2023-07-18; City Council; 09; Carlsbad Tomorrow Growth Management Citizens Committee Report — Carlsbad City Council, July 18, 2023 (part 2 of 3)

0 250 ~ 1,000 F-
l I I I I I I I
Cartsbad Boulevard Realignment: R19ht-of-Way and Available Land Analysis* ,_,,... C Proposed ROW (Approximately43 acres) --~
July 13• 2021 c::J Area Available fol Other Uses (Approximately 62 ac~I,, 1114 • M.lysi, is b.Md Oft ...... ..._,, P.:q:ft-«.,.,"#/ bound.,,e ,nd --.,. --,;nd mondod"" pl,nrw,v lo,,ol .n.t,,1is orly.

P•e~47 of 53
* * For comparative visual reference the area is the 6.5 acre eastern portion of Planning Area F. Page 2 of 2

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Excerpt from Monday, May 1, 2023 12:08 PM email to City of Carlsbad, and CA Coastal Commission & State Parks regarding City of Carlsbad's proposed PCH Relocation Project

1. City has indicated it will Cost Carlsbad tax-payers at least $65-80 million for a 3-mile PCH Relocation from Island Way to La Costa Avenue that per the City's 2001 PCH Relocation Analysis will only MAYBE make available about 16-acres of Carlsbad Blvd (aka Coast Highway/PCH) "surplus land" in this area for uses that maybe different than what they are used for now which is mostly constrained protected habitat. The City's 2001 Land Use and Financial Feasibility Studies of PCH Relocation has already 1) documented these 16 acres of "surplus land" which is mostly very narrow and highly constrained, 2) itemized only about 4 acres of reasonable Park land in North of Palomar Airport Road that maybe created from PCH Relocation, and 3) clearly documented that outside funding for PCH Relocation is very unlikely so most or the entire $65-80 million cost for these 16 acres will be paid for by Carlsbad tax-payers. Carlsbad's 2001 PCH Relocation Financial study concluded the only viable way to pay for PCH Relocation was to sell most all the "documented and numbered Surplus Land" for commercial uses. So per the City's 2001 financial report PCH Relocation is not an Open Space or Park project but a land development project. Per Proposition H Carlsbad tax-payers will have to vote if they want the City to send $65-80 million for maybe allowing some of 16 acres of Surplus land available for other uses, or $4 to $5 million per "surplus acre". Recent polling by the City shows that Carlsbad Citizens are not wanting PCH Relocation and voting for PCH Relocation is high unlikely. Verbatim Summary information from the City's 2001 PCH Relocation Studies by URS and ERA include:
a. The 2001 URS Carlsbad Boulevard Realignment Study documented the amount of potential "Surplus land" created by PCH Relocation as noted below. Only "Surplus Areas 4, 5 and 6A" which total 16.5 acres are in South Carlsbad (South of Palomar Airport Road) and need PCH Relocation to be accessible. Surplus Area 6A is east of PCH and can be used now without any PCH Relocation. The City has been misrepresenting how much "surplus land" is created by PCH Relocation. A lot of PCH land is does not need Relocation to be used for needed sidewalks and enhancing current bike lanes. The City incorrectly communicates that 60 acres of City land can be used due to PCH Relocation, which is not correct per the City's own 2001 URS Carlsbad Boulevard Realignment Study.

Page 2 ends

IEmDIFOUR Pllase II Rlldl,_s

4.1 LAND USE ANALYSIS
Figure 4--l A shows the General Plan Land Use Designations, and Figure 4-1 B shows lhc Zoning Designations. Most of the project area is residential, open space/unplanned, and industrial. The parcels being considered for this project are all currently designated as open space.

4.1.1 Surplus Lands
A City-provided GlS parcel map was used in conjWlction with a City-generated map showing land ownership in the project area to caJculate tl1e acres of land remaining after Carlsbad Bou1evard is realigned (Figure 1-3). Additionally, the amount of land owned by the State in the area north of Palomar Airport Road and south of Manzano Drive was calcuJated, The ac~ of land available following realignment of Carlsbad Boulevard are shown in Table 4.1-1. The amount of City-owned land available for other uses following realignment of Carlsbad Boulevard is approximately 41 acres.

The amount of land owned by the State in the area north of Palomar Airport Road and south of Manzano Drive is approximately 15 acres.

TabJe 4.J-1

LAND OWNERSHIP AND AMOUNT OF LAND AVAILABLE

CARLSBAD BOULEY ARD REALIGNMENT
Landowner Acreage
City or Carisbad 41
State or Califomfa 15
The surplus useable land that will result from realigning Carlsbad Boulevard has been grouped into a total of seven surplus land areas, described in Table 4.1-2 below and illustrated in Figures 1-3 through 1-IO.

Surplus Land Area Number
1 2
3 4
5 6A
69 URS
Table 4.1-2

SURPLUS LAND AREA DESCRIPTIONS

CARLSBAD BOULEY ARD REALIGNMENT
Surplus Land Area Name Acreage
Manzano Parcel 20.8
Palomar Point 5 \
North Ponto Beach 10.1
State Beach and 13.7 Campground
Boca Beach 2.3
Seapoinle Parcel 0.5
PA "F• Frontage 2.0
Owner
Stale: approximately 14 aaes
City: app,oximalely 6 a~
State: approximately 0.5 aae
City. approximately 4.5 acres
City
City
City
City
City
w.'9853003KID002•-0.fl.DOCS-OCT .(JIISDG 4-1

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b. The 2001 ERA Carlsbad Boulevard Realignment Study used the URS data to fiscally analyze alternative scenarios for realigning Carlsbad Boulevard away from the coast bluff edge and, in the process, creating opportunities for commercial, recreation, and open space uses. One of the study's objectives is to explore ways to generate revenue from useable public land created, including potential land sale or lease opportunities, and using this revenue to help offset the cost of realigning the road.
c. The scenario that provided the most "Park and Open Space" is Alternative 1. The PCH Relocation "Surplus Areas" that are in South Carlsbad are #4, 5 and 6A or 6B as documented below. Table 1 below documents how many Gross Acres of "Surplus land Area" PCH Relocation provides. The report notes that there are many Constraints on these "Surplus Areas" and the acres listed below may not be achievable or may cost much more to be made/mitigated to be used as noted.

T-t: OEVELOl'MENT PftOGIIAM ICEJIARIOS • -• 1 • PMb .. d Op .. Sp•,_ su,,.,.NM.
-
1 z 3 • ' .... '8
Aare!i• 201 $1 101 1~T 23 0~ 2.0
l>o',,dopolllt eom._1a1
~ H
P\lld<p..-1,g 1.0 o.~ u 0.9 OS
eo,,...,.,11,,-.<>tt, 01 0.1 0.1
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Vlsft)l'Caffllf' ., 2,500 3,000
-·
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~ ~. W.,tlaoe. Roocffl: & 1'Ddd: .ano Ecoron'K• R.Hoa,ct, .\slOd.n:s d.
e.

Table S: PRELIMINARY REVENUE/COST COMPARISON (Y&ar 2001 Ooll.ar5) RevanuH from Commtrclal ~nd S.10$
Capltallnd Value of Flsc.al Revenues to City & ROA
Total Pot•nlial Reven~•
Less.: Ro.ad Con.sltlJCIIOn Costs
l'fel Revenues <OeflclP Alt« Rolld Construction CMts
La&&: Public P.ar1clng, Par11s, Open Sp.Ke, and Faellltlt$ Nel Revenues <Oefle,11> Altf!< Public Costs
Attam.atlva&
1 $ 1,131,000 $
$ 217.000 $
$ 1,348,000 $
$ 18,800,000 s
$ (17,452,000) $
$ 8.999,580 $
$ (26,451,580) $
Source: Economics Research Associales: URS; Wallace, Robens & Todd

Page 4 of 5 ends

2 3 4

9.219,000 s 28,155,000 s 19.465,000
10,849,000 s 24,743,000 $ 16,4.29,000

20.068,000 s 52,898,000 $ 35,894,000

18.800,000 s 18,800.000 s 18.800.000
1,268.000 s 34,098.000 s 17.094,000

12.,062,589 $ 8,496.734 $ 9,358.925
(10.794,589) S 25,601.266 s 7.735.075
Qualifications: While it appears that alternatives 3 and 4 generate enough revenue to cover development costs, the findings at this preliminary planning stage of analysis are qualified, as follows: • The cost estimates are based on gross cost factors and need to be refined as project design becomes more specific. • The cost estimates do not include any extraordinary off-site costs, such as for environmental or traffic mitigation. • Some of the parcels identified for potential development, particularly those west of the alignment, may be vulnerable to long term erosion problems; therefore, their stability needs to be verified. • Most of the value is generated on Surplus Area 1 [aka the Manzano Drive Site that is north of Palomar Airport Road], which is owned by the State of California. The City or Redevelopment Agency would not realize the value of Surplus Area 1 unless the State trades the parcel to the City or Agency for other considerations. Therefore, the City or Agency may not be able to apply proceeds from the value of Surplus Area 1 to road realignment and public facility costs. f. [other tax-payer funding] CONCLUSION: Both the SAN DAG representative and the CalTrans Local Assistance Program representative noted that most road or highway realignments are done to facilitate development. Policymakers are aware of this and generally design funding programs in a way that encourages the private sector to pay for as much of the project costs as possible. Programs are also designed to encourage municipalities to utilize funds from their share of the gas tax, Trans Net, and even the General Fund and Community Development Block Grants before turning to State and Federal funds. Finally, due to the limited funds available, all funding sources give priority to projects of a regional significance over those of local importance.

Since PCH Relocation is not needed to add any new roadway (or bike lane or sidewalk) capacity to PCH, and in fact will DECREASE vehicle roadway capacity if PCH is converted from 4 to 2 lanes, additional roadway funding to Relocate PCH is unlikely. The cost of PCH Relocation will therefore likely fall predominately on Carlsbad tax-payers. The tax-payer value of PCH Relocation has always been questionable at best. That is the reason it has not been built over the past 40-years and even now the City's General Plan DOES NOT COMMIT to providing PCH Relocation only that it "may" or 'may not' ever

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happen. A People for Ponto Citizen prepared using City cost data A Cost-Benefit Analysis comparing PCH Relocation with simply providing the missing sidewalks on PCH and buying Vacant Ponto land for a Ponto Park. That Cost-Benefit Analysis showed that Buying Ponto Park would save Carlsbad's and other tax-payers tens of millions of tax-dollars and while also providing more and better Park and beach parking facilities and benefits. These 2001 Study and People for Ponto's Cost-Benefits facts need to be publicly disclosed to and considered by the Planning Commission.

Tammi Cloud-McMinn
From:

Sent:

Enchanted Seashells < [email protected] >
Monday, July 17, 2023 3:22 PM All Receive -Agenda Item#:}___ To: City Clerk; Melanie Burkholder For the Information of the:

Subject: MAYOR/CITY COUNCIL ~rry COUNCIL
oate7/l'?/J2,:..A .....-cc~
CM ~ACM..:::::_ DCM (3) L
Mayor, Council, District 1 rep:

I've lived here since 1985. Since then, I've raised numerous issues about parks and open space, most recently in 2015 when the city was considering the last update to the General Plan.

Apparently, I'm in District 1 and I would like my representative to pay attention to what the community has been talking about for decades. It should be a no-brainer to provide open space and parks and to save whatever is left of Carlsbad's natural beauty.

In spite of these issues getting more public comments than every either issue combined, they fell on deaf ears and no changes were made.

Imagine how much more precious parks and open space will be when every available parcel is built on, density bonus projects can happen anywhere, and there are thousands of more residents.

If these issues are not addressed now, it will be too late! Since Carlsbad has so much critical natural land still remaining, what happens in Carlsbad also has huge impacts on the success of our entire regional conservation plan. • What happened to the promise of 40% open space at build-out? • Why was over half of the city exempted from the requirement for 15% open space? • Why is there no commitment to a walkable nearby park for every neighborhood? • Why is there no coastal access park in the entire southern half of the city? While our focus is on parks and open space, traffic is also a major concern-and there are many other issues that are also important.

My recommendations:
1 Study park proximity so every neighborhood has access to a park.

2. Add a coastal access park for the southern half of the city.

3. Develop a corrective action plan for the 16 zones exempted from the open space standard.

Rosanne Bentley
619-2007417
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Subject:

Patti Greely <[email protected]>
Monday, July 17, 2023 6:36 PM
City Clerk; [email protected]; Planning
July 18 2023 City Council Meeting Agenda ltem#9 Public Comment Fwd: Ponto Site 18 To Carlsbad City Council, Ca Coastal Commission Ca State Parks and Carlsbad Parks and Planning Commissions Please see again my request for Park and Open Space for the limited resource in Carlsbad Coastal corridor. Reserving this space for CONTINUAL DAILY use by VAST numbers of people versus converting it into a limited number of houses for a small number especially when the costs of ownership for the majority of those homes would be prohibitive for "low income" buyers seems like an obvious decision to make. Coastal land especially at its current erosion rate (see Del Mar bluff collapse or San Clemente train track bluff collapse) is a LIMITED and potentially diminishing resource, whereas inland open space is still available for providing needed expansion of housing and infrastructure (water, electricity, internet, roads). Rail service itself, as it passes thru this designated area, is critical to not only local transportation, but also our economy. Ensuring that existing tracks through Carlsbad have the "space" they need to operate safely and timely as they transport through this specific area undisturbed (noise/vibration/safety) to and from LA ports etc appears essential to our economic and possibly even our military supply chain. Please look at all the various factors that could impact this area and consider how a park would result in providing the best overall benefit for the largest number of "users" that you serve in making this decision.

Thank you
Patti Greely
----------Forwarded message---------
From: Patti Greely <[email protected]>
Date: Tue, May 2, 2023 at 11:15 AM
Subject: Ponto Site 18
To: <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, [email protected] <[email protected]>, <[email protected]>, [email protected] <[email protected]>, <[email protected]> Dear Carlsbad Planning Commission, Parks Commission, City Council and CA Coastal Commission:

RE: 5-3-23 Planning Commission Agenda item #4; portion of Ponto Site 18 land use change and development applications
I request the Planning Commission require the Ponto Site 18 developer to provide actual parkland at Ponto to meet the developer's required Parkland dedication per Carlsbad Municipal Code 20.44. The developer owns over 17 acres at Ponto and such developers should provide their required .7 acres of City Parkland as actual park land; particularly given the City park need at Ponto. Do not allow the developer to pay a Parkland dedication as an in-lieu fee. We need an actual Park at Ponto.

I personally have experience in the real estate and hotel construction field and understand the balance of community and development, as well as the importance of preserving our limited diminishing open coastal spaces for future generations. Please strongly consider what can be lost to the community now and in the future if a Park is not chosen for this specific coastal site Thank you to all
Patti Greely
Vista Mar -Carlsbad resident
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From:

Sent:

To:

Cc:

Subject:

Lance Schulte < [email protected]>
Monday, July 17, 2023 6:54 PM
Council Internet Email; City Clerk; [email protected] 'People for Ponto'
FW: July 18 2023 City Council Meeting Agenda ltem#9 Public Comment Fwd: Ponto Site 18 /Public input I received for the aforementioned City Council agenda item #9 on 7 /18/23, and for Carlsbad's proposed Local Coastal Program Amendment.

From: Patti Greely [mailto:[email protected]]
Sent: Monday, July 17, 2023 6:36 PM
To: :; [email protected]; [email protected] Subject: July 18 2023 City Council Meeting Agenda Item#9 Public Comment Fwd: Ponto Site 18 To Carlsbad City Council, Ca Coastal Commission Ca State Parks and Carlsbad Parks and Planning Commissions
Please see again my request for Park and Open Space for the limited resource in Carlsbad Coastal corridor. Reserving this space for CONTINUAL DAILY use by VAST numbers of people versus converting it into a limited number of houses for a small number especially when the costs of ownership for the majority of those homes would be prohibitive for "low income" buyers seems like an obvious decision to make. Coastal land especially at its current erosion rate (see Del Mar bluff collapse or San Clemente train track bluff collapse) is a LIMITED and potentially diminishing resource, whereas inland open space is still available for providing needed expansion of housing and infrastructure (water, electricity, internet, roads). Rail service itself, as it passes thru this designated area, is critical to not only local transportation, but also our economy. Ensuring that existing tracks through Carlsbad have the "space" they need to operate safely and timely as they transport through this specific area undisturbed (noise/vibration/safety) to and from LA ports etc appears essential to our economic and possibly even our military supply chain. Please look at all the various factors that could impact this area and consider how a park would result in providing the best overall benefit for the largest number of "users" that you serve in making this decision.

Thank you
Patti Greely
----------Forwarded message---------
From: Patti Greely <[email protected]>
Date: Tue, May 2, 2023 at 11 : 15 AM
Subject: Ponto Site 18
To: <[email protected]>, <[email protected]. gov>, <roni [email protected]. gov>, 1 <[email protected]>, <[email protected]>, [email protected] <[email protected]>, <[email protected]>, [email protected] <[email protected]>, <[email protected]> Dear Carlsbad Planning Commission, Parks Commission, City Council and CA Coastal Commission:

I personally have experience in the real estate and hotel construction field and understand the balance of community and development, as well as the importance of preserving our limited diminishing open coastal spaces for future generations. Please strongly consider what can be lost to the community now and in the future if a Park is not chosen for this specific coastal site Thank you to all
Patti Greely
Vista Mar -Carlsbad resident
CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content i 2 Tammi Cloud-McMinn
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Subject:

Dear Mayor and City Council
Lynda Daniels <[email protected]>
Monday, July 17, 2023 8:15 PM
City Clerk
Agenda Item #9
I live very close by to the new park being proposed at Cannon and El Camino Real.

I would very much like to see more trails and open space rather than tennis courts,. volley ball and pickle ball courts! With the acreage allotted we could use the trails! More trees please!!
Thank you!
Lynda Daniels
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Chas Wick <[email protected]>
Monday, July 17, 2023 9:35 PM
City Clerk; Council Internet Email; [email protected]; People for Ponto public input for 7 /18/23 City Council meeting Agenda Item #9" Dear Carlsbad City Council, CA Coastal Commission and CA State Parks, and Carlsbad Parks and Planning Commissions:

We have documented the need and the desire for Ponto Park for years over many petitions and many meetings -Please do the right thing, Build Ponto Park!
Thank you
Chas Wick
7 425 Neptune Dr
Carlsbad, CA 92011
Sent from my iPhone
--
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Tamm! Cloud-McMinn
From:

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To:

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People for Ponto Petition <[email protected]>
Monday, July 17, 2023 9:39 PM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report show$ Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Accordingly, I am making my position known and requesting that I want the Growth Management Committee, City Council and CA Coastal Commission to:
1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acre Park to serve minimal neighborhood needs based on Ponto buildout and City's current minimal Park Standard). Ponto Park should be an appropriately wide, viable, flat and fully useable multi-use grassed field -allow kids space to play informal sports. No thin strip of non-park land.
2) Address loss of 32+ acres of Coastal Open Space Land from sea level rise by providing for Non-neighborhood City and State buildout-population and visitor demands for both Coastal Recreation land use and the loss of the Campground.

Provide sufficient Coastal Recreation and Low-cost Visitor Accommodation land use to address the CA Coastal Act and City/State 'unlimited buildout population/visitor demand', and planned loss of current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City on Ponto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act & Commission relative to the State's recent requirement for unlimited City and State population growth. Document, plot the Seal Level Rise inundation and coastal erosion/bluff hazard areas in Carlsbad's General Plan including the Land Use Map, PCH Relocation Project maps, and in the PCH Project replace all 32+ acres of high-priority Coastal land use that will be lost to sea level rise and coastal erosion, and increase the supply of these high-priority Coastal land uses to address State required unlimited increases 2 in City/State population and visitor demands.
5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposed PCH Relocation, to assure tax-payers (City and/or State) are getting the best and most sustainable value for their tax-payer dollars. The City should use tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CA Coastal Commission, and the Letters from Carlsbad visitor industry, Surfrider Foundation, and Batiquitos Lagoon Foundation.
7) Within the Local Facilities Management Plan Zone 9 portion fully provide the 30- acers of documented missing Unconstrained Growth Management Open Space that developers were supposed to provide. Also fully disclose and incorporate the Ponto Open Space recommendations from North County Advocates per City's lawsuit settlement.

Fully preserve or mitigate sensitive habitat areas within and adjacent to the PCH Project area.
8) Fully provide required storm water quality purification and dentition basins in the PCH Project before project waters and waters passing through the project area are discharged into the ocean and Batiquitos Lagoon.
9) I am concerned about the PCH Modification Project more than doubling traffic congestion along Coast Highway for an extremely costly walkway, when the same walkway and other needed Coastal land uses can be provided for a fraction of the cost along existing Coast Highway. It is not appropriate to try to pass off a walkway as "linear park".
10) Lastly as requested since 2017, directly engage and specifically involve the San Pacifico Community Association and Ponto Community in that portion of the City's PCH Project of planning and design of land use in that community. 3 11) We request the above 11 citizen issues be fully addressed by the Growth Management Committee, City Council, and CA Coastal Commission regarding Park Useable
Open Space and Coastal Land Use issues and City Capital Improvement Projects at Ponto and Coastal South Carlsbad.

Name
Amy Schaefer
Email
[email protected]
City
Carlsbad
State
Ca
Sent from Pegpl~ for Ponto
----- en attachments or click on links unless vou recoqnize the sender and know the content i. 4 Tamm,l Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition < [email protected]>
Monday, July 17, 2023 9:40 PM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit I in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Provide sufficient Coastal Recreation and Low-cost Visitor Accommodation land use to address the CA Coastal Act and City/State 'unlimited buildout population/visitor demand', and planned loss of current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City on Ponto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act & Commission relative to the State's recent requirement for unlimited City and State population growth. Document, plot the Seal Level Rise inundation and coastal erosion/bluff hazard areas in Carlsbad's General Plan including the Land Use Map, PCH Relocation Project maps, and in the PCH Project replace all 32+ acres of high-priority Coastal land use that will be lost to sea level rise and coastal erosion, and increase the supply of these high-priority Coastal land uses to address State required unlimited increases 2 I
j
in City/State population and visitor demands.
5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposed PCH Relocation, to assure tax-payers (City and/or State) are getting the best and most sustainable value for their tax-payer dollars. The City should use tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CA Coastal Commission, and the Letters from Carlsbad visitor industry, Surfrider Foundation, and Batiquitos Lagoon Foundation.
7) Within the Local Facilities Management Plan Zone 9 portion fully provide the 30- acers of documented missing Unconstrained Growth Management Open Space that developers were supposed to provide. Also fully disclose and incorporate the Ponto Open Space recommendations from North County Advocates per City's lawsuit settlement.

Name
Collin Schaefer
Email
[email protected]
City
carlsbad
State
ca
Sent from Peo[}le for Ponto
CAUTION: Do not open attachments or click on links unless vou recognize the sender and know the content i. 4 Tamm,l Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition < [email protected]>
Monday, July 17, 2023 9:40 PM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South C_arlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land - "High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Provide sufficient Coastal Recreation and Low-cost Visitor Accommodation land use to address the CA Coastal Act and City/State 'unlimited buildout population/visitor demand', and planned loss of current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City on Ponto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act & Commission relative to the State's recent requirement for unlimited City and State population growth. Document, plot the Seal Level Rise inundation and coastal erosion/bluff hazard areas in Carlsbad's General Plan including the Land Use Map, PCH Relocation Project maps, and in the PCH Project replace all 32+ acres of high-priority Coastal land use that will be lost to sea level rise and coastal erosion, and increase the supply of these high-priority Coastal land uses to address State required unlimited increases 2 r-in City/State population and visitor demands.
5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposed PCH Relocation, to assure tax-payers (City and/or State) are getting the best and most sustainable value for their tax-payer dollars. The City should use tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CA Coastal Commission, and the Letters from Carlsbad visitor industry, Surfrider Foundation, and Batiquitos Lagoon Foundation.
7) Within the Local Facilities Management Plan Zone 9 portion fully provide the 30- acers of documented missing Unconstrained Growth Management Open Space that developers were supposed to provide. Also fully disclose and incorporate the Ponto Open Space recommendations from North County Advocates per City's lawsuit settlement.

Name
Brayden Schaefer
Email
[email protected]
City
Carlsbad
State
CA
Sent from Pegpl~foi:J:onto
CAUTION: Do not open attachments or click on links unless you recoqnize the sender and know the content i. 4 Tamml Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition <[email protected]>
Monday, July 17, 2023 9:42 PM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Name
Todd Schaefer
Email
todct.schaefer@sbcglobi)l.net
City
Carlsbad
State
CA
Sent from Pe9~for Po_Dto
en attachments or click on links unless vou recoqnize the sender and know the content i 4 Tamm! Cloud-McMinn
From:

Sent:

To:

Subject:

Dee Forsberg, Global Hire <[email protected]>
Monday, July 17, 2023 10:05 PM
City Clerk
Ponto
Dear Carlsbad City Council, CA Coastal Commission and CA State Parks, and Carlsbad Parks and Planning Commissions:

We have documented the need and the desire for Ponto Park for years over many petitions and many meetings -do the right thing, Build Ponto Park!
Thank you
Dee Forsberg
~
A full-cycle executive search firm f ,n recruiting mid-level to e)(ecutive management professionals
[email protected] -(760) 214-7458
Licensed and Insured
en attachments or click on links unless you recognize the sender and know the content i 1 Tamml Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition <[email protected]>
Monday, July 17, 2023 10:06 PM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 -~-------
Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Provide sufficient Coastal Recreation and Low-cost Visitor Accommodation land use to address the CA Coastal Act and City/State 'unlimited buildout population/visitor demand', and planned loss of current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City on Ponto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act & Commission relative to the State's recent requirement for unlimited City and State population growth. Document, plot the Seal Level Rise inundation and coastal erosion/bluff hazard areas in Carlsbad's General Plan including the Land Use Map, PCH Relocation Project maps, and in the PCH Project replace all 32+ acres of high-priority Coastal land use that will be lost to sea level rise and coastal erosion, and increase the supply of these high-priority Coastal land uses to address State required unlimited increases 2 l
I
in City/State population and visitor demands.
5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposed PCH Relocation, to assure tax-payers (City and/or State) are getting the best and most sustainable value for their tax-payer dollars. The City should use tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CA Coastal Commission, and the Letters from Carlsbad visitor industry, Surfrider Foundation, and Batiquitos Lagoon Foundation.
7) Within the Local Facilities Management Plan Zone 9 portion fully provide the 30- acers of documented missing Unconstrained Growth Management Open Space.that developers were supposed to provide. Also fully disclose and incorporate the Ponto Open Space recommendations from North County Advocates per City's lawsuit settlement.

Fully preserve or mitigate sensitive habitat areas within and adjacent to the PCH Project area.
8) Fully provide required storm water quality purification and dentition basins in the PCH Project before project waters and waters passing through the project area are discharged into the ocean and Batiquitos Lagoon.
9) I am concerned about the PCH Modification Project more than doubling traffic congestion along Coast Highway for an extremely costly walkway, when the same walkway and other needed Coastal land uses can be provided for a fraction of the cost along existing Coast Highway. It is not appropriate to try to pass off a walkway as "linear park".
10) Lastly as requested since 2017, directly engage and specifically involve the San Pacifico Community Association and Ponto Community in that portion of the City's PCH Project of planning and design of land use in that community. 3 ---------
11) We request the above 11 citizen issues be fully addressed by the Growth Management Committee, City Council, and CA Coastal Commission regarding Park Useable.

Open Space and Coastal Land Use issues and City Capital Improvement Projects at Ponto and Coastal South Carlsbad.

Name
Rob Schindelheim
Email
rob.schindelheirT1_@fil!1ail.com
City
Carlsbad
State
CA
-
Sent from People_f9r P9_nto
en attachments or click on links unless you recognize the sender and know the content i. 4 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition <[email protected]>
Monday, July 17, 2023 10:10 PM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:
. Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Accordingly, I am making my position known and requesting that I want the Growth Management Committee, City Council and CA Coastal Commission to:
1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acre Park to serve minimal neighborhood needs based on Ponto buildout and City's current minimal Park Standard). Ponto Park should be an appropriately wide, viable, flat and fully useable multi-use grassed field -allow kids space to play informal sports. No thin strip of non-park land.
2) Address loss of 32+ acres of Coastal Open Space Land from sea level rise by providing for Non-neighborhood City and State buildout-population _and visitor demands for both Coastal Recreation land use and the loss of the Campground.

Name
Leandro Festino
Email
lfestino.@g_mail.com
City
Carlsbad
State
CA
Sent from Peof}lefor Ponto
CAUTION: Do not open attachments or click on links unless you recoqnize the sender and know the content i. 4 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition <[email protected]>
Monday, July 17, 2023 10:34 PM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Accordingly, I am making my position known and requesting that I want the Growth Management Committee, City Council and CA Coastal Commission to:
1) Address the true neighborhood Park needs for Ponto (minimal 6-7 acre Park to serve minimal neighborhood needs based on Ponto buildout and City's current minimal Park Standard). Ponto Park should be an appropriately wide, viable, flat and fully useable multi-use grassed field - allow kids space to play informal sports. No thin strip of non-park land.
2) Address loss of 32+ acres of Coastal Open Space Land from sea level rise by providing for Non-neighborhood City and State buildout-population and visitor demands for both Coastal Recreation land use and the loss of the Campground.

Name
Gil Genel
Email
gil@genelbiomedical~~m
City
Carlsbad
State
CA
Sent from PeopJ.e for Ponto
~
CAUTION: Do not ooen attachments or click on links unless vou recoqnize the sender and know the content i. 4 Tamml Cloud-McMinn
From:

Sent:

To:

Subject:

Dear City Council Members,
Andrew Eads <[email protected]>
Monday, July 17, 2023 10:35 PM
City Clerk; Council Internet Email; [email protected]; Carlsbad [email protected]
Ponto Park
I hope this email finds you well. I am writing to express my deep concern regarding the potential development of the open land in our community near Ponto. I strongly believe that this land should be utilized for the creation of a much needed public park rather than being allocated for luxury housing, hotels, etc.

As a resident who deeply values green spaces and community well-being, I believe a park would bring numerous benefits to our neighborhood. Here are a few key points supporting the establishment of a community park:

1. Health and Recreation: A park would provide a safe and accessible space for residents of all ages to engage in physical activities, enjoy nature, and improve their overall well-being. With rising urbanization and limited recreational areas, it is crucial to prioritize spaces that promote an active and healthy lifestyle.

2. Social Cohesion: Parks have a remarkable ability to bring people together, fostering a sense of community and belonging. By providing a common gathering place, a park would encourage social interactions, strengthen neighborhood bonds, and create opportunities for residents to connect with one another.

3. Environmental Conservation: The open land in question possesses ecological value, featuring natural habitats and potential biodiversity. Developing the area for more housing would result in the loss of these invaluable natural resources. Preserving it as a park would allow us to protect and sustain the local environment for future generations.

Considering these points, I urge you to prioritize the long-term benefits a park would bring to our community. The availability of green spaces is essential for the health, happiness, and overall vitality of our neighborhood. I kindly request that you carefully consider the impact of using this open land for luxury housing, which may cater to a select few, rather"than benefitting the entire community.

I encourage the City Council to engage in open dialogue with residents, community organizations, and environmental experts to explore the feasibility of establishing a community park on the identified land. Your thoughtful consideration of this matter is greatly appreciated, and I am confident that your decision will reflect the best interests of the entire community.

Thank you for your time and dedication to serving our community.

Sincerely,
Andrew and Melissa Eads
7436 Capstan Dr., Carlsbad, CA 92011
1 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition <[email protected]>
Monday, July 17, 2023 11:10 PM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 ---
Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Provide sufficient Coastal Recreation and Low-cost Visitor Accommodation land use to address the CA Coastal Act and City/State 'unlimited buildout population/visitor demand', and planned loss of current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City on Ponto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act & Commission relative to the State's recent requirement for unlimited City and State population growth. Document, plot the Seal Level Rise inundation and coastal erosion/bluff hazard areas in Carlsbad's General Plan including the Land Use Map, PCH Relocation Project maps, and in the PCH Project replace all 32+ acres of high-priority Coastal land use that will be lost to sea level rise and coastal erosion, and increase the supply of these high-priority Coastal land uses to address State required unlimited increases 2 ---7
in City/State population and visitor demands.
5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposed PCH Relocation, to assure tax-payers (City and/or State) are getting the best and most sustainable value for their tax-payer dollars. The City should use tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CA Coastal Commission, and the Letters from Carlsbad visitor industry, Surfrider Foundation, and Batiquitos Lagoon Foundation.
7) Within the Local Facilities Management Plan Zone 9 portion fully provide the 30- acers of documented missing Unconstrained Growth Management Open Space that developers were supposed to provide. Also fully disclose and incorporate the Ponto Open Space recommendations from North County Advocates per City's lawsuit settlement.

Fully preserve or mitigate sensitive habitat areas within and adjacent to the PCH Project area.
8) Fully provide required storm water quality purification and dentition basins in the PCH Project before project waters and waters passing through the project area are discharged into the ocean and Batiquitos Lagoon.
9) I am concerned about the PCH Modification Project more than doubling traffic congestion along Coast Highway for an extremely costly walkway, when the same walkway and other needed Coastal land uses can be provided for a fraction of the cost along existing Coast Highway. It is not appropriate to try to pass off a walkway as "linear park".
10) Lastly as requested since 2017, directly engage and specifically involve the San Pacifico Community Association and Ponto Community in that portion of the City's PCH Project of planning and design of land use in that community. 3 I
---~--~ -~ --
11) We request the above 11 citizen issues be fully addressed by the Growth Management Committee, City Council, and CA Coastal Commission regarding Park Useable
Open Space and Coastal Land Use issues and City Capital Improvement Projects at Ponto and Coastal South Carlsbad.

Name
Jay Marquand
Email
[email protected]
City
Carlsbad
State
CA
Sent from PeoJ}le for Ponto
CAUTION: Do not open attachments or click on links unless you recoqnize the sender and know the content i. 4 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition <[email protected]>
Monday, July 17, 2023 11:35 PM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 -------
Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Provide sufficient Coastal Recreation and Low-cost Visitor Accommodation land use to address the CA .Coastal Act and City/State 'unlimited buildout population/visitor demand', and planned loss of current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City on Ponto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act & Commission relative to the State's recent requirement for unlimited City and State population growth. Document, plot the Seal Level Rise inundation and coastal erosion/bluff hazard areas in Carlsbad's General Plan including the Land Use Map, PCH Relocation Project maps, and in the PCH Project replace all 32+ acres of high-priority Coastal land use that will be lost to sea level rise and coastal erosion, and increase the supply of these high-priority Coastal land uses to address State required unlimited increases l ~-----
2 in City/State population and visitor demands.
5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposed PCH Relocation, to assure tax-payers (City and/or State) are getting the best and most sustainable value for their tax-payer dollars. The City should use tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CA Coastal Commission, and the Letters from Carlsbad visitor industry, Surfrider Foundation, and Batiquitos Lagoon Foundation.
7) Within the Local Facilities Management Plan Zone 9 portion fully provide the 30- acers of documented missing Unconstrained Growth Management Open Space that developers were supposed to provide. Also fully disclose and incorporate the Ponto Open Space recommendations from North County Advocates per City's lawsuit settlement.

Additional Comments
WE WANT THE PONTO PARK!!! WE LIVE AND RAISE OUR FAMILIES HERE, PAY TAXES, VOTE AND ARE ENTITLED TO THE OPEN SPACE AND PARK!!
Name
Shirley Keating-Hudson
Email
skeatinghudson@yaho~Q.~om
City

CARLSBAD
State
CA
Sent from PeoJ?.le fen.Ponto
4 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition <[email protected]>
Tuesday, July 18, 2023 12:17 AM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Fully preserve or mitigate sensitive habitat areas within and adjacent to the PCH Project area.
8) Fully provide required storm water quality purification and dentition basins in the PCH Project before project waters and waters passing through the project area are discharged into the ocean and Batiquitos Lagoon.
9) I am concerned about the PCH Modification Project more than doubling traffic congestion along Coast Highway for an extremely costly walkway, when the same walkway and other needed Coastal land uses can be provided for a fraction of the cost along existing Coast Highway. It is not appropriate to try to pass off a walkway as "linear park".
10) Lastly as requested since 2017, directly engage and specifically involve the San Pacifico Community Association and Ponto Community in that portion of the City's PCH Project of planning and design of land use in that community. - -. - l
3 11) We request the above 11 citizen issues be fully addressed by the Growth Management Committee, City Council, and CA Coastal Commission regarding Park Useable
Open Space and Coastal Land Use issues and City Capital Improvement Projects at Ponto and Coastal South Carlsbad.

Name
Susan Marsteller
Email
[email protected]
City
Carlsbad
State
CA
Sent from PeQP.Le for f:onJ.g
·en attachments or click on links unless vou recoqnize the sender and know the content i 4 TammI Cloud-McMinn
From: Council Internet Email
Sent:

To:

Tuesday, July 18, 2023 8:25 AM
City Clerk
Subject: FW: Keep Ponto for a Park
-----Original Message-----
From: Holly Turnbull <[email protected]>
Sent: Tuesday, July 18, 2023 6:07 AM
To: Council Internet Email <[email protected]> Subject: Keep Ponto for a Park
Dear city council
Consider this request from a resident who is requesting that you keep the Ponto space for a park. The last bit of coastline should be maintained for a park. The congestion that will be created for the proposed plan will only further destroy our coastline and add to the depletion of valuable resources already being taxed by other developments in close proximity.

Respectfully,
Holly Turnbull
7360 Seafarer Place 92011
CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe. 1 Tamml Cloud-McMinn
From: Council Internet Email
Sent:

To:

Tuesday, July 18, 2023 8:26 AM
City Clerk
Subject: FW: Ponto Park Preserve open space
From: Valerie and Dennis Cowan <[email protected]>
Sent: Tuesday, July 18, 2023 6:25 AM
To: Council Internet Email <[email protected]> Subject: Ponto Park Preserve open space
Dear Carlsbad City Council, CA Coastal Commission and CA State Parks, and Carlsbad Parks and Planning Commissions:

We have documented the need and the desire for Ponto Park for years over many petitions and many meetings -do the right thing, Build Ponto Park!
Please do the right thing.

Thank you,
Val and Dennis Cowan
CAUTION: Do not open attachments or click on links unless you recoqnize the sender and know the content i 1 Tamm,l Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition <[email protected]>
Tuesday, July 18, 2023 8:27 AM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Provide sufficient Coastal Recreation and Low-cost Visitor Accommodation land use to address the CA Coastal Act and City/State 'unlimited buildout population/visitor demand', and planned loss of current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City on Ponto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act & Commission relative to the State's recent requirement for unlimited City and State population growth. Document, plot the Seal Level-Rise inundation and coastal erosion/bluff hazard areas in Carlsbad's General Plan including the Land Use Map, PCH Relocation Project maps, and in the PCH Project replace all 32+ acres of high-priority Coastal land use that will be lost to sea level rise and coastal erosion, and increase the supply of these high-priority Coastal land uses to address State required unlimited increases 2 in City/State population and visitor demands.
5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposed PCH Relocation, to assure tax-payers (City and/or State) are getting the best and most sustainable value for their tax-payer dollars. The City should use tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CA Coastal Commission, and the Letters from Carlsbad visitor industry, Surfrider Foundation, and Batiquitos Lagoon Foundation.
7) Within the Local Facilities Management Plan Zone 9 portion fully provide the 30- acers of documented missing Unconstrained Growth Management Open Space that developers were supposed to provide. Also fully disclose and incorporate the Ponto Open Space recommendations from North County Advocates per City's lawsuit settlement.

Name
Karen Johnson
Email
[email protected]
City
Carlsbad
State
CA
Sent from PeQQle for Ponto
,en attachments or click on links unless vou recoanize the sender and know the content i 4 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

Council Internet Email
Tuesday, July 18, 2023 8:28 AM
City Clerk
FW: People for Ponto
From: Richard Nucci <[email protected]>
Sent: Tuesday, July 18, 2023 7:07 AM
To: Council Internet Email <[email protected]> Subject: People for Ponto
Dear Carlsbad City Council, CA Coastal Commission and CA State Parks, and Carlsbad Parks and Planning Commissions:

Please listen to your residents and act accordingly -we want to protect Park and Open Space in the South Carlsbad Coastal corridor. Reserving this last bit of coastal space for residents and visitors to enjoy is an easy decision to make. This land and the close by natural lagoon are precious natural resources that we need to protect and keep open for generations to come.

We have documented the need and the desire for Ponto Park for years over many petitions and many meetings -do the right thing, Build Ponto Park!
Thank you,
Concerned neighbor, Richard Nucci
Sent from Richard's iPad Pro
,en attachments or click on links unless vou recognize the sender and know the content i.

Tamm,l Cloud-McMinn
From: Council Internet Email
Sent:

To:

Tuesday, July 18, 2023 8:31 AM
City Clerk
Subject: FW: Ponto Park
From: Victor Cavataio <[email protected]>
Sent: Tuesday, July 18, 2023 7:55 AM
To: Council Internet Email <[email protected]> Subject: Ponto Park
Dear Carlsbad City Council, CA Coastal Commission and CA State Parks, and Carlsbad Parks and Planning Commissions:

We have documented the need and the desire for Ponto Park for years over many petitions and many meetings -do the right thing, Build Ponto Park!
Thank you
Victor Cavataio --------------------
CAUTION: Do not open attachments or click on links unless vou recognize the sender and know the content i. 1 Tammi Cloud-McMinn
From: Council Internet Email
Sent:

To:

Tuesday, July 18, 2023 8:32 AM
City Clerk
Subject: FW: You MUST approve Ponto Park or the opportunity will be gone forever! From: Bill Bradford <[email protected]>
Sent: Tuesday, July 18, 2023 8:18 AM
To: Council Internet Email <[email protected]> Subject: You MUST approve Ponto Park or the opportunity will be gone forever! My parents built their first house in Carlsbad in 1945, and I was born in Oceanside Hospital in 1946.

My parents taught me that if a Park was not approved by the City that the land would be lost FOREVER!
Please keep this in the forefront of you thoughts as you consider Ponto Park, which we need and deserve in this southern Gateway to Carlsbad!
William Curley Bradford, SOS Stern Way
en attachments or click on links unless you recoqnize the sender and know the content i. 1 Tammi Cloud-McMinn
From: Council Internet Email
Sent:

To:

Tuesday, July 18, 2023 8:32 AM
City Clerk
Subject: FW: public input for 7 /18/23 City Council meeting Agenda Item #9" From: Bill Carlsbad <[email protected]>
Sent: Tuesday, July 18, 2023 8:20 AM
To: Council Internet Email <[email protected]> Subject: public input for 7 /18/23 City Council meeting Agenda Item #9" My parents built their first house in Carlsbad in 1945, and I was born in Oceanside Hospital in 1946.

My parents taught me that if a Park was not approved by the City that the land would be lost FOREVER!
Please keep this in the forefront of you thoughts as you consider Ponto Park, which we need and deserve in this southern Gateway to Carlsbad!
William Curley Bradford, 505 Stern Way
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From:

Sent:

To:

Subject:

People for Ponto Petition < [email protected] >
Tuesday, July 18, 2023 8:49 AM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Fully preserve or mitigate sensitive habitat areas within and adjacent to the PCH Project area.
8) Fully provide required storm water quality purification and dentition basins in the PCH Project before project waters and waters passing through the project area are di.scharged into the ocean and Batiquitos Lagoon.
9) I am concerned about the PCH Modification Project more than doubling traffic congestion along Coast Highway for an extremely costly walkway, when the same walkway and other needed Coastal land uses can be provided for a fraction of the cost along existing Coast Highway. It is not appropriate to try to pass off a walkway as "linear park".
10) Lastly as requested since 2017, directly engage and specifically involve the San Pacifico Community Association and Ponto Community in that portion of the City's PCH Project of planning and design of land use in that community. ----
3 11) We request the above 11 citizen issues be fully addressed by the Growth Management Committee, City Council, and CA Coastal Commission regarding Park Useable
Open Space and Coastal Land Use issues and City Capital Improvement Projects at Ponto and Coastal South Carlsbad.

Name
Shara Solitare
Email
[email protected]
City
Carlsbad
State
Ca
Sent from PegQ~ f9r_ P._onto
CAUTION: Do not open attachments or click on links unless vou recor:,nize the sender and know the content i 4 Tamm,l Cloud-McMinn
From:

Sent:

To:

Subject:

Jennifer Philion <[email protected]>
Tuesday, July 18, 2023 8:50 AM
Council Internet Email; City Clerk; [email protected]; [email protected]
Public input for 7 /18/23 City Council Mtg Item #9
Dear Carlsbad City Council, CA Coastal Commission and CA State Parks, and Carlsbad Parks and Planning Commissions:

Please listen to your residents and act accordingly -we want to protect Park and Open Space in the South Carlsbad Coastal corridor. Reserving this last bit of coastal space for residents and visitors to enjoy is an easy decision to make. We have documented the need and the desire for Ponto Park for years over many petitions and many meetings -do the right thing, Build Ponto Park! Thank you
Jennifer Philion, San Pacifico
CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content i. 1 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition <[email protected]>
Tuesday, July 18, 2023 8:52 AM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+. acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Additional Comments
We have made our views clear over and over through petitions and meetings. Please listen and do the right thing!
Name
Jennifer Philion
Email
[email protected]
City
Carlsbad
State
CA
Sent from .E_~l_e_Jor Ponto
4 Tamml Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition < [email protected] >
Tuesday, July 18, 2023 9:02 AM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Additional Comments
Save our natural space please! Save our beautiful space. No building! Green space only.

For environmental reasons and for conservation please don't take it away and create more pollution thank you
Name
Amanda Gardstrom
Email
[email protected]~om
City
Carlsbad
State
Ca
Sent from People_for Ponto
4 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition <[email protected]>
Tuesday, July 18, 2023 9:10 AM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Fully preserve or mitigate sensitive habitat areas within and adjacent to the PCH Project area.
8) Fully provide required storm water quality purification and dentition basins in the PCH Project before project waters and waters passing through the project area are discharged into the ocean and Batiquitos Lagoon.
9) I am concerned about the PCH Modification Project more than doubling traffic congestion along Coast Highway for an extremely costly walkway, when the same walkway and other needed Coastal land uses can be provided for a fraction of the cost along existing Coast Highway. It is not appropriate to try to pass off a walkway as "linear park".
10) Lastly as requested since 2017, directly engage and specifically involve the San Pacifico Community Association and Ponto Community in that portion of the City's PCH Project of planning and design of land use in that community. -----
3 11) We request the above 11 citizen issues be fully addressed by the Growth Management Committee, City Council, and CA Coastal Commission regarding Park Useable
Open Space and Coastal Land Use issues and City Capital Improvement Projects at Ponto and Coastal South Carlsbad.

Additional Comments
While the Alila Ma·rea Resort is not in Carlsbad, this clearly demonstrates the need for more open space recreational land use for the enjoyment of all. There is very little sandy beach for the guests to share with Carlsbad residents and visitors alike. And furthermore it does not seem fair that what little space there is can be occupied by hotel chairs and blanl<ets.

Presumably we are trying to attract visitors to our lovely neighborhood to enjoy its natural beauty. If every bit of coastal land is given up to the development of more cement structures, what will the attraction be? A very expensive room with a view of the horizon and nowhere to walk?
Coastal erosion is out of our control, but we can prevent further wildlife habitat loss through prudent planning.

Name
Patti Hughes
Email
[email protected]
City
Carlsbad
4 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

Comment:

Mrs Hughes < [email protected]>
Tuesday, July 18, 2023 9:26 AM
City Clerk
Public input for 7 /18/23 City Council meeting Agenda Item #9 While the Alila Marea Resort is not in Carlsbad, this clearly demonstrates the need for more open space recreational land use for the enjoyment of all. There is very little sandy beach for the guests to share with Carlsbad residents and visitors alike. And furthermore it does not seem fair that what little space there is can be occupied by chairs and blankets bearing the hotel logo. It's a public beach.

Thank You,
Patti Hughes
South Carlsbad
CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content i 1 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition <[email protected]>
Tuesday, July 18, 2023 9:38 AM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land - "High-priority Coastal Land Uses".
- There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Name
Jason Bishop
Email
[email protected]
City
Carlsbad
State
CA
Sent from People foJ:PontQ
CAUTION: Do not open attachments or click on links unless you recoqnize the sender and know the content i. 4 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

People for Ponto Petition < [email protected] >
Tuesday, July 18, 2023 9:38 AM
[email protected]
Protect Ponto Petition Letter
Protect Ponto Petition:

Dear Carlsbad Growth Management Committee, City Council, and California Coastal Commission:

Since 2017 the City received over 5,000 petitions, written and verbal testimony regarding the need for Ponto Park and the Park and Useable Open Space unfairness at Ponto and Coastal South Carlsbad. The City staff should provide the Growth Management Committee all that citizen input since 2017. -The City's 2017 & 2020 Sea Level Rise Report shows Ponto will lose over 32-acres of "High-priority Coastal Land Use" due to coastal erosion and flooding. (14+ acres of Coastal Recreationand 18+ acres of Campground will be lost) in Carlsbad's General Plan.
-Carlsbad's Growth Management Program and 2015 General Plan did not consider this critical 2017 & 2020 Sea Level Rise data and new actions and a new Plan are needed to address the 32+ acre loss AND increased population/visitor demand for "High-priority Coastal Land Uses".
-Carlsbad's Growth Management Program and General Plan also did not incorporate requirements for unlimited population growth that will need even more City and Coastal Recreation land -"High-priority Coastal Land Uses".
-There is a current Growth Management Program 6.6-acre City park deficit in Coastal 1 ------------------~--~-~-
Southwest Carlsbad, and a 30-acre Unconstrained/Useable Coastal open-space deficit in Zone 9 (Ponto area -west of 1-5 and south of Poinsettia) that only gets worse as we lose 32+ acres of Coastal Open Space lands from Sea Level Rise.

Provide sufficient Coastal Recreation and Low-cost Visitor Accommodation land use to address the CA Coastal Act and City/State 'unlimited buildout population/visitor demand', and planned loss of current supply due to planned sea level rise. 3) Disclose and address 2017 CA Coastal Commission direction to City on Ponto Vision Plan and Planning Area F Existing LCP in the PCH Project. 4) Fully address Sea Level Rise impacts consistent with CA Coastal Act & Commission relative to the State's recent requirement for unlimited City and State population growth. Document, plot the Seal Level Rise inundation and coastal erosion/bluff hazard areas in Carlsbad's General Plan including the Land Use Map, PCH Relocation Project maps, and in the PCH Project replace all 32+ acres of high-priority Coastal land use that will be lost to sea level rise and coastal erosion, and increase the supply of these high-priority Coastal land uses to address State required unlimited increases 2 ---- - -. ------------
in City/State population and visitor demands.
5) Fully disclose and consider the 2022-June General Comparative tax-payer Costs/Benefits Analysis of Ponto Park-PCH completion-proposed PCH Relocation, to assure tax-payers (City and/or State) are getting the best and most sustainable value for their tax-payer dollars. The City should use tax-payer money wisely. 6) Incorporate the 5,000+ written/emailed petitions to the Council & CA Coastal Commission, and the Letters from Carlsbad visitor industry, Surfrider Foundation, and Batiquitos Lagoon Foundation.
7) Within the Local Facilities Management Plan Zone 9 portion fully provide the 30- acers of documented missing Unconstrained Growth Management Open Space that developers were supposed to provide. Also fully disclose and incorporate the Ponto Open Space recommendations from North County Advocates per City's lawsuit settlement.

Additional Comments
Please preserve our open space and allow not only the residents to enjoy what little beach we have but more importantly the animals. The heartless and greedy development of this beautiful land is a travesty and needs to be stopped.

Name
Eden Hughes
Email
[email protected]
City
Carlsbad
State
California
Sent from People_ fQI Ponto
4 Tammi Cloud-McMinn
From:

Sent:

To:

Subject:

Barbara Campbell <[email protected]>
Tuesday, July 18, 2023 9:47 AM
Council Internet Email; City Clerk; [email protected] People for Ponto Have a voice !!
Dear Carlsbad City Council, CA Coastal Commission and CA State Parks, and Carlsbad Parks and Planning Commissions:

We have documented the need and the desire for Ponto Park for years over many petitions and many meetings -do the right thing, Build Ponto Park!
Thank you
Barbara C. Campbell
562-252-6685
CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content i safe.'
1 Tamm! Cloud-McMinn
From:

Sent:

To:

Subject:

Lauren < [email protected]>
Tuesday, July 18, 2023 9:58 AM
City Clerk
Ponto Park
Dear Carlsbad City Council, CA Coastal Commission and CA State Parks, and Carlsbad Parks We REALLY want to protect Park and Open Space in the South Carlsbad Coastal corridor. Reserving this last bit of coastal space for residents and visitors to enjoy is an easy decision to make.

OUR kids need a park that we can walk to!!! Our community deserves open green space! We have documented the need and the desire for Ponto Park for years over many petitions and many meetings -do the right thing, Build Ponto Park!
Thank you,
Lauren, Callie(2), Addison(5) & Mookie (doggie friend) Robertson Sent from my iPhone
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From:

Sent:

To:

Subject:

Council Internet Email
Monday, July 17, 2023 8:40 AM
City Clerk
FW: South Carlsbad State Beach Agenda Item #9
From: Mitch Warachka <[email protected]>
Sent: Saturday, July 15, 2023 4:13 PM
To: Council Internet Email <[email protected]> Subject: South Carlsbad State Beach
Hello,
All Receive - Agenda Item # 9..

For the Information of the:
_ Sl"f'Y_COUNCIL
oate~ .,,,- cc ...
cMLACM_cDCM(3} ---'
I am curious if there is any procedure that would enable South Carlsbad State Beach to be administered by the city of Carlsbad? It is a wonderful property that unfortunately is poorly managed by the state park system. As the location is not remote (as is the case with most state parks) but clearly part of Carlsbad, it could be better utilized by local residents if it were administered by the city . ·
Thanks in advance,
Mitch
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From:

Sent:

To:

Cc:

Subject:

Dear Mayor and Council,
joan herskowitz <[email protected]>
Monday, July 17, 2023 6:45 AM
City Clerk
Joan Herskowitz
Council July 18 Agenda Item # 9 - Growth Management Rpt I am writing on behalf of the Buena Vista Audubon Society with regard to the recently issued report on the proposed Growth Management Plan performance standards . These have not been modified since adopted in 1986 and are in much need of upgrades , as Carlsbad still has considerable amounts of critical natural lands.

The standards should address the following questions:

What happened to the promise of 40% open space at build-out? Why was over half the City exempted from the requirement for 15% open space? Why is there no commitment to a walkable nearby park for every neighborhood? Why is there no coastal access park in the entire southern half of the City? Our specific recommendations include the need to: study park proximity so every neighborhood has access to a park; add a coastal access park for the southern half of the City; and, develop a corrective action plan for the 16 zones exempted from the open space standard.

The City should enact the committee's recommendation to "address potential open space deficits and evaluate opportunities to acquire more open space by updating the list of candidate properties for proactive open space acquisition ... ". These should include additional open space to protect sensitive areas and varied habitats (grassland , coastal sagebrush , riparian , etc.) from development.

Standards and policies adopted by Carlsbad that protect open space and natural lands affect quality of life and the regional effort to protect open space and wildlife corridors throughout our region.

Thank you for consideration of our views on thi_s matter.

Joan Herskowitz
Conservation Committee
Buena Vista Audubon Society
CAUTION: Do not open attachments or click on links unless ize the sender and know the content i safe.
1 Tammy Cloud-McMinn
From:

Sent:

To:

Greg Kahn <[email protected]>
Saturday, July 15, 2023 6:22 PM
City Clerk
Subject: Questions for Next City Council Meeting

1. In South Carlsbad, we don't have beaches. It is just rocks and beaches that can no longer be enjoyed. What does the city plan to do to give us back our beautiful beaches? ·

2. In South Carlsbad, we need more park spaces for our kids to play or for us to take leisurely walks. What will the city do to have park space available comparable - to our neighboring cities?
Greg Kahn
[email protected]
1 Tammy Cloud-McM inn
From: Lance Schulte < [email protected]>
Friday, July 14, 2023 10:40 AM Sent:

To:

Cc:

City Clerk; Council Internet Email; [email protected] 'Smith, Darren@Parks'; Homer, Sean@Parks; 'Moran, Gina@Parks'; 'People for Ponto'; Eric Lardy
Subject: 2023-7-18 Council agenda item #9 - Public input for Carlsbad LCPA-Parks Master Plan & Growth Management Plan Updates - do the right and smart thing for our future CTGMC key issues and suggest ions -2022-12-6.pdf; Carlsbad 2019 proposed Draft LCP Amendment - People for Ponto 2023-Jul Updated Public Comments - Coastal Recreation.pdf; TPL Support for Ponto Park - 2022-3-11.pdf; History of Open Space at Ponto - 2022-1-26.pdf; Sea Level Rise and Carlsbad DLCP-LUPA planned loss of OS at Ponto - 2022.pdf; 2022 General Comparative cost-benifits of Completing PCH-PCH Modification -Ponto Park - Part 1 of 2 (2).pdf; City's PCH area map w numbered notes of Constraints - 2 of 2.pdf
Attachments:

Dear Carlsbad City Council, CA Coastal Commission and CA State Parks, and Carlsbad Parks and Planning Commissions:

We again send you data and request you read, publicly disclose/discuss/consider the extensive Carlsbad Citizen input and documented data, as has been asked of you by over 5,500 petitions and many verbal presentations . • Your Staff Report did not clearly disclose to you and Carlsbad Citizens the extent of Public Input on the Growth Management Update. The Staff Report hides from your and Citizen review 1,248 pages and 21 MB of Citizen Public in a link at a bottom of a report and does not even not even attempt to summa rized the magnitude and main points of Citizen Input on Growth Management . Those failings are a disservice to you and Carlsbad Citizens. The vast majority of Carlsbad Citizens wanted an honest addressing of needed Park Accessibility, removing false 'exemptions' to the Open Space Standard, and because these issues intersect in a crit ical location specifically provide a much needed (and better tax-payer solution) Ponto Park. T his was the vast m ajority of Citizen input, but was/ is being hidden and 'swep t under the rug' in the report to you and Citizens. Over 400 formal written petitions were submitted to the Committee. o Do the Right Thing - require an honest and full public accounting of the Carlsbad Citizen Input on Growth Management and Council Please discuss and honestly consider and represent that Carlsbad Citizen input.
o Do the Right Thing - read and publicly disclose/discuss and direct staff to work WITH (not against) Citizens on the practical and data based suggestions in the attached "CTGMC key issues and suggestions 2022-12-6" file.
• Carlsbad Citizens had to find out that Carlsbad is 5 more cities worst at providing Park access for its residents . Carlsbad is the worst city in t he 29 cities from Santa Barbara south to the Mexican board - for over 250 miles of CA coastline - in provid ing park access. T he Council and staff should be embarrassed if this is Park Standard you are providing citizens. See the attached "Coastal Recreation" data file for that and other data showing the past Council's failu re in Parks and Coastal Land use planni ng for Parks in South Carlsbad. o Do the Right Thing - plan and fund Park accessibility for all Carlsbad residents be best not the worst. o Do the Right Thing- plan/f und a well-documented and much needed Ponto Park that is adequate in size/share to be a Park. A 'fancy sidewalk' is not a Park. o Do the Right Thing - READ, publicly discuss, take ownership in your direction to City staff on the Updated Park and Coastal Recreation (i.e. Public Park) data in the attached "2023 Jul - Coastal Recreation" file.
o Do the Right Thing - READ, publicly discuss, take ownership the Park input from the nationa lly recognized Trust for Public Land in the attached "TPL Support for Ponto Park" file. 1 o Do the Right Thing - fix the unfair distribution of City Parks and fix the clear need for a true Ponto Park as outlined in the attached "CTGMC key issues and suggestions 2022-12-6" file. o Do the Right Thing and work with Carlsbad People for Ponto Citizens. Carlsbad can be great if you let Carlsbad Citizens in and work for them . We have offered to help with dotation's but have been turned away by the City.
• It is well documented in the attached "History of Open Space at Ponto" data file that past Council's falsely "exempted" certain developers from providing the 15% Useable Growth Amendment Open Space required by the Open Space Standard. Ponto {LFMP Zone 9) developers were falsely 'exempted' as City data clearly shows Ponto was not developed in 1986 and did not in 1986 already dedicate 15% of the developable land as GM Open Space. In fact the City removed planned GM Open Space out of Ponto in 1996 land use changes that converted planned GM Open Space into Residential land use. The data in the "History of Open Space at Ponto" shows why Ponto, even with its currently 32 acres of vacant land - that last along Coastal South Carlsbad, is already developed at 40% higher residential density than the rest of the Carlsbad. Ponto has 40% more residential density, NO Park, and is missing due to past false 'exemptions' about 30 acres GM Open Space that Ponto developers should have been required to provide. If this Council perpetuates a false 'exemption' that falsehood and lie to citizens will be your personal lie to both current and future ca'rlsbad families. o Do the Right Thing - READ and publicly and honestly discuss the History of Growth Management Open Space at Ponto, and take ownership in your direction to City staff in the attached "History of Open Space at Ponto" file.
o Do the Right Thing - and don't perpetuate a lie to Carlsbad Citizens about False Growth Management Open Space Exemptions . Be honest in your representation of current and future Citizens o Do the Right Thing - fix the False Open Space Exemptions as out lined in the attached "CTGMC key issues and suggestions 2022-12-6" file .
• Sadly Carlsbad found out in 2017 it will lose about 30 acres of Open Space (the State Campground and City's ONLY Low-cost Visitor Accommodations) in Coastal South Carlsbad due to sea level rise and increased Coastal/bluff erosion . Prior Council's never considered this loss of Open Space in the 2015 General Plan. Yet the City still asking the CA Coastal Commission to adopt the 2015 General Plan even though the Council now knows about how Carlsbad will lose 30 acres of Coastal Open Space in South Carlsbad. The attached "sea level rise & DLUP-LUPA planned loss of OS at Ponto" data file documents the Coastal Open Space loss the Past Council ignored. The current Council should account for and replace this loss of 30 acres of Coastal Open Space due to sea level rise in both the Growth Management plan and Local Coastal Program Updates. o Do the Right Thing - READ and publicly and honestly discuss Sea Level Rise/Coastal Erosion issues never considered in the Growth Management Plan Update, 2015 General Plan Update, and City proposed LCPA based on 2015 General Plan. The Sea Level Rise/Coastal Erosion issues are in the attached "Sea Level Rise & Carlsbad DLCP-LUPA planned loss of OS at Ponto" file . o Do the Right Thing - address this Coastal Open Space loss now with full public disclosure to Citizens, and directing accountab le plans and funded actions in both the proposed Growth Management and Local Coastal Program updates.
o Do the Right Thing - use the data/suggestions in the attached "CTGMC key issues and suggestions 2022- 12-6" file to synergistically support addressing the loss of Coastal Open Space and critica l Coastal Open Space Land Use in Coastal South Carlsbad.
• Sadly the current Council, and Carlsbad Citizens, were not provided all the over $2 million in tax-payer paid Council studies and past Council's actions/inactions over 40-years on the proposed PCH Median Relocation Proposal. Most critically the current Council and Carlsbad Citizens have not been publicly presented the two 2001 Studies by URS & ERA that defined the number/amount of "Surplus Area" created by PCH Median Relocation and the "Financial Feasibility" of PCH Median Relocation. The current Council and Citizens are not being provided all the facts and data on the City's website . It is dishonest not to fully provide Citizens that data. Sadly the past Council's never considered other tax-payer saving solutions to address the well documented need for Ponto Park. Then, as now, there are more tax-payer efficient means to address the 2 •documented need for a Ponto Park and Complete PCH with needed sidewalks, bike lane improvements, and beach parking along PCH as documented in the attached "2 Part General Comparative Cost-Benefit & PCH Constraints Map" data files.
0 0
Do the right thing - direct staff to provide you and Carlsbad Citizens the 2001 Studies by URS and ERA, and the 2013 Study that shows likely environmental constraints in the PCH. • The current Council is now seeing PCH Relocation around Palomar Airport Road is already falling short and not able to 'create' the amount of "Surplus Area" from PCH Median Relocation as mapped out in the 2001 Studies; and the current Council is seeing costs are coming in at a far higher tax-payer cost.
• Other better options to address Ponto Park needs are available and documented in the attached "2 Part General Compa.rative Cost-Benefit & PCH Constraints" data files.

Do the Right Thing - read, disclose and make publicly avail~.ble to Carlsbad Citizens the two 2001 PCH Studies and the attached "2 Part Comparative Cost-Benefits & PCH Constraints" data files. • Carlsbad tax-payers will need to vote on PCH Median Relocation and both YOU and Citiz~ns need to know the facts and fully consider the better options available to address the documented need for a true Ponto Coastal Park and PCH (sidewalk, bikelane improvements, and beach parking).

If the current Council has a once in lifetime opportunity to correct past false exemptions and errors before it is too late. If the current Council fails to represent Carlsbad Citizens and perpetuates past falseho(?ds/errors/unfairness, they will become your personal falsehoods to the current Citizens you are supposed to represent and a false and failed legacy for future Carlsbad Citizens and their children. If the current Council fails to honestly represent and address Citizens' data/desires o,n Growth Management and Quality of Life issues you will ultimately lead the City down a path of lower quality of life (and reduced relative investment and value) as other cities provide more and better distributed Parks.

Failure to honestly provide a much needed and TRUE and significant Ponto Park (the last vacant land and opportunity to provide a true and meaningful Coastal Park) will push demand, inc_rease VMT, traffic and parking congestion into North Carlsbad. Failure to provide a TURE and significant Ponto Park will undermine the South Carlsbad's Coastal Recreation needs (and future economic and social sustainability) of all of current and future Carlsbad residents and visitors.

Ponto has the last remaining vacant and unplanned Coastal land for a 6-mile length of coast that is without Coastal Park. Buying Ponto Park is the far better and magnitude CHEAPER means for tax-payers to provide a significant Coastal Park for this 6-mile length of Coast (and ALL South Carlsbad) that is without a Coastal Park. The current Council should give Citizens the option to vote on the best and most cost effective solution for a much needed Ponto Park.

The current Council needs to responsibly address the data and issues thousands of Carlsbad Citizens have sent you. If the current Council fails to address these issues you will forever negativity impact forever our qual ity of life and eliminate the fast viable, least constrained, and tax-payer effective option (Buying Ponto Park) for our future.

Each of the City Council members individually our your decision. Go down in history as being wise, true and doing the right thing for the future. Don't fail to disclose/address the FACTS. Your time is now. do the Right (and most tax-payer efficient) Thing - buy Ponto Park!
Lance Schulte
3 CTGMC needed actions: 6 key issues and suggestions - from People for Ponto Carlsbad Citizens 8/8/22 1" submittal, 12/12/22 updated :t' submittal
Following are 6 key major Growth Management Standards issues of citywide relevance that the Carlsbad Tomorrow Growth Management Committee (CTGMC) needs to act on, and citizen "Suggestions to CTGMC" on how to honestly and responsibly act on these 6 key issues in the CTGMC's recom·mendations to the New City Council. This Update includes new information (pp 5-6) on the improved affordability of Ponto Park, and on how GM Open Space shortfall can be repaired. We hope the CTGMC will act honestly to make recommendations that truly and responsibly address known documented shortfalls in both Parks and GM Open Space. Responsible recommendations by the CT_GMC can provide a . sustainable Quality of Life to future Carlsbad generations and visitors. Only you own your recommendations.

1. The State of CA is forcing Carlsbad and all cities/counties in CA to provide for unlimited or Infinite Population and Visitor growth. So there will be an l~finite population & visitor demands for Parks, Open Space, water, and demands on our roads/transportation systems, and other Growth Management (GM) Quality of Life facilities. These infinite increases in population and visitor demand will come from high density development that requires more public Parks and Open Space to balance the high-densities. Carlsbad's new GM Standards will have to provide for a system of Infinite proportional increases in the supply of Parklands, Open Spaces, water, transportation facility capacity, etc. or our Quality of Life will diminish. a. Suggestions to CTGMC:
i. Completely restructure the General Plan, Local Coastal Program and GM Program to clearly recognize these facts and State requirements to proportionately prov ide public facilities to maintain/improve Carlsbad GM Quality of Life Standards for this Infinite growth of Population and Visitor .demands.
ii. Being a Coastal city Carlsbad has an added responsibility .to proportionately maintain/improve providing High-Priority Coastal land uses (Coastal Recreation {i.e. Public Parks} and Low-cost Visitor Accommodations) needed at a regional and statewide level to address visitor needs for Coastal Recreation, access, and affordable accommodations. Carlsbad needs to work with the State of CA Coastal Commission to completely restructure Carlsbad's Coastal Land Use Plan to addresses the State's requirement to provide an Infinite amount high-priority Coastal land uses for those Infinite Population and Visitor demands. iii. Trying to ignore these Infinite demands for Carlsbad's Quality of Life facilities - like Parks and Open Spaces is a path to disaster and the ultimate degradation of Carlsbad's Quality of Life.

2. Carlsbad has a huge Jobs v. Housing supply imbalance - far too many jobs around the airport for our amount of housing. This creates negative and costly land use and transportation planning distortions that radiate from the Airport Central Jobs through Carlsbad in all directions. CA Housing law penalizes um balanced cities like Carlsbad by requiring more housing in Carlsbad to bring jobs/housing ratio into balance. Carlsbad can correct this imbalance by 1 of 2 ways: 1) greatly increase housing supply (and thus increase the need and City expense for more GM Quality of Life facilities), or2) more logically and cost effectively greatly decrease the amount of Jobs land use, so Carlsbad's housing supply is in balance with jobs. These jobs will move to surrounding Cities that have more housing than jobs . Rebalancing by reducing jobs land use creates added benefits for Carlsbad and our region by reducing Carlsbad's peak-hour job commute traffic volumes and CTGMC key issues and suggestions - People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 1 of 9 vehicle miles traveled (VMT), and by reducing the costs Carlsbad (and other cities and the region) have to pay to accommodate inter-city commute traffic. If Carlsbad reduces jobs land use will also reduce the amount of housing the State of California and SANDAG requires Carlsbad provide in its Housing Element thus reducing forcing incompatible high-density development into established neighborhoods and pressure to convert useable GM Open Space lands to housing land use. a. Suggestions to CTGMC:
i. Carlsbad can logically and cost effectively balance Jobs/housing supply by updating Growth Management Policy to reduce jobs to be in balance with housing by changing some of Carlsbad's General Plan land use around the airport into several high-density residential mixed-use Villages. The City has started some of this, but can expand this effort but has not planned creating mixed-use village environments . These high-density villages will reduce jobs and provide both high quality and high-density (affordable) housing within walking/biking distance to the major job center and new ne'ighborhood commercial and Park uses in the Villages. ii. Prioritize transportation investments in safe bike paths, walking paths between Carlsbad's Central Jobs Core ar?und the airport and Carlsbad's housing, particularly strongly connecting these new high-density mixed-use villages with the Central Jobs Core.
iii. Update General Plan land use and housing policy to reduce concentrations of higher-density housing except around the airport jobs core. iv. Recognize the central Airport jobs core is 'Carlsbad's New Urban Downtown and "Transect Plan" accordingly toward lower densities on the City periphery.

3. Although some very critical areas (such as the Coastal lands at Ponto) are still vacant and can be wisely used for critical GM Quality of Life needs, much of Carlsbad is largely developed.

Redevelopment of developed land will require creating increased supplies of Parkland, Open Spaces, transportation capacity, and other Quality of Life facilities. a. Suggestions to CTGMC:
i. Completely rethink all City planning on existing vacant lands to assure that remaining vacant land is planned and being used wisely and fairly distributed to address critical Quality of Life needs in those areas, and not squandered on redundant land use. The location of vacant land to address critical Park & Open Space needs should be preserved with land use planning. ii. Work with the State and CA Coastal Commission to preserve our Finite vacant Coastal lands for High-Priority Coastal Land Uses (Coastal Recreation {i.e. Public Parks} and Low-cost Visitor Accommodations and services) for the Infinite population and visitor demands both internal and external to Carlsbad that are/will be placed on them.
iii. Fully and at the very beginning of any Carlsbad General Plan, Local Coastal Program and Growth Management Program actions going forward fully disclose, map and require consideration of the impact of future sea level rise and coastal erosion on Coastal land acres and land uses. Carlsbad has lost and will accelerate loosing acres of Coastal land and High-priority Coastal Land Uses. Carlsbad must know, see, and discuss these losses BEFORE making any land use decisions in Carlsbad's Coastal Zone and any vacant Coastal Land.

4. Carlsbad General Plan & Growth Management Plan do not provide a fair distribution of adequately sized City Parks for all Carlsbad families. Veterans Park is a classic example. What will CTGMC key issues and suggestions - People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 2 of9 be the City's largest park is only about 1-mile away from three other major City Parks (Zone 5, and the future Robinson Ranch and Hub Parks). This is a poor and unfair distribution and a misallocation City Park land resources. Saying Veterans Park is 'the park to serve SW, SE, and NE Carlsbad families' (the overwhelming major/majority funders of veterans Park) when those families are upwards of 6- miles away on major commercia l arter ials that kids can't logically/safely use is false and unfair.

Most all the funding (developer fees) to build Veterans Park come from the SW, SE and NW Carlsbad but those areas are denied the Park the paid for. Veterans Park is inaccessible by almost all its intended users except by driving their cars and then storing their cars in parking lots on Parkland thus making less park land available for actual park use -this makes little common sense and is a great waste of tax-payer funds. This is dysfunct ional along with being very unfair to families in SW, SE and NE Quadrats that are denied park acres near their homes which they funded . Carlsbad's Park Master Plan maps 'Park Service' areas of existing known Park Inequity or Unfairness (dysfunction), _to show where new City Park investme'nts should be made (See City map image with ·notes below). ·
No Coastal Park in South Carlsbad
• Appx. 6 miles of Coast
without a Coastal Park is a
City & Regional need
• South Carlsbad has 64,000
residents & thousands of
hotel visitors without a
Coastal park
• Closest park to Ponto is
Poinsettia Park, approx. 2.5
miles across 1-5
• Proposed Veterans Park is
approx. 6 miles away
~ ?l-.'-'11IIC-.utl,.._,._
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...,.___,,.. ... ,,.,,,.c..u,;-'"
The Trust for Public Land provides a Park-Score to compare both a City's amount of park acres and the 'fairness' of access (within a 10-minute walk) to parks. Carlsbad is below national averages in both park acres and fair access to parks. Carlsbad is also well below what our adjacent Coastal cities of Encinitas and Oceanside provide. Carlsbad only requires 3 acres of Park land per 1,000 population, while Encinitas and Oceans require 5 acres - 67% more than Carlsbad - of parkland.

Also, Encinitas and Oceanside require parks to be within a 10-mintue walk to their citizens and families. Carlsbad has no such requirement.
a. Suggestions to CTGMC:

CTGMC key issues and suggestions - People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 3 of 9 Carlsbad should change its General Plan, Parks and Growth Management Standards and CMC 20.44 to:
i. Be Above Average Nationally in both providing park acreage and in locating adequate park acreage to be within a 10-minute walk to all neighborhoods. ii. Raise its minimum park acreage standard to 5 acers per 1,000 population, versus the current low 3 acres per 1,000. Carlsbad should be at least as good as Encinitas and Oceanside in requiring 5 acres, not 40% below what our adjacent Cities require/provide.
iii. Raise its park location standard to require an_ adequately sized park be provided to serve the neighborhood population within a 10-minute walk for all neighborhoods.
iv. Prioritize City Policy and Park Budgets and investments to achieve park fairness in 'Park Unserved areas' identified by Carlsbad's Park Master Plan. v. Per Carlsbad's Municipal Code Chapter 20.44- DEDICATION OF LAND FOR RECREATIONAL FACILITIES to require developers in 'Park Unserved areas' and in areas that do not have an adequately sized (S acres per 1,000 population) park within a 10-minute walk to provide their developments required Park land acre dedication in actual Park land within a 10-minute walk to their developme~t. vi. Update the City's Park-in-lieu fee to assure the fee is adequate to actually buy the amount of park land a developer is to provide within a 10-miunte walk of their development. The City's current 'Park-in-lieu-fee' is far too low and inadequate to actually buy land in area surrounding the proposed development. vii. Only allow developers to pay a Park-in-lieu-fee where there is an adequately sized park (provide 5 acres per 1,000 population) within a 10-minute walk of their development, and growth management planned future development in that area will not require more park land to provide 5 acres per 1,000 population) within a 10-minute walk.
viii. Consider updating Park policy to provide more multi-use flexibility in park land acres and development on Parks. Many Carlsbad Park acres are developed/dedicated to a single-purpose use, and unavailable for other park uses. ix. Consider eliminating car parking lots from land that can be counted as parkland; or by significantly limiting park land used for parking to around 5%. x. Eliminate the counting of 'GM Constrained and Unusable land' and Protected Endangered Species Habitat land as Park land. GM Constrained/Unusable lands are undevelopable. Protected Habitat lands are by definition not useable for development by people. Habitat is dedicated for plants and animals. Parks are open spaces dedicated intended for people. Parkland calculations should exclude Unusable lands and Protected Habitat lands and only count 100% people Useable land as Park land. Where Park land abuts Habitat land a sufficient buffer space shall be provided to prevent people mixing with animals (ex. Rattlesnakes, etc.) and animals from people (habitat disturbance or destruction). This buffer area should not be counted as Park or Habitat acres, but as natural/developed buffer open space acres, and can be counted as part of the City's 15% Growth Management 'Aesthetic open Space'.

5. Carlsbad's Coast is the most, if not the most, important feature of Carlsbad; and is consistently identified by citizens and businesses and our Community Vision. Carlsbad's Coastal Parks (west of the 1-5 corridor) are grossly unfairly distributed. Carlsbad's Coastal Parks do not fairly match the CTGMC key issues and suggestions - People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 4 of9 locational needs of the population. North Carlsbad that is 38% of Carlsbad's population and has 10 Coastal Parks totaling 37+ acres in size. South Carlsbad that is 62% of Carlsbad's population has 0 [ZERO) Coastal Parks totaling O [ZERO) acres. Again, Carlsbad's Park Master Plan maps this citywide unfairness (dots show park locations and circles show the area served by each park) and says that the City should look at buying and building New Parks in these areas that are unserved by City Parks (are not covered by a circle). The GM Update should correct this citywide unfair distribution of City Parks by making plans for new Park purchases to create City Parks in these unserved areas of Park Inequity.

To address citywide Coastal Park unfairness the current City Council wants to spend $60-85 million in Carlsbad tax-payer funds to Relocate 2.3 miles of constrained Pacific Coast Highway median to try to make some of the narrow PCH median 'useable' by people. 2001 and 2013 City PCH Relocation studies identified only a small amount of 'people-useable acres' would be created next to PCH. The $60-85 million tax-payer cost ($26-37 million per mile) does NOT add one single square foot of new City land, it only inefficiently rearranges a small amouot PCH median . The City can most tax-payer cost effectively provide needed sidewalks and bike improvements along the outside edges of PCH without PCH Relocation. The City's 2001 PCH Relocation Financial Study and 2013 PCH Relocation Design both indicated minimal useable land could be achieved by Relocation, and that the very high tax-payer cost to do so would be very difficult to fund. The City has known for well over 20-years that PCH Relocation is a high-cost and a poor solution to address the Citywide Coastal. Park unfairness in South Carlsbad.

However, a better and far less costly solution to correct Citywide Coastal Park unfairness and provide a much needed South Carlsbad Coastal Park is to simply buy currently vacant land that is for sale. The City did this (although the City actually bought existing homes) when it expanded Pine Park. Carlsbad tax-payers have used the City's own data to compare the tax-payer Cost/Benefits of simply purchasing vacant land v. trying to rearrange existing City owned land at PCH. Simply buying vacant land saves tax-payers saves tax-payers over $32.7 to $7.7 million. Please read the following data files:
• 2022-June General Comparative tax-payer Costs/Benefits of Completing PCH, 2.3 miles of PCH Modification (Island Way to La Costa Ave.), and 14.3 acre Ponto Park (Kam Sang) to address planned loss of 30+ acres of Coastal Open Space Land Use at Ponto in South Carlsbad: Part 1 of 2.
• City's PCH Modification Proposal Area Map with notes on usability Constraints and Issues:

P4P Input: Part 2 of 2
• The most recent (9/19/22) land sale of 11.1 acre Ponto Planning Area F was less than $8 million (less than $706,000 per acre).
• Buying and developing t his 11.1 acre Ponto Park would cost less than $20 million assuming a 10% profit to the new land-owner, and $1 million per acre park construction cost like our newest Buena Vista Reservoir Park. The cost to help correct a Citywidt;! Coastal Park unfairness by simply buying & building a much needed 11.1 acre Ponto Coastal Park would cost tax-payers less than the recently approved Measure J City Monroe Street Pool Renovation. Investing less than $20 million ($1.8 million per acre) to buy and build an

11.1 acre Ponto Coastal Park is a great tax-payer value v. $65-80 million in tax-payer funds to rearrange 15.8 acres of narrow strips of constrained PCH median (City documented "Surplus Land Area #4 &5") for some minimal people use at a tax-payer cost of $4-5 million per acre. The overall and per acre costs of buying/building Ponto Park are over 2 to 3 times better value for tax-payers than PCH Relocation/rearrangement.

CTGMC key issues and suggestions - People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 5 of9 • The City Council could/can buy land for Open Space (Parks are the most useable of the City's 4 Open Space categories) under voter approved Prop C Open Space land acquisition authority. The City has been advised to buy Ponto Park under Prop C per the City's settlement of a Growth Management law suit.

The Park and Coastal Park Inequity at Ponto and Coastal South Carlsbad is clearly a citywide issue.

Park and Coastal Park Inequity at Ponto and Coastal South Carlsbad as it is unfair to the vast majority of Carlsbad citizens and their families as 62% of Carlsbad is in South Carlsbad. Park and Coastal Park'lnequity at Ponto and Coastal South Carlsbad is unfair to our major Visitor serving industries (and tax generators) in South Carlsbad. Park and Coastal Park Inequity at Ponto and Coastal South Carlsbad are clearly inconsistent with the CA Coastal Act, Carlsbad's Community Vision, and common sense. The Coastal South Carlsbad Park Inequity is also unfair to North Carlsbad because South Carlsbad's Coastal Park demand is being forced into Coastal North Carlsbad and congesting those parks, and adding to Coastal North Carlsbad traffic and parking impacts. It also increases greenhouse gases and VMT as it forces longer vehicle trips. a. Suggestions to CTGMC:
i. 11.1 acre Ponto Planning Area F has a specific Local Coastal Program Land Use Policy that says The City of Carlsbad must for the Ponto Area LCP 'Consider and Document the need for Coastal Recreation (i.e. Public Park) and or Low-Cost Visitor Accommodations west of the railroad tracks (at Ponto) prior to any Land Use change. The discussion of Parks _b_y the CTGMC is such a situation that requires the CTGMC to consider this adopted LCP Land Use Policies. Official public records requests have shown the City never followed this LCP Land Use Policy Requirement during the 2005 Ponto Vision Plan and 2015 General Plan Update, and in 2010 the CA Coastal Commission rejected the Ponto Vision Plan and told the City in 2017 that that land uses at Ponto could change based on the need for Coastal Recreation and/or Low Cost Visitor Accommodations. The Mello II LCP that covers most of Carlsbad's Coastal Zone also has Land Use Policy 6.2 for the City to consider a major park in the Batiquitos (Ponto/South Carlsbad) area. The City has only implemented 1/6 to 1/3 of this policy. The CTGMC should fully evaluate the citywide/South Carlsbad and local Ponto need for Coastal Parks as required by the City's adopted LCPs and CA Coastal Act.
ii. Carlsbad's 2015 General Plan Update and Growth Management Plan (GMP) did not, and was not updated to, consider the 2017 Sea Level Rise (SLR) Impact report showing the loss/impact on 32+ acres of Carlsbad's Coastal Land Use acreage in South Carlsbad - primarily Open Space Land Use (beach and Campground). Both the General Plan (and Local Coastal Program Land Use Plan) and GMP should be updated to account for the loss and replacement of these 32+ acres of high priority Coastal Open Space Land Use due to SLR. The updates and the CTGMC should use the newest CA Coastal Commission SLR Guidelines/science, not the old guidelines used in 2017. Carlsbad's LCP and CA Coastal Act Land Use Polies call for 'upland relocation' to replace the SLR loss of high-priority Coastal Land Uses. iii. The availability over the past several years of the last two sufficiently sized vacant lands suitable for a Ponto/South Carlsbad Coastal Park is a citywide issue. If these last two vacant lands are lost to development forever future generations will have lost the last opportunity for the needed South Carlsbad Coastal Park. The 5/3/22 Citizen requests for the City to jointly study acquisition of one or both these last vacant lands for a needed (and only possible) true and meaningful Coastal Park for CTGMC key issues and suggestions - People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 6 of9 South Carlsbad should be recommended by the CTGMC. The CTGMC should recommend Carlsbad's GMP be updated to incorporate Parkland acquisition of these last opportunities to provide the needed Coastal Park for South Carlsbad.

6. Carlsbad Growth Management Open Space Standard is that 15% of all the Useable (unconstrained and fully buildable) areas is to be preserved as Useable Open Space, and that all the 25 Local Facility Management Plans (LFMP) show how that 15% is provided . The City says:

OPEN SPACE
A. Performance Standard
Fifteen percent of the total land area in the Local Facility Management Zone (LFMZ) exclusive of environmentally constrained non-developable land must be set aside for permanent open space and must be available concurrent with development.

Yet the City has mapped and documented that this 15% Useable Open Space Performance Standard was not complied with. The City also acknowledges that without changes to current City planning the 15% Useable Open Space Performance Standard will ~ever be complied w ith. The City acknow ledges that only 13% has/wi ll under current plans ever be provided. This missing 2% equals 501 acers of lost GM Open Space the GMP promised citi zens. Carlsbad law the Growth Management Ordinance 21.90, and section '21.90.130 Implementation of facilities and improvements requirements'; provide guidance on how non-compl iance with a Performance Standards is to be handled.
a. Suggestions to CTGMC:
i. Retain the GM Open Space Standard of 15% of all unco nstrain ed and developable land is maintained as Open Space. If the City removes the Open Space Standard, it will allow and encourage land use changes to remove GM Open Space and replace with development.
ii. The CTGMC should make a recommendation that an inventory of all 25 LFMP Zones be conducted and an inventory of each LFMP Zones provision of at least 15% Useable Open Space shall be compiled. No LFMP Zone shall be allowed to be "exempt" from this inventory. The City1s computerized GIS mapping system makes it easy and clear as shown in the following City GIS map for LFMP Zone 9 (aka Ponto).

CTGMC key issues and suggestions - People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 7 of9 City GIS map of Ponto's (LFMP Zone 9)
.. Open Space:
• Light green areas meet the City's 15%
unconstrained Growth Management
\
Program Open Space Standard
• • Most Ponto Open Space (pink hatch &
blue [water] on map) is "Constrained"
and does not meet the Standard
• Aviara - Zone 19, Ponto - Zone 9 and
Hanover/Poinsettia Shores - Zone 22
all developed around the same time
and had similar vacant lands.
• City required Aviara - Zone 19 east of
Ponto to provide the 15% Standard
Open Space. Why not Ponto? Aviara
includes the same lagoon.
• City required Hanover & Poinsettia
Shores area Zone 22 just north of
Ponto to provide the 15% Standard
Open Space. Why not Ponto?
• Why Ponto developers were not
required to comply with t he 15%
Useable Open Space Standard is
subject to current litigation
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rl• - 01.....,- 1 l lfl.129Beu--,
I<
A ;--s ,.o,.,,.._ I 7 . .000 • Below is City GIS data from this map - ,_ L •......,_,.,,_ 0 1 0 o,
-=-c::a.-===-- -0 *200J00-400
City GIS map data summary of the Growth Management Standard of 15% Useable Open Space at Ponto 472 Acres
(197 Acres)
275 Acres
X 15%
41 Acres
(11 Acres)
30Acres
Total land in LFMP Zone 9 [Ponto]
Constrained land excluded from Growth Management (GMP) Open Space Unconst rained land in LFMP Zone 9 [Ponto]
GMP Minimum Unconstrained Open Space requirement
GMP Minimum Unconstrained Open Space required
GMP Open Space provided & mapped per City GIS data
Missing Unconstrained Open Space needed in LFMP Zone 9 [Ponto] to meet the City's minimum GMP Open Space Standard per City's GIS map & data 73% of the City's minimum 15% required Open Space Standard is missing due to over development of LFMP Zone 9 [Ponto]
CTGMC key issues and suggestions - People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page8of9 iii. In instances like LFMP Zone 9 (above image) that clearly did not provide at least 15% Useable Open Space and/or were falsely "exempted" the CTGMC should . recommend that a Local Facilities Zone Useable Open Space Correction Plan shall be developed that explores the GM Open Space use/reuse of City land, land use planning requirements, and/or possible acquisitior:is of remaining vacant land acres to make up for any shortfall in meeting the 15% Useable Open Space in that a Zone.

An example of this in LFMP Zone 9 is that the City's regional Rail Trail will convert 2- lanes of almost all of Avenida Encinas to wider buffered bike lanes and an adequate portion of the converted 2 vehicle lanes can be landscaped (v. just painting strips as a buffer) to provide a safer/better bike lane buffer within a GM compliant Open Space. 2 vehicle lanes in Windrose Circle could also be similarly landscaped and converted to GM complaint Open Space. This is just one example of a cost-effective means to add GM Open Space that developers were falsely allowed to remove. iv. A Local Facilities Zone Useable Open Space Correction Plan should involve a Citizens Advisory Committee composed of citizens within the impacted Zone and appointed by the Council Members representing the Zone, and a representative of each vacant land owner over of over 1-acre in size.
v. Consistent with the Growth Management Ordinance land use changes and development applications within a Local Facilities Zone Useable Open Space Correction Plan Zone shall be deferred until the applications can considered with (or after adoption of) a Local Facilities Zone Useable Open Space Correction Plan.

CTGMC key issues and suggestions - People for Ponto Carlsbad Citizens submitted on 8/8/22 & 12/8/22 Page 9 of 9 Carlsbad Draft Local Coastal Program Amendment - Coastal Recreation Land Use People for Ponto Updated Public Comments as of 7/14/2023 On 7 /14/23 the following data was sent to the City of Carlsbad & CA Coastal Commission. The City is the worse Coastal City for over 250 miles of coastline from the City of Santa Barbara to the Mexican border in providing Parkland access to its citizens. Requiring Fenton the Ponto developer to provide their Required Parkland as land at Ponto will be a small but very important step in the right direction to start digging Carlsbad out of being dead last in providing park access. In 2023 Carlsbad refused to even ask the Ponto developer to provide their required Parkland Dedication as actual Parkland at Ponto. The Trust for Public Land has mapped and documented this fact. The Trust for Public Land has also sent a letter to the City and City Council highlighting the need for a City Park at Ponto. Following is the Trust for Public Land data showing that Carlsbad is the worst City in providing Park access to its citizens. Ponto is one of worst areas in Carlsbad for City Park access per the City's Park Master Plan. The Trust for Public Land documents a city's 10-minute walk to Park at https://www.tpl.org/parkserve. The Average USA City provides Parks within 10-minute walk to 55% of residents [10% above Carlsbad]. Carlsbad provides Parks within 10-minute walk to 49.9% of residents [10% below National Average).

Carlsbad is the worst of 29 Southern CA Coastal cities (from Santa Barbara south to the Mexican Border on over 250 miles of coastline) in providing Parks within 10-minute walk to residents:

1. Palos Verdes Estates provides Parks within 10-minute walk to 100% of residents

2. El Segundo provides Parks within 10-minute walk to 100% of residents

3. Hermosa Beach provides Parks within 10-minute walk to 100% of residents

4. Redondo Beach provides Parks within 10-minute walk to 98% of residents

5. Manhattan Beach provides Parks within 10-min_ute walk to 95% of residents

6. Del Mar provides Parks within 10-minute walk to 93% of residents

7. Dana Point provides Parks within 10-minute walk to 89% of residents

8. Carpinteria provides Parks within 10-minute walk to 87% of residents

9. Huntington Beach provides Parks within 10-minute walk to 85% of residents

10. Long Beach provides Parks within 10-minute walk to 84% of residents

11. Laguna Beach provides Parks within 10-minute walk to 82% of residents

12. Santa Monica provides Parks within 10-minute walk to 82% of residents

13. Oxnard provides Parks within 10-minute walk to 82% of residents

14. San Diego provides Parks within 10-minute walk to 81% of residents

15. Santa Barbara provides Parks within 10-minute walk to 78% of residents

16. Coronado provides Parks within 10-minute walk to 76% of residents

17. Newport Beach provides Parks within 10-minute walk to 76% of residents

18. Imperial Beach provides Parks within 10-minute walk to 74% of residents

19. Port Hueneme provides Parks within 10-minute walk to 73% of residents

20. Ventura provides Parks within 10-minute walk to 69% of residents

21. Encinitas provides Parks within 10-minute walk to 68% of residents

22. Los Angeles provides Parks within 10-minute walk to 63% of residents

23. Solana Beach provides Parks within 10-minute walk to 63% of residents

24. Oceanside provides Parks within 10-minute walk to 58% of residents

25. Seal Beach provides Parks within 10-minute walk to 57% of residents

26. Malibu provides Parks within 10-minute walk to 53% of residents

27. San Clemente provides Parks within 10-minute walk to 52% of residents

28. Rancho Palos Verdes provides Parks within 10-minute walk to 50% of residents

29. Carlsbad provides Parks within 10-minute walk to 49.9% of residents [Carlsbad is lowest & most unfair]

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Carlsbad is the lowest & most unfair to citizens of the 29 Southern California Coastal cities along over 250 miles of CA Coastline from Santa Barbara to the Mexican border. The population in these 29 cities is in the millions, and Carlsbad is the worst in providing (and planning to provide) Park access. Additional facts in this document, further documents the situation, and need for Ponto Park.

Source of data: Trust for Public land parkscores
Trust for Public Land's 10-minute walk to Park Maps/data:

Carlsbad= https://parkserve.tpl.org/mapping/index.html?CitylD=0611194#reportTop Encinitas= https://parkserve.tpl.org/mapping/index.html?CityID=0622678 Irvine = https://parkserve.tpl.org/mapping/index.html?CityID=0636770 As fully documented in the "History of Open Space at Ponto" data file sent to both the City & CCC. The initial 1986 LCP for Ponto included a 12.8 acre Recreation Commercial land use (along with other additional Recreation and Open Space uses) that were never built. The 12.8 Recreation Commercial land use was eliminated by the City & CCC and converted to Residential land use in a 1994 LCP amendment with a land use regulation Policy placed on a 11.1 acre Planning Area F site to address the Coastal Recreation and Low-cost Visitor Accommodation needs for the State and LCP area. That existing Planning Area F LCP Policy a critical subject of the Carlsbad's proposed 2019 LCP Amendment Updated Pubic Comments Coastal Recreation submitted on Oct 12th 2021:

On 10/8/21 the Carlsbad City Council and CA Coastal Commission were emailed data from an Official Carlsbad Public Records Request(# R002393-092121) on the City of Carlsbad's past compliance/noncompliance with the currently exiting Mello II LCP Land Use Policies# 6-2, 6-4 & 6-10 Certified in the mid-1980s. The City's documents show:
• For Policy 6-2 the 200-300 acre Park called out in Policy 6-2 has been reduced to Veterans Park's 91.5 acres, of which only 54% or 49.5 acres is even useable as a Park. The City provided no documents on how a 200- 300 acre park called for in Policy 6-4 is now only 49.5 useable acres. • For Policy 6-4 there were no City documents were provided. There was no City Public discussion, consideration, or City compliance with Policy 6-4 since the mid-1980's. • For Policy 6-10 concerns providing Low Cost Visitor Accommodations. Public Parks are the lowest cost (free) Visitor accommodating land use there is.

The 3 existing LCP Land Use Policies are important for Carlsbad, and California's, Coastal land use resources. There appears little to no discussion of the City's past apparent failure to implementation of these 3 LCP LUPs in the current · City consideration of changes to the LCP.
-Following is a copy of Public Records Request# R002393-092121: "Carlsbad's Local Coastal Program (LCP) for the Mello II Segment of Carlsbad's Coastal Zone has long established land use Policies 6-2, 6-4 & 6-10 that were adopted by Carlsbad and Certified by the CA Coastal Commission in the early/mid-1980's. Mello II LCP Policies 6-2, 6-4 & 6-10 are shown on page 86-87 of Carlsbad's 2016 compiled LCP and are:
• "POLICY 6-2 REGIONAL PARK: If the population of Carlsbad increases in accordance with SANDAG's projected Series V Population Forecasts, it is estimated that Carlsbad will need to develop a new regional park containing 200 to 300 acres in order to adequately serve the public . A location for a new regional park must,

Page 2 ends

therefore, be established. Consfderation should be given to a facility within the Aqua Hedionda Specific Plan Area, or adjacent lands. The Batiquitos Lagoon area should also be considered. • POLICY 6-4 NEED FOR ADDITIONAL OVERNIGHT CAMPING: Additional overnight camping facilities, the main source of lower cost visitor and recreat ional facilities, are needed throughout the San Diego coastal region.

Additional facilities of this kind should be provided in a regional park within the Carlsbad area. This can be accomplished in conjunction with an eventual Batiquitos Park, within the Aqua Hedionda Specific Plan Area, and/or along with the development of private recreational facilit ies. • POLICY 6-10 LOWER COST VISITOR-SERVING RECREATIONAL USES: Lower cost visitor and recreational facilities shall be protected, encouraged, and, where feasible, provided. Encourage a range of affordability for overnight visitor accommodations. Evaluate the affordability of any new or redeveloped overnight visitor accommodations, including amenities that reduce the cost of stay. Mitigation may be applied to protect and encourage affordable overnight accommodations"
The public record request is to see documents of:
• City Staff reports, presentations and communications to the Carlsbad Planning and Parks Commissions, and City Council regarding the City's consideration and implementation of these 3 specific (6-2, 6-4, and 6-10) Mello II LCP land use policies; and
• Carlsbad Planning and Parks Commissions, and City Council minutes, resolut ions and ordinances documenting City of Carlsbad consideration and implementation of these 3 specific (6-2, 6-4, and 6-10) Mello II LCP land use policies."
Updated Pubic Comments on Coastal Recreation subm itted on January 2021:

Over 11-months ago in a 1/29/20 1:56PM email People for Ponto Carlsbad citizens first provided the City of Carlsbad both data and comments on 14 critical Coastal Recreation issues (see pages 5-30 below). The data and the 14 critical issues do not seem to be receiving appropriate disclosure/presentation/discussion/consideration in the Dec 2, 2020 Staff Report to the Planning Commission. To assure the 26-pages of citizen data and requests in the 1/29/20 email was received by the Planning Commission the file was re-emailed on 12/22/20 12:24pm and specifically· addressed to City Council, City Clerk, Planning Commission, Parks Commission, Housing Commission, HEAC, CA Coastal Commission, and CA HCD. As citizens we request each of these 14 data points (with supporting data) be honestly considered.

In reading the Dec 2 Staff Report citizens conducted additional analysis of City Park data. That research further reinforces and documents the 14 Critical Coastal Recreation issues and highlights the relatively poor amount of City Park and Coastal Recreation planned by Carlsbad's Staff proposed Draft LCP-LUPA. We hope the City Council and City Commissions, and CA Coastal Commission & HCD will consider this additional analysis of City data and citizen input:

Coastal Zone data
Coastline miles
Coastal Zone Acres
Coastal Zone Acres
City Park Standard data
Carlsbad

6.4 9,219
100%
City Park Standard 3
Oceanside

3.9 1,460
16%
5 Encinitas

6.0 7,845
85%
5 note or source
Carlsbad Draft LCPA 201, Google Maps
& Oceanside & Encinitas LCPs
% relative to Carlsbad
required park acres/ 1,000 population

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Park Standard% 100% 167% 167% % is relative to Carlsbad • Oceanside & Encinitas 'require' and plan for 67% MORE Parkland than Carlsbad • Carlsbad 'requires' and plans for ONLY 60% as much Parkland as Oceanside & Encinitas • Carlsbad only requires developers provide 60% of the parkland (or in-lieu fees) as Oceanside & Encinitas require • Encinitas has a 'Goal' to provide 15 acres of Park land per 1,000 population Developed City Park 2.47 3.65 5.5 acres/ 1,000 population Developed Park 100% 148% 223% % is relative to Carlsbad • Oceanside provides 48% MORE developed park land than Carlsbad • Encinitas provide 123% MORE developed park land than Carlsbad • Carlsbad ONLY provides 68% and 45% as much Parks as Oc~anside & Encinitas respect ively National Recreation & Park Asso. Metric: a typical City provides 1 park/ 2,281 pop. & 9.9 Park acres/ 1,000 population • Carlsbad (3 acre) Park Standard is ONLY 30% of what a typical City provides nationally • Carlsbad requires developers to provide, 70% LESS Parl< acres than typical City provides nationally National Recreation & Park Asso., Trust for Public Land, et. al.: 10 minute (1/2 mile) Walk to a Park Planning Goal • Both Oceanside and Encinitas plan parks to be within a 10-minute (1/2 mile) walk to homes. • Carlsbad DOES NOT plan Parks with in walking distance to homes • Carlsbad is NOT providing equitab le and walking/b iking access to Parks Some Carlsbad Parks that are not fully useable as Parks:

Existing Parks with
total
park
Unusable Open Space acreage acres
Alga Norte - SE quadrant 32.1
Hidden Hills - NE quadrant
La Costa Canyon SE quadrant
Leo Carrillo - SE quadrant
Poinsettia - SW quadrant
Existing Park subtotal
Anticipated Future Park
development projects
Park - quadrant
Veterans - NW
Cannon Lake - NW
Zone 5 Park expansion - NW
Robertson Ranch - NE
Future park subtotal

22.0 14.7

27.4 41.2
137.4

91.5 6.8

9.3 11.2
118.8
Unusable
park
acres

10.7 12.7

8.9 16.5

11.1 59.9

49.S

3.4 0
Q

52.9 Unusable Open Space acres
in Existing & Future Parks 256.2 112.8
% of park
unusable
33%
58%
61%
60%
27%
44%
54%
50%
0 Q
45%
44%
reason unusable
1/3 of park is a Parking lot not a park
In many other Carlsbad Parks a significant
percentage of those Parks are consumed by
paved parking lots and unusable as a Park.
city identified unusable habitat open space
city identified unusable habitat open space
city identified unusable habitat open space
city identified unusable habitat open space
44% of these Parks are unusable as Parkland
estimated unusable habitat open space
estimated unusable water open space
appears 100% useable as a Park
appears 100% useable as a Park
45% of Future Parks are unusable as Parks
112.8 acres or 44% is unusable as Parks
• 112.8 acres or 44% of the Existing & Future Parks are unusable Open Space and can't be used as Parkland • Based on City's minimum 3-acres/1,000 population Park Standard, 112.8 acres of Unusable Parkland means 37,600 Carlsbad Citizens (or 32.5% of Carlsbad's current population of 112,877) will be denied the minimum amount of Parkland that they can actually use as a Park.

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• 59.9 acres of Existing unusable 'park'/ 3 acre park standard x 1,000 population = 19,967 Carlsbad citizens and their children are currently being denied useable park land. 19,967 is 17.7% of Carlsbad's current population. • In addition to these 19,967 existing citizens and their childr en denied park land, the City needs to develop additi onal Park acreage in the NE, SW and SE quadrants t o cover curren t shortfalls in meeting in the minimal 3 acre/1,000 population park standard for th e current populations in the NE, SW and SE quadrants. • The current NE, SW and SE quadrants park acreage shortfalls are in addition to the 19,967 Carlsbad citizens and their children that do not have the minimum 3 acres of parkland per 1,000 population • Current FY 2018-19 MINIMUM park acreage shortfalls are listed in the table below. They are:
o 4.3 acres for 1,433 people in NE quadrant,
o 6.8 acres for 2,266 people in SW quadrant, and
o 2.3 acres for 767 people in SE quadrant
NW quadrant
NE quadrant
SW quadrant
SE quadrant
Shortfall (excess) in
Current Quadrant
Min. Park standard by
population
acres need
(-14.2) (-4,733)

4.3 1,433

6.8 2,266

2.3 767
Future Park
acres %
107.6 91%

11.2 9%
0 0%
0 0%
existing Park shortfalls are fo r NE, SW & SE quadrants Current NW parks are 14.2 acres over min. standard &
capacity for 4,733 more people at min. park standard .
91% of all Future City Parks are in NW quadrant
Future Park will exceed minimum NE park standard
No min. parks for 2,266 people in SW quad. Park deficit No min. parks for 767 SE quadrant Park deficit
A Park Standard minimum is just a "Minimum". City policy allows the City to buy/create parks above the City's current 3 acre/1,000 pop. MINIMUM (and lowest) Park Standard of surrounding Coastal cities. Carlsbad already did this in the NW quadrant. It then added 3.1 more NW quadrant Pa rk acres as part of the Poinsettia 61 Agreement . Poinsettia 61:
• converted 3.1 acres of NW City land planned/zoned for Residential use to Open Space Park land use/zoning, • facilitated a developer building condos (increasing park demand) in the SW quadrant, • required the SW Quadrant developer pay $3 million to build the 3.1 acre NW quadrant park, and • required the SW Quadrant developer pay to convert 3.1 acres of NW Quadrant & 5.7 acres of SW Quadrant City Park land to habitat that will be unusable as a City Park.

So Poinsettia 61 increased SW Quadrant development (that both increased SW Park Demand and expanded the current SW Quadrant Park deceit) while simultaneously using SW Quadrant development to pay for the conversion of 3.1 acres of residential land in the NW Quadrant to City Park (the NW Quadrant already has surplus park land per the City's minimum standard).

People for Ponto strongly supports creating City Parks above the City's current low 3-acre per 1,000 population minimum, as the City's minimum standard is relatively low and substanda rd relative to other cities; many Carlsbad parks have significant acreage that is in fact 'unusable' as a park. Most importantly People for Ponto Citizens think it is very important to prioritize providing City Parks in areas of Park Inequity that are unserved by City Parks. However it seems very unfair to the SW Quadrant citizens to be so unserved and starved of the bare minimum of City Parks while at th e same time funding City Parks in excess of City standa rd in ot her Quadrants.

The Poinsettia 61 illustrates a larger unfair (and dysfunctional) distribution of Quadrant based City Park demand and supply that is keenly evident in the demands/supply funding and location disparity of Veterans Park. Most all the

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development impact and park demand that paid Veterans Park fees came from the SW, SE and NE Quadrants yet the Veterans Park (supply) is not in those SW, SE and NE Quadrants. This inequity is counter to t he implicit City requirement that City Parks be provided within the Quadrant of their Park demand. It is logical and proper that City Parks be provided and equitably distributed to be close to the development and population that generated the Park demand.

The City Park inequity at Ponto and in other Coastal areas of the City is counter to several CA Coastal Act policies; counter to good city planning and good CA.Coastal planning. Park Inequity is highly detrimental to the City, and City and CA citizens in the long-term; fails to properly distribute and match the location supply with the location of demand for Parks; and is counter to basic fundamental issues of fairness. Since 2017 People for Ponto has tried to get the City Council and Staff to address this inequity, specifically at Ponto, and to do so in a way that embraces a t rue and honest Citizensbased planning process.

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Carlsbad Staff proposed Draft Local Coastal Program Amendment - People for Ponto comments submitted 1/29/2020 Coastal Recreation:

2. Request that the City as part of its Draft LCP Public Review process broadly-publicly disclose to all Carlsbad Citizens the City's acknowledged prior LCPA processing and planning "mistakes" regarding the requirement that the Ponto area be considered as a public park: This disclosure is needed to correct about 20 years of City misrepresentation to the public on the since 1996 and currently Existing LCP requirements at Ponto, and the City's prior planning mistakes at Ponto. Citizens have been falsely told by the City that all the Coastal planning at Ponto was done already and that the City followed its Existing LCP regarding the need for a park at Ponto, and that this is already decided and could not be reversed. This misinformation has fundamentally stifled public review and public participation regarding the Coastal Zone. City failure to provide such a broad-public disclosure on the documented prior, and apparently current proposed, "planning mistakes" would appear to violate the principles of Ca Coastal Act Section 30006 . A broad-public disclqsure would for the first time allow citizens to be accurately informed on the Existing LCP requirements at Ponto so they can provide informed public review and comment regarding the need for a Coastal Park in in this last vacant 'unplanned' area. The requested broad-public disclosure by the City of the City past mistakes and the Existing LCP requirements at Ponto is consistent with CA Coastal Act (CCA) "Section 30006 Legislative findings and declarations; public participation - The Legislature further finds and declares that the public has a right to fully participate in decisions affecting coastal planning, conservation and developmen t; that achievement of sound coastal conservation and development is dependent upon public understanding and support; and that the continuing planning and implementation of programs for_coastal conservation and development should include the widest opportunity for public participation." The public cannot partic ipate as outlined in CCA Section 30006 if past City 'mistakes'_ and misrepresentations on Coastal planning at Ponto go undisclosed to the public. If the public isn't fully informed about the 20-years of LCP planning mistakes at Ponto how could the public in the past (and now in the present) participate in the proposed LCP Amendment - Public Participation as noted in Section 30006 above is the means to sound coastal conservation and development and is " ... dependent upon public understanding ... ". The City's past mistakes at Ponto need to be correct~d by slightly different a Draft LCP Amendment process than currently outlined by the City; a new process is needed that clearly, opening and honestly informs and engages the public on the Existing LCP Ponto issues. The City's current Draft LCP Amendment process fails to follow CCA Section 30006 in that most all the citizens we encounter are as yet unaware of the City's Ponto mistakes and how they can participate in in the DLCPA process without that information. We see this daily in conversations we have with our fellow citizens. We even saw at the Oct 20, 2019 Carlsbad Planning Commission meeting that the Planning Commission was unaware of the planning mistakes at Ponto. How can a decision body of the City make a decision without knowing about these prior 'planning mistakes' facts that surround what they are being asked to decide on? Repeatedly since 2017 Carlsbad citizens and People for Ponto have asked the City to fully acknowledge the City's prior flawed planning at Ponto, and to correct that with ether maintaining the Existing LCP Non-residential Reserve Land Use or restarting the Coastal Planning at Ponto with a true and accurately informed Community-based Coastal Planning process consistent with Section 30006.

We request the City during the DLCPA Public Review period broadly and publicly disclose to all Carlsbad Citizens the City's acknowledged prior LCP and other "planning efforts" public participation processing and planning "mistakes" regarding the requirement that the Ponto area be considered as a public park, and 1) provide a truly honest public participation process on that disclosure consistent with CCA Section 30006 as _part of the Draft LCP Amendment process or 2) retain the Existing LCP Non-residential Reserve Land Use and require a comprehensive and honest community-based redo of Coastal Resource planning at Ponto.

Page 7 of 32 ends

3. City fully and publicly reply to and the City Council consider the 11-20-19 citizen concerns/requests regarding the City's proposed LCP Amendment process: Lance Schulte on 1/23/20 received an email reply by the City to his follow up email regarding the status of the 11/20/19 citizen concerns/requests public comments and letters presented to the Planning Commission. This is appreciated, however it is request that the City fully publicly reply to the 11-20-19 citizen concerns/requests regarding the City's proposed LCP Amendment process and present the to the City Council 11/20/19 citizen concerns/requests so the City Council can consider them and provide any direction to City Staff.

City Staff first presented a summary presentation of the proposed Draft LCP Amendment to the Carlsbad Planning Commission on November 20, 2019, and indicated the public comment period would close on November in less than 2-weeks. Citizens and citizen groups provided public testimony to the Planning Commission, both verbally and in two written letters. The CCC was copied on those letters. The testimony and letters noted significant concerns about the City's proposed LCP Amendment process and made three requests:
• Disclose and provide a publically accessible 'Redline Version' of the Existing 2016/Proposed LCP land use Plan and Policies so everyone can see t~e proposed changes to the Existing LCP. • Provide true Citizen Workshops on the major remai ning vacant Coastal land that still have outstanding Citizen Concern or objections. Citizen Workshops , when done right, are valuable means to openly educate, discuss and work to consensus options . These areas, including Ponto, were/are subject to mult iple lawsuits, so true open and honest public workshops would provide an opportunity to openly and honestly discuss the issues and hopefully build public consensus/support for solut ions. This approach seems consistent with CCA Section 30006, and common sense.
• Extend the public comment period 6-months to allow Citizen Review of the Redline Version of the LCPA and allow time for Citizen Workshops .

The City did extend the Public Review period 2-months over the holidays to January 31, 2020. This is appreciated although many think this is inadequate given the significance of the Proposed Land Use Plan Amendments , and lack of Redline Version to compare. The City and their consultants required several extra years beyond schedule prepare the proposed LCP Amendments. The extra years of City Staff work reflects on the volume of the over 500-pages in the documents and the time needed to understand the Existing LCP and then create an Amended LCP. Citizens need sufficient t ime, prope r comparative tools (red line) and a process (workshops) to understand the proposed LCP Amendments that is reflective of extensive extra time needed by City Staff and consultants needed. Truncation of lay public review to a few months for an Amendment that took paid professionals many years to produce seems a more than a bit inappropriate. The City appears to be rejecting citizens' request to be provided a 'Redline Version' of the Existing 2016/Proposed LCP land use Plan. So public review comments will tainted or will miss many issues due having to manually cross-reference a 150-page Existing LCP LUP with a Proposed 350-page Proposed LCP LUP.

There will be unknown and unconsidered changes in the Draft LCP Amendment that the public and city and CCC decision makers will not know about due to the lack of 'Redline Version'.

The City also appears to reject citizen requests for true Citizen Workshops on the majo r remaining vacant Coastal land that still have outstanding Citizen Concern - such as Ponto. Like Coastal Recreation issue #1 above the following citizen requests appear consistent with CA Coastal Act (CCA) Section 30006, and the City's rejection of that requests seem counter to the CA Coastal Act.

We again request of the City to provide : 1) a 'Redline Version' to the public and decision makers, along with suffic ient time to review and comment on the 'Redline Version'; and 2) true Citizen Workshops fo r Ponto and the

Page 8 of 32 ends

other last remaining significant vacant Coastal lands in Carlsbad as part of the Draft LCP Amendment process, or as part of deferred LCP Amendment process for those areas.

4. Coastal Zoned land is precious: the very small amount of remaining vacant Coastal land should be reserved for "High-Priority" Coastal Recreation Land Uses under the CA Coastal Act to provide for the growing and forever 'Buildout' needs of Carlsbad and CA Citizens, and our visitors. • Less than 1.8% (76 square miles) of San Diego County's 4,207 square miles is in Coastal Zone. This small area needs to provide for all the forever Coastal needs of the County, State of CA, and Visitors. Upland Coastal Recreation (Coastal Park) land use is needed to provide land to migrate the projected/planned loss of "High Priority" Coastal Recreation land uses due to Sea Level Rise impacts. There is only 76 miles of total coastline in San Diego County; a significant amount is publicly inaccessible military/industrial land. So how the last few portions of Coastal Land within Carlsbad (which is about 8% of San Diego County's Coastline) is planned for the forever needs for High-Coastal-Priority Recreation Land Use is critical for Carlsbad, San Diego, and · California Statewide needs into the future.
• Most all the developable Coastal land in Carlsbad is already developed with Low-Coastal-Priority residential uses. Only a very small percentage of Carlsbad's developable Coastal land, maybe 1-2%, is still vacant. This last tiny portion of fragment of vacant developab le Coastal Land should be documented in the Draft LCP and reserved for "High-Priority" Coastal Land uses - most critically Coastal Recreation - to address the growing Coastal Recreation needs from a growing population and visitors. These growing needs are all the more critical in that existing Coastal Recreation lands will be decreasing due to inundation and erosion due to DLCPA planned Sea Level Rise.
• This image of the western half of San Diego County graphically shows (in the blue line) the very small Coastal_ Zone Area that needs to provide the Carlsbad's and California's Coastal Recreational needs for all San Diego County residents and Visitors:

Page 9 of 32 ends

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We request that 1} the amount and location of remaining vacant Coastal land in Carlsbad be documented and mapped and be reserved for high-priority Coastal Land Uses consistent with CCA Goals in Section 30001.5 " ... (c} ... maximize public recreational opportunities in the coastal zone consistent with sound resources conservation principles and constitutionally protected rights of private property owners . (d} Assure priority for coastal dependent and coastal-related development over other development on the coast . ... "; 2). This data be used in the City's analysis and the public's review and discussion about the City's proposed Draft 'Buildout' Land Use Plan.

The City's proposed Draft 'Buildout' Land Use Plan will forever lock in the amount "maximum public recreational opportunities in the coastal zone" and will be the final Coastal Land Use Plan that is supposed to "assure priority for coastal-dependent and coastal-related development over other development on the coast" . Most of Carlsbad's Coastal Zone is already developed or committed to low-priority land uses contrary to these CCA Goals, so how we finally and forever plan to use of the last small remaining vacant Coastal Land is very important .

5. The proposed Draft LCP Amendment in Chapter 3 makes unfounded statements regarding the proposed Amendment to the LCP Land Use Plan provision of "High-Priority" Coastal Recreation land use: On page 3-3, at the beginning of the Chapter 3- Recreation and Visitor Serving Uses the City correctly states that the CA Coastal Act (CCA} places a high priority on maxim izing Recreation uses, and cites multiple CCA Sections to that effect. The City's proposed Coastal Land Use Plan then states on page 3-5 that a high proportion of land in the City is dedicated open

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space available for passive and active use, yet provides no justification or accurate metric to support this statement.

This is a critical unsubstant iated and speculative statement that is not supported by any comparative data (justifying the "high proportion" statement). The City later in Chapter 3 compared the adjoining cities of Oceanside _and Encinitas to try to show how the proposed Draft LCP LUP Amendment provides higher levels of Visitor Serving Accommodations . That 'non-common denominator' comparison was fundamentally flawed, as noted in a prior separate Draft LCPA public review comment from People for Ponto regarding another high-priority Coastal land use (visitor accommodations) planned for in Chapter 3, but at least it was an attempt to compare. However, for the Coastal Recreation portion of Chapter 3, the City does not even attempt to provide any comparative data to support (or justify) the proposed Coastal Recreation Land Use Plan and statements. The Coastal Recreation Chapter also fails to disclose Carlsbad's adopted City Park Master Plan (Park Service Area and Equity map) data that shows a clear conflict between the CA Coastal Act Policy Sections noted at the beginning of Chapter 3 and Chapter 3's proposed Draft Coastal Recreation Land Use Plan.

Comparative Coastal Recreation: Comparing the Land Use Plan and policies of Oceanside, Carlsbad and Encinitas, one finds Carlsbad's proposed Coastal Recreational Plan and Policies are not "high", but very low compared with Oceanside and Encinitas. Carlsbad has a General Plan Park Standard of 3 acres of City Park per 1,000 Population.

Oceanside has a 5 acres of City Park Standard per 1,000 population, and Encinitas has a 15 acres per 1,000 population standard, and an in-lieu park fee requirement of 5 acres per 1,000 populat ion. Carlsbad's proposed Coastal Recreation Land Use Plan is in fact not 'high' but is in fact the lowest of the three cities, with Carlsbad providing only 40% of Oceanside's park standard, and only 20% of Encinitas's Park Standard. Citywide Carlsbad currently has 2.47 acres of developed park per 1,000 population, Oceanside currently has 3.6 acres of developed park per 1,000 population, and Encinitas currently has 5.5 acres of developed park per 1,000 population. Although this data is citywide, it shows Carlsbad's current amount of developed parkland is less than 70% of what Oceanside currently provides, and less than 45% of what Encinitas currently provides. Carlsbad is not curren tly providing, nor proposing a Coastal Land Use Plan to provide, a 'high' proportion of Coastal Recreation Land Use compared to Oceanside and Encinitas.

On page 3-5 Carlsbad may be misrepresenting city open space that is needed and used for the preservat ion of federally endangered species habitats and lagoon water bodies. This open space Land cannot be Used for Coastal Recreation purposes; and in fact Land Use regulations prohibit public access and Recreational Use on these Lands and water bodies to protect those endangered land and water habitats. 78% of Carlsbad's open space is "open space for the preservation of natural resources" and cannot be used for Coastal Parks and Recreational use.

Although "open space for the preservation of natura l resources" does provide scenic or visual amenity, and this amenity is addressed as a different coastal resource. Visual open space is not Coastal Recreation Land Use. It appears Carlsbad is proposing in the Draft LCP Amendment to continue to, providing a 'low' percentage of Coastal Park Land Use and Coastal Recreation Land Use compared to adjoining cities.

In addition to the comparatively low amount of Coastal Park land Carlsbad plans for, Carlsbad scores very poorly regarding the equitable and fair distribution and accessibility of Coastal Parks and Coastal Recreation Land Uses.

Both the City of Oceanside and Encinitas have very robust and detailed Park and Land Use plans to promote an equitable distribution of, and good non-vehicular accessibility, to their Coastal Parks. By comparison, Carlsbad's park land use plan scores poorly, as exemplified in Ponto and South Carlsbad. Ponto's existing population requires about

6.6 acres of City Parkland per Carlsbad's low 3 acres per 1,000 population standard. Yet the nearest City Park is several miles away and takes over 50 minutes to walk along major arterial roadways and across Interstate 5 to access. As such this nearest park is not an accessible park for Ponto children, and thus Ponto children have to play in

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our local streets to find a significant ly large open area to play in. Ponto residents have to drive their kids to get to a park increasing VMT and GHG emissions. The City's proposed Coastal Recreation Land Use Plan 'solution' to Ponto's no-park condition, along with the City's need to add an additional 6.5 acres of new City parks in Southwest Carlsbad to comply with the Southwest Carlsbad's 2012 population demand (at a ratio of 3-acre/1,000 population) is to provide a City Park - Veterans Park - over 6-miles away from the Ponto and Southwest Carlsbad populat ion need.

This makes a bad situation worse. The City's proposed location is totally inaccessible to s_erve the needs of the population of children or anyon~ without a car, that it is intended to serve in South Carlsbad. This City proposed Coastal Recreation Land Use Plan 'solution' seems inappropriate and inconsistent with the CA Coastal Act and common sense. During the City's Veterans Park and budget community workshops citizens expressed a desire for a Ponto Park to be the solution to our Ponto and Southwest Carlsbad Park deficits. Those citizen requests were not apparently considered as part of the City's proposed Draft Coastal Recreation Land Use Plan. Following is an image summarizing the magnitude of citizen needs/desires expressed at the City's Budget workshop. Note the number and size of the text citing Ponto Park and South Carlsbad that reflects the number and magnitude/intensity of citizen workshop groups' input. The failu re to acknowledge this public part icipation and data in the Coastal Recreation Land Use Plan Park seems in confl ict with CCA Sections 30006 and 30252(6):

For South Carlsbad there is a complete lack of any existing or planned City Coastal Park and park acreage west of 1-5, while North Carlsbad has 9 existing and 1 planned City Coastal Parks totaling 37.8 acres of City Coastal W of 1-5 North Carlsbad. Not only is this unfair to South Carlsbad, it is also unfair to North Carlsbad as it increases VMT and parking impacts in North Carlsbad because South Carlsbad is not provid ing the City Coastal Parks for South Carlsbad resident/visitor demands. This City Park disparity is shown on Figure 3-1 of the Coastal Recreation Land Use Plan;

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however it more accurately illustrated in the following data/image from the adopted Carlsbad Park Master Plan's "Service Area Maps (Equity Maps}". The image below titled 'No Coastal Park in South Carlsbad' shows Carlsbad's adopted "Park Service Area Maps (Equity Maps)" from the City's Park Master Plan that says it maps "~he population being served by that park type/facility." The added text to the image is data regarding park inequity and disparity in South Carlsbad. The image compiles Carlsbad's adopted Park "Park Service Area Maps (Equity Maps)" for Community Parks and Special Use Area Parks that are the City's two park acreage types produced by the City's comparatively low standard of 3 acre of City Park per 1,000 population. The City's Park Service Area Maps (Equity Maps) shows areas and populations served by parks within the blue and red circles. City data clearly shows large areas of overlapping Park Service (areas/populations served by multiple parks) in North Carlsbad and also shows large areas in South Carlsbad with No Park Service (areas/populations unserved by any parks) and Park Inequity in South Carlsbad. It clearly shows the City's Documented Park Need and Park inequity at Ponto. The Existing LCP LUP for Ponto's Planning Area Fin is required to "consider" and "document" the need for a "Public Park". The City's adopted Park Service Area Maps (Equity Maps) clearly shows the inequity of Coastal City Park between North and South Carlsbad, and the need for Coastal Parks in South Carlsbad - particularly at Ponto. The City's proposed Draft 'Buildout' Coastal Recreation Land Use Plan instead proposes to lock-in documented City Public Coastal Park inequity and unserved Coastal Park demand at Ponto and South Carlsbad forever. It does so by proposing the last vacant undeveloped/unplanned Coastal land - Ponto Planning Area F - in the unserved Ponto and South Carlsbad coastline areas instead of being planned for much needed City Park and Coastal Recreation use be converted to even more low-priority residential and general commercial land uses. These 'low-priority" residential uses, by the way, further increase City Park and Coastal Recreation demand and inequity in Coastal South Carlsbad. This is wrong, and a proposed 'forever-buildout' wrong at the most basic and fundamental levels. The proposed Draft Coastal Recreation Land Use Plan by NOT providing documented needed City parks for vast areas of Coastal South Carlsbad is inconsistent with the CA Coastal Act policies and Existing LCP LUP requirements for Ponto Planning Area F; and also inconsistent with fair/equitab le/commonsense land use and park planning principles, inconsistent with CA Coastal Commission social justice goals, inconsistent with social equity, inconsistent with VMT reduction requirements, and inconsistent with commo n fairness. A different Coastal Recreation Land Use Plan should be provided that provides for a socially equitable distribut ion of Coastal Park resources so as to would allow children , the elder ly and those without cars to access Coastal Parks. The proposed Draft 'Buildout' Coastal Recreat ion Land Use Plan forever locking in the unfair distribut ion of City Parks appears a violation of the not only CCA Sections 30213, 30222, 30223, and 30252(6) but also the fundamental values and principles of the CA Coastal Act. The Draft also appears a violation of Carlsbad's Community Vision.

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No Coastal Park in South Carlsbad
. Appx. 6 miles of Coast & ... ..:I
without a Coastal Park is a ------ (----·
._._.....__,...

City & Regional need ., ..... -~ ~ ...... ._
-~ ..... , ... c....t,,ii, ""y~~
'-Cot-•--. South Carlsbad has 64,000
n.,r," ,oc..c. ,~ ... _,.,_
- c_,.... r'tw .-A tlC....""'•
resi9ents & thousands of \ai,0.""'6.i~--""'--· --c--hotel visitors without a ....._ ..... ..,_ __ Coastal park
c..- .,......_ __
,.. ._,. ~ &lauw~
.... ..... ...,.."-ca...u,.-.,
. Closest park to Ponto is
Poinsettia Park. approx.. 2.5 l
I miles acrossl-5 - t::::::> ,_ . Proposed Veterans Park is approx. 6 miles away
--
A different Coastal Recreation Land Use Plan is required to provide a more equitable distribution of City Parks with non-vehicular accessibility. Such a different plan would advance State and City requirements to reduce vehicle Miles Traveled (VMT) and greenhouse gas emissions that contribute to climate change and sea level rise impacts. Please note that the data for the above basic comparison comes from City of Carlsbad, Oceanside and Encinitas General Plan and Park Maste r Plan documents.

Data shows the proposed Coastal Recreation Plan conflicts with the CA Coastal Act policy Sections. As mentioned page 3-3 correctly states that the CA Coastal Act (CCA) places a high priority on maximizing Recreation Land Uses, and pages 3-5 list multiple CA Coastal Act (CCA) policy Sections that confirm this. However, given the significant statewide importance of Coastal Recreation Land Use, the City proposed 'Buildout' Coastal Recreation Land Use Plan does not appear to adequately address and implement these CCA Policies, and most noticeably in the Ponto area of South Carlsbad. Coastal Recreation is a significant Statewide High-Priority Land Use under the CCA. For a substantially developed non-coastal-industry city like Carlsbad Coastal Recreation is likely the biggest land use issue.

This issue is even more elevated due to the fact that there are only a few small areas left of undeveloped Coastal land on which to provide Coastal Recreation, and Carlsbad is proposing a Coastal 'Buildout' Land Use Plan on those areas. The use of the last few remaining vacant port ions of Coastal land for Coastal Recreation Land Use is the most important land use consideration in the proposed Draft LCP Land Use Plan Amendment as populat ion and visitor growth will increase demands for Coastal Recreation. It is thus very surprising, and disturbing that the proposed Coastal Recreation Land Use Plan is so short, lacks any comparative and demand projection data, lacks any resource demand/distribution and social equity data, and lacks any rational and clear connection with CCA Policy and the proposed 'Buildout' Coastal Land Use plan. This is all the more troubling given that:
• The Ponto area represents the last significant vacant undeveloped/unplanned land near the coast in South Carlsbad that can provide a meaningful Coastal Park.
• The fact that the City's Existing LCP requires the city consider and document the need for a "i.e. Public Park" on Ponto's Planning Area F prior to the City proposing a change of Planning Area F's "Non-residential

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Reserve" land use designation. The City has repeatedly failed to comply with this LCP LUP requirement, and worse has repeatedly failed to honestly inform citizens of this LCP LUP requirement at planning Area F before it granted any land use. The City, apparently implementing speculative developer wishes, has repeatedly proposed changing Planning Area F's Coastal Land Use designation to "low-priority" residential and general commerc ial land uses without publically disclosing and following the Existing LCP LUP. • The City's currently developed parks in the southern portion of the City do not meet the city's comparat ively low public park standard of only 3 acres per 1,000 population. Since 2012 there has been City park acreage shortfall in both SW and SE Carlsbad. • The Existing population of Ponto (west of 1-5 and south of Poinsettia Lane) requires about 6.6 acres of Public Park based on the City's comparat ively low public park standard of 3 acres per 1,000 population. There ois no Public Park in Ponto. Adding more population at Ponto will increase this current park demand/supply disparity.
• Carlsbad and other citizens have since 2017 expressed to the City the strong need for a Coastal Park at Ponto, and requested the City to provide a true citizen-based planning process to consider the Public Park need at Ponto. The Citizens' requested process is fully in-line with CCA Goals, Public Participation Policy, Land Use Policies, and the Existing LCP land Use Plan/requirements fo r Planning Area F and is the most appropriate means to consider and document the need for a Public Park at Ponto as required by the Existing LCP Land Use Plan.
• Planning Area Fis for sale, and a non-profit citizens group has made an offer to purchase Planning Area F for a much needed Coastal Park for both Ponto and inland South Carlsbad residents and visitors. How should these facts be considered by the City and CCC?
• Carlsbad has no Coastal Parks west of 1-5 and the railroad corridor for the entire southern half of Carlsbad's 7-mile coastline.
• The southern half of Carlsbad's coastline is 5.7% of the entire San Diego County coastline and represents a significant portion of regional coastline without a meaningful Coastal Park west of 1-5 and the Railroad corridor.
• The City's proposed Coastal Recreation Land Use Plan provides No Documentation, No Rational, and No Supporting or Comparative Data to show the proposed Coastal Recreation Land Use Plan in fact compl ies with the CA Coastal Act.
6 . . There is no Coastal Recreation/Park west of interstate 5 for all South Carlsbad, or half of the entire City. This is an obviously unfair and inequitable distribution of Coastal Recreation/Park resources that should be cor rected by changes to the Draft LCP Land Use Amendment: The following image (which was sent to the City and CCC on several prior communications) was first requested by former Carlsbad Councilman Michael Schumacher during a People for Ponto presentation/request at the Oct 23, 2018 City Council meeting. The data compiled in the image shows how the South Coastal Carlsbad (Ponto) is not served by a Park per the City's adopted Parks Master Plan. The blue dots on the map are park locations and blue circle(s) show the City's Park Master Plan adopted Park Service Areas and Park Equity. This data, from pages 87-88 of the City of Carlsbad Parks Master Plan, shows all City Parks (both Community Parks and Special Use Areas in Coastal Carlsbad (except Aviara Park east of Poinsettia Park and west of Alga Norte Park). The text on the left margin identifies the South Carlsbad Coastal Park (west of 1-5) gap along with the number of South Carlsbad Citizens (over half the City's population) without a Coastal Park. The left margin also identifies more local issues for the over 2,000 Ponto area adults and child ren. For Ponto residents the nearest Public Park and City proposed 'solution' to the South Carlsbad and Ponto Public Park deficit are rriiles away over high speed/traffic roadways and thus somewhat hazardous to access and effectively unusable by children/the elderly or

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those without cars. Having been a 20-year resident of Ponto I regularly see our children have to play in the street as there are no Public Park with large open fields to play at within a safe and under 1-hour wal k away. Ponto citizens have submitted public comments regarding this condition and t he lack of a Park at Ponto No Coastal Park in South Carlsbad
• Appx. 6 miles of Coast
without a Coastal Park is a
City & Regional need
• South Carlsbad has 64,000
residents & thousands of
hotel visitors without a
Coastal park
• Closest park to Ponto is
Poinsettia Park, approx. 2.5
mites across t-5 ,_
• P roposed Veterans Park is
approx. 6 miles away
-~--
~ •• (Md ...... ,..,. --
~G•...- ~~
~ .. >Oc.o..tt"1•.,.
~ """"'"'_,, .......
~c.,,i.,..,~ ~ --- , ..

So.Ac...-~- ......
~.,,.,..~ .. "'~ '-.. '""""' __ . -~,t-~ ........ ..,.... .... ~ • ...._l Ponto is at the center of regiona l 6-mile Coastal Park Gap. A Coastal Park in this instance being a Public Park with practical green play space and a reasonable connectio n with the Coast (i.e. located west of the regional rail and lnterstate-5 corridors). The follo wing image shows this larger regional Coastal Park Gap centered on the Ponto Area, and the nearest Coastal Parks - Cannon Park to the north, and Moonlight Park to the south.

Regionally this image shows Ponto is the last remaining significant vacant Coastal land that could accommodate a Coastal Park to serve the Coastal Park current needs of over existing 2,000 Ponto residents, 64,000 existing South Carlsbad residents, and a larger regional population. It is also t he only area to serve the Coastal Park needs for the thousands of hotel rooms in Upland Visitor Accommodations in South Carlsbad.

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How Ponte Serves Region
As People for Ponto first uncovered and then communicated in 2017 to the City and CCC; Carlsbad's Existing (since 1994) Local Coastal Program LUP currently states (on page 101) that Ponto's Planning Area F: carries a Non-Residential Reserve (NRR) General Plan designation. Carlsbad's Existing Local Coastal Program Land Use Plan states: "Planning Area F carries a Non-Residential Reserve (NRR) General Plan designation. Planning Area Fis an "unplanned" area ... " and requires that : " ... As part of any future planning effort, the City and Developer must consider and document the need for the provision of lower cost visitor accommodations or recreational facilities (i.e. public park) on the west side of the railroad.'' CA Coastal Commission actions, Carlsbad Public Records Requests 2017-260, 261, and 262, and 11/20/19 City Planner statements confirm the City never fully communicated to Carlsbad Citizens the existence of this LCP requirement nor did the City comply with the requirements. Of deep concern is that the City is now (as several times in the past) still not honestly disclosing to citizens and implementing this Existing LCP requirement as a true and authentic 'planning effort'. The lack of open public disclosure and apparent fear of true public workshops and Public Comment about the Existing Planning Area F LCP requirements are troubling. The point of a 'planning effort' is to openly and publically present -data, publically discuss and explore possibilities/opportunities, and help build consensus on the best planning options. Citizens are concerned the city has already made up its mind and there is no real "planning effort" in the proposed Draft LCP Amendment process, just a brief Staff Report and at the end provide citizens 3-minutes to comment on the proposal. This is not the proper way to treat the last remaining significant vacant land is South Carlsbad that will forever determine the Coastal Recreation environment for generations of Carlsbad and California citizens and visitors to come.

The following data/images show how Ponto is in the center of the 6-mile (west of 1-5 and Railroad corridor) regional Coastal Park gap. Ponto is the last remaining vacant and currently "unplanned" Coastal land that is available to address this regional Coastal Park Gap.

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How Por:1to Serves Region cont.

Page 18 ends

How Per:1te Serves Region cont.
s Region cont.

Page 19 ends

Penta Coastal Park Concept
~
One possible Concept image of a potent ial Ponto Coastal Park at Planning Area F is illustrated below. T he potential for a Ponto Coastal Park is real. The speculative land investment fund (Lone Star Fund #5 USA LP. and Bermuda LP.) that currently owns Planning Area F is selling the property, and is available for the City of Carlsbad to acquire to address the documented demand/need for a City Park and City Park inequ ity at Ponto and in Coastal South Carlsbad. A Ponto Beachfront Park 501c3 is working to acquire donat ions to help purchase the site for a Park. ·These situations and opportunities should be publicly discussed as part of the City Staff's proposed Local Coastal Program Land Use Plan Amendment.

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~~~-.... -~~---- ..... ~ •-.s ~,..., ..... ._ t,c
,,~ ...,. ....... . JIM&.Jllf ..a.c."'t. ov,r -...; .,.. V4l"! u,- ee-.,. ~ a tJI' ..,,,-~ ---.:- ,.,,,, ~ •.a,;..•.;. ~ - Ill,) .. -~
~ ............. .., ....., • .......,v .. ~ ...
-
( . -~------............... ---

7. Projected increases in California, San Diego County and Carlsbad population and visitor growth increases the demand for High-Priority-Coastal Recreation land use:
• Increasing Citizen demand for Coastal Recreational land needs to be addressed with increased Coastal Recreation land:

San Diego County Citizen Population - source: SANDAG Preliminary 2050 Regional Growth Forecast 1980 1,861,846
1990 2,498,016
2000 2,813,833
2010 3,095,313
2020 3,535,000 = 46,500 Citizens per mile of San Diego County coastline 2030 3,870,000
2040 4,163,688
2050 4,384,867 = 57,700 Citizens per mile of San Diego County coastline 2020 to 2050 = 24% increase in San Diego County population.

Citizen Population will continue beyond 2050. Carlsbad may plan for 'Buildout' in 2050, but what is San Diego County's 'Buildout'? There is a common-sense need to increase the amount of Coastal Recreation Land Use in the Proposed LCP Amendment to the Land Use Plan for this growing population. If we do not increase our supply of Coastal Recreational Resources for these increased demands our Coastal Recreation Resources will become more overcrowded, deteriorated and ultimately diminish the Coastal Recreation quality of life for Citizens of Carlsbad and California. Ponto sits in the middle of an existing 6-mile regional Coastal Park Gap (no Coastal Park west of Interstate 5) and there is No Coastal Park in all of South Carlsbad to address the Coastal Recreation needs of the 64,000 South Carlsbad Citizens.

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• Increasing Visitor demand for Coastal Recreational land needs to be addressed with increased Coastal Recreation land:

Yearly Visitors to San Diego County - source: San Diego Tourism Authority; San Diego Travel Forecast, Dec, 2017 2016 34,900,000
2017 34,900,0 00
2018 35,300,000
2019 35,900,000
2020 36,500,000 = average 100,000 visitors per day, or 2.83% of County1s Population per day, or 1,316 Visitors/coastal mile/day in 2020
2021 37,100,000
2022 37,700,000
This is growth at about a 1.6% per year increase in visitors. Projecting this Visitor growth rate from 2020 to 2050 results in a 61% or 22,265,000 increase in Visitors in 2050 to:
2050 58,765,000 = average 161,000 visitors per day, or 3.67% of the County's projected 2050 Population per day, or 2,120 Visitors/coasta l mile/day in 2050.

The number of Visitors is likely to increase beyond the year 2050. There is a common -sense need to increase the amount of Coastal Recreation Land Use in the Proposed LCP Amendment to the Land Use Plan for these projected 2050 61% increase, and beyond 2050, increases in Visitor demand for Coastal Recreational Resources. Increasing Coastal Recreation land is a vital and critically supporting land Use and vital amenity for California's, the San Diego Region's and Carlsbad's Visitor Serving Industry. Ponto sits in the midd le of an existing 6-mile regional Coastal Park Gap (no Coastal Park west of Interstate 5). There are thousands of hotel rooms in South Carlsbad that have NO Coastal Park to go to in South Carlsbad. This needs correcting as both a Coastal Act and also a City economic sustainability imperative. • We request that the as part of the public's review, the City Staff proposed Draft LCP Amendment to the Land Use Plan clearly document if and/or how future forever 'Buildout" City, Regional and Statewide population and visitor population demand for Coastal Recreation and City Coastal Parks are adequately provided for both in amount and locationa l distribution in the Carlsbad proposed Amendment of the LCP Land Use Plan.

8. Carlsbad's Draft Local Coastal Program Land Use Plan Amendment says it plans to a year 2050 buildout of the Coastal Zone. The Draft Local Coastal Program Land Use Plan Amendment then is the last opportunity to create a Coastal land Use Plan to provide "High-Pri ority " Coastal Recreation land Use, and will forever impact future generations of California, San Diego County, and Carlsbad Citizens and Visitors:
• The Draft LCPA indicates in 2008 only 9% of All Carlsbad was vacant land. Less is vacant now in 2019.

Carlsbad's Coastal Zone is 37% of the City, so vacant unconstrained land suitable for providing Coastal Recreation is likely only 3-4%. The prior request for a full documentation of the remaining vacant Coastal lands will provide a better understanding needed to begin to make the final 'bui ldout' Coastal land Use Plan for Carlsbad. The Draft lCPA does not indicate the amount and locations of currently vacant unconstrained Coastal land in Carlsbad. This fina l limit ed vacant land resource should be clear ly documented and mapped in the DLCPA as it represents the real focus of the DlCPA-the Coastal Plan for these remaing n undeveloped

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lands. These last remaining vacant lands should be primarily used to provide for and equitably distribute "High-Priority" Coastal Recreation Land Uses consistent with CCA Sections:
i. Section 30212.5 " ... Wherever appropriate and feasible, public facilities, including parking areas or facilities, shall be distributed throughout an area so as to mitigate against the impacts, social and otherwise, of overcrowding or overuse by the public of any single area."; ii. Section 30213 " ... Lower cost visitor and recreational facilities shall be protected, encouraged, and, where feasible, provided. Developments providing public recreational opportunities are preferred . ... ";
iii. Section 30222 "The use of private lands suitable for visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have priority over private residential, general industrial, or general commercial development, but not over agriculture or coastal-dependent industry."
iv. Section 30223 "Upland areas necessary to support coastal recreational uses shall be reserved for such uses, where feasible",
v. Section 30251 ... The location and amount of new development should maintain and enhance public access to the coast by ... 6) assuring that the recreational needs of new residents will not overload nearby coastal recreation areas by correlating the amount of development with local park acquisition and development plans with the provision of onsite recreational facilities to serve the new development"
Adopted City Park Service Area and Park Equity maps discussed earlier document the proposed Draft LCP Amendment's inconstancy with the above CCA Policy Sections. The locations and small amounts remaining vacant Coastal lands provide the last opportunities to correct the inconsistencies of City proposed Draft "buildout" LCP Land Use Plan Amendment with these Coastal Act Policies.

Current ly and since 1996 there has been LCP LUP Policy/regulations for Ponto Planning Area F that require considerat ion of a "Public Park" prior to changing the existing "unplanned Non-residential Reserve" Land Use designation. A map and data base of vacant developable Coastal land should be provided as part of the Draft LCPA and the Draft LCPA. This map and data base should document the projected/planned loss of Coastal land use due to Sea Level Rise. Draft LCPA projects Sea Level Rise will eliminate several beaches and High-Priority Coastal Land Uses like Coastal Lagoon Trails and the Campground. • The LCP Land Use Plan should plan and reserve the very limited vacant developable Coastal land for the long-term 'Buildout' needs of "High-Priority" Coastal Recreation Land Use. Vacant developable Coastal land is too scarce to be squandered for "low-priority" uses. Sea Level Rise will reduce "High-Priority" Coastal Uses. So how vacant developable Upland area should be preserved for "High-Prior ity" Coastal Uses is a key requirement to be fully documented and discussed in the Draft LCPA. If not one of two thing will eventually happen 1) any new Coastal Park land will require very expensive purchase and demolition of buildings or public facilities to create any new Coastal Park land to meet existing and growing demand; or 2) Coastal Recreation will hemmed-in my "low-priority" uses and thus force Coastal Recreation to decrease and become increasing concentrated and overcrowded in its current locations; and thus will promote the eventual deterioration of our current Coastal Recreation resources. A plan that fails to fix Coastal Park deficits and then increase Costa I Parks in pace with increased population/visitor demand is a plan that can

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only result in degradation. How the Draft LCPA documents and addresses the land use planning of the last small portions of vacant developable Coastal land is critical for the future and future generations.

9. Citizens of South Carlsbad are concerned about the City's mult iple prior flawed Ponto planning processes or 'mista kes' the City has made yet is basing the City Staff's proposed Draft LCP LUP. The concerns being the City is not openly and honestly communicating information to citizens and the public, and not allowing a reasonable and appropriate community-based planning process to address the documented Park, Coastal Recreation and unconstrained open space needs in South Carlsbad. One of these groups of citizens has created a www.peopleforponto.com website to try to research and compile information and hopefully provide a better means for citizens to understand facts and then express their concerns/desires to the City of Carlsbad (City) and CA Coastal Commission (CCC). Over 2,000 emails have sent to the City and CCC regarding Coastal Land Use Planning Issues at Ponto. The San Pacifico Planned Community (i.e. San Pacifico Community Association) has also, since 2015, sent numerous emailed letters to the City and CCC noting the significant concerns about changes in Coastal planning the City is proposing for our Planned Community.

Repeatedly over 90% of surveyed citizens (results emailed prior to both the City and CCC) have expressed the vital need and desire for a Coastal Park at Ponto to serve the current and future Coastal Recreation needs for all both Ponto and South Carlsbad and for larger regional and State Coastal Recreational needs. This desire is supported by data, CA Coastal Act Policy, and also Carlsbad's Community Vision - the foundation for the City's General Plan.

Ponto is the last remaining vacant Coastal area available to provide for those needs in South Carlsbad and for a regional 6-mile stretch of coastline. Citizens have expressed deep concern about the City's flawed prior Coastal planning efforts for Coastal Recreation at Ponto, including two repeated LCP Amendment "mistakes" (Ponto Beachfront Village Vision Plan in 2010 and General Plan Update in 2015) when the City twice failed to publicly disclose/discuss and then follow the Existing LCP requirements at Ponto - specifically for Planning Area F. People for Ponto had to use mult iple Carlsbad Public Records Requests in 2017 to find these "mistakes". CCC Staff was helpful in both confirming the City "mista kes" and communicating back to the City. As citizens we are still unclear has to how/why these two repeated "mistakes" happened. There is citizen concern that the City is again repeating these two prior "mistakes" by not at the beginning of the Public Comment Period clearly and publicly disclosing the Planning Area F LCP requirements to citizens as part of the current LCP Amendment process, and also by not implementing the exiting LCP requirement PRIOR to proposing an Amended Coastal Land Use Plan for Ponto. The City in its proposed LCP Amendment process is putting-the-cart-before-the-horse with respect to honest and open consideration, documentation and public discussion of the need for high-priority Coastal Recreation land use required of Planning Area F at Ponto. The City is also not clearly letting all Carlsbad citizens know about the Existing LCP requ irements for Ponto's Planning Area F so they can be informed to reasonably participate in public review and comment regarding amending that LCP requirement, and the need for Coastal Recreation land uses in South Carlsbad. Since 2017 there has been repeated citizen requests to the City (copies were provided to the CCC) to fix these multiple fundamental/foundational flaws by in the City's prior Coastal Recreation and Public Parks and Open Space at planning, and the currently Proposed Draft LCP Land Use Plan Amendment. Since 2017 there have also been repeated citizen requests to the City to provide a truly open, honest, inclusive community-based planning process and workshops with the accurate and honest information, prior to forming a proposed Draft LCP Land Use Plan Amendment. As citizens we believe we can constructively work with the City and CCC towards a consensus or viable options on these important Coastal Recreation issues if the City allows and encourages such an open, honest and inclusive process. We request the City respond to the requests submitted to the City since 2017, and again request such a process from the City before any LCP Amendment is first considered by the Planning Commission and City Council. Such a requested process benefits all.

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10. Why the Draft LCPA Land Use Plan for Ponto should provide for the current and future Coastal Park and Recreation needs for South Carlsbad, the San Diego Region and California. • Ponto, is one of last remaining vacant and undeveloped Coastal lands in North County • Ponto is the last remaining undeveloped Coastal land in South Carlsbad • Ponto has the last unplanned Planning Area of the Existing Poinsettia Shores Planned Community & Local Coastal Program that can be. planned for high-priority Coastal Recreation land use. This Existing LCP requires Planning Area F be considered for a "Public Park".
• Following is a map of the Ponto area in South Carlsbad:

Following is the LCP Land Use map from the Existing Poinsettia Shores Master Plan & Local Coastal Program adopted in 1996. This is the Land Use map that the City is proposing to change in the proposed LCP Amendment to the Land Use Plan. As the Existing LCP Land Use map shows most all the land is 'low-priority' residential use at an RM Residential medium density, a small portion is 'high-priority' Visitor Serving TC/C Tourist Commercial. Most all the

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Open Space is constrained and undevelopable land (the steep CSS habitat bluffs above Batiquitos Lagoon) or water (the lagoon water) . This land/water is owned by the State of California, like the inner lagoon east of 1-5. Only Planning Area Mat 2.3 acres is unconstrained Open Space and it provides a small private internal recreation facility for the approximately 450 homes and 1,000 people in the Planned Community . This small recreation area is a City requirement for 'planned developments' to off-set loss open space from planned development impacts on housing quality . Planned developments can propose designs that reduce normal setback and open space areas - they bunch together buildings to increase development - such as the smaller lot sizes, and extensive use of "zero-setbacks" to reduce typical lot sizes that occurs at Poinsettia Shores. A private recreation facility in any of the City's planned developments is never considered a replacement for required City Parks. Planned Developments, like unplanned developments, are required to dedicate Park land to the City, or pay a Park In-Lieu fee to the City so the City provide the developer's obligation to provide City Park acreage to address the population increase of their proposed planned development. For Poinsettia Shores' population the City's minimum City Park Standard would require developers set aside 3 acres of City Park land for local park needs. For the larger Ponto area population about 6.6 acres of City Park Land is required. The Existing LCP reserves Planning Area Fas an unplanned "Non -residentia l Reserve" Land Use until the Public Park needs for Ponto are considered and documented. Only then can the NRR land use be changed.

Al'l'RU,..

GROSS AC.

9.8 13.5

10.2 l ◄ .7

20.9 2.9

11.2 4.4

0.9 11.3

8.4 3.7

11.9 13.8

18.3 4.6

2.3 11. Developers have overbuilt in the Ponto area of the Coastal Zone. The City of Carlsbad has under questionable circumstances is currently choosing to 'exempted' Ponto developers from providing the minimum amount of unconstrained Open Space according to the City's developer required Open Space Public Facilities Standard. The legality of these confusing circumstances is subject to a lawsuit against the City. However the City's computerize mapping system has documented that the Ponto area of the Coastal Zone is missing about 30-acres of Unconstrained Open Space that can be used to fulfill the City's Open Space Performance Standard that states that

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15% of unconstrained and developable land must be preserved by developers as Open Space. Following is a summary of data from the City data regarding the missing Open Space at Ponto (Local Facility Management Plan Zone 9, LFMP Zone 9) in the Coastal Zone pursuant to the City's Open Space Performance Standard. If it is desirable People for Ponto can provide the City GIS map and parcel-by-parcel data base on which the following summary is based:

City of Carlsbad GIS data calculations of Open Space at Ponto area of Coastal Zone:
472 Acres = Total land in LFMP Zone 9 [Ponto area] per City of Carlsbad GIS data (197 Acres) = Constrained land/water/infrastructure that is excluded from the City's Open Space Standard 275 Acres = Unconstrained land in LFMP Zone 9 (Ponto) subject to the City's Open Space Standard X 15% = Minimum unconstrained Open Space requirement per the City Open Space Standard 41 Acres = Minimum unconstrained Open Space required in LFMP Zone 9 (11 Acres) = Actual unconstrained Open Space provided & mapped by City in LFMP Zone 9 30 Acres = Missing unconstrained Open Space needed in LFMP Zone 9 [Ponto area of Coastal Zone] to meet the City's minimum GMP Open Space Standard. 73% of the required Open Space Standard _ is missing.

Thus the Ponto area of the Coastal Zone appears overdeveloped with 30 additional acres of "low -priority" residential land uses due to developers' non-compliance to the City's Open Space Public Facility Performance Standard's Minimum developer required Open Space requirement. As noted a citizens group has a pending lawsuit with the City over the City's current 'exempting' Ponto and future developers from meeting the Open Space Standard.

12. The prior pre-1996 LCP for Ponto -the Batiquitos Lagoon Educational Park Master Plan & LCP (BLEP MP/LCP) had significant Open Space-and recreational areas. These significant Open Space and Recreational areas where removed with BLEP MP/LCP's replacement in 1996 by the currently existing Poinsettia Shores Master & LCP (PSMP/LCP) and its City Zoning and LCP LUP requirements that reserved Planning Area F with the current "Non-residential Reserve" Land Use designation. Since the BLEP MP/LCP it appears developers and the City of Carlsbad have worked to remove "High-Priority" Coastal land uses (i.e. Coastal Recreation and Park uses) out of the Ponto area and replaced them with more "low-priority" residential and general commercial land uses. For example:
• Planning Area Fused to be designated "Visitor Serving Commercial" as part of the original 1980's BLEP MP/LCP for Ponto.
• In 1996 the BLEP MP LCP was changed by developer application to the now current PSMP LCP, and the LCP LUP designation changed from "Visitor Serving Commercial" to "Non-Residential Reserve" with the requirement to study and document the need for "High-Priority" Coastal Recreation (i.e. Public Park) and/or Low-cost visitor accommodations prior to any change to Planning Area F's "Non-resi dential Reserve" LCP land use.
• In 2005 the City started to try to change Planning Area F to low-priority residential and general commercia l land use in the City's Ponto Beachfront Village Vision Plan (PBVVP). At this time the City made its first documented Coastal 'planning mistake' by not disclosing to the public the existence of Planning Area F's LCP requirements and then also not following those LCP requirements. The City's planning process seemed focused on addressing developer's land use desires, and increasing land use intens ity to boost "Tax increment financing" as the City had established a Redevelopment Project Area at Ponto. A short time after the State of CA dissolved Redevelopment Agencies due in part to such abuses by cities. The CCC formally rejected the PBVVP in 2010, citing the City's failure to follow the LCP requirements for Planning Area F.

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• Five years later in 2015 the City again adopted a proposed General Plan Update to again change Planning Area F to low-priority residential and general commercial land use. The General Plan Update cited the City's PBVVP that was in fact rejected by the CCC only a few years before. The City again repeated their PBWP's Coastal land use 'planning mistake' by again not disclosing to the public the existence of Planning Area F's LCP requirements and then not following those LCP requirements. It is unclear why the City did this only 5- years after the CCC specifically rejected the Ponto Beachfront Village Vision Plan for those same reasons. • In 2017 citizens found and then confirmed these Ponto Coastal 'planning mistakes' by the City through multiple official Carlsbad Public Records Requests and CCC Staff confirmation. The CCC readily identified the mistakes, but the City's 2019 proposed Draft LCP Land Use Plan and planning process still has yet fully disclose these prior Coastal 'planning mistakes' to ALL citizens of Carlsbad - the failure to disclose and follow the Planning Area F LCP LUP and City Zoning requirements. Full City disclosure is needed now to try to correct many years of City misrepresentation to citizens on LCP required Coastal land Use planning at Ponto.

It is needed now so the public is aware at the start of the Public Comment Period. In 2017 citizens began asking the City fix the City's over 12-years of misinformation and planning mistakes by 'restarting' Coastal land use planning at Ponto with an open and honest community-based Coastal planning process. These citizens' requests have been rejected.
• In 2019 the City Staff proposed citywide Draft LCP land Use Plan Amendment that again proposed to change Planning Area F to "low-priority" residential and general commercial land use, without First disclosing the Planning Area F LCP requirements with corresponding analysis of the Need for Coastal Recreation (i.e. Public Park) and/or low-cost visitor accommodations at Planning Area F and providing that Documented analysis for public review/Consideration/comment. This seems like another 3rd repeat of the prior two Coastal planning mistakes by the City. In 2019, again citizens asked for a reset and a true community-based process for the last remaining significant vacant Coastal lands - including Ponto. Again the City rejected citizens' requests.
• In 2020 thousands of public requests again asked, and are currently asking, for a reset and a true community-based process for the last remaining significant vacant Coastal lands - including Ponto. Again these requests are being rejected. Based on the significant citizen concern and the documented prior 'planning mistakes' at Ponto it appears reasonable and responsible for Ponto's Planning Area F to ether:
i. Retain its current Existing LCP LUP land Use of "Non-Residential Reserve" until such time as the City's past Ponto Beacnfront Village Vision Plan and General Plan Update planning mistakes and other issues subject to current planning lawsuits against the City are resolved with a true, honest and open community-based Coastal planning process asked for by citizens since 2017. Or ii. Propose in the Draft LCP Land Use Plan Amendment to re-designated Planning Area F back to a Visitor Serving Commercial and Open Space ("i.e. Public Park") to provide both "High-Priory" coastal uses v. low-priority residential/general commercial uses due to the documented Coastal Recreation and Low-cost visitor accommodation needs for both citizens and visitors at Ponto and South Carlsbad.

13. Questionable logic and inconsistency in proposed Draft land use map and policies: Chapter 2 Figure 2-28 & Con pages 2-19 & 20 proposes to Amend the existing LCP Land Use Plan Map, and policies LCP-2-P.19 and 20 on pages 2- 27 to 2-29 propose Amendments to existing LCP policy and create a new added layer of policy referencing a Ponto/Southern Waterfro _nt. The proposed Land Use Map and Policies serve to firmly plan for "low-priority" residential and general commercial land uses at Ponto with a clear regulatory Land Use Plan Map showing these land uses and by specific regulatory policy (LCP-2-20) that clearly requires (by using the words "shall") these "low

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priority" uses. In contrast the "High-Priority" Coastal Recreation and Coastal Park land uses that would be designated as Open Space are not mapped at all in Figure 2-28 & C; and the proposed policy LCP-2-P.19 is both mislead ing and specifically does Not Require any "High-Priority" Coastal Recreation and Coastal Park land Use at Ponto and South Carlsbad. In fact page 2-22 specifically indicates two "may" criteria that would first need to occur in the positive before any potential Coastal Recreation and Coastal Park Land could then theoretically even be possible. It is highly probable that it is already known by the City that the proposed relocation of Carlsbad Boulevard (Coast Highway) is not very feasible and not cost effective, and will not yield (due to environmental habitat constraints, narrowness of the roadway median, and other design constraints) any significant dimensions of land that could potentially be designated Open Space and realist ically be used as a Park.

The blank outline map (Figure 2-2B &C) provides no mapped Open Space Land Use designation, other than for the currently existing State Campgrounds' low-cost visitor accommodations, so the proposed Land Use Plan Map is Not providing/mapping any new Open Space land use to address Coastal Recreation and Coastal Park needs. The Draft LCP Land Use Plan Amendment's proposed/projected/planned Sea Level Rise and associated coastal erosion appears to indicate that this "High-Priority" low-cost visitor accommodation (Campground) land use designated as Open Space will be reduced in the 'Buildout' condition due to coastal erosion . So the Draft LCP Land Use Plan is actually planning for a Reduction in Open Space Land Use in South Carlsbad and Ponto. Both the blank outline map and the proposed Land Use Map Figure 2-1 DO NOT clearly map and designate both South Carlsbad's Draft LCP Planned Loss of the Open Space Land Use and also any New or replacemen t unconstrained land as Open Space land use for Coastal Recreation and Coastal Park. This is an internal inconsistency in Land Use Mapping that should be correct ed in two ways:
1) Showing on all the Land Use (Figure 2-1), Special Planning Area (Figure 2-2B & C), and other Draft LCP Maps the Draft LCP's planned loss of land area in those maps due to the Draft LCP's· planned loss of land due to Sea Level Rise and Coastal Land Erosion. This is required to show how land use boundaries and Coastal Recourses are planned to change over t ime. or
2) Provide detailed Land Use Constrain t Maps for the current Carlsbad Boulevard right-of-way that the City "may'' or 'may not' choose (per the proposed "may'' LCP-2-P.19 policy) use to explore to address the City's (Park Master Plan) docume nted Coastal Recreation and Coastal Park land use shortages in Coastal South Carlsbad and Ponto. Clearly showing the potential residual Unconstrained Land with in a Carlsbad Boulevard relocation that have any potential possibility to add new Open Space Land Use Designations (for Coastal Recreation) is needed now to judge if the policy is even rationa l, or is it just a Trojan horse.

The proposed internal inconsistency in mapping and policy appears like a plan/policy 'shell game'. The proposed Land Use Plan Maps and Policies should be consistent and equality committed (mapped -shall v. unmapped -may) to a feasible and actual Plan. If not then there is No real Plan.

There is no Regulatory Policy requirement in LCP-2-P.19 to even require the City to work on the two "may" criteria.

The City could choose to bury the enti re Carlsbad Boulevard relocation concept and be totally consistent with Policy LCP-2-P.19 and the LCP. As such the language on 2-22, Figure 2-2C (and the proposed Land Use Map) , and policy LCP-2-P.19 and 20 appear conspire to create a shell game or bait -and-switch game in that on ly "low-prio rity" residential and general commercial uses are guaranteed (by "shall" policy) winners, and "high-prior ity" Coastal Recreation and Coastal Park Land Uses are at best a non-committal 'long-shot" ("may" policy) that the city is specifically not providing a way to ever define, or commit to implement. The proposed Draft LCP Land Use Plan Coastal Recreation and Coastal Park statements for Ponto are just words on paper that are designed to have no force, no comm itment, no defined outcome, and no defined requirement to even have an outcome regarding the

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documented "High-Priority" Coastal Recreation and Costal Park needs at Ponto, Coastal South Carlsbad and the regional 6-mile Coastal Park gap centered around Ponto .

Policy LCP-2-P.19 falsely says it "promotes development of recreational use" but does not in fact do that. How is development of 'recreational use promoted' when the Use is both ,unmapped and no regulatory policy requirement and commitment (no "shall" statement) to 'promote' that Use is provided? Policy LCP-2-19.19 appears a misleading sham that does not 'promote' or require in any way "High-Priority" Coastal Recreation and Park Land Use at Ponto.

There should be open and honest public workshops before the Draft LCP Amendment goes to its first public hearing to clearly define the major environmental constraints and cost estimates involving possible relocation of Carlsbad Boulevard and constructing needed beach access parking, and sufficient and safe sidewalks and bike paths along Carlsbad Boulevard; and then map the amount and dimensions of potential 'excess land' that maybe available for possible designation as Open Space in the City General Plan and Local Coastal Program. The City should not repeat the mistakes at the Carlsbad Municipal Golf Course (resulting in the most expensive to construct maniple course in the USA) by not defining and vetting the concept first. A preliminary review of City GIS data appears the amount, dimensions and locations of any potential 'excess' land maybe modest at best. However before the City proposes a 'Buildout' Coastal Land Use Plan this critical information should be clearly provided and considered. It is likely the City's Carlsbad Boulevard relocation concept is unfeasible, inefficient, too costly, and yields too little actual useable 'excess land' to ever approach the Coastal Recreation and Coastal Park needs for South Carlsbad. This may already be known by the City, but it surely should be publicly disclosed and discussed in the DLPCA.

The proposed Coastal Land Use Plan to address Carlsbad's, San Diego County's and California's High-Priority Coastal Recreation Land Use and Coastal Park needs should NOT be vague "may" policy that appears to be purposely designed/worded to not commit to actually providing any "High-Priority" Coastal Recreation and Coastal Park land uses on the map or in policy commitments. The Land Use Plan and Policy for High-Priority Coastal Recreation and Coastal Park Land Use should be definitive with triggered "shall" policy statements requiring and assuring that the 'Forever' "High-Priority" Coastal Recreation and Coastal Park needs are properly and timely addressed in the City's proposed 'Buildout' Coastal Land Use Plan. This "shall" policy commitment should be clearly and consistently mapped to show the basic feasibility of the planned outcomes and the resulting actual Land that could feasibly implement the planned outcome.

Providing safe and sufficient sidewalks, bike paths, and public parking along Carlsbad Boulevard: Providing safe and sufficient sidewalks, bike paths, and public parking along Carlsbad Boulevard are Coastal Access and Completes Streets issues. South Carlsbad Boulevard now and has for decades been a highly used Incomplete Street that is out of compliance with the City's minimum Street Standards for pedestrian and bike access and safety. The Coastal Access portion of the Draft Land Use Plan should strongly address the Complete Street requirements for South Carlsbad Boulevard. Those policy commitments should be reference in Policy LCP-2-P.19 and 20 as Carlsbad Boulevard in South Carlsbad is the most Complete Street deficient portion of Carlsbad Boulevard. Forever Coastal Access parking demand and the proposed LCP Amendment's Land Use Plan to supply parking for those demands should also be addressed as part ofthe Coastal Access and Complete Streets issues for South Carlsbad Boulevard . If much needed Coastal Access Parking is provided on South Carlsbad Boulevard as part of a "maybe" implemented realignment, most of the "maybe" realignment land left after constraints are accommodated for and buffered will likely be consumed with these parking spaces and parking drive aisles/buffer area needed to separate high-speed vehicular traffic from parking, a buffered bike path, and a sufficiently wide pedestrian sidewalk or Coastal Path.

After accommodating these much needed Complete Street facilitates there will likely be little if any sufficiently

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dimensioned land available for a Coastal Recreation and a Coastal Park. The needed Coastal Access and Complete Street facilities on South Carlsbad Boulevard are very much needed, but they are NOT a Coastal Park.

As ment ioned the proposed Draft Coastal Land Use Plan's Maps and Policies are very specific in provid ing for the City's proposed LCP Land Use changes to 'low-priority" Residential and General Commercial' on Planning Area F (proposed to be renamed to Area 1 and 2). It is curious as to why the proposed Draft LCP Land Use Plan Amendment has no Land Use Map and minor vague unaccountable Land Use Policy concerning 'High-priority Coastal Recreation Land Use' at Ponto, while the very same time proposing very clear Land Use Mapping and detailed unambiguous "shall" land use policy requirements for 'low-priority" Residential and General Commercial land use at Ponto. Why is the City Not committing and requiring (in a Land Use Map and Land Use Policy) to much needed 'High-priority" Coastal Recreation and Coastal Park Land Use' needs at Ponto the same detail and commitment as the City is providing for "low-priority" uses? This is backwards and inappropriate. It is all the more inappropriate given the 'Buildout' Coastal Land Use Plan the City is proposing at Ponto. These issues and plan/policy comm itments and non-commitments will be 'forever' and should be fully and publicly evaluated as previously requested, or the Exiting LCP Land Use Plan of "Non -residential Reserve" for Planning Area F should remain un~hanged and until the forever-buildout Coastal Recreation and Coastal Park issues can be clearly, honestly and properly considered and accountably planned for. This is vitally important and seems to speak to the very heart of.the CA Coastal Act, its founding and enduring princip les, and its policies to maximize Coastal Recreation. People for Ponto and we believe many others, when they are aware of the issues, think the City and CA Coastal Commission should be taking a long term perspective and be more carefu l, thorough, thoughtful, inclusive, and in the considerat ions of the City's proposal/request to permanently convert the last vacant unplanned (Non-residential Reserve) Coastal "land at Ponto to "low-priority" land uses and forever eliminate any Coastal Recreation and Coastal Park opportunities.

14. Public Coastal View protection: Avenida Encinas is the only inland public access road and pedestrian sidewalk to access the Coast at Ponto for one mile in each direction north and south. It is also hosts the regional Coastal Rail Trail in 3' wide bike lanes. There exist now phenomenal coastal ocean views for the public along Avenida Encinas from the rail corridor bridge to Carlsbad Boulevard. It is assumed these existing expansive public views to the ocean will be mostly elim inated with any building development seaward or the Rail corridor. This is understandable, but an accountable ('shall") Land Use Plan/Policy addition to proposed Policy LCP-2-P.20 should be provided for a reasonable Public Coastal View corridor along both sides of Avenida Encinas and at the intersection with Carlsbad Boulevard. Public Coastal view analysis, building height-setback standards along Avenida Encinas, and building placement and site design and landscaping criter ia in policy LCP-2-P.20 could also considered to reasonably provide for some residual public coastal view preservation.

15. Illogical landscape setback reductions proposed along Carlsbad Boulevard, and Undefined landscape setback along the Lagoon Bluff Top and rail corridor in Policy LCP-2-P.20: Logically setbacks are used in planning to provide a buffering separation of incompatible land uses/activities/habitats. The intent of the setback separation being to protect adjacent uses/act ivities/habitats from incompatibility, nuisance or harassment by providing a sufficient distance/area (i.e. setback) between uses/act ivities/habitats and for required urban design aesthetics - almost always a buffer ing landscaping. Policy LCP-2-P.20. A.4 and C.3 says the required 40' landscape setback along Carlsbad Boulevard "maybe reduced due to site constraints or protection of environmental resources." The ability to reduce the setback is illogical in that setbacks are intendent to protect environmental resources and provide a buffe r for constraints. In the Carlsbad Boulevard right-of-way there is documented sensitive environmental habitat, along with being a busy roadway. How could reducing the protective 40' setback in anyway bette r protect that habitat or provide a better landscaped compatib ility or visual aesthesis buffer along Carlsbad Boulevard? It is

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illogical. If anything the minimum 40' landscaped setback should likely be expanded near "environmental resources". Regarding reducing the minimum 40' landscape setback for "site constraints" there is no definition of what a "site constraint" is or why it {whatever it may be) justifies a reduction of the minimum landscaped setback.

Is endangered species habitat, or a hazardous geologic feature, or a slope, or on-site infrastructure considered a "site constraint"? There should be some explanation of what a "site constraint" is and is not, and once defined if it warrants a landscape setback reduction to enhance the buffering purpose of a landscape setback. Or will a reduction only allow bringing the defined constraint closer to the adjacent uses/activities/habitats that the landscape setback is designed to buffer. It is good planning practice to not only be clear in the use of terms; but also, if a proposed reduction in a minimum standard is allowed, to define reasonably clear criteria for that reduction/mod ification and provide appropriate defined mitigation to assume the intended performance objectives of the minimum landscape setback are achieved.

Policy LCP-2-P.20.C.4 is missing a critical Bluff-Top landscape setback. It seems impossible that the DLCPA is proposing no Bluff-Top setback from the lagoon bluffs and sensitive habitat . The Batiquitos Lagoon's adjoining steep sensitive habitat slopes directly connect along the Bluff-top. Batiquitos Lagoon's and adjoining steep sensitive habitat is a sensitive habitat that requires significant setbacks as a buffer from development impacts. Setbacks similar to those required for the San Pacifico area inland of the rail corridor, should be provided unless updated information about habitat sensitivity or community aesthetics requires different setback requirements.

Policy LCP-2-P.20 does not include a landscape setback standard adjacent to the rail corridor. This is a significant national transportation corridor, part of the 2nd busiest rail co.rridor in the USA. Train travel along this corridor is planned to increase greatly in the years to come. Now there is significant noise, Diesel engine pollution, and extensive ground vibration due to train travel along the rail corridor. Long freight trains which currently run mostly at night and weekends are particularly noisy and heavy, and create significant ground vibration {underground noise).

These issues are best mitigated by landscape setbacks and other buffers/barriers. A minimum setback standard for sufficient landscaping for a visual buffer and also factoring appropriate noise and ground vibration standards for a buildout situation should be used to establish an appropriate landscape setback that should be provided along the rail corridor. Carlsbad's landscape aesthetics along the rail corridor should be factored into how wide the setback should be and how landscaping should be provided. An example for the landscape aesthetic portion of the setback standard could be landscape design dimensions of the San Pacifico community on the inland side of the rail corridor .

However, noise and vibrationa l impacts at San Pacifico are felt much further inland and appear to justify increased setbacks for those impacts.

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March 1111\ 2022
Carlsbad City Council
1200 Carlsbad Village Drive
Carlsbad, CA 92008
Re: Support creation of Ponto Park - a needed park for South Carlsbad Dear Mayor Hall,
The Trust for Public Land (TPL) is strongly supporting the efforts of 'People for Ponto' and thousands of Carlsbad residents to bui ld Ponto Park in the 11-acre coastal parcel known as 'Planning Area F' in South Carlsbad. For over 40-years TPL has been designing and building parks in California and although we have world -class parks and beaches, the fact remains 3.2 million Californians don't have access to a ark, and some of those Californians are residents of South Carlsbad. While the National Recreation and Park Association calls for 10-acres of park lands per 1000 residents as standard metric for healthy and vibrant cities, Carlsbad has a comparat ively and relatively low park standard of only 3-acres/1,000 population and no requirement to provide accessible parks within walking distance.

And according to our own Trust for Public Land 2020-21 'City Parkscore', Carlsbad is also below national averages both providing park land acreage and in providing residents a park within a 10-minute walk.

The City of Carlsbad's Park Master Plan on pages 86-89 documents park service and park equity/inequity. Carlsbad's Park Master Plan documents that Ponto area has no park and all of South Carlsbad (over 61% of the entire city population) has no Coastal Park while . Carlsbad provides 10 City Coastal Parks (totaling over 35-acres) in North Carlsb~d, while South Carlsbad has no coastal parks to serve the 64,000 residents, many of which are children. Ponto Park at 11-acre Planning Area F is the last remaining reasonable bit of vaca nt and currently unplanned Coastal land to provide a Coastal Park for South Carlsbad. Ponto Park would also be in the middle of a 6-mile long section of North San Diego County coastline without Coastal Park, and would help address a regional. need for a Costa! Park for these 6-miles of coastline.

The CA Coastal Act has numerous policies that support the creation of Ponto Park and Coastal Recreation land use. The City of Carlsbad's history of following these CA Coastal Act polies now and over the past 40-years in its Local Coastal Program should be considered now in the City's proposed Local Coastal Program Amendment. Over the past 40-years Carlsbad and California residents have forever lost numerous opportunities to create vital Coastal Parks and Coastal Recreation for our growing population.

In addition to the clear need for coastal parks in South Carlsbad, the citizens are overwhelmingly supporting the creation of Ponto Park in Planning area F. As you know during the past 2-years during the City Budget and Local Coastal Program Amendment processes, residents strongly demonstrated their desire that the City Council purchase and build Ponto Park. In 2019, 2020 and 2021 over 90% of citizen input expressed need was for Ponto Park, along with extensive verbal and written citizen testimony.

As COVID-19 vividly pointed out, parks are not an amenity, but a key component to human physical and mental health. Parks also provide environmental benefits and contribute to cleaner air and water, climate adaptation and social cohesion. TPL think you have a great opportunity to address equity and access to park space and improving the lives of thousands of Carlsbad residents and strongly urge you to support the building of Ponto Park for families and community.

Sincerely.

Rico Mastrodonato
Government Relations Director
History of the false exemption ofthe Growth Management Open Space Standard provided Ponto developers in Local Facility Management Plan Zone 9 (LFMP-9}:

The history of how required Growth Management Open Space (i.e. unconstrained/developable land) that should have been dedicated Open Space was, and is now being proposed to be, inappropriately converted to Residential land use by a Perpetuating a False Exemption of the Open Space Standard provided Ponto Developers. This False Exemption needs correction and restitution. Ponto's False Exemption of the Open Space Standard and the 'amendment shell-game' GM Open Space history is a critical warning sign to the Carlsbad Tomorrow Growth Management Committee, Planning Commission and City Council. Ponto is a critical warning that a strong, accountable and accurate Open Space Standard needs to be established for Carlsbad Tomorrow, AND a Growth Management Open Space restitution plan needs to be established and funded that corrects the False Exemption for Ponto Developers. If Ponto Developers were required like other similar developers at the time (Aviara and Poinsettia Shores, "urbanizing La Costa Zones 11 & 12, etc.) to provide the required Growth Management Open Space some of the critical Coastal Recreation and Coastal Park issues and extensive Carlsbad Citizen needs/demands/desires at Ponto could likely have already been addressed.

How citizens found out about the False Exemption provided Ponto Developers:

In 2017 for the l't time the city provided the GIS maps/data base accounting of Open Space in the City.

The City did this a part of settlement to a North County Advocates citizens' lawsuit. The City Open Space maps/data base allowed Carlsbad Citizens for the 1st time the ability to see and confirm what Open Space was produced by Growth Management (GM). The City's Open Space map/data based for Ponto (LFMP-9) documented that about 30-acres of GM Open Space was missing (see; Carlsbad Official Public Records Request - PRR 2017-164). As required by GM, and as Staff has said, to count as GM Open Space it must be dedicated and 'unconstrained/developable land' to meet the GM Open Space Standard.

Being able to see for the 1st time the missing GM Open Space was one of the key awakenings that started People for Ponto Carlsbad Citizens. Below is the City's Open Space Map for LFMP-9, with notes.

We have the City's parcel-based Open Space data base that confirms all the numerical data in the notes.

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City GIS map of Ponto's {LFMP Zone 9)
Open Space:
• Light green areas meet the City's 15%
unconstrained Growth Management
Program Open Space Standard
• Most Ponto Open Space (pink hatch &
blue [water] on map) is "Constrained"
and does not meet the Standard
Aviara • Zone 19, Ponto - Zone 9 and
Hanover/Poinsettia Shores - Zone 22
all developed around the same time
and had similar vacant lands.
• City required Aviara - Zone 19 east of
Ponto to provide the 15% Standard
Open Space. Why not Ponto? Aviara
had the same lagoon waters.
• City required Hanover & Poinsettia
Shores area Zone 22 just north of
Ponto to provide the 15% Standard
Open Space. Why not Ponto?
•
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Why Ponto developers were never
required to comply with the 15%
Standard Open Space is subject to
current litigation
~ •""""""'"'- • Below is City GIS data from this map
City GIS map data summary of the 15% Growth Management Standard Open Space at Ponto 472 Acres
(197 Acres)
275 Acres
X 15%
41 Acres
(11 Acres)
30 Acres
Total land in LFMP Zone 9 [Ponto]
Constrained land excluded from GMP Open Space
Unconstrained land in LFMP Zone 9 [Ponto]
GMP Minimum Unconstrained Open Space requirement
GMP Minimum Unconstrained Open Space required
GMP Open Space provided & mapped per City GIS data
Missing Unconstrained Open Space needed in LFMP Zone 9 [Ponto] to meet the City's minimum GMP Open Space Standard per City's GIS map & data 73% of the City's minimum 15% required Open Space Standard is missing due to over development of LFMP Zone 9 [Ponto]
So were did the missing GM Open Space go?
In early 1985 prior to the Ponto's developer {SAMMIS) annexing Ponto into the City of Carlsbad, San Diego County's LAFCO {local agency formation commission) General Planned and pre-zoned, Ponto's Batiquitos Lagoon waters and the lagoon bluff slopes as Open Space. This Open Space was "Constrained Open Space" - State jurisdictional waters, and steep slopes with Coastal Sage Scrub {CSS) habitat. These already pre-zoned constrained/non-developable Open Spaces were accounted for as part of the City's 25% pre-Growth Management Plan Open Space, and per Growth Management can't be counted in meeting the 15% Growth Management Open Space Standard. The pre-zoned Open Space is shown in the City's Open Space map and properly marked as "Preservation of Natural Resources" Open Space land. This already pre-zoned Constrained (non-developable, aka 'Preservation of Natural Resources'} Open Space land at Ponto was documented in the proposed SAMMIS Batiquitos Lagoon Educational Park {BLEP) Master Plan MP-175 as Areas N, 0, and Pin the Land Use Summary below.

On Oct, 11985 Carlsbad approved SAMIS's Master Plan and EIR to develop Ponto. SAMIS's BLEP Master Plan MP-175 . Following are BLEP MP-175's General Plan & Land Use Summary maps:

GENERAL PLAN
TSJC
iRA vel SERVICE CO>NJ.ERCIAL

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EXHIBIT 1-C

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CONCEPTUAL

LAND USE SUMMARY
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The BLEP MP-175 did include a variety of GM compliant Open Space.

EXHIBIT!lf-13
• 12.8 acre Recreation Commercial land use that was playfields and Coastal Recreation site for MP-175 and South Carlsbad. This is a Critical GM Open Space that was never dedicated. • A minimum 30' wide landscaped Open Space on both sides of Windrose Circle that circled the Area P. Windrose Circle was bordered on each side by 30' of landscaped Open Space. • Additional minimum 30' wide landscaped setbacks between buildings in Area A • 2.8 acres of private recreation open space for the maximum amount of residential units • 45' to 50' landscaped setbacks from the Batiquitos Lagoon Bluff edge (this was later developed with Residential land use in some areas of Ponto}.
• 75' landscaped separation between Areas C and D
• 70' landscaped separation between Areas D and E
• 25' landscaped setback along Avenida Encinas for Area E • 30' to 80' landscape setback between Lakeshore Gardens and Area F • 25' landscaped setback along Avenida Encinas for Area F • 50' landscaped setback between Areas F and I
• 75' landscaped separation between Areas G and H
• 50' to 80' landscape setback for Area I between Lakeshore Gardens and between Area F

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So, prior to Ponto being annexed into the City of Carlsbad in the mid-1980's and prior to Growth Management the Batiquitos Lagoon and lagoons bluff slopes (constrained and unusable due to habitat and slope constraints) were already pre-zoned Open Space and General Planned as Constrained Habitat Open Space. This constrained Open Space did not and cannot meet the 15% GM Open Space Standard.

In 1986 Citizens voted for the City's version of Growth Management that included at New Standard for Useable Open Space. The new standard was that 15% of all unconstrained useable/developable 'land within a Local Facility Management Zone was to be dedicated as Open Space. Once the vote was in the City adopted the Growth Management Ordinance 21.90 of Carlsbad's Municipal Code (City Council Ordinance No. 9791. (Ord. 9829 § 1, 1987; Ord. 9808 § 1, 1986)).

In adopting the Growth Management Ordinance 21.90.010 the Council Clearly stated:
(b) The city council of the city has determined despite previous city council actions, including but not limited to, amendments to the land use, housing, and parks and recreation elements of the general plan, amendments to city council Policy No. 17, adoption of traffic impact fees, and modification of park dedication and improvement requirements, that the demand for facilities and improvements has outpaced the supply resulting in shortages in public facilities and improvements, including, but not limited to, streets, parks, open space, schools, libraries, drainage facilities and general governmental facilities. The city council has further determined that these shortages are detrimental to the public health, safety and welfare of the citizens of Carlsbad.
(c) This chapter is adopted to ensure the implementation of the policies stated in subsection (a), to eliminate the shortages identified in subsection (b), to ensure that no development occurs without providing for adequate facilities and improvements, ... " The Citizens and Council recognized that prior City plans were not adequate to address the current (and future) needs for facilit ies. Upon adoption of the New Growth Management Standards certain facilities were already below-Standard simply based on the existing development and population. Growth Management required additional facilities simply to bring the then current development/population up to the New Minimum Standards. I am personally familiar with 3 GM Standards in LFMP-6 {old La Costa) that I worked on - Library, Fire, and Park where already below-Standard i.e. existing development/population in Old La Costa required more facilities to meet the new Growth Management Standards. We worked to provide these new facilities for the existing development/population (i.e. fix the Standard deficits) and then to also plan even more additional facilities at a ratio that met the New Standards for the additional future development in Old La Costa. I can provide you some interesting stories on that.

I also recall working on the surrounding La Costa LRMP Zones 11 & 12 that Like Ponto/FMP-9 were considered "Cat II: Urbanizing" yet Unlike Ponto/LFMP-9 LFMP Zone 11 & 12 were not falsely exempted

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Carlsbad City CouncilJuly 18, 2023

Carlsbad City Council
July 18, 2023