State and Federal Discretionary
Programs resulting from IIJA is $6.35 billion.
In Fiscal Years 2021-2023 since the passage of IIJA, SANDAG has·
already received $1.6 billion in discretionary funding revenue
($876 million in state funding and $766 million in federal funding)
compared to the Amendment's assumed $950 million in discretionary
funding revenue ($507 million in state funding and $441 million in
federal funding).
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-73
Appendix F.1: Response to Comments on the Draft SEIR
As explained in Response to Comment 4-19, the Draft SEIR does
evaluate a reasonable range of alternatives that achieve most of the
basic project objectives and that are potentially feasible.
RESPONSE TO COMMENT 4-21
This comment restates the City's comments on the approved Plan. At
the direction of the SANDAG Board, the proposed Amendment is
narrowly focused on removing the regional road usage charge while
meeting state and federal requirements. The Amendment includes no
changes to land use.
For the approved Plan, population and growth impacts are analyzed in
Section 4.14 of the Final PEIR. As stated on pages 4.14-16 and 4.14-17:
"the regional growth and land use change forecasted in the proposed
Plan would be implemented by local jurisdictions through local plans
and individual development projects, and most transportation
network improvements would be implemented by transportation
project sponsors other than SAN DAG. The approved Plan was
developed to accommodate forecasted regional growth and failing to
do so would be inconsistent with the federal and State requirements
for RTPs. In addition, precluding growth would conflict with the
requirements to provide sufficient housing for the region's population
contained in SB 375. As discussed in Section 4.14.2, Government Code
Section 65080(b)(2}(B)(ii) requires that the RTP/SCS must house all
the population of the region, including all economic segments of the
population, over the course of the planning period of the regional
transportation plan."
This comment also addresses future transit priority projects. As
described above, future development projects would be
implemented by local jurisdictions. CEQA Guidelines Sections 21155
through 21155.4 identify CEQA streamlining provisions for transit
priority projects that are consistent with an MPO's SCS that has been
accepted by CARB. Figures D.8 and D.9 in Appendix D of the approved
Plan identify potential areas for transit priority projects. The
approved Plan is an iterative planning document that is typically
updated every four years to account for new data, analysis, policy,
and experience. SAN DAG looks forward to coordinating with the City
on future Plan updates.
4-2'
conl.
4-2.2
Gt1• of Carlsbad C.>mments on Draft Sl.lpplemerm1I En~ironmenlal Impact P.cport for the prupc~ed
Amendmenttothe212.l ReglcnalPlan
t..ugust2S, l0l3
Pae7
transit servic!!li ln the AmeudeU Pla11. Smart ,::ro111th areas id:ntified recei~ prloritlted ll'lfrastnJc.ture
investments and transit :services to support sman srowtti T/l\s carries true lo tho~e sman grom.h
all:'a$Lh;itare;iccommo:fatedbyei.:istinggenl!!ra)plans,andforolherareasth1tarenotco,,erl!dby
ulsting general plans. CEQA ,cquires that an [Ill. dls.:uss the way.s. in which the proposed project
ccwld foster economic or population growth or the construction of additional housine, either
dire-ctly ur indirl'tlly, iu the environment surrnuni:!ing the project. CEQA requires this dlKU5slon lo
lnclw:le w.iys in which :i project would ,eroo11P ntm:.icle!i to popu~tlon 11rowth or encourage and
facilitate other ac:th1ities tnat could significan1il' affect the e1winmment (Cf QA Guideline~ 5ec:tion
l5126.2{dH. The level of detall ihould reflecrthe levelcom;;lned in the plan or plan element :>eing
con5idered !Ria VirtG Form &,r~cm Ci'r1tt>r v. CG:mty •f Solano (1992) 5 Cal.ApJJ.~th 351), lnc.11;.s!Ve of
newsraartgrow1hareasi!sdesienated.
Oty rtatt looks forwa1d to 111ori.1r1~ wrtt, SA.NllAG on impro~ing mobTilt,,· and land use access In the ~gion
ar.d building H1stalnable, equ!table and he<!lttiy modes ::if transportation. We apprcdate the opportunity
to rnrnrmmt on the r1mP.nd~d l"J;m that will help the region reall?e these soa!s. While at the same time!,
dty staff aim looiuiorward to helpi~ ~rmAG ;id~;mce a legallv adequate enwironmental document to
suppart the disclosuri! and decis!on-makins 11rocess. Since the major premise otCEQA. i~ th JI rt ·tie
interpreted 1n such manmiras 1::i afford 1he ful.lt!11 possible protection ta the environment within the
reasonable scope of lhe stat\Jtory !;mguag::" (Frientis of Mammoth~-Baord of 5upervlsor5. supra, 2d7,
2.59), SANDAG should ta~! allactlcn necessary to alert the decision-makers.ind the publi( to thi!'
emirumnenl.li ch,mges .1SSoci•relll with the project (Cauntr of lnro v. Yorty (1973) 32 Cat. A:;ip. 3d 795.
LUO). There Js no shortwt lo CfQA-lhe EIP. process protects not only the emrironment !Jul also
iniorme,d self-govemment iLo!!rel Helgnt5 lmpra11!men1 Ann. \I. Regl!'nts of Unillt!rsizy of Ca/ifomiv,
supra, 376,392) Th~SANDAG S.an:I tnust certifyttiat the flnalSE!R has been completed In compliance
wlthCEQA and that It considered all of !he intorma1ion in the final SEIR before approving or
dis,111pmvlng the prnject. As of this writing, the SEI;\ Is not In complli!nce with C[QA.
II you have any questlc~ rela;:ed to comments on tne transportation netwolil;, pli-;;se conlid:T Tom
Fr.ink, Tr;in~portction Direcror/Citv Englrieer, at Tom.Frank@carlsbadca.gov or, if you need addillonat
ir.iormation related to comrncnt:5 an the land use assu1llptions, p\ea.5!= contact fric Lard~, City Planner,
atErfc.Lardy/5'.lcar!sbadca.go11,
Sinceretv,
j(jflS «,11#-&Sfll;,IV~,,.,,.
JEFF MURPHY
ConimunityDt!Veloprne11tOirect□r
TOM FRANK
Tranoi,ortatlonDlrector/Cltytng:n~r
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-74
Appendix F.1: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-22
SANDAG has fully complied with the requirements of CEQA
in the preparation of the Draft and Final SE I Rs for the
proposed Amendment Regarding disclosure of the proposed
Amendment's physical impacts on the environment in the
Draft and Final SE!Rs, SANDAG has disclosed impacts and
identified mitigation measures for impacts on air quality;
energy; GHG; noise and vibration; transportation; and
cumulative impacts, and has identified alternatives to the
proposed Amendment consistent with CEQA, the CEQA
Guidelines, and the discussion in Friends of Mammoth v.
Board of Supervisors (1972) 8 Cal.3d 247 referenced in the
comment For clarity with respect to the cited discussion in
County of Inyo v. Yorty (1973) 32 Cal.App. 3d 795, the court
states that an EIR is an "environmental 'alarm bell' whose
purpose it is to alert the public and its responsible officials
to environmental changes before they have reached
ecological points ofno return" ( County of Inyo v. Yort;y,
p. 810). The court also cites an earlier version of PRC Section
21000, which states that the government of the state should
"take all action necessary to protect, rehabilitate, and
enhance the environmental quality of the state" ( County of
Inyo v. Yorty, p. 802).
The court in County of Inyo v. Yorty does not state that lead agencies
"should take all action necessary to alert decision-makers and the
public to the environmental changes associated with the project,"
contrary to the comment's assertion.
Prior to consideration and certification of the Final SEIR, and
consistent with the discussion in Laurel Heights Improvement Assn. v.
Regents of University of California /1988} 47 Cal. 3d 375, SAN DAG will
provide the SAN DAG Board of Directors with a Final SEIR completed in
compliance with CEQA Guidelines Section 15132 that reflects
SANDAG's independent judgment and analysis as required by CEQA
Guidelines Section 15090 (a). SAN DAG will also present the SAN DAG
Board of Directors with Findings consistent with CEQA Guidelines
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-75
Appendix F.1: Response to Comments on the Draft SEIR
Section 15091, a Statement of Overriding Considerations consistent
with Section 15093, and a Mitigation Monitoring and Reporting
Program consistent with Section 15097 prior to the SAN DAG Board
consideration of the proposed Amendment and Final SEIR.
City ofCartsbadComment-. on C'lraftSupplement;il En¥lronmental Impact nepon tortht proposed
Am<!mlment lo the 2021 Regional Plan
AU8U5t28, 2023
P ,e8
Attachment:
1. Aug. 8, 2023, City or Carlsbad Comment Letter on the Amendment to the 2021 k~ion.al 1-'lan
(Includes Aug. 6, 2021, comment letter on Draft flegional Plan and Sept. 30, 2021, clarification
letter!
ScoUChadWlck,CltyManai:er
Clndlt McMahon, Oty Atmrn~
Geoff PalllOl', ~!st.int City Mllnager
Ron kemp, Senior Asslslallt City Attorney
Gaf'I Ouberio, Deputv Qty Manager, Community Se-rvi~
PnGome,, Deputy Cil,.i Manaie,. PubllcWorics
MilieStront. Auistant Communhy Development Oireaor
ErlclilnJy,ut'fP!anner
Nam.in Sd1midl, Transl)Ol'Qtion Plarmlng and Mobility Miln1ger
J,nonGeldert,Englneerll\flManai;:er
RobenEfird,PrlncipalPlannP.r
ScottDonnell,SeniorP!c1nner
Nlccle Morrow,Asslsta11t?lanner
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report
Appendix F.1: Response to Comments on the Draft SEIR
Page F.1-76
4-23
(wtiole
•oc/
Aug.&, 2023
San D1eco Asoot1ation ol Governments
401BSul!.et,Suitl!.800
5anDiegoCA9Zl01
Via;Rl'giorialPlilnArnen~rn~t@sandag.ofJ
RE: Cill' of Carlsbad Comments on tl'IQ-Amendment t11 tht 2021 Re11lonal Plan
To Whom It Ma~ Concern,
(city of
Carlsbad
The City of C,v!shad aµµredates the oppCJrtunity to provide comments on the proposed am~mimr111 lo
rhe 2a2.l Reg!o11al Plan tHPlan Amendment"). This is an impcrtant plan fur thi~ rcglori and guides the
11u1 ph;uef of grDW'lh fer !he roernller agencies ol the San Ole go Assc::latlon of Govtmmen-.s
("SANOAGHI. 0.1'1 ctfuctivety desigrted and Implemented re;iona1 trarupomrion plan ensures imi,roved
transporto1r!on options forarl!.a re,,dents, b1.1Slne= and other community meinbers; meaningful
reductions In greenhouse gas l"Gl-!G~) emhsions; am! improved qual/ty of life as we srow our
ro111munities.
The C.ity of Carls!J.ld 1•c1t'fl b submitting the following commentt based on the pollcie.s, oroj&ts,
programs and other Improvements includedl11 the Pl~n f\mendrrierr .. fhE" city rc$Crv~ lhe.rifht to add,
ame11d, cl\ange or replilct' comments and n:oaimmend,1tions based on additional revleY.• a11d
underst.1ndi"£ of the Pl.in Amendment ;md th~ ~nvironmental anal\l5i~ provld~ under lrM-Califc.,rnia
Environmenul Quality Act (~CEQA").
SECTION I: LAND USE
1. Alternative;; Included in 1he approvi!d 20Zl Regional Plan .issumed housi1~ In loO'IUon~ that
were lnr:0ns!nent with th!! city'\ Lanr1 use plans; this Wils disc~ed In oerall in the city's August
6, Z021/ie11temt,,.--t ~. 2021, tomments 011 the di.tr. 2CIJ:l ~~!anal Plan (Attachment 'l 1.
Consinent wi'.h those comments, cir, staff rt-a1mmencl the Plan A.metldme11L:
a. Consider the city's l~nd u.Sl" p~n~ tndudin& the Gerrera! Plan, Habitat Manaa!'me-nI
Plan. and Loc.il Co~stal Program
b. Considerlh! McClella11-Palomar Airport L,ind Use CompatiiJii!ly Pla11 {adopted by the
count')' Aifl]ort land Ust Com<nissioo 11nd ame11ded 0&. l, 201U and the constuinh
lllenllfiedthereln,
2. Ctt,,i staff a.11! encouraged by recent conver.satioo~ wi.,lt;SANDAG staff that 1t1e proposed 2025
Re.11:ionat Plan wi.11 considt't lhe cilv'~ land use dorume,iu. Do!ng so h recommended a°'
e.1pecled .i:,d will help enwt! better aa:uraq, of dalit and am,mptions.
SECTION 2: COMMEIIITS AND RECOMMENDATIONS
City mff remain concerned that there is nol enou1:1h delail on the teasillilitv of lmplern1?.11Ution of this
signiricant shift in traJtSportatJon strategy, On sp!!clflc content in the plans, we oUTtine our
recommendnior.s ;md comments below:
Trar.sportiltion & C.Ommunitv Oellf!lopment Cepanment.s
1635 Faraday Avent.e I ~rlsbad. CA 92008 l 75{!-€,02-2710 l
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-77
Appendix F.1: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-23
This comment addresses the proposed Amendment and the approved
Plan and is not related to the adequacy of the Draft SEIR. As such, no
further response is required.
S A G
Amendment to the
2021 Regional Plan
October 13, 2023
Attachment E
• ~
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•.
Table of Contents
7. I ntrod uction ...................................................... , .... ~ ........... ; ........................................................................................................ 3
2. Project Modifications ....... ~'··················································································································································3
3. Revenue Assumptions .................................... :0 ................................................................................................................... 4
4 . SB 375 and the Sustainable Communities Strategy ....................................................................................... .5
5. Network Performance ........................................................................................................................................................ 6
6. Air Quality Planning and Transportation Conformity ................................................................................... 73
7. Public Review .......................................................................................................................................................................... 74
8. Attachments ............................................................................................................................................................................ 74
Amendment to the 2027 Regional Plan 2
Amendment to the 2021 Regional Plan
1. Introduction
On December 10, 2021, the Board of Directors approved the 2021 Regional Plan, which details
interdependent strategies including transportation policies and programs, infrastructure
investments, and technological advancements to achieve regional goals for transportation,
the environment, and equity. One of the pricing strategies included in the plan is a regional
road usage charge (RUC), which is a direct user fee where drivers pay to use the roadway
network, whether the vehicle is powered by gas, electricity, or hydrogen, based on distance
traveled or other factors.
On September 23, 2022, the Board directed staff to prepare,
"a focused amendment of the 2027 Regional Plan without the regional road
usage charge and a supplemental California Environmental Quality Act
analysis for Board consideration within one year ... "
Under federal metropolitan transportation planning regulations, a regional transportation
plan amendment requires an opportunity for public review and comment, demonstration of
fiscal constraint, and an air quality conformity determination.
The amendment removes the regional RUC from the 2021 Regional Plan, updates the
financial strategies necessary to demonstrate that it will have sufficient revenues to pay for
the planned transportation improvements, and documents federal Air Quality Planning and
Transportation Conformity. This amendment also analyzes consistency with state targets to
reduce greenhouse gas (GHG) emissions consistent with Senate Bill 375 (SB 375).
2. Project Modifications
The amendment is focused on the removal of the regional RUC from the 2021 Regional Plan
and provides updated revenue assumptions. There are no other changes to the
transportation projects, programs, or policies identified in the 2021 Regional Plan.
Separate from the regional RUC, the 2021 Regional Plan also assumes revenues resulting
from a state-administered RUC. SAN DAG will continue to coordinate with the state and other
metropolitan planning organizations (MPOs) on the state's RUC pilot program.
Attachment A, Errata to the 2021 Regional Plan, includes the revisions to the 2021 Regional
Plan resulting from removal of the regional RUC.
Model and Input Corrections: After adoption of the 2021 Regional Plan, staff observed low
traffic counts and employment at some large employment location sites and made minor
corrections resulting in slight changes to regional employment figures. Staff also fixed a
software bug resulting in more accurate traffic volumes on SR ll. A full discussion of the
activity-based modeling inputs is included in Attachment B.
Amendment to the 2027 Regional Plan 3
3. Revenue Assumptions1
Federal la w requires that an MPO identify revenues to cover the improvements included in
its regional transportation plan. The funding strategy for the 2027 Regional Plan considered
all reasonably anticipated revenues to be received through 2050 necessary to cover the
identified cost of $763 billion. State and local revenue from fuel taxes have declined w ith the
increase in vehicle fuel efficiency. Therefore, the 2027 Regional Plan concluded that new
sources of funding beyond the fuel tax w ould be needed for full implementation.
The regional RUC was only one of several potential revenue sources included in the
2027 Regional Plan.
The amendment includes the follow ing updated revenue assumptions:
(1) Removal of the Regional RUC: Removal of the regional RUC reduces anticipated
revenues by $74.2 billion over the life of the 2027 Regional Plan.
(2) Delay timing of future local sales tax revenue: The 2027 Regional Plan assumes a one-
half-cent sales tax measure follow ing the 2022 election. In 2022, a proposed citizen
initiative for a half-cent sales tax measure to help fund the 2027 Regional Plan failed to
qualify for the November 2022 ballot. The amendment assumes the citizen initiative w ill
be circulated for the 2024 ballot and postpones the revenue generated from the new
measure and potential financing opportunities to begin follow ing the 2024 presidential
election, rather than the 2022 midterm election. A second assumed half-cent sales tax
measure in 2028 has not been changed w ith the amendment.
(3) Update to TransNet Revenue: The TransNet program is a voter-approved half-cent
sales tax for transportation purposes in the San Diego region. It was approved by voters
in 2004 and w as estimated to generate $13 billion for regional transportation
improvements for the remaining years of the measure (2027-2050). On April 22, 2022, the
Board approved updated TransNet program revenues based on actual sales tax revenue
collections for FY 2022, w hich are higher than previously anticipated sales tax revenues
for FY 2023. The growth rate is applied to the higher base, generating an additional
$2 billion through 2050. Those additional revenues have been included in the updated
revenue assumptions.
(4) Federal and State Funding: The revenue assumptions for the 2027 Regional Plan w ere
developed prior to the Infrastructure Investment and Jobs Act {IIJA), also known as the
Bipartisan Infrastructure La w {BIL), being signed into law by President Biden in
November 2027. The law authorized $7.2 trillion for transportation and infrastructure
spending w ith $550 billion of that figure going toward "new" investments and
programs. The historic level of infrastructure investment from the federal and state
government in the early phase years of the 2021 Regional Plan w as unknow n and
underestimated. The federal and state discretionary programs near-term estimates
have been updated to assume historical leveraging rates of local TransNet revenue.
These changes w ould result in a net decrease in revenues from $173 billion identified in the
2021 Regional Plan to $165 billion. This revenue would still be sufficient to fund the
anticipated $163 billion of planned transportation improvements included in the
2021 Regional Plan. No changes to projects listed in the 2021 Regional Plan result from the
Amendment. These revenue changes are identified in Tables 3.1 and 3.2 below.
7 All funds are in 2020$ unless otherw ise noted.
Amendment to the 2027 Regional Plan 4
Table 3.7: Amendment Revenue Assumpt ions ,;
-. ---.
• Amendment Revenue Assumptions
Changes sir.ce Regional Plan Approval ($ _ lmp_a11~t ) in m I ions
Removal of Regional RUC
Delay Future Local Revenues for Transportation to start in 2025
Update TransNet Revenue based on A pril 2022 board-approved estimates
Update near-term State Discretionary Programs estimates to incorporate historic
levels of transportation investment (2022-2030)
Update near-term Federal Discretionary Programs estimates to incorporate
historic levels of transportation investment (2022-2030)
Table 3.2: Com parison of Revenues and Costs
Total
($14,229)
($1,896)
$7,914
$2,454
$3,896
($7,861)
r-.. . . . --. C~~~~-ris~· of ~evenues-and C.osts ---,_ ~
Total Revenue Sources
Total Costs
Difference (Rev-Costs)
2021 Regional Plan Amendment Difference
$772,820
$762,538
$70,282
$164,959
$762,538
$2,427
($7,867)
$0
4. SB 375 and the Sustainable Communities Strategy
Under the Sustainable Communities Act, the Ca lifornia Air Resources Board (CARB) sets
regional targets for GHG emissions reductions from passenger vehicle use. CARB has set
targets for 2035 for each of the 78 MPO regions. SANDAG's target is a 79% reduction in per
capita passenger vehicle GHG emissions relative to 2005 as part of the 2027 Regional Plan.2
The amendment removes the regional RUC of3.3 cents per mile starting in 2030. The
resulting decrease in the cost to operate an automobile, results in an increase in single
occupancy drivers that would cause an increase in vehicle miles traveled (VMT) and an
increase in GHG emissions and air pollutants from tailpipe emissions compared to the
2027 Regional Plan. The amendment results in an increase ofl.3 million VMT per day in 2035.
This results in a 78.6% per capita reduction in GHG emissions in 2035 relative to 2005 levels,
w hich is rounded to the nearest w hole number of79% consistent w ith CARB guidelines.3
2 In addition to the CHG reduction target, CARB w ill analy ze w hether the strategies and commitments
in this amendment support the Sustainable Community Strategy's stated CHG emission reductions
and w hether there are any risks to not achieving those strategies and commitments. Final SCS
Program and Evaluation Guidelines, p. 57.
3 "MPOs that rely on a combination of modeled and off-model methods to estimate per capita CHG
emission reductions from its RTP/SCS should round to the nearest integer percent" (Final SCS
Program and Evaluation Guidelines, A ppendices, p. 28).
Amendm en t to the 2027 Regional Plan 5
Table 4.1: Comparison of SB 375 Results •
Population
SB 375 VMT
SB 375 VMT/Person
CHG Per Capita Reduction from 2005
3,620,348
80,766,669
22.l
-20.4%
3,620,348
87 ,478,476
22.5
-78.6
0
7,257,807
0.4
7.8
Notes: 7 2027 Regional Plan w ith transportation model and input corrections as discussed above.
2 May not add up due to rounding.
5. Network Performance
The amendment makes no changes in the transportation network in the 2027 Regional Plan.
Revisions to the primary and supporting performance measures for 2035 and 2050 resulting
from removal of the regional RUC in the amendment are provided in Tables 5.7 and 5.2.
Amendmen t to the 2027 Region a l Plan 6
Table 5.1: Performance of Revenue-Constrained Transportation Network Regionw ide:
Primary Measures , . •
Walk
Bike
Transit
73.9%
97.7%
66.5%
74.8%
97.6%
67.4%
73.9%
97.7%
66.5%
74.8%
97.6%
67.4%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
' Percentage of residents that can access parks within 15 minutes · ,_
Walk
Bike .
Transit
53.4%
95.2%
44.5
53.5%
95.7%
45.4
53.4%
95.2%
44.5
Percentage of residents that can access Tier 1 employment centers
Within 30 minutes by Transit
Within 45 m inutes by Transit
37.7%
57.8%
35.9%
58.4%
o<c.. -' • • ' I -{ --~ • • ' • \ •• <
37.7%
57.7%
Percentage of residents that can access Tier 2 employment centers
Within 30 minutes by Transit
Within 45 minutes by Transit
57.2%
77.4%
59.5%
79.6%
57.7%
77.3%
53.5%
95.7%
45.4
35.9%
58.3%
59.5%
79.6%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
r)'"11~';::; .,...,~ •' --•'"'••' •: I -,,._ ~ _,,;;--v;,;:rc...;;;."''7'-:_..., ,· ";;;V"1:;c,,-_~;:_, ••, ,,~',."«~, •~ •.,-i:;-e•_';-~/.;'",-_::<V-1 :--•I<',,,,.••~ q"', '.r;-.-1
·,Percentage of residents that can access any,employment center (Tier 1-4) • L-... -~ ~'t. • l -. r~M",~!.' -~·~.:-, ~--• ~, -• .... ,_ -. ..._-· -. ~-"' -
Within 30 minutes by Transit
Within 45 minutes by Transit
84.7%
85.7%
85.6%
86.7%
84.7%
85.7%
85.6%
86.7%
0.0%
0.0%
0.0%
0.0%
0.0%
0.7%
-0.7%
0.0%
0.0%
0.0%
0.0%
r . , .. . . . , ~ " . . --. . . ,
l Pe~centage of residents that ca_ri _access h_i~her e'!ucat(on institu!io!'.'s . ;
Within 30 minutes by Transit
Within 45 minutes by Transit
54.7%
78.5%
55.8%
80.4%
54.0%
78.5%
55.7%
80.4%
-0.7%
0.0%
0.0%
0.0%
~ ' ,,
!pn-road COz emissions (change from ~00:5 levels}3 •
Total Tons
Per Capita
38,276
27.l
39,776
20.9
38,767
27.4
39,677
27.2
544
0.3
507
0.3
JI'-•,~ --,.,_!."Ili!;-:: ~'t' ._ .... , • , ...
!:,Y.~hi~le ~!Jes T_r~y~_le_d • .
All Vehicle Classes Regionwide 85,868,724 88,735,779 87,737,224 89,846,864
Per Capita 24.0 24.0 24.4 24.3
7,262,499
0.4
7,777,085
0.3
Notes: 7 2027 Regional Plan with transportation model and input corrections as discussed above.
2 May not add up due t o rounding.
3 Change in on-road CO2 emissions from 2005 values (EMFAC 2074). Negative values indicate
emission reductions. These measures quantify changes in total tons and pounds per capita
and are used to calculate the percent reduction per capita required in SB 375.
A mendment to the 2027 Regional Plan 7
Table 5.2: Performance of Revenue-Constrained Transportation Network: Supporting Measures
Bike &walk 6.5% 8.2% 6.4% 8.1% -0.1% -0.1%
Carpool 15.0% 16.0% 15.2% 16.1% 0.1% 0.1%
Work Trips (peak period) Drive alone 66.6% 62.4% 66.9% 62.7% 0.2% 0.3%
Other (TNC, MicroMobility, 0.5% 0.6% 0.5% 0.6% 0.0% 0.0% Taxi, School bus)
Transit 11.3% 12.8% ll.1% 12.5% -0.2% -0.3%
Bike&w alk 7.0% 8.7% 6.9% 8.6% -0.1% -0.1%
Carpool 14.6% lS.6% 14.7% 15.7% 0.1% 0.1%
Work Trips (all day) Drive alone 66.4% 62.1% 66.8% 62.5% 0.3% 0.3%
Other (TNC, MicroMobility, 0.5% 0.6% 0.5% 0.6% 0.0% 0.0% Taxi, School bus)
Transit 11.4% 12.9% ll.1% 12.6% -0.3% -0.3%
Bike &walk 11.8% 13.5% 11.7% 13.4% -0.1% -0.1%
Carpool 40.5% 40.3% 40.6% 40.5% 0.1% 0.1%
All Trips Drive alone 40.9% 38.9% 41.1% 38.9% 0.1% 0.1%
Other (TNC, MicroMobility, 2.1% 2.3% 2.1% 2.2% 0.0% 0.0% Taxi, School bus)
Transit 4.7% 5.1% 4.5% 5.0% -0.1% -0.1%
Amendment to the 2021 Regional Plan 8
"
Number 119,876 262,471 119,876 262,471 0 0.
Commuter Rail (Tierl)
Percent 3.4% 7.7% 3.4% 7.7% 0.0% 0.0%
Number 322,632 463,722 322,632 463,722 0. 0
Light Rail (Tier 2)
Percent 9.0% 72.5% 9.0% 72.5% 0.0% 0.0%
Number 7,089,742 1,799,095 7,089,742 7,199,095 0 0
Next Gen Rapid (Tier 3)
Percent 30.5% 32.4% 30.5% 32.4% 0.0% 0.0%
Number 1,773,585 7,293,654 7,773,585 7,293,654 0 0
Access to any of the tiers (7-3)
Percent 32.8% 35,0% 32.8% 35.0% 0.0% 0.0%
•'Nu"mber/perce~t of jobs within 0.5 miles of a ~om muter rail, light rail, or next gen Rapid (Tier 1/Tie'r 2/Tier 3) traniit st;,p -,
Number 135,518 232,588 135,518 232,588 0 0
Commuter Rail (Tier 7)
Percent 7.7% 11.1% 7.1% 71.7% 0.0% 0.0%
Number 289,270 370,838 289,270 370,838 0 0
Light Rail (Tier 2)
Percent 75.0% 77.8% 75.0% 17.8% 0.0% 0.0%
Number 874,628 923,202 874,628 923,202 0 0
Next Gen Rapid (Tier 3)
Percent 42.4% 44.2% 42.4% 44.2% 0.0% 0.0%
Number 887,095 7,007,787 887,095 7,007,787 0 0
Access to any of the tiers (7-3)
Percent 46.1% 48.3% 46.7% 48.3% 0.0% 0.0%
Amendment to the 2021 Regional Plan 9
Performance of Revenue-Constrained Transportation Network Regionwide
2021 Regional Plan 1 Amendment
Supporting Performance Measures
2035 2050 2035 2050
N·umber/percent of people within 0.25 miles of a bike facility (class I and II, cycletrack or bike boulevard)
Region
Mohub
Number
Percent
Commuter Rail (Tier7)
Light Rail (Tier 2)
Next Gen Rapid (Tier 3)
Local Bus and Express Bus
All transit boardings
Commuter Rail (Tier7)
Light Ra i I (Tier 2)
Next Gen Rapid (Tier 3)
Local Bus and Express Bus
All transit boardings
Total time engaged in transportation related physical activity per
capita
Percent of the population engaged in 20 min or more of
transportation related physical activity
2,747,020
76.9%
59,906
346,272
383,456
432,345
7,227,978
55,297
338,834
332,407
338,299
7,064,837
17.77
18.5%
' --
3,075,475 2,747,020
87.5% 76.9%
796,793 58,220
355,767 339,077
405,773 377,965
446,240 427,887
7,404,572 7,797,744
795,307 53,796
344,789 331,795
346,626 322,489
349,399 330,877
1,236,127 1,038,957
13.73 77.66
20.4% 18.3%
3,075,475
87.5%
797,708
349,022
395,484
436,325
7,372,538
790,347
338,252
337,532
342,477
7,208,596
13.04
20.3%
Average truck/commercial vehicle travel times to and around regional gateways and distribution hubs (minutes)
15.97 16.20 16.03 16.21
Amendment to the 2027 Regional Plan
Difference 2
2035
0
0.0%
-7,686
-7,740
-77,490
-70,458
-30,774
-l,507
-7,039
-9,912
-7,422
-25,874
-0.71
-0.2%
0.06
2050
0
0.0%
-5,085
-6,744
-70,289
-9,975
-32,034
-4,966
-6,537
-9,094
-6,928
-27,525
-0.09
-0.1%
O.Ol
70
Performance of Revenue-Constrained Transportation Network Regionwide
Supporting Performance Measures
;Average Particulate Matter (Ptv12,S) , •
Exposure per person
Truck travel time index
Highway (SHS)
Arterial
Highway (SHS) + Arterial
. -Heavy Duty Truck delay by facility type (average daily)
Highway (SHS)
All day -Heavy Heavy Duty
Arterial
AM and PM peak -Heavy Heavy Highway (SHS)
Duty Arterial
Highway (SHS)
All day-Medium Heavy Duty
Arterial
AM and PM peak -Medium Highway (SHS)
Heavy Duty Arterial
Highway (SHS)
All day -Light Heavy Duty
Arterial
AM and PM peak -Light Heavy Highway (SHS)
Duty Arterial
Highway (5HS)
Amendment to the 2027 Regional Plan
2021 Regional Plan 1
2035
5.30
7.14
120
176
3,087
5,545
7,948
2,467
7,757
2,958
682
7,788
2,639
7,446
7,473
2,807
6,870
2050
5.44
178
120
179
4,693
5,857
2,833
2,587
7,671
3,092
952
7,275
3,733
7,854
2,079
2,896
70,098
Amendment
2035
5.36
175
127
7.17
3,273
5,586
2,024
2,577
7,209
2,993
717
7,202
2,765
7,577
7,529
2,834
7,787
2050
5.50
179
120
179
4,800
5,868
2,900
2,607
7,717
3,727
979
7,235
3,837
7,974
2,079
2,947
70,354
Difference 2
2035 2050
0.06
0.07
0.07
0.07
733
47
76
56
58
34
28
74
726
72
56
26
377
0.06
0.07
0.00
0.00
707
77
67
26
46
28
27
27
703
60
60
45
257
77
~~ • ~
'. Performance of Revenue-Constrained Transportation Network Regionwide
2021 Regional Plan 1 Amendment Difference 2
Supporting Performance Measures
2035 2050 2035 2050 2035 2050
All day-All Heavy Duty Arterial 15,949 16,803 (HHD + MHD + LHD)
AM and PM peak -All Heavy Duty Highway (SHS) 4,103 5,804
(HHD + MHD + LHD) Arterial 6,456 6,692
Transportation system use costs
Percent of Income Consumed by Out-of-Pocket Transportation
Costs 10.0% 10.4%
Change in Percent of Income Consumed by Out-of-Pocket
Transportation Costs 2.4% 2.7%
Notes: '2021 Regional Plan with transportation model and input corrections as discussed above.
2 May not add up due to rounding.
Amendment to the 2021 Regional Plan
16,095 16,902 147 99
4,264 5,957 161 154
6,553 6,784 96 92
9.5% 10.0% -0.5% -0.4%
1.9% 2.3% -0.5% -0.4%
12
6. Air Quality Planning and Transportation Conformity
SAN DAG must ensure that the amendment w ill not cause or contribute to new air quality
violations, worsen existing violations, or delay the attainment of any relevant National
Ambient Air Quality Standards (NAAQS). This process, known as air quality planning and
transportation conformity, is necessary to be eligible for federal funding for future
transportation projects.
Currently San Diego County is in a nonattainment area for ozone only. Ozone is measured by
its precursors of reactive organic gases (ROG) and nitrogen oxides (NOx). The amendment
removes the regional RUC, which increases total VMT and tailpipe emissions of ozone
precursors. A regional emissions analysis was performed using EMFAC20l7, wh ich is the
emission model used for the transportation conformity analysis for the 2027 Regional Plan.
Air quality emissions modeling for the 2020 State Implementation Plan {SIP) analysis years
and budgets for the 2008 Ozone and 2075 Ozone NAAQS was completed for 2023, 2026, 2029,
2032, 2040 and 2050. Those results are provided in Table 6.7.
Table 6.7: Transportation Conformity Analysis
2023 77 ,258 85,457 73.6 73.4 79.3 77.3
2026 77 ,558 85,667 72.7 77.6 77.3 75.0
2029 77,892 86,285 77.0 70.3 75.9 73.5
2032 72,278 87,358 70.0 9.2 75.7 72.6
2040 72,986 88,730 70.0 7.3 75.7 77.6
2050 73,779 90,083 70.0 6.7 75.7 77.9
Note: The SIP evaluates the ozone precursor pollutants of ROG and NOx as modeled in EMFAC2077 air
quality model. Emissions budgets from the 2020 Plan for Attaining the National Ambient Air Quality
Standards for Ozone in San Diego County (October 2020) were found adequate for transportation
conformity purposes by U.S. EPA, effective October 79, 2027.
The amendment continues to meet transportation conformity requirements with the
removal of the regional RUC. SAN DAG initiated conformity consultation for the amendment
w ith the San Diego Region Air Quality Conformity Working Group (CWG) on November 2,
2022. SAN DAG concluded conformity consultation on March 7, 2023, and circulated the pre-
draft transportation conformity determination for CWG review on April 25, 2023. The Air
Quality Planning and Transportation Conformity is included as Attachment B to this
amendment.
Amendment to the 2027 Regional Plan 73
7. Public Review
SANDAG prepared a Public Involvement Strategy for development of the amendment based
on the Public Involvement Plan for the 2027 Regional Plan. The strategy includes public
meetings, social media, visualizations, and other approaches to outreach. On June 73, 2023,
SAN DAG posted the draft Amendment on the SAN DAG website at sandag.org/regional-
plan/2027-regional-plan.
On June 23, 2023, SAN DAG conducted a public hearing and also discussed the key planning
assumptions for the amendment with the Board of Directors. SAN DAG also hosted three
virtual workshops over the summer to provide the public with the information and tools
necessary to understand the issues and policy choices in the amendment. Comments on the
amendment were accepted via a dedicated phone line, email address, ahd on line comment
tool through August 8, 2023.
A summary of comments received on the amendment, SANDAG's response, as well as copies
of the comments themselves are provided in Attachment C-Public Participation.
8. Attachments
Attachment A-Errata to the 2027 Regional Plan
Attachment B -Air Quality Planning and Transportation Conformity
Attachment C -Public Participation
Amendment to the 2027 Regional Plan 74
March 6, 2023
SANDAG
Attn: Kirsten Uchitel
401 B Street, Suite 800
San Diego, CA 92101
Attachment F
( City of
Carlsbad
City of Carlsbad comments on Notice of Preparation of an Environmental Impact Report for the 2025
Regional Plan
Dear Ms. Uchitel:
Thank you for the opportunity to provide comments on the scope and content of the Environmental
Impact Report (EIR) for the 2025 Regional Plan. The city is familiar with the proposed Regional Plan and
this Notice of Preparatibn (NOP) as we attended the scoping meetings on January 12 and February 15,
2023. Below are considerations the city would like to submit as SANDAG moves forward with the
preparation of its EIR:
1. The regional forecast of jobs, population, and housing establishes the scale and type of growth
that is to be assumed over the proposed Plan's planning period. The most recent planning
assumptions from local agencies must be utilized, including land use model inputs from local land
use plans. At the proposed Plan EIR scoping meetings, SAN DAG noted its intent to analyze several
environmental topic areas in the EIR, including air quality, energy, greenhouse gas emissions, land
use/planning, and population/housing. Please ensure analysis includes clear disclosure and
meaningful study of inconsistencies and impacts to Carlsbad's adopted land use plans and policies
and/or the potential for induced, unplanned population growth within areas of the city. This
should include specific information and timing of transit stops proposed within the city so that
state laws (such as Assembly Bill 2097) that change local land use regulations associated with high-
frequency transit can be fully evaluated. The inconsistency within the 2021 Regional Plan and with
the city's General Plan has driven questions from community members and within comments
received during public review of documents prepared under the California Environmental Quality
Act (CEQA).
2. Please ensure the EIR considers the impact of the proposed Plan and EIR alternatives to the city's
land use plans, including the General Plan, Habitat Management Plan, and Local Coastal Program.
3. Please ensure the EIR considers the impact of the proposed Plan and EIR alternatives to the
McClellan-Palomar Airport Land Use Compatibility Plan (adopted by the County Airport Land Use
Commission and amended Dec. 1, 2011) and the land use regulatory constraints identified
therein. EIR alternatives included in the 2021 Regional Plan assumed future housing growth in
locations that were inconsistent with this plan.
4. The Sustainable Communities and Climate Protection Act of 2008, also known as Senate Bill (SB)
375, requires metropolitan planning organizations (MPOs) to prepare a sustainable communities
strategy using the most recent planning assumptions, as part of their regional transportation
plans. The proposed Plan is also required to achieve specific greenhouse gas emissions target
reductions, pursuant to Government Code §65080. The 2018 California Air Resource Board targets
are the most recent targets established for SANDAG planning purposes and is expressed as a
percent change in per capita passenger vehicle greenhouse gas emissions relative to 2005. The
Community Development Department
Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008 I 442-339-2600
SANDAG
Attn: Kirsten Uchitel
March 6, 2023
Page 2
EIR shou ld identify and descri be the 2018 State Air Resources Board's regional greenhouse gas
emission reduction targets and also address where and how customized and in-house land use
inputs may project higher economic activity and population and housing growth. The effects of
such in terms of its direct, indirect, and cumulative impact to the environment mu st be analyzed
in accordance with CEQA. Furthermore, the EIR must identify and address in a meaningful manner
how competing land use assumptions can be reconciled with the California Air Resource Board
and address what impact that may have on the 2018 regional target.
5. The proposed Plan is legally required to accommodate the forecasted growth in population,
employment, hou seholds, and housing units for the region, using the most recent planning
assumptions. SAN DAG must also apply this legal constraint to the EIR alternatives in order to allow
for an 11apples-to-apples" comparison of the proposed Plan and the EIR alternatives and to provide
a reasonable range of feasible alternatives that could accommodate the forecasted growth. The
term 11feasible" is defined to mean "capable of being accomplished in a successful manner within
a reasonable period of time, taking into account economic, environmental, legal, social, and
technological factors." (CEQA Guidelines §15364.) On this basis, each of the EIR alternatives is
constrained by the same planning assumptions as the proposed Plan, which must maintain the
same regional growth forecasts -population, employment, households, and housing units based
on the most recent planning assumptions, and maintain the same forecast of reasonably available
revenues for Plan implementation.
6. It is anticipated that the proposed Plan would seek to reduce per capita vehicle miles traveled
(VMT), increase accessibility by mode share of bicycle, pedestrian, and transit travel, and reduce
greenhouse gas emissions. City staff recommends using local screening criteria and significance
thresholds as appropriate. When there is a local impact, city staff also recommends maximizing
mitigation benefits locally by prioritizing community specific mitigation including the
establishment of local programs or methods to reduce VMT and support appropriate bicycle,
pedestrian, and transit infrastructure in the areas that bear the impact, with a preference to
proximity.
7. It is city staff's understanding that a program-level EIR will be prepared to support the proposed
Plan, which will set a framework for future environmental analysis and other factors that apply to
the program as a whole. The EIR must consider the activities associated with the proposed Plan
to determine the short-term and long-term effects associated with their implementation
(including associated past, present, and reasonably foreseeable future projects). In doing so, the
EIR should identify how individual specific environmental analysis of each project will be
performed, and by what agency has any permit authority or other approval power over any aspect
of the proposed project prior to each project being implemented.
Should you have any questions, please contact me at eric.lardy@carlsbadca.gov or 442-339-2712.
Sincerely,
ERIC LARDY
City Planner
Attachment G
1
2
9
3
4
,·
SANDAG 13
Population = Fewer Births, Stable Migration,
More Deaths
Births, Deaths, and Net Migration, San Diego County
60.000 50,028
50,000 ...... __________ 37,217
40,000 :-----------------------------_ .:32 -;:6
Births
10,000 400
0 ---'1----1--------1,-~---e___--~~--~-=-~~------~~----=-=--=-=-=-=-=-=-=-...-~
-10,000 Net Migration
-26,659
-40,000
------------Deaths
---------------------
-50,000 -40, 138
-60,000
1990 2000 2010 2020 2030 2040 2050 2060
SANDAG 14
10
5
I
6
Population Projection Summary
Population
4,000,000
3,800,000
3,600,000
3,400,000
3,200,000
3,000,000
2,800,000
2,600,000
2,400,000
1990 2000 2010 2020
Series 14
___________ °i>oF (Vintage 2020)
,,-----------------------l
I ,.--:,:-----3.3t:::i~lion 2060 ♦ ,._.. ----0-------O 3,26 million
c::::=-------------------<> Series 15
2022 3.3::i~lion ------1 3-29 million California Economic Forecast
2030 2040 2050 2060
SA NDAG I 5
The Region Will Continue to Grow More Diverse
1%
2060 38% 34%
2022 43% 34%
■ White ■ Hispanic ■ Asian ■ Multi-Race ■ Black Other
SANDAG 16
11