Carlsbad City Council
December 7, 2023

To the members of the:

CllYCOUNCIL
Date P-\112~A / CC ~ /
CML_ACM~M(3)L
December 7, 2023
Council Memorandum
To:

From:

Honorable Mayor Blackburn and Members of the City Council Gary Barberio, Deputy City Manager, Community Services
Jeff Murphy, Community Development 2-5ector
{city of
Carlsbad
Memo ID# 2023122
Via
Re:

Geoff Patnoe, Assistant City Manager ~
SAN DAG 2021 Regional Plan Amendment/2025 Regional Plan (Districts -All) This memorandum provides information about the city's continuing invo lvement in the San Diego Association of Governments' (SAN DAG) 2021 Regional Plan (RP) Amendment, the 2025 RP and an update to the City Council Memorandum dated October 21, 2021 (Attachment A).

Background
RPs are long-range planning documents, usually 30 years, that define how regions will make future transportation investments, based on regional goals, and estimates of available funding. Federal regulations require that long-range RPs be updated every four years.

The 2021 RP
As reported under the "Next Steps" section of the City Council Memorandum dated October 21, 2021, the SAN DAG Board of Directors was scheduled to consider the 2021 RP and associated Environmental Impact Report (EIR) at their December 10, 2021, meeting. After substantial public testimony, the SAN DAG Board of Directors ultimately approved the 2021 RP as recommended by SAN DAG staff, which failed to address the city's previously documented concerns.

At th e time of adoption, the 2021 RP included a regional Road User Charge (RUC)1 as one of the region's projected funding sources. This item was strongly opposed by stakeholders and many jurisdictions and, as a result, the SAN DAG Board of Directors directed SANDAG staff at the same December 10, 2021, meeting to amend the approved 2021 RP and remove the RUC. The process of amending th e 2021 RP required that SAN DAG staff revise their environmental analysis, referred to as a Supplemental Environmental Impact Report (SEIR), and follow a coordinated procedure invo lving data analysis, interagency consultation, and community engagement. 1 The RUC is a "user pays system" where all drivers pay to maintain roads based on how much they drive rather than how much gas they purchase. Under this system, all drivers share roadway maintenance and repair costs based on what they use.

Community Services Branch
Community Development Department
1635 Faraday Avenue I Carlsbad, CA 92008 I 442-339-2600 t Council Memo -SAN DAG 2021 Regional Plan Amendment/2025 Regional Plan {Districts -All) December 7, 2023

SAN DAG phased the public comment period for the 2021 RP Amendment in two parts: one for review of the amended RP (which focused solely on the RUC) and a second for review of the SEIR.

City staff submitted a comment letter on the 2021 RP Amendment on August 8, 2023, (Attachment B), and a second comment letter on the SEIR on August 28, 2023, (Attachment C). The comments provided were largely a duplication of the comments city staff provided to SAN DAG staff in August 2021, which were not addressed when the SANDAG Board of Directors approved the 2021 RP.

All comments and responses (Attachment D) were presented to the SAN DAG Board of Directors at their October 13, 2023, meeting where they voted to approve the 2021 RP Amendment and certify the Final SEIR {Attachment E). The 2021 RP Amendment can be found at:
https://www.sandag.org/regional-plan/2021-regional-plan/amendment-to-2021-regional-plan Refer to the "Discussion" section below for information on SAN DAG staff's response to city comments.

The 2025 RP
In 2023, SAN DAG held several public outreach events and input opportunities as part of the 2025 RP preparation. In response to a Notice of Preparation2 issued by SAN DAG in January 2023, city staff participated in public scoping meetings for the RP's Program Environmental Impact Report (PEIR) and provided a letter commenting on what the PEIR should consider {Attachment F). The provided comments mirror many of the comments included in both the 2021 RP and 2021 RP Amendment comment letters.

In June 2023, city staff attended the 2025 RP kickoff meeting. The event provided an overview of the 2025 RP and featured an open question and answer session. SANDAG staff discussed what had been learned from the 2021 RP and what feedback they are planning to integrate into the upcoming RP. SAN DAG staff indicated that after receiving comments from stakeholders and the public, the agency will be focused on developing a variety of near and long-term proposals to address access, safety, and affordability as well as ensuring that there is consistency between the RP and local jurisdictions' General Plans. Recently, the SAN DAG Board of Directors at their September 22, 2023, meeting provided direction to SAN DAG staff to develop a concept for the 2025 RP that does not include or reintroduce a regional RUC or any other per-mile charge.

For each RP, SAN DAG creates a new computer growth model that shows housing and population forecasts and the envisioned regional transportation network in future years. For the 2025 RP, SAN DAG is developing the "Series 15" growth model.

Discussion
The 2021 RP Amendment
City staff's full comments as submitted in the August 8, 2023, and August 28, 2023, comment letter are provided in Attachments B and C, and SAN DAG staff's responses to the SEIR comments are provided in Attachment D. But, in summary, the 2021 RP Amendment focused on the RUC 2 A Notice of Preparation (NOP) is a notice sent by the lead agency (in this case SAN DAG) to notify the public, responsible agencies, and impacted jurisdictions that they plan to prepare an EIR for their project. This is early notification required under the California Environmental Quality Act (CEQA).

Council Memo -SAN DAG 2021 Regional Plan Amendment/2025 Regional Plan (Districts-All) December 7, 2023

changes and did not address city staff's concerns with the original 2021 RP. These concerns primarily related to two consequential components of the RP: 1) Inconsistencies between the RP's land use patterns and the city's approved General Plan land uses; and 2) The suitability of certain factors used in the RP's population growth forecasts. City staff also submitted comments related to the technical sufficiency of the 2021 RP Amendment SEIR.

These comments notwithstanding, SAN DAG staff have stated that they will address these concerns in the 2025 RP update, the development of which is on-going and is expected to be finalized within the next two years.

The 2025 RP
Through much of 2023, SAN DAG staff has worked with local jurisdictions, including Carlsbad, to obtain feedback on the data and assumptions that will be used in Series 15 growth model. This process starts with land use factors and then considers transportation network factors. To date, city staff have provided approximately 130 site-specific comments to address errors and potential discrepancies related to land use, constraints, parcel buildout status, project locations and status, and regulatory residential capacity. The process for land use data collection and verification concluded on November 2, 2023, and city staff will continue to consult with SAN DAG as it develops the data and will provide accurate information related to the city's General Plan. At this early stage, city staff does not have any issues or concerns to raise to City Council's attention . More information will become available as the regional model components are developed further and outputs are made available for review.

It is worth noting that recent economic and demographic forecasting from the California Department of Finance, which helps form the basis for the 2025 RP, forecasts a decline in population starting in 2035 (Attachment G). This is a first in San Diego. Further, the 2021 RP forecasts (Series 14) not only assumed growth, but substantial growth, throughout the forecast time horizon of 2050. As such, the difference between the two models for the forecast year of 2050 varies by approximately 400,000 people. While the impacts of this change on the 2025 RP are unclear, they are likely to be wide-ranging . Staff will communicate any pertinent information about the RP's forecasts and land use and transportation network assumptions as they become available later this winter and spring.

Next Steps
SAN DAG anticipates the following future actions related to the preparation of the 2025 RP:
• All of 2024/early 2025: Validation and evaluation of land use and transportation network information provided by member agencies, development and evaluation of PEIR alternatives, and preparation of environmental documentation for public review • Spring/Summer 2025: Draft PEIR release for public review • Fall 2025: Final PEIR and response to comments release for public review • Winter 2025: SAN DAG Board considers approval of the final 2025 RP and PEIR Council Memo -SAN DAG 2021 Regional Plan Amendment/2025 Regional Plan (Districts-All) December 7, 2023

As with past RP's, city staff will continue to facilitate interagency consultation by participating in community engagement events and reviewing all project-related materials and recommend changes at each milestone, as necessary, to ensure that re.gional goals, policies, and priorities are fiscally responsible, sustainable, context-sensitive and collaborative.

Attachment: A. City Council Memorandum -Dated October 21, 2021 https://records.carlsbadca.gov/Weblink/DocView.aspx?id=5493674&dbid=0&r epo=CityofCarlsbad
(Due to the size of Attachment A, a hard copy is on file in the Office of the City Council, as reference)
B. City of Carlsbad letter dated August 8, 2023 (Amendment to the RP) (Due to the size of Attachment B, a hardcopy is on file in the Office of the City Council, as reference)
C. City of Carlsbad letter dated August 28, 2023 (Draft SEIR for Amendment to the RP; Without Attachment)
D. SAN DAG Responses to the August 28, 2023, Carlsbad Draft SEIR comment letter E. Adopted SAN DAG 2021 RP Amendment (Without Attachments) F. City of Carlsbad letter dated March 6, 2023 (Notice of Preparation for an EIR) G. SANDAG Series 15 Regional Growth Forecast Slides
cc: Scott Chadwick, City Manager
Cindie McMahon, City Attorney
Ron Kemp, Senior Assistant City Attorney
Gina Herrerra, Assistant City Attorney
Paz Gomez, Deputy City Manager, Public Works
Tom Frank, Transportation Director
Tina Ray, Communication & Engagement Director
Mike Strong, Assistant Community Development Director
Eric Lardy, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager Jason Geldert, Engineering Manager
Robert Efird, Principal Planner
Scott Donnell, Senior Planner
Nicole Morrow, Assistant Planner
•
•
..

Attachment A
To the members of the:

CITY COUNCIL
Date~ CA / cc ./
cM _LAcM ✓ocM (3) L
Council Memorandum
Oct. 21, 2021
To:

From:

Via:

Honorable Mayor Hall and Members of the City Council
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Jeff Murphy, Community Development Director
Tom Frank, Transportation Director/ C~ gineer
{city of
Carlsbad
Memo ID# 2021195
Re:

Geoff Patnoe, Assistant City Manager~
SAN DAG 2021 Regional Transportat ion Plan Draft EIR Comment Letter (Districts -All) This memorandum provides an update to a previous Council Memorandum dated Aug. 12, 2021 (Attachment A), with information on staff's recent comment letter (Attachment B) on the San Diego Association of Governments (SAN DAG) draft Environmental Impact Report (EIR) proposed for the 2021 Regional Transportation Plan (RTP), a long-term blueprint of the region's transportation system.

Background
RTPs are long-range planning documents (usually 30 years) that define how regions will make future transportation investments, based on regional goals and estimates of available funding.

Federal regulations require that long-range RTPs be updated every four years.

Beginning in 2016, SAN DAG began the process of updating its RTP for the San Diego region.

During development of thi_s draft RTP, an interim plan was adopted in 2019 to comply with federal requirements but did not make substantial revisions to the previously adopted plan. This new RTP, once adopted, will become the region's long-term plan to be implemented incrementally through the Regional Transportation Improvement Program (RTIP).

Federal transportation legislation requires that regionwide transportation planning be coordinated with local agencies and other stakeholders. It also implements requirements for SAN DAG under Senate Bill 375 to reduce greenhouse gas targets adopted by the.California Air Resources Board. An informational website, which includes the draft RTP and draft EIR, is available at https://sdforward.com/ .

Discussion
The draft 2021 RTP was the result of years of planning, data analysis and community engagement where SAN DAG reimagined a more transformative transportation system, a sustainable pattern of growth and development, and innovative demand and management strategies (referred to as "5 big moves"). The draft 2021 RTP was circulated for public review and comment from Community Services and Public Works Branches
Community Development and Transportation Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-4600 t Council Memo -SAN DAG 2021 RTP Draft EIR Comment Letter (Districts -All) Oct. 21, 2021

May 28, 202t, to Aug. 6, 2021. The city provided comments to SAN DAG on Aug. 6, 2021, which were provided to City Council in a Council Memorandum dated Aug. 12, 2021 (Attachment A).

On Aug. 27, 2021, SAN DAG released the draft EIR for the 2021 RTP for a 45-day public review period. The draft EIR failed to address the issues raised in the city's Aug. 6, 2021 letter. In response, the city provided a comment letter on Oct. 11, 2021 (Attachment B), that highlights all of the same points as the previous letter, with the following additional comments/concerns:
1) Procedures related to CEQA, and the timeline that hinders public input since the comments on the draft RTP were not responded to or incorporated into the draft EIR; 2) Evaluation of impacts to existing Land Use Plans, and the lack of a reasonable range of alternatives that show what would occur if funding or land use assumptions are not made; and,
3} Lack of sufficient detail in the chapters related to transportation, hazards, noise or other planned growth in the draft EIR.

Next Steps
According to the latest correspondence with SAN DAG, the SAN DAG Board of Directors will be asked to adopt the RTP on Dec. 10, 2021. City staff will continue to review all project-related materials and recommend changes at each milestone as necessary to ensure that regional goals, policies and priorities are fiscally responsible, safety-conscious, sustainable, context-sensitive and collaborative .

Attachments: A. Council Memorandum dated Aug. 12, 2021
B. City of Carlsbad letter dated Oct. 11, 2021
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Laura Rocha, Deputy City Manager, Administrative Services Robby Contreras, Assistant City Attorney
Ron Kemp, Assistant City Attorney
Mike Strong, Assistant Director of Community Development Nathan Schmidt, Transportation Planning & Mobility Manager Don Neu, City Planner
Eric Lardy, Principal Planner
To the members of the:
,,f.lT{ COUNCIL
Date~ CA X.. CC _L
CM ~ ACM ...::k_ DCM (3) ~
Aug.12,2021
Council Memorandum
To: Honorable Mayor Hall and Mem of the City Council
From: Gary Barberio, Deputy City Ma ager, ommunity Services Branch Paz Gomez, Deputy City Manag , Pu lie Works Branch
Jeff Murphy, Community Develop
Torn Frank, Transportation Directo /C ~~~
Via: Geoff Patnoe, Assistant City Mana er
Attachment A
{cityof
Carlsbad
Memo ID #2021154
Re: Draft SAN DAG 2021 Regional Trans rtation Plan Comment Letter {Districts -All) This memorandum provides information on staffs recent comment letter (Attachment A) on the San Diego Association of Governments (SAN DAG) proposed 2021 Regional Transportation Plan (RTP), a long-term blueprint of the region's transportation system.

Background
RTPs are long-range planning documents (usually 30 years) that define how regions will make future transportation investments, based on regional goals and estimates of available funding.

Federal regulations require that long-range RTPs be updated every four years. Beginning in 2016, SAN DAG began the process of updating its RTP for the San Diego region. During development of this draft RTP, an interim plan was adopted in 2019 to comply with federal requirements but did not make substantial revisions to the previously adopted plan. The new RTP plan, once adopted, will become the region's long-term plan to be implemented incrementally through the Regional Transportation Improvement Program (RTIP).

Federal transportation legislation requires that regionwide transportation planning be coordinated with local agencies and other stakeholders. To that end, the draft 2021 RTP was circulated for public review and comment from May 28, ·2021 to Aug. 6, 2021. Comments that were received during the public review period will be reviewed and incorporated, as appropriate, into the environmental analysis and/or final RTP. •
Discussion
The draft 2021 RTP was the result of years of planning, data analysis and community engagement where SAN DAG reimagined a more transformative transportation system, a sustainable pattern of growth and development, and innovative demand and management strategies, referred to as "5 big moves". The draft 2021 RTP also implements requirements for SAN DAG under Senate Bill 375 to reduce greenhouse gas targets adopted by the California Air Resources Board. An informational website, which includes the draft 2021 RTP plan, is available at https :lj sdforwa rd. com/.

Community Services and Public Works Branches
Community Development and Transportation Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-4600 t Council Memo - Draft SAN DAG 2021 RTP Comment Letter (Districts-All) Aug. 12, 2021

To facilitate interagency consultation, city staff from the Community Development and Transportation Departments reviewed available project materials and transmitted comments in a letter on Aug. 6, 2021 (Attachment A). Below is a summary of the major issues/concerns and recommendation ·s provided in staff's Aug. 6, 2021, comment letter:
1) The draft 2021 RTP inventories and assesses existing and future conditions in each city.

However, despite previously providing information to SAN DAG staff, the assumptions they used in the d~aft 2021 RTP for "existing'' and "planned" land use and transportation in the City of Carlsbad are not consistent with our adopted land use and transportation pollcies (e.g., forecasted housing and roadway capacities). For example:
• SAN DAG projects over 700 new residential units will be constructed adjacent to the McClellan-Palomar Airport Runway (residential use is not currently planned in this area under the city's General Plan nor allowed by the Federal Aviation Administration)
• Roughly 2,800 units are assumed to be developed on existing lands that are either currently developed as hotel resorts or are dedicated open space • SAN DAG assumes a declining population of roughly 2,300 persons in areas outside of the city's local mobility hubs (most of the city) due to children who have grown up and left their parents' homes. This assumption is being applied regionwide, where they assume a reduction of approximately 85,000 persons throughout San Diego
2) The land use assumptions, many of which are not substantially supported with facts, are used to justify reduction targets in greenhouse gas emissions and vehicle miles travelled.

If their assumptions do not occur on the macro or micro level, which staff finds that it is very likely that they will not be achieved, the draft 2021 RTP will adversely impact any . public and private projects that are required to use the regional transportation models for California Environmental Quality Act (CEQA) purposes (e.g., future General Plan amendments, private development projects). Existing land use and transportation plans and studies should serve as the starting point to best understand how new goals, policies and priorities may target transportation investments and best increase real choices in travel modes. It should be clear how the draft 2021 RTP expects these changes to occur, instead of modeling a scenario constructed in order to meet reduction goals. 3) Since the transportation system provides access and mobility to the traveling public and land uses impose demands on the system, the draft 2021 RTP should address if there are changes in ridership behavior which may have occurred because of the COVID-19 pandemic.
4) The draft 2021 RTP needs to more extensively address the disruption that is expected from automated/shared vehicle technologies and conduct an alternatives analysis. For example, autonomous vehicles are expected to have a huge impact on mobility demands Council Memo - Draft SAN DAG 2021 RTP Comment Letter (Districts -All) Aug. 12, 2021

in the future, but the draft 2021 RTP does not provide enough analysis on how it will impact future transpC?rtation needs.
5) Emphasis is being placed on regional rail improvements for a high-speed rail system, including improvements to the LOSSAN Rail Corridor. More information is ne~ded on the anticipated alignment, segments and cost estimates . The portion of the corridor in the City of Carlsbad will likely need to 'be a special study area. 6) The appendix in the draft 2021 RTP only lists potential projects; it does not show potential alignments, right of way needed or coordination with specific agencies. More information needs to be provided in the draft 2021 RTP on project implementation phasing (both short -range and long-range improvements), unfunded projects and various . funding mechanisms that can bridge the unfunded gaps. 7) The draft 2021 RTP was released without the benefit of availability of the Draft Environmental Impact Report (Draft EIR), which staff were told would be released later this summer . The quick release of the Draft EIR following the due date of comments for the draft 2021 RTP makes it practically impossible to make changes to the Dra~ EIR before it is released. SAN DAG should clarify how these comments will be addressed in the Draft EIR required topic areas of CEQA.

Next Steps
SAN DAG reports that the Draft EIR will be released in summer 2021. According to the work program schedule, the SAN DAG Board of Directors will be asked to adopt the draft RTP in late 2021. City staff will continue to review all project-related materials and recommend changes at each milestone as necessary to ensure that regional goals, policies and priorities are fiscally responsible, safety-conscious, sustainable, context -sensitive and collaborative.

Attachment: A. City of Carlsbad letter dated Aug. 6, 2021 cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Laura Rocha, Deputy City Manager, Administrative Services Robby Contreras, Assist~nt City Attorney
Ron Kemp, Assistant City Attorney
Mike Strong, Assistant Director of Community Development Nathan Schmidt, Transportation Planning & Mobility Manager .

Don Neu, City Planner
Eric Lardy, Principal Planner
Oct. 11, 2021
SANAG Regional Plan EIR
San Diego Association of Governments
401 B Street, Suite 800
San Diego CA 92101
C/O Kirsten Uchitel, Associate Planner.

Via: [email protected]
Attachment B
( city of
Carlsbad
RE: City of Carlsbad Comments on Draft Environmental Impact Report for the 2021 Regional Plan Dear Ms. Uchitel:

The City of Carlsbad ("city") appreciates the opportunity to provide comments on the draft Program Environmental Impact Report ("PEIR") for the 2021 Regional Plan ("Plan"), dated Aug. 27, 2021. This is an important plan for the region and will guide the next phase of growth for the member agencies of the San Diego Association of Governments ("SAN DAG"), including the city. An effectively designed and implemented regional transportation plan would help ensure improved transportation options for area residents, businesses and other community members, as well as meaningful reductions in greenhouse gas ("GHG") emissions and improved quality of life as we grow our communities.

The city previously submitted comments on the Plan to SANDAG staff on August 6, 2021 (Attachment 1), expressing multiple concerns about the Plan, its implementation and its potential impacts on the environment. Additionally, the city sent a follow up letter on September 30, 2021 (Attachment 2), to clarify the city does not wish to remove El Camino Real (project CB32) from the Regional Arterials Project List. Copies of the city's prior letters are included here as Attachment 1 and Attachment 2, respectively. Both letters are incorporated herein by this reference as additional comments on the adequacy of the PEIR and should be included in the administrative record of SANDAG's proceedings concerning the Plan and the PEIR.

The California Environmental Quality Act ("CEQA") is intended "to afford the fullest possible protection to the environment within the reasonable scope of the statutory language." (Friends of Mammoth v.

Board of Supervisors (1972) 8 Cal.App.3d 247, 259.) With narrow exceptions, CEQA requires an EIR whenever a public agency proposes to approve or to carry out a project or activity that may have a significant effect on the environment. (CEQA Guidelines§ 15002(f).) The basic purpose of an EIR is to provide public agencies and the public in general with detailed information about the effect that a proposed project or activity is likely to have on the environment and to identify ways in which the significant effects might be reduced or avoided. (Public Resources Code § 21061; CEQA Guidelines§ 15003.) The EIR and its associated process create layers of accountability and must "reflect a good faith effort at full disclosure." (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal. App. 3d 692, 712, citing CEQA Guidelines§ 15151.) The EIR process must provide meaningful information for an environmental assessment so that the public will know the basis on which decisions are made on a proposed project or activity and can respond accordingly to action with which it disagrees.

Transportation & Community Development Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2710 t City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan Oct. 11, 2021

In this case, the city seeks to ensure that SAN DAG prepares an environmental document that is adequate, complete and ft.illy discloses the potential significant adverse effects of the Plan. Further, to implement the principles of CEQA, SANDAG should not truncate the requisite cumulative impact analysis (CEQA Guidelines section 15168(b)(2)), use improper baselines (CEQA Guidelines section 15152), or foreclose the consideration of any alternative or mitigation measure that would ordinarily be part of CEQA review of a regional plan (C:EQA Guidelines section 15004(b)(2)(B)). If the EIR fails to prov ide decision-makers and the public with all of the relevant information regarding a project that is necessary for informed decision-making and public participation, the environmental document is flawed and deficient and the agency's decision will be set aside (Kings County Farm Bureau v. City of Hanford, supra, 221 Cal. App. 3d at p. 712).

CEQA prescribes review procedures a public agency must follow before approving or carrying out proposed projects. Those procedures emphasize the importance of public participation in the CEQA process, including mandatory opportunities for public review and comment and the lead agency's obligation to provide meaningful responses to comments received. A Notice of Preparation (NOP) was -issued on November 14, 2016 and a public scoping meeting was held on December 8, 2016. Although the early consultation with affected agencies and organizations was appreciated, and a necessary procedural step per CEQA Guidelines section 15082, SAN DAG subsequently made a material change in the_ scope of the project to encompass the vision of 5 Big Moves, without providing an opportunity for additional scoping and consultation with the public and affected agencies. SANDAG failed to re-engage the public and affected agencies to provide them with sufficient information regarding the revised Plan and its potential environmental effects to enable them to make a meaningful response about the scope and content of the anticipated environmental work. Due to this procedural error, the public and affected agencies have been denied the opportunity to provide SAN DAG with specific detail about the significant environmental issues and reasonable alternatives and mitigation measures that needed to be explored in the draft PEIR, early enough in the CEQA process for SAN DAG to have considered their comments in preparing the draft PEIR. In addition, SANDAG failed to comply with CEQA by conducting the scoping and public review process for the Plan and the draft PEIR separately, which has resulted in a disconnected, piecemeal and rushed process in which previous comments on the Plan were not responded to or incorporated into the draft PEIR.

The disjointed and rushed process for public participation continues to the present. According to SAN DAG staff, responses to comments on the Plan will be published at the end of October, several weeks after public and agency comments are due on the draft PEIR. Thus, the public and affected agencies like the city must submit comments on the PEIR without knowing whether or how SANDAG has responded to previous comments on the Plan. SAN DAG has already indicated that the SANDAG Board will review and consider the Plan and the Final PEIR in December 2021. Thus, there appears to be insufficient time for SANDAG to evaluate comments received on the draft PEIR; prepare meaningful responses and make those responses available as required by CEQA Guidelines sections 15087 and 15088. As such, SAN DAG is foreclosing on a "meaningful public participation process" and subjecting itself to a claim that SAN DAG is prejudicing the outcome of the environmental review process by ensuring there is little opportunity for public comments to influence the Plan's program and design. ("Enviro.nmental review derives its vitality from public participation" (Ocean View Estates Homeowners Assn. V. Montecito Water Dist. (2004) 116 Cal. App. 4th 396, 400.) If the issues that were addressed in the city's August 6, 2021 comment letter on the Plan (Attachment 1) are not addressed in the PEIR, the PEIR will be insufficient as an informative document and it will reduce the validity and efficacy o.f the Plan, including its use of faulty assumptions r!=!garding land use and population growth to comply with City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan Oct. 11, 2021

state and federal mandates, such as the Sustainable Communities Strategy and greenhouse gas reduction targets. These faulty assumptions misrepresent the vital land use-transportation planning connections and do nothing to reduce greenhouse gasses and will instead result in unplanned increases to traffic, greenhouse gases, and result in increased housing unaffordability.

While the city supports the main concepts of the Vision in the Regional Plan, the 5 Big Moves, there needs to be an adequate analysis on how the Plan will be implemented, and what will occur if there are changes to the projected growth, technology, and/or state law impacting existing conditions. The city's residents, businesses, and property owners would have benefited from more time to read the details in the Plan and draft EIR. After years of public outreach that lacked detail of the assumptions and projects proposed in the Plan, the Plan is riow being rushed to decision by the SANDAG Board of Directors by the end of 2021. This is a procedural error and not adequate for the purposes of CEQA.

The city also restates its prior request that the following language be added to the Regional Plan for additional clarification on land use authority: "Land use authority is reserved to local jurisdictions because they are best positioned to effectively implement the objectives outlined in the Plan through understanding of the unique needs of their communities and geographies." This language is needed to clarify that land use authority rests with the local jurisdiction. Although this principle should be obvious, the inconsistencies between the Plan and the city's General Plan discussed below suggest that it has been ignored. Further the draft EIR should identify how the Program EIR will be utilized for streamlining with later activities and/or for use with subsequent El Rs and negative declarations in compliance with CEQA Guidelines section 15168(c) and (d).

In addition, the dty has the following substantive comments on the adequacy of the PEIR:

1. The PEIR fails to disclose the Plan's inconsistencies with the Carlsbad General Plan and to analyze the related potential environmental impacts. The Legislature has declared a policy "to protect California's land resource, to ensure its preservation and use in ways which are economically and socially desirable in an attempt to improve the quality of life in California." (Gov. Code§ 65030.) To further this policy, each of the state's cities and counties is required to adopt a comprehensive, long­ term general plan for the physical development of that city or county. (Gov. Code§ 65300.) Accordingly, the city adopted a General Plan in compliance with state law and most recently updated it in 2015. the city's General Plan "sets forth land use compatibility policies applicable to future development in the vicinity." These policies are designed to ensure that future land uses in the surrounding area will be compatible with the realistically foreseeable activity in the city.

Growth projections for the region are based on population, vehicle trends and land use plans developed by the cities and the County of San Diego ("County'') as part of their general plans. Many different regional documents rely on the same information to develop water demand projections, air quality performance standards, emission inventories, and emission reductions. The Plan would result in an increase in residential land use resulting in corresponding increases in indirect and cumulative vehicle miles traveled ("VMr'), GHG emissions and air pollutant emissions, as well as inconsistencies with RAQS, SIP, and regional traffic modeling. This is not disclosed in the draft PEIR.

CEQA Guidelines section 15125(a) requires EIRs to contain a description of the physical . environmental conditions in the vicinity of the project, as they exist at the time the NOP is published, or if no NOP is published, at the time environmental analysis is commenced, from both a local and regional perspective. Existing general plans, including their Land Use Elements, should City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan Oct. 11, 2021
Page4
. .
have been utilized for this baseline analysis and to derive future population and housing estimates.

The draft PEIR is legally inadequate because it fails to plainly identify the specific assumptions included in its baseline for land use. (San Joaquin Rescue Center v. County of Merced (2007) 149 Cal.

App. 4th 645.)
In the draft PEIR, SAN DAG should have evaluated and clearly articulated the Plan's potential impacts on land use. Instead, the PEIR states that: "The forecasted development of the proposed Plan is based on the Series 14 Regional Growth Forecast SCS land use pattern, which is, in turn, based on the adopted general plans of the cities and County of San Diego and on the most recent planning assumptions, considering local general plans .and other factors, as required by SB 375." This statement is incorrect. The Plan is inconsistent with _the city's General Plan because it proposes residential land uses where such uses are not authorized by the General Plan. The PEIR appears to ignore this inconsistency in concluding there will be le~s than significant impacts for the years 2025, 2035 or 2050.

The city has two mobility hubs in the proposed Plan and draft PEIR: McClellan-Palomar Airport, the fifth largest employment center in the region; and Carlsbad State Beach and Carlsbad Village as ''Tier 3 and Tier 4" employment centers. Attachment 1 shows a summary of the Mobility Hubs and housing units assumed in the Series 14 Growth Forecast for the year 2050. The assumptions in the updated Series 14 Growth Fprecast contain inconsistencies with respect to at least three locations in which density is shown to be inconsistent with the city's General Plan, the Airport Land Use Compatibility Plan and good planning principles. These three problematic areas are:
a. 736 units on parcels immediately adjacent to the McClellan-Palomar Airport runway. The location of the airport within this mobility hub was shared with SANDAG staff multiple times at workshops. This is inconsistent with the regulations provided by the San Diego County Regional Airport Authority and conflicts with standard planning principles for siting housing away from hazards;
b. 2,755 units on existing developed resort properties and open space dedicated lands adjacent to Legoland; and
c. 65 units in a preserved open space area.

The Plan proposes residential uses in areas which are not designated for such uses in the city's General Plan. This inconsistency results in potential sigoificant impacts with respect to land use, public safety and noise. (See CEQA Guidelines, Appendix G, §§ IX(e), Xl(b), Xlll(c).) Because residential use is not authorized in those locations in the city's General Plan, the Plan's assumption that residential use will occur there results in an overstatement of the extent to which other impacts, such as those associated with VMT, GHG an·d other pollutant emissions, will be reduced and understates those potential impacts of the Plan. The only meaningful evaluation of the Plan's potential impacts is a brief qualitative description of the City of San Diego's community plan process.

However, the PEIR does not meaningfully address the inconsistency with the general plans of the other 17 member jurisdictions, which if not implementing this plan will cause a significant environmental impact due to the conflict with any land use plan, policy or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

As noted above, the Land Use, Hazards and Noise sections of the draft PEIR must include an evaluation of the inconsistencies with local land use plans. Multiple areas in Carlsbad are controlled as to their use and activity density and intensity through their spatial association with the McClellan­ Palomar Airport. The McClellan-Palomar Airport is defined by the Federal Aviation Administration I
l
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan Oct. 11, 2021

("FAA") as a commercial service airport that, in addition to private aircraft, has regularly scheduled commercial flights . The McClellan-Palomar Airport Land Use Compatibility Plan ("ALUCP") is prepared according to FAA requirements and adopted by the San Diego County Regional Airport Authority acting as the Airport Land Use Commission for the County of San Diego. Further detail on this is included in the city's August 6, 2021 comment letter (Attachment 1).

2. Additionally, looking at data provided by SANDAG, it is now clear why the citywide numbers only show moderate increases in population. Our analysis has shown that there is an assumed reduction of population by 2,310 persons in the areas within the city but outside of the mobility hubs. This is likely due to assumed reductions in persons per household over time, but SAN DAG should clarify the source' and reasonableness of this assumption. If housing is provided outside the Mobility Hubs consistent with these areas, is it still reasonable to assume persons per household will be reduced in 2050? The PEIR also rails to consider the effect of Senate Bill 9 ("SB 9"), which will allow duplex or quadplex development in any area previously zoned for single family use. As a result of the new law, hou~ing growth would be expected to increase in single-family residential areas. By failing to take into account the effect on population growth of developing additional housing outside the Mobility Hubs, the PEIR results once again in an u~derstatement of the Plan's potential impacts and an overstatement of the Plan's beneficial effects on VMT, GHG and other pollutant emissions.

Furthermore, this reduction in population is not limited to the city of Carlsbad. There is an approximately 85,000 person reduction in population assumed outside of mobility hubs regionwide.

SAN DAG nee_ds to address if that is a reasonable assumption and if this will result in other impacts to public and private projects that will rely on this growth forecast, and the associated Activity Based Model (2+) to project future impacts to transportation, GHG, air quality and noise.

3. A project will normally have a significant effect on the environment if it will conflict with _ adopted environmental plans and goals of the community where it is located (see Appendix G to the CEQA Guidelines). The facts and analysis in the PEIR don't support a finding of less than significant impact for consistency with general plans beyond the year 2025, where at least there is a correlation, intentional or otherwise, with the current Regional Housing Needs Allocation that each jurisdiction is planning for. Beyond 2025, the assumptions in the land use chapter have had a more in-depth analysis, and if not substantiated, should be designated as significant and unavoidable. If there are impacts determined to be significant and unavoidable, mitigation measures should be designed to lessen the impact; the current draft EIR includes no related mitigation measures. In Citizens for a Sustainable Treasure Island v. City and County of San Francisco (2014) 227 Cal. App. 4th 1036, the Court of Appeal for the First Appellate District held that an EIR must satisfy the substantial evidence standard of review as to all of the required elements of an EIR; address the environmental impacts of the proposed project to a degree of specificity consistent with the underlying activity being approved; and properly allow for supplemental review that may be necessary in the future.

Therefore, the draft PEIR must be revised to explain the nature and magnitude of a proposed project or activity with respect to land use and planning checklist criteria (Appendix G to the CEQA Guidelines).

4. Since these projections are related to the GHG reductions and compliance with Senate Bill 375, it puts the entire evaluation and basis for compliance into question. If these assumptions are not made, it will have significant impacts to the GHG emissions, and the metric tons of annual emissions that comprise over 40 percent of the regional total. As currently drafted, the Plan's land use assumptions related to GHG contributions do not comply with other specific state and federal mandates including SB 375, which achieves targets set by the California Air Resources Board and City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan Oct. 11, 2021

compliance with federal civil rights (Title VI) requirements, environmental justice considerations, air quality conformity, and public participation . Please refer to Attachment 1 for more background discussion about the city's concerns regarding the technical methodology used to estimate GHG emissions from the sustainable communities strategy. Pursuant to CEOA, the environmental baseline for GHG emissions shall be established based upon the physical conditions at the project site at the time of the NOP, or no NOP, at the time the environmental analysis commenced. The environmental setting requirements of CEQA Guidelines section 15125, which directs SAN DAG to utilize existing general plan land use maps, helps establish the basis for compliance with Government Code section 65080(b)(2)(H) and (J) as those land use map regulations existed at the time of the NOP or when the environmental analysis commenced; and should have been used as the most recent planning assumptions to develop per capital passenger vehicle-related greenhouse gas emissions targets for 2035 set by the California Air Resources Board.

5. The Transportation chapter of the draft EIR lacks sufficient detail and explanation to adequately understand and provide comment _on the transportation analysis that was used to determine the project impacts and related performance metrics such as Average Daily Trips (ADT), VMT and travel mode share. }"he following comments are intended to provide this additional information and a better understanding of the identified transportation impacts:
a. The analysis methodology used for the Transportation chapter does not provide a description of how the ABM2+ analysis outputs such as Average Daily Trips (ADT), Mode Share, and Vehicle .Miles Traveled (VMT) are calculated for each of the travel modes. Without this information, it is difficult to understand how the transportation network improvements impact these analysis metrics for future year conditions and for consideration of potential project mitigations .
b. Section 4.16.4 "Transportation Environmental Impact and Mitigation Measures" should provide a description ofthe proposed transportation projects for each travel mode by horizon year with ~eference to Appendix B of the EIR document.
c. In order to directly compare the project list with the project impacts found in section 4.16.4, it is recommended to reorganize the tables found in Appendix B by travel mode and horizon year with indication of project mileage
d. Does the EIR consider the long term or permanent impact of COVID-19 on travel behavior patterns throughout the region? Was the ABM2+ model adjusted to account for changes in travel behavior due to the COVID-19 pandemic? Were additional adjustments made to key mode choice variables such as rates for tele-work, vehiclE;? ownership, and traveler sensitivity to use transit or carpool as a result of these travel behavior changes? e. As mentioned above, significant issues need to be addressed in the Plan which should also be addressed in the EIR including:
i. Grade separation in Carlsbad from Cannon Road to the northern border. ii. The impacts of implementing roundabouts in the Complete Corridors. iii. Alternative analysis for moving the grade separated 110mph transit leap commuter rail to the east thereby reducing all the negative impacts of having the current North ·county Transit District (NCTD) alignment running along the sensitive coastline, lagoons City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan Oct. 11, 2021

and coastal open space, and coastal village_ land use that promote mobility and look to reduce bifurcation issues caused by the current at grade NCTD alignment. The potential bifurcation issues also constitute a potential significant impact on land use in that the Plan will exacerbate the alignment's effect on dividing the established downtown Carlsbad community.

6. The alternatives analysis does not describe a rarige of reasonable alternatives to the project because it does not include an analysis of an alternative that evaluates what will occur if the faulty land use, and therefore transportation, assumptions do not occur. The alternatives are constructed to reduce impacts through even more focused growth in Mobility Hubs and through increased value pricing and revenue generation . While it may be true t.hese would reduce impacts, it does not provide policy makers or members of the public a reasonable range of alternatives as required by CEQA.

Additionally, due to the aforementioned SB 9 being signed by the Governor, the reduction in population assumed in suburban areas outside of the mobility hubs is both inconsistent with reality a·nd with planning principles required by the California Department of Housing and Comml!nity Development to not concentrate all future growth in certain locations. CEQA and the CEQA Guidelines require that an EIR describe all reasonable alternatives to the project and any feasible mitigation measures (Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal. 3d 400,404). Because the draft PEIR does not discuss future land use conflicts with applicable general plans, it fails to disclose ways to reduce or eliminate the environmental impacts of the project and to respond to the major environmental issues identified during the planning process (as a project alternative or as a mitigation measure) pursuant to Public Resources Code section 21002 (see Friends of the Old Trees v. Department of Forestry & Fire Protection ( 1997) 52 Cal.

App. 4th 1383). The draft PEI R's analysis of the project alternatives and mitigation measures is incomplete and, therefore, inadequate.

Section 15126 of the CEQA Guidelines requires that all aspects of a project must be considered when evaluating its impact on the environment, including planning, acquisition, development, and operation. The implementation and challenges to fund the Plan have not been appropriately discussed. One of the project alternatives should accommodate transportation investments that can be reasonably funded within the horizon of the plan under the current ("known") funding mechanisms. Because the draft EIR does not discuss a financially constrained alternative, the analysis of the project alternatives and mitigation measures is incomplete, and therefore, inadequate .

7. Where regional planning processes have not resulted in the adoption of plans or regulations relating to the environment, CEQA requires public agencies to engage in an analysis of the impacts of the proposed project on the environment. (Public Resources Code§§ 21000; 21002.1; 21003.l(b); 21080(d); 21081; 21082.2(a).) Although there is a general analysis of projected growth in the region, there is a lack of detail with respect to growth inducement or reasonably foreseeable future projects implementing Public Resources Code section 21155 - 21155.4 (CEQA streamlining for SCS consistency) and/or other reasonably foreseeable development that may result. The provision or improvement of transportation infrastructure, utilities, yv-ater and sewer service to an area can induce growth by removing impediments to developmeht. Once services are extended or improved in an area, economic incentives for development exist. The basic elements and principles of the Plan have been designed to facilitate future smart growth and concentrate population growth in areas that would be efficiently served by transportation facilities. The smart growth concept is the basis City of Carlsbad Comments on Draft l:nvironmental Impact Report for 2021 Regional Plan Oct. 11, 2021

for the framework for prioritizing public la'nd use and transportation investments in the region. The smart growth concept identifies areas where smart growth development exists or could be built and provides a basis for planning transportation facilities and transit services in the proposed Plan.

Smart growth areas identified receive prioritized infrastructure investments and transit services to support smart growth. This carries true to those smart growth areas that are accommodated by existing general plans, and for other areas that are not covered by existing general plans. CEQA requires that an EIR discuss the ways in which the proposed project could foster economic or population growth or the construction of additional housing, -either directly or indirectly, in the environment surrounding the project. CEQA requires this discussion to include ways in which a project would remove obstacles to population growth or encourage and facilitate other activities that could significantly affect the environment (CEQA Guidelines section 15126.2(d)). The level of • detail should reflect the level contained in the plan or plan element being considered (Rio Vista Farm Bureau Center v. County of Solano (1992) 5 Cal.App.4th 351), inclusive of new smart growth areas as designated.

City staff looks forward to working with SANDAG on improving mobility and land use access in the region and building sustainable, equitable and healthy modes of transportation. We appreciate the opportunity to comment on the Plan that will help the region realize these goals. While at the same time, city staff also looks forward to helping SAN DAG advance a legally adequate PEIR to support the disclosure and decision-making process. Since the major premise of CEQA is that it "be interpreted in such manner as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language" (Friends of Mammoth v. Board of Supervisors, supra, 247, 259), SAN DAG should take all action necessary to alert the decision-makers and the public to the environmental changes associated with the project (County of Inyo v. Yorty (1973) 32 Cal. App. 3d 795, 810). There is no shortcut to CEQA- the EIR process protects not only the environment by also informed self-government (Laurel Heights Improvement Assn. v. Regents of University of California, supra, 376, 392). The SAN DAG Board must certify that the final PEIR has been completed in compliance with CEQA and that it considered all of the information in the final EIR before approving or disapproving the project. As of this writing, the draft PEIR is not in compliance with CEQA.

If you have any questions related to comments on the transportation network, please contact Tom Frank, Transportation Director/City Engineer, at [email protected] or, if you need additional information related to comments on the land use assumptions, please contact Eric Lardy, Principal Planner, at [email protected].

JEFF MURPHY
Community Development Director

TOM FRANK
Transportation Director/City Engineer
City of Carlsbad Comments on Draft Environmental Impact Report for 2021 Regional Plan Oct. 11, 2021

Attachments:

1. City of Carlsbad Comment Letter on Draft Regional Plan (Aug. 6, 2021)

2. City of Carlsbad Comment Letter- Regional Arterials · (Sept. 30, 2021) cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Assistant City Attorney
Robby Contreras, Assistant City Attorney .

Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Director, Community Development
Don Neu, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager Jason Geldert, Engineering Manager
Eric Lardy, Principal Planner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Aug.6,2021
San Diego Association of Gov~rnments
401 B Street, Suite 800
San Diego CA 92101
Via: [email protected]
RE: City of Carlsbad Comments on Draft 2021 Regional Plan To Whom it May Concern,
ATTACHMENT 1
{ cityof
Carlsbad
The City of Carlsbad appreciates the opportunity to provide comments on the draft 2021 Regional Plan ("Plan"). This is an important plan for this region and will guide the next phase of growth for the member agencies of the San Diego Association of Governments ("SAN DAG"). An effectively designed and implemented regional transportation plan would help ensure improved transportation options for area residents, businesses and other community members; meaningful reductions in greenhouse gas ("GHG") emissions; and improved quality of life as we grow our communities.

The City of Carlsbad ("city") is submitting comments based on the policies, projects, programs and other improvements included in•the Plan. Our agency's comment letter is divided into two sections. The first section seeks clarity and other considerations that pertain to our agency's review of the Plan. The second section identifies the city's preliminary co.mments and recommendations.

Implementing the regional transportation network outlined in the Plan requires municipalities to support the regional vision and deliver on local Infrastructure and services like the priority bus routes, local bus services, and pedestrian and cycling connections to major transit infrastructure. These components, which are delivered by municipalities, are essential to creating a coherent and comprehensive local transportation network that feeds into regional services. For that reason, an effective public review of the Plan should involve a transparent and thorough process for identifying and evaluating potential hazards, physical changes to the environment and indirect (off-site and cumulative) impacts that might result from implementation activities that may reasonably occur with the Plan.

The city's residents, businesses and other community members will greatly benefit from the Involvement and technical assistance from the prospective Draft Environmental Impact Report ("EIR").

Therefore, what follows in this correspondence represents our agency's preliminary comments and recommendations. The city reserves the right to add, amend, change or replace comments and recommendations based on additional review and understanding of the Plan and the environmental analysis provided under the California Environmental Quality Act ("CEOA'').

The city thanks SAN DAG staff for meeting with city staff on Aug. 2, 2021, to discuss some of these comments in advance of this letter. Following that meeting, SAN DAG provided language that they may recommend adding to the Regional Plan for additional clarification on land use authority. The language is, "Land use authority is reserved to local jurisdictions because they are best positioned to effectively implementthe objectives outlined in the Plan through understanding of the unique needs of their communities and geographies." This language will be helpful to clarify that land use authority rests with Transportation & Community Development Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2710 t City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021

the local jurisdiction. The city still offers the following comments with the intent to support development of a defensible and realistic regional plan.

SECTION 1: CLARITY AND OTHER CONSIDERATIONS
City staff have attended the series of workshops that SANDAG hosted during the public review period, and respectfully starts this section with several questions related to the process of the Plan and the Draft EIR. By way of introduction, a jurisdiction's General Plan, such as the city's General Plan, identifies the expected population of the city and any lands outside of the city limits but within their Sphere of Influence where future growth is anticipated to occur. The city's General Plan identifies the subject area adjacent to the McClellan~Palomar Airport for development under the designation for limited and light industrial use.

For future land use planning, land use assumptions must reasonably proxy and be generally consistent with local planning standards and programs, to be considered growth accommodating rather than growth inducing . SAN DAG has the authority under Government Code Section 65584 to determine existing and projected housing needs, as well as the share of housing needs to be allocated to cities and counties, but it is unclear if SAN DAG has jurisdiction to allocate new housing growth to areas in a manner not consistent with Government Code Section 65584. Attachment 1 includes additional information on the applicable Government Code and standards. Therefore, and as indicated above, the build-out of properties within the Business Park and flight activity zone must be done in accordance with the city's General Plan Land Use Diagram, as amended, in accordance with city approval.

The initial questions on the planning process associated with developing the Plan are provided below:

1. The SANDAG website states, ''The SANDAG Sustainable Communities Strategy and Final EIR from its 2015 Regional Plan will remain valid and in compliance for purposes of state funding eligibility and other state and federal consistency purposes until the SAN DAG Board of Directors adopts a new Regional Plan and EIR, provided those actions are completed by the end of December 2021." SAN DAG needs to clarify how the Draft EIR, Response to Comments and Adoption will be completed this year and what will occur if they are not completed by the end of this year. Additionally, please clarify when the Draft EIR will be available; it is difficult to completely assess the full impacts of this plan when the public review of the documents is piecemealed.
a. SANDAG should clarify how public comments on the Plan are going to be addressed in the Draft EIR prior to its release.
b. In the Draft EIR, SAN DAG needs to clearly articulate the impacts to land use and if the Plan will cause a significant environmental impact due to a conflict with any land use plan, policy or regulation adopted for the purpose of avoiding or mitigating an environmental effect. _Appendix F: Regional Growth Forecast and Sustainable Communities Strategy Land Use Pattern appears to be inconsistent with the city's General Plan and rezone program to accommodate the Regional Housing Needs Assessment, as well as the general plans of other jurisdictions such as the cities of Coronado, Del Mar and the County of San Diego. The Draft EIR should clarify how implementation of this Plan can occur if those changes are not made.

City of Carlsbad Comments on Draft 2021 Regional_ Plan
Aug. 6, 2021

2. The city has three mobility hubs, associated with the Employment Centers Published supporting the SANDAG Regional Plan.1 McClellan-Palomar Airport is the fifth largest employment center in the region, with Carlsbad State Beach and Carlsbad Village as "Tier 3 and Tier 4" employment centers. The city thanks SAN DAG for providing data for analysis to determine impacts and provide for accurate comments on the Plan. Attachment 2 shows a summary of the Mobility Hubs and housing units assumed in the Series 14 Growth Forecast for the year 2050. In summary:
a. The assumptions in the updated Series 14 Growth Forecast contain inconsistencies with the city's General Plan. The Carlsbad Palomar Major Employment Mobility Hub does include increases in density beyond what the citywide numbers appear to show when they are looked at in more detail.

I. There are three locations in which density is shown to be inconsistent wi~h good planning principles, the city's General Plan and the Airport Land Use Compatibility Plan. The three most problematic areas (shown in Attachment 3) are:

1. 736 units on parcels immediately adjacent to the McClellan-Palomar Airport runway. The location ofthe airport within this mobility hub was shared with SANDAG staff multiple times at workshops. This is inconsistent with the regulations provided by the San Diego County Regional Airport Authority and conflicts with standard planning principles for siting housing away from hazards.

2. 2,755 units on existing developed resort properties and open space dedicated lands adjacent to Legoland.

3. 65 units in a preserved open space area.
ii. SAN DAG should provide additional detail why units were assumed in these areas, what planning principles those decisions were based on, and how SAN DAG expects this to be implemented.
iii. Concentration of units in the mobility hubs alone appears to conflict with the direction received from the California Department of Housing and Community Development ("HCD'') to implement new Affirmatively Furthering Fair Housing ("AFFH"), which seeks to combat housing discrimination, eliminate racial bias, undo historic patterns of segregation, and lift barriers that restrict access in order to foster inclusive communities and achieve racial equity, fair housing choice and opportunity for all Californians. The allocations of land use provided by SAN DAG seem to focus all the higher density housing into one area of the city. (This is one of the largest points of analysis that each jurisdiction in the region needs to respond to in order to receive a certified Housing Element.) b. Additionally, looking at the detailed data provided by SAN DAG, it is now clear why the citywide numbers only show moderate increases in population. Our analysis has shown that there is an assumed reduction of population by 2,310 persons in the areas within the city but outside of the mobility hubs. This is likely due to assumed reductions in persons per household over time, but SAN DAG should clarify the source and reasonableness of this assumption. If housing is not provided consistent with these areas, is it still reasonable to assume persons per household will be reduced in 2050? 1 SAN DAG Website : Employment Centers SAN DAG :: PROJECTS :: San Diego' s Regional Plann ing Agency I
I
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page4
c. Furthermore, this reduction in population is not limited to the City of Carlsbad. There is • an approximately 85,000 reduction in population assumed outside of mobility hubs regionwide. SAN DAG needs to address if that is a reasonable assumption and if this will result in other impacts to public and private projects that will rely on this growth forecast, and the associated Activity Based Model (2+) to project future Impacts to transportation, GHG, air quality and noise.
d. The forecast has decreased in future population based on current trends, but it is not clear if there is enough housing provided with reductions and increases in some jurisdictions. Will the reduced amount of housing that will be provided result in an increased exacerbation of the affordability crisis?
e. There is a lack of clarity about how the Plan would be implemented at the municipal level. SANDAG should develop an approach for engaging with municipalities to ensure local support for delivering the regional transportation network. Staff from local jurisdiction have the knowledge and ability to share where there are land use assumptions that conflict with planning and zoning laws. Our analysis focused on the City of Carlsbad, but if these types of assumptions are made regionwide, it presents flaws in the overall analysis. These flaws put the assumed reductions in vehicle miles traveled (''VMT") and ability to implement the Regional Plan into question.

3. The area designated is controlled for use and activity density and intensity through its spatial association with the McClellan-Palomar Airport. The McClellan-Palomar Airport is defined by the Federal Aviation Administration ("FAA") as a commercial service airport that, in addition to private aircraft, has regularly scheduled commercial flights to Los Angeles International Airport ("LAX"). The McClellan-Palomar Airport Land Use Compatibility Plan ("ALUCP") is prepared according to FAA requirements and adopted by the San Diego County Regional Airport Authority acting as the Airport Land Use Commission for the County of San Diego. a. The ALUCP provides measures to minimize the public's exposure to excessive noise and safety hazards within areas around the airport and identifies areas likely to be impacted by noise and flight activity created by aircraft operations at the airport. These impacted areas include the Airport11nfluence Area ("AIA"), the Clear Zone and the Flight Activity Zone. •
b. Within the AIA, the ALUCP establishes six safety zones for the purpose of evaluating safety compatibility of new/future land use actions. The safety zone boundaries depict relative risk of aircraft accidents occurring near the airport and are derived from general aviation aircraft accident location data and data regarding the airport's runway configuration and airport operational procedures. The ALUCP limits development intensities in these zones by imposing floor area and lot coverage maximums, by incorporating risk reduction measures in the design and construction of buildings, and/or by restricting certain uses altogether. For example, all residential and virtually all non-residential uses are considered incompatible land uses in some zones, while considered to be either compatible or conditionally compatible with the airport in other zones. Attachment 4 shows the McClellan-Palomar Airport, noise contours and SANDAG's proposed housing units.
c. If the proposed SAN DAG land use assumptions are endorsed, an amendment to the city's General Plan would be required to change the land use designation to Mixed-Use Commercial or residential land uses within the existing Business Park In order to effectuate the underlying assumptions of SANDAG staff. This is not a realistic I
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug.6,2021

assumption. Further, the protected airspace referenced In the AIA and the ALUCP must also be amended based on SANDAG's regional planning assumptions . (The FAA establishes airspace protection zones in the airspace above and surrounding airports in order to protect aircraft from obstructions such as buildings, towers, etc. in navigable airspace.)
d. When a General Plan is adopted or amended, the allowable growth pattern of an area is identified and the expansion or updating of the various land uses as specified in the General Plan can occur throughout the planning horizon. Without such growth considerations, the expansion or intensification of existing land uses could be considered "growth inducing ." Unplanned and uncontrolled growth may have significant adverse impacts on the environment. CEOA requires a discussion of how a "project" could increase population, employment or housing growth in surrounding areas and the Impacts resulting from this growth . The CEOA Guidelines indicate that a "project" would normally have a significant effect on the environment if it would induce substantial growth or a substantial concentration of population .

4. At this point, it is not clear if SANDAG's assumptions adequately contemplate the development patterns included in the Sustainable Communities Strategy {"SCS")/Regional Transportation Plan ("RTP"), and Regional Air Quality Strategy ("RAQS"), local climate action planning business-as­ usual estimates, sub-regional traffic modeling, or the airspace assumptions of AIA and the ALUCP.

5. The city seeks clarity on the Plan's underlying assumptions made to justify the proposed extensive high-speed rail network considering the significant changes in travel behavior which have occurred throughout the region as a result of the COVID-19 pandemic and due to the advancements in disruptive technologies such as telecommuting, autonomous vehicles, microtransit, etc.
a. Recent North County Transit District ("NCTD") Coaster ridership data show riders are not returning to riding the Coaster in comparison to other modes of travel as shown in Attachment 5.
b. This question is consistent with comments made by SANDAG's panel expert Bob Poole . regarding the impact of the COVID-19 pandemic on transit ridership and mega-transit projects. {See comments by Bob Poole during the March 12, 2021 presentation to SANDAG starting at timestamp 1:30 p.m.: https://youtu.be/g -e6bNYSJ 8?t=5410)

6. The city seeks clarity on why an alternatives analysis was not conducted with consideration of other transit alternatives such as automated /shared vehicle technologies and personalized zero emissions transit programs that are capable of utilizing the existing regional freeway infrastructure in response to these recent developments explained in the above comment .

7. The city seeks clarity on why the Plan does not incorporate policies to promote roundabouts over signalized intersections and include a budget line item under the Complete Corridors to fund the construction of roundabouts at new locations and to replace signalized intersections when found feasible. This clarification would support the Federal Highway Administration ("FHWA")'s project fo r Accelerating Roundabout Implementation in the United States and the County of s·an Diego Air Pollution Control Board's support for implementing roundabouts to address GHG and reduce fatalities .

8. The city seeks clarity on the project phasing proposed within the Plan. Specifically, the city is seeking to understand the timi~g of implementation of unfunded TransNet projects related to City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021

the new projects presented within the Regional Plan. To support this, the city is requesting that SAN DAG input the information requested in Table 1 (Attachment 6). '

9. The city seeks specific data on the proposed 200 miles of rail service contemplated in the Plan.

To support this, the city is requesting that SAN DAG input the information requested in Table 3 (Attachment 7). Specific questions:
a. Please provide more information about the scope of the high-speed rail alignments, potential vehicle technologies and their cost estimates. b. Will the Coaster keep the same rail alignment?
c. What funding is programmed or planned for the Carlsbad Village railroad trench and the other projects along the current NCTD/Coaster Service right-of-way? d. Will some of the tracks be at grade with fencing and trains traveling at 110 miles per hour speeds?
SECTION 2: COMMENTS AND RECOMMENDATIONS
In addition to the comments on process and the Draft EIR provided above, city staff remain concerned that there is not enough detail on the feasibility of implementation of this significant shift in transportation strategy . On specific content in the plans, we outline our recommendations and comments below :

1. Paying for the Plan:

The draft 2021 Regional Plan sets out an ambitious plan to build and operate a region-wide system of transportation projects, programs and other improvements. This is a substantial role for SAN DAG to play in supporting both the construction and operation of these projects, programs and other improvements. SANDAG should set annual revenue targets to directly fund everything and should approve any recommended sustainable revenue tools to help meet these targets. Many of the f~nding strategies will require legislative changes, or voter-approved taxation. SAN DAG should clarify what will occur if the funding is not available, if opposition to projects stops them from construction, and if General Plans in the region are not modified to implement the Plan.

2. Appendix D: Sustainable Community Strategy Documentation :

Appendix D includes the Sustainable Communities Strategy, which outlines assumptions included in the Activity Based Model 2+ ("ABM 2+"), updated for this. This model will be necessary for use by publicly and privately initiated land use projects preparing documents for consistency with VMT/CEQA Guidelines and Traffic Impact Analysis ("TIA") Evaluations. City staff respectfully request direction from SAN DAG on how to conduct modeling with the service bureau and how to factor in these assumptions applied to ABM 2+. Specifi~ally, the addition of pricing, parking costs for coastal communities, 10% teleworking and micromobility. SAN DAG should provide direction on how this could be worked into General Plans that are updated every 5-20 years.

3. Appendix A: Transportation Projects, Programs, and Phasing:

Trips to and from school sites result in a significant congestion, VMT generation, and peak hour delay throughout the region. Additional funding and projects should be recommended with a specific focus on improving safety and mult imodal access in and around school sites along with programs to incentivize non-single occupancy vehicle trips to schools.

City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021
Page7
Table A.11: Given the proven success of the Carlsbad Connector microtransit pilot program, the city agrees with the Plan's recommendations to provide similar on-demand microtransit systems throughout North County at all mobility hub sites and major transit centers .

Table A.13: The segment of El Camino Real between Poinsettia Lane and Camino Vida Roble is proposed to be widened from two to three.lanes to prime arterial standards. With the adoption of the city's General Plan, the city has determined that the widening of this portion of El Camino Real is not feasible due to constrained right-of-way and would result in negative impacts to 9thertravel modes. City staff recommend removal of this proposed project recommendation CB32 (that is, a 'do nothing' scenario, or appraise and evaluate different moblllty projects and/or alternative designs).

The preferred lnterstate-5 freeway alternative identified in the North Coast Corridor ("NCC") Final EIR/EIS is the refined 8+4 Buffer alternative, with four freeway lanes and two managed lanes in each direction and completion by 2035. Appendix A, Table A.5 describes NCC project IDs CC004, 007 - 009 as "SF to 6F+4ML" with completion by 2050. While this might lead to further study, it is not clear why there is a different freeway configuration (i.e., reduction in freeway lanes) proposed. How does a reduction in lanes continue to meet NCC potential project benefits of maintaining or improving traffic operations and improving the safe and efficient regional movement of people and goods?

4. Active Transportation:

The city appreciates the Regional Plan's overall approach of providing a connected network of high-quality bicycle facilities throughout the region. Regional bikeways are recommended throughout the city including along Palomar Airport Road which will provide a key east-west connection and El Camino Real which will provide a new north-south bikeway connection through the city. Both roadways are proposed to include "on-street bikeways" . Due to the high traffic volumes and vehicle speeds experienced along most of both corridors, the city recommends considering "off-street bikeways" or Class I facilities where feasible in order to stimulate the shift from personal motor vehicle use to people choosing to bike.

It is extremely important that municipal transportation plans align with regional transportation plans to achieve regional goals for land use and transportation and to promote the region working together to build a cohesive regional transportation network. Considering there are currently no mechanisms in ";:,lace to ensure municipalities coordinate local transportation plans with regional planning documents, the Plan should provide an approach on how SAN DAG plans to engage with municipaliti _es, especially in areas of potential disagreement or conflict (as aforementioned in this subsection and others). It Is also recommended that the Plan provide additional direction regarding the application of protected bikeways In a variety of applicable contexts. While vertical measures such as soft hit posts may be appropriate in lower volume and lower speed roadways, arterial roadways with high traffic volumes and high speeds warrant much more substantial physical protection from vehicles. In addition, special consideration should be given at intersections and driveways which may be impacted due to the additional width and visibility impacts created by protected bikeways.

City staff look forward to working with SANDAG on improving mobility and land use access in the region and building sustainable, equitable and healthy modes of transportation, and we appreciate the opportunity to comment on the Plan that will help the region realize these goals.

City of Carl_sbad Comments on Draft 2021 Regional Plan
Aug.6,2021

If you have any questions related to comments on the transportation network. please contact Tom Frank, Transportation Director/City Engineer, at [email protected] or if you need additional Information related to comments on the land use assumptions, please contact Eric Lardy, Principal Planner, at [email protected].

Sincerely,
ft/VOS
For

JEFF MURPHY
Community Development Director
-7-?~

TOM FRANK
Transportation Director/City Engineer
Attachments:

1. Government Code 65020 (S.B. 375) Summary

2. City of Carlsbad Moblllty Hubs

3. City of Carlsbad - Palomar Airport_ Road Mobility Hub Analysis

4. Palomar-Mclellan Airport Flight Paths

5. Recent NCTD Coaster Ridership Data

6. Table 1- Project Data Request

7. Table 3 - Detail of Proposed Rail Lines
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberio, Deputy city Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Director, Community Development
Don Neu, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager Jason Geldert, Engineering Manager
Eric Lardy, Principal Planner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Attachment 1: Government Code 65020 (S.B. 375) Summary
Government Code section ("GOV§") 65080, also referred to as California Senate Bill 375 (Steinberg, 2008) ("SB 375"), is one area of law that provides SAN DAG with guidance to which a regional transportation plan must be developed.

Among other things, the regional transportation plan that is developed "shall be an internally consistent document" (GOV § 65080 (b)) and shall include a "sustainable communities strategy prepared by each metropolitan planning organizations as follows" (GOV§ 65080 (b)(2)(B)):

Each metropolitan planning organization shall prepare a sustainable communities strategy, subject to the requirements of Part 450 of Title 23 ot and Part 93 of Title 40 ot the Code of Federal Regulations, including the requirement to utilize the most recent planning assumptions considering local general plans and other factors. The sustainable communities strategy shall (i} identify the general location of uses, residential densities, and building intensities within the region, (ii} identify areas within the region sufficient to house all the population of the region, including all economic segments of the population, over the course of the planning period of the regional transportation plan taking into account net migration into the region, population growth, household formation and employment growth, (iii) identify areas within the region sufficient to house an eight-year projection of the regional housing need for the region pursuant to Section 65584, (iv) identify a transportation network to service the transportation needs of the region, (v) gather and consider the best practically available scientific information regarding resource areas and farmland in the region as defined in subdivisions (a) and (b) of Section 65080.01 , (vi) consider the state housing goals specified in Sections 65580 and 65581, (vii) set forth a forecasted development pattern for the region, which, when integrated with the transportation network, and other transportation measures and policies, will reduce the greenhouse gas emissions from automobiles and light trucks to achieve, if there is a feasible way to do so, the greenhouse gas emission reduction targets approved by the state board, and (viii) allow the regional transportation plan to comply with Section 176 of the federal Clean Air Act ( 42 U.S. C. Sec. 7506 ).

The 2021 draft Regional Transportation Plan includes a Sustainable Communities Strategy ("SCS"), as required by SB 375 for the San Diego region (herein after called "draft Regional Plan"). The draft Regional Plan indicates that "SB 375 requires the SCS to include a pattern for forecasted growth and development that accomplishes the following: 1) When combined with the transportation network, the SCS will achieve the regional GHG emission-reduction targets; 2). The SCS accommodates the Regional Housing Needs Assessment ("RHNA") Determination; and 3) The SCS utilizes the most recent planning assumptions. (Reference p. 19 of the 2021 Regional Plan.)
Predicting the effect of transportation plans or projects on land uses and land use planning is critical to developing context sensitive solutions for transportation projects. Therefore, utilization of the most recent planning assumptions is not only necessary but is required as specifically stated therein GOV § 65080. If inconsistencies are found in the land use assumptions or adverse impacts are anticipated, SAN DAG should be actively engaged in the development of measures to address these issues.

The SANDAG Board of Directors approved the final RHNA plan with the final housing unit allocation on July 10, 2020, which was based on the most recent land use planning assumptions and an adopted methodology to allocate housing in accordance with GOV §§ 65584.04(d and m). The City of Carlsbad received a total RHNA allocation of 3,873 units as a result of RHNA plan adoption. The adopted April 6, 2021 city's Housing Element accommodates its housing needs through current zoning and other programs City of Carlsbad Comment Letter August 6, 2021
Attachment 1: Government Code 65020 (S.B. 375) Summary
as needed to meet the city's RHNA obligation at all income levels. The land use inputs derived from this local planning document constitutes the most recent land use assumptions. On July 13, 2021 the Department of Housing and Community Development found "the adopted housing element is in substantial compliance with State Housing Element Law (Article 10.6 of the Gov. Code).

The most recent planning assumptions are critical for the development of the draft Regional Plan as the document must comply· with other specific state and federal mandates including a SCS per California Senate Bill 375, which achieves GHG emissions reduction targets set by the California Air Resources Board and compliance with federal civil rights (Title VI) requirements, environmental justice considerations, air quality conformity, and public participation. To monitor compliance and attainment of state reduction goals in GHG, GOV§ 65080 (b)(2)) requires that:
(H) Prior to adopting a sustainable communities strategy, the metropolitan planning organization shall quantify the reduction in greenhouse gas emissions projected to be achieved by the sustainable communities strategy and set forth the difference, if any, between the amount of that reduction and the target for the region established by the state board. (J)(i) Prior to starting the public participation process adopted pursuant to subparagraph (F}, the metropolitan planning organization shall submit a description to the state board of the technical methodology it intends to use to estimate the greenhouse gas emissions from its sustainable communities strategy and, if appropriate, its alternative planning strategy .

There is inevitably some uncertainty regarding the use of projected future conditions . However, what is certain is that the project will not operate under the conditions that exist today. There will be new residential and employment growth in the intervening years between now and the proposed build-out of the draft Regional Plan. Nonetheless, projections utilized should represent the best available information assembled by the local agencies with jurisdiction and expertise. Judgments about land use assumptions utilized in the draft Regional Plan should be based on and supported by facts, adopted plans, and "most recent planning assumptions," rather than speculation and personal opinions. The land use assumptions for "uses, residential densities, and building intensities within the region" (as required by GOV§ 65080 (b)(2)(B)(i)) should also be the same, as that provided to the state board (as required per GOV §§ 65080 (b)(2)(H and J) in estimating and analyzing GHG from the SCS and the effect on growth and whether the effects of that growth would be significant in the context of the region's plans, natural setting, and growth patterns. Ultimately, the SCS must demonstrate whether SANDAG can meet the per capita passenger vehicle-related GHG emissions targets for 2035 set by the California Air Resources Board ("CARB").

SB 375 directs CARB to accept or reject the determination of SANDAG that its SCS submitted to CARB would, if implemented, achieve the region's GHG emissions reduction targets. CAR B's technical evaluation of SANDAG's draft Regional Plan would be based on all the evidence provided, including the models, the data inputs and assumptions, the SCS strategies, and the performance indicators.

The transportation and planning assumptions are also extremely important as it is relied on for other master planning exercises. The Regional Air Quality Strategy ("RAQS") relies on information from CARB and SAN DAG for information regarding projected growth in the cities and San Diego County. This in turn is utilized to address other state requirements, including the San Diego portion of the California State Implementation Plan ("SIP") and promulgating their own rules and regulations regarding air quality in the region or to address federal requirements.

City of Carlsbad Comment Letter August 6, 2021
Attachment 1: Government Code 65020 (S.B. 375) Summary
The analysis of land use impacts for transportation projects is guided by FHWA Technical AdvisoryT 6640.8 and the CEQA Guidelines.

Under the FHWA Technical Advisory T 6640.8 (G)(l), Guidance for Preparing and Processing Environmental, states :

This discussion [of land use] should identify · the current development trends and the State and/or local government plans and policies on land use and growth in the area which will be impacted by the proposed project. These plans and policies are normally reflected in the area's comprehensive development plan, and include land use, transportation, public facilities, housing, community services, and other areas.

The land use discussion should assess the consistency of the alternatives with the comprehensive development plans adopted for the area and (if applicable) other plans used in the development of the transportation plan required by Section {23 U.S. Code §] 134. The secondary social, economic, and environmental impacts of any substantial , foreseeable, induced development should be presented for each alternative, including adverse effects on existing communities .

Where possible, the distinction between planned and unplanned growth should be identified .

There is also a requirement to analyze the land use planning inconsistencies per CEQA Guidelines § 15126.2(a), which specifies that an EIR for a proposed project include:

The Significant Environmental Effects of the Proposed Project. An £JR shall identify and focus on the significant effects of the proposed project on the environment. In assessing the impact of a proposed project on the environment, the lead agency should normally limit its examination to changes in the existing physical conditions in the affected area as they exist at the time the notice of preparation is published, or where no notice of preparation is published, at the time environmental analysis is commenced. Direct and indirect significant effects of the project on the environment shall be clearly identified and described, giving due consideration to both the short­ term and long-term effects. The discussion should include relevant specifics of the area, the resources involved, physical changes, alterations to ecological systems, and changes induced in population distribution, population concentration, the human use of the land (including commercial and residential development), health and safety problems caused by the physical changes, and other aspects of the resource base such as water, historical resources, scenic quality, and public services. The EIR shall also analyze any significant environmental effects the project might cause or risk exacerbating by bringing development and people into the area affected. For example, the £JR should evaluate any potentially significant direct, indirect, or cumulative environmental impacts of locating development in areas susceptible to hazardous conditions (e.g., floodplains, coastlines, wildfire risk areas), including both short-term and long-term conditions, as identified in authoritative hazard maps, risk assessments or in land use plans addressing such hazards areas.

Since the new land use assumptions are being utilized, as described by this letter, the EIR that is prepared shall also analyze any significant environmental effects the project might cause by bringing development and people into the area affected. The following are the basic steps in analyzing land use impacts as part of the community impact assessment process:

City of Carlsbad Comment Letter August 6, 2021
Attachment 1: Government Code 65020 (S.B. 375) Summary

1. Inventory the existing land use patterns (including undeveloped land), development trends, and transportation systems. The inventory of existing land uses should include the following land use types : residential, commercial, industrial, recreational, institutional, public services, community services, emergency services, transportation, utilities, agriculture, and undeveloped land in the study area. The study area should include the surrounding community that is generally associated with the project area within which community impacts could occur. The inventory should also address development trends and identify recent developments in the study area to include the development's name, size, status (planned, built, under construction), and the jurisdiction in which it is located. A map showing the location of existing and planned land uses in the area should also be prepared.

2. Determine whether the project is consistent with local and regional policies that govern land use and development. For the consistency analysis, the policies and programs considered in the analysis should include: transportation plans and programs (MTPs/RTPs and MTIPs/RTIPs), regional growth plans, local General Plans that establish land use and growth management policies for the study area, and any specific or pipeline development proposals. This analysis should also include a discussion of consistency with the Coastal Zone Management Act of 1972, California Coastal Act of 1976, the National Wild and Scenic Rivers Act (16 USC 1271) and the California Wild and Scenic Rivers Act (Pub. Res. Code§ 5093.50 et seq.). After preparing a preliminary list of relevant plans to be considered in the analysis, the SAN DAG planner should meet with the staff of the various agencies to review the list to determine if it is complete and revise the list as necessary.

3. Assess the changes that would occur in land uses and growth with and without the project .

4. The draft Regional plan and each project alternative should be considered separately since the results may be different .

5. Develop measures to avoid, minimize, and/or mitigate potential adverse effects.

The resulting environmental analysis should identify the current development trends and the State and/or local government plans and policies on land use and growth in the area which will be impacted by the proposed project . These plans and policies are normally reflected in local General Plans. If found to be consistent, then the findings fn the EIR should be documented in the report and no further analysis or action is necessary. When found not to be inconsistent with a policy or program, then consideration must be given to modifying the draft Reginal Plan alternative to make it consistent, or measures to address the inconsistency must be developed. SANDAG should be actively engaged in the development of measures to address these issues and be prepared to assess the consistency of the draft Regional Plan and alternatives with the comprehensive development plans adopted for the area and (if applicable) other plans used in the development of the transportation plan required by Section 23 U.S. Code§ 134. For any new land use growth assumptions, the secondary social, economic, and environmental impacts of any substantial, foreseeable, induced development should be presented for the draft Regional Plan and each alternative, including adverse effects on existing communities. The results should be shared with the public during the public involvement process, e.g., at community meetings, etc. Public input should be considered by SANDAG and if necessary, the findings of the analysis should be revised to reflect information gained through the public involvement process.

City of Carlsbad Comment Letter August 6, 2021
I SANDAG Mobility Hubs I
N
I]] Mobility Hub MGRAs with 2016-2050 Increased Unit Change - Carlsbad Mobility Hubs
0 Carlsbad MGRAs
i."!. Carlsbad Quadrant
1:1 Carlsbad Boundary
A
0 2
Miles
Hub Name Hub Type Total Total Total Total Total Jobs Total Population Houses Population Houses 2025 Population
2016 2016 2025 2025 2035
Carlsbad Coastal 14087 6430 15095 6539 9290 16177
Village
Carlsbad Major 12853 5475 12275 5461 61074 19465
Palomar Employmen
Center
N/A Outside of 86239 34247 88793 35855 13896 84039
Hubs
N/A All of 113179 46152 116163 47855 84260 119681
Carlsbad
Total Total Jobs Total
Houses 2035 Population
2035 2050
7075 9667 17293
8503 67005 21080
35855 14345 83929
51433 91017 122302
Total Total lobs
Houses 2050
2050
7607 10044
9265 72900
35855 14900
52727 97844
The City of C8r1sbad dJsclaiOl!i any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EX Cl.US NE AND IN LIEU OF AU. OTl-lER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR At-N OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the Ctty of Csr1sbad become liable to usets of this map, or any Olher party, for any loss or damages, consequential or athel'Nise, induding but not llmlted to time, money, or gOOO\NIII, arising from the use, operation or modiftcatlon af the map. In using this map, user 1\lrther agree to Indemnify, defend, and hold harmless the City ofCar1abad for any and an liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Path: \ \shares\GIS_App\RetjuestsMarc.h2015\CamEronDev\Pfannlng\RITM0023436_21 \SANDAG Mobility Hub5.aprx Carlsbad Village Mobility Hub MGRAs
Dill Mobility Hub MGRAs with
2016-2050 Increased Unit Change
CJ Carlsbad Mobility Hubs
D Carlsbad MGRAs
N c:::J Carlsbad Boundary
A
0 0.25 0.5
Miles
The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUS FOR PARTICULAR PURPOSE AND/OR Af.JY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad consequential or ather-Nise, including but not limited to time, money, or goodwill, arising from the uae, operation or modification of the map. In of Carlsbad for any and all liability of any nature arising out of or reiaulling from the lack of accuracy or correctness of the map, or the use of the Path: \\llhare,\QS_App\Request5Mlillrch201.5\CcmEeonDev\P'lanning\RITM0023 ◄36_21 \SANDAG Moblity HuD5.;ipr,r

FALL OTHER WARRANT R MERCHANTABI FITNESS
ugers of this map, or any o rty, for any loss or ges,
, user further agree to indem efend, and hold ha s the City The City of Carlsbad dlsclalms any responsib!llty for the accuracy o ol Carlsbad become liable to uaers of this map, or any other party, I any nature arising out of or reeuJtlng from the lack of accuracy or cor Palh: \\ffl1re.s\GISJ,pp\Requnt1Mlrch2015\ComEccinOl'Y\Pllflnlt\g\lU'TI'1(l02J'l36_21\SA~OAG Mobility Hubs.apnc MGRA Closer Look
N
A

0.13 0.25
MIies
c:::J Carlsbad Boundary
~ : :, Carlsbad Quadrant
D CarlsbadMobllltyHubs
- Carlsbad MGRAs
D Carlsbad Palomar MGRAs with 2016-2050 Increased Unit Change General Plan Land Use
Q L, local Shopping Center
Q OS, Open Space
- P,Publlc
0 PI, Planned Industrial
D PI/O, Planned Industr1al/Office
- R, Regional Commercial
D R-1.5, Residential 0-1.5 du/ac
D R-15, Residential 8-15 du/ac
D R-23, Residential 15-23 du/ac
D R-4, Residential CK du/ac
D R-8, Residential 4-8 du/ac
c::::J TC, ll'ansportatlon Corridor
- VC, Visitor Commercial
a VC/OS, Visitor CommerdaVOpen Space
N
A
0 0 .010.01
Miles
c::::J Carlsbad Boundary
;;, : ~ Carlsbad Quadrant
Cl CarlsbadMobllityHubs
Carlsbad MGRAs
c::::J Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
~ OS, Open Space
D R-15, Residential 8-15 du/ac
D R-4, Residential D-4 du/ac
5;J VC/OS, Visitor Commercial/Open
Space
MGRA: 14249
The City of Ctnisbad dlaolalme any respon1lblllty for the accuracy or correctnea1 of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF A of Carta bad become liable to usera or thl• map, or any other parfy, for any loss or damages, consequential or othel'Nl8e, lncludlng but not 11mtted to time, money, or any nature aria Ing out of or reeultlng from the lack of accuracy or correctness of the map, or the use of the map. ~th : \\shl'rb\GIS_App\RequulsMarch20lS\ComEcon0ev\Plarinlng\lUTMO0ZJ~36_21\SAN0AG l'llobllity Hubs.avrx ai:I P.aloma
EmP-lo:v.me
enter,)
(j
. .
.

N
A
0 0.02 0.04
Miles
c:::J car1sbad Boundary
;: : :, car1sbad Quadrant
Cl car1sbadMobilityHubs
carlsbad MGRAs
c:::J car1sbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
ts] OS, Open Space
CJ R·15, Residential 8·15 du/ac
D R-4, Residential 0-4 du/ac
CJ TC, lransportatlon Corridor
VC/OS, Visitor Commercial/Open
Space
MGRA: 14251
T11o City of Carlebad dleclalmo any retponelblllty for tho accuracy or corroclneH of Ihle map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU o1 Carlabad become llable to users ofthl• map1 or any other party, for any lose or damegoa, consequentlel or otherwise, Including but not limited to time, money, any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Path; \\shares\GlS..App\R«quut>Much2015\ComEton0.11\Plllnnlno\!UTM002J436_21\SANDAG MoblKty Hubs.apl'K N
A
0 0.010.01
-==::J
Miles
c:::J cartsbad Boundary
i:,::, carlsbad Quadrant
□ caJ1sbadMobilityHubs
- carlsbad MGRAs
c:::J carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
~ OS, Open Space
CJ R~, Residential +8 du/r.

CJ TC, Transportation Corridor
vc, Visitor Commercial
~
P;i,th; \\d·1.1rl's\GlS_App\R.equestfM.rch2015\ComEconDw\Plannin11\RITMOOZ]ofJ6_Zl\SANDAG MobiKty Hub,.apnc MGRA: 14265
OfALLOTlaftMIWITll80R~-.itv. PmaNfCIRPMTICUIMNll'Dla...,__on9111'/PIWHll'IB ....,..~~----..-.•........,_,hlllllL .............. -.,.__ID....,......,.,,,._.

N
A
0 0.01 0.02
Miles
c::J carlsbad Boundary
t: ~ carlsbad Quadrant
D carlsbadMobllltyHubs
□ carlsbad MGRAs
c::J carlsbad Palomar MGRAs with
2016-2050 Increased Unit Olange
General Plan Land Use
D I., Local Shopping Center
D PI, Planned Indusbial
D R-23, ResidenHal 15-23 du/ac
MGRA: 17984
/
The Cly olC•--•an, ._.-y Jorthe
OI CRNd beoorM labte to usera of this tnap. or any
any nahn alielng out of or reeUIUng from the lack of
~
., ...,.,..._ cl this m111> TIE FOREGOING WARRNITY IS EXCWSII/E AND IN LIEU OF AI.LOTIER WARRANTIES OR MERCHANTAIIIUTY, ATNESS FOR PARTICIA.AR PIAlPOSE ANO/OR /W'f OTHER TYPE WHETHER EXPRESSED OR IMPLleo:-tr;~ shal the Cily po,ty. to, anyloa or dam-__,._., ___ lld,dqi bulnol-lDflmo. - ar~ ~-the- . .,,._,,,_ ollho map. In Ullngthlomap. USOffulthltlQ!H1o lndamnll'/, de!ond, and hokl ha!mleaa tho City o! Canobad for any aiia o! o, correctn .. of the map, or the use orthe map.

P!th: \ \~h~rf'~\l;l5 __ J1.µµ\R11que.sts~arth2015\ComEcoriDe~\Pla rmlng\l!ln100.U~i5 _21 \SANDAG Mobility Hubs.~r,., N
A
0 0.02 0.04
Miles
c::::J cartsbad Boundary
t: ~ cartsbad Quadr,mt
C] cartsbadMobilityHubs
Carlsbad MGRAs
c::::J cartsbad Palomar MGRAs with
2016-2050 Increased Unit Olange
General Plan Land Use
t::::J OS, Open Space
D IH5, ResidenHal 8-15 du/llC
Piilt!: \ \$hlll'~\GIS J,pp\R~que!itsMuc.h2015\ComEconDev\Plannino\RITMOO nue _21 \SAN DAG Mabi~ty Hubs.aprx MGRA: 22902
N
A
0 0.02 0.04
Miles
c:::J Carlsbad Boundary
t: •_. Carlsbad Quadrant
c=J CarfsbadMobilltyHubs
Carlsbad MGRAs
c:::J Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
C] OS, Open Space
D PI, Planned Indusbial
D R-4, Residential 0-4 du/ac
MGRA: 22906
I
•ILi.~-..,.,.. ... ~ FITJQe FIJlt
•-....... ,..,.,.._ ..... .., __ ... _., .. lllll'I ..
(i)
. . .
.

N
A
0 0 .01 0.03
Miles
c:::J Carlsbad Boundary
;: : -.: Carlsbad Quadrant
D CarlsbadMobilityHubs
c:) Carlsbad MGRAs
c:::J Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Olange
General Plan Land Use
D OS, Open Spare
D PI, Planned Industrial
D R-4, Residential 0-4 du,'ac
MGRA: 22910
I
I
I
JIIIClr,f//--mj',.___.llo .. ~•-------THEPCIIIOO .. IU.9IR"""'IIIPCCLINMll.~ 81CN'-~otl~~l'QIINlnl:IIIMl"l#DIE-lltf'tDnRW.........-=;,:: ~~l!ll::~~IIUll!Jl~lf.,,-l orCMW ... a..1a-1111.-- ·s-,-,-ii,.1ar1111m••--•-•---IIIMl'llllll......,.la •--~• . .,-.•-• ...... ...,. .. ____ ID.._,.,,.~ii,,lw "'• llll_.,._..,.,._,._ .. _ _,__, • ...._ .. 11,_..,_,_1111,._ot111t•, N
A
0 0.02 0.04
Miles
c::::J car1sbad Boundary
;;, : ~ car1sbad Quadrant
C] CarlsbadMobilityHubs
C] carlsbad MGRAs
c::::J car1sbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
[:;J] OS, Open Space
D R-1,5, Resldentlal 0-1.5 du/ac
D R-15, Residential 8-15 du/ac
D R-4, Residential 0-4 du/ac
MGRA: 22917
The 0lf ol~ ..... ff'/1---- l\ll'llto- ar---ollhll map. 1llE FORIIOOING WAAR»ffY 18 EXCWIIMIN//DIIIJBJOF:/U.C11'Ml!l!~OlltlllRClHANTABIUIY, FITIBl1I FOR PAAJl0UI.AR o!Qdlllad_...,..., ._,...,1111,.....,-..-any...,_fllr!Y,for·-•or-..a-,~ot~,~IIUlnot ...... lD...,,i,-otgocdl,lf. ....... 11,iM .. iao,;__,., ....... ...,61hfflllP,1hud,gll,loffllll, 11111' ............... ola,,.a,g_.,._.,......., ....... .,,._,,, ......... ,,, ...... ., .... _ Pith: \\shara\GIS_.llpp\RequestsMar<h 2015\ComEcon0ev\Mannlng\lUTM0023<136_2 l \SANO.AG Mobllity Hubs.apnc N
A
0 0.01 0.03
MIies
i'..::, carlsbad Quadrant
CJ carlsbadMobllilyHubs
Carlsbad MGRAs
c:::J carlsbad Palomar MGRAs with
2016-2050 Increased Unit Olange
General Plan Land Use
rn OS, Open Space
CJ PI, Planned Industrlal
MGRA: 22925
N
A
i'.,: ~ cartsbad Quadrant
D CartsbadMobilityHubs
carlsbad MGRAs
c:::J cartsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
E:]] OS, Open Space
D PI, Planned Industrial
R, Regional Commercial
0 0 .03 0.05 - VC, Visitor Commercial
Miles
P~ : \\th1r."IGISj.pp\R111unt1Mlrd,20IS\ComEtonDev\Pl~nnlng\Rm10023436_21 \~NDAG Mobdlty ~l>s.tfm i; MGRA: 22926
N
A
0 0.02 0.04
Miles
t::, Carlsbad Quadrant
t=) Car1sbadMobilllyHubs
Carlsbad MGRAs
c:::J Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
Q OS, Open Space
D PI, Planned Indusbial
VC, Visitor Commercial
Pith: \\stmas\GIS_App\RequutsMlrch201S\ComEconOev\Plo1nnlng\RITMOD2J'lJ6_21\SANDAG Mobllltv Hubup,x MGRA: 22928
Of' ALL OfllRIIIMRAIITaClR ...,. .. ....-,....,,... .. _ In M'I.ED, In __ ....... ca,
llfc.......i1or..,11111•111111lJor
N
A
0 0.01 0.03
Miles
;:, : :, car1sbad Quadrant
c:J car1sbadMobilityHubs
carlsbad MGRAs
c:::J car1sbad Palomar MGRAs with
2016-2050 Increased Unit Olange
General Plan Land Use
C3 OS, Open Space
D PI, Planned Industrial
D Pl/O, Planned Industrial/Office
MGRA: 22930
N
A
o 0.01 0.02
Miles
c:::J Carlsbad Boundary
t: ~ Carlsbad Quadrant
□ CarlsbadMobllltyHubs
Carlsbad MGRAs
c:::J Carlsbad Palomar MGRAs with
2016-2050 Inaeasm Unit Oiange
General Plan Land Use
D PI, Planned Industrial
,_ ~ _, dl Ml ta~,.2L'WWitu.Ma
MGRA: 22931
(i)
N
A
0 0.01 0.03
MIies
c:::J Carlsbad Boundary
i'..::, Carlsbad Quadrant
D CartsbadMobllltyHubs
Carlsbad MGRAs
c:::J Carlsbad Palomar MGRAs with
2016-2050IncreasedU™ tOlange
General Plan Land Use
t=] OS, Open Space
- P,Publlc
CJ PI, Planned Industrial
D F'I/O, Planned Industrial/Office
---· .., ............

MGRA: 22933
\
....._,..~/MJtl!SIOl'M.L-WMIWlla,OR ,Pffl89RRl'lllfflCII.M~Nff1111&1'1weNfflfHEREllCPIIIIIEJOR ........ IIO_ .... ._°"I' -- ......... l'llll-•- ................ ~ ........ 1111 ..... ___ ,.. .. ....., ................. -.ai, .. 011111aa..,, ... ...., .. ...__., ...

N
A
0 0 .01 0.02
Miles
C cartsbad Boundary
;:, : ~ cartsbad Quadrant
CJ cartsbadMobilityHubs
cartsbad MGRAs
C cartsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
E:::@ OS, Open Space
D PI, Planned Industrial
VC, Visitor Commercial
MGRA: 22934
1-0INIIITYl'E'llltfflllR-01-- 1111111-N,-ai,
111......,..~...,....,.,_..._cni,4111:111•11111•-.•18•11r"' N
A
0 0.01 0.03
Miles
c:::I cartsbad Boundary
t: ~ cartsbad Quadrant
c::J c.artsbadMobllityHubs
r;::;:;:;;;J c.artsbad MGRAs
c::J Carlsbad Palomar MGRAs with
2016·2050 Increased Unit Change
General Plan Land Use
CJ OS, Open Space
- P,Public
D PI, Planned Industrial
D PI/O, Planned Industrial/Office
MGRA: 22936
\
'TlloClyolCnllad_q_..,_lora._w_of11111- THEF0REOOINGWWIANTYIIEXCWIIIWNIDtlUEUOIFALLOTlliR'IIWWfflEIIOR ~ FITNS116FORPN!TICULAR PURPOeENIIIORIHr011t!Rl'VPE~E)CflREIISED0R IIIPUED. lftno-llllla.C<II' 01--...111111o"'-oftNomop,•..,-lllltv.lor..,._.,,....,__,...-,-.giunct.,._"'....,_"'..-_a11q-.__, __ .,,_ota._lft...,..,..IIIIP, _____ ~-----~1hoClyof~lorllff..,IIW..of ..,na11n111-1gowC11«_.,.._.,,._ot_«_o1111o-"'"'--TII""• ~
~
N
A
0 0.010.01
Miles
C eartsbad Boundary
;;_:: Carlsbad Quadrant
CJ CarlsbadMobllttyHubs
Carlsbad MGRAs
C Carlsbad Palomar MGRAs with
201&-2050 Increased Unit Olange
General Plan Land Use
- P,Public
D PI, Planned Indusb1al
MGRA: 22937
llaCIIWll~.,._.,,,_...,.., .. .._..- ...... 1MEl'OMilaolta- ■ ~NellLBl~,U.CfflB - laaClll~~IIQll.-nc&AMl'llll'OIIEHIIUIMlt01tel'l'lftWHmllll.,_,0Rll'Ull).lnno_nl .. Cllr IICIIIINjl-llllltll_lf ___ ..,_lllllllllr-•• ................ •---~----11-._..,•....., ......... -....-.- ............. _ _._ ...... ....,__..,_._.._ ___ 0llllllldfor-,_.11_.,II .,,, _ _.._.,_.....,. ___ .,....., __ .,.,....,_.,._ ... .. ... ----
c::J Carlsbad Boundary
;:, : :, Carlsbad Quadrant
D Cal1sbadMobUltyHubs
W Carlsbad MGRAs
MGRA: 22941
c::J Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Olange
N
A
0 0.02 0.04
Miles
General Plan Land Use
D OS, Open Space
D PI, Planned Indusbial
R, Regional Commercial
VC, Visitor Commercial
n.ca,111~ ................... .___. otCIMIII....,,.,_., _ _, .. ..,.,..., ....... . .. -. .... ., ....... _ ...... __,. ., ..... 'llll!,._..WMRIWN.~MDlfl.lli1l...,_Olta ..,....; ......................... "" ........... _ . ...,.. , ... ...., .. _., .. ....

PMli; \~.-H\GIS _~p\~'°'Ml"tart.h2015\ComEcooO iev\r!Mnlflg\JUTIIIO0D4J6_J.1\SANDAG Motlftlty Hutn;.apot N
A
0 0,01 0.02
Miles
c:::J car1sbad Boundary
t::, car1sbad Quadrant
CJ car1sbadMobilityHubs
carlsbad MGRAs
c:::J carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
General Plan Land Use
c:::Jl OS, Open Space
D Pl, Planned Industrial
- VC, Visitor Commercial
P-dth: \\sha1es\GIS_.Q,pp\Requut:1M.trdl20l5:\ComEc1m01v\Plannln9\RITM002J<1J6_ll \SANOAG Moll>llity H1,1t,,«.,,iprx MGRA: 22947
Carlsbad Palomar Mobility Hub MGRAs Near Airport
Notes

1. 2010 McClellan-Palomar Airport ALUCP Policy 3.3.3 prohibits residential uses on properties, or portions of properties, with airport noise exposures greater than 65 dB CNEL.
2, 2010 McClellan-Palomar Airport ALUCP Policy 3.4.4 prohibits residential uses on properties, or portions of properties, within airport safety zones 1, 2 and 5.
, , , , ,
, , ,
, , ,.

N
A
0 0.04 0.08
Miles
t: :• Carlsbad Quadrant
CJ MGRAs with 2016-2050
Increased Unit Change
CJ Airport MGRA
ALUCP 2010 Safety Zones:

D Zone 1
0Zone2
0Zone3
D Zone4
Ozones
0Zone6
' ,
T lty of Carlsbad ~\claims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY 18 EXCLUSIVE ANO IN LIEU OF ALL OTHER WARRANTIES OR MEg!tHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no eventahall the City 1 Carlsbad become llablt to users of this map, or any other party, for any loss or dama~, consequential or otherwise, lnctudlng but not limited to time, money, or goodwfll, arising from the use, operation or modincation of the map. In ualng thla map, user further agree to Indemnify, defend, and hold harmleH the Clfy ofCarlabad ror any and all llabUlty ot any nature arising out of o~qisultlng from the lack of accuracy or correctness of the map, or the use of the map. , ' • Peth: \\sh1re,\GIS_App\fteQ1,1UbM1rch2015\ComEcon0ev\Pt1nnlng\lUTM002J4l6_2l\SANOAG Mabi~ty H1.1b1.1pl'll Attachment 5
PLEASE NOTE: PRELIMINARY RIDERSHIP DATA-UNAUDITED AND SUBJECT TO ADJUSTMENTS I .... ~-TOfM.ltlD!UHIP
ffl1 ..,.. ·v...-
"' July 10,263 149,515 (139,252) (93.1%)
Aug 9,412 133,482 (124,070) (92.9%)
Sept 10,020 114,233 (104,213) (91.2%)
Oct 10,968 111,045 (100,0TT) (90.1%)
Nov 9,232 94,551 (85,319) (90.2%)
Dec 7,519 83,951 (76,432) (91.0%)
Jan 6,848 98,791 (91,943) (93.1%)
Feb 7,866 91 ,845 (83,979) (91.4%)
Mar 11 ,203 46,510 (35,307) (75.9%)
Apr 15,184 5,244 9,940 189.5%
May 19,214 6,207 13,007 209.6%
June .. 44,978 8,734 36,244 415.0% .. Not final as of July 19, 2021 YTDTotal 162,707 0 (781,401)
FY Total 162,707 944,108
I .. .\ l!KfUMY
.,._ "20 ~ s
July 10,263 131,218 (120,955) (92.2%)
Aug 9,412 112,100 (102,688) (91.6%)
Sept 10,020 92,159 (82,139) (89.1%)
Oct 10,968 105,601 (94,633) (89.6%)
Nov 9,232 80,912 (71,680} (88.6%)
Dec 7,519 75,534 (68,015) (90.0%)
Jan 6,848 89,920 (83,072) (92.4%)
Feb 7,866 B4,613 (76,747) (90.7%)
Mar 11,203 44,368 (33,165) (74.7%)
Apr 15,184 5,244 9,940 189.5%
May 17,221 6,207 11,014 1TT.4%
June** 35,192 8,734 26,458 302.9% "*Not final as of July 19, 2021 YTDTotal 150,928 0 (685,682)
FY Total 150,928 836,610
1 11111111111 ~~M'RIRDIIV ,_ ,_
---
~
July . 9,415 (9,415) (100.0%)
Aug - 14,348 (14,348) (100.0%)
Sept - 8,449 (8,449) (100.0%)
Oct - 3,247 (3,247) (100.0%)
Nov . 8,385 (8,385) (100.0%)
Dec - 4,387 (4,387) (100.0%)
Jan - 3,218 (3,218) (100.0%)
Feb - 5,181 (5,181) (100.0%)
Mar - 665 (665) (100.0%)
Apr - 0 0
May 1,387 0 1,387
June** 5,881 0 5,881 ••Not final as of July 19, 2021
YTDTotal 7,268 0 (50,027)
FYTotal 7,268 57,295
I Month OOA$11.R- lllliliv..Y
PU'I PVIO .~ 1'
July . 8,882 (8,882) (100.0%)
Aug . 7,034 (7,034) (100.0%)
Sept . 13,625 (13,625) (1 00.0%)
Oct . 2,197 (2,197) (100.0%)
Nov . 5,254 (5,254) (100.0%)
Dec . 4,030 (4,030} (100.0%)
Jan - 5,653 (5,653) (1 00.0%)
Feb . 2,051 (2,051) (1 00.0%)
Mar . 1,4n (1,477) (1 00.0%)
Apr . 0 0
May 606 0 606
June .. 3,905 0 3 ,905 0 Not final as of July 19, 2021
YTD Total 4,511 0 (45,692)
FY Total 4,511 50,203
ATTACHMENT 6- Project Data Request
Table 1: Project Information Request
Estimated Current Draft RTP Assumed
Project Total Project Planned Year of Assumed Year Federal/State Cost Construction of Construction Matchina Fundina (%)
San Dieguito Lagoon Double Track
and Platform
Batiquitos Lagoon Double Track and
Bridqe Replacement
Eastbrook to Shell Double Track
Carlsbad Villaqe Trench
La Costa to Swami Double Track
San Onofre Bridoe Replacements
Rose Canyon Bridqe Replacements
ATTACHMENT 7- Detail of Proposed Rail Lines
Table 3: Detail of Proposed Rail Lines
Average Interoperable
Rail Mode (CR, Directional % of Directional Number Distance Average with LR, HSR, Miles Miles Grade of Between Speed COASTER
Hybrid) Separated/Tunnel Stations Stations Operated equipment (Y/N)
New Rail Line
Sept. 30, 2021
San Diego Association of Governments
401 B street, Suite 800
San Diego, CA 92101
Via: SDForward@sandag .org
RE: City of Carlsbad Comments on Draft 2021 Regional Plan To whom it may concern,
ATTACHMENT 2
( city of
Carlsbad
This letter serves to inform SANDAG that the City does not wish to remove project CB32 from the Regional Arterials Project list.

Please disregard the comment regarding project CB32 from the attached letter sent to SAN DAG on Aug. 6, 2021.

Thank you for bringing this to our attention, and please contact me if you have any other questions regarding the 2021 Regional Plan comment letter.

Best Regards,
Tom Frank, PE
Transportation Director/City Engineer
Attachment A: Letter to SAN DAG dated Aug. 6, 2021
I
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public works
Mike Strong, Assistant Director, Community Development
Public Works Branch - Transportation Department
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2766 cc: Don Neu, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager Jason Geldert, Engineering Manager
Eric Lardy, Principal ~lanner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Public Works Branch - Transportation Department
1635 Faraday Avenu e I Carlsbad, CA 92008 I 760-602-276 6 ( City of
Carlsbad
Aug.8,2023
San Diego Association of Governments
401 B Street, Suite 800
San Diego CA 92101
Via: [email protected]
RE: City of Carlsbad Comments on the Amendment to the 2021 Regional Plan To Whom it May Concern,
( City of
Carlsbad
The City of Carlsbad appreciates the opportunity to provide comments on the proposed amendment to the 2021 Regional Plan ("Plan Amendment"). This is an important plan for this region and guides the next phases of growth for the member agencies of the San Diego Association of Governments (
11 SANDAG11 ). An effectively designed and implemented regional transportation plan ensures improved transportation options for area resi.dents, businesses and other community members; meaningful reductions in greenhouse gas ("GHG") emissions; and improved quality of life as we grow our communities.

The City of Carlsbad ("city") is submitting the following comments based on the policies, projects, programs and other improvements included in the Plan Amendment. The city reserves the right to add, amend, change or replace comments and recommendations based on additional review and understanding of the Plan Amendment and the environmental analysis provided under the California Environmental Quality Act ('
1 CEQA11 ).

SECTION 1: LAND USE

1. Alternatives included in the approved 2021 Regional Plan assumed housing in locations that were inconsistent with the city's land use plans; this was discussed in detail in the city's August 6, 2021/September 30, 2021, comments on the draft 2021 Regional Plan (Attachment 1).

Consistent with those comments, city staff recommend the Plan Amendment:
a. Consider the city's land use plans, including the General Plan, Habitat Management Plan, and Local Coastal Program.
b. Consider the McClellan-Palomar Airport Land Use Compatibility Plan (adopted by the county Airport Land Use Commission and amended Dec. 1, 2011) and the constraints identified therein.

2. City staff are encouraged by recent conversations with SAN DAG staff that the proposed 2025 Regional Plan will consider the city's land use documents. Doing so is recommended and expected and will help ensure better accuracy of data and assumptions.

SECTION 2: COMMENTS AND RECOMMENDATIONS
City staff remain concerned that there is not enough detail on the feasibility of implementation of this significant shift in transportation strategy. On specific content in the plans, we outline our recommendations and comments below:

Transportation & Community Development Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2710 t Attachment B
......
< .
..

I.
..
. ,
..
•
City of Carlsbad Comments on the Amendment to the 2021 Regional Plan Aug. 8,2023

1. Paying for the Plan:

The 2021 Regional Plan sets out an ambitious plan to build and operate a region-wide system of transportation projects, programs and other improvements. This is a substantial role for SAN DAG to play in supporting both the construction and operation of these projects, programs and other improvements. SAN DAG should set annual revenue targets to directly fund everything and should approve any recommended sustainable revenue tools to help meet these targets.

Many of the funding strategies will require legislative changes, or voter-approved taxation.

SAN DAG should clarify what will occur if the funding is not available, if opposition to projects stops them from construction, and if General Plans in the region are not modified to implement the Plan/Plan Amendment.

2. Appendix D: Sustainable Community Strategy Documentation:

Appendix D includes the Sustainable Communities Strategy, which outlihes assumptions included in the Activity Based Model 2+ ("ABM 2+"). This model will be necessary for use by publicly and privately initiated land use projects preparing documents for consistency with VMT/CEQA Guidelines and Traffic Impact Analysis ("TIA") Evaluations. City staff respectfully request direction from SAN DAG on how to conduct modeling with the service bureau and how to factor in these assumptions applied to ABM 2+. Specifically, the addition of pricing, parking costs for coastal communities, 10% teleworking and micromobility. SAN DAG should provide direction on how this could be worked 'into General Plans that are updated every 5-20 years.

The plan should provide a process for implementing all phases of the Build North County Corridor (NCC) managed lanes project and the supporting active transportation infrastructure projects. It is also recommended that the plan pivot from the existing low ridership fixed routes transit services to flexible fleets along the 1-5 and SR-78 corridors to maximize the objectives of the plan. As stated in the Regional Plan, priority Flexible Fleet will help make the region more accessible, equitable, and environmentally friendly.

3. Appendix A: Transportation Projects, Programs, and Phasing:

Trips to and from school sites result in a significant congestion, VMT generation, and peak hour delay throughout the region. Additional funding and projects should be recommended with a specific focus on improving safety and multi modal access in and around school sites along with programs to incentivize non-single occupancy vehicle trips to schools.

Table A.11: Given the proven success of the Carlsbad Connector microtransit pilot program, the city agrees with the Plan/Plan Amendment's recommendations to provide similar on-demand microtransit systems throughout North County at all mobility hub sites and major transit centers.

The preferred lnterstate-5 freeway alternative identified in the North Coast Corridor ("NCC") Final EIR/EIS is the refined 8+4 Buffer alternative, with four freeway lanes and two managed lanes in each direction and completion by 2035. Appendix A, Table A.5 describes NCC project IDs CC004, 007 - 009 as "8F to 6F+4Ml" with completion by 2050. While this might lead to further study, it is not clear why there is a different freeway configuration (i.e., reduction in freeway lanes) proposed. How does a reduction in lanes continue to meet NCC potential project benefits of maintaining or improving traffic operations and improving the safe and ef f
icient regional
movement of people and goods?
.. '
. ..
.
' '
. '
' .
,.
..
.. ·, . ,
••• t
. '
• <
..

City of Carlsbad Comments on the Amendment to the 2021 Regional Plan Aug.8,2023

4. Active Transportation:

The city appreciates the Plan/Plan Amendment's overall approach of providing a connected network of high-quality bicycle facilities throughout the region. Regional bikeways are recommended throughout the city including along Palomar Airport Road which will provide a key east-west connection and El Camino Real which will provide a new north-south bikeway connection through the city. Both roadways are proposed to include "on-street bikeways". Due to the high traffic volumes and vehicle speeds experienced along most of both corridors, the city recommends considering "off-street bike.ways'' or Class I facilities where feasible in order to stimulate the shift from personal motor vehicle use to people choosing to bike.

It is extremely important that municipal transportation plans align with regional transportation plans to achieve regional goals for land use and transportation and to promote the region working together to build a cohesive regional transportation network. Considering there are currently no mechanisms in place to ensure municipalities coordinate local transportation plans with regional planning documents, the Plan should provide an approach on how SANDAG plans to engage with municipalities, especially in areas of potential disagreement or conflict (as aforementioned in this subsection and others). It is also recommended that the Plan Amendment provide additional direction regarding the application of protected bikeways in a variety of applicable contexts. While vertical measures such as soft hit posts may be appropriate in lower volume and lower speed roadways, arterial roadways with high traffic volumes and high speeds warrant much more substantial physical protection from vehicles. In addition, special consideration should be given at intersections and driveways which mc1y be impacted due to the additional width and visibility impacts created by protected bikeways.

City staff look forward to working with SAN DAG on improving mobility and land use access in the region and building sustainable, equitable and healthy modes of transportation, and we appreciate the opportunity to comment on the Plan Amendment that will help the region realize these goals.

If you have any questions related to comments on the transportation network, please contact Tom Frank, Transportation Director/City Engineer, [email protected] or if you need additional information related to comments on the land use assumptions, please contact Eric Lardy, City Planner, at [email protected].

JEFF MURPHY
Community Development Director

TOM FRANK
Transportation Director/City Engineer
City of Carlsbad Comments on the Amendment to the 2021 Regional Plan Aug. 8,2023

Attachment:

1. City of Carlsbad comments on draft 2021 Regional Plan dated August 6, 2021 cc: Scott Chadwick, City Manager
Cindie McMahon, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Senior Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberio, Deputy City Manager, Comtnunity Services Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Director, Community Development
Eric Lardy, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager Jason Geldert, Engineering Manager
Robert Efird, Principal Planner
Scott Donnell, Senior Planner
Nicole Morrow, Assistant Planner ..
(city of
Carlsbad
Sept. 30, 2021
San Diego Association of Governments
401 B street, Suite 800
San Diego, CA 92101
Via: [email protected]
RE: City of Carlsbad Comments on Draft 2021 Regional Plan To whom it may concern,
This letter serves to inform SAN DAG that the City does not wish to remove project CB32 from the Regional Arterials Project list.

Please disregard the comment regarding project CB32 from the attached letter sent to SAN DAG on Aug. 6, 2021.

Thank you for bringing this to our attention, and please contact me if you have any other questions regarding the 2021 Regional Plan comment letter.

Best Regards,
Tom Frank, PE
Transportation Director/City Engineer
Attachment A: Letter to SAN DAG dated Aug. 6, 2021
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberib, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public works
Mike Strong, Assistant Director, Community Development
Public Works Branch - Transportation Department
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2766 Attachment 1
cc: Don Neu, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager Jason Geldert, Engineering Manager
Eric Lardy, Principal Planner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Public Works Branch - Transportation Department
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2766 (Cityof
Carlsbad '
Attachment A
Aug.6,2021
San Diego Association of Governments
401 B Street, Suite 800
San Diego CA 92101
Via: [email protected]
RE: City of Carlsbad Comments on Draft 2021 Regional Plan To Whom it May Concern,
( Cityo f
Carlsbad
The City of Carlsbad appreciates the opportunity to provide comments on the draft 2021 Regional Plan ("Plan"). This is an important plan for this region and will guide the next phase of growth for the member agencies of the San Diego Association of Governments ( 11 SANDAG" ). An effectively designed
and implemented regional transportation plan would hell) ensure improved transportation options for area residents, businesses and other community members; meaningful reductions in greenhou se gas ("GHG") emissions; and improved quality of life as we grow our communities.

The City of Carlsbad ("city " ) is submitting comments based on the policies, projects, programs and other improvements included in the Plan. Our agency's comment letter is divided into two sections. The first section seeks clarity and other considerations that pertain to our agency's review of the Plan. The second section identifies the city's preliminary comments and recommendations .

Implementing the regional transportation network outlined in the Plan requires municipalities to support the regional vision and deliver on local infrastructure and services like the priority bus routes, local bus services, and pedestrian and cycling connections to major transit infrastructure. These components , which are delivered by municipalities, are essential to creating a coherent and comprehensive local transportation network that feeds into regional services. For that reason, an effective public review of the Plan should involve a transparent and thorough process for identifying and evaluating potential hazards, physical changes to the environment and indirect (off-site and cumulative) impacts that might result from implementation activities that may reasonably occur with the Plan.

The city's residents, businesses and other community members will greatly benefit from the involvement and technical assistance from the prospective Draft Environmental Impact Report ("EIR").

Therefore, what follows in this correspondence represents our agency's prelim inary comments and recommendation s. The city reserves the right to add, amend, change or replace comments and recommendations based on additional review and understanding of the Plan and the environmental analysis provided under the California Environmental Quality Act ("CEQA").

The city thanks SAND AG staff for meeting with city staff on Aug. 2, 2021, to discuss some of these comment s in advance of this letter. Following that meeting, SAN DAG provided language that they may recommend adding to the Regional Plan for additiona l clarification on land use authority. The language is, "Land use authority is reserved to local jurisdictions because they are best positioned to effectively implement the objectives outlined in the Plan through understanding of the unique needs of their communities and geographies." This language will be helpful to clarify that .land use authority rests with Transportation & Communi ty Development Departm ents
1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602~2710 t Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plah
Aug. 6,2021

the local jurisdiction. The city still offers the followin_g comments with the intent to support development of a defensible and realistic regional plan.

SECTION 1: CLARITY AND OTHER CONSIDERATIONS
City staff have attended the series of workshops that SAN DAG hosted during the public review period, and respectfully starts this section with several questions related to the process of the Plan and t he Draft EIR. By way of introduct ion, a jurisdiction's General Plan, such as the city's General Plan, identifies the expected population of the city and any lands outs ide of t he city limit s but within their Sphere of Influence where future growth is anticipa ted to occur, The city's General Plan identifies the subject area adjacent to the McClellan-Palomar Airport for development under the designation for limited and light industrial use.

For future land use planning, land use assumptions must reasonably proxy and be generally consistent with local planning standards and programs, to be considered growth accommodating rather than growth inducing. SAN DAG has the authority under Government Code Section 65584 to determin e existing and projected housing needs, as well as the share of housing needs to be allocated to cities and counties, but it is unclear if SAN DAG has jurisdiction to allocate new housing growth to areas in a manner not consistent with Government Code Section 65584. Attachment 1 includes additional information on the applicable Government Code and standards. Therefore, and as indicated above, the build-out of properties within the Business Park and flight activity zone must be done in accordance with the city's General Plan Land Use Diagram, as amended, in accordance with city approval.

The initial questions on the planning process associated with developing the Plan are provided below:

1. The SAN DAG website states, "The SAN DAG Sustainable Communities Strategy and Final EIR from its 2015 Regional Plan will remain valid and in compliance for purposes of state funding eligibility and other state and federal consistency purposes until the SAN DAG B0cird of Directors adopts a new Regional Plan and EIR, prov ided those actions are completed by the end of December 2021.'' SAN DAG needs to clarify how the Draft EIR, Response to Comments and Adoption will be completed this year and what will occur if they are not completed by the end of this year. Additionally, please clarify when the Draft EIR will be available; it is difficult to completely assess the full impacts of this plan when the public review of the documents is piecemealed.
a. SAN DAG should clarify how public comments on the Plan are going to be addressed in the Draft EIR prior to its release.
b. In the Draft EIR, SAN DAG needs to clearly articulate the impacts to land use and if the Plan will cause a significant environ mental impact due to a conflict with any land use plan, policy or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Appendix F: Regional Growth Forecast and Sustainable Communities Strategy Land Use Pattern appears to be inconsistent with the city's General Plan and rezone program to accommodate the Regional Housing Needs Assessment, as well as the general plans of other juri sdictions such as the cities of Coronado, Del Mar and the County of San Diego. The Draft EIR should clarify how implement ation of this Plan can occur if those changes are not made.

Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug.6,2021

2. The city has three mobility hubs, associated with the Employment Centers Publi shed supporting the SAN DAG Regional Plan.l McClellan-Palomar Airport is the fifth largest employment center in the region, with Carlsbad State Beach and Carlsbad Village as "Tier 3 and Tier 4" employment centers. The city thanks SAN DAG for providing data for analysis to determine impacts and provide for accurate comments on the Plan. Attachment 2 shows a summary of the Mobility Hubs and housing units assumed in the Series 14 Growth Forecast for the year 2050. In summary:
a. The assumptions in the updated Series 14 Growth Forecast contain inconsistencies with the city's General Plan. The Carlsbad Palomar Major Employment Mobility Hub does include increases in density beyond what the citywide numbers appear to show when they are looked at in more detai l.
i. There are three locations in which density is shown to be inconsistent with good planning principles, the city's General Plan and the Airport Land Use Compatibility Plan. The three most problematic areas (shown in Attachment 3) are:

1. 736 units on parcels immediately adjacent to the McClellan-Palomar Airport runway. The location of the airport within this mobility hub was shared with SAN DAG staff multiple times at workshops. This is inconsistent with the regulations provided by the San Diego County Regional Airport Authority and conflicts with standard planning principles for siting housing away from hazards.

2. 2,755 units on existing developed resort properties and open space dedicated lands adjacent to Legoland.

3. 65 units in a preserved open space area.
ii, SAN DAG should provide additional detail why units were assumed in these areas, what planning principles those decisions were based on, and how SAN DAG expects this to be implemented.
iii. Concentration of units in the mobility hubs alone appears to conflict with the direction received from the California Department of Housing and Community Development ("HCD") to implement new Affirmative 'ly Furthering Fair Housing ("AFFH"), which seeks to combat housing discrim ination, eliminate racial bias, undo historic patterns of segregation, and lift barriers that restrict access in order to foster inclusive communities and achieve racial equity, fair housing choice and opportunity for all Californians. The allocatio ns of land use provided by SAN DAG seem to focus all the higher density housing into one area of the city. (This is one of the largest points of analysis that each jurisdiction in the region needs to respond to in order to receive a certified Housing Element.) b. Additionally, looking at the detailed data provided by SAN DAG, it is now clear why the citywide numbers only show moderate increases in populati on. Our analysis has shown that there is an assumed reduct ion of population by 2,310 persons in the areas with in the city but outside of the mobility hubs. This is likely due to assumed reductions in persons per household over time , but SAN DAG should clarify the source and reasonableness of this assumption. If housing is not provided consistent with these areas, is it still reasonable to assume persons per household will be reduced in 2050? 1 SAN DAG Website: Employment Centers SAN DAG :: PROJECTS:: San Diego's Regional Planning Agency Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021

c. Furthermore, this reduction in population is not limited to the City of Carlsbad. There is • an approximately 85,000 reduction in populat ion assumed outs ide of mobility hubs regionwide. SAN DAG needs to address if that is a reasonable assumpt ion and if this will result in other impacts to public and private projects that will rely on this growt h forecast, and the associated Activity Based Model (2+) to project future impacts to transportation, GHG, air quality and noise.
d. The forecast has decreased in future population based on current trends, but it is not clear if there is enough housing provided with reductions and increases in some jurisdictions. Will the reduced amount of housing that will be provided result in an increased exacerbation of the affordability crisis?
e. There is a lack of clarity about how the Plan would be implemented at the municipal level. SAN DAG should develop an approach for engaging with municipalities to ensure local support for delivering the regional tra)1sportation network . Staff from local jurisdiction have the knowledge and ability to share where the re are land use assumptions that conflict with planning and zoning laws. Our analysis focused on the City of Carlsbad, but if these types of assumptions are made regionwide, it presents flaws in the overall analysis. These flaws put the assumed reductions in vehicle miles traveled ("VMT") and ability to implement the Regional Plan into question .

3. The area designated is controlled for use and activity density and intensity throug h its spatial association with the McClellan-Palomar Airport. The McClellan-Palomar Airport is defined by the Federal Aviation Administration ("FAA") as a commercial service airport that, in addition to private aircraft , has regularly scheduled commercial flights to Los Angeles Internat ional Airport ("LAX"). The McClellan-Palomar Airport Land Use Compatibility Plan ("ALUCP") is prepared according to FAA requirements and adopted by the San Diego County Regional Airport Author ity c'lcting as the Airport Land Use Commission for the County of San Diego. a. The ALUCP provides measures to minimize the public's exposure to excessive noise and safety hazards within areas around the airport and identif ies areas likely to be impacted by noise and flight activity created by aircraft operat ions at the airport. These impacted areas include the Airport 1Influence Area ("AIA"), the Clear Zone and the Flight Activity Zone.
b. Within the AIA, the ALUCP establishes six safety zones for the purpose of evaluating safety compatibil ity of new/future land use actions. The safety zone boundaries depict relat ive risk of aircraft accidents occurring near the airport and are derived from general aviation aircraft accident location data and data regarding the airport's runway configuration and airport operational procedures. The ALUCP limits development intensities in these zones by imposing floor area and lot coverage maximums, by incorporating risk reduction measures in the design and construction of buildings, and/or by restricting certain uses altogether. For example, all residential and virtually all non-residential uses are considered incompatible land uses in some zones, while considered to be either compatib le or conditionally compatible with the airport in other zones. Attachment 4 shows the McClellan-Palomar Airport, noise contours and SANDAG's proposed housing units.
c. If the proposed SAN DAG land use assumptions are endorsed, an amendment to the city's General Plan would be required to change the land use designation to Mixed-Use Commercial or residential land uses within the existing Business Park in order to effectuate the underlying assutnptions of SAN DAG staff. This is not a realistic Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6,2021

assumption. Further, the protected airspace referenced in the AIA and the ALUCP must also be amended based on SANDAG's regional planning assumptions. (The FAA establishes airspace protection zones in the airspace above and surround ing airports in order to protect aircraft from obstructions such as buildings, towers, etc. in navigable airspace.)
d. When a General Plan is adopted or amended, the allowab le growth pattern of an area is identified and the expansion or updating of the various land uses as specified in the General Plan can occur throughout the planning horizon. Without such growth considerations, the expansion or intensification of existing land uses could be considered "growth inducing." Unplanned and uncontrolled growth may have significant adverse impacts on the environment. CEQA require s a discussion of how a "project" could increase population, employment or housing growth in surrounding areas and the tmpacts resulting from this growth. The CEQA Guidelines indicate that a "project" would normally have a significant effect on the environment if it would induce substantial growth or a substantial concentration of population.

4. At this point, it is not clear if SANDAG's assumptions adequate ly contemplate the development patterns included in the Sustainable Communities Strategy ("SCS")/Regional Transportation Plan ("RTP"), and Regional Air Quality Strategy ("RAQS"), local climate action planning business-as­ usual estimates, sub-regional traffic modeling, or the airspace assumptions of AIA and the ALUCP.

5. The city seeks clarity on the Plan's underlying assumptions made to justify the proposed extensive high-speed rail network considering the significant changes in travel behavior which have occurred throughout the region as a result of the COVID-19 pandemic and due to the advancements in disruptive technologies such as telecommuting, autonomous vehicles, microtransit, etc.
a. Recent North County Transit District ("NCTD") Coaster ridership data show riders are not returning to riding the Coaster in comparison to other modes of travel as shown in Attachment 5.
b. This question is consistent with comments made by SANDAG's panel expert Bob Poole regarding the impact of the COVID-19 pandemic on transit ridership and mega-transit projects. (See comments by Bob Poole during the March 12, 2021 presentat ion to SANDAG starting at timestamp 1:30 p.m,: https://youtu .be/q-eGbNYSJ 8?t-S410 )

6. The city seeks clarity on why an alternatives analysis was not conducted with consideration of other transit alternatives such as automated /shared vehicle technologies and personalized zero emissions transit programs that are capable of util izing the existing regional freeway infrastructure in response to t hese recent developments explained in the above comment.

7. The city seeks clarity on why the Plan does not incorporate policies to promote round abouts over signalized intersections and include a budget line item under the Complete Corridors to fund the construction of roundabouts at new locations and to replace signalized intersections when found feasible. This clarification would support the Federal Highway Administration ("FHWA")'s project for Accelerating Roundabout Implementation in the United States and the County of San Diego Air Pollution Control Board's support for implement ing roundabouts to address GHG and reduce fata lities.

8. The city seeks clarity on the project phasing proposed within the Plan. Specifically, the city is seeking to understand the timing of implementation of unfunded Trans Net projects related to Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021

the new projects presented within the Regional Plan. To support this, the city is requesting that SANDAG input the information requested in Table 1 (Attachment 6).

9. The city seeks specific data on the proposed 200 miles of rail service contemplated in the Plan.

To support this, the city is requesting that SAN DAG input the information requested in Table 3 (Attachment 7). Specific questions:
a. Please provide more information about the scope of the high-speed rail alignments, potential vehicle technologies and their cost estimates. b. Will the Coaster keep the same rail alignment?
c. What funding is programmed or planned for the Carlsbad Village railroad trench and the other projects along the current NCTD/Coaster Service right-of~way? d. Will some of the tracks be at grade with fencing and trains traveling at 110 miles per hour speeds?
SECTION 2: COMMENTS AND RECOMMENDATIONS
In addition to the comments on process and the Draft EIR provided above, city staff remain concerned that there is not enough detail on the feasibility of implementation of this significant shift in transportation strategy. On specific content in the plans, we outline our recommendations and comments below:

1. Paying for the Plan:

The draft 2021 Regional Plan sets out an ambitious plan to build and operate a region-wide system of transportation projects, programs and other improvements. This is a substantial role for SAN DAG to play in supportin g both the construction and operation of these projects, programs and other improvements. SAN DAG should set annual revenue targets to directly fund everything and should approve any recommended sustainable revenue tools to help meet these targets . Many of the funding strategies will require legislative changes, or voter-approved taxation. SAN DAG should clarify what will occur if the funding is not available, if opposition to projects stops them from construction, and if General Plans in the region are not modified to implement the Plan.

2. Appendix D: Sustainable Community Strategy Documentation:

Appendix D includes the Sustainable Communities Strategy, which outlines assumptions included in the Activity Based Model 2+ ("ABM 2+"), updated for this. This model will be necessary for use by publicly and privately initiated land use projects preparing documents for consistency with VMT/CEQA Guidelines and Traffic Impact Analysis ("TIA") Evaluations. City staff respectfully request direction from SAN DAG on how to conduct modeling with the service bureau and how to factor in these assumptions applied to ABM 2+. Specifically, the addition of pricing, parking costs for coastal communities, 10% telework ing and micromobility. SAN DAG should provide direction on how this could be worked into General Plans that are updated every 5-20 years.

3. Appendix A: Transportation Projects, Programs, and Phasing:

Trips to and from school sites result in a significant congestion, VMT generation, and peak hour delay throughout the region. Additional funding and projects should be recommended with a specific focus on improving safety and multimodal access in and around school sites along with programs to incentivize non~single occupancy vehicle trips to schools.

Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6, 2021

Table A.11: Given the proven success of the Carlsbad Connector microtransit pilot program, the city agrees with the Plan's recommendations to provide similar on-demand microtransit systems throughout North County at all mobility hub sites and major transit centers.

Table A.13: The segment of El Camino Real between Poinsettia Lane and Camino Vida Roble is proposed to be widened from two to three lanes to prime arterial standards. With the adoption of the city's General Plan, the city has determined that the widening of this portion of El Camino Real is not feasible due to constrained right-of-way and wou ld result in negative impacts to other travel modes. City staff recommend removal of this proposed project recommendation CB32 (that is, a 'do nothing
1 scenario, or appraise and evaluate different mobility projects and/or alternative designs).

The prefer red lnter state -5 freeway alternative identified in the North Coast Corridor ("NCC") Final EIR/EIS is the refined 8+4 Buffer alternative, with four freeway lanes and two managed lanes in each direction and completion by 2035. Appendix A, Table A.5 describes NCC project IDs CC004, 007 - 009 as "8F to 6F+4MLJI with completion by 2050. While this might lead to further study, it is not clear why there is a different freeway configuration (i.e., reduction in freeway lanes) proposed. How does a reduction in lanes continue to meet NCC potential project benefits of mainta ining or improving traffic operations and improving the safe and efficient regional movement of people and goods?

4. Active Transportation:

The city appreciates the Regional Plan's overall approach of providing a connected network of high-qL1ality bicycle facilities throughout the region. Regional bikeways are recommended throughout the city including along Palomar Airport Road which will provide a key east-west connection and El Camino Real which will provide a new north -south bikeway connection through the city. Both roadways are proposed to include "on-street blkeways". Due to the high traffic volumes and vehicle speeds experienced along most of both corridors, t he city recommends considering "off-street bikeways" or Class I facilities where feasible in order to stimulate the shift from personal motor vehicle use to people choosing to bike.

It is extre mely important that municipal transportation plans align with regional transportation plans to achieve regional goals for land use and transportation and to promote the region working toge ther to build a cohesive regional transportation network. Considering there are currently no mechanisms in place to ensure munic ipalit ies coordinate local trans portat ion plans with regional planning documents, the Plan should provide an approach on how SAN DAG plans to engage with municipali ties, especially in areas of potential disagreement or conflict (as aforementioned in this subsection and others). It is also recommende d that the Plan provide additional direction regarding t he application of protected bikeways in a variety of applicable contexts. While vertica l measures such as soft hit posts may be appropriate in lower volume and lower speed roadways, arterial roadways with high traffic volumes and high speeds warrant much more substantial physical protect ion from vehicles. In addition, special consideration should be given at intersections and driveways which may be impacted due to the additiona l width and visibility impacts created by protected bikeways.

City staff look forwa rd to working with SAN DAG on improving mobility and land use access in the region and building sustainable, equitable and healthy modes of transportation, and we appreciate the opportunity to comment on the Plan that will help the region realize these goals.

Attachment A
City of Carlsbad Comments on Draft 2021 Regional Plan
Aug. 6,2021

If you have any questions related to comments on the transportation network, please contact Tom Frank, Transportation Director/City Engineer, at [email protected] or if you need additional information related to comments on the land use assumptions, please contact Eric Lardy, Principal Planner, at [email protected].

Sincerely,
For

JEFF MURPHY
Community Development Director
TOM FRANI<
Transportation Director/City Engineer
Attachments:

1. Government Code 65020 (S.B. 375) Summary

2. City of Carlsbad Mobility Hubs

3. City of Carlsbad - Palomar Airport Road Mobility Hub Analysis

4. Palomar-Mclellan Airport Flight Paths

5. Recent NCTD Coaster Ridership Data

6. Table 1- Project Data Request

7. Table 3 - Detail of Proposed Rail Lines
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Geoff Patnoe, Assistaht City Manager
Ron l(emp, Assistant City Attorney
Robby Contreras, Assistant City Attorney
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Director, Community Development
Don Neu, City Planner
Nat han Schmidt, Transportation Planning and Mobility Manager Jason Geldert, Engineering Manager
Eric Lardy1 Principal Planner
Scott Donnell, Senior Planner
Corey Funk, Associate Planner
Attachment 1: Government Code 65020 (S.B. 375) Summary
City of Carlsbad Comment Letter August 6, 2021
Government Code section (“GOV §”) 65080, also referred to as California Senate Bill 375 (Steinberg, 2008) (“SB 375”), is one area of law that provides SANDAG with guidance to which a regional transportation plan must be developed.

Among other things, the regi
onal transportation plan that is developed “shall be an internally consistent document” (GOV § 65080 (b)) and shall include a “sustainable communities strategy prepared by each metropolitan planning organizations as follows” (GOV § 65080 (b)(2)(B)):

Each metropolitan planning organization shall prepare a sustainable communities strategy, subject to  the  req
uirements  of  Part  450  of  Title  23  of,  and  Part  93  of  Title  40  of,  the  Code  of  Federal Regulations, including the requirement to utilize the most recent planning assumptions considering local general plans and other factors.   The sustainable communities strategy shall (i) identify the general location of uses, residential densities, and buil ding intensities within the region, (ii) identify areas within the region sufficient to house all the population of the region, including all economic segments of the population, over the course of the planning period of the regional transportation plan taking into account net migration into the region, popul ation growth, household formation and  employment  growth,  (iii)  identify  areas  within  the  region  sufficient  to  house  an  eight‐year projection of the regional housing need  for the region pursuant  to Section 65584, (iv) identify a transportation network to service the transportation needs of the region, (v) gather and consider the best practically available scientific information regarding resource areas and farmland in the region as defined in subdivisions (a) and (b) of Section 65080.01 , (vi) consider the state housing goals specified in Sections 65580 and 65581, (vii) set forth a forecasted development pattern for the  region,  which,  when  integrated  with  the  transportation  network,  and  other  transportation measures and policies, will reduce the greenhouse gas emissions from automobiles and light trucks to  achieve,  if  there  is  a  feasible  way  to  do  so,  the  greenhouse  gas  emission  reduction  targets approved by the state board, and (viii) allow the regional transportat ion plan to comply with Section 176 of the federal Clean Air Act ( 42 U.S.C. Sec. 7506 ).

The  2021  draft  Regional  Transportation  Plan  includes  a  Sustainable  Communities  Strategy  (“SCS”),  as required by SB 375 for the San Diego region (herein after called “draft Regional Plan”). The draft Regional Plan indicates that “SB 375 requires the SCS to include a pattern for forecasted growth and development that accomplishes the following: 1) When combined with the tran sportation network, the SCS will achieve the regional  GHG emission–reduction  targets; 2). The SCS accommodates the Regional Housing  Needs Assessment  (“RHNA”)  Determination;  and  3)  The  SCS  utilizes  the  most  recent  planning  assumptions. (Reference p. 19 of the 2021 Regional Plan.)
Predicting the effect of transportation plans or projects on land uses and land use planning is critic al to developing  context  sensitive  solutions  for  transportation  projects.  Therefore,  utilization  of  the  most recent planning assumptions is not only necessary but is required  as  specifically stated therein  GOV § 65080.  If  inconsistencies  are  found  in  the  land  use  assumptions  or  adverse  impacts  are  anticipate d, SANDAG should be actively engaged in the development of measures to address these issues.

The SANDAG Board of Directors approved the final RHNA plan with the final housing unit allocation on July  10,  2020,  which  was  based  on  the  most  recent  land  use  planning  assumptions  and  an  adopted methodology to allocate housing in accorda
nce with GOV §§ 65584.04(d and  m). The City  of Carlsbad received a total RHNA allocation of 3,873 units as a result of RHNA plan adoption. The adopted April 6, 2021 city’s Housing Element accommodates its housing needs through current zoning and other programs Attachment A
Attachment 1: Government Code 65020 (S.B. 375) Summary
City of Carlsbad Comment Letter August 6, 2021
as needed to meet the city’s RHNA obligation at all income levels. The land use inputs derived from this local  planning  document  constitutes  the  most  recent  land  use  assumptions.  On  July  13,  2021  the Department  of  Housing  and  Community  Development  found  “the  adopted  housing  element  is  in substantial compliance with Stat
e Housing Element Law (Article 10.6 of the Gov. Code).

The most recent planning assumptions are critical for the development of the draft Regional Plan as the document  must  comply  with  other  specific  state  and  federal  mandates  including  a  SCS  per  California Senate Bill 375, which ac
hieves GHG emissions reduction targets set by the California Air Resources Board and compliance with federal civil rights (Title VI) requirements, environmental justice considerations, air quality conformity, and public participation. To monitor compliance and attainment of state reduction goals in GHG, GOV § 65080 (b)(2)) requires that:
(H) Prior to adopting a
sustainable communities strategy, the metropolitan planning organization shall  quantify  the  reduction  in  greenhouse  gas  emissions  projected  to  be  achieved  by  the sustainable communities strategy and set forth the difference, if any, between the amount of that reduction and the target for the region established by th e state board. (J)(i)  Prior to starting the public participation process adopted pursuant to subparagraph (F), the metropolitan planning organization shall submit a description to the state board of the technical methodology  it  intends  to  use  to  estimate  the  greenhouse  gas  emissions  from  its  sustainable communities strategy and, if appropriate, its al
ternative planning strategy.

There is inevitably some uncertainty regarding the use of projected future conditions. However, what is certain  is  that  the  project  will  not  operate  under  the  conditions  that  exist  today.  There  will  be  new residential and employment growth in the intervening years between now and the proposed build‐ out of the draft Regional Plan. Nonetheless, projections utilized should represent the best available information assembled by the local agencies with jurisdiction and expertise. Judgments about land use assumptions utilized in the draft Regional Plan should be based on and supported by facts, adopted plans, and “most recent planning assumptio
ns,” rather than speculation and personal opinions. The land use assumptions for “uses, residential densities, and building intensities within the region” (as required by GOV § 65080 (b)(2)(B)(i)) should also be the same, as that provided to the state board (as required per GOV §§ 65080 (b)(2)(H and J) in estimati
ng and analyzing GHG from the SCS and the effect on growth and whether the effects of that growth would be significant in the context of the region’s plans, natural setting, and growth patterns.  Ultimately,  the  SCS  must  demonstrate  whether  SANDAG  can  meet  the  per  capita  passenger vehicle‐related GHG emissions targets for 2035 set by the California Air Resources Board (“C ARB”).

SB 375  directs CARB to accept or reject the determination of SANDAG that its SCS submitted to CARB would, if implemented, achieve the region’s GHG emissions reduction targets. CARB’s technical evaluation of SANDAG’s draft Regional Plan would be based on all  the evidence provided, including the models, the data inputs and assumptions, the SCS strategies, and the performance indicators.

The  transportation  and  planning  assumptions  are  also  extremely  important  as  it  is  relied  on  for  other master planning exercises. The Regional Air Quality Strategy (“RAQS”) relies on information from CARB and SANDAG for information regarding projected growth in the citi es and San Diego County. This in turn
is utilized  to  address other state requirements, including  the  San  Diego portion  of the California State Implementation Plan (“SIP”) and promulgating their own rules and regulations regarding air quality in the region or to address federal requirements.

Attachment A
Attachment 1: Government Code 65020 (S.B. 375) Summary
City of Carlsbad Comment Letter August 6, 2021
The analysis of land use impacts for transportation projects is guided by FHWA Technical Advisory T 6640.8 and the CEQA Guidelines.

Under  the  FHWA  Technical  Advisory  T  6640.8  (G)(1),  Guidance  for  Preparing  and  Processing Environmental, states:

This discussion [of land use] should identify the curren t development trends and the State and/or
local government plans and policies on land use and growth in the area which will be impacted by the proposed project. These plans and policies are normally reflected in the area's comprehensive development  plan,  and  include  land  use,  transportation,  publi c  facilities,  housing,  community services, and other areas.

The land use discussion should assess the consistency of the alternatives with the comprehensive development plans adopted for the area and (if applicable) other plans used in the development of  the  transportation  plan  required  by  Section  [23  U.S.  Code  §]  134.  The  secon dary  social, economic,  and  environmental  impacts  of  any  substantial,  foreseeable,  induced  development should  be  presented  for  each  alternative,  including  adverse  effects  on  existing  communities.

Where possible, the distinction between planned and unplanned growth should be identified.

There  is  also  a  requirement  to  analyze  the  land  use  planning  inconsistencies  per  CEQA  Guidelines  § 15126.2(a), which specifies that an EIR
for a proposed project include:

The Significant Environmental Effects of the Proposed Project. An EIR shall identify and focus on the significant effects of the proposed project on the environment. In assessing the impact of a proposed project on the environment, the lead ag ency should normally limit its examination to changes in the existing physical conditions in the affected area as they exist at the time the notice of  preparation  is  published,  or  where  no  notice  of  preparation  is  published,  at  the  time environmental analysis is commenced. Direct and indirect significant effe cts of the project on the environment shall be clearly identified and described, giving due consideration to both the short‐ term  and  long‐term  effects.  The  discussion  should  include  relevant  specifics  of  the  area,  the resources involved, physical changes, alterations to ecological systems, and changes induced in population  distribution,  populatio n  concentration,  the  human  use  of  the  land  (including commercial  and  residential  development),  health  and  safety  problems  caused  by  the  physical changes, and other aspects of the resource base such as water, historical resources, scenic quality, and public services. The EIR shall also analyze any significant environmental effects the project might cause or risk exacer
bating by bringing development and people into the area affected. For example,  the  EIR  should  evaluate  any  potentially  significant  direct,  indirect,  or  cumulative environmental impacts of locating development in areas susceptible to hazardous conditions (e.g., floodplains, coastlines, wildfire risk areas), including both short‐term and long‐term conditions, as iden
tified  in  authoritative  hazard  maps,  risk  assessments  or  in  land  use  plans  addressing  such hazards areas.

Since the new land use assumptions are being utilized, as described by this letter, the EIR that is prepared shall also analyze any significant environmental effects the project might cause by bringing development and people into the area affected. The f
ollowing are the basic steps in analyzing land use impacts as part of the community impact assessment process:

Attachment A
Attachment 1: Government Code 65020 (S.B. 375) Summary
City of Carlsbad Comment Letter August 6, 2021

1. Inventory the existing land use patterns (including undeveloped land), development trends, and transportation systems. The inventory of existing land uses should include the following land use types: residential, commercial, industrial, recreational, institutional, public services, community services, emergency services, transporta
tion, utilities, agriculture, and undeveloped land in the study area. The study area should include the surrounding community that is generally associated with the project area within which community impacts could occur. The inventory should also address development trends and identify recent developments in the study area to include the development’s name, size, statu
s (planned, built, under construction), and the
jurisdiction in which it is located. A map showing the location of existing and planned land uses in the area should also be prepared.

2. Determine whether the project is consistent with local and regional policies that govern land use and development. For
the consistency analysis, the policies and programs considered in the analysis should include: transportation plans and programs (MTPs/RTPs and MTIPs/RTIPs), regional growth plans, local General Plans that establish land use and growth management policies for the study area, and any specific or pipeline development proposals. This analysis should also include a discussion of consistency with the Coastal Zone Manage ment Act of 1972,
California Coastal Act of 1976, the National Wild and Scenic Rivers Act (16 USC 1271) and the California Wild and Scenic Rivers Act (Pub. Res. Code § 5093.50 et seq.). After preparing a preliminary list of relevant plans to be considered in the an alysis, the SANDAG planner should
meet with the staff of the various agencies to review the list to determine if it is complete and revise the list as necessary.

3. Assess the changes that would occur in land uses and growth with and without the project.

4. The draft Regional plan and each projec
t alternative should be considered separately since the results may be different.

5. Develop measures to avoid, minimize, and/or mitigate potential adverse effects.

The resulting environmental analysis should identify the current development trends and the State and/or local government plans and policies on land use and grow th in the area which will be impacted by the proposed project. These plans and policies are normally reflected in local General Plans. If found to be consistent, then the findings in the EIR should be documented in the report and no further analysis or action is necessary. When found not to be inconsistent with a policy or program, then consideration must
be given to modifying the draft Reginal Plan alternative to make it consistent, or measures to address the inconsistency must be developed. SANDAG should be actively engaged in the development of measures to  address  these  issues  and  be  prepared  to  assess  the  consistency  of  the  draft  Regional  Plan  and alternatives with the comprehensive development plans adopted for the area and (if applicable) other plans used
in the development of the transportation plan required by Section 23 U.S. Code § 134. For any new land use growth assumptions, the secondary social, economic, and environmental  impacts of any substantial, foreseeable, induced development should be presented for the draft Regional Plan and each alternative,  i
ncluding  adverse  effects  on  existing  communities.  The  results  should  be  shared  with  the public during the public involvement process, e.g., at community meetings, etc. Public input should be considered  by  SANDAG  and  if  necessary,  the  findings  of  the  analysis  should  be  revised  to  reflect information gained through th
e public involvement process.

Attachment A
Carlsbad
Village
(Coastal)
Carlsbad Palomar
(Major Employment
Center)1
2 1
125
65 10
248
5 79521
581
228
1010 217 49
162415 178 51
SE
NW
NE
SW
Carlsbad
Vil
lage
Coastal 14087 6430 15095 6539 9290 16177 7075 9667 17293 7607 10044 Carlsbad
Palomar
Major
Employment
Center
12853 5475 12275 5461 61074 19465 8503 67005 21080 9265 72900 N/A Outside of
Hubs
86239 34247 88793 35855 13896 84039 35855 14345 83929 35855 14900 N/A All of
Carlsbad
113179 46152 116163 47855 84260 119681 51433 91017 122302 52727 97844 Hub Name Hub Type Total
Population
2016
Total
Houses
2016
Total
Population
2025
Total
Houses
2025
Total Jobs
2025
Total
Population
2035
Total
Houses
2035
Total Jobs
2035
Total
Population
2050
Total
Houses
2050
Total Jobs
2050
P
ath: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

SAND
AG Mobility Hubs
# Mobil ity Hub MGRAs with 2016-2050 Increased Unit Change Carlsbad Mobi
lity Hubs
Carlsbad MGRAs
Carlsbad Quadr
ant
Carlsbad B
oundary
0 21
Miles
Attachment A
3 83
34 21
50 14
2 2
1 1
4 38
5 35
18 27
72 72
50 22
7 36
63 8
923
2860
36 15141
231411 158 1611
17 87
2 171
11 24
83 32
8 6
4 1
3 1
2 36
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map. # Mobil ity Hub MGRAs with
2016-2050 Increased Unit Change
Carlsbad Mobility Hubs
Carlsbad MGRAs
Carlsbad Boundary
0 0.50.25
Miles
Carlsbad Village Mobility Hub MGRAs
Attachment A
Carlsbad
Village
(Coastal)
Carlsbad Palomar
(Major Employment
Center)
1 2
1 125
65 10
248
5 79
521
581
228
1010 217
49 162
415 178 51
SE
NW
NE
SW
Copyright nearmap 2015
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with 2016-2050 Increased Unit Change General Plan Land Use
L, Local Shopping Center
OS, Open Space
P, Public
PI, Planned Industrial
PI/O, Planned Industrial/Office
R, Regional Commercial
R-1.5, Residential 0-1.5 du/ac
R-15, Residential 8-15 du/ac
R-23, Residential 15-23 du/ac
R-4, Residential 0-4 du/ac
R-8, Residential 4-8 du/ac
TC, Transportation Corridor
VC, Visitor Commercial
VC/OS, Visitor Commercial/Open Space
0 0.25 0.13
Miles
MGRA Closer Look
Attachment A
R-4
OS
Carlsbad Palomar
(Major Employment
Center)
1 Unit
Change 2 Unit Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
R-15, Residential 8-15 du/ac
R-4, Residential 0-4 du/ac
VC/OS, Visitor Commercial/Open
Space
0 0.01 0.01
Miles
MGRA: 14249
Attachment A
R-4
OS Carlsbad Palomar
(Major Employment
Center)
1 Unit Change
2 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
R-15, Residential 8-15 du/ac
R-4, Residential 0-4 du/ac
TC, Transportation Corridor
VC/OS, Visitor Commercial/Open
Space
0 0.04 0.02
Miles
MGRA: 14251
Attachment A
VC TC
R-8
Carlsbad Palomar
(Major Employment
Center)
1 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
R-8, Residential 4-8 du/ac
TC, Transportation Corridor
VC, Visitor Commercial0 0.01 0.01
Miles
MGRA: 14265
Attachment A
L
R-23
Carlsbad Palomar
(Major Employment
Center)
125 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
L, Local Shopping Center
PI, Planned Industrial
R-23, Residential 15-23 du/ac
0 0.02 0.01
Miles
MGRA: 17984
Attachment A
OS
Carlsbad Palomar
(Major Employment
Center)
65 Unit
Change
5 Unit Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
Gener
al Plan Land Use
OS, Open Space
R-15, Residential 8-15 du/ac
0 0.04 0.02
Miles
MGRA: 22902
Majority
owned by
State of CA
Small portion owned by Kelly
Land Co. and Agua Hedionda
Lagoon Foundation
Attachment A
OS
PI
R-4
Carlsbad Palomar
(Major Employment
Center)
10 Unit
Change
248 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
R-4, Residential 0-4 du/ac
0 0.04 0.02
Miles
MGRA: 22906
Attachment A
OS
PI
R-4
Carlsbad Palomar
(Major Employment
Center)
10 Unit
Change
248 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
R-4, Residential 0-4 du/ac
0 0.03 0.01
Miles
MGRA: 22910
Attachment A
OS
OS
R-4
OS
Carlsbad Palomar
(Major Employment
Center)
65 Unit
Change
5 Unit Change
217 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
R-1.5, Residential 0-1.5 du/ac
R-15, Residential 8-15 du/ac
R-4, Residential 0-4 du/ac0 0.04 0.02
Miles
MGRA: 22917
Attachment A
PI
OS
Carlsbad Palomar
(Major Employment
Center)
79 Unit
Change217 Unit
Change
162 Unit
Change
178 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
0 0.03 0.01
Miles
MGRA: 22925
Attachment A
PI
VC
OS
Carlsbad Palomar
(Major Employment
Center)
521 Unit
Change
581 Unit
Change
1010 Unit
Change
415 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Unit Change
Gener
al Plan Land Use
OS, Open Space
PI, Planned Industrial
R, Regional Commercial
VC, Visitor Commercial0 0.05 0.03
Miles
MGRA: 22926
Owned by Gemological Institute
of America
Owned by
CB Ranch
Enterprises
OS
Attachment A
OS
VC
PI
Carlsbad Palomar
(Major Employment
Center)
5 Unit
Change
521 Unit
Change
581 Unit
Change
1010 Unit
Change
415 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map. THE FOREGOING W ARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Increased Uni
t Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
VC, Visitor Commercial
0 0.04 0.02
Miles
MGRA: 22928
Owned by M and
A Gabaee
OS
Owned by Grand
Pacific Carlsbad LP
VC designation
does not allow
residential uses
Attachment A
PI
PI/O
OS
OS
Carlsbad Palomar
(Major Employment
Center)
5 Unit
Change
79 Unit
Change217 Unit
Change
162 Unit
Change
178 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
PI/O, Planned Industrial/Office
0 0.03 0.01
Miles
MGRA: 22930
Attachment A
PI
Carlsbad Palomar
(Major Employment
Center)
49 Unit
Change
51 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
PI, Planned Industrial
0 0.02 0.01
Miles
MGRA: 22931
Attachment A
PI
PI/O
OS
Carlsbad Palomar
(Major Employment
Center)
79 Unit
Change
217 Unit
Change
162 Unit
Change
178 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
P, Public
PI, Planned Industrial
PI/O, Planned Industrial/Office0 0.03 0.01
Miles
MGRA: 22933
Attachment A
OS
VCPI
Carlsbad Palomar
(Major Employment
Center)
521 Unit
Change
581 Unit
Change
1010 Unit
Change
415 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
VC, Visitor Commercial
0 0.02 0.01
Miles
MGRA: 22934
Attachment A
OS
PI
Carlsbad Palomar
(Major Employment
Center)
79 Unit
Change
217 Unit
Change
162 Unit
Change
178 Unit
Change
51 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
P, Public
PI, Planned Industrial
PI/O, Planned Industrial/Office0 0.03 0.01
Miles
MGRA: 22936
Attachment A
PI
Carlsbad Palomar
(Major Employment
Center)
49 Unit
Change
178 Unit
Change
51 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
P, Public
PI, Planned Industrial
0 0.01 0.01
Miles
MGRA: 22937
Attachment A
PI
VC
VC
OS
Carlsbad Palomar
(Major Employment
Center)
521 Unit
Change
581 Unit
Change
228 Unit
Change
1010 Unit
Change415 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
R, Regional Commercial
VC, Visitor Commercial0 0.04 0.02
Miles
MGRA: 22941
Attachment A
PI
VCCarlsbad Palomar
(Major Employment
Center)
581 Unit
Change
228 Unit
Change
Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Boundary
Carlsbad Quadrant
CarlsbadMobilityHubs
Carlsbad MGRAs
Carlsbad Palomar MGRAs with
2016-2050 Incr
eased Unit Change
General Plan Land Use
OS, Open Space
PI, Planned Industrial
VC, Visitor Commercial
0 0.02 0.01
Miles
MGRA: 22947
Attachment A
70 dB CNEL
65 dB CNEL
60 dB CNE
L
70 dB CNEL
65 dB CNEL
60 dB CNEL
75+ dB CNEL
79 217
49 162
178
51 Path: \\shares\GIS_App\RequestsMarch2015\ComEconDev\Planning\RITM0023436_21\SANDAG Mobility Hubs.aprx The City of Carlsbad disclaims any responsibility for the accuracy or correctness of this map.

THE FOREGOING WARRANTY IS EXCLUSIVE AND IN LIEU OF ALL OTHER WARRANTIES OR MERCHANTABILITY, FITNESS FOR PARTICULAR PURPOSE AND/OR ANY OTHER TYPE WHETHER EXPRESSED OR IMPLIED. In no event shall the City of Carlsbad become liable to users of this map, or any other party, for any loss or damages, consequential or otherwise, including but not limited to time, money, or goodwill, arising from the use, operation or modification of the map. In using this map, user further agree to indemnify, defend, and hold harmless the City of Carlsbad for any and all liability of any nature arising out of or resulting from the lack of accuracy or correctness of the map, or the use of the map.

Carlsbad Quadrant
MGRAs with 2016-2050
Incr
eased Unit Change
Airport MGRA
ALUCP 2010 Safet
y Zones:

Zone 1
Zone 2
Zone 3
Zone 4
Zone 5
Zone 6
0 0.08 0.04
Miles
Notes

1. 2010 McClellan-P
alomar Airport ALUCP Policy 3.3.3 prohibits residential uses on properties, or portions of properties, with airport noise exposures greater than 65 dB CNEL.

2. 2010 McClellan-Palomar Airport ALUCP Policy 3.4.4 prohibits residential uses on properties, or portions of properties, within airport safety zones 1, 2 and 5.

Carlsbad Palomar Mobility Hub MGRAs Near Airport
Attachment A
Attachment 5
PLEASE NOTE: PRELIMINARY RIDERSHIP DATA ‐ UNAUDITED AND SUBJECT TO ADJUSTMENTS Month
FY21 FY20 Variance %
July 10,263 149,515 (139,252) (93.1%)
Aug 9,412 133,482 (124,070) (92.9%)
Sept 10,020 114,233 (104,213) (91.2%)
Oct 10,968 111,045 (100,077) (90.1%)
Nov 9,232 94,551 (85,319) (90.2%)
Dec 7,519 83,951 (76,432) (91.0%)
Jan 6,848 98,791 (91,943) (93.1%)
Feb 7,866 91,845 (83,979) (91.4%)
Mar 11,203 46,510 (35,307) (75.9%)
Apr 15,184 5,244 9,940 189.5%
May 19,214 6,207 13,007 209.6%
June** 44,978 8,734 36,244 415.0% **Not final as of July 19, 2021 YTD Total 162,707 0 (781,401)
FY Total 162,707 944,108
Month
FY21 FY20 Variance %
July 10,263 131,218 (120,955) (92.2%)
Aug 9,412 112,100 (102,688) (91.6%)
Sept 10,020 92,159 (82,139) (89.1%)
Oct 10,968 105,601 (94,633) (89.6%)
Nov 9,232 80,912 (71,680) (88.6%)
Dec 7,519 75,534 (68,015) (90.0%)
Jan 6,848 89,920 (83,072) (92.4%)
Feb 7,866 84,613 (76,747) (90.7%)
Mar 11,203 44,368 (33,165) (74.7%)
Apr 15,184 5,244 9,940 189.5%
May 17,221 6,207 11,014 177.4%
June** 35,192 8,734 26,458 302.9% **Not final as of July 19, 2021 YTD Total 150,928 0 (685,682)
FY Total 150,928 836,610
Month
FY21 FY20 Variance %
July - 9,415 (9,415) (100.0%)
Aug - 14,348 (14,348) (100.0%)
Sept - 8,449 (8,449) (100.0%)
Oct - 3,247 (3,247) (100.0%)
Nov - 8,385 (8,385) (100.0%)
Dec - 4,387 (4,387) (100.0%)
Jan - 3,218 (3,218) (100.0%)
Feb - 5,181 (5,181) (100.0%)
Mar - 665 (665) (100.0%)
Apr - 0 0
May 1,387 0 1,387
June** 5,881 0 5,881 **Not final as of July 19, 2021 YTD Total 7,268 0 (50,027)
FY Total 7,268 57,295
Month
FY21 FY20 Variance %
July - 8,882 (8,882) (100.0%)
Aug - 7,034 (7,034) (100.0%)
Sept - 13,625 (13,625) (100.0%)
Oct - 2,197 (2,197) (100.0%)
Nov - 5,254 (5,254) (100.0%)
Dec - 4,030 (4,030) (100.0%)
Jan - 5,653 (5,653) (100.0%)
Feb - 2,051 (2,051) (100.0%)
Mar - 1,477 (1,477) (100.0%)
Apr - 0 0
May 606 0 606
June** 3,905 0 3,905 **Not final as of July 19, 2021 YTD Total 4,511 0 (45,692)
FY Total 4,511 50,203

COASTER - TOTAL RIDERSHIP

COASTER - WEEKDAY

COASTER - SATURDAY

COASTER - SUNDAY
Attachment A
T bl 1 P . t I f a e ro1ec n orma 10n f R eques
Project
San Dieguito Lagoon Double Track
and Platform
Batiquitos Lagoon Double Track and
Bridqe Replacement
Eastbrook to Shell Double Track
Carlsbad Villaqe Trench
La Costa to Swami Double Track
San Onofre Bridge Replacements
Rose Canyon Bridqe Replacements
ATTACHMENT 6 - Project Data Request
t
Estimated Current Draft RTP Assumed
Total Project Planned Year of Assumed Year Federal/State Cost Construction of Construction Matching Funding (%)
Attachment A
ATTACHMENT 7 - Detail of Proposed Rail Lines
T bl 3 D t ·1 f P a e e a1 o ropose al mes d R ·1 L"
Average Interoperable
Rail Mode (CR, Directional % of Directional Number Distance Average with LR, HSR, Miles Miles Grade of Between Speed COASTER
Hybrid) Separated/Tunnel Stations Stations Operated equipment (Y/N)
New Rail Line
Attachment A
August 28, 2023
SANAG Regional Plan SEIR
C/O Kirsten Uchitel, Associate Planner
San Diego Association of Governments
401 B Street, Suite 800
San Diego CA 92101
Via: [email protected]
Attachment C
( City of
Carlsbad
RE: CITY OF CARLSBAD COMMENTS ON DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FOR THE PROPOSED AMENDMENT TO THE 2021 REGIONAL PLAN
Dear Ms. Uchitel:

The City of Carlsbad ("city") appreciates the opportunity to provide comments on the draft Supplemental Environmental Impact Report ("SEIR") for the proposed amendment to the 2021 Regional Plan ("Plan Amendment"). The SEIR is dated July 2023. The Regional Plan ("Plan") is an important plan for the region and will guide the next phase of growth for the member agencies of the San Diego Association of Governments ("SAN DAG"), including the city. An effectively designed and implemented regional transportation plan would help ensure improved transportation options for area residents, businesses and other community members, as well as meaningful reductions in greenhouse gas ("GHG") emissions and improved quality of life as we grow our communities.

The California State Legislature created specific provisions to promote streamlining environmental review for certain types of projects. Determining in a particular situation whether it is appropriate to prepare a subsequent or supplemental EIR is a project-sp ecific consideration , based on many factors.

Pursuant to CEQA Guidelines section 15163(b), "[a] supplement to the EIR need only the information necessary to make the previous EIR adequate for the project as revised." CEQA Guidelines section 15163 provides, in pertinent part: "(a) The lead or responsible agency may choose to prepare a supplement to an EIR rather than a subsequent EIR if: (1) Any of the conditions described in Section 15162 would require the preparation of a subsequent EIR, and (2) Only minor additions or changes would be necessary to make the previous EIR adequately apply to the project in the changed situation. Thus, CEQA Guidelines section 15163 applies when an EIR can be made adequate by additions or changes that respond to a limited set of issues, whereas a subsequent EIR is necessary when the previous EIR must be rewritten from the ground up to make its environmental analysis adequate. For the reasons stated in this letter, a subsequent EIR or new EIR is appropriate . There is no support to proceed under CEQA's supplemental review provisions because the original environmental document does not retain informational value to the ongoing decision-making process. It is only logical that SAN DAG start from the beginning under CEQA section 21151 by conducting an initial study to determine whether the project may have substant ial effects on the environment. Failure to satisfy this CEQA obligation constitutes a prejudicial abuse of discretion, which is precisely what CEQA seeks to avoid, and it undermines the public's ability to obtain a fully informed evaluation of the project.

Transportation & Community Development Departments
1635 Faraday Avenue I Carlsbad, CA 92008 I 442-339-2600 t City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 2
The city previously submitted comments on the Program Environmental Impact Report ("PEIR") for the Plan on Oct. 11, 2021. As the proposed SEIR is a supplement to that document and is largely based on the information, assumptions and analysis therein (e.g., regarding land use), many of the comments remain valid and are repeated in this letter.

The city seeks to ensure that SAN DAG prepares an environmental document that is adequate, complete and fully discloses the potential significant adverse effects of the Amended Plan. To implement the principles of CEQA, SAN DAG should correct previous deficiencies and not truncate the requisite cumulative impact analysis {CEQA Guidelines section 15168{b)(2)), use improper baselines (CEQA Guidelines section 15152), or foreclose the consideration of any alternative or mitigation measure that would ordinarily be part of CEQA review of a regional plan (CEQA Guidelines section 15004(b)(2)(B)). The former EIR failed to provide decision-makers and the public with all of the relevant information regarding the project that is necessary for informed decision-making and public participation.

CEQA prescribes review procedures a public agency must follow before approving or carrying out proposed projects. Those procedures emphasize the importance of public participation in the CEQA process, including mandatory opportunities for public review and comment and the lead agency's obligation to provide meaningful responses to comments received. SAN DAG failed to comply with CEQA by conducting the public review process for the Amended Plan and the SEIR separately though with some overlap, which has resulted in a disconnected, piecemeal and rushed process in which comments made on the Amended Plan were not responded to or incorporated into the SEIR.

The public and affected agencies like the city must submit comments on the SEIR without knowing whether or how SAN DAG has responded to previous comments on the Amended Plan. SAN DAG has already indicated that the SAN DAG Board is expected to review and consider the Amended Plan and the Final SEIR on October 27, 2023. Thus, there appears to be insufficient time for SANDAG to evaluate comments received on the SEIR, prepare meaningful responses and make those responses available as required by CEQA Guidelines sections 15087 and 15088. As such, SAN DAG is foreclosing on a "meaningful public participation process" and subjecting itself to a claim that SAN DAG is prejudicing the outcome of the environmental review process by ensuring there is little opportunity for public comments to influence the Amended Plan's program and design. ("Environmental review derives its vitality from public participation" (Ocean View Estates Homeowners Assn. V. Montecito Water Dist. (2004) 116 Cal. App. 4th 396, 400.)
If the issues that were addressed in the city's August 8, 2023 comment letter on the Amended Plan (Attachment 1) are not addressed in the SEIR, the SEIR will .be insufficient as an informative document and it will reduce the validity and efficacy of the Amended Plan, including its use of faulty assumptions regarding land use and population growth to comply with state and federal mandates, such as the Sustainable Communities Strategy and GHG reduction targets. These faulty assumptions misrepresent the vital land use-transportation planning connections and do nothing to reduce GHG and will instead result in unplanned increases to traffic, GHG, and result in increased housing unaffordability.

While the city supports the main concepts of the Vision in the Regional Plan, the 5 Big Moves, there needs to be an adequate analysis on how the Amended Plan will be implemented, and what will occur if there are changes to the projected growth, technology, and/or state law impacting existing conditions.

City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 3
The city appreciates SAN DAG adding language, as the city requested, that provides additional clarificati on on land use authority. This language is needed to clarify that land use authority rests with the local jurisdict ion. Although this principle should be obvious, the inconsistencies between the Amended Plan and the city's General Plan discussed below suggest that it has been ignored .

While the proposed amendment is focused on the removal of the regional road usage charge from the 2021 Regional Plan, the Amended Plan also provides updated regional employment figures, revenue assumptions, traffic volumes, etc., all of which are significant changes and/or new information of substantial importance. In addition, the city made the following substantive comments on the adequacy of the PEIR in its Oct. 11, 2021, letter on that document. These comments remain valid and highlight significant concerns that stem largely from faulty land use assumptions contained in the PEIR and 2021 Regional Plan, which the SEIR does not modify.

1. The PEIR/SEIR fail to disclose the Plan's and Amended Plan's inconsistencies with the Carlsbad General Plan and to analyze the related potential environmental impacts. The Legislature has declared a policy "to protect California's land resource, to ensure its preservation and use in ways which are economically and socially desirable in an attempt to improve the quality of life in California." (Gov. Code§ 65030.) To further this policy, each of the state's cities and counties is required to adopt a comprehensive, long-term general plan for the physical development of that city or county. (Gov. Code § 65300.) Accordingly, the city adopted a General Plan in compliance with state law and most recently updated it in 2015. the city's General Plan "sets forth land use compatibility policies applicable to future development in the vicinity." These policies are designed to ensure that future land uses in the surrounding area will be compatible with the realistically foreseeable activity in the city.

2. Growth projections for the region are based on population, vehicle trends and land use plans developed by the cities and the County of San Diego (''County") as part of their general plans. Mariy different regional documents rely on the same information to develop water demand projections, air quality performance standards, emission inventories, and emission reductions. The Amended Plan would result in an increase in residential land use resulting in corresponding increases in indirect and cumulative vehicle miles traveled ("VMT"). GHG emissions and air pollutant emissions, as well as inconsistencies with RAQS, SIP, and regional traffic modeling . This was not disclosed in the PEIR and thus influences the analysis in the SEIR. CEQA Guidelines section 15125(a) requires EIRs to contain a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the NOP is published, or if no NOP is published, at the time environmental analysis is commenced, from both a local and regional perspective. Existing general plans, including their Land Use Elements, should have been utilized for this baseline analysis and to derive future population and housing estimates.

In the PEIR, SAN DAG should have evaluated and clearly articulated the Plan's potential impacts on land use. Instead, the PEIR states that: "The forecasted development of the proposed Plan is based on the Series 14 Regional Growth Forecast SCS land use pattern, which is, in turn, based on the adopted general plans of the cities and County of San Diego and on the most recent planning assumptions, considering local general plans and other factors, as required by SB 375." This statement is incorrect. Thus, the Amended Plan is inconsister,t with the city's General Plan because it proposes residential land uses where s~ch uses are not authorized by the General Plan. The city's City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed Amendment to the 2021 Regional Plan
August 28, 2023
Pa e4
comments on the PEIR indicated that it appeared to ignore this inconsistency in concluding there would be less than significant impacts for the years 2025, 2035 or 2050.

The city has two mobility hubs in the Plan and PEIR: McClellan-Palomar Airport, the fifth largest employment center in the region; and Carlsbad State Beach and Carlsbad Village as "Tier 3 and Tier 4" employment centers. The city's Aug. 6, 2021 comments on the PEIR included an attachment that showed a summary of the Mobility Hubs and housing units assumed in the Series 14 Growth Forecast for the year 2050. The assumptions in the updated Series 14 Growth Forecast contain inconsistencies with respect to at least three locations in which density is shown to be inconsistent with the city's General Plan, the Airport Land Use Compatibility Plan and good planning principles.

These three problematic areas are:
a. 736 units on parcels immediately adjacent to the McClellan-Palomar Airport runway. The location of the airport within this mobility hub was shared with SANDAG staff multiple times at workshops. This is inconsistent with the regulations provided by the San Diego County Regional Airport Authority and conflicts with standard planning principles for siting housing away from hazards;
b. 2,755 units on existing developed resort properties and open space dedicated lands adjacent to Legoland; and
c. 65 units in a preserved open space area.

Since it does not change the Plan's land use assumptions, the Amended Plan continues to propose residential uses in areas which are not designated for such uses in the city's General Plan and the McClellan-Palomar Airport Land Use Compatibility Plan, as discussed below. This inconsistency results in potential significant impacts with respect to land use, public safety and noise. (See CEQA Guidelines, Appendix G, §§ IX(e), Xl(b), Xlll(c).) Because residential use is not authorized in those locations in the city's General Plan, the Amended Plan's assumption that residential use will occur there results in an overstatement of the extent to which other impacts, such as those associated with VMT, GHG and other pollutant emissions, will be reduced and understates those potential impacts of the Amended Plan. If the SEIR does not meaningfully address the inconsistency with the general plans of all member jurisdictions, which if not implementing this plan will cause a significant environmental impact due to the conflict with any land use plan, policy or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Multiple areas in Carlsbad are controlled as to their use and activity density and intensity through their spatial association with the McClellan-Palomar Airport, and some of these areas restrict residential use. The McClellan-Palomar Airport is defined by the Federal Aviation Administration ("FAA") as a commercial service airport that, in addition to private aircraft, has regularly scheduled commercial flights. Further detail on thiswas included in the city's August 6, 2021, comment letter on the draft Plan, part of Attachment 1 to this letter.

3. Table 4.5-1 indicates changes in demand for all modes of travel from the approved Plan to the Amended Plan under 2025 conditions. Given that the SEIR states that the roadway user charge would not be implemented until year 2035 conditions please explain why there would be any changes under the 2025 scenario.

4. As expressed in comments on the EIR, the analysis methodology used for the Transportation chapter does not provide a description of how the ABM2+ analysis outputs such as Average Daily Trips City of Carlsbad Comments on Draft Supplemental Environmenta l Impact Report for the proposed Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 5
(ADT), Mode Share, and Vehicle Miles Traveled (VMT) are calculated for each of the travel modes.

Without this information, it is difficult to understand how the transportation network improvements impact these analysis metrics for future year conditions and for consideration of potential project mitigations. The document link provided in response to this prior comment in the footnote with descriptions of the ABM2+ model outputs is not currently active.

5. The SEIR should evaluate the impact of the reduction in total funding resulting from the removal of the road usage charge. This evaluation should encompass the Regional Plan's reduced capacity to execute projects, including but not limited to additional roadways, transit systems, and active transportation. Furthermore, the analysis should address how the curtailment of projects could influence broader shifts in travel modes, vehicle miles traveled (VMT), and resulting GHG emissions.

6. The alternatives analysis does not describe a range of reasonable alternatives to the project because it does not include an analysis of an alternative that evaluates what will occur if the faulty land use, and therefore transportation, assumptions do not occur. The alternatives are constructed largely to reduce impacts through even more focused growth in Mobility Hubs and through increased value pricing and revenue generation. While it may be true these would reduce impacts, it does not provide policy makers or members of the public a reasonable range of alternatives as required by CEQA. Additionally, due to SB 9, which became effective Jan. 1, 2022, the reetuction in population assumed in suburban areas outside of the mobility hubs is both inconsistent with reality and with planning principles required by the California Department of Housing and Community Development to not concentrate all future growth in certain locations.

CEQA and the CEQA Guidelines require that an EIR describe all reasonable alternatives to the project and any feasible mitigation measures (Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal. 3d 400, 404). Because the SEIR does not discuss future land use conflicts with applicable general plans (as well as other city land use documents, such as the Local Coastal Program, Habitat Management Plan and McClellan-Palomar Airport Land Use Compatibility Plan), it fails to disclose ways to reduce or eliminate the environmental impacts of the project and to respond to the major environmental issues identified during the planning process (as a project alternative or as a mitigation measure) pursuant to Public Resources Code section 21002 (see Friends of the Old Trees v. Department of Forestry & Fire Protection (1997) 52 Cal. App. 4th 1383).

The SEIR's analysis of the project alternatives and mitigation measures is incomplete and, therefore, inadequate.

Section 15126 of the CEQA Guidelines requires that all aspects of a project must be considered when evaluating its impact on the environment, including planning, acquisition, development, and operation. The implementation and challenges to fund the Amended Plan have not been appropriately discussed. One of the project alternatives should accommodate transportation investments that can be reasonably funded within the horizon of the plan under the current ("known") funding mechanisms. Because the SEIR does not discuss a financially constrained alternative, the analysis of the project alternatives and mitigation measures is incomplete, and therefore, inadequate.

City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 6
In addition to the comments above, SEIR Alternative 3, the same as described in Chapter 6 of the approved Plan PEIR, includes the road usage charge. Following adoption of the approved Plan, the SAN DAG Board directed staff to prepare a focused amendment to the approved Plan that deletes the regional road usage charge. SEIR Section 2.3, Project Objectives, notes, "the proposed Amendment [to the 2021 Regional Plan] has the additional objective of removing the regional road usage charge while continuing to meet State and federal planning requirements, regional GHG reduction targets, and federal air quality conformity standards." As Section 6 states, Section 15126.6 of the CEQA Guidelines requires that an EIR "describe a range of reasonable alternatives to the project ... which would feasibly attain most of the basic objectives of the project..." Alternative 3's inclusion of the road usage charge conflicts with the fundamental reason for the Amended Plan. This alternative should be replaced or modified to exclude the road user charge.

7. The alternatives analysis also does not satisfy federal requirements. Federal legislation requires that the Plan include a financially constrained scenario (23 USC 134(h)(2)(B)). "Financially constrained" means that the RTP only includes projects that the region can afford to complete with existing revenues or with revenues that are reasonably expected to be available. The RTP must consider not only the cost of expanding the transportation system to meet future demand, but also the cost of maintaining the existing system. Costs must not exceed likely revenues. To date, there has been no such evaluation in the alternatives section. Although there is no mandate to include project alternatives in a Supplemental EIR, the SEIR must include financially constrained scenario to fulfill the federal requirement that the Amended Plan be financially constrained (i.e., budgeted). The removal of the road usage charge from the network has been replaced with speculative financing options. Rather, SANDAG must estimate revenues that are reasonably expected to be available from known federal, state, local, and private resources for transportation funding to implement the proposed projects.

Projecting revenues and expenditures over this length of a planning period will be difficult. The analysis should rely partly on historical funding patterns from state and federal sources. In addition, the year of expenditure must be considered when estimates for capital projects are developed (this is required by the Federal Surface Transportation Act).

8. Where regional planning processes have not resulted in the adoption of plans or regulations relating to the environment, CEQA requires public agencies to engage in an analysis of the impacts of the proposed project on the environment. (Public Resources Code§§ 21000; 21002.1; 21003.l(b); 21080(d); 21081; 21082.2(a).) Although there is a general analysis of projected growth in the region, there is a lack of detail with respect to growth inducement or reasonably foreseeable future projects implementing Public Resources Code section 21155 - 21155.4 (CEQA streamlining for SCS consistency) and/or other reasonably foreseeable development that may result. The provision or improvement of transportation infrastructure, utilities, water and sewer service to an area can induce growth by removing impediments to development. Once services are extended or improved in an area, economic incentives for development exist. The basic elements and principles of the Amended Plan have been designed to facilitate future smart growth and concentrate population growth in areas that would be efficiently served by transportation facilities. The smart growth concept is the basis for the framework for prioritizing public land use and transportation investments in the region. The smart growth concept identifies areas where smart growth development exists or could be built and provides a basis for planning transportation facilities and City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 7
transit services in the Amended Plan. Smart growth areas identified receive prioritized infrastructure investments and transit services to support smart growth. This carries true to those smart growth areas that are accommodated by existing general plans, and for other areas that are not covered by existing general plans. CEQA requires that an EIR discuss the ways in which the proposed project could foster economic or population growth or the construction of additional housing, either directly or indirectly, in the environment surrounding the project. CEQA requires this discussion to include ways in which a project would remove obstacles to population growth or encourage and facilitate other activities that could significantly affect the environment (CEQA Guidelines section 15126.2(d)). The level of detail should reflect the level contained in the plan or plan element being considered (Rio Vista Farm Bureau Center v. County of Solano (1992) 5 Cal.App.4th 351), inclusive of new smart growth areas as designated.

City staff looks forward to working with SAN DAG on improving mobility and land use access in the region and building sustainable, equitable and healthy modes of transportation. We appreciate the opportunity to comment on the Amended Plan that will help the region realize these goals. While at the same time, city staff also looks forward to helping SAN DAG advance a legally adequate environmental document to support the disclosure and decision-making process. Since the major premise of CEQA is that it "be interpreted in such manner as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language" (Friends of Mammoth v. Board of Supervisors, supra, 247, 2S9), SAN DAG should take all action necessary to alert the decision-makers and the public to the environmental changes associated with the project (County of Inyo v. Yorty (1973) 32 Cal. App. 3d 795, 810). There is no shortcut to CEQA - the EIR process protects not only the environment but also informed self-government (Laurel Heights Improvement Assn. v. Regents of University of California, supra, 376, 392). The SAN DAG Board must certify that the final SEIR has been completed in compliance with CEQA and that it considered all of the information in the final SEIR before approving or disapproving the project. As of this writing, the SEIR is not in compliance with CEQA.

If you have any questions related to comments on the transportation network, please contact Tom Frank, Transportation Director/City Engineer, at [email protected] or, if you need additional information related to comments on the land use assumptions, please contact Eric Lardy, City Planner, at [email protected].

Sincerely,
/()/JS A,fl/:6S{f2$6 {"6p.-

JEFF MURPHY
Community Development Director

TOM FRANK
Transportation Director/City Engineer
SD :mh
City of Carlsbad Comments on Draft Supplemental Environmental Impact Report for the proposed Amendment to the 2021 Regional Plan
August 28, 2023
Pa e 8
Attachment:

1. Aug. 8, 2023, City of Carlsbad Comment Letter on the Amendment to the 2021 Regional Plan (includes Aug. 6, 2021, comment letter on Draft Regional Plan and Sept. 30, 2021, clarification letter)
cc: Scott Chadwick, City Manager
Cindie McMahon, City Attorney
Geoff Patnoe, Assistant City Manager
Ron Kemp, Senior Assistant City Attorney
Gary Barberio, Deputy City Manager, Community Services
Paz Gomez, Deputy City Manager, Public Works
Mike Strong, Assistant Community Development Director
Eric Lardy, City Planner
Nathan Schmidt, Transportation Planning and Mobility Manager Jason Geldert, Engineering Manager
Robert Efird, Principal Planner
Scott Donnell, Senior Planner
Nicole Morrow, Assistant Planner
COMMENT LETTER 4: CITY OF CARLSBAD
August 28, 2023
SANAG Regionill Plan 5[1R
C/OiCir.stenUthitel,l\ssoci11t.el'i~nner
Si!nO.-egoA.ssociaUonof Governments
401 0Street,Su ite800
SanDiegoCA92lOI
V-ia:RegK1ualPlar-iSl:IR@:\<t1ll'l,\p.ltP.

Commen1Letter4
( City of
Carlsbad
Rf; CJTV OF CARLS DAD COMMENTS ON DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FOR llff PROPOSED AMENDMENT TO THE 2.0Zl REGION Al. PlAN OearMs.l>c.hitel:

TI,e C!ty of Carlsbad ("cit(') apprecla1es the opporrunity to provide ccmmenu on the dra~ Supplemenl~ I Environmenta l lmpa::t Report ("SEIRn) for the rm:.posed amendment to the 2021 Region.ti Plan ( .. Pl.10 Amendment~). The SEIR ii dated July 2.023. The Regional Plan j"Plari"I is an important plan

4.1 forth= region and will gulcle the ne(t phase. of growth for the member al!endes of the San Oi!go Asscciation of Govemmeno: j"SANDflG"). including the city. An effe<.ti\Pely designetl ;,nd implemented r~eii:mal transportition plan wou ld help en; uri:- improved tr.msportation optio ns for area r!!sldents, businesses-ilm:I othe r commuri ity membe~s, as we!l 115 meaningful r~u ct!ons in t:reenh:iuse gas /"GHG") em·1s~ions and lmpravt>d quality af 1ife as W?- crow our communil1!."~ The Cilitomia Sure l egislature created specific provisions to promo~ streilmlinlng erwlronme11tal re11ie".Y for r.ertain ty/,e~ of r,rnjeos_ fleterminmg io a parlkul arsituation whet her II is appropriate to prepa re a subsequent or supplement al EIR is a project-specific crmslderatlon, based on marry fatbrs.

Pursuant to CEQAGuldelln~ section 15l 53(b)1 "!al supplement to !he ElR need on!y ttie information ,umi~s.ary In m~k~ the previa1,s FIRadE:"quale f•r !Ile µruji:c\ .i~ re'lisetJ." CEQA Guidel!nes serUon 15163 1Jro11ides, In pertir.ent part; "{a) The lead or responsible agencymayc hoo;;e to prepare a supplement l:> an EIR rat.her than a subseque.nt EIF. if: (1) /,ny of the conditio n~ descrlbeC In SE'.cticn 15162 wnuld re.t1uire the preparation of a ~l1bw111ue11t E1R, :and (2) Only minor addition~ or chang~ wou ld l:>e 4_2 nece;sarv to mak~ the pre.vious t lll adequately :1,ply to the project ln the changed sltiJ;nion. Thus, CEQA Guidelines sec.tion l 5163 apphes when an EIR can IH! mad~ adequa!e hy ;Hid1tiollS or dl;irige.~ l1Ia\ responiJ to a limited sel of issue~. w~reasa subseq11 ent EIR is ne~;;~ary when th e previous EIR mun be rewritten from the ground up to m:1ke its envir;;nmen tal analj•s!s adequate. For the reasons stated in this lrtrer, a subsequ<!nl EIR or new ElR isap proprbt e.. There ls nosupµo rl to prQ("eet:I ur1tle-r CEQA'~ s<.1pplemental review pro11i~lons because t ne or!ginal eri11ironmental doc1.1ment does nol retain Information al value to tile onsoirtB decislon·making process. It is •ntv log/ca! that SANIAG start from ttie be!;irming underCEQA ~ectIon 21151 by cond1..1rl•n& ,1n init ial stull1• le detennine whl!thi:r U,i: pro~d rr.ay have substantial effects on 1he environment. Failur.-: to satisfy this CEQA obl!gation constitlJ!e> a orejudJcla1 abuse of dl.metlon, which is precisely what CEQA 5eekl t:i a11oid, and it undermine! the public'sabilltyloobt<1inahilly!nformedevalu.JtionofthC?project.

Tr.in-.portati1111 & Commtmity Development Deparfm!".nts U,.3..S F;irad a y Av1mue ' C...rl~bad, C~ 92008 •1tJ2-J39-26Utl t Amendment to the 2021 Regional Plan
Supplemental Enviro nmental Impact Report Page F.1-55
Attachment D
Appendix F.l: Response t o Comments on the Draft SEIR
RESPONSE TO COMMENT 4-1
This comment includes opening remarks and notes the importance of the approved Plan. No further response is required .

RESPONSE TO COMMENT 4-2
The basic purposes of the CEQA are to inform government decision makers and the public about poten t ial significant environment al impacts of projects, ident ify ways the impacts can be reduced or avoided, prevent significant avoidable environmental damage through alternati ves and mitigation , and disclose to the public the reason t hat decision makers approved a project t hat may result in unavoidable significant impacts. Under CEQA, a lead agency may choose to prepare a supplement t o an EIR when substantial changes are proposed that may result in new significant environmen t al effects or a substantial increase in the severity of previously identified significant effects, but only minor additions or changes w ould be necessary to make the previous EIR adequatel y apply to the project in the changed situation. Pursuant to CEOA Guidelines Section 15163, a supplement to an EIR "need contain only the information necessary to make the previous EIR adequat e for the project as revised." Section 1, Introduction, includes a brief discussion explaining why the impacts on 14 of the 19 Appendi x G resource areas would not be significant with the project modifications in the proposed Amendment. The lead agency is required to consider the information in the previous EIR as revised by the supplemental EIR, along with any othe r relevant information, in making its decisions on the project approval. SAN DAG is the lead agency for the proposed Amendment and Draft SEIR.
qry of Carlsbad Comments ai Draft Supp!ementi l Erwlronme:nral Impact Report for the proposl!d Amendment ro the 2021 Rl!gion;1I Plil:l
August 28, 2023
4-3 Plan on Oct.11, 2021. As the proposed SEIR is a supplemimt to that document and is lars:ely baS2d on I
The city previous¥ subrnilled comments on the Program Environmental Impact Report rPE:111~) fer the the information, a~m,tions and an:alysis therein (e.g., regarding laild use), rnar,1• cf lh~ comments re main valid and are repeated in lhls letter.

I
The city seiclls to en5<lre that SAN DAG. prepares .1n 1mviron.nient;i! docu.menl th~t is at.leql.lale. roruplete am tully r1:sclos6 !he potent!a l slgnrflc.int adverse erfocts of the Amended Plan. To !mpleml!nl th.e principles cfCEQA, SANDA.G should torrect previous deficiencies and nol lruncate the requisite o.,mulativl! im~ct an.iiy'\ls {CEttAGu1deiinesse r;ti1m 15l58{b)(l)), 1.15e improper baserines {CfQA A-4 Guideli11es sc-ctio11 15152), or roredo~ the consideration or any alternc1tive or m!tigatkm measure that wot1ld ordlna rny be port of CfQA review af a regrona! plan (CCOA Guldeltnes section 15Q0,1(b}(2){8)). The former EIR failed to provide liecision-makers ....ct lhl' public with al or tlloc' 1 e-lev:1nl i11fonnalio 11 rt'Jl,or"ng lhe p,oject that is rieceSSilry rOt" informed decision-making and publJc particlpation.

CEO.Aprescribe5 review procedure; .i public agency mus! follow hl!'!'Ofi" aµprrno!nior carryi111:out IITTIP(Y.ied projects. Those p1ocedures emphasize the Import1111ce of public pa!tlclpatlon lo the er.QA proce55, tncludlng mandatory cpponunities for public fe'ew and comment ..-v;j the lead .igentV's 4-5 obflg;,iti•n 10 provide meanlnf;ful respm1ses lD comments received. SANDAG failed lo comply with CEQA by conducllng the public review process for the Amended Plan arn:l tlie SEIi! separately though with some overlap, Whlch has resulted In a disconnected, piecemeal and rushed proc:E!ss ill wh.ic:h comment~ made on the Amended Pl.in were r, ■ l re~polldcd ti;i or lncorpi;iraled into the SEIR.

The, ptiblfc and affected agencies like the c!tv must 1ubmitco mment son the SEIR without knowing whether or how SAN DAG ha-. re,.ponded lo prc\tious comments on the Amended Plan. SAND AG has all'l!ady Indicated that the SANDAGBoard Is expected to review and considertheAme:nded Plan and the Final SElR on October 27, 2023. Thus, there appears lo be insufficier'lt tim e f17 SAND AG to evaluale com nll.'11ts receive d on the SEiR,. prepare meaningful responses and make those responses avallable a.s 4-0 required by CEQA Guidelines sections 15081 a'1d 1508.S. As Stich, SAND AG Is foreclosing CJ'! a "mea:iingful publlc: panicip all ot1 process" and subj~ ,tsl."!ftc a daim lid SANDAG 15 prejullicing the 01Jtcom,; of the environmental review procGs by(:nsuring Uiere ls litt!! owortunity far public comments to Influence lhe Amended Pl~n·s prog~ and design. ("Environmental re View der ives Its vitality from pubHc particip.ition~ {9ceDn Vi-ts.toles Homeown!!nA.ssn. V. Montedro Water Di~ (2004} 116 Cal. App. 4th 396, 400.j
I
If the im11:is 1ha1 Wef"P. artdrP.SSed ln lhe city's August 8, 2023comment letter on the Amended P.1.in !Att.-dimen l 1) are ncd addressed in the SEIR, the 5EIR wm be Insufficient ~s an lnfonn atlve docume ril l!ll.!. It wlll r~uce the validity and effic;.cy of the, Amended Plan, it1Cluding its use of fau!1y assumptions 4-7 rega rding land u-SP. ~11d fl('pul.al Ion i.rowUi t ■ c:umply with natc and fl:'deral mar.dates. su:h as thl! Sustainable Communities Strategy and GHG reductio n target s. Thes@ bulty ;;i,;surnptlons misrepresent the, vital land use-transportation planning ccnnectiol'IS and do nothinc to reduce, GHG and. will instpad re.suit in unpl,mned im::n;a.s.es to !r.affir, GHG, olf'IJ result in incre,11sed hou5ini: unaffordabilrty.

I
While the city supporu the milin corn:..epts of ttJI! Vision in the Region.11 P'l~n, I tie!> fli& Moves, lhel'l! 4-8 needs to be an adec,i;ile ,m.i1yii~ on how the .A1n~nUed Plan wiH be implemented, and what will or cur if lhere are changes to the projec!edgrowth, technology, and/or state law Impacting e;,:lsting coriditions.

Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-56
Appendix F.1: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-3
This comment states that many comments from the City' s October 11, 2021, letter are repeated in this letter. No further response is required.

RESPONSE TO COMMENT 4-4
This comment addresses the City's comments on the approved Plan and Final PEIR and does not pertain to the proposed Amendment or adequacy of the Draft SEIR.

The Final PEIR informed decisionmakers and the public generally of the significant environmental effects of the approved Plan, identified ways to minimize the significant effects, and described reasonable alternatives to the approved Plan (CEQA Guidelines Section 15121(a)) .

The Final PEIR properly considered cumulative impacts (CEQA Guidelines Section 15168(b)(2)), identified a baseline (CEQA Guidelines Section 15125), described a range of reasonable alternatives to the approved Plan (CEQA Guidelines Section 15126.6), and described feasible mitigation measures that would minimize significant adverse.environmental impacts (CEQA Guidelines Section 15126.4).

RESPONSE TO COMMENT 4-5
The comment mischaracterizes the CEQA requirements for review of the Draft SEIR. There is no CEQA requirement to conduct the public comment period for the Draft SEIR required by CEQA Guidelines Section 15087 simultaneously with the public comment period required by Government Code Section 65080 for the proposed Amendment . There is also no CEQA requirement for comments on the Draft SEIR to be responded t o before publishing, or incorporated into , the Draft SEIR. The Draft SEIR properly evaluates the Draft Amendment and preparation of each has run concurrently consistent wit h CEQA Guidelines Section 15004. SANDAG has evaluated Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-57
Appendix F.l: Response to Comments on the Draft SEIR
comments received on significant environmental issues and prepared written responses consistent with CEQA Guidelines Section 15088.

Responses to comments received on the Draft SEIR are included in this Appendix (Appendix F.l of this SEIR).

RESPONSE TO COMMENT 4-6
This comment mischaracterizes the process for public participation in the Draft and Final El Rs. There is no CEQA requi rement to conduct the public comment period for the Draft SEIR required by CEQA Guidelines Section 15087 simultaneously with the public comment period required by Government Code Section 65080 for the proposed Amendment. There is also no CEQA requirement for comments on the Draft Amendment to be responded to befo re publishing, or incorporated into, the Draft SEIR. The Draft SEIR properly evaluates the Draft Amendment and preparation of each has run concur rently consistent with CEQA Guidelines Section 15004. SAN DAG has evaluated comments received on significant environmental issues and prepared written responses consistent with CEQA Guidelines Section 15088. Responses to comments received on the Draft SEIR are included in this Appendix (Appendi x F.l of this SEIR), and responses to comments received on the proposed Amendment are included in Appendix F.2 of this SEIR.

Specific to public outreach conducted by SAN DAG, there have been extensive opportunities fo r meaningful public participation in the proposed Amendment and Draft SEIR. SAN DAG initiated the SEIR scoping process on December 9, 2022, through the circulation of an NOP. Receipt of the NOP by the State Clearinghouse at the California Office of Planning and Research on December 9, 2022, initiated a 30- day comment period that ended January 9, 2023. The NOP provided fo rmal notification to all fede ral, State, and local agencies involved with funding, and to other interested organizations and members of the public , that an SEIR would be prepared for the proposed Amendment . The NOP was intended to encourage interagency communication concerning the proposed Amendment and provide sufficient background information so that agencies, organizations, and individuals could respond to SAN DAG with specific comments and questions on the scope and content of this SEIR.

Amendment to the 202 1 Regional Plan
Supplemental Environmental Impact Report Page F.1-58
Appendi x F.1: Response to Comments on the Draft SEIR
The NOP is provided in full in Appendi x A-1. The written comments are provided in full in Appendi x A-2.

Consistent with CEQA (PRC Section 21083.9), SAN DAG noticed and held a public scoping meeting on December 21, 2022, at SANDAG's office at 401 B Street, San Diego, CA 92101. The purpose was to receive perspective and input from agencies, organizations , and individuals on the scope and content of the environmental information to be addressed in the Draft SEIR. To support the development of the proposed Amendment, SAN DAG implemented a public outreach and involvement program consistent with State and federal requirements . Early in the planning process, SAN DAG developed a Public Involvement Strategy (Strategy) to guide the public outreach program . The Strategy identifies public engagement techniques to involve the public and collect input for the proposed Amendment , including public meetings, social media, visualizations, and other approaches to outreach.

The Draft SEIR for the proposed Amendment was released to the public on July 13, 2023, and was available for a 47-day public review period , consistent with CEQA which requires a 45-day public revie w.

SAN DAG published a public notice for the Draft SEIR public review period in local newspapers on or about July 12, 14, 21, and 28, 2023.

SANDAG also filed a Notice of Completion (NOC) with the State Clearinghouse to indicate the availability of the Draft SEIR for public review and comment on July 13, 2013. The Draft SEIR was distributed to the agencies, organizations, and individuals that provided written comments on the NOP, the SAN DAG Board of Directors , SAN DAG member agencies, and other interested parties and st akeholders.

Agencies, organizations, and individuals were invited to provide written comments on the Draft SEIR during the public review period from July 12 to August 28, 2023.

The Draft SEIR and all appendices were available for review online at www.sandag.org, at SANDAG offices located at 401 B Street, Suite 800, San Diego, California 92101, and at the San Diego Central Library located at 330 Park Boulevard, San Diego, California 92101. The Central Library will facilitate inter-library transfers upon request by a member of the public in order to provide access at local libraries .

Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-59
Appendix F.1: Response to Comments on the Draft SEIR
On a case-by case basis, the San Diego Central Library can also digitize documents and transfer them to other libraries. There will be a further opportunity for public participation on October 13, 2023, at the SANDAG Board of Directors meeting where decision makers will consider certification of the SEIR and adoption of the proposed Amendment.

RESPONSE TO COMM ENT 4-7
The City's August 8, 2023, comment letter on the proposed Amendment addressed the approved Plan and does not pertain to the adequacy of the Draft SEIR. At the direction of the SAN DAG Board of Directors, the proposed Amendment is narrowly focused on removing the regional road usage charge while meeting state and federal requirements. The Amendment includes no changes to land use.

This comment incorrectly asserts that the previously approved Plan uses faulty land use assumptions. Government Code Section 65080{b)(2l(B) provides that an SCS "use most recent planning assumptions considering local general plans and other factors." It also requires that the SCS "set forth a forecasted development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, will reduce the greenhouse gas emissions from automobiles and light trucks to achieve, if there is a feasible way to do so, the greenhouse gas emission reduction targets approved by the state board." The SCS projects development that would achieve the State-mandated GHG emissions reduction target when integrated with the transportation investments, programs, and policies in the approved Plan, as amended.

RESPONSE TO COMM ENT 4-8
SAN DAG is typically required to update the Regional Plan every four years to account for the changes since the last Plan was adopted, including projected growth, technology and/or state law, as mentioned by the commenter. Those assumptions will be updated as needed in developing the 2025 Regional Plan.

Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-60
Appendix F.l : Response to Comments on the Draft SEIR
With respect to implementation , Appendix B, Implementation Actions, of the approved Plan as revised by Attachment A to the Amendment, Errata to the 2021 Regional Plan, provides SANDAG's strategy for implementing the proposed Amendment.

Cit)' of Carlsbo1d Comments on Draft Supplemental Environment al Imp.1ct P. eport for the proposed Amendment to the 2021. Region.ii Pl.in
,\u (lust28,2023
'.,
4-9 dari fiCiltion on land use authority . Ttis l;111gu~111: is neede d to cfailfy tr.ft !,md u;;e authority rests ,1ith I
Thctitvapprec iates SANDAG al'!d!ng language, as the cityreques1ed, that provides: additiomi l 4-11
4-12
the local 1urisdlc;i0n. Ahl'lo1igh th is princip le should be obvious, the lnconsl ste;ndes between l he Amended P!i111 and thecJty's:General Plandiscussedbelo w;;ugge;;t thaf it has beeJi ignored.

Whl!.> the prap o;;ed ilmendme/lt Is focuwd on the rl!ITTJval of the region.;! road usage charg !': from the 2021 Reg;onal Plan, th e Amended Pl;m also provides updilt&! regional employment flgure.s, revenue auumptiort5, traffic volume, , etc., aU of whicli are slsnlficant change5 and/or new Informati on o[ substan tial Importance. In addit,on, the city made th e fellowi ng sub.mint Ive tomments on t he a::iequaq1 of the Pf IP. in its Oct, 11, 2021, lett er ol'I that document These i::omments remair1 valid and hiBhlisht sie;11lflcarn concerns that s!em largely horn faulty land use assumptions contained in the PEIR and 2021 AeglonalPlan,wh!cht h.-SElRdoesnotmodJfy .

1. The PE IRiSE!R foll to disclose the Plan'; and Amended Plan's Inconsistencies wll h the Ci!rl!ibad General Ptm ilnd to ilrn.lyze the re1a1ed potM tlal environmental impact'l. The l egislature has declare.a a poITq• "to protect C.1llfarnia'~ !ancl resource, 10 ensure il'> preservation ~nd use ln ways which are economically and socl;i.l(y desirable In ;i.n ,;ntemptto ll'Tlprove the qualitv of life in c.,torni.a." (Gov. Code§ 65030.J To furt h~rth is polcy, each of the stale·~ cl1ies ao-.J counties is requin2d to adopt acomprehen§ive, lon11-1erm a:eneral plan for the physical dewelopment of that city ortounty . (Gov. Code§ 65300.) Acco1dlr.£ly. the city adopted a G,e,neral Plan in compUa11ce with staU! law and mostre cent>v updaLed it in 2015 lhe clly's: General Plan "sets forth land use ccmpatlbl!l~• poltcles applicable to ruture develnpmenl In the vicinity.•~ policies are deslin!!:d to ensure that ft.!rure land uses ln the surrounding are~ will he compal!ble with the rcatistlcatly rores.:oeableactfllltyin thedt y.

2. Growth project ions for the rei:ion .t1 e bi!!ted oo popul11tion, vehlde trend5a nd land u5e plans de11elope,cl by the cltles:arid the Counl y of S,m Diego 1~county -j as part of their gen~ral plans. Many d!Rerent re11lon.1I docume:,t; 1erv on the same lrirormation to develop water demand oroJectlons, air quality pe<f.ormance ~tandMds, ernlu ion inventnrl6, and emission reductiofl~- The Amended P!anw ould resul1 inan lncreaselnresidet1 1i.ll landuse resulting in correspondingi ncreases in Indirect and cumulative vehide mil es traveled {"VMT"), GHG emissions and air pelhrtant emissions, as well ilS Inconsistencies- wll h RAQS, SlP, a!ld regio11.tl traffic modeling. ThiswasflO l dbclcsed in the PEIR and t h Lis influences the an.2ly~is ln the S£1R.. CEQA Guidelinessec1ion l5l 2S{a) reQuires E!Rs to conl~iil a rlescrij'.>tion cf the physi::al e11vircmm~nhl conditions ill !he vicinity cf t he project, as they ex Isl ill the time the NOP- ls pubrisheli, or If no NOP is published, Bt t he time enviro nmental an<1lysis Is commence-d, fr om both a locat and regional perspective. histing i:eneral plans, inclvd ing their land Us.eF.lernent\, should have beer. utira:ed fOf this baseline /Jll.tlysisandu:rd erive fut.ure popula1ionan d housinges t irr,ates
In 1he PEIR, )A.tJDAG ; hould ha Ye ev1luated and clearly articulated ttie Plan's potentia l imp~c.l.!-on ~no' use. instead. the PEJR na1e~ t li:.r:. '"The tol"eca~ted de.11eb pment of the propo~ed P!,m iS b.iowd on the Series 14 Regional Growth Forecast SCS la!id use pattern, wh ich is, JI turn, :>ased co the adopti::d general plans ol'the cl ties and County of San Diego ~nd en !he most recent planning assumptions, considering local general pl~,u .and other racte1s, a~ requirl"d by SS 375. • Thi5 stat ement Is i11correct. Tin.Ii , the Amended Plan Is inam sisto?f)t wi.lh the city"s Get1eral Plan hecau~e it prapo;es 1esldent:al l;;nd uie~where such u~es are not auU,orized by lhe General Pliln. Th~city's Amendment to the 2021 Regional Plan
Supplemental Environmenta l Impact Report Page F.1-61
Appendi x F.l : Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-9
This comment does not pertain to the proposed Amendment or the adequacy of the Draft SEIR. At the direction of the SAN DAG Board of Directors, the proposed Amendment is narrowly focused on removing the regional road usage charge while meeting state and federal requirements. The Amendment includes no changes to land use.

The comment inaccurately suggests that the City's General Plan was ignored in developing the previously approved Plan. SAND AG relied upon local general plans and other factors to develop the forecasted development pattern for the region consistent with Government Code Section 65080(b)(2)(B). Consistency of the appro ved Plan with relevant general plans is analyzed in Section 4.11, Land Use, of the Final PEIR. Due to the programmatic nature of the EIR analysis, the Final PEIR did not call out specific policies from local jurisdictions' general plans or other local planning documents . Consistency of individual second-tier projects with these policies would be considered during project-specific CEQA reviews.

RESPONSE TO COMMENT 4-10
The basic purposes of the CEQA are to inform government decision makers and the public about potential significant environmental impacts of projects, identify ways the impacts can be reduced or avoided, prevent significant avoidable environmental damage through alternatives and mitigation , and disclose to the public the reason that decision makers approved a project that may result in unavoidable significant impacts.

Under CEQA, a lead agency may choose to prepare a supplement to an EIR when substantial changes are proposed that may result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects, but only minor additions or changes would be necessary to make the previous EIR adequately apply to the project in the changed situation. Pursuant to CEQA Guidelines Section 15163, a supplement to an EIR "need contain only the information necessary to make the previous EIR adequate for the project as revised." Section 1, Introduction, includes a brief discussion explaining why the impacts on 14 of the 19 Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-62
Appendix F.l: Response to Comments on the Draft SEIR
Appendi x G resource areas would not be significant with the project modifications in the proposed Amendment. The lead agency is required to consider the information in the previous EIR as revised by the supplemental EIR, along with any other relevant information, in making its decisions on the project approval. SAN DAG is the lead agency for the proposed Amendment and Draft SEIR.

This comment also refers to the City's comments on the approved Plan. At the direction of the SAN DAG Board, the proposed Amendment is narrowly focused on removing the regional road usage charge while meeting state and federal requirements. The Amendment includes no changes to land use.

This comment incorrectly asserts that the previously approved Plan uses faulty land use assumptions. Government Code Section 65080(b)(2)(B) provides that an SCS "use most recent planning assumptions considering local general plans and other factors ." It also requires that the SCS "set forth a forecasted development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, will reduce the greenhouse gas emissions from automobiles and light trucks to achieve, if there is a feasible way to do so, the greenhouse gas emission reduction targets approved by the state board." The SCS projects development that would achieve the State­ mandated GHG emissions reduction target when integrated with the transportation investments, programs, and policies in the approved Plan, as amended.

RESPONSE TO COMMENT 4-11
This comment refers to the City's comments on the previousl y approved Plan. At the direction of the SAN DAG Board, the proposed Amendment is narrowly focused on removing the regional road usage charge while meeting state and federal requirements. The Amendment includes no changes to land use.

Consistency of the approved Plan with relevant general plans and LCPs is analyzed in Section 4.11 of the Draft PEIR. Due to the programmatic nature of the Final PEIR analysis, the Final PEIR does not call out specific policies from local jurisdictions ' general plans, Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-63
Appendix F.l: Response to Comments on the Draft SEIR
LCPs, or other local planning documents . Consistency of individual second-tier projects with these policies would be considered during project-specific CEQA reviews.

Government Code Section 65080{b)(2)(B) provides that an SCS "use most recent planning assumptions considering local general plans and other factors ." It also requires that the SCS "set forth a forecasted development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, will reduce the greenhouse gas emissions from automobiles and light trucks to achieve, if there is a feasible way to do so, the greenhouse gas emission reduction targets approved by the state board." The SCS projects development that would achieve the State­ mandated GHG emissions reduction target when integrated with the transportation investments, programs, and policies in the approved Plan, as amended.

RESPONSE TO COMM ENT 4-12
This comment inaccurately asserts that the Draft SEIR does not disclose analysis of VMT, GHG and air pollutant emissions, and inconsistencies with RAQs, SIP, and regional traffic modeling. The Draft SEIR evaluates each and the relevant identified impacts in Sections 4.1 (Air Quality) , 4.3 (Greenhouse Gas Emissions), and 4.5 (Transportation), as well as Chapter 5 (Cumulative Impact Analysis), among others.

This comment also refers to the City's comments on the approved Plan. At the direction of the SAN DAG Board of Directors, the proposed Amendment is narrowly focused on removing the regional road usage charge while meeting state and federal requirements. The Amendment includes no changes to land use.

The comment inaccurately suggests that the City's General Plan has been ignored in the previously approved Plan. SANDAG relied upon local general plans and other factors to develop the forecasted development pattern for the region consistent with Government Code Section 65080(b)(2)(B). The thresholds for land use analysis in Appendix G of the CEQA Guidelines include an evaluation of whether the project causes a significant environmental impact due to a conflict with a land use plan, policy, or regulation adopted for the purpose of Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-64
Appendix F.l : Response to Comments on the Draft SEIR
avoiding or mitigating an environmental effect . A conflict alone does not necessarily result in a significant environmental impact. As stated above, consistency of the approved Plan with relevant general plans is analyzed in Section 4.11 of the Final PEIR. Due to the programmatic nature of the EIR analysis, the Final PEIR does not call out specific policies from local jurisdictions' general plans or other local planning documents. Consistency of individual second-tier projects with these policies would be considered during subsequent project-specific CEQA reviews.

City of C'.arhbad Comments on Drah Sllj)pl!!ml!lltal fn,..ironrrumtal Impact Repo;t for tN! propost>d Amendment to !he 2021 Reg~I Plan
A11g.11sl 28, 2023
, , 4
4-12 I comrne11lson Lhe ?EIR indlcaredttat ir appe.ared to ignore I his inconslstencyi ncoocludfng there cont would be leu t han significant Impacts far lhe ye;us ZOZS. 203-5 or 20S0 4-13
The city has two mobllily hubs in lhe Plan artd PEIR; McCleUa.n-Paloma:r Airport, the fl~h \;,ug1m employmt<nl tenter in U•.e regio11; and Carlsbad Stat~ Beach •md Catlsbad Village ;is ,;-ie r 3 and Tier 4~ employment. centers. Th! city's Aug. 6, 2021commen lsuu lhl' PEIR Included an attachment that showed a wmma rv af lhe Mobility Hubs and housifl@ units assumed in thl!Se ries l <1 Growth Forecast for the vear 2050. The assurnptlon! in the iJp::lated series 14 Growth Foreu sl contain incor.sistendes v.1th !"eSpl!Ct to al lean three lacalio ns ir, WtiichdertSity is5hov.m to be lnconsistent with the city's Gene""al Plan, the Ai1pnr1 llllrd Use CompatlbllitY Plan and good planning prlnc'iple-$.

Thesethreeprobleni.11!c,ire;u:!!'e:
a. 7 36 lll'llts on parcels lmmedlate.ly adjacootto th! McC!ellan•Pill•niar A.ir,ort runwil\'· The location of the alrpoitwithin this mob/Ill y hub was shtlff!d with SAND AG staff multiple times at workshops. Thili is inconsistent with tl1e regUl;itlons pro'Jlded by the San •\ego Ct>\!rty Refiorial Airport Authority and ccrrlli.ro with sti!ndard planning principles fOf siting housing away from h;nards;
b. Z,755 units on e.ldstirig ftvcl opell resort properties and open space ciedh:ate.d tarods adjacentlolegoland;a nd
c. 6Suniti !n a pr-5eNetl open spa::e affia.

Since lt does r,ot ch;inge the.Flan's land use assumplioros, !he Amended f>l.an contfnuesi o propose resldentlal uses in areas wh,ch arr ool design.stet! for such uses In the city's Ger\el'al Plan and U1e McClell,rn-Palomar Aifport l and Use CompatlbiUtY Plan, as di!.cussed belilw, This inco~ls tency' resulb In potel"lti.if sl11nificant imp.acts with ~ -:• l o land 1-Ge, public safety 2r1d noise, (See CEO.A Guidelil'\e~, Appel'\di11 G, §§ U(te), Xl/b), Xlll(c}.) Because re;fde nlial 1.151! is not illlllthorized in 1h~ loc.ations in the city's General l'larl, the Amended Pl:an's nwmp tion that reside11tial use wiU occur there reSl.ilts in an overstatement of the extent to which other imp!lcb, such u those :usociated with Vlv1T, GHG and 0U1er'pol!uti!llt emiuiora, wfll be redlced and tinder.states tho~'! poten tial impact5 of the Ameni::led Plan. lf lhe S~li\ d•es not meaningfully .-iddres5 the Jn,onslslenc~ with th! genera! plans of all member jurisdictiC!f't5, which If not implementing this- plan wlll c;iuse a signifitant envlranraenu t impac::t i.Jue to the conflict with illrty Ulncl use plan, poli,y or regulalion.adopled tor the purpose of a,.,oidins or mitig attns: an environmenta!df.ect.

Multip le areas Ir, carlsbad we contro!led as to thei r l£e .:ind activity density ;rid !11tenslty through tile tr spatial assor.:ialion with I.he M::C!e!lan·?i!lorrrar Airport, and some of these areas resltic l resid~ tia! use. The McCler.an-Palomar Airport is defined by the Feder;il Avfdtion AdmlrJlstr.atlon ("'f"AA ") as a commercial s!!Nic e .Jirpnrt that. in ~dili ori to prl\•a~e alrmh, has regularly sched1Jled commercial flights. Further tlel ail orithiswas indu dedi n the city's AIJjl;ust 6, 2021, r:omment Jetter on l tle drafl Pl.in, part ofAtta chment.1 l o thi s li!mer.

Tl!bJe 4.5-1 indicatES chanees h demarod for aJ mode, of traY!lfrom lhe app,ov11d iJlari lo lhe Amended Plan under lOZS condltlons. Gi'len that tre SElR ~te:s that tht> roathv.>'f user charge would not be lmplerntmted IMttil yw;r 2rtl5 ruHitlon; please explain why the.-~ would be ariv chan,gesur,di!rthe.lOZSsccnari o.

I
4 tu l!'Kpr es.sed in commerits on the EIR, the andfySis melhodo!oe:Y used for the Transportat ion chapte; 4-15 • does net prGl'ide a descriplion ofh:lwthe ABM2t arlil!ysis outpUts su:h asAvera~c. Daily Trips Amendment to the 2021 Regional Plan
Supplemental Environmental Imp act Report
PageF .1-65
Appendix F.l : Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-13
This comment refers to the City's comments on the appro ved Plan. At the direction of the SAN DAG Board of Directors, the proposed Amendment is narrowly focused on removing the regional road usage charge while meeting state and federal requirements. The Amendment includes no changes to land use.

Government Code Section 65080(b)(2)(B) provides that an SCS "use most recent planning assumptions considering local general plans and ot her factors ." It also requires that the SCS "set forth a forecasted development pattern for the region, which, when integrated wit h the transportation network and othe r transportation measures and policies, will reduce the GHG Emissions from automobiles and light trucks to achieve, if the re is a feasible way to do so, the greenhouse gas emission reduction targets approved by the state board." The SCS projects development that would achieve the State-mandated GHG emissions reduction target when integrated with the transportat ion investments , programs, and policies in the appro ved Plan, as amended.

This comment mischaracterizes the impact of the land use assumptions underl ying the previously approved Plan on the VMT, GHG, and air quality resource analyses included i'1 the Final PEIR. The approved Plan focuses growth and development in the Mobility Hub areas. The allocation of housing units to subregional areas represents general areas projected for fut ure growth, not specific parcels, for future housing development or housing unit type. Specifically, outputs are generated at the Master Geographic Reference Area (MGRA)-level for use as inputs to SANDAG's Activity Based Model (ABM). MGRAs are comparable in size to census blocks and cover the entire region. A number of land uses at the parcel level, aggregated up, comprise these general areas and VMT, GHG, and air quality impacts are analyzed at the regional level consistent with t he programmatic nature of the Final PEIR.

For Carlsbad, the SCS land use pattern forecasts 6,575 housing units from 2016 to 2050, w hich is within the total housing unit capacity of the City's general plan as provided to SAN DAG (6,992 housing unit s) and accommodates the City's RH NA allocation of 3,873 housing units Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-66
Appendix F.1: Response to Comments on the Draft SEIR
by 2035. The precise zoning at the parcel level is within local ju risdictions' land use authority. As such, future development projects would undergo separate, project-specific environmental review, and any impacts associated with conflicts with land use plans, policies or regulations, including the general plan and any applicable airport land use compatibility plans, would be evaluated and mitigated when the timing, location, and other specifications of a specific project have been defined.

RESPONSE TO COMMENT 4-14
In 2022, anomalous traffic counts and employment at some large employment location sites and Traffic Analysis Zones (TAZs) were identified and corrected, and the Series 14 Regional Growth Forecast was updated to incorporate these corrections. The corrected inputs resulted in slight changes to regional employment figures and more concentrated employment across a handful of sectors at a limited number of employment locations; previously employment had been more dispersed across the region. These corrections resulted in a regional vehicle miles traveled (VMT) increase.

ABM 2+ model runs for the Amendment also reflect corrections made to one of the special market models included in ABM2+, the crossborder model. The crossborder model measures the impact of Mexican resident travel on the San Diego transportation network. In 2022, a software bug was discovered in the crossborder model that affected the number of crossings via Otay Mesa East and resulting traffic volumes on SR 11. The software bug was fixed, improving the accuracy of t raffic volumes on SR 11. The fix had minor impacts on regional VMT.

RESPONSE TO COMM ENT 4-15
For additional information about modeling procedures, please see Appendix S, Travel Demand Modeling Tools, of the approved Plan and Attachment B, Air Quality Planning and Transportation Conformity , of the proposed Amendment. A detailed description of the background, data sources, methodologies, and outputs associated with ABM2+ can also be found at https://github .com/SANDAG/ABM/wiki.
;;~: I
City af Cartsbad UJmme/lt': on Dutt SupplEme.nlal Environrmental Impact Repon: f or the proposed Amornlment to the 20Zl Reg!ona! Plan
August2B,2023
Pa1e5
(A.OT), Mode Sh..re, J!'ll Ve hid~ Miles Traveled {VMT) are calculated !or each ol the uave! mode~ Without this info rmation, it ls difficult to understand how ll'let ra11sp1;1rtatlon network Improvements /mpacr the~e analys!• metrics for futureye4r conditions and for comlderatlan ofpotenti11! proJ«t mitigations, The document link provided In response to this prior comment ln the foot;.ote with descriptions of the ASMl .. model output$. is not currentl1• active 1 5 TheSEIR should ev11\ltte the lrr,pact of the reduction in tot.i i funding rcsulling from the removal of • 1he road usage charge. This-1.'valualion !i:hould encompass the Regkmacl Plan's reduced Cilpacity to 4-16 exe.:ute projects, including but not timlt cdto additional roadw;iys, transit ~ys1cms, and ~ctive tnmsportation. furthermore. the anc11v.sis-5hould address haw1hc curt.Jflmcnt of projects could !nfluc nc::ebroadershift:s in tr.tvel madets, vehide milestra11eleC {VMT), and re suiting GHG E:missions.

6. Thi'! altemallves analnis"d= oot desxribe a rang I! of reasonable alternatives to the JNO.Jf:ct because it does not (nelude an ana\ysh of an alternativ e thilt evaluates whlll wiU o~ur if the faulty land use, and therefore tr;i,nsportation, auumptlons do nol occur . The alternatives are constnJcted l11rgely to reduce impacts through even more focused growth in Mobility Hubs and through increased value pricing and reYl!flue ~ ner.!ltion. Wh~e it l'Tll!Y be true: tt.,,..le 'IYOUld r!:'duce impacts, it does not provide policy rnakeu or members or the publlc a reasonableranj;e of alternatives a~ required by CEQA. Addit ionally, due to SB 9, wtiith beCMne effective Jan. l , 2022, the reduction in popul11tio11 a5sumed iri iuburban areas outside of the mobility hubs L!; both inconsistent with reality ood with planning principles required by the l:.l!itomia Departmeol of Housing and Community DeYe.loprnen! tonottoncen\ rcteallfuturegrowthinc.e t tainlocatlons .

CfQ A and the CEQA Guideiin es r e11 uire that an Elfl. describe al! re:1som1ble alternativ2s to the ~oject ,rnd any feasible mitigation meil~u,u (la11rtl l~ighcs lmprovementAr sn. v, Reoents J/Universityof C.Glijarnla (1988) 47 Cal. 3d 40D, 404J. Because the SEIR c:loes notdisc.us.sfulure lar"!d LM conflicts with applicable general plans (as well as other::ity land use document~. sc1ch as tht Lo~l Coastal Program, Habitat Management Pilln and Mca~Jan-Pa lomar Airport Ulnd Use Compatibility Plan), it f,1iils to disdose Wi \'l to reduce or elimin ate the en11ironmental impacts tif the proje-ct and to respond to the majorenvironmen t.il issu~ identified during the planning process /a > a project altema li ve or as ii mitQ;ation measure] pursuant to Public Re;ourc~ Code section 21002 (see Friencb oft he Old i n= v. Deportment of Forestry& Fire Protection (1937) 52 C:il. App. 4U1 1383).

The SEIR's ~m,lys\~ of the project alternatives andm it~at ion me.;sures is incomplete and, therefore, inadequate.

Section 15-116 of the CTQA Guidelines r CQuires that all a~pects of a proj ect must be considered wherr ev;i.lu.,ting its impact on the enviro nment, Including planni11g, acquisition, deYelopmeot, and operation. The implementation and challenges to fund the Amemlf'd Plan have not been appropri.itely disOJssed. One of the project altunatives 5hou!d accommodate t r.rnsportation investments t hat can be re:a5onablvfunded w ithfn ttie horilon of the plan under the curref\l /~knownff) funding mechanisms. Bec:iuse !he SEfR does not ::liscuss a financlallv const rained alle:-native, the analvsU of t he project.iltc rn~tive~ and mitital lon measures 1$ incomplete , and therefore,in ac:lequ<1te.

Amendment to the 2021 Regional Plan
Supplement al Environm ental Impact Report Page F.1•67
Appendix F .1: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-16
The regional road usage charge was not intended to be implemented until 2030, and as such was only a revenue source for the final 20 years of the approved Plan.

Updated revenue assumptions for the Amendment provide sufficient revenues to fund the projects in the appro ved Plan, including historic levels of infrastructure investment from the federal and state government resulting from the Infrastructu re Investment and Jobs Act (IIJA, also known as the Bipartisan Infrastructure Law).

RESPONSE TO COMMENT 4-17
CEQA requires the consideration of alternatives t o the propo sed Amendment and the analysis of impacts associated with tho se alternatives . By comparing the proposed Amendment to the alternati ves, the advantages of each can be weighed and analyzed.

Section 15126.6 of the CEQA Guidelines requires that an EIR "describe a range of reasonable alternatives to the project, or to the location of • the project , which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparati ve merits of the alternat ives." An EIR must discuss alternatives to a project in its entirety and is not required to discuss alternati ves to each particular componen t of a project. Also, an EIR need not evaluate in detail alternatives that would not substantially lessen the proposed project's significant environmental impacts. Finally, CEQA Guidelines Section 15126.6 specifically states that "[a]n EIR need not consider every conceivable alternati ve to a project ."
This comment also inaccurately characterizes the discussion in Laurel Heights Improvement Assn. v. Regents of University of Californi a (1988} 47 Cal. 3d 376. The Court does not st ate that CEQA requires an EIR to describe all reasonable alternatives to the project. Rather, the Court in Laurel Heights stated that " [a]n El R's discussion of alt ernatives must contain analysis sufficient to allow informed decision making" (Laurel Heights Improvement Assn. v. Regents of University of California /1988) 47 Cal. 3d 376, 404). As mentioned Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-68
Appendix F.1: Response to Comments on the Draft SEIR
above, CEQA Guidelines Section 15126.6 specifically states that "[a]n EIR need not consider every conceivable alternative to a project." The Draft SEIR Alternatives were developed as alternate means of achieving most of the basic project objectives for the Final PEIR.

Those objectives are found in Chapter 2, Project Description, of the Final PEIR.

The proposed Amendment has the additional objective of removing the regional road usage charge while continuing to meet State and federal planning requirements, regional GHG reduction targets, and federal air quality conformity standards . As discussed in Chapter 6, Alternatives Analysis, of the Draft SEIR, five alternatives were considered in detail:

Alternative 1: No Project (the approved Plan). The No Project Alternative assumes that all of the plans and policies included in the approved Plan would be implemented, including the regional road usage charge, and is further described in Chapter 2, Project Description, of the approved Plan Final PEIR.

Alternative 2: 2019 Transportation Network With New Value Pricing and User Fee Policies. Alternative 2 is the same as described in Chapter 6, Alternatives Analysis, of the approved Plan Final PEIR.

Alternative 3: All Growth In Mobility Hubs and More Progressive Value Pricing And User Fee Policies. Alternative 3 is the same as described in Chapter 6 of the approved Plan Final PEIR.

Alternative 4: Progressive Pricing and No Regional Road Usage Charge. Alternative 4 consists of the approved Plan transportation network and land use pattern included in the SCS, with more progressive toll pricing and parking costs. Alternative 4 does not include the regional road usage charge.

Alternative 5: All Growth In Mobility Hubs, Progressive Pricing, and No Regional Road Usage Charge. Alternative 5 consists of the approved Plan transportation network , a land use pattern focusing all regional growth in mobility hubs, with more progressive toll pricing and parking costs. Alternative 5 does not include a regional road usage charge.

Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-69
Appendix F.1: Response to Comments on the Draft SEIR
This comment also restates the City's comments on the approved Plan. At the direction of the SANDAG Board of Directors, the proposed Amendment is narrowly focused on removing the regional road usage charge while meeting state and federal requirements. The Amendment includes no changes to land use.

This comment incorrectly asserts that the Final PEIR uses faulty land use assumptions. Government Code Section 65080(b)(2)(B) provides that an SCS "use most recent planning assumptions considering local general plans and other factors." It also requires that the SCS "set forth a forecasted development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, will reduce the greenhouse gas emissions from automobiles and light trucks to achieve, if there is a feasible way to do so, the greenhouse gas emission reduction targets approved by the state board." The SCS projects development that would achieve the State-mandated GHG emissions reduction target when integrated with the transportation investments, programs, and policies in the approved Plan, as amended .

With respect to SB 9, which took effect on January 1, 2022, the Series 14 Regional Growth Forecast incorporates assumptions about ADUs occurring in the local jurisdictions as potential future capacity for housing unit development. ADUs were assumed to be available on 5 percent of all single-family lots in the region that were 5,000 square feet or larger. This equates to about 20,000 additional units of housing unit capacity throughout the region outside of the rural villages in the unincorporated area. The Series 15 Regional Growth Forecast is currently being developed in coordination with local jurisdictions and may include updated assumptions surrounding ADU development.

Consistency of the approved Plan with relevant general plans is analyzed in Section 4.11 of the Final PEIR. Due to the programmatic nature of the PEIR analysis, the Final PEIR does not call out specific policies from local jurisdictions' general plans or other local planning documents. Consistency of individual second-tier projects with these policies would be considered during subsequent project-specific CEQA reviews.

Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-70
Appendix F.l: Response to Comments on the Draft SEIR
RESPONSE TO COMM ENT 4-18
This comment mischaracterizes the requirements for a financially constrained RTP and inaccurately states that the imp lementation and challenges to fund the proposed Amendment have not been appropriately discussed. Federal and State laws require SAN DAG to develop a regional plan built on reasonable assumptions of the revenues that will be available during the period covered by that plan (Government Code Section 65080(bl(4) ; 23 CFR 450.322(fl(10l(ii)) .

New funding sources are revenues that do not currently exist or that may require additional steps before the MPO or transit agency can commit such funding to a transportation project. (2017 RTP Guidelines for MPOs). Strategies for ensuring their availability must be identified and future revenues may be projected based on historical trends, including consideration of past legislative or executive actions (2017 RTP Guidelines for M POs). The level of uncertainty in projects based on historical t rends is generally greatest for revenues in the "outer years" (10 years or more) of an RTP.

Appendix Vof the approved Plan as revised by Attachment A to the Amendment, Errata to the 2021 Regional Plan, explains the anticipated revenues to fund implementation of the proposed Amendment . Table V.3 as revised by Attachment A to the Amendment describes the availability assumptions for new revenue sources identified in Appendix V.

As explained in Response to Comment 4 -19, the Draft SEIR does evaluate a reasonable range of alternatives that achieve most of the basic project objectives and that are potent ially feasible. 4-19
4-21
Cily ofQi rbb,1d Comments<1n Draft Suppl!mlentat r n11ironmental Impact Report for the pr•posed .Amendment to the 202l Regional Plan
ALJ (:Ust28, 20B
- -~·- - -------- - --- ----
h addition 10 the cornmenl:!i .:ibovc, SEIR Alternatl-.,e 3, the same ;u- described In Chapter 5 of the appn:,ved Plan PEIR, lnclude.s ~ road usage charge, l:cllowing ador llon of the appro11 ed Plan, the SAN DAG Board dlrect!:d staff to prepai·e a focused ;3.'llendment to the approv!d Plan that deletes the reg1onal road usaee ch.rge. SEIR. Sett loo 2.3, Pro Jett Obj! ctives, roles, "'t~ proposed Ainendment [to t he 2021 ~gio naJ Plan] hu th!! additlonal olrjf!Cl,ve of removing the regional road usage charge whlle tontinulnc t o meet State and fe<Jcral planning requirements, regional GHG reduction largels, and federal air quality conformity srandards. • As 5€:cticm 6 states, Sect ion 1512fi.6' or the CEQI\ Guideli~ requires that an ClR "describe a range of reasonable altemati\.es \.D lhe project. . .wh!ch would feasibly att.i! n mosr ofthe basit objectiv~ ofl he proj!!ct .. " Alternative 3's Inclusion of the road usaged>.1fJ:ec•nflictswitf1 the foncla.m~t;iJ ruion fOftheAme nded Plan,. This altemative should be replaced or modlf,ed to exclude t he road us€rcha ti;:e.

7. The atternatlves analysis also doas not ntisfy federal requiremenu. Federal legl.sl2tion require1th ~1 lhe Plan include a tinanclal!y constrained scenario (2J USC l3'1(h]{2)(6)). "Finar,6alty conslrained"' means that the fl:TP on!y inc.ludes pro}ects that lhe regiun can afford to complete with e)drtinf re"enue.s. or with reve.,iucs that o1re reasonably upecte d to be av affable. Th!' RTP must coru.ider nol oo!y \he cost of ellpanding the 1ransportat!on system to meet future demand, but also the cost of mainta!rilng the Hist ing system. Costs must nc.l ex,:;eed ~kely reve11ues. To date, there has been no such evatu;i\!on in the allem ilti-Jes section. Al&.ouah th ere IJi no mandate t o include p,-oject .illern.rtives In a Supplemental ElR, Ifie SEI!\ must inc!11de financially constrained scer.;r,rlo·to fulflD the fed er.ii requirement that thl.' Amerided !'I.in be flnanciat111 coortraf ned ~., ., budgeted). The removal or the road kJSiJ!l.e charge from the nt?Wcrk has been replaced w;th sptculative financirig op(lons. ilather, SANO AG must estimate rev,n ue; that are r~o nably eipected to be avallable ftGTl known feder;;I, state, local, ar.d private resoutc!!s tor lransportatlon f undfr1g to lm~lement the proposed µ,·oje.c!S.

Project/nil revenues aod P.rpeniillures over UU lenffl h oh planning period wl l be d:ffi rul.t. T~ analysis should rely partly on hirtarl ca\ funding patt erns from state .nd teaefil i source~~ aCditlon. the year of expenditure must be considered when estimates 101 c.ipital projects are developed {this Is required bytfie Federil.lSk.!rf;ice Tran~portali on Act).

8. Where reglorial planning proc,es.se5 ~ve rd ri!sulled in lhe adoption of plil.ns or resutatiotlS reining to the e11 vironmenr, CEQA requir~ public agencfe,s t o engage In an anztvsis afthe imp aces of1he p,oposed project on lhe t:!nvircom~nt, (Publk Resources Code §§ 21000; 21007..J; 21003.l (b):
21080(d); 21081; l108Z.2(a).) Although there 15, a gel'lera1 anal'fs!s of projected growth in the region, there!s it Lick of detail witt, re:.pect to gro·,,,.....h inducement orrea sonably-fo,-eseeable future projer.ls Implementing Public Resources Code section 211~5-21 155.4 (CEQA streamlining for SCS corisistency) and/or other reasonablv fOll'.seeolJll• de11elQpmen t that may rewlt. The provisl:inot Improvement of1ransportation inrrastructure. ut!litles, water and sewer service le an arP..1 Cilll iriduce growt h by removing Impediments to developmer,t. ence ,;ervices are c11 ler,ded or improved in an area., economic incenti11es fordeve lopml'.nl e•i51. The basic e1'!11lents and pr!ncip!es of the Amended Plan h.ive bl'c n ~<:Signe.ti to facilltate. future smart grC1.,th and c~ncentrate population growt h in i:reas thilt would~ effici ently set\/ed by transpQrl11liori fad!iUe5. The smart growth concept ii the ba..<is for the framework forprior iliti11g public land use aru:I transportiltlon inve!;tnHml s in the recion. The smart growth concept ldmtif ies areas where !.mart growth development exists or could b! bk.littand pr ovides ;i basis fllf p!annin&: tri'll1sportation fac.intle~al'!d Amendm ent to the 2021 Regional Plan
Supplemental Environment al Impact Report
Page F.1·71
Appendix F.1: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-19
The basic purposes of the CEOA are to inform government decision makers and the public about potential significant environmental impacts of projects , identify ways the impacts can be reduced or avoided, prevent significant avoidable environmental damage through alternatives and mitigation, and disclose t o the public the reason that decision makers approved a project that may result in unavoidable significant impacts.

CEOA requires the consideration of alternati ves to the proposed Amendment and the analysis of impacts associated with those alternatives . By comparing the proposed Amendment t o the alternatives, the advantages of each can be weighed and analyzed.

Section 15126.6 of t he CEOA Guidelines requires that an EIR "describe a range of reasonable alternatives to the project, or to the location of the project , w hich would feasibly attain most of the basic objectives of the project but would avoid or substantiall y lessen any of the significant effects of the project and evaluate the comparati ve merits of the alternatives ."
Five alternati ves were analyzed in the Draft SEIR, including the No Project Alternative , to afford decision makers with information about the potential environmental impacts of the proposed Amendment .

The SEIR carried forw ard t wo of the alternatives analyzed in the Final PEIR, as well as analyzing the No Project Alternative and two new alternative s based on the additional objective of the proposed Amendment to remove the regional road usage charge.

RESPONSE TO COMMENT 4-20
The regional road usage charge was not intended to be implemented until 2030, and as such was only a revenue source for the final 20 years of t he approved Plan. Updated revenue assumption s for the Amendment provide sufficient revenues to fund the projects in the approved Plan, including historic levels of infrastructu re investment from the federal and state government resulting from the Amen dment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-72
Appendix F.l : Response to Comments on the Draft SEIR
Infrastructure Investment and Jobs Act (IIJA, also known as the Bipartisan Infrastructure Law).

This comment also mischaracterizes the requirements for a financially constrained RTP and inaccurately states that the implementation and challenges to fund the proposed Amendment have not been appropriately discussed. Federal and State laws require SAN DAG to develop a regional plan built on reasonable assumptions of the revenues that will be available during the period covered by that plan (Government Code Section 65080(b)(4); 23 CFR 450.322(f)(lO)(ii)) .

New funding sources are revenues that do not currently exist or that may require additional steps before the MPO or transit agency can commit such funding to transportation project (2017 RTP Guidelines for MPOs). Strategies for ensuring their availability must be identified and future revenues may be projected based on historical trends, including consideration of past legislative or executive actions (2017 RTP Guidelines for MPOs). The level of uncertainty in projects based on historical trends is generally greatest for revenues in the "outer years" (10 years or more) of an RTP. Appendix V of the approved Plan, as revised by Attachment 1 to the proposed Amendment, explains the anticipated revenues to fund implementation of the proposed Amendment . Table V.3 in the approved Plan, as revised by Attachment 1 of the proposed Amendment, describes the availability assumptions for new revenue sources identified in Appendix V.

IIJA authorized $1.2 trillion for transportation and infrastructure spending with $550 billion of that figure going toward "new " investments and programs. The federal and state discretionary programs near-term estimates have been updated accordingly to assume historkal leveraging rates of local TransNet revenue.

The total estimate of near-term State and Federal Discretionary Programs resulting from IIJA is $6.35 billion .

In Fiscal Years 2021-2023 since t he passage of IIJA, SANDAG has· already received $1.6 billion in discretiona ry funding revenue ($876 million in state funding and $766 million in federal funding) compared to the Amendment's assumed $950 million in discretionary funding revenue ($507 million in state funding and $441 million in federal funding) .

Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-73
Appendi x F.1: Response to Comments on the Draft SEIR
As explained in Response to Comment 4-19, the Draft SEIR does evaluate a reasonable range of alternatives that achieve most of the basic project objectives and that are potentially feasible .

RESPONSE TO COMMENT 4-21
This comment restates the City's comments on the approved Plan. At the direction of the SANDAG Board, the proposed Amendment is narrowly focused on removing the regional road usage charge while meeting state and federal requirements . The Amendment includes no changes to land use.

For the approved Plan, population and growth impacts are analyzed in Section 4.14 of the Final PEIR. As stated on pages 4.14-16 and 4.14-17:
"the regional growth and land use change forecasted in the proposed Plan would be implemented by local jurisdictions through local plans and individual development projects, and most transportation networ k improvements would be impleme nted by transportation project sponsors other than SAN DAG. The approved Plan was developed to accommodate forecasted regional growth and failing to do so would be inconsistent with the federal and State requirements for RTPs. In addition, precluding growth would conflict with the requirements to provide sufficient housing for the region's population contained in SB 375. As discussed in Section 4.14.2, Government Code Section 65080(b)(2}(B)(ii) requires that the RTP/SCS must house all the population of the region, including all economic segments of the population, over the course of the planning period of the regional transportation plan."
This comment also addresses future transit priority projects . As described above, future development projects would be
implemented by local jurisdictions. CEQA Guidelines Sections 21155 through 21155.4 identify CEQA streamlining provisions for transit priority projects that are consistent with an MPO's SCS that has been accepted by CARB. Figures D.8 and D.9 in Appendix D of the approved Plan identify potential areas for transit priority projects . The approved Plan is an iterative planning document that is typically updated every four years to account for new data, analysis, policy, and experience. SAN DAG looks forward to coordinating with the City on future Plan updates.
4-2'
conl.
4-2.2
Gt1• of Carlsbad C.>mments on Draft Sl.lpplemerm1I En~ironmenlal Impact P.cport for the prupc~ed Amendmenttothe212.l ReglcnalPlan
t..ugust2S, l0l3
Pae7
transit servic!!li ln the AmeudeU Pla11. Smart ,::ro111th areas id:ntified recei~ prloritlted ll'lfrastnJc.ture investments and transit :services to support sman srowtti T/l\s carries true lo tho~e sman grom.h all:'a$Lh;itare;iccommo:fatedbyei.:istinggen l!!ra)plans,andforolherareasth1tarenotco,,er l!dby u lsting general plans. CEQA ,cquires that an [Ill. dls.:uss the way.s. in which the proposed project ccwld foster economic or population growth or the construction of additional housine, either dire-ctly ur indirl'tl ly, i u the environment surrnuni:!ing the project. CEQA requires this dlKU5slon lo lnclw:le w.iys in which :i project would ,eroo11P ntm:.icle!i to popu~tlon 11rowth or encourage and facilitate other ac:th1ities tnat could significan1il' affect the e1winmment (Cf QA Guideline~ 5ec:tion l5126.2{dH . The level of detall ihould reflecrthe levelcom;;lned in the plan or plan element :>eing con5idered !Ria VirtG Form &,r~cm Ci'r1tt>r v. CG:mty •f Solano (1992) 5 Cal.ApJJ.~th 351), lnc.11;.s!Ve of newsraartgrow1hareas i!sdesienated.

Oty rtatt looks forwa1d to 111ori.1r1~ wrtt, SA.NllAG on impro~ing mobTilt,,· and land use access In the ~ gion ar.d building H1stalnable, equ!table and he<!lttiy modes ::if transportation. We apprcdate the opportunity to rnrnrmmt on the r1mP.nd~d l"J;m that will help the region reall?e these soa!s. While at the same time!, dty staff aim looiuiorward to helpi~ ~rmAG ;id~;mce a legallv adequate enwironmental document to suppart the disclosuri! and decis!on-makins 11rocess. Since the major premise otCEQA. i~ th JI rt ·tie interpreted 1n such manmiras 1::i afford 1he ful.lt!11 possible protection ta the environment within the reasonable scope of lhe stat\Jtory !;mguag::" (Frientis of Mammoth~- Baord of 5upervlsor5. supra, 2d7,

2.59), SANDAG should ta~! allactlcn necessary to alert the decision-makers.ind the publi( to thi!' emirumnenl.li ch,mges .1SSoci•relll with the project (Cauntr of lnro v. Yorty (1973) 32 Cat. A:;ip. 3d 795.

LUO). There Js no shortwt lo CfQA- lhe EIP. process protects not only the emrironment !Jul also iniorme,d self-govemment iLo!!rel Helgnt5 lmpra11!men1 Ann. \I. Regl!'nts of Unillt!rsizy of Ca/ifomiv, supra, 376, 392) Th~SANDAG S.an:I tnust certifyttiat the flnalSE!R has been completed In compliance wlthCEQA and that It considered all of !he intorma1ion in the final SEIR before approving or dis,111pmvlng the prnject. As of this writing, the SEI;\ Is not In complli!nce with C[QA.

II you have any questlc~ rela;:ed to comments on tne transportation netwolil;, pli-;;se conlid:T Tom Fr.ink, Tr;in~portct ion Direcror/Citv Englrieer, at [email protected] or, if you need addillonat ir.iormation related to comrncnt:5 an the land use assu1llptions, p\ea.5!= contact fric Lard~, City Planner, atEr fc.Lardy/5'.lcar!sbadca.go11,
Sinceretv,
j(jflS «,11#-&Sfll;,IV~,,.,,.

JEFF MURPHY
ConimunityDt!Veloprne11tOirect □ r

TOM FRANK
Tranoi,ortatlonDlrector/Cltytng:n~r
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-74
Appendix F.1: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-22
SANDAG has fully complied with the requirements of CEQA in the preparation of the Draft and Final SE I Rs for the proposed Amendment Regarding disclosure of the proposed Amendment's physical impacts on the environment in the
Draft and Final SE!Rs, SANDAG has disclosed impacts and identified mitigation measures for impacts on air quality; energy; GHG; noise and vibration; transportation; and
cumulative impacts, and has identified alternatives to the proposed Amendment consistent with CEQA, the CEQA
Guidelines, and the discussion in Friends of Mammoth v.

Board of Supervisors (1972) 8 Cal.3d 247 referenced in the comment For clarity with respect to the cited discussion in County of Inyo v. Yorty (1973) 32 Cal.App. 3d 795, the court states that an EIR is an "environmental 'alarm bell' whose purpose it is to alert the public and its responsible officials to environmental changes before they have reached
ecological points ofno return" ( County of Inyo v. Yort;y, p. 810). The court also cites an earlier version of PRC Section 21000, which states that the government of the state should "take all action necessary to protect, rehabilitate, and enhance the environmental quality of the state" ( County of Inyo v. Yorty, p. 802).

The court in County of Inyo v. Yorty does not state that lead agencies "should take all action necessary to alert decision-makers and the public to the environmental changes associated with the project ," contrary to the comment's assertion.

Prior to consideration and certification of the Final SEIR, and consistent with the discussion in Laurel Heights Improvement Assn. v.

Regents of University of California /1988} 47 Cal. 3d 375, SAN DAG will provide the SAN DAG Board of Directors with a Final SEIR completed in compliance with CEQA Guidelines Section 15132 that reflects SANDAG's independent judgment and analysis as required by CEQA Guidelines Section 15090 (a). SAN DAG will also present the SAN DAG Board of Directors with Findings consistent with CEQA Guidelines Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report Page F.1-75
Appendix F.1: Response to Comments on the Draft SEIR
Section 15091, a Statement of Overriding Considerations consistent with Section 15093, and a Mitigation Monitoring and Reporting Program consistent with Section 15097 prior to the SAN DAG Board consideration of the proposed Amendment and Final SEIR.

City ofCartsbadComment-. on C'lraftSupplement;il En¥lronmental Impact nepon tortht proposed Am<!mlment l o the 2021 Regional Plan
AU8U5t28, 2023
P ,e8
Attachment:

1. Aug. 8, 2023, City or Carlsbad Comment Lette r on the Amendment to the 2021 k~ion.a l 1-'lan (Includes Aug. 6, 2021, comme nt letter on Draft flegional Plan an d Sept. 30, 2021, clarification lette r!
ScoUChadWlck,CltyManai:er
Clndlt McMahon, Oty Atmrn~
Geoff PalllOl', ~!st.int City Mllnager
Ron kemp, Senior Asslslallt City Attorney
Gaf'I Ouberio, Deputv Qty Manager, Community Se-rvi~
PnGome,, Deputy Cil,.i Manaie ,. PubllcWorics
Milie Stront. Aui stant Communhy Development Oireao r
ErlclilnJy,ut'fP!anner
Nam.in Sd1midl, Transl)Ol'Qtion Plarmlng and Mobility Miln1ger J,nonGeldert,Englnee rll\flManai;:er
RobenEfird,P rlncipalPlannP.r
ScottDonnell,SeniorP !c1nner
Nlccle Morrow,Asslsta11t?lanner
Amendment to the 2021 Regional Plan
Supplemental Environmental Impact Report
Appendix F.1: Response to Comments on the Draft SEIR
Page F.1-76
4-23
(wtiole
•oc/
Aug.&, 2023
San D1eco Asoot1atio n ol Governments
401BSul!.et,Suitl!.800
5anDiegoCA9Zl0 1
Via;Rl'gioria lPlilnArnen~rn~ t @sandag.ofJ
RE: Cill' of Carlsbad Comments on tl'IQ- Amendment t11 tht 2021 Re11lonal Plan To Whom It Ma~ Concern,
( city of
Carlsbad
The City of C,v!shad aµµreda tes the oppCJrtunity to provide comments on the proposed am~mimr 111 lo rhe 2a2.l Reg!o11al Plan tHPlan Amendment"). This is an impcrtant plan fur thi~ rcglori and guides the 11u1 ph;uef of grDW'lh fer !he roernller agencies ol the San Ole go Assc::latlon of Govtmmen-.s ("SANOAGHI. 0.1'1 ctfuct ivety desigrted and Implemented re;iona1 trarupom rion plan ensures imi,roved transporto1r!on options forarl!.a re, ,dents, b1.1Slne= and other comm unity meinbers; meaningful reductions In greenhouse gas l"Gl-!G~) emhsions; am! improved qual/ty of life as we srow our ro111munities.

The C.ity of Carls!J.ld 1•c1t'fl b submitting the following commentt based on the pollcie.s, oroj&ts, progra m s and other Improvements includedl11 the Pl~n f\mendrrierr .. fhE" city rc$Crv~ lhe.rifht to add, ame11d, cl\ange or replilct' comments and n:oaimmend,1tions based on additiona l revleY.• a11d underst.1ndi"£ of the Pl.in Amendment ;md th~ ~nvironmental anal\l5i~ provld~ under lrM- Califc.,rnia Environmenul Quality Act (~CEQA").

SECTION I: LAND USE

1. Alternativ e;; Included in 1he approvi!d 20Zl Regional Plan .issumed housi1~ In loO'IUon~ that were lnr:0ns!nent with th!! city'\ Lanr1 use plans; this Wils disc~ ed In oerall in the city's August 6, Z021/ie 11temt,,.--t ~. 2021, tomments 011 the di.tr. 2CIJ:l ~~!anal Plan (Attachment 'l 1.

Consinent wi'.h those comments , cir, staff rt-a1mmencl the Plan A.metldme11L:
a. Consider the city's l~nd u.Sl" p~n~ tndudin& the Gerrera! Plan, Habitat Manaa!'me-nI Plan. and Loc.il Co~stal Program
b. Considerlh! McClella11-Palomar Airport L,ind Use CompatiiJii!ly Pla11 {adopted by the count')' Aifl]ort land Ust Com<nissioo 11nd ame11ded 0&. l, 201U and the constuinh lllenllfiedth ereln,

2. Ctt,,i staff a.11! encouraged by recent conver.satioo~ wi.,lt;SANDAG staff that 1t1e proposed 2025 Re.11:ionat Plan wi.11 considt't lhe cilv'~ land use dorume,iu. Do!ng so h recommended a°' e.1pecled .i:,d will help enwt! better aa:uraq, of dalit and am,mpti ons.

SECTION 2: COMMEIIITS AND RECOMMENDATIONS
City mff remain concerned that there is nol enou1:1h delail on the teasillilitv of lmplern1?.11Ution of this signiricant shift in traJtSportatJon strategy, On sp!!clflc content in the plans, we oUTtine ou r recom mendnior.s ;md comments below:

Trar.sportiltion & C.Ommunitv Oellf!lopment Cepanment.s 1635 Faraday Avent.e I ~rlsbad. CA 92008 l 75{!-€,02-2710 l Amendment to the 2021 Regional Plan
Supplemental Enviro nmental Impact Report
Page F.1-77
Appendix F.1: Response to Comments on the Draft SEIR
RESPONSE TO COMMENT 4-23
This comment addresses the proposed Amendment and the approved Plan and is not related to the adequacy of the Draft SEIR. As such, no further response is required.

SA G
Amendment to the
2021 Regional Plan
October 13, 2023
Attachment E
• ~
Free Language Ass istance I Ayuda gratuita con el idioma I Libreng Tu long sa Wika I Ho trd ng6n ngQ mien phi ~ 0 ~~,.g2'5til)WJ I ~1':t!~t~M I~~ ~y.l ,.ict.... I "f-li C2:f Oj :i::1 %I I uK;I_) ul./j cS...S I ~'f40)~~!xHi: I 6ecnnarnas:i s:i3b1Kosas:i noMoW,b Assistencia lingufstica gratuita I~ 'l-fll'TT~ I Assistance linguistique gratuite I d~WFnM<"inlia\nt\'.;j c;.gT'.'.)e§, c,Y'oJ." c"0;;':;£c:mo I muQ°ovctl}ecf~uwi:;:m.Js I Kaalmada Luqadda ee Bilaashka ah I 6e3K0WTOBHa M0BHa ,o,onoMo,a SANDAG .org/ LanguageAss istance I 679.699.7900
•.

Table of Contents

7. I ntrod uction ...................................................... , .... ~ ........... ; ........................................................................................................ 3

2. Project Modifications ....... ~'··················································································································································3

3. Revenue Assumptions .................................... :0 ................................................................................................................... 4

4. SB 375 and the Sustainable Communities Strategy ....................................................................................... .5

5. Network Performance ........................................................................................................................................................ 6

6. Air Quality Planning and Transportation Conformity ................................................................................... 73

7. Public Review .......................................................................................................................................................................... 74

8. Attachments ............................................................................................................................................................................ 74 A mendment to the 2027 Regional Plan 2
Amendment to the 2021 Regional Plan

1. Introduction
On December 10, 2021, the Board of Directors approved the 2021 Regional Plan, which details interdependent strategies including transportation policies and programs, infrastructure investments, and technological advancements to achieve regional goals for transportation, the environment, and equity. One of the pricing strategies included in the plan is a regional road usage charge (RUC), which is a direct user fee where drivers pay to use the roadway network, whether the vehicle is powered by gas, electricity, or hydrogen, based on distance traveled or other factors .

On September 23, 2022, the Board directed staff to prepare, "a focused amendment of the 2027 Regional Plan without the regional road usage charge and a supplemental California Environmental Quality Act analysis for Board consideration within one year ... "
Under federal metropolitan transportation planning regulations, a regional transportation plan amendment requires an opportunity for public review and comment , demonstration of fiscal constraint, and an air quality conformity determination .

The amendment removes the regional RUC from the 2021 Regional Plan, updates the financial strategies necessary to demonstrate that it will have sufficient revenues to pay for the planned transportation improvements, and documents federal Air Quality Planning and Transportation Conformity. This amendment also analyzes consistency with state targets to reduce greenhouse gas (GHG) emissions consistent with Senate Bill 375 (SB 375).

2. Project Modifications
The amendment is focused on the removal of the regional RUC from the 2021 Regional Plan and provides updated revenue assumptions. There are no other changes to the transportation projects, programs, or policies identified in the 2021 Regional Plan .

Separate from the regional RUC, the 2021 Regional Plan also assumes revenues resulting from a state-administered RUC. SAN DAG will continue to coordinate with the state and other metropolitan planning organizations (MPOs) on the state's RUC pilot program.

Attachment A, Errata to the 2021 Regional Plan, includes the revisions to the 2021 Regional Plan resulting from removal of the regional RUC.

Model and Input Corrections: After adoption of the 2021 Regional Plan, staff observed low traffic counts and employment at some large employment location sites and made minor corrections resulting in slight changes to regional employment figures. Staff also fixed a software bug resulting in more accurate traffic volumes on SR ll. A full discussion of the activity-based modeling inputs is included in Attachment B.

Amendment to the 2027 Regional Plan 3

3. Revenue Assumptions 1
Federal law requires that an MPO identify revenues to cover the improvements included in its regional transportation plan. The funding strategy for the 2027 Regional Plan considered all reasonably anticipated revenues to be received through 2050 necessary to cover the identified cost of $763 billion . State and local revenue from fuel taxes have declined w ith the increase in vehicle fuel efficiency . Therefore, the 2027 Regional Plan concluded that new sources of funding beyond the fuel tax w ould be needed for full implementation .

The regional RUC w as only one of several potential revenue sources included in the 2027 Regional Plan .

The amendment includes the follo w ing updated revenue assumptions :
(1) Removal of the Regional RUC: Remo val of the regional RUC reduces anticipated revenues by $74.2 billion over the life of the 2027 Regional Plan . (2) Delay timing of future local sales tax revenue: The 2027 Regional Plan assumes a one­ half-cent sales ta x measure follo w ing the 2022 election . In 2022, a proposed citizen initiative for a half-cent sales ta x measure to help fund the 2027 Regional Plan failed to qualify for the November 2022 ballot . The amendment assumes the citizen initiati ve w ill be circulated for the 2024 ballot and postpones the revenue generated from the new measure and potential financing opportunities to begin follo w ing the 2024 presidential election, rather than the 2022 midterm election . A second assumed half-cent sales ta x measure in 2028 has not been changed w ith the amendment . (3) Update to TransNet Revenue: The TransNet prog ram is a voter-appro ved half-cent sales ta x for transportation purposes in the San Diego region. It w as appro ved by vote rs in 2004 and w as estimated to generate $13 billion for regional transportation impro vements for the remaining years of the measu re (2027-2050) . On April 22, 2022 , the Board appro ved updated TransNet program revenues based on actual sales ta x revenue collections for FY 2022, w hich are higher than previously anticipated sales ta x revenues for FY 2023. The growth rate is applied to the higher base, generating an additional $2 billion through 2050 . Those additional revenues have been included in the updated revenue assumptions .
(4) Federal and State Funding: The revenue assumptions for the 2027 Regional Plan w ere developed prior to the Infrastructure Investment and Jobs Act {IIJA), also known as the Bipartisan Infrastructure Law {BIL), being signed into law by President Biden in November 2027. The law authorized $7.2 trillion for transportation and infrastructure spending w ith $550 billion of that figure going tow ard "new" investments and programs. The historic level of infrastructure investment from the federal and state government in the early phase years of the 2021 Regional Plan w as unkno w n and underestimated . The federal and state discretionar y programs near-term estimates have been updated to assume historical leveraging rates of local TransNet revenue .

These changes w ould result in a net decrease in revenues from $173 billion identified in the 2021 Regional Plan to $165 billion . This revenue w ould still be sufficient to fund the anticipated $163 billion of planned transportation improvements included in the 2021 Regional Plan . No changes to projects listed in the 2021 Regional Plan result from the Amendment. These revenue changes are identified in Tables 3.1 and 3.2 belo w. 7 All funds are in 2020$ unless other w ise noted .

A mendment to the 202 7 Reg iona l Plan 4
Table 3.7: Amendment Revenue Assump t ions ,;
- . - - - .
• Amendment Revenue Assumptions
Changes sir.ce Regional Plan Approval ($ _ lmp_a11~t )
in m I ions
Removal of Regional RUC
Delay Future Local Revenues for Transportation to start in 2025 Update TransNet Revenue based on A pril 2022 boa rd-appro ved estimates Update near-term State Discretionary Programs estimates to incorporate histori c levels of transportation investment (2022-2030)
Update near-term Federal Discretionar y Programs estimates to incorporate histo ric levels of transportation investment (2022- 2030) Table 3.2: Com pari son of Revenue s and Costs
Total
($14,229)
($1,896)
$7,914
$2,454
$3,896
($7,861)
r- .. . . . -- . C~~~~-ris~ · of ~evenues -and C.osts - -- ,_ ~ Total Revenue Sources
Total Costs
Difference (Rev-Costs)
2021 Regional Plan Amendment Difference
$772,820
$762,538
$70,282
$164,959
$762,538
$2,427
($7,867)
$0

4. SB 375 and the Sustainable Communities Strategy
Under the Sustainable Communities Act , the California Air Resources Board (CARB) sets regional targets for GHG emissions reductions from passenger vehicle use. CARB has set targets for 2035 for each of the 78 MPO regions . SANDAG's target is a 79% reduction in per capita passenger vehicle GHG emissions relative to 2005 as part of the 2027 Regional Plan .2 The amendment removes the regional RUC of3 .3 cents per mile starting in 2030 . The resulting decrease in the cost to operate an automobile , results in an increase in single occupancy drivers that w ould cause an increase in vehicle miles traveled (VMT) and an increase in GHG emissions and air pollutants from tailpipe emissions compared to the 2027 Regional Plan . The amendment results in an increase ofl.3 million VMT per day in 2035.

This results in a 78.6% per capita reduction in GHG emissions in 2035 relati ve to 2005 levels , w hich is rounded to the nearest w hole number of79 % consistent w ith CARB guidelines .3 2 In addition to the CHG reduction target , CA RB w ill anal yze w hether the strategies and commitments in this amendment support the Sustainable Communit y Strateg y's stated CHG emission reductions and w hether there are any risks to not achie ving those strategies and commitments. Final SCS Program and Evaluation Guidelines , p. 57.
3 "MPOs that rely on a combination of modeled and off-model methods to estimate per capita CHG emission reductions from its RTP/SCS should round to the nearest integer percent " (Final SCS Program and Evaluation Guidelines, A ppendices, p. 28).

A men d m en t to the 202 7 Regio nal Plan 5
Table 4.1: Compariso n of SB 375 Result s •
Population
SB 375 VMT
SB 375 VM T/ Person
CHG Per Capita Reduction from 2005
3,620,34 8
80,766 ,669

22.l
-20 .4%
3,620,348
87,478,476

22.5 -78.6
0 7,257,807

0.4 7.8
Notes : 7 2027 Regional Plan w ith transportation model and input corrections as discussed above. 2 May not add up due to rounding.

5. Network Performance
The amendment makes no changes in the transportation net w ork in the 2027 Regional Plan .

Revisions to the primary and supporting performance measures for 2035 and 2050 resulting from remo val of the regional RUC in the amendment are provided in Tables 5.7 and 5.2.

Amendme n t to the 2027 Regio na l Plan 6
Table 5.1: Performance of Revenue-Const rained Transportation Network Region w ide :

Primary Measures , . •
Walk
Bike
Transit

73.9%

97.7%

66.5%

74.8%

97.6%

67.4%

73.9%

97.7%

66.5%

74.8%

97.6%

67.4%

0.0%

0.0%

0.0%

0.0%

0.0%

0.0%
' Percentage of residents that can access parks within 15 minutes · ,_ Walk
Bike .

Transit

53.4%

95.2%

44.5 53.5%

95.7%

45.4 53.4%

95.2%

44.5 Percentage of residents that can access Tier 1 employment centers Within 30 minutes by Transit
With in 45 m inutes by Transit

37.7%

57.8%

35.9%

58.4%
o<c.. - ' • • ' I - { -- ~ • • ' • \ •• <

37.7%

57.7%
Percentage of residents that can access Tier 2 employment centers Within 30 minutes by Transit
Within 45 minutes by Trans it

57.2%

77.4%

59.5%

79.6%

57.7%

77.3%

53.5%

95.7%

45.4 35.9%

58.3%

59.5%

79.6%

0.0%

0.0%

0.0%

0.0%

0.0%

0.0%

0.0%
r)'"11~';::; .,...,~ •' --•'"'••' •: I -,,._ ~ _,,;;--v;,;:rc...;;;."''7'-:_..., ,· ";;;V"1:;c,,- _~;:_, ••, ,,~',."«~, •~ •.,-i:;-e•_';-~/.;'",-_::<V-1 :-- •I<',,,,.••~ q"', '.r;- .- 1 ·,Percentage of residents that can access any,employment center (Tier 1-4) • L-... -~ ~'t. • l -. r~M",~!.' -~·~.:-, ~--• ~, - • .... ,_ - . ..._-· -. ~- "' - Within 30 minutes by Transit
Within 45 minutes by Transit

84.7%

85.7%

85.6%

86.7%

84.7%

85.7%

85.6%

86.7%

0.0%

0.0%

0.0%

0.0%

0.0%

0.7%
-0.7%

0.0%

0.0%

0.0%

0.0%
r . , .. . . . , ~ " . . - - . . . ,
l Pe~centage of residents that ca_ri _access h_i~her e'!ucat(on institu!io!'.'s . ; Within 30 minutes by Transit
Within 45 minutes by Transit

54.7%

78.5%

55.8%

80.4%

54.0%

78.5%

55.7%

80.4%
-0.7%

0.0%

0.0%

0.0%
~ ' ,,
!pn-road COz emissions (change from ~00:5 levels}3 •
Total Tons
Per Capita
38,276

27.l
39,776

20.9 38,767

27.4 39,677

27.2 544

0.3 507

0.3 JI'-•,~ - -,.,_!."Ili!;-:: ~'t' ._ .... , • , ...
!:,Y.~hi~le ~!Jes T_r~y~_le_d • .

All Vehicle Classes Regionwide 85,868,724 88,735,779 87,737,224 89,846,864 Per Capita 24.0 24.0 24.4 24.3
7,262,499

0.4 7,777,085

0.3 Notes: 7 202 7 Regiona l Plan with transportation mode l and input corrections as discussed above. 2 May not add up due to rounding.
3 Change in on -road CO2 emissions from 2005 values (EMFAC 2074). Negat ive values indicate emiss ion reductions. These measures quantify changes in total tons and pounds per capita and are used to calculate the percent reduct ion per capita required in SB 375.

A mendment to the 2027 Regional Plan 7
Table 5.2: Performa nce of Revenue-Constra ined Transportation Netw ork: Supporting Measures Bike &walk 6.5% 8.2% 6.4% 8.1% -0.1% -0.1%
Carpoo l 15.0% 16.0% 15.2% 16.1% 0.1 % 0.1%
Work Trips (peak period) Dri ve alone 66.6% 62.4% 66.9% 62.7% 0.2% 0.3% Other (TNC, MicroMobility, 0.5% 0.6% 0.5% 0.6% 0.0% 0.0% Taxi, School bus ) Transit 11.3% 12.8% ll.1% 12.5% -0.2% -0.3%
Bike& w alk 7.0% 8.7% 6.9% 8.6% -0.1% -0.1%
Carpool 14.6% lS.6% 14.7% 15.7% 0.1% 0.1%
Work Trips (all day) Dri ve alone 66.4% 62.1% 66.8% 62.5% 0.3% 0.3% Other (TNC, MicroMobility, 0.5% 0.6% 0.5% 0.6% 0.0% 0.0% Taxi, School bus ) Transit 11.4% 12.9% ll.1% 12.6% -0.3% -0.3%
Bike &walk 11.8% 13.5% 11.7% 13.4% -0.1% -0.1%
Carpool 40.5% 40.3% 40.6% 40.5% 0.1 % 0.1%
All Trips Dri ve alone 40.9% 38.9% 41.1% 38.9% 0.1% 0.1% Other (TNC, MicroMobil ity, 2.1% 2.3% 2.1% 2.2% 0.0% 0.0% Taxi, School bus) Transit 4.7% 5.1% 4.5% 5.0% -0.1% -0.1%
Amendm ent to the 2021 Regiona l Plan 8
"
Number 119,876 262,471 119,876 262,471 0 0.

Commuter Rail (Tierl)
Percent 3.4% 7.7% 3.4% 7.7% 0.0% 0.0%
Number 322,632 463,722 322,632 463,722 0. 0
Light Rail (Tier 2)
Percent 9.0% 72.5% 9.0% 72.5% 0.0% 0.0%
Number 7,089,742 1,799,095 7,089,742 7,199,095 0 0
Next Gen Rapid (Tier 3)
Percent 30.5% 32.4% 30.5% 32.4% 0.0% 0.0%
Number 1,773,585 7,293,654 7,773,585 7,293,654 0 0
Access to any of the tiers (7-3)
Percent 32.8% 35,0% 32.8% 35.0% 0.0% 0.0%
•'Nu"mber/perce~t of jobs within 0.5 miles of a ~om muter rail, light rail, or next gen Rapid (Tier 1/Tie'r 2/Tier 3) traniit st;,p - , Number 135,518 232,588 135,518 232,588 0 0
Commuter Rail (Tier 7)
Percent 7.7% 11.1% 7.1% 71.7% 0.0% 0.0%
Number 289,270 370,838 289,270 370 ,838 0 0
Light Rail (Tier 2)
Percent 75.0% 77.8% 75.0% 17.8% 0.0% 0.0%
Numbe r 874,628 923,202 874,628 923,202 0 0
Next Gen Rapid (Tier 3)
Percent 42.4% 44.2% 42.4% 44.2% 0.0% 0.0%
Number 887,095 7,007,787 887,095 7,007,787 0 0
Access to any of the tiers (7-3)
Percent 46.1% 48.3% 46.7% 48.3% 0.0% 0.0%
Amendment to the 2021 Regiona l Plan 9
Performance of Revenue -Constrained Transportation Network Regionwide 2021 Regional Plan 1 Amendment
Supporting Performance Measures
2035 2050 2035 2050
N·umber/percent of people within 0.25 miles of a bike facility (class I and II, cycletrack or bike boulevard) Region
Mohub
Number
Percent
Commuter Rail (Tier7)
Light Rail (Tier 2)
Next Gen Rapid (Tier 3)
Local Bus and Express Bus
All transit boardings
Commuter Rail (Tier7)
Light Ra i I (Tier 2)
Next Gen Rapid (Tier 3)
Local Bus and Express Bus
All transit boardings
Total time engaged in transportation related physical activity per capita
Percent of the population engaged in 20 min or more of
transportation related physical activity
2,747,020

76.9%
59,906
346,272
383,456
432,345
7,227,978
55,297
338,834
332,407
338,299
7,064,837

17.77 18.5%
' - -
3,075,475 2,747,020

87.5% 76.9%
796,793 58,220
355,767 339,077
405,773 377,965
446,240 427,887
7,404,572 7,797,744
795,307 53,796
344,789 331,795
346,626 322,489
349,399 330,877
1,236,127 1,038,957

13.73 77.66

20.4% 18.3%
3,075,475

87.5%
797,708
349,022
395,484
436,325
7,372,538
790,347
338,252
337,532
342,477
7,208,596

13.04 20.3%
Average truck/commercial vehicle travel times to and around regional gateways and distribution hubs (minutes)

15.97 16.20 16.03 16.21
Amendm ent to the 2027 Regional Plan
Difference 2
2035
0 0.0%
-7,686
-7,740
-77,490
-70,458
-30,774
-l,507
-7,039
-9,912
-7,422
-25,874
-0.71
-0.2%

0.06 2050
0 0.0%
-5,085
-6,744
-70,289
-9,975
-32,034
-4,966
-6,537
-9,094
-6,928
-27,525
-0.09
-0.1%
O.Ol
70 Performance of Revenue-Constrained Transportation Network Regionwide Supporting Performance Measures
;Average Particulate Matter (Ptv12,S) , •
Exposure per person
Truck travel time index
Highway (SHS)
Arterial
Highway (SHS) + Arterial
. -
Heavy Duty Truck delay by facility type (average daily) Highway (SHS)
All day - Heavy Heavy Duty
Arterial
AM and PM peak - Heavy Heavy High way (SHS)
Duty Arte rial
Highway (SHS)
All day- Medium Heavy Duty
Arterial
AM and PM peak - Medium High way (SHS)
Heavy Duty Arterial
Highway (SHS)
All day - Light Heavy Duty
Arterial
AM and PM peak - Light Heavy Highway (SHS)
Duty Arterial
High way (5HS)
Amendment to the 2027 Regional Plan
2021 Regional Plan 1
2035

5.30 7.14
120
176
3,087
5,545
7,948
2,467
7,757
2,958
682
7,788
2,639
7,446
7,473
2,807
6,870
2050

5.44 178
120
179
4,693
5,857
2,833
2,587
7,671
3,092
952
7,275
3,733
7,854
2,079
2,896
70,098
Amendment
2035

5.36 175
127

7.17 3,273
5,586
2,024
2,577
7,209
2,993
717
7,202
2,765
7,577
7,529
2,834
7,787
2050

5.50 179
120
179
4,800
5,868
2,900
2,607
7,717
3,727
979
7,235
3,837
7,974
2,079
2,947
70,354
Difference 2
2035 2050

0.06 0.07

0.07 0.07
733
47 76
56 58
34 28
74 726
72 56
26 377

0.06 0.07

0.00 0.00
707
77 67
26 46
28 27
27 703
60 60
45 257
77 ~~ • ~
'. Performance of Revenue -Constrained Transportation Network Regionwide 2021 Regional Plan 1 Amendment Difference 2
Supporting Performance Measures
2035 2050 2035 2050 2035 2050
All day-All Heavy Duty Arterial 15,949 16,803 (HHD + MHD + LHD) AM and PM peak - All Heavy Duty Highway (SHS) 4,103 5,804 (HHD + MHD + LHD) Arterial 6,456 6,692
Transportation system use costs
Percent of Income Consumed by Out-of-Pocket Transportation Costs 10.0% 10.4%
Change in Percent of Income Consumed by Out-of-Pocket
Transportation Costs 2.4% 2.7%
Notes : '2021 Regional Plan with transportation model and input corrections as disc ussed above. 2 May not add up due to rounding.

Ame ndme n t to the 2021 Regiona l Plan
16,095 16,902 147 99
4,264 5,957 161 154
6,553 6,784 96 92

9.5% 10.0% -0.5% -0.4%

1.9% 2.3% -0.5% -0.4%
12 6. Air Quality Planning and Transportation Conformity SAN DAG must ensure that the amendment w ill not cause or contribute to new air quality violations, worsen existing violations, or delay the attainment of any relevant National Ambient Air Quality Standards (NAAQS). This process, known as air quality planning and transportation conformity, is necessary to be eligible for federal funding for future transportation projects .

Currently San Diego County is in a nonattainment area for ozone only. Ozone is measured by its precursors of reactive organic gases (ROG) and nitrogen oxides (NOx). The amendment removes the regional RUC, which increases total VMT and tailpipe emissions of ozone precursors . A regional emissions analysis was performed using EMFAC20l7, wh ich is the emission model used for the transportation conformity analysis for the 2027 Regional Plan .

Air quality emissions modeling for the 2020 State Implementation Plan {SIP) analysis years and budgets for the 2008 Ozone and 2075 Ozone NAAQS was completed for 2023 , 2026, 2029 , 2032, 2040 and 2050 . Those results are provided in Table 6.7.

Tab le 6.7: Transportation Confo rmity Analysis
2023 77 ,258 85,457 73.6 73.4 79.3 77.3
2026 77 ,558 85,667 72.7 77.6 77.3 75.0
2029 77 ,892 86,285 77.0 70.3 75.9 73.5
2032 72,278 87,358 70.0 9.2 75.7 72.6
2040 72,986 88,730 70.0 7.3 75.7 77.6
2050 73,779 90,083 70.0 6.7 75.7 77.9
Note : The SIP evaluates the ozone precursor pollutants of ROG and NOx as modeled in EMFAC2077 air quality model. Emissions budgets from the 2020 Plan for Attaining the National Ambient Air Quality Standards for Ozone in San Diego County (October 2020) were found adequate for transportation conformity purposes by U.S. EPA, effective October 79, 2027.

The amendment continues to meet transportation conformity requirements with the removal of the regional RUC. SAN DAG initiated conformity consultation for the amendment w ith the San Diego Region Air Quality Conformity Working Group (CWG) on November 2, 2022. SAN DAG concluded conformity consultation on March 7, 2023, and circulated the pre­ draft transportation conformity determination for CWG review on April 25, 2023 . The Air Quality Planning and Transportation Conformity is included as Attachment B to this amendment.

Amendment to the 202 7 Regio nal Plan 73

7. Public Review
SANDAG prepared a Public Involvement Strategy for development of the amendment based on the Public Involvement Plan for the 2027 Regional Plan. The strategy includes public meetings, social media, visualizations, and other approaches to outreach . On June 73, 2023, SAN DAG posted the draft Amendment on the SAN DAG website at sandag .org/regiona l­ plan/2027-regional -plan .

On June 23, 2023, SAN DAG conducted a public hearing and also discussed the key planning assumptions for the amendment with the Board of Directors . SAN DAG also hosted three virtual workshops over the summer to provide the public with the information and tools necessary to understand the issues and policy choices in the amendment. Comments on the amendment were accepted via a dedicated phone line, email address, ahd on line comment tool through August 8, 2023.

A summary of comments received on the amendment, SANDAG 's response, as well as copies of the comments themselves are provided in Attachment C- Public Participation .

8. Attachments
Attachment A- Errata to the 2027 Regional Plan
Attachment B -Air Quality Planning and Transportation Conformity Attachment C - Public Participation
Amendment to the 2027 Reg iona l Plan 74
March 6, 2023
SANDAG
Attn: Kirsten Uchitel
401 B Street, Suite 800
San Diego, CA 92101
Attachment F
( City of
Carlsbad
City of Carlsbad comments on Notice of Preparation of an Environmental Impact Report for the 2025 Regional Plan
Dear Ms. Uchitel:

Thank you for the opportunity to provide comments on the scope and content of the Environmental Impact Report (EIR) for the 2025 Regional Plan. The city is familiar with the proposed Regional Plan and this Notice of Preparatibn (NOP) as we attended the scoping meetings on January 12 and February 15, 2023. Below are considerations the city would like to submit as SANDAG moves forward with the preparation of its EIR:

1. The regional forecast of jobs, population, and housing establishes the scale and type of growth that is to be assumed over the proposed Plan's planning period. The most recent planning assumptions from local agencies must be utilized, including land use model inputs from local land use plans. At the proposed Plan EIR scoping meetings, SAN DAG noted its intent to analyze several environmental topic areas in the EIR, including air quality, energy, greenhouse gas emissions, land use/planning, and population/housing. Please ensure analysis includes clear disclosure and meaningful study of inconsistencies and impacts to Carlsbad's adopted land use plans and policies and/or the potential for induced, unplanned population growth within areas of the city. This should include specific information and timing of transit stops proposed within the city so that state laws (such as Assembly Bill 2097) that change local land use regulations associated with high­ frequency transit can be fully evaluated. The inconsistency within the 2021 Regional Plan and with the city's General Plan has driven questions from community members and within comments received during public review of documents prepared under the California Environmental Quality Act (CEQA).

2. Please ensure the EIR considers the impact of the proposed Plan and EIR alternatives to the city's land use plans, including the General Plan, Habitat Management Plan, and Local Coastal Program.

3. Please ensure the EIR considers the impact of the proposed Plan and EIR alternatives to the McClellan-Palomar Airport Land Use Compatibility Plan (adopted by the County Airport Land Use Commission and amended Dec. 1, 2011) and the land use regulatory constraints identified therein. EIR alternatives included in the 2021 Regional Plan assumed future housing growth in locations that were inconsistent with this plan.

4. The Sustainable Communities and Climate Protect ion Act of 2008, also known as Senate Bill (SB) 375, requires metropolitan planning organizations (MPOs) to prepare a sustainable communities strategy using the most recent planning assumptions, as part of their regional transportation plans. The proposed Plan is also required to achieve specific greenhouse gas emissions target reductions, pursuant to Government Code §65080. The 2018 California Air Resource Board targets are the most recent targets established for SANDAG planning purposes and is expressed as a percent change in per capita passenger vehicle greenhouse gas emissions relative to 2005. The Community Development Department
Planning Division I 1635 Faraday Avenue I Carlsbad, CA 92008 I 442-339-2600 SANDAG
Attn: Kirsten Uchitel
March 6, 2023