Carlsbad City Council
July 18, 2023

for the GMP Open Space Standard and had to provide the GM Open Space Standard of 15% of the unconstrained/developable lands as dedicated Useable Open Space.

The Citizens vote on Proposition E and the subsequent Growth Management Ordinance 21.90 are the rules on which the Growth Management Plans (both Citywide and 25 Local Facility Plans) are required to follow.

To create the Citywide and the Local plans (Zones 1-6) for the largely developed areas the City needed to temporarily pause development activity to allow time for city staff to Draft the Growth Management Plan (my work as a city planner at the time was re-directed to draft growth management plans). So the Growth Management Ordinance 21.90.030, established a Temporary Development Moratorium to pause development processing activity while the Growth Management Plan was being Drafted.

Following is that language of 21.90.030. Notes are shown as italicized text within [example]:
"21.90.030 General prohibition-Exceptions.
(a) Unless exempted by the provisions of this chapter, no application for any building permit or development permit shall be accepted, processed or approved until a city-wide facilities and improvements plan has been adopted and a local facilities management plan for the applicable local facilities management zone has been submitted and approved according to this chapter. [Clearly indicates the exemptions in 21.90.030 are only from the temporary development moratorium created by 21.90.J
(b) No zone change, general plan amendment, master plan amendment or specific plan amendment which would increase the residential density or development intensity established by the general plan in effect on the effective date of this chapter shall be approved unless an amendment to the citywide facilities management plan and the applicable local facilities management plan has first been approved. [FYI, this provision of 21.90.030 has direct implications with respect of currently City/developer proposed General Plan/Zoning code/Local Coastal Program Amendments now being pursued by the City at Ponto Planning Area F and Ponto Site 18. The City did not and has not yet amended the CFMP and LFMP-9 to increase the City/developer proposed residential density or development intensity at Ponto] (c) The classes of projects or permits listed in this subsection shall be exempt from the provisions of subsection (a). Development permits and building permits for these projects shall be subject to any fees established pursuant to the city-wide facilities and improvement plan and any applicable local facilities management plan. [Then lists various exemptions from the temporary development processing/building permit moratorium in 21.90. The BLEP MP's exemption from the temporary moratorium is {g)]
(g) The city council may authorize the processing of and decision making on building permits and development permits for a project with a master plan approved before July 20, 1986, subject to the following restrictions [this only applies to the "approved before July 20, 1986" BLEP MP, and NOT to any subsequent Master Plan Amendment]:

(1) The city council finds that the facilities and improvements required by the master plan are sufficient to meet the needs created by the project and that the master plan developer has agreed to install those facilities and improvements to the satisfaction of the city council. [The Ponto developer needed to provide the 12.8 acre Recreation Commercial land use and install the GM compliant Open Space required in the 1986 MP175 but did not] (2) The master plan developer shall agree in writing that all facilities and improvement requirements, including, but not limited to, the payment of fees established by the city-wide facilities and management plan and the applicable local facilities management plan shall be applicable to development within the master plan area and that the master plan developer shall comply with those plans. [this required the LFMP-9/BLEP MP to have 1) already been fully developed or 2) have already have dedicated 15% of the LFMP-9 as Growth Management compliant Open Space (i.e. Unconstrained and developable) to qualify for the Open Space exemption later falsely noted in the city-wide facilities and management plan. As clearly documented (he BLEP MP did not meet the requirements to qualify for Open Space Standard Exemption in the city-wide facilities and management plan. · The section also requires "all facilities" (including Open Space) requirements in the Citywide Growth Management Standard to apply to BLEP MP, not provide a means for a false exemption of the Open Space Standard] (3) The master plan establishes an educational park and all uses within the park comprise an integral part of the educational facility. ["all uses" including the 12.8 acre Recreation Commercial land use and all the other GM compliant Open Spaces are an integral part.

However the 12.8 acre c>pen space land use was never built and the BLEP MP GM compliant Open Space never dedicated.]
(4) Building permits for the one hundred twenty-nine [129] unit residential portion of Phase I of the project may be approved provided the applicant has provided written evidence that an educational entity will occupy Phase I of the project which the city council finds is satisfactory and consistent with the goals and intent of the approved master plan. {Clearly indicates the 21.90.030 exemption is only for building permits for Phase I of the BLEP MP. Of the 129 units only the 75 unit Rosalena development applied for and received building permits under this exemption. There are some very interesting issues related to this Rosalena Phase I development relative to GM complaint Open Space along the bluff edge that can be expanded on later if the CTGMC has questions.]
(5) Prior to the approval of the final map for Phase I the master plan developer shall have agreed to participate in the restoration of a significant lagoon and wetland resource area and made any dedications of property necessary to accomplish the restoration. [Again clearly notes the exemption only allows a final map for Phase I to be processed. The "lagoon and wetland resource area" are part of the same constrained/undevelopable lands already pre-zoned prior to the BLEP MP being incorporated into the City of Carlsbad]"

The Aviara Master Plan (directly adjacent and east of Ponto) and was also being developed at the same time as Ponto/BLEP MP. 21.90.030 also provided the Aviara Master Plan a similar exemption (h) and similar lagoon related quid-pro-quo for that exemption . But Aviara did not receive a GM Open Space Standard Exemption. :
"(iv) Prior to any processing on the [Aviara] master plan the applicant shall grant an easement over the property necessary for the lagoon restoration and the right-of-way necessary for the widening of La Costa Avenue and its intersection with El Camino Real. (Ord. NS-63 § 1, 1989; Ord. 9837 § 1, 1987; Ord. 9808 § 1, 1986)"
Some City staff have incorrectly stated to the City Council that they believe 21.90.030 exempts Ponto/LFMP-9 from the Growth Management Ordinance/Prbgram or Growth Management Open Space Standard. RESOLUTION NO. 8666- A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD, CALIFORNIA APPROVING TWO AGREEMENTS FOR BATIQUITOS LAGOON EDUCATIONAL PARK also shows the 21.90.030 exemption was only for development permits during the temporary building moratorium .

In 1986 the City falsely exempted in the Citywide Facilities Plan all Ponto developers from providing 15% oftheir useable/developable land as GM required Open Space. The City's documented/adopted rational in the Citywide Plan was that Ponto/LFMP-9 was 1) in 1986 already developed, or 2) in 1986 the developer had already met the GM Open Space Standard by having already dedicated 15% of the useable land as Open Space. Both situations were/are false. Any air photo map or even the 1986 LFMP- 9 clearly states Ponto was NOT developed in 1986, as only the Lakeshore Gardens existed and the Ralphs Center was just starting construction. Also the City's GIS Open Space mapping (see above) shows that SAMMIS the Ponto developer (BLEP Master Plan MP-175) in 1986 had Not dedicated as Open Space 15% of the useable land as Growth Management compliant Open Space as shown/described in the BLEP MP (i.e. the 12.8 Acre Recreation Commercial site and all the landscaped open space setbacks required in the BLEP MP-175. If that 15% was dedicated in 1986 it would show -up on the City's inventory of Dedicated Open Space now. So how did this occur?
How Ponto's planned GM Open Space was eliminated and replaced with Residential land use:

In late 1980's SAMMIS the BLEP MP-175 developer started building the 75-home Rosalena Development as the first part of Phase I of the BLEP MP. The City (based on my recollection was very desirous to develop the BLEP MP) and required special time limits on the BLEP MP to actually advanc~ building the 'Educational Park' with all the "in itiated" land uses (including GM compliant Open Space) within a certain per iod of time. SAM IS was having financial issues and difficulty delivering the BLEP MP land uses. Amendments (A, B, and C) to BLEP MP reflected on these difficulties :
• MP 175(A) to allow mino r accessory structures within the rear yards of all Phase I single family lots located in Planning Area "C". {This is the Rosalena development that was part of Phase I for BLEP MP. This amendment has implications on the landscaped Open Space setback along the Batiquitos Lagoon bluff top, and the required Coastal access trail required by the Coastal

Development Permit for Rosalena. This is an interesting history that can be explained later if the CTGMC would like.]
• MP 175(8) to realign Carlsbad Blvd., between North Batiquitos Lagoon and west of 1-5 to accommodate the Sammis Development was WITHDRAWN January 12, 1990, and • MP 175(() a request for 5-year extension oftime for Master Plan approva l related to educational uses on this project was Approved Planning Commission Resolution No. 2841, April 19, 1989 and approved City Council Ordinance No. NS-83, September 5, 1990.

SAMMIS went bankrupt around 1990 and Kaiza Development purchased the BLEP MP. Kaiza completed the Rosalena development started by SAMM IS. Kaiza then sought to completely change the planned land uses on all the remaining unconstrained/developable land in the BLEP MP.

General Plan and Master Plan Amendments eliminated/reduced BLEP's Growth Management compliant Open Space and replace with Residential uses in the "amended" Poinsettia Shores Master Plan:

When Kaiza acquired the BLEP MP-175 and its vacant land only the State Campground, Lakeshore Gardens, Ralphs Center, and now Rosalena were approved/existing developments at Ponto. Kaiza proposed a Master Plan Amendment to delete the BLEP MP-175 and all its developable land uses, except for the only portion of Phase I developed -the 75 unit Rosalena subdivision. The pre-BLEP MP pre-zoned (and General Planned) constrained/undevelopable Lagoon waters and lagoon bluff Open Spaces and the CA Coastal Act (LCP) required bluff top setbacks were the only Open Spaces retained in Kaiza's proposed General Plan land use and Master Plan Amendments.

Most all of the BLEP MP-175 (and Ponto/LFMP-9) land area was still undeveloped at the time Kaiza proposed changing all the General Plan land uses at Ponto and eliminating the usable Open Space in BLEP MP.

Kaiza's General Plan land use and Master Plan 'Amendments' made radical land use changes that converted some critical Useable GM Open Space to residentia l land use and also reduced some GM Open Space provided in BLEP MP. Following is Kaiza's Amended General Plan land use map and bullet summary of the major Open Space changes without getting into a very detailed forensic analysis:
• Eliminated the 12.8 acre Recreation Commercial land use. • Eliminated the minimum 30' wide landscaped Open Space on both sides of Windrose Circle for the large unbuilt portions of Windrose Circle
• Reduced by 10' the landscaped Open Space on the smaller built portion of Wind rose Circle • Eliminated on 40.3 acres the additional minimum 30' wide landscaped setbacks between buildings
• Reduced BLEP's 2.8 acres of private recreation open space to 2.3 acres • Except for the Rosalena (BLEP Area C) and (PSMP Area J), maintained the 45' to 50' landscaped setbacks from the Batiquitos Lagoon Bluff edge
• Eliminated the 75' landscaped separation between BLEP MP Areas C and D

• Eliminated the 70' landscaped separation between BLEP MP Areas D and E • Maintained the 25' landscaped setback along Avenida Encinas. [However new Master Plan Amendments MP-175L propose reducing the setback to 10' on the undeveloped frontage of Avenida between PCH and the railroad tracks]
• Placed a road in most of the 80' landscape setback between Lakeshore Gardens • Eliminated the 50' landscaped setback between BLEP MP Areas F and I • Eliminated the 75' landscaped separation between BLEP MP Areas G and H • Added a 20' wide by 1,000' long landscaped strip for an HOA tra il ArPRu ....

GROSS AC.

9.8 13.S

10.2 14.7

20.9 2.9

11.2 4.4

0.9 11.3

8.4 3.7
lf.9

13.8 18.3

4.6 2.3
Kaiza's Master Plan Amendment MP 175 (D) eliminated the 12.8 acre Open Space land use (with an associated General Plan Amendment to add more residential land use) and reduced the other useable Open Spaces required in the BLEP MP. When the 1994 Kaiza MP 175 (D) General Plan Amendments were proposed, it seemed they voided the '1986 GM Open Space exemption' that was clearly specific only to the 1986 BLEP MP land uses and regulation. Although this was a false exempted, the exemption only applied to the _complete/integrated land use and open space provided in the 1986 BLEP MP. The 1986 exemption specific to BLEP MP could not apply to a different and later 1994 General Plan land use plan that eliminated the 12.8 acre Recreation Commercial (Open Space) site to add residential land use

and that also reduced the GM compliant Open Space provided in the 1986 BLEP MP. 21.90.030(b) notes that:
"(b) No zone change, general plan amendment , master plan amendment or specific plan amendment which would increase the residential density or development intensity established by the general plan in effect on the effective date of this chapter shall be approved unless an amendment to the citywide facilities management plan and the applicable local facilities management plan has first been approved."
The 1994 Kaiza General Plan land use and Master Plan (MP 175(D)) Amendments removed 12.8 acres of Recreation Commercial (GM compliant Open Space) to add residential land use. This violated

21.90 .030(b) by doing so without a first providing a Citywide Facilities Plan Amendment that analyzed the actual amount of GM compliant Open Space being proposed in the 1994 Kaiza MP 175(D) relative to the 1986 BLEP MP on which the 1986 GM Open Space exemption for LFMP-9 was based. MP 175(D) is noted in the MP as follows :
• "MP 175 (D) Kaiza Poinsettia Master Plan To replace educational uses with residential land uses And rename to Poinsettia Shores Master Plan (was) Approved Planning Commission Resolution No. 3552, November 3, 1993, Approved City Council Ordinance No. NS-266, January 18, 1994." Kaiza's MP 175(D) inaccurately and bizarrely claimed BLEP MP's prior false exemption from the GM Open Space Standard as the justification that Kaiza's new 1994 Open Space land use changes that seem to reduce the amount of GM complaint Open Space in the 1986 BLEP MP are also exempt from the GM Open Space Standard. Kaiza's MP 17S(D) claims the pre-Growth Management and pre-BLEP MP Constrained/Undevelopable lagoon waters and bluff habitat that per the 15% Growth Management Open Space Standard CAN NOT be counted as meeting the 15% GM Open Space Standard can be magically counted as meeting the 15% GM Open Space Standard. The GM Open Space Standard specifically states that only Unconstrained/Developable lands CAN BE counted as meeting the GM Open Space Standard. The stated principles of Growth Management, the Growth Management Ordnance 21.90 and the Growth Management Open Space Standard DO NOT allow a developer or the City to count already documented Constrained and unbuildable habitat (and water) as Unconstrained and developable land. You can't just turn 'an apple into a banana by saying it', or turn 'Constrained/Undevelopable land into Unconstrained/Developable land by just saying it.

Compliance with the law in this Open Space issue is a part of a current lawsuit by North County Advocates a group of Citizens watchdogs. The City has unsuccessfully tried to diminish this lawsuit. A judge/jury will determine the outcome.

Additional MP 175 Amendments have been proposed by and approved to further modify land use and regulatory limitations at Ponto. These include :
• MP 175(E) Poinsettia Shores Master Plan, Redefinition of minor amendment to provide a flexible regulatory procedure to encourage creative and imaginative planning of coordinated communities, WITHDRAWN November 1, 1994

• MP 175(F) Poinsettia Shores Master Plan minor amendment to actualize off-site option for provision of 90 affordable housing dwelling units, Approved Planning Commission Resolution No.3774,April1~1995
• MP 175(G) Poinsettia Shores Master Plan minor amendment to adopt Coastal Commission Suggested modifications, Approved Planning Commission Resolution No. 3922, June 5, 1996 Approved City Council July 16, 1996, NS-367
• MP 175(H) Poinsettia Shores Master Plan - major amendment FOR HOTEL AND TIMESHARE USES, WITHDRAWN January 16, 2003
• MP 175(1) Poinsettia Shores Master Plan - Rosalena Trail Amendment, WITHDRAWN January 8,2002
• MP 175(J) Poinsettia Shores Master Plan - major amendment for Carlsbad Coast Residential project to allow RM land use on Poinsettia Shores, WITHDRAWN January 8, 2002 • MP 175 (K) Poinsettia Shores Master Plan - Ponto Area Specific Plan Mixed use consisting of residential, commercial and retail uses, WITHDRAWN August 19, 2004 • MP 175(L) Poinsettia Shores Master Plan - Major amendment for commercial and residential development on Planning Area F, Still being proposedjJy developers and being processed by the City.

The false exemption for the BLEP MP based LFMP-9 should never have occurred. However, completely eliminating BLEP MP's OpenSpace land use (12.8 acre Recreation Commercial) and reducing BLEP MP's required Open Space while at the same time claiming the false BLEP MP Open Space Exemption is a violation of common sense, 21.90, and the very founding principles Growth Management.

The CA Coastal Commission in MP 175 (G) in part recognized the elimination of the 12.8 acre Recreation Commercial land use and maybe some of the Open Space land use changes and added the following land use regulations for 11.1 acre Planning Area F in the Carlsbad's Local Coastal Program LCP). The LCP as per State Law and referenced in Carlsbad's General Plan is the controlling land use regulation over the General Plan, Poinsettia Shores Master Plan and in the Coastal Zone:
"PLANNING AREA F: Planning Area F is located at the far northwest corner of the Master Plan area west of the AT&SF Railway right-of -way. This Planning Area has a gross area of 11 acres and a net developable area of 10.7 acres. Planning Area F carries a Non-Residential Reserve (NRR) General Plan designation. Planning Area Fis an "unplanned" area, for which land uses will be determined at a later date when more specific planning is carried out for areas west of the railroad right-of -way. A future Major Master Plan Amendment will be required prior to further development approvals for Planning Area F, and shall include an LCP Amendment with associated environmental review, if determined necessary . . The intent of the NRR designation is not to limit the range of potential future uses entirely to nonresidential, however, since the City's current general plan does not contain an "unplanned" designation, NRR was determined to be appropriate at this time . In the future, if the Local Coastal Program Amendment has not been processed, and the City develops an "unplanned"

General Plan designation, then this site would likely be redesignated as "unplanned." Future uses could include, but are not limited to: commercial, residential, office, and other uses, subject to future review and approval.

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."
In 2010 the CA Coastal Commission in 2010 rejected the Ponto Beachfront Village Vision Plan on which MP 17S(K) was based. MP 175(K) was withdrawn.

On July 3, 2017 the CA Coastal Commission provided direction to the City of Carlsbad regarding MP 175(G), Carlsbad's 2015 General P,lan Update, Carlsbad proposed Local Coastal Program Amendment Land Use Plan (LUP) . CA Coastal Commission wrote to t~e City the following. Notes on the context of communication are in bracketed italics [example]:
"The existing LUP includes policies that require certain visitor-serving developments and/or studies relevant to the Ponto ... area. For example, Planning Area F requires the city and developer to "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 . ... this study should be undertaken as a part of the visitor serving use inventory analysis described above. [the discussion of the need for the City to conduct a citywide analysis of the location and amount of these uses in the Coastal Zone to assure the City General Plan within the Coastal Zone is providing the adequate amounts and locations of these land uses to fulfill the long-term population/visitor needs for these uses according to the CA Coastal Act] If this analysis determines that there is a deficit of low cost visitor accommodations or recreation facilities in this area, then Planning Area F should be considered as a site where these types of uses could be developed."
In 2017 the City conducted the first Sea Level Rise (SLR) Vulnerability Assessment https://www.carlsbadca.gov/civicax/filebank/b1obdload.aspx?Blob1D=33958 . That first initial analysis, shows significant SLR impacts that will reduce existing Ponto Open Space - the State beach and Campground and along the Batiquitos Lagoon. The City identified SLR impacts on Ponto Open Space are summarized in the next section of this history.

In 2023 the CA Coastal Commission will consider the data and public input and decide the appropriate land use for 11.1 acre Planning Area F ~ased the CA Coastal Act and Coastal Act land use policies.

You can determine the Open Space and Park Quality of Life Standards that will be applied to this and other future land uses.

City assessment of Sea Level Rise impacts on reducing Ponto Open Space

The City's 2017 SLR assessment shows SLR will significantly reduce or eliminate only existing Open Space land at Ponto. The City's assessment quantifies the speratic/episodic loss of Ponto/Coastal South Carlsbad Open Space land and land uses being at the State Campground, Beaches, and Batiquitos Lagoon shoreline - about 32 acres by the year 2100, this would be an average loss of 17,000 square feet of Open Space per year. Following (within quotation marks) is a description, quantification and images of the City's projected loss of Ponto/Coastal South Carlsbad Open Space land and land use due to SLR. {Italicized text within brackets] is added data based on review of aerial photo maps in the Assessment. "Planning Zone 3 consists of the Southern Shoreline Planning Area and the Batiquitos Lagoon. Assets within this zone are vulnerable to inundation, coastal flooding and bluff erosion in both planning horizons (2050 and 2100). A summary of the vulnerability assessment rating is provided in Table 5. A discussion of the vulnerability and risk assessment is also provided for each asset category.

5.3.1. Beaches
Approximately 14 acres of beach area is projected to be impacted by inundation/erosion in 2050 ....

Beaches in this planning area are backed by unarmored coastal bluffs. Sand derived from the natural erosion of the bluff as sea levels rise may be adequate to sustain beach widths, thus, beaches in this reach were assumed to have a moderate adaptive capacity. The overall vulnerability rating for beaches is moderate for 2050.

Vulnerability is rated moderate for the 2100 horizon due to the significant amount of erosion expected as the beaches are squeezed between rising sea levels and bluffs. Assuming the bluffs are unarmored in the future, sand derived from bluff erosion may sustain some level of beaches in this planning area. A complete loss of beaches poses a high risk to the city as the natural barrier from storm waves is lost as well as a reduction in beach access, recreation and the economic benefits the beaches provide.

5.3.3. State Parks
A majority of the South Carlsbad State Beach day-use facilities and campgrounds (separated into four parcels) were determined to be exposed to bluff erosion by the 2050 sea level rise scenario (moderate exposure). This resource is considered to have a high sensitivity since bluff erosion could significantly impair usage of the facilities. Though economic impacts to the physical structures within South Carlsbad State Beach would be relatively low, the loss of this park would be significant since adequate space for the park to move inland is not available (lo'vl( adaptive capacity). State parks was assigned a high vulnerability in the 2050 planning horizon. State park facilities are recognized as important assets to the city in terms of economic and recreation value as well as providing low-cost visitor serving amenities. This vulnerability poses a high risk to coastal access, recreatio n, and tourism opportunities in this planning area.
lfl 2100, bluff erosion of South Carlsbad State Beach day-use facilities and campgrounds become more severe and the South Ponto State Beach day-use area becomes exposed to coastal flooding during extreme events. The sensitivity of the South Ponto day-use area is low because impacts to usage will be temporary and no major damage to facilities would be anticipated. Vulnerability and risk to State

Parks remains high by 2100 due to the impacts to South Carlsbad State Beach in combination with flooding impacts to South Ponto.

Table 5: Planning Zone 3 Vulnerability Assessment Summary [condensed & notated]:

Asset
Category
Beaches
Public Access
State Parks
[Campground -
Low-cost Visitor
Accommodations]
See Figure 5.J
Transportation
(Road, Bike,
Pedestrian)
Horizon
[time] Hazard Type Impacted Assets
2050 Inundation/ Erosion, Flooding 14 acres (erosion)
2100 Inundation/Erosion , Flooding 54 acres (erosion)
2050 Inundation , Flooding
2100 Inundation, Flooding
6 access points
4,791 feet of trails
10 access points
14,049 feet of trails
Vulnerability
Rating
Moderate
Moderate
Moderate
Moderate
2050 Flooding, Bluff Erosion 4 parcels {<18 Acres] High 2100 Flooding, Bluff Erosion
2050 Bluff Erosion
2100 Flooding, Bluff Erosion
4 parcels {>18 Acres] High
[loss of over 50% of
the campground &
its Low-cost Visitor
Accommodations,
1,383 linear feet
11,280 linear feet
Moderate
High

Environmentally 2050 Inundation, Flooding 572 acres Moderate Sensitive 2100 Inundation, Flooding 606 acres High
Lands
" . , ....

---- ~-"AP.'2,:a..;;:,;.~ - -c."
fl!1,-.de-, - ,.~ - ~ ...
....
(cityof
Carlsbad
fXlflBITM
Seo Level Rise Vulnerobiltty Assessment
Figure 5: CoSMoS Bluff Erosion Projections by 2100
{CoSMoS -COAST 2015)

[Figure 5 show the loss of over 50% of the campground and campground sites with a minimal .2 meter Sea Level Rise (SLR), and potentially the entire campground (due to loss of access road) in 2 meter SLF.]" This 2017 SLR data and quantified losses of Ponto/Coastal South Carlsbad Open Space land and land uses was not considered in the City's rejected (by CCC) Ponto Beachfront Village Vision Plan. The Ponto Vision Plan is the basis for the City's 2015 General Plan Update that is now ~eing proposed in the City's local Coastal Program Amendment now befo re the CA Coastal Commission.

Summary:

LFPM-9 was clearly not developed in 1986, and did not then or now dedicate 15% of the unconstrained/developable land as Open Space as required by the Growth Manageme nt Open Space Standard. These two reasons for the City to "exempt" LFMP-9 from Open Space Standard were/are False. Saying Constrained/undevelopable land can be counted as Unconstrained/developable land is also false and clearly not allowed according to the Growth Management Ordinance, Standards, principles , and common -sense honesty to Carlsbad Citizens. LFMP-9, as the City's own maps/data base show is clearly missing 30-acres of GM Open Space. In addition in 2017 we learned that Ponto/Coastal South Carlsbad will lose about 32 acres of existing Open Space due to SLF.

Closing thoughts:

Growth Management is based on the type/amount/location of General Plan land use designations, the development potential of those land use designations in creating the demand for the type/amount/location of facilities, and supply of the type/amount/distribution of facilities - like Open Space and Parks. If the type/amount/location of supply of facilities does not meet the demand for those facilities then growth management fails and Quality of Life is reduced.

Quality of Life Standards are used to assure supply and demand for facilities is properly balanced with respect to type/amount/ location.

Ponto is clearly unbalanced. The Ponto Census Track is at a 40% higher population density than the rest of Carlsbad, yet is Ponto is NOT meeting the Open Space Standard and has NO Park (see City Open Space maps and Park Master Plan). Ponto and all South Carlsbad have higher population demand for Parks and Open Space facilities yet Ponto (that is the only place to provide Coastal Park and Open Space needs for South Carlsbad) has lower or none of those two most critical GM Facilities needed to balance and mitigate the 40% higher population density at Ponto and also the higher residential density in South Carlsbad.

Ponto and Coastal South Carlsbad also have additional State and regiona l responsibilit ies to provide Coastal Recreation and Open Space for populations of people and visito rs from outside of Ponto and Carlsbad.

This failure to honestly and adequately balance the type/amount/location higher population density by providing higher levels of Parks and Open Space in those areas will lead to a slow and but eventual reduction of the Quality of Life for those areas.

Common sense and the Carlsbad's Growth Management law say if you change the land use (like what was done and is still being proposed at Ponto) you change the type/amount/ location of potential development and population and the Growth Management impacts. Land use changes require and honest/accurate/balanced update to Citywide and Local Growth Management Plans to accurately reflect those changes and provide an updated plan to provide facilities that meet the Standards for those land use changes. This is the fundamental heart of any Growth Management.

The Carlsbad Tomorrow Growth Management Committee, and City Commissions and Council are all now facing the same issues and responsibility that we faced in the 1980's at the beginning of Growth Management. We established New Quality of Life Standards - for Open Space and Parks - that required New investments in Parks and Open Space by both the City and developers.

Open Space and Parks have always been identified as most critical for Carlsbad's quality of life. The Carlsbad Tomorrow Growth Management Committee, and City Commissions and Council, and Carlsbad Citizens are all at a critical crossroad.
• Do we, or don't we, enforce and set new standards that achieve the quality of life we desire? • Do we or don't we, fix existing past errors and below desired standard situations? • Do we or don't we, roll-up our sleeves a work together to a better Quality of Life? As a long-time Carlsbad Citizen I am extremely disappointed by some who say we can't fulfill our Community Vision, we can't fix things, can't make things better, and can't add more Parks and Useable Open Space. This can't attitude is not out Community Vision. We can and we did before, and we can do it again and better.

Great cities for hundreds of years have Upgraded their Quality of Life Facility Standards, made and implemented/funded facilities to fix things up to those Standards. A City is just like a business or person - If you don't. improve you decline. Examples of Upgrading and funding to New Parks and Open Space are many but include - Carlsbad's Buena Vista Reservoir Park, additions to Pine Park, Village H Park, and Aura Circle Open Space acquisition; and SDSU's major new Park at the redeveloped Qualcomm Stadium site.

Now like at the beginning of Carlsbad Growth Management the City can "despite previous city council actions" make improvem~nts to its Growth Management and Quality of Life Standards to address past and future needs. Following illustrates existing R-23 (up to 23 dwellings per acre) development in Carlsbad - most of our future residential development will be required to be like this or more dense.

High-density housing can be great, but it requires MORE Parks and MORE useable Open Space within walking distance to balance the density and provide large places for families and kids to really play. In Carlsbad's high-density residential future with no backyards and stacked flat multi-family homes the need for both more Parks and Useable Open Space is much greater than in 1980's.

The time to fix the Parks and Useable Open Space problems af Ponto (LFMP-9) is now. Already Ponto is developed at a density that is 40% great than .the rest of Carlsbad. New proposed and even higher­ density developments (developer driven Amendments) propose to make Ponto even more dense, yet there are not Parks at Ponto and Ponto is missing 30-acres of Useable Open Space past developers should have provided.

A doable, time-tested , accountable , tax-payer saving, strongly citizen desired, accountable, and honest way to fix this was presented to you in 8/8/22 and 12/27 /22 emails with attached "CTGMP Key Issues and Suggestions - 2022-12-6". Over 5,000 petitions expressing the need to fix the Park and Open Space problems at Ponto have been sent to the City and the City should have provided these to you in considering Park and Open Space issues.

Ponto Park and Open Space needs your help fixing NOW. If not Carlsbad Tomorrow will be less than it is today, and tragically will have failed our Communi ty Vision.

Sea Level Rise and Carlsbad's DLCP-LUPA's projected/planned Loss of Open Space at Ponto Introduction:

Carlsbad first documented Sea Level Rise (SLR) and associated increases in coastal erosion in a December 2017 Sea Level Rise Vulnerability Assessment (2017 SLR Assessment). Prior planning activities (2010 Ponto Vision Plan - rejected by CA Coastal Commission, and 2015 General Plan Update) did not consider SLR and how SLR would impact Coastal Open Space Land Use & CA Coastal Act 'High-Priority' Coastal Open Space Land Uses at Ponto. The 2017 SLR Assessment shows Open Space land and Open Space Land Uses are almost exclusively impacted by SLR at Ponto & South Coastal Carlsbad. The 2017 SLF Assessment also shows significant LOSS of Open Space land acreage and Land Uses. Most all impacted Open Space Land Uses are CA Coastal Act "High -Priority Coastal Land Uses" - Coastal Recreation (i.e. Public Park) and Low-Cost Visitor Accommodations. Existing Ponto Open Space Land Uses are already very congested (non-existent/narrow beach) and have very high, almost exclusionary, occupancy rates (Campground) due to existing population/visitor demands. Future population/visitor increases will make this demand situation worst. The significant permanent LOSS of existing Coastal Open Space land and Coastal Open Space Land Use (and land) due to SLR reduces existing supply and compounds Open Space congestion elsewhere . Prior Ponto planning did not consider, nor plan, for significant SLR and current/future "High-Priority" Coastal Open Space Land Use demands.

Open Space and City Park demand at Ponto:

Open Space at Ponto is primarily 'Constrained' as defined by the City's Growth Management Program (GMP), and cannot be counted in meeting the City's minimal 1S% 'Unconstrained' GMP Open Space Standard. Per the GMP Open Space Standard, the developers of Ponto should have provided in their developments at least 30-acres of additional 'Unconstrained' GMP Open Space at Ponto. City GIS mapping data confirm 30-acres of GMP Standard Open Space is missing at Ponto (Local Facilities Management Plan Zone 9).

The City of Carlsbad GIS Map on page 2 shows locations of Open Spaces at Ponto. This map and its corresponding tax parcel-based data file document Ponto's non-compliance with the GMP Open Space Standard. A summary of that City GIS data file is also on page 2. The City said Ponto's non-compliance w ith the GMP Open Space Standard was 'justified' by the City 'exempting' comp liance with the Standard. The City 'justified' this 'exemption' for reasons that do not appear correct based on the City's GIS map and data on page 2, and by a review of 1986 aerial photography tha t shows most of Ponto as vacant land. Th.e City in the Citywide Facilities Improvement Plan (CFIP) said 1) Ponto was already developed in 1986, or 2) Ponto in 1986 already provided 15% of the 'Unconstrained' land as GMP Standard Open Space. Both these 'justifications' for Ponto 'exemption' in the CFIP were not correct.

The legality of the City 'exempting' Ponto developers from the GMP Open Space Standard is subject to current litigation.

The City proposes to contin ue to exempt future Ponto developers from providing the missing 30-acres of minimally required GMP Open Space, even though a change in Ponto Planning Area Fland use from the current 'Non-Residential Reserve" Land Use requires comprehensive Amendment of the Local Facilitates Management Plan Zone 9 to account for a land use change. City exemption is subject of litigation.

Ponto (west of 1-5 and South of Poinsettia Lane) currently has 1,025 homes that per Carlsbad's minimal Park Standard demand an 8-acre City Park. There is no City Park at Ponto. Coastal Southwest Carlsbad has an over 6.5 acre Park deficit that is being met 6-miles away in NW Carlsbad. Ponto is in the middle of 6-miles of Coastline without a City Coastal Park west of the rail corridor .

Sea Level Rise and Carlsbad's DLCP-LUPA's projected/planned Loss of Open Space at Ponto Page 1 of 7 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?
• Why Ponto developers were never
required to comply with the 15%
Stanpard Open Space is subject to
current litigation
~-.caq,,, Cl ...__
n I ,,,_.,_,oll<>anl,.__,,.. = lJ'J.IZ!I~ Below is City GIS data from this map I 7 .tlJO • l-0-~ Q>enS..,.h,m
w -01 0 0 I 4_...._
O_-=-c,Wll- 200-==JOO--•«rl _..

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 Opeh Space
Unconstrained land in LFMP Zone 9 [Ponto]
GMP Minimum Unconstrained Ope_n 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]
Sea Level Rise and Carlsbad's DLCP-LUPA's projected/planned Loss of Open Space at Ponto Page 2 of 7 Sea Level Rise impacts on Open Space and Open Space Land Use Planning at Ponto:

The City's 2015 General Plan Update did not factor in the impacts of Sea Level Rise (SLR) on Ponto's Open Space land. In December 2017 the City conducted the first Sea Level Rise Vulnerability Assessment https://www.carlsbadca.gov/civicax/filebank/blobdload.aspx?Blob1D=33958. The 2017 SLR Assessment is an initial baseline analysis, but it shows significant SLR impacts on Ponto Open Space.

More follow -up analysis is being conducted to incorporate newer knowledge on SLR projections and coastal land erosion accelerated by SLR. Follow-up analysis may likely show SLR impacts occurring sooner and more extreme.

Troubling ly the 2017 SLR Assessment shows SLR actually significantly reducing or eliminating Open Space land at Ponto. SLR is projected to only impact and eliminate Open Space lands and Open Space Land Use at Ponto. The loss of Ponto Open Space land and Land Use being at the State Campgrbund, Beaches, and Batiquitos Lagoon shoreline . The losses of these Open Space lands and land uses would progress over time, and be a permanent loss. The 2017 SLR Assessment provides two time frames near­ term 2050 that match with the Carlsbad General Plan, and the longer-term 'the next General Plan Update' time frame of 2100. One can think of these timeframes as the lifetimes of our children and their children (2050), and the lifetimes of our Grandchildren and their children (2100). SLR impact on Coastal Land Use and Coastal Land Use planning is a perpetual (permanent) impact that carries over from one Local Coastal Program (LCP) and City General Plan (GP) to the next Updated LCP and GP.

Following (within quotation marks) are excerpts from Carlsbad's 2017 Sea Level Rise Vulnerability Assessment:
{Italicized text within brackets] is added data based on review of aerial photo maps in the Assessment. "Planning Zone 3 consists of the Southern Shoreline Planning Area and the Batiquitos Lagoon. Assets within this zone are vulnerable to inundation , coastal flooding and bluff erosion in both planning horizons (2050 and 2100). A summary of the vulnerability assessment rating is provided in Table 5. A discussion of the vulnerability and risk assessment is also provided for each asset category.

5.3.1. Beaches
Approximately 14 acres of beach area is projected to be impacted by inundation/erosion in 2050 ....

Beaches in this planning area are backed by unarmored coastal bluffs. Sand derived from the natural erosion of the bluff as sea levels rise may be adequate to sustain beach widths, thus, beaches in this reach were assumed to have a moderate adaptive capacity. The overall vulnerability rating for beaches is moderate for 2050.

Vulnerab ility is rated moderate for the 2100 horizon due to the significant amount of erosion expected as the beaches are squeezed between rising sea levels and bluffs. Assuming the bluffs are unarmored in the future, sand derived from bluff erosion may sustain some level of beaches in this planning area. A complete loss of beaches poses a high risk to the city as the natural barrier from storm waves is lost as well as a reduction in beach access, recreation and the economic benefits the beaches provide.

5.3.3. State Parks
A majority of the South Carlsbad State Beach day-use facilities and campgrounds (separated into four parcels) were determined to be exposed to bluff erosion by the 2050 sea level rise scenario (moderate exposure). This resource is considered to have a high sensitivity since bluff erosion could significantly impair usage of the facilities . Though economic impacts to the physical structures within South Carlsbad State Beach would be relatively low, the loss of this park would be significant Sea Level Rise and Carlsbad ' s DLCP-LUPA's projected/planned Loss of Open Space at Ponto Page 3 of7 since adequate space for the park to move inland is not available (low adaptive capacity). State parks was assigned a high vulnerability in the 2050 planning horizon. State park facilities are recognized as important assets to the city in terms of economic and recreation value as well as providing low-cost visitor serving amenities. This vulnerability poses a high risk to coastal access, recreation, and tourism opportunities in this planning area.

In 2100, bluff erosion of South Carlsbad State Beach day-use facilities and campgrounds become more severe and the South Ponto State Beach day-use area becomes exposed to coastal flooding during extreme events. The sensitivity of the South Ponto day-use area is low because impacts to usage will be temporary and no major damage to facilities would be anticipated. Vulnerability and risk to State Parks remains high by 2100 due to the impacts to South Carlsbad State Beach in combination with flooding impacts to South Ponto.

Table 5: Planning Zone 3 Vulnerability Assessment Summary [condensed & notated]:

Asset
Category
Beaches
Public Access
State Parks
{Campground -
Low-cost Visitor
Accommodations]
Transportation
(Road, Bike,
Pedestrian)
Environmentally
Sensitive
Lands
Horizon
[time] Hazard Type
2050
2100
2050
2100
2050
2100
2050
2100
2050
2100
Inundation/Erosion, Flooding
Inundation/Erosion, Flooding
Inundation, Flooding
Inundation, Flooding
Flooding, Bluff Erosion
Flooding, Bluff Erosion
Bluff Erosion
Flooding, Bluff Erosion
Inundation, Flooding
Inundation, Flooding
Impacted Assets
14 acres (erosion)
54 acres (erosion)
6 access points
4,791 feet of trails
10 access points
14,049 feet of trails
4 parcels {<18 Acres]
4 parcels {>18 Acres]
[loss of over 50% of
the campground &
its low-cost Visitor
Accommodations,
See Figure 5.)
1,383 linear feet
11,280 linear feet
572 acres
606 acres
Sea Level Rise and Carlsbad's DLCP-LUPA's projected/planned Loss of Open Space at Ponto Vulnerability
Rating
Moderate
Moderate
Moderate
Moderate
High
High
Moderate
High
Moderate
High

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LJ ......... - :..0.-.~
EXH181TB6
Sea Level Rise and Carlsbad's DLCP-LUPA's projected/p lanned Loss of Open Space at Ponto Page 5 of 7 (Cityof
Carlsbad
CJ I I .- of n J Sea Level Rise Vulnerability Assessment Figure S: CoSMoS Bluff Erosion Projections by 2100
{CoSMoS-COAST 2015)
[Figure S show the loss of over 50% of the campground and campground sites with a minimal .2 meter Sea Level Rise (SLR), and potentially the entire campground (due to loss of access road) in 2 meter SLF.]" Directions to· analyze and correct current and future LOSS of Coastal Open Space Land Use at Ponto On July 3, 2017 the CA Coastal Commission provided direction to Carlsbad stating:
"The existing LUP includes policies that require certain visitor-serving developments and/o r studies relevant to the Ponto ... area. For example, Planning Area F requires the city and dev~loper to "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 .... this study should be undertaken as a part of the visitor serving use inventory analysis described above. If this analysis determines that there is a deficit of low cost visitor accommodations or recreation facilities in this area, then Planning Area F should be considered as a site where these types of uses could be developed."
Official Carlsbad Public Records Requests (PRR 2017-260, et. al.) confirmed Carlsbad's Existing LCP and its Ponto specific existing LUP polices and Zoning regulations were never followed in the City's prior Ponto planning activities (i.e. 2010 Ponto Vision Plan & 2015 General Plan Update). The projected SLR loss of recreation (beach) and low-cost visitor accommodations (campground) at Ponto should factor in this Existing LCP required analysis, and a LCP-LUP for Ponto and Ponto Planning Area F.

In a February 11, 2020 City Council Staff Report City Staff stated:
"On March 14, 2017, the City Council approved the General Plan Lawsuit Settlement Agreement (Agreement) between City of Carlsbad and North County Advocates (NCA). Section 4.3.15 of the Agreement requires the city to continue to consider and evaluate properties for potential acquisition of open space and use good faith efforts to acquire those properties." Sea Level Rise and Carlsbad's DLCP-LUPA's projected/planned Loss of Open Space at Ponto Page 6 of 7 In 2020 NCA recommended the City acquire Ponto Planning Area Fas Open Space. The status of City processing that recommendation is unclear. However the Lawsuit Settlement Agreement and NCA's recommendation to the City should also be considered in the required Existing LCP analysis.

Summary:

Tragically Carlsbad's' Draft Local Coastal Program - Land Use Plan Amendment (DLCP-LUPA) is actually planning to both SIGNIFICATLY REDUCE Coastal Open Space acreage, and to eliminate 'High-Priority Coastal Open Space Land Uses at Ponto due to SLR.

The Existing LCP requirements for Ponto Planning Area F to analyze the deficit of Coastal Open Space Land Use should factor in the currently planned LOSS of both Coastal Open Space acreage and Coastal Open Space Land Uses at Ponto due to SLR. As a long-range Coastal Land Use Plan this requ ired LCP analysis needs to also consider the concurrent future increases in both population and visitor demand for those LOST Coastal Open Space acres and Coastal Open Space Land Uses.

It is very troubling that demand for these CA Coastal Act 'High-Priority' Coastal Open Space Land Uses is increasing at the same time the current (near/at capacity) supply of these CA Coastal Act 'High-Priority' Coastal Open Space Land Uses is significantly decreasing due to SLR. Instead of planning for long-term sustainability of these CA Coastal Act 'High-Priority' Coastal Open Space Land Uses for future generations there appears to be a plan to use SLR and inappropriate (lower-priority residential) Coastal Land Use planning to forever remove those CA Coastal Act 'High-Priority' Coastal Open Space Land Uses from Ponto. CA Coastal Act Policies to address these issues should be thoroughly considered. 2021 -2 proposed Draft Local Coastal Program - Land Use Plan Amendment (DLCP-LUPA) will likely result in City and CA Coastal Commission making updates to the 2015 General Plan, based on the existing Ponto Planning Area F LCP - LUP Policy requirements, Ponto Open Space issues, high-priority Coastal Land Use needs, and SLR issues not addressed in the 2015 General Plan.

Sea Level Rise and Carlsbad's DLCP-LUPA's projected/p lanned Loss of Open Space at Ponto Page 7 of7 2022 General Comparative tax-payer Costs/Benefits of Completing PCH, PCH Modification, and Ponto Park to address planned loss of 30+ acres of Coastal Open Space Land Use at Ponto/West BL/South Carlsbad: Part 1 of 2
Key base facts regarding tax-payer Cost/Benefit comparison:

City Coastal Park Fairness: Ponto/Coastal South Carlsbad has ZERO Parks and ZERO Park acres v. 10 Coastal Parks in North Carlsbad. 62% of Carlsbad citizens and major visitor industries live in South Carlsbad with no Coastal Park. 38% of Carlsbad citizens have the entire City's Coastal Parks. The City also falsely allowed Ponto Developers to NOT PROVIDE the required 15% unconstra ined Open Space required by other developers in Carlsbad. Consequently Ponto is already developed at a density 35% higher than the rest of City.

What is missing from South PCH: The only missing components of a Carlsbad Livable·(complete) Street are adequate Coastal sidewalks/pedestrian paths. Better safer protected bike paths for the volume of bike traffic on a higher-speed roadway are highly desired. Both these missing features can be (and should have already long ago been) provided in the existing PCH configuration.

Generalized Costs: Costs come from publ icly stated costs by Mayor Hall in a 2019 at Meet the Mayor Realtor luncheon at Hilton Garden Inn, City PCH Modification Cost Studies for South PCH, $13 million per mile cost for the simpler City CIP #6054 PCH Modification Project at Terra mar, general City cost data from official public records requests, and vacant Ponto land costs of $1.4 to $2.4 million per acre from recent recorded land sales at Ponto.

Generalized Benefits: The number of acres and the quality and usability of each of those acres, and the number of new added beach parking for each of the known Option's define each dption's benefits.

There may be other unknown Options that have different benefits. The City's 2001 PCH Modification Studies' highest Park and Open Space Option (2001 ERA Financial Analysis "Alternative 1-parks and open space scheme") only made possible a 4-acre Active Park north of Palomar Airport Road in North Carlsbad. The City's 2013 PCH Concept design eliminated that 4-acre Active Park and only showed a few small open space areas with picnic tables. Any PCH Modification Benefits are limited by existing PCH constraints. See attached Part 2: City PCH map with numbered notes on various existing land use constraints from the City's 2013 PCH Modification Design.

PCH Modification: PCH Modification does not add any new City land. Rearranging PCH land may add some usability beyond the usability of existing parkway areas along PCH. However significant land in PCH right -of-way is already constrained by habitat, slopes, and water quality detention basins. Past City Studies in 2001 and 2013 showed relative ly modest changes in useable acreage from major PCH Modifications. Forever removing 2-travel lanes (over 50% of PCH capacity due to removing passing ability) will create Terramar traffic congestion, but could repurpose that City pavement for open space.

Any net usable amount of open space land will however be relativity narrow and may be modest once all constraints are accounted for. PCH Modification should be accurately compared with the existing usable and open space parkway areas in the existing PCH configuration and Ponto Park situation. See attached Part 2: City PCH map with numbered notes on various existing land use constraints from the City's 2013 PCH Modification Design.

General Comparative cost-benefits of Completing PCH-PCH Modification -Ponto Park - part 1 Pagelof4 Comparative tax-payer Cost/Benefits:
.1. Completing PCH & adding missing sidewalk/path and additional public parking and bike safety:
177 existing parking spaces along South Carlsbad Blvd
Existing 4 vehicle lanes and 2 bike lanes
The only missing component of "Complete/Livable Street" is a pedestrian sidewalk/path Total Cost to provide missing sidewalks per City data= $3-5 million (based on path width) Costs for desirable safety upgrade to existing bike lanes are not known Cost to add more Beach parking in abandoned PCH North and South of Poinsettia ranges from:
• 273 additional spaces=$ 0.76 million
• 546 additional spaces= $ 1.1 million
• Plus an estimated $1.5 million for 2 signalized intersection upgrades for full 4-way access • Cost per parking space is estimated at $19,275 to $13,899 per additional parking space Total cost:$ 3.8 to 6.1 million to provide missing sidewalk/path and add more parking+ unknown amount for any desired upgrades to existing bike lanes
l.:. '2013 PCH Modification Proposal' [AECOM 11/26/2013 Alternative Development Meeting) Total Cost is $75 million per Mayor Matt Hall. PCH Modification would be most the expensive City project so far. $75 million current cost appears consistent with 20-years of cost inflation of the basic (unmitigated environmental and traffic) 2001 costs of $26.5 to 37.3 million (in 2001dollars) identified by "the City. The City's 2001 Study indicated fully mitigated costs will be higher.

Total $75 million PCH Modification cost comes to:
$ 18.7 to 7.5 million per acre for narrow open space areas (from portions of city roadway) $872,093 per additional parking space
• 86 additional parking spaces created= 263 replacement spaces - 177 existing spaces removed • Includes multi-use pathway (sidewalk) within primarily native/natural landscaping. • Possible 50% reduction in vehicle lanes (from 4 to 2 lanes) with corresponding traffic congestion like at Terramar. Not clear if Citizens will approve spending $75 million to double traffic congestion. • Includes about 4 - 10 acres for possible narrow passive Park area identified in City's 2001 PCH Modification Studies. However City's 2013 PCH Modification (AECOM) plans look like smaller acreage is provided.
• Does not purchase any new land (only reconfigures existing City land) so requires Carlsbad Citizens to vote to expend funds per Proposition H.
• 2013 PCH Modification proposal did not consider and map City's 2017 sea level rise data to show what areas would be lost due to sea level rise and account for any added cost and issues. ~ Ponto Coastal Park
Total Cost: $20- 22 million to purchase and build 11-acres as Mayor Matt Hall has publicly stated $ 2 to 1.8 million per acre (per Mayor) for new and fully useable City Park area 175% to 10% more total park land than 'PCH Modification options' • Includes adding 11-acres of new and viable parkland similar in shape (but larger in size) than Carlsbad's Holiday Park. Site includes both habitat and E-W and N-S connections.

General Comparative cost-benefits of Completing PCH-PCH Modification -Ponto Park - part 1 Page 2 of4 • Since an Open Space land purchase per Proposition C acquisition voters exempted such purchases from Proposition H. NCA recommend the site be considered for purchase as Open Space per the City's obligations under a lawsuit sett lement. ·
• Ponto Park's cost savings over 'PCH Modification' = $55 to 53 million • Ponto Park's+ adding missing sidewalks cost savings over 'PCH Modification'= $51 to 47 mill ion • Ponto Park's+ adding missing sidewalks+ 273 additional parking spaces cost savings over "PCH Modification'= $50.4 to 46.1 million
• Ponto Park's+ adding missing sidewalks+ 546 additiona l parking spaces cost savings over "PCH Modification'= $50.1 to 45.8 million
1'" Combining both #1-PCH Completion and #3-Ponto Park:

Combining #1 and #3 creates at cost effective and more beneficial Coastal Park-Coastal Parking­ Completes Streets solution. This solution actually adds 11-acres of new City land for a needed Park, provides for a Complete PCH without increasing traffic congestion, does not forever congest PCH travel if future PCH traff ic increases, adds comparatively more beach parking, and provides the City with Coastal land use and sea level rise planning flexibility to address future needs by not forever committing the City's PCH land to a Final solution. See map on page 4 showing land use synergy of combin ing #1 and #3.
$50.4 to 45.8 million in tax-payer cost savings are estimated from combining #1 & #3 compared to the estimated $75 million PCH Modificat ion concept. Combining #1 and #3 provide all the features provided by more Benefits for a reduced
a . . Ponto Park's location allows it to use the 337-610 parking spaces created by #1 above (177 existing+ 273 to 546 new parking spaces). The 337-610 parking spaces will allow Ponto Park to effectively host Carlsbad's special community events. b. Acquiring Ponto Park's 11-acres provides both the City and State of CA with important future land use options to address the Sea Level Rise and Coastal Erosion (SLR) planned by the City. These options are created by leaving the exiti ng South Carlsbad Blvd right -of-way substantially the same (except for adding needed sidewalks and using the existing Old paved roadway for parking) thus allowing future upland relocation of the Campground. If $75,000,000 is spent on #2 the likelihood this very expensive City expenditure would never be abandoned by the City to allow relocation of the Campground. c. Carlsbad' 2017 Sea Level Rise study shows SLR will eliminate½ of the State Campground- a high-priority Coastal land use under the CA Coastal Act. The CA Coastal Act calls for "upland" relocation of high-priority Coastal land uses due to SLR impacts. Ponto Park could also provide for "upland" relocation of the State Campground.

Part 2 of this Comparative analysis is a separate 2-page data file. This Part 2 file consists of the City's PCH map with numbered notes to documented City data on PCH design constraints, mapping the City's 2017 Sea Level Rise Impact Areas, and outlining the easterly 6.5 acre portion of the 11-acre Planning Area F site that could be Ponto Park for acreage comparison purposes.

General Comparative cost-benefits of Completi ng PCH-PCH Modification-Ponto Park~ part 1 Page 3 of 4.

Map 1: COSt effectivett using OJd carfsba d Blvd pavement for beach, campground & Ponto Part parking - W!hide access at Breakwater Rd, Poinsettia Lane. and Ponto Drive between the
centers of
panting.and
Ponto Park
ceoua.l roadway
.,.- ~ linking inland South
Carlsbad to !he Coast.

General Comparative cost-benefits of Completing PCH-PCH Modification -Ponto Park- part 1 Page 4 of 4 City's PCH Modification Proposal Area Map with notes on usability Constraints and Issues: P4P Input 2 of 2 The City's map below is marked with the following numbered list of Area Constraints and Issues. The Constra ints are from the City's 2013 PCH Modification designs, the City's older 2017 Sea Level Rise Impact Study, and on-site observat ions. The Constraints will limit any fundamental change to the existing PCH landscape. For instance existing slope and habitat area will remain or have to be relocated which will limit the use of any · excess land area from PCH Modification. These Constraints will then reduce from 62 acres the actual number of unconstrained and acres that are actual ly useable and can be used for different uses than curren tly exist. l. Loss of the last section of Old "Histor ic 101" design, ambiance, and openness. Will it be replaced w ith typica l urban arterial design ?

2. Freshwater habitat

3. Sewer pumping facility

4. City's 2013 PCH plan for RESTORED RIP ARIAN HABIT AT

5. Sea Level Rise 2 meter Impact Area

6. City's 2013 PCH plan for BIO SWALE AND RESTORED RIPARIAN HABITAT

7. Existing beach parking to be retained

8. Least Tern habitat

9. Major storm water detention basin

10. Water

11. Slopes will likely need retaining walls to move road inland closer to proposed Kam Sang Resort

12. Endangered Species Habitat

13. City's 2013 PCH plan for COASTAL SAGE SCRUB RESTORATION

14. City's 2013 PCH plan for NATIV E GRASSLAND RESTORATION

15. City's 2013 PCH plan for BIO SWALE AND RESTORED RIPARIAN HABITAT

16. Eliminating access road for homes/businesses south of Cape Rey Resort. Who pays to replace?

17. Removes Cape Rey Resort developer required GMP Open Space for this LFMP. This GMP Open Space will have to be replaced. Who Pays?

18. City's 2013 PCH plan for L.I.D. BASIN / BIO SWALE

19. City left several acres vacant for 20+ years . This area can cost-effectively provide 200-500 more parking spaces w/o any PCH relocation ·.

20. Unusual jog in roadway. Is this viable?

21. City's 2013 PCH plan for RESTORED NATIVE LANDSCAP E

22. Habitat & need to provide major storm water quality detention basin before discharging urban and creek runoff into ocean.

23. Slopes will likely need retaining walls to move road inland closer to mobile home community.

24. Steep unusable slopes needed for Palomar Airport Road overpass over railroad corridor.

For a Cost/Benefit reference point, the City's PCH Modificat ion at Terramar (ClP project #6054 from Cannon to Manzano) that is less constrained and simpler than South Carlsbad is projected to cost aro und $13 million per mile. Vacant primarily unconstrained land sale costs at Ponto are documented at around $1 .4 to $2.4 million per acre. Honest Cost/Benefit of these two options should be a public tax-payer discussion.

EXJ-HBJT 17
0 250 500 1,000 i'<ti Carlsbad Boulevard Realignment: Right-of-Way and Available Land Analygs• "'kL"""' c::::I Proposed ROW (Approximately 43 acres)
Cl Area Available for Other Uses (Approximately 62 acres1 ) July 13, 2021 t<eln 1114 Page 47 of53 • Mo,~ ls b.sed O'\ ~ irn,qe,y. Rigl,t-of-w,y bol,nd;,ries .nd ..cre.ge, ""• ""'""°"""' ..od ;,,-,..,.iod io< ;,l.nning i.,,.i ....,►(Sis only. * * For comparative visual reference the area is the 6.5 acre eastern portion of Planning Area F. Page 2 of2 Tammy Cloud-McMinn
From:

Sent:

To:

Subject:

Phil Johnston <[email protected]>
Thursday, July 13, 2023 6:34 PM
City Clerk
Growth Management Plan
Dear Mayor and City Council-
Please make sure the Growth Management plan has a proper treatment of traffic concerns. Traffic is a serious prob lem which already degrades the quality of life in all of San Diego County. Do not be influenced by developers who always say the impact on traffic of their project will be minimal, and can be addressed by inexpensive band-aid local tweaks. This is always a lie. Not one input from a developer will say the freeways and major roads w ill be become severely impacted and near-disfunctional. But consider your own experience- what do you see at rush hour? Please consider traffic issues properly and competently.

Also, please ensure the following components are included in the Growth Management Plan. a. Study park proximity so every neighborhood has access to a park, b. Add a coastal access park for the southern half of the city, and c. Develop a corrective action plan for the 1 6 zones exempted from the open space standard.

Thank you, Phil Johnston
CAUTION: Do not open attachments or click on links unless you reco nize the sender and know the content i 1 Tammy Cloud-McMinn
From: Lance Schulte < [email protected]>
Thursday, July 13, 2023 5:18 PM Sent:

To:

Cc:

City Clerk; Council Internet Email; [email protected] 'Smith, Darren@Parks'; Homer, Sean@Parks; 'Moran, Gina@Parks'; Eric Lardy; Tom Frank; Kyle Lancaster; Mick Calarco; 'People for Ponto' Subject: 2023-7-18 Council meeting agenda Item #9 Public Input data for Carlsbad's proposed Local Coastal Program Amendment, Park Master Plan Update, Growth Management Plan Update, and South Carlsbad Coastline Project.
2qos_Carlsbad_Blvd_Realignment_Summary_Memo by Debbie Fountain.pdf; 2022 General Comparative cost-benifits of Completing PCH-PCH Modification-Ponto Park - Part 1 of 2 v1 .pdf; City's PCH area map w numbered notes of Constraints - 2 of 2.pdf; Excerpt from 5-1-23 email to City and CCC on PCH Relocation cost-acres south of Island Way.pdf
Attachment s:

Dear City Council; CA Coastal Commission & State Parks; and Carlsbad Planning, Mobility/Traffic and Park Commissions:

Please receive and consider this public input email and attached '2008 internal City Staff memo, and 2-part Cost/Benefit/Constraints data regarding the Carlsbad's 40-year old PCH Median Relocation/ Adjustment proposal , as Pubic Input data for 1) Carlsbad's proposed Local Coastal Program Amendment, 2) Park Master Plan Update, 3) Growth Management Plan Update, and 4) South Carlsbad Coastline Project.

The attached "2008 ." file is ·an internal City Memo to "Leadership Team" on the 40-year history of City plans/mot ivations for PCH_ Median Relocation that discusses several issues that the City has not publicly disclosed to Carlsbad Citizens nor posted on the City's South Carlsbad Coastline Project, thus preventing Citizens from being properly informed about the City's proposal that will require a Citizen vote to fund. Some of the key points from that internal City Memo include:
• The project was to be "dedicated to recreational purposes, including campsites" • 7 parcels of land could be created.
• Most of the 7 parcels of land, and the most useable/viable land, is owned by the State of California • Without a trade of City and State land the City "would not experience any significant revenue producing land that could help finance the alignment"
• 2001 City Financial Analysis concluded:
o Project costs are high, and the acreage of the 7 Parcels is modest as noted in the Memo (documented in 2001 URS & ERA Studies)
o Since project does not increase roadway capacity the project is NOT fundable by developers or traffic/road funds
o City studied different land use plans on the 7 Parcels that were NOT "dedicated to recreational purposes, including campsites", and the "highest development value (was) attributed to ("risky") hote l development" of the Parcels
o No project funding source was identified by the Financial Analysis • City's Ponto Vision Plan
o moved southbound lanes east
o used "narrow median " for parking, 'line r park', and possible campground addition o concluded public funding is needed for a realignment of median • The August 4, 2008 internal City Memo to "Leadership Team" includes "Table 6-2 Comparison of Carlsbad Boulevard Re-alignment Alternates" that documents comparative data on the 4 re-alignment alternat ives in the Ponto Vision Plan area
1 The City's 2001 URS and ERA PCH Relocation Studies of both the amount of land in the 7 Parcels that could be created from PCH Median Relocation/Modification and the City's current cost estimates should be fully disclosed to Citizens. For the 3-mile segment from Island Way south to La Costa Avenue (aka State Campground), there is only about 16 acres in 3 of the 7 Parcels. The City's current cost estimate for this 3-mile segment is $65 to $80 million or $21.6 to $26.6 million per mile, or $4 to $5 million per acre to access the City's existing land in the PCH Median . Attached are summary portions of the City's URS & ERA Relocation Studies that list the 7 Parcels and note key PCH Financing issues (this was emailed to the City and CA Coastal Commission and State Parks on Monday, May 1, 2023 12:08 PM).

The attached 2-part 'Cost/Benefit/Constraints' data uses City data to summarize and compare the City's PCH Median Relocation/Modification project with other alternative Plans to achieve a much needed Ponto Coastal Park and the Projects stated purpose to be "dedicated to recreational purposes, including campsites". For example a recent sale of

11.1 acres of vacant Ponto land sold for around $720,000 per acre and another 15 acre vacant parcel at Ponto current ly for sale for about $2.5 million per acre. Both the vacant sites are far more cost effective for tax-payers than the $4 to $5 million per acre cost to make narrow (less useable/desirable) Parcels from the City's already owned PCH Median.

The City Council and CA Coastal Commission should consider this Alternative and the comparative data as part of the City's analysis and Public communication/discussion of 1) Carlsbad's proposed .Local Coastal Program Amendment, 2) Park rylaster Plan Update, 3) .Growth Management Plan Update, and 4) South Carlsbad Coastline Project.

Can Citizens please get a confirmation from the City and CCC that this data will be Publicly communicated/discussed and considered?
Thank you,
Lance Schulte
CAUTION: Do not o en attachments or click on links unless ou reco nize the sender and know the content i 2 CARLSBAD BOULEVARD REALIGNMENT
• City and State began to explore a program to relocate the southbound lanes in early 1980s • Potential reallgnment Incorporated Into South Carlsbad State Beach General Plan.and adopted by State In 1982. • Plan proposed additional property to the west be dedicated to recreational purposes, including campsites, parking, beach access, and state administration and maintenance facilltles. • A major feature of plan was a group campsite and hostel on Manzano property. • Plan anticipated a 'T' Intersection with Carlsbad Blvd.

Studies Summary I ,
I
• 1992 · - report completed on Carlsbad Blvd and Palomar Airport Intersection • Study concluded not cost effective to salvage the existing bridge; minimize the skew of Intersection • Conceptual eastem alignment for Carlsbad Blvd and studied from an environmental standpoint In 1998. • 7 parcels of land adjacent to the existing So. Carlsbad State Beach campground and coastline created • No significant environmental constraints.
• Additional evaluation needed on historical significance of bridges. • Exterior noise levels might be exceeded at Solamar Mobile Home P!irk; mitigation possible • Most of value in surplus land generated on the land owned by the State • Unless there was a trade of lands, the City would not experience any significant revenue producing land that could be used to help finance the alignment.
• 2001- Financial analysis completed for Carlsbad Blvd Realignment. • Explore ways to generate revenue from useable public land created from project. • Use revenue to offset costs of reallgnment
• Preliminary estimates were $18.8 million to realign.
• Highest development value attributed to hotel development. • May be difficult to have private development pay for road realignment if it does not create enhanced capacity for private development; no nexus
• City could negotiate contributions from private developers. • No specific funding source for the realignment project; included in SCCRA as a result. • SCCRA could bond or take a loan from the City to complete realignment project; repay through future tax increment generated by private development
Ponto Plan
• Southbound lanes to move east; public amenities such as parking, linear park included on surplus land • Ponto Drive to the lagoon bridge; northbound lanes stay where they are • Narrow median, remove cypress trees and create a standard Intersection at Avenida Encinas. • Surplus land could be used for expansion of campgrounds. • Assumption that realignment project would need to be publicly financed to create the opportunities.

August 4, 2008
TO: LEADERSIDP TEAM
FROM: HOUSING AND REDEVELOPMENT DIRECTOR

INFORMATION ON CARLSBAD BOULEVARD REALIGNMENT STUDY AND OTHER DISCUSSIONS AS RELATED TO PONTO BEACHFRONT VU..LAGE VISION PLAN AND

OTHER PLANNING EFFORTS
Per the request of the Leadership Team, this memorandum is provided to summarize the activity to date as related to studies of the Carlsbad Boulevard Realignment Project, project financing and any related planning documents , studies, etc. , 1
'
Historicnl Background from State perspective
Based on research related to the Carlsbad Boulevard Realignment, the City and State of California began to explore a program to relocate the southbound lanes of Carlsbad Boulevard (between Manzano Drive and San Marcos Creek to the east and adjacent to the northbound lanes) in the early 1980s. The potentinl realignment was incorporated into the South Carlsbad State Beach General Plan and adopted by the State in 1982.

Toe 1982 plan proposed that nil additional property west of the realigned Carlsbad Boulevard be dedicated to various recreational purposes, including additionnl campsites, parking, beach access, and State administration and maintenance facilities. A major feature of this plan was a group campsite and hostel on property owned by the State between Manzano Drive ~d Palomar Airport Road; This plan anticipated that Palomar Airport Road would be realigned to a 'T' intersection with Carlsbad Boulevard. To date, limited progress has been made towards implementing this plan.

Studies of Carlsbad Boulevard Realignment by the City
The City commissioned a study of the reconfiguration of the Carlsbad Boulevard and Palomar Airport Road (PAR) Intersection in the early 1990s. A report was prepared by Boyle Engineering in 1992.

Key issues evaluated in the study included the irregular angle created where PAR joins Carlsbad Boulevard, vertical alignments, and the feasibility of salvaging the existing railroad bridge west of Avenida Encinas. Toe study concluded that it was not cost effective to salvage the existing bridge and recommended an alternative that would minimize the skew of the intersection.

A conceptual eastern alignment for Carlsbad Boulevard was developed by staff and a study of the environmental constraints and opportunities created by the realignment was commissioned in 1998.

Toe study was also to include 1) a technical evaluation of alt~mative land uses for the surplus land, with a number-one priority on open~space recreational opportunities; and, 2) potential for reveue­ generating recreational/tourist -serving commercial land uses to fund the realignment. If realigned according to the staff conceptual plan, which includes the ''T" intersection at Carlsbad Boulevard and PAR, seven (7) parcels of land adjacent to the existing South Carlsbad State Bench campground and the coastline would be created for public and/or private development.

Conclusions of this study included: 1) no significant environmental constraints; 2) two bridges located across Encinas Creek o~ the southbound lanes of Carlsbad Boulevard were built in 1928 and may be historically significant. Further-evaluation was recommended; 3) City's exterior noise levels may be exceeded at the Solamnr Mobile Home Park due to the expected increases in traffic. However, mitigation could easily be achieved; and, 4) most of the value in surplus land would be generated on the land owned by the State. Unless there was a trade of lands, the City would not experience any significant revenue producing land that co~ld be used to help finance the realignment.

In 2001, a financial analysis was completed for the Carlsbad Boulevard Realignment project. An objective of this study was to explore ways to generate revenue from useab]e pubJic land created from the realignment project, including potential land sale or lease opportunities, and using this revenue to help offset the cost of. realigning the road. The preliminary estimates of the Carlsbad Boulevard Realignment project were $18.8 million. The s~gnificant value for development purposes (to assist in paying. for the improvements) was attributable to hotel development,. but considered risky from ' a financing standpoint. A specific note in the financial analysis indicated that if the road realignment simply mo.ves the road without enhancing capacity for future local developments, developer financed road improvements or impact fees may not apply due to the lack of a nexus. The report indicated that the City could negotiate contributions to the road alignment costs. Because there was not 1:1 specific funding source (including developer financing) identified for the Carlsbad Boulevard Realignment project and the realignment was deemed necessary to generate developable properties, the City fonned a Redevelopment Area, known as the South Carlsbad Coastal Redevelopment Area in 2000. It was intended that the Redevelopment Agency would initially finance the realignment and that subsequent development would then reimburse the Agency and repay the debt. No action has been taken to date to proceed with the Carlsbad Boulevard Realignment project and create financing through the Redevelopment Agency. However, it is important to note that a portion of Carlsbad Boulevard was realigned with the Poinsettia Properties project. Apparently, this was a negotiated project with the developer. This created some surplus land ( city-owned land) in front of, and immediately adjacent to, the State campground.

When work began on the Ponto Vision Plan, staff reviewed the initial studies completed on the Carlsbad Boulevard Realignment. A consensus was reached at that time with Public Works that the specific alignment within the Ponto Vision Plan area could be further studied to detennine the most appropriate alignment to benefit the City. The consultant for the Ponto Vision Plan was instructed to ~~ I
Ponto Vision Plan Studies
Preliminary land use strategies by RBF (consultant on the Ponto Vision Plan) indicated that the City would get the most public benefit from relocating the Carlsbad Boulevard southbound travel lanes eastward (which is consistent with the initial studies) and adjacent to the northbound lanes. No realignment was recommended for the northbound lanes. The staff team working on this project felt that it was important to include public parking and public space (linear park) in the excess right-of­ way to be created by the realignment
In 2007, 4 alternatives for the realignment of Carlsbad Boulevard were presented to the City Council and Housing and Redevelopment Commission for consideration and a selection of alignment choice.

The Council selected the alignment which: moved the Southbound lanes to the east from Ponto Drive to the lagoon bridge (adjacent to the northbound lanes, which would not be realigned), nmowing the median in middle, removing the Cypress Trees and creating a more standard intersection at A venida Encinas. This would create additional land on the west side for more public parking and an expanded linear park. It could also be used for expansion of the State campground if a subsequent decision is approved to do so. At the time of this approval, no decision was made as to how the realignment project or the public improvements would be funded. If a nexus can be made or a deal negotiated with a private developer, these improvements could potentia11y be developer financed. It is more likely, however, that the realignment project and public improvements would need to be publicly financed with the potential to raise additional revenues through development to repay the financing debt.

South Carlsbad Coastal Redevelopment Area (SCCRA) Master Plan When the SCCRA was adopted in 2000, the ·original intent was to subsequently prepare a Master Plan for the entire area that would address the Carlsbad Boulevard Reelignment project (~d make a finjll decisio_n on the alignment) as well as develop a desired comprehensive land use strategy for the are·a, including both private and public development. The Master Plan was intended to provide better detail and a more comprehensive plan for future development. However, after adoption of the redevelopment plan, a subsequent decision was made to discontinue efforts for an area-wide Master Plan. The SCCRA was subsequently divided into three (3) planning areas for land use planning purposes (see attached map). Planning Area .#3 (the Ponto Area) was identified as the first area for which to develop a land use strategy. This is because it was the only area at the time with interested developers and the greatest immediate demonstrated need for City/Agency guidance. The Ponto Vision Plan was completed and approved in November/December, 2007.

It was intended that Planning Area #1 (the power plant properties) would be the second area for which a land use strategy would be developed. However, this action was delayed in order to incorporate the area into the larger "Cannon Corridor land use strategy". This strategy was also subsequently abandoned and the focus was placed on the .. Prop 0" lands. The llll)d use strategy for these open space areas did not incorporate the power plant properties or the 48 acres of visitor-serving commercial land east of 1-5 (owned by SDGE). As a result, it may be necessary for the City and/or Redevelopment Agen~y to reconsider a land use strategy for these properties at a later date.

Planning Area #2 (Manzano Property to Ponto Drive) was considered the last area for which a land use strategy was needed due to the influence that the State of California had over much of the land and their public statements that they had no interest (at the time) in trading lands with the City or pursuing development on their properties. This plan was also put on hold due to the decline in tax increment revenues for the Redevelopment Agency as a result of reassessment of the power plant properties. There was concern that there would be no potential funding for the Carlsbad Realignment project and that bonds could not be issued to finance the project due to the uncertain tax increment revenues. A loan from the General Fund to the Redevelopment Agency was also viewed as financially infeasible due to concerns over future ability by the Agency to repay the debt. At this time, there are no land use planning strategies under development for PlllJliling Areas #1 or #2.

Please contact me at X2935 if any additional information is required, or if there are any questions on the information provided above.

Debbie Fouotajn
Table 6-2
Comparison of Carlsbad Boulevard Re-Alignment Alternatives ¥~CTO!t . ~T:E~AT~J - :~A1:;,mm1i\tiVE 2 . ·ALTERNATIVE 3 ALTERNATIVE 4 w• •- I ,,,_ . : - ; 'I-- • l - .. ... ~ .-- + · -·
Additional Creates 0.8 acres on Creates 2.0 acres on Creates 0.8 acres on Creates 0.5 acres on Vacated west side of west side of west side of Carlsbad west side of Acreage Carlsbad Boulevard, Carlsbad Boulevard Boulevard, available Carlsbad Boulevard.

Available for available for use as a north of Avenida to be used as a public available for use as a Other Uses public linear park. Encinas and 1.8 linear park. public linear park. acres on west side Creates 1.2 acres on
of Carlsbad east side of Carlsbad South of Beach
Boulevard south of Boulevard, nor1h of Way: Avenida Encinas, Avenida Encinas and ' available for use as 2.2 acres on east side Creates 0.8 acres on a public linear park of Carlsbad west side of
or potential Boulevard, south of Carlsbad Boulevard,
available for use as a expanded use for the Avenida Encinas, public linear park. South Carlsbad available for State Beac;h additional
Cnmpground. development or
community
amenities.

Effect on Approximately 3.0 Approximately 3. 7 Approximately 3.7 Approximately 3.0 Vegetative acres ofDisturbed acres of Disturbed acres of Disturbed acres of Disturbed Communities Diegan coastal sage Diegan coastal sage Dicgan coastal sage Diegan coastal sage scrub to be affected scrub to be affected scrub to be affected scrub to be affected in median between in median between in median bi;tween in median between Ponto Drive and Ponto Drive and Ponto Drive and Ponto Drive and Avenida Encinas. Avcnida Encinas. Avenida Encinas. Avenida Encinas.

Retains cypress trees Potential Potential disturbance Retains cypress trees in median south of disturbance to to approximately 0.6 in median south of A venida Encinas. approximately 0.6 acres of Southern A venida Encinas. acres.of Southern Coastal Salt Marsh in
Coastal Salt Marsh median immediately
in median north of the Los
immediately north Batiquitos Lagoon
of the Los bridges.

Batiquitos Lagoon Removal of cypress
bridges. trees in median south
Removal of cypress of Avenida Encinas.
trees in median
south of Avenida
Encinas.

Parking Provides 61 parking Provides 61 parking Provides 61 parking Provides 61 parking spaces (60 degree spaces (60 degree spaces (60 degree spaces (60 degree diagonal) and 48 diagonal) and 48 diagonal) and 48 diagonal) and 48 parallel parking parallel parking parallel parking parallel parking spnces. spaces. spaces. spaces.
. .
' ALTERN'ATiVE 2 .:ALTERNATIVE 3 ·. FACTOR .- · ALTERNATIVE-l ALTERNATIVE 4 - - .. !'. ..... .. . · ., . ... . , . . . - .

Traffic Signal More complex signal Less complex signal Less complex signal More complex signal Operations operation at Avenida operation at operation at Avenida operation at A venida Encinas due to width Avenida Encinas, Encinas, due to Encinas due to width of median (longer due to standardized standardized of median (longer time to make turning intersection (i.e., no intersection (i.e., no tiine to make turning movements) but wide median). wide median). movements) but similar to existing similar to existing
condition. condition.

Vehicular Retains existing Retains existing Requires two new Retains existing Bridges northbound bridge; northbound bridge; bridges - one northbound bridge; I requires new requires new northbound and one requires new southbound bri~ge to southbound bridge southbound. southbound bridge to implement the to accommodate accommodate lanes
grade-separated lanes re-location re-location and to
pedestrian underpass and to implement implement the
to the west. the grade-separated grade--separated
pedestrian pedestrian underpass
underpass to the to the west.
west.
2022 General Comparative tax-payer Costs/Benefits of Completing PCH, 2.3 mile PCH Modification, and Ponto Park to address planned loss of 30+ acres of Coastal Open Space Land Use at Ponto/West BL/South Carlsbad: Part 1 of 2
Key base facts regarding tax-payer Cost/Benefit comparison:

City Coastal Park Fairness: Ponto/Coastal South Carlsbad has ZERO Parks and ZERO Park acres v. 10 Coastal Parks and 37 Park acres in North Carlsbad. 62% of Carlsbad citizens and major visitor industries live in South Carlsbad with no Coastal Park. 38% of Carlsbad citizens have the entire City's Coastal Parks.

The City also false ly allowed Ponto Developers to NOT PROVIDE the required 15% unconstrained Open Space required by other developers in Carlsbad. Consequently Ponto is already developed at a density 35% higher than the rest of City. Higher density logically requires more parks and park acres.

What is missing from 2.3 mile South PCH: The only missing components of a Carlsbad Livable (Complete) Street are about 1.6 miles of adequate Coastal sidewalks. Better, safer protected bike paths for the volume of bike traffic on a higher-speed roadway are highly desired. Both these features can be (and should have already long ago been) provided in the existing PCH configuration.

Generalized Costs: Costs come from publicly stated costs by Mayor Hall in a 2019 at Meet the Mayor Realtor luncheon at Hilton Garden Inn, City PCH Modification Cost Studies for South PCH, $13 million per mile cost for the simpler City CIP #6054 PCH Modification Project at Terra mar, general City cost data from official public records requests, and vacant Ponto land costs of $1.4 to $2.4 million per acre from recent recorded land sales at Ponto.

Generalized Benefits: The number of acres and the quality and usability of each of those acres, and the number of new added beach parking for each of the known Option's define each Option's benefits.

There may be other unknown Options that have different benefits. The City's 2001 PCH Modification Studies' highest Park and Open Space Option (2001 ERA Financial Analysis "Alternative 1-parks and open space scheme") only made possible a 4 -acre Active Park nort h of Palomar Airport Road in North Carlsbad. The City's 2013 PCH Concept design eliminated that 4-acre Active Park and only showed a few small open space areas with picnic tables. Any PCH Modification Benefits are significantly limited by existing PCH constraints. See attached Part 2: City PCH map with numbered notes on various existing land use constraints from the City's 2013 PCH Modification Design.

PCH Modification: PCH Modification does not add any new City land. Rearranging PCH land may add some usability beyond the existing usability of parkway areas along PCH. However significant land in PCH right-of-way is already constrained by habitat, slopes, and water quality detention basins. Past City Studies in 2001 and 2013 showed relatively modest changes in useable acreage from major PCH Modifications. Forever removing 2-travel lanes (over 50% of PCH capacity due to removing passing ability) will create Terramar traffic congestion, but could repurpose some of that City pavement for open space. Any net usable amount of open space land will however be relativity narrow and may be modest once all constraints are accounted for. PCH Modification should be accurately compared with the existing usable and open space parkway areas in the existing PCH configuration and Ponto Park situation. See attached Part 2: City PCH map with numbered notes on various existing land use constraints from the City's 2013 PCH Modification Design.

General Comparative cost-benefits of Completing PCH-PCH Modifica tion -Ponto Park - part 1 Page 1 of 4 Comparative tax-payer Cost/Benefits:
.1. Completing 2.3 miles of PCH by adding missing sidewalk/path. Adding parking and bike safety:

Only about 1.6 miles of the 2.3 miles needs sidewalks
There are 177 existing parking spaces along South Carlsbad Blvd Existing 4 vehicle lanes and 2 bike lanes
The only missing component of "Complete/Livable Street" is some pedestrian sidewalk/paths Total Cost to provide missing sidewalks per City data= $3-5 million (based on path width) Costs for desirable safety upgrade to existing bike lanes are not known Cost to add more beach parking in abandoned PCH North and South of Poinsettia ranges from:
• 273 additional spaces= $ 0.76 million
• 546 additional spaces=$ 1.1 million
• Plus an estimated $1.5 million for 2 signalized intersection upgrades for full 4-way access • Cost per parking space is estimated at $19,275 to $13,899 per additional parking space Total cost:$ 3.8 to 6.1 million to provide missing sidewalk/path and add more parking+ unknown amount for any desired upgrades to existing bike lanes
b '2013 PCH Modification Proposal' [AECOM 11/26/2013 Alternative Development Meeting] Total Cost is $75 million per Mayor Matt Hall. PCH Modification would be most the expensive City project so far. $75 million current cost appears consistent with 20-years of cost inflation of the basic (unmitigated environmental and traffic) 2001 costs of $26.5 to 37.3 million (in 2001dollars) identified by the City. The City's 2001 Study indicated fully mitigated costs will be higher.

Total $75 million PCH Modification cost comes to:
$ 18.7 to 7.5 million per acre for narrow open space areas (from portions of city roadway) $872,093 per additional parking space
• 86 additional parking spaces created= 263 replacement spaces - 177 existing spaces removed • Includes multi-use pathway (sidewalk) within primarily native/natural landscaping . . • Possible 50% reduction in vehicle lanes (from 4 to 2 lanes) with corresponding traffic congestion like at Terramar. Not clear if Citizens will approve spending $75 million to double traffic congestion. • Includes about 4 - 10 acres for possible narrow passive Park area identified in City's 2001 PCH Modification Studies. However City's 2013 PCH Modification (AECOM) plans look like smaller acreage is provided.
• Does not purchase any new land (only reconfigures existing City land) so requires Carlsbad Citizens to vote to expend funds per Proposition H.
• 2013 PCH Modification proposal did not consider and map City's 2017 sea level rise data to show what areas would be lost due tb sea level rise and account for any added cost and issues.

3. Ponto Coastal Park
Total Cost: $20 - 22 million to purchase and build 11-acres as Mayor Matt Hall has publicly stated $ 2 to 1.8 million per acre (per Mayor) for new and fully useable City Park area 175% to 10% more total park land than 'PCH Modification options' • Includes adding 11-acres of new and viable parkland similar in shape (but larger in size) than Carlsbad's Holiday Park. Site includes both habitat and E-W and N-S connections.

General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park - part 1 Page 2 of 4 • Since an Open Space land purchase per Proposition C acquisition voters exempted such purchases from Proposition H. NCA recommend the site be considered for purchase as Open Space per the City's obligations under a lawsuit sett lement.
• Ponto Park's cost savings over 'PCH Modificat ion' = $55 to 53 million • Ponto Park's+ adding missing sidewa lks cost savings over 'PCH Modification'= $51 to 47 million • Ponto Park's+ adding missing sidewa lks+ 273 additional parking spaces cost savings over "PCH Modification' = $50.4 to 46.1 million
• Ponto Park's+ adding missing sidewal ks+ 546 additional parking spaces cost savings over "PCH . Modification'= $50.1 to 45.8 million

4. Combining both #1-PCH Completion and #3-Ponto Park:

Combining #1 and #3 creates at cost effective and more beneficial Coastal Park-Coastal Parking­ Completes Streets solution. This solution actually adds 11-acres of new City land for a needed Park, provides for a Complete PCH without increasing traffic congestion, does not forever congest PCH travel if future PCH traffic increases, adds comparatively more beach parking, and provides the City with Coastal land use and sea level rise planning flexib ility to address future needs by not forever comm itting the City's PCH land to a Final solution. See map on page 4 showing land use synergy of combining #1 and #3.
$50.4 to 45.8 million in tax-payer cost savings are estimated from combining #1 & #3 compared to the estimated $75 million PCH Modification concept. Combining #1 and #3 provide all the features provided by more Benefits f~r a reduced
a. Ponto Park's location allows it to use the 337-610 parking spaces created by #1 above (177 existing+ 273 to 546 new parking spaces). The 337-610 parking spaces will allow Ponto Park to effectively host Carlsbad's special community events. b. Acquiring Ponto Park's 11-acres provides both the City and State of CA with important future land use options to address the Sea Level Rise and Coastal Erosion (SLR) planned by the City. These options are created by leaving the exiting South Carlsbad Blvd right-of-way substantially the same (except for adding needed sidewalks and using the existing Old paved roadway for parking) thus allowing future upland relocation of the Campground . If $75,000,000 is spent on #2 the likelihood this very expensive City expenditure would never be abandoned by the City to allow relocation of the Campground. c. Carlsbad' 2017 Sea Level Rise study shows SLR will eliminate½ of the State Campground - a high-priority Coastal land use under the CA Coastal Act. The CA Coastal Act calls for "upland" relocation of high-priority Coastal land uses due to SLR impacts. Ponto Park could also provide for "upland" relocation of the State Campground.

Part 2 of this Comparative analysis is a separate 2-page data file. This Part 2 file consists of the City's PCH map with numbered notes to documented City data on PCH design constraints, mapping the City's . 2017 Sea Level Rise Impact Areas, and outlining the easterly 6.5 acre portion of the 11-acre Planning Area F site that could be Ponto Park for acreage comparison purposes.

General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park- part 1 Page 3 of 4 Map 1.: COst eff ecti'ioel'Y using OJd carlsbad Btvd pa·.-.ernent for beach, carrwound & Ponto Patk parting - vehide access at Breakwater Rd, Poinsettia Lane, and Pont o Drive betw~en tne
centeTs of
parking and
Ponto Parle
road ... vay
inland South
General Comparative cost-benefits of Completing PCH-PCH Modification-Ponto Park - part 1 Page 4 of 4 City's PCH Modification Proposal Area Map with notes on usability Constraints and Issues: P4P Input 2 of 2 The City's map below is marked with the follow ing numbered list of Area Constraints and lssues . The Constraints are from the City's 2013 PCH Modification designs, the City's older 2017 Sea Level Rise Impact Study, and on-site observations . The Constraints will limit any fundamental change to the existing PCH landscape. For instance existing slope and habitat area will remain or have to be relocated which will limit the use of any excess land area from PCH Modification . These Constraints will then reduce from 62 acres the actual number of unconstrained and acres that are actually useable and can be used for different uses than current ly exist.

1. Loss of the last section of Old "Histor ic lO I" design , ambiance , and openness. Will it be replaced with typical urban arterial design?

2. Freshwater habitat

3. Sewer pumping facility

4. City's 2013 PCH plan for RESTORED RIPARIAN HABITAT

5. Sea Level Rise 2 meter Impact Area

6. City's 2013 PCH plan for BIO SWALE AND RESTORED RIPARIAN HABITAT

7. Ex isting beach parking to be retained

8. Least Tern habitat

9. Major storm water detention basin
IO. Water

11. Slopes will likely need retaining walls to move road inland closer to proposed Kam Sang Resort

12. Endangered Species Habitat

13. City's 2013 PCH plan for COASTAL SAGE SCRUB RESTORATION

14. City's 2013 PCH plan for NATIVE GRASSLAND RESTORATION

15. City's 2013 PCH plan for BIO SW ALE AND RESTORED RIP ARIAN HABITAT

16. Eliminating access road for homes/businesses south of Cape Rey Resort. Who pays to rep lace?

17. Removes Cape Rey Resort developer required GMP Open Space for this LFMP. This GMP Open Space will have to be replaced. Who Pays?

18. City's 2013 PCH p lan for L.l.D . BASIN / BIO SWALE

19. City left several acres vacant for 20+ years. This area can cost-effectively provide 200-500 more parking spaces w/o any PCH relocation.

20. U nusual jog in roadway. Is this viable?

21. City's 2013 PCH plan for RESTORED NA TJVE LANDSCAPE

22. Habitat & need to provide major storm water quality detention basin before discharging urban and creek runoff into ocean.

23. Slopes will likely need retain ing walls to move road inland closer to mobile home community.

24. Steep unusable slopes needed for Palomar Airport Road overpass over railroad corridor.

For a Cost/Benefit reference point, the City 's PCH Modification at Terramar (CIP project #6054 from Cannon to Manzano) that is less constra ined and simpler than South Carlsbad is projected to cost around $13 million per mile. Vacant primarily unconstrained land sale costs at Ponto are documented at around $1.4 to $2.4 million per acre. Honest Cost/Be nefit of these two options should be a public tax-payer discussion.

0 250 500 1,000 i'eet

I I' I I I I I
St-.t .,~@
July 13, 2021
cartsbad Boulevard Realignment: Right-of-Way and Available Land Analysis~ c:::::I Proposed ROW (Approximately 43 acres}
c::J Area Available for Other Uses (Approximately 62 acr°Wefu #l4 • Al\.,lys;s ;s ~ <>' ;,en,! lm.ge,y, R9ht.<>f-w.y boo.,,d>rio,; •nd "'_."9", ""• •~ .,d inw,ded for pl.nl'lnq i..-e1 Dl'djsis only. * * For comparative visual reference the area is the 6.S acre eastern portion of Planning Area F.

EXHIBIT 17
Page47 of53

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 P<;:H Relocation, which is not correct per the City's own 2001 URS Carlsbad Boulevard Realignment Study.

SICTIDIFOUR Phase II Rndlngs

4.1 LAND use ANALYSIS
Figure 4-1 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 thi.s project arc all currently designated as open space. 4, 1.1 Surplus Lands
A City-provided OIS parcel map was u~ in conjunction with a City~generated map showing land owner.ship in the project area to calculate the acres of land remaining after Carlsbad BouJevan:.I 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 calculated. The acr~ of land available following realignment of Carlsbad Boulevar:d are shown in Table 4.1 -1. Toe amount of City-owned land available for other uses following realignment of Carlsbad Boule,•ard 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. ·
Table4.l-1

LAND OWNERSHIP AND AMOUNT OF LAND AVAILABLE

CARLSBAD BOULEY ARD-REALIGNMENT
landowner Acreage
City of Carlsbad 41
Slate or California 15 .

The surplus useable rand that will result from realigning Carlsbad Boulevard has been grouped into a total of seven SUIJ)lUs land areas, described in Table 4.1-2 below and illustrated in Figures 1-3 through l-10.

Surplus Land Area Number
1 2
3 4
5 6A
68 URS
Tabfe4.1-2

SURPLUS LAND AREA DESCRIPTIONS

CARLSBAD BOULEVARD REALIGNMENT
Surplus Land Area Name Acreage
Manzano Parcel· 20.8
.

P.alomar Point 5.1
.

North Ponto Beach 10.1
Slate Se~ and 13.7 Campground -
Boca Be.lch 2.3
Sea-pointe Parcel 0,5
PA ''F' Front.age 20
Owner
State; c1ppn;,)(imately 14 acres
City. approxirrtalely 6 ac:-es
State: approxirna.te!y 0,5 oo-e
City: approximately 4.5 acres
City
Cit1
City
City
City
'A':198S300.JK•~002•-0-R.OOCl:5-0CT-'.it•.SDG 4- l

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 .
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Tab le S: PR£UMINARY REVENUE/COST COMPARISON (Y&ar 2001 Dollan;) R9Vgnucs From Comrnercl:al I.and S~les.

Capitalized Value of Fisca l Rever,ues to City & RDA
To~I Potenlial RC'Venuo,
Lj!u; Ro-,d Con.sltUC:IJ()l'I C~ts
Net Revenues ~&flc lt> Afte.r R<i~ C911$trUctlon Costs
less: Public Par1<1ng, Par1<.&, Open Sp-, .;md Faeilitl1>s Nol Revonue9 C:Oeflc:11> After Public Costs
Altematives
1 $ 1,131,000 $
$ 217.000 s
$ 1,348,000 $
s 18,800,000 s
$ <H.452,000) S
$ 6.9S9,550 s
$ (26.451,580) $
Source: Economics , Research Associates; URS; Wallaoo, Roberts & Todd Page4of5
2 3 4
G.219,000 s 28,155,000 s 19.465 ,000

10.64e.ooo s 24,743 ,000 s 16,429,000
20,068,,000 s 52,898,000 s 35,894 .000
18,800,000 s '8,800.000 s 18.800,000
1,26a,OOO s 34,098 ,000 s 1? ,094,000
12',062,589 s 8,496,734 s ~.358,925
(10.794 ,S89) S 25,601266 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, · particular ly 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 Relocatio n 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

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.

Eric Lardy, City Planner
Community Development Department
July 18, 2023
Carlsbad Tomorrow: Growth
Management Citizens Committee
1 { City of
Carlsbad
TODAY’S PRESENTATION
• Overview of Growth Management Program
• Formation Carlsbad Tomorrow: Growth Management Citizens Committee
• Growth Management Citizens Committee recommendations
– Changes to existing public facility standard
– Other quality of life concerns and recommendations
• Next steps
ITEM #9: Carlsbad Tomorrow: GMP Committee
2 { City of
Carlsbad

PROPOSED ACTION
Adopt a resolution:
• Accepting the report
• Directing staff to return with an implementation
program three months after the completion of
the housing element rezoning program
ITEM #9: Carlsbad Tomorrow: GMP Committee
3 {city of
Carlsbad

GROWTH MANAGEMENT PROGRAM

BACKGROUND
• Mid-1980s - period of rapid growth
• Concerns about adequate public facilities
• Citizens committee appointed
• Committee recommendations led to
Growth Management Program
ITEM #9: Carlsbad Tomorrow: GMP Committee
4 {city of
Carlsbad

TWO PARTS
ITEM #9: Carlsbad Tomorrow: GMP Committee
Ensure adequate public facilities
• Provide facilities with development
• Establish standards
Limit residential development
• Proposition E
• Limits number of housing units
5 GROWTH MANAGEMENT PROGRAM
ITEM #9: Carlsbad Tomorrow: GMP Committee
Proposition E:

Housing Caps
Citywide Facilities
Management Plan
Growth
Management
Ordinance
Local Facility
Management Plans
6 cD

CITYWIDE FACILITIES AND

IMPROVEMENTS PLAN
City admin. facilities Circulation
Libraries Drainage
Parks Sewer collection
Open space Water distribution
Schools Wastewater treatment capacity
Fire response
ITEM #9: Carlsbad Tomorrow: GMP Committee
7 ( City of
Carlsbad

LOCAL FACILITIES

MANAGEMENT ZONES
• 25 local facility zones
• Local Facility Management Plans
required
ITEM #9: Carlsbad Tomorrow: GMP Committee
8 ndary
ortlle s Ou ran
ortnwest auact:ranl
ou heasl Ouadr nl
Southwest Quad rant
City of Cad sbad
Quadrants . & LFMP Zones
( City of
Carlsbad

PROPOSITION E

HOUSING CAPS
NE
9,042
Total
SE
17,328
Total
NW
15,370
Total
SW
12,859 Total
Citywide Housing Cap: 54,599
Existing Housing Units: 48,687
ITEM #9: Carlsbad Tomorrow: GMP Committee
9 NW
15,370
otal
E
9,042
Total
859 Total
-
7,328
otal
( City of
Carlsbad
WHY NOW?
• New state laws passed that render parts of
city’s Growth Management Program
unenforceable
• Can no longer put a limit on how many
homes can be built in city
ITEM #9: Carlsbad Tomorrow: GMP Committee
10 {city of
Carlsbad

OTHER KEY CITY DOCUMENTS
General Plan Master PlansOther Dev. StandardsLocal Coastal Program Subdivision Ordinance
Building Code
Parks & Rec
Mobility
ITEM #9: Carlsbad Tomorrow: GMP Committee

EXAMPLES EXAMPLES
Municipal Zoning Code Title 21
11 GENERAL PLAN
• 2021-2029 Housing Element density increases
• Due in April 2024
• 3,897 Units
• Housing Element compliance
• Critical to retain local control of growth
• Avoid “builders remedy”
• Future changes
• After 2029 - uncertain
ITEM #9: Carlsbad Tomorrow: GMP Committee
12 { City of
Carlsbad

GROWTH MANAGEMENT COMMITTEE
• March 2022 – resident-led committee formed
• 19 primary members and 19 alternates
• Committee mission:
• Consider of a range of perspectives on issues
affecting the future growth and quality of life in
Carlsbad
• Identify the key elements of a new plan to manage
growth in a way that maintains an excellent quality
of life while also complying with state law
ITEM #9: Carlsbad Tomorrow: GMP Committee
13 Orientation,
background &
history

COMMITTEE PROCESS
Review existing standards,
presentations from
subject matter experts,
committee dialogue
Formulate
proposed
standards
MARCH
2022
Consider final
input. Refine and
finalize draft
standards.

Finalize
report
APRIL
2022
ITEM #9: Carlsbad Tomorrow: GMP Committee
14 COMMITTEE CONSIDERATIONS
• Current program uses housing cap, facility
standards, funding strategies, and moratorium
if standards are not met
• Housing cap and moratorium are no longer
allowed under state law
• Remaining way to manage growth is standards
and funding
ITEM #9: Carlsbad Tomorrow: GMP Committee
15 { City of
Carlsbad

COMMUNITY ENGAGEMENT
ITEM #9: Carlsbad Tomorrow: GMP Committee
16 (
City of Carlsbad @carlsbadcagov • Mar 28, 2022
#Getinvolved in #Carlsbad this week. The 1st Growth Management Citizens Committee mtg will be at 5 pm on 3/ 30 at Faraday. You can also livest ream meeting by using this link loom.ly/aMJoBWo. Agenda and more info can be found here loom.ly/Oc60Cbw #loca lgov
City of Carlsbad @carlsbadcagov • Jan 11
Carlsbad Tomorrow Growth Management Citizens Committee meeting is about to start . The committee will develop a new plan for how to manage growth while maintaining #Carlsbad quality of life
Watch loom.ly/cuJ2VVo
Agenda loom.ly/Oc60Cbw
#localgov #getinvolved
0 n 0 2
Carlsbad ..,..

RR W
Grow1h M.an.ment Otlzem. Cornmlttee
1l,1 625
Jan. 11, 2023
Sp.m.

Carlsbad
-v-
R w
Growth MJin.tgOrMnl Clhz ns. Comm1ttN
Feb.23,2023
Sp.m.

The Carlsbad Tomorrow Growth Managemen t Citizens Committee will meet Thursday evening to discuss Its last few remaining topics to help the city develop a new plan for how to manage growth. Specific topics up for discussion on Thursday will include:
• Open space
• Climate Action Plan
• Environmental sustainability - renewable energy and local electric power generation
• Draft performa nce standard pages that summarize the committee's recommendations so far (these will be included in the committee's final report presented to the City Council)
Bac kgrou nd
• Since March of last year, the resident-led committee has been learning about and discussing 11 existing :11erformance standards." Performance standards refer to the level of service that needs to be maintained to ensure Carlsbad's excellent quallty of life.
• Developers either pay fees toward or build the infrastructure and amenities needed to maintain these standards based on the new residents who will live in their housing.
• The current standards were first put in place in tl1e 80s. • The committee is helping to update the standards to reflect the community's current needs and priorities.

The group has learned about and discussed the existing standards, and are now working on finalizing their recommendations for future Growth
Com mittee studying growth fi nalizing draft re port
A resident-led committee created by the City Council is finalizing a draft report !hat idenlifies issues and standards to help ensu re Carlsbad retains an excellent quality of life as it continues to grow.

The year-long committee process is the first step in developing a new long­ lerm growth manage ment program. Afte r meeting 13 limes in the past year, the committee is getting ready to finalize its recommen dations.

Why now?
The City of Carlsbad's growth manage ment program was crealed in the late 80s and is largely credited with maintaining the city's ex cellent quality of life, well-planned infrastructure and finan cial health over the past 35+ years.

In recent years, new state laws have been passed th at mean some parts of the program are not enforceable, including puttin g a limit on how many new homes can be built in th e city.
• The stale laws are meant to address a critical statewide shortage of housing by making it more difficult for cities to deny new housing projects.
• Affordable housing, which is usually apartments and condos, is a big focus of the new stale laws, as is locating new housing close to transit hubs.

What is t he com mittee recommend ing?
The committee reviewed the "performance standa rds" identified in the current growt h mana geme nt program - which refer to th e level of service for fa cilities like roads, sewer pipes, parks and libraries. Currently, developers pay fees or build infrastructure neede d to accommodate new residents who will live in th eir housing.

Eric Larson, Chair
Carlsbad Tomorrow Growth Management
Citizens Committee
July 18, 2023
Carlsbad Tomorrow: Growth
Management Citizens Committee
Recommendations
17 { City of
Carlsbad

COMMITTEE

RECOMMENDATIONS
• Final Report
• Recommends key public facilities to
be addressed in a new plan to manage
growth
ITEM #9: Carlsbad Tomorrow: GMP Committee
18 Carlsbad -v--:

TOMORR W
Growth Management Citizens Committee
!FINAL REPORT
APRIL 2023

DEPARTMENTS AND AGENCIES CONSULTED
 City Attorney  Communication & Engagement  Community Services  Cultural Arts  Environmental Sustainability  Finance  Fire  Housing & Homeless Services  Innovation
 Land Use Engineering  Library  Parks & Recreation
 Planning  Police  Transportation
 Utilities  CMWD  SANDAG
ITEM #9: Carlsbad Tomorrow: GMP Committee
19 NO CHANGE/KEEP 5 EXISTING STANDARDS
• Library has served community well.
• Current standard based on 1980’s industry standard.
• No new industry standard to replace it.

Committee considered:
• How Carlsbad compares to other cities
• Quadrant vs. citywide standard
• Potential increase in park standard
• Access to parks for all residents
• In the end, majority voted to retain standard as is
ITEM #9: Carlsbad Tomorrow: GMP Committee
20 ...

Libraries 0
Parks 0
NO CHANGE/KEEP 5 EXISTING STANDARDS
Committee considered:
• Ability to move safely/conveniently critical to quality of life • Traffic congestion needs to be addressed
• Streets should better accommodate all modes of travel • Some preferred staff-recommended standard based on
Sustainable Mobility Plan
• In the end, majority voted to retain standard as is
ITEM #9: Carlsbad Tomorrow: GMP Committee
21 Circulation 0
(mobility)
NO CHANGE/KEEP 5 EXISTING STANDARDS
• Drainage infrastructure important to future quality of life • Drainage infrastructure needs are specific to development • Current standard will be effective for future development • Sewer collection important to future quality of life
• Sewer collection needs are specific to development
• City assesses system capacity every 5 years
• Sewer collection system has adequate capacity to meet demand ITEM #9: Carlsbad Tomorrow: GMP Committee
22 =I~ • s ¥4"' 0
Drainage
III T 0 Sewer
collection
system
REMOVE 4 EXISTING STANDARDS
• Sufficient processes exist to maintain sewer system/treatment • Encina Wastewater Authority long-term program ensures adequate service for future growth
• Standard no longer reflects modern business operations • New civic center/city hall will exceed standard
• Standard unnecessary to continue to provide admin. facilities ITEM #9: Carlsbad Tomorrow: GMP Committee
23 ffll @ Waste ·water
treatment
capacity
&
I
City @
adm i'nistrati've
faciliti'es
REMOVE 4 EXISTING STANDARDS
• Fire Chief advised existing standard is not best method to evaluate service needs or performance
• Best practices include ever-evolving metrics not related to development • Fire Dept. annually reports to City Council on Fire service needs • Also considered Police services as a related public safety service • Determined both fire and police services are adequately addressed through other city policies and plans.
• Schools maintain their own service standards
• City has no control over development of schools
• School district facility plans include city growth projections • New development must confirm adequate should capacity ITEM #9: Carlsbad Tomorrow: GMP Committee
24 efte
Schoo ils
Existing Standard (Retained) Additional Recommendation

3.0 acres of community park or special use area
per 1,000 population within the park district
must be scheduled for construction within a five-
year period beginning at the time the need is
first identified.

The committee is requesting that the City Council
direct staff to evaluate the feasibility of creating
and implementing a distance based standard to
any publicly accessible park.

PARKS STANDARD

ADDITIONAL RECOMMENDATION
ITEM #9: Carlsbad Tomorrow: GMP Committee
25 Existing Standard Modified Standard (Summary)
Line capacity to meet demand as determined by
the appropriate water district must be provided
concurrent with development.

A minimum 10-day average storage capacity
must be provided prior to any development.

Concurrent with development, coordinate with
the appropriate water district to ensure water
pipelines have capacity to meet increased
demand
MODIFY

WATER DISTRIBUTION SYSTEM STANDARD
ITEM #9: Carlsbad Tomorrow: GMP Committee
26 MODIFY OPEN SPACE STANDARD
Existing Standard Modified Standard (Summary)
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.
[Applies to Local Facilities Management
Zones 11-15 and 17-25]
 Specify that open space is required in all Local
Facility Management Zones, consistent with city
policies and regulations.
 Require 15% open space, as currently required,
and clarify which Local Facilities Management
Zones it does and does not apply, pursuant to the
Citywide Facilities and Improvements Plan
adopted by the City Council in 1986.
 Refer to the rationale used in 1986 to determine
where to apply the 15% open space requirement.

ITEM #9: Carlsbad Tomorrow: GMP Committee
27 COMMITTEE

RECOMMENDATIONS
• Quality of Life Concerns &
Recommendations
• Important quality of life topics –
not to be included in new plan to
manage growth
ITEM #9: Carlsbad Tomorrow: GMP Committee
28 Carlsbad -v-~
TOMOR
Growth Management Citizens Committee

QUALITY OF LIFE CONCERNS
& RECOMMENDATIONS
APRIL 2023

QUALITY OF LIFE TOPICS CONSIDERED
 Arts and culture  Behavioral health  Cellular service/wi-fi access  Climate change  Energy resources  Homelessness
 Physical health  Proposition H  Public safety (Police)  Ponto park  Senior community needs  Technology
 Village development  Walkability  Water resources & quality ITEM #9: Carlsbad Tomorrow: GMP Committee
29 Arts & Culture Energy Advisory
Committee
Coastline
 Give arts high priority in
strategic planning and
operating budget
 Give serious consideration
to a 750-seat cultural
performing arts center
 Create a citizens group
that would annually report
to the City Council on
energy-related activities
that impact residents and
businesses.
 Give top priority to
expansion, protection, and
enhancement of public
access to and use of the
beach and shoreline bluffs

SUMMARY

QUALITY OF LIFE CONCERNS & RECOMMENDATIONS
ITEM #9: Carlsbad Tomorrow: GMP Committee
30 Fees Homelessness Senior/Aging Community
 Evaluate all public facility
impact fees on a regular
basis (no more than every
5 years) and update as
needed
 Homelessness should
remain a priority in the
Strategic Plan and
Operating Budget
 Support continued efforts
of Homeless Outreach
Team and affordable
housing programs
 Continue efforts to ensure
needs of seniors are met
 Senior community and
aging population should
remain a priority in the
Strategic Plan and
Operating Budget

SUMMARY

QUALITY OF LIFE CONCERNS & RECOMMENDATIONS
ITEM #9: Carlsbad Tomorrow: GMP Committee
31 Open Space Proposition H
 Evaluate adding open space needs to the
purview of the Parks & Recreation
Commission
 Adopt a policy to discourage actions that
would decrease open space
 Consider a ballot measure to increase the
$1M expenditure limit of Proposition H
 Set aside funding for public safety capital
improvement projects, like fire stations
 Specify in a future ballot measure that
certain types of projects don’t require
voter approval to exceed the spending
limit ($1M)

SUMMARY

QUALITY OF LIFE CONCERNS & RECOMMENDATIONS
ITEM #9: Carlsbad Tomorrow: GMP Committee
32 Transportation and Mobility
 Use Sustainable Mobility Plan and Multimodal Transportation Impact Fee to implement future multimodal transportation projects
 Require new development to conduct intersection level of service and multimodal level of service analysis
 Complete the typology-based street network, pursuant to the General Plan  Update the multimodal transportation impact fee for all modes  Improve traffic signal synchronization to improve vehicle mobility and reduce potential environmental impacts from vehicle emissions

SUMMARY

QUALITY OF LIFE CONCERNS & RECOMMENDATIONS
ITEM #9: Carlsbad Tomorrow: GMP Committee
33 Eric Lardy, City Planner
Community Development Department
July 18, 2023
Carlsbad Tomorrow: Growth
Management Citizens Committee
34 { City of
Carlsbad

COMMITTEE DECISIONS
Libraries Water distribution system
Parks Open space
Circulation (mobility) Wastewater treatment capacity
Drainage City Administrative Facilities
Sewer collection system Fire
Schools
ITEM #9: Carlsbad Tomorrow: GMP Committee
35 0
0 0
0 0
©
©
0 0
0 0

PROPOSED ACTION
Adopt a resolution:
- Accepting the Report
- Directing staff to return with an
i
mplementation program three months
after completion of the housing element
rezoning program
ITEM #9: Carlsbad Tomorrow: GMP Committee
36 { City of
Carlsbad

CARLSBAD PARKS INVENTORY
• 42 existing community parks and
special use areas
38 \
------ ~arlsbad City Parks
~- '-- --7
I
'
---
,.

I
' , '
Commun ity Park
Special Use Area
Future Park
'
L._
---
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